THE FIVE RCRA EMERGENCY PLAN REQUIREMENTS FOR HAZARDOUS WASTE GENERATORS
No one ever
said working with hazardous wastes on a day-to-day basis doesn’t come with its
own set of potential dangers. Even if your company is trained in the most
carefully planned preventative measures, preventative action (while worthy
indeed) cannot completely safeguard your facility from accidental spills
and inconspicuous leaks.
That’s why
the Resource Conservation and Recovery Act (RCRA) promulgates that all
small quantity generators (SQG) and large quantity generators (LQG) must have
emergency hazardous waste contingency plans set in place. As set out in the
federal rule, there are five requirements of the emergency plan that SQG
and LQG generators must follow.
Emergency
plans are also essential in that they can mean the difference between life and
death in some cases. A proper spill response plan, for instance, can contain
and control an accidental spill or unplanned release of hazardous waste which
could otherwise turn catastrophic.
The
five RCRA emergency planning requirements are:
An
adequate alarm or communication system within the facility is necessary, one
that all personnel in the building can hear. If the facility is smaller, voice
should suffice.
A
designated full-time emergency coordinator or alternate must either be present
or on call at all times. If the designated coordinator cannot be reached during
an EPA inspection, it could mean a pricey violation fine for the company.
Emergency
information, including phone numbers for the local fire department or HAZMAT
team, the names, home or cell phone numbers, and addresses of the emergency
coordinator(s), and any other relevant information—such as a detailed map of
the facility in case a chemical fire necessitates a quick exit—should be
on hand and easy to find at the facility.
Cordoning
off the necessary aisle space for movement, plus having enough water on the
premises for fire-fighting, well-maintained extinguishers, spill control
materials, and decontamination supplies.
Detailed,
thorough arrangements must be made in advance with local police stations, fire
departments, emergency response teams, hospitals, and equipment suppliers.
Additionally,
large quantity generators (LQG) are required by RCRA to set out a written
contingency plan which is meant to minimize and contain the hazards of
chemical releases, spills, leaks, fires, and explosions. This written
contingency plan must be kept on-site at all times, and must be provided to
local emergency services.
Although
it is recommended that small quantity generators (SQG) also prepare a written
contingency plan, it is not necessary under federal law. Yet some level of
hazardous materials (HAZMAT) training for small quantity generators (SQG) and
their first-line personnel is advisable.
Emergency
plans can be tough to prepare and practice, but once one is set in place,
anything that goes out of sync in your facility will be accounted for and the
proper action will be available to all employees.