Chapter 296-824 WAC, Emergency Response
to Hazardous Substance Releases Rule, requires you to do the
following if there could be an uncontrolled release of a hazardous
substance in your workplace:
Develop and follow an Emergency Response
Plan (ERP)
OR
Develop and follow an Emergency Action
Plan (EAP)
This optional tool will help
you develop an ERP. Planning an ERP and preparing designated
employees for responding (including training, equipment, and
medical surveillance) is more complex than the requirements
for an EAP.
Before using this guideline see:
The “Scope” section of Chapter
296-824 for more information about uncontrolled releases.
The EAP requirements in Chapter 296-24-567
WAC, Employee Emergency Plans and Fire Prevention Plans.
INSTRUCTIONS:
Before you use this guideline:
- Identify (by performing a hazard assessment),
the types of uncontrolled hazardous substance releases that
could occur in your workplace.
- Familiarize yourself with the rule requirements
in Chapter 296-824 WAC.
Follow all these steps to plan for EACH TYPE
of uncontrolled release that could occur.
Step 1. Identify expected hazards.
Hazard assessment needs to be done by an individual
who has appropriate technical knowledge and experience.
This information forms the basis for selection
of personal protective equipment (PPE) and development of emergency
response procedures.
If confined spaces could exist site-specific
evaluations and procedures may be necessary. Follow requirements
in Chapter 296-62 WAC, Part M to identify confined spaces.
Step 2. Make sure all potential participants
are involved in planning, whether the response involves only your
employees or other employees at the site. Make a written agreement
covering all of the following:
How potential participants
will be notified when a release occurs. Be specific about
the communication system to be used (for example, method to
use, and sequence of contact).
What roles your employees will
take during the response.
See Table 1 in Chapter 296-824 WAC for
roles and duties employees may assume during a response.
Who assumes the Incident Commander
position both initially and whenever a new response participant
arrives.
New response participants you
should consider are site-response teams, fire departments,
law enforcement, HAZMAT teams, emergency medical services,
state or federal officials, and other affected employers
in the vicinity.
Step 3. Describe how your employees will be alerted to
the release.
Examples of methods to use for alerting employees
include dedicated radio frequencies, siren blasts, and alarms
linked to monitoring devices.
Step 4. Plan and describe your site’s evacuation
procedures. Specify:
Who initiates
the evacuation and notifies employees
Primary and alternate
escape routes
Who will assist in
evacuating employees, including physically challenged employees
Where the “safe”
primary and secondary assembly areas will be
How you will account
for all employees and any others present
How first aid needs
will be supported
Step 5. For releases at your facility
or job site, decide if any of your employees (for example, process
operators) need to control or shut down critical processes before
designated responders arrive.
If actions require these employees to enter
the danger area they need to be trained as emergency responders.
Develop procedures for these
employees, including:
Identifying circumstances that
trigger such actions
Specifying how selected employees
will be notified to start the procedures
Describing how to perform actions
safely
Step 6. Identify employees who will
be emergency responders. Make arrangements to train these employees,
or certify competencies, on their expected roles and duties.
Decide and document
how competencies will be determined.
Review course outlines to make
sure training is complete.
Make sure documentation of training
or competency is provided.
Step 7. Develop and carry out a medical
surveillance program for your employees as specified in Chapter
296-824 WAC, Sections 11050 through 11060.
Identify covered employees.
Make arrangements for appropriate
medical surveillance (for example: exams or consultations).
Provide and document the appropriate
surveillance for employees.
Step 8. Develop and carry out
a written PPE program for your emergency response employees that
covers all of the following:
Selection of PPE for
the hazards expected
Limitations, capabilities and
hazards of wearing PPE
How to identify and prevent heat
stress (and related injuries), if applicable
Proper fit procedures for PPE,
if applicable
Procedures for maintenance (decontamination,
cleaning, repairs, storage and disposal)
Training and documentation to
support all program elements
How to effectively evaluate
the PPE program
You can combine other written PPE-related
program requirements from the WISHA Safety and Health
Core Rules, Chapter 296-800 WAC, and The General Occupational
Health Standards, Chapter 296-62 WAC, into this program
to prevent duplication of written programs.
Step 9. Make arrangements to properly
equip your emergency response employees. Provide:
PPE such as respirators,
protective suits, gloves.
Rescue equipment, if needed (for
example, retrieval devices for confined spaces).
Air-monitoring devices and other
field equipment, if needed.