Posts

Natural Disaster Series: Special Requirement for LQG Waste Generators

Over the past few weeks, our blogs have been addressing issues pertaining to emergency response and natural disasters. A Large Quantity Generator (LQG) of hazardous waste must comply with prevention and preparedness standards that address daily management to prevent release, as well as develop a written Contingency Plan that documents how an imminent or actual release, fire, or explosion is mitigated and operations are returned to normal. Moving forward, new LQGs and LQGs updating their Contingency Plans will need to develop and distribute a Quick Reference Guide (QRG).

On November 28, 2016 the Generator Improvement Rules were published in the Federal Register, taking effect on May 30, 2017 in Iowa and Alaska. Over the past few months Pennsylvania, New Jersey, Georgia and Utah have also adopted the new rules. And while states that require legislative action for these changes have up to two years to adopt the more stringent portions, knowing the changes now can prepare you for when they take effect in your state. States are not required to adopt the less stringent requirements, but Quick Reference Guides are considered more stringent.

The Quick Reference Guide is required to be distributed to police departments, fire departments, hospitals and State and local emergency response teams that may be called upon to provide emergency services, and the Local Emergency Planning Committee (LEPC). Following the effective date of this updated regulation, new LQGs would be required to submit a Quick Reference Guide instead of the whole Contingency Plan when they update their Contingency Plans, and LQGs making modifications would only need to submit this new Quick Reference Guide.

Depending on the complexity of the facility, Contingency Plans can be quite lengthy. Contingency Plans include planning and response information which increases the complexity of the document. The size and complexity of the document can prevent first responders from identifying the relevant information needed to respond to an emergency situation. Having a shorter document that provides limited, relevant information for initial response is beneficial to both responders as well as facility operations management.

Required elements of the Quick Reference Guide are:

1. Type/names of hazardous wastes and the associated hazards;

2. Estimated maximum amount of each waste present at any one time;

3. Identification of hazardous wastes where exposure would require unique or special treatment by medical or hospital staff;

4. Map of the site where hazardous wastes are generated and accumulated and route to access the wastes;

5. Street map of the facility in relation to surrounding businesses, schools, and residential areas, how to best get to the facility or evacuate the community;

6. Locations of the water supply (i.e., fire hydrants and flow rates);

7. Identification of on-site notification systems (i.e., fire alarms, smoke alarms, release alarms, etc.); and

8. Name of emergency coordinator(s) and 24/7 phone number.

Heritage recommends submitting the Quick Reference Guide to your private emergency response provider(s) as well.

While the EPA is not formalizing the manner in which the Quick Reference Guide is submitted, they encourage generators to discuss with their local emergency responders how they would like the information conveyed. This could include incorporating the information into an existing application.

Heritage, in a continuing effort to support our customers, has created a model Quick Reference Guide. This document, which is approximately 5 pages in length, is a great place for generators to start in creating their own summary. Click here for the Example Quick Reference Guide 2017

Natural Disaster Series: Business Continuity Plan 

In the first part of this series, we shared three initial steps you can take to begin your natural disaster preparation plan. Part 2 introduced three key plans that can help you, your employees, and your facility quickly respond to an impending natural disaster. Here in Part 3, you will review the basics of preparing a Business Continuity Plan, including preparing for the elevated waste disposal needs that typically follow a natural disaster.

A business continuity plan helps you to be prepared to deal with the aftermath of a natural disaster. One initial concern is identifying an alternative location from where you can conduct administrative functions after a natural disaster. From there you can be in contact with emergency agencies, employees, customers, and suppliers. You will need to maintain an up-to-date list of contact information for those people and businesses and include it in the off-site backup that was discussed in Part 1.

To enable your business to stay operational or get back online, you need to evaluate potential supply chain issues. Your suppliers are a key part of your business operations. Disruption in your supply chain can stall your own recovery. For example, Hurricane Sandy in 2012 affected an estimated 10,000 manufacturing facilities, many of which were not heavily damaged but were forced to temporarily suspend operations due to supply chain disruptions. Prepare for this potential business impact by asking the following questions ahead of time: For each supplier, how long could you go without their supplies or services? What alternative suppliers could you use? Can you inventory a surplus of key products in advance?

The volume of debris and wastes that can be generated by a natural disaster is staggering. Hurricane Andrew generated more than 43 million cubic yards of debris, and the Joplin, Missouri tornado generated more than 1.5 million cubic yards. Although not on the same scale as these regional numbers, your business will undoubtedly need to prepare for out-of-the-ordinary waste disposal needs following a natural disaster. In addition to construction and demolition-like debris, you may have equipment that could release special wastes when damaged—materials such as hydraulic fluid, PCB-containing materials, lead acids, and so forth. Plan ahead by coordinating with your preferred waste disposal provider about post-natural disaster communications, potential waste types and volumes, and other facility-specific issues.

These important topics and more are discussed in the “Business Continuity Toolkit” available from the Insurance Institute for Business and Home Safety (IBHS). The toolkit walks you through the following steps in plan development:

  • – Know Your Risks
  • – Know Your Operations
  • – Know Your Employees
  • – Know Your Key Customers, Contacts, Suppliers, and Vendors
  • – Know Your Information Technology
  • – Know Your Finances
  • – Know When to Update Your Plan
  • – Know When to Test Your Plan

Although the toolkit states that it is particularly useful for small businesses, it can easily be expanded upon to meet the needs of larger operations. You can download the entire toolkit in pdf format, and the toolkit’s forms in customizable format, at this webpage:

http://disastersafety.org/ibhs-business-protection/ofb-ez-business-continuity/

We hope this information helps you get started on your preparations for potential natural disasters. If you would like to talk to us about facility-specific strategies, please contact us via our website at https://www.heritage-enviro.com/contact/ or call 877-436-8778. Heritage is here to help you succeed, no matter what Mother Nature may throw at you!

Natural Disaster Series: Planning Is Key

Part 1 of this series discussed three initial steps you can take to begin your natural disaster preparation plan. In this post, you will be introduced to three key plans that can help you, your employees, and your facility quickly respond to an impending natural disaster. 

“What?! More plans?” you groan. Not to worry, much of the information you’ll need for your natural disaster plan is already available in your emergency response plans and evacuation plans. It is best to pull that information out and put it in a stand-alone natural disaster plan so getting to it is quick and easy—you don’t want to be pouring through three other plans to find the natural disaster information you desperately need.

Every business needs to establish the emergency communications procedures to be used during a crisis. Identify an emergency communications coordinator that will work with specific individuals responsible for communications in distinct parts of your facility. You may also want to establish an emergency alert system for your site. Cellular communications can be easily disrupted during a natural disaster, so have alternative methods of communication established. Make sure your employees are well trained on how your emergency communications plan will work.

The Insurance Institute for Business and Home Safety (IBHS) provides excellent guidance and options you may want to consider using in your emergency communications plan. You can find the IBHS information here:

Know your shelter and evacuation plan. The type of natural disaster will determine if you and your employees need to evacuate the facility or shelter in-place. Include specific procedures and locations for each type of natural disaster you identify as having the potential to strike your site. Make sure your employees are trained on the correct shelter and evacuation procedures and that you provide reminder training before common natural disaster seasons arrive.

Have an emergency shutdown plan for securing materials and equipment that may be at risk during a natural disaster, such as those in outside areas or other vulnerable locations on your site. Identify equipment that needs to be powered down safely, equipment and materials that need to be secured, and utilities that may need to be shut off. If you have adequate warning of an impending natural disaster, arrange for hazardous and other regulated wastes to be removed from your facility by your waste disposal partner.

IBHS offers an “EZ-PREP™ Emergency Preparedness and Response Planning” guide for preparing an emergency preparedness and response plan, including customizable checklists for supplies and emergency preparation and response tasks.  You can download the guide and checklists here:

Next up in this series, we will present tips for getting started on your Business Continuity Plan, a must-have as you prepare for the unpredictable.