“I don’t worry about a zombie apocalypse. Mainly because it’s unlikely, but also because I think I’d be pretty good in that type of emergency.” — Sarah Millican
A couple of days ago at a plant here in St. Louis, a 55-gallon drum of acetone failed and released its contents. In the scheme of catastrophic releases of highly hazardous chemicals, this release was much less severe than most of the incidents that keep us up at night. No one was hurt and the spilled acetone evaporated into the atmosphere.
How do I know about it? The St. Louis Fire Department, whose Hazardous Materials Task Force responded to the release, announced it on their Twitter account, and the local news media picked it up.
Was this news? Was it an emergency?
Is a Spilled Drum of Acetone News?
A little past noon on Friday, September 30, 2022, a HazMat team from the St. Louis Fire Department responded to the release. Their tweet said “…on scene of a chemical spill/ruptured 55-gallon drum of acetone.” About an hour-and-a-half later, they sent a second tweet that said, “All affected employees evacuated & accounted for; no injuries reported. The spilled contents/acetone has evaporated into the atmosphere. Building checked for potentially hazardous vapors; negative readings. Companies clearing the scene.”
That’s it. Those two tweets are the basis of reporting from four media outlets in the St. Louis area. Naturally, they chose the word “rupture” instead of “spill”; it’s much more dramatic.
Was it news? It must have been, because four news organizations published accounts of the spill, although their reporting was simply a recitation of the SLFD’s first tweet. Should it have been news? That depends on the day. News organizations need to churn out content, and on slow news days, even minor events make the news. Being a glass-half-full kind of guy, I am relieved that this was news. It means that nothing worse was happening in St. Louis that day.
Is a Spilled Drum of Acetone an Emergency?
Emergencies are in the eyes of the beholder. “Responses to incidental releases of hazardous substances can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered emergency responses” within the scope of OSHA’s HazWOpER regulation, 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response. There is not a size limitation. The release of a drum of acetone might not be an emergency if maintenance personnel or workers in the immediate area can control the release at the time.
If employees in the immediate release area or maintenance personnel aren’t prepared to respond to the spill, however, then it is an emergency no matter how small. Any release that requires efforts by designated responders is an emergency. “Designated responders” includes mutual-aid groups and local fire departments. It also includes employees from outside the immediate release area that are designated for emergency response.
So, the spill of a drum of acetone isn’t per se an emergency. Calling in emergency responders makes it an emergency, however, covered under the HazWOpER standard.
Prepare to Respond to a Non-Emergency
The HazWOpER standard is rigorous and has strict requirements for training and equipment. As a result, many facilities would like to avoid being covered under the HazWOpER standard. They can. All they must do is
- Evacuate their employees from the danger area when an emergency occurs
- Prohibit any of their employees from assisting in handling the emergency
- Provide an emergency action plan in accordance with 29 CFR 1910.38.
The challenge is to prevent a release from becoming an emergency. Arnold Glasgow said, “One of the tests of leadership is the ability to recognize a problem before it becomes an emergency.” The Process Safety Management standard, 29 CFR 1910.119, addresses this in paragraph (n) Emergency planning and response, when it requires that emergency action plans “include plans for handling small releases.” A written procedure for handling small releases is more than what is normally required to be included in an emergency action plan, but it is essential in preventing a release from becoming an emergency.
Check Your Emergency Action Plans
A spilled drum is not a zombie apocalypse. But in the absence of appropriate small release procedures, it could be an emergency.
If you handle drums, a release from those drums is a credible scenario. Drums can leak, fall off a pallet while being moved with a forklift, be speared by the fork of a forklift, or “rupture.”
Do you want these events to be emergencies, published in local newspapers and reported on the evening news? If not, then make sure that your EAP addresses these events and plan on the non-emergency response you intend.