['HAZWOPER']
['Hazardous Waste Treatment, Storage, and/or Disposal', 'HAZWOPER', 'HAZWOPER Emergency Response', 'Hazardous Waste Cleanup Operations']
10/22/2024
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The HAZWOPER Standard defines an incidental spill as one where the hazardous substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel. An incidental release does not pose a “significant” safety or health hazard to employees in the immediate vicinity or to the employee cleaning it up, nor does it have the potential to become an emergency within a short time frame. Incidental releases are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to employees in the immediate work area or those assigned to clean them up. An incidental spill may be safely cleaned up by employees who are familiar with the hazards of the chemicals with which they are working.
On the flip side, an emergency release is defined as an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance that requires a response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.). Emergency releases of hazardous substances pose a sufficient threat to health and safety that, by their very nature, require an emergency response regardless of the circumstances surrounding the release or the mitigating factors. An emergency response includes, but is not limited to, the following situations:
- The response comes from outside the immediate release area.
- The release requires evacuation of employees in the area.
- The release poses, or has the potential to pose, conditions that are immediately dangerous to life or health (IDLH).
- The release poses a serious threat of fire or explosion (exceeds or has the potential to exceed the lower explosive limit or lower flammable limit).
- The release requires immediate attention because of imminent danger.
- The release may cause high levels of exposure to toxic substances.
- There is uncertainty about whether the employees in the work area can handle the severity of the hazard with the personal protective equipment and other equipment that has been provided and the exposure limit could easily be exceeded.
- The situation is unclear, or data are lacking on important factors.
The quantity of a substance spilled does not by itself determine if an incidental spill or emergency release has occurred. The properties of hazardous substances, such as toxicity, volatility, flammability, explosiveness, corrosiveness, etc., as well as the particular circumstances of the release itself, such as quantity, confined space considerations, ventilation, etc., will have an impact on what employees can handle safely and what procedures should be followed. Additionally, there are other factors that may mitigate the hazards associated with a release and its remediation, such as the knowledge of the employee in the immediate work area, the response and personal protective equipment at hand, and the pre-established standard operating procedures for responding to releases of hazardous substances. There are some engineering control measures that will mitigate the release that employees can activate to assist them in controlling and stopping the release.
These considerations (properties of the hazardous substance, the circumstances of the release, and the mitigating factors in the work area) combine to define the distinction between incidental spills and releases that require an emergency response. The distinction is facility-specific and is a function of the emergency response plan.
Compliance Point
OSHA has a letter of interpretation that attempts to explain whether “small” anhydrous ammonia (NH3) releases may be considered incidental or must always be treated as emergency response situations under 29 CFR 1910.120. The agency says that “some” releases of NH3 may constitute incidental releases, including those that are extremely small, such as minor valve packing leaks where exposures in the breathing zone of a worker would be less than the permissible exposure limit and there’s no risk of a catastrophic release. The letter is a nice refresher on the transition between incidental and emergency releases, not just for warehouses that refrigerate using anhydrous ammonia but for any warehousing and storage operation that uses or stores hazardous substances. Source: OSHA letter of interpretation 10/2/2017.
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['HAZWOPER']
['Hazardous Waste Treatment, Storage, and/or Disposal', 'HAZWOPER', 'HAZWOPER Emergency Response', 'Hazardous Waste Cleanup Operations']
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