IIAR

EMERGENCY RESPONSE: KNOW WHAT TO DO BEFORE THE CLOCK STARTS TICKING

In most situations, the correct response to a threat involving ammonia in the first thirty minutes after it is identified will effectively contain most potential hazards, before they have enough time to grow into an unmanageable problem. Preparation can mean the difference between a disorganized response and the ability to shut down a potential incident when time matters the most.

Within a community as conscientious about preparing for and responding to risk as the ammonia refrigeration industry, there isn’t an issue more fundamental than safety.

Yet, emergency planning can take so many forms that companies often drift from one end of the preparedness spectrum to another without a measure of the practicality of their response plan in a real-world environment.

“In our industry, we’ve placed a serious emphasis on safety, but we need to take a look at how that extends to development and planning,” said Fred Walker, Vice President of Engineering Support for Americold. “Creating a good plan and training for that plan are two different things. If you don’t do both, a response effort doesn’t work.”

The Ammonia Safety and Training Institute, an organization with the mission to “make ammonia the safest managed hazardous material in the world,” has created a response plan and training guideline it hopes will see widespread industry adoption.

The organization’s project, called “the first thirty minutes plan,” is a comprehensive framework detailing the basics of a practical response, said ASTI President Gary Smith.

“Almost everybody in this industry has emergency plans, but in many facilities they’re located in a binder somewhere in an office,” said Smith. “The idea of how to make those plans work operationally, to make them into a reality, in many cases hasn’t been flushed out.”

One reason for that is the emphasis the industry places on prevention, said Ward Miller, Health and Safety Director for ConAgra Foods.

“From a response standpoint, obviously prevention is the first step, and we accomplish that by paying a lot of attention to process safety management and maintenance. As an industry, we’re very good at prevention,” said Miller. Nevertheless, “a risk management plan will identify risks, but there should also be a solid plan in place that is practiced on a regular basis. The first time you go through those steps should not be when you’re dealing with a release.”

Because the nature of any incident involving ammonia grows with time, there is no room for a learning curve. That’s why the idea of responding with a practiced strategy in the first thirty minutes is at the heart of ASTI’s plan, said Smith.

Often, a threat can start out so small that it can be contained immediately without escalating into a release requiring a full scale response.

“As an industry, we see small issues all the time, but how we deal with them determines if they become an emergency or not,” said Michael Chapman, Manager of Process Safety and Risk Management Programs for Tyson Foods.

Chapman, a 22-year veteran of the fire service, said in many cases he has witnessed throughout his career, a proactive approach to training could have introduced options that weren’t accessible by the time outside emergency response teams got involved in an incident.

“Many times, these incidents could have been mitigated and solved quickly, but the people involved weren’t prepared. Because they couldn’t respond effectively, the incident turned into an emergency.”

Another factor that can often be a barrier to the development of a “first thirty minutes” plan is a reluctance to assume a formal role in a response, said Smith. Often, companies feel that they don’t have the resources to “become emergency responders,” or they simply assume that a responding fire department, contractor or even the 911 emergency network will be better equipped to deal with an incident than they are.

However, “this plan really is in the scope of the experience we have as an industry,” said Smith, adding that the ASTI plan focuses on simple action any designated professional can take to secure the safety of everyone in a facility and control a situation immediately.

“You don’t have to be an emergency responder to make a difference here if you have the training and awareness you need,” said Tyson’s Chapman. “You can minimize an emergency because you are the only one that has the power to take action in the most critical time window.”

That’s because it will take at least thirty minutes for an outside response team to respond, assemble and establish control of the incident.

Generally, by the time a facility discovers it has a leak on its hands, the clock has started ticking, said Americold’s Walker. “The ideal situation is to take the proper steps to establish a safe environment right away, get the problem under control and manage it until emergency teams show up.”

At that point, handing the situation over to an outside team means that responders have a head start in dealing with the issue and in most cases can simply continue the response process and shut the problem down.

The alternative, doing nothing until response teams arrive, will mean that valuable time is lost and the problem has had an opportunity to grow out of control, possibly requiring a much higher level of response by the time personnel is in place to deal with it.

“By the time the first wave of responders, usually the fire department, arrives on the scene, the volume of the leak is increasing unchecked. Then, there’s an even longer delay if a more sophisticated team, for example a Hazmat team, needs to be called in,” said Walker.

Whether a company is depending on its own employees and safety contractors to respond with the knowledge necessary to handle an emergency, or relying on outside teams, disorganization will hinder the response if specific roles are not designated ahead of time.

“I’ve been involved with teams that are well trained when it’s time to act, and those that are not,” said Miller. “The teams that are well trained have much better outcomes. The value of following a plan for the first thirty minutes is in understanding what everybody’s roles are.”

In fact, said Smith, the backbone of “the first thirty minutes” plan is a specific framework for roles and responsibilities that should be designated ahead of time and assumed immediately as soon as a threat is detected.

While the four roles specified under ASTI’s first thirty minutes response plan may seem involved outside of the context of the full plan – with all its accompanying material and checklist information – the procedures outlined by ASTI are actually very simple, said Smith.

“Over the last five years, we’ve created checklists and guidelines that operationally connect a response plan to action,” he said. “The methodology is simple to follow, and it accomplishes what we actually need to accomplish in an emergency.”

Smith added that the origin of the emergency plan created by ASTI was developed in part due to a mandate from the Clean Air Act that was implemented by the White House in the early 1990’s. The National Response Team, led by the Environmental Protection Agency was asked to look at the status of public and private emergency response in the U.S. After considerable evaluation it was recommended that all public agencies and industries develop an integrated contingency plan for emergency response that they called the “One Plan.”

“What we’re doing with emergency response for ammonia refrigeration has implications beyond our industry,” he said. “Our plan will be the hallmark for emergency response plans at all of the nation’s chemical facilities.

” Nevertheless, said Tyson’s Chapman, ASTI’s first thirty minutes plan is already starting to benefit ammonia refrigeration. “Safe handling is what we’re all about in this industry, and this plan contributes a lot to the work we’re doing in the safety arena. We’re hoping the industry will adopt it.”

Meanwhile, the plan may get more attention in the next few years with the release of a safety training video, currently being co-produced by ASTI and IIAR.

The video will feature interviews with participants of the first thirty minutes plan, and provide an overview of its basic structure, said IIAR President Dave Rule. “ASTI, and the companies that have adopted this plan are helping our industry lead the way in safety planning and emergency response. We’re excited to bring all the knowledge and expertise of IIAR members to that process,” he said.

ASTI’S FOUR EMERGENCY LEADERSHIP ROLES

According to ASTI, any facility planning a response should identify and train personnel to assume four primary command team roles: plant incident commander (plant administrator); lead responder (systems operator); notification unit leader (administrative role); and evacuation group supervisor (lead supervisor).

Each role assumes several specific responsibilities according to four main objectives: discovery; initial response; sustained response and termination of an emergency.

It is important to note that the actions listed in the discovery and initial response phases can be accomplished by using an emergency action plan, or EAP, rather than an emergency response plan, or ERP, said ASTI President Gary Smith. The key factor is to assure that the engagement of the hazard zone control plan occurs by plant responders working outside of the area designated as “immediately dangerous to life and health” (IDLH) which is 300 part-permillion (ppm) for ammonia.

The command team and response checklists designed to be engaged during the four phases of response are designed for an all-hazards response, he said. In other words, the same command team and the same basic approach to emergency command and control works for fire, chemical release, medical emergency, or any other emergency event.

Under the ASTI plan, the discovery objective begins with an alert process that notifies the plant incident commander and the command team with the first details about the incident. Those details, said Smith, include questions that address who, what, where, and issues surrounding life safety concerns. The plant incident commander , or IC, will assume command and announce the hazard zone location, level of concern (1-incidental, 2-contained but not controlled, 3-emergency out of control), an established isolation zone distance (NH3 100’ to 1,000’), and the location of an incident command post.

INCIDENT COMMANDER

The incident commander’s responsibility is then to establish a life safety objective designed to prioritize personnel safety and to initiate an emergency control plan based upon the location of the hazard zone. The mechanical room, roof-top condensers and pipelines, cold room would have a two page hazard zone checklist associated with different life safety and emergency control plan expectations, said Smith.

The incident commander’s announcement of those critical details engages the command team on pre-determined initial response actions identified in the Hazard Zone Emergency Shut-Down Operations Checklist.

LEAD RESPONDER

Meanwhile, the lead responder’s responsibilities are to size-up life safety within the area of origin of the release or fire, and initiate an emergency shut-down. The discovery objective in this role is to: size-up and secure life safety; clear the emergency zone and perform decontamination and first aid for those escaping.

NOTIFICATION LEADER

The notification leader, meanwhile, is responsible for performing notification and documentation throughout an emergency. In the discovery phase, the notification leader: engages preauthorized notifications from ASTI’s hazard zone checklist for the level of concern communicated by the plant incident commander; assigns a notification team to accomplish the notification assignments; and coordinates with the plant incident commander to assure that regulatory notifications are made within a 15 minute time-line.

EVACUATION GROUP SUPERVISOR

he fourth role, that of evacuation group supervisor, exists to assure “life safety in the isolation zone.” The discovery objective in this role is: to review ASTI’s hazard zone checklist and engage evacuation concerns for the level of concern established by the plant incident commander; assure safe movement out of the isolation zone according to the LANCE protocol; secure movement in and out of the isolation zone from non-essential personnel; and establish safe refuge locations outside the evacuation meeting spot or inside refuge areas.

Next, the first-in fire response will require immediate access to the plant incident commander, said Smith, adding that the fire officer in charge will want an explanation about where the emergency zone is located and what is happening with the spread of the emergency threats. As part of the plan, the fire officer asks questions about the life safety status and location of evacuated personnel, said Smith. The fire office will also ask about what is expected from their support. The first-in fire officer will likely assume command if public safety resources are needed to contain and control the emergency event, he said. The plant incident commander will become a liaison to public safety incident commander and together they review a situation status report and jointly create an incident action plan for on-site and off-site response objectives. This process follows pre-determined teaming guidelines provided within the ASTI One Plan.

Finally, when the emergency is under control and a hazard analysis reveals that it is safe to begin clean-up and recovery operations the incident commander must issue a public safety termination proclamation form to formally end the emergency. The command team assumes responsibilities for engaging the business recovery plan.