The Role of Emergency Preparedness for Facilities with Natural Refrigerants
“There are multiple regulatory avenues the government is trying to address in emergency response,” said Lowell Randel, vice president of government and legal affairs for the Global Cold Chain Alliance. “Regulatory bodies are evaluating emergency response policies and looking to ensure that the regulatory landscape has sufficient rules around it to support effective emergency response at the facility level and from local response teams.”
There have been federal rulemakings that are either just completed or underway. The Environmental Protection Agency’s recent changes to the Risk Management Program has an emergency response element, and there is also a proposed OSHA emergency response regulation. “I expect that OSHA will be doing something with PSM similar to the recent RMP changes,”
Randel said. The Risk Management Program is a key regulation for facilities with over 10,000 pounds of ammonia and requires them to engage in emergency response planning and engagement with their local responders. “The recently finalized rule strengthens some of the requirements for emergency response. It sets forth a specific timeline for field exercises and emphasizes the importance of coordination and communication with local responders as well as the local community,” Randel said.
It also emphasizes the importance of employee communication and participation in the emergency response planning process. “There are a lot of core principles you’ll see from facility to facility, but every facility will be different, so you’ll take into account the unique factors for your facility and your team what the details of your emergency plans will be,” Randel said.
OSHA’s proposed Emergency Response rule would extend and “beef up” provisions around how a facility’s responders would respond to fire or other type of incidents, i.e. how they plan for an emergency event, how they train employees, and equipment maintenance, usage and upkeep to ensure they are responding in a safe manner.
“It is important to note that if the facility qualifies as a non-responding facility, they would not be subject to the proposed rule change, but if they have responders who enter an Immediately Dangerous to Life and Health (IDLH – 300 ppm) atmosphere, the HAZWOPER -and process safety management requirements do become subject to this proposed rule,” Randel said.”
CREATING A PLAN
The Ammonia Safety Training Institute offers a range of emergency preparedness insights and has been asked by the Region 9 Environmental Protection Agency to conduct four tabletop exercises (TTX) per year within Region 9 for the last five years. A TTX is an emergency preparedness activity that uses a fictitious ammonia loss of containment ‘event’ to engage participants from industry, public safety and government (the Tripod) to respond to pre-developed inject questions that are created by ASTI. The TTX process invokes the need for the Tripod responders to communicate their plan of action for the inject response challenge TTX ‘Event’ that they face.
ASTI facilitators encourage a cooperative and constructive command and operations connection between the local industrial and public safety first responders, government personnel, and other Tripod attendees to evaluate the key messages that would improve the future engagement of their own emergency response practices.
“We create tabletop experiences with high-profile ammonia-related scenarios that begin as an accidental release Event that escapes containment and control and progresses through the four stages of response: discovery, initial response, sustained response, and termination/recovery stages. During the recovery stage, we conduct a debriefing that points out the key points needed by responders that address their locally adopted concept of operations (Ammonia Response CONOPS),” said Gary Smith, CEO and co-founder of the Ammonia Safety Training Institute.
This is a federal framework that outlines the core components of an emergency response plan. “The overreaching emergency response framework then officially links to the states, especially the states enforcing the federal regulations. Even if they aren’t, states have certain rights to come up with requirements they think are necessary, and the authorities have the jurisdiction to dictate how to address ammonia emergency events,” Smith said.
IIAR standards offer valuable emergency system components such as operational SOPs and best practices guideline documents such as the Critical Task Guidance for Ammonia Refrigeration System Emergency Planning. The guidance should be considered by the AJJ for inclusion within the Ammonia Response CONOPS.
“The emergency preparedness and system control recommendations for industrial responders and operators that extend from training and certification provided by RETA and IIAR adds a great deal of validity and strength to the locally adopted ammonia response CONOPS,” Smith said. “The Tripod agreement to utilize a local ammonia response CONOPS is the best opportunity to stop an emergency when it is small.”
Smith said ASTI’s framework for training and emergency response includes four key areas. These include:
Ammonia Emergency Response Concept of Operations (CONOPS): The CONOPS is to be utilized based upon emergency response logic adopted by the local Authorities Having Jurisdiction (AHJ) that must also comply with the State and Federal emergency response framework. The adopted response CONOPS is nurtured during pre-event training sessions and tabletop exercises. The goal is to attain Tripod cooperation and compliance with the contents of an AHJ-adopted ammonia response CONOPS.
Cooperative Research and Development Agreement (CRADA): ASTI was invited by IIAR leadership to work with the Department of Homeland Security – Chemical Security Analysis Center (CSAC) to share insights about the emergency management readiness to contain and control ammonia and aqueous ammonia hazards, risks and threats of high-impact emergency events that could become catastrophic disaster events.
The ASTI report is a compendium of lagging and leading indicators that play a part in the Bowtie hazard analysis. Lagging indicators inspire preventative barriers (risk mitigations) that contain and control the threats associated with a loss of hazard containment event. If preventative barriers fail, a top event—an emergency—emerges.
System operator specialists and emergency responders must collaborate and use Leading indicators to assess the risks and threats and devise an incident action plan to safely contain and control the top event before it becomes catastrophic.
Playbooks Based on Federal Emergency Response Framework: The One Plan Playbook emergency response system that plays on a web-app platform. The Playbook platform allows a facility to upload emergency response details that apply to each hazard zone in their plant.
The One Plan (Integrated Contingency Plan) was built by the National Response Team (NRT) and adopted by EPA in 1991. The web-app system provides the facility owner with the opportunity to upload emergency plans, master maps, diagrams, pictures, and video clips that depict critical information needed during the four stages of response. The goal is to provide the facility owner with a self-sufficient custom built response system that complies with all governmental regulations and public safety responder needs.
The Playbooks are used for emergency planning, compliance training, and to provide guidance and documentation of situation status during an emergency event that the facility team leader can link to off-site response contractors and corporate tech support.
Significantly Improve Operational Critical Tasks First Responder Capability: ASTI recommends that a facility owner/employer consider selecting two or more facility operators and/or ammonia system maintenance personnel to engage in defensive actions to address Discovery and Initial Response actions under the auspices of an Emergency Action Plan First Responder Operations-level Emergency Action Plan rather than to select the non-responder option.
The OSHA standard for “Operational” eight-hour responder training is found in 1910.120(q)(6)(ii) HAZWOPER training. This would allow the employer to use the IIAR Critical Tasks Guidance information as a recommended standard of operation to support life safety during reconnaissance, rescue support, and emergency system control while working outside of the IDLH (300 ppm) threat.
