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Tactical Considerations for Hazmat Facilities

Fire department training programs tend to mainly focus on response to transportation accidents, but this article looks at the variety of facilities we can encounter.

Everyday throughout the United States, fire departments respond to hazardous material incidents involving transportation accidents and fixed facilities. While Department of Transportation (DOT) regulations provide requirements for the transportation of hazardous materials, other code entities provide regulations for fixed facilities manufacturing, storing, using, and processing hazardous materials.

Fire department training programs tend to mainly focus on response to transportation accidents. Personnel are taught to stage back, recognize and identify container types, materials, spills and release conditions and mitigate accordingly. Training on fixed facilities tends to be generalized and provide minimal information for response.

The first step to effectively responding to incidents at fixed facilities is to properly pre-plan all occupancies in your response area. Before beginning the process check with your local building inspection authority. The building inspection department may have site/building plans for the facility including building locations and sizes, as well as tank locations and sizes. Mechanical heating, ventilation and air conditioning (HVAC), electrical and plumbing plans may also be available as well.

The local GIS department should also be contacted for aerial photos, topographical maps, and other valuable site information that may be available. The local fire marshal's office should also be on the list of entities to contact. Site and building information may be available and information on any construction or operational permits can be obtained.

Section 105.6 and 105.7 of the International Fire Code (IFC) requires building and operational permits for the manufacture, storage, use and dispensing of hazardous materials. The conditions of the permit will outline the quantities, methods of storage, use and dispensing allowed.

The fire inspection history should be checked. Any constant reoccurring violations or hazards found during fire inspections will likely be present during an incident at the site. Pre-planning should also include identifying multiple staging areas remote to the site for responding units and equipment. Having several pre-determined staging areas allows responders to adjust to changing weather and scene conditions if circumstances warrant relocating resources. Pre-plans should be thorough and complete for each site. Thorough pre-planning allows for a game plan to be in-place the day the incident occurs.

Dispatch and Response Policies
Upon being dispatched to a call at a fixed hazmat facility, company officers should begin thinking about hazardous material response. This applies equally to medical as well as fire and spill responses. Questions should be relayed back to dispatch about critical information. Upon being dispatched on a medical call such as breathing difficultly or chest pain to a fixed facility, the officer should ask "why is this person having a medical problem?" Is this because the employee has been exposed to a hazardous material spill or release or is it a health issue unrelated to the facility?

When dispatched to a fire, spill or release the officer should check the facility pre-plan and find out as much information as possible prior to arrival. What is the chemical, are tanks involved if so, what are the capacities (bulk or non-bulk), pressurized or non-pressurized, solid, liquid or gas, etc. Answering these questions will give the first-due officer valuable information to formulate a size-up and begin their tactical objectives upon arrival.

Arrival and Initial Actions
Upon arrival and after assuming command, company officers should contact facility personnel. OSHA General Industry Standards (29 CFR 1910) requires facilities to have emergency plans (fire, EMS, natural disasters, etc.) in-place and facility personnel be trained in the implementation and operation of the plan. As a part of these plans facilities are required to have an incident command system in-place including; incident commander, fire department liaison, safety officer, first aid and hazardous materials officers, among others. Company liaison personnel are the key to ascertaining what has happened, accountability of facility employees and what actions, if any, are being taken to control the incident, shut down machinery or processes, or lessen environment impact. Other valuable company resources often overlooked by fire department responders are facility safety officers, chemists and industrial hygienists, fire brigades and hazmat teams.

To understand the capability of these personnel, fire departments should cross-train in order for a seamless transition between facility personnel and fire department responders during an incident. Pre-planning and joint operational training are the key to developing theses necessary relationships. Effective relationships develop goodwill between all agencies involved. Facilities may offer their resources to the fire department for mutual aid on incidents not occurring on facility property.

Research and Identification
After the initial size-up, the incident commander should begin research and identification (R&I) of the incident. Facility personnel should be included in the incident command structure and assist with R&I. These individuals can be an excellent resources in the control of the incident by offering information on facility confinement, containment devices or give the location of critical emergency tank, piping and vessel shut off devices. A chemist can assist in chemical research. These individuals can give critical information about "what's next" on chemical spills, reactions and releases.

Section 2703.4 of the IFC requires facilities to maintain Material Safety Data Sheets (MSDS). These sheets are to be available and maintained in accordance with OSHA Hazard Communication laws. After identification of the chemical has been completed, the incident commander should direct the facility liaison to gather all related MSDS and associated materials to augment fire department resources. If pre-planning determines that MSDS may be compromised by an incident, the fire department should attempt to have the facility purchase and install an exterior, weather proof MSDS cabinet in a remote location to the hazard the fire department can access in an emergency to obtain all MSDS for the facility.

Section 2701.5.1 and 2701.5.2 requires the facility to have a hazardous materials management plan and inventory statement. These documents give the incident commander information on chemical names and synonyms, storage, uses, amounts, container types, emergency shut off valve locations, emergency containment systems and the storage plan for chemicals used at the facility. This information is vital in development and initiation of tactical objectives to successfully control the incident.

U.S. Environmental Protection Agency laws require companies to submit annual "Tier II" reports. These documents are required to be submitted to the state emergency response commission, the local emergency planning committee and the local fire department providing protection to the facility. In general, Tier II reports give quantities of hazardous substances manufactured, stored and/or used at a facility above certain amounts. Obtaining these reports during pre-planning can offer tremendous information while developing an emergency response plan for the facility.

Section 2701.3.3 of the IFC requires numerous safeguards, systems, hazard analysis, written safety plans or operating procedures, mitigation and engineering controls, safety audits and consequence analysis, and other specific requirements based upon occupancy classification and use.

Chapter 27 of the IFC requires numerous safeguards, including among others: limiting the amount of chemicals that can be stored in an occupancy below an "exempt amount", the installation of remote emergency shut off valves in safe locations away from the tanks and/or processes controlled by the valve, leak detection monitoring equipment to alert employees and firefighters of a leak from the tank or cylinder, fire and employee evacuation alarms to alert employees of a fire, spill or leaks.

Firefighting Considerations
Once research and identification has been conducted, tactical considerations can be developed based upon life safety, property conservation and environmental protection. If a chemical has been released, tactics should involve safe rescue and decontamination of victims, calling for hazmat and decontamination teams. Also, consider the use of engineering controls, such as closing interior and exterior doors on buildings, shutting of remote emergency valves, closing or opening containment vessels or floor/driveway drains to contain or route spilled materials to areas designed to contain runoff.

Downwind evacuation should be considered while using "defend-in-place" measures for those victims who cannot be readily evacuated. An incident that occured in Apex, NC, in October 2006 stresses the need to expect incidents to migrate from the facility complex to adjoining neighborhoods. Pre-plans should include how to notify the public and where to shelter large numbers of displaced citizens for an indefinite period of time.

Responders should expect to encounter numerous contaminated individuals and be prepared to decontaminate large numbers of ambulatory and non-ambulatory victims. Pre-plans should include what type of decontamination procedures may be necessary.

At this point, fixed facility incidents begin to take on the anticipated character of a hazmat incident. Entries are made, victims are processed, the the incident is mitigated and a clean up contractor notified. These incidents may take days or even weeks to resolve. Responders should expect to potentially stay on the incident site for an extended period of time and adjust their personal lives accordingly.

Response to hazardous materials incidents involve the gathering of extensive information to properly and safely conduct scene operations. First due officers must be prepared to deal with rapidly changing conditions involving many different chemicals from potentially multiple hazard groups. Incidents occurring at fixed industrial facilities can be challenging and offer many "unknowns" to first responders. Through adequate preplanning, utilization of facility resources, and systematic R&I, tactical operations can be developed to identify these "unknowns" to successfully manage and mitigate an incident occurring at a fixed industrial facility.

MARK A. BROWN, a Contributing Editor, serves as Fire Prevention Bureau Chief for the Concord, NC, Department of Fire & Life Safety. A 20-year veteran of the fire service, he is an appointed board member of the North Carolina Fire Marshal's Association and possesses an Associates Degree in Fire Protection and is. To read Mark's complete biography and view his archived articles, click here.