Emergency Action and Response Programs

Facilities that store hazardous chemicals understand that they must plan for emergency situations. However, when one attempts to research the regulatory requirements for emergency situations, you can quickly become confused. For a facility in California that utilizes Hazardous Materials there are several emergency response-related regulations that you must be familiar with.

Hazardous Waste Operations and Emergency Response (Hazwoper) – Title 8 CCR §5192(q) and Title 29 CFR §1910.120(q)

Section (q) of the Hazwoper regulations (California and Federal regulations) regulate hazmat-related emergency response activities. An exemption exists for facilities who do not require employees to engage in emergency response activities involving hazardous materials. However, if your facility has assembled a hazmat response team, these regulations outline the applicable requirements including the preparation of an Emergency Response Plan (ERP).

Emergency Action Plan (EAP) – Title 8 CCR §3220 and Title 29 CFR §1910.38

Any business with more than 10 employees must have an Emergency Action Plan (EAP) for emergency situations. The EAP must address communication, alarms, emergency procedures, etc. The EAP is not specific to emergencies involving hazardous materials, but rather applies to any emergency (earthquake, fire, medical emergency, etc.).

CalARP and RMP Emergency Response Program – Title 19 CCR §2765 and Title 40 CFR §95

Both the CalARP and RMP regulations require facilities to develop an Emergency Response Program (ERP). This CalARP/RMP ERP must not be confused with the Hazwoper ERP since the requirements differ greatly. A facility may not require a Hazwoper ERP because employees are not required to respond to release situations, but that same facility must develop an ERP which complies with CalARP/RMP. The CalARP/RMP ERP requires facilities to address coordination with local responders, training, notifications, and first-aid.

Emergency Planning and Response – Title 8 CCR §5189(n) and Title 29 CFR 1910.119(n)

The Process Safety Management (PSM) regulation requires facilities to address Emergency Planning and Response within the PSM regulation. A facility can comply with the Emergency Planning and Response requirements by either 1) developing an EAP meeting the requirements summarized above; or 2) using the Emergency Response information which was submitted in conjunction with the Hazardous Materials Business Plan (HMBP) summarized below.

Emergency Response Plans and Procedures – Title 19 CCR §2731

In California, the Hazardous Materials Business Plan regulation requires businesses to prepare response plans and procedures to address notification, medical assistance needed, mitigation measures in place, and evacuation. In addition, facilities are required to identify areas that may require inspection and isolation in the event of earthquake related ground motion.

Summary

In summary, navigating the requirements of a compliant emergency plan can be difficult, but the regulations which are summarized above provide the information to help get the plan started. Consult each of the regulations above to ensure that your response plan adequately addresses the hazards at your facility and the applicable regulatory requirements.