The University of Chicago
Safety Manual
Occupational Safety and Health Programs

Section 3.5

Emergency Response Plan for Hazardous Materials

Policy

The following plan has been developed to minimize the severity of damage to human health and the environment in the event of an unexpected hazardous materials release.

Scope

The Emergency Response Plan for Hazardous Materials pertains to any hazardous material incidents.  This shall also include any confirmed fire, suspected contamination and serious injuries and/or death as a direct result of a hazardous material incident.

Authority and Responsibility

The implementation of the Emergency Response Plan for Hazardous Materials program is the responsibility of various University Departments.

The University Police Department shall be responsible for:

  1. Notifying the "On-Call" Safety Officer in the event of a hazardous material incident;
  2. Initiating an evacuation of an area or building by orders of the On-Scene Incident Commander and securing the area to prevent access to unauthorized personnel; and
  3. Notifying additional resources to request assistance as determined by the On-Scene Incident Commander.

Environmental Health and Safety shall be responsible for:

  1. Providing a "On-Call" Safety Officer twenty-four hours a day, seven days a week;
  2. Responding with appropriate action to control and remedy the incident;
  3. Responding to a reported incident in a timely manner;
  4. Maintaining liaison with the local Police and Fire Departments;
  5. Notifying Administration of an incident and providing periodic status reports; and
  6. Reviewing and amending the Emergency Response Plan for Hazardous Materials.

Pre-Emergency Planning and Coordination

Arrangements have been made to coordinate the University's Emergency Response Plan for Hazardous Materials and applicable emergency services with the local Police Department, Fire Department and the Fire Department's Hazardous Materials Team.  Copies of the plan and all revisions shall be submitted on an annual basis or as the plan is amended to the aforementioned authorities.

Community contacts include:

Meetings shall be held annually with personnel from these authorities.  A representative from Environmental Health and Safety shall be responsible for scheduling annual meetings and recording minutes.

Copies of the University's Emergency Response Plan for Hazardous Materials shall be maintained at the facility within Environmental Health and Safety located at 6054 South Drexel Avenue - 2nd floorand within the University of Chicago's Safety Manual.  Copies shall also be maintained at the facilities on-site emergency response carts located at:

The Emergency Response Plan for Hazardous Materials shall be reviewed and amended by Environmental Health and Safety on an annual basis and when any of the following situations occur:

  1. Applicable regulations are revised;
  2. Plan fails during an emergency;
  3. List of emergency coordinators changes;
  4. List of emergency equipment changes; or
  5. Any facility change that would affect the plan.

Incident Notification

The University of Chicago Police shall be notified immediately upon discovery of an emergency incident by dialing 123 (from a campus phone) or 773-702-8181.

Chemical Spill

If a chemical spill occurs within a University building or property, the University Police shall immediately notify the "On-Call" Safety Officer.  The "On-Call" Safety Officer shall gather information pertaining to the incident.  Once information is obtained, the "On-Call" Safety Officer shall notify the Director of Environmental Health and Safety or Associate Director in his/her absence.  The Director of Environmental Health and Safety or Associate Director shall advise the "On-Call" Safety Officer on the appropriate action to be initiated depending on the incident.  If the Emergency Response Team is activated, refer to the section "Emergency Response Team" in this policy for duties.

Notification of Outside Agencies

When a reportable quantity of a hazardous material is released into the environment, it is necessary that certain regulatory agencies be contacted.  The On-Scene Incident Commander from Environmental Health and Safety shall determine the need to report a release and consult with the University's Office of Legal Counsel prior to notification.  The regulatory agency shall be provided with the following:

  1. The location of the incident;
  2. The name and telephone number of contact at the incident;
  3. The type and amount of hazardous material released; and
  4. The size of the area involved in the incident.

The outside agencies shall include the following:

In addition, Risk Management and University News and Community Affairs shall be notified and given information on the incident as soon as practical by the "On-Call" Safety Officer.

Emergency Response Team

On-Scene Incident Commander

The Director of Environmental Health and Safety or Associate Director shall be the On-Scene Incident Commander.  In the absence of the above On-Scene Incident Commander, the "On-Call" Safety Officer shall assume the On-Scene Incident Commander duties.

Duties may include:

  1. Activating the Emergency Response Plan for Hazardous Materials and Hazardous Materials Response Team;
  2. Identifying hazards and risks involved in an emergency response situation;
  3. Activating internal facility alarms or communication systems to notify all applicable personnel;
  4. Establishing a staging area for equipment, resources and personnel;
  5. Setting up an initial perimeter for security and entrance;
  6. Notifying, if needed, the Police Department, Fire Department, and any applicable State and Federal organizations;
  7. Assuming overall authority for managing the emergency unless higher command arrives (e.g., Fire Department Chief);
  8. Performing emergency response termination procedures; and
  9. Conducting emergency response critique and arranging follow-up procedures.

Hazardous Materials Technician

The Hazardous Materials Technicians include staff from Environmental Health and Safety and Radiation Safety (Industrial Hygienists, Safety Officer and Health Physicists).

The Hazardous Materials Technician shall perform all duties assigned by the On-Scene Incident Commander consistent with his/her training.

Duties of the Hazardous Materials Technician may include:

  1. Implementing the Emergency Response Plan for Hazardous Materials;
  2. Selecting and using monitoring equipment;
  3. Selecting and using specialized personal protective equipment (PPE);
  4. Performing advanced control, containment and/or confinement operations;
  5. Implementing decontamination procedures;
  6. Participating in hazard and risk assessment of the site and termination procedures; and
  7. Participating in the development of site safety and control plan.

One Hazardous Materials Technician shall be given the title of Entry Team Leader.  The Entry Team Leader shall be chosen by the On-Scene Incident Commander.

Duties of the Entry Team Leader may include:

  1. Coordinating emergency response zones with the On-Scene Incident Commander;
  2. Coordinating entry plans with the On-Scene Incident Commander;
  3. Coordinating decontamination activities with the On-Scene Incident Commander;
  4. Supervising entry team activities; and
  5. Continually reevaluating the incident scene and reporting status to the On-Scene Incident Commander. 

Emergency Medical Team

Persons injured at the scene of the incident shall be provided with medical care.  To obtain medical care, contact the City of Chicago Fire Department Emergency Medical Service by calling 911.

Site Safety Officer

The Site Safety Officer advises the On-Scene Incident Commander on all aspects of health and safety on site and recommends stopping work if any operation threatens worker or public health or safety.  

Duties of the Site Safety Officer may include:

  1. Enforcing the "buddy" system;
  2. Conducting periodic inspections to ensure safety;
  3. Monitoring onsite hazards and conditions;
  4. Monitoring the work parties for signs of stress, such as cold exposure, heat stress and fatigue;
  5. Controlling entry and exit at the access control points;
  6. Selecting protective clothing and equipment;
  7. Ensuring that protective clothing and equipment are properly stored and maintained;
  8. Periodically inspecting protective clothing and equipment; and/or
  9. Stopping an activity if a safety concern arises.

Incident Follow-up

After each incident, the incident and Emergency Response Plan shall be reviewed and revised as necessary.  This review shall involve answering the following questions:

Training Requirements

First Responder Awareness Level

The First Responder Awareness Level are employees of the University who are likely to discover a hazardous materials release.

Training shall include:

  1. Risks associated with hazardous materials;
  2. The recognition of the presence of hazardous materials;
  3. Identification of hazardous materials;
  4. Notification procedures; and
  5. Basic decontamination procedures.

Initial required training and continuing education requirements for emergency response personnel are based on the duties and functions to be performed by each responder during an emergency response situation.  The required training and continuing education courses shall be conducted by a training facility with qualified instructors as required by the governing regulation.

On-Scene Incident Commander

The On-Scene Incident Commander shall be a trained Hazardous Materials Technician.  A minimum of eight hours On-Scene Incident Commander training or equivalent experience is required initially and eight hours of continuing education annually thereafter.  The training shall include:

  1. Risks associated with hazardous material incidents;
  2. Potential outcomes of hazardous material incidents;
  3. Advanced hazard and risk assessment techniques;
  4. The selection and usage of personal protective equipment;
  5. Advanced control, containment and confinement operations;
  6. Decontamination procedures; and
  7. The resources available during an incident.

Hazardous Materials Technician

The Hazardous Material Technician shall be required to complete 24 hours of required training and eight hours of continuing education annually thereafter.  The training shall include:

  1. Identifying hazardous materials;
  2. Risks associated with hazardous material incidents;
  3. The incident command system;
  4. Advanced control, containment and confinement operations;
  5. Advanced decontamination procedures; and
  6. The classification, identification and verification of known and unknown materials.

Communication

The On-Scene Incident Commander shall be in charge of all communication when an emergency response situation is under the University's control.  When outside personnel are called for assistance, the On-Scene Incident Commander and the "On-Call" Safety Officer shall be the primary communication sources for the University of Chicago.

The following authorities may be contacted for assistance:

Outside emergency response companies which may be contacted by Environmental Health and Safety, if necessary, include any of the below listed companies.

Outside companies may be contacted by the On-Scene Incident Commander for additional supplies such as absorbents, personal protective equipment, plug and dike, salvage drums and emulsifiers.  Companies include:

Site Characterization and Analysis

The following factors shall be considered during the preliminary evaluation to assist in determining the appropriate plan of action:

  1. Whether the incident could involve a fire, spill, release or leak;
  2. The quantity of the material and its harmful nature;
  3. The type of container and its condition;
  4. The location, time and weather conditions;
  5. Any exposures to life, property and the environment; and
  6. Available resources.

To determine the appropriate plan of action, the following reference materials are recommended:

  1. Area blueprints;
  2. Chemical inventory list;
  3. Computerized material safety data sheet (MSDS) system to help evaluate chemicals and materials present in the site area;
  4. Poison Control Center to help evaluate chemicals and possible exposure effects to on-site victims and response personnel;
  5. NIOSH Pocket Guide to Hazardous Materials;
  6. National Fire Protection Association Handbook of Hazardous Materials;
  7. Department of Transportation Emergency Response Guidebook; and
  8. The University of Chicago Pre-Fire Safety Plans.

During an incident, a more detailed evaluation of the site's specific characteristics shall be performed by emergency response team members.  The entry team shall identify existing site hazards to the On-Scene Incident Commander.  This information will aid in the selection of appropriate engineering, containment and clean-up controls, as well as the selection of personal protective equipment for remaining response team members and support staff members.

Site Control

Purpose

To prevent employee/visitor contamination and harm during emergency response activities, site control activities including the following shall be used:

  1. Site maps (e.g., blueprints, floor exit plans);
  2. Designation of hot, warm and cold zones;
  3. Communication center (a central location where all communications and plans will originate); and
  4. Emergency decontamination protocol.

The site shall be controlled and maintained by the University of Chicago Police Department and/or local Police Department personnel.

The On-Scene Incident Commander shall use information provided from the site characterization and analysis survey to determine the three emergency response zones (Hot Zone, Warm Zone and Cold Zone).  The aforementioned zones shall be determined by using the following guidelines.

Exclusion Zone

The area containing the incident itself, including the product and its container.  This area may be immediately dangerous to life and health (IDLH).  Personnel permitted in this zone shall be dressed in the appropriate personal protective equipment.

Contamination Zone

A larger geographical area surrounding the Hot Zone that is considered safe for workers to enter with limited personal protective equipment unless assigned a task requiring increased protection.

Support Zone

The area adjacent to the Warm Zone that is restricted to administration and emergency response personnel.  Minimum personal protective equipment may be required such as protective gloves and Tyvek coveralls.

Spill Control

Basic Control

Basic control is the first step taken to prevent further release of the hazardous materials.  Basic control may include shutting off a valve or shutting down a piece of machinery.

Extinguishment

When a hazardous material incident involves fire, the following procedure shall be initiated:

  1. Notify the Fire Department by calling the University Police at 123 or 702-8181;
  2. Determine the type of hazardous material in the fire; and
  3. Before attempting to extinguish the fire, determine if the hazardous material involved is compatible with the extinguishing media.  The Material Safety Data Sheet and other references will assist you in determining what type of extinguisher can be used.

Containment

There are four types of procedures that can be taken to keep the involved material in its container.

  1. Shut-off Valves:  Shut-off valves may cause spills or releases.  Ensure that all shut-off valves on the affected cylinder and/or drums are properly closed and secured.
  2. Plugging:  Plugging devices may be placed or pounded into a penetration to stop a leak.  Pieces of wood, golf tees, soap or stakes wrapped with cloth may be used.  Metal objects shall not be used for plugging purposes due to the possibility of sparking.
  3. Patching:  Materials like clay or putty may be used to patch a leak.  Look for decomposition of the patching compound as well as the possibility of the build-up of internal pressure, which could cause the patch to fail.
  4. Overpacking:  Overpacking is accomplished by placing a damaged container into a larger undamaged container.

Confinement

There are three types of procedures which can be used to keep a material in a confined area.

  1. Diking:  Materials like sand, earth, straw or absorbent material can be placed around the perimeter of the leak.  The type of diking material used shall be compatible with the spilled hazardous material.
  2. Blocking:  Drains, ditches or storm sewers shall be covered or diked to prevent run-off of spilled materials.  Blocking can be accomplished with absorbent pads or a heavy piece of plastic.
  3. Absorption:  Run-off can sometimes be absorbed with dirt, sand, soda ash, saw dust, vermiculite or other absorbent materials.  The absorbent material shall be positioned so that the spilled material runs into it.  Care shall be taken to ensure that the absorbent is compatible with the spill.

Monitoring Equipment

Quantitative measurements of hazardous materials within the environment shall be made prior to any entry.

Monitoring shall be conducted at the completion of a response to determine if the area is safe for re-entry.

The following quantitative instruments shall be used in hazardous atmospheric assessments.

  1. TMX410 Gas Meter to determine if the atmosphere is at an explosive level and if adequate oxygen is present;
  2. Dragger and/or Sensidyne Tubes to determine and/or identify the concentration of chemicals present in the atmosphere;
  3. pH paper to determine the pH of a substance for proper neutralization; and
  4. Miran IBX to measure over 100 common toxic compounds and their concentrations.

Decontamination

All clothing, equipment or person(s) assigned to duties in the hot or warm zones shall be decontaminated to remove the presence of any hazardous materials encountered.  The decontamination area shall be set-up prior to the mitigation of the incident.

Decontamination can be accomplished by:

  1. Physically removing contaminants (e.g., liquid rinse, evaporation);
  2. Inactivating contaminants by chemical detoxification (e.g., neutralizing agents); and
  3. Disinfecting/sterilizing infectious or biological materials (e.g., bleach solution).

The decontamination procedures shall be initiated by the On-Scene Incident Commander.  To ensure that the proper decontamination procedures are initiated, the Incident Commander shall make reference to following:

  1. Material Safety Data Sheets;
  2. The National Fire Protection Association Hazardous Materials Handbook;
  3. The chemical manufacturer;
  4. Chemtrec; and
  5. Other related reference materials.

Once the proper decontamination procedures are determined, the On-Scene Incident Commander shall designate an area within the warm zone to set up the decontamination process.  The equipment shall consist of portable wash tubs, sprayers, heavy gauge plastic tarp and disposable scrub brushes.

The following eight steps constitute the decontamination process for personnel involved in the remediation of the incident.

  1. All personnel exiting the hot zone shall place monitoring equipment, hand tools and other equipment in this area.  A recovery drum and/or tarp shall be set in place so all tools and equipment can be put aside for further decontamination.  All equipment and tools shall be decontaminated when work is concluded in accordance with the Decontamination of Equipment section in this policy.  Personal protective clothing, self-contained breathing apparatus and/or respirators worn by personnel are excluded at this stage and shall remain worn by personnel.
  2. After placing equipment and tools in the recovery drum or on tarps, all persons who have been within the hot zone shall be washed down with the appropriate solution, as determined by the Material Safety Data Sheet, while wearing all personal protective equipment.  All water used in this step shall be contained in a recovery drum or decontamination pool while this process is carried out and treated as hazardous waste at the completion of the decontamination process.
  3. After emergency response personnel are completely washed down, they shall remove their protective clothing.  The protective clothing shall be placed in a recovery drum or approved bag and labeled with a tag as to their contents.  Support personnel may be required to assist personnel being decontaminated with removing their protective clothing.
  4. After removing protective clothing, personnel being decontaminated shall remove their self-contained breathing apparatus or respirators.  The breathing apparatus shall be placed on a tarp for further decontamination.  For decontamination procedures of breathing apparatus and respirators, refer to the section in this policy for the Decontamination of Self Contained Breathing Apparatus.
  5. Upon removing the personal protective equipment, the emergency response personnel shall remove any clothing that may have become contaminated.  The clothing shall be placed in recovery drums or approved bags and labeled as to its contents.
  6. Emergency response personnel shall shower thoroughly if it has been determined that personal protective equipment has failed to protect the user.
  7. Emergency response personnel and persons that were in the hot zone and warm zone shall receive a post-medical evaluation by a qualified individual if overexposure or injury occurs.
  8. If it is determined that emergency response personnel or persons involved with the incident need further medical attention, transportation shall be arranged by the On-Scene Incident Commander.

Decontamination of Equipment

Decontamination of equipment shall be performed by using portable wash tubs, sprayers, and disposable scrub brushes.  Any equipment that cannot be thoroughly decontaminated along with the contents from the wash tub shall be considered hazardous and shall be stored and disposed of in accordance with the University of Chicago's Hazardous Materials Management policy, Section 6.2.

Monitoring Equipment

If monitoring equipment becomes contaminated, it shall require special cleaning techniques.  Methods for decontamination shall be obtained from the EPA's Regional Office (312) 353-2000 or the equipment's manufacturer.

Hand Tools

Emergency response hand tools shall be cleaned as appropriate by chemical or physical means.  The EPA's Regional Office may be consulted at (312) 353-2000 for specific methods of decontaminating the hand tools.  At the end of the incident, if the hand tools cannot be decontaminated, they shall be disposed of as hazardous waste.

Office and Laboratory Items

Use the same decontamination techniques used for hand tools and monitors.

Equipment that cannot be decontaminated shall be disposed of as hazardous waste.  The equipment shall be replaced immediately or as funding is secured.

Decontamination of Respirators and Self-Contained Breathing Apparatus

Personnel responsible for the decontamination of respirators shall follow the "Maintenance of Respirators" section of the University of Chicago's Respiratory Protection Program, Section 3.6.

Personal Protective Equipment

Emergency response personnel shall use appropriate personal protective equipment for each assigned job.

The following personal protective equipment shall be available for use depending on the requirements of the situation and the training of the individual response personnel:

  1. Positive pressure self-contained breathing apparatus;
  2. Totally encapsulating chemical protective suits capable of maintaining positive air pressure and capable of preventing inward gas leakage of more than 0.5%;
  3. Chemical resistant gloves and boots;
  4. Air purifying half-mask or full-face respirator with appropriate cartridges;
  5. Chemical resistant total body coverall Tyvek suits;
  6. Chemical resistant goggles; and
  7. Personal Alerting Safety System (PASS) device.

Medical Surveillance

All members of the Emergency Response Team shall be placed in the medical surveillance program.  Medical examinations and consultations shall be made to each employee on the following schedules:

 

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Environmental Health and Safety
Issued:  01/24/96
Revised:  07/28/09