Hazard Based Planning
HAZARD BASED PLANNING
Guideline for the Development of a Municipal Hazardous Materials Emergency Plan
The potential for a hazardous materials emergency exists throughout the province. Even if a municipality does not have a hazardous material commercial or industrial facility, an incident may be caused by the transportation of dangerous goods near or through the area. Hazardous materials emergencies are capable of endangering the health of the local population and the emergency responders directed to assist them.
Under the Emergency Management and Civil Protection Act (EMCPA), municipalities in Ontario are required to have an emergency response plan as part of their emergency management programs. The development and implementation of a hazardous materials emergency plan is voluntary since it exceeds the requirements of the current legislated program; however it is recommended to increase the resilience of the municipality.
Aim and Scope
The aim of this plan is to allow for a more coordinated response to an emergency arising from hazardous materials. A hazardous materials hazard involves the release of a hazardous material during production, storage, use, or transport. Hazardous materials are substances that are potentially hazardous to humans, animals, and the environment when mishandled or accidentally spilled.
The scope of this plan is to identify lead agencies and detail their responsibilities in the case of an emergency caused by hazardous materials, whether it is at a fixed-site or in transit. The plan should also detail resource and emergency information requirements.
Authority and Maintenance
[Identify the authority this plan falls under (e.g. by-law)]
[Discuss the review and revision cycle of the plan, who is responsible for it, and how often the task will need to be carried out. It is recommended that this be done annually or after an event related to the hazard (i.e. after an exercise, after an actual emergency)]
Example: “This plan is published as Annex _ to the ______________ Emergency Response Plan as authorized by By-law ________; and the Emergency Management and Civil Protection Act, RSO 1990. The custodian of this plan shall be the _____________________, who is responsible for the annual review, revision, and testing of this plan.”
Description of Hazard and Risk
Characteristics of Hazard
A hazardous material can be defined as any material that, because of its quantity, concentration, or physical or chemical characteristics, may pose a hazard to human health or the environment. Hazardous materials include the following categories:
- Flammable and combustible materials
- Toxic materials
- Corrosive materials
- Compressed gases
Characteristics of Risk
An accidental or uncontrolled hazardous materials release into the environment poses a risk. Municipalities and industries should collaborate and consult regarding the risks to determine their response capabilities and address any identified gaps. Any information shared by the facility is protected under the Emergency Management and Civil Protection Act as proprietary information and emergency planning purposes.
Hazardous materials emergencies may be instigated by:
- Severe weather (e.g. lightning strike)
- Failure of a containment tank or berm
- Equipment/process failure
Potential consequences of the risks posed by hazardous materials include:
- Threat to worker/public health and safety
- Environmental contamination
- Loss of critical infrastructure
Locations in the municipality with a greater risk of a hazardous materials emergency because of the presence of a particular material may be identified in the plan with a strategy for containing and cleaning up spills. The plan could identify response considerations such as whether a fire involving a hazardous material can be extinguished or allowed to burn. Some hazardous materials are ‘water-reactive’ meaning they would pose a greater risk when in contact with water.
[Example: Anhydrous ammonia railcar offloading occurs 4-5 times per week with the potential of a hose or connection failure (high probability). The potential release of 33,500 United States Water Gallons (USWG) of the product would cause environmental contamination and a threat to employees’ and public health and safety (high consequence).]
A valuable resource is the Emergency Response Guidebook (ERG). This Guidebook was designed to assist first responders in identifying the hazards of the material(s) involved in an incident, and in being able to protect themselves and the public during the response phase of an incident. This Guidebook may be a useful planning tool in the prevention, mitigation, preparedness, and recovery phases as well. More information may be obtained from Transport Canada’s website at http://wwwapps.tc.gc.ca/saf-sec-sur/3/erg-gmu/erg/ergmenu.aspx.
Implementation of Plan
[Who has the authority to implement the plan (e.g. municipal emergency control group, industry, fire department)?]
[Who maintains the notification list of external partners?]
[Who notifies those who have responsibilities under this plan and how?]
The Plan should indicate who has the authority to initiate the notification process and implement the Plan. The authority may lie with key individuals, such as a member of the Municipal Emergency Control Group or a department head. The person responsible for maintaining the notification list for internal personnel and external partners should be clearly indicated. A clear and succinct notification process must show who is responsible for making the notification contacts and list the primary and secondary notification methods.
Functional Roles and Responsibilities
According to the Canadian Environmental Protection Act and its associated Environmental Emergency Regulations “anyone using or storing a listed substance in a quantity equal to or above the specified threshold, or who has a container with a capacity for that substance equal to or in excess of the specified quantity, will have to notify Environment Canada of the place where the substance is held, along with the maximum expected quantity and the size of the largest container for that substance. If both criteria are met, the regulatee is required to prepare and implement an environmental emergency plan and notify Environment Canada accordingly. An Environmental Emergency plan documents ways to prevent, prepare for, respond to and recover from environmental emergencies caused by toxic or other hazardous substances.”
Furthermore, Transport Canada requires companies to have an approved Emergency Response Assistance Plan prior to the movement of “any dangerous good that could present wide-spread hazard if released during transport.” An Emergency Response Assistance Plan ensures that on-site assistance is available to responding agencies to contain the dangerous good. The assistance provided would include, without being limited to, the provision of emergency response advice first by telephone, then by a knowledgeable person attending the accident site, and the supply of specialised equipment and a response team to mitigate the effect of the dangerous goods at the accident site.
According the Environmental Protection Act “the owner of the spilled materials and the person who had control of a material when it was spilled” is required to promptly clean-up and restore the environment. Municipalities have the right under the Act “to respond to spills, and the right and mechanism to recover the costs.”
Municipalities should work with partners to determine functional roles and responsibilities. Departments and agencies that may be involved in a response include (but is not limited to) fire, police, emergency medical services, emergency social services, volunteer agencies (e.g. Canadian Red Cross, Salvation Army, etc.), provincial ministries (e.g. Environment and Labour), and industry representatives. Which roles and responsibilities that will need to be fulfilled for any given emergency will depend upon the following considerations:
- The hazardous material involved, including:
- The degree of health hazard
- The amount of the hazardous material involved
- The rate of vapour movement
- The population being threatened, based on:
- The location of the spill
- The number of people effected
- Building types and availability
- The presence of special institutions and populations
- The weather conditions
The list below provides a sample of responsibilities that may need to be assigned:
- Warning neighbouring areas
- Preventing further escape of hazardous material
- Establishing the necessary perimeters (i.e. cold, warm, and hot zones)
- Rescue and firefighting
- Establishing staging areas, and ingress and egress routes
- Determining the nature and effects of the hazardous material
- Initiating the first level of decontamination of patients prior to transportation to health care facilities
- Activating contamination protocols
- Providing security of perimeters
- Ensuring appropriate health and safety measures are taken by all responders including the use of personal protective equipment
- Advising hospitals of possible contaminated “walking wounded” arriving at emergency departments
- Assessing the impact on the health of the public
- Determining if evacuation or shelter-in-place is required
- Facilitating evacuation orders or shelter-in-place protocols
- Arranging for transportation of evacuees to shelters as required
- Managing the evacuation or shelter-in-place operations
- Coordinating with the Ministry of Transportation regarding Emergency Detour Routes (EDR)
- Activating and managing evacuation shelters
- Providing food for responders and evacuees
- Contacting the Fire Coordinator to activate the provincial CBRNE teams via the Ontario Fire Marshall as needed
- Providing decontamination dyking as required (eg. sand, drain covers)
- Activating/deactivating pumping stations to protect drainage systems
- Providing specialized equipment and expertise required to mitigate the response
- Advising the Provincial Emergency Operations Centre
- Declaring a state of emergency as appropriate
- Implementing Mutual Assistance Agreements as required
- Initiating cost tracking
- Determining human resources, resource, and equipment needs
- Advising the public on matters concerning public health
- Emergency lodging and/or care of pets and livestock
- Advising the Ministry of Environment Spills Action Centre
- Advising the Ministry of Labour
Further to the functions listed above, specific ministries or federal departments may have a role in a hazardous materials emergency. For instance, the Ministry of the Environment, through the Spills Action Centre, is available to support the first response for emergencies that have an environmental component. This support may include:
- Monitoring water and air quality in affected areas
- Ensuring cleanup and remediation of affected areas by responsible parties
- Ensuring disposal of contaminants in accordance with pertinent regulations by responsible parties
- Assisting in identification of responsible parties
- Providing technical advice to response agencies
The Ministry of Labour is responsible for ensuring compliance with the Occupational Health and Safety Act (OHSA), which includes compliance during emergency operations. As per Section 21 of the OHSA, employers are required to take every precaution reasonable for the protection of a worker’s health and safety. The Ministry:
- Assesses employers’ efforts to ensure worker safety through the supervision and training of all workers engaged in the operation
- Reviews the various hazards workers may be exposed to and audits the employers’ policies and procedures addressing the hazards as required by the OHSA
Environment Canada may also be available to provide scientific and technical support, including information on the characteristics of substances and how they might affect human health and the environment, weather forecasting and spill modeling, sampling and laboratory support, and information on clean-up techniques. Environment Canada may also be involved in oversight of an emergency if the incident has an impact on another country, on federal lands, or on areas of federal regulatory authority.
Evacuation and Shelter-In-Place
Evacuation is often the first response to a hazardous materials emergency. The Emergency Response Guidebook provides suggested evacuation distances for specific materials. For potential fixed-site incidents, the Plan should consider the hazards in the municipality and make reference to the suggested evacuation distances and the means by which evacuation will be accomplished. Considerations would include how to move traffic quickly outside the area, how to prevent traffic from re-entering the area, and how to facilitate the relocation of special and vulnerable populations (e.g. schools or hospitals within the area).
If there is insufficient time to evacuate or it would be unsafe to do so, Shelter-in-Place may be the better choice. The Plan should outline the considerations that would trigger a Shelter-in-Place response rather than an evacuation, as well as pre-scripting emergency information on this procedure. Shelter-in-Place procedures can be included in the Emergency Information and Communications section of this plan, as an annex to this plan, in a Shelter-in-Place plan, or in an Emergency Information Plan.
In addition to the immediate threat posed by a hazardous material, a longer-term relocation of the population may be necessary. For example, a hazardous material may contaminate the soil or water in an area. The Plan should outline methods to identify threats to the water supply and/or the sewage system in order to assist decision-making on longer-term relocations.
Arrangements with Neighbouring Communities and/or Lower and Upper-Tiers
[Detail arrangements (mutual assistance agreements, MOUs, etc.) with neighbouring communities to provide assistance, such as the hosting of evacuees, the availability and use of alternate EOCs and/or Hazmat teams, and human resource sharing. Remember that your outside resources from neighbouring communities maybe already committed as they have been impacted by the same event and/or their response may be delayed.]
[Detail the extent of municipal assistance that would be considered in assisting evacuees (financial, logistics/advice).]
Emergency Information and Communications
The Plan should identify who has the authority to release emergency information to the public during an emergency. As hazardous materials emergencies typically involve many partners, the procedures and protocols should be determined in advance of an emergency. Consider whether the municipality has a public notification system established and when and how it would be activated. It is recommended that the municipality establish partnerships with the local media in order to help facilitate emergency information dissemination. In addition, it would be useful to include in this Plan a contact list for media outlets.
The Plan should include pre-scripted emergency information messages for potential hazardous materials emergencies identified in the Community Risk Profile. This information can be included in this section, as an appendix to this Plan, or in an Emergency Information Plan. Messages can be pre-scripted for Shelter-in-Place instructions or evacuation planning.
The links below provide a sample of pre-scripted emergency information for hazardous materials emergencies:
- Hazardous Material Information:
Municipalities should work with the partners identified in the functional roles and responsibilities section to determine resource availabilities or requirements. The list below provides a sample of resources that may be required:
- Firefighting and rescue equipment, including respirators and resuscitators
- Communication equipment
- Hazardous materials equipment
- Decontamination equipment
- Mobile public address equipment
- Personal Protective Equipment
- Emergency lodging and feeding facilities
- Auxiliary power
- Auxiliary lighting
- Wrecker/tower equipped with cutting torches
- Hazardous materials test equipment
If your municipality has arrangements with resource suppliers, include a contact list.
[Outline financial procedures and obligations, such as:
- Pre-existing contracts with 24/7 suppliers
- Extra-ordinary expenditures
- Expenditure authorities (e.g. who can sign a purchase order?)
- Human resources considerations (e.g. tracking of over-time, volunteers, collective agreements)
- Potential cost recovery (e.g. third party liability)
- Location and procedure for accessing emergency petty cash
- Donations Management]
Support and Supplemental Plans that may be referenced in this Hazardous Materials Emergency Plan include:
- EOC activation and operations
- Public works agreements
- Fire services agreement
- Industry Environmental Emergency Plans
- Municipal Mutual Assistance Agreements.
Consider what processes or procedures are available or in place to prevent an emergency, including those activities conducted by partners (e.g. replacing the product with less-hazardous materials; storing smaller quantities.) Commercial and industrial facilities may include the following as preventative measures:
- Risk assessment
- Facility design and construction to specific standards
- Preventative maintenance checks and programs
- Maintaining effective operating procedures and facility documentation
- Operator competence assurance
- Management of change in design, service or staff to minimize impacts on operations
- Incident investigation and analysis to minimize recurrence
- Assessment of compliance to standards
Consider what processes or options are available or in place to reduce the impact of the event, including those activities conducted by partners (e.g. berms surrounding loading and offloading areas; containment pools; containment buildings to enclose off-gasing; buffer zones; transportation routes through unpopulated areas.)
All stakeholders (public, municipal, industry, health sector, school boards, NGOs) should be included in the planning process. Municipalities may consider forming a steering committee (or Community Awareness Emergency Response group) to conduct consultations, training, and exercises; to ensure a comprehensive plan; and to bridge the gap between industry and municipal response.
Preparedness activities may include, but are not limited to the following:
- Training of response personnel (industry and municipal)
- Testing the plan, exercising the people and processes, and updating the plan as necessary
- Reviewing the plan at least annually, as processes change, or after an incident as required
- Obtaining contracts with external hazardous materials response agencies
- Conducting public education and public awareness campaigns
- Implementing a Public Alerting System
- Identifying gaps between industry and municipal capabilities and limitations and matching these gaps to the resources available (i.e. external contractors)
- Mapping worst case scenarios, plume modeling, spills, waterways, etc.
- Establishing hazardous materials transportation routes or Emergency Detour Routes.
- Conducting training for first responders.
- Providing and training on appropriate personal protective equipment.
Continuity of Operations Planning (COOP)
[Based on recommended practices, consider including Continuity of Operations (COOP) as part of the risk management process. Consider locations of municipal services, facilities and infrastructure as they may be affected by a hazard.]
Commercial or industrial facilities, or contracted transportation companies are responsible for the hazardous materials under their control. This includes the restoration of the effected area following a spill. The recovery activities involved will depend upon the material that has been spilled. Municipalities may also be involved in the clean-up and recovery operations and this section of the plan should detail activities to restore the environment or municipal services.
[Consider post-event reporting procedures, such as:
- Quick tactical de-briefing (hot-wash)
- More detailed operational de-briefing
- Questionnaire (to volunteers, contractors, media, owners of facilities used, etc.) in order to identify gaps and future considerations for improvement
- Development of an After Action Report, a financial report, and a report to program committee/council]
[Discuss who generates the above, when they will be created, to whom they will be presented, and how the lessons learned will be incorporated into the hazard plan.]