No commercial or industrial enterprise that involves chemicals or petroleum is immune from the possibility of a disaster: some unexpected contingency that occurs beyond normal operations and catastrophically impacts yourhazardous waste management.
No matter how large or small your enterprise, you need to consider the environmental damage that might be caused by escaped hazardous materials that are supposed to be under your control—and for which you will ultimately be held legally and financially responsible, regardless of whether such a disaster is manmade (e.g. human error) or an Act of God (e.g. a tornado).
Decide today: what’s a disaster?
The onset of a disaster is not the time to begin a discussion about whether you’re actually experiencing one—whether major or minor. And the definition of that contingency shouldn’t be left to employees’ ad hoc interpretations of what’s occurring as things begin to unravel.
This is important because recognizing an unfolding disaster should instigate a well-defined and rehearsed contingency plan, with all employees knowing what triggers its implementation.
Our advice: no matter how benign the potential effect, the possible release of any amount of hazardous material into the environment should thrust your contingency plan into motion. This is especially true if circumstances are going to attract attention from mainstream news media, which are prone to sensationalize anything having to do with hazardous waste removal.
Who’s in charge?
Keep in mind that a disaster has no regard for your organizational chart, so that who should be in charge during an environmental emergency might not be the person who’s running things during your normal operations. Thus, it’s important to develop an Incident Command System, wherein once the emergency is declared, authority and responsibilities are clear, unequivocal, and without regard to the usual departmental boundaries.
Developing a contingency plan
Of course, your contingency plan must accommodate the nature of your enterprise and the kind of chemical disposalnormally required during the course of workaday operations. But in general, disaster planning should map out exactly what must be done during the first hours, days, and weeks of an incident, with responsibilities delegated to specific personnel at each juncture to ensure no important detail is inadvertently neglected that might later become a legal liability.
Keep things uncomplicated
Each step of your contingency plan should be stated in simple language and well-rehearsed. During an emergency, adrenaline kicks in while “executive processing” checks out. That means that personnel won’t be in the right state of mind to read and evaluate pages of instructional do’s and don’ts, but they can effectively execute simple, well-rehearsed assignments.
Maintain and rehearse your contingency plan
Ensure all your personnel are aware of your contingency plan and that each knows his or her role within it. Provide regular training to educate new employees and keep current ones qualified. And run drills—some planned and some a surprise—to improve your contingency plan and assess employee readiness to implement it quickly and effectively.
Of course, print (and/or post online) any changes you make to your contingency plan, and in the case of printed collateral, destroy the old and distribute the new so that there’s no confusion should disaster strike.
Printed copies of your contingency plan should be kept offsite as well as onsite in places that are intuitive and easily assessable to employees. Web copies are best kept in a secure cloud-based platform and assessable from virtually anywhere on any device.
A suitable contingency plan for contending with possible accidents and disaster scenarios is your first defense against the financial, legal, and political damage caused by any disaster that involves hazardous waste. The first step is to identify your operation’s greatest vulnerabilities.
While it might not be possible to foretell how an unplanned event will exactly impact your hazardous waste management, you can nonetheless develop a contingency plan that will lessen the degree of damage to your operations, your reputation, and—ultimately—your finances.