Let’s Get Our Act Straight: 5 RCRA Emergency Planning Requirements
January 13, 2015
The Five RCRA Emergency Plan Requirements for Hazardous Waste Generators
No one ever said working with hazardous wastes on a day-to-day basis doesn’t come with its own set of potential dangers. Even if your company is trained in the most carefully planned preventative measures, preventative action (while worthy indeed) cannot completely safeguard your facility from accidental spills and inconspicuous leaks.
That’s why the Resource Conservation and Recovery Act (RCRA) promulgates that all small quantity generators (SQG) and large quantity generators (LQG) must have emergency hazardous waste contingency plans set in place. As set out in the federal rule, there are five requirements of the emergency plan that SQG and LQG generators must follow.
Emergency plans are also essential in that they can mean the difference between life and death in some cases. A proper spill response plan, for instance, can contain and control an accidental spill or unplanned release of hazardous waste which could otherwise turn catastrophic.
The five RCRA emergency planning requirements are:
- An adequate alarm or communication system within the facility is necessary, one that all personnel in the building can hear. If the facility is smaller, voice should suffice.
- A designated full-time emergency coordinator or alternate must either be present or on call at all times. If the designated coordinator cannot be reached during an EPA inspection, it could mean a pricey violation fine for the company.
- Emergency information, including phone numbers for the local fire department or HAZMAT team, the names, home or cell phone numbers, and addresses of the emergency coordinator(s), and any other relevant information—such as a detailed map of the facility in case a chemical fire necessitates a quick exit—should be on hand and easy to find at the facility.
- Cordoning off the necessary aisle space for movement, plus having enough water on the premises for fire-fighting, well-maintained extinguishers, spill control materials, and decontamination supplies.
- Detailed, thorough arrangements must be made in advance with local police stations, fire departments, emergency response teams, hospitals, and equipment suppliers.
Additionally, large quantity generators (LQG) are required by RCRA to set out a written contingency plan which is meant to minimize and contain the hazards of chemical releases, spills, leaks, fires, and explosions. This written contingency plan must be kept on-site at all times, and must be provided to local emergency services.
Although it is recommended that small quantity generators (SQG) also prepare a written contingency plan, it is not necessary under federal law. Yet some level of hazardous materials (HAZMAT) training for small quantity generators (SQG) and their first-line personnel is advisable.
Emergency plans can be tough to prepare and practice, but once one is set in place, anything that goes out of sync in your facility will be accounted for and the proper action will be available to all employees.
If you would like more information on the emergency planning process, please call 800-936-2311 to speak with an expert today or click here to email us.