Hazardous Waste Contingency Plans Must Include a Quick Reference Guide [40 CFR 262.262]
Large quantity generators of hazardous waste have always been required to have a contingency plan for hazardous waste spills, fires, and emergencies. The plan must be made available to local hospitals, fire departments, police departments, and state and local emergency response teams that might be called upon to provide emergency services. Because of all the information required in the plan, it can be cumbersome to quickly find essential information when it is needed in the event of an emergency.
EPA has addressed this issue by establishing a new requirement for contingency plans in the Hazardous Waste Generator Improvements Rule
, which goes into effect at the federal level on May 30, 2017. States with authorization to implement the Resource Conservation and Recovery Act will have 6 months to update their regulations in order to implement this and other more stringent requirements of the new rule.
Under the new requirement, large quantity generators of hazardous waste must prepare a quick reference guide for the site contingency plan and submit this guide to the local emergency responders, or as appropriate, to the Local Emergency Planning Committee (LEPC).
The quick reference guide must include:
- The types/names of hazardous wastes in layman’s terms and the associated hazard associated with each hazardous waste present at any one time (for example, flammable paint waste, toxic electroplating waste, corrosive nitric acid waste);
- The estimated maximum amount of each hazardous waste that may be present at any one time;
- The identification of any hazardous wastes where exposure would require unique or special treatment by medical or hospital staff;
- A map of the facility showing where hazardous wastes are generated, accumulated and treated, and routes for accessing these wastes;
- A street map of the facility in relation to surrounding businesses, schools and residential areas to understand how best to get to the facility and also evacuate citizens and workers;
- The locations of water supply (for example, fire hydrant and its flow rate);
- The identification of on-site notification systems (for example, a fire alarm that rings off-site, smoke alarms); and
- The name of the emergency coordinator(s) and 24/7 emergency telephone number(s) or, in the case of a facility where an emergency coordinator is continuously on duty, the emergency telephone number for the emergency coordinator.
Large quantity generators of hazardous waste must update their quick reference guides as necessary whenever the contingency plan is amended, and submit these documents to the local emergency responders or the LEPC.
Now would be a good time for you to update your contingency plan to reflect not only the changes in the regulations, but also to update any other outdated or incomplete aspects of the plan. For example, is our emergency equipment list up to date? Does the equipment list include the locations and capabilities of equipment that you would use in the event of a hazardous waste incident? Does your plan identify the correct names and phone numbers of organizations that you would call upon in the event of an emergency? Do you have written emergency assistance agreements with these emergency organizations? Are your emergency response procedures adequate and effective for the types and volumes of hazardous waste on-site? Have your personnel been trained in implementing your emergency procedures? If you need assistance in updating your plan or training your employees, contact Environmental Resource Center