Anniversary of World’s Deadliest Industrial Accident Keeps Hazardous Chemical Management Top of Mind
On December 3, 1984, a leak at a pesticide plant in the city of Bhopal, India caused the release of 40 tons of a highly toxic gas called methyl isocyanate – as well as a number of other poisonous gases – into the air. The poisonous gas had both immediate and lasting effects; it’s estimated that 500,000 people suffered at least some degree of exposure to the hazardous chemicals, with a total of 15,000 people who lost their lives – including those initially killed and others who passed away in the weeks and months that followed. And over thirty years later, the leaked toxic materials remain and many of those who were exposed to the gas have given birth to physically and mentally disabled children.
Today, the disaster at Bhopal is still considered the world’s deadliest industrial accident of all time. At the time, it raised urgent questions about how governments monitor and regulate hazardous chemicals. In the U.S., these questions resulted in several government actions, including the creation of the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986, which increased requirements for public awareness of hazardous chemicals and related emergency planning. It also played an important role in the authorization of the Chemical Safety Board (CSB) – a federal agency charged with investigating the causes of industrial chemical accidents with the goal of preventing their recurrence – in 1990 as part of the Clean Air Act amendments.
On the individual level, the anniversary of the Bhopal disaster must also serve as an important reminder of making hazardous chemical management and safety a priority. In the years since the Bhopal disaster, several other major chemical and industrial events – including the West, Texas fertilizer plant explosion and Tianjin explosions – continue to demonstrate the disastrous consequences of improper hazardous chemical storage. There are a number of ways safety professionals can actively protect their facilities, employees and communities from potential chemical disasters. Following is a quick look at some of the steps you can take and how VelocityEHS can help.
Ensure You and Your Employees Know What Hazardous Chemicals Are On Site
Under HazCom, employers are responsible for knowing all of the hazardous chemicals present in the workplace, and for ensure that accurate hazard information is available and communicated to employees in a clear and easily accessible way. Why? Because employees armed with the necessary chemical information and proper training are not just more prepared to prevent accidents from occurring in the first place, but also better equipped to handle incidents and mitigating risk when they do occur.
A well-maintained written plan that details all aspects of your company’s HazCom program – including how and where chemical information and safety data sheets (SDSs) are made available to employees, and the training efforts in place to ensure employees know how to properly access and use this information – is an important first step. Other key HazCom requirements include keeping an up-to-date chemical inventory list, retaining SDSs for every hazardous chemical in your inventory (and that employees have right-to-know access to them), ensuring all hazardous chemical workplace labels include all key information (such as product identifiers and hazard statements), and training employees to know and understand the specific chemical hazards they are exposed to in the workplace.
VelocityEHS’ MSDSonline Chemical Management solutions simplify the enterprisewide management of chemicals and provide an easy way for you to safeguard employees for all hazards. The award-winning, cloud-based HQ and HQ RegXR Accounts give you visibility of all chemicals in your inventory, making it easy to give your entire workforce access to SDSs anytime, anywhere. You can also use the system to more easily print labels for chemical containers to further ensure employees always have the hazard information they need to work safely.
Create an Emergency Prevention and Response Plan
In addition to outlining prevention measures, a comprehensive emergency plan should also include procedures for employees to follow during and after an event. FEMA recommends the following steps in developing and maintaining a business emergency plan:
- Program Management: Identify regulations that establish requirements, and develop and administer your program
- Planning: Assess risks, conduct a business impact analysis, and examine ways to prevent hazards and reduce risks
- Implementation: Write a preparedness plan addressing areas such as emergency response, incident management, and training
- Testing and Exercises: Test and evaluate the plan by developing and conducting exercises to gauge effectiveness
- Program Improvement: Identify when the program should be reviewed, determine methods to evaluate it, and use the findings to make necessary improvements
One important, but often overlooked part of disaster planning is identifying and communicating with first responders (local and state agencies) before an incident occurs to make sure they are properly equipped with the information and tools they need. Without this open and active dialogue with all involved parties, the plan is less likely to go smoothly in the event of an emergency.
The MSDSonline Plan1 First Responder Share Service gives companies an efficient way to provide emergency response teams with quick and easy access to facility-specific hazardous chemical inventory information. Available at no additional cost to HQ and HQ RegXR Account customers, this cloud-based information sharing service helps you provide local first responders with access to SDSs, chemical location details and facility floorplans so they can better plan, prepare and assess the risks associated with emergencies involving hazardous chemicals in your facility ahead of an emergency.
Understand You Hazardous Chemical Reporting Obligations
The EPA requires facilities with highly hazardous and regulated toxic chemicals to annually submit reports on their types, quantities and locations.
The first are Tier II Reports, which are due to the EPA by March 1 and designed to help local and state emergency responders prepare for chemical events that could impact the community. This is a critical requirement since first responders responding to fires and unaware of the chemicals within facilities are put in additional danger, especially in cases where those chemicals are highly explosive or negatively react to water. Our Tier II Cheat Sheet provides a quick guide to understanding you reporting obligations, while our Tier II on-demand webinar provides a more in-depth look at staying in compliance with the reporting requirements.
Toxics Release Inventory (TRI) reports are another important reporting requirement for facilities with 10 or more employees in specific industries that manufacture, process or use EPA-regulated toxic chemicals in quantities above the agency’s threshold level in a given year. Due by July 1 each year, these reports help provide the EPA and the public with information about the toxic chemical releases, disposals or other waste management and pollution prevention activities taking place in communities across the country. Our TRI on-demand webinar helps address many common questions and concerns surrounding your compliance obligations.
Our MSDSonline Chemical Management software also helps simplify Tier II and TRI reporting by identifying and flagging products as well as sub-component ingredients that are regulated on various state, federal and international hazardous substance lists, and generating submittable forms. This not only helps ensure your facility is meeting critical reporting obligations, but also submitting required report data based on up-to-date chemical inventory information.