“We Didn’t Think That Through”: Emergency Response in Research Applications

This is a slight update and reissue of an article accidently removed earlier this year.

In a normal, non-Covid year I do numerous safety audits of laboratories and research operations, something I also did many times during my 40 year tenure before I retired to go into consulting full time. ?Almost invariably when I ask about a site’s emergency response plans, I am told they exist, are reviewed periodically, and there is no need to look at them. My experience often suggests otherwise.

When I first became involved in emergency planning as an emergency forces supervisor it was because of a significant problem which arose during a recent incident. The first responders were faced with a process emergency for which they had never trained, struggled to analyze on the fly, and – as a result -failed to take effective response actions. The incident dragged on needlessly long, some responders were placed at needless risk, and some of their actions inadvertently introduced additional unrecognized hazards. Fortunately, no one was hurt but the incident clearly showed a lack of training and realism in our emergency planning.?Decades later I recognize that this should not have surprised me. Most in-house emergencies involve relatively straight forward situations such as medical issues (heart attacks, fainting, personal health issues), slips and falls, spills, and small fires. In-house emergency forces easily and routinely handle these with fast, effective responses. However, much like the infamous safety pyramid, these more common minor incidents are but the large base of a taller pyramid leading to much less frequent but potentially much more serious incidents. These more serious incidents are often not effectively and realistically addressed in any emergency plans, never addressed in training and invariably result in catching the in-house responders by surprise if they do occur. Worst, some larger or more serious incidents often highlight major problems with the planned responses leading to poor decisions, less effective responses, and needless risk. And anyone trying to come up with a plan I the middle of emergency rapidly recognizes that it is needlessly difficult, prone to error, and a much higher risk activity than one developed, reviewed, and approved well in advance of the need.

So, what are the most common problems I continually encounter?

Failure to address many possible process emergencies. Almost all emergency plans cover handling a small spill, a small fire, a small toxic gas leak, or one leaking gas cylinder. Most fail to address less likely but nevertheless possible – and more significant- ?scenarios. Most become a major problem as they are larger or a problem because they have never been identified. What if a pallet of 4 drums is damaged and starts leaking between the solvent storage building and the process bay on a road? (A lot bigger issue than one drum inside a building.) What if the 2,000 gallon product tank springs a leak in the piping outside the dike? (A lot bigger issue than allowing the dike to contain the leak.) What if your house hydrogen system fails a component? (A lot larger release than a failure on a single pilot plant or piece of lab equipment.) What if the toxic material forces you to evacuate an entire wing, building, or site? (A lot different from a single laboratory or process bay.) What do you do if there is a fire in a vent stack??What happens if a pressurized vessel on your pilot plant develops a pin hole and starts to spray acid around a wide area? What happens if your pump seal fails and you can’t safely reach the shut off switch? In many cases there are relatively easy mitigative measures that, when identified and implemented before needed can easily address the emergency. Providing a valve to flood the vent header with nitrogen or providing a remotely actuated valve to depressure the tank can make major problem a minor response. In other cases, just thinking through the response makes the situation significantly easier. Training an operator to shut off the power to the unit at the remote panel can bring the incident to a quick and safe conclusion.

While less likely you need to give some thought as to what you would do if you are unable to easily resolve the incident. All too often the emergency plan calls for handing the problem off to the local fire department who may have no idea such a problem can exist, may not have the equipment to deal with it, and may never have planned nor trained for it. They will do their best but you cannot expect miracles.

Failure to think through and test the proposed response actions before they are needed. The first time I?found a detonable peroxide with significant visual indication of degradation I implemented our long established plan. We evacuated adjacent area except we really had no good idea of how far back we should evacuate based on the size of the container leading to confusion and a hasty rush to try and evaluate the potential extent of a failure.?We posted responders to keep people out of the evacuated area but we quickly realized we had no real idea of how many different ways there were to get into the area. Once identified, we were seriously short of responders to block all of them off, had no readily available barricades or signs, and limited ways to keep in touch with the dispersed personnel. We then baulked at the step which suggested we “carefully remove the container to a safe location” as the prospects of sending someone with a face shield, goggles, apron, and gloves to move a potentially explosive container produced no volunteers and certainly no support from anyone. So we called the state police bomb squad. After we found their number. Then found that we had to first bring in the state police as they were the only ones who could authorize the bomb squad. After recognizing how long this would take, ?we had to hurriedly make plans to keep the area clear for that long while allowing work in unaffected areas to continue. We then wasted a lot more time when the bomb squad arrived to try and identify a safe route out of the building. This resulted in the need for more evacuations and more monitoring.?Needless to say, this problem lasted well into the evening with tremendous confusion at various stages.

This is a true example of issues I find in many emergency plans. “Evacuate the area and let the cylinder vent safely” sounds good but what if the area is an entire wing and the cylinder will take days to vent? What if the gas is so toxic, corrosive, or flammable that the venting creates problems? Many, I dare say perhaps most, emergency plans are never really “tested’ for their viability or feasibility. These tests rarely need to be extensive. Simply walking through the plan in a room often highlights obvious problems. Testing it in the field usually highlights many more. Most issues are quickly apparent; some may take more effort to identify.

Failure to realize the proposed response actions are not detailed enough. Our emergency plan called for evacuating a central gas supply area until the leaking cylinder vented. Two responders were required to control the access assuming they stood right in the two doors to the area. Some thought clearly showed that they really needed to be further away for their safety. That?lead to the need for significantly more people as there were multiple ways to reach the two doors. This is but one example of the type of too casual a response plan. “Check the SDS for the material”. (Who is going to get it? Where are they to bring it? Who are they to give it to? Who is going to review the data and advise on proper PPE and response actions?) “Make sure the emergency personnel are wearing proper PPE”. (Who determines what is necessary? Where do they get it? Are they trained in it?) “A responder wearing an SCBA will go into the area and shut off the main feed valve”. (Shouldn’t there be two people just in case? Shouldn’t there be a back up team ready to go if the primary team encounters problems? Should they bring tools? Do they need a flashlight rated for the area? Do they have a drawing showing them where the valve is? How is the valve identified?) Have you identified the vacuum truck vendor your plan calls for in advance who is trained and able to suck up the large spill in a diked area or are you going to waste days locating a qualified contractor and getting authorization? “Correct/repair/Fix the leak” is easy to write but often hard to do. Should the responder really be tightening a fitting that could fail? What if the repair efforts fail? A wise person one told me “Always have a Plan B”.

Failure to ensure emergency equipment is on hand in sufficient quantities and in working order. During one drill I asked for the large, wheeled fire extinguisher to be deployed. It took 20 minutes to find out where it had been pushed out of the way of normal operations. The rusted wheels allowed if to be moved with two hefty operators at a blinding crawl to the proposed emergency site. We then wasted time trying to figure out how to remove the cover, neatly and robustly tied off to prevent animal nesting and deploy the unit. Thank heaven it was only a drill! In another, the need to several hundred pounds of absorbent led to the embarrassing discovery that we rarely had more then 100 pounds on site at any one time. No one knew how to contact our usually supplier or any idea of how long it would take them to deliver it. Realistic advance planning often results in the needs for additional supplies, pre-deployment at nearby locations, and training as to where they are located and how to get them in an emergency. Do you have enough spare respirators, gloves, goggles, face shields, and aprons? Where are you storing them? Who maintains this supply? This and a hundred other issues should be identified and addressed in advance.

Failure to realistically assess how well the emergency equipment will work. During a drill involving aluminum alkyls we deliberated spilled the smallest container on a concrete pad to test our training with the small specialty extinguishers designed for these fires. After using up our entire supply we eventually waited for the fire to burn out after we realized that we had nowhere near the amount required to be effective. Discussions with the extinguisher vendor indicated that they recommend 10 times the amount we had on hand but this had been dismissed as a self-serving recommendation. Further research suggested we could consider keeping a load of sand on site to be used to smother a larger spill. At least until we realized we did not always have a front end loader available to move it. Nor any contractor who could drive it certified and trained to use an SCBA. Nor could it reach many of the areas it could be needed. Yet, I know many of the organizations we reached out to had this as their response plan while being no more able to implement it effectively than we could. I often see plans that mention using a gas cylinder plugging kit. Where is it? Who has been trained to use it? Worse, most are only rated for less than 200 psig so their use on 2,200 psig gas cylinders is not possible. And you really think it is safe to send someone next to a leaking cylinder to hammer in a plug? I suspect volunteers, even if you allowed them to try,?will be sadly lacking.

Failure to realize that normal site operations may not be readily available during an emergency. “Get a forklift to move the absorbent from the storage building to the emergency” sounds viable. Except the storage building is locked and the supervisor and all your forklift operators are lost among the mass of employees patiently milling about in their rally points in the parking lot. What if the evacuation area happens to block access to either the forklift or the building? How close can the forklift get to where it may be needed? Does sending one operator to get the forklift and then get the absorbent seem prudent? Should there be two people? Should they have radios? What route will they take to bring it to the site? Is it safe? These, and many other “simple” questions can waste inordinate time during and emergency and often result in less optimum decisions during these stressful situations. Plans to take equipment up on an elevator often require someone have a fire override key to limit access. Larger equipment may not fit as no one bothered to check in advance. Access to stockrooms for required supplies may be slow or limited. Everyone will want to help but without some advance planning mobilizing them to effectively assist is difficult. And some personnel may be too uncomfortable going into an emergency so you need to have alternate plans or a way to adequately address their concerns.

Failure to think about how to get supplies required for the emergency. Where do you get hand tools to try and fix a leak? Where can you obtain more absorbent for immediate delivery? Who has enough warning tape, signs, or blocking devices to cordon off the area? In a longer emergency, who will provide water and possibly food? What about rest rooms as running back into the building is all too common an approach. Do you need some contingency contracts with nearby suppliers? (Who may not be your usual ones nor the lowest cost ones.)

Failure to address emergency communication needs in advance.?Your normal radio net may be overwhelmed when both emergency responders and normal operations try to use it. Even an emergency channel may prove problematic if the response lasts for a long period or starts to involve numerous people or organizations. While cell phones have made some of this communication easier, does everyone have a list of the required phone numbers? Do they carry it with them at all times or how will you deploy the list when needed? Does the list use names and functions? How is it organized? (Trying to find?Bill, the utility supervisor, on an alphabetical list by last names can waste tremendous time.) In larger or longer emergencies this can tie up 1-3 people. Do you have spare radios if additional personnel are drawn into the response? Do you have spare units to loan to outside organizations that come on site? Do you have enough spare batteries and, often more importantly, enough charging stations to support this load, particularly longer term?

Failure to address how to support the inhouse emergency responders particularly in larger emergencies or over longer periods. In-house emergency forces often appear overly generous for the normal routine issues that arise. During larger problems or problems that last over an extended period, particularly past the normal shift, their staffing is usually found to be inadequate and can often result in the need for significant extra support. This may be to cover a wider area, provide more people to work an issue, provide replacements when responders need to rest, or a host of similar issues. How will you get these extra personnel? Do they need any advance training? Do you have a plan to provide additional trained supervision? Do you need more trained supervision because they are less experienced/trained? Do you have a viable procedure to call them in off hours? Do any of them need advance medical certification and training to use respirators or SCBA’s?

Failure to have a liaison who is trained and experienced to coordinate with any outside responders. Are they known to these outside organizations? Have they met them in advance and provided some general information to their key personnel? Too often I have seen emergency plans that assign the communications director or the head of HR to this role when the person needed is the facility manager or a process specialist. And, if this liaison is unfamiliar to the responders, their advice and consultation is often likely to be given less weight. Often, as the liaison, I have had to work to inject myself into the outside organization’s command to make sure they understand a less obvious risk or a more hazardous condition. When they knew me in advance it was always easier and much more effective.

Failure to train with the outside organizations in advance, familiarize them with you general hazards, ?and understand how they will typically respond. A meeting with the local fire chief easily resolved a contentious issue of how to respond to a fire in a larger solvent storage area when it was made plain that, if called, the fire department would simply prevent the fire spread until the fire burned out. In other cases, the outside responders asked for additional information to be available when they arrived (easily done in advance, less easily on the fly), additional on site response equipment, or suggested practical modifications to the in house plans.

My bottom line is that research emergency response plans often are inadequate and need significant additional review and revision to be effective. You will not cover every eventuality. You cannot address every unique situation. Something new and different can always arise. But good advance planning can minimize these and greatly lower your risk and improve your emergency response effectiveness.

For this and other topics on research safety concerns you may want to consider Engineered Career Solutions course on Pilot Plant and Laboratory Safety given virtually given virtually July 13-15, 2022. For more information and registration see https://ecstechtraining.com/pilot-plant-lab-safety .