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It is the policy of Stanford University to establish and
maintain emergency response procedures and capabilities to:
- respond to incidents involving hazardous materials;
- assist the Fire Department with hazardous materials expertise;
- clean up modest hazardous materials releases;
- maintain records of all hazardous materials releases and accidents;
- report incidents to outside agencies as required;
- review causes of incidents to reduce recurrence; and,
- review responses to incidents in order to improve service.
This policy and associated procedures are intended to provide
tiered response to incidents involving hazardous materials appropriate
to their magnitude and risk. If the appraisal of magnitude and risk is
uncertain, should be taken that these procedures are followed explicitly
and consistently and that the reporting party provides accurate and complete
information to the responding entity. The purpose of this statement is
to set forth procedures to be followed in the event of an emergency involving
the accidental release of hazardous materials, in order to:
- protect research personnel, the general public, and the environment;
- protect property and research assets;
- comply with the regulatory response reporting, recording and abatement
requirements;
- encourage safe practices and requests for assistance when personnel
are in doubt about hazardous materials; and
- standardize response procedures throughout the University.
Refer to Section II A) "Definitions" for a summary
of required responses and actions.
Conditions and releases involving asbestos are excluded
from this policy (call 3-8143 for attention to asbestos-related concerns).
B) RESPONSIBILITIES
The Environmental Health and Safety Office (EH&S) is
responsible for:
1. maintaining a trained emergency response team and equipment capable
of addressing modest Hazardous Material Releases;
2. maintaining working knowledge of applicable laws and regulations;
3. maintaining records of Hazardous Material Releases and incidents;
4. informing the campus community of the Emergency and Hazardous Material
Release Response Policy.
5. maintaining collaborative relationships with the Medical Center Office
of Environmental Health and Safety.
Department Chairs, Principal Investigators, and Supervisors
are responsible for:
1. ensuring the safety of those working under their direction;
2. assisting the EH&S Emergency Response Team or Palo Alto Fire Department
in any hazard evaluation in areas under their direction;
3. training those under their direction in correct emergency response
procedures;
4. ensuring that emergency response procedures are posted conspicuously
in each work area.
Faculty, Students, Staff and Visitors are responsible for:
1. following sound health and safety practices;
2. reporting any emergency or hazardous situation immediately according
to these procedures;
3. cooperating and assisting with any emergency response personnel;
4. complying with all applicable University policies and practices.
EMERGENCY
An unforeseen event that calls for immediate action to protect individuals,
the environment, or property.
NON-EMERGENCY RELEASE
A spill that is not the result of a container failure and the quantity
of which is less than one ounce (30 ml) and can be cleaned up within
15 minutes. (Non-emergency releases do not require recording or reporting,
but must be cleaned up immediately. If assistance is required, contact
EH&S at 3-0448.)
HEALTH THREATENING
An emergency in which there is a clear potential for serious injury
to a person or release of contaminants to the environment if immediate
action is not taken. (If in doubt, consider the emergency health-threatening.)
NON-HEALTH THREATENING
Any emergency in which there is not a clear potential for serious injury
to any person. (If unsure whether an emergency is health-threatening
or non health-threatening, assume it is health-threatening.)
HAZARDOUS MATERIALS RELEASE
A Health Threatening or Non-Health Threatening spill, unauthorized or
unexpected release of a hazardous material from primary containment,
as defined in any of the referenced laws or regulations. If Health Threatening,
the EH&S Emergency Response Team (ERT) will assist the Palo Alto
Fire Department or other responding agency in cleanup and report of
incident to Santa Clara County. If Non-Health Threatening, Health and
Safety will call the Medical Center Emergency Page Operator (MCEPO)
at 286 if assistance is needed. Conditions and releases involving asbestos
are excluded from this policy (call 3-8143 for attention to asbestos-related
concerns). CONTAINED Indicates a Hazardous Material Release that is
within secondary containment, i.e. a floor, tray or engineered containment
system. (The ERT will clean up and record the release.)
RELEASED TO THE ENVIRONMENT
Indicates a Hazardous Material Release that is discharged to the surface,
soil sewer, surface water or air outside of a building at a hazardous
level as defined by applicable regulations. This also refers to a Contained
Hazardous Material Release that takes more than eight hours to clean
up as is specified in the Santa Clara County Hazardous Materials Storage
Permit Ordinance. (The ERT will call Central Communications at 9-911
and proceed to clean up the release obtaining assistance as necessary
and reporting to regulatory and other cognizant agencies as required).
These procedures are intended to provide tiered response
to incidents involving hazardous materials appropriate to their magnitude
and risk. The evaluation of the hazard of what to report or record, and
of how to respond will be made by the Health and Safety Emergency Response
Team (ERT) Command Staff in consultation with the Principal Investigator
(PI) (or other knowledgeable or responsible parties and the Palo Alto
Fire Department (PAFD) when they are involved).
In the event that there is no time for a full hazard evaluation,
or there are many chemical or other complexities involved, or there is
insufficient information available about the materials or situation involved,
then precautions based on the worst case scenario for the incident will
be applied to the response to protect the ERT, the public and the environment.
These precautions will be taken by the ERT and any other agency responding
to a call for assistance.
Extreme care should be taken that these procedures are followed
explicitly and consistently and the reporting party should provide accurate
and complete information to the responding entity.
ACTIVATING PROCEDURE FOR EMERGENCY RELEASE
EXTREMELY IMPORTANT: FOLLOW THESE STEPS EXPLICITLY
In all cases when any person becomes aware of an emergency,
regardless of its location:
- If Health Threatening, call 286 and/or pull the
nearest fire alarm.
- If Non-Health Threatening, call EH&S at 3-0448 (in patient care
areas, call 3-8143).
- If involving radiation or radioactive material, call Health Physics
at 3-3201.
- If the reporting party is unclear of the Health Threatening nature of
the emergency, assume it is health-threatening and proceed accordingly.
- If the release is in a laboratory, in addition notify the Principal
Investigator responsible for that area as soon as it is practical to do
so. If the Principal Investigator is unknown or unavailable then notify
the Department Administrator, Safety Committee Chairperson, or Department
Chairperson. When possible, leave appropriate messages in each case. (The
work and home phone numbers of these people should be posted near every
room containing hazardous material.)
When 286 (Medical Center Emergency Page Operators) receives
a report of an emergency involving hazardous materials during working
hours, they will notify EH&S and the Medical Center Emergency Response
Team immediately. During non-working hours, 286 will contact University
Operations and Maintenance (O&M) who in turn will call the University
ERT directly. In the event of an emergency involving radiation or radioactive
materials, 286 will notify the Health Physics Office at 3-3201.
1) DURING WORKING HOURS:
When EH&S receives a call from the reporting party or MCEPO at
286 the following will occur:
a) The report receiver will acquire all pertinent information
regarding the emergency (time, date, nature and location of the incident,
name and phone number of reporting party and type and quantity of hazardous
materials involved) and record that on a Request and Response (R&R)
form. If the incident is in a laboratory, obtain if possible, the name
and phone number of the PI and determine if the PI has been contacted
and record this on the R&R form. If the PI has not been contacted
the reporting party should be told to contact the PI immediately.
b) The R&R form will be given to a designated ERT Leader who will
establish the Incident Command System (ICS) to the extent necessary
to respond to the incident.
c) The ERT is in command of the affected area until further notice or
command is transferred to the PAFD.
d) The ERT will consist of a Team Leader, an Operations Staff and a
Command Staff. The Command Staff will include at minimum a Safety Officer
and if needed a Public Information Officer. The Team Leader may function
in any or all of these roles.
e) The ERT Leader will contact the reporting party to gather more information
about the incident, if necessary.
f) The ERT Leader will see that the PI (or other responsible party in
the order previously stated if PI is not available) has been called.
g) The ERT Leader will call for assistance such as the PAFD or cleanup
contractor if the release is either Health Threatening or Released to
the Environment or is otherwise necessary.
h) If the PAFD is called to the scene, Command will be transferred to
the PAFD by the ERT Leader.
i) The ERT will respond to the site of the incident.
j) The ERT Leader, in consultation with the Operations Staff, Command
Staff, the PI or other responsible party, and others if needed, should
establish the response strategy (compliant with all requirements of
the OSHA regulations in 29 CFR part 1910.120 and the SCCHMSO and other
relevant laws and regulations).
k) The Operations Staff will then initiate the response strategy to
abate the hazard accordingly.
2) DURING NON-WORKING HOURS:
When a reporting party calls 286 the following will occur:
a) The dispatcher for Medical Center Emergency Page Operator
will acquire all pertinent information regarding the emergency (time,
date, nature and location of incident, name and phone number of reporting
party, and type and quantity of hazardous materials involved) and record
that information.
b) 286 will then request dispatch of SUMC Emergency Response Team, fire,
police and ambulance service as appropriate.
c) If 286 requests dispatch of the PAFD, the PAFD is in command until
further notice or command is transferred to the ERT.
d) 286 will request dispatch of members of EH&S ERT.
e) Pertinent information will be given to the ERT Member.
f) The first designated ERT Leader contacted will establish the Incident
Command System (ICS) to the extent necessary to respond to the incident.
g) ERT will consist of an ERT Leader, an Operations Staff and a Command
Staff. The Command Staff will include at minimum a Safety Officer and
if needed a Liaison Officer and a Public Information Officer. The Team
Leader may function in any or all of these roles.
h) The ERT Leader will contact the reporting party to gather more information
about the incident, if necessary.
i) The ERT Leader will call for assistance such as the PAFD or cleanup
contractor if the release is either Health Threatening or Released to
the Environment or if otherwise necessary.
j) If the PAFD is called to the scene, Command will be transferred to
the PAFD by the ERT Leader.
k) The ERT Leader will see that the PI or other responsible department
member has been called.
l) The ERT will respond to the ESF to pick up the ER vehicle.
m) At ESF the Team Leader will begin an R&R form on the incident.
n) The ERT will then respond to the site of the incident.
o) The ERT Leader, in consultation with the Operations Staff, Command
Staff, the PI or other responsible party, and others if needed, will
establish a response strategy that complies with all requirements of
the OSHA regulations in 29 CFR part 1910.120 and the Santa Clara County
Hazardous Material Storage Ordinance (SCCHMSO) and other relevant laws
and regulations.
p) The Operations Staff will then initiate the response strategy to
abate the hazard accordingly.
3) For a Non-Health Threatening, Contained incident (the PAFD or other
agencies are not present) the following procedures apply:
a) On arrival at the site the ER Team will conduct an initial
hazard evaluation of the incident.
b) If the ERT Leader determines that the incident is either Health Threatening
or Released to the Environment, then the ERT will call for additional
assistance from the PAFD and transfer Command to the PAFD at that time.
If time permits this should be done after consulting with the PI or
other responsible party and the Director, Associate Director, Fire Marshall,
or other designated Command Staff members of the Health and Safety ERT.
c) A full hazard evaluation should then be conducted if time permits.
d) Under the command of the PAFD, the ERT Leader, in consultation with
the Operations Staff, Command Staff, the PI or other respon-sible party,
and others if needed, will establish the response strategy complying
with all requirements of the OSHA regula-tions in 29 CFR part 1910.120
and the Santa Clara County Hazardous Material Storage Ordinance (SCCHMSO)
and other relevant laws and regulations.
e) The Operations Staff will then initiate the response strategy to
abate the hazard accordingly.
4) Whenever the PAFD or Police arrive, they designate an Incident Commander
and establish their own ICS. The ERT Leader will then render any assistance
that the Incident Commander may need.
5) All Emergency Hazardous Material Releases will be reported to EH&S
and recorded on an R&R. All spills due to container failure must be
reported to EH&S. Non-container spills greater than one ounce (30
ml) that can not be cleaned up within 15 minutes must also be reported
to EH&S. For any Health Threatening Hazardous Material Release to
the Environment, Central Communications will be notified immediately to
assist in the response and the Santa Clara County Health Department will
also be notified immediately at (408) 299-6930.
Santa Clara County Hazardous Material Storage Ordinance
(SCCHMSO) (SCC Ord. NS517.31 Sec. B11-306.01):
Specifies Hazardous Materials release recording
and reporting requirements and that an emergency and spill response plan
be developed and implemented.
Chapter 6.6 of the Health and Safety Code
(Safe Drinking Water and Toxic Enforcement Act):
Contains requirements for the reporting of hazardous
materials releases. They do not apply, however, until a particular chemical
has been listed by the Governor for more than 12 months. Even then the
requirements will only apply to those chemicals that are listed.
Chapter 6.95 of the Health and Safety Code (H&SC)
(Hazardous Material Release Response Plans and Inventories,
H&SC sec. 25359.4):
Refer to spill reporting requirements. Title 19
California Administrative Code Sections 2701 et sec.
California Occupational Safety and Health Administration
regulations:
Require reporting industrial injury as defined
on OSHA form 5020.
Cal/OSHA (Hazardous Materials Information and Training
Act):
See OSHA 29 CFR.
Superfund Amendments and Reauthorization Act of Environmental
Protection Agency (EPA) part 1910.1200 Title III CERCLA Amendments:
Community right to know, reporting and cleanup
of releases to the environment.
Resource Conservation and Recovery Act of Environmental
Protection Agency (EPA):
Defines illegal disposal
OSHA 29 CFR part 1910.120:
Regulates emergency response teams.
Proposed OSHA 29 CFR 1910.1450:
Regulates emergency response teams.
OSHA 29 CFR 1910.1200:
Hazard Communications Standard, emergency information
and training.
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