In this chapter we will explore the process of reporting a spill.
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Chapter 3 – Initial Responders & External Resources
We have already discussed how important it is that a company has a team and procedures or Emergency Response Plans (ERPs) in place. There is usually a main supervisor/manager and assisting coordinators delegated.
Incident Command System (ICS)
ICS is designed to allocate accountability, chain of command and systematic procedures that can be evaluated and improved upon as operations evolve. The concept was initially formed in 1968 in the US, after millions of dollars of damage occurred and many people were both injured and killed in fires.
Studies determine that response problems are often related to deficiencies in management preparedness and communication rather than lack of resources or tactics.
- An employee can decide if the spill is low risk and manageable, or high risk and needs specialized assistance.
- The responder can utilize resources to contain and clean up a spill or make the authorizing decision to bring in third-party assistance.
- The manager or supervisor assists by dealing with the spill and/or reporting. Managers are concerned about safety, especially in a case of evacuation and personnel security.
- A coordinator‘s responsibility is to provide prevention techniques including corrective actions or mitigation procedures that can reduce or eliminate the probability that the event will occur again (i.e. ordering/restocking spill response supplies changing processes/procedures or providing additional specialized training). They also collect information to properly report the occurrence and follow up, if necessary, with regulating agencies.
Remember: Safety Is A Key Priority
Proper procedures, training and resources keep workers, public and the environment safe.
Annual review and practice provide due diligence and regular maintenance to the Emergency Response Plan, which reduces risk and expenses.
Responders have the right to refuse unsafe work and should bring in specialized personnel and resources to mitigate the risk.
How, When, What & Who to Report
Reporting is imperative to evaluation of both responses and opportunities for improvements. Government agencies and other stakeholder organizations are formed to assist and regulate the safety and effectiveness of emergency responses.
For example, some upstream petroleum industries (working with hydrocarbons that are unrefined) have their own regulating agencies called Energy Regulator’s. In addition, they have their own spill cooperative’s who have collaborated in supplying spill kits and other helpful equipment along hydrocarbon-containing pipelines and facilities.
Hydrocarbons are commonly found in workplaces due to the fact that most engines are fuel-based rather than electrical. These types of hydrocarbon fuels are refined (downstream) and are commonly regulated by other non-energy provincial agencies.
Substances that are not regulated by the Oil and Gas Conservation Act, the Dangerous Good Transportation and Handling Act or special approvals, licenses or permits granted under those acts, may report under other federal, provincial or territorial regulations such as the Environmental Protection and Enhancement Act (EPEA) and the Water Act.
Certain observed substance spills and release events create an immediate obligation to report the releases. Regulatory concerns are applicable when the released substances have the potential to impair or damage human health, the environment, safety or property.
In high risk release of substances situations, qualified professionals need to implement Environmental Site Assessments (ESAs). These assessments can be done for both new and fresh spills or are done on historical sites that have contaminants of potential concern (CoPC). In either case, an ESA facilitates in determining if the spill has potential adverse effects and what mitigating measures need to be implemented. These reports may require a Professional Declaration with an environmental professional’s signature and stamp/seal or professional registration number.
Who To Call
Any spill, release or emergency that may cause, is causing, or has caused an adverse effect to the environment should be reported immediately to the appropriate 24-hour Environmental Hotline. Affected third parties must be notified that property is potentially impacted. The Transportation of Dangerous Goods Regulation indicates in their regulations that Class 3 substances (flammable liquid such as fuel) needs to be reported when any quantity of gasoline or 30 L or 30 kg of diesel is released. A release also needs to be reported if there is an adverse effect potentially about to occur or is currently occurring.
Keep It Out Of Water!
The release is reportable if:
- The amount is at or in excess of the quantity or emission levels set out in the Table in the section 1(1) of Part 8 of the Transportation of Dangerous Goods Regulations or
- The substance is released into a watercourse or into groundwater or surface water.
- It is important to note that ANY release into most waterways needs to be reported – regardless of the volume.
The report usually is a phone call into the 24-hour hotline number – however, some locations allow electronic reporting. A reference number will be issued to confirm that the report was made.
Who Should Call?
The person who releases a substance or the person having control of the substance should report.
By participating in this course, you should be inquiring on who your commanding manager is so that the proper report can be issued and followed up on to assist in developing preventative measures.
Anyone involved in a release can assist by documenting the time, location, description of circumstances, quantities and any other details describing actions and surrounding areas.
As mentioned, reporting depends on what, where and how the material has been released. You may have to report to multiple stakeholders such as municipal, provincial or federal regulators.
The 24-hour Transportation of Dangerous Goods (TDG): 1-800-272-9600 or *666 from you cell phone
PROVINCIAL EMERGENCY CONTACT INFORMATION
NOTE: numbers from https://www.canada.ca/en/environment-climate-change/services/environmental-emergencies-program/report-emergency.html
Gather Report Information
The report usually is a phone call into the 24-hour hotline and then at the Director’s (person on the other end of the phone or person delegated by the person on the other end of the phone) discretion will request a follow-up repertory.
A written report must include the following:
- the date and time of the release
- the location of the point of the release
- the duration of the release and the release rate
- the composition of the release showing with respect to each substance
- its concentration and
- the total weight, quantity or amount released
- a detailed description of the circumstances leading up to the release
- the steps or procedures which were taken to minimize, control or stop the release
- the steps or procedures which will be taken to prevent similar releases
- any other information required by the Director