From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

February 28, 2008

Contingency Plan Updates

Large Quantity Generators: When does your business need to change its contingency plan?

If the list of emergency coordinators changes. This is the most common change that occurs and the most often overlooked. If your emergency coordinator or his/her alternate leaves the position, or their contact information changes, then the contingency plan must be updated with current information.
If the list of emergency equipment changes. New, improved emergency equipment is a good thing. However, when new equipment arrives, it should be added to the contingency plan. The same goes for old equipment that is phased out. The equipment removed from service must also be removed from your contingency plan.
If the plan fails in an emergency. Contingency plans must cover fire, explosions, and the unplanned release of hazardous waste. If your business' contingency plan fails during one of these emergencies then it must be improved to address the failure.
If the regulations are revised that effect your business. For example, if laws governing hazardous waste tanks are amended and you have hazardous waste tanks, then your contingency must be updated.

Contingency plans are ONLY required for businesses that generate large quantities of hazardous waste or small quantity generators that store 1,000 kilograms of hazardous waste on site. For further information on contingency plans please see the previous contingency plan listservs below.

March 12, 2007

What is a contingency plan?
The short definition is: a plan that provides resources for problem solving if something unexpected happens.

What does a contingency plan mean to your business? It could be the difference between success and failure during an emergency situation. Large Quantity Generators are required to have a contingency plan that meets very specific requirements. These are spelled out below. Small Quantity Generators and Conditionally Exempt Small Quantity Generators are NOT required to have such a plan - but it may be helpful to review the requirements so that you can be prepared in the event of fire, flood, tornado, earthquake or other emergency. If your business is a Small Quantity Generator or a Conditionally Exempt Small Quantity Generator ask yourself "How can I improve my business' reaction to the unexpected?"

A contingency plan for a Large Quantity Generator must be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned release of hazardous waste, and must be carried out immediately when necessary. It must also be kept up to date and employees must be trained in how to implement it (for more information on training, review the January 8, 2007, listserv article, Safety and Preparedness).  A contingency plan must include:

ACTIONS that facility personnel must take in an emergency - The actions should be specific to the hazardous waste generated at your business and the characteristics of your facility and its surroundings. For instance, explain how fire will be suppressed if you have ignitable waste or the technique that will be used to cleanup a corrosive waste spill. You should also address the specific characteristics of your facility and its surroundings. For example, you may include information such as the size of your building, the presence of nearby streams, neighboring businesses, etc.

ARRANGEMENTS agreed to by local police, fire departments, hospitals, contractors, and emergency response teams to coordinate emergency services - The plan should state that the authorities have been notified of:

  • properties and hazards of the wastes generated at your business;
  • facility layout including the location of hazardous waste;
  • approximate number of employees that work in your facility and where within the building they work;
  • evacuation routes;
  • services that the authorities will provide;
  • other important site-specific information.

EMERGENCY COORDINATOR information - Names, addresses, and phone numbers (both work and home) of all persons qualified to act as your business' emergency coordinator. The list must be kept up-to-date and if more than one person is qualified to act as emergency coordinator, the list must be in the order in which they will assume responsibility as alternates.

EQUIPMENT - A complete list of all emergency equipment at your business. This must include fire-extinguishing systems, communication systems, alarm systems, spill control, and decontamination equipment. The location and a physical description of the emergency equipment and its capabilities should also be included. The physical description can include the size of the item, its intended use, and its limitations. This list must also be kept up-to-date.

EVACUATION PLAN for facility personnel - This must include signal(s) to begin the evacuation, routes, and alternate routes. A scaled site diagram would be the best way to convey this important information quickly in an emergency. The diagram can be posted on walls in work areas as well as being part of the contingency plan.

If you are a Large Quantity Generator, your contingency plan must be maintained at your facility and submitted to local authorities. You may keep a copy of the cover letter and envelope that transmitted your contingency plan to these authorities to show inspectors that you have met this requirement. It is a good idea to give each division or section manager a copy of the contingency plan so that they are aware of what is expected of them in an emergency. As always, please review the requirements for contingency plans set forth in the Code of Federal Regulations § 265.51, §265.52, and §265.53

It has been said that if you fail to plan, you can plan to fail. Just as your business needs a business plan for economic success, a contingency plan is needed for emergencies that can occur. It makes good business sense to prepare for unexpected events. Putting together an effective contingency plan can protect your employees and investments.

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If you need further assistance, please email or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

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