Regulatory Spotlight - Emergency Preparedness
Have you heard the adage “Failure to Plan is a Plan to Fail”? No one wants to think that an emergency can happen at their site, but emergencies do happen and a failure to plan could result in harm to your workers or community. One of the issues we see regularly during inspections is a lack of preparation for emergencies and the records of those preparations. As with many regulations, there are some differences between requirements for small and large quantity generators.
SQG Requirements are listed in two parts:
Preparedness and Prevention: 40 CFR 262.16(b)(8) covers required equipment, access to communication or alarm systems, required isle space, and arrangements with local emergency response authorities.
Emergency Procedures: 40 CFR 262.16(b)(9) requires at least one employee be designated as an emergency response coordinator and that their name and contact information, along with other information, be posted in areas where waste is generated or stored. Also included in this part are the training requirements covered in our last newsletter.
The most common issues we see at SQGs are a lack of an emergency coordinator and no emergency contacts posting. Free templates for this posting can be found online.
LQG Requirements:
The Generator Improvements Rule (adopted in Montana in May 2022), consolidated emergency preparedness requirements for LQGs and compiled them in a separate section of Part 262. 40 CFR 262.17(a)(6) requires compliance with 40 CFR Part 262 Subpart M (40 CFR 262.250-265). This is a long list of requirements that we will not detail here. The most common issues seen during inspections are 1) Lack of, incomplete, or non-current contingency plan; 2) Lack of or incomplete contingency plan quick reference guide; and 3) Failure to coordinate with local response agencies.
VSQG Requirements:
There are no regulations covering emergency preparedness for very small quantity generators. However it is never a bad idea to think through what emergencies could occur and how you would respond. As with the larger generators, VSQGs are responsible for cleaning up any environmental contamination that may be caused from an accidental spill of hazardous waste.
If you have questions about emergency preparedness requirements, please contact our office.
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