Emergency Procedures, Contingency Plans, and Notification

The Office of Compliance Fact Sheet Series

Preventing Accidents

If you store hazardous waste onsite, you must minimize the potential risks from fires, explosions or other accidents. Therefore, your facility must be equipped with:

An internal communications or alarm system capable of providing immediate emergency instruction to all personnel.

A device, such as a telephone or a hand-held, two way radio, capable of summoning emergency assistance from local police and fire departments or emergency response teams.

Portable fire extinguishers, fire control devices, spill control materials, and decontamination supplies.

Water at adequate volume and pressure to supply water hose streams, foam-producing equipment, automatic sprinklers, or water spray systems.

You must test and maintain all equipment to ensure proper operation. You should secure arrangements with fire departments, police, and local hospitals to provide services in the event of an emergency.

Responding to Emergencies

You must be prepared for an emergency at your facility. One way is to develop a contingency plan. The purpose of a contingency plan is to help you prepare and plan for accidents that could possibly occur at your facility. A contingency plan must be carried out immediately if there is an emergency and can be thought of as a set of answers to a series of "what if" questions. For example:

• "What if there is a fire in the area where solvents are stored?" or
• "What if I have a spill of hazardous waste or one of my containers leaks?"

You may want to make your own list of these "what if" questions and to write down specific steps that you would take if such an emergency occurred. Review these with your employees so they are also informed about their responsibilities in the event of an emergency.

Am I Required to Have a Contingency Plan?

If you are a large quantity generator (LQG), you are required to have a written contingency plan.

If you are a small quantity generator (SQG), you are required to establish basic safety guidelines and response procedures. Although a written contingency plan is not federally required for SQGs, it is strongly recommended.

If you are a conditionally exempt small quantity generator (CESQG), you are not federally required to have a contingency plan or basic contingency procedures. However, as advised for SQGs, a written contingency plan is strongly recommended.

It is also important to check with your State and local hazardous waste management agencies for any additional contingency plan or emergency preparedness requirements.

What must be Included in the Contingency Plan or Procedures?

LQG Contingency Plan Contents
If you are a large quantity generator of hazardous waste, you are required to have a written contingency plan. This contingency plan must contain:

• Instructions on what to do in the event of a fire, explosion, or release
• The arrangements agreed to by local police and fire departments, hospitals, and State and local emergency response teams to provide emergency services
• An emergency coordinator (employee) who is responsible for assessing emergency situations and making decisions to respond
• The names, addresses, and phone numbers of all persons qualified to act as emergency coordinator
• All emergency equipment at the facility
• An evacuation plan.

Copies of the contingency plan must be submitted to the local police and fire departments, hospitals, and State and local emergency response teams that may be called upon to provide emergency services. You should maintain documentation showing that local authorities have been notified.

SQG Contingency Procedures
If you are a small quantity generator of hazardous waste, you are not required to develop a written contingency plan. However, you are required to have basic safety guidelines and response to follow in the event of an emergency. These procedures are not federally required to be in writing and include the following:

• You must have an emergency coordinator (employee) either at the facility or on call who is responsible for coordinating all emergency response measures.
• You must post next to the telephone: (1) the name and number of the emergency coordinator; (2) the locations of the fire extinguishers and spill control material; and (3) the telephone number of the fire department.
• You must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures.

Additional Information

Contacts:

General Information regarding EPA
RCRA Hotline at 1-800-424-9346

Publications:

Hazardous Waste: Determining Your Generator Status Fact Sheet
Hazardous Waste: The Conditionally Exempt Small Quantity Generator Fact Sheet
Hazardous Waste: The Small Quantity Generator Fact Sheet
Hazardous Waste: The Large Quantity Generator Fact Sheet
Understanding the Hazardous Waste Rules: A Handbook for Small Businesses - 1996 Update, EPA530-K-95-001, June 1996