| In an emergency | Call 911 for fire, injury or a release the ERT cannot control. Call the Building B control room: ext. 0, or (555) 555-0110. Radio Channel 1. After 11:00 p.m. and on weekends: Gate 2 security, ext. 2, or (555) 555-0112. |
SECTION 1Purpose, Scope and Relationship to Other Plans
29 CFR 1910.120(q)(1)
1.1 Purpose
This is the emergency response plan for Perry's Awesomeness Factory, Building B, required by 29 CFR 1910.120(q)(1). It sets out how the Building B Emergency Response Team (ERT) responds to releases, or substantial threats of releases, of hazardous substances on the Perry Industries campus at 1 Perry Parkway, New Mos Eisley. The plan is in place before any emergency response operation begins.
1.2 Scope
This plan applies to every response by the Building B ERT: in Building B, the flammable tank farm, the ammonia storage area, both tank truck unloading pads, the R-101 room, the Awesomeness and Brilliance lines, packaging, shipping, the 90-day hazardous waste area (HWA), Lab/QC, the transformers and GEN-1; and in Building A and Building C when the control room calls the ERT (Campus Emergency Action Plan, Section 3.5 for Building C).
Releases that employees in the immediate area can absorb, neutralize or otherwise control at the time of release are incidental releases. They are handled under Campus Emergency Action Plan Section 13 and are not emergency response under this plan. Employees who are not ERT members do not take part in emergency response. They report the release, get away from it and keep others out, and evacuate or shelter as the Campus Emergency Action Plan directs.
1.3 Regulatory Basis
Building B employees respond to releases, so Perry Industries keeps this written plan under 29 CFR 1910.120(q) rather than relying on evacuation alone (1910.120(q)(1)). This plan is also the written emergency response plan for the Polyjuice Base process under 40 CFR 68.95 (RMP-PJB-001, Section 7.2), and the LQG Contingency Plan counts the emergency response training given under this plan for ERT members (40 CFR 262.17(a)(7)(i)(D)).
1.4 Relationship to Other Plans
1910.120(q)(2) requires the elements of this plan to the extent they are not addressed elsewhere. The plans below address some of them; this plan refers to them rather than repeating them.
| Plan | What it covers that this plan uses | Owner |
|---|---|---|
| Campus Emergency Action Plan (29 CFR 1910.38) | Reporting, employee alarm signals, evacuation routes and maps, assembly areas, shelter in place, critical operations shutdown, accounting for employees, first aid responders, outside agency notifications (Section 3.6), small releases (Section 13). | Dana Scully, EHS Manager |
| Risk Management Program, Polyjuice Base, RMP-PJB-001 (40 CFR 68) | Emergency response program for T-2 (68.95), coordination with local responders (68.93), exercises (68.96). This plan is the written plan Section 7.2 of that program refers to. | Dana Scully; Steve Resko for Subpart E |
| Process Safety Management Program, Thunderbolt Solvent System, PSM-TSS-001 (29 CFR 1910.119) | ESD-101, operating limits, safe hold, hot work, contractor controls, small Thunderbolt releases (Section 15). | Doug Heasley, PSM Coordinator |
| LQG Contingency Plan, Building B (40 CFR 262 Subpart M) | Hazardous waste emergencies, Emergency Coordinator checklist (262.265), emergency equipment list (Section 8). | Dana Scully, EHS Manager |
| SPCC Plan, Building B (40 CFR 112) | Oil discharges from Building B containers. | Dana Scully, EHS Manager |
| SPCC Plan, Building C, Tier I, self-certified January 12, 2026 (40 CFR 112) | Oil discharges at the Building C fueling area. | Ellen Ripley, Fleet and Fueling Supervisor |
| Chemical Hygiene Plan, Building A (29 CFR 1910.1450) | Laboratory chemical safety in Building A. | Arthur Dent, Chemical Hygiene Officer |
Table 1-1. Related plans.
1.5 Availability of the Plan
This plan is in writing and is available for inspection and copying by employees, their representatives and OSHA personnel (1910.120(q)(1)). Controlled copies are kept at the locations on the Distribution page. An electronic copy is on the plant document system.
SECTION 2Hazardous Substances and Emergency Recognition
1910.120(q)(2)(iii)
2.1 Materials the ERT May Respond To
Exposure limits and transport guide numbers are taken from the safety data sheets in the SDS binders (Building B control room and HWA entrance, Building A lab office, Building C dispatch office) and on the plant document system.
| Material | Where; largest quantity | Main hazards | OSHA PEL; NIOSH IDLH | ERG guide |
|---|---|---|---|---|
| Thunderbolt (isopropyl alcohol, ≥99.5%), UN1219 | T-1, 12,000 gal, flammable tank farm. R-101, normal 2,000-gal charge at reflux (about 180 °F). V-102, 500 gal. Tank truck at the flammable/oil unloading pad (compartments up to 3,000 gal). | Flammable liquid, flash point 53 °F (12 °C). Vapor heavier than air (2.1); LEL 2.0%. Flame nearly invisible in daylight. | PEL 400 ppm; IDLH 2,000 ppm | 129 |
| Polyjuice Base (ammonia solution, 25%), UN2672 | T-2, 15,000 gal, ammonia storage area. P-201 and piping to the Brilliance line. Tank truck at the ammonia unloading pad. | Causes severe skin burns and eye damage. Ammonia vapor is toxic and irritating; it is flammable in air between 15% and 28%. | Ammonia: PEL 50 ppm; IDLH 300 ppm | 154 |
| Sodium hydroxide solution, 50%, UN1824 | Up to four 275-gal totes, Awesomeness line. | Causes severe skin burns and eye damage; corrosive to metals. Not flammable. No odor. | PEL 2 mg/m³; IDLH 10 mg/m³ | 154 |
| Awesomeness, UN2920 | Blend tanks BT-1 to BT-3 (1,200-gal batches). 55-gal drums in packaging, shipping and Building C. | Flammable liquid, flash point 97 °F (36 °C); corrosive, pH about 14. Releases hydrogen on contact with aluminum or zinc. | Isopropyl alcohol: PEL 400 ppm; IDLH 2,000 ppm | 132 |
| Brilliance | BR-1 to BR-3 and line piping. Drums in packaging, shipping and Building C. | Corrosive to skin and eyes, pH 11.6. Slippery. Gives off a toxic gas if mixed with bleach. Not regulated for transport. | Mineral oil mist: PEL 5 mg/m³; IDLH 2,500 mg/m³ | — |
| Hazardous waste: D001 spent Thunderbolt and still bottoms; D002 caustic washwater | HWA: up to 40 55-gal D001 drums; TK-HW1, 2,500 gal D002. | As for Thunderbolt and sodium hydroxide. See LQG Contingency Plan. | See the materials above | — |
| Oils: white mineral oil, diesel, transformer oil | T-3, 5,000 gal; T-4, 6,000 gal (GEN-1); TX-1 and TX-2, 200 gal each; Building C D-1 and D-2, 5,000 gal each. | Combustible. A sheen on Lake Tiberius through the storm inlets and Outfall 001. | — | See SPCC Plans |
| Hydrogen Peroxide 35%, UN2014 | Building A formulation lab, oxidizer cabinet OX-1, up to four 1-gal vented containers. | Oxidizer; causes serious eye damage. Do not absorb with combustible material. | PEL 1 ppm; IDLH 75 ppm | 140 |
Table 2-1. Hazardous substances on campus.
2.2 How Releases Are Recognized
- Ammonia detectors AD-1 to AD-4 around T-2: alarm at 25 ppm, high alarm at 50 ppm, in the control room.
- LEL detectors LD-1 to LD-3 in the R-101 room: alarm at 10% LEL; high alarm at 25% LEL trips ESD-101.
- Tank alarms: T-2 high-level alarm LAH-201; T-4 interstitial monitor; Building C D-1 and D-2 high-level alarms and interstitial monitors.
- Operator rounds. The weekend and overnight operator records T-1, T-2, T-3 and T-4 levels and the detector readings on each round.
- Attended tank truck deliveries, received on day shift Monday to Friday only.
- Employee reports under Campus Emergency Action Plan Section 3, and Building C reports under Section 3.5.
- What people notice: liquid on the floor or ground, a sharp ammonia odor (ammonia odor threshold, mean 17 ppm), an alcohol odor, a sheen at a storm inlet or at Outfall 001.
2.3 Prevention
Releases are prevented under the PSM program (operating procedures, mechanical integrity, ESD-101 and safe hold of R-101 at the end of each night shift and before weekends), the RMP prevention program for T-2, both SPCC Plans, and LQG Contingency Plan Section 3. The ERT inspects its equipment monthly and after each use (Section 10.4) so it is ready when a release occurs.
SECTION 3Roles, Lines of Authority and Communication
1910.120(q)(2)(ii), (q)(3)
3.1 Lines of Authority
- The Emergency Coordinator (EC) on duty is the individual in charge of the site-specific Incident Command System (ICS) from the time the ERT is called until NMEFD arrives (1910.120(q)(3)(i)). The EC order is: Steve Resko (primary, days); Marty McFly (nights, 2:30 to 11:00 p.m.; first call after 11:00 p.m. and on weekends); Jenn Resko; Montgomery Scott. The same people are the Emergency Coordinators under the Campus Emergency Action Plan and the LQG Contingency Plan.
- Until the EC reaches the scene, the ERT Leader on shift (Steve Resko on days, Marty McFly on nights), or the senior ERT member on scene, is in charge.
- When NMEFD arrives, the senior NMEFD officer becomes the individual in charge, and command passes up NMEFD's line of authority. The Perry EC stays at the command post as the senior official present for Perry Industries and directs Perry employees through the NMEFD incident commander.
- All responders and their communications are coordinated and controlled through the individual in charge. No one enters a release area unless the individual in charge has assigned them to.
The command post is at AA-2 "Shire" (Gate 2 visitor lot) unless it is downwind of the release, in which case it moves to AA-1 "Rivendell" (Gate 1 lot). Gate 2 security directs NMEFD to the command post.
3.2 Response Roles
The individual in charge assigns these roles on the scene. They are roles, not job titles. One person may hold more than one role when few responders are available, but the safety official is never the individual in charge, and entry team members hold no other role while they are in the hot zone.
| Role | Who | Duties |
|---|---|---|
| Individual in charge (incident commander) | EC on duty; then the senior NMEFD officer | Identifies the hazardous substances and conditions; decides on the response; approves the entry plan and the PPE; limits the people in the hot zone; decides respiratory protection from air monitoring; names the safety official; implements decontamination after operations end (1910.120(q)(3)(ii)–(ix)). Orders shelter in place, evacuation and the all-clear through the control room. |
| Safety official | Named by the individual in charge from ERT members not on the entry team; Dana Scully when she is on site | Identifies and evaluates hazards and directs the safety of operations. Checks PPE, air monitoring, time in suit and the condition of the entry team. Has the authority to alter, suspend or terminate any activity judged to be IDLH or an imminent danger, and tells the individual in charge at once (1910.120(q)(3)(vii)–(viii)). |
| Entry team leader | ERT Leader on shift, or the senior ERT member | Briefs and leads the entry team and carries out the entry plan. |
| Entry team | At least two ERT members (buddy system) | Approach the point of release to stop, plug, patch or contain it. |
| Backup team | At least two ERT members, dressed to the same level as the entry team | Stand by with equipment, ready to assist or rescue the entry team (1910.120(q)(3)(vi)). |
| Decontamination | ERT members not entering | Set up and run the decontamination line before entry (Section 11). |
| First aid support | Kaitlyn Perry, RN, when on site; first aid, CPR and AED responders (Campus Emergency Action Plan Appendix C); EMS through 911 | Stand by with medical equipment and transportation (Section 12). |
| Equipment and utilities | Montgomery Scott, or the maintenance technician on shift | Utility shutoffs on the EC's direction, spare SCBA cylinders and the cascade fill at the Gate 2 house, resupply from Sheaves Environmental Response. |
| Records and notifications | Dana Scully; the EC on duty when she is not on site | Keeps the response log. Makes the outside agency notifications (Section 5.8). |
| Control room operator on shift | Qualified operator | Sounds the employee signals, calls 911, pages the ERT and EC, trips ESD-101 and closes XV-201 and stops P-201 as needed, reads the fixed detectors, relays messages. |
| Gate 2 security | Security officer on duty | Meets and directs NMEFD and EMS, stops inbound traffic, brings sign-in sheets to AA-2, makes the after-hours call-out. |
| Specialist employees (1910.120(q)(5)) | Doug Heasley (Thunderbolt and the R-101 process); Jenn Resko (Polyjuice Base and the Brilliance line) | Give technical advice to the individual in charge at the command post. They do not enter the hot zone. |
| Public and media | Brian Phillips, VP Sales and Marketing | Only spokesperson for media and public inquiries. |
Table 3-1. Response roles.
3.3 Who Is Available, by Shift
| Shift | ERT members on site | Emergency Coordinator |
|---|---|---|
| Shift A, days, Monday–Friday, 6:00 a.m.–2:30 p.m. | 6: Steve Resko (ERT Leader), Kara Thrace, Montgomery Scott, Leia Skywalker, Zoe Washburne, Rick Deckard | Steve Resko on site; Jenn Resko and Montgomery Scott also on site |
| Shift B, nights, Monday–Friday, 2:30 p.m.–11:00 p.m. | 5: Marty McFly (night ERT lead), Ender Wiggin, River Tam, Samwise Gamgee, Trinity Anderson | Marty McFly on site |
| On call, all shifts | Dana Scully, EHS Manager (ERT member) | Notified by the EC on every callout |
| After 11:00 p.m. and weekends | None on site. The on-call EC calls back the ERT; ERT on site within 30 minutes. NMEFD responds until the ERT arrives. | Gate 2 security calls, in order, until one answers: Marty McFly, Steve Resko, Jenn Resko, Montgomery Scott |
Table 3-2. ERT and EC coverage. The full shift rosters are in Campus Emergency Action Plan Appendix E.
Building C is open from 5:00 a.m. to 3:30 p.m., Monday to Saturday. From 5:00 to 6:00 a.m. on weekdays and all day Saturday, no ERT member is on shift, and the on-call EC calls back the ERT (Campus Emergency Action Plan Section 3.5).
3.4 Communication
- Plant radio Channel 1 is the emergency channel. During a response it carries response traffic only. Two spare Channel 1 radios are kept in the ERT room.
- Building B control room: ext. 0, outside line (555) 555-0110. Gate 2 security: ext. 2, outside line (555) 555-0112, 24 hours.
- Each entry team has a radio and stays in contact with the entry team leader. Hand signals for the entry are agreed at the pre-entry briefing. If radio contact is lost, the entry team leaves the hot zone by the planned route.
- Orders and readings are repeated back by the person receiving them.
- Emergency withdrawal: the individual in charge or the safety official calls "Emergency, all teams out" on Channel 1, three times. Every entry team leaves the hot zone at once through decontamination.
| Name | Role in this plan | Phone |
|---|---|---|
| Steve Resko | ERT Leader; primary EC; plan owner | (555) 555-0101 |
| Marty McFly | Night ERT lead; alternate EC 1 | (555) 555-0105 |
| Jenn Resko | Alternate EC 2; specialist employee (Polyjuice Base) | (555) 555-0102 |
| Montgomery Scott | Alternate EC 3; ERT member; equipment and utilities | (555) 555-0103 |
| Dana Scully | EHS Manager; ERT member on call; notifications | (555) 555-0104 |
| Doug Heasley | Specialist employee (Thunderbolt) | (555) 555-0106 |
| Kara Thrace | Lead Operator, Thunderbolt Solvent System; ERT member | (555) 555-0109 |
| Hari Seldon | Plant Manager, Building B | (555) 555-0107 |
| Kaitlyn Perry, RN | Occupational Health Nurse; first aid; medical surveillance and fit testing | (555) 555-0143 |
| Wendy Weaver | Director of Human Resources; training and medical records | (555) 555-0142 |
| Brian Phillips | VP Sales and Marketing; media | (555) 555-0144 |
| Mike Perry | Founder and Chief Awesomeness Officer; commits resources | (440) 336-0262 |
Table 3-3. Contacts.
SECTION 4Pre-Emergency Planning and Coordination with Outside Parties
1910.120(q)(2)(i), (q)(2)(xii)
4.1 Outside Parties
| Organization | Role and arrangement | Phone |
|---|---|---|
| New Mos Eisley Fire Department (NMEFD), Station 7 | Fire, rescue, EMS and the hazmat team (Level A entries), about 2 miles away. Coordination at least once a year (RMP-PJB-001, 68.93); most recent March 2026, a tour of the ammonia storage area and ammonia unloading pad. NMEFD has toured the R-101 room and the flammable tank farm and has the Thunderbolt SDS. | 911; non-emergency (555) 555-0180 |
| New Mos Eisley Police Department | Traffic control on Perry Parkway; neighborhood evacuation with NMEFD. | 911; non-emergency (555) 555-0182 |
| Tiberius Regional Medical Center | Emergency department. Has the Polyjuice Base SDS. | 911; (555) 555-0183 |
| New Mos Eisley LEPC | Community emergency response plan; EPCRA 304 notices. | (555) 555-0185 |
| State Emergency Response Commission (SERC) | EPCRA 304 notices. | (555) 555-0195 |
| National Response Center | CERCLA and oil discharge reports. | 1-800-424-8802 |
| State environmental spill line | State spill reports. | (555) 555-0190 |
| Sheaves Environmental Response (Mike Sheaves) | 24-hour cleanup, containment, waste removal and emergency equipment; on site within 2 hours of a call. | (555) 555-0177 |
| Kaer Morhen Chemical Supply Co. (Thunderbolt) | Product technical advice, 24 hours. | (555) 555-0188 |
| Tyrell Chemical Distributors (Polyjuice Base) | Product technical advice, 24 hours. | (555) 555-0189 |
| Cyberdyne Caustics, Inc. (sodium hydroxide) | Product technical advice, 24 hours. | (555) 555-0194 |
| Weyland-Yutani Specialty Chemicals (Hydrogen Peroxide 35%) | Product technical advice, 24 hours. | (555) 555-0197 |
| Kessel Run Alarm Monitoring | Monitors the building fire alarm panels and calls NMEFD on any fire alarm. | (555) 555-0186 |
| New Mos Eisley Gas & Electric | Gas and electric shutoff at the street. | (555) 555-0187 |
Table 4-1. Outside parties.
4.2 Community Emergency Response Plan
This plan is coordinated with the New Mos Eisley community emergency response plan prepared under EPCRA section 303. Perry Industries gives the LEPC and NMEFD this plan, the Campus Emergency Action Plan and updated contacts, and gives other information on request. NMEFD runs the community notification system (reverse-call and sirens) for the neighborhood north of Perry Parkway; the EC asks NMEFD to activate it for any release that reaches, or may reach, the fenceline (RMP-PJB-001, Section 7.2).
4.3 Information Kept at the Command Post
- This plan, the Campus Emergency Action Plan, the LQG Contingency Plan, both SPCC Plans and RMP-PJB-001.
- Drawings PI-C-001 (campus), PI-B-101 (Building B), PI-C-201 (Building C) and PI-A-101 (Building A).
- The SDS for each material in Table 2-1.
- The current Emergency Response Guidebook.
- Shift rosters and the visitor and contractor sign-in sheets (brought by Gate 2 security).
4.4 Drills and Exercises
| Drill or exercise | Frequency | Status |
|---|---|---|
| ERT drill, each shift | At least once a year | Run by Steve Resko (days) and Marty McFly (nights); critique per Section 14 |
| Notification exercise, Polyjuice Base (68.96(a)) | Once each calendar year | Last November 18, 2025; next November 2026 |
| Tabletop exercise with NMEFD and the LEPC (68.96(b)(2)) | At least every three years | November 2026; scenario: T-2 failure into the ammonia dike |
| Field exercise with NMEFD (68.96(b)(1)) | At least every ten years | February 2027; scenario: unloading hose failure, ERT deployment, community notification test |
| Campus shelter-in-place drill | At least once a year | Campus Emergency Action Plan Section 11.4 |
Table 4-2. Drills and exercises.
SECTION 5Emergency Alerting and Response Procedures
1910.120(q)(2)(ix), (q)(3)
5.1 Calling Out the ERT
- Whoever discovers a release follows Campus Emergency Action Plan Section 3: move away and upwind, keep others out, call 911 for a fire or injury, and call the control room, ext. 0, or radio Channel 1.
- The control room operator sounds the employee signal the situation calls for (Campus Emergency Action Plan Section 4.3), pages the ERT Leader and the EC on Channel 1 and by phone, and calls 911 for NMEFD for any fire, injury, release of Polyjuice Base, or release the ERT may not be able to control.
- The control room operator makes critical operations safe from the console: ESD-101 for the Thunderbolt Solvent System; close XV-201 and stop P-201 for T-2 (Campus Emergency Action Plan Section 7).
- ERT members on shift report to the ERT room by the control room, dress as the ERT Leader directs and take the equipment. For Building C, the ERT takes the response trailer out door B-6, east to East Drive and south into the truck yard.
- After 11:00 p.m. and on weekends, the Building B operator on duty or Gate 2 security calls 911, then the on-call EC in the order in Section 3.3. The EC reached calls back the ERT and notifies Dana Scully.
5.2 First Actions on Scene (Size-Up)
- Approach from upwind and uphill. Check the windsock on the Building B roof.
- Look for people who are hurt or trapped. Rescue in a release area is made only by ERT members in SCBA and the required PPE, working in pairs with backup ready (Campus Emergency Action Plan Section 9.1).
- Identify the material from the location, the container or equipment ID, labels and placards, the SDS, the fixed detector readings and the shipping papers on a delivery truck.
- Set the initial isolation area (Section 6.1) and keep everyone out of it.
- Report to the individual in charge: material, source, amount released and still leaking, direction of travel, wind, people hurt or missing, and what has been shut down.
5.3 Actions of the Individual in Charge
- Identify, to the extent possible, all hazardous substances and conditions present, and address site analysis, engineering controls (ESD-101, XV-101, XV-200, XV-201, WM-1 water fog, drain covers), exposure limits, handling procedures and the use of any new technologies (1910.120(q)(3)(ii)).
- Decide the response: contain from a distance; approach the source to stop the release; or make no entry and wait for NMEFD. The ERT makes no entry when the job needs Level A protection, when fire is beyond the incipient stage, or when a backup team cannot be staffed.
- Complete the entry plan (Appendix C) before anyone enters: objectives and tasks, hazards and controls for each task, PPE and respiratory protection, entry and backup team names, decontamination, first aid support, entry time limit, communication and the emergency withdrawal signal. Brief the entry and backup teams on it.
- Limit the people in the hot zone to those actively performing emergency operations. Work in the hot zone is done in pairs or larger groups (1910.120(q)(3)(v)).
- Name the safety official (1910.120(q)(3)(vii)).
- Make sure backup personnel stand by with equipment ready, and that first aid support stands by with medical equipment and transportation, before entry (1910.120(q)(3)(vi)).
5.4 Respiratory Protection and Air Monitoring
- Responders exposed to a hazardous substance that presents an inhalation hazard or potential inhalation hazard wear positive-pressure SCBA until the individual in charge determines, through air monitoring, that a decreased level of respiratory protection will not result in hazardous exposures (1910.120(q)(3)(iv)).
- The ERT's entry respirators are SCBA (8 units, 30-minute cylinders). The ammonia escape respirators in SK-10 are for escape only and are never used for entry.
- Where the exposure cannot be identified or reasonably estimated, the atmosphere is treated as IDLH (29 CFR 1910.134(d)(1)(iii)).
- Monitoring equipment: portable 4-gas meter (O2, LEL, CO, H2S) with PID, a spare 4-gas meter, ammonia colorimetric tubes and pump, and the fixed detectors AD-1 to AD-4 and LD-1 to LD-3 read from the control room.
- Entry teams leave the area if the meter reads 10% LEL or more, the alarm point of the fixed LEL detectors.
- Readings, times and locations are recorded on the entry log (Appendix C).
5.5 Protective Equipment
The individual in charge makes sure the PPE worn is appropriate for the hazards (1910.120(q)(3)(iii)). The safety official checks each entrant's PPE before entry. PPE levels and the written PPE program are in Section 10.
5.6 Authority of the Safety Official
When the safety official judges an activity to be an IDLH condition or an imminent danger, the safety official alters, suspends or terminates it and tells the individual in charge at once (1910.120(q)(3)(viii)). Every responder also stops work and reports any condition they believe is unsafe.
5.7 Response Guides by Material
| Situation | Actions and limits |
|---|---|
| Thunderbolt: R-101 room, T-1, flammable/oil unloading pad, piping | ESD-101 closes the steam valve to the R-101 jacket, closes XV-101 and stops P-101. Stop all hot work and remove ignition sources. Use non-sparking tools, and bond and ground transfer equipment. Cover pools with alcohol-resistant foam from the AR-AFFF cart at SK-1. Keep liquid out of floor drains and storm inlets SI-1 and SI-2 (drain covers from SK-2 and SK-4). Leave at 10% LEL. Fire beyond the incipient stage: NMEFD. |
| Polyjuice Base: T-2, ammonia unloading pad, P-201 and piping | Shelter-in-place signal (control room; Campus Emergency Action Plan Section 6). Close XV-200 and XV-201 and stop P-201. Level B with SCBA. Water fog from WM-1 (fed from FH-2) to knock down vapor. Keep runoff inside the ammonia dike; DV-2 stays locked closed. Drain cover from SK-10 over SI-1 for releases on the pad. Ammonia tubes at the edge of the isolation area and toward the neighborhood. Entries needing Level A: NMEFD hazmat team. |
| Sodium hydroxide totes, Awesomeness line, blend tanks BT-1 to BT-3 | Contain inside the curbed line area with booms and pads from SK-13. Overpack a leaking tote or drum. Neutralize the residue with citric acid from SK-13 only after the liquid is contained, checking with pH paper. Keep caustic away from aluminum. For Awesomeness, remove ignition sources and use non-sparking tools. The individual in charge decides respiratory protection (Section 5.4); spraying or misting is an inhalation hazard. |
| Brilliance: BR-1 to BR-3, line piping | Contain with SK-14. If Brilliance has been mixed with bleach or another cleaner, or there is a strong ammonia or chlorine-type odor, treat it as a toxic gas release: SCBA, isolate the area, and ventilate. Polyjuice Base feed piping leaks: follow the Polyjuice Base row. |
| Drums of product: packaging, shipping, Building C docks | Overpack the drum (SK-15, SK-16, SK-11, SK-12 or the ERT room overpacks). Non-sparking tools for Awesomeness. Cover storm inlet SI-3 and the section of trench drain TD-1 in the release path at Building C. |
| Hazardous waste in the HWA | Follow the LQG Contingency Plan Section 6 checklist with the EC. SK-5. Control ignition sources for D001 waste. |
| Oil: T-3, T-4, transformers, drums, Building C fueling area | Follow the response actions in the SPCC Plan for the building. Drain covers over SI-1, SI-2 or SI-3. Booms. Any sheen at Outfall 001 or on Lake Tiberius: call Sheaves Environmental Response at once. |
| Building A laboratories | Arthur Dent, Chemical Hygiene Officer, gives the ERT the chemical and the location. Hydrogen Peroxide 35%: no combustible absorbents; vermiculite from SK-9 or SK-18. |
Table 5-1. Response guides.
5.8 Notifications
Dana Scully, EHS Manager, makes the notifications to outside agencies; when she is not on site, the EC on duty makes them (Campus Emergency Action Plan Section 3.6). The release-specific lists are in RMP-PJB-001 Section 7.2 (Polyjuice Base and ammonia vapor), LQG Contingency Plan Section 6.4 (hazardous waste), the Building B SPCC Plan and the Building C SPCC Plan (oil). Reportable quantities are in Sections 6 and 15 of each SDS.
5.9 Ending the Response
- The individual in charge confirms that the release is controlled and that no further emergency operations are needed.
- The individual in charge implements decontamination of people and equipment (1910.120(q)(3)(ix); Section 11).
- The EC directs the control room to sound the all-clear when air monitoring shows it is safe and, if NMEFD is on scene, after consulting NMEFD.
- Cleanup is handed over under Section 15. The debrief and critique follow Section 14.
SECTION 6Safe Distances and Places of Refuge
1910.120(q)(2)(iv)
6.1 Initial Isolation Area
The ERT sets the initial isolation area from the guide in the current Emergency Response Guidebook for the material (Table 2-1), measured from the release, and adjusts it using the windsock and air monitoring. The individual in charge may enlarge it at any time.
6.2 Places of Refuge
- Assembly areas: AA-1 "Rivendell" (Gate 1 lot), AA-2 "Shire" (Gate 2 visitor lot) and AA-3 "Hoth" (Gate 3 lot), with the alternates in Campus Emergency Action Plan Section 5.7.
- Shelter rooms for an outdoor ammonia release: Building A conference room "The Restaurant at the End of the Universe"; Building B break room and locker rooms; Building C dispatch office and break room (Campus Emergency Action Plan Section 6.3). The control room operator stays in the control room.
- The neighborhood north of Perry Parkway is about 400 ft from the flammable tank farm and about 600 ft from the ammonia storage area. NMEFD and police decide on protective actions for the neighborhood; the EC gives them the release information they need.
- Responders stage in the cold zone, upwind of the release.
SECTION 7Site Security and Control
1910.120(q)(2)(v)
- Hot zone: the area where the release and its hazards are. Only the entry and backup teams on the entry plan go in.
- Warm zone: the decontamination line between the hot zone and the cold zone. Everyone and everything leaving the hot zone goes through it.
- Cold zone: the command post, staging, first aid support and the specialist employees.
- The zones are marked with tape or cones. An ERT member at the entry point keeps the entry log (Appendix C): name, time in, SCBA cylinder pressure, time out.
- Gate 2 security stops inbound traffic. Honey Badger dispatch closes Gate 3 during shelter in place. NMEFD and police control Perry Parkway.
- Tank truck deliveries stop. Visitors and contractors are accounted for under Campus Emergency Action Plan Section 8.
- No one re-enters an evacuated building or the isolation area until the all-clear.
SECTION 8Evacuation Routes and Procedures
1910.120(q)(2)(vi)
- Employee evacuation routes, maps (Figures 1–4), shelter in place and accounting for employees are in Campus Emergency Action Plan Sections 5, 6 and 8.
- ERT routes: from the ERT room by the control room, out door B-6 (ERT only) to the flammable tank farm and the ammonia storage area; for Building C, east on East Drive and south into the truck yard (about 400 ft from door B-6 to Dock 3).
- Emergency withdrawal from the hot zone: on the signal in Section 3.4, entry teams leave by the route on the entry plan and go through decontamination. An injured entrant gets emergency decontamination (Section 11.1). The entry point keeper accounts for every entrant and reports to the individual in charge.
SECTION 9Training
1910.120(q)(2)(ii), (q)(4)–(q)(8)
9.1 Who Responds, and the Training for Each
Training is based on the duties and function of each responder (1910.120(q)(6)).
| Level | Who | Initial training | Refresher |
|---|---|---|---|
| Hazardous materials technician, 1910.120(q)(6)(iii) | The 12 ERT members (Table 9-2) | At least 24 hours equal to the first responder operations level, plus the technician competencies (Section 9.3); certified by Perry Industries | Annual (Section 9.7) |
| On-scene incident commander, 1910.120(q)(6)(v) | The four Emergency Coordinators: Steve Resko, Marty McFly, Jenn Resko, Montgomery Scott | At least 24 hours equal to the first responder operations level, plus the incident commander competencies (Section 9.4); certified by Perry Industries | Annual (Section 9.7) |
| Specialist employee, 1910.120(q)(5) | Doug Heasley; Jenn Resko | Training in their area of specialization (Section 9.5) | Annual training or demonstrated competency |
| Hazardous materials specialist, operations level, awareness level | None designated | — | — |
| All other employees | Not responders | Campus Emergency Action Plan review (1910.38(e) and (f)); hazard communication; small-release procedures (Campus Emergency Action Plan Section 13) | As those programs require |
Table 9-1. Responders and training.
Employees not listed as responders do not take part in emergency response. They report a release, get away from it and keep others out. Campus Emergency Action Plan Appendix E shows each person's HAZWOPER technician status.
9.2 Training Before Taking Part
A new ERT member, EC or specialist employee takes part in actual emergency operations only after completing the training for that role (1910.120(q)(6)). Until then they do not enter the hot zone or hold a role in Table 3-1.
9.3 Hazardous Materials Technician
Each ERT member has at least 24 hours of training equal to the first responder operations level, and competency in the following areas, and Perry Industries so certifies (1910.120(q)(6)(iii)):
- Know how to implement the employer's emergency response plan.
- Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment.
- Be able to function within an assigned role in the Incident Command System.
- Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician.
- Understand hazard and risk assessment techniques.
- Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.
- Understand and implement decontamination procedures.
- Understand termination procedures.
- Understand basic chemical and toxicological terminology and behavior.
Site-specific training covers: this plan; the materials in Table 2-1 and their SDSs; SCBA donning, use and cylinder changes; the Level B suits; the 4-gas meter with PID and the ammonia tubes; ESD-101, XV-101, XV-200 and XV-201; WM-1; drain covers, booms and overpacks; the decontamination line; and the layout of Buildings A, B and C on the drawings.
9.4 On-Scene Incident Commander
Each Emergency Coordinator has at least 24 hours of training equal to the first responder operations level, and competency in the following areas, and Perry Industries so certifies (1910.120(q)(6)(v)):
- Know and be able to implement the employer's incident command system.
- Know how to implement the employer's emergency response plan.
- Know and understand the hazards and risks associated with employees working in chemical protective clothing.
- Know how to implement the local emergency response plan.
- Know of the state emergency response plan and of the Federal Regional Response Team.
- Know and understand the importance of decontamination procedures.
Steve Resko, Marty McFly and Montgomery Scott hold both the technician and the incident commander certifications. Jenn Resko holds the incident commander certification only and does not enter the hot zone.
9.5 Specialist Employees
Specialist employees work with and are trained in the hazards of specific hazardous substances in their regular jobs and give technical advice to the individual in charge. They receive training or demonstrate competency in their area of specialization annually (1910.120(q)(5)).
| Specialist employee | Area of specialization |
|---|---|
| Doug Heasley, Process Controls Engineer, PSM Coordinator | Thunderbolt and the Thunderbolt Solvent System: process safety information, R-101 operating limits, ESD-101, LD-1 to LD-3, safe hold. |
| Jenn Resko, Production Supervisor, Brilliance Line (days) | Polyjuice Base and the Brilliance line: T-2, P-201, XV-200, XV-201, AD-1 to AD-4, the ammonia unloading procedure, Brilliance. |
Table 9-3. Specialist employees.
9.6 Skilled Support Personnel
Perry Industries does not designate its own employees as skilled support personnel. When an outside operator of equipment such as earth-moving, digging, crane or hoisting equipment is needed temporarily and may be exposed to the hazards at the scene, the individual in charge or the safety official gives that person an initial briefing at the site before they take part: how to wear the PPE provided, the chemical hazards involved, and the duties to be performed. They get the same safety and health precautions as Perry responders (1910.120(q)(4)). The briefing is recorded on the response log.
9.7 Annual Refresher
Every ERT member, Emergency Coordinator and specialist employee receives annual refresher training of sufficient content and duration to maintain their competencies, or demonstrates competency in those areas at least yearly (1910.120(q)(8)(i)). The refresher includes hands-on work with the ERT equipment and a review of the responses, drills and exercises of the past year. A statement of the training or competency is made for each person; where competency is demonstrated, the method used is recorded (1910.120(q)(8)(ii)).
9.8 Respirator Training, Medical Evaluation and Fit Testing
- Each SCBA user receives respirator training that recurs annually, and more often if necessary (29 CFR 1910.134(k)).
- Each SCBA user has a medical evaluation before fit testing or first use (1910.134(e); Section 13).
- Each SCBA user is fit tested before first use, whenever a different facepiece is used, and at least annually (1910.134(f)(2)). Kaitlyn Perry, RN, does the fit testing.
9.9 Trainers
The 24-hour technician course, the incident commander course and the annual refresher are given by an outside training provider whose instructors have the training, credentials and instructional experience required by 1910.120(q)(7). Site-specific and hands-on sessions are given by Steve Resko, ERT Leader; meter training is given by Montgomery Scott, who calibrates the meters.
9.10 Certification and Records
Hari Seldon, Plant Manager, signs the technician and incident commander certifications (Appendix B) on the ERT Leader's recommendation. Human Resources (Wendy Weaver) keeps, for each person: name, course or session, date, hours, trainer, and the means used to verify competency, with the signed certification and the annual refresher statement.
| Name | Shift | Technician (q)(6)(iii) | Incident commander (q)(6)(v) | Specialist (q)(5) |
|---|---|---|---|---|
| Steve Resko | A (days) | Yes | Yes | — |
| Kara Thrace | A (days) | Yes | — | — |
| Montgomery Scott | A (days) | Yes | Yes | — |
| Leia Skywalker | A (days) | Yes | — | — |
| Zoe Washburne | A (days) | Yes | — | — |
| Rick Deckard | A (days) | Yes | — | — |
| Marty McFly | B (nights) | Yes | Yes | — |
| Ender Wiggin | B (nights) | Yes | — | — |
| River Tam | B (nights) | Yes | — | — |
| Samwise Gamgee | B (nights) | Yes | — | — |
| Trinity Anderson | B (nights) | Yes | — | — |
| Dana Scully | On call (all shifts) | Yes | — | — |
| Jenn Resko | A (days) | No | Yes | Yes |
| Doug Heasley | A (days) | No | — | Yes |
Table 9-2. Training matrix.
SECTION 10Personal Protective Equipment and Emergency Equipment
1910.120(q)(2)(xi), (q)(10), (g)(3)–(g)(5)
10.1 ERT Equipment
| Location | Equipment |
|---|---|
| ERT room, by the control room | 8 SCBA with 30-minute cylinders and 8 spare cylinders (cascade fill at the Gate 2 house); 6 Level B encapsulating splash suits; 12 pairs butyl gloves, 12 pairs nitrile gloves, 12 pairs chemical boots; portable 4-gas meter (O2, LEL, CO, H2S) with PID (10.6 eV lamp) and a spare 4-gas meter; ammonia colorimetric tubes and pump; pH paper; 2 spare Channel 1 radios; decontamination kit (pool, brushes, sprayers, bags); 2 95-gal overpack drums; stretcher. |
| Ammonia storage area | Water-fog monitor WM-1 (fed from FH-2); spill kit SK-10 with 4 ammonia escape respirators; safety shower and eyewash SS-4. |
| Main aisle outside the R-101 room door | Spill kit SK-1 with non-sparking tools and the grounded steel salvage drum; AR-AFFF foam cart. |
| Campus | Hydrants FH-1 (Gate 2), FH-2 (between the flammable tank farm and the ammonia storage area) and FH-3 (Building C east); safety showers SS-1 to SS-4; spill kits SK-1 to SK-20 (contents in LQG Contingency Plan Section 8.3). |
Table 10-1. Emergency equipment.
10.2 Levels of Protection
| Level | When the ERT uses it |
|---|---|
| Level B: positive-pressure SCBA, Level B encapsulating splash suit, chemical gloves (inner and outer), chemical boots | Every entry into an inhalation hazard or a potential inhalation hazard, and every entry where the material is not yet identified (1910.120(q)(3)(iv)). Standard ERT entry level for Thunderbolt and Polyjuice Base releases. |
| Chemical splash protection without respirator: chemical suit, face shield and goggles, chemical gloves and boots | Only when the individual in charge has determined through air monitoring that a decreased level of respiratory protection will not result in hazardous exposures (1910.120(q)(3)(iv)). |
| Level A: totally-encapsulating chemical protective suit | Required where skin absorption may result in a substantial possibility of immediate death, immediate serious illness or injury, or impair the ability to escape (1910.120(g)(3)(iv)). Perry Industries has no Level A suits; these entries are made by the NMEFD hazmat team. |
| Firefighting beyond the incipient stage | NMEFD. The ERT does not fight fires beyond the incipient stage. |
Table 10-2. Levels of protection.
Glove and suit material for each entry is chosen from Section 8 of the SDS and the manufacturer's chemical resistance data.
10.3 Written PPE Program
The chemical protective clothing and equipment used by the ERT meets 1910.120(g)(3) through (g)(5) (1910.120(q)(10)). The PPE program elements are:
| Element (1910.120(g)(5)) | How Perry Industries meets it |
|---|---|
| (i) Selection based on site hazards | Section 10.2 and the entry plan (Appendix C); SDS Section 8. |
| (ii) Use and limitations | Manufacturer instructions kept with each SCBA and suit type in the ERT room; covered in training (Section 9.3). |
| (iii) Work mission duration | Set by the individual in charge and the safety official before entry and written on the entry plan; never longer than the SCBA cylinder allows with a reserve to exit. |
| (iv) Maintenance and storage | Stored in the ERT room out of sunlight; maintained per manufacturer (Section 10.4). |
| (v) Decontamination and disposal | Section 11. Suits damaged or contaminated beyond cleaning are bagged and disposed of under the LQG Contingency Plan. |
| (vi) Training and proper fitting | Sections 9.3 and 9.8; suit sizes matched to each ERT member. |
| (vii) Donning and doffing | Manufacturer procedures attached in the ERT room; practiced at each refresher. |
| (viii) Inspection before, during and after use | Buddy check before entry; safety official observes during entry; inspection after decontamination and monthly (Appendix D). |
| (ix) Evaluation of effectiveness | ERT Leader reviews the program at the annual plan review and after each response (Section 14). |
| (x) Temperature extremes and heat stress | Safety official checks entrants before and after each entry, sets rest periods in the cold zone and provides fluids; work mission duration is shortened in heat. |
Table 10-3. PPE program.
10.4 Inspection and Maintenance
- The ERT inspects all ERT equipment monthly and after each use (Appendix D).
- SCBA are serviced as the manufacturer requires. Cylinders are refilled at the cascade at the Gate 2 house after each use. A spare cylinder is used only on an SCBA of the same capacity and pressure rating (1910.120(q)(3)(x)).
- The portable meters are calibrated monthly by Montgomery Scott and bump-tested before each use.
- Ammonia detectors AD-1 to AD-4 are bump-tested monthly and calibrated quarterly.
- Spill kits are inspected monthly and restocked after use (LQG Contingency Plan Section 3.3).
- Defective equipment is tagged out and replaced before the ERT is considered ready.
SECTION 11Decontamination
1910.120(q)(2)(vii), (q)(3)(ix)
11.1 Emergency Decontamination
A person who is contaminated and hurt, or splashed with a corrosive, is decontaminated at once: remove contaminated clothing and flush with water for at least 15 minutes at the nearest safety shower or eyewash outside the hazard (SS-1 flammable tank farm, SS-2 flammable/oil unloading pad, SS-3 Awesomeness line, SS-4 ammonia storage area) or with the decontamination hose. People come first; runoff is contained afterward.
11.2 Decontamination Line
- The decontamination line is set up in the warm zone, upwind of the hot zone, before anyone enters.
- Equipment drop: tools and equipment are left at the hot zone edge on plastic.
- Gross wash: the entrant stands in the decontamination pool and is washed down with water and brushes, top to bottom. Soap and water are used for oils and Thunderbolt; plain water for corrosives and Polyjuice Base. Neutralizers are never used on people.
- Rinse.
- Outer gloves and boots, then the suit, are removed with help from the decontamination team.
- The SCBA facepiece is removed last.
- The entrant goes to the safety official and first aid support for a check.
11.3 Wash Water and Equipment
Wash water stays in the decontamination pool and is collected, tested and managed under the LQG Contingency Plan; caustic wash water at pH 12.5 or higher is D002 hazardous waste. Nothing leaves the hot zone without decontamination. Reusable equipment is cleaned and inspected before it goes back into service; disposable items are bagged.
SECTION 12Emergency Medical Treatment and First Aid
1910.120(q)(2)(viii), (q)(3)(vi)
- Before any entry into the hot zone, the individual in charge requests an EMS unit through 911 to stand by at the command post, unless NMEFD EMS is already on scene. A first aid responder with the trauma bag and AED from the Building B nurse's station also stands by in the cold zone (1910.120(q)(3)(vi)).
- Kaitlyn Perry, RN, Occupational Health Nurse, gives first aid and triage until EMS arrives. First aid, CPR and AED responders are listed in Campus Emergency Action Plan Appendix C.
- Chemical contact: flush at once (Section 11.1). Ammonia inhalation: move to fresh air; oxygen is given only by trained personnel.
- Injured or exposed people go to Tiberius Regional Medical Center. The SDS, or the trade name if the SDS is not at hand, goes with the person. Gate 2 security meets the ambulance.
- Any responder who shows signs or symptoms that may have resulted from exposure during the response, then or later, is provided medical consultation (Section 13.3).
SECTION 13Medical Surveillance
1910.120(q)(9), (f); 1910.134(e)
13.1 Who Is Covered
The Building B ERT is an organized and designated hazmat team. All 12 ERT members receive a baseline physical examination and medical surveillance (1910.120(q)(9)(i), (f)(2)(iv)).
13.2 Examinations
| When | Basis |
|---|---|
| Before assignment to the ERT | 1910.120(f)(3)(i)(A) |
| At least every 12 months, unless the physician sets a longer interval, not more than two years | 1910.120(f)(3)(i)(B) |
| At termination of employment or reassignment off the ERT, if no examination in the last six months | 1910.120(f)(3)(i)(C) |
| As soon as possible after a member reports signs or symptoms of overexposure, an injury, or exposure above the PEL in an emergency | 1910.120(f)(3)(i)(D) |
| More often if the physician finds it medically necessary | 1910.120(f)(3)(i)(E) |
Table 13-1. Examination schedule.
Examinations are done by Tiberius Regional Medical Center Occupational Health under the supervision of a licensed physician, at no cost to the employee, without loss of pay, at a reasonable time and place (1910.120(f)(5)). Kaitlyn Perry, RN, schedules them and gives the physician a copy of 1910.120 and its appendices and the information in 1910.120(f)(6), including the respirator information required by 1910.134. The physician's written opinion is given to the employee (1910.120(f)(7)). The respirator medical evaluation required by 1910.134(e) is part of the examination.
13.3 Medical Consultation After a Response
Any responder who may have been injured, developed signs or symptoms, or been exposed above the PEL or published exposure level without the necessary PPE during a response is provided a medical consultation as soon as possible after the incident (1910.120(q)(9)(ii), (f)(3)(ii)). This applies to every responder, not only ERT members.
13.4 Records
Medical surveillance records are kept by Kaitlyn Perry, RN, separate from personnel files, for at least the duration of employment plus 30 years (1910.120(f)(8); 1910.1020(d)(1)(i)).
SECTION 14Critique of Response and Follow-Up
1910.120(q)(2)(x)
- Debrief: when the release is controlled, and at each shift change during a long response, the individual in charge holds a short debrief with the responders: whether anyone is hurt or exposed, what went well, and what anyone would do differently.
- Written critique: within 14 days the ERT Leader writes a critique of the response: the timeline, what worked, what did not, equipment used and its condition, exposures and injuries, and recommendations.
- Corrective actions: each recommendation gets an owner and a due date. Dana Scully tracks them to closure.
- Drills and exercises are critiqued the same way. RMP exercises get an evaluation report within 90 days (40 CFR 68.96(b)(3)).
- Related reports: incident investigation under the PSM program or RMP-PJB-001 where they apply; the LQG Contingency Plan operating record entry and 15-day written report (262.265(i)) for a hazardous waste emergency.
- Before the ERT is considered ready again: equipment is decontaminated, inspected, refilled and restocked, and the response is reviewed against this plan (Section 16).
SECTION 15Post-Emergency Response Operations
1910.120(q)(11)
When the emergency response is over and hazardous substances or contaminated materials must be removed from the site, the cleanup is post-emergency response.
- Sheaves Environmental Response, as the employer conducting the cleanup, does the cleanup and removal under 1910.120(q)(11).
- Perry employees who clean up on plant property have completed training under 29 CFR 1910.38, 1910.134 and 1910.1200, and the PPE and decontamination training the task requires. Equipment used is in serviceable condition and inspected before use (1910.120(q)(11)(ii)).
- When ERT members who took part in the initial response continue the cleanup, it is part of the initial response under this plan (1910.120(a)(3)).
- Recovered material and contaminated debris are managed under the LQG Contingency Plan (Section 6.7) and the SPCC Plans for oil.
SECTION 16Plan Review and Update
Steve Resko, ERT Leader, reviews this plan at least once a year and after any of the following, and updates it as needed:
- A response, drill or exercise that shows a need for change.
- A change in processes, chemicals, quantities, equipment or the layout of the campus.
- A change in a person named in this plan, an Emergency Coordinator, or an ERT member.
- A coordination meeting with NMEFD or the LEPC, or a change in the community emergency response plan.
- An incident investigation that shows a need for change.
- A change to the Campus Emergency Action Plan, RMP-PJB-001, the PSM program, the LQG Contingency Plan or either SPCC Plan that affects this plan.
Employees affected by a change are told at shift meetings. Revised copies go to every location on the Distribution page, including NMEFD Station 7 and the New Mos Eisley LEPC.
APPENDIX ARegulatory Cross-Reference
| Citation | Requirement (summary of eCFR text) | Where met |
|---|---|---|
| 1910.120(q)(1) | Written emergency response plan, developed and implemented before emergency response operations; available to employees, their representatives and OSHA | 1.1, 1.5; Distribution page |
| 1910.120(q)(2)(i) | Pre-emergency planning and coordination with outside parties | 4 |
| 1910.120(q)(2)(ii) | Personnel roles, lines of authority, training and communication | 3, 9 |
| 1910.120(q)(2)(iii) | Emergency recognition and prevention | 2 |
| 1910.120(q)(2)(iv) | Safe distances and places of refuge | 6 |
| 1910.120(q)(2)(v) | Site security and control | 7 |
| 1910.120(q)(2)(vi) | Evacuation routes and procedures | 8; Campus EAP 5, 6, 8 |
| 1910.120(q)(2)(vii) | Decontamination | 11 |
| 1910.120(q)(2)(viii) | Emergency medical treatment and first aid | 12 |
| 1910.120(q)(2)(ix) | Emergency alerting and response procedures | 5 |
| 1910.120(q)(2)(x) | Critique of response and follow-up | 14 |
| 1910.120(q)(2)(xi) | PPE and emergency equipment | 10 |
| 1910.120(q)(2)(xii) | Use of the local or state emergency response plan to avoid duplication | 4.2 |
| 1910.120(q)(3)(i)–(x) | Procedures for handling emergency response: ICS, hazard identification, PPE, SCBA, limiting personnel and buddy system, backup and first aid support, safety official and its authority, decontamination, SCBA cylinders | 3.1, 3.2, 5.3–5.6, 5.9, 10.4 |
| 1910.120(q)(4) | Skilled support personnel: initial briefing | 9.6 |
| 1910.120(q)(5) | Specialist employees: annual training or demonstrated competency | 9.5 |
| 1910.120(q)(6) | Training based on duties; before taking part; technician (iii); incident commander (v) | 9.1–9.4 |
| 1910.120(q)(7) | Trainer qualifications | 9.9 |
| 1910.120(q)(8) | Annual refresher; statement of training or competency | 9.7, 9.10 |
| 1910.120(q)(9) | Medical surveillance for hazmat team members; consultation after symptoms | 13 |
| 1910.120(q)(10) | Chemical protective clothing meets (g)(3)–(g)(5) | 10.2, 10.3 |
| 1910.120(q)(11) | Post-emergency response operations | 15 |
| 40 CFR 68.95(a)(1)(i) | Informing the public and local emergency response agencies | 4.2, 5.8; RMP-PJB-001 7.2 |
| 40 CFR 68.95(a)(1)(ii) | First aid and emergency medical treatment | 12 |
| 40 CFR 68.95(a)(1)(iii) | Procedures and measures for emergency response | 5, 5.7 |
| 40 CFR 68.95(a)(2) | Use, inspection, testing and maintenance of emergency response equipment | 10 |
| 40 CFR 68.95(a)(3) | Training for employees in their responsibilities | 9 |
| 40 CFR 68.95(a)(4) | Review and update of the plan; informing employees of changes | 16 |
Table A-1. Cross-reference.
APPENDIX BTraining Certification
Perry Industries certifies that the employee named below has received at least 24 hours of training equal to the first responder operations level and has competency in each area listed for the level checked, under 29 CFR 1910.120(q)(6).
| Employee name | |
| Job title and shift | |
| Level certified | ☐ Hazardous materials technician, 1910.120(q)(6)(iii), competencies (A)–(I) ☐ On-scene incident commander, 1910.120(q)(6)(v), competencies (A)–(F) |
| Course, provider and dates | |
| Hours of training | |
| Site-specific training (Section 9.3) completed, date and trainer | |
| How competency was verified (test, performance demonstration, drill) | |
| Recommended by (ERT Leader), signature and date | |
| Certified by (Plant Manager), signature and date |
Original to Human Resources. Copy to the ERT Leader.
Annual Refresher Statement (1910.120(q)(8))
| Year | Refresher course or competency demonstration | Hours | Method (if competency demonstrated) | ERT Leader initials |
|---|---|---|---|---|
APPENDIX CEntry Plan and Entry Log
Completed by the individual in charge before any entry into the hot zone. Briefed to the entry and backup teams. Kept with the response log.
| Date and time | |
| Location and material (SDS reviewed) | |
| Individual in charge | |
| Safety official | |
| Objectives | |
| Tasks, with the hazard and the control for each | |
| PPE level and glove and suit material | |
| Respiratory protection and air monitoring (instrument, action levels) | |
| Entry team (names) | |
| Backup team (names, same PPE level) | |
| Decontamination set up (location, method) | |
| First aid support and EMS standing by | |
| Entry time limit | |
| Radio channel; hand signals agreed | |
| Emergency withdrawal signal and route | |
| Approved by individual in charge (signature, time) |
Entry Log
| Name | Time in | SCBA psi in | Time out | SCBA psi out | Readings and notes |
|---|---|---|---|---|---|
APPENDIX DMonthly ERT Equipment Inspection
Month and year: ______________________ Inspected by: ______________________
| Item | OK | Problem found and action taken | Initials |
|---|---|---|---|
| SCBA (8): cylinder pressure, facepiece, straps, regulator, alarm | |||
| Spare SCBA cylinders (8): full, in service date | |||
| Cascade fill at the Gate 2 house: pressure, condition | |||
| Level B encapsulating splash suits (6): no tears, zipper, visor | |||
| Butyl gloves (12 pairs), nitrile gloves (12 pairs), chemical boots (12 pairs) | |||
| 4-gas meter with PID: calibration date, bump test, battery | |||
| Spare 4-gas meter: calibration date, battery | |||
| Ammonia colorimetric tubes (in date) and pump; pH paper | |||
| Spare Channel 1 radios (2): charged | |||
| Decontamination kit: pool, brushes, sprayers, bags | |||
| Overpack drums (2) and stretcher | |||
| Response trailer: loaded, tires, hitch | |||
| WM-1 water-fog monitor and FH-2: accessible, valve operates | |||
| SK-10 escape respirators (4): sealed, in date | |||
| AR-AFFF foam cart at SK-1: full, hose and nozzle | |||
| Copies of this plan, the SDSs and the drawings at the command post kit |
Signature: ______________________ Date: ______________