New regulations increase the frequency of live emergency simulations.
Environment and Climate Change Canada’s revised Environmental Emergency (E2) regulations are encouraging a higher level of emergency preparedness and communication at facilities handling hazardous substances.
The revised regulations, published in the Canada Gazette earlier this year, came into effect on Aug. 24, 2019. Facilities handling and storing hazardous substances, including anhydrous ammonia (NH3), have various timeframes to submit information but must be fully compliant by Aug. 24, 2020.
Mark Coppicus, agro regulatory and safety manager with Federated Co-operatives Limited (FCL), says the biggest change that retailers should be aware of is the requirement to perform more frequent live simulations of their facility’s environmental emergency plan. Under the updated regulations, a live simulation must be conducted within five years from the day on which the plan is brought into effect, and every five years thereafter, ideally with the involvement of local fire departments and emergency response teams.
With the new regulations in place, retailers…must conduct at least one live simulation with their management team and staff every five years to test the effectiveness of their plan.
“Until now, retailers had the choice of doing an annual tabletop exercise or a live simulation to test their facility’s emergency plan,” says Coppicus. “With the new regulations in place, retailers can continue to do their annual tabletop exercises, but they must conduct at least one live simulation with their management team and staff every five years to test the effectiveness of their plan and identify possible shortfalls.”
Coppicus and his colleague Darren Cameron, who make up FCL’s Agro Regulatory and Safety Team, support compliance for two dozen retail locations that handle NH3 and lead the writing of simulation exercises for those retail sites.
Coppicus says that although it is ideal to have local emergency response teams involved in each simulation, this may be difficult to co-ordinate, especially in areas where there are several businesses handling, retailing or supplying products listed in the Environmental Emergency Regulations, and in larger, busier municipalities.
Regulations dictate that a live simulation exercise must be conducted for each branch location, as every site will have different variables such as layout, equipment, geography and exposures. While this may seem daunting, Coppicus points out that the scenarios that need to be tested for are limited because the E2 regulations only apply to NH3 when it’s inside the storage vessel and in the vessel’s plumbing at the retail location. After that, it falls under different regulations.
“Everything that’s mobile is covered by ERAP – the Transportation of Dangerous Goods Emergency Response Assistance Plan,” says Coppicus. “Even the loading and unloading of the storage vessel is covered by ERAP.”
Coppicus lists leaky pipes, valves and pressure relief valves as realistic, testable scenarios to include in the simulation exercises. He says the likelihood of a storage vessel having a catastrophic separation is minimal, due to the inspecting and testing requirements implemented by provincial regulators and Fertilizer Canada’s Ammonia Code of Practice. Terrorism, however, is a possible scenario to consider testing for.
Updating Your Facility’s E2 Plan
There are several additional changes to the E2 regulations that affect retailers who handle NH3, including: consolidation and modification of Schedule 1; conditions for notice of substance at a facility; development of an environmental emergency plan; requirements for periodic submission of notices; and requirements for communication to the public.
Coppicus says the best way for retailers to update their existing environmental emergency plan is to carefully and methodically compare their plan to the new E2 regulations.
“Through the review process, retailers will be able to identify and make the necessary adjustments to remain in compliance,” he says. “The regulations spell out exactly what has to be in their plan.”
One important component of the E2 plan that a retailer might need some assistance with is the modeling and mapping of a release of a substance showing the emergency planning zone and, in it, critical infrastructure, vulnerable and high occupancy locations, and environmental receptors.
Coppicus says there are several resources to help retailers with modeling, including an app called HazMat Evac that can simulate a chemical plume, taking into account factors like geography and weather. He also suggests retailers check with their commercial insurance provider, who may also offer modeling services for a fee.
Don Merriam, emergency response planning manager at Emergency Response Assistance Canada (ERAC), says those who require further assistance, or are starting from scratch, can also turn to an organization like his for help.
Merriam’s team at ERAC, a national emergency preparedness and response organization, has written many E2 plans for NH3 dealers in all parts of Canada and takes an active role in tabletop and on-site exercises designed to test facility preparedness and regulatory compliance. As well, ERAC can provide help with public outreach, another new component of the E2 regulations.
“In addition to creating safer workplaces and increasing the speed and efficiency at which emergencies are handled, the updated regulations meet the goal of providing more information to the community through mandatory public outreach before, during and after an emergency,” says Merriam. “This not only helps reassure the public, it’s something that will protect and enhance the image and reputation of the company and its employees.”
For additional information, click here to read Fertilizer Canada’s E2 bulletin.
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