Biting off manageable pieces and reaching out for support will help agri-retailers show their ERAP who’s boss.
The November 1979 derailment and rupture of several rail cars carrying chlorine, which caused the evacuation of 220,000 people in Mississauga, Ont., revealed a need for specialized response teams and equipment to aid first responders on the scene.
This incident was the catalyst for the Grange Commission Report recommendations and subsequent adoption of the Transportation of Dangerous Goods (TDG) act in 1980, requiring any person, organization or company that handles, offers for transport, transports or imports certain dangerous goods to have a Transport Canada-approved Emergency Response Assistance Plan (ERAP).
The process of writing and implementing an ERAP can seem daunting at first glance, but is a necessary undertaking for any business transporting goods that fall under the act. In the agri-retail sector, one of the most common reasons to require an ERAP is for the transportation of anhydrous ammonia.
Belmont Farm Supply has had an ERAP in place for anhydrous ammonia for more than 20 years. Brad Walker, the operation’s co-owner and assistant manager, says agri-retailers will benefit from taking small steps toward ERAP completion, rather than worrying about the bigger picture.
“It’s overwhelming when you first look at it. Take one bite at a time, and just work at each section,” says Walker.
The company’s existing emergency response plan was upgraded in response amendments made to the TDG Act in 1992. “Our emergency response didn’t change much. We added the anhydrous ammonia, and it takes up two-thirds of the book, and the rest is the existing [emergency response plan] for on-site pesticides, fire-fighting measures, and all of that normal stuff,” he says, noting that the addition of the anhydrous ammonia ERAP took approximately 250 man hours.
Walker says it was also a challenge to work out what was applicable information and what was extraneous when filling out ERAP application forms. One of the pitfalls of ERAP drafting is including too much, often irrelevant, detail. “One of the hurdles was making sure we had only the information that was necessary,” he says.
“It’s overwhelming when you first look at it. Take one bite at a time, and just work at each section.” – Brad Walker.
Topics addressed in an ERAP include the basic elements of emergency response, such as hazard identification and analysis; roles and responsibilities of key personnel; internal and external resources required for response; third-party agreements; emergency response procedures for critical tasks; and contact lists, to name a few. A full description of essential features of an ERAP is available on Transport Canada’s website at tc.gc.ca.
In the event of a product spill, owners are notified immediately of the incident, and they then determine whether the ERAP is to be activated or if the incident is to be handled by staff.
Usually, ERAP activation is required in the event of product release. When more than five litres of anhydrous ammonia is released, the law requires immediate reporting to the appropriate authorities. However, agri-retail personnel may handle an incident that involves no product release.
Not only is drafting and maintaining an effective and up-to-date ERAP crucial, ensuring staff members are trained and ready to assist in the event of an accident involving the transport of ERAPable products is also essential, according to Paul Driver, a Transport Canada remedial measures specialist.
“Companies that hold ERAPs are required to demonstrate, through training and hands-on exercises, that their plans are effective in providing assistance when needed. An ineffective response may endanger the lives of the public or first responders at the scene, and cause needless delays in properly dealing with the incident,” says Driver.
250: The approximate amount of man hours it took Belmont Farm Supply for the addition of the anhydrous ammonia ERAP.
Companies are also required to conduct regular training exercises with their response teams. This training should include hands-on exercises involving the actual product, so team members can become familiar with emergency response procedures, and the use of response equipment under realistic conditions.
Furthermore, team members must have an adequate level of understanding of the tanks used to transport the product, in order to assess damage that could occur during an accident.
“This assessment is important to assist the responders in developing a successful response plan to most safely deal with the situation,” says Driver. He also recommends tabletop-type exercises, which help individual team members understand their roles.
New team members may also require training in basic emergency response concepts and skills before moving to those specific to a particular dangerous good, he adds.
Fortunately, there is help on hand for staff members charged with drafting and implementing an ERAP, as well as TDG training of personnel. CAAR, Transport Canada and the Canadian Emergency Response Contractors’ Alliance (CERCA) have resources available for putting an ERAP in place as well as personnel training for the handling of goods requiring an ERAP, such as anhydrous ammonia.
Transport Canada offers a step-by-step guideline for the ERAP application process. Sample ERAPs can be found on the website, as well as a tool for finding organizations providing TDG training and guidelines for training criteria.
CAAR has also recognized its members’ needs for ERAP guidance and support. The organization holds information sessions for its members, such as the ERAP session held during the Retail Management Workshop at the 2016 CAAR Conference. CAAR also holds anhydrous ammonia TDG courses for agri-retail personnel, to promote the safe transportation and handling of the fertilizer. Successful trainees receive a TDG certificate valid for three years, confirming they are qualified to transport and handle anhydrous ammonia.
CERCA members provide a number of services for companies implementing a plan, such as ERAP development and guidance, emergency response teams, 24-hour emergency telephone numbers, TDG training, and specialized equipment for incident response. Using CERCA-verified emergency response contractors is a common solution for many agri-retailers and small businesses.
In the near future, ERAP application and submission may become that much easier. In the TDG December 2015 newsletter, Transport Canada announced the ERAP section of its website is to be revised. According to the newsletter, the refurbished website will contain a new ERAP application package to “ensure better process efficiency, improve consistency and quality control for clients having to apply, update, renew or terminate an ERAP.”
The new package will consist of FAQs, guidelines and tools to aid users in following the TDG Directorate’s four steps to submit a new ERAP application.
Although the task may seem overwhelming at first, Walker says chipping away at the plan and reaching out to various associations and organizations specializing in ERAPable products and support may help ease the journey to ERAP implementation.
“Don’t be scared of it. It’s only paper…. You just have to [tell yourself] there’s going to be an extra 40 pages in my emergency response plan to do with ERAPable products,” says Walker. “There are places you can go to and ask for help. If you don’t have time or the employee capacity, you can certainly hire a company that will tell you, ‘this is what we think you need in your plan.’”
Click here to find a useful ERAP template courtesy of Rack Petroleum!
The ERAP Application
According to Transport Canada, the ERAP application process can be broken down into seven basic steps:
- Determine if an ERAP is required for the consignment.
- Determine if you require an ERAP (are you importing or offering for transport?).
- Determine if in-house resources or emergency response contractors will be used for incident response (or a combination of the two). In the case of emergency response contractors, confirm the contractor has the capability to respond to the dangerous goods and means of containment.
- Complete a Potential Accident Assessment (PAA) per 7.2(2)(h) of the TDG Regulations.
- Prepare or have someone prepare the ERAP.
- Prepare the ERAP application by filling out form 16-0075E.
- Submit the application to the Chief, Enforcement and Response Operations, including a copy of the ERAP, PAA and signed agreements with third-party response contractors.
After an ERAP application is submitted, it is reviewed by a remedial measures specialist, who may contact the applicant to request changes or additional information. Once the evaluation has been completed, the remedial measures specialist will recommend approval or rejection of the ERAP application.
If the ERAP is approved, an official letter will be sent to the applicant. No product may be shipped until the approval letter has been received by the applicant, confirming plan approval.
For more information, visit the Transport Canada website.
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