Page 46 - OHS, April 2021

FACILITY SAFETY
Restructure Your Next Spill Drill
It is time to rethink your spill drills to make them more engaging and easier to understand.
BY KAREN HAMEL
Spills don’t happen every day, so it can be easy to overlook the need to conduct spill response trainings. Skipping spill drills can compromise safety, expose employees to unfamiliar hazards and increase the likelihood of injuries during response.
Before a new process is introduced, risks are evaluated and hazards are identified. Processes, procedures and policies are documented, and training is developed. After employees are trained, they typically must be able to demonstrate that they can perform routine duties safely.
While it is certainly essential to ensure that each employee can recognize and avoid hazards in their routine duties, they also need to know what to do when something goes wrong. The list of things that could go wrong is probably a long one that is unique to each facility. However, one of the most common things that can go wrong is for liquids to spill.
For many facilities, spill response training falls into one of two categories. In facilities with chemicals that could cause immediate emergencies, employees are likely to be trained under OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard [29 CFR 1910.120.] Alternatively, they are trained to evacuate when anything that presents an immediate hazard spills so that HAZWOPER-trained responders can clean up the spill.
In facilities where spills are not likely to cause an immediate emergency and are more of an interruption or nuisance, spill response is often covered as part of hazard communication training. It may also be taught as part of Lean Manufacturing training or as a good housekeeping practice.
Whether spills are emergencies or interruptions, because they don’t happen often, most facilities don’t spend a lot of time conducting response training. Alternatively, they set up the same annual training that has been done since the facility began operation, which can leave safety to chance.
Get Out
Minimize the time spent lecturing on spill response topics. Spill response is a tactical skillset that needs to be practiced. Instead of showing the same slide deck or watching the same video, take a field trip. Look at the areas of the facility where spills have happened in the past, or where they could happen.
Visit liquid storage areas, waste collection areas and fluid transfer areas. These are all common places for spills. Tracing the paths of pipelines and hoses can also help employees to recognize how widespread the potential for spills may be.
Throughout the tour, point out where spill kits or supplies are located. If spill response supplies are stored in one central area, visit that location.
Hands On
One of the most common ways to conduct an annual spill drill is to wait for nice weather, gather everyone in a roped-off section of the parking lot, then spill a drum of water and clean it up. It’s better than
nothing, but it probably doesn’t reflect true spill conditions within the facility and won’t prepare employees for other unexpected hazards that can pop up when something spills.
It may not be practical to conduct a mock spill in some areas of the facility, such as a manufacturing area or warehouse. However, there may be areas within the facility, like a waste collection area or fluid dispensing station, where hands-on response skills can be refreshed.
In addition to actually cleaning up a spill in one of the areas where it’s likely to happen, take time to review other safety precautions related to each area where spills can occur. For example, spills may require machinery to be shut down before cleanup can begin. Employees may need to block off an aisle or area to prevent foot or forklift traffic through the area during clean up. The potential for slips and falls increases when something has spilled. The spill may also create electrical hazards.
Give employees the opportunity to point out potential hazards specifically created by spills. Hands-on drills are a good time to review procedures for notifying supervisors, safety managers or environmental managers of spills. They are also a good opportunity to identify exit routes as well as spill scenarios that could necessitate evacuating the building rather than immediately cleaning up the spill.
Listen
As employees practice tactical spill response skills, note any frustrations they have. Some may be easy to fix. For example, if response is hampered by spill supplies stored in tall, round overpacks with lids that are nearly impossible to remove, an easy fix would be to change the container to something that is easier to access. This can make it safer and faster for employees to respond.
If employees are having trouble remembering where response supplies are located, signage may help. If spills are so uncommon that they’re not sure they’ll remember how to use items in kits, post instructions or pictures that show how to use each item.
Encourage feedback on both existing and new spill response tools and equipment, especially from seasoned employees. They are likely to have good instincts on what will or won’t work when it comes to spill response. They may even have insights into making response easier, faster or safer.
With the possible exception of professional spill response teams and agencies, no one looks forward to spills. They’re always inconvenient and they take valuable time away from production efforts.
However, regardless of how infrequent they are, employees need to be prepared to respond to spills quickly and safely. Restructuring annual spill response trainings into functional drills that reflect actual conditions improves skillsets and safety so that everyone is better prepared for fast response.
Karen D. Hamel CSP, CIT, WACH, is a regulatory expert, trainer and technical writer for HalenHardy.
42 Occupational Health & Safety | APRIL 2021
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