Emergency and Non-Emergency Hazardous Material Release Response

Presents Stanford University policy and plan for responding to all incidents involving the release of hazardous materials.

1. Introduction

Federal, state, and local regulations require employers to develop and implement a Hazardous Materials Release Response Plan to provide a consistent and adequate means of handling an incident involving hazardous materials. As part of Stanford’s continuing commitment to develop and implement policies and procedures consistent with these regulations, the policy below has been established. The policy has been designed to assure that PIs are fully informed of and included in the response strategy.

In the case of an emergency involving a hazardous materials release that is “health threatening” or “imminent danger to the environment” as defined in Appendix I of this policy document, the Palo Alto Fire Department (PAFD) is to be notified immediately by calling 9-911 or at the Medical Center, 286, and/or pulling a fire alarm if the building needs to be evacuated or if a telephone is not available. Once involved, the PAFD is in command until the hazard has been fully abated and they relinquish command. In the case of a significant release that is “non-health threatening” and “contained” as defined, the Department of Environmental Health and Safety (EH&S) Hazardous Materials (HazMat) Response Team should be contacted immediately and will assume command until relinquishing it to the PAFD or the hazard has been fully abated. In the case of a non-emergency (incidental) release, as defined, the person responsible for the spill should clean it up using available materials and appropriate personal protective equipment. (Lab coat, gloves, protective eye wear, long pants, closed toe shoes).

As stated in the following section of this policy, the participation of all members of the Stanford community is required for its successful implementation. Department Chairs, Laboratory Directors, Principal Investigators, and Supervisors have the specific responsibility to see that individuals for whom they are responsible are trained in proper emergency response procedures and that the work areas for which they are responsible are posted conspicuously with emergency response procedures.  (Please refer to the Definitions section and Activating Procedures for a summary of required responses in an emergency involving hazardous materials.)

EH&S can provide information for a department in establishing emergency response procedures for a specific area. An “IN CASE OF EMERGENCY” poster is available for posting from EH&S.  Please call that office (723-0448) with any questions you may have.

Non-compliance with this policy may result in a citation, fine or other civil or criminal penalties by the enforcing agency.

2. Policy Statement

It is the policy of Stanford University to establish and maintain response procedures and capabilities to:

• Respond to incidents involving hazardous materials
• Assist the Fire Department with hazardous materials expertise
• Clean up modest hazardous materials releases
• Maintain records of all hazardous materials releases and accidents
• Report incidents to outside agencies as required
• Review causes of incidents to reduce recurrence
• Review responses to incidents in order to improve service

This policy and associated procedures are intended to provide tiered response to incidents involving hazardous materials appropriate to their magnitude and risk. If the appraisal of magnitude and risk is uncertain, the response strategy will address the worst case scenario. Due diligence is expected that these procedures are followed explicitly and consistently and that the reporting party provides accurate and complete information to the responding entity.

The purpose of this statement is to set forth procedures to be followed in the event of an emergency involving the accidental release of hazardous materials, in order to: 

• Protect research personnel, the general public, and the environment
• Protect property and research assets
• Comply with the regulatory response reporting, recording and abatement requirements
• Encourage safe practices and requests for assistance when personnel are in doubt about hazardous materials
• Standardize response procedures throughout the University

Refer to Definitions for a summary of required responses and actions. 

Conditions and releases involving asbestos are excluded from this policy (call 723-0486 for attention to asbestos concerns).

3. Responsibilities

Environmental Health & Safety responsibilities:

• Maintaining a trained hazardous materials response team and equipment capable of addressing modest Hazardous Materials Releases
• Establishing procedures for use by local personnel for responding to non-emergency releases as defined
• Maintaining working knowledge of applicable laws and regulations
• Maintaining records of Hazardous Materials Releases and incidents
• Informing the campus community of the Emergency and non-Emergency Hazardous Material Release Response Policy

Medical Center Security responsibilities:

• Recording information provided by the reporter
• Securing the area and preventing entry
• Notifying EH&S and providing incident information

Department Chairs, PIs, and Supervisors responsibilities:

• Ensuring the safety of those working under their direction
• Assisting the Health and Safety Hazardous Materials Response Team or Palo Alto Fire Department in any hazard evaluation in areas under their direction
• Training those under their direction in correct emergency response procedures
• Ensuring that emergency response procedures are posted conspicuously in each work area

Faculty, Students, Staff and Visitors responsibilities:

• Following sound health and safety practices
• Reporting any emergency or hazardous situation immediately according to these procedures
• Cooperating and assisting with any emergency response personnel
• Cleaning up non-emergency releases as defined
• Complying with all applicable University policies and practices

4. General Procedures Applicable to All Incidents

These procedures are intended to provide tiered response to incidents involving hazardous materials appropriate to their magnitude and risk. The evaluation of the hazard and of what to report or record, and of how to respond will be made by the HazMat Team Leader in consultation with the PI or other knowledgeable or responsible parties, and the Palo Alto Fire Department (PAFD) when they are involved.

In the event that there is no time for a full hazard evaluation, or there are many hazardous materials or other complexities involved, or there is insufficient information available about the materials or situation involved, then precautions based on the worst case scenario for the incident will be applied to the response to protect the HazMat Team, the public, and the environment.

Due diligence must be taken that these procedures are followed explicitly and consistently and the reporting party provides accurate and complete information to the responding entity.

5. Activating Procedures for Hazardous Material Release

Extremely Important: Follow These Steps Explicitly

In all cases, when any person becomes aware of a hazardous material incident:

• If in the Medical Center, call 286 regardless of the nature of the incident.
• If not in the Medical Center, and the incident is Health Threatening, call 9-911 and/or pull the nearest fire alarm if the building needs to be evacuated or if a telephone is not available.
• If not in the Medical Center, and the release is a Non-Health Threatening Emergency, call EH&S at 725-9999.
• If an non-Emergency (Incidental) release, and the responsible party is knowledgeable of the hazards of the material spilled, they should clean it up themselves using appropriate personal protective equipment; at a minimum gloves, protective eyewear, closed toe shoes, long pants, and lab coat.
• If involving radiation or radioactive materials, call 286 from the Medical Center, and from all others call Health Physics at 723-3201.
• The following procedures are provided as a guideline to biohazardous/rDNA spill cleanup. If the spill is considered too large or too dangerous for laboratory personnel to safely clean up, secure the entire laboratory and call EH&S at 725-9999 immediately for assistance.
• If the reporting party is unclear of the health threatening nature of the emergency, assume it is health-threatening and proceed accordingly.
• If the release is in a laboratory, notify the PI or supervisor responsible for that area as soon as it is practical to do so. If any injuries are involved, follow the required University injury procedures, found below in "Related Items".

IMPORTANT: Any injury/illness resulting in death, permanent disfigurement, dismemberment, or hospitalization expected to last more than 24 hours shall be reported immediately to the EH&S Emergency Hotline at 725-9999. Refer to the attached PDF for details.

• If the PI unknown or unavailable then notify the Department or Building Administrator, Safety Committee Chairperson, or Department Chairperson. When possible, leave appropriate messages in each case. (The work and home phone numbers of these people should be posted near every room containing hazardous materials.)
• When Medical Center Security (286) or Central Communications (9-911) receives a report of an emergency involving hazardous materials during working hours, they will notify EH&S immediately.
• During non-working hours, Medical Center Security or 9-911 will notify EH&S at 725-9999.
• Medical Center Security or  9-911 will notify the Health Physics Office at 723-3201 in the event of an emergency involving radiation or radioactive materials.

6. Definitions

Emergency

An unforeseen event that calls for immediate action by responders from outside the immediate area to protect individuals, the environment, or property.

Non-Emergency (Incidental)Release 

A spill that is not the result of a container failure, the personnel are knowledgeable of the hazards associated with the release,  and the quantity can be cleaned up by personnel from the immediate area within 15 minutes.  (Non-emergency releases must be cleaned up immediately.  If assistance is required, or to record the incident contact EH&S at 725-9999.) Releases smaller than 30 ml do not need to be reported to EH&S.

Health Threatening

An emergency in which there is a clear potential for serious injury to a person or release of contaminants to the environment if immediate action is not taken.  (If in doubt, consider the emergency health-threatening.)

Non-Health Threatening

Any emergency in which there is not a clear potential for serious injury to any person.  (If unsure whether an emergency is health-threatening or non health-threatening, assume it is health-threatening.)

Hazardous Materials Release 

A Health Threatening or Non-Health Threatening release, unauthorized or unexpected release of a hazardous material from primary containment, as defined in any of the referenced laws or regulations. If Health Threatening, the EH&S Hazardous Material Response Team (HazMat Team) will assist the Palo Alto Fire Department or other responding agency in cleanup and reporting of the incident to regulatory agencies. If Non-Health Threatening, EH&S will call Central Communications if assistance is needed. Conditions and releases involving asbestos are excluded from this policy. Call 723-9747 for attention to asbestos concerns.

Contained

Indicates a Hazardous Material Release that is within secondary containment, i.e. a floor, tray or engineered containment system.

Imminent Danger to the Environment

Indicates a substantial Hazardous Material Release that is discharged to a stream, creek or other water body or to the storm drain system. (The HazMat Team will coordinate with PAFD and proceed to clean up the release obtaining any other assistance as necessary and reporting to regulatory and other cognizant agencies as required). 

Any emergency in which there is not a clear potential for serious injury to any person.  (If unsure whether an emergency is health-threatening or non health-threatening, assume it is health-threatening.)