Emergency response / spill control
This Technical Measures Document refers to the emergency response and
spill control measures that can be adopted in plant operation to ensure safe
It should be noted that the criteria requirements for the section of the
COMAH Report dealing with Emergency Response Arrangements are provided in
Part 2, Chapter 6 of the Safety Report Assessment Manual (SRAM). This
Technical Measures Document is intended to provide additional detail on the
measures that should be considered in plant design and operational
Related Technical Measures Documents include:
The relevant Level 2 Criterion is 18.104.22.168(29)d,
Safety management systems
Generation and implementation of effective emergency response and spill
control procedures are fundamental aspects of a safety management system.
Site emergency plan
The on-site emergency plan, prepared for Regulation 9 of COMAH should
address procedures for dealing with emergency situations involving loss of
containment in general terms. Full detail of the required contents is
provided in Part2, Chapter 6 of the SRAM. In brief, the main points for
- Containing and controlling incidents so as to minimise the effects and
to limit danger to persons, the environment and property;
- Implementing the measures necessary to protect persons and the
- Description of the actions which should be taken to control the
conditions at events and to limit their consequences, including a
description of the safety equipment and resources available;
- Arrangements for training staff in the duties they will be expected to
- Arrangements for informing local authorities and emergency services;
- Arrangements for providing assistance with off-site mitigatory action.
The emergency plan should be simple and straightforward, flexible and
achieve necessary compliance with legislative requirements. Furthermore
separate on-site and off-site emergency plans should be prepared.
Emergency operating procedures / training
The emergency procedures should include instructions for dealing with
fires, leaks and spills. The procedure should describe how to:
- Raise the alarm and call the fire brigade;
- Tackle a fire or control spills and leaks (when it is safe to do so);
- Evacuate the site, and if necessary nearby premises.
Evacuation of areas in the event of fire or toxic gas emission should be
addressed in an emergency evacuation procedure. This should specify
designated safe areas, assembly points and toxic gas shelters. The procedure
should also identify responsible personnel whose duties during area
- Responsibility for a specific area;
- Collecting ID badges from plant racks;
- Ensuring roll calls are undertaken to identify missing persons;
- Communication of missing persons to central emergency services.
A fire fighting strategy should consider:
- Appointment of fire wardens, with subsequent training;
- Location plans of fire hoses, extinguishers and water sources;
- Access for emergency services;
- Provision of firewater lagoons.
Removal of substance to safe place
The emergency spill control procedure should include the following key
- Spills involving hazardous materials should first be contained to
prevent spread of the material to other areas. This may involve the use
of temporary diking, sand bags, dry sand, earth or proprietary booms /
- Wherever possible the material should be rendered safe by treating
with appropriate chemicals (refer to Stabilisation / dilution to safe
- Hazardous materials in a fine dusty form should not be cleared up by
dry brushing. Vacuum cleaners should be used in preference, and for
toxic materials one conforming to type H (BS 5415) should be used;
- Treated material should be absorbed onto inert carrier material to
allow the material to be cleared up and removed to a safe place for
disposal or further treatment as appropriate;
- Waste should not be allowed to accumulate. A regular and frequent
waste removal procedure should be adopted.
Stabilisation / dilution to safe condition
Once the hazardous material has been contained to prevent spread of the
material to other areas, the material should be treated wherever possible to
render it safe. Acids and alkalis may be treated with appropriate
neutralising agents. Due to the differing properties of the various groups
of chemical, an appropriate treatment strategy with suitable chemicals
should be established in each case. For example, highly concentrated
hydrochloric acid will fume when spilled so prior to neutralisation the
spill should be diluted with a water spray.
Once the material has been treated the cleared up the area should be
washed with large volumes of water. Most chemical plants and associated
areas are serviced by chemical drains that feed to the effluent treatment
plant. The washing operation will represent an abnormal loading on the
effluent treatment plant, and it is vital that in any situation where this
is likely to happen the staff responsible for operation of the effluent
treatment plant are notified so that appropriate measures can be adopted.
The effluent treatment plant operatives are likely to require the following
- Approximate quantity of hazardous material;
- Approximate composition of hazardous material;
- Physical properties of hazardous material;
- State of hazardous material (whether neutralised etc.).
In the case of fire water run off, much larger volumes of water are
employed and the provision of firewater lagoons to contain potentially toxic
firewater is required.
Availability of neutralising substances / foam
Process specific emergency spill kits (acid, alkali, solvent, toxic etc)
and appropriate personal protective equipment should be readily available
with supporting procedures. These spill kits should be maintained on a
regular basis to ensure that they are always available and fit for purpose.
This ensures that the most appropriate measure is at hand to deal with a
spill or fire in the most effective way.
Issues that should also be addressed include:
- Maintenance and condition of fire hoses, extinguishers.
Status of guidance
Existing guidance provides comprehensive information with respect to best
practice for emergency response and spill control procedures.
Guidance for emergency responses for chlorine, anhydrous ammonia, LPG,
nitrocellulose, flammable dusts, and flammable liquids storage plants and
chemical warehouses are given in the specific guidance notes listed below.
Additional material providing much insight into analysis of offsite
consequences through a risk management program is now available from the
United States Environmental Protection Agency. This provides guidance on
offsite consequence analysis for toxic gases, toxic liquids, and flammable
substances. The risk management analysis will have a significant impact on
the format and content of an emergency response or spill control procedure.
General guidance is available in the ILO publication 'Major hazard
control: A practical manual'.
Guidance relating to Emergency response / spill control
- HS(G)191 Emergency planning for major
accidents. Control of Major Accident Hazards Regulations 1999, HSE,
- HS(G)71 Chemical warehousing: the storage of
packaged dangerous substances, HSE, 1992.
Paragraph 46 provides guidance on methods for containing spillages of
Paragraphs 130 to 164 provide guidance on fire fighting and emergency
- HS(G)103 Safe handling of combustible dusts
: precautions against explosions,HSE, 1994.
Paragraph 40 gives guidance on the need and methods for clean-up of
dusts to prevent explosions.
Paragraph 78 gives guidance on emergency procedures.
- HS(G)186 The bulk transfer of dangerous
liquids and gases between ship and shore, HSE, 1998.
Paragraphs 259 to 264 give guidance on emergency procedures.
- HS(G)135 Storage and handling of industrial
nitrocellulose, HSE, 1995.
Paragraphs 59 to 60 give guidance on emergency procedures.
- HS(G)30 Storage of anhydrous ammonia under
pressure in the UK : spherical and cylindrical vessels, HSE, 1986.
(not in current HSE list)
Paragraphs 143 to 148 inclusive provide guidance on creation of an
- HS(G)28 Safety advice for bulk chlorine
installations, HSE, 1999.
Appendix 8 provides guidance on emergency plans for bulk chlorine
Paragraphs 247-263 provide guidance on emergency procedures for bulk
- LPGA COP 1 Bulk LPG storage at fixed installations. Part 1 : Design,
installation and operation of vessels located above ground, LP Gas
Association, 1998. (Supersedes HS(G)34 - see below).
Paragraph 7.1.2 of Part 1 requires that written emergency procedures are
provided and displayed and training should be given, including practices
run at least once per year.
- HS(G)34 Storage of LPG at fixed
installations, HSE, 1987.
(Superseded by LPGA Cop 1 - see above).
Paragraphs 46 and 194 give guidance on dealing with spills and emergency
- BS 5908 : 1990 Code of practice for fire
precautions in the chemical and allied industries, British Standards
Section 7, Paragraph 36.4.3 provides guidance on the provision of an
emergency procedure plan, and training of personnel.
Section 10, Paragraph 54.4 provides guidance on spill control and
identification and mitigation of leaks from equipment. It recommends
bunding, interception and drainage to reduce the effects of fires.
Further reading material
- ILO, PIACT, `Major Hazard Control: A Practical Manual', 1988.
- Seeley, L.A. and Moosemiller, M.D., 'Planning for Emergency Response',
DNV Technica, Inc., Chemical Engineering, 102, 6, p84, June 1995.
- AIChE/CCPS, `Plant Guidelines for Technical Management of Chemical
Process Safety', New York, 1992.
- EPA / CEPP, 'Risk Management Program Guidance for Offsite Consequence
Analysis', RMP Series, United States Environmental Protection Agency /
Chemical Emergency Preparedness and Prevention Office, April 1999.
- Robinson, B.W. and UK Chlorine Producers, 'General guidance on emergency
planning within the CIMAH Regulations for chlorine installations', 1986.
- Lees, F.P., 'Loss Prevention in the Process Industries: Hazard
Identification, Assessment and Control', Second Edition, Butterworth
- CONCAWE Reports (published by the Oil Companies European Organizations
for Environmental and Health Protection), Emergency planning guidance notes:
- Part 1: Selecting the incident scenarios for off-site emergency
- Part 2: Responsibilities of petroleum industry and regulating
authorities in emergency off-site planning;
- Part 3: Information to the public;
- Part 1: Content of emergency plans;
- Part 2: Planning for mutual aid.
Case studies illustrating the importance of Emergency response / spill