1. Emergency Planning in your business St. Louis City LEPC General Meeting September 4, 2013

2. Disclaimer This presentation is an overview of specific regulations and practices. You must determine the applicability of this information to your business. This information is not exhaustive, it is a summary of minimum requirements only. You must determine what is right for your business and take necessary steps to keep your employees safe in an emergency. Safety is not based on doing the minimum required – it requires taking the necessary extra steps and being proactive.

3. Overview Requirements for having an Emergency Plan ▫EPCRA (EPA) ▫OSHA ▫Fire Code Contents of the Emergency Plan ▫EPCRA Plan Specifics ▫OSHA Plan Specifics ▫Fire Code Plan Specifics Best Practices

4. Requirements for Emergency Plan: Emergency Planning and Community Right –to- Know Act (EPCRA) - Occupational Safety and Health Administration (OSHA) International Fire Code Local Ordinances where applicable.

5. EPCRA Requirements What facilities are subject to the EPCRA emergency planning requirements? ▫Any facility with any Extremely Hazardous Substance (EHS) on- site greater than the relevant Threshold Planning Quantities (TPQs). ▫Any other facility designated as subject to the emergency planning requirements by the Governor of State or the State Emergency Response Commission (SERC), after a period of public comment. What are facilities required to do? ▫Cooperate in emergency plan preparation and designate a facility emergency coordinator to participate in the planning process. ▫Notify MERC and the LEPC within 60 days of becoming subject to the emergency planning requirements (such as from a shipment or production of an EHS).

6. OSHA Requirements OSHA 1910.38 Means of Egress ▫An emergency action plan must be in writing, kept in the workplace, and available to employees for review. An employer with 10 or fewer employees may communicate the plan verbally to employees. OSHA 1910.157 Fire Protection ▫Where the employer has established and implemented a written fire safety policy which requires the immediate and total evacuation of employees from the workplace upon the sounding of a fire alarm signal and which includes an emergency action plan and a fire prevention plan which meet the requirements of 29 CFR 1910.38

7. Fire Code Requirements INTERNATIONAL FIRE CODE, Section 404 ▫Buildings and occupancies must prepare and maintain an approved fire safety and evacuation plan for the following types of buildings:  Group A. (Assembly)  Group B. (Business)  Group E. (Educational)  Group H. (High-hazard)  Group I. (Institutional)  Group R-1. (Hotels & Motels)  Group R-2. (Dorms, Fraternities, & Sororities)  Group R-4. (Residential Care/Assisted Living)  High-rise buildings.  Group M. (Mercantile)  Covered malls  Underground buildings.

8. Contents of the Emergency Plan Plan must be tailored to your business Plan must be site – specific Plan must be kept current Names & contact info must be current Signage and plot plans must be current An Alarm/Notification System must be in place. A method for tracking employees and visitors must be in place. (Sign In/Out Log)

9. EPCRA Plan Specifics Sections 301 to 303. Emergency Planning Local governments are required to prepare chemical emergency response plans, and to review plans at least annually. State governments are required to oversee and coordinate local planning efforts. Facilities that maintain Extremely Hazardous Substances (EHSs) on-site in quantities greater than corresponding Threshold Planning Quantities (TPQs) must cooperate in emergency plan preparation. Section 304. Emergency Notification Facilities must immediately report accidental releases of EHS chemicals and "hazardous substances" in quantities greater than corresponding Reportable Quantities (RQs). Sections 311 and 312. Community Right-to-Know Facilities manufacturing, processing, or storing designated hazardous chemicals must make Material Safety Data Sheets (MSDSs) available to state and local officials and local fire departments. Facilities must also report inventories of all on-site chemicals for which MSDSs exist. Section 313. Toxics Release Inventory Facilities must complete and submit a Toxic Chemical Release Inventory Form annually for each of the more than 600 Toxic Release Inventory (TRI) chemicals that are manufactured or otherwise used above the applicable threshold quantities.

10. OSHA Plan Specifics Procedures for reporting a fire or other emergency; Procedures for emergency evacuation, including type of evacuation and exit route assignments; Procedures to be followed by employees who remain to operate critical plant operations before they evacuate; Procedures to account for all employees after evacuation; Procedures to be followed by employees performing rescue or medical duties; and The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan. An employer must designate and train employees to assist in a safe and orderly evacuation of other employees.

11. Fire Code Plan Specifics Site and Floor plans showing evacuation routes and other information. Specific instructions for employees who must remain to operate critical equipment prior to evacuation. Post-evacuation accounting procedure for all occupants. Personnel responsible for rescue or emergency medical aid. The primary and secondary means of occupant notification in a fire or emergency event. The primary and secondary means of reporting a fire or emergency event to the designated emergency response organization. A description of the emergency voice/alarm communication system, alert tone and preprogrammed voice messages, if so equipped. Designation of personnel who can further explain specific duties outlined by the plan. A list of hazards associated with the premises

12. Best Practices Keep an up to date site plot plan showing all evacuation routes, assembly points, hazards, and locations of fire extinguishers, hoses, hydrants, and alarm boxes. Keep current employee contact lists with “next- of-kin” and after-hours contacts. Keep list of Civil and Regulatory contacts. Maintain current (M)SDS sheets for emergency responders (consider providing Tier 2 report)

13. Best Practices Develop evacuation kits containing: ▫Contact Information (employee and regulatory) ▫Plot plans ▫(M)SDS and Tier 2 forms ▫SOPs & Equipment shutdown procedures ▫Emergency Personnel Assignments* ▫First Aid equipment ▫Other useful stuff:  Ponchos, flashlights, cameras, phone charger, water bottles. ▫Business Continuation Information

14. Best Practices Emergency Personnel Assignments: ▫Establish Incident Command ▫Sound alarms ▫Bring Evacuation Kit to assembly point ▫Take attendance (visitor and employee logs); ▫Call 911 and/or other emergency numbers; ▫Provide First Aid (as needed) & establish shelter ▫Perform Process Shutdown ▫Establish Site Security/Property Safeguard ▫Designate Emergency Response & Fire Control ▫Designate liaison with Civil Responders ▫Designate liaison with Media

15. Websites Do I need an Emergency Action Plan? https://www.osha.gov/SLTC/etools/evacuation/need.html https://www.osha.gov/SLTC/etools/evacuation/need.html OSHA Evacuation Plan e-Tool https://www.osha.gov/SLTC/etools/evacuation/index.html https://www.osha.gov/SLTC/etools/evacuation/index.html Evacuation Elements https://www.osha.gov/SLTC/etools/evacuation/evac.html https://www.osha.gov/SLTC/etools/evacuation/evac.html Emergency Preparedness and Response https://www.osha.gov/SLTC/emergencypreparedness/index.html https://www.osha.gov/SLTC/emergencypreparedness/index.html OSHA 29 CFR 1910.38 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9726 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9726 EPCRA Overview http://www.epa.gov/osweroe1/content/lawsregs/epcraover.htm#overview http://www.epa.gov/osweroe1/content/lawsregs/epcraover.htm#overview EPCRA Local Emergency Planning Requirements http://www.epa.gov/emergencies/content/epcra/epcra_plan.htmhttp://www.epa.gov/emergencies/content/epcra/epcra_plan.htm Ready.Gov - Emergency Response Plan http://www.ready.gov/business/implementation/emergency http://www.ready.gov/business/implementation/emergency CDC Emergency Plan Template http://www.cdc.gov/niosh/docs/2004-101/emrgact/emrgact.pdfhttp://www.cdc.gov/niosh/docs/2004-101/emrgact/emrgact.pdf