The new hazardous waste rules (August 2020) that adopt the federal Generator Improvement Rules, became effective in Michigan. Since that time, all large quantity generators (LQGs) of hazardous waste have been required to have a full contingency plan that includes a quick reference guide. The updated contingency plan that includes the new quick reference guide must also be shared with local emergency responders.
The new quick reference guide does not replace the full contingency plan. Instead, it supplements the contingency plan, making it much easier for emergency responders to quickly evaluate site specific details to determine the initial response action. The quick reference guide is a concise summary of the most relevant information for the emergency responders, formatted in a way that is easy to follow and quickly review. The full contingency plan itself is much broader in scope, can be lengthy, and is difficult to use during the initial response.
See our Contingency Plan and Emergency Procedures for Fully Regulated Generators guide. It includes a short, 3-page example of a quick reference guide provided by the United States Environmental Protection Agency (U.S. EPA) (see pages 5-7). Under the rules, the quick reference guide must contain:
- The types/names of hazardous wastes in layman’s terms and the associated hazard associated with each hazardous waste present at any one time (e.g., toxic paint wastes, spent ignitable solvent, corrosive acid).
- The estimated maximum amount of each hazardous waste that may be present at any one time.
- The identification of any hazardous wastes where exposure would require unique or special treatment by medical or hospital staff.
- A map of the facility showing where hazardous wastes are generated, accumulated, and treated and routes for accessing these wastes.
- A street map of the facility, in relation to surrounding businesses, schools, and residential areas to understand how best to get to the facility and also evacuate citizens and workers.
- The locations of water supply (e.g., fire hydrant and its flow rate).
- The identification of on-site notification systems (e.g., a fire alarm that rings off-site, smoke alarms).
- The name(s) of the emergency coordinator(s) and 7/24-hour emergency telephone number(s), or in the case of a facility where an emergency coordinator is continuously on duty, the emergency telephone number for the emergency coordinator.
Sites that become an LQG on or after August 3, 2020, must have the quick reference guide in their initial contingency plan. LQGs in existence before August 3, 2020, need to update their contingency plans to include a quick reference guide, when amending their contingency plans. LQGs are specifically required to amend their contingency plans whenever:
- The regulations change.
- The plan fails in an emergency.
- The site changes in design, operation, maintenance, or in any other way that increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency.
- The emergency coordinator changes.
- The emergency equipment changes.
New and updated LQGs’ contingency plans must be shared with local responders, and the coordination must be documented. Small quantity generators of hazardous waste are encouraged to include a quick reference guide in their emergency response plans, which also must be documented and shared with emergency responders. The quick reference guide helps both hazardous waste generators and emergency responders mitigate emergencies and protect our communities and the environment
For questions on contingency planning and quick reference guides please contact me at James.Charles@iso14001-training.com or (616) 666-5490.
