Planning for Emergencies

If a fire, flood, hurricane, or other disaster hit your scrap plant, would you be ready? An emergency response plan can help you be prepared—for anything.

By Lynne Meredith Cohn

Lynne Meredith Cohn is a writer based in Ferndale, Mich.

When the Mississippi River rose more than 10 feet above its banks during the 1993 flood, it inundated Hannibal Iron & Metal Co. (Hannibal, Mo.). In response, the company disconnected the main electricity trunk down the road, hauled balers out of its submerged plant, and moved scales and motorized equipment to higher ground. Ultimately, it suffered $380,000 in equipment damage, less than half of which was covered by federal flood insurance, notes Robert Fletcher, president.

Louis Cohen & Son Inc. (Wilkes-Barre, Pa.) likewise knows the destructive power of floodwater. In 1972, the Susquehanna River overflowed and ran through the processor’s plant, wrecking equipment, destroying railroad tracks, and burying parts of its operation under as much as 10 inches of mud. Twenty-one years later, the company faced an emergency of a different kind when an electrical malfunction in a breaker panel set off a fire in its facility, notes president Charles Medico.

In contrast, heavy snow was the problem for Manitoba Corp., located in Lancaster, N.Y., near Buffalo. During the blizzard of 1977, Manitoba employees found themselves snowed in at the plant—they were forced to leave their vehicles behind and trudge home in high drifts. Adding insult to injury, during the week-long citywide shut-in that followed, the water mains broke and flooded the part of the plant where the cars were parked.

What these companies have in common is that they have faced disaster—the kind that can affect virtually any scrap processing operation. A fire, flood, blizzard, hurricane, tornado, or earthquake as well as the potential hazards of handling certain types of scrap can disrupt operations, damage property and equipment, cause significant financial losses or bankruptcy, and—in the worst case—claim lives.

Some of these problems can be avoided—or at least minimized—through foresight and preparation, including drafting an emergency response plan. The purpose of such a plan is to prepare your operation and employees for the unexpected, even the unlikely.

Various OSHA standards include requirements for emergency action plans—as defined under 29 CFR 1910.38—for certain situations such as using portable fire extinguishers to fight small fires or responding to hazardous substance releases. (There are also nonmandatory guidelines that mention other emergencies such as floods, blizzards, and hurricanes.) For example, if a company decides to designate certain employees as firefighters during a small fire, they must be trained to use fire extinguishers. For the rest of the work force, the company must have an emergency action plan that includes sections on emergency escape procedures, rescue and medical duties, alarm systems, training, and other topics. Moreover, employers with 10 or more employees must put this plan in writing and make it available for employee review. Employers with fewer than 10 employees still need a plan, it just doesn’t have to be written.

(For more information, contact OSHA or visit its Web site at www.osha.gov. Hit the Search button, then type Employee Emergency Plans in the Full Site Search box.)

Noting that OSHA is taking “a closer look at scrap industry safety,” Sunday Vogler, vice president of loss control with CNA Insurance Cos. (Chicago), points to one scrap processing firm cited by OSHA for failing to have a written plan. The company started out with fewer than 10 employees, Vogler explains, but when it grew larger the managers overlooked the fact that the rule now applied to them.

And it’s not only federal OSHA that’s prompting a greater emphasis on emergency planning. Twenty-three states have OSHA-approved occupational safety and health plans that must meet at least all the requirements of federal OSHA standards (at which point OSHA can decide to suspend federal enforcement in certain areas covered by the state’s plan). Moreover, states can also enact rules covering hazardous situations not addressed by federal OSHA and can adopt other emergency rules under some nonoccupational category—say, public safety—without conflicting with OSHA’s requirements. Under Washington’s state plan, for instance, scrap operations such as Seattle Iron & Metals Corp. (Seattle) must comply with emergency plan requirements that cover floods, fires, and other disasters, explains Marc J. Sidell, vice president. Although Sidell doubts it will ever be necessary, the emergency plan keeps the company prepared to evacuate all its personnel to higher ground in case there’s a major flood.

(Check with your state’s department of labor or similar agency to determine which rules apply to your business. The 23 “state plan” states are listed on OSHA’s Web site at www.osha.gov/oshprogs/stateprogs. html.)

While having an emergency response plan can’t safeguard your company completely, it can help you minimize the likelihood of certain emergencies—through fire prevention efforts, for instance—and help reduce the damage caused by other disasters. This is one instance in which an ounce of prevention is truly worth a pound of cure.

Know Your Risks

Though there’s no model emergency contingency plan to follow—in part because each company faces different potential emergencies—you can start by following these four steps:

• Conduct a risk assessment to identify and prioritize the potential emergencies that threaten your particular site;
  
• Prepare an action plan—written procedures on how to respond to emergencies;
  
• Train your employees and acquire whatever equipment—such as fire extinguishers—that will help you respond better to emergencies; and
  
• Keep your emergency plan updated.
  

Taking a closer look at each of these steps, first identify the different emergencies that could occur at your operation. If your company is located near a river, for example, flooding should be on your list. If you operate in the Southeast, hurricanes could threaten your facility.

Seattle Iron & Metals, for one, kept the Pacific Northwest’s abundant rainfall in mind when identifying the hazards of using electrically powered equipment, explains Sidell. In addition to avoiding electrocution hazards, the company must be prepared for storm-related power outages. When those happen, equipment must be locked out and tagged to prevents injuries if the power comes on unexpectedly.

And don’t overlook the potential dangers that exist in the materials your firm processes. For aluminum recycler Imco Recycling Inc. (Irving, Texas), molten aluminum explosions are a major concern, notes Kimberly Querrey, manager of corporate safety and health. “We try to avoid having water in our facilities because of the explosion dangers of mixing molten aluminum and water. The other issue is that any material coming in could have fertilizer or contaminants on it, which could also cause an explosion.” In another case, if you handle potentially volatile materials such as magnesium turnings, then fire should be at the top of your list.

According to Vogler, in fact, fire is one of the most common threats to scrap operations due to torchcutting, welding, molten metal, and more. And it’s not enough to just say that your operation has potential fire hazards, you need to know the type of fire hazard—electrical fires are different and require different responses than, say, oil fires—and then have the appropriate type of extinguishers on hand, advises Medico.

To help identify your hazards, one useful step is to invite local firefighters to tour your operations. They may notice potential hazards that you may overlook. Plus, their familiarity with your facility and its materials could help prevent problems in the event of an emergency. Offering one cautionary tale, Vogler recounts the story of one processor that ended up with an even worse disaster when the fire department arrived and didn’t know how to extinguish a fire in titanium scrap. Had the firefighters been familiar with the company’s operations, their response may have been more appropriate and effective. “The key is communication—making sure you have a good rapport with your local fire department or emergency team to make sure that they understand the hazards of what you’re dealing with,” says Querrey.

It’s also a good idea to have a loss control representative from your insurance company examine your property, notes Ed Steele, custom accounts loss control executive of Wausau Insurance Cos. (Wausau, Wis.). Moreover, local and state environmental protection agency officials or first response-type organizations are good contacts for help with potential spills and spill cleanup, while local civil defense forces can point out safe areas where you can wait out tornados or other bad storms.

Put It in Writing

After compiling your list of potential emergencies, decide which of those you can take steps to prevent in the first place. While you can’t stop a hurricane, for instance, you can prevent fires. As Medico maintains, “Housekeeping is almost everything when it comes to fire hazards. If you keep your house in good order—no accumulation of debris that could become a kind of spontaneous combustion problem—then fire hazards become almost negligible.”

After outlining such preventive steps, the next challenge is to draft your action plan—written procedures on how to respond to the emergencies that could affect your operation. As Sidell asserts, “We want to keep from having any type of injuries. That costs the company a lot of money, so we have written plans and written training for every employee already rehearsed, forward and backward, before anything happens.” Querrey adds, “Proper planning prevents poor performance. In emergency planning, that’s really true—planning things out minimizes the damage and injury.”

Drafting your response procedures requires foresight—the ability to think ahead to a potential threat—as well as imagination—the ability to imagine yourself actually confronting the threat. Then you have to bring logic into play in order to devise a step-by-step response plan that minimizes both danger to your employees and damage to your operation.

It’s a good idea to involve your employees—or at least your plant managers and supervisors—in this process as their input can be invaluable. One strength of Hannibal Iron & Metal’s plan, Fletcher notes, is that the employees who know each area best are the ones to ensure its safety. “The people who are working in a specific division know what’s done to protect their areas,” he says. “We used a lot of their input.”

If you’ve faced disasters in the past, certainly draw on your experience as well as that of other processors. For instance, floods in 1993 and 1997 at Great Western Recycling Industries Inc. (St. Paul, Minn.) taught the company how to handle high water, notes Andrew Staebell, president. Records kept from the 1993 flood helped the firm gauge how high the waters could rise during last year’s flood. “The key element was understanding the topography of our site, and where the equipment was located,” he explains. “The thing about a flood is generally it’s predicted—you’re able to track the progress of a flood and the timeline at which it’s going to crest. It gradually comes in and gradually disappears, so you’re able to stage your work based on what areas are going to flood first—different elevations throughout the plant, heights of soil, work areas, machinery. We used our site drawings to know which areas to address first.”


Likewise, Louis Cohen & Son learned a great deal from its experience with the 1972 flood. About six years later, the Susquehanna River threatened to spill over its dykes again. This time, the company was ready. It had a plan to move all potentially affected equipment to a warehouse and secured parking area, away from the flood zone. Afterward, the company added water- and fireproof vaults, which saved documents during the 1993 fire.

Hannibal Iron & Metal also learned a thing or two in the 1993 Mississippi River flood. When it hit, the company wasn’t prepared for the speed and scale of the disaster, and it paid a hefty price, Fletcher notes. Now, however, the firm knows what the river can do, and it has response plans to deal with the next big flood, whenever it comes. And that’s a good thing. Every year since the 1993 flood, the river has risen near the plant.

As for what specific points to include in your response plan, that depends largely on the type of emergency you’re dealing with. Still, here are a few general questions to consider:
• What steps should employees follow to prepare buildings, material, property, and equipment for an emergency? One lesson Fletcher learned from his flood experience is that “anything like No. 2 heavy melt and above can remain in the yard if we stack it 20 or 30 feet high, create a dome effect, so when the waters hit, it’s not going to bust loose.”

• How much time should it take to complete each type of emergency response procedure?
  
• Which types of emergencies should employees try to address themselves and which should they avoid? For instance, small fires can perhaps be handled with a fire extinguisher, while larger fires should be left to professional firefighters. And since minutes often count in an emergency, it helps to know exactly who’s qualified to respond to particular problems. One scrap company requires emergency action personnel, who are trained in CPR, to wear easily identifiable colored hats or pins.
  
• If someone is injured, when should employees administer first aid and when should they defer to trained medical personnel? “We have emergency action teams,” Staebell explains. “If anyone is seriously injured, we have a process using radios to announce it to the office and get the basic information up there so we can call 911.” At the very least, Steele suggests, “Make sure to have a first-aid kit on hand, flashlights, and emergency items for injuries.”
• How are employees to evacuate different parts of your operation in an emergency? As part of this, don’t forget about visitors, suppliers, and vendors, all of whom won’t be familiar with your emergency response procedures. “Make sure you have a contingency plan for finding people who aren’t employees—vendors dropping off or picking up a load,” notes Vogler. “Have employees assigned to do a search.”
  

Also have a plan for how you’ll warn individuals out of earshot—either outside on widespread acreage or in loud areas of the plant—of impending disaster, says Steele. And consider conditions outside your yard as well. If your plant is on a shoreline, he posits, “what means of egress are available, how would you get off the island or peninsula? Say there’s only one bridge. Plan a strategy for getting off before severe weather or flooding conditions hit.”

As you develop your plan, try not to make it too complicated and paper-intensive, or employees might decide not to wade through all the details. “We’ve developed a lot of documentation for the implementation of safety and emergency plans,” says Tim Todd, environmental administrator for Schnitzer Steel Industries Inc. (Portland, Ore.). “We have such voluminous documentation that it can be hard to wade through it and find what you need. Our next step will be to pare back, get rid of the extraneous information, and have a document that’s more user-friendly.”

Get On the Training Train

Once you have your response plans in writing, the next step is training. After all, if your employees don’t know what they’re supposed to do, your plan isn’t much good.

An effective training program has three parts: initial training, practice, and repetitive training. The initial training involves explaining to employees the who, what, when, where, and how of the plan—in other words, all the specific steps and rules to follow if an emergency develops. Also important is the why—employees must understand the importance of and need for the emergency response plan.

Then, employees should physically go through the response procedures—practice them—to the extent possible. This walk-through will help ingrain the training and improve the chances that employees will respond correctly and effectively when an emergency strikes. As Querrey asserts, it’s key “to make sure that you’re constantly communicating and practicing these drills with employees. Oftentimes people develop a plan, it sits on a shelf, and when it comes time to do it, people don’t know what to do. It’s the execution of the plan that gets into difficulty.”

Taking that lesson to heart, Hannibal Iron & Metal practices its plan twice a year, in the winter and fall—the two seasons when the Mississippi is less likely to flood, notes Fletcher. This is one case where practice can make perfect. It can also give employees the knowledge and confidence to respond immediately and correctly. At Hannibal Iron & Metal, Fletcher notes, “As soon as we see the water at the 19- or 20-foot level, we implement our procedures and evacuate.” 

The last component of a good training program is repetition—you reinforce the procedures by continually repeating them at staff meetings, in company newsletters, in one-on-one conversations, and so on. “Training has to be ongoing because that helps all of the employees who are involved to be continuously refreshed on how to respond properly,” Querrey says.

Revise as Needed

One reason to continually discuss your emergency response plans is that they can change, especially if you come up with better procedures or if you think of new emergencies to add to your roster. And that brings us to the last element of a good emergency contingency plan—revise, update, and refine it as needed. No matter how prepared you think you are, there’s always room for improvement. So make it a habit to review your plan frequently.

Much of the improvements will come from internal sources—supervisors, managers, plant employees—though some external people and organizations can also offer helpful direction. Schnitzer Steel Industries, for example, received help on its emergency plan from its local fire department as well as neighboring plants. “We’ve attended a number of meetings with local businesses that have the same kinds of exposures we do, so we get a lot of input from managers of other facilities, and that’s really helped,” notes Todd. “The focus has been how to deal with environmental regulations, but we’ve expanded into emergency preparedness.”

An emergency response plan is one pivotal element in the preparedness equation. And though it’s not a panacea, it can certainly help you weather those unexpected storms—and fires and floods and so on—in the future. •