Wood preservation facilities, general recommendations: chapter A-12

12. Environmental Emergency Notification and Contingency Planning

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Preparedness for emergencies is essential in any wood preservation facility. Hence, all wood preservation facilities should prepare and have readily available detailed contingency plans to ensure that response to spills and fires is quick, safe and effective.

It is recommended that all chemical discharge events be documented to improve future spill and fire contingency planning. Have the necessary documents including pesticide labels readily available (preferably in a firebox outside the facility entrance) for both facility workers and for emergency responders.

12.1 Environmental Emergency Notification

In the event of an environmental emergency or occurrence, such as an oil or chemical spill, federal and provincial/territorial authorities need to be notified.

Environmental Canada should be notified by calling the appropriate (local) 24-hour telephone number listed in Appendix III. Additional information regarding notification requirements under the Canadian Environmental Protection Act, 1999 and the Fisheries Act is available from the Environment Canada’s website.

The Environmental Emergency Regulations and its requirements are applicable for pesticides containing substances listed in Schedule 1 of CEPA 1999.

12.2 Spill Contingency Planning

Facilities using any of the substances listed in Schedule 1 of the Environmental Emergency Regulations may be required to submit information to the Minister of the Environment as well as prepare, implement and test environmental emergency (E2) plans. E2 plans help to prevent releases or to react quickly in the event of an uncontrolled, unplanned or accidental release of a regulated substance in order to minimize the impact on human health and the environment.

For more information on environmental emergencies and the requirement of E2 planning, refer to the Environment Canada website

For more information on the substances listed in Schedule 1 of the Environmental Emergency Regulations, refer to the Environment Canada website.

The Implementation Guidelines for Part 8 of the Canadian Environmental Protection Act, 1999 - Environmental Emergency Plans (update 2004) provide contextual information on Part 8 of CEPA 1999 and on the Environmental Emergency Regulations.

12.2.1 General Components

Facilities that are required to submit information to the Minister of the Environment as well as prepare, implement and test environmental emergency (E2) plans should use the Implementation Guidelines mentioned above.

Facilities that are not required to prepare E2 plans under either section 200 or section 199, Part 8 of CEPA 1999, can use the following general components as a basis for a contingency plan.

Although the details of a contingency plan are facility-specific, the following provisions are typical of most spill contingency plans. This can be adapted to individual facility conditions. It is recommended that the individual facility plan be filed with the authority and/or municipality that has jurisdiction over the facility.

A contingency plan should (but is not limited to)

1. Have policy, purpose and organizational structure.
2. Be geared to the most probable spill size.
3. Address the following phases of spill response:
   1. discovery and notification
   2. evaluation and initiation of action
   3. containment and countermeasures
   4. cleanup, mitigation and disposal
   5. documentation and cost accounting.
4. Clearly assign duties and roles to responsible personnel and organizations.
5. Outline equipment (including PPE) requirements for spill control.
6. Include procedures for updating the plan on a scheduled basis.
7. Outline training needs for personnel in prevention and response.
8. Coordinate with other chemical spill prevention plans and procedures if appropriate.
9. Be submitted to chemical suppliers and the cleanup consultant or contractor for review.
10. Subsequently be submitted to appropriate government agencies including the local fire department for review.
11. Be tested through drills and exercises to identify gaps and opportunities for improvement to the contingency plan.
12. Address other site-specific aspects as necessary.

12.2.2 Implementation Capability

A contingency plan should

1. Describe the location, capability and limitations of cleanup and containment equipment.
2. Pre-arrange for use of the best available cleanup and containment equipment.
3. Identify detailed response options and strategies.
4. Provide for training programs and regular practice sessions.
5. Identify communication requirements with police, fire departments and regulatory agencies.
6. Describe how communications will be maintained among all parties during response operations.
7. Describe steps to be taken as a routine precaution against spills.
8. Address human safety issues.
9. Assign selected personnel to respond to public and media calls.
10. Provide for sampling of and data collection about runoff waters.

It may be necessary to develop specific procedures for multi-preservative facilities. Procedures should be kept simple and direct to avoid confusion.

12.2.3 Environmental Protection and Other Liability Risks

A contingency plan should

1. Identify high-risk areas and operations.
2. Discuss expected chemical and physical behaviour of spill materials.
3. Identify and prioritize sensitive environments for protection.
4. Detail specific actions planned for minimizing damage to resources.
5. Define explicit standards for the components and extent of effective cleanup.
6. Include provisions for responding to spills under all anticipated weather conditions.
7. Pre-arrange all response capability needed for the estimated worst-case spill.

12.2.4 Examples of Action Steps

Safety of people is a prime concern. Before any action, you need to do a quick assessment of the situation to find the source of the spill and identify if there is an immediate danger to workers. Appropriate personal protective equipment should be put on immediately. A spill kit accompanied with appropriate PPE should be stored in a centralized area that is within ready access to the unloading pad, tank farm, treating cylinder and waste storage area. More than one spill kit may be required depending on the distance between these areas or other potential areas where spills could occur.

If a spill occurs, the following steps should be taken:

1. Stop the flow of preservative solutions or any liquids containing preservative components:
   1. Use common sense, always stay upwind of the spill.
   2. Act quickly.
   3. Shut off pumps, close valves, etc., if this can be done without risk.
   4. If applicable, shut down mechanical production systems first (e.g. lumber movement) to prevent injury.
2. Warn people in the immediate vicinity:
   1. Sound alarm.
   2. Do not allow unauthorized personnel to enter the area and remove all unauthorized personnel from the scene of the spill.
   3. Consult the pesticide label.
   4. Provide proper protective equipment for on-site personnel.
   5. Avoid any contact with skin, eyes, clothing or shoes.
3. Contain the spill:
   1. Act promptly.
   2. Block off drains, culverts and ditches.
   3. Surround spilled material with earth, peat, straw, sand, booms or commercial sorbents.
   4. Use a liquid-recovery type vacuum cleaner (or empty cylinder and vacuum pump) for recovery of pools.
4. Obtain assistance as needed from
   1. Company personnel (advise at earliest opportunity);
   2. Chemical suppliers;
   3. Fire/police/public works/highways department/contractors (depending on the situation).
5. Notify applicable government agencies:
   1. Prompt notification is especially important for spills that have entered or may enter receiving waters.
   2. Spills to marine waters require contact with Environment Canada.
   3. Spills to water bodies with fish or spills on or adjacent to First Nations lands require contact with Environment Canada and the provincial emergency program office.
   4. For all other spills, contact the provincial emergency program office.
6. Commence recovery, cleanup and restoration action:
   1. Recover pools using vacuum systems and contain recovered liquid for reuse.
   2. Use an inert absorbent to complete cleanup.
   3. Neutralize preservative solution spills, if appropriate, before recuperating them.
   4. Ensure compatibility of materials before using tanks for salvage purposes.
   5. Carry out cleanup and disposal in consultation with provincial and federal regulatory personnel.

12.3 Fire Contingency Planning

Precautions should be taken in the event that a fire occurs in the vicinity of preservative solutions. It is, therefore, important that wood preservation facilities devise an adequate contingency plan for fire protection. Proactive actions, like ensuring that preservatives are stored in fire-protected areas, is an example of a best practice to minimize fire impact.

Not all preservatives or their components are flammable, and they may behave differently in fires depending on their physical-chemical characteristics. All preservative substances can emit toxic fumes during fires. The contingency plan recommendations made here are of a general nature as outlined as acceptable solutions in the National Fire Code of Canada (always refer to last version available).

12.3.1 General Components

A fire contingency plan should

1. Be prepared in consultation with local fire authorities and be in accordance with Division B, Section 2.8 of the National Fire Code of Canada 2010 (NFCC) (8).
2. Describe policy, purpose and organizational structure with up-to-date contact lists.
3. Ensure that creosote, petroleum oil solutions (including PCP/oil solutions) and other flammable and combustible liquids are stored as per the applicable acceptable solutions outlined in the Division B, Part 4 of the NFCC (8).
4. Address medical and environmental aspects.
5. Be geared to the most probably affected area.
6. Address the following phases of fire response:
   1. discovery and notification
   2. evaluation and initiation of action
   3. cleanup, mitigation and disposal
   4. documentation and cost accounting.
7. Ensure that proper fire extinguishing agents are available in adequate quantities.
8. Clearly assign duties and roles to responsible personnel and organizations.
9. Include procedures for updating the plan on a scheduled basis.
10. Coordinate with other fire prevention plans and programs as appropriate.
11. Be submitted to local fire department for review and resubmitted when the plan is updated.
12. Be accompanied by a training program and emergency drill.
13. reviewed annually.
14. Be stored in accessible locations, including a fire proof box outside the entrance to the facility.

The NFCC 2010 also provides additional acceptable solutions outlined in

• Division B, Sentence 3.1.2.6-1 for Dangerous Goods
• Division B, Article 3.2.2.5 for Indoor Storage
• Division B, Article 3.3.2.9 for Outdoor Storage
• Division B, Article 4.1.5.5 for Flammable and Combustible Liquid
• Division B, Subsection 5.1.5 for Hazardous Processes and Operations

12.3.2 Action Steps

Fire contingency plans and defined action steps will be site-specific. Nonetheless, an overall strategy should include provisions to ensure that

1. Water can be used to cool fire-exposed containers.
2. Appropriate firefighting media are available:
   1. water blanket area
   2. water spray to suppress toxic dust and gases and to keep temperatures of other oxidizable material below that for ignition
   3. use of foam, dry chemical or carbon dioxide on oil fires
   4. other fire protection agents.
3. Firefighters are protected from dusts, gas and smoke emissions by the use of appropriate respirators approved by National Institute for Occupational Safety and Health (NIOSH) and National Fire Protection Association (NFPA).
4. An evacuation plan is prepared for populations with potential exposure to the smoke plume.
5. Contaminated runoff waters are contained.
6. The provincial emergency program office is notified if runoff waters could have entered receiving waters.
7. Clean-up has to be made in consultation with provincial and federal regulatory personnel. Note that ashes from treated wood should be considered a hazardous waste and disposed of as such.

A generic spill and fire contingency plan is available for Canadian treated wood manufacturer at Wood Preservation Canada Association.