Page 76 - Root Cause Failure Analysis

Regulatory Compliance Issues 67

Table 5-1 Major Regulatory Reporting Requirements for Chemical Spilk (continued)
Regulation Reference Reporting Requirements
HMTA Generally, the transporter of hazardous materials
(including wastes) must immediately report to the
NRC and the state response center a release during
transport if the release meets any of the following
criteria: causes death or serious injury, involves
more than $50,000 in property damage, involves
the release of radioactive materials or etiological
agents, requires public evacuation lasting at least
one hour, closes one or more “major transportation
artery or facility” for at least one hour, alters the
Right pattern or routine of an aircraft. Even if none
of these criteria are met, it should be reported if the
carrier believes a spill or incident poses “such a
danger” that it should be reported. Follow-up writ-
ten reports are due within 30 days. The carrier also
must file DOT Form 5800.1.
For all releases:
Always call 91 1 first to assure that first responders are dispatched to the scene to stabilize the release. ren-
der first aid, establish a perimeter, and extinguishhinimize the threat of fire or explosion.
Useful telephone numbers:
Coast Guard’s National Response Center (NRC): 800-424-8802
EPA’s national database of all toxic chemical release information: 800-638-8480
EPA’s Emergency Planning and Community Right-to-know Information Hotline: 800-535-0202
CFR = Code of Federal Regulations,
CWA = Clean Water Act,
EPCRA = Emergency Planning and Community Right-to-Know Act.
TSCA = Toxic Substance Control Act,
RCRA = Resource Conservation and Recovery Act,
HMTA = Hazardous Materials Transportation Act Source: Adapted by Integrated Systems. lnc..
from Environmental Compliance Nurionnl Edition (Issue No. 181. Business & Legal
Reports, Inc.. Madison, CT, Dec. 1996) and other sources.

This section summarizes the requirements for OSHA’s PSM of Highly Hazardous
Chemicals, Explosives, and Blasting Agents procedures for incident investigation
(CFR 1910, Part 11.9, Section m).

Incident Investigation Requirements
The regulation states:

The employer shall investigate each incident which results in, or could reasonably
have resulted in, a catastrophic release of highly hazardous chemicals into the
workplace.