TRAFFIC INCIDENT MANAGEMENT IN HAZARDOUS MATERIALS SPILLS IN INCIDENT CLEARANCE
6.0 DOCUMENTED PRACTICES FOR HAZARDOUS MATERIALS INCIDENT CLEARANCE
In an attempt to ease traffic congestion during incidents involving a vehicular fluid spill or a hazardous materials cargo spill, some states have begun adopting regulations, disposal guidelines, and documented practices to help guide first responders. Table 8 presents highlights of incident management practices which have been implemented and used by other agencies. These highlights are not all inclusive of how an incident is handled, but they show unique efforts to improve clearance efforts for a hazardous materials spill. For instance, the highlights provide a glimpse of efforts by states to:
- Use quick clean-up techniques by first responders;
- Protect water resources by implementing quick clean-up techniques by first responders;
- Hire pre-designated private response contractors to handle the spill; and
- Improve coordination and preparedness efforts by DOT, police, fire, and tow operators.
Table 8 Incident Management Practices Implemented and Used by Other Agencies
- In situations involving vehicle fluid spills on a roadway, from both commercial and private vehicles, the preferred clean-up method is to soak up as much material as possible using absorbent materials. The absorbent materials are also moved out of the travel lanes and stored at the roadside, preferably well off the shoulder. In some cases, the material may be containerized and placed in the damaged vehicle(s) for removal by the towing company.
- DOT and other crash-scene responders may apply absorbents and sweep off travel lanes regardless of the quantity. It is not necessary to await a licensed clean-up contractor.
- Clean-up normally involves the use of granular absorbents or vermiculite, floor sweep, peat moss, pads and booms, clay, or topsoil. In limited situations, sand can also be used, but it is better suited for increasing friction than for use as an absorbent. If immediately available, an alternative method for dealing with the thin film that may remain after absorbents are used is to apply a light dusting with Portland cement.
- The responsible party is accountable for vehicle fluid spillage, including the final removal and proper disposal of absorbents and, if needed, the subsequent site remediation. If the responsible party does not or cannot handle this responsibility in a timely manner, the governing authority (State of Florida, county, city, etc.) will initiate disposal and the responsible party will be billed. Clean-up actions taken by early responders do not affect or limit this responsibility.
- Additional or incidental material spilled during the relocation of the vehicle out of the travel lanes of the roadway can be cleaned up and moved to the roadside with the other absorbents used at the scene. The responsible party remains accountable!
- Absorbent material moved out of travel lanes may be bagged in heavy-duty trash bags, wrapped or ‘diapered’ in plastic sheeting, or containerized in pails or barrels. The material should be well off the travel portion of the roadway and can remain there for a reasonable time to allow for disposal by the responsible party or a contractor (paid by the responsible party).
- The material may be placed in a container and placed in the damaged vehicles and removed by the towing company. The containers used to hold the material should be tagged and clearly marked to indicate the type of absorbent used and the material that was spilled. It is also desirable to indicate the responsible party. Care should be taken not to overload the containers used to store the absorbents. If trash bags are used, double bag and limit each bag to about 15 pounds.
- The reportable quantity of 25 gallons does not automatically prevent or limit on-scene actions to mitigate the spill. In fact, prompt intervention is encouraged to limit the congestion impact and prevent the high probability of secondary incidents as a result of extended traffic blockage. It is very important that every effort be made to limit the amount of time the spilled fluids are in contact with asphalt pavement.
- Vehicle Fluid Spill Clean-Up Quick Action Guide
- Identify spill as a vehicle fluid
- Stop leaking material at the source
- Contain and limit spill from spreading
- Apply available absorbents
- Sweep material off travel lanes
- Second application, if necessary
- Gradually restore traffic flow
- Identify responsible party and mark location of material
- Assure proper notification made to State Warning Point
- In situations involving a transportation accident/incident that results in a product/fuel spill, reporting and clean-up by the responsible party is necessary if:
- The amount of petroleum fuel spilled exceeds 25 gallons, or other reportable quantity according to Environmental Protection Agency (EPA) SARA Title III, Consolidated List of Chemicals25and/or
- The spilled materials have impacted or threaten to impact state waters.
- Where a transportation accident/incident results in a product/fuel spill, any accidental discharge to a sanitary sewer system must be reported immediately to the local sewer authority and the affected wastewater OSHA Permissible Exposure Limit31 treatment facility.
- If the spill has affected surface water, downstream water users should be notified immediately. This may be coordinated with the Colorado Department of Public Health and Environment (CDPHE) through the 24-hour spill reporting line.
- All appropriate actions should be taken to protect the incident scene, e.g., prevent vehicle/pedestrian access and move to a location upwind to await first response agencies. Persons should not attempt to mitigate or remediate the spill unless they have:
- Been properly trained and certified;
- The appropriate personnel protective equipment (PPE) available to them;
- The required support personnel available to effect an entry; and
- The response equipment necessary to stabilize the scene.
- First response agencies should make a good faith effort to stabilize the scene to keep the spill from spreading and affecting additional soil and water resources and other environmental receptors. Suggested actions include, but are not limited to:
- Covering the spill area with plastic,
- Placing absorbent booms in affected water,
- Placing clean soil berms and/or absorbent booms downhill of the spill and/or between the spill area and nearest waterway,
- Neutralizing or chemical stabilizing, if appropriate, and
- Diverting surface and storm water.
- Clean-up of spilled materials is required for any quantity of spilled fuel above the reportable quantity into soil or ground surface, and/or if the spill impacted soil, or has the potential to impact state waters. State OSHA Permissible Exposure Limit31waters include: lakes, reservoirs, ponds, streams, rivers, ditches, storm drains, manholes, wetlands, storm water, and ground water.
- Spills need to be remediated to CDPHE and EPA-approved thresholds where applicable, and to the strictest standards, where different. Other clean-up thresholds may depend on the material spilled, the media affected (soil, groundwater, surface water), and the risk of leaving the material in place. Clean-up thresholds need approval by Colorado DOT in order to issue a “No Further Action” determination to the responsible party.
- Excavation and off-site disposal is the preferred and most common method of soil remediation at Colorado highway spill sites. If excavation is not feasible or allowed, clean-ups may also include a variety of technologies, including, but not limited to, some combination of: excavation, air sparge, soil venting, bioremediation, steam cleaning, physical collection, and monitored natural attenuation.
- OSHA Permissible Exposure Limit31 – A closure report is required for all transportation incidents involving spills in excess of 100 gallons on property owned by the Colorado DOT. This report should be compiled by the responsible party or their designee after clean-up is complete.
- Texas DOT (TxDOT) personnel may only participate in containment, clean-up, or neutralization of material that has been determined to be non-hazardous to their health or safety.
- Texas Water Code requires that the Texas Commission on Environmental Quality (TCEQ) and TxDOT develop a contractual agreement whereby TxDOT may be used for spill and discharge clean-up throughout the state. The following conditions must be met:
- The TCEQ and TxDOT execute an Interagency Contract (IAC) each biennium that incorporates requirements of the Texas Water Code. A copy of this IAC is provided to each district.
- Clean-up activities performed under this contract generally are at locations off the right-of-way and at sites that TCEQ has assumed responsibility for clean-up actions. TxDOT personnel should comply with the requirements contained in the Occupational Safety Manual 32 when requested to handle oil and hazardous materials.
- Only trained personnel should ever approach a fire or a spill. Containment, clean-up, or neutralization of the hazardous material should be accomplished by individuals or organizations familiar with or trained in such activities. The following steps should be considered general guidelines and may not apply for all circumstances:
- Notify law enforcement and fire department of roadway accident.
- Survey the scene from a safe distance and determine the responsible person.
- Consult the USDOT Emergency Response Guidebook 7 for specific hazardous material information. From a safe distance, determine the integrity of the container(s), determine the existence or possibility of runoff, determine if any dead animals are near, evaluate the distressed nature of surrounding vegetation, evaluate any markings on containers, and assess the physical characteristics of the material (color, solid, liquid, powder, or granules).
- Using guidelines in the Emergency Response Guidebook,7 restrict access to the spill site. Keep the public away from the hazard. Provide traffic control, as needed.
- Notify supervisor by radio or telephone.
- Supervisor should notify local fire department, Department of Public Safety, and district hazardous materials coordinator. Supervisor should ensure that field personnel only conduct traffic control from a safe distance from the spill.
- Determine if a reportable discharge or spill has occurred and if so, the district hazardous materials coordinator should ensure TCEQ has been notified of the spill or release as soon as possible but not later than 24 hours after the discovery of the spill or discharge.
- Contracting (handled through District Maintenance or District Safety Office) : Contracting for clean-up, testing, and disposal is to be handled by:
- Third party—trucking company or manufacturer
- TCEQ—should they assume responsibility for the clean-up
- District—purchasing personnel with the assistance of the General Services Division Purchasing Section, if the responsible party is not taking appropriate actions or if TCEQ has not assumed responsibility for the clean-up.
- Hazardous Substance Spill Contingency Plan - The TCEQ is the lead agency in hazardous materials spill response. Emergencies involving spillage, release, and/or abandonment of known or suspected toxic/hazardous materials are the prime responsibility of the TCEQ. (Ref. Texas Water Code) It is important for TxDOT employees to remember that only trained personnel should ever approach a fire or spill. TxDOT personnel are specifically prohibited from handling, cleaning up, or otherwise coming in contact with toxic/hazardous materials at accident scenes or abandonment sites on TxDOT’s right-of-way. Doing so may adversely affect the health and/or safety of TxDOT personnel.
- The best practices for transportation agencies are to:
- Develop response protocols for freeway closures, which include pre-planned diversionary routes and traffic control in coordination with local public agencies. Meet with police, fire, and other local officials before incidents to review such plans.
- Install urban freeway reference markers at 2/10th-mile increments, which will allow cellular telephone callers to report incident locations with greater accuracy.
- Deploy freeway service patrol vehicles to remove debris from travel lanes and assist motorists who are broken down on the freeway shoulder or in travel lanes; include arrow boards to assist with traffic control for incidents.
- Create video links from traffic management centers to share with law enforcement and fire/rescue agencies. These video images can be used to minimize the amount of fire apparatus dispatched to a scene.
- Participate in the incident command system to communicate with fire and police agencies and advocate for the prompt clearance of the scene.
- Set up safe traffic control around the crash scene; divert traffic upstream of an incident through the use of changeable message signs; and provide traffic information to the media and general public.
- The best practices for law enforcement agencies are:
- Meet with fire and transportation agencies to review predetermined incident response plans.
- Within the unified incident command system, communicate with transportation agencies to establish traffic management/ detours, and direct a partial or complete reopening of the roadway as quickly as possible, under OSHA Permissible Exposure Limit.31
- For accident investigations, efficiently collect evidence and survey scene using Total Station equipment or aerial surveying.
- For minor (non-injury) crashes, have dispatchers provide guidance to drivers on local policy for moving vehicles from travel lanes and exchanging information as per state law.
- The best practices for fire and emergency medical agencies are:
- Dispatch the minimum amount of equipment necessary to reduce the exposure of personnel at the scene. (Fire agencies can be aided by the receipt of video images from DOT traffic management cameras).
- Use effective training in the identification of hazardous materials to avoid lengthy lane closures for materials that do not pose a threat to people or the environment.
- Use effective training in temporary traffic control around incidents in order to keep lane(s) of traffic open when possible. Use effective communications as part of the incident command system so that partner response agencies are aware of progress in rescue efforts and can make correct decisions regarding traffic management and provide traveler information to local media.
Commercial vehicle recovery involves unique considerations. Most importantly, commercial vehicle loads might still have value and there is an implicit right to salvage such cargo which can delay the prompt reopening of travel lanes. For recovery of some commercial loads, specialist companies are called in to handle a certain material, such as the case with a hazardous material or fuel spill. Other times, the trucking company or owner of the cargo will want to dispatch their own vehicles and personnel for the salvage operation. Involvement of such “third-party” recovery teams often takes inordinate amounts of time, depending on the distance of the company from the incident. Incidents involving hazardous materials, fuel spillage, and other pollutants may require oversight by the Ohio Environmental Protection Agency (OEPA) Emergency Response and local hazardous material handlers, where available. First responders involved with such an incident should call the OEPA Emergency Response Hotline.
- The best practices for towing and recovery include:
- Pre-qualification of towing companies by municipalities, so the towing company called to an incident scene has the capability to handle the vehicles involved.
- Training law enforcement in the Towing and Recovery Association of America’s vehicle identification guide to ensure the correct equipment can be requested and dispatched to the incident.
- Weighing the cost-benefit of calling in third-party recovery teams, if their distance/time of travel will have an excessive impact on the amount of time lanes remain closed.
- Moving commercial vehicles or trailers to the roadside or shoulder to restore as many travel lanes as possible, as soon as possible; then performing any necessary salvage operations after the peak hour
Pre-Incident Planning, Incident Command, and Major Incident Review
Repeatedly, in the course of developing these best practices, it was revealed that communication is the key to improving incident management practices. Often, agencies are unaware of the impacts their operations have on traffic or the value of communicating incident information which can be relayed to the public.
Pre-incident planning brings agencies together to review policies and best practices, so that all incident management operations can be carried out efficiently and safely when the need arises. The best practices for pre-incident planning are:
- Transportation agencies should pre-plan diversion routes, so that traffic control and detours are arranged as efficiently as possible when the need arises. Such pre-planning should include a review of practices for incident command, communication with local media, etc. Transportation agencies should have equipment on-hand to handle traffic control, such as arrow boards, portable message signs, etc. All agencies involved in incident management should meet regularly to review a transportation agency’s pre-planned diversionary routes and best practices and policy.
- OSHA Permissible Exposure Limit31
- Communicate with transportation agencies in the incident command structure, so that proper decisions can be made regarding traffic management;
- Assess and request the proper towing equipment in parallel with other activities, so that towing and salvage can begin as soon as possible;
- Provide regular updates to the media, who can help inform the public about road closures, detours, and expected duration of the incident.
Major Incident Review
It is unfortunate, but certain, that major traffic incidents will plague Ohio for the foreseeable future. Just as certainly, some incidents will not be handled as efficiently as possible, leading to increased exposure of incident responders, more traffic congestion delay, and secondary crashes. Best practices are:
- In an environment of mutual professional respect, hold meetings after major traffic incidents to review performance, decisions, policies, or procedures that conflicted with the goal of efficient incident management;
- Communicate the meeting results so as to resolve conflicts in future traffic incidents.
- CONTROL THE DISCHARGE (stopping the leak) - Procedures used to control the accidental discharge of motor vehicle fluids should be based upon the availability of a local fire department’s equipment and training related to these activities.
- CONTAIN THE DISCHARGE (preventing the spread) - Fire departments generally have equipment, such as shovels, absorbents, and plastic sheeting necessary to contain an accidental discharge of motor vehicle fluids (non-cargo). However, use of this equipment for containment activities also requires training at a minimum of the (HAZWOPER) Hazardous Materials Operations Level. In addition, the use of air-monitoring equipment, such as combustible gas indicators and photo ionization devices, is strongly recommended to provide for the health and safety of responders.
- RECOVERY OF MOTOR VEHICLE FLUIDS (clean-up and disposal)
- Recovery includes the following steps:
- Step 1 – Reporting the incident
- Step 2 – Determining the responsible party
- Step 3 – Determining the appropriate clean-up enforcement authority
- Step 4 – Cleaning up the discharge
- Step 5 – Disposing of contaminated materials
- CLEAN-UP EQUIPMENT RESUPPLY - There are several options available to allow fire departments to restock containment and clean-up supplies used during clean-up operations. These options, along with specific details to obtain resupply through the Virginia Department of Emergency Management (VDEM).
- The following discharges, when NOT a threat to navigable waters, are exempt from reporting requirements (exemptions are permitted under VA Code, Section 62.1-44.34:23):
- Accidental discharges [Editor’s note: meaning discharges of oil] from farm vehicles or noncommercial vehicles.
- Accidental discharges from the fuel tanks of commercial vehicles or vessels that have a fuel tank capacity of 150 gallons or less. For example, a commercial vehicle with two fuel tanks, each with 70-gallon capacity, has a total tank capacity of 140 gallons.
- CLEAN-UP PERFORMED BY A FIRE DEPARTMENT, WRECKER OPERATOR, PROPERTY OWNER, OR RESPONSIBLE PARTY
- Clean-up performed by a fire department, wrecker operator, property owner, or responsible party should be limited to spills of a magnitude within their capabilities.
- Clean-up normally involves the use of granular absorbents, pads and booms, and dispersants. Dispersants are chemical agents applied to the spill.
- The use of dispersants is regulated. Guidance on the use of dispersants can be obtained from VDEQ.
- LARGE amounts of granular absorbents should be used to safely clean-up spills of gasoline. This is necessary to reduce the concentration of gasoline’s benzene component to acceptable levels for personal safety and health.
- Biodegradable absorbents and absorbents that can release their contents when compressed (such as pads and booms) can only be disposed of in approved landfills as determined by VDEQ.
- Contaminated absorbent material and soil should be placed in a suitable container, such as large plastic trash bags (double lined for strength), five-gallon plastic pails, or recovery drums. Care must be taken not to overload the capacity of any container used to store contaminated absorbents.
- If possible, separate biodegradable and non-biodegradable absorbents into different containers. Non-biodegradable absorbents include “kitty litter,” soil, sand, and vermiculite.
- Each container should be securely sealed and clearly marked to indicate its content. Markings should include the type of absorbent used and the material absorbed. Also, if a fire department conducts the clean-up, a point-of-contact for the department should be included. The preceding information is critical to ensure proper disposal.
- DISPOSING OF CONTAMINATED MATERIALS
- It is recommended that personnel from fire departments, law enforcement organizations, and transportation departments SHOULD NOT take possession of contaminated materials.
- Contractors or the wrecker company that conduct clean-up operations will remove and dispose of contaminated materials in a lawful manner.
- Fire departments that conduct clean-up operations should attempt to have contaminated materials disposed of in any one of the following manners:
- Request that the wrecker operator remove the contaminated materials along with the vehicle being towed. - OR –
- Leave all containers on site for disposal by either the responsible party or property owner. Stage the containers off the roadway and, if possible, behind existing guardrails, or otherwise in protected areas delineated by road cones, barrier tape, etc.
- The California Highway Patrol (CHP) is the named Incident Commander (IC) on all freeways and most state routes. All communications will be through the IC.
- California Transportation Department (CalTrans) will take the lead to ensure proper clean-up of spills, but must confer with the appropriate jurisdictions, such as the County Health Officer, the County Agricultural Commission, and the Air Pollution Control District.
- If there is a disagreement between CalTrans and other responding agencies regarding closure or reopening of the roadway, the dispute will be resolved in favor of the maximum protection for the public and the CalTrans employees.
- If an emergency is declared, the IC has the authority to waive the Hazardous Waste Control laws to allow CalTrans or its agents to haul any amount of spill off the highway in order to eliminate gridlock and restore public safety.
- It is noted that CalTrans workers cannot work beyond their level of training or capabilities during hazardous materials emergencies.
- Principal tasks for handling a spill include:
- Safe approach
- Isolation and containment
- Identification and hazard assessment
- Clean-up and disposal
- Depending on conditions, clean-up may be preformed by a qualified person with a minimum training at the First Responder-Operational Level.
- The spiller of the material is responsible for mitigation and associated costs.
- All CalTrans personnel who may respond to a highway spill emergency must have received training in the Standardized Emergency Management System (SEMS) as appropriate for the level of responsibility.
- Responsibilities, training, and reporting requirements according are specifically spelled out for each level of authority.
- Clean-up responsibilities are primarily done by specialty contract either through the spiller or through CalTrans.
- The California Maintenance Manual specifically addresses gasoline spills and recommends not using CalTrans personnel. If it must be done, the following conditions must be met.
- The clean-up method involves no contact with the liquid or vapors.
- The spill occurs in a well ventilated outdoor area.
- Employees will work upwind of the spilled material.
- Clean-up methods will produce no sources of ignition.
- The CalTrans Maintenance program keeps a statewide database to track hazardous spills and costs.
NOTE: Information contained in this table was obtained by reviewing numerous documents, and selecting a cross section of incident management practices implemented and used by agencies. The following documents were used to highlight these practices:
- Florida – Guidelines For The Mitigation Of Accidental Discharges Of Motor Vehicle Fluids (Non-Cargo)33
- Colorado - Procedures for Hazardous Materials Spills That Occur on State and Federal Highways Within Colorado as a Result of a Highway Transportation Incident 34
- Texas - Maintenance Management Manual, Texas Department of Transportation, Revised Jan 200835
- Ohio - Ohio Quick Clear Best Practices Guide, March 200336
- Virginia – Guidelines For The Mitigation Of Accidental Discharges Of Motor Vehicle Fluids(Non-Cargo) Prepared By Virginia Department Of Emergency Management In Cooperation With Virginia Department Of Environmental Quality, Virginia Department Of Transportation, and the Virginia State Police. July 200037
- California--Chapter D5, Spills of Substance on Highway Rights of Way, California Department of Transportation Maintenance Manual.http://www.dot.ca.gov/hq/maint/manual/Ch_D5.pdf 38