September is National Preparedness Month, an annual event to raise awareness about the importance of preparing for emergencies. As noted by the Federal Emergency Management Agency (FEMA), this month is a great time to take small steps to make a big difference in being prepared. In laboratories and other types of facilities where hazardous materials are handled, chemical spills are often the most common type of emergency encountered.
If a hazardous chemical was spilled at your facility, would employees know if they could clean it up themselves? Do they know what measures to take to manage different spill scenarios? Would they know who to call to make this determination?
It’s critical to be prepared for chemical spills as they can cause employee exposure to hazardous materials, lead to environmental contamination, result in significant financial losses, and damage an organization’s reputation.
There are many safety program elements to consider for adequate preparation when evaluating spill situations and planning for emergency responses. Among the top two are having the appropriate written procedures and conducting training on them.
Emergency Action Plans
A Plan must be developed and implemented with well-defined procedures, including those for determining how to respond in emergency situations. For research laboratories, OSHA typically requires an Emergency Action Plan. For companies that meet the criteria of a large quantity generator (LQG) of hazardous waste per the Environmental Protection Agency (EPA), a Contingency Plan is needed.
Regardless of the type of Plan, it should include information about which spills can be cleaned up in-house versus those that require assistance from a third-party, such as a waste vendor that is staffed with hazardous materials response-trained employees. This determination is often based on whether a spill is considered controlled or uncontrolled.
Controlled (incidental) spills are those that are easily managed by the individuals involved in the spill using supplies nearby or from a readily available spill kit. They pose minimal risk to the health and safety of personnel and there is no risk of an environmental release.
Specific procedures should be developed with step by step instructions for employees to mitigate a controlled spill, including materials to be used, protective clothing and equipment to be worn, and how to properly dispose of the waste. It should also be mentioned that if employees need to gather spill supplies, they must also have a buddy present when performing the clean-up.
An uncontrolled spill is often large in volume, but regardless of the size, a release that poses a risk to personnel and/or creates a hazardous atmosphere, would also be considered an emergency response situation. There may also be a possibility of fire, explosion, chemical reaction, or a release to the environment. Because of the potential risks associated with an uncontrolled spill, the first action is to evacuate and call for assistance from emergency services and/or a third-party vendor.
In addition to a company’s policy for determining the type of spill and proper response, the Plan should also include information on additional procedures including those listed below:
- Emergency contact information and how to alert others
- Details on addressing controlled spills and using spill kits
- Evacuation and how to account for employees after any emergency including spill events
- First aid for assisting exposed employees
Training
Spills may only be addressed by appropriately trained personnel, and the level of training required depends on the duties and the function employees would serve in an emergency response situation. OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard [29 CFR 1910.120], outlines the requirements designed to protect workers when responding to releases of hazardous substances.
Five levels of training are defined by the Standard that are summarized here:
- First Responder Awareness Level (FRAL): Respond by notifying the proper authorities
- First Responder Operations Level (FROL): Respond defensively to (potential) releases of hazardous substances to protect nearby persons, property, or the environment; contain the release from a safe distance, keep it from spreading, and prevent exposures
- Hazardous Materials Technician (HMT): Respond offensively to (potential) releases; approach and stop the hazardous substance release
- Hazardous Materials Specialist (HMS): Respond with and provide support to HMTs; have direct/specific knowledge of substances on site; may act as the site liaison with federal, state, local and other government authorities
- On-scene Incident Commander (IC): Assumes control of the incident scene
To help you determine which level of HAZWOPER applies to you and your employees, and their responsibilities in the event of a release, please visit our HAZWOPER FAQ webpage.
Often our clients have designated individuals that may be called on to make decisions about spill response. If this is the case at your organization, FROL training is required. This level of training is intended for employees who perform the functions identified below in the event of an unintentional release:
- Involvement in determining if a spill of a hazardous material is considered controlled or uncontrolled
- Response to hazardous material releases is defensive with the purpose of protecting nearby persons, property, or the environment from the effects of the release
- Responsibility for activities in addition to notifying and evacuating, but do not actively stop the release
We can help you with preparing for chemical spill emergencies, including developing an Emergency Action Plan or Contingency Plan. For information on plan development and the appropriate training required for your employees—contact us!
We are providing training over the next few weeks that may meet your facility’s needs: Emergency Response First Responder Operations Level (FROL) Annual Refresher Training in Safety Partners’ Bedford, MA office on September 11, 2025 and FROL Initial Training on October 2, 2025. If these offerings don’t work with your schedule, visit our EHS Training & Professional Development website for future dates or to schedule on-site training at your facility.
This blog was cowritten by Beth Graham, Safety Partners’ Director of Quality, Research, and Training and Kim E. Folger, Senior Training and Development Manager.
