1.5 Hazardous Materials Management
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- Nigel Wade
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1 Envirnmental, Health, and Safety (EHS) Guidelines 1.5 Hazardus Materials Management Applicability and Apprach...36 General Hazardus Materials Management...37 Hazard Assessment...37 Management Actins...37 Release Preventin and Cntrl Planning...38 Occupatinal Health and Safety...38 Prcess Knwledge and Dcumentatin...39 Preventive Measures...39 Hazardus Materials Transfer...39 Overfill Prtectin...39 Reactin, Fire, and Explsin Preventin...40 Cntrl Measures...40 Secndary Cntainment (Liquids)...40 Strage Tank and Piping Leak Detectin...41 Undergrund Strage Tanks (USTs)...41 Management f Majr Hazards...42 Management Actins...42 Preventive Measures...43 Emergency Preparedness and Respnse...44 Cmmunity Invlvement and Awareness...44 Applicability and Apprach These guidelines apply t prjects that use, stre, r handle any quantity f hazardus materials (Hazmats), defined as materials that represent a risk t human health, prperty, r the envirnment due t their physical r chemical characteristics. Hazmats can be classified accrding t the hazard as explsives; cmpressed gases, including txic r flammable gases; flammable liquids; flammable slids; xidizing substances; txic materials; radiactive material; and crrsive substances. Guidance n the transprt f hazardus materials is cvered in Sectin 3 f this dcument. When a hazardus material is n lnger usable fr its riginal purpse and is intended fr dispsal, but still has hazardus prperties, it is cnsidered a hazardus waste (see Sectin 1.4). This guidance is intended t be applied in cnjunctin with traditinal ccupatinal health and safety and emergency preparedness prgrams which are included in Sectin 2.0 n Occupatinal Health and Safety Management, and Sectin 3.7 n Emergency Preparedness and Respnse. Guidance n the Transprt f Hazardus Materials is prvided in Sectin 3.5. This sectin is divided int tw main subsectins: General Hazardus Materials Management: Guidance applicable t all prjects r facilities that handle r stre any quantity f hazardus materials. Management f Majr Hazards: Additinal guidance fr prjects r facilities that stre r handle hazardus materials at, r abve, threshld quantities 39, and thus require special treatment t prevent accidents such as fire, explsins, leaks r spills, and t prepare and respnd t emergencies. The verall bjective f hazardus materials management is t avid r, when avidance is nt feasible, minimize uncntrlled releases f hazardus materials r accidents (including explsin and fire) during their prductin, handling, strage and use. This bjective can be achieved by: 39 Fr examples, threshld quantities shuld be thse established fr emergency planning purpses such as prvided in the US Envirnmental Prtectin Agency. Prtectin f Envirnment (Title Threshld quantities are prvided in the US Envirnmental Prtectin Agency. Prtectin f Envirnment (Title 40 CFR Parts 68, 112, and 355). APRIL 30,
2 Envirnmental, Health, and Safety (EHS) Guidelines Establishing hazardus materials management pririties based n hazard analysis f risky peratins identified thrugh Scial and Envirnmental Assessment; Where practicable, aviding r minimizing the use f hazardus materials. Fr example, nn-hazardus materials have been fund t substitute asbests in building materials, PCBs in electrical equipment, persistent rganic pllutants (POPs) in pesticides frmulatins, and zne depleting substances in refrigeratin systems; Preventing uncntrlled releases f hazardus materials t the envirnment r uncntrlled reactins that might result in fire r explsin; Using engineering cntrls (cntainment, autmatic alarms, and shut-ff systems) cmmensurate with the nature f hazard; Implementing management cntrls (prcedures, inspectins, cmmunicatins, training, and drills) t address residual risks that have nt been prevented r cntrlled thrugh engineering measures. General Hazardus Materials Management Prjects which manufacture, handle, use, r stre hazardus materials shuld establish management prgrams that are cmmensurate with the ptential risks present. The main bjectives f prjects invlving hazardus materials shuld be the prtectin f the wrkfrce and the preventin and cntrl f releases and accidents. These bjectives shuld be addressed by integrating preventin and cntrl measures, management actins, and prcedures int day-t-day business activities. Ptentially applicable elements f a management prgram include the fllwing: Hazard Assessment The level f risk shuld be established thrugh an n-ging assessment prcess based n: The types and amunts f hazardus materials present in the prject. This infrmatin shuld be recrded and shuld include a summary table with the fllwing infrmatin: Name and descriptin (e.g. cmpsitin f a mixture) f the Hazmat Classificatin (e.g. cde, class r divisin) f the Hazmat Internatinally accepted regulatry reprting threshld quantity r natinal equivalent 40 f the Hazmat Quantity f Hazmat used per mnth Characteristic(s) that make(s) the Hazmat hazardus (e.g. flammability, txicity) Analysis f ptential spill and release scenaris using available industry statistics n spills and accidents where available Analysis f the ptential fr uncntrlled reactins such as fire and explsins Analysis f ptential cnsequences based n the physicalgegraphical characteristics f the prject site, including aspects such as its distance t settlements, water resurces, and ther envirnmentally sensitive areas Hazard assessment shuld be perfrmed by specialized prfessinals using internatinally-accepted methdlgies such as Hazardus Operatins Analysis (HAZOP), Failure Mde and Effects Analysis (FMEA), and Hazard Identificatin (HAZID). Management Actins The management actins t be included in a Hazardus Materials Management Plan shuld be cmmensurate with the level f 40 Threshld quantities are prvided in the US Envirnmental Prtectin Agency. Prtectin f Envirnment (Title 40 CFR Parts 68, 112, and 355). APRIL 30,
3 Envirnmental, Health, and Safety (EHS) Guidelines ptential risks assciated with the prductin, handling, strage, and use f hazardus materials. Release Preventin and Cntrl Planning Where there is risk f a spill f uncntrlled hazardus materials, facilities shuld prepare a spill cntrl, preventin, and cuntermeasure plan as a specific cmpnent f their Emergency Preparedness and Respnse Plan (described in mre detail in Sectin 3.7). The plan shuld be tailred t the hazards assciated with the prject, and include: Training f peratrs n release preventin, including drills specific t hazardus materials as part f emergency preparedness respnse training Implementatin f inspectin prgrams t maintain the mechanical integrity and perability f pressure vessels, tanks, piping systems, relief and vent valve systems, cntainment infrastructure, emergency shutdwn systems, cntrls and pumps, and assciated prcess equipment Preparatin f written Standard Operating Prcedures (SOPs) fr filling USTs, ASTs r ther cntainers r equipment as well as fr transfer peratins by persnnel trained in the safe transfer and filling f the hazardus material, and in spill preventin and respnse SOPs fr the management f secndary cntainment structures, specifically the remval f any accumulated fluid, such as rainfall, t ensure that the intent f the system is nt accidentally r willfully defeated Identificatin f lcatins f hazardus materials and assciated activities n an emergency plan site map Dcumentatin f availability f specific persnal prtective equipment and training needed t respnd t an emergency Dcumentatin f availability f spill respnse equipment sufficient t handle at least initial stages f a spill and a list f external resurces fr equipment and persnnel, if necessary, t supplement internal resurces Descriptin f respnse activities in the event f a spill, release, r ther chemical emergency including: Internal and external ntificatin prcedures Specific respnsibilities f individuals r grups Decisin prcess fr assessing severity f the release, and determining apprpriate actins Facility evacuatin rutes Pst-event activities such as clean-up and dispsal, incident investigatin, emplyee re-entry, and restratin f spill respnse equipment. Occupatinal Health and Safety The Hazardus Materials Management Plan shuld address applicable, essential elements f ccupatinal health and safety management as described in Sectin 2.0 n Occupatinal Health and Safety, including: Jb safety analysis t identify specific ptential ccupatinal hazards and industrial hygiene surveys, as apprpriate, t mnitr and verify chemical expsure levels, and cmpare with applicable ccupatinal expsure standards 41 Hazard cmmunicatin and training prgrams t prepare wrkers t recgnize and respnd t wrkplace chemical hazards. Prgrams shuld include aspects f hazard identificatin, safe perating and materials handling prcedures, safe wrk practices, basic emergency prcedures, and special hazards unique t their jbs. 41 Including: Threshld Limit Value (TLV ) ccupatinal expsure guidelines and Bilgical Expsure Indices (BEIs ), American Cnference f Gvernmental Industrial Hygienists (ACGIH), U.S. Natinal Institute fr Occupatinal Health and Safety (NIOSH), Permissible Expsure Limits (PELs), U.S. Occupatinal Safety and Health Administratin (OSHA), S&p_id=9992; Indicative Occupatinal Expsure Limit Values, Eurpean Unin, and ther similar surces. APRIL 30,
4 Envirnmental, Health, and Safety (EHS) Guidelines Training shuld incrprate infrmatin frm Material Safety Data Sheets 42 (MSDSs) fr hazardus materials being handled. MSDSs shuld be readily accessible t emplyees in their lcal language. Definitin and implementatin f permitted maintenance activities, such as ht wrk r cnfined space entries Prvisin f suitable persnal prtectin equipment (PPE) (ftwear, masks, prtective clthing and gggles in apprpriate areas), emergency eyewash and shwer statins, ventilatin systems, and sanitary facilities Mnitring and recrd-keeping activities, including audit prcedures designed t verify and recrd the effectiveness f preventin and cntrl f expsure t ccupatinal hazards, and maintaining accident and incident investigatin reprts n file fr a perid f at least five years Prcess Knwledge and Dcumentatin The Hazardus Materials Management Plan shuld be incrprated int, and cnsistent with, the ther elements f the facility ES/OHS MS and include: Written prcess safety parameters (i.e., hazards f the chemical substances, safety equipment specificatins, safe peratin ranges fr temperature, pressure, and ther applicable parameters, evaluatin f the cnsequences f deviatins, etc.) Written perating prcedures Cmpliance audit prcedures 42 MSDSs are prduced by the manufacturer, but might nt be prepared fr chemical intermediates that are nt distributed in cmmerce. In these cases, emplyers still need t prvide wrkers with equivalent infrmatin. Preventive Measures Hazardus Materials Transfer Uncntrlled releases f hazardus materials may result frm small cumulative events, r frm mre significant equipment failure assciated with events such as manual r mechanical transfer between strage systems r prcess equipment. Recmmended practices t prevent hazardus material releases frm prcesses include: Use f dedicated fittings, pipes, and hses specific t materials in tanks (e.g., all acids use ne type f cnnectin, all caustics use anther), and maintaining prcedures t prevent additin f hazardus materials t incrrect tanks Use f transfer equipment that is cmpatible and suitable fr the characteristics f the materials transferred and designed t ensure safe transfer Regular inspectin, maintenance and repair f fittings, pipes and hses Prvisin f secndary cntainment, drip trays r ther verflw and drip cntainment measures, fr hazardus materials cntainers at cnnectin pints r ther pssible verflw pints. Overfill Prtectin Overfills f vessels and tanks shuld be prevented as they are amng the mst cmmn causes f spills resulting in sil and water cntaminatin, and amng the easiest t prevent. Recmmended verfill prtectin measures include: Prepare written prcedures fr transfer peratins that includes a checklist f measures t fllw during filling peratins and the use f filling peratrs trained in these prcedures Installatin f gauges n tanks t measure vlume inside Use f dripless hse cnnectins fr vehicle tank and fixed cnnectins with strage tanks APRIL 30,
5 Envirnmental, Health, and Safety (EHS) Guidelines Prvisin f autmatic fill shutff valves n strage tanks t prevent verfilling Use f a catch basin arund the fill pipe t cllect spills Use f piping cnnectins with autmatic verfill prtectin (flat valve) Pumping less vlume than available capacity int the tank r vessel by rdering less material than its available capacity Prvisin f verfill r ver pressure vents that allw cntrlled release t a capture pint Reactin, Fire, and Explsin Preventin Reactive, flammable, and explsive materials shuld als be managed t avid uncntrlled reactins r cnditins resulting in fire r explsin. Recmmended preventin practices include: Strage f incmpatible materials (acids, bases, flammables, xidizers, reactive chemicals) in separate areas, and with cntainment facilities separating material strage areas Prvisin f material-specific strage fr extremely hazardus r reactive materials Use f flame arresting devices n vents frm flammable strage cntainers Prvisin f grunding and lightning prtectin fr tank farms, transfer statins, and ther equipment that handles flammable materials Selectin f materials f cnstructin cmpatible with prducts stred fr all parts f strage and delivery systems, and aviding reuse f tanks fr different prducts withut checking material cmpatibility Strage f hazardus materials in an area f the facility separated frm the main prductin wrks. Where prximity is unavidable, physical separatin shuld be prvided using structures designed t prevent fire, explsin, spill, and ther emergency situatins frm affecting facility peratins Prhibitin f all surces f ignitin frm areas near flammable strage tanks Cntrl Measures Secndary Cntainment (Liquids) A critical aspect fr cntrlling accidental releases f liquid hazardus materials during strage and transfer is the prvisin f secndary cntainment. It is nt necessary fr secndary cntainment methds t meet lng term material cmpatibility as with primary strage and piping, but their design and cnstructin shuld hld released materials effectively until they can be detected and safely recvered. Apprpriate secndary cntainment structures cnsist f berms, dikes, r walls capable f cntaining the larger f 110 percent f the largest tank r 25% percent f the cmbined tank vlumes in areas with abve-grund tanks with a ttal strage vlume equal r greater than 1,000 liters and will be made f impervius, chemically resistant material. Secndary cntainment design shuld als cnsider means t prevent cntact between incmpatible materials in the event f a release. Other secndary cntainment measures that shuld be applied depending n site-specific cnditins include: Transfer f hazardus materials frm vehicle tanks t strage in areas with surfaces sufficiently impervius t avid lss t the envirnment and slped t a cllectin r a cntainment structure nt cnnected t municipal wastewater/strmwater cllectin system Where it is nt practical t prvide permanent, dedicated cntainment structures fr transfer peratins, ne r mre alternative frms f spill cntainment shuld be prvided, such as prtable drain cvers (which can be deplyed fr the duratin f the peratins), autmatic shut-ff valves n strm water basins, r shut ff valves in drainage r sewer facilities, cmbined with il-water separatrs APRIL 30,
6 Envirnmental, Health, and Safety (EHS) Guidelines Strage f drummed hazardus materials with a ttal vlume equal r greater than 1,000 liters in areas with impervius surfaces that are slped r bermed t cntain a minimum f 25 percent f the ttal strage vlume Prvisin f secndary cntainment fr cmpnents (tanks, pipes) f the hazardus material strage system, t the extent feasible Cnducting peridic (e.g. daily r weekly) recnciliatin f tank cntents, and inspectin f visible prtins f tanks and piping fr leaks; Use f duble-walled, cmpsite, r specially cated strage and piping systems particularly in the use f undergrund strage tanks (USTs) and undergrund piping. If dublewalled systems are used, they shuld prvide a means f detecting leaks between the tw walls. Strage Tank and Piping Leak Detectin Leak detectin may be used in cnjunctin with secndary cntainment, particularly in high-risk lcatins 43. Leak detectin is especially imprtant in situatins where secndary cntainment is nt feasible r practicable, such as in lng pipe runs. Acceptable leak detectin methds include: Use f autmatic pressure lss detectrs n pressurized r lng distance piping Use f apprved r certified integrity testing methds n piping r tank systems, at regular intervals Cnsidering the use f SCADA 44 if financially feasible 43 High-risk lcatins are places where the release f prduct frm the strage system culd result in the cntaminatin f drinking water surce r thse lcated in water resurce prtectin areas as designated by lcal authrities. Undergrund Strage Tanks (USTs) 45 Althugh there are many envirnmental and safety advantages f undergrund strage f hazardus materials, including reduced risk f fire r explsin, and lwer vapr lsses int the atmsphere, leaks f hazardus materials can g undetected fr lng perids f time with ptential fr sil and grundwater cntaminatin. Examples f techniques t manage these risks include: Aviding use f USTs fr strage f highly sluble rganic materials Assessing lcal sil crrsin ptential, and installing and maintaining cathdic prtectin (r equivalent rust prtectin) fr steel tanks Fr new installatins, installing impermeable liners r structures (e.g., cncrete vaults) under and arund tanks and lines that direct any leaked prduct t mnitring prts at the lwest pint f the liner r structure Mnitring the surface abve any tank fr indicatins f sil mvement Recnciling tank cntents by measuring the vlume in stre with the expected vlume, given the stred quantity at last stcking, and deliveries t and withdrawals frm the stre Testing integrity by vlumetric, vacuum, acustic, tracers, r ther means n all tanks at regular intervals Cnsidering the mnitring grundwater f quality dwn gradient f lcatins where multiple USTs are in use Evaluating the risk f existing UST in newly acquired facilities t determine if upgrades are required fr USTs that will be cntinued t be used, including replacement with new systems r permanent clsure f abandned USTs. Ensuring that new USTs are sited away frm wells, 44 Supervisry Cntrl and Data Acquisitin 45 Additinal details n the management f USTs is prvided in the EHS Guidelines fr Retail Petrleum Statins. APRIL 30,
7 Envirnmental, Health, and Safety (EHS) Guidelines reservirs and ther surce water prtectin areas and fldplains, and maintained s as t prevent crrsin. Management f Majr Hazards In additin t the applicatin f the abve-referenced guidance n preventin and cntrl f releases f hazardus materials, prjects invlving prductin, handling, and strage f hazardus materials at r abve threshld limits 46 shuld prepare a Hazardus Materials Risk Management Plan, in the cntext f its verall ES/OHS MS, cntaining all f the elements presented belw. 47 The bjective f this guidance is the preventin and cntrl f catastrphic releases f txic, reactive, flammable, r explsive chemicals that may result in txic, fire, r explsin hazards. 48 Management Actins Management f Change: These prcedures shuld address: The technical basis fr changes in prcesses and peratins The impact f changes n health and safety Mdificatin t perating prcedures Authrizatin requirements Emplyees affected Training needs Cmpliance Audit: A cmpliance audit is a way t evaluate cmpliance with the preventin prgram requirements fr each prcess. A cmpliance audit cvering each element f 46 Threshld quantities shuld be thse established fr emergency planning purpses such as prvided in the US Envirnmental Prtectin Agency. Prtectin f Envirnment (Title 40 CFR Parts and 700 t 789). 47 Fr further infrmatin and guidance, please refer t Internatinal Finance Crpratin (IFC) Hazardus Materials Risk Management Manual. Washingtn, D.C. December The apprach t the management f majr hazards is largely based n an apprach t Prcess Safety Management develped by the American Institute f Chemical Engineers. the preventin measures (see belw) shuld be cnducted at least every three years and shuld include: Preparatin f a reprt f the findings Determinatin and dcumentatin f the apprpriate respnse t each finding Dcumentatin that any deficiency has been crrected Incident Investigatin: Incidents can prvide valuable infrmatin abut site hazards and the steps needed t prevent accidental releases. An incident investigatin mechanism shuld include prcedures fr: Initiatin f the investigatin prmptly Summarizing the investigatin in a reprt Addressing the reprt findings and recmmendatins A review f the reprt with staff and cntractrs Emplyee Participatin: A written plan f actin shuld describe an active emplyee participatin prgram fr the preventin f accidents. Cntractrs: There shuld be a mechanism fr cntractr cntrl which shuld include a requirement fr them t develp hazard materials management prcedures that meet the requirements f the hazardus materials management plan. Their prcedures shuld be cnsistent with thse f the cntracting cmpany and the cntractr wrkfrce shuld underg the same training. Additinally, prcedures shuld require that cntractrs are: Prvided with safety perfrmance prcedures and safety and hazard infrmatin Observe safety practices Act respnsibly Have access t apprpriate training fr their emplyees Ensure that their emplyees knw prcess hazards and applicable emergency actins APRIL 30,
8 Envirnmental, Health, and Safety (EHS) Guidelines Prepare and submit training recrds fr their emplyees t the cntracting cmpany Infrm their emplyees abut the hazards presented by their wrk Assess trends f repeated similar incidents Develp and implement prcedures t manage repeated similar incidents Training: Prject emplyees shuld be prvided training n Hazmat management. The training prgram shuld include: A list f emplyees t be trained Specific training bjectives Mechanisms t achieve the bjectives (i.e., hands-n wrkshps, vides, etc.) The means t determine whether the training prgram is effective Training prcedures fr new hires and refresher curses fr existing emplyees Preventive Measures The purpse f preventive measures is t ensure that safetyrelated aspects f the prcess and equipment are cnsidered, limits t be placed n the peratins are well knwn, and accepted standards and cdes are adpted, where they apply. Prcess Safety Infrmatin: Prcedures shuld be prepared fr each hazardus materials and include: Cmpilatin f Material Safety Data Sheets (MSDS) Identificatin f maximum intended inventries and safe upper/lwer parameters Dcumentatin f equipment specificatins and f cdes and standards used t design, build and perate the prcess Operating Prcedures: SOPs shuld be prepared fr each step f all prcesses r peratins within the prject (e.g. initial startup, nrmal peratins, temprary peratins, emergency shutdwn, emergency peratins, nrmal shutdwn, and start-up fllwing a nrmal r emergency shutdwn r majr change). These SOPs shuld include special cnsideratins fr Mazmats used in the prcess r peratins (e.g. temperature cntrl t prevent emissins f a vlatile hazardus chemical; diversin f gaseus discharges f hazardus pllutants frm the prcess t a temprary strage tank in case f emergency). Other prcedures t be develped include impacts f deviatins, steps t avid deviatins, preventin f chemical expsure, expsure cntrl measures, and equipment inspectins. Mechanical Integrity f prcess equipment, piping and instrumentatin: Inspectin and maintenance prcedures shuld be develped and dcumented t ensure mechanical integrity f equipment, piping, and instrumentatin and prevent uncntrlled releases f hazardus materials frm the prject. These prcedures shuld be included as part f the prject SOPs. The specific prcess cmpnents f majr interest include pressure vessels and strage tanks, piping systems, relief and vent systems and devices, emergency shutdwn systems, cntrls, and pumps. Recmmended aspects f the inspectin and maintenance prgram include: Develping inspectin and maintenance prcedures Establishing a quality assurance plan fr equipment, maintenance materials, and spare parts Cnducting emplyee training n the inspectin and maintenance prcedures Cnducting equipment, piping, and instrumentatin inspectins and maintenance Identifying and crrecting identified deficiencies APRIL 30,
9 Envirnmental, Health, and Safety (EHS) Guidelines Evaluating the inspectin and maintenance results and, if necessary, updating the inspectin and maintenance prcedures Reprting the results t management. Ht Wrk Permit: Ht wrk peratins such as brazing, trch-cutting, grinding, sldering, and welding are assciated with ptential health, safety, and prperty hazards resulting frm the fumes, gases, sparks, and ht metal and radiant energy prduced during ht wrk. Ht wrk permit is required fr any peratin invlving pen flames r prducing heat and/r sparks. The sectin f SOPs n ht wrk shuld include the respnsibility fr ht wrk permitting, persnal prtectin equipment (PPE), ht wrk prcedures, persnnel training, and recrdkeeping. Pre-Start Review: Prcedures shuld be prepared t carry ut pre-start reviews when a mdificatin is significant enugh t require a change in safety infrmatin under the management f change prcedure. The prcedures shuld: Cnfirm that the new r mdified cnstructin and/r equipment meet design specificatins Ensure that prcedures fr safety, peratin, maintenance, and emergency are adequate Include a prcess hazard assessment, and reslve r implement recmmendatins fr new prcess Ensure that training fr all affected emplyees is being cnducted Emergency Preparedness and Respnse When handling hazardus materials, prcedures and practices shuld be develped allwing fr quick and efficient respnses t accidents that culd result in human injury r damage t the envirnment. An Emergency Preparedness and Respnse Plan, incrprated int and cnsistent with, the facility s verall ES/OHS MS, shuld be prepared t cver the fllwing: 49 Planning Crdinatin: Prcedures shuld be prepared fr: Infrming the public and emergency respnse agencies Dcumenting first aid and emergency medical treatment Taking emergency respnse actins Reviewing and updating the emergency respnse plan t reflect changes, and ensuring that emplyees are infrmed f such changes Emergency Equipment: Prcedures shuld be prepared fr using, inspecting, testing, and maintaining the emergency respnse equipment. Training: Emplyees and cntractrs shuld be trained n emergency respnse prcedures. Cmmunity Invlvement and Awareness When hazardus materials are in use abve threshld quantities, the management plan shuld include a system fr cmmunity awareness, ntificatin and invlvement that shuld be cmmensurate with the ptential risks identified fr the prject during the hazard assessment studies. This shuld include mechanisms fr sharing the results f hazard and risk assessment studies in a timely, understandable and culturally sensitive manner with ptentially affected cmmunities that prvides a means fr public feedback. Cmmunity invlvement activities shuld include: Availability f general infrmatin t the ptentially affected cmmunity n the nature and extent f prject peratins, and the preventin and cntrl measures in place t ensure n effects t human health 49 Fr a cmprehensive treatment f the develpment f emergency respnse plans in cnjunctin with cmmunities refer t the Awareness and Preparedness fr Emergencies at Lcal Level (APELL) Guidelines available at: APRIL 30,
10 Envirnmental, Health, and Safety (EHS) Guidelines The ptential fr ff-site effects t human health r the envirnment fllwing an accident at planned r existing hazardus installatins Specific and timely infrmatin n apprpriate behavir and safety measures t be adpted in the event f an accident including practice drills in lcatins with higher risks Access t infrmatin necessary t understand the nature f the pssible effect f an accident and an pprtunity t cntribute effectively, as apprpriate, t decisins cncerning hazardus installatins and the develpment f cmmunity emergency preparedness plans. APRIL 30,
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