Emergency Preparedness and Response - ISO 14001 Clause 4.4.7 - Aquaculture company

First of all, and since I'm new here, I would like to thank U all. I found so many usefull information. Although you covered almost all the topics concerning the 14001 standard, I still have a question about the requirement 4.4.7 of the standard. Actually I'm stuck!
I'm actually implementing the standard in an aquaculture company. We don't deal with hazardous materials unlike other industries (like petrochemical, etc..). So I find this requirement a little bit tricky since there are no specific emergencies or accidental release that could have a significant negative environmental impact. The only emergencies I can think of have to do with safety. We also did not have any incident in the past.

Any suggestion on how to satisfy this requirement?

Thank you in advance

Cecile

Yep...You must be able to respond to and mitigate any type of situation that could potentially or actually harm the environment.

Try looking at it from another direction? Sounds like you've got yourself hung up in one spot. Just because you've never had an incident (good for you, hope your streak holds) doesn't mean that you shouldn't be prepared. How would you handle a fire or an explosion? a medical incident (aquaculture-drowning?), what about weather emergencies (tornado, hurricane, blizzard, whatever your area throws at you)? of course you need to think about spills, what if the truck delivering to you should overturn and spill out a full tank of diesel?, terroristic threats? (ok, just like our facility, I cannot imagine someone trying to bomb us...but like they say "what about a disgruntled ex-employee?)If you still cannot think of anything, start searching the internet for incidents that involve aqua-culture facilities, maybe that will help?

Another incident that we just identified during our certification audit (we just passed the 2004 cert by the way!), is biohazardous waste. This can also safety related, for example if an employee has a severe injury resulting in a lot of blood, there is a potential environmental impact if the area and 1st aid supplies are not treated or disposed of properly (it's considered bio-hazardous waste in Canada, anyway). Not very likely, but we still need procedures in place to deal with the situation, should it occur.

Other than that, all the items that Steel listed could occur at pretty much any workplace in the world. Again, they may not be likely, but they still need to be identified and addressed.

Dean

Dear Friend,

You have raised an interesting question. The ISO-14001 system is applicable to those aspects which you can control or you can influence. Natural calamities are those on which you donot have any control or influence. I do not say that they are not important or not emergencies...my submission is that they are not the emergencies that ISO-14001, section 4.4.7 refer to. I would suggest that under the ISO-14001 system you formulate a framework for identifying potential environmental emergencies and accidents; that will help you to not only to meet the requirement of the system but also to prepare yourself for an emergency or accident that is applicable to your activities or services. For example, I use a questionnaire to identify potential emegency situations in our organization; if the answer to any of the questions is yes that situation is a potential emergency situation. The list may be improved with additions of new questions. Please see the questions below:


1.Does the situation result in actual or potential exposure of the nearby population, flora and fauna or food chain to hazardous/toxic substances or pollutants or contaminants ?
2.Does the situation result in actual or potential contamination of drinking water supplies or sensitive eco-systems ?
3.Does the situation result in an actual or potential threat of release of hazardous/toxic substances or pollutants or contaminants in drums, barrels, tanks or other bulk storage/transport carriers ?
4.Does the situation result in an actual or potential possibility of soil contamination by high levels of hazardous/toxic substances or pollutants or contaminants at the surface or near the surface that they might migrate ?
5.Does the situation result in actual or potential possibility of fire involving chemicals/oxidizing agents/explosives/dust giving out toxic fumes and smoke that may affect the nearby population, animals, food-chain etc.?
6. Does the situation warrant the preparation of "on site" and/or "off site" emergency plan as per the law of the land ?

It is possible that the above questionnair is not complete; please take the concept - that a framework is needed to identify as to what is emergency or not ? Otherwise, many extraneous issues get identified as "potential emergencies" under section 4.4.7 of ISO-14001. By the way, if natural calamities result in a "yes" to any of the questions that situation will be identified as a potential emergency situation under the system.

With best regards,

Ramakrishnan

Dr. L. Ramakrishnan said:

Dear Friend,

You have raised an interesting question. The ISO-14001 system is applicable to those aspects which you can control or you can influence. Natural calamities are those on which you donot have any control or influence. I do not say that they are not important or not emergencies...my submission is that they are not the emergencies that ISO-14001, section 4.4.7 refer to. Ramakrishnan

Click to expand...

You are correct in stating that we cannot control natural calamities, such as the weather, but respectfully, you are incorrect in stating that we do not need to have plans for their occurrence. If that weather emergency could create an environmental incident, and we can put measures into place to mitigate the problem, we need to have a control plan to cover it. For example: we are prone to hurricanes. We have advance warning as well as knowledge of what our potential "disasters" would be. Therefore, we have a plan of when to shut what areas off, how and when to close off and contain certain chemical storage areas, (as well as several pages of other things that need to be done). Natural calamity by your definition, but we can and do have to have an emergency action plan in place. If you lived near to us, you wouldn't want us to blow up the oxygen plant because we didn't have to have a plan in place for a weather emergency. Tornados, same thing, there are procedures in place for powering down areas if a tornado is sighted as the employees move to the shelters.

No matter what sort of natural calamity may befall a plant, there is some potential for an environmental emergency associated with it. Snow/ice from blizzards=overturned vehicles or a possible problem if the electricity goes off, any storm big enough to cause significant damage is something that can and should be considered in the emergency plan. Now, if it poses no threat environmentally, don't do anything, at least you can show that you looked into it and considered what the ramifications would be.

SteelMaiden said:

You are correct in stating that we cannot control natural calamities, such as the weather, but respectfully, you are incorrect in stating that we do not need to have plans for their occurrence. If that weather emergency could create an environmental incident, and we can put measures into place to mitigate the problem, we need to have a control plan to cover it. For example: we are prone to hurricanes. We have advance warning as well as knowledge of what our potential "disasters" would be. Therefore, we have a plan of when to shut what areas off, how and when to close off and contain certain chemical storage areas, (as well as several pages of other things that need to be done). Natural calamity by your definition, but we can and do have to have an emergency action plan in place. If you lived near to us, you wouldn't want us to blow up the oxygen plant because we didn't have to have a plan in place for a weather emergency. Tornados, same thing, there are procedures in place for powering down areas if a tornado is sighted as the employees move to the shelters.

No matter what sort of natural calamity may befall a plant, there is some potential for an environmental emergency associated with it. Snow/ice from blizzards=overturned vehicles or a possible problem if the electricity goes off, any storm big enough to cause significant damage is something that can and should be considered in the emergency plan. Now, if it poses no threat environmentally, don't do anything, at least you can show that you looked into it and considered what the ramifications would be.

Click to expand...

Dear Steel Maiden,

I fully appreciate and agree with you; please see my last sentence. To Quote: "By the way, if natural calamities result in a "yes" to any of the questions that situation will be identified as a potential emergency situation under the system"

I hope I understand you right. If the natural calamity can cause, say for example, leakage of a gas that can affect the population, flora, fauna around(when the answer is YES to one on of the questions) we have to identify that as a potential emergency situation. I hope I will be understood now - natural calamity itself is not an environmental emergency according to the system; the result of the natural calamity. which can cause an environmental impact of certain magnitude, is a potential emergency situation. I think that is what you are also saying in your last sentence.

Thank you for giving me this opportunity to clarify

With best regards,

Ramakrishnan

Cecile, I haven't had a lot of experience with aquaculture. In fact it's limited to being the engineer for the supplier of oxygen used to oxygenate incoming water for a salmon farm in Maine. They were required to have a minimum dissolved oxygen level in the stream leaving the facility and also controlled incoming oxygen levels to help assure efficient growth. Do you have similar requirements? I'm extrapolating from that situation.

Issues that could occur at that site would be low oxygen levels in the water leaving the facility or a sudden dump of excrement/waste from the fish being farmed into the stream. I do not remember if they used antibiotics or not, but there use at therapeutic levels could also be an environmental issue.

Just some thoughts. Just because you're not using hazardous chemicals does not mean you would not have a potential accident that could harm the environment.

Steel, you and the good Dr. are thinking pretty right on. To plan for potential emergencies requires "out-of-the-box" thinking. Many companies that don't handle or use so called hazardous materials stop at that point and say "nothing can happen".

But what can happen if delivery vehicles develop a fuel or coolant leak?

What can happen if the sewage line breaks?

What can happen if.......?

Organizations have to plan for the "if" situation.

Thanks, Dr., as I read the post the first (second and third) time, I kind of got stuck on the first para., and missed the meaning of the last. My bad.