clean up companies

[mfdsort]

We are seeking feedback on incident command protocols and would appreciate any insights you guy's might offer.

Where does an Incident Commanders liability end when turning a haz-mat scene over to a clean-up company?

what training documentation do you require from those companies.

Is insurance required and if so, how much?

Do you require them to have permits to transport hazardous waste and if not do you require a contract with someone who does hold those permits?

Do you need proof of hazardous waste storage permits?

Do you require documentation of proper disposal?

Anything you can provide will be appreciated.

Ken Reeves

[TEAM-1 Emergency Services]

I am the manager of a private E/R company in Ontario Canada. PLEASE DO YOUR HOME WORK SUCH AS YOU ARE NOW BEFORE HIRING A CONTRACTOR. Unbfortuanly in Ontario anyone with a bag of kittly litter and a shovel thinks they are in HazMat Response. Pre qualify the personnel and skills before doing work with or handing over responsiblity. If you have prior contact with the spill, you have ASSUMED CARE AND CONTOL AND MUST RELENQUISH RESPONSIBILITY TO A RESPONSIBLE PARTY, to avoid liabilty. If you want some protocol please email me and i will give you the goods and the horror.

Thanks,

Mitchell gibbs
Manager of Emergency Services
TEAM-1

------------------

[Ken Hanks]

In Connecticut, the State Department of Environmental Protection maintains a list of qualified clean-up contractors. In the event of a spill requiring clean-up, DEP is notified and responds to the scene. The generator is allowed to choose a contractor off the list if they do not have their own qualified (by DEP standards) in-house crew.

DEP wants to be the agency to coordinate the cleanup. The generator of the spill is responsible for the costs of clean up. If the generator cannot or refuses to pay the clean-up contractors, the State of Connecticut will pay and then recover the costs through the courts.

If the local FD calls a contractor and the generator does not pay, the FD is responsible for the costs.

The system works pretty good here. Most of the contractors that I have dealt with have been professional and prepared for the job.



------------------
Ken Hanks
Captain
Naugatuck FD
IAFF L1219

Instructor
Connecticut Fire Academy

[Steamer]

Ohio has a similar situation to Ken's in Connecticut. We generally have the Ohio EPA that responds to anything of a serious size, so we generally leave the contractor selection to the EPA. That way if the spiller "welches" on his responsibility to call a contractor, it's the EPA's ball to carry. They have much deeper pockets to prosecute these cases to get their money back.
You are definitely on the right track trying to recognize and resolve these issues before your under the gun, so to speak. Check with your state academy, or the NFA about their Hazmat Incident Commander course. Many of these issues come up during the course, and it teaches you to think on the fly when unforseen issue arise.

------------------
Steve Gallagher
Chillicothe (Ohio) Fire Department

[Robert Burke]

Most of your questions should be directed to your State Environmental Protection Agency. They keeps lists of contractors and oversee permits and waste disposal. The incident commander should oversee the operation until it concludes, if for no other reason than to make sure it gets done right. An incident occurred where the fire department turned the scene over to the contractor and left. The contractors did not wear proper protective equipment and personnel went down. The fire department was called back now for a rescue to treat contractor personnel who had now become victims. They further compounded the situation by not decontaminating the victims and contaminated three ER's.

[Deputy53]

I am a hazardous materials instructor as well as an owner of an Environmental Consultant company, 1st. you were the OIC at the site, Do you OWN the site??, if not then Did you hire the contractor??, once you turn the site back over to the owner thats where your "IC" ends.If there is gross contamination the DEP of your state will want to look over the site, if they have not done so already, The fire departmets job is to "DIKE, DAM & DIVERT" not to clean-up or oversee such a job.Any Questions please feel free to talk with someone who has been in the environmental industry fo over 15 years as well as a Deputy Fire Chief. Thanks

[Chris Stabile]

Our guidelines are to provide the responsible party with a list of EPA/DEP approved clean-up companies. It is the responsible parties job to contact one of the clean-up companies. We generally give them one hour to contact an clean-up co. As mentioned in a previous reply, if the FD calls the contracor, and the RP does not pay, the responsibility falls back to the FD.

[mfdsort]

Just a note to thank you guy's for your replies and to clarrify the situation we are in and where we are trying to go.
We currently maintain a list of prequalified clean-up contractors that we provide to people out in the streets in case they don't have a company already on contract.We never hire the companies ourselves.(in case of no responsible party the local EMA hires the clean-up co.)
We would like to determine some more concrete standards for the companies that we recommend.
1. How much insurance would it be prudent for us to require before that contractor is allowed to begin work?
2.What training levels should we require of the people who handle product?
3. Do you guy's stay on the scene through-out the clean-up operation to ensure safety?
Bear in mind that some clean-up operations last for days or weeks. If we do turn the operation over to the contractor, are we still responsible if he screws up?
4. Must we require a permit to transport Hazardous waste (or a contract with someone who does) from everyone who cleans up a site under our supervision?
These questions were brought to light when a production company responded to a spill of their product out on the roadway and wanted to save themselves thousands of dollars in clean-up costs by doing it themselves.They had a team trained to the technician level, but the questions I've posted here were the reasons we gave for not allowing them to do it. But now that we've done that, the standards need to be in black and white and the same for everybody.
Thanks again and please forgive the long post.
Ken Reeves

[Brian Johnson]

Ken:

I know you are looking for concrete answers but I think your approaching it all wrong. Your job is to protect the People first, then do what you can to protect the Environment and Property. Once the spill is contained and can no longer hurt people your job is over. You should have a county and or state EPA that handles all of the clean-up questions.

Even if the RP is going to hire a contractor or clean it up themselves it is the responsibilty of the County or State EPA to determine if it is being done properly.

Upon confirmation of a HazMat incident your dispatch should automatically be dialing your County or State EPA to come down to the scene. They should handle it for you once the emergency is over.

This procedure should be spelled out for you in your local area contingency plan. Check it out. If you do not have one then check out the states oil spill and hazardous substance plan. These plans all should be in place as they are needed to qualify for federal funding should the need arise.

Good Luck



------------------
Brian Johnson
Assistant Chief
Okinawa, Japan