What does Emergency Management involve?
The first priority for any business is prevention of accidents and incidents. But when things to go wrong, good emergency management can limit the adverse effects of an incident.
The HSNO Act provides a number of tools to prevent or lessen the possibility of an emergency occurring (eg controls like Approved Handlers, Locations Test Certificates, Stationary Container Test Certificates) (link to pages). However, the primarily emergency management requirements are found in the Hazardous Substances (Emergency Management) Regulations. These regulations list three levels of emergency management requirements which change depending on the quantities of hazardous substances that you hold (ie. the level of potential risk).
The levels include requirements for the provision of:
- information (eg first aid instructions or spill response procedures)
- equipment (eg fire-extinguishers)
- emergency response plans.
Level 1
- Information - for example first aid directions or emergency response contact details on labels, should be clear and readily available so people know the effects of the substance and the remedies
Level 2
- Documentation - such as safety data sheets, should be made available so that people will know in advance the properties of the substance and what to do in an emergency
- Fire extinguisher requirements
Level 3
- Signage requirements
- Emergency response plans
- Secondary containment, or bunding, to contain spills
What Level of Emergency Management do I need?
This depends on the quantity of hazardous substances held at the location. The trigger quantities' for each class of hazardous substance for each level of emergency management are listed in the various schedules to the Emergency Management Regulations. Where a substance has more than one hazard classification, the required trigger is the lowest trigger quantity for those hazard classifications.
In the case of the fire extinguisher, emergency response planning and signage requirements, the trigger quantities are based on the aggregated quantity of all hazardous substances held at that location.
Labelling
Every container or package held at a location in excess of the trigger quantities listed in Schedule 1 of the Hazardous Substances (Emergency Management) Regulations must have emergency management information on the label or some other means of providing such information. This information must be available within 10 seconds.
See Labelling page for more information.
Where do Safety Data Sheets come in?
One means of complying with the documentation requirements (Level 2) is a Safety Data Sheet. These must be available for each substance held at a place of work when in excess of the trigger quantities in Schedule 2 of the Hazardous Substances (Emergency Management) Regulations.
Fire Extinguishers
Every place where explosive, flammable or oxidising substances are held above certain quantities must have the specified number of fire extinguishers as listed in Schedule 3 of the Emergency Management regulations. You do not need to add up the number of extinguishers required for all substances present. You only need the highest number specified for any hazardous substance present.
The regulations set out the minimum performance standard for fire extinguishers as well as details of where they should be located.
Additional fire fighting equipment is specified for tanks where large volumes of particularly hazardous substances (class 2.1.1 or 3.1) are stored. In these cases you will need a Test Certificate for the tank and your Test Certifier can advise what additional fire fighting equipment is needed.
Signage
Signage is required wherever the quantity of a substance held at a place of work exceeds the trigger quantities in Schedule 5 of the Hazardous Substances (Emergency Management) Regulations. Among other things, signs must indicate the action to be taken in an emergency.
Emergency Response Plans
Schedule 4 of the Hazardous Substances (Emergency Management) Regulations sets down the trigger quantities for Emergency Response Plans. A single plan is required for the place and it must cover all hazardous substances held, or likely to be held there.
The plan must identify:
- all likely emergencies that may arise due to the presence of the substances at the place. For each emergency, the plan must:
- describe the actions to be taken in an emergency
- identify the people responsible for these actions, their skills and responsibilities
- list emergency contact details
- identify the location and purpose of materials needed in an emergency
- provide information on the emergency management decision-making procedures and sequence of emergency response actions.
- additional firefighting equipment required or other emergency management facilities (eg, safety shower) or materials (e.g. neutralising agents).
The plan must be tested at least every 12 months or within 3 months of a change to the plan (including persons identified in the plan). Testing must demonstrate that every procedure or action in the plan is workable and effective. Records of testing must be kept for at least 2 years.
These plans can be part of other emergency planning documentation required under other legislation, such as the HSE Act.
ERMA New Zealand in association with the Department of Labour has produced a printable flip chart in pdf form that will aid you in setting up your response plans.
Download ERMA Flip Chart
Secondary containment
Secondary containment is required wherever liquid hazardous substances are held in quantities exceeding the trigger quantities listed in Schedule 4.
The specific requirements of a secondary containment system depend on the capacities of the containers, the hazardous properties of the substances and whether they are held above or below ground.
Secondary containment is designed to prevent the spread of hazardous substances following any incident, fire, spillage or leaks. It is provided to contain the substance and prevent any adverse effects on people or the environment.
Who is responsible for ensuring emergency management steps are in place?
For labelling and safety data sheet requirements, the supplier is primarily responsible for providing these with the substance, and ensuring they meet the required performance standards.
The Person in Charge is responsible for ensuring emergency management procedures are in place wherever threshold quantities are exceeded. This includes ensuring:
- the right number of adequate fire extinguishers are present and they are correctly located
- adequate emergency response plans are prepared, made available to staff and tested
- secondary containment is provided
- safety data sheets are available
- labelling requirements continue to be met.
Are there exclusions?
Dependent on the trigger quantities for the particular hazard classifications involved, small amounts may not need to meet all of the Emergency Management requirements. However, it is advisable to make yourself familiar with the hazards of all substances that you handle as well as the precautions to be taken.
If you transport hazardous substance you will need to ensure you meet the Land Transport rules. Hazardous substances that are in the fuel system, control systems or electrical systems of a vehicle, aircraft or ship are excluded from the HSNO regulatory requirements.
An example - Petrol
The table below depicts the Emergency Management requirements applying to a location holding petrol, according to the quantity held. You might wish to construct similar tables for your substances. (X = not required, O = required)
| Quantity held | <1L | 1L-5L | 5L-50L | 50L - 200L | 200L - 250L | 250 - 1000L | >1000L |
|---|---|---|---|---|---|---|---|
| Level 1 info | X | O | O | O | O | O | O |
| Level 2 info | X | X | O | O | O | O | O |
| Fire extinguisher (no.) | X | X | X | O(1) | O(2) | O(2) | O(2) |
| Signage | X | X | X | X | X | O | O |
| Emergency response plan | X | X | X | X | X | X | O |
| Secondary containment | X | X | X | X | X | X | O |