If you’ve never had an unintended release of a hazardous material around your shop or on the golf course, pat yourself on the back. You have obviously been cautious, and attentive to safe procedures when handling those materials.
You’ve also been lucky.
It’s difficult to load, store, open, mix, transport and apply fertilizers, pesticides, soil amendments, fuel, and other materials over 100-plus acres of uneven terrain, many times a year, without unintentionally releasing some of that material, in a quantity greater than labeled rates, or to an area outside label recommendations. In other words, experiencing a chemical spill.
Eventually, it’s going to happen. And whether it’s a push rotary spreader half full of gypsum that tips over on the cart path or a 300-gallon sprayer full of preemergent herbicide that flips over coming off a tee box, they are both “chemical” spills that require action and cleanup.
I’m sure you’ve heard the adage “hope for the best, but plan for the worst.” It’s good advice for handling hazardous materials on the golf course. The first part is easy, but planning for the worst takes a little work. Let’s look at what’s involved in creating an Emergency Action Plan (EAP).
An Emergency Action Plan describes procedures for dealing with various types of emergencies. Although spilling a few pounds of gypsum on the cart path may not seem like an emergency, an EAP assures that all chemical spills are handled correctly. Following these five steps will help you reduce exposure and limit any negative impact of the spill:
- Evaluate the spill and rescue contaminated persons
- Confine the spill
- Report to responsible person or agency
- Secure the area of the spill
We’ll look at each step in the plan in more detail, but first, think about the potential hazardous consequences of a chemical spill. Knowing who, or what, could be at risk of injury or contamination gives context to each step, and helps you achieve the goal of your EAP, reducing the risk of harm to people and the environment.
Your first concern is for the health and safety of any people that might be exposed to a potentially toxic substance. This, of course, includes crew members working with the material at the time of the spill, but also other crew members or golfers in proximity to the spill. You also need to consider potential toxicity to the environment, including the turf in the immediate area of the spill, the soil below the spill and other areas, especially water features, the material could contaminate by runoff or washing.
A critical piece of information for determining the potential risk is to ascertain the material’s toxicity.
Labels and Safety Data Sheets give you all the specific information you need, to understand the hazards associated with a product. Looking at any product label you’ll quickly see the signal word – either “Warning” or “Danger” – as an indication of the relative severity of the hazard. The signal word tells you at a glance how dangerous the material is. If you see “Danger” and the skull-and-crossbones pictogram, be extremely careful because this product could be lethal. Every label also has a precautionary statement describing recommended measures to minimize risks associated with exposure to the chemical in case of an accidental spill. The precautionary statement also has other safety information, including PPE required for handling, use and cleanup; what to do in case of a fire; and first-aid treatments.
You’ll find the most detailed information in the product Safety Data Sheet. There are 16 sections to the new GHS (Globally Harmonized System) Safety Data Sheet, four of them have specific information you’ll need when responding to a spill.
Section 2 - Hazard Identification. Has the hazard class, for example “Flammable Liquid,” the signal word, pictograms giving a graphic indication of the type of hazard and the Precautionary Statement that is on the label.
Section 4 - First Aid. Instructions for administering first aid to exposed persons, including important symptoms/effects, acute, delayed; required treatment.
Section 5 - Firefighting Measures. Lists suitable extinguishing techniques, equipment; chemical hazards from fire.
Section 6 - Accidental Release Measures. List includes emergency procedures; protective equipment; proper methods of containment and cleanup. This section helps you distinguish a small or large spill when volume has a significant impact on the level of the hazard and suggested emergency procedures for evacuations and consulting other experts when needed.
This information, found on product labels and Safety Data Sheets, help you develop your Emergency Response Plan and put it into action. Now use those five steps to make up your Emergency Action Plan.
When a spill happens, or an unintended release of a hazardous material is detected, the first thing you should do is make a quick evaluation of the spill area and provide immediate assistance to anyone involved. You can quickly determine whether this is a minor spill or a major spill based on things like where the spill happened; what type of material has been released, gas, solid or liquid; approximately how much has been released; is there a fire or risk of a fire; has anyone been contaminated or injured. Use these guidelines to categorize the spill. The rest of your actions will be based on this determination.
Once you’ve made your evaluation of the situation, if material is still leaking, try to stop the discharge, then confine the spill. Depending on where the spill occurred you may need to close doors, cover floor drains and use soil or an absorbent to restrict movement of liquids. It’s a good idea to keep spill kits on hand with absorbent pads, pillows or loose absorbent material like kitty litter or floor-dri; PPE, gloves, goggles, boots; heavy plastic bags for cleanup; signage to warn others to stay clear. Remember, your primary goal is reducing the risk of harm to any individuals so make sure you are wearing proper PPE, and don’t contaminate yourself while trying to contain the spill.
Next, report the spill to a responsible person. This could be your safety coordinator, the superintendent or assistant superintendent, or possibly someone designated as leader of a response team. Be prepared to provide information on injured persons, the material spilled, estimated quantity and the location. In some cases, other agencies or medical assistance should be contacted. Obviously, if there is a fire that is too large for you to extinguish, call the local fire department.
Reporting requirements are established through the Emergency Planning and Community Right-to-Know Act (EPCRA). Any releases of a hazardous material in quantities greater than their corresponding Reportable Quantities (RQs) must be reported to state and local officials. Find contact information for your state at www.epa.gov/epcra/state-emergency-response-commissions-contacts and record it as part of your EAP along with your local fire department and any other local authorities you may need to contact.
For major spills, the area should be secured until an emergency response team arrives to make sure no one enters the spill area.
Cleanup should be performed by qualified persons with appropriate training, personal protective equipment and cleanup materials. Typical cleanup procedures include: waiting at least 30 minutes if volatile materials are present; wearing appropriate PPE to protect skin, eyes, and respiration; gently sweep or use damp towels to collect powders; absorb free liquids with towels or other absorbents; and collect waste and contaminated PPE for proper disposal. Cleanup for a major spill on turf may require the testing and removal of soil to a depth below the contamination.
These steps can be revised and edited to write a EAP for your course. Include specific information about your location and responsible parties, a copy of your hazardous materials inventory, the location of SDS book, and contact information for state and local agencies.
Once you’ve developed your Emergency Action Plan, share it with your crew and hold mock accident training sessions. Hopefully you’ll never have a chemical spill, but that’s just hoping for the best.