MIT SPILL POLICY AND PROCEDURES

INTRODUCTION

PURPOSE

This document describes the procedures used by the Massachusetts Institute of Technology (MIT) staff and students to respond to spills or releases of chemicals or petroleum. These procedures are applicable to, and included within, the MIT Environmental Management System (EMS).

PROCESS OWNER:	APPROVED BY:
Lou DiBerardinis Director EHS Office	Jamie Lewis Keith Managing Director Environmental Programs / EHS Headquarters Office /Sr. Counsel

REASON FOR ISSUE

Policy Revised and Issued in EMS Format.

DESCRIPTION OF CHANGE

Policy Revised and Issued in EMS Format.

DISTRIBUTION:

EHS staff members
Facilities Operations Center
Emergency Response Group
Campus Police Department

I. GENERAL

MIT has established these procedures to be followed by different groups (Emergency Response Group (ERG) members, Campus Police officers, laboratory personnel, etc.) in response to threats or actual spills or releases of chemicals and/or petroleum. These procedures are communicated through various means (e.g., laboratory personnel are provided with spill response procedures in their department’s Chemical Hygiene Plan). These procedures are an integral part of MIT’s EH&S Management System.

II. DEFINITIONS

A Minor Spill is one in which ALL of the following conditions are met:

§	the responsible party is at the scene; and
§	the material spilled is known; and
§	the material spilled is not highly toxic; and
§	the quantity spilled is small; and
§	there is no fire hazard present; and
§	the spill is completely contained inside a building; and
§	the material has little or no potential to reach the environment (e.g., via a floor drain); and
§	the spill is not in a common area (e.g., a hallway) or other area accessible to the general public; and
§	advanced personnel protective equipment (i.e., more than gloves and a half-face respirator) is not needed to respond to the spill

 

A Major Spill is one in which ANY of the following conditions apply:

§	the responsible party is unknown (it’s an “orphan” spill); or
§	the material spilled is unknown; or
§	the material spilled is highly toxic; or
§	a large (or undetermined) quantity was spilled; or
§	a significant fire hazard may be present; or
§	the material has the potential to reach the environment (e.g., via a floor drain); or
§	the spill is in a common area (e.g., hallway) or other area accessible to the general public; or
§	advanced personnel protective equipment (more than gloves and a half-face respirator) is required to respond to the spill; or
§	a responder is unsure whether the spill should be considered “Minor” or “Major”.

III. ROLES AND RESPONSIBILITIES

The Industrial Hygiene Program (IHP) and the Environmental Management Program (EMP) have primary responsibilities within EHS in spill response situations.

• Industrial Hygiene provides hazard assessment on all chemical spills. For minor spills, IHP may provide cleanup advice or assistance.
  
• Environmental Management: 1) retains and manages the contractors who perform cleanup for major spills; 2) provides hazardous waste pick-up services for small spill cleanup materials; and 3) determines the need to, and where appropriate, makes release notifications to local, state, and federal authorities.
  
• EMP is the primary responder for all spills of mercury, petroleum, and hazardous waste.

IV. POLICY AND PROCEDURES

Minor Spills -

MIT policy is that minor, indoor spills of hazardous materials or waste that present no immediate threat to personal health or safety, or of being released to the environment, are to be cleaned up by the personnel responsible for the spill unless they are not comfortable doing so. Hazardous material users and hazardous waste generators must be aware of the properties of the materials they use and the waste they generate.

All chemical and petroleum spills must be reported. Notification for minor spills is generally made to the Operations Center (617-253-1500) or directly to EHS (617-452-EHSS). If the Operations Center receives the initial contact, they contact the Primary EHS on-call staff person. The EHS on-call staff person immediately notifies the IHP secondary on-call staff member when the primary on-call staff person is not an IHP staff. The IHP on-call staff member then responds to the scene of the spill and assesses the situation. The IHP staff person may page an EMP or RPP staff person for relevant assistance. Once assessment and clean up is complete, the IHP staff person notifies EHS senior managers and logs the details in the on-call logbook. EMP is contacted, and control of the response is deferred to EMP, if petroleum or mercury was released.

Major Spills -

Major spills are to be reported to the MIT emergency number (x100) or Operations Center (617-253-1500) immediately. If initial notification is made of a major spill, or if at any time during the spill response it is determined that the incident should be considered a “Major Spill”, EMP is contacted immediately to respond to the site. EMP will take control of the situation once they are on site, fully briefed, and accept control. EMP will defer to the ERG Incident Commander or the Cambridge Fire Department once either party is on site, fully briefed, and accepts control. EMP will determine if notification to outside authorities is required (and if so, will make the notification), will procure the services of an outside contractor is required, and will control the clean up work.

Communication among the affected parties, EHS Office and EP/EHO staff, and (if applicable) outside authorities will be handled by IHP during the assessment phase (in some cases both beginning and end) and EMP during the clean up phase. IHP will also conduct all monitoring that is required to give the “all clear” for an area to be reoccupied.

V. SUPPLEMENTARY INFORMATION

Attachment A (EHS incident log)

Attachment B (Spill Response Flow Chart)

Attachment C (Emergency Notifications Telephone Numbers)