Emergency response assistance plans

By: Candace A. Sellar, Royal Roads University

In my previous career as an Environmental Emergencies Officer, I spent a considerable amount of time surrounded by twisted and torn metal at train derailment sites with spills of hazardous materials (hazmat) from dangerous goods shipments.  “An estimated 12 percent of all goods carried by rail in Canada are hazardous materials” (Conway, 2006, para. 12) and these materials travel over “73,047 kilometers [sic] of railway tracks across the country posing a significant potential environmental risk from derailments and spills” (Duncan & Nowlan, 2008, p. 264).  One of the most notable spills in Canadian history was a chlorine gas release from the Mississauga, Ontario train derailment that occurred on November 10th, 1979.  The Mississauga derailment was a critical event as it focussed attention on the potential risk associated with transporting dangerous goods through our communities.  Quarantelli (1981) articulated the situation quite profoundly when he stated that “a community need not contain chemical producers to have potential chemical problems” (p. 3).  In order to address these rail related hazardous material problems, the Canadian Transportation of Dangerous Goods Act (TDGA) requires Emergency Response Assistance Plans (ERAPs).  This paper will examine ERAPs including a description of the planning practice, historical roots, and cultural influences.  In addition, this paper will outline the influence of the Mississauga derailment on the regulatory scene and examine the current state of hazmat rail emergency planning practice in Canada.

Emergency Response Assistance Plans (ERAPs)

ERAPs are important tools required by Transport Canada for addressing the preparedness and response requirements of hazmat releases caused by the derailment of trains carrying dangerous goods such as explosives, toxic gases, flammable gases, multiple hazards and poisons.   “Part 7 of the Transportation of Dangerous Goods Act 1992, requires that before a person offers for transport or imports certain dangerous goods, the person must have an approved Emergency Response Assistance Plan (ERAP)” (Transport Canada, 2009b, para. 2).  Dangerous good rail shipments requiring ERAPs demand expert knowledge and specialized response equipment during a spill that is typically beyond the capacity of the local responders.  The requirement for an ERAP forces the responsible party to conduct a Potential Accident Assessment (PAA), which “will help identify problems that could be encountered in the transportation cycle and determine which resources will be needed to mitigate an incident” (Transport Canada, 2009a, Potential Accident Assessment section, para. 1).  Consequently, an ERAP may be considered the first line of defence for local responders when arriving at the scene of a train derailment with a hazardous material release.  As Denis (2001) asserted,   “risk management begins with information” (p. 209), and ERAPs serve as vital source of information in an emergency.

ERAPs contain detailed information specific to the dangerous goods hazards onboard a derailed train–information proven to be essential to those first at the scene.  ERAPs provide information on plan activation (e.g. authority and key contact numbers), response capabilities, contacts of qualified experts, lists of specialized response equipment available for deployment, response actions to be taken, equipment and personnel logistical arrangements, and communication systems to be implemented.  These plans are empowering sources of information to local responders and are designed to eliminate uncertainty regarding “how a dangerous goods release could occur, how these materials could react under the circumstances and what actions can be undertaken to remedy the situation” (Transport Canada, 2009a, Introduction section, para. 5).  Without a doubt, the information contained in ERAPs is critical for minimizing local responder uncertainty regarding the hazmat emergency, promoting quick and effective response activities, and protecting the overall health and safety of those first at scene and in the surrounding community in which the derailment occurs.

Historical and Cultural Roots of ERAPs

Prior to the Transport Canada requirement for ERAPs, local responders operated predominantly in an information vacuum with great personal risk at the scene of a hazmat spill.  This information vacuum was in large part created by the disconnect of having a federally regulated railway system with the responsibility for railway emergency response left to the local municipality.  As a result, municipalities did not have the authority to directly obtain valuable shipment information from the rail operator.  Consequently, the local responders were not aware of the exact nature of the dangerous goods passing through their communities and as a result had very little information regarding the specialized responses required for complex hazmat releases.  Furthermore, “there appeared to be an information void regarding what each organization was really empowered and able to do, i.e., what the community could reasonably expect from each organization in the event of a major transportation accident involving chemicals” (Quarantelli, 1981, p. 33).  Local responders at the 1979 Mississauga train derailment faced all of these challenges, and as a result “the [ERAP] may be traced to the recommendations made by Justice Grange following the enquiry into the Mississauga train derailment” (Transport Canada, 2009b, para. 1).  As a result of the investigation, Justice Grange acknowledged that there was a significant information gap and subsequently “recommended that any shipper of dangerous goods must have a plan to control any release of dangerous goods in the event of an accident” (Transport Canada, 2009b, para. 1).  Thus the ERAPs came into existence and to this day need to be submitted and approved by the Minister of Transport and available to local responders.

The enquiry into the 1979 Mississauga train derailment was in part spurred by the media, public interest organizations, and citizen-based pressure following the massive emergency evacuation.  Prior to this event, many Canadians did not perceive the railways as high-risk.  However, post-event, public perception altered as “public concern about the risk of hazmat incidents [became] rather intense.  This [was] primarily due to the involuntary nature of the risk and the potential for significant consequences in the case of a rail hazmat incident” (Glickman, Erkut, & Zschocke, 2007, p. 1015).  Furthermore, “in every disaster, the effects on health . . . constitute the most vital and crucial uncertainty, the one that causes the most anxiety for communities” (Denis, 2001, p. 204).  Therefore, when you combine involuntary risk with uncertainty about the impacts of the hazard, the end result is a very concerned and politically active community.

Hence, in the case of dangerous goods spills from train derailments, this resulted in a cultural shift away from public non-awareness and a perception of satisfactory railway safety practices, to one of increased (albeit somewhat uninformed) awareness and a perception of increased risk.  This was likely exacerbated by Quarantelli’s (1981) prophetic observation that “there is also reason to suspect that actual and potential hazardous-in-transit accidents may be on the increase” (p. 8).

The Mississauga Train Derailment:  A Focussing Event

A significant catalyst for reform in the transportation of dangerous goods by rail was the aforementioned derailment of Canadian Pacific freight train 54, carrying thirty-eight cars of “cargo designated as hazardous, including chlorine, liquid petroleum products, and caustic soda” (Liverman & Wilson, 1981, p. 365), at the Mavis Road crossing in Mississauga, Ontario, late in evening on November 10th, 1979.  The derailment and subsequent chlorine gas release resulted in “the evacuation of a quarter of a million residents of the city of Mississauga… at that time, the largest peacetime evacuation ever conducted in North America” (Liverman & Wilson, 1981, p. 365).  Nevertheless, what made the Mississauga train derailment such a significant focussing event for change was how completely the event illustrated the vulnerability created by the hazmat information void and how desperately emergency planning was required in order to adequately prepare for and respond to such emergencies. “The key questions were, what had been on the train and what was in the wreck?  There was a critical need for information about what was there and information about how to deal with the problem; however, the uncertainty would last for days” (Scanlon, 1989, pp. 308).  “Even when the railway confirmed chlorine was in the wreckage, the frustration continued, because those in charge had no expertise in the chemical area” (Scanlon, 1989, p. 308) and “the loading note supplied by CP was a listing for information which nobody could read or understand” (Legadec, 1982, p. 2).  Consequently, the Mississauga train derailment “was Canada’s introduction to a major threat from toxic chemicals” (Scanlon, 1989, p. 304) and from a hazmat emergency planning and response perspective it was clear to all that it was an utter failure.  As a result, the Canadian Transport Commission (CTC) launched what was to become known as the Grange Enquiry and “the federal minister of transport announced he would introduce legislation on the control of transport of dangerous materials” (Legadec, 1982, p. 5).  This legislation resulted in the ERAPs that we know today.

The Current State of Rail Transport of Dangerous Goods in Canada

ERAPs transformed how and what information is shared at the time of a rail hazmat spill and vastly improved the associated emergency preparedness and response functions.  However, recent train derailments resulting in hazmat releases, such as the derailment which “dumped 700,000 litres of fuel oil and potentially cancer-causing wood preservative into Wabamun Lake near Edmonton” (Conway, 2006, para. 11), illustrate that many of the issues experienced at the 1979 Mississauga train derailment have re-emerged as issues today.  Transportation Safety Board investigation reports detail “inadequate labelling and reporting of potentially hazardous loads; and inadequate emergency response planning, training and supervision.” (Duncan & Nowlan, 2008, p. 269).  Duncan and Nowlan (2008) connected the re-emergence of these railway safety issues to an “increased resilience on industry self-reporting and voluntary compliance [as] a growing trend across Canadian enforcement agencies” (p. 267).  Based upon recent derailment events and as a result of intense public criticism, Transport Canada has revised the TDGA reinforcing the need for ERAPs, adding the requirement for security incidents to be considered in the PAA for ERAPs, developing requirements for dangerous goods transportation security clearances, and enabling “the drafting of regulations requiring that dangerous goods be tracked during transport [emphasis added] and that incidents involving loss or theft be reported” (“Government of Canada”, 2009).  In summary, although the TDGA has been enhanced, the value and importance of an ERAP at the scene of a hazmat rail spill remains unquestioned.

Conclusion

The development and implementation of ERAPs has become a successful process for closing the information void for local responders attending train derailments involving dangerous goods.   The Government of Canada has actively registered and approved ERAPs, and currently, “there are over 900 active ERAPs filed with Transport Canada” (Transport Canada, 2009b, para. 7).   ERAPs will continue to be relevant as “significantly increased rail traffic is projected across Canada and the United States east to west to serve the burgeoning North American trade with Asia” (Duncan & Nowlan, 2008, p. 267).  In closing, it is important to remember that “almost everyone in Canada lives within 50 kilometres of a railway of some kind” (Conway, 2006, para. 36), which indicates that we are all vulnerable to spills from dangerous goods rail shipments and beneficiaries of comprehensive Emergency Response Assistance Plans.

References

Conway, C. (2006). Long train running. Canadian Geographic, 126(2), 68-80. Retrieved from http://web.ebscohost.com.ezproxy.royalroads.ca/ehost/detail?vid=5&hid=13&sid=a2f91ba2-35e4-4adf-8385-6a9ceb7210e8%40sessionmgr12&bdata=JnNpdGU9ZWhvc3QtbGl2ZQ%3d%3d#db=aph&AN=19938908

Denis, H. (2001). Managing disasters involving hazardous substances in Canada: technical and sociopolitical issues. Journal of Hazardous Materials, 88(2/3), 195-211. Retrieved from http://www.sciencedirect.com.ezproxy.royalroads.ca/science?_ob=MImg&_imagekey=B6TGF-447MXV5-4-3&_cdi=5253&_user=1067470&_pii=S0304389401002679&_orig=search&_coverDate=12%2F14%2F2001&_sk=999119997&view=c&wchp=dGLzVlb-zSkWA&md5=e2a3c16d2366ce6237c8a5b798674c1a&ie=/sdarticle.pdf

Duncan, L., & Nowlan, L. (2008, April). Track B: Detecting noncompliance – Off the rails: The environmental enforcement challenge of Canada’s railway industry. Paper presented at the Eighth International Conference on Environmental Compliance and Enforcement, Cape Town, South Africa.  Abstract retrieved from http://www.inece.org/conference/8/proceedings/proceedingsfinal.pdf#page=273

Government of Canada enhances safety in the transportation of dangerous goods. (2009, February 2). Canada NewsWire. Retrieved from http://proquest.umi.com.ezproxy.royalroads.ca/pqdweb?index=0&did=1636963671&SrchMode=1&sid=1&Fmt=3&VInst=PROD&VType=PQD&RQT=309&VName=PQD&TS=1279460554&clientId=4565

Legadec, P. (1982). Major technological risk: An assessment of Industrial Disasters. Retrieved from http://citeseerx.ist.psu.edu

Liverman, D., & Wilson, J. (1981). The Mississauga train derailment and evacuation 10-16 November 1979. Canadian Geographer, 25(4), 365-375. doi:10.1111/j.1541-0064.1981.tb01339.x 

Glickman, T. S., Erkut, E., & Zschocke, M. S. (2007). The cost and risk impacts of rerouting railroad shipments of hazardous materials. Accident Analysis & Prevention, 39(5), 1015-1025. doi:10.1016/j.aap.2007.01.006

Quarantelli, E. L. (1981). Sociobehavioral response to chemical hazards: Preparations for and responses to acute chemical emergencies at the local community level (Final Project Report #28). Retrieved from University of Delaware Library Institutional Repository website: http://dspace.udel.edu:8080/dspace/handle/19716/1168

Scanlon, T. J. (1989). Toxic chemicals and emergency management: The evacuation of Mississauga, Ontario, Canada. In P. T. Hart (Ed.), Coping with crises: The management of disasters, riots and terrorism (pp. 303-322). Springfield, IL England: Charles C Thomas, Publisher.

Transport Canada (2009a). Emergency Response Assistance Plans. Retrieved July 17, 2010 from http://www.tc.gc.ca/eng/tdg/publications-tp9285e-355.htm

Transport Canada. (2009b). Introduction to Emergency Response Assistance Plans. Retrieved July 17, 2010 from http://www.tc.gc.ca/eng/tdg/erap-intro-327.htm