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j i TRACY, PLANT #20 F TEMPLE-INLAND POLLUTION PREVENTION AND EMERGENCY RESPONSE MANAGEMENT PLAN I , Sometimes, even if the spill is neutralized and the cleanup process presents no significant hazards, the spill may be too large to 'be disposed of given the it equipment available. e. Employees are not at risk. Again, the physical and chemical properties of the material.must be carefully considered before a decision is made how to clean up a spill. The MSDS contains valuable information regarding volatility, reactivity and/or harmful chemical interactions that may result in employee exposure. If the determination is made that employees may be at risk from the chemical'spill, measures should be made 1 to evacuate the area of risk and initiate outside emergency response. f. The environment is not at risk. r The environment is usually at risk when an uncontrolled or uncontainable spill that has the potential to be introduced,to land, water or air. For example, a spill or a hazardous substance is considered to require emergency response if the spill must be prevented from entering the environment by diking from a location other than the spill source. Furthermore, if the choice is made to allow an Inland employee to dike the spill, at a minimum, that employee must have the 8-hour HAZWOPER first responder operations level training. I g. The facility is not at risk. ' Many times this is an issue of the flammability of the substance. h. The spill can be cleaned up with normal PPE. This is usually one of the'major limiting factors. In most cases, our employees are not trained to use PPE such as respirators and chemical protective clothing. The majority of our employees are limited in training to the use of splash goggles, face shield, chemical protective gloves and apron. Anytime the hazards exceed the PPE the employee has been trained to use, then this is an emergency response. The MSDS usually provides information regarding the PPE necessary for non-routine events. When determining the airborne hazards of volatile chemicals and subsequent respirator needs, our employees are also usually limited in the availability of instantaneous air monitoring equipment necessary to determine airborne concentrations. In situations where an airborne hazard may be present, assume that an emergency response is necessary. Again, the MSDS j Page 14 of 15 Amended 09/07/06