Mitigation Plan for companies recycling car batteries
Stephen Aguilar/Myles Stover/Ahmed Al-Mosalmani
March 31, 2013
Technical Communications (21922)-Spring 2013
Purpose
Implantation of an emergency plan for basic operational controls for moderately sized
industrial facilities and any surroundings, which produce car batteries and its hazardous
chemicals through its manufacturing process. The plan is to be used when there is an accidental
release of hazardous chemicals when producing car batteries that may endanger human lives
and cost the industry a substantial amount of money.
Risk Assessment
A large number of industries and organizations use, or handle, hazardous materials on a
day to day basis. The presence of these materials can pose a risk to the employees and/or the
facilities in which they are contained. It is critical for these locations to have some form of
emergency response plan, or hazard mitigation plan, to deal with the potential for a hazardous
materials incident. A critical step in any plan is creating a risk assessment. A risk assessment is
an estimate of the social & economic impact that hazards can have on people, services,
facilities, infrastructure, and the environment. There are many forms of risk assessments in use
today, and most can be formatted to fit an organizations needs. A basic risk assessment can be
created by doing the following:
1. Identify the Hazard(s)-This can be done by examining all the potential threats to the
organization, based on organizational goals, the activities the employees perform, the
materials used, experience of those working with the materials, equipment
characteristics and warnings, and civil, legal and environmental considerations just to
name a few.
2. Assess the Hazard(s)-Take all the identified hazards and assess them by probability
and severity, then determine a risk level.

Probability-The likelihood of the event occurring
o Frequent-Occurs often, known to happen regularly
o Likely-Occurs several times, a common occurrence
o Occasional-Occurs sporadically, but is not uncommon
o Seldom-Remotely possible, could occur at some time
o Unlikely-Can assume will not occur, but not impossible

Severity-The degree to which the incident will impact human life or the
facility.
o Catastrophic-Death or permanent total disability, severe
environmental damage
o Critical-Permanent partial disability or temporary total disability,
Significant damage to property or the environment
o Marginal-Lost days due to injury or illness, Minor damage to property
or the environment
o Negligible-First aid or minor medical treatment, Little or no property
or environmental damage

Determine Risk Level
o Extremely High-Severe consequences
o High-Serious consequences
o Moderate-Losses exists
o Low-Little or no impact
A simple matrix can help the organization determine what the risk level could be before
any mitigation measures are implemented, as well as determine what those measures will be.
Simply follow a row across based on the severity, and then down the column based on the
probability to determine the risk level. An example, you determine that the severity of the risk
is critical and the probability of its occurrence is occasional then the risk level would be” High.”
RISK ASSESSMENT MATRIX
PROBABILITY
SEVERITY
Frequent
Likely
Occasional
Seldom
Unlikely
Catastrophic
E
E
H
H
M
Critical
E
H
H
M
L
Marginal
H
M
M
L
L
Negligible
M
L
L
L
L
E-Extremely High
H-High
M-Moderate
L-Low
3. Develop Controls-Here is where controls are developed and applied. Each
organization is different, in which case they would need to tailor the controls to fit their unique
environment. The controls can be educational (training), physical, and/or avoidance or
elimination. It is wise to reassess risks in this step as well as in step 4 to evaluate the outcomes
of your control measures. Changes may need to be made and the goal is to reduce the risk to
the lowest level, which is “Low.”
4. Implement Controls- Everyone in the organization will need to follow the controls
once they are standardized and implemented. This step is one that continues to evolve, that is,
once a control measure is applied it may need to be adjusted later to fit changes in any of the
factors in the first two steps.
5. Supervise and Evaluate-Personal safety and risk reduction control measures are
ongoing processes that will need to be closely monitored by the leadership. Strict adherences
to the controls are vital to ensure the safety of the employees and will help to reduce the
possibility of damage to the facility and the environment around it.
Vulnerabilities
Each organization will need to assess their vulnerabilities based on what they discover
while completing their risk assessments. These will be different from state to state as well as
from organization to organization within the same state, even the same cities and towns.
Organizations will also need to look outside their boundaries in order to determine if
neighboring facilities may suffer from a hazardous waste incident.
People, more so than the facilities they work in, are the most vulnerable to the
chemicals associated with the recycling of car batteries. Most cars today run with lead-acid
batteries which contain lead plates surrounded by a sulfuric acid electrolyte solution. Car
batteries containing those two elements, both classified as hazardous, have the potential to
cause harm to employees, if handled incorrectly.
Although damage to the facilities may be marginal compared to human life, it still needs
to be addressed through a thorough risk assessment. The environment, mainly runoff from the
facility during a hazardous waste spill, will also need to be factored into a good response plan.
The National Institute for Occupational Safety and Health (OSHA), in cooperation with the
Centers for Disease and Control (CDC), provide International Chemical Safety Cards which
outline the hazards associated with these chemicals. Because lead products can have long-term
effects from low-level exposure, assessments of vulnerabilities should include a long-term
focus, as well as a short-term approach.
The CDC (2002 a), provides these guidelines for those working with lead products.
TYPES OF
FIRST AID/
HAZARD/
ACUTE HAZARDS/ SYMPTOMS
PREVENTION
FIRE FIGHTING
EXPOSURE
FIRE
EXPLOSION
Not combustible. Gives off
In case of fire in the surroundings:
irritating or toxic fumes (or gases)
use appropriate extinguishing
in a fire.
media.
Finely dispersed particles form
Prevent deposition of dust; closed
explosive mixtures in air.
system, dust explosion-proof
electrical equipment and lighting.
EXPOSURE
See EFFECTS OF LONG-TERM OR
PREVENT DISPERSION OF DUST!
REPEATED EXPOSURE.
AVOID EXPOSURE OF (PREGNANT)
WOMEN!
Local exhaust or breathing
Fresh air, rest.
•INHALATION
protection.
Protective gloves.
•SKIN
Remove contaminated clothes.
Rinse and then wash skin with
water and soap.
Safety spectacles.
First rinse with plenty of water for
several minutes (remove contact
•EYES
lenses if easily possible), then take
to a doctor.
•INGESTION
Abdominal pain. Nausea.
Do not eat, drink, or smoke during Rinse mouth. Give plenty of water
Vomiting.
work. Wash hands before eating.
to drink. Refer for medical
attention.
The CDC (2002 b), provides these guidelines for those working with sulfuric acid.
TYPES OF
ACUTE HAZARDS/
FIRST AID/
HAZARD/
PREVENTION
SYMPTOMS
FIRE FIGHTING
EXPOSURE
FIRE
Not combustible. Many
NO contact with flammable
NO water. In case of fire in the
reactions may cause fire or
substances. NO contact with
surroundings: powder, foam,
explosion. Gives off irritating
combustibles.
carbon dioxide
or toxic fumes (or gases) in a
fire.
EXPLOSION
Risk of fire and explosion on
In case of fire: keep drums, etc.,
contact with base(s) ,
cool by spraying with water but
combustible substances ,
NO direct contact with water.
oxidants , reducing agents or
water .
PREVENT GENERATION OF
IN ALL CASES CONSULT A
MISTS! AVOID ALL CONTACT!
DOCTOR!
Corrosive. Burning sensation.
Ventilation, local exhaust, or
Fresh air, rest. Half-upright
Sore throat. Cough. Labored
breathing protection.
position. Artificial respiration
EXPOSURE
•INHALATION
breathing. Shortness of
may be needed. Refer for
breath. Symptoms may be
medical attention.
delayed (see Notes).
Corrosive. Redness. Pain.
Protective gloves. Protective
Remove contaminated clothes.
Blisters. Serious skin burns.
clothing.
Rinse skin with plenty of water
•SKIN
or shower. Refer for medical
attention.
Corrosive. Redness. Pain.
Face shield or eye protection
First rinse with plenty of water
Severe deep burns.
in combination with breathing for several minutes (remove
•EYES
protection.
contact lenses if easily possible),
then take to a doctor.
•INGESTION
Corrosive. Abdominal pain.
Do not eat, drink, or smoke
Rinse mouth. Do NOT induce
Burning sensation. Shock or
during work.
vomiting. Refer for medical
collapse.
attention.
The above mentioned processes are cyclic in nature that is to say that they will change
as procedures, regulations, and guidelines change. Proper planning and preparations will
ensure that your organization stays ahead of potential hazards in the recycling process.
Mitigation Strategy
Goals
The goals of this plan include a mitigation strategy that provides a blueprint for reducing
the losses identified in the risk assessment. The strategy shall include goals that are based on
the risk assessment. These goals will guide the company’s strategies and selection of actions to
achieve the desired, long-term hazard protection. In addition to the goals and actions
influenced from the risk assessment, training will also be another area of focus for the
implantation of the emergency plan. With the implantation of goals, actions and training a
successful emergency plan can be thoroughly followed.
Training
In the process of developing a training plan, consider the training and information needs for
employees, contractors, visitors, managers and those with an emergency response role
identified in the plan (Firemen, and Police).
The training plan made by the company will have to address:

Who will be trained

Who will do the training

What training activities will be used

When and where each session will take place

How the session will be evaluated and documented
The training table is advised to be provided in the manner shown in the following example:
The Training must be done within a 12 month period and as stated must be provided to
employees, contractors, visitors, managers and those with an emergency response role
identified this training shall cover:
•
Individual roles and responsibilities
•
Information about threats, hazards and protective actions
•
Notification, warning and communications procedures
•
Means for locating family members in an emergency
•
Emergency response procedures
•
Evacuation, shelter and accountability procedures
•
Location and use of common emergency equipment
•
Emergency shutdown procedures
Training of employees in emergency procedures in the company can take many forms:
Orientation and Education Sessions-These are regularly scheduled discussion sessions to
provide information, answer questions and identify needs and concerns.
Tabletop Exercise-Members of the emergency management group meet in a conference
room setting to discuss their responsibilities and how they would react to emergency
scenarios. This is a cost-effective and efficient way to identify areas of overlap and
confusion before conducting more demanding training activities.
Walk-through Drill-The emergency management group and response teams actually
perform their emergency response functions. This activity generally involves more people
and is more thorough than a tabletop exercise.
Functional Drill-These drills test specific functions such as medical response, emergency
notifications, warning and communications procedures and equipment, though not
necessarily at the same time. Personnel are asked to evaluate the systems and identify
problem areas.
Evacuation Drill-Personnel walk the evacuation route to a designated area where
procedures for accounting for all personnel are tested. Participants are asked to make notes
as they go along of what might become a hazard during an emergency, e.g., stairways
cluttered with debris, smoke in the hallways. Plans are modified accordingly.
Full-scale Exercise-A real- life emergency situation is simulated as closely as possible. This
exercise involves company emergency response personnel, employees, management and
community response organizations.
Mitigation Process
Consider ways to reduce the effects of emergencies, such as moving or constructing
facilities away from floodplains and fault zones. Also consider ways to reduce the chances of
emergencies from occurring, such as changing processes or materials used to run the business.
Physical retrofitting measures such as:
•
Upgrading facilities to withstand the shaking of an earthquake or high winds

“Flood proofing” facilities by constructing flood walls or other flood protection devices
(see Section 3 for additional information)

Installing fire sprinkler systems

Installing fire-resistant materials and furnishing

Installing storm shutters for all exterior windows and doors

There are also non-structural mitigation measures to consider, including installation of
fire-resistant materials and furnishing

Securing light fixtures and other items that could fall or shake loose in an emergency

Moving heavy or breakable objects to low shelves

Attaching cabinets and files to low walls or bolting them together

Placing Velcro strips under typewriters, tabletop computers and television monitors

Moving work stations away from large windows

Installing curtains or blinds that can be drawn over windows to prevent glass from
shattering onto employees

Anchoring water heaters and bolting them to wall studs

Consult a structural engineer or architect and your community’s building and zoning
offices for additional information
Records Preservation
One of the more important aspects of mitigation is record preservation; this can help a
company protect itself from future incidents such as being liable in case of an emergency spill.
Vital records may include:
•
Financial and insurance information

Engineering plans and drawings

Product lists and specifications

Employee, customer and supplier databases

Formulas and trade secrets

Personnel files
Preserving vital records is essential to the quick restoration of operations. Analyzing vital
records involves:
1. Classifying operations into functional categories, e.g., finance, production, sales,
administration
2. Determining essential functions for keeping the business up and running, such as
finance, production, sales, etc.
3. Identifying the minimum information that must be readily accessible to perform
essential functions, e.g., maintaining customer collections may require access to
account statements
4. Identifying the records that contain the essential information and where they are
located
5. Identifying the equipment and materials needed to access and use the information
Establishing procedures for protecting and accessing vital records is also advised for proper
preservation. Among the many approaches to consider are:

Labeling vital records

Backing up computer systems

Making copies of records

Storing tapes and disks in insulated containers

Storing data off-site where they would not likely be damaged by an event affecting your
facility

Increasing security of computer facilities

Arranging for evacuation of records to backup facilities

Backing up systems handled by service bureaus

Arranging for backup power
Conclusion
Industrial facilities dealing with hazardous chemicals must have contingency plans in
order to protect lives of workers and residents around the industrial area; also through
mitigation and preparedness plans placed to minimize cost of repair and loss of material. This
plan provided the industry with sufficient “defense” from threats of fines from the government
that can reach millions of dollars. The Federal Emergency Management Agency (FEMA) process
was used as guide for constructing an emergency response plan and was used as a template for
creating said emergency response plan to ensure federal guidelines are met.
References
Centers for Decease Control and Prevention 1. (2002 a). Lead Metal International Chemical
Safety Cards (ICSC No. 0052). Retrieved from
<http://www.cdc.gov/niosh/ipcsneng/neng0052.html>.
Centers for Decease Control and Prevention. (2002 b). Sulfuric Acid International Chemical
Safety Cards (ICSC No. 0362). Retrieved from
<http://www.cdc.gov/niosh/ipcsneng/neng0362.html>.
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