Who is causing mercury spills in Vancouver’s Stanley Park?

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For the third time in less than a month, a Hazmat Crew was dispatched to Vancouver’s Stanley Park to clean-up a mercury spill.  In each of the incidents, the cause of the spill is either a broken thermometer or broken thermostat.

In each incident, it took hazmat teams a couple of hours completely clean up the tiny droplets of metal.

Vancouver police are working with Fire officials to determine if the three incidents are related, who is responsible, and what is the possible motive.

Exposure to Mercury and Health Implications

Mercury is a naturally occurring toxic heavy metal that is widely dispersed in nature.  Most human exposure results from fish consumption or dental amalgam.  Exposure to high levels of mercury, including acute exposure (exposure occurring over a short period of time, often less than a day) can have serious health impacts.

Typical acute exposure to mercury occurs due to an industrial accident.  Factors that determine whether health effects occur and their severity include: the type of mercury concerned; the dose; the age or developmental stage of the person exposed; the duration of exposure; and the route of exposure (inhalation, ingestion or dermal contact).

Elemental and methylmercury are toxic to the central and peripheral nervous systems. The inhalation of mercury vapour can produce harmful effects on the nervous, digestive and immune systems, lungs and kidneys, and may be fatal.

Mercury Clean-up

There are several methods for cleaning up mercury spills.  One method involves sprinkling sulfur powder over the contaminated area and rubbing it gently all over the surface and into the cracks with a cloth. The sulfur powder binds with mercury and can be collected with a cloth.

Environment Canada has a guidance document on how to clean up small mercury spills.  The United States Environmental Protection Agency has a 133-page guidance document that describes eight different treatment technologies for mercury in soil, waste, and water.

 

Ontario: Discussion paper on modernizing hazardous waste reporting

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The Ontario Ministry of the Environment, Conservation and Parks (MECP) recently announced that it received 76 comments on its “Modernizing Hazardous Waste Reporting in Ontario” discussion paper.

The MECP made changes to the Resource Recovery and Circular Economy Act (RRCEA), and the Environmental Protection Act (EPA) in Fall 2019, which allow the RPRA to provide digital reporting services, fee setting and collection for a wider range of waste and resource recovery programs.

The MECP issued a written letter of direction instructing the RPRA to prepare to deliver a digital reporting service for the Hazardous Waste program. The new hazardous waste digital reporting service would align with the open for business red tape reduction strategy by making it easier for the regulated community to track and report on waste.

Comments contributed to the proposed regulatory amendments and new proposed regulation and the MECP will continue to consider these comments as they take steps to update the Registration Guidance Manual for Generators of Liquid Industrial and Hazardous Waste and transition to the new digital reporting service.

Proposed Regulatory Changes

1. Amend Regulation 347 under the EPA to transition the delivery of hazardous waste digital reporting services to the RPRA

A. Transition delivery and operation of the hazardous waste digital reporting service

The MECP is proposing to amend Regulation 347 under the EPA to require the regulated community (including waste generators, carriers and receivers) to report waste management information to the RPRA instead of to the MECP, as they currently do. This would enable the RPRA to deliver and operate the hazardous waste digital reporting service, including collecting reports and fees from the regulated community.

B. Change registration and reporting requirements to support electronic service delivery

The amendments would also include changes to registration and reporting requirements to support a fully electronic reporting service. The new digital reporting service is intended to replace www.hwin.ca and paper document submissions.

Annual registration

The MECP is proposing to remove the annual registration renewal requirement (currently between January 1st to February 15th) and only collect information from generators at the time the business has a waste management activity to report (i.e. onsite storage/disposal/processing, or offsite movement of subject waste).

This would mean that businesses would complete an initial waste management activity report when they are reporting their first activity (using the new registry for the first time).

To ensure ongoing accuracy with facility, contact and payment information, the RPRA would require that businesses review and update their initially reported information when they are ready to report their first waste management activity after 365 days from the last time they reviewed and confirmed this information.

Reporting requirements

The MECP is proposing to amend Regulation 347 to provide more clarity about what waste management activities need to be reported to the RPRA and when they need to be reported. Reportable activities include both onsite and offsite management of subject waste and would remain the same. Reporting requirements for the Hazardous Waste program would be consolidated into one section.

The following activities would continue to be reportable waste management activities under the Hazardous Waste program:

  • Offsite management:
    • prior to completing the first off-site shipment of a subject waste
  • Onsite management:
    • within 90 days of generating and storing a subject waste where such waste is to be temporarily stored for more than 90 days and less than two years
    • prior to processing a subject waste onsite with the applicable Environmental Compliance Approval
    • prior to disposing of a subject waste onsite with the applicable approvals
    • prior to storing a subject waste for longer than two years with a valid Environmental Compliance Approval

Businesses that generate subject waste would be required to report their activities on, or prior to, the date that the activity takes place or within 90 days of generating or temporarily storing the subject waste if no other waste management activity has taken place. No generator of subject waste would be permitted to store subject waste for a period of greater than 90 days without reporting an activity to the RPRA. No generator would be permitted to manage such waste without reporting the activity to the RPRA.

In the near term, the ministry’s approach is to ensure that the proposed amendments would support the continued use of paper manifesting as an alternative to electronic reporting through the RPRA’s Registry, in a manner similar to that currently provided for under Regulation 347. Such reporting would continue to be provided directly to the ministry (director).

Report Completion

The MECP is proposing to amend Regulation 347 to clarify that reporting information would not be accepted in the new hazardous waste digital reporting service unless:

  • The entire waste management activity report is completed in a manner consistent with the requirements of the Regulation.
  • Any applicable fee payable by the generator is paid by or on behalf of the business.

This is intended to ensure that all members of the regulated community provide accurate information, on a timely basis and that they are paying for the subject waste that they generate in a timely manner.

Delegating Authority

The MECP is proposing that the new hazardous waste digital reporting service would allow delegates to register, report, and pay fees on behalf of generators. The generator would remain responsible for the subject waste that they generate and the information that is reported on their behalf. The RPRA would be responsible for ensuring confidential business information remains protected. The MECP is proposing to amend Regulation 347 to include a definition for ‘Delegate’ that would clarify this role.

The ability to delegate authority would provide flexibility for businesses (waste generators) to comply with the new hazardous waste digital reporting service, and ensure that the most accessible, knowledgeable and capable individuals are able to act on behalf of a business, should it be needed.

Paper-based reporting

The rules for paper-based reporting would remain the same in Regulation 347 because there is still a possibility that paper documents could be used in certain circumstances. In situations where paper manifests are used, businesses would continue to be required to ensure their manifest travels with the waste and applicable filing requirements are met with the ministry.

C. General housekeeping amendments to provide more clarity

The MECP is proposing to amend Regulation 347 to make various minor changes to provide more clarity and ensure consistency with other regulations.

Align with Federal regulatory phrases

Aligning with Federal regulatory phrases under the Transportation of Dangerous Goods Act(TDGA) would make it easier for businesses to learn and comply with both federal and provincial rules.

  • Align with the Federal phrasing in the TDGA by replacing “packaged” to “means of containment”.
  • The word “issued” should be removed when referencing TDGA manifests – because TDGA no longer “issues” manifests.
Definitions

Changes are needed to some existing definitions to provide more clarity for the regulated community.

  • The ‘field operation’ definition would be amended to clarify that specific medical clinics (blood donation/vaccinations and flu clinics) are included in the definition. This would reduce burden as these sites will not need to register and manifest at every site.
  • The ‘empty pesticide container’ definition would be updated to match the definition in Pesticides Act to help clarify and align with existing requirements.
  • The ‘reactive waste’ definition would be updated to correct a grammatical error and make it clear that the definition of reactive waste contains an independent list of criteria and not a multi-checklist of requirements. For example, if the waste meets any one criterion in the list, then it meets the reactive waste definition.
  • Both the ‘ignitable waste’ and ‘reactive waste’ definitions would be updated to align with the actual federal titles.

Some new definitions (i.e. RPRA, Registrar, Registry) would be needed so that the RPRA can deliver and operate the new hazardous waste digital reporting service. These definitions would have the same meaning as in the RRCEA. Other defined terms may also be required or desirable.

2. Create a new regulation under the RRCEA to carry over fee exemptions for certain activities related to hazardous waste – the RPRA would be required to consider the exemptions when setting program cost recovery fees.

The MECP is proposing a new regulation under the RRCEA that would carry over fee exemptions for certain activities related to hazardous waste from Regulation 347. The RPRA would be required to consider these exemptions, which would be based on the current exemptions when setting fees to recover the full cost of the Hazardous Waste program.

All fee setting references in Regulation 347 would be revoked when the new hazardous waste digital reporting service is implemented because the RPRA would have the responsibility to set and collect fees. The RPRA would be required to consult with stakeholders prior to establishing or amending fees for 45 days and post these fees on their website.

Read about and comment on the related proposed new regulation under the RRCEA.

Maintain government oversight for the hazardous waste program

Government would continue to play an important and on-going role in protecting the health and safety of the people of Ontario, and the environment. With respect to the Hazardous Waste program, the ministry would maintain compliance and enforcement, and program and policy oversight activities.

The RPRA would be responsible for operating the hazardous waste digital reporting service to ensure reports are complete and related fees are collected. The RPRA would also notify the ministry of any suspected non-compliant activities. All incidents of non-compliance with program requirements would continue to be followed-up on by the ministry.

The ministry would continue to ensure all generators, carriers, and receivers are complying with requirements under the EPA and Regulation 347 to safely store, transport, process, and manage subject waste in Ontario. The ministry would continue to do this by conducting compliance inspections and following up on reported incidents of improper management of waste. The ministry would also continue to enforce program requirements through investigations and prosecutions.

Benefits of the new digital reporting service

A new digital reporting service for the Hazardous Waste program, would make reporting simpler, faster and more cost-effective. This change would also help us to meet our goals to:

  • Go digital – Implementing a modern digital reporting service that replaces the existing paper-based manifest program would improve our existing service and knowledge base, making it easier to report activities related to subject waste (i.e. hazardous waste and liquid industrial waste as defined in Regulation 347).
  • Hold polluters accountable – Implementing a modern digital reporting service would allow for more effective and timely compliance monitoring and enforcement actions.

Improved electronic data tracking and reporting would provide the regulated community and the ministry with an important set of tools that reduce administrative burden, saving time and money. For example, the service would:

  • Reduce unnecessary manual data entry.
  • Reduce the amount of time and money businesses spend preparing and mailing paperwork to the ministry, correcting administrative errors on paper, or searching for missing paperwork.
  • Provide the ministry with more accurate and timely information to inform decision making and policy development.
  • Allow the ministry to focus on risk-based compliance and enforcement to ensure subject waste is appropriately managed.

This new hazardous waste digital reporting service would align with Ontario’s Digital Service mandate by eliminating outdated approaches to processes, such as reporting using the existing online system (i.e. Hazardous Waste Information Network – HWIN) and using the more burdensome paper-based submission processes (e.g. paper manifests) that prevent the delivery of people-centered services.

The new hazardous waste digital reporting service would align with the Made-in-Ontario Environment Plan by modernizing the way that the regulated community tracks and reports on subject waste (i.e. hazardous waste and liquid industrial waste as defined in Regulation 347 of the EPA). A better digital reporting service will enable more efficient and timely compliance monitoring and enforcement actions, which would provide assurance for Ontarians that polluters are held accountable, and subject waste is being appropriately and safely managed.

 

4 ways simulator technology can aid CBRN training

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Written by Bryan W Sommers – SGM U.S. Army, Ret., Argon Electronics

A commitment to ongoing education and training is a vital factor in ensuring that military personnel are prepared and equipped for the full spectrum of combat operations that they may encounter.

The U.S. Marine Corps’ individual training standards focus on marines’ competence in recognizing chemical, biological, radiological, and nuclear (CBRN)-related incidents and in taking the required protective measures to achieve their mission objectives.

Key training goals include: being able to recognise CBRN hazards or attack indicators; the checking, donning and doffing of personal protective equipment (PPE); recognizing CBRN alarms, markers and signals; employing detection equipment and relaying CBRN signals, alarms and reports.

Typically this training will comprise a combination of classroom, teaching, practical application and/or field training as appropriate.

The challenging nature of many CBRN environments however can often difficult, or in many cases impossible, to successfully replicate using traditional training methods.

Over the past decade there has been increasing recognition of the potential of live simulations and simulator training in being able to plug this crucial training gap.

While the laptop based Deployable Virtual Training Environment (DVTE) simulator has been a staple of the Marine Corps’ training programme for more than a decade, the integration of CBRN-specific simulator training is still a relatively new area.

But it is one that offers many opportunities.

In this article we examine four of the primary benefits of integrating an element of simulator-based training into an existing CBRN programme of instruction.

1. Enhanced realism

A key benefit of utilising simulator detector technology is the enhanced degree of realism and authenticity that it provides.

With the help of simulators, it is possible to place Marines in life-like scenarios that mirror the hazards of real events – but where there is zero risk of harm.

The use of simulator detectors also enables trainees to experience for themselves those extreme incidents that never occur outside of normal use.

Recreating the presence of a blood agent for example, is something that is otherwise impossible to achieve using traditional training methods.

With the use of a simulator however, trainees are able to see and hear for themselves exactly how their actual detectors will react in response to a real blood agent.

2. Increased trainee empowerment

A secondary benefit is the extent to which greater responsibility for training and learning can be handed over to the trainees.

Simulator detectors enable more of the decision-making to be placed in the hands of the students, removing the necessity for the instructor to have to drip-feed information to his or her students.

In shifting the onus onto the trainee there is more opportunity for them to make sense of the information they receive and to formulate appropriate responses based on that information.

3. Trust in the functionality of equipment

Simulators can also be invaluable in enabling trainees to receive realistic feedback and establish greater trust in their real-world systems.

In training with a simulator that mirrors every aspect of their real device – from the weight of the detector, to the position of the buttons, to the sound of the alarms – students are able to better rely on themselves and on the functionality of their equipment.

3. A better learning experience

Simulator-based training provides trainers with the capability to have eyes on all aspects of the training process, and for all errors to recorded even if they may not spot those errors themselves.

This information can then provide a valuable learning point when it comes to post-exercise evaluation.

Crucially too, the use of simulator detector equipment provides CBRN trainees with the freedom to not only be able to safely make mistakes, but to recognise when they make those mistakes and to adapt their actions accordingly.

The growing interest in CBRN technologies

The U.S. Marine Corps is committed to “innovation, education enhancement and investment in the resources, and technologies that facilitate learning.”

Those investments, it says, include the continued modernisation of its “training ranges, training devices, and infrastructure,” as well as the leveraging of “advanced technologies and simulation systems to create realistic, fully immersive training environments.”

The ability to achieve objectives and maintain freedom of action in a CBRN environment are vital factors in achieving mission success.

As the diversity, complexity and unpredictability of CBRN incidents continues to grow, the interest and investment in simulator technologies is only likely to increase as more organisations recognise their value in improving safety, heightening realism and enhancing learning outcomes.

About the Author

Sergeant Major Bryan W Sommers has forged a distinguished career in the fields of CBRNe and HazMat training. He recently retired after twenty-two years service in the US Army, with fourteen years spent operating specifically in Weapons of Mass Destruction (WMD) environments. In 2020 he was appointed as Argon Electronics’ North American business development manager.

A guide to the four levels of Hazardous Materials (HazMat) response

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Written by Bryan W Sommers – SGM U.S. Army, Ret. , Argon Electronics

Hazardous materials that are mishandled, incorrectly transported or used with malicious intent, can pose a substantial risk to human health and the environment.

How effectively hazardous materials (HazMat) incidents are managed and resolved hinges on the knowledge, training and skill of those charged with response.

In this article we examine the roles and responsibilities of the four HazMat response levels and we discuss how simulator detector technology can be used to enhance HazMat training outcomes.

Awareness Level

For responders working in awareness level roles, the chance of encountering the presence of a hazardous material in the course of their normal daily duties is relatively small.

In many cases though, it is awareness level personnel who will be “first on the scene” of a HazMat incident – and it is they who will be responsible for taking charge of the initial protective actions (isolating or evacuating the area, calling for specialist assistance etc) that will minimize the impact on people and the environment.

Among the expected competencies of an awareness level responder are:

  • An understanding of what hazardous materials are and the situations and locations in which they are most likely to be present
  • The ability to recognize markings, placards or labels that indicate the presence of hazardous materials
  • Familiarity with the documentation / resources used to identify hazardous materials (such as the Emergency Response Guidebook (ERG) or its equivalent)

Operations Level

Responders working at the operations level play a hands-on and defensive role in initial HazMat response.

It is expected however that they will do as much as is possible to mitigate the incident without having to set foot inside the Hot Zone.

The mission-specific responsibilities of operations level responders include:

  • Assisting in controlling, and minimizing the spread, of the HazMat release
  • Knowledge of defensive HazMat techniques such as absorption, damming, diverting, vapour dispersion and suppression
  • Experience in basic air monitoring
  • Technical and mass decontamination
  • Assisting with evacuation and victim rescue
  • The establishing of hazard zones
  • The preserving of evidence

Technician Level

Responders operating at technician level are highly specialized HazMat personnel who take an offensive-action role when responding to known or suspected releases of hazardous materials.

While HazMat technicians may not be expected to be experts in science, it is assumed that they will have a robust understanding of chemistry, biology and/or nuclear physics. Many also have a substantial CBRN training background.

A HazMat Technician’s primary responsibilities include:

  • The performing of advanced risk-based hazard assessments in order to analyse the scope of HazMat incidents
  • Experience in the selection and operation of advanced detection, monitoring and testing equipment
  • The ability to select and use specialized Personal Protective Equipment (PPE)
  • Selection of decontamination procedures and control equipment

Depending on their level of training and the scope of the incident, HazMat Technicians may also be required respond to specialized incidents involving flammable gases or flammable liquids and/or to have knowledge of radiological dosimetry and recording procedures.

Specialist Level

The Specialist responder is the highest level of responder for HazMat incidents, with an in-depth and highly advanced level of scientific knowledge.

In many cases they may be required to provide a more observational, trouble-shooting role – observing Technicians and watching out for potential complications. In other cases they may take a more hands-on approach, working alongside HazMat Technicians within the Hot Zone.

Specialist level responders may also be expected to work with the Incident Commander (IC) from within a command post.

Importance of Training

The real-world demands of a responder’s day-to-day role, together with the ongoing challenges of limited time and resources, means it is crucial that the HazMat training they receive is relevant to their work and tailored to their expected duties and tasks.

Equally too, it is important that they are provided with the opportunity to demonstrate their HazMat response skills and knowledge in both a classroom setting and in the context of a real-life environment.

The provision of realistic and engaging hands-on training can have a vital role to play in ensuring responders are equipped for the challenges of managing live HazMat incidents.

Integrating the use of simulator detector equipment into training scenarios can also be beneficial in enabling trainees to experience hands-on training that is rigorous, compelling and repeatable, but where there is no health and safety or environmental risk.

If you are interested to explore how the use of simulator detectors can enhance your HazMat training outcomes then please get in touch with one of our experts today.

About the Author

Sergeant Major Bryan W Sommers has forged a distinguished career in the fields of CBRNe and HazMat training. He recently retired after twenty-two years service in the US Army, with fourteen years spent operating specifically in Weapons of Mass Destruction (WMD) environments. In 2020 he was appointed as Argon Electronics’ North American business development manager.

Preparing Post-Construction Cleanup Sites for Natural Disasters

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The United States Association of State and Territorial Waste Management Officials (ASTSWMO) CERCLA Post Construction Focus Group has developed a checklist called, Preparing Post-Construction Cleanup Sites for Natural Disasters, which is intended to help States in identifying efficient and effective measures for preparation in advance of potential natural disasters to aid in the identification of likely concerns following a natural disaster. The information provided on the checklist can be used to identify and respond to changed conditions at sites to support action to ensure protectiveness of human health and the environment.

Purpose of the Checklist

The purpose of this checklist is to provide a planning tool for post-construction sites (sites) in the event of a natural disaster. The checklist was developed for CERCLA post-construction sites; however, it may also be used for similar “non-CERCLA” post-construction sites. The checklist includes site-specific information that should be considered prior to and post natural disaster event to streamline site security, minimize damage to remedy components, and reduce the risk of site-related environmental impacts. The checklist does not replace Health
and Safety Plans (HASP), Standard Operating Procedures (SOP), or other site-specific / programmatic guidance documents. Site managers are encouraged to complete the checklist following review of these guidance documents, and incorporate supporting information, as  appropriate.

Recommendations

Based upon the development of this checklist, the team recommends the following practices that will help States be prepared to react following a natural disaster:
• Pre-event planning: Assess site conditions to compile site specific details to complete the checklist prior to a natural disaster.
• Pre-event information: Identify and collect site plans/data and contact information so the information is readily available should a disaster occur. Periodically review this information to ensure that it is current.
• Post-event information: Use the checklist to identify conditions that require action/repair and track planned actions.

The team also recommends considering the use of a version of this checklist for sites that may be in active cleanup stages.

 

About the ASTSWMO CERCLA CPC FG

The ASTSWMO CERCLA Post Construction Focus Group (CPC FG) is comprised of State and Territorial (State) members from all United States Environmental Protection Agency (EPA) regions. This checklist was prepared by the ASTSWMO CPC FG, under Cooperative Agreement 83870001 with the U.S. EPA Office of Superfund Remediation and Technology Innovation (OSRTI).

The mission of the ASTSWMO CPC FG is to promote facilitation and maintenance of reliable, effective, and protective remedies constructed at contaminated sites, to include identification of the resources necessary following remedy construction, and to communicate State program strategies effectively among interested parties.

Dangerous Goods Online Training: How to Choose the Best Provider

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Written by Hazmat University

Dangerous goods training is required for anyone who handles or ships dangerous goods by ground, air, or ocean. You have to be trained in IATA/ICAO regulations (if you ship by air), 49 CFR (if you ship by ground), or IMDG regulations (if you ship by vessel).

Choosing the right dangerous goods online training provider is critical if you want to be adequately trained in the applicable federal and international regulations related to the safe transportation of dangerous goods.

The factors you need to consider while choosing a dangerous goods online training provider are listed below.

Training Programs Offered

Does the dangerous goods training provider offer initial training as well as recurrent training programs? Do their training programs thoroughly cover all relevant regulations? These are the first questions you need to ask while choosing a hazmat training provider.

It is also advisable to choose a training provider who offers function-specific training programs for each mode of transportation (IATA programs for air, IMDG programs for  ocean, and 49 CFR programs for ground). If you ship by more than one mode of transportation, then you would likely choose a dangerous goods training provider that offers multimodal training programs. These in-depth courses cover the dangerous goods regulations pertaining to two or three modes of transportation, depending on the course.

By proactively seeking a reputable and knowledgeable training provider that offers the exact services you need, you can attend a dangerous goods training program that is tailored to your business needs. For instance, if you ship dangerous goods by ground and air, you can sign up for a multimodal training program which covers 49 CFR and IATA regulations.

Dangerous Goods Online Course Material

The quality of a dangerous goods online training program depends to a great extent on the course material it covers. Ideally, the course material should cover a minimum of the following information:

  • Identification and classification of dangerous goods based on the risks the materials present and the criteria of the 9 hazard classes
  • The regulatory requirements pertaining to packing, marking, and labeling dangerous goods
  • Dangerous goods placarding and segregation requirements for transport vehicles
  • The regulatory requirements related to loading/unloading of dangerous goods
  • Completion of the various forms of shipping paperwork that are required to ship dangerous goods by ground, air, and ocean
  • The regulations pertaining to prohibited and restricted dangerous goods
  • Regulatory exceptions and the circumstances under which they are applicable
  • The most common security hazards associated with shipping dangerous goods and applicable safety measures to take

Dangerous Goods Training Methodologies

What methods of presentation does the dangerous goods training provider offer? Do they provide in-person, instructor-led webinars, as well as online training programs? This is something you need to consider, especially if you have budgetary and/or time constraints to contend with.

Dangerous Good Classroom Training and Instructor-led Webinars

Classroom and webinar training programs are instructor-led and are conducted at a specific location at a specific time. Such training sessions are often held at a centralized location that is convenient to a wide range of attendees.  Participants are required to physically attend the classroom presentation or webinar and these training sessions are most often designed to provide general information that is common to a wide-array of shippers. This is often an economical option to receive interactive face-to-face training but this option still requires planning and budgeting from a travel standpoint.

Dangerous Goods Onsite Training

Onsite training programs, on the other hand, are usually highly personalized and are held at your specific place of business. The course material is tailored to the specific needs of your organization, which provides many advantages. However, similar to classroom and webinar training programs, onsite training still requires participants to physically attend the course at the determined place and time. These types of training courses also usually come at a premium cost.

Dangerous Goods Online Training

On the contrary, Dangerous goods online training programs, do not require your physical presence at all. You can access the course material using your tablet or computer at any time or any place with an internet connection. As such, this is perhaps the most convenient and cost-effective method of obtaining required dangerous goods training. Online dangerous goods training sessions can save you a lot of time and money, since they do not involve any travel costs, instructor fees, or scheduling commitments.

Choose the Best Dangerous Goods Online Training Program Provider

Even amidst the COVID-19 crisis, dangerous goods online training options are available for hazmat employees on the frontlines of the supply chain.

About the Author

Hazmat University provides online hazmat training to help you satisfy hazardous materials training requirements for all modes of transportation.

Transport Canada Emergency Response Guidebook — 2020

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The Emergency Response Guidebook 2020 edition will be available late spring 2020. For free paper copies’ pre-order, please send an email to: [email protected]

Who is eligible to get free paper copies?

Canadian First Responders from public emergency services such as:

  • municipal fire departments
  • police departments
  • ambulance services
  • RCMP
  • First Nation emergency services, can get free paper copies according to operational needs

These First Responders can get free paper copies according to operational needs, which include:

  • one paper copy of the Guidebook per emergency vehicle or per emergency kit bag (such as for volunteer firefighters who use their personal vehicle)
  • replacement copies as required for broken or damaged copies
  • copies used in class for in-house training purposes, on the condition they are to be retained for reuse in future classes
  • Canadian dispatch centers that pass on technical information about dangerous goods to First Responders can get a small number of free paper copies for use in the dispatch center
  • in remote areas where there are no First Responders available, other Canadian municipal, provincial, territorial or federal authorities acting as public emergency services may get free paper copies according to emergency response operational needs, if they are likely to be the first to arrive on scene of a dangerous goods incident
  • transportation of dangerous goods inspectors, remedial measures specialists and provincial inspectors who respond to dangerous goods accidents can get one free copy each for use during their duties

The importance of collaboration in countering CBRNe threats

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Written by Steven Pike, Argon Electronics

In what is a rapidly changing and increasingly challenging global environment, the importance of maintaining international cooperation in countering CBRNe threats has never been more crucial.

The successful management of any form of cross-border hazard – be it biological, chemical, nuclear or otherwise – relies on targeted, sustained and collaborative action.

The value of developing a cohesive approach to CBRNe response was just one of the topics touched on by Henriette Geiger in her opening speech at the Annual General Meeting of the European Union CBRN Risk Mitigation Centres of Excellence in Brussels in June 2019, in which she stated:

“We are facing challenges today that go beyond national borders and [that] cannot be tackled alone.

“This is true for cooperation on CBRN matters, as witnessed by recent CBRN attacks and events in Europe…[and] also by the re-emergence of epidemic diseases.”

Countering invisible threats

Fast forward just nine months, and the impact of the COVID-19 pandemic is demonstrating all too starkly just how vitally important it is to maintain global cooperation in the fight against an invisible yet deadly threat.

From governments to tech companies to international agencies, the race is on to put in place measures that can help to contain the spread of the coronavirus.

The challenge in any crisis situation though is in ensuring that those personnel operating on the frontline of emergency response are sufficiently trained and equipped to handle what can often be complex, highly charged and in many cases unprecedented emergency situations.

The role of realistic CBRNe training

When planning exercises for diverse CBRNe or HazMat threats, a key priority is to develop relevant scenarios that facilitate optimum readiness, maintain maximum levels of safety and present minimal regulatory burden.

In the last decade, there has been an increasing interest in the use of hands-on training exercises using simulators to enable civilian and military CBRNe practitioners to test their technical knowledge in a manner that is realistic, cost-effective and safe.

Classroom learning will always continue to provide value in helping build theoretical understanding of the science and technology that underpins CBRNe defence.

But it is through the provision of realistic training that knowledge and competency can truly be put to the test.

Hands-on training that uses actual equipment (or its simulator equivalent) can help to build deeper understanding of the key science that underpins the release, dispersal and measurement of CBRNe agents.

By incorporating the use of simulator detectors in the context of CBRNe exercises, there is also the opportunity for personnel to gain familiarity both with the chemical and physical properties of specific hazards and with the ways that these hazards may affect individuals, equipment and infrastructure.

The value of international collaboration

At a time when international cooperation can offer significant benefits, the cooperative research agreement (CRADA) signed between Argon Electronics UK Ltd and the the Lawrence Livermore National Laboratory (LLNL) is an initiative that promises to both bolster and re-envision the delivery of realistic hands-on CBRNe training.

The two-year agreement, valued at $2.55 million, merges LLNL’s game-changing Radiation Field Training Simulator (RaFTS) technology with Argon Electronics’ extensive experience in the creation and development of simulation hardware and software.

While the project is currently focused on enhancing the provision of radiation training, there is the ability for the same technology to be applied across the broader range of CBRNe response, and in doing so to substantially raise the bar of emergency preparedness.

As the events of COVID-19 pandemic have demonstrated, the consequences of CBRNe emergencies can stretch national capabilities to their very limits.

While responsibility for first response remains with individual nations, there is also much to be gained from countries working together, combining their resources and developing common frameworks in order to mitigate against the effects of future global threats.

About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators. He is interested in liaising with CBRN professionals and detector manufacturers to develop training simulators as well as CBRN trainers and exercise planners to enhance their capability and improve the quality of CBRN and Hazmat training.

Challenges to Environmental Investigations and Cleanups During the COVID-19 Crisis

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Written by John McGahren, Stephanie R. Feingold, Ariel Kapoano, and Jenna Ferraro, Morgan, Lewis & Bockius LLP

Business closures and remote work requirements, work stoppages, travel restrictions, state and federal government slowdowns, and supply-chain disruptions are impacting parties’ abilities to satisfy obligations pursuant to environmental settlements, including administrative consent orders or judicial consent decrees with the US Environmental Protection Agency (EPA), and administrative orders with various state environmental agencies as well as compliance obligations under federal environmental laws such as the Clean Air Act, Clean Water Act, and Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).

State Guidance

Although the CDC has released guidelines recommending work from home and social distancing, there are currently no federal mandates or executive orders requiring business shutdowns or mandatory quarantine. Instead, many states, counties, and municipalities are releasing executive orders as well as nonbinding policies ranging from shelter-in-place to closing nonessential businesses and limiting gatherings of people.

These state and local mandates uniformly exempt “essential businesses” from such directives. The “essential business” exemption includes services and sectors that promote public safety, health, and welfare, although exactly what constitutes an “essential business” can vary. For example:

New York: Executive Order 202.6 exempts “essential businesses” to include healthcare operations (including research and laboratory services); essential infrastructure (including utilities); telecommunication; airports and transportation infrastructure; essential manufacturing (including food processing and pharmaceuticals); essential retail (including grocery stores and pharmacies); essential services (including trash collection, mail, and shipping services; news media; banks and related financial institutions); providers of basic necessities to economically disadvantaged populations; construction; vendors of essential services to maintain the safety, sanitation and essential operations of residences or other essential businesses; and vendors that provide essential services or products (including logistics and technology support, child care, and services needed to ensure the continuing operation of government agencies and provide for the health, safety, and welfare of the public).

New Jersey: Executive Order No. 104 exempts “essential businesses,” defined to include “grocery/food stores, pharmacies, medical supply stores, gas stations, healthcare facilities and ancillary stores within healthcare facilities.” All gatherings within the state are limited to 50 persons or fewer, except for “normal operations at airports, bus and train stations, medical facilities, office environments, factories, assemblages for the purpose of industrial or manufacturing work, construction sites, mass transit, or the purchase of groceries or consumer goods.”

It is less clear, however, whether environmental cleanups and investigations would constitute “essential businesses” subject to these exemptions. Furthermore, some states have expanded their initial executive orders, and others may follow suit. For example, while Pennsylvania initially recommended the closure of nonessential businesses, on March 19 Governor Tom Wolf signed an executive order forcing the closure of all but “life-sustaining” businesses. The state will begin enforcement actions against noncompliant businesses on March 21 under the terms of this order. Construction activities, for example, are no longer permitted to operate in Pennsylvania.  Additionally, on March 19, Governor Gavin Newsom of California signed an executive order requiring all residents to stay home, except as needed to maintain continuity of operations of the 16 “federal critical infrastructure sectors” including critical manufacturing, chemical, emergency services, energy, healthcare and public health, financial services, food and agriculture, and water and wastewater. And on March 20, just one day after having directed 75% of all nonessential employees to stay home, New York Governor Andrew Cuomo announced that he would be putting out an executive order mandating that 100% of employees in “nonessential” businesses in the state stay home.

Many state environmental agencies have not yet released guidance on the impacts of COVID-19. Moreover, even if environmental cleanups are permitted to proceed, maintaining the recommended “social distancing” in site investigation or remediation activities presents a challenge. Further challenges to ongoing site investigations and cleanups may also arise due to workforce absenteeism due to illness or caring for an ill family member.

EPA Guidance

EPA has not yet released guidance on the impact to agency operations due to COVID-19. Moreover, each site is differently situated, so there may be no one-size-fits-all solution. Parties currently remediating sites pursuant to settlements with EPA should carefully scrutinize their respective agreements and orders, including the force majeure clauses, to determine whether current circumstances may constitute such an event, and how and when to notify the agency. Most such provisions require notification within days, or even hours, of the discovery of the force majeure event, prompting yet more uncertainty as to whether there has been a trigger based on the novel pandemic response gripping the nation.

For example, EPA’s Model Consent Decree Language and Model Administrative Consent Order Language both define force majeure events as any event arising from “causes beyond the control” of respondents that “delays or prevents the performance of any obligation” under the order despite respondents’ “best efforts to fulfill the obligation.”

Each ongoing cleanup faces unique challenges depending on locality and nature of the cleanup. Responsible parties should consider outreach to EPA requesting the following actions:

  • Recognize the rapidly changing circumstances at the local, state, and federal level caused by COVID-19
  • Temporarily suspend notice deadlines for force majeure events caused by the COVID-19 crisis, as well as waive penalties for failure to timely notice or meet a deadline where the implications of COVID-19 have made it impracticable or impossible
  • Work with responsible parties on an individualized basis to determine whether ongoing work can continue and the extent to which deadlines should be extended, and follow a dispute process in the event of disagreement
  • Acknowledge that there may not be a one-size-fits-all approach for sites that are at different stages of remedial progress and subject to varying state restrictions

Until state and federal environmental authorities take affirmative action, responsible parties should consider proactive outreach to their EPA and state agency contacts for their specific cleanup sites for further guidance in this unprecedented situation, and stay tuned for further announcements on the status of environmental cleanups in the midst of the COVID-19 pandemic.

Copyright 2020.  Morgan, Lewis & Bockius LLP.  All Rights Reserved. 

 This article is provided as a general informational service and it should not be construed as imparting legal advice on any specific matter.

About the Authors

John McGahren is the Princeton litigation practice leader and deputy chair of the firm’s global environmental practice. John counsels clients on litigation, enforcement, and transactional matters. He prosecutes and defends citizen suits, Superfund and RCRA disputes, Clean Water and Air Act litigation, state law actions, and natural resource damage claims.

Stephanie R. Feingold represents clients in litigation and dispute resolution and provides environmental and regulatory counseling. Her work spans investigations, cost recovery and contribution actions, and enforcement actions brought by and against environmental agencies and government authorities, as well as private party actions.

Ariel Kapoano represents clients in complex environmental, toxic tort, contract, and consumer fraud litigation matters. She has experience in all aspects of litigation including factual investigation, discovery management, motions practice, and trial.

Jenna C. Ferraro is a part of the firm’s litigation team, which counsels clients and provides legal services in a wide range of areas, including general civil and commercial litigation, environmental law and toxic torts. Jenna’s experience includes many aspects of litigation, including discovery matters and motion practice.

How Virtual Reality and real-world tech can aid CBRNe training

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Written by Steven Pike, Argon Electronics

Hands-on training in realistic environments is a cornerstone of CBRNe disaster preparedness, whether for the purpose of military exercises, first response or civilian operations.

The quality, frequency and consistency of CBRNe training has a substantial part to play in how easily personnel are able to acquire both the theory and the practice – and in how effectively they are able to continue to apply that knowledge in the long-term.

The impact and the authenticity of CBRNe training relies on three fundamental principles.

First is the importance of providing trainees with the opportunity to use actual equipment.

Second is enabling those personnel to apply their understanding of this equipment through exposure to realistic scenarios.

And thirdly is ensuring that the scenarios that are provided are conducted in relevant environments or locations.

Time restrictions, cost implications and safety considerations however, can all too often limit the opportunities for responders to practice, test and hone their crucial skills.

Training for radiation incidents

When an incident involves the presence of a high-radiation source or radioactive contamination, it can present some additional challenges.

At the same time, the equipment that radiological responders are required to use is also becoming increasingly sophisticated – and in particular when it comes to effective search and radionuclide identification (spectrometry.)

Many traditional radiation safety training methods can struggle to credibly recreate the complexities of real-life radiological events.

Field exercises can offer the promise of a high fidelity training experience, but sometimes fall short due to the minimal quantity of radiation source that can be safely used.

In the process, an understanding of essential physics can all too easily be diluted, misinterpreted or omitted altogether.

To ensure best preparedness, it is vital that emergency responders are provided with the opportunity to train against robust scenarios that take place in their home locations, that utilise their actual operating equipment and that enable them to put their protocols to the test.

Is virtual reality immersion the key?

Over the couple of decades there has been an increased interest in the potential applications of virtual reality (VR) and augmented reality (AR) in the enhancement of CBRN disaster preparedness.

In contrast to traditional user desktop interfaces, such as viewing a scenario on a computer screen, VR harnesses the power of computer technology to create a simulated environment that aims to recreate as many of the senses as possible.

Virtual reality enables the user to be placed directly “inside” the training experience, and once they are immersed in this artificial world, to be able to interact with a hyper realistic 3D environment.

Immersive multi-user VR training systems can be used to enhance situational awareness, to aid in the operation of equipment or to improve reaction times.

Some systems are designed to provide a pre-defined scenario (or scenarios) in order to train multiple users – for example when a large number of simulators are used in order to train military personnel for specific land, air or naval operations. Others allow the creation of self-defined scenarios that can be applied in multi-user training exercises.

Whilst VR creates an artificial environment in which the user can “inhabit”, augmented reality can be used to enhance live exercises in a real environment by superimposing computer-generated images over the user’s view of the real world.

But while virtual reality or augmented reality immersion exercises can offer many advantages, it is still extremely difficult to replicate the logistical, physiological and sensory realities of a taking part in a live incident.

In many cases too, virtual reality training must be restricted to specialised facilities. And perhaps most crucially, trainees miss the opportunity to practice with the actual detector equipment that they will be required to use in real incidents.

Maintaining operational readiness is vital, however it can often be difficult to provide personnel with access to the hands-on radiological training that they need.

Emergency training requires the mastery of a variety of skills and abilities – but placing trainees in real emergency situations, especially during the initial stages of training, is something that is best avoided.

What is of greater benefit is being able to provide personnel with expert guidance that takes place in a setting that mimics, as closely as possible, the challenges of real-life events.

What is required is a paradigm shift in the approach to radiological preparedness training.

If, for example, the potential applications of virtual technology can be merged with the hands-on application of real-world capabilities, then the possibilities could well be limitless.

With this goal in mind, Argon Electronics is excited to have joined forces with the Lawrence Livermore National Laboratory (LLNL) to explore the potential of the LLNL’s Radiation Field Training Simulator (RaFTS).

About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators. He is interested in liaising with CBRN professionals and detector manufacturers to develop training simulators as well as CBRN trainers and exercise planners to enhance their capability and improve the quality of CBRN and Hazmat training.