Under theResource Conservation and Recovery Act (RCRA), specifically40 CFR Part 264/265 Subpart D, the Environmental Protection Agency (EPA) mandates that hazardous waste generators (particularly Large Quantity Generators) develop and maintain a formal contingency plan.1The primary objective of this requirement is toprevent or minimize damage to human health and the environmentfrom fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water.
A RCRA contingency plan is a "living" document that must be implemented immediately whenever there is an incident.2It must contain specific elements, including:
Emergency Procedures:A description of the actions facility personnel must take in response to a release.
Coordination Agreements:Documentation of arrangements made with local police, fire departments, and emergency response teams.
Emergency Coordinator:A designated individual available 24/7 with the authority to commit the resources needed to carry out the plan.3
Equipment List:An up-to-date list of all emergency equipment at the facility (e.g., fire extinguishers, spill control equipment, and decontamination supplies).
Evacuation Plan:A description of the signals used to begin evacuation and the primary/secondary evacuation routes.
For theCEDPprofessional, the contingency plan is a critical bridge between daily operations and disaster response. While Option C refers to theToxic Substances Control Act (TSCA), that act primarily deals with the introduction of new or existing chemicals into the market, whereasRCRAgoverns the waste and the contingency planning process. By mandating these plans, the EPA ensures that facilities are not caught off-guard by an accident. The plan ensures that the "Initial Response" is disciplined and effective, preventing a localized spill from cascading into a major environmental disaster that could contaminate local aquifers or require massive federal intervention under Superfund (CERCLA) authorities.
