CCPA's TEAP system covers Canada east to west, north to south.
Responsible Care is a familiar initiative to those working in or with the Canadian chemical industry. Developed by the Canadian Chemical Producers' Association (CCPA), Responsible Care is a set of guiding principles, supporting policies and codes of practise which govern the management of chemicals and chemical products through their life cycle.
Another CCPA program related to Responsible Care is the Transportation Emergency Assistance Plan (TEAP). Established in 1971, TEAP was a forerunner of Transport Canada's CANUTEC plan. From 1971 until 1982, TEAP provided first responders with chemical hazard information on how incidents should be handled. There was no formalized hands-on function.
Between 1982 and 1983, TEAP went through quite a "dramatic" change, according to CCPA project manager Dave Finlayson, as CANUTEC assumed its role. The TEAP system was helpful to Transport Canada in establishing CANUTEC.
A legal contract was developed for TEAP members which mandated a physical response to emergency situations. This is the basic system as it is today.
TEAP is a type of mutual aid plan. There are a series of regional response centres across Canada along the main chemical transportation routes. These centres are located at TEAP member company sites. The centres are only required to respond to requests from existing TEAP members.
Prior to the contract arrangement, TEAP teams were often called upon for information and help. Providing information was fine, but physical response was difficult because of personnel, equipment and liability concerns that could arise in dealing with others' products.
Not all CCPA members belong to TEAP and not all TEAP signees are required to belong to the CCPA. The latter category must be ineligible for CCPA membership, e.g., transporters, chemical blenders/distributors. They must, however, meet TEAP auditing criteria.
After 1982, TEAP evolved into a system of a few large companies responding on behalf of many. Each company must have its own response team and technical advisor who is knowledgeable in the particular properties of that company's products. The advisor must also be on the scene to assist TEAP members as soon as possible after an accident occurs. The company's response team must follow soon after. The regional team will stay at the site until relieved by the requesting company's team or until the response is successfully completed.
TEAP audits members to ensure that each company has a trained response team and the necessary equipment. The TEAP team has more generalized chemical knowledge; the companies must provide the specifics about their products.
Finlayson said that most calls are minor in nature, e.g., a leaking drum in the back of a truck.
By 1989, some pressures on the system were becoming apparent. There were calls for improved public and professional standards of response when emergency situations arose. This was complicated by the beginning of a recession which was imposing severe economic restraints on the industry.
Within the CCPA, there was a feeling that the TEAP system had created a situation in which the companies sponsoring the regional response centre (eight across Canada) were acting on behalf of the many (50 to 60 companies) and that a more equitable arrangement was needed.
"We asked the non-sponsoring members to establish volunteer response centres to act as their capabilities permit," Finlayson said. Twenty-five companies agreed. Unlike the regional centres, these voluntary responses members are not obligated by the TEAP contract to respond. "We now have 30 volunteer response centres," Finlayson added. "It was the initial step to spreading the burden -- financial and otherwise -- more equitably."
Also in 1988, Transport Canada began a comprehensive review to ensure that emergency response assistance plans registered in accordance with the Transportation of Dangerous Goods Regulations were proficient. TEAP was analyzed in great detail and although it met all the legal requirements of the Transport of Dangerous Goods Act, some shortcomings were revealed, especially in hard-to-access regions.
Therefore, the TEAP contract was amended. If a regional response centre cannot cover an area, then the company itself must have its own emergency response plan. "The review helped to strengthen our own internal auditing of members," Finlayson noted.
The continued recession and resulting corporate downsizings, merges and closures exerted additional pressures on the TEAP system. In 1990, the regional centre in the Niagara area was closed. The three other regional response centres in the area agreed to expand their coverage as a stopgap measure.
A novel plan was developed to replace the regional centre -- a co-op arrangement. "This was a quantum leap in burden sharing from voluntary response centres to co-op centres," Finlayson added.
The Toronto area companies agreed to a co-op system. Thirty companies are involved. Rohm & Haas is the lead company with participation by four other companies. On a rotating basis, these five put personnel on call 24 hours a day. The other 25 contribute financially.
An emergency response contractor, Philip Environmental, is integral to the centre, providing hands-on response expertise and equipment.
When Allied Chemical in Windsor, ON, cut back its operations it was not able to continue sponsoring a regional response centre. However, the other companies in the area have been asked to form a new centre. According to Finlayson, this has encouraged the members to look at how TEAP is organized overall and how some cost-sharing options can be integrated into the plan.
"The old system could be vulnerable to misuse," Finlayson said. "The expenses of a few provided benefits for many. We are looking at ways to equalize costs, either financially or with personnel/equipment. With the recession, this is especially important." As Finlayson added, companies are trying to do as much or more with less money.
The CCPA must keep close watch on corporate re-organizations and closings, not only for itself, but for the effects it could have on TEAP. "Keep in mind that TEAP is a legal contract. We must ensure companies are aware of TEAP and what it means to them," Finlayson said.
How it works in practise
Three TEAP member companies were involved in the Oakville, MB, derailment -- Dow Chemical, Celanese and MARSULEX. However, the incident did not stimulate a TEAP response. All the companies were able to act on their own.
Finlayson said this example may be indicative of TEAP's spin-off benefits. While regional response teams only handle about four to 12 incidents annually, Finlayson explained that all the principals involved at Oakville, including the railway, had met before as members of the TEAP Emergency Response Committee. "Although there was no formal TEAP response, the existence of TEAP has helped in the fact that the players knew the responsibilities of the others, how to act themselves and the proper procedures. The lessons learned at Oakville will definitely be discussed at future committee meetings." (The Emergency Response Committee includes representatives of Environment Canada, the Coast Guard, Transport Canada and the railways. It was expanded from its original format to include the principals who would be involved in an accident.)
Transport Canada inspectors at Oakville had also been involved in TEAP committee work. "I hope that the relationships built up in committee will help in these incidents," Finlayson added.
Out to sea
In 1989 (before the Exxon Valdez disaster), TEAP established a marine working group in recognition that marine chemical response was not as developed to the degree achieved for land transportation.
The TEAP marine working group was established in 1989. Its aim was to enhance members' abilities to respond to marine incidents to match their land abilities.
The program heavily involved the Canadian Coast Guard. This meant mutual training, equipment sharing, simulation exercises and sharing of expertise with the Coast Guard. Finlayson stressed that there has been good progress, especially in training. "We act as both students and teachers at the Coast Guard's Marine Emergency Management Course.
A manual is being prepared for those who ship by water and it should be completed sometime in 1993. So far, TEAP has handled only one marine incident -- a leaking container on board a docked ship.
Another CCPA initiative that involves TEAP is the CCPA Safety Train. This is a chemical tank car outfitted as a travelling classroom. It will show all the safety procedures, equipment, etc for loading, travelling and unloading. It comes under the Responsible Care program and is a joint effort between the CCPA, the railways and rail car manufacturers.
"It shows how a tank car is constructed and outfitted with emphasis on safety and preventive aspects," Finlayson said. "In the future, it may be modified to allow it to simulate leaks."
The CCPA also established a chemical referral centre which is non-emergency. Calls are not necessarily elaborate. It may be people cleaning their garage and who find an unknown substance. The centre can refer the caller to its list of industry contacts which is cross-referenced with brand and product names. The referral centre's number is 1-800-267-6666.
It all fits
TEAP goes hand in hand with the Responsible Care program. There are codes of practise for transportation in Responsible Care. If not a TEAP member, CCPA companies must have an emergency response plan which is similar to TEAP criteria.
Programs like TEAP and Responsible Care cannot succeed without the willing participation of the members. Finlayson agrees. "Those who sponsor the regional centres are very generous. Many TEAP members have gone beyond what they are required to do under the legal contract. They are acting in good will."
What is CCPA?
The Canadian Chemical Producers' Association was founded in 1962 and now includes 63 member companies representing 150 communities across the country. Its members are responsible for more than 90% of the chemicals -- petrochemicals, inorganic chemicals and other organic and specialty chemicals -- produced in Canada.
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|Title Annotation:||Canadian Chemical Producers' Association's Transportation Emergency Assistance Plan|
|Publication:||Canadian Chemical News|
|Date:||Mar 1, 1993|
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