Incidents, release reporting and emergency response

Despite every precaution, packages leak, trucks crash and tank cars derail. When that happens, the first minutes decide how bad the outcome will be. This lesson covers what drivers, warehouse workers and supervisors should do when dangerous goods are released or about to be released, how to use the Emergency Response Guidebook, and what the law requires you to report and to whom. It is awareness training: it does not prepare you to clean up a spill or enter a contaminated area. Spill response is covered in HSE-251, and hazardous materials responders receive specialized training far beyond this course.

The first actions

If you are the driver or the person on site when dangerous goods are released, your priorities are, in order: protect yourself, protect others, call for help and give responders accurate information. In practice that means:

• Stop the vehicle in a safe place if you can, away from people, buildings, drains and waterways, turn off the engine and set the brakes.
• Stay out of any vapor, smoke, mist or spilled material. Do not walk into or touch it, and do not try to plug leaks unless you are trained and protected.
• Move yourself and others away, upwind, uphill and upstream of the release.
• Warn others, keep bystanders back and prevent smoking or other ignition sources.
• Call 911 or the local emergency number and give your location, the UN numbers or shipping names, the classes, the quantities and what you can see happening.
• Take the shipping documents with you if it is safe, and hand them to the first responders who arrive.
• Follow the instructions of responders, and call the emergency telephone number on the shipping document.

Do not move damaged packages, restart a vehicle that is leaking fuel, or let curiosity draw you closer. Several gases, including hydrogen sulfide (HSE-244) and carbon monoxide, can disable people within minutes or seconds, and others such as propane are heavier than air and collect in low areas where a single spark can ignite them.

The Emergency Response Guidebook

The Emergency Response Guidebook (ERG) is published jointly by the US Department of Transportation, Transport Canada and Mexico's transport secretariat, and PHMSA distributes it free to emergency services. The current edition is ERG 2024; editions are normally issued every four years. It is designed for first responders in the first 30 minutes of an incident involving hazmat, before more detailed information is available. Many carriers carry it as their emergency response information under 172.602, and it is free as an app and online.

The ERG is organized in colored sections:

• The white pages at the front explain how to use the guide, show the placards with the guide to use if only the placard can be seen, and include rail car and road trailer identification charts.
• The yellow pages list materials by UN number, each with a three-digit guide number. Entries highlighted in green indicate a material that is toxic by inhalation, reacts with water to produce toxic gases, or is a chemical warfare agent.
• The blue pages list the same materials alphabetically by name, with the same guide numbers.
• The orange pages are the guides themselves, numbered from 111 to 174. Each guide gives potential hazards (fire or explosion and health), public safety advice (isolation distances, protective clothing, evacuation) and emergency response actions (fire, spill or leak, first aid).
• The green pages give initial isolation and protective action distances for the highlighted materials, for small and large spills, by day and by night, and for some large spills of common toxic gases, by wind speed.

# A tiny ERG-style lookup: UN number -> guide number -> first message (simplified extract).
YELLOW = {"1203": 128, "1075": 115, "1830": 137, "3480": 147, "1005": 125}
ORANGE = {
    115: "Gases, flammable: extremely flammable; may form explosive mixtures with air.",
    125: "Gases, corrosive: toxic, may be fatal if inhaled; fumes extremely irritating.",
    128: "Flammable liquids (non-polar/water-immiscible): highly flammable; fumes may travel to an ignition source.",
    137: "Substances, water-reactive, corrosive: reacts with water; contact causes severe burns.",
    147: "Lithium ion and sodium ion batteries: may ignite; may release toxic and flammable gases.",
}
GREEN = {"1005"}   # toxic-by-inhalation entries highlighted in the yellow pages (illustrative)

for un, guide in YELLOW.items():
    flag = " -> check green pages for isolation distances" if un in GREEN else ""
    print(f"UN{un}: guide {guide}. {ORANGE[guide]}{flag}")

UN1203: guide 128. Flammable liquids (non-polar/water-immiscible): highly flammable; fumes may travel to an ignition source.
UN1075: guide 115. Gases, flammable: extremely flammable; may form explosive mixtures with air.
UN1830: guide 137. Substances, water-reactive, corrosive: reacts with water; contact causes severe burns.
UN3480: guide 147. Lithium ion and sodium ion batteries: may ignite; may release toxic and flammable gases.
UN1005: guide 125. Gases, corrosive: toxic, may be fatal if inhaled; fumes extremely irritating. -> check green pages for isolation distances

In a real incident, responders use the full guide, not a short extract like this. The point is the workflow: identify the material by UN number or name, find the guide, check the green pages if the entry is highlighted, and read the whole orange guide before acting. If the material cannot be identified, guide 111 (mixed load or unidentified cargo) gives cautious general advice.

Emergency advice centers

CHEMTREC, a call center funded by the chemical industry, provides 24-hour emergency response information and can connect responders with shippers and manufacturers; many shippers list it as their emergency response number. Emergency services also contact the National Response Center, operated by the US Coast Guard, which receives release reports and alerts federal agencies. Calling the emergency response number on the shipping paper brings in the people who know the product best. For cross-border shipments, CANUTEC in Canada provides the equivalent service.

What must be reported

Under 49 CFR 171.15, a carrier must give immediate telephone or online notice to the National Response Center, at 1-800-424-8802, as soon as practical and no later than 12 hours after an incident in which, as a direct result of the hazmat, a person is killed or injured and hospitalized, the general public is evacuated for one hour or more, a major transportation artery or facility is closed for one hour or more, the flight pattern of an aircraft is altered, there is fire, breakage, spillage or suspected contamination involving radioactive material or an infectious substance (other than regulated medical waste), or a marine pollutant is released above set amounts. The carrier must also report any situation it judges important enough to report.

Under 171.16, a written Hazardous Materials Incident Report, DOT Form F 5800.1, must be submitted to PHMSA within 30 days for any unintentional release of hazmat in transportation, including loading and unloading, with some exceptions for small releases of certain lower-hazard materials, and for any incident that required an immediate notice. Undeclared hazmat discovered in transportation must also be reported. A follow-up report may be required within a year if new information comes to light. Releases of hazardous substances at or above their reportable quantity must also be reported to the National Response Center under environmental law, and state and local rules may add their own reporting duties.

# Which US reports are needed? (simplified from 171.15 and 171.16; check the regulations)
def reports(release, hospitalized=False, evac_hours=0, artery_closed_hours=0,
            radioactive_or_infectious=False, small_exempt=False):
    out = []
    if hospitalized or evac_hours >= 1 or artery_closed_hours >= 1 or radioactive_or_infectious:
        out.append("immediate notice to National Response Center within 12 hours")
    if (release and not small_exempt) or out:
        out.append("Form 5800.1 to PHMSA within 30 days")
    return out or ["no DOT incident report (still clean up and record)"]

cases = [("small leak of consumer paint, exception applies", (True, False, 0, 0, False, True)),
         ("drum of solvent leaks at dock", (True,)),
         ("tank truck rollover, highway closed 3 hours", (True, False, 0, 3))]
for label, args in cases:
    print(label, "->", "; ".join(reports(*args)))

small leak of consumer paint, exception applies -> no DOT incident report (still clean up and record)
drum of solvent leaks at dock -> Form 5800.1 to PHMSA within 30 days
tank truck rollover, highway closed 3 hours -> immediate notice to National Response Center within 12 hours; Form 5800.1 to PHMSA within 30 days

These helpers show the logic, not the full legal test. When in doubt, report: regulators would rather receive an unnecessary report than miss one that was required, and failing to report is itself a violation.

After the emergency

Once responders have the situation under control, the shipper, carrier and their response contractors arrange cleanup, product transfer and disposal, often under environmental law. Everyone involved should preserve evidence, record what happened and cooperate with investigators. A good internal review asks why the release happened (a loose closure, a wrong packaging, poor securement, a crash) and what will prevent the next one, using the investigation methods covered in HSE-403.