ALLGEMEINE BAU-CHEMIE (ABC) PHIL., INC.

CEBU PLANT
NA-ALAD, CITY OF NAGA, CEBU

COMPREHENSIVE CONTINGENCY PLAN

(D407-Mercury and Mercury Compounds)

I.

Introduction
The use of hazardous material like mercury and mercury compounds has become an
everyday occurrence especially those contained in lamps. They can be found in
administrative offices, laboratory and production area. This lamps will eventually be not
functional, thus, there is an increase of generation of such hazardous waste. The
company is committed to safely store, transport and treat this hazardous waste to avoid
possible negative effect of such waste to the environment.
The purpose of this contingency plan is to minimize the hazards to human health or the
environment for possible unplanned sudden release of hazardous materials or
hazardous waste constituents to air, soil or surface water.
Mercury released from broken lamps and mercury contaminated materials vaporize at
room temperature. Mercury vapor is extremely toxic. Mercury is the only heavy metal
that is liquid at room temperature. Because of this and other useful properties its usage
is commonplace. It can be more harmful to inhale the vapor from a bead of mercury
than to ingest the same bead. At room temperature mercury vaporizes readily into an
invisible, odorless, and tasteless and potentially harmful element.
Ambient mercury levels in the breathing zone can be controlled if personnel are aware
of and trained in mercury management. Be conscious of the hazard of unseen mercury
contamination in cracks, corners and untreated storage containers.

II.

Emergency Response Organizational Structure

ENGR. NOLI S. SEMENIANO
MANAGING HEAD/Incident Commander

BERNARD PALERMO
PLANT OIC/SUPERVISOR

NESSA AMPOLOQUIO

NEIL JOHN LEQUIGAN

Public Information
Officer

Pollution Control
Officer

City of Naga- Local

Government Unit,
Bureau of Fire
Protection, etc.

DENR- Environmental
Management Bureau
Region VII

JEFFREY TABAR
Logistics/Warehouseman

ENGR. DARYLL
MARANON
Operations/Maintenance

FIRST RESPONDERS
PRODUCTION WORKER, UTILITIES

NEIL JOHN LEQUIGAN

POLLUTION CONTROL
OFFICER

Note: Green and Blue box indicate that the following entity is not part of the proponents workforce.
Roles and Responsibilities

First Responders
1.
Immediately warn other personnel working near the area.
2.
Evacuate the area if the health and safety of personnel is threatened.
3.
Notify direct supervisor who will initiate the response operations.
4.
In the absence of danger, take any safe and reasonable measure to stop, contain
and identify the nature of the incident.
5.
Participate in response as directed by the Pollution Control Officer/Operations.
6.
Conduct cleanup under direction of direct supervisor.
Pollution Control Officer
1.
Submit incident report to EMB.
2.
Ensures cleanup is completed to standards.
3.
Notify Operations Manager, Logistics, and PIO.
4.
Provides update to the Operations, Supervisor and Incident Commander.
5.
Record date, location, volume, reason for release, any negative impact, status of
cleanup, and corrective actions taken.
6.
Conducts ongoing monitoring of cleanup operations leading to close-out.
Operations/Maintenance
1.
Provides advice and ensures cleanup is completed to standards
2.
Ensures Emergency Response Team is adequately trained in incident response.
3.
Ensures Emergency response and/or monitoring equipment and supplies are
regularly inspected and maintained
4.
Organize response training and exercises.
5.
Lead investigation and identify measure and/or training to prevent similar incidents.
Logistics/Warehouseman
1.
Regularly check warehouse and busted lamps storage area to avoid possible
breakage of busted lamps.
2.
Ensures busted lamps has reached destination in case of transportation for
treatment of hazardous waste.
Public Information Officer
1.
Notify City of Naga-Local Government Unit in case of incidents.
2.
Secure permits from other Government Agencies.
Plant OIC
1.
Assist in initial and ongoing response efforts.
2.
Provide advice to assist with cleanup.
3.
Co-ordinate inspections and closure by applicable agencies.
4.
Assist with investigation and identify measure and/or training to prevent similar
incidents.

Managing Head/Incident Commander

1.
Spearhead the emergency response team.
2.
Ensure tracking and recording of non-reportable incidents.
3.
Provides advice, when required, to the Pollution Control Officer, and Operations
Manager on handling the situation, storage and disposal options.
4.
Assists in developing effective incident management and prevention practices.

III.

List of Potential Emergencies and Scenarios

The table below shows the list and descriptions of possible incidents and emergencies that
might occur inside and outside plant premises. This involves mercury and/or mercury
compounds contained in busted lamps. The emergency response team has to do reporting
and corrective actions according to procedure which will be discussed in the following
pages.

IV.

Emergencies/Incidents

Description

Broken Busted Lamps inside

plant premises

A scenario wherein possible inhalation of mercury vapour

occurs.

Vehicle accident during

transportation of mercury
and mercury compounds
contained in busted lamps

This worst case scenario could result in busted lamps being

transported causing the breakage of busted lamps and
eventually can cause possible inhalation of mercury
compounds.

Mercury and mercury

compounds storage drums
leaking

Storage tank of busted lamps may be corroded and cause

possible leaking of mercury and/or mercury compounds.

Procedure for Handling and Responding to Mercury and Mercury

Compounds contained in Busted Lamps Releases
1. Proper Handling Procedures for Mercury Lamps
PURPOSE: To ensure that an employees exposure to mercury is minimized and that
materials containing mercury are handled and disposed of in an environmentally sound
manner.

BACKGROUND: All fluorescent lamps and most other types of energy efficient lighting
contain elemental mercury. Mercury has a unique combination of properties that make
it the most efficient material for use in fluorescent and 4 HID lamps. The basic operating
principles of fluorescent lamps depend on production of ultraviolet (UV) light and
mercury is the most efficient product of the required UV. Safeguarding used lamps from
breaking will minimize releases of mercury into the environment. Normal handling is a
very low risk activity.

HANDLING PROCEDURES:

Procedure for handling unbroken fluorescent lamps for packaging. Employee should
wear the following safety equipment.
1. Gloves made of leather, or equivalent
2. Safety glasses with side shields or full face shield
3. Safety toed shoes or boots
STEP 1:
Place used lamps into new or used lamp boxes (the original egg crate material does not
have to be placed back into the boxes) and tape the ends to secure the box, but do not
make it hermetically sealed (air tight). There are other suitable containers available
commercially or from recyclers.

Broken or crushed lamps should be packaged in an approved container (e.g. 55 gallon drum) or
bagged into smaller containers.
Badly damaged boxes, wet boxes, etc. may not be accepted for transport.
Boxes should be kept in a secure, dry area.
For larger quantities, cross-stack and palletize lamp boxes to a maximum height of 6 feet. Secure
boxes to pallet with shrink wrap or stretch film.
All pallets need to be labelled as Used Mercury Lamps.
STEP 2:
All employees who handle Busted Lamps Wastes shall wash hands with soap and water
when beginning a work shift, before a break, and upon completion of the work shift. No
tobacco materials, food, or beverages are permitted while working with mercury lamps.
STEP 3:
It is the employees responsibility to ensure that these handling and disposal
procedures are fully carried out. The proper use of the prescribed safety equipment will
protect the employee from the potential dangers of contamination from mercury.

2. Emergency Procedures- Breakage

PURPOSE: To ensure that accidental breakage is cleaned up without spreading the
mercury and with minimum exposure to employees.
BACKGROUND: Lamps are fragile and they can easily break. The regulations distinguish
between accidental breakage that occurs during normal transport and intentional
breakage or crushing.
1. If a lamp breaks in your home or workplace, close off the room to other parts of the
building.
2. Open a window to disperse any vapor that may escape, and leave the room for at
least 15 minutes.
3. Carefully scoop up the fragments with a stiff paper or a broom and dustpan (do not
use your hands) and wipe the area with a disposable paper towel to remove all glass
fragments.
4. Do not use a vacuum, as this disperses the mercury over a wider area.
5. All fragments should be placed in a sealed plastic bag and properly disposed of. A
hazardous lamp that is broken must be cleaned up and placed in a container. The
container must be closed, structurally sound, compatible with lamps, and lacking any
evidence of spillage.
6. For larger quantities of lamps broken at the same time (for example, a box of lamps
falling from a lift truck) the use of Personal Protective Equipment may be required and
we suggest contacting a hazardous waste cleanup contractor.

V.

Schedule and Conduct of Drills

A drill is to be held annually. This drill must include a familiarization of all onsite personnel on their
responsibilities including what to do in case of a breakage and spill of mercury compounds. The drill
must also include a hands-on scenario where the Emergency Response Team utilizes equipment to deal
with the breakage and spill scenario. The drill may be broken down into two or more sessions to ensure
adequate coverage. Records of this testing are to be kept on file and posted to provide access for those
who were unable to attend.

REFERENCE:
Training Module (1-hour version) for Generators and Handlers of Fluorescent and MercuryContaining Lamps (and Ballasts) prepared by The Lamp Recycling Outreach Project