Spills can be catastrophic. But more spills happen when operators, mechanics, and applicators are fatigued or in a hurry. Bypass the stress and worry about having a spill by planning out your actions before those decisions are time-critical.
An Incident Response Plan is required for some businesses, but a good practice for all. A good plan is tailored to your business practices. It outlines the steps for effective spill response and cleanup.
A sample incident response plan is available from the MDA. Incident Response Plan Sample (PDF)
Developing and Maintaining your Incident Response Plan
Who is required to have a plan?
Some businesses are legally required to develop and maintain an incident response plan. If your business is engaged in one or more of the following, it must establish and maintain an incident response plan:
- Commercial pesticide application;
- Pesticide dealer;
- Noncommercial pesticide application;
- Structural pest control;
- Storage of bulk pesticides; and/or
- Storage of bulk fertilizers, including anhydrous ammonia
Regardless of whether you fall into one of these categories, an incident response plan is part of good business planning.
Where should I keep the plan?
The incident response plan must be kept at the principal business site or location within the state. This is a location that is staffed year-round and is the repository of business documents. It is still necessary that unmanned or seasonal-use facilities have the knowledge, training, and resources to respond to an incident at those locations.
We recommend that another copy of the plan be kept at a secondary location so that if an incident makes the site or plan inaccessible, you will still be able to obtain and refer to a copy of the plan.
Incident Response Plan Contents
State pesticide and fertilizer laws require the following activities to be documented accordingly:
- be updated every three years, or whenever contents become outdated;
- be reviewed with employees once per year
- be made available to local first responders
Plan contents include:
- Identity and contact information for persons, companies, and agencies to be notified in the event of a release
- Ag chemical purchase information
- Procedures to implement to control and respond to a release and recovery of product during transport, storage or application.
- Emergency equipment and supplies
- Maps and diagrams of the facility itself and surrounding environment
- Ag chemical inventory, labels, and SDS
Incident Response Plan Backgrounder & Disclaimer
Legislative changes to incident response plan requirements were enacted in 2015. The changes were made to clarify who needs a plan, what the plan must contain, and how to maintain a plan. Identical language is now used for both fertilizer and pesticide plans so if you handle both products, you only need one plan.
This sample plan has been prepared by the Minnesota Department of Agriculture (MDA) to provide general guidance to those persons required to develop and maintain an incident response plan.
Facility owners/managers are not required to use this sample form, but plans must cover all the contents of this sample form. Contents of the Appendix are not required but firms are strongly encouraged to consider any topics that apply and include them in your plans.
Plan contents found in an approved federal Risk Management Plan (RMP) Prevention Program and Emergency Response sections for your facility may fulfill requirements for the anhydrous ammonia portion of your incident response plan provided they are 1) updated at least every three years, 2) reviewed with employees at least once per calendar year and include documentation of training events, and 3) are made available to local first responders and documented accordingly.
The MDA makes no claims, implied or otherwise, as to the suitability of the personal protective gear, emergency response and excavation equipment, or procedures with regard to release remediation, firefighting, or first aid discussed in this sample plan.
This incident response plan fulfills requirements established by the MDA. Other local, state, federal, or tribal agencies may have additional information needs not covered in this sample plan.
The Occupational Safety and Health Act (OSHA) places substantial emphasis on employee training. All employees of the facility should be trained to identify an emergency response incident (e.g., major or minor spills, potential for fire, etc.), who to call for remediation assistance, and/or evacuation routes. If employees are to participate in emergency response and remediation (e.g., firefighting, etc.), those employees must be trained to perform the necessary tasks safely. Employees must also know what personal protective equipment to use, when and how to use it, and who to call for assistance.
Pesticide Environmental Stewardship is sponsored by the Center for Integrated Pest Management to promote proper pesticide use and handling.
National Pesticide Information Center at Oregon State University is funded by the US EPA and contains information on health, safety and regulations on pesticides that may be valuable when developing an Incident Response Plan.
Pesticide Application Certification-University of Minnesota Extension
Study manuals include guidance on incident response, first aid, PPE and other related topics. The MDA partners with the University of Minnesota Extension to ensure responsible management of pests and pesticides for public health, safety, and environmental protection.
The Agricultural Retailers Association is an industry association that offers professional development courses on crisis management and crisis communications.
Emergency Management Institute (EMI) offers self-paced course designed for people who have emergency management responsibilities and the general public. All are offered free-of-charge to those who qualify for enrollment. Recommended courses are ICS-100, ICS-200, IS-700, and IS-800.
Implementation of the preparedness program includes identifying and assessing resources, writing plans, developing a system to manage incidents and training employees so they can execute plans. Look at a variety of plans available to you to expand your suite of emergency planning.