EMS 1.4.6

When to Consider Contacting a Qualified Hazmat Responder

EV recovery operations can involve complex hazards, including chemical leaks, battery fires, and potential environmental contamination. While tow operators are trained to manage many of these situations, certain conditions warrant the involvement of a certified hazardous materials (hazmat) subcontractor to ensure safety and compliance with regulatory standards. This lesson outlines the decision-making criteria for determining when to bring in hazmat specialists. The following list is not exhaustive, and each scene requires an independent assessment.  

Chemical Spills or Leaks
• Presence of liquids with a sweet, ether-like odor, indicating lithium-ion battery electrolyte leakage.
• Uncertainty about the source of a fluid leak, particularly if it could involve hazardous substances.
• Signs of chemical burns, corrosion, or visible damage to the high-voltage battery casing.
Active or Residual Fire Risks
• Visible flames, smoke, or evidence of thermal runaway, such as hissing, popping, or bubbling sounds.
• High residual heat detected in the battery system using thermal imaging, even after initial cooling efforts.
• Re-ignition risks during transport or storage due to battery damage.
Environmental Contamination
• Evidence of hazardous material spreading into nearby soil, water, or drainage systems.
• Recovery operations taking place near environmentally sensitive areas, such as wetlands or protected habitats.
• Leaking fluids or debris from the vehicle posing risks of contamination.
Vehicle Submersion in Water
• Vehicles submerged in saltwater, which increases risks of electrical short circuits and corrosion.
• Submersion incidents involving visible damage to the high-voltage system.
Severe Structural Damage to Battery Systems
• Visible detachment of battery cells or modules from the main casing.
• High-voltage cables with torn or pinched sheathing that may expose conductors.
Regulatory or Compliance Concerns
• Incidents requiring documentation and reporting to regulatory bodies due to hazardous material involvement.
• Situations where local environmental laws or industry standards mandate hazmat oversight.
A hazmat team in general can provide the following guidance and support:
• Hazmat teams are trained to contain, neutralize, and properly dispose of hazardous substances.
• Specialized equipment, such as spill containment kits and neutralizing agents, may be required.
• They ensure proper handling and monitoring to prevent or reduce secondary incidents.
• Certified hazmat teams follow environmental protocols to mitigate contamination and restore affected areas.
• They can help to ensure proper isolation and containment of compromised systems.
• Hazmat teams provide the expertise and documentation needed to comply with regulatory requirements.
Ultimately, the decision to engage a hazmat team rests with the tow operator, who must evaluate the specific risks of the incident in alignment with their company’s protocols, industry best practices, and applicable insurance requirements.
Acion Items to Consider
• Create a Subcontractor Qualification Checklist to streamline the vetting process
or secure a pre-approved list of contractors to call upon.
• Develop a Recovery Communication Form to document information shared
with subcontractors, emergency personnel, and regulatory officials.
• Prepare a Template Contract to standardize agreements with subcontractors,
emphasizing EV-specific recovery standards.
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