Emergency Response Plan

The

Emergency Response Plan (ERP)

is a core supporting document used to demonstrate that the receiving facility identified in

Block 7

can manage incidents safely and maintain environmentally sound management (ESM). Competent authorities often expect an ERP (or equivalent site-specific emergency procedures) where the waste stream presents credible risks (e.g., flammable solvents, corrosives, batteries, ULABs, reactive chemicals). A generic corporate HSE manual is rarely sufficient — the plan must be

site-specific

and aligned to the facility’s permitted operations.

← Back to Knowledge Hub

What This Document Covers

This ERP is the facility’s operational playbook for managing emergencies that could occur during receipt, storage, handling, and processing of hazardous waste. It supports the facility’s claim of capability underBlock 7and helps demonstrate that the site can respond to incidents without creating additional cross-border environmental harm.

When Authorities Expect It

• Higher-risk waste streams: flammable liquids, corrosives, toxics, reactive waste, batteries, ULABs, e-waste, or mixed hazardous residues.
• Thermal or chemical treatment: incineration (D10), physico-chemical treatment (D9), metal recovery (R4), battery recycling operations, or any process involving heat/acid/alkali.
• Facilities with complex logistics: multiple storage areas, intermediate handling steps, subcontracted operations, or shared industrial sites.
• Where the permit requires it: many national environmental permits include emergency preparedness obligations and reporting timelines.

Required Sections

• Facility Identification: legal entity, site address (operational location), 24/7 emergency contact details, and after-hours escalation chain.
• Site Layout & Control Points: site map showing storage zones, processing areas, drainage controls, bunding, spill kits, extinguishers, isolation valves, and muster points.
• Credible Emergency Scenarios: spill/leak, fire/explosion, gas release, incompatible mixing, runaway battery event, container rupture, vehicle incident, and severe weather/flooding impacts where relevant.
• Immediate Response Procedures: isolate area, stop source, contain/collect, prevent discharge to drains, decontamination steps, and safe temporary storage of cleanup residues.
• PPE & Equipment: minimum PPE by scenario, location of equipment, maintenance/inspection schedule, and responsible persons.
• Notifications & Reporting: who must be notified (internal + external), timelines, incident log requirements, and corrective/preventive actions (CAPA).
• Training & Drills: induction training, refresher training frequency, drill schedule, and records retention.
• Interface With Transport: receiving procedures for damaged loads, emergency handover, and how transport documents (SDS / emergency instructions) are used on arrival.

Common Gaps That Trigger Questions

• Not site-specific: a corporate policy document without site maps, equipment locations, or scenario procedures.
• No linkage to waste hazards: ERP does not address the actual chemicals/materials listed in the notification (e.g., acids for ULABs, thermal risk for lithium batteries).
• Missing 24/7 contacts: only business-hour phone numbers provided, with no escalation path.
• Unclear containment controls: no detail on bunding, drainage isolation, or how spills are prevented from reaching soil/water.
• No proof of readiness: absent drill records, equipment inspections, or training evidence.

How To Use It In a Basel Notification Pack

Attach the facility ERP (or the emergency preparedness section of the facility’s permit package) as a supporting document referenced in your submission. Ensure the ERP aligns to thefacility named in Block 7and theoperation identified in Block 10. Where the ERP is lengthy, include a one-page ERP summary highlighting the emergency contacts, response capabilities, and containment controls.

Real-World Example

A lead-acid battery recycler receiving ULABs maintains a site-specific ERP that includes acid spill neutralization procedures, lead exposure controls, containment to prevent discharge to drains, and a 24/7 emergency escalation chain. The ERP references equipment locations (spill kits, neutralizing agents, bunded areas) and includes drill records and inspection logs.

Related Documents

• Transport Documentation✅ - Emergency instructions, hazard communication, and transport controls that interface with facility receiving procedures.
• Basel Compliance Checklist✅ - A consolidated checklist to verify your notification pack is complete and internally consistent.

Common Error: Uploading a generic “Health & Safety Policy” and calling it an emergency plan. Authorities (and auditors) look for

site-specific procedures

: scenario response steps, site map, equipment locations, 24/7 contacts, containment controls, and evidence of training/drills. If the facility operates multiple sites, the ERP must match the

exact operational site address

identified in Block 7. Compliance Tip: For ULAB and e-waste shipments, validate that the ERP specifically covers

acid spills, fire/thermal events, and contaminated cleanup residues

. Confirm the facility has practical controls (bunding/drain isolation, neutralization agents, spill kits) and that emergency contacts are reachable 24/7. If the receiving facility uses subcontractors (e.g., off-site treatment), document the emergency interface and responsibilities clearly. Back to Knowledge Hub

COP-17 update: Annex IV and e-waste guidelines

COP-17 was held from 28 April to 9 May 2025 and adopted 28 Basel Convention decisions. Operators should treat those decisions as the current reference point when preparing Basel Convention files for transboundary movements.

BC-17/15 adopted a replacement Annex IV. The update is scheduled to become effective on 1 January 2030, following depositary communication on 1 July 2029. Until national implementation is confirmed, use current domestic rules but plan workflows, contracts, and recovery/disposal references for the 2030 Annex IV replacement.

BC-17/4 adopted new technical guidelines on transboundary movements of e-waste and used electrical and electronic equipment (EEE). For e-waste and used EEE movements, reference these COP-17 guidelines when preparing classification, PIC, ESM, and supporting documentation.

Practical operator note: for 2025–2029 files, record which Basel decision basis is being used, confirm competent-authority expectations, and revisit Annex IV and e-waste assumptions before shipment approval or renewal.