Eight hours of training is mandatory for the first-responder operations level, in addition to worker competency at the first-responder awareness level. The required training is to prepare these employees to perform diking, ditching, and similar activities of a defensive nature -- activities that do not require chemical protective clothing. Where a fire occurs at the operations level, offensive actions may be taken to extinguish the fire provided that no chemical protective clothing is required. For example, in the case of a liquified petroleum gas fire, personnel at the first-responder operations level would work to shut off the gas flow and extinguish the fire once it was determined that no other chemicals are present and that offensive actions are required. Show
When these employees are expected to handle emergencies involving flammable liquids and gases in an offensive mode, then additional training is necessary and a minimum of 24 hours of training at the first-responder operations level is recommended. Such a 24-hour operations level training course will prepare those wishing to move up to the technician level of the on-scene commander level. _________________ 3 See NFPA Publication No. 472-1989, Standard for Professional Competence of Responders to Hazardous Materials Incidents (Quincy, Massachusetts: NFPA, 1989). Next in the training hierarchy are the requirements for "hazardous materials technicians" and "hazardous material specialists." These are the employees OSHA expects to be used to staff "hazardous materials teams" (Hazmat teams), spill control teams, and similar groups. Consequently, these employees must have chemical protective clothing available for their use. The skill requirements for the hazardous material technicians are somewhat lower than those for the hazardous materials specialists. Hazardous materials technicians must have 24 hours of training at the first-responder operations level in addition to the knowledge and skills training the standard sets forth as necessary for these technicians. The standard requires that hazardous materials technicians know, among other things, how to implement the employer's emergency response plan, how to properly select and use specialized chemical personal protective equipment and clothing, and how to implement proper decontamination procedures for hazardous substances. The more skilled hazardous materials specialists will generally serve as the senior members of hazmat teams. At this level are the most highly skilled and trained responders having the broadest knowledge of hazardous substances. The training required for a hazardous material specialist includes at least 24 hours of training at the technician level and such additional training or experience as necessary to acquire the knowledge and skills set forth in the standard. The necessary skills and knowledge are to include, among other things, (1) how to implement the emergency response portions of the local emergency response plan developed under SARA Title III, (2) how to develop a site safety and control plan for hazardous substances emergency incidents, (3) how to properly use and calibrate hazardous substance sampling instruments (such as multiple organic vapor analyzers and the photoionization detectors), and (4) an understanding of the emergency response portions of the state emergency response plan developed under SARA Title III. The on-scene incident commander, or officer in charge of the overall operations at the scene of an incident, should be a generalist with a broad knowledge of managing emergency incidents. The commander level requires at least 24 hours of training at the first-responder operations level, with additional training or experience in how to manage emergency incidents involving hazardous substances. At a minimum, the additional training is to include an understanding of (1) how to implement the employer's incident command system and the employer's emergency response plan, (2) the hazards and risks that are faced by responders working in chemical protective clothing, (3) how to implement the relevant parts of the local emergency response plan created under SARA Title III, and (4) the importance of following decontamination procedures. Other categories of emergency responders identified in the standard include the "skilled support person," and "specialist employee." Skilled support personnel are those who may occasionally assist the incident commander by operating cranes, back hoes, or trucks. Since many of these workers do not expect to help in such incidents and do not have even minimal awareness training, attention must be given to their proper safety and health protection at the scene before they participate in the incident. This can be accomplished by an on-site briefing that includes a discussion of the hazards present, the personal protective clothing and equipment to be used, how the equipment is used, and the exact task they are expected to perform. The "specialist employee" is an expert who may assist, counsel, or advise the incident commander. Specialist employees may provide technical assistance in operations such as servicing specific valves on a tank car, or in similarly skilled areas, in addition to offering advice. Specialist employees could also be medical or environmental experts. Even though specialist employees are experts in their respective areas, they must be trained in how to interact within the incident command structure, and how to follow the operating procedures established by their employer. Their required training also is to inform them of the hazards that may be present at an emergency site. All emergency response personnel covered by paragraph (q) must receive refresher training, at least annually, to ensure that their skills and competencies do not deteriorate and are not forgotten. Training that expands the knowledge of emergency responders upward along the continuum is acceptable to meet the annual refresher training requirements for the year during which the training was received. It should be mentioned that the OSHA interim final rule requires 24 hours of training annually for emergency responders. The emergency responders who received training under the interim final rule should be able to apply a good portion of that training towards meeting the requirements of the final rule for their specific level of response. For example, fire department or fire brigade members who received training at the first-responder operations level under the interim final rule may use those training hours that are relevant to their assigned duties to meet their obligations under the final rule. This is also true for hazardous materials team members and on-scene incident commanders. As a result, some additional training for experienced emergency responders may be necessary to comply fully with the training requirements for their response level. Newly employed personnel, however, will need to comply fully with all the hours of training and related competencies for the level of work they are expected to perform. Summary Title III of SARA, "The Emergency Planning and Community Right to Know Act of 1986," focuses on numerous issues that complement OSHA's standard. This law prescribes in detail the efforts to be made by states and local planning districts to develop and implement effective emergency response plans for their communities. The planning efforts are now, and will continue to be, of major significance in helping employers and emergency response organizations develop complete, quality plans, and to utilize such plans effectively. Local emergency response plans must include training schedules, and schedules for conducting drills and exercises of the local district plans. Drills and exercises may be used, in part, to help meet the annual refresher training requirements for covered employees. As discussed above, OSHA's hazardous waste standard requires that various responders be trained according to their responsibilities so they are knowledgeable of local emergency response plans, and are able to effectively implement the plan. These OSHA requirements and those of Title III of SARA interact effectively and support each objective in achieving the ultimate goals of ensuring the safety and health of emergency responders, as well as providing improved coordination and protection for local communities. Thomas Seymour is Deputy Director of OSHA's Directorate of Safety Standards Programs. Bibliography Brunacini, Alan V. Fire Command. Quincy, Massachusetts: NFPA, 1985. Brunacini, Alan V., and Beageron, J. David. Workbook for Fire Command. Quincy, Massachusetts, 1985. Comprehensive Environmental Response, Compensation, and Liability Act of 1980. Public Law 96-510. 42 United States Code 9601. December 11, 1980. Incident Command System. Fire Protection Publications. Stillwater, Oklahoma, Oklahoma State University, 1983. National Fire Protection Association. Standard for Professional Competence of Responders to Hazardous Materials Incidents, NFPA No. 471-1989. Quincy, Massachusetts: NFPA, 1989. Superfund Amendments and Reauthorization Act of 1986. Public Law 99-499. 42 United State Codes 9601, Titles I-IV. October 17, 1986. U.S. Environmental Protection Agency. Worker Protection Standards for Hazardous Waste Operations and Emergency Response - Final Rule. 40 Code of Federal Regulations Part 311.2. In: Federal Register, Vol. 54, No. 120, Part IV. Washington, D.C.: Office of the Federal Register, June 23, 1989. Pp 26654-62258. U.S. Department of Health and Human Services. National Institute for Occupational Safety and Health. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities. NIOSH/OSHA/USCG/EPA. Publication No. DHHS (NIOSH) 85-115. Washington, D.C.: U.S. Government Printing Office, 1985. U.S. Department of Labor. Occupational Safety and Health Administration. Hazardous Waste Operations and Emergency Response - Final Rule. 29 Code of Federal Regulations Part 1910.120. In: Federal Register Vol. 54, No. 42, Part III. Washington, D.C.: Office of the Federal Register, March 6, 1989,. Pp 9294-9336. U.S. Department of Labor. Occupational Safety and Health Administration. Hazardous Waste Operations and Emergency Response - Interim Final Rule. 29 Code of Federal Regulations Part 1910.120. In: Federal Register, Vol. 51, No. 244, Part IV. Washington, D.C.: Office of the Federal Register, December 16, 1986. Pp 45654-45675. U.S. Department of Labor. Occupational Safety and Health Administration. Hazardous Waste and Emergency Response. Publication No. OSHA 3114. Washington, D.C.: U.S. Government Printing Office, 1989. U.S. Department of Transportation. Research and Special Programs Administration. Office of Hazardous Materials Transportation. 1987 Emergency Response Guidebook. Publication No. DOT P 5800.4. Washington, D.C.: USDOT, 1987. On May 2, 1990, Ms. MaryAnn Garrahan of your staff requested a review by this office of an interpretation of 29 CFR 1910.120. The interpretation was requested by Mr. Terry A. Noteboom of
Rockwell International Avionics Group in a letter to you dated April 12, 1990. The following comments are offered by this Directorate: 1. In the second paragraph, after the first sentence, we would suggest language similar to the following: "The quantity of product spilled does not by itself determine if an incidental spill has occurred. Several variables, including the volume of the spill, must be considered in evaluating the hazard of the release to employees." Many employers are trying to
draw a parallel connection between OSHA's emergency response definition and EPA's use of reportable quantities. We need to emphasize that other factors should play a role in the determination of an emergency. 2. In the fifth paragraph, beginning "The training requirements...", in the second sentence, the parenthetical note implies that 24 hours of emergency response training is the upper limit of training necessary in (q). The highest level of response, the hazardous materials specialist,
requires a minimum of 24 hours of hazardous materials technician training plus competency in nine specific areas of response. Any attempt to acquire the competencies covered under (q)(6)(iv)(A) through (I) would require more than 24 hours of training. Experience from the rulemaking, including testimony at our hearings, shows that employees trained to the levels of competency required in (q)(6)(iv) have received in excess of 100 hours of training. We suggest adding the phrase, "...plus the
training necessary for the competencies listed", at the end of the parenthetical note. Which of the following is a 24 hour resource operated by the Chemical Manufacturers Association?The Chemical Manufacturers Association supports an excellent resource, the CHEMTREC 24-hour information number, 1-800-424-9300.
Which of the following zones designates where the hazardous materials contamination is actually?The exclusion zone (or hot zone) is the area with actual or potential contamination and the highest potential for exposure to hazardous substances.
What is the number of patients that generally serves as the lower threshold for a multiple casualty incident?If the incident necessitates a deviation from the normal course of EMS operations, consideration should be given to activate the MCI plan. The threshold number has been established at 6 victims.
What does the C in the mnemonic Tracem stand for?TRACEM-P is used to remember the mechanisms that cause harm in terrorism: T - Thermal. R - Radiological. A - Asphyxiation. C - Chemical.
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Which of the following hazmat training levels requires at least 24 hours of training?
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