Many employers at work sites where chemicals are used
believe the employee training requirements in paragraph (q)(6) of the HAZWOPER standards do not
apply to their work site because if they were to have a large chemical spill or
release at the site, they would simply call in an outside firm or
organization (like the local Fire Department) to handle the emergency. However,
what many employers do not realize is that even if they call in an outside
company or organization to deal with the spill, they may still have people in their
organization that are required to have a certain level of training per paragraph
(q)(6) of the HAZWOPER standards for general industry (1910.120) and construction (1926.65). To help illustrate what I mean, consider the
following hypothetical scenario:
“A
forklift operator at a factory accidentally strikes some pipes that run between
chemical tanks located behind the shop, and the chemical began running onto the
ground. The forklift operator quickly alerts his foreman about the accident.
The foreman looked at the accident site from a safe distance and realizes that the
quantity of chemical being released is beyond an incidental spill that could be
safely handled by normal operating personnel, so he tells his workers to
evacuate the area, and then he contacts the site safety manager to report the
incident. The site safety manager immediately calls the local Fire Department
to report the spill and specifically requests they send their hazardous
materials (HAZMAT) response team to the site. He then goes to the general area
of the accident, careful to remain a safe distance, and observes some of the
liquid chemical is running across the pavement towards a storm drain inlet. So
he quickly grabs some absorbent “pigs” from a nearby spill response kit and
places them across the opening of the storm drain inlet before the chemical can
reach the area.
Once
the fire department’s HAZMAT team arrives, their incident commander confers
with the safety manager, and then instructs two of his team members to gear up
and take monitoring equipment to the point of release to confirm which chemical
is involved and to evaluate any potential atmospheric and/or safety hazards. By
that time, the company’s head of the engineering department arrives at the
scene, and he gears up to go into the hot zone with the fire department’s
HAZMAT team members so he can point out which valves need to be shut off to
stop the flow of chemical. Once the valves are identified, one of the HAZMAT
team members turns off the valves to stop the chemical from running out of the
broken pipes, and then they stabilize the area to prevent further spread of the
chemical.”
Wherever there is an initial response to a hazardous
material that is spilled or otherwise released in quantities beyond an
incidental spill, such as at the factory in our scenario, the OSHA HAZWOPER
standard has specific training standards in paragraph (q) for five distinct categories
of workers potentially involved in the initial response. Here is an overview of
training requirements for workers in all five worker categories mentioned in our
scenario:
· The first worker category listed in paragraph (q)
of the standard is called “First Responder Awareness Level”, and their training
requirements are described in 1910.120(q)(6)(i). In our scenario, this person is
the foreman in the area where the forklift struck the pipes. In other
incidents, this may be someone such as a police officer who happens upon a
major wreck involving a chemical tank-truck, or perhaps a security officer
making rounds after hours at a chemical manufacturing plant who happens upon an
unexpected spill or release of chemicals. The First Responder Awareness Level employee
must be provided with training sufficient to understand that the release of
chemicals is beyond the scope of an incidental release, and that it will
require response and clean-up by specially trained workers. The foreman in our
scenario notified the site safety manager of the release, and also initiated
the evacuation of workers in the area per his company’s emergency action plan.
He did not take any further action to try to contain or confine the chemical
release. Awareness level responders must also receive adequate training to be
able recognize and identify the hazardous substance(s) involved in the release,
to understand the risks presented by the hazardous material(s) involved, and be
able to implement whatever part they are assigned in executing the emergency
action plan at the site. There is no minimum time period that their training
must cover, just a requirement that the training enable the first responder to
perform his or her duties.
·
The next person involved in the emergency
response in our scenario is the site safety manager, who had been trained as a
“First Responder Operations Level”, as outlined in 1910.120(q)(6)(ii). In other
cases, this may be a fire-fighter who responds to a wreck and sprays water on a
burning tanker from afar, or an equipment room operator who tries to
electronically manipulate valves from the control room to shut off an
electronic valve or pump on a broken chemical line. The site safety manager in
our scenario responded to the initial chemical release in a purely defensive
fashion to protect the environment from the effects of the chemicals by placing
the absorbent pigs in front of the storm drain inlet, never putting himself in
a position to be harmed by the released chemical. Operations level responders
must be trained to the same level of knowledge required for an Awareness Level
responder (previously described), as well as in whatever defensive steps should
be taken to contain the release from a safe distance to protect nearby workers
and property. Operations-level responders must also be trained to properly
utilize any personal protective equipment (PPE) necessary to perform their job
safely, have an understanding of the basic terminology used in emergency
responses to chemical releases, and know the procedures needed to ensure safe
decontamination of their equipment and PPE when needed. The OSHA standard
states their training must take at least eight (8) hours to complete or that
person must have enough experience to objectively demonstrate competency in all
required areas.
· The next level of responder covered in our
scenario are the members of the fire department’s HAZMAT crew who went into the
hot zone (where the accident actually occurred) to evaluate the atmosphere and
stop the actual leak. They are referred to as “Hazardous Materials
Technicians”, and their training requirements are addressed in OSHA standard
1910.120(q)(6)(iii). These workers must receive at least 24 hours of training
on topics needed to enable them to perform their duties safely, which includes
but is not limited to understanding the means and methods necessary to stop the
actual release of chemicals (for example, closing valves or patching / plugging
a ruptured line). Their training must consist of instruction equaling that of
the First Responder Operations Level, plus additional instruction to enable
them to implement the emergency action plan for their organization, select and
utilize personal protective equipment necessary for the particular incident in
which they are involved, utilize equipment to identify and verify the hazardous
materials (chemical, biological, and/or radiological) involved in the incident,
function within their role in the Incident Command System (ICS). They must also
have a basic knowledge of the terms commonly used in hazardous materials
responses, as well as have an understanding of the harmful effects of the
materials to which they are exposed.
· The next level of emergency responder is called
the “Hazardous Materials Specialist”, covered in 1910.120(q)(6)(iv). They
provide support to the Hazardous Materials Technicians by offering skills or
knowledge about the specific materials or processes involved in the incident,
and/or act as liaison to various agencies responding to the event. In our scenario, this is the company’s head
of the engineering department, who went into the hot zone with the Hazardous
Materials Technicians to point out which valves shut off the flow of chemicals
in the ruptured pipes. In other events, this could be someone trained to
operate specialized monitoring equipment to evaluate conditions in the hot
zone. These “Specialists” must have a minimum of 24 hours training in the same
general topics as that required for the First Responder Operations Level, plus
whatever specialized knowledge is needed to perform their designated task (such
as use of specialized monitoring instrumentation, ability to identify and/or
operate critical valves . . .). While commonly employed, a HAZMAT Specialist
may not be utilized in all emergency response incidents.
· The fifth and final classification of emergency
responder found in paragraph (q) of the OSHA HAZWOPER standard is that of the
“On Scene Incident Commander.” In our scenario, the On Site Incident Commander
was the leader of the Fire Department’s HAZMAT Response Team. However, the
person acting in this role may change from person to person over time as
different agencies respond to the scene, per the protocols outlined in the
Incident Command Systems (ICS). Their training requirements are outlined in
1910.120(q)(6)(v), and must consist of at least 24 hours training in topics
covered for the First Responder Operations Level, plus additional training to
be able to oversee the execution of the emergency action plans for all entities
involved (local, state, federal). They must have knowledge of the hazards of
the hazardous materials (chemical, biological, and/or radiological) involved in
the incident, and also be able to manage or evaluate the selection, use, and
decontamination of the personal protective equipment used in the response
incident.
As you can now see, three different company employees in our
scenario were involved in the response to the point that they were required to
be trained under paragraph (q) of the OSHA HAZWOPER standards, even though the company
called in an outside organization (the Fire Department HAZMAT team) to deal
with the spill. Those employees were the foreman (First Responder Awareness
Level), the site safety manager (First Responder Operations Level), and the
head of engineering (Hazardous Materials Specialist).
With this information in mind, reconsider your
own operations. Do you have employees who would be expected to respond in some
fashion to a chemical spill or release and therefore fall into one or more of
these five categories covered in paragraph (q) of the HAZWOPER standard? At the
least, employers with hazardous chemicals on site in quantities that could potentially
exceed an incidental spill would need a worker (or workers) trained to the First
Responder Awareness Level so someone is available to recognize when it is actually
necessary to call in outside assistance. So double check what your emergency
response plan entails, and if one or more workers are involved to the degree covered
in our scenario, you need to ensure you have documentation to show they were provided
with the necessary HAZWOPER training specified for their appropriate level of
response.Do you have employees trained for any level of response in your operations? Can you think of a different scenario that helps demonstrate an event where such training for employees might be overlooked? If so, please make a comment below. And as always, feel free to share this information with others in your network.
apply this test:
ReplyDeleteIf you don't have a government-labeled hazardous waste site, then you might be covered if you have a hazardous substance, very broadly defined, and there is a reasonable probability that a release in the workplace might require intervention of a specially trained/equipped team from outside the immediate release area. By Charles Lankford, MBA, CSP
The forklift driver is also responding as a First Responder Awareness Level when he recognizes that the leaking chemical is an event that should be reported. His training is to notify the foreman to take control of the scene while keeping himself and others in the area safe.
ReplyDeleteThe 8 hour Awareness level training applies to many manufacturing facilities unless the company instructs everyone to pull the fire box and evacuate. Most facilities that use fuel oil for heat have a need for an SPCC plan, and those almost always trigger the need for equipment and training under hazwoper!
ReplyDeleteCOSHH plays a big part in the Health and Social Care sector because of its chemicals and usage, and also medication. lt is important to follow and adhere to the rules, and receive training.
ReplyDeleteRegard