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Industrial Management of Hazardous Materials Training

Managing hazardous materials training is a complex task. The challenge is to conduct training that meets the requirements of OSHA 29 CFR 1910.120 and EPA 40 CFR 311 (EPA311). Both of these standards require that emergency responders be completely trained before they perform their task. Employers¹ responsibilities under these regulations fall into four primary areas:

  • Development of an emergency response plan
  • Development of specific procedures for handling hazardous materials incidents (SOPs)
  • Employee Training Requirements
  • Health and safety requirements (medical monitoring and exposure records)

Employers must ensure that employees receive training in emergency response to hazardous materials incidents, based on their expected duties and functions.
  • An employer is responsible for determining the appropriate level of training required based on actions expected of employees.
  • An employer is responsible for implementing the required training. Emphasis should be on achieving the required competencies for the appropriate level of response rather than on minimal requirements for the length of training.
  • An employer is responsible for selecting qualified and competent instructors.
  • An employer must provide annual refresher training sufficient to maintain competencies, or the employee must demonstrate the required competencies annually.
  • An employer must maintain a record of demonstrated competencies explaining how each competency was completed. Training records must contain dates, student rosters, curriculum outlines, demonstration checklist or performance records and evaluation tools, and scores.

OSHA has defined the minimum number of hours for training at operations, technician, specialist and incident commander level. However, each employer is responsible for their employees being trained to meet the competency. Industry often exceeds the minimum hours of training above those by outlined OSHA. The training needed to reach competency depends on the preexisting skills and experience of the trainees. Agencies frequently discover that training needs exceed the minimum required hours by law. On the other hand, employees of a response agency who have sufficient skills and experience may require minimal time to attain the competency level desired. An effective response is based on the competency of the responders, not the number of training hours they receive.

OSHA realizes that it will not take as many hours to cover the information in a review as during the initial presentation; therefore, there is no hour requirement for competencies through refresher training.

First Responder Awareness Level Training

First responders at the awareness level are those individuals who are likely to witness or discover a release of hazardous materials. No hourly training requirement is listed in either OSHA 1910.120 or EPA 311, but these documents indicate that first responders must have sufficient training or experience to demonstrate competency in the following areas:

  • An understanding of what the hazards are and their associated risks.
  • An understanding of potential outcomes when hazardous materials are present.
  • The ability to recognize the presence of hazardous materials.
  • An understanding of the first responder¹s role and use of the DOT Emergency Response Guidebook.
  • The ability to recognize the need for additional resources and the knowledge of the company¹s procedures to make appropriate notifications.

First Responder Operations Level Training

First responders at the operations level are those individuals who respond to release, or potential release, as part of the initial response to protect people, property, and the environment. Operations-level first responders are trained to take defensive actions rather than trying to physically stop the release. Their functions are to contain the release from a safe distance, keep it from spreading, and prevent any additional exposures. OSHA 1910.120 requires the first responder at the operations level receive at least 8 hours of training or have sufficient experience to demonstrate competencies objectively. First responders must have the knowledge of awareness level plus the following competencies:

  • Know basic hazard and risk assessment
  • Know how to select and use protective equipment available
  • Understand basic hazardous materials terms
  • Know how to perform the basic control, containment and confinement operations within the capabilities of their resources and protective equipment
  • Know basic decontamination procedures
  • Understand relevant SOPs and termination procedures

Hazardous Materials Technician Training

Hazardous Materials technicians are those who respond to releases or the potential releases for the purpose of stopping the leak. This level requires at least 24 hours of training at the operations level or training equal to the competencies at the technician level. Hazardous materials technicians assume a more aggressive role than first responders at the operations level. They approach to plug, patch, or otherwise stop the release of the hazardous substance. They must be trained at the first responder operations level, plus the following competencies, and the employer must so certify:

  • Know how to implement the employer¹s emergency response plan
  • Know how to identify materials by using field survey instruments
  • Be able to function in an assigned role in the incident command system
  • Know how to select and use specialized personal protective equipment
  • Understand hazard and risk assessment techniques
  • Be able to perform advanced control and containment operations with the available equipment and resources
  • Understand and implement decontamination procedures

On-scene Incident Commander Training

Incident commanders who assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level. In addition, the employer must certify that personnel are able to meet the following competencies:

  • Be able to implement the employer's incident command system
  • Be able to implement the employer's emergency response plan
  • Understand the risk associated with working in chemical protective clothing
  • Know how to implement the local emergency response plan
  • Understand the importance of decontamination and be able to implement the company's decontamination plan

Hazardous Materials Refresher Training

Employers must certify on an annual basis that employees continue to meet the performance objectives as defined in OSHA 1910-120. This may be accomplished through refresher training or demonstration of the competency.

Refresher training or competency retesting requirements may vary for each of the response levels. In general, refresher training should include critical practical skills, technical information updates, and refinement of incident scene coordination through team field exercises. At a minimum, competency should be demonstrated for the skills directly affecting the safety of responding personnel.

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Jonathan Jones,   State Fire Marshal
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