Working with hazardous materials, whether as part of day-to-day operations or emergency response, is always risky; mistakes can be sudden and complications and hazards can be masked. Once a problem emerges, the dangers to health, property and life can escalate rapidly.

The need for specialized training is such that companies that manufacture, transport, store or otherwise handle hazardous substances are required by the Occupational Safety and Health Administration to train their employees to detailed standards. The difficulty that industrial and emergency services personnel face is that of sorting through applicable standards and available training curricula, and even determining the levels of training employees need.

Understanding the different levels of training is crucial not only because handling hazardous materials and responding to incidents requires a variety of personnel responsibilities, but because personnel must understand that their response role is limited by the level of training they've received. In short, personnel must not try to fill roles they aren't trained to fill.

Employment standards

Companies that expose their employees to harmful substances are required by OSHA to adhere to the requirements in its Hazardous Waste Operations and Emergency Response standard. The intent of the HAZWOPER standard is to protect employees from exposure to the health and physical hazards associated with hazmat activities, from routine operations to emergency incident response.

OSHA requires hazmat training programs for employees involved in cleanup operations required by a government body; corrective actions involving cleanup operations at sites governed by the Resource Conservation and Recovery Act; voluntary cleanup operations at sites recognized by a government body; operations involving hazardous waste that are conducted at RCRA-permitted treatment, storage and disposal facilities; and for all emergency response activities.

According to OSHA, individual employers or local jurisdictions are responsible for training their personnel to perform their assigned job duties safely. The employer or local jurisdiction must determine each employee's expected job duties and train each accordingly.

HAZWOPER requires employers to prepare a written emergency response plan that defines the roles each employee will assume during incident response. As you're probably aware, many states operate OSHA-approved state safety and health programs that provide worker protection that's at least as effective as OSHA standards but may be more strict. Moreover, some safety and health programs extend coverage to include employees of the state and local governments.

Three Code of Federal Regulations titles govern hazmat response:

• 40 CFR: Protection of Environment
• 49 CFR: Transportation
• 29 CFR: Labor

The third, 29 CFR, is the standard of greatest interest here, as it details labor standards related to worker safety and training and contains the HAZWOPER rules that govern emergency response plans and personnel responsibilities.

Emergency response plans

Emergency response plans must be developed and implemented by individual employers. At minimum, they must address the following:

Pre-emergency planning and coordination with outside parties, including procedures for coordinating with outside emergency response organizations, telephone numbers for officials and local authorities, procedures for coordinating with the local emergency planning committee, and information about hazardous chemicals from facilities that must comply with SARA Title III.

Personnel roles, lines of authority, training, and communication, including job titles and associated responsibilities during emergency response, clearly delineated lines of authority, outlines of training associated with each level of operation, demonstration that personnel have received training appropriate to their response roles, schedules for annual refresher training, and procedures for communication and notification.

Emergency recognition and prevention, including locations of on-site hazardous substances along with storage quantities; transportation methods; and information about the consequences of uncontrolled release and procedures for shutting down specific processes, closing emergency valves and otherwise securing operations during emergencies Safe distances and places of refuge, including maps with safe places of refuge identified for each section of the area where hazmat emergencies could occur and identification of all buildings, equipment, emergency apparatus, first-aid stations, routes of entry and exit, and emergency exit routes.

Emergency response plans also must address site security and control, evacuation routes and procedures, decontamination procedures, emergency medical treatment and first aid, and emergency alerting and response procedures. The plans are responsible for assigning specific tasks and for identifying site-specific hazards, but they have no responsibility for detailing how specific tasks will be accomplished. That responsibility is reserved for standard operating procedures, standard operating guidelines and checklists.

HAZWOPER professionals

There are two types of HAZWOPER individuals: those performing cleanup operations and those performing emergency response operations. Cleanup operations at hazardous waste sites are governed by 29 CFR 1910.120 paragraphs A through P; operations at hazardous waste treatment, storage and disposal facilities are covered as well. After an incident's emergency response phase is complete, contractors often are hired to provide cleanup and disposal services. With properly trained personnel, this work could be done in-house.

Emergency operations in response to the release of hazardous substances is governed by Paragraph Q. Employee response actions are divided among personnel who will not respond and require evacuation plans, and personnel who will respond and require an emergency response plan.

Training must address the duties an individual is expected to perform; and training is to be provided prior to incident response.

A training or response organization must have a detailed understanding of your personnel and the duties they will be required to perform, as their responsibilities will dictate the level of training to which they will be trained. Personnel working with hazardous materials will be required to recognize hazards, perform defensive counter measures, or respond with offensive measures to releases and spills; these basic factors are the foundations of Hazmat Awareness, Operations, and Technician-level training. Employees and responders who are trained to these different levels must always remember to work within the scope of their training and never attempt activities that are above their level of expertise.

First Responder: Awareness-Level training is intended for individuals likely to witness or discover a release and who are trained to initiate an emergency response sequence, including activation of internal emergency alarm systems or other notifications. Training for these personnel should include knowledge of hazardous substances and their associated risks, and of potential outcomes associated with hazardous substances, the ability to recognize hazardous substances and identify them, if possible. They also should be trained to know their individual roles as described in their employer's Emergency Response Plan, how to use the DOT Emergency Response Guidebook, how to recognize the need for additional resources and how to respond within the confines of their training.

The function of the First Responder: Operations Level is to take defensive action to contain an uncontrolled release, acting at a safe distance from the point of release. Defensive activities include placing absorbent material, shutting off valves outside the danger area, or activating emergency control systems. Performing skimming and boom placement duties are prime examples of operations-level skills, which concentrate on containing the release from a safe distance to keep it from spreading and to prevent exposures.

Operations-level first responders are limited to defensive actions; they aren't allowed to enter the danger area to attempt to stop a release, which means that any organization that chooses not to train its personnel beyond the operations level must arrange in advance to call in an outside hazmat team if on-site personnel are unable to control a release through the use of defensive actions. Outside resources can include local fire departments or hazmat teams accessed through the 911 system, mutual aid organizations, or private contractors and spill-response companies.

Training for operations-level personnel should include all of the awareness-level competencies plus knowledge of hazard- and risk-assessment techniques; PPE selection; basic decontamination procedures; relevant sops and termination procedures; and actions to take to protect nearby persons, property and the environment. Personnel also should have the ability to perform defensive operations: basic control, containment and confinement.

On-site personnel

Hazmat technicians aggressively seek to stop a spill at its source. An emergency responder with technician-level responsibilities must approach the point of release to plug, patch or otherwise stop the release of a hazardous substance; unlike the operations-level actions, the technician is taking offensive actions designed to stop the release, not just minimize or protect against it. Only personnel who are trained to the technician level can take offensive response actions.

Training for technician-level personnel should include all of the awareness- and operations-level competencies plus knowledge of procedures for implementing the employer's emergency response plan, the technician's role according to the Incident Command System, advance control operations, the decontamination process, and basic chemical toxicological terminology and behavior. The technician also should have the ability to use field survey instruments and equipment for detecting and identifying known and unknown materials.

Hazmat specialists, usually members of hazmat teams, provide support for and may respond with hazmat technicians. Their duties often require them to have advance knowledge of chemical hazards or experience with specialized modes of transportation of hazardous materials. Specialist-level training may include disciplines such as rail car, highway, pipeline and marine transportation, and should address:

• The care, use and/or testing of chemical protective clothing, including totally encapsulating suits.
• The medical surveillance program.
• The standard operating procedures for the hazmat team, including the use of advanced plugging and patching equipment and other subject areas.
• Implementation of local emergency plans.
• Knowledge of the state response plans.
• Knowledge of hazard and risk techniques.
• The ability to develop site safety and control plans.

Someone on site must be responsible for managing incident response and must be trained accordingly. HAZWOPER describes this individual as the senior official, and prohibits the designation of a plant manager or supervisor as the senior official if that person will be called in from off-site.

Facility emergency response plans must detail the procedures to be followed, the roles and duties of responders, and the lines of authority and communication that will be in place during an incident. All activity must be coordinated through ICS, which specifies that one individual be in charge of coordinating and supervising emergency response efforts. ICS requires a pre-established chain of command that passes control of the incident up as more senior officers arrive.

Training for the senior officer (including, at the facility's discretion, off-site plant managers) will be dictated by the characteristics of individual facilities and the complexity of defensive emergency prevention measures. In situations relying on outside hazmat teams, the role of senior official will be passed up the pre-established chain of command to the head of the outside hazmat team, who must be certified as an on-scene incident commander as described in 29 CFR 1910.120(Q)(6)(v). On-scene incident commanders must be trained to awareness and operations levels and must also receive additional training to ensure that they will be able to accurately and effectively instruct personnel to all of the required skill levels.

Those employees who are trained in accordance with Paragraph (Q)(6) of 29 CFR 1910.120 must either receive annual refresher training of sufficient content and duration to maintain their competencies or demonstrate competency in those areas at least annually. Refresher training can be conducted in staggered segments, but those segments must be completed within a year of the previous training. Moreover, refresher training should focus on the level of the responder's job duties and competencies.

It's essential that employers maintain training records for all employees who are expected to respond to a hazmat spill or release, and these records should include information about the methodology used to demonstrate individual competencies.

The future of training

The current trend in emergency response training programs revolves around “certification-based” training. Certification means that an individual has been tested by an accredited examining agency against a body of clearly delineated material and found to meet or exceed the minimum standard. Certification provides the individual with the opportunity to test skills and knowledge against peers from all types of fire departments and fire service agencies. Examinations are based on widely available NFPA standards; in the case of hazmat training, this means following NFPA 472 guidelines.

One of the more popular and technically sound approaches to “certification-based” training is through the National Board on Fire Service Professional Qualifications, commonly referred to as Pro Board. Pro Board operates under the direction of a board of directors composed of member from national fire service organizations.

Pro Board issues accreditation to those agencies that test to approved fire service standards. Accredited agencies are responsible for conducting certification-based training and testing, and issuing certification to individuals who successfully complete the testing and skills demonstration process. Today, accreditation is issued for certification in 67 levels of 16 standards of competencies related to the fire service. Individuals may become certified in as many disciplines as they desire.

Departments are improved in a variety of ways by having nationally certified members. First, the respect, reputation and prestige of such professional organizations will expand in proportion to the number of certified members it has. These departments will have officers and civilian professionals whose credibility is unquestionable. Second, a fire department's training program will improve as higher goals are secured through the acceptance of the standards. As a result, such training programs will be able to measure themselves as part of a national fire training system. Third, training programs that adopt Pro Board certification will minimize the inconsistencies that span other hazmat training approaches. When your employees are training to a certain level of competency under Pro Board guidelines, you can be assured that they have clearly defined missions and tasks to follow.

When we look at the different levels of hazmat individuals specified in NFPA 472 we find that the awareness, operations, and technician levels are covered. These three levels are often referred to as the meat and potatoes of hazmat training and response. In addition to these levels, NFPA 472 also covers incident commander, private sector specialist, branch officer, branch safety officer, tank car specialty, cargo tank specialty, and intermodal tank specialty.

Professional standards are particularly important in high-risk industries such as the fire service and other response-based organizations. The widespread adoption of the accreditation and certification movement offered by the Pro Board will go far toward ensuring that this trend continues to the benefit of each one of us. Certification from a nationally accredited agency is a statement of success for you and your response organization.

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Gordon L. Lohmeyer is the Hazmat Material Program Coordinator for Texas A&M's Texas Engineering Extension Service/Emergency Services Training Institute. Prior to that he worked for Texas Petrochemicals LP as an emergency response coordinator, environmental health and safety specialist, and senior technician/emergency response team captain.