Search:

6/8/2012

How to Determine What Training is Required for Emergency Response Team Members [29 CFR 1910.120(q)(6)]

Safety


OSHA's Hazardous Waste Operations and Emergency Response standard (HAZWOPER) is codified at 29 CFR 1910.120.  Paragraph (q) of the standard applies to emergency response operations where personnel respond to releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.  Paragraph (q) requirements do not cover operations at worksites covered under other sections of the HAZWOPER standard which include:

The table below identifies the initial training requirements of 29 CFR 1910.120(q)(6) applicable for hazmat team personnel who participate in emergency response operations covered under paragraph(q) of the HAZWOPER standard.  The types of emergency responders include:  First Responder Awareness Level, First Responder Operations Level, Hazardous Materials Technician Level, Hazardous Materials Specialist, and On-Scene Incident Commander.

The table below also identifies the HAZWOPER training requirements for Skilled Support Personnel (see 29 CFR 1910.120(q)(4)) and Specialist Employees (see 29 CFR 1910.120(q)(5)) who are not trained members of the hazmat team but who may be called upon to assist during emergency response operations.


Emergency Responder Type

Description

Required Hours for Initial Training

Initial Training Requirements

First Responder Awareness Level

Worker that is likely to witness or discover a hazardous substance release and who have been trained to initiate emergency response sequence by notifying proper authorities, but would take no action beyond notifying the authorities of a release.

No set hourly training requirement, but must be capable of demonstrating listed training requirements.

Have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:

· Understanding of what hazardous substances are, and the risks associated with them in an incident

· Understanding of the potential outcomes associated with an emergency created when hazardous substances are present

· Ability to recognize the presence of hazardous substances in an emergency

· Ability to identify the hazardous substances, if possible

· Understanding the role of the first responder awareness level in the employer?s emergency response plan including site security and control and the DOT?s Emergency Response Guidebook

· Ability to realize the need for additional resources, and to make appropriate notifications to the communication center

First Responder Operations Level

Worker who responds to releases or potential releases in a defensive manner to protect people, property, and the environment from the effects of the release, without actually trying to stop the release.

At least 8 hours or have sufficient experience to objectively demonstrate competence at the awareness level and in the listed training requirements with the employer certifying this competency.

Training equal to the first responder awareness level and in addition have competency in the following areas:

· Knowledge of basic hazard and risk assessment techniques

· Knowledge of how to select and use proper PPE to be provided to operations level responders

· Understanding of basic hazardous materials terms

· Knowledge of how to perform basic control, containment and/or confinement operations within the capabilities of the resources and PPE available

· Knowledge of how to implement basic decontamination procedures

· Understanding of relevant standard operating procedures and termination procedures

Hazardous Materials Technician Level

Worker who responds to the release or potential release for the purpose of stopping the release. Capable of performing in proactive role to approach the point of release in order to plug, patch, or otherwise stop the release.

At least 24-hours training equal to first responders operation level and have competence in the listed requirements with the employer certifying this competency.

Training equal to the first responder operations level and in addition have competency in the following areas:

· Know how to implement the employer's emergency response plan

· Know the classification, identification, and verification of known and unknown materials by using field survey instruments and equipment

· Be able to function within an assigned role in the Incident Command System

· Know how to select and use proper specialized chemical PPE provided for their assignment

· Understand hazard and risk assessment techniques

· Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and PPE available with the unit

· Understand and implement decontamination procedures

· Understand termination procedures

· Understand basic chemical and toxicological terminology and behavior

Hazardous Materials Specialist

Worker with training similar to the Hazardous Materials Technician; however, the specialist is required to have greater knowledge of the chemicals to which he or she might respond, be capable of providing support to hazardous materials technicians, and be capable as a liaison with governmental authorities.

At least 24-hours training equal to first responders technician level and have competence in the listed requirements with the employer certifying this competency.



Training equal to the first responder technician level and in addition have competence in the following areas:

· Know how to implement the local emergency response plan

· Understanding classification, identification, and verification of known and unknown materials by using advanced survey instruments and equipment

· Knowledge of the state emergency response plan

· Being able to select and use proper specialized chemical PPE

· Understanding in-depth hazard and risk techniques

· Being able to perform specialized control, containment, and /or confinement operations within the capabilities of the resources and PPE available

· Being able to determine and implement decontamination procedures

· Having the ability to develop a site safety and control plan

· Understanding chemical, radiological, and toxicological terminology and behavior

On-scene Incident Commander

The on-site person designated and trained to assume control of the incident scene and be in charge of an incident response any time a response at the site goes beyond First Responder Awareness Level.

At least 24 hours training equal to first responder operations level and have competence in listed requirements with the employer certifying this competency.

Training equal to the first responder operations level and in addition have competency in the following areas:

· Knowledge of and ability to implement the employer's incident command system

· Knowledge of how to implement the employer?s emergency response plan

· Knowledge and understanding of the hazards and risks associated with employees working in chemical protective clothing

· Knowledge of how to implement the local emergency response plan

· Knowledge of the state emergency response plan and of the federal regional response team

· Understanding the importance of decontamination procedures

Skilled Support Personnel
29 CFR 1910.120(q)(4)

Personnel not necessarily an employer's own employees, skilled in operating certain equipment (e.g., earth moving equipment or cranes), needed temporarily to perform immediate emergency support work that cannot reasonably be performed in a timely fashion by an employer's own employees.

Training required by
29 CFR 1910.120(q)(4) rather than emergency response level training identified at
29 CFR 1910.120(q)(6).

Initial briefing at the site prior to participation in any emergency response must include:

· Instruction in wearing PPE they will use

· What chemical hazards are involved

· Duties they will perform

Specialist Employees
29 CFR 1910.120(q)(5)

Employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances, and will be called upon to provide technical advice or assistance at a hazardous substance release incident.

Must receive training required by 29 CFR 1910.120(q)(5) rather than emergency response level training identified at
29 CFR 1910.120(q)(6).

Receive training or demonstrate competency in the area of their specialization annually.



In accordance with 29 CFR 1910.120(q)(8), each of the emergency responder types listed above must receive the training specified at 29 CFR 1910.120(q)(6) and must receive annual refresher training of sufficient content and duration to maintain their competencies, or must demonstrate competency in those areas at least yearly.

In addition to the training requirements in the chart, there is a 40-hour training requirement that applies to general site workers at uncontrolled waste sites (e.g., CERCLA or Superfund Cleanup sites) who are subject to paragraph (e) of the standard.  There is a 24-hour training requirement which applies to workers at hazardous waste treatment, storage, and disposal (TSD) facilities covered under paragraph (p) of the standard who must comply with the training requirements of paragraph (p).  Neither the 40-hour training requirement of paragraph (e) or the 24-hour training requirement of paragraph (p) apply to members of a HAZMAT team when the emergency response operations they conduct are subject to paragraph (q) and the training requirements outlined in the table above.

To meet the HAZWOPER training requirements appropriate for you, attend Environmental Resource Center's HAZWOPER 40-Hour Training, 24-Hour Training, 8-Hour Refresher Training, or attend the HAZWOPER 8-Hour Refresher Webcast.