Page 51 - Occupational Health & Safety, May 2018

Of course, not every spill is an emergency incident. Knowing the difference between an incidental cleanup and an emergency re- sponse situation is part of the awareness that Level 1 training builds.
Employees who work with hazardous chemicals that do not pose a significant safety or health hazard should be trained ac- cording to OSHA’s Hazard Communication Standard, or HCS. U.S. DOT requires safety training, too, for employees involved in ship- ping hazardous materials.
Level 2 ‘Operations’
First responders at the operations level are individuals who re- spond to releases, or potential releases, of hazardous substances to protect nearby people, property, or the environment. Like awareness employees, operations level HAZWOPER respond- ers keep a safe distance from the release and do not try to stop it. That said, these employees also perform critical defensive response actions when a release occurs, such as remote shut- down of equipment, covering floor drains, or placing absorbent barriers to contain the release.
Employees with Level 2 responsibilities must complete eight hours of HAZWOPER training, unless the employee has sufficient experience to demonstrate both awareness level and operations level competencies.
Operations first responder training must cover all elements of Level 1 training and several additional aspects of emergency re- sponse, such as:
1. Hazardous substance terminology and risk assessment
2. Selecting and using proper personal protective equipment (PPE)
3. Basic control, containment, and confinement of releases
4. How to follow relevant facility emergency response procedures [29 CFR 1910.120(q)(6)(ii)]
Level 3 ‘Hazardous Materials Technician’
Hazardous materials technicians, also called emergency response technicians or simply “hazmat techs,” are individuals who actively respond to stop a hazardous substance release. Level 3 person- nel are trained to approach the point of release and plug, patch, or otherwise stop the emergency.
Because this responsibility may involve putting themselves in harm’s way, hazardous materials technicians must complete 24 hours of HAZWOPER training before starting the job. Level 3 training must cover the elements described in Levels 1 and 2 above. In addition, each Level 3 employee must be trained to:
1. Understand hazard and risk assessment techniques
2. Understand basic hazardous substance terminology and behavior
3. Implement the facility’s emergency response plan and rel- evant procedures
4. Select and use proper PPE for the job
5. Perform his or her role within the Incident Command Sys- tem (ICS)
6. Classify, identify, or verify materials involved using field sur- vey instruments and equipment
7. Perform advanced control, containment, and/or confine- ment operations
[29 CFR 1910.120(q)(6)(iii)]
Level 4 ‘Hazardous Materials Specialist’
Hazmat Specialists also play a critical role in the active response to stop a hazardous substance release. Specialists respond with and provide support for hazardous material technicians. Specialist have more specific knowledge about chemical substances, their proper- ties, and their hazards. They also act as liaisons with any local au- thorities that may be involved with the response.
Specialists must be trained to the technician level and demon- strate additional competencies for aspects of emergency response, such as:
1. How to develop or implement all emergency plans and pro- cedures
2. How to use advanced field survey instruments and equip- ment
3. How to perform specialized control, containment, and/or confinement of a release
4. Knowledge of hazardous substances and emergency response
Level 5 ‘On-scene Incident Commander (IC)’
During a chemical release, the on-scene incident commander manages the facility response. He or she establishes objectives, plans response strategies, and ensures the plan is followed. Like all responders Level 3 and above, incident commanders must com- plete 24 hours of initial HAZWOPER training, be competent at least to the operations level, and demonstrate additional compe- tencies generally related to big picture emergency response plan- ning, such as:
1. Know and understand the hazards and risks of emergency response
2. Have knowledge of the Federal Regional Response Team
3. Know, understand, and be able to implement the Incident Command System and all company, local, and state emergency re- sponse plans and procedures
Once Is Not Enough
Once employees have been trained to the proper level based on their responsibilities, training must be repeated annually. Annual refresher training is required for every HAZWOPER first respond- er, from the awareness level to the Incident Commander. [29 CFR 1910.120(q)(8)]
When a release occurs, your employee may not have time to “remember” his or her training. HAZWOPER training needs to be repeated to ensure employees can play their roles at a moment’s notice. Whether the employees’ responsibilities involve active mea- sures to stop a release or simply pulling the fire alarm and evacuat- ing the building, each and every worker must know what to do in the event of a chemical release. If employees take the wrong re- sponse actions, don’t know what to do, or try to perform jobs they are not capable of, the resulting mistakes, confusion, and disarray will stand in the way of a safe, efficient response—and could cost a worker his or her life.
Roger Marks is a researcher and writer at Lion Technology Inc., a leading provider of 49 CFR, IATA DGR, and IMDG Code dan- gerous goods training in the United States. Find nationwide pub- lic workshops, 24/7 online training solutions, and live webinars at www.Lion.com.
www.ohsonline.com
MAY 2018 | Occupational Health & Safety 47