EMERGENCY RESPONSE TO HAZARDOUS SUBSTANCE RELEASES
- Emergency response operations for releases of , or substantial threats of releases of, hazardous substances without regard to the location of the hazard.
OSHA 1910.120(q) - This paragraph covers employers
whose employees are engaged in emergency response no matter where it occurs . [exceptions:
OSHA 1910.120(a)(1)(i-iv)] OSHA 1910.120(q) declares that:
- Emergency Response Plan
An emergency response plan shall be developed and implemented to handle anticipated emergencies prior to
the commencement of emergency response operations. The plan shall be in writing and available for
inspection and copying by employees, their representatives, and OSHA personnel.
Employers who will evacuate their employees from the workplace when an emergency occurs,
and who do not permit any of their employees to assist in handling the emergency,
are exempt from the requirements of this paragraph if they provide an emergency action plan in
accordance with CFR 1910.38(a).
- Elements of an emergency response plan.
The employer shall develop an emergency response plan for emergencies which shall address, as a minimum, the following to the extent that they are not addressed elsewhere.
- Pre-emergency planning and coordination with outside parties.
- Personnel roles, lines of authority, training, and communication.
- Emergency recognition and prevention.
- Safe distances and places of refuge.
- Site security and control.
- Evacuation routes and procedures.
- Emergency medical treatment and first aid.
- Emergency alerting and response procedures.
- Critique of response and follow-up
- PPE and emergency equipment.
- Emergency response organizations may use the local emergency response plan or the state emergency response plan or both, as part of their emergency response plan to avoid duplication. Those items of the emergency response plan that are being properly addressed by the SARA Title III plans may be substituted into their emergency plan or otherwise kept together for the employer and employee's use.
- Procedures for handling emergency response
- The senior emergency response official responding to an emergency shall become the individual in charge of a site-specific Incident Command System (ICS). All emergency responders and their communications shall be coordinated and controlled through the individual in charge of the ICS assisted by the senior official present for each employer. The Senior officials at an emergency response is the most senior official on the site who has the responsibility for controlling the operations at the site. Initially it is the senior officer on the first-due piece of responding emergency apparatus to arrive on the incident scene. As more senior officers arrive (i.e., battalion chief, fire chief, state law enforcement official, site coordinator, etc.) the position is passed up the line of authority which has been previously established.
- The individual in charge of the ICS shall identify, to the extent possible, all hazardous substances or conditions present and shall address as appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures, and use of any new technologies.
- Based on hazardous substances and /or conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards to be encountered. However, personal protective equipment shall meet, at a minimum, the criteria contained in 29 CFR 1910.156(e) when worn while performing fire fighting operations beyond the incipient stage for any incident or site.
- Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard shall wear positive pressure self-contained breathing apparatus while engaged in emergency response, until such time that the individual in charge of the ICS determines through the use of air monitoring that a decreased level of respiratory protection will not result in hazardous exposures to employees.
- The individual in charge of the ICS shall limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure to incident or site hazards, to those who are actively performing emergency operations.
- Back-up personnel shall stand by with equipment ready to provide assistance or rescue. Advance first aid support personnel, as a minimum, shall also stand by with medical equipment and transportation capability.
- The individual in charge of the ICS shall designate a safety official, who is knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety of operations for the emergency at hand.
- When activities are judged by the safety official to be an IDLH condition and/or involve an imminent danger condition, the safety official shall have the authority to alter, suspend, or terminate those activities. The safety official shall immediately inform the individual in charge of the ICS of any actions needed to be taken to correct these hazards at an emergency scene.
- After emergency operations have terminated, the individual in charge of the ICS shall implement appropriate decontamination procedures.
- When deemed necessary for meeting the tasks at hand, approved self-contained compressed air breathing apparatus may be used with approved cylinders from other approved self-contained compressed air breathing apparatus provided that such cylinders are of the same capacity and pressure rating. All compressed air cylinders used with self-contained breathing apparatus shall meet U.S. Department of Transportation and National Institute for Occupational Safety and Health criteria.
- Skilled Support Personnel.
Personnel, not necessarily an employer's own employees, who are skilled in the operation of certain
equipment, such as mechanized earth moving or digging equipment or crane and hoisting equipment,
and who are needed temporarily to perform immediate emergency support work that cannot reasonably be
performed in a timely fashion by an employer's own employees, and who will be or may be exposed to the
hazards at an emergency response scene, are not required to meet the training required in this paragraph
for the employer's regular employees. However, these personnel shall be given an initial briefing at the
site prior to their participation in any emergency response. The initial briefing shall include instruction
in the wearing of appropriate personal protective equipment, what chemical hazards are involved, and what duties are to be performed. All other appropriate safety and health precautions provided to the employer's own employees shall be used to assure the safety and health of these personnel.
- Specialist Employees.
Employees who, in the course of their regular job duties, work with and are trained in the hazards of
specific hazardous substances, and who will be called upon to provide technical advice or assistance at a
hazardous substance release incident to the individual in charge, shall receive training or demonstrate
competency in the area of their specialization annually.
Training shall be based on the duties and function to be performed by each responder of an emergency response organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, shall be conveyed to them through training before they are permitted to take part in actual emergency operations on an incident. Employees who participate, or are expected to participate, in emergency response, shall be given training in accordance with the following paragraphs:
- First responder awareness levels. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. First responders at the awareness level shall have sufficient training or have insufficient experience to objectively demonstrate competency in the following areas:
- An understanding of what hazardous material are, and the risks associated with them in an incident.
- An understanding of the potential outcomes associated with an emergency created when hazardous materials are present.
- The ability to recognize the presence of hazardous materials in an emergency.
- The ability to identify the hazardous materials, if possible.
- An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook.
- The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.
- First responder operations level. First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level and the employer shall so certify:
- Knowledge of the basic hazard and risk assessment techniques.
- Know how to select and use proper personal protective equipment provided to the first responder operational level.
- An understanding of basic hazardous materials terms
- Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit.
- Know how to implement basic decontamination procedures.
- Hazardous Materials Technician. Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations level in that they will approach the point of release in order to plug, patch or otherwise stop the release of a hazardous substance. Hazardous materials technicians shall have received at least 24 hours of training equal to the first responder operations level, and in addition have competency in the following areas and the employer shall so certify.
- 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 personal protective equipment provided to the hazardous materials technician.
- Understand hazard and risk assessment techniques.
- Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.
- Understand and implement decontamination procedures.
- Understand termination procedures.
- Understand basic chemical and toxicological terminology and behavior.
- Hazardous Materials Specialist. Hazardous materials specialists are individuals who respond with and provide support to hazardous materials technicians. Their duties parallel those of the hazardous materials technician, however, those duties require a more directed or specific knowledge of the various substances they may be called upon to contain. The hazardous materials specialist would also act as the site liaison with federal, state, local and other government authorities in regards to site activities. Hazardous materials specialists shall have received at least 24 hours of training equal to the technician level and in addition have competency in the following areas and the employer shall so certify:
- Know how to implement the local emergency response plan.
- Understand classification, identification, and verification of known and unknown materials by using advanced survey instruments and equipment.
- Know of the state emergency response plan.
- Be able to select and use proper specialized chemical personal protective equipment provided to the hazardous materials specialist.
- Understand in-depth hazard and risk techniques.
- Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available.
- Be able to determine and implement decontamination procedures.
- Have the ability to develop a site safety and control plan.
- Understand chemical, radiological and toxicological terminology and behavior.
- On-scene Incident Commander. Incident commanders, who will 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 and in addition have competency in the following areas and the employer shall certify:
- Know and be able to implement the employer's incident command system.
- Know how to implement the employer's emergency response plan.
- Know and understand the hazards and risks associated with employees working in chemical protective clothing.
- Know how to implement the local emergency response plan.
- Know of the state emergency response plan and the Federal Response Team.
- Know and understand the importance of decontamination procedures.
Trainers who teach any of the above training subjects shall have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as the courses offered by the U.S. Fire Academy, or they shall have the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills, and a good command of the subject matter of the courses they are to teach.
- Refresher Training.
- Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.
- A statement shall be made of the training or competency, and if a statement of competency is made, the employer shall keep a record of the methodology used to demonstrate competency.
- Medical Surveillance and Consultation.
- Members of an organized and designated HAZMAT team and hazardous materials specialists shall receive a baseline physical examination and be provided with medical surveillance as required in paragraph (f) of this section.
- Any emergency response employees who exhibits signs or symptoms which may have resulted from exposure to hazardous substances during the course of an emergency incident, either immediately or subsequently, shall be provided with medical consultation as required in paragraph (f)(3)(ii) of this section.
- Chemical Protective Clothing.
Chemical protective clothing and equipment to be used by organized and designated HAZMAT team members, or to be used by hazardous materials specialists, shall meet the requirements of paragraphs (g)(3) through (5) of this section.
- Post-emergency Response Operations.
Upon completion of the emergency response, if it is determined that it is necessary to remove hazardous substances, health hazards, and materials contaminated with them (such as contaminated soil or other elements of the natural environment) from the site of the incident, the employer conducting the cleanup shall comply with one of the following:
- Meet all of the requirements of paragraphs (b) through (o) of this section; or
- Where the cleanup is done on plant property using plant or workplace employees, such employees
shall have completed the training requirements of the following: 29 CFR 1910.38(a); 1910-134; 1910.1200, and other appropriate safety and health training made necessary by the tasks that they are expected to be performed such as personal protective equipment and decontamination procedures. All equipment to be used in the performance of the cleanup work shall be in serviceable condition and shall have been inspected prior to use.
Link to FIRST RESPONDER AWARENESS
PERSONAL PROTECTIVE EQUIPMENT (PPE)
The purpose of personal protective clothing and equipment (PPE) is to shield or isolate individuals from the chemical, physical, and biologic hazards that may be encountered. Careful selection and use of adequate PPE should protect the respiratory system, skin, eyes, face, hands, feet, head, body, and hearing. No single combination of protective equipment and clothing is capable of protecting against all hazards. Thus PPE should be used in conjunction with other protective methods. The use of PPE can itself create significant worker hazards, such as heat stress, physical and psychological stress, and impaired vision, mobility, and communication. In general, the greater the level of PPE protection, the greater are the associated risks. For any given situation, equipment and clothing should be selected that provide an adequate level of protection. Overprotection as well as under-protection can be hazardous and should be avoided.
Use of PPE is required by Occupational Safety and Health Administration (OSHA) regulations in 29 CFR
Part 1910 and reinforced by U.S. Environmental Protection Agency (EPA) regulations in 40 CFR Part 300.
[Link to OSHA regulations]
NOTE: Employees must have medical clearance from a licensed physician to wear a respirator or personal protective equipment. The body incurs extra physical stress during the wearing of this
protective equipment and it is important that employees be cleared by a licensed physician to undertake this additional stress.
CHEMICAL PROTECTIVE CLOTHING:
Chemical-protective clothing (CPC) is available in a variety of materials that offer a range of protection against different chemicals. The most appropriate clothing material will depend on the chemicals present and the task to be accomplished. Ideally, the chosen material resists permeation, degradation, and penetration. Permeation is the process by which a chemical dissolves in and/or moves through a protective clothing material on a molecular level. Degradation is the loss of or change in the fabric's chemical resistance or physical properties due to exposure to chemicals, use, or ambient conditions (e.g., sunlight). Penetration is the movement of chemicals through zippers, stitched seams or imperfections (e.g., pinholes) in a protective clothing material.
Selection of chemical-protective clothing is a complex task and should be performed by personnel with training and experience. Under all conditions, clothing is selected by evaluating the performance characteristics of the clothing against the requirements and limitations of the site- and task-specific conditions. If possible, representative garments should be inspected before purchase and their use and performance discussed with someone who has experience with the clothing under consideration. In all cases, the employer is responsible for ensuring that the personal protective clothing (and all PPE) necessary to protect employees from injury or illness that may result from exposure to hazards at the work site is adequate and of safe design and construction for the work to be performed (see OSHA standard 29 CFR Part 1910.132-1910.137).