TRAINING IS REQUIRED BY LAW
Workers are required to receive proper training if they work with, near or have the potential to encounter chemical hazards in the workplace, whether in the normal course of business or in the event of an accidental spill and/or chemical release.
OSHA HAZWOPER regulation 29 CFR 1910.120 is designed to protect health and safety of the worker. In any workplace, even in an emergency response, the employer under the General Duty Clause of the Occupational Safety and Health Act is:
"(a) Each Employer....
Recognizing this, the employer's approach to providing a safe workplace is to :
- Shall furnish to each of his employees employment a place of employment which
are free from recognized hazards that are causing or are likely to cause death or
physical harm to his employees:
Shall comply with the occupational safety and health standards promulgated under
This concept applies to all workplaces including all workplaces, hazardous waste sites and emergency response.
- Recognize the hazards
- Evaluate the hazards.
- Control the hazards.
The OSHA HAZWOPER is a 40 hour initial class with an annual 8 hour refresher. This class can only be taught by a qualified instructor and must be paid for by the employer. The HAZWOPER class gives employees the basic knowledge they need to safely work in a chemical environment. This class is not optional, but mandatory for employees who work with chemicals or have to respond to potential chemical emergencies. To locate where OSHA HAZWOPER classes are being conducted in your area, inquire at your local university, trade association, or environmental agency.
[LINK to http://www.osha-slc.gov/FedReg_osha_data/FED19940822.html]
Internet Responder Training
Various instruments are used to measure chemical air contamination as well as oxygen levels.
The results of these readings will determine the level of protection needed to work safely in
that environment. The two most important instruments to use when entering an area with unknown
chemicals or unknown quantities of chemicals are the Oxygen Meter and the LEL Meter
(Lower Explosive Limit). When entering an area with unknown chemicals or unknown quantities of
chemicals, Level A protection should be used if possible, but no lower than Level B protection
shall be used until initial environmental hazards are fully recognized and quantified.
The Oxygen Meter will determine if there is enough oxygen (19.5% to 25%) to support life safely or
if there is to much oxygen creating a fire/explosion hazard (over 25%). The LEL Meter
(Lower Explosive Limit) will measure the concentration of chemical(s) in the atmosphere.
If the concentration is too high (greater than 25% of the LEL outside, or greater than 10% of the
LEL in a confined area) than a fire/explosion hazard exists.
OTHER DETECTION INSTRUMENTS
Other instruments include Direct Reading Instruments which measure the level of a specific
chemical(s) in the air. Direct Reading Instruments can be designed for one particular contaminate or multiple contaminates, however, with multiple reading instruments the probability of out-of-service because of calibration or other problems is greater. If the contaminate is at levels above the Permissible Exposure Limit (PEL) then appropriate measures of Personal Protective Equipment (Level A,B,C) shall be utilized. This type of instrumentation is available for about 100 chemicals and generally has a high cost in the thousands of dollars.
Colorimetric tubes, commonly referred to as Drager Tubes, are relatively inexpensive ($10 average) and when exposed to a particular chemical cause a chemical reaction by a color change in the tube. Different tubes have different reaction and color scales. If the contaminate is at levels above the Permissible Exposure Limit (PEL) then appropriate measures of Personal Protective Equipment (Level A,B,C) shall be utilized. Colorimetric tubes are available for approximately 300 chemicals.
Photo Ionization Detector/Flame Ionization Detectors
can detect a large range of unspecified chemicals and are often used when the chemical contaminate is unknown. High humidity can create false/positive readings with these detectors and positive readings should be evaluated by experienced personnel. In general for unknown contaminates the following applies:
0 - 5 ppm* detected = Level C Personal Protection Equipment (PPE)
5 - 500 ppm* detected = Level B Personal Protection Equipment (PPE)
greater than 500 ppm* detected = Level A Personal Protection Equipment (PPE)
* Parts Per Million
If the air monitoring shows sufficient oxygen (19.5% to 25%), and any chemical contaminates are below Permissible Exposure Limits (PEL), then the area is considered safe to work in without Personal Protection Equipment (PPE).
Court rulings have limited OSHA in how and when the agency can inspect facilities for compliance
with health and safety laws. The agency is basically limited to "after the accident" investigations,
a prodigious accident history that warrants an investigation, or having an employee turn-in the
facility for violations. An employee who notifies OSHA about heath and
safety violations has the right to have their name withheld and remain anonymous throughout
the proceedings. However, in reality, employees risk being fingered as a "trouble-maker"
because of circumstantial evidence (i.e. previously complained about problem, specific
knowledge of violations, etc.) and risk real retaliation. The law is supposed to protect
workers against retaliation, but this is much easier said then done as the employee may end
up having to hire an attorney to adequately represent the employee's interest. An employee who
takes on a workplace that has far more resources than the employee clearly faces potential
economic ruin. An employee who turns in a facility for workplace violations after he/she
has been terminated from employment is often labeled "disgruntled" by agency and facility alike, greatly reducing the chances for an OSHA compliance inspection. Because of the current inadequacy in laws and court decisions, employees can be forced into making hard decisions if they happen to work for a facility that chooses to defy compliance.
SPECIAL CAUTION ON HANDLING DRUMS AND OTHER CONTAINERS OF CHEMICALS
Accidents may occur during handling of drums and other hazardous chemical containers. Hazards
include detonations, fires, explosions, vapor generation, and physical injury resulting from
moving heavy containers by hand and working around stacked drums, heavy equipment and deteriorated
drums. While these hazards are always present, proper work practices such as minimizing handling
and using equipment and procedures that isolate workers from hazardous substances can minimize
the risks to personnel. DO NOT HANDLE DRUMS OF WHICH THE CONTENTS ARE UNKNOWN.
of drums is a must to avoid unintended exposure and the mixture of incompatible wastes or
chemicals. DO NOT HANDLE DRUMS WHICH ARE BULGING. BULGING DRUMS CAN
PRESENT AN EXTREME DANGER.
Pressurized drums can be explosive upon opening and should only be opened by trained professionals
with the proper equipment, including remote control devices, that provides the necessary
Do not use picks, chisels or firearms to open drums.
Extreme caution should be used when handling unfamiliar chemicals or wastes. Workers should not
handle or move chemicals or chemical containers until the worker has the proper training and
knowledge about those chemicals and chemical containers are properly labeled and identified as
prescribed by law.
[link to Chemicals in workplace]
EMERGENCY RESPONSE TO HAZARDOUS SUBSTANCE RELEASES
- Emergency response operations for releases of , or substantial treats of releases of,
hazardous substances without regard to the location of the hazard.
[LINK to http://www.osha-slc.gov/OshStd_data/1910_0120.html]
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
- 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 shal monstrate 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 HAZ MAT 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 HAZ MAT 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.