"Hazwoper? We're not a waste site!"

September 1, 2005
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Are you aware of the science of reaching a conclusion before doing research? Preconceptual scientists simply dismiss anything contrary to their preconceived notions. Subsequent dismissals are quite easy because this breed of scientist simply ignores all evidence that proves them wrong when an opposing view is presented.

These kinds of “scientists” are the bane of many a safety manager trying to make a daily difference. In the workplace, they are the contrarians. The employee who says, “Oh no, that’s not the way we do things around here.”

Here’s an example of the resistance they can brew up: You want to roll out hazmat emergency response training. But the Preconceptual Scientist in the workforce looks at the title of OSHA’s standard — “Hazardous Waste Operations and Emergency Response” — and exclaims HAZWOPER does not apply because your facility is not involved in hazardous waste operations.

Don’t kid yourself.

Get the facts straight

Tell your dismissive resister he or she has reached their conclusion prematurely. Tell them to read 29CFR 1910.120, subparagraph (q): Emergency response program to hazardous substance releases. This paragraph covers employers whose employees are engaged in emergency response no matter where it occurs except that it does not cover employees engaged in operations specified in paragraphs (a)(1)(i) through (a)(1)(iv) of this section. Those emergency response organizations who have developed and implemented programs equivalent to this paragraph for handling releases of hazardous substances pursuant to section 303 of the Superfund Amendments and Reauthorization Act of 1986 (Emergency Planning and Community Right-to-Know Act of 1986, 42 U.S.C. 11003) shall be deemed to have met the requirements of this paragraph.

Dangerous preconceptions

Preconceived notions about hazmat safety can be particularly dangerous. A healthy respect for hazardous chemicals and substances on your site, and the byproducts of their interactions, is a pre-requisite for effective hazmat response activities. I strive to build this respect during basic safety orientation and start with hazard communication training.

Your hazcom training lays the foundation for the understanding of, and appreciation and respect for, the hazards of chemicals found onsite. Then you can proceed through task, process, and floor activity training to best manage the likelihood of a chemical release, by decreasing the probability of a chemical release. Of course all “good intentions” are so named because of the ever-existent possibility (that is, Murphy’s Law) of “anything happening at any time.”

Murphy’s Law, in effect, is why HAZWOPER applies to your site. Once this is clear to everyone, you can address the critical issue of how to respond to emergency releases.

Levels of response

OSHA’s HazMat training requirements have existed for about 15 years now and run the gamut from Awareness Level to Incident Commander. They require a very real investment in time, equipment, material and personnel. At my facility, I organized our response activities in a way that requires us to train only through the first two (of five) levels. The requirements for the first level are: First Responder Awareness Level - 29 CFR 1910.120(q)(6)(i)

First responders at the awareness level are those persons who, in the course of their normal duties, can be the first on the scene of an emergency involving hazardous materials. First responders at the awareness level are expected to recognize the presence of hazardous materials, protect themselves, call for trained personnel, and secure the area.

Suggested criteria for specific courses:

(A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q).

(B) Hands-on experience with the U.S. Department of Transportation’s Emergency Response Guidebook (ERG) and familiarization with OSHA standard 29 CFR 1910.1201.

(C) Review of the principles and practices for analyzing an incident to determine both the hazardous substances present and the basic hazard and response information for each hazardous substance present.

(D) Review of procedures for implementing actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of DOT’s ERG including emergency notification procedures and follow-up communications.

These steps are part of our hazcom training. Hazcom training provides a good starting point for addressing the chemical hazards faced by first responders and their personal protection needs.

The requirements for the second level of emergency response activity are: First Responder Operations Level - 29 CFR 1910.120(q)(6)(ii)

First responders at the operational level are those persons who respond to releases or potential releases of hazardous materials as part of the initial response to the incident 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 to control the release from a safe distance and keep it from spreading.

Suggested criteria for specific courses:

(A), (B), (C) and (D), as for First Responder Operations Level and:

(E) Review of the principles and practice for proper selection and use of personal protective equipment.

(F) Review of the principles and practice of personnel and equipment decontamination.

(G) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.

(H) Awareness and knowledge of the competencies for the First Responder at the Operations Level covered in the National Fire Protection Association’s Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents.

Chemical management

Fortunately we are able to minimize the number of employees trained to this level because of the nature of our activities, the limited amount of chemical substances onsite, and the management of those substances. I’ve developed our hazcom plan to: 1) restrict the introduction of new chemicals until review and approval by the safety department, 2) regulate onsite quantities and storage arrangements, and 3) manage waste removal. It turns out this management plan is far less work than it might sound — mainly because its requirements are introduced on the first day of employment.

For those of you required to train the next three levels of Hazardous Materials Technician, Hazardous Materials Specialist and Incident Commander, I will leave the research up to you. I’ve been involved with those levels in the past and can realistically state that if you can manage the first levels you can reasonably deal with the others. But I’ve hit the maximum word count for this article and don’t want to have the “Preconceptual Scientist” bit cut.

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