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MANAGING BEST PRACTICES: Be careful what you ask for . . .

February 28, 2003
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A significant chunk of the nearly $30 billion authorized by Congress for spending in FY 2002 and FY 2003 on domestic terrorism protection goes to training and equipping local law enforcement, fire, medical and other government personnel to respond to an emergency release of hazardous material. On first blush, this might seem like a good deal for industry. Help is on the way.

But be careful what you ask for. Consider these stories:

An Indiana manufacturing plant asked to borrow a carbon monoxide meter from the local fire department. Personnel from the fire department said they would measure CO at the plant. Peak levels were measured near 15 ppm, well below OSHA's 50 ppm time-weighted average limit. But the fire chief said he had to follow city code and ordered an evacuation until CO levels dropped below 10 ppm.

A New Jersey manufacturing plant left a few ounces of an epoxy resin too long in a small industrial oven. A slight haze of smoke and a disagreeable odor filtered through the plant. Management wanted to eliminate the nuisance as soon as possible. A local fire department brought in portable exhaust fans - and fire trucks that blocked the front of the plant. Firemen entered the building in full turnout gear. Work stopped and all occupants were evacuated for more than two hours until the fire chief declared the building safe to reenter.

Different assessments

If your view comes from industry, you might feel fire department personnel in these examples overreacted. But the response and actions were clearly proper and appropriate if the position of the fire department is taken. Private and public first responders can have widely differing assessments and responses to hazardous materials incidents.

Consider "first aid kit," "fish scrap" and "wet hay" in the Department of Transportation's 2000 Emergency Response Guidebook (ERG2000). If there is a transportation incident involving these materials, the ERG2000 recommends that public emergency response personnel isolate the spill or leak area immediately for at least 30 to 80 feet in all directions, keep unauthorized personnel away, and stay upwind.

ERG2000 protection distances increase significantly when Toxic Inhalation Hazard (TIH) materials are involved. A spill of slightly more than 50 gallons (more than 200 liters) of some TIH materials may require, at night, protecting people who are downwind at more than seven miles.

Crazy recommendations? Not really. Not when all the possibilities are considered. And if there is an error, it's better to err on the side of caution.

We're blessed with outstanding service from our public responders to emergencies. But the better trained and equipped these responders are, the more formal and structured their response will be to real or potential emergencies. If you're unfamiliar with an incident command system and modern response to hazardous material releases, you might feel you're getting more help than you need.

Employers can usually protect people, property, and the environment from a hazardous material release quicker and more directly on their own than through outside help. But this means stepping up your training and support of hazardous materials technicians, hazardous materials specialists, and on-scene incident commanders.

Training requirements for response to hazardous materials emergencies can be found in several sections of OSHA regulations, most particularly, the Hazardous Waste Operations and Emergency Response (Hazwoper) regulations found at 29 CFR 1910.120(q).

Two options

Hazwoper requires employers to train employees for either awareness/defensive response or an aggressive (stop the source of the spill) response. For many employers the choice of training is a matter of time and cost. An awareness/defense response requires a minimum of eight hours of training, and response equipment may be limited to basic equipment - such as absorbent products. Aggressive training requires a minimum of 24 hours of training, and response equipment, including personal protective equipment, is more advanced, such as using SCBA respirators.

Awareness/defense response training limits you to simply controlling the release until outside help - such as the fire department - arrives. Once help arrives, if its personnel are trained in the elements of Hazwoper, an incident command system takes over and, usually, you lose the right to make final decisions on how the emergency is resolved.

Updated training elements, such as treating a response location as a "crime scene," for public first responders, are outlined in the Justice Department's Office of Domestic Preparedness (ODP) August 1, 2002, Emergency Responder Guidelines (see www.ojp.usdoj.gov/odp/). ODP's guidelines (not requirements) establish the broad and in-depth understanding of emergency response to hazardous materials expected of law enforcement, fire service, emergency medical services, emergency management, and public works.

Control vs. cost

If you choose aggressive response training for your people, in many cases you'll control an emergency from start to finish. If the hazardous material release has not left company property, notifications to outside parties might not be necessary.

Which way should you go? Weigh the entire cost/benefit, considering both direct and indirect factors. In the examples cited here, employers might have saved more if they trained and equipped employees to handle hazmat problems rather than turning to outside help.

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