These kinds of â€œscientistsâ€ 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, â€œOh no, thatâ€™s not the way we do things around here.â€
Hereâ€™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 OSHAâ€™s standard â€” â€œHazardous Waste Operations and Emergency Responseâ€ â€” and exclaims HAZWOPER does not apply because your facility is not involved in hazardous waste operations.
Donâ€™t kid yourself.
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 â€œgood intentionsâ€ are so named because of the ever-existent possibility (that is, Murphyâ€™s Law) of â€œanything happening at any time.â€
Murphyâ€™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.
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 Transportationâ€™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 organizationâ€™s standard operating procedures, and the current edition of DOTâ€™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 Associationâ€™s Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents.
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. Iâ€™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 Iâ€™ve hit the maximum word count for this article and donâ€™t want to have the â€œPreconceptual Scientistâ€ bit cut.