In emergency situations, responders are focused on performing their assigned task and often neglect the most basic safety procedures. That's why the assigned safety official's job - to scrutinize every aspect of the response and to make sure hazards are controlled and no unsafe acts are committed - is so important.
OSHA addresses emergency response safety in 29 CFR 1910.120, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. Paragraph (q) of this standard specifically covers employees who are involved in emergency response or hazmat emergency operations. It requires that emergency operations be conducted through the use of the Incident Command System (ICS) and that the person in charge of the ICS - the incident commander - assigns an individual as safety official.
This assigned safety official has the authority to override the incident commander's decisions and either alter, suspend or terminate the operations if at any time conditions at the emergency response site are considered immediately dangerous to life and health (IDLH) or pose imminent danger to personnel. The safety official plays a vital role in overseeing everyone's safety and that all operations are carried out in a safe manner.
The safety official is charged with two specific responsibilities - identifying and evaluating hazards, and providing direction with respect to safety in the emergency operation. At a minimum, this official needs to address the following eight specific areas
1) Identify site-specific hazardsThe safety official should identify, to the extent possible, all hazardous substances, health hazards and hazardous conditions present at the site. All potentially affected emergency responders should be informed of the site-specific hazards prior to entering the site.
Examples of hazards may include chemical, physical (such as slip, trip and fall), fire, noise and those associated with confined space operations and/or trenching and excavation operations. Appropriate engineering controls, such as ventilation or shoring, and administrative controls, such as hazardous substance handling procedures, should be put into place.
2) Evaluate atmospheric hazardsChemical contamination in the air must be evaluated to ensure safe conditions for response personnel. The HAZWOPER standard requires that air monitoring be conducted upon initial entry of the site and periodically thereafter. Direct reading instruments should be used to monitor the air for oxygen deficiency/enrichment, flammability, radiation present above dose levels, and contaminant levels present above applicable exposure limits or IDLH levels. Air monitoring results are then used to ensure that the proper engineering and administrative controls and personal protection equipment (PPE) are used.
3) Select appropriate PPEPPE should be selected based on the specific hazards present at the site. The safety official must evaluate the amount and type of skin protection needed and the level of respiratory protection required to ensure the safety of the responder (see sidebar below). PPE should be used as a last resort after hazard controls are implemented, according to OSHA's Hierarchy of Controls.
4) Ensure fitness for dutyAll personnel donning protective clothing should be medically monitored to ensure they are fit for duty. This includes documenting their blood pressure, pulse rates, respiration rates and body temperature at both pre- and post-entry. Entry times, SCBA bottle pressures before and after entry, and any other pertinent information should also be documented. This procedure also allows the safety official to monitor the effectiveness of the protective measures used on the site.
5) Control site zoningThe safety official is responsible for establishing appropriate protective action zones at the spill site. The hot zone, or exclusion zone, is where contamination is present. Responders entering the hot zone must be using the appropriate PPE and should not enter alone, but should be using a "buddy system" in groups of two or more. Backup personnel dressed to the same level of protection shall stand by in the cold zone ready to provide assistance or rescue. Advanced first-aid support should be on standby with medical equipment and transport capability.
Decontamination is located in the warm zone, or contamination reduction zone, which is outside of the hot zone. The cold zone, or support zone, is the area outside of the warm zone and should be located where no contamination is present. This is where staging of personnel and equipment occurs.
Pre-incident planning should include methods used for site control, site communications, provisions for emergency alerting, identification of the nearest medical facilities and establishing standard operating procedures.
6) Oversee decontamination proceduresThe safety official should help determine whether decontamination procedures are appropriate for the hazards present at the site, as well as the layout of the decontamination stations and the level of PPE required by the decontamination team. After decontamination, the entry team's PPE should be assessed to determine the effectiveness of the process.
7) Contain spillsEnsuring that the responders are performing spill containment operations within the capabilities of the PPE being used is also the job of the safety official. Spill containment operations issues include: compatibility of plugs and patches with contaminants present; grounding and bonding procedures for transfer of flammable liquids; and the use of non-sparking tools in the presence of flammable products.
8) Train response personnelIt's the safety official's responsibility to make sure personnel working at hazardous materials incidents are properly trained. All personnel entering the hot zone to take offensive actions, such as approaching the point of release in order to plug, patch or otherwise stop the release, must be trained to the technician level. Personnel entering the hot zone to take part in defensive actions, like confining the release from a safe distance and keeping it from spreading, should at least be trained to the operations level.
Skilled support personnel, such as heavy equipment operators and crane operators, are not required to meet the same training requirements as response personnel. However, they must be briefed at the site prior to their participation in an emergency response. This briefing must include PPE requirements, chemical hazards present and the duties they are to perform.
Demanding positionBy identifying and evaluating these hazards and providing direction with respect to the safety of the operation, the safety official occupies one of the most important and demanding positions at a hazardous materials emergency operation.
SIDEBAR: Levels of protectionEPA identifies four levels of PPE ensembles for responding to chemical spills:
- Level A protection - used when contaminants are present that require the highest possible degree of both respiratory and skin protection. Includes the use of an atmosphere supplying respirator such as a self-contained breathing apparatus (SCBA) and a totally encapsulating chemical protective (TECP) suit.
- Level B - used when contaminants are present that require the same degree of respiratory protection as Level A, but require a lesser degree of skin protection, such as a splash suit that is not totally encapsulating or gas tight.
- Level C - involves the same degree of skin protection as Level B, but a lesser degree of respiratory protection. Oxygen levels and chemical concentration levels must be known in order to use the air purifying respirators in the Level C ensemble.
- Level D - provides protection only against "normal" workplace hazards and is not designed to protect against chemical hazards. Includes safety glasses, hard hats, steel toe boots and leather work gloves.