To accurately select the level of emergency response training under the HAZWOPER standard (29 CFR 1910.120) one must first determine the end result or goal of the training. This will vary greatly from company to company based upon a variety of factors such as what hazardous chemicals and in what quantity are present, what types of processes are involved and the resources available for the response actions.
Other regulations require emergency response training as well as 29 CFR 1910.120. These may include process safety, DOT, and standards specific to a particular chemical such as chlorine or ammonia. Therefore, before a decision is made, one should view training requirements in a broad sense, and combine as many of the required programs as possible to avoid duplication of effort.
The first step is to determine what is an emergency. For example, employees can be trained under hazard communication to clean up routine, low hazard spills and releases. The employee should have an understanding of the hazards the material they may be working with. This should allow them to safely clean up the spilled material and dispose of it correctly. There are many variables to determining what is a routine spill and what is an emergency response, including location, quantity spilled, the characteristics of the material and even the employees comfort level wit the material.
The next step in determining the training level is to develop the written emergency response plan. To have an effective plan, a commitment must be made by all parties involved to follow the plan and to assign sufficient resources to the plan. Deciding to use the local fire department as the response team may look good on paper, but until the arrangement is discussed with and approved by the local fire department, it does not exist. Many fire departments may not have the resources to adequately respond to major chemical emergencies. If they have the resources they may not be in proximity to the location to be effective. Regardless of the level of response plan, the local fire department should be advised as to the emergency response plan.
The first level of response is the first responder awareness level. These are employees that work in areas where the hazardous materials are used, stored or transported. Any employee who is likely to discover a hazardous material release that would be considered an emergency should be trained to this level. The training focuses on hazard recognition and what constitutes an emergency and how to initiate the companies emergency response program. They may also warn other employees in the area and prevent anyone from coming in to contact with the released material.
The length of training can vary from 2 hour up to 8 hours. However it is important to note that much of the same subject matter can be covered during hazard communication training.
The second level of response is the first responder operations level. These are employees who will work in a defensive manner only, with little or no risk of exposure. Examples of operations level activities are using absorbents or other materials to block drains in front of the release, act as support for technician level personnel, site control, etc. The determination is based upon risk of exposure. The training for operations level will vary from 8 to 24 hours.
The third level is the hazardous materials technician. These are employees that will respond aggressively to halt the release and control the spread of the hazardous materials. This may include hazard mitigation and will generally have a higher risk of exposure from the released material. This level has a prerequisite of 24 hours of training at the operations level and meeting the additional competencies as shown of the attached summary sheet.
Next is the hazardous material specialist level. These employees can be in house experts such as some one who has a complete understanding of the characteristics and hazards of the released material. Specialists are required to acquire 24 hours at the technician level as well as satisfy the additional requirements listed. Hazardous materials specialists will typically provide information and insights to the incident commander for decision making purposes.
The final level of training is the incident commander. This is the person who will take charge and direct the response action. The incident commander is responsible for the safety of all personnel involved. This training requires 24 hours at the operations level as a prerequisite in addition to the topics listed in the attached summary sheet.
One can quickly become overwhelmed by the amount of effort to support an internal emergency response team. For example, to respond at the technician level, that is to aggressively attack the release, an incident commander is required. This requires additional training. This leads to staffing issues. Will there be sufficient staff trained to the technician and incident commander levels for all shifts, during vacations, right sizing , swing shifts, weekends, etc.
The equipment costs can be considerable as well. Respiratory protection, protective clothing, air monitoring can add to several thousands of dollars just to get started.
However, if the commitment can be made, a very valuable resource can be developed. The in house response team can literally save lives and money by control the hazardous release before damage is done. This can result in lowering product loss, down time and insurance rates.
Another option is out source the more dangerous response to a private company. This is a reasonable compromise for those companies with infrequent emergencies or limited resources.