A. Initial Training: Training shall be based on the duties and functions to be performed by each responder of an emergency response organization.

B. Employees who participate or are expected to participate in emergency response shall be given training as follows:

1. First responder awareness level:(2-4 hours) 29 CFR 1910.120(q)(6)(i)- First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:
   1. an understanding of what hazardous substances are, and the risks associated with them in an incident;
   2. an understanding of the potential outcomes associated with an emergency created when hazardous substances are present;
   3. the ability to recognize the presence of hazardous substances in an emergency;
   4. the ability to identify the hazardous substances, if possible;
   5. an understanding of the role of the first responder awareness individual in the employer’s emergency response plan, including site security and control and DOT’s Emergency Response Guidebook; and
   6. the ability to realize the need for additional resources, and to make appropriate notifications to the communication center.



NOTE: Persons trained to the awareness level are able to recognize an emergency and activate the emergency response plan.



1. First responder operations level:(8-24 hours) 29 CFR 1910.120(q)(6)(ii) First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level:
2. knowledge of basic hazard and risk assessment techniques;
3. knowledge of how to select and use proper PPE provided to the first responder operational level;
4. an understanding of basic hazardous materials terms;
5. knowledge of how to perform basic control, containment, and/or confinement operations within the capabilities of the resources and PPE available with their unit;
6. knowledge of how to implement basic decontamination procedures; and
7. an understanding of the relevant standard operating procedures and termination procedures.



NOTE: Persons trained to the operations level may respond to emergencies in a defensive manner only, when there is little or no potential for exposure to hazards.



2. Hazardous materials technician:( 8-24 hours) 29 CFR 1910.120(q)(6)(iii) Hazardous materials technicians shall have received at least 24 hours of training equal to the first responder operations level and in addition:
   1. know how to implement the employer’s emergency response plan;
   2. know the classification, identification, and verification of known and unknown materials by using field survey instruments and equipment;
   3. be able to function within an assigned role in the Incident Command System;
   4. know how to select and use proper specialized chemical PPE provided to the hazardous materials technician;
   5. understand hazard and risk assessment techniques;
   6. be able to perform advanced control, containment, and/or confinement operations within the capabilities of the resources and PPE available with the unit;
   7. understand and implement decontamination procedures;
   8. understand termination procedures; and
   9. understand basic chemical and toxicological terminology and behavior.




3. Hazardous materials specialist:(8-24 hours) 29 CFR 1910.120(6)(q)(iv) Hazardous materials specialists shall have received at least 24 hours of training equal to the technician level and in addition:
   1. know how to implement the local emergency response plan;
   2. understand classification, identification, and verification of known and unknown materials by using advanced survey instrument and equipment;
   3. know of the state emergency response plan;
   4. be able to select and use proper specialized chemical PPE provided to the hazardous materials specialist;
   5. understand in-depth hazard and risk techniques;
   6. be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and PPE available;
   7. be able to determine and implement decontamination procedures;
   8. have the ability to develop a site safety and control plan; and
   9. understand chemical, radiological, and toxicological terminology and behavior.




4. On-scene incident commander:(8-16 hours) 29CFR1910.120(q)(6)(v) On-scene incident commanders shall receive at least 24 hours of training equal to the first responder operations level and in addition:
   1. know and be able to implement the employer’s incident command system;
   2. know how to implement the employer’s emergency response plan;
   3. know and understand the hazards and risks associated with employees working in chemical protective clothing;
   4. know how to implement the local emergency response plan;
   5. know of the state emergency response plan and of the Federal Regional Response Team; and
   6. know and understand the important of decontamination procedures.

OSHA regulations (29 CFR 1910.120(e)(4) require that on-site management and supervisors directly responsible for, or who supervise employees engaged in, hazardous waste operations, receive at least eight additional hours of specialized training at the time of job assignment on such topics as, but not limited to, the employer’s safety and health program and the associated employee training program, personal protective equipment program, spill containment program, and health hazard monitoring procedure and techniques. Prerequisite: Completion of 40 hour waste site worker training.

This course meets the requirements in OSHA 29 CFR 1910.120(e)8 for eight hours of annual refresher training for workers at hazardous waste sites. This course is designed for general site workers who remove hazardous waste or who are exposed or potentially exposed to hazardous substances or health hazards. Topics include reviewing attendees past years experiences, new applicable regulations and standards, PPE, air monitoring and site safety plans..

This course is specifically designed for workers who are involved in government mandated and voluntary clean-up operation of hazardous substances and uncontrolled hazardous waste sites. This course covers topics included in 29 CFR 1910.120 (e) 3. Such as air monitoring, hazard assessment, selection and use of personal protection equipment including respiratory protection, site safety plans, decontamination and site emergencies. Typically presented in 4 ten hour days, the course will focus on identifying site hazards and how to protect the worker on hazardous waste sites.

Each year the affected employees must satisfy the 8 hour annual refresher training requirements by their respective anniversary date.

This refresher class will be focused solely on the requirements as listed in 29 CFR 1910.120(e) 8 and will related to work on hazardous waste sites. We will cover a variety of related topics including excavation safety, working around heavy equipment, site safety plans and toolbox/tailgate talks, chemical safety, risk assessment, PPE selection, and control of contamination.

Other areas of discussion will include work zone safety, fall protection, respiratory protection, on site emergencies and a review of past year’s experiences of the attendees.

Our presentation will be a directed round table discussion so as to address specific issues brought up by the attendees. We will present case studies to evaluate safety and both positive and negative examples of work practices.

The course will not be 8 hours of power points, interaction is promoted during all parts of the class.

We will also present new PPE and other related equipment. All attendees will have an opportunity to evaluate this new equipment with hands on experiences.

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.

• An understanding of what hazardous substances are, and the risks associated with them in an incident;
• An understanding of the potential outcomes associated with an emergency created when hazardous substances are present;
• The ability to recognize the presence of hazardous substances in an emergency;
• The ability to identify the hazardous substances, if possible;
• An understanding of the role of the first responder awareness individual in the employer’s emergency response plan, including site security and control and DOT’s Emergency Response Guidebook; and
• The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.

NOTE: Persons trained to the awareness level are able to recognize an emergency and activate the emergency response plan.

• Knowledge of basic hazard and risk assessment techniques;
• Knowledge of how to select and use proper PPE provided to the first responder operational level;
  An understanding of basic hazardous materials terms;
• Knowledge of how to perform basic control, containment, and/or confinement operations within the capabilities of the resources and PPE available with their unit;
• Knowledge of how to implement basic decontamination procedures; and
• An understanding of the relevant standard operating procedures and termination procedures.

NOTE: Persons trained to the operations level may respond to emergencies in a defensive manner only, when there is little or no potential for exposure to hazards.

• Know how to implement the employer’s emergency response plan;
• Know the classification, identification, and verification of known and unknown materials by using field survey instruments and equipment;
• Be able to function within an assigned role in the Incident Command System;
• Know how to select and use proper specialized chemical PPE provided to the hazardous materials technician;
  Understand hazard and risk assessment techniques;
• Be able to perform advanced control, containment, and/or confinement operations within the capabilities of the resources and PPE available with the unit;
• Understand and implement decontamination procedures;
• Understand termination procedures; and
• Understand basic chemical and toxicological terminology and behavior.

NOTE: Persons trained to the technician level may respond aggressively to emergency responses.

• Know how to implement the local emergency response plan;
• Understand classification, identification, and verification of known and unknown materials by using advanced survey instrument and equipment;
• Know of the state emergency response plan;
• Be able to select and use proper specialized chemical PPE provided to the hazardous materials specialist;
• Understand in-depth hazard and risk techniques;
• Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and PPE available;
• Be able to determine and implement decontamination procedures;
• Have the ability to develop a site safety and control plan; and
• Understand chemical, radiological, and toxicological terminology and behavior.

• Know and be able to implement the employer’s incident command system;
• Know how to implement the employer’s emergency response plan;
• Know and understand the hazards and risks associated with employees working in chemical protective clothing;
• Know how to implement the local emergency response plan;
• Know of the state emergency response plan and of the Federal Regional Response Team; and
• Know and understand the importance of decontamination procedures.

There are several steps the employer needs to take prior to conducting training. The first step is to develop a written confined space program. This includes a listing of all potential spaces. Then, the employer must decide if there is a way to complete the necessary activity without a person entering the space. One of the most overlooked issues at this stage is can non-entry(retrieval) rescue be performed for permit required spaces. If not, then how is the rescue team developed. Simply calling 911 is not adequate.

If it is decided that the employee is to enter the space, the employer must be committed to doing it right. This typically involves a substantial investment. To perform a proper confined space entry and accomplish a task that previously involved no entry procedures will increase the amount of time both in production and administration. Future work scheduling activities must allow for this extra time and management expectations should be adjusted accordingly.

The training requirements related to confined space entry are performance based and need to be employer specific. This means that the training must relate to the employers’ written confined space program. The actual length of time varies depending on the specific activities of the individuals and how long it takes to achieve proficiency at the needed competencies.

Developing the Training Program

Step One – Training Needs Analysis
This is used to determine who needs what. The analysis breaks down the overall operation into activities associated with individuals. These individuals are then grouped by similar functions associated with the confined space entry. They are then trained on their specific activities and duties related to the confined space. This would include an evaluation of the types of spaces entered, what duties the employee will be performing, rescue options, potential chemical and physical hazards, and the amount and content of previous training.

A review of other training requirements is conducted to determine if any overlap exists. If overlapping content is found, then the training program is designed to satisfy both requirements at the same time. For example, employees are required to be trained in proper lock-out, tag-out procedures. The requirement is also found in confined space training. Other areas of potential overlap are hazard communication, respiratory protection, and emergency response.

Step Two – Identify the Audience
The particular make up of the audience is critical to delivering the training at the appropriate technical level. The actual duties and types of spaces are another audience sorting factor. Certain duties such as welding would require different training than someone doing visual inspections. Those persons entering a chemical process vessel or boiler may differ in their training needs from someone entering sanitary sewers.

It is also critical to train with the equipment the employees will have access to. Although most air monitoring equipment operates in the same basic manner, each model will have peculiarities that are unique. Entry and retrieval equipment also have unique characteristics. Even full body harnesses vary on how a person straps into them.

Within each group, it is important to have those employees who will be functioning as entrants, attendants and supervisors together so they will understand the others’ duties. This is also a good time to review the employer’s confined space entry program. Many times the plan is written without input from those employees who will have to function under it. This approach will also facilitate the team approach which is necessary to the operation succeeding.

Those employees who have been designated as the rescue team must have specialized training in addition to that required for attendants. This is not the place to short cut. Rescue training should be upwards of 40 hours initially, and continuously practiced.

Step 3 – Scheduling

The training must be successfully completed prior to the employee entering a confined space. Additional training may be required if the conditions regarding the activities or the space the employee is entering changes.

The length of the training is dependent on several factors such as the technical background of the employees, the characteristics of the spaces to be entered, and the specific reasons for entering the confined space. Usually sessions are 8 to 24 hours in length, with rescue training an additional 8-24 hours.

The important point on which to focus is that the employee must actually have an understanding of the material presented and be able to function at their assigned duties. The actual length of the training must be adequate to accomplish this.

The training sessions should be scheduled in advance with the employee understanding why the training is being conducted. The sessions should also be scheduled during the employees’ normal work hours. If possible, the sessions should be scheduled for those times when representative spaces will be available for practice entries. These spaces should be similar to what the employee may encounter during their normal course of work.

While there is no requirement for annual refresher training for normal entry activities, a review of problems or areas for improvements would be prudent, even for those conducting frequent entries. Rescue personnel are required to conduct annual training, although more frequent practice is strongly encouraged.

Step – 4 Follow Up

As part of the written confined space program, continuous feedback is needed from the participants. Areas for improvement need to be identified and dealt with. The program administrator should periodically monitor the entire confined space entry process to determine if the original training was adequate. This is especially important for the infrequent participants. As regulations develop and change, the written program must change accordingly. This is also true for changes in the work involved with the confined spaces.

Workers involved with confined spaces are required to be trained according to 29 CFR 1910.146. This course will focus on hazard assessment, air monitoring, hazard control measures and non-entry rescue. Details will be based upon the employers written confined space entry program.

It’s the Law!
Code of Federal Regulations
Title 49, Subpart H, §172.700-172.704
(Formerly Docket HM-126F)

DEFINITIONS

HAZMAT EMPLOYEE means a person who is employed by a hazmat employer and directly affects hazmat transportation safety including:

an owner-operator of a motor vehicle which transports hazmat; a person (including a self-employed person) who:

• loads, unloads, or handles hazmat;
• tests, reconditions, repairs, modifies, marks, or otherwise represents packagings as qualified for use in the transportation of hazmat;
• prepares hazmat for transportation;
• is responsible for safety of transporting hazmat; or
• operates a vehicle used to transport hazmat.

HAZMAT EMPLOYER means a person who uses one or more of its employees in connection with:

• transporting hazmat in commerce;
• causing hazmat to be transported or shipped in commerce; or
• representing, marking, certifying, selling, offering, reconditioning, testing, repairing, or modifying packagings as qualified for use in the transportation of hazmat.

(The term “hazmat employer” also includes any department, agency, or instrumentality of the United States, a State, a political subdivision of a State, or an Indian tribe engaged in offering or transporting hazmat in commerce.)

TRAINING means a systematic program (i.e., consistent approach, testing, and documentation) that ensures that a hazmat employee has knowledge of hazardous materials and the HMR, and can perform assigned hazmat functions properly. See § 172.700(b) through § 172.704.

Training and the Hazmat Law
The Federal hazardous materials transportation law (49 U.S.C. § 5101 et seq.), is the basic statute regulating the transportation of hazardous materials (hazmat) in the United States. This law requires the training of ALL hazmat employees. The purpose is to increase a hazmat employee’s safety awareness and be an essential element in reducing hazmat incidents. The Hazardous Materials regulations (HMR) include training requirements in several sections of Title 49 Code of Federal Regulations (CFR) as follows:

TRAINING REQUIREMENTS

Each hazmat employer must:

• train and test,
• certify, and
• develop and retain records of current training (inclusive of preceding three years) for each hazmat employee (during the period of employment and 90 days thereafter).

Hazmat training must include:

• General awareness/familiarization,
• Function-specific,
• Safety, and
• Driver training (for each hazmat employee who will operate a motor vehicle).

Frequency of training

Initial training

• a new employee, or an employee who changes job functions, may perform hazmat job functions before completing training, provided:
  • the employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee; and
  • the hazmat training is completed within 90 days of employment or change in job function.
• Recurrent training is required at least once every three years. The three year period begins on the actual date of training.
• Relevant training received from a previous employer or source may be used to satisfy the requirements provided a current record of training is obtained from the previous employer or source.

Training Records must include:

• Hazmat employee’s name;
• Completion date of most recent training;
• Training Materials (Copy, description, or location);
• Name and address of hazmat trainer; and
• Certification that the hazmat employee has been trained and tested.