General emergency response training should be conducted for all site workers with industrial facilities. This preparedness training should provide employees with basic response knowledge so that they can perform defensive actions in the event of an emergency. Unless employees are specifically trained and qualified in more advanced hazardous spill response techniques, the typical employee’s trained response or function is to contain a release from a safe distance, keep it from spreading, and prevent exposures.
This general training should familiarize employees with site-specific emergency procedures, equipment, and systems. Covered topics should include, but are not limited to:
- Incident reporting
- Instruction and procedures for using personal protective and emergency equipment.
- Evacuation and alarm procedures.
- Specific roles and responsibilities in response to fires and explosions.
- An understanding of the role of the first responder in an emergency.
- Safe use of engineering controls and equipment.
Advanced specialized training programs typically include detailed course instruction and regulatory agency certifications. An operational hazard or site-specific coordinated program often consist of classroom or online instruction, drills, and exercises. Specialized training may include, but is not limited to:
- Basic hazard and risk assessment techniques.
- Selection and use of proper personal protective equipment.
- Basic control, containment and/or confinement operations within the capabilities of the resources available.
- Relevant standard operating procedures and termination procedures.
- Principles of the Incident Command System.
- First Responder Operations Level.
- Hazardous Materials Incident Commander.
Retraining, or refresher courses, should be conducted for both general and specialized training requirements at a minimum of every 12 months or when certification requirements state. At a minimum, annual refresher training should cover current industry and in-house emergency operating experience, as well as changes in emergency operations plans, policies, procedures, and equipment. Additionally, annual training can highlight weaknesses identified through employee feedback and review of the program, drills, and exercises.
Federal OSHA HAZWOPER training requirements apply to “General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards” (per 29 CFR 1910.120(e)(3)(i) for general industry and 29 CFR 1926.65(e)(3)(i) for construction). These individuals must receive a minimum of 40 hours of instruction, either in a classroom or online, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.
According to OSHA, trainees must become familiar with standard and site specific safety processes and applicable response equipment in a non-hazardous setting. To ensure compliance, companies should verify that appropriate and thorough hands-on training is being conducted in conjunction with any online or classroom instruction.
As web-based technologies become more accessible and mobile, different options for online training programs have evolved. These flexible training portals can be used as an intricate tool in the context of an overall training program. Online training is often in conjunction with additional site training. However, it is critical that trainees have the opportunity and mechanism to clarify unfamiliar information in order to become proficient. A computer-based training program should include access to a telephone hotline or an e-mail contact at the time the training is being conducted so that trainees will have direct access to a qualified trainer at the time their questions are raised.
To ensure online training programs are accomplishing its goals, companies should develop methods of training evaluations. OSHA recommends the following:
- Questionnaires or informal discussions with employees can help employers determine the relevance and appropriateness of the training program.
- Supervisors' observations. Supervisors are in good positions to observe an employee's performance both before and after the training and note improvements or changes. Drills and exercises should be routinely conducted to confirm response proficiency and specific training knowledge
- Workplace improvements. The ultimate success of a training program may be changes in processes, procedures, or equipment that result in reduced injury or accident rates.
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