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The Misinterpretations of HAZWOPER Response Capabilities

Posted on Fri, Aug 13, 2010

Numerous organizations have emergency response policies in place based on misinterpretation of the HAZWOPER regulations. The purpose of the initial responder (operations level) of an emergency is to protect life, property, or the environment from the effects of the release, not stop the release.

Operational responders are trained to respond in a defensive fashion without actually trying to terminate the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.

Employees who are exposed or potentially exposed to hazardous substances, including hazardous waste, are required to be HAZWOPER certified.  According to OSHA, first responders at the operations level are those individuals who respond to releases, or potential releases, of hazardous substances as part of the initial response to the site.

Any employee or contractor, upon discovering a significant event or condition that requires urgent response from outside trained personnel, should take the suggested initial response actions listed below and report the emergency to the designated onsite Emergency Dispatch Center to render additional response.

Initial Response Actions:

  • Discovery of an emergency situation.
  • Warn others in the immediate area by word of mouth and activate local alarms.
  • Take immediate personal protective measures (PPE, move to safe location, etc.).
  • Report the emergency to Security.
  • Implement local response actions (process shutdowns, activate fire protection systems, etc.) if safe to do so, and consistent with level of training and area specific procedures.

A response effort by trained emergency personnel from outside the immediate area, or by other designated responders (i.e., mutual aid groups, local fire departments, etc.), would then go into effect. An event that requires outside emergency assistance can be, but is not limited to, an uncontrolled release of a hazardous material, fire, explosion, and serious injury or illness to personnel where there is a potential risk of exposure to blood borne pathogens.

Below are examples of classification levels and potential responses.

LEVEL ONE Classification: Minor Incident

  • Minor threat to life, property, or environment DOES NOT extend outside of immediate area.
  • No spill/release or fire in progress, no potential for explosion or loss of control.
  • Area Supervisor and Unit personnel can effectively manage situation.

Response

  • On-Scene Incident Commander and Emergency Response Team assistance limited to routine medical response, advice, assessment, and post-incident support/cleanup activities.
  • External assistance limited to routine medical transport and/or law enforcement assistance.
  • Notifications as required.

LEVEL TWO Classification: Serious Incident

  • Serious threat to life, property, or environment may extend outside of immediate area, but DOES NOT extend Off-Site.
  • Protective actions required for unit and/or nearby areas.
  • Rescue or medical response - Serious injuries reported or possible.

Response

  • On-Scene Incident Commander and Emergency Response Team respond or on stand-by.
  • External assistance at discretion of On-Scene IC.
  • Emergency Operation Center will be activated.

 LEVEL THREE Classification: Significant Incident

  •  Significant threat to life, property, or environment extending or with POTENTIAL to extend Off-Site.
  • Protective actions required for nearby units/areas, and/or off-site communities.
  • Potential for significant impact to company reputation, operability, or revenues.

Response

  • On-Scene Incident Commander and Emergency Response Team respond.
  • External coordination and/or assistance is required.
  • An Emergency Command Center is activated.
  • Corporate Crisis notification at discretion of Emergency Operations Center Director

In conclusion, operational responders are trained for defensive reactions, not to terminate the release. Their main function is to contain the release from a safe distance, keep it from spreading and creating exponential incidences, and prevent exposures.

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Tags: PHMSA, Pipeline, OSHA HAZWOPER, SPCC, HAZWOPER, OSHA HAZWOPER standard training