Your Solution for SMART Response Plans

The Importance of Response Plan Training for the First Responder

Posted on Thu, Jan 22, 2015

Any employee has the potential to be put in a first responder role in the event of an emergency at the office, jobsite, or facility.  As a result, all employees should be trained in response measures appropriate for site-specific vulnerabilities and identified risks. The rapid mobilization and proficiency of initial actions, as well as response procedure familiarity is essential in order to minimize potential chaos, scenario consequences, and plausible chain-reaction events.

In order to avoid the onset of panic or prolong emergency circumstances, necessary and effective reactive measures should become second nature to any potential initial responder. Familiarity through training and exercises can combat the natural effects of stress in tense situations. Having a well-rehearsed emergency plan enables efficient and effective response coordination, reduces losses, and can limit the impact to employees, the environment, and surrounding community.

Efforts must be made to train non-response team members in initial response actions and the appropriate initiation procedures. Any employee or contractor, upon discovering a significant event or condition that requires urgent response from outside trained personnel, should be trained to take the suggested initial response actions listed below:

Initial Response Actions:

  1. Warn others in the immediate area through verbal communication and/or activate local alarms.

  2. Take immediate personal protective measures (PPE, move to safe location, etc.).

  3. Report the emergency to Security or 9-1-1, depending on company policy.

  4. 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.

Industrial facility employees often encounter unique, site-specific hazards, and potential threats, unlike those in other fields. Specialized training must complement response team roles and responsibilities in order to address these specific vulnerabilities and risks. But despite an industrial setting, not all employees will be assigned to a formal response team.

Employees who may be exposed to hazardous substances are required to be HAZWOPER certified. HAZWOPER, an acronym for the Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Standard, communicates the required training that addresses hazardous operations and potential spills or releases. The intent of the HAZWOPER standard is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).  However, this does not mean that all HAZWOPER certified employees are responsible for terminating a release. According to the standard, the following first responder levels are not trained to terminate a hazardous incident.

The Awareness Level:  According to OSHA, the first responders at the “awareness level” must demonstrate competency in areas such as recognizing the presence of hazardous materials in an emergency, the risks involved, and the role they play in their employer’s plan.

Who should be trained? This level is applicable for persons who, in the course of their normal duties, could be the first on the scene of an emergency involving hazardous material. Responders at the awareness level are expected to recognize the presence of hazardous materials, protect themselves, call for trained personnel, and secure the area without engagement.

Individual companies can set their own hourly training requirements; however, employees must be capable of demonstrating the following:

  • What hazardous substances are, and associated risks during an incident

  • The potential outcomes associated with an emergency when hazardous substances are present

  • Ability to recognize the presence of hazardous substances in an emergency

  • Ability to identify the hazardous substances, if possible

  • The role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook

  • Ability to realize the need to make appropriate notifications for additional resources

The Operations Level: Operations level responders meet and exceed the competency level of the awareness responder. 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.

Who should be trained? These responders are part of the initial response for the purpose of protecting nearby persons, the environment, and/or property from the effects of the release.   Operations may receive additional training in HAZMAT/CBRNE defensive techniques of absorption, damming and diking, diverting, retention, vapor dispersion and suppression. They may also be trained in basic decontamination procedures and PPE.

First responders at the operational level should complete the 8-hour HAZWOPER training course or have had sufficient experience to objectively demonstrate competency in the following areas:

  • Basic hazard and risk assessment techniques

  • How to select and use proper personal protective equipment

  • Basic hazardous materials terms

  • How to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit

  • How to implement basic decontamination procedures

  • The relevant standard operating procedures and termination procedures

For a free download on conducting an effective exercise, click here or the image below.

TRP Corp Emergency Response Planning Exercises

Tags: OSHA HAZWOPER, Facility Response Plan, Response Plans, Facility Management, Disaster Response, Workplace Safety, Chemical Industry, HSE Program

How HSE Audits Can Address Gaps in your Regulatory Plans

Posted on Mon, Mar 03, 2014

Regulatory requirements are designed to prevent injuries, releases of hazardous materials, and ensure adequate responses are in place if and when an incident occurs. However, companies often find themselves scrambling to fill identified gaps in processes, procedures, and response plans after a response or audit is completed. If these gaps are left open, companies can face fines, lawsuits, shutdowns, and/or reputational risk.

Fortunately, audits, whether conducted by in-house professionals or experienced consultants, can often reveal the same deficiencies and opportunities for improvement as regulatory agencies. Some companies address response plan gaps only after an incident or audit occurs. With an objective eye, a gap analysis can bolster an overall emergency management program and minimize the potential for an incident, fine, or inadequate response.

Regulatory requirements must be identified in order for gaps to be identified.. In order to maintain consistent compliance, facility managers and company health, safety, and environmental professionals should become familiar with regulations applicable to their area of responsibility and operations. If necessary, outside consults can be utilized to identify all applicable regulations based on company location(s), industry, operations, and hazards.

GAP EVALUATION/CONTROL

After an incident or audit, new or unidentified risks or regulatory gaps may be identified that were not previously included in response plans. Upon recognition, every effort should be made for mitigation. However, if the risks cannot be eliminated, new countermeasure processes and procedures must be implemented and response plans adjusted accordingly in order to eliminate potential gaps. If audits identify that applicable regulatory requirements are not met, specific content, and/or processes must be implemented and/or documented to satisfy those requirements.

The following concepts can assist in addressing gaps in regulatory plans:

  • High probability and operational risks should be cross-referenced with potential regulatory requirement(s).
    • Evaluate accident probability for each process, procedure, handled material, and their resulting levels of potential severity if an accident were to occur.
    • The probability and severity of a risk should determine the priority level for correcting the hazard. The higher the probability and severity of risk, the higher the emphasis should be on corrective action.
  • If accidents or incidents occur, isolate, eliminate, or mitigate the root cause, and identify any/all linking regulatory requirements.
    • Response plan documentation should include processes and procedures applicable to the accident or incident. If a gap was identified during the response, amendments must communicated, incorporated into training, and documented in the response plan.
  • If audits reveal regulatory gaps, changes in processes and/or procedures should be made in order to become compliant with regulatory agencies.
    • Process or procedural amendments must communicated, incorporated into training, and documented in the response plan.
    • Implement and document any risk reducing engineering controls
  • Proactive administrative controls or work place practices can reduce the potential of gaps in response plans, training, and/or exercises.
  • Accident prevention signs should be posted to remind occupants of the presence of hazards and applicable regulations
  • Establish and communicate emergency response plan content  to employees and appropriate emergency response team members. Provide a mechanism for workplace process feedback and regulatory implementation.
  • Implement web-based, database driven response plans.
    • Advanced technology allows for an audit “checklist”, specifically linking specific requirements to applicable content within the plan.
    • Provides the ability to duplicate recurring facility information to satisfy multiple agency requirements.
    • Eases the administrative time by easing the ability to update content and ever-changing regulations, minimizing the opportunity for regulatory implementation delays.

 

For a free white paper on how audits can assist your company with regulatory compliance, click the image below:

Regulatory Compliance with TRP Corp

Tags: PHMSA, OSHA HAZWOPER, Facility Response Plan, EPA, Regulatory Compliance, Emergency Management Program

Curbing Costs with Preparedness: OSHA's Top Ten Cited Standards

Posted on Thu, Jan 30, 2014

“Statistics suggest that every dollar invested in disaster preparedness yields savings of $4–$11 in disaster response, relief, and recovery.” The Harvard Humanitarian Initiative

Preparedness is directly tied to issues that can adversely affect profitability.  Instituting, upgrading, and/or maintaining a proactive preparedness program may be seen as a superfluous expenditure. However, when companies can deliberately protect lives, prevent hazardous environmental impacts, limit property damage, and eliminate regulatory fines, prioritizing an EHS program becomes an investment in the sustainability of a company. 

OSHA recently revealed its Top Ten most frequently cited standards for the 2013 fiscal year (October 1, 2012 through September 30, 2013). The list incorporates worksite inspection findings of Federal OSHA inspectors from across the country. Ideally, companies should utilize this list to conduct assessments, identify potential site-specific compliance lapses, and mitigate these highly recognized hazards. In a press release, OSHA stated, “Far too many preventable injuries and illnesses occur in the workplace.”  The Top Ten most frequently cited standards include:

  1. 1926.501 - Fall Protection
  2. 1910.1200 - Hazard Communication
  3. 1926.451 - Scaffolding
  4. 1910.134 - Respiratory Protection
  5. 1910.305 - Electrical, Wiring Methods
  6. 1910.178 - Powered Industrial Trucks
  7. 1926.1053 - Ladders
  8. 1910.147 - Lockout/Tagout
  9. 1910.303 - Electrical, General Requirements
  10. 1910.212 - Machine Guarding

The Bureau of Labor Statistics revealed that fatal falls, slips, or trips took the lives of 668 workers in 2012, down slightly from 2011. In 2012, the height of the fall was reported in 437 of the fatal falls to a lower level. Of those cases, about one in four occurred after a fall of 10 feet or less. Another one-fourth of the fatal fall cases occurred from falls of over 30 feet. Companies should utilize this information to evaluate their site-specific safety measures. By analyzing current safety elements, processes, and procedures, companies can potentially mitigate inefficiencies and substandard compliant operations.

A cost-benefit analysis of an emergency management program can highlight the potential cost savings of an effective program. Prevention, mitigation, and planning costs should be compared with the financial impact of situational recovery processes and the overall costs of an incident. These costs may include, but are not limited to:

  • Human life
  • Short term or long term business interruption
  • Lawsuit(s)
  • Infrastructure damage
  • Equipment failure
  • Inventory/stock losses
  • Fines
  • Reputation
  • Environmental destruction

Additionally, companies must ensure that their facilities are compliant with OSHA requirements to develop  written Emergency Action Plans (EAP) and Fire Prevention Plans. The requirement is based on the number of employees that are physically in a facility at any time of the working day. The regulation states that employers with 10 or fewer employees do not have to create a written EAP. However, employers are still required by OSHA to communicate an EAP to staff. An EAP must communicate the following minimum requirements:

  • Procedures for emergency evacuation, including type of evacuation and exit route assignments (29 CFR 1910.38(c)(2))
  • Procedures to be followed by employees who remain to operate critical operations before they evacuate (29 CFR 1910.38(c)(3))
  • Procedures to account for all employees after evacuation (29 CFR 1910.38(c)(4))
  • Procedures to be followed by employees performing rescue or medical duties (29 CFR 1910.38(c)(5))
  • Means of reporting fires or other emergencies (29 CFR 1910.38(c)(1))
  • The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan. (29 CFR 1910.38(c)(6))
For a free download on Fire Pre Plans, click the image below:
TRP Corp Fire Pre-Plans Pre Fire Plan

Tags: OSHA HAZWOPER, OSHA, Emergency Preparedness, Emergency Management Program, Emergency Action Plan

Advanced HAZWOPER Training Supports HAZMAT Responses

Posted on Mon, Aug 05, 2013

The intent of the OSHA’s HAZWOPER standard (Hazardous Waste Operations and Emergency Response ) is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).  Employees who may be exposed to or respond to hazardous material emergencies are required by the Occupational Health and Safety Administration (OSHA) to have specific HAZWOPER training.  

There are various OSHA training levels of HAZWOPER that are commensurate with the type of work and the potential involvement with hazardous materials. The HAZMAT technician and the HAZMAT specialist are to have significant knowledge of HAZMAT situations and can assist the incident commander in response assessments. Both the technician and specialist levels are required to initially complete, at a minimum, the 24-hour training HAZWOPER training. However, technician level responders vastly outnumber specialist level responders, and are the most frequent personnel in handling HAZMAT incidents.

Trained HAZMAT technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. These individuals assume a more aggressive role than an operational level first responder in that they are trained to approach the point of release in order to plug, patch, or otherwise stop the release of a hazardous substance. HAZMAT technicians may not be classified as scientific experts; however, most have an understanding of chemistry that may range from basic to advanced.

The HAZMAT technicians must demonstrate competency in the following areas:

  • Implementation of the employer's emergency response plan.
  • Classification, identification and verification of known and unknown materials through the use of specialized equipment.
  • Functioning within an assigned role in the Incident Command System.
  • Selecting and using proper specialized chemical personal protective equipment provided to the hazardous materials technician.
  • Hazard and risk assessment techniques.
  • Performing advanced control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.
  • Understanding and implementing decontamination procedures.
  • Understanding termination procedures.
  • Understanding basic chemical and toxicological terminology and behavior.

On average, HAZMAT technicians complete 40-hours of training. Certified technicians new to a site must receive appropriate, site-specific training before site entry and have appropriate supervised field experience at the new site. Equivalent training includes any academic training or the training that existing employees might have already received from actual hazardous waste site experience.

The HAZMAT specialist receives the highest level of HAZWOPER training. The specialist typically responds with and supports the duties of hazardous materials technicians. These individuals’ duties parallel those of the technician; yet require a greater knowledge of the various substances they may be called to contain. HAZMAT specialists often act as a site liaison with Federal, State, Local and other government authorities in regards to site activities.

The HAZMAT specialist must demonstrate competency in the following areas:

  • Implementation of their employer’s emergency response plan.
  • Classification, identification and verification of known and unknown materials by using advanced survey instruments and equipment.
  • Knowledge of the state emergency response plan.
  • Selecting and using proper specialized chemical personal protective equipment provided to the hazardous materials specialist.
  • Detailed hazard and risk assessment techniques.
  • Performing specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available.
  • Implementing decontamination procedures.
  • Developing a site safety and control plan.
  • Understanding chemical, radiological and toxicological terminology and behavior.

The Specialist responder typically has an in-depth and highly advanced level of knowledge in chemistry, biology or some other discipline of science. According to FEMA the HAZMAT specialist is responsible for:

  • Providing ongoing monitoring of local environmental conditions during operations.
  • Providing an initial and ongoing survey for presence of hazardous materials at search and rescue sites.
  • Implementing defensive mitigation practices when indicated.
  • Directing emergency decontamination procedures for any task force member or victim.·
  • Providing assistance to medical personnel for  chemical exposure and injuries.
  • Documenting all related information.
  • Adhering to all safety procedures.
  • Accountability, maintenance, and minor repairs for all issued equipment.
  • Performing additional tasks or duties as assigned during a mission.
  • Ensuring MSDS are provided for all hazardous materials carried or used by the task force.
  • Ensuring all specialized equipment is maintained and calibrated according to the manufacturers’ specifications.

Although HAZMAT specialists are required to initially pass the 24-hour HAZWOPER training, most specialists have completed university-level courses. A HAZMAT specialist often holds a four-year Bachelor of Science degree in engineering, chemistry, biology, or other science related field.  It is not uncommon for a specialist level responder to have an advanced degree.

TRP Corp Emergency Response Planning Exercises

Tags: OSHA HAZWOPER, Training and Exercises, Workplace Safety, HAZWOPER, Chemical Industry, OSHA HAZWOPER standard training

Safety Training Through HAZWOPER Certification

Posted on Thu, Jul 25, 2013

America’s largest retail store was recently fined $81 million for improper handling of hazardous wastes and pesticides. The chain did not have a store level safety program in place to train its employees on proper hazardous waste management and disposal practices. As a result, hazardous wastes were transported without proper documentation or improperly discarded, including being put into municipal trash bins or poured into the local sewer system.

From manufacturing facilities to store fronts, hazardous substances can be found in an array of company locations. Facility safety training should incorporate processes and procedures applicable to hazardous material interactions and disposal. Unless handled by training individuals and disposed of properly, hazardous material can create health risks for people and damage the environment.

If a site houses hazardous material, HAZWOPER training may be necessary. The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to specific groups of employers and their employees. Employees who are exposed or potentially exposed to hazardous substances, including hazardous waste, are required to obtain -Online Training.

There are various Occupational Health and Safety Administration (OSHA) training levels of HAZWOPER that are commensurate with the type of work and the potential involvement with hazardous materials. The following two levels of HAZWOPER training apply to employees that will not assume the aggressive role of attempting to plug, patch, or otherwise stop the release of a hazardous substance.

HAZWOPER training - TRP

Awareness Level

According to OSHA, the first responders at the “awareness level” must demonstrate competency in areas such as recognizing the presence of hazardous materials in an emergency, the risks involved, and the role they play in their employer’s plan.

This level is applicable for persons who, in the course of their normal duties, could be the first on the scene of an emergency involving hazardous materials. Responders at the awareness level are expected to recognize the presence of hazardous materials, protect themselves, call for trained personnel, and secure the area without engagement.

Individual companies can set their own hourly training requirements, however, employees must be capable of demonstrating the following:

  • Understanding what a hazardous substance is, and associated risks
  • Understanding potential outcomes associated with an emergency involving hazardous substances
  • Ability to recognize the presence of hazardous substances during  an emergency
  • Ability to identify the hazardous substances, if possible
  • Understanding the role of the first responder awareness individual in the employer's emergency response plan, including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook
  • Ability to recognize the need to make appropriate notifications for additional resources

Operations Level

Operations level responders meet and exceed the competency level of the awareness responder. 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.

These trained responders are part of the initial response to the incident for the purpose of protecting nearby persons, the environment, and/or property from the effects of the release. Operations may receive additional training in HAZMAT/CBRNE defensive techniques of absorption, damming and diking, diverting, retention, vapor dispersion and suppression. They may also train in basic decontamination procedures and PPE.

First responders at the operational level should complete the 8-hour HAZWOPER training course or sufficient experience to objectively demonstrate competency in the following areas:

  • Basic hazard and risk assessment techniques
  • Selection and use of proper personal protective equipment provided to the first responder operational level
  • Basic hazardous materials terms
  • Basic control, containment and/or confinement operations within the capabilities of available resources and personal protective equipment
  •  Implementation of basic decontamination procedures
  • Relevant standard operating and termination procedures
TRP Corp Emergency Response Planning Exercises

Tags: OSHA HAZWOPER, OSHA, Training and Exercises, Safety, HAZWOPER, OSHA HAZWOPER standard training

Emergency Response Exercises and HAZWOPER Training

Posted on Thu, Apr 18, 2013

A recently released study entitled Staging and Performing Emergencies: The Role of Exercises in UK Preparedness states that comprehensive exercises are essential for an effective response to various types of emergencies. Just as incidents vary in scale, duration, and complexity, training and response exercises need to be inclusive of site specific threats and risks. Authors Dr Ben Anderson and Dr Peter Adey of the report told  Science Omega magazine that there are three core reasons why exercises are beneficial and increase the likelihood of an effective response.

  1. Collaboration Rehearsal: Exercises enable separate organizations to collaborate in a real-world simulation of an incident. Organizations that operate separately on a day-to-day basis must collaborate on procedures that would be necessary in an actual emergency. Dr. Anderson states, “Exercises allow organizations the opportunity to work together, both formally, in terms of enabling various protocols or communication procedures to be used, and informally, in terms of getting to know the organizational culture of other bodies”.
  2. Test strategies and plans: Exercises allow the various strategic response components to be tested. Through real-world exercise scenarios, companies can evaluate procedures and plans before the real event.
  3. Confirm roles and responsibilities: Exercises reveal response competencies. Employees and responders must have a thorough understanding of required roles and responsibilities in order to react effectively, make timely decisions, and perform appropriate actions within high-pressure emergency situations.

Response plan exercises may incorporate on-site operational responders. The typical staffed operational responder is 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 prevent exposures. The ability to terminate a release may require a higher level of training.

A response effort by trained emergency personnel or other designated responders (i.e., fire brigade, mutual aid groups, local fire departments), 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.

If a facility has hazardous material on-site, HAZWOPER training may be necessary. The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to specific groups of employers and their employees. Employees who are exposed or potentially exposed to hazardous substances, including hazardous waste, are required to obtain HAZWOPER training.

OHSA mandates that individuals who work in the following areas must complete the standard HAZWOPER training.

  • General site workers: Individuals, such as equipment operators, general laborers and supervisory personnel, who are engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health.
  • Operations crew: Individuals involved in hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations.
  • Emergency response operations team: Those directly involved in responding to the releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.

There are various training levels with HAZWOPER. Training levels should reflect the type of work and the potential hazard involved in the work.

  • 40-hour HAZWOPER Training: Those individuals directly involved in the cleaning up of hazardous materials, its storage, or its transportation should take the 40-hour HAZWOPER course. The 40 hour course is required for the safety of workers at uncontrolled hazardous waste sites.
  • 24-hour HAZWOPER Training: Appropriate training for those who are less directly involved with uncontrolled hazardous waste sites (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying).
  • 8-hour HAZWOPER Training: Managers are required to attain the same level of training (either the 40-hour or 24-hour training) as those they supervise, and an additional 8 hours.

There are numerous sources for OSHA-based HAZWOPER training, from community colleges to private consultants. However, companies must insure that the trainer teaches the required material and provides certification to the students. The certification is assigned to the employee, not the employer. Because of this, individuals must receive the full training mandated, not just those areas that are covered at the current work site.

For tips and best practices on designing a crisis management program, download Tips for Effective Exercises.

Exercises - TRP Corp

Tags: OSHA HAZWOPER, OSHA, Training and Exercises, HAZWOPER, OSHA HAZWOPER standard training

Training and Multiple Levels of Exercises in Emergency Management

Posted on Mon, Dec 03, 2012

Environmental, Health, and Safety (EHS) departments are required to, conduct and document response training and exercises to satisfy industry-specific regulations. Training and exercises should enhance specialized skills and knowledge to improve overall preparedness. Exercises and training are separate, yet coordinated methods that come together to achieve this common objective.

Training: an individual instructional component or instructor-led classroom-based activity with a focus on individual knowledge development sufficient to perform specific roles and undertake prescribed responsibilities.

Exercise: the activity of practicing roles, responsibilities, and/or procedures with a focus on development of individual skills and/or to test and identify deficiencies in plans and procedures.

Company emergency managers should aim to create an efficient method to track individual training needs and identify team members’ current qualifications. Through proper maintenance of a training portal, individuals will remain at peak optimal response capabilities. Training should include, but not be limited to:

  • Familiarization with Response Plan
  • Individual roles and responsibilities.
  • Plan review training whenever a substantial change or revision is made to the plan that affects organization, procedures, roles and responsibilities, or response capability.
  • Refresher courses, as necessary

Training may include general employees at the first responder awareness level to the hazardous material specialist or incident commander level. Each company site may require specialized training depending on the current operations, location, and associated regulations.

The goal of the exercise program should be to improve the overall readiness and capabilities of emergency response program that encourages:

  • Realistic scenarios
  • Proper training validation
  • Effective emergency plans
  • Identification of action items
  • Operational response capabilities
  • Preparedness to respond to incidents, regardless of the threat or hazard.

To ensure employees and response personnel are prepared to respond to an incident in an efficient and effective manner, exercise guidelines should be established as minimum requirements within an emergency preparedness program. Management should ensure that:

  • All aspects of response plans are exercised annually with participation of the appropriate response, incident management, and support teams.
  • Each response plan component is exercised at more frequent intervals, as appropriate, to prepare for the main annual exercise.
  • Notification exercises for each team and response component are verified and practiced at least twice per year. This exercise should involve unannounced checks of the communication procedures, , equipment, and contact information.
  • National and local training and exercise requirements should be used to assess the overall preparedness of your response teams.

Companies should utilize the following full range of exercise activities in planning and executing the exercise program

Level 1 Tabletop Exercises: Useful for considering policy issues, and for building team relationships in a low stress environment.

  • Practice application of National Incident Management System (NIMS) and the Incident Command System (ICS)
  • Demonstrate a functional understanding of the Emergency Response Team (ERT) and Incident Management Team (IMT) organizations.
  • Practice integration of Unified Common organization(s), and general responsibilities and expectation of the company
  • Demonstrate the ability to document and communicate actions, management decision, and track resources, using standardized Incident Command System (ICS) forms and the Emergency response Plan (ERP)

Level 2 Mobilization and/or Notification Exercise: Used to validate mobilization and response times, and verify internal/external notifications and contact information.

  • Practice and assess specific functional response elements
  • Validate response contractor equipment deployment response times
  • Practice and validate specific response procedures and locations

Level 3 Limited Exercises: Used to validate mobilization and response capabilities of specific team functions, and the status of integration and coordination among these groups and other company-based response organizations.

  • One or more teams
  • Optional external involvement
  • Scenario presented through both written materials and limited role-playing by simulators

Level 4 Full Scale Exercise: Full-scale exercises offer comprehensive validation of current emergency and crisis management system, and should demonstrate a degree of response integration throughout the system.

  • Expanded demonstration Crisis Management and Emergency Response capabilities
  • Promotes extensive comprehensive coordination and integration of capabilities
  • Maximize realism for participants with multiple realistic injects
  • Extensive use of controllers to ensure the exercise activity remains within intended parameters and to coordinate the scenario among multiple sites

For a free guide that details the world of HAZWOPER training, download A Guide to HAZWOPER Training.

HAZWOPER training guide

Tags: OSHA HAZWOPER, Resiliency, Regulatory Compliance, Event Preparedness, Workplace Safety

Emergency Planning for Key Regulatory Agencies

Posted on Mon, Jun 04, 2012

In today’s environment, government regulators have much more scrutiny of  emergency  response planning for industrial facilities. The most widely applicable regulations are those under the realm of the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). Additional agency regulations, such as those mandated by the Department of Transportation’s PHMSA or the Department of Homeland Security may apply to specialized types or locations of facilities, but EPA and OSHA regulations pertain to most industrial sites. By ensuring the EPA and OSHA requirements are met, shared information can be used to comply with additional requirements.

EPA:

  • Facility Response Plan (FRP) -  Requires an owner or operator of a facility that could reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines to prepare and submit a facility response plan.
  • Resource Conservation and Recovery Act (RCRA) - The primary governing law that oversees the generation and containment of solid and hazardous waste.
  • Spill Prevention Control and Countermeasure Plans (SPCC) – Requires developing site specific plans for oil storage facilities that describe spill prevention and response procedures.  .
  • National Pollutant Discharge Elimination System (NPDES) - Permitting program designed to control water pollution by regulating point sources that discharge pollutants into waters of the United States. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters.
  • Emergency Planning and Community Right to Know (EPCRA) - Establishes requirements for federal, state and local governments, Indian tribes, and industry regarding emergency planning and "Community Right-to-Know" reporting on hazardous and toxic chemicals to enable a more effective emergency response planning process.

OSHA:

  • Emergency Action Plan (29 CFR 1910.38(a)) - and Fire Prevention Plans (29 CFR 1910.38) - Requires plans to facilitate and organize employer and employee actions during workplace emergencies. A written plan is required for facilities that have at least ten employees that are present at a facility at any time.
  • Hazard Communication  (29 CFR1910.1200) – Requires communication of information to employees who may be exposed to hazardous chemicals in the workplace.
  • Hazardous Waste Operations and Emergency Response (29 CFR 1910.120) - Requires protecting workers engaged in emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. It applies to all employers who have their employees respond to an emergency situation where a hazardous substance may exist.
  • Process Safety Management (29 CFR 1910.119) - Identifies procedures for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards.

Implementing a regulatory tracking management system can eliminate redundancies across converging compliance specifications. It can be extremely beneficial and time saving for organizations that have multiple applicable regulatory requirements.

For a free guide that details the world of HAZWOPER training, download A Guide to HAZWOPER Training.

HAZWOPER training guide

Tags: OSHA HAZWOPER, OSHA, EPA, Oil Spill, Regulatory Compliance

Material Safety Data Requirements for Emergency Planning

Posted on Thu, Feb 02, 2012

Accurate Material Safety Data Sheets (MSDS) need to be available to employees and  potential  responders. There is the potential that the MSDSs will not be useful to local response groups unless they are familiar with the presented information.  Understanding this information will assist responders in assessing hazards assessment for pre-emergency planning or actual response to an emergency.

According to Department of Labor’s Occupational Safety and Health Administration (OSHA)

  • The Chemical Sampling Information (CSI) file contains listings for approximately 1500 substances
  • The Environmental Protection Agency's (EPA's) Toxic Substance Control Act (TSCA) Chemical Substances Inventory lists information on more than 62,000 chemicals or chemical substances
  • Some chemical libraries maintain files of material safety data sheets (MSDS) for more than 100,000 substances.

The number of chemicals is growing on a daily basis. The Chemical Abstract Service (CAS), a division of the American Chemical Society has registered more than 62 million substances. According CAS’s website, “The CAS registry is a collection of disclosed unique organic and inorganic substances, such as alloys, coordination compounds, minerals, mixtures, polymers, and salts, and more than 62 million sequences.”

The Beginning the Hazard Analysis Process, which was originally published as part of the Hazardous Materials Response Handbook (third edition) states, “a first responder might
reasonably be expected to encounter any of 1.5 million of these chemicals in an emergency, with 33,000 to 63,000 of them considered hazardous. To complicate matters, these hazardous chemicals are known by 183,000 different names. Fortunately, not all of these chemicals are equally common.”

OSHA's Hazard Communication Standard (HCS) specifies required information that must be included on MSDSs. The standard states that “chemical manufacturers and importers shall obtain or develop a material safety data sheet for each hazardous chemical they produce or import. Employers shall have a material safety data sheet in the workplace for each hazardous chemical which they use.”

OSHA requires that each MSDS must contain the following sections, written in English:

  1. Manufacturer's Name and Contact Information, including emergency numbers and addresses.
  2. Hazardous Ingredients/Identity Information, including chemical name, formula, common name, chemical family and associated synonyms. 
  3. Physical/Chemical Characteristics, including detailed chemical properties
  4. Fire and Explosion Hazard Data
  5. Reactivity Data
  6. Health Hazard Data
  7. Precautions for Safe Handling and Use,  including spill and leak procedures
  8. Control Measures, includng special protection information and  precautions

The American National Standards Institute (ANSI) approved an alternative format and published a standard Z400.1-1993, "American National Standard for Hazardous Industrial Chemicals-Material Safety Data Sheets-Preparation."

The following are standards set forth by ANSI. However, OSHA requirements must be included in the MSDS in order to meet compliance requirements.

Section 1. Chemical Product & Company Information
Section. 2. Composition/Information on Ingredients
Section. 3. Hazards Identification
Section. 4. First Aid Measures
Section. 5. Fire Fighting Measures
Section. 6. Accidental Release Measures
Section. 7. Handling and Storage
Section. 8. Exposure Controls/Personal Protection
Section. 9. Physical and Chemical Properties
Section. 10. Stability and Reactivity
Section. 11. Toxicological Information
Section. 12. Ecological Information
Section. 13. Disposal Considerations
Section. 14. Transport Information
Section. 15. Regulatory Information
Section. 16. Other Information

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

TRP Fire Pre Plan Image

Tags: Radiation, OSHA HAZWOPER, OSHA, Emergency Preparedness, Emergency Management Program, Terrorism Threat Management, HAZWOPER, Chemical Industry

Hazardous Materials Response Team Training Requirements

Posted on Mon, Jan 30, 2012

A Hazardous Materials (HAZMAT) Response team is comprised of hazardous material experts who specialize in detecting, containing, and removing any release or potential release of hazardous substances in order to control or stabilize an incident. According to the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), a HAZMAT team “is not a fire brigade, nor is a typical fire brigade termed a HAZMAT team. However, a HAZMAT team is often a separate component of a fire brigade or fire department.”

The acronym  HAZMAT refers to any substance (gas, liquid or solid) capable of creating harm to people, the environment, or property. It is often used when discussing the production, transport, use, disposal, cleanup, or emergency response of hazardous materials.

HAZWOPER is one of the training components of a HAZMAT team. The intent of the HAZWOPER standard is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).

31033.jpg

According to the HAZMAT Team Planning Guide of the EPA’s Office of Superfund Remediation and Technology Innovation, a HAZMAT Team should be trained to the “Hazardous Materials Technician” level defined by NFPA Standard 472 and HAZWOPER 29 CFR 1910.120.

HAZMAT Training Regulations

HAZMAT employees, that may or may not be part of a HAZMAT team, must be trained, at a minimum, in accordance with:

Records need to be maintained for all employees that have been, or will be trained before handling hazardous materials, in accordance with the training requirements set forth in 49 CFR §172.704 and 172.602, and 29 CFR §1910.120 and 1910.1200.

Click the image below for a free Response Procedures Flow Chart:

New Call-to-Action

 

 

Tags: HAZCOM, PHMSA, OSHA HAZWOPER, Training and Exercises, Emergency Management Program, Disaster Recovery, HAZWOPER, OSHA HAZWOPER standard training, Fire Department HAZWOPER training