29 CFR 1910 120q Bureau of Workers Compensation

29 CFR 1910. 120(q) Bureau of Workers’ Compensation PA Training for Health & Safety (PATHS) Hazardous Waste Operations and Emergency Response PPT-097 -01 1

29 CFR 1910. 120(q) This paragraph (q) covers employers whose employees are engaged in emergency response, no matter where it occurs (Fire, Police, EMS personnel and private HM Teams) PPT-097 -01 2

Applicability It also covers employees engaged in § Clean-up operations § Corrective actions § Voluntary clean-up operations at sites § Operations involving hazardous wastes that are conducted at treatment, storage and disposal (TSD) facilities unless the employer can demonstrate the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards. PPT-097 -01 3

Abbreviations Used HM-Hazardous Materials Haz. Mat-Hazardous Materials IC-Incident Commander ICS-Incident Command System Decon-Decontamination ERP-Emergency Response Plan PPT-097 -01 4

Emergency Response Plan § Shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. § In writing and available for inspection and copying by employees, their representatives and OSHA personnel. PPT-097 -01 5

ERP Elements § Pre-emergency planning and coordination with outside parties § Personnel roles, lines of authority and communication § Emergency recognition and prevention § Safe distances and places of refuge § Site security and control PPT-097 -01 6

ERP Elements § Evacuation routes and procedures § Decontamination procedures not covered by site safety and health plan § Emergency medical treatment and first aid § Emergency alerting and response procedures § PPE and emergency equipment § Critique of response and follow-up PPT-097 -01 7

ERP Elements Also include in the Plan: § Site topography, layout and prevailing weather conditions, as well as, § Procedures for reporting incidents to local, state and federal governmental agencies. Emergency Response organizations may use the local or state ERP, or both, as part of their ERP to avoid duplication. PPT-097 -01 8

Handling Emergencies PPT-097 -01 9

Handling Emergencies Senior ER official responding to an emergency shall become the individual in charge of a sitespecific Incident Command System (ICS). Usually designated as Incident Commander (IC). This person § Coordinates and controls all emergency responders and their communications § Passes authority up the line to more senior officials who arrive. PPT-097 -01 10

Incident Commander Duties § Identifies hazardous substances present § Performs site analysis § Implements engineering controls § Address Maximum Exposure Limits § Handles procedures and new technologies § Implements emergency operations § Assures proper PPE is worn § Limits number of entrants to hazard zones PPT-097 -01 11

Incident Commander Duties § § Ensures a “Buddy System” is used Provides first aid support as minimum Designates a Safety Officer Implements decon after operation. PPT-097 -01 12

Safety Officer Duties When activities are judged by the safety officer to be an IDLH condition and/or to involve imminent danger condition, • Shall have authority to alter, suspend, or terminate those activities. • Safety official will immediately inform IC of any actions needed to correct hazards at an emergency scene. PPT-097 -01 13

Skilled Support Personnel, not necessarily an employer's own employees, who are skilled in the operation of certain equipment: § Mechanized earth moving or digging equipment, or § Crane and hoisting equipment, and § Are needed temporarily to perform immediate emergency support work PPT-097 -01 14

Specialist Employee In the course of their regular duties, work with and are trained in the hazards of specific hazardous substances. § Technical advice or § Assistance at a hazardous substance release incident to person in charge PPT-097 -01 15

Awareness Level Duties First Responder Awareness Level (Level 1) • Witness or discover a hazardous substance release • Initiate an emergency response by notifying the proper authorities • Take no further action beyond notifying authorities of the release • Sufficient training or experience to objectively demonstrate competency in the following areas: PPT-097 -01 16

Awareness Level Duties § Understand what hazardous materials are, and risks associated. § Understand potential outcomes when hazardous materials are present. § Able to recognize the presence of hazardous materials in an emergency. § Able to identify the hazardous materials, if possible. PPT-097 -01 17

Awareness Level Duties § Understand role of the first responder awareness individual in the employer's ERP including site security and control and Emergency Response Guidebook. § Able to realize the need for additional resources, and make appropriate notifications to the communication center. *Able to initiate scene management (i. e. implement the ICS, isolate the immediate site, deny entry to unauthorized persons, and evacuate). PPT-097 -01 18

Operations Level Duties q Operations Level 2, Defensive Response q Respond to actual or potential releases to protect persons, property or environment Basic hazard and risk assessment techniques Select and use proper PPE Understand basic hazardous materials terms. Perform basic control, containment and/or confinement § Implement basic decon § § PPT-097 -01 19

Operations Level Duties § Understand relevant SOPs and termination procedures * Perform basic record keeping * Expand the ICS PPT-097 -01 20

Haz. Mat Technician (Level 3) Duties q Respond to stop the release; more aggressive response q Plug, patch or otherwise stop the release. § Implement ERP § Classify, identify and verify known or unknown materials using survey instruments § Function within ICS § How to select proper specialized chemical PPE • Able to select and use Level B PPE plus others. PPT-097 -01 21

Haz. Mat Technician (Level 3) Duties § Understand hazard and risk assessment § Advanced control, containment and/or confinement § Implement decon § Understand termination procedures § Understand basic chemical, toxicological terms and behavior (*biological and radiological) * Complete record keeping procedures. PPT-097 -01 22

Haz. Mat Specialist (Level 4) Duties q Respond with and provide support to the HM Technicians. q Specialized knowledge required q Act as liaison with various governmental agencies. § Implement local ERP § Classify, identify, verify known and unknown materials using instruments § Know state ERP § Select and use specialized PPE PPT-097 -01 23

Haz. Mat Specialist (Level 4) Duties § Select and use Level A PPE and other specialized PPE § In-depth hazard and risk techniques § Specialized control, containment and/or confinement § Implement decon § Develop site safety and control plan § Understand chemical, radiological, toxicological terms and behavior (*and biological) § Function in assigned role in ICS § Implement record keeping and perform termination procedures. PPT-097 -01 24

“Off-Site Specialist Employee” q This SPECIALIST is one who, in the course of regular duties, is trained in or works with specific materials or containers. They may be called upon to furnish technical assistance relative to the material. Level A Specialist Level B Specialist Level C Specialist Facility designations-not formal hazmat team designation. PPT-097 -01 25

Level A Specialist Duties § Handle facility related incidents of chemicals and containers. § Analyze chemical incidents within the framework of the agency’s SOP’s and Emergency Response Plan § Implement the planned response, and § Evaluate the response. PPT-097 -01 26

Level B Specialist Duties • May work in the Hot Zone • Work with or trained concerning chemical hazards and containers • Due to education, training, or work experience, may be called upon to respond to a chemical incident. • May gather and record information, • Provide Technical advice and assistance in accord with their agency’s SOP’s, ERP or Local Emergency Operations Plan. PPT-097 -01 27

Level C Specialist Duties § Not expected to enter incident Hot or Warm Zone § May respond to incidents involving chemicals and containers within their agency’s area of specialization. § May gather and record information § Provide technical advice and arrange for technical assistance per their agency’s ERP and SOPs. PPT-097 -01 28

Incident Commander (Level 5) q Assume control of incident scene beyond first responder awareness level. • Able to implement employer's ICS • Implement the employer's ERP • Understand hazards and risks associated with employees working in chemical protective clothing. • Implement local ERP • Know state emergency response plan and of the Federal Regional Response Team • Understand decon procedures. PPT-097 -01 29

Incident Commander (Level 5) • Direct and coordinate all incident aspects • Operates within integrated emergency management Plan • Operates under clear procedures for notification and utilization of nonlocal resources • Directs resources • Provide management overview, technical review and logistical support to private and government personnel • Focal point for information transfer to media and local elected officials. PPT-097 -01 30

Incident Commander (Level 5) *Provides documentation of the hazardous materials incident. *Advises on the reporting requirements of federal, state and local agencies. *Conducts critique of the incident. PPT-097 -01 31

Medical Surveillance Members of an organized and designated HAZMAT Team and HM specialists: § Shall receive a baseline physical examination, and § Be provided with medical surveillance as required in paragraph (f) of this section. PPT-097 -01 32

Chemical Protective Clothing CPC and equipment to be used by organized and designated HAZMAT Teams members or by hazardous materials specialists, shall meet requirements of paragraphs (g)(3) through (5) of this section. • PPE Selection • Totally Encapsulating Chemical Protective Suits and • PPE Program PPT-097 -01 33

Post-Emergency Operations Upon completion of emergency response, if necessary to remove hazardous substances, health hazards, and materials contaminated with them (i. e. contaminated soil or other elements of the natural environment) from the incident site, the employer conducting the clean-up shall comply with (1) of the following: Ø Meet all requirements of paragraphs (b) through (o) of this section; or PPT-097 -01 34

Post-Emergency Operations Ø Where the clean-up is done on plant property using plant or workplace employees, such employees shall have completed training of: § § 29 CFR 1910. 38(a); 1910. 134; 1910. 1200, and Other training made necessary by tasks they are expected to be such as; -PPE -Decontamination procedures PPT-097 -01 35

Training for all Categories Based on duties and function to be performed Skill and knowledge levels required for all new responders, Those hired after the effective date of this standard (March 6, 1990), shall be conveyed to them through training before they are permitted to take part in actual emergency operations. Employees who participate, or are expected to participate, in emergency response, shall be given training in accordance to the regulation. PPT-097 -01 36

Training: Awareness First Responder Awareness Level (Level 1) Witnesses or discovers a hazardous materials release; is trained to notify proper authorities. § Sufficient Training § Proven experience in specific competencies § Annual refresher PPT-097 -01 37

Training: Operations First Responder Operations Level (Level 2) Responds to release in defensive manner without trying to stop release. § Level 1 competency § 8 hours initial or proven experience in specific competencies § Annual refresher PPT-097 -01 38

Training: Technician Haz. Mat Technician (Level 3) Responds aggressively to stop release of hazardous substance. § 24 hours of level 2 § Proven experience in specific competencies § Annual refresher PPT-097 -01 39

Training: Specialist Haz. Mat Specialist (Level 4) Responds with and in support of Haz. Mat Technicians but have specific knowledge of various hazardous substances. § 24 hours of Level 3 § Proven experience in specific competencies § Annual refresher PPT-097 -01 40

Training: Incident Commander (Level 5) Assumes control of the incident scene beyond first responder awareness level (*see note) § 24 hours equal to level 2 § Additional competencies § Annual refresher *As of January 1, 2001, the Joint Commission requires an Incident Command System be staffed for internal and external emergencies. ) PPT-097 -01 41

Training: Specialist A, B, C Specialist Employee Shall receive training or demonstrate competence in the area of their specialization annually. PPT-097 -01 42

Legal Considerations § A comment was made years ago that if you didn’t call your team a hazmat team, you didn’t have to comply with the requirements of 29 CR 1910. 120(q). § Court found that the name didn’t matter; the actions engaged in determined if you were functioning the same as a “hazmat team. ” § If you were operating in a similar fashion, your group was a “hazmat team. ” PPT-097 -01 43

Economic Considerations For creating and training an in-house spill team or hazmat team should look at the following costs: Medical surveillance for members Equipment required Spill control equipment Training of each team member; initial and annual refresher § Potential liability if you attempt to be selfreliant when materials and processes are beyond your control § § PPT-097 -01 44

Practical Considerations For creating and training an in-house spill or hazmat team. § Are off-site response agencies adequately trained to handle your possible hazmat incidents? § Will they respond in a timely manner? § Will your in-house team reduce injury and damage more quickly then waiting for off-site? § Will off-site responders be familiar with your processes and chemicals when they arrive? PPT-097 -01 45

Bibliography NFPA 471, “Recommended Practice for Responding to Hazardous Material Incidents, ” National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169 -7471. NFPA 472, “Standard for Professional Competence of Responders to Hazardous Material Incidents, ” National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169 -7471. PPT-097 -01 46

Bibliography Code of Federal Regulations, 29 CFR 1910. 120(q) Hazardous Waste Operations and Emergency Response, (HAZWOPER), March 6, 1990. PPT-097 -01 47

Contact Information Health & Safety Training Specialists 1171 South Cameron Street, Room 324 Harrisburg, PA 17104 -2501 (717) 772 -1635 RA-LI-BWC-PATHS@pa. gov Like us on Facebook! https: //www. facebook. com/BWCPATHS PPT-097 -01 48

Other Power Points of Interest You may also wish to view our other Power Points to create your own in-house training program for this topic: § Basic Air Monitoring § PPE § Compressed Gas § Flammable and Combustible Liquids § Hazard Communication + GHS § Hazardous Materials Awareness Find them on our website at www. dli. state. pa. us/PATHS then click Training Resources in the left column. If not on our web, request our list of programs at RA-LI-BWCPATHS@pa. gov PPT-097 -01 49