Next to preventing accidents, my second love is an efficiently and safe run HAZMAT incident! Although I am no longer allowed to wear LEVEL A’s anymore (Boss thinks I do not need to engage in this level risk!!!) I still do a lot of responses each year as a HAZMAT Specialist and man do I see some crazy things around the world. But one common thing that I see often is LACK OF PROPER TRAINING for responders.
I have discussed the use of off-site training and on-line training resources in previous posts as they relate to things like LOTO training and PSM training and I will be the first to admit that both of these types of training have their place in a facility’s EHS training program, but WE MUST UNDERSTAND the pro’s and con’s of such training. TOO OFTEN facilities think that a 20-minute on line course meets all the training requirements and they are done with their training obligations. In this article I want to point out some potential flaws when sending your emergency responders to an off-site training course to meet your emergency response team’s training needs. Let me be up front in saying that there are dozens of reputable training courses at “off-site training facilities” that I often recommend to clients. But even the very best “off-site” training facility has limitations in MEET YOUR Team’s SPECIFIC NEEDS!
First let me state that we do very few 16-hour and 24-hour hour HAZMAT courses anymore. Not to say we do not do HAZMAT training, as we do dozens of courses each year, training hundreds of responders, both in private industry and public municipalities, but we try very hard to get the client to do a 40-hour course rather than the OSHA minimum of 24 hours. Our 40-hour course is the EXACT SAME COURSE as the 24-hour course, but the extra two days ALLOW us to do MUCH MORE HANDS ON TRAINING on critical items like respirators, LEVEL A and LEVEL B ensembles, monitoring equipment etc. It also allows for the students to spend MUCH MORE time in this type of PPE so they can become more familiar with it and more time getting use to it. I put my money where my mouth is and the price for our 40-hr course is only $1K more than the 24-hr course, that means I make less than $500/day for the extra two days of training! If SCBA’s are NEW to your facility or to your new HAZMAT team members, this new piece of PPE is a MAJOR change for the members and it is my opinion that there is just not enough time in 24-hours to properly train the member in all the OSHA required HAZWOPER topics and how to properly DON and DOFF the SCBA, it’s limitations, how to inspect, how to store, how to change cylinders, etc.! And this is just the classroom portion and does not include the HANDS-ON part of the training. A new member needs “time” wearing the SCBA so they can get used to it; then throw in all the other specialized PPE they have to be trained in and have time for hands-on training and the 24-hours is quickly getting eaten up. But I digress…
So you want to send some new HAZMAT members to an off-site training course. These courses usually have the exact same curriculum as anyone you would hire to do training on your plant site, but there is ONE HUGE DIFFERENCE…the style and brands of the equipment the off-site training company uses in their training. (NOTE: if you hire an off-site company to come in and do the training on your plant site, but use the training companies equipment instead of your own, you are in the same boat!). Just this week I was helping a regional client with an emergency response critique, investigation and the following OSHA inspection. This is a smaller facility, but they do fall under PSM. They do NOT have a full-time EHS professional on-site so they use the local community college for their HAZMAT training for NEW members and I provide their annual 8-hr refreshers. The facility recently went through some turn-over because a new employer arrived in town and began hiring away some of their employees; so the business sent their new employees to the local CC for their HAZMAT Tech 24-hour training. These new employees had never been trained in any type of respirators, much less in SCBA’s and Level A suits. They received their certificates and became FULL HAZMAT TEAM members ready to respond to any releases in just three days. The problem is they were trained with MSA brand SCBA’s and Rear-Entry Level A’s and the facility uses SCOTT brand SCBA and Front-entry Level A suits. These two brands of SCBA’s are DISTICNTLY DIFFERENT with completely different regualtor locations, low level alarms, bottle assembly with the pack, etc. They also received training on air monitoring equipment that their employer does not have or use, as well as all the decon equipment was completely different. The ONLY time they will receive hands on training on their actual equipment will be during the 8-hr refresher the following year. Not knowing any better, this practice finally caught up to them when they had a release and the team members did as they were TRAINED, they went to dress out and MADE SOME SERIOUS MISTAKES and it took them WAY TOO LONG to get in and stop the leak. NO ONE on the team (during this response the team was 100% made up of new employees with less than 6 months of employment) had ever even seen their SCBA’s until that day and they had to collectively put their heads together and figure out how the SCOTT brand regulator fit into the face peice, what the DEMAND button on the regualtor did, and the BIG SUPRISE came when the low level air alarm went off…a vibrating face piece can be quite scary when you are not expecting it and you are in a cloud of NH3!!!!! One other major limitation that I had not thought of until this incident was the AIR CAPACITY of the SCBA. The off-site training facility was using 45000 psi bottle and the facility was using 2216 psi bottles. In their off-site training the members had plenty of air to do their drill; but in real life they quickly found out the hard way that setting up HOT, WARM, COLD zones is critical as they were TOO CONSERVATIVE and established a HOT ZONE that was WAY TOO BIG and thus they had serious problems with breathing air limitations. NEVER FORGET…if it takes you five minutes to walk in, it will take you ATLEAST five minutes to walk out; if your bottle is a 2216 psi bottle this does not allow for much time in the HOT ZONE – something they learned the hard way!
There is a very good likelihood that the State OSHA may cite the facility for improper training; EVEN THOUGH all the members had a certificate from a very recognized training facility in the community. But when OSHA interviews responders and finds out they were unsure of their SCBA’s as they had never been trained in those styles it is a MAJOR RED FLAG. My bet is that the facility will be cited under 1910.134 for all the respirator issues and not 1910.120. And yes, the CC also provide the fit testing for the new members as part of the 24-hr course (more time spent on something other than HANDS-ON training during the 24 hours!) and yes the fit testing was done with MSA equipment and not SCOTT facepieces, so I know OSHA will be citing this under 1910.134 for not having fit test done with the make, model, style and size of mask the employee will be using.
So these are just a few examples that we have to CONSIDER when using an off-site training resource, REGARDLESS of who good the training facility is. PPE plays a CRITICAL ROLE for our responders and if they are not receiving HANDS-ON TRAINING with their ACTUAL PPE this is a potentially serious gap in their training. This is not the fault of the off-site training facility, but our RESPONSIBILITY to ensure our responders receive training with their actual PPE. In the past when I was a S&H Manager at a chemical facility, I would work it out ahead of time with the off-site facility so they would be ready for my team members who would show up with our SCBA’s, our LEVEL A suits, our boots, our _______, etc. I wanted to make sure the off-site trainer was experienced in training with our makes, models, styles of PPE before throwing them to the sharks with my team arriving with PPE they had NO FAMILIARITY with. So as you can see, there are some flaws in PPE training when using off-site training facilities. But is this the only flaw? Nope!
How about training on your facility’s Emergency Response Plan (ERP)? Employees get their annual Emergency Action Plan (EAP) training as an ordinary employee at the facility. But when it comes to training on the ERP, when will the HAZMAT Team members get their training on this site specific plan? The off-site training facility may have 20 students from 10 different organizations in the course and this makes it impossible for them to cover all 10 different and specific ERP’s in the 24-hour course. So they normally cover 1910.120(q) requirements in a general format so that students learn what OSHA requires in an ERP and how the plan is to be used in each response. But again, your team members are NOT receiving the plan specific training they need to implement your response plan as REQUIRED by OSHA. And this leads me to my last concern…Incident Command. At off-site training, members will receive some very generalized IC training and not the training on how and who plays a role in your facility’s IC structure. We often discover in audits that the actual responders have no idea who can fill the roll of an Incident Commander, even though the ERP list the IC’s.
OSHA quickly caught onto the PPE Training limitations in their inspection of the release. After spending two days with them, I walked away with the feeling that the facility may very well receive more citations and higher amounts per citation regarding the emergency response rather than the issues that lead up to the release. The facility does a much better job on PSM than most facilities, but the practice of send their team members off-site for their HAZMAT training may come back to haunt them. I hope this article helps you understand the PRO’s and CON’s of using off-site training facilities for your HAZMAT Team members. We can not just simply send them off for three days, collect their certificates when they return, file them away and think all is done. The off-site facility can ONLY DO SO MUCH for us, we have to do the rest.
DISCLAIMER: I am NOT bashing any training facility, trainers, or the concept of using consultants and off-site training facilities. I have used off-site ERT resources for 20 years, but over this time I have learned the hardway that we can not just wipe our hands clean after sending our responders to off-site training. The off-site facility HAS TO TRAIN in generalizations as their audience is just too diverse to cover specifics. If the off-site facility has the capabilities, as many of them do, to use the brands, styles and types of response equipment that your facility has, then you would be in MUCH BETTER shape. BUT IT IS UP TO the business to identify limitations/gaps and ensure they CLOSE these gaps BEFORE sending their employee(s) into potentially life threatening situations.