I still do about a dozen 24 or 40-hr HAZMAT Tech courses and dozens of 8-hr Refreshers each year. And in each class, it never fails that someone will ask the question…
Does OSHA/EPA actually require that?
Backstory: I’ve been on the ERT for 20 years, and this is the first time I’ve heard this. In other words, “are you full of S__t Mr. Instructor?”
Here is an inside look at the EPA’s expectations for ERT training and responses from a recent consent decree.
EMERGENCY RESPONSE TRAINING ─ CONSENT DECREE COMPLIANCE REQUIREMENTS
No later than twelve (12) months after the Effective Date, CUSA will complete emergency response training (“ER Training”) at each of the Covered Refineries, which will consist of two training modules, as follows:
a. Leak-Response Training.
This ER Training module will be based on XXXXX Manufacturing Leak Response Protocol Instruction (MFG 205) and include guidance on the type of information necessary to (1) evaluate leaks, including the physical and chemical characteristics of the leaking material, and (2) determine actions to be taken in response to the evaluation, including whether to shut down, modify or continue operation. This ER Training module will be provided to XXXXXXX Incident Commanders, XXXXX First Responders, XXXXX operations supervisors, and XXXXX operators at each of the Covered Refineries.
b. Hazardous Materials Incident Command Training.
This ER Training module will include guidance for setting up incident-command structures and establishing boundary limits and exclusion zones. This ER Training module will be provided to CUSA Incident Commanders and CUSA First Responders at each of the Covered Refineries by Texas A&M University or a National Fire Protection Association-accredited provider.
No later than ninety (90) Days after the Effective Date, XXXXX will add leak-response training referenced above in Paragraph 48.a to the training otherwise required for XXXXX Incident Commanders, XXXXX First Responders, CUSA operations supervisors and CUSA operators at each Covered Refinery.
No later than ninety (90) Days after the Effective Date, CUSA will add hazardous materials incident command training referenced above in Paragraph 48.b to the training otherwise required for XXXXX Incident Commanders and XXXXX First Responders at each Covered Refinery.
For each Covered Refinery, in accordance with the reporting requirements contained in Section XV, XXXXXX will submit to EPA no later than twelve (12) months after the Effective Date:
a. A copy of the written training materials for each module of the ER Training Program;
b. The date(s) each ER Training module was provided; and
c. The titles and employment locations of CUSA personnel who attended each module of the ER Training.