This is one of the top emergency response questions we receive each year. It seems there are some facilities that feel the Incident Command training their personnel receive in their 16-hr Operations Level and 24-hr Technician Level training qualifies those personnel to be an Incident Commander. The question is… is the training offered in these courses adequate to training a person to serve as an Incident Commander? The answer…
NOT LIKELY! OSHA states the following regarding IC training in 1910.120(q)(6)(v)…
Incident commanders, who will assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify:
1910.120(q)(6)(v)(A) Know and be able to implement the employer’s incident command system.
1910.120(q)(6)(v)(B) Know how to implement the employer’s emergency response plan.
1910.120(q)(6)(v)(C) Know and understand the hazards and risks associated with employees working in chemical protective clothing.
1910.120(q)(6)(v)(D) Know how to implement the local emergency response plan.
1910.120(q)(6)(v)(E) Know of the state emergency response plan and of the Federal Regional Response Team.
1910.120(q)(6)(v)(F) Know and understand the importance of decontamination procedures.
Let’s break down these requirements and see what may be missing if our ICs are only receiving training during their OPs and Tech level training courses.
1910.120(q)(6)(v)(A) Know and be able to implement the employer’s incident command system.
This implies each facility should have a site SPECIFIC command structure and pre-identify those personnel who are “trained and qualified” to fulfill the role of the IC. Notice the language used, “know and be able to implement”. This means that the person who will fill the role of IC must have the ABILITY to implement the necessary actions to SAFELY manage the incident. This INCLUDES SHUTTING DOWN processes and EVACUATING the facility when necessary. What we find more often than not, is that the personnel assigned to fill this role have the technical capability to make the right decisions; however, they are hampered by management from making these decisions WITHOUT FIRST CHECKING with them. This is NOT how the IC system is supposed to work!
1910.120(q)(6)(v)(B) Know how to implement the employer’s emergency response plan.
Often times the training received in the Operations Level and Technician Level courses are NOT site-specific and may ONLY briefly mention the EAP and ERP. But the IC is intended to the “master” of these plans and know them from cover to cover in great detail. If we look back at 1910.120(q)(2) we see the eleven elements of the required Emergency Response Plan (ERP) and I have written extensively about the details that are needed for these eleven sections of the plan. It is also OSHA’s intent that this plan contains these details so that someone who may not be as involved in safety and emergency response will still have the plan to safely execute the IC management system. For example: Does your plan make it explicitly clear that if the entry team is donned in Level A that the first line of Decon personnel must be in Level B? Does the plan have decon procedures for each of the facility’s hazardous materials?
1910.120(q)(6)(v)(C) Know and understand the hazards and risks associated with employees working in chemical protective clothing.
This should be covered in painstaking detail in both the Operations Level and Technician Level courses. This is why I personally feel that an IC should have been a Technician at some point in their response career; however, this is MY PERSONAL opinion and not a requirement by OSHA. But anyone who is trained as a Technician and has severed in this capacity will certainly meet this requirement.
1910.120(q)(6)(v)(D) Know how to implement the local emergency response plan.
This requirement is a bit tricky and I have to admit that even my IC course may fall short on this requirement. Luckily, most of my clients are located in rural locations and they are the full response, meaning there is little that can be done by off-site responders. I advise them to meet regularly with the FD and PD chiefs and county EMA directors and LEPCs to advise these groups and ER leaders of their plans, training, and response capabilities. ALWAYS remember there may come that day when your facility will need to either activate an off-site evacuation or shelter in place (SIP). It is these moments that the facility MUST understand the local ERP to ensure this plan is followed for any off-site activities. And if your facility falls under EPA’s RMP you can bet your _____ that EPA expects that your facility is FULLY integrated into the community’s ERP. This requirement also comes into play for those facilities that have no on-site response capabilities and will rely 100% on off-site responders to manage their chemical/fire/EMS emergencies. Even in these situations, someone at the facility will need to UNDERSTAND the local ER plan so as to be prepared when the off-site responders arrive at the facility and seek out “someone in charge”.
1910.120(q)(6)(v)(E) Know of the state emergency response plan and of the Federal Regional Response Team.
Notice the wording of this requirement… “know of the state ERP and of the federal regional response team”. To “know of” something is much less than “know how to implement” something. If you wish to learn more about the Regional Response Teams you can CLICK HERE.
1910.120(q)(6)(v)(F) Know and understand the importance of decontamination procedures.
Again we see the wording “know and understand” implying intimate knowledge of the decon procedures for the chemicals the team may be responding to. Again I point us back to the ERP in which OHA requires DECON procedures. As to the level detail these procedures need to be at will depend on the types of chemicals involved, but the plan must contain decon procedures. It is my opinion that these procedures need to cover staffing needs, PPE needs, decon media, and disposal of the contaminants and PPE. Keep in mind that on the larger responses we may be deconning people, PPE, and equipment (from bulldozers to SCBAs and radios).
I advise my clients to seek out a reputable training organization and to send their people to these training courses ON TOP of what they receive in their OPs and Technician level courses. As I have said before, ICs should be those people who have spent time in Level A suits. They don’t need to be chemist, but they need to have a very good understanding of the behaviors of and the hazards of the materials they are dealing with. IC training is MUCH DIFFERENT than that for responders; it needs to teach students how to think “in advance”, be fast thinkers, rely on technical personnel to implement the incident response plan, and how to be strong leaders (IC is NOT leadership by committee, so you may NOT be as popular as you’d hoped after “saving the day”!). Remember, as the IC you are ultimately responsible for ALL ASPECTS of the response, and our #1 responsibility is RESPONDER & COMMUNITY SAFETY.