We have been using OSHA’s HAZWOPER standard since the 1980’s to establish the absolute minimum training for personnel who would discover and/or respond to uncontrolled releases of hazardous materials. This HAZMAT training was intended to be a “Step-Progression” style of training, meaning that you would have the baseline level (e.g. Awareness) and then get the Operations Level content, and then if you wanted you would progress on to the Technician level and so on. If you had no previous training/competencies and you wanted to become a Technician then you would sign up for a 24-hour course which you train you on the skills and competencies of Awareness, Operations, and Technician. And for decades, these levels were UNOFFICIALLY dictated an 8-hour window; hence, Awareness is 8-hrs, Op’s is 8-hrs, and Tech is 8-hrs which equates to 24-hrs of training and so it became known as the 24-hr Technician Course. This is where I call foul! In my line of work, I can take a chemical operator or maintenance technician at a PSM/RMP facility where the use of Level B and C PPE ensembles is a weekly occurrence for vessel entries, line breaks, unloading HAZMATs, etc. and turn those individuals into an emergency responder in 24 hours. This of course is based on their HAZCOM and PPE training for their normal duties was top notch. But I would argue, strongly, that it is impossible to take a worker who has never donned a respirator, much less LEVEL C, B, or A ensemble, and turn them into a responder in 24-hours. Can you find a trainer who will perform a great 24-hour course – absolutely; however, the student who has never had anything more than a HAZCOM training course will be in WAY OVER THEIR HEAD and oftentimes ill-prepared to walk into an IDLH cloud of your HHC/EHS. Heck, these employees probably could not even explain the contents/data of an SDS based on the HAZCOM training that is very common in plants with lesser chemical hazards, so to expect them to become HAZMAT techs in 3-days is really pushing the envelope in an area of safety that we need a high degree of certainty. Here are the competencies that one MUST possess in order to be a HAZMAT technician in the eyes of OSHA (e.g. absolute minimum!):
- An understanding of what hazardous substances are, and the risks associated with them in an incident.
- An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.
- The ability to recognize the presence of hazardous substances in an emergency.
- The ability to identify hazardous substances, if possible.
- An understanding of 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.
- The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.
- Knowledge of the basic hazard and risk assessment techniques.
- Know how to select and use proper personal protective equipment provided to the first responder operational level.
- An understanding of basic hazardous materials terms.
- Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit.
- Know how to implement basic decontamination procedures.
- An understanding of the relevant standard operating procedures and termination procedures.
- Know how to implement the employer’s emergency response plan.
- Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment.
- Be able to function within an assigned role in the Incident Command System.
- Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician.
- Understand hazard and risk assessment techniques.
- Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.
- Understand and implement decontamination procedures.
- Understand termination procedures.
- Understand basic chemical and toxicological terminology and behavior.
Folks, let’s be honest – working in a “controlled IDLH environment” and complying with 1910.134(g)(3) is one thing. Sending personnel into an UNKNOWN and UNCONTROLLED atmosphere is an ENTIRELY DIFFERENT situation that requires magnitude more levels of safety and consideration and TRAINING. The emergency response aspect of your safety program is NOT the area we need to be looking for the cheapest and fastest training solutions.