WARNING! If you have an ER instructor who claims you can enter the Hot or Warm zone the first time in using LEVEL C PPE, you need to fire them!
I have been conducting HAZMAT training for 28 years, and every year, I pick up a few new ER clients who need a refresher course. And every year, those who attend one of my 8-hr refresher courses are surprised to hear me say…
The minimum level of PPE for the first time into the HOT or WARM zones MUST BE AT LEAST LEVEL B. As we know, the driving piece of PPE for B is an SCBA (positive pressure mode).
SO the debate begins… “Is this a Haywood thing,” or “is this required by OSHA or EPA”? When I explain it’s an OSHA “thing”, they always ask “show us” because we don’t have SCBAs (!!!!).
1910.120(q)(3)(iv) Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard shall wear positive pressure self-contained breathing apparatus while engaged in emergency response, until such time that the individual in charge of the ICS determines through the use of air monitoring that a decreased level of respiratory protection will not result in hazardous exposures to employees.
Now for the question of the week:
What four (4) pieces of information, of which you most likely know none upon arrival, or you may know one (1) piece of this info if you’re part of an industrial ERT responding to an event at your facility, MUST we know before we can use LEVEL C in a Hot or Warm Zone for response activities? I’ll give the first piece:
Hint: MUC and the Inherent Limitations of an APR
1) Chemical(s)
2) The Concentration of said chemical(s)
3) Those concentrations are BELOW the chemical(s) IDLH
4) There is at least 19.6% O2 (Note: 19.5% O2 is OSHA’s IDLH for Oxygen Deficiency-I use 20.8% for uncontrolled release environments!)