How do all the different levels of HAZWOPER training fit together and what level do I need to respond?

Paragraph (q) of HAZWOPER lists seven emergency responder categories, which include the following five principal training levels under (q)(6): first responder awareness level, first responder operations level, HAZMAT technician, HAZMAT specialist, and on-scene incident commander. The remaining two categories include skilled support personnel (q)(4) and specialist employees (q)(5). Employees responding to emergencies at different levels in the command structure are required by OSHA to have specific training that is intended to ensure that emergency responders are properly trained and equipped to perform their assigned tasks.  In this article I will explain the different levels and when they would be required:

Awareness Level
Individuals who are likely to witness or discover a hazardous substance release and are to initiate an emergency response sequence by notifying the proper authorities of the release must be trained to the first responder awareness level. They are to take  NO further action beyond notifying the authorities of the release.  Generally, law enforcement and facility security personnel should be trained to the awareness level since they are likely to witness or discover a release of a hazardous substance.  Security guards or other similar personnel who, upon discovery of a release requiring an emergency response, are limited to activation of an alarm, notification of appropriate authorities, and controlling access to the release from a remote area (safe distance) must also at a minimum receive first responder awareness level training. These employees can initiate an emergency response sequence by notifying the authorities of the release, including alarm activation. Employees trained to the awareness level may control entry to and exit from the site from a remote location but must NOT assist in setting up safe distances because they lack knowledge regarding the potential for exposure, explosions, or radiation.  The operators of vehicles involved in an emergency response would need to be trained at least to the first responder awareness level to recognize an emergency situation, understand their role in an emergency response, and call pre-designated authorities for the containment and control of the release.

The standard does not set a minimum number of hours for this training, but such courses often run from 4 to 12 hours. Regardless of the duration of the training, employees must have sufficient training or have had sufficient experience to objectively demonstrate competency in the six areas of knowledge listed in the standard (see 1910.120(q)(6)(i)(A)-(F)).

• 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 the 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.

Operations Level
Employees who respond to releases as part of the initial response for the purpose of protecting nearby persons, property, or the environment by responding in a DEFENSIVE fashion must be trained to the first responder operations level. Their DEFENSIVE actions must be performed from a SAFE distance and may include activities such as placing absorbents or constructing dikes.  Firefighters expected to respond to releases of hazardous substances must be trained to at least the operations level since they will respond to releases, or potential releases, of hazardous substances for the purpose of protecting nearby persons, property, or the environment.  Personnel expected to set up boundaries designating safe and unsafe areas must be trained to the first responder operations level. An employee trained to the first responder awareness level may not set up safe distances because they lack knowledge regarding the potential for exposure, explosion, or radiation. Once these areas have been established, first responder operations level personnel must control entry and exit from the area of the release. (Note: Awareness level trained personnel may assist in preventing unauthorized entry into the area of the release providing all of their activities are done at a safe remote location.)

SPECIAL NOTE regarding Firefighters responding to propane and gasoline fires:
Firefighters trained to the operations level, who are also trained in the hazards of propane, may enter the danger area to shut off the valves that will starve the fire and thus extinguish it. Normally, employees trained to the operations level would be restricted from taking aggressive action. This is considered to be a special case. The principal hazards from propane are fire and explosion, not toxicity. Because propane fires are common, most firefighters are fully trained and equipped to respond to propane fires, including taking aggressive action by shutting off the valves in the danger area.  If firefighters are fully trained and equipped (which is a high degree of training), and have also received operations level training, OSHA believes they have sufficient training to take aggressive action due to propane’s relatively low toxicity. Releases of gasoline similar to the example involving propane discussed above may be addressed by operations level emergency responders if they have the required PPE, emergency response equipment, and specific training in the safety and health hazards associated with gasoline.  Employers who expect firefighters to shut off a gasoline valve in the danger area, and who can show that employees are trained to the operations level and adequately trained in the hazards of gasoline, have committed a technical violation of 1910.120(q)(6)(iii) for such employees not having the training required of a HAZMAT technician.  (Note: The fire and explosion hazards of propane and gasoline are very substantial. The interpretations herein are applicable only when firefighters are fully trained and equipped to handle the explosion and fire hazards of propane, gasoline, or similar flammable gases and liquids.)

First responders at the operations level MUST receive AT LEAST eight (8) hours of training, OR have had sufficient experience to objectively demonstrate competency in the six areas of knowledge listed in the standard (see 1910.120(q)(6)(ii)(A)-(F)) in ADDITION TO those listed for the awareness level).

• 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 the 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.

Therefore, depending on an employee’s competencies, more than eight hours may be required.

Technician Level

Employees who respond to releases in an OFFENSIVE (e.g. agressive) fashion for the purpose of STOPPING the release MUST be trained to the technician level. These individuals APPROACH THE POINT OF RELEASE to plug, patch, or otherwise stop the hazardous substance release.

SPECIAL NOTE regarding chemical plant operators:
Employees such as chemical process operators may be required to shut down processes, close emergency valves and otherwise secure operations that are not in the danger area before evacuating in the event of an emergency (see 1910.38(c)(3)). These procedures need to be delineated in the Emergency Response Plan (ERP), and employees MUST be trained to be able to perform these pre-evacuation procedures safely. Employees who perform these operations are NOT considered “emergency responders.” However, if they are expected to perform duties in the danger area beyond what they are trained to do and comparable to those of a HAZMAT technician or the defensive role of the first responder at the operations level, then they would be expected to be trained as emergency responders in accordance with 1910.120(q).  Process operators who have (1) informed the incident command structure of an emergency (defined in the facility’s ERP); (2) adequate PPE; (3) adequate training in the procedures they are to perform; and (4) employed the buddy system, may take limited action in the danger area (e.g., turning a valve) before the emergency response team arrives. The limited action taken by process operators must be addressed in the ERP.  Once the emergency response team arrives, these employees would be restricted to the actions that their training level allows. This limited action ASSUMES that the emergency response team is on its way and that the action taken is necessary to prevent the incident from increasing in severity (i.e., to prevent a catastrophe).  Employers must inform such employees during their training that they are to evacuate when they lack the capabilities to respond in a safe manner and in accordance with the standard operating procedures defined in the ERP.

First responders at the technician level MUST receive at least 24 hours of training equal to the operations level, and IN ADDITION have competency in the nine areas of knowledge listed in the standard (see 1910.120(q)(6)(iii)(A)-(I)).

• 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 the 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.

Therefore, depending on an employee’s competencies, more than 24 hours of training may be required.

Hazardous Materials Specialist

Employees who respond to releases to provide SUPPORT to HAZMAT technicians in the form of specialized knowledge of substances involved in the release are HAZMAT specialists. The duties of these individuals parallel those of the HAZMAT technician.

First responders at the specialist level MUST receive at least 24 hours of training equal to the technician level, and in addition have competency in the nine areas of knowledge listed in the standard (see 1910.120(q)(6)(iv)(A)-(I)).

• 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 the 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.
• Know how to implement the local emergency response plan.
• Understand classification, identification and verification of known and unknown materials by using advanced survey instruments and equipment.
• Know the state emergency response plan.
• Be able to select and use proper specialized chemical personal protective equipment provided to the hazardous materials specialist.
• Understand in-depth hazard and risk techniques.
• Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available.
• Be able to determine and implement decontamination procedures.
• Have the ability to develop a site safety and control plan.
• Understand chemical, radiological and toxicological terminology and behavior.

Therefore, depending on an employee’s competencies, more than 24 hours of training may be required.

On Scene Incident Commander
The incident commander is an individual who will assume control of the incident scene beyond the first responder awareness level. The intent of the standard is to provide an incident command system that is headed by a single person who is well trained in managing emergencies of differing severity, as well as overseeing the HAZMAT team, but does not necessarily have extensive knowledge of certain technical aspects such as classification and verification of hazardous substances.  Consequently, the IC requires more training in general matters, plus extensive training in command and management. Training for the IC may require more than 24 hours of total training.  Individuals serving in the role of IC MUST minimally receive 24 hours of training equal to first responder operations level, and in addition have competency in the six areas of knowledge listed in the standard (see 1910.120(q)(6)(v)(A)-(F)).

• 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 the 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 and be able to implement the employer’s incident command system.
• Know how to implement the employer’s emergency response plan.
• Know and understand the hazards and risks associated with employees working in chemical protective clothing.
• Know how to implement the local emergency response plan.
• Know of the state emergency response plan and of the Federal Regional Response Team.
• Know and understand the importance of decontamination procedures.

Therefore, depending on an employee’s competencies, more than 24 hours of training may be required.

Trainers
OSHA will determine the type of training provided to employees and assure that qualified instructors with proper training and/or academic training delivered the training. For example, the U.S. National Fire Academy offers courses that are appropriate for trainers. An in-house training program, among other options, may be developed. Credential requirements for trainers are defined in 1910.120(q)(7). Furthermore, trainers should maintain professional competency by participating in professional development programs or successfully completing an annual refresher course.  A video-only approach to train employees would not be sufficient, although videos could be used for part of the training if the employer can demonstrate that the employee has achieved sufficient knowledge and skills. For example, providing an instructor to respond to the employees’ questions after the video presentations, and evaluating employee understanding of the material would be required. First responder operations level training (q)(6)(ii) and higher would require hands-on training and more interaction with the instructor.  Similarly, computer-based training can serve as a valuable training tool in the context of an overall training program but, by itself, would not be sufficient to meet the intent of the training requirements. Training under HAZWOPER includes site-specific elements and must be tailored to employees’ assigned duties, including hands-on training involving PPE and equipment.

Refresher Training
Employees who must receive training as described above, MUST ALSO receive refresher training or demonstrate competency at least ANNUALY (every 365 days). Refresher training is required because employees must stay up-to-date in their skills and knowledge.  OSHA’s intent is that employees should complete their refresher training within twelve months of their initial training, although sometimes courses may be missed due to unavoidable circumstances. In such an event, employees should take the next available refresher training course. However, there should be a record in the employee’s file indicating why the training has been delayed and when the training will be completed. If the employee has gone without refresher training for more than twelve months, the employer must evaluate whether the initial comprehensive training needs to be repeated. The need to repeat initial training must be determined based on the employee’s familiarity with safety and health procedures and potential hazards.  Refresher training may be given in segments throughout the year so long as the required training has been completed by the employee’s anniversary date. Time spent by emergency response employees reviewing incidents can also be credited toward their refresher training requirements.  The employer must have a “statement of training” or “statement of competency” for annual refresher training or competency for all employees trained in emergency response.  This should reside in your ERP section on training.

Summary:
The level of training required for each employee will vary based on that employee’s assigned duties and responsibilities during an emergency response. Employees who are likely to discover a damaged package, and whose only responsibility is to summon assistance, must be trained to the awareness level (1910.120(q)(6)(i)). Operations level training would be appropriate for employees who respond in a DEFENSIVE manner to releases or potential releases from damaged packages from a safe distance (1910.120(q)(6)(ii)). Technician level training is required for all employees expected to take OFFENSIVE measures to approach and control a release (1910.120(q)(6)(iii)). Additional training may be necessary based on each employee’s expected response to an emergency.

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