Here is OSHA’s current interpretation of the HAZWOPER standard as it relates to IDLH operations. The LOI specifically addresses the HAZWOPER requirement for workers who are engaged in remedial operations as well as in emergency response operations in atmospheres that are or may be IDLH AND who utilize self-contained breathing apparatus (SCBA) for the control of inhalation hazard(s).
The HAZWOPER standard addresses three (3) categories of employees:
- workers at hazardous waste sites (paragraphs b-o),
- workers at Treatment, Storage, and Disposal facilities (paragraph p) and
- workers in workplace situations where they face an actual or potential emergency from the release of hazardous substances (paragraph q)
Fire fighters are often involved in emergency response operations when serving as members of an organized HAZMAT team, and as such, would be covered by the HAZWOPER standard.
Paragraph 1910.120(q)(3)(v) of HAZWOPER requires that “operations in hazardous areas (emphasis added) shall be performed using the buddy system in groups of two or more.” In addition, paragraph 1910.120(q)(3)(vi) states that “backup personnel shall stand by with equipment ready to provide assistance or rescue.”
This section means that, as a minimum, the buddy system must be used within the hazardous area (entry by at least two persons), and at least two additional personnel shall stand by outside the hazardous area. Thus, there must be at least four (4) individuals at the site. One (1) of the two (2) individuals outside the hazard area can be assigned to another task, provided that the second assignment does not interfere with the performance of the standby role.
Regarding the use of buddy systems, OSHA understands the HAZWOPER standard to mean the following:
a buddy shall be assigned who is able to:
(1) provide the partner with assistance;
(2) observe the partner for signs of chemical, heat, or other hazardous exposure;
(3) periodically check the integrity of the partner’s personal protective equipment/clothing; and
(4) if emergency help is needed, notify the appropriate individual (i.e., the Command Post Supervisor, the On-Scene Incident Commander).
The standard defines a “buddy system” and “IDLH” below as:
Buddy system means a system of organizing employees into workgroups in such a manner that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency.
IDLH or Immediately dangerous to life or health means an atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life or would cause irreversible or delayed adverse health effects or would interfere with an individual’s ability to escape from a dangerous atmosphere.
Source: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.120