If your facility has a HAZMAT team (e.g. they respond to chemical spills and releases) then your facility, and more specifically your response team fall under Section (q) if 1910.120.
The purpose of this article is to breakdown all the regulatory requirements of 1910.120(q) for you and your team. In the article I have italized the OSHA standard text and then I attempt to explain what the requirement actually requires.
I am not going to spend much time talking about the VERY FIRST requirement…the Emergency Response Plan (ERP). I have posted eleven articles that break down all the sections required to be in your ERP and explained what OSHA requires to be in each section of the ERP. But don’t be fooled, your ERP is suppose to be SPECIFIC to your workplace, chemicals, and response capabilities. The first sentence of (q)(1) states…
An emergency response plan shall be developed and implemented to handle anticipated emergencies (emphasis added by me) prior to the commencement of emergency response operations.
Coupled with the fact that the first requirement of an ERP is Pre-emergency planning and coordination with outside parties; if this does not make it clear that we should do some “pre-planning” based on our hazardous chemicals, their quantities, their locations, and the teams response capabilities I am not sure what will. And if the facility identifies gaps in their capabilities and they turn to agencies outside of the facility for help, then they MUST “coordinate with these outside parties” so that the outside responders will know their role(s) during the type of response they will be asked to participate in.
The next section deals with “Procedures for handling emergency response”. This is where OSHA lays out the requirements that an Incident Command System be established on ALL responses that fall under the standard (see previous article on “incidental spills” that do not fall under 1910.120).
The senior emergency response official responding to an emergency shall become the individual in charge of a site-specific Incident Command System (ICS). All emergency responders and their communications shall be coordinated and controlled through the individual in charge of the ICS assisted by the senior official present for each employer.
It is important to point out once again the reference to the use of the term “site-specific”. The facilities ICS needs to be clearly defined in Section II of your ERP (e.g. Personnel roles, lines of authority, training, and communication). It is my opinion that the IC role needs to have a clear leader when four or five trained IC’s are on the scene. This should be spelled out BEFORE a response.
NOTE TO PARAGRAPH (q)(3)(i). – The “senior official” at an emergency response is the most senior official on the site who has the responsibility for controlling the operations at the site. Initially it is the senior officer on the first-due piece of responding emergency apparatus to arrive on the incident scene. As more senior officers arrive (i.e. , battalion chief, fire chief, state law enforcement official, site coordinator, etc.) the position is passed up the line of authority which has been previously established. (See my previous article regarding who can be an IC).
The individual in charge of the ICS shall identify, to the extent possible, all hazardous substances or conditions present and shall address as appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures, and use of any new technologies.
This means that the IC identify the chemical(s) involved in the response, as well as their exposure limits (e.g. IDLH, PEL/TLV, STEL, etc.) and other pertinent physical properties (e.g. LEL/UEL, Vapor Density, Vapor Pressure, etc.). They must also identify the conditions under which the response will be taking place. This could be a whole range of things, like temperature extremes (both hot and cold), elevated surfaces, dangerous access (e.g. getting down into creek/river beds, slippery surfaces, etc.). Unfortunately we do not have a lot of opportunities to use engineering controls in the middle of a bean field at 3:00 a.m., but if we are at a fixed facility’s chemical storage room that has a ventilation system, the IC needs to identify this control and put it to use within their response plan.
Based on the hazardous substances and/or conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards to be encountered. However, personal protective equipment shall meet, at a minimum, the criteria contained in 29 CFR 1910.156(e) when worn while performing fire fighting operations beyond the incipient stage for any incident.
The IC is responsible for approving the PPE ensemble that will be used for the entry team (including the back-up team) and the Decon Team. On a large response, the Planning Team will most likely set the level of PPE for the response, but it is the IC that will either accept or reject the plan and the plan includes the PPE that will be used. I will pass on the reference to the fire fighting operations for now and will cover that in a future article.
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.
This requirement is one that still amazes me, as so many facilities just do not get it. What OSHA (and EPA takes the same position) is trying to state here is that response personnel will be in AT LEAST LEVEL B PPE during their initial response. LEVEL B consist of an SCBA that is a pressure-demand (e.g. positive pressure) and chemical clothing. Responders can also use an air-line respirator with an escape bottle instead of a SCBA if they so choose, but be ready for a nightmare in the Decon Line! Also, dragging around air lines through contamination is NOT a good idea and remember with an air-line, the doors you go through going in will be the same doors you will have to use to get out, which if things go wrong you may not be able to travel the same path (hence the emergency escape bottle). I am also taken back by the companies we do some refresher training for and no one, including those trained to be IC’s, have never even seen the “Maximum Use Concentration” (MUC) equation so that once they know the hot zone concentration(s) they can determine the level of necessary respiratory protection. I guess everyone could stay in Level A or B for the entire entry, but so many facilities we work with are limited by the amount of Grade D breathing air they have access to, so that is not really an option.
The individual in charge of the ICS shall limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure to incident or site hazards, to those who are actively performing emergency operations. However, operations in hazardous areas shall be performed using the buddy system in groups of two or more.
This is a big one and it gets to the heart of what an IC is all about…controlling the scene before it controls you! The scene has to be “controlled chaos” and part of this is to limit the number of responders on scene. To reduce chemical exposure risks to personnel, the number of personnel permitted to entry the hot and warm zones needs to be limited; but this is a balancing act, as we can not repeatedly send in the same responders time and time again.
Back-up personnel shall be standing by with equipment ready to provide assistance or rescue. Qualified basic life support personnel, as a minimum, shall also be standing by with medical equipment and transportation capability.
Most of us know this first statement as the “Buddy System” (e.g. two entrants – two backups). It is the second part of this requirement that many facilities fall short. Most facilities can provide the basic life support personnel, as OSHA will accept “first responders” in this role; but when it comes to the “transportation capability” they fall short. Let’s be clear, Bryan’s Pick-Up truck is not what OSHA was intending here. “Transportation capability” means an ambulance that is at least a Basic Life Support (BLS) level unit. Also, keep in mind that a “state OSHA plan” may have higher requirements (i.e. OR-OSHA requires Advanced Life Support).
The individual in charge of the ICS shall designate a safety officer, who is knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety of operations for the emergency at hand.
The safety officer plays a MAJOR role on large scale responses. I should let you know that at a small scale response, the IC can fullfil the role of the safety officer as long as they can fully meet the role of both the IC and SO. The SO must be someone who has the skills and ability to identify and evaluate hazards and to provide direction with respect to the safety of operations. In my opinion this is someone who knows respirators, LEVEL A/B/C ensembles and all that goes with using this level of PPE properly. They also need to have a STORNG working knowledge of the chemicals involved (e.g. IDLH, VP, VD, LEL/UEL, etc.)
When activities are judged by the safety officer to be an IDLH and/or to involve an imminent danger condition, the safety officer shall have the authority to alter, suspend, or terminate those activities. The safety official shall immediately inform the individual in charge of the ICS of any actions needed to be taken to correct these hazards at the emergency scene.
This should be self explanatory.
After emergency operations have terminated, the individual in charge of the ICS shall implement appropriate decontamination procedures.
I should point out that part of your ERP will be written “Decon Procedures” as require dby section (q)(2)(vii). When we think of decon, we usually think of deconing the entry team when they exit the hot zone, but we do not think about deconing their equipment, tools, or even the entrant themselves. Bottom line…EVERYTHING that goes into the Hot and Warm zone will either be deconned for reuse or disposed of as hazardous waste or some other classification of waste based on the degree of contamination.
When deemed necessary for meeting the tasks at hand, approved self-contained compressed air breathing apparatus may be used with approved cylinders from other approved self-contained compressed air breathing apparatus provided that such cylinders are of the same capacity and pressure rating. All compressed air cylinders used with self-contained breathing apparatus shall meet U.S. Department of Transportation and National Institute for Occupational Safety and Health criteria.
This is something that OSHA added in 2002 after the September 11, 2001 terrorist strikes and the ensuing response and clean-up. It is just allowing responders to use spare bottles from other manufacturers as long as the bottles are the same pressure and threading aligns.
The next article will address the seven (7) recognized levels of training for responders. Then I will have one last article to write on the medical monitoring and PPE that comes from 1910.120(f) and (g)(3)-(5).