Most safety and emergency response personnel understand that an Emergency Action Plan (EAP) is intended to cover the reporting, sounding an alarm, and evacuating and accounting for everyone. But most will say 1910.120(q) applies ONLY when the facility has a “response team”, but is this correct?
Way back in the 1990’s OSHA stated the following regarding which employees would be considered ones who would need to be trained to the “Awareness Level”. You may find this surprising…
(emphasis by me)
Employees who work in an area (or areas) where there is a POTENTIAL to witness or discover an uncontrolled release of a hazardous substance and whose response actions will be LIMITED TO INITIATING EMERGENCY RESPONSE PROCEDURES by notifying the proper authorities, MUST RECEIVE first responder AWARENESS LEVEL training consistent with the requirements of 29 CFR 1910.120(q)(6)(i). Such employees are NOT LIMITED to police, hospital, or fire department personnel as suggested in your letter, but would INCLUDE ANY EMPLOYEE MEETING THE ABOVE DESCRIPTION.
So what does all this mean at a facility that has hazardous substances and/or extremely hazardous substances?