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?
All personnel who must receive emergency responder training under 1910.120(q)(6), including Awareness Level, MUST also receive annual refresher training in accordance with paragraph (q)(8). When there is the potential for employee exposure to hazardous substances under NON-EMERGENCY RELEASES of hazardous substances, training under 29 CFR 1910.1200 (Hazard Communication) is applicable.
1910.120(q)(6)(i) First responder awareness level.
First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release. First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:
1910.120(q)(6)(i)(A) An understanding of what hazardous substances are, and the risks associated with them in an incident.
1910.120(q)(6)(i)(B) An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.
1910.120(q)(6)(i)(C) The ability to recognize the presence of hazardous substances in an emergency.
1910.120(q)(6)(i)(D) The ability to identify the hazardous substances, if possible.
1910.120(q)(6)(i)(E) 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.
1910.120(q)(6)(i)(F) The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.
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 b y 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.
CSHOs should verify that employees who may discover an emergency release and whose duties are limited to initiating an emergency response sequence receive first responder awareness level training at a minimum. 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)).