Consider this scenario
A chemical facility has a processed covered by OSHA Process Safety Management standard. The facility has extensive in-house response capabilities with a well staffed and equipped HAZMAT team, which trains all of the responders to the Technician level and supervisors are trained as Incident Commanders.
But is this all the training from 1910.120(q) that applies to this facility? Well as you can imagine by me writing this article the answer is no and let me explain….
The “awareness level” training in 1910.120(q)(6)(i) applies to any of the workers “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”.
This is very broad language and is intended to cover a wide array of workers; but without a doubt, it will cover chemical operators and maintenance personnel who work in, on or adjacent to ANY process from which a release of a hazardous material could occur. LET ME BE CLEAR HERE – the process does NOT have to be a PSM covered process or even a PSM listed chemical, as there are a lot of hazardous chemicals that could require an “emergency response” under 1910.120 that are not listed as a PSM covered chemical. As well as, there are a lot of processes out there that have PSM covered chemicals that contain less than the threshold amount and thus are not covered by the PSM standard. So this requirement will inevitably cover MANY workers in all types of facilities around the country; even those workers NOT covered by OSHA (but are covered by 40 CFR 311 – see my article on EPA enforcement of 1910.120).
Now for the good news! 1910.120(q) (nor 40 CFR 311) define any set length of time for “awareness” training like they do for Operations Level through Incident Command level. They do require some specific items to be covered, but many facilities are ALREADY covering these topics in their current training efforts through other safety and environmental training. The standard states the following:
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.
A thorough HAZCOM training program will cover this, especially if the program gets into details about the bulk chemicals on site. But keep in mind, we can have an “emergency” with some chemicals in very small quantities, so it may not be adequate to just cover the bulk chemicals.
1910.120(q)(6)(i)(B) An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.
A thorough PPE training program that trains the users to recognize the LIMITATIONS of the PPE and when it is time to evacuate due to a spill or release.
1910.120(q)(6)(i)(C) The ability to recognize the presence of hazardous substances in an emergency.
This is a combination of thorough HAZCOM training and PPE training. ALL workers who could come up on a release MUST have the ability to recognize the release is an “emergency” (e.g. the release is too large, or too complex, or too toxic for their level of training and PPE). This one requirement is probably the MOST CRITICAL one, as most employees will have a tendency to want to jump in and stop the release. THEY MUST KNOW THEIR LIMITATIONS!
1910.120(q)(6)(i)(D) The ability to identify the hazardous substances, if possible.
This is another one that can be easily covered by a thorough HAZCOM training program. Workers need to be able to identify the chemical via the container it is leaking from [e.g. labeling] and if they cannot identify the container from with the material leaked from, then they need to be able to identify the chemical [or at least the class of chemical] when it is sitting in a puddle, vaporizing into a cloud, etc.)
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.
This is covered in a thorough emergency response plan annual training program. One slide to reinforce their duty is to ACTIVATE the response plan by reporting the spill per the procedures in the response plan and to establish a safety zone around the spill to prevent others from being exposed. I would argue that training operators and maintenance personnel at a fixed facility that has a well trained and staffed HAZMAT team of Technicians on the DOT ERG book is a waste of time! Let’s be honest here, the DOT ERG is really intended for deputy sheriffs, police officers, state troopers, EMS personnel, and firefighters that are arriving on an accident scene involving a transportation container. Having been a FF/EMT for many years I could not count the number of times we were called to a vehicle accident only to discover a HAZMAT incident upon our arrival. 100% of our actions were based on the DOT ERG book instructions. But an operator or maintenance mechanic on a fixed site “should” be able to identify a placard, look up the chemical in the DOT ERG book and implement the actions in BOTH the response guide (orange section) and the initial isolation; I would never expect a worker, who is NOT trained to an incident commander level, to ever implement the “protective action distances”! But the argument is, that on a fixed size with a well-staffed HAZMAT team (who is extensively trained on the ERG) , it is not a critical safety matter that we train all operators and maintenance personnel on the DOT ERG. With that said I can train a large group on the DOT ERG in 30-45 minutes (minus the protective action distances”); so we are not looking at a huge investment in time or effort to go ahead and get them trained.
1910.120(q)(6)(i)(F) The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.
This goes in line with having the ability to recognize when the worker’s capabilities, either because of lack of specialized training or not having the proper PPE for the chemical exposures, has been overcome and they MUST exit the area and call for additional and more specialized assistance.
So as we can see, operators and mechanics that work around hazardous chemicals should probably be trained in the above requirements. But the good news is, if we have strong HAZCOM and PPE training programs, all we have left is the DOT ERG book to cover and like I said that is at max 45 minutes. There is NO minimum time specified for awareness level and although there a lot of trainers out there that will tell us that annual refresher training must be 8-hours long, that is a myth and NOT a requirement! For annual refresher training for these folks would be the DOT ERG book and their normal annual safety training for HAZCOM and PPE. So we are not talking about another group of workers who need to be removed from their jobs for an entire day to maintain this level of certification!