Personnel roles must be clearly defined in the ERP. One method of doing this is to list job titles and describe their projected roles in emergency response operations. Although specific HAZWOPER titles are not required, employees should be designated to assume duties that parallel 1910.120(q)(6) and must be trained accordingly.
Lines of authority must also be made clear in the ERP. The senior official or on-scene incident commander (IC) must be notified expeditiously by a predefined chain of communication in the event of a release that would require an emergency response. Although employees at the scene of the release may be expected to inform their supervisors (as opposed to the on-scene IC), the supervisor, unless properly trained, can do nothing other than call for the emergency response personnel and report what is known to be present.
The lines of communication need to be defined clearly in the ERP. Essentially all employees that may encounter a release that requires an emergency response must be addressed in the ERP and each employee must understand to whom they are to report a release.
Means of communication to be used during an emergency response must be established and written into the ERP. This might include dedicated radio frequencies, hand signals, siren blasts, light indicators (e.g., strobe lights), or any other system devised by the employer to alert employees that an emergency response operation has begun. OSHA standard 1910.165 may be used as a guide for employee alarm systems.