If you have additional questions concerning coverage under the EPA regulations, I suggest that you contact: Vickie Santoro United States Environmental Protection Agency ERT (MS101) Woodbridge Avenue Building 18 Edison, New Jersey 08837 (201) 906-6917. Overview of EPA and OSHA Worker Protection Authority The Occupational Safety and Health Act of 1970, as amended (OSH Act), established health and safety standards for the American workplace. The employer should provide employees engaged in hazardous waste site activities with information and training prior to initial assignment into their work area, as follows: (1) The requirements of the hazard communication program including the location and availability of the written program, required lists of hazardous chemicals, and safety data sheets. Therefore, proper and extensive training of not only the Incident Commander, but also the other employees is crucial. Industrial Consultants are outreach OSHA trainers and have personal experience at the facility level. S-130, Firefighter Training; S-190, Introduction to Wildland Fire Behavior; S-131, Firefighter Type 1 Training . (d) Confined-space hazards and procedures. e. The employees will review and discuss the site safety plan as part of the training program. Without incident commander training, the individuals in charge will not have a clear understanding of the regulations required during a hazmat response. Additionally, the Incident Commander must be able to understand and interpret the Emergency Response Plan and the Emergency Action Plan that are in place for the facility. 472, Professional Competence of Responders to Hazardous Materials Incidents. 6. (4) Maintenance and availability of records. (9) Container sampling procedures and safeguarding; general drum and container handling procedures including special requirement for laboratory waste packs, shock-sensitive wastes, and radioactive wastes. Thank you for your August 25, 2003 letter to the Occupational Safety and Health Administration (OSHA) requesting guidance on the role of an Incident Commander (IC) 1910.120(q)(6)(v) and an operations level responder within 1910.120(q)(6)(ii). (5) Personnel to be contacted and procedures to be followed when signs and symptoms of exposures are recognized. (e) Hands-on review of new or altered PPE or decontamination equipment or procedures. Facilities for representative hands-on training. Course materials. Answer: See above. The Joint Commission on Accreditation of Healthcare Organizations (JCAHO) requires an all-hazard approach to allow organizations to be flexible enough to respond to emergencies of all types, whether natural or manmade (unintentional or intentional). Proficiency should be evaluated and documented by the use of a written assessment and a skill demonstration selected and developed by the Training Director and training staff. Adequacy and appropriateness of quality control and evaluation plans for training programs should be considered, including: 1. Question 1: Do these process operators have to act under the control of an IC? 2. The following non-mandatory general criteria may be used for assistance in developing site-specific training curriculum used to meet the training requirements of 29 CFR 1910.120(e); 29 CFR 1910.120(p)(7), (p)(8)(iii); and 29 CFR 1910.120(q)(6), (q)(7), and (q)(8). 6. Student-instructor ratios should not exceed 30 students per instructor. It is noted that the legal requirements are set forth in the regulatory text of 1910.120. (6) Decontamination procedures and practices. This letter constitutes OSHA's interpretation of the requirements discussed. Hazwoper Incident Command Refresher Training. training specific to the fire department's vehicles 4.4 Incident Commanders: As outlined in section 1910.156(c)(1) of the OSHA regulations, those chiefs, officers or firefighters who have been designated or may perform the duties of a fire service incident commander must receive training which is superior than that provided to the general Question 2: Does the IC have to be physically present before defensive response steps can be taken? Lieutenant/EMS Coordinator Adequacy and appropriateness of the quality control and evaluation program to ensure appropriate course evaluation, feedback, updating, and corrective action. Course Details Code: 1008 Subjects: OSHA Emergency Response Courses Price: US $79.00 REGISTER NOWREGISTER NOW Who Should Take This Class? Is the course material current and relevant to the target group? (h) A review of hazard communication programs meeting the requirements of 29 CFR 1910.1200. e. Name and address of the training provider. Assurance that the student already possess the necessary skills for their job, including necessary documentation. 4. (1) A laminated, dated card or certificate with photo, denoting limitations and level of protection for which the employee is trained should be issued to those students successfully completing a course. February 14, 2004 Occupational Safety and Health Program: Each hazardous waste site clean-up effort will require an occupational safety and health program headed by the site coordinator or the employer's representative. 4. (i) Safe use engineering controls and equipment on site. The Training Director should conduct or direct an annual written audit of the training program. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190. (B) Hands-on experience with retrieval and use of written and electronic information relative to response decision making including but not limited to the U.S. Department of Transportation's Emergency Response Guidebook (ERG), manufacturer safety data sheets, CHEMTREC/CANUTEC, shipper or manufacturer contacts, computer data bases and response models, and other relevant sources of information addressing hazardous substance releases. The IC must be notified expeditiously by a predetermined chain of communication. (D) Review of procedures for implementing continuing response actions consistent with the local emergency response plan, the organization's standard operating procedures, and the current edition of DOT's ERG including extended emergency notification procedures and follow-up communications. Question 4: Can the IC be a trained person from the facility, or must they be from the outside agency who will command the technician level responders? For Level A or Level B personal protective equipment the ratio should be 5 students per instructor. These records should be available and provided upon the student's request or as mandated by law. The location of the site safety plan and all written programs should be discussed with employees including a discussion of the mechanisms for access, review, and references described. Standard Number: 1910.120 OSHA requirements are set by statute, standards and regulations. Also, from time to time we update our guidance in response to new information. We have a plethora of degreed personnel with several disciplines and backgrounds in our organization. General Hazardous Waste Operations and Site-specific Training 1. (E) Review of the principles and practice for proper selection and use of personal protective equipment. Trained incident commanders reduce the cost involved, including loss of life, property and even the business. Student's name. This letter constitutes OSHA's interpretation of the requirements discussed. (f) An review of the employer's training program and the parties responsible for that program. (5) Safe use of engineering controls and equipment available on site. 1. 1910.120 - Hazardous Waste Operations and Emergency Response. Regulatory knowledge. Physical . The decisions made by the Incident Commander have the potential to change the lives of the people in and around the facility. Price $115.00. (7) Emergency procedures, first aid, and self-rescue. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov. (G) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards. In addition, the ICs should not be at or near the release area, which would allow them to perform their duties without becoming too closely involved in the response effort. (5) A curriculum should be established for the required 8-hour training for supervisors. Incident commanders shall receive at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify: (A) Know and be able to implement the employer's incident command system. 5. It is specifically aimed at ammonia users, but will relate to many other chemicals. (m) A review of the applicable appendices to 29 CFR 1910.120. 10. Answer: ICs may be from the facility, provided they have had appropriate training in accordance with 1910.120(q)(6)(v). Refresher training. Type 1 is the highest qualification level. "Demonstration" means the showing by actual use of equipment or procedures. Exact dates have not been determined and plenty of notice will be given once they have been set. Demonstrated competency in the skills and knowledge provided in a 40-hour course should be a prerequisite for supervisor training. b. Appropriateness and adequacy of the training methods used by the instructors. Reviews should possess expertise in the following disciplines were applicable: occupational health, industrial hygiene and safety, chemical/environmental engineering, employee education, or emergency response. After attending this course, participants will: Know how to implement the employer's incident command system. ICS-200 provides training and resources for personnel who are likely to assume a supervisory position within the ICS. General considerations. Hands-on activity requiring the use of personal protective equipment should have the following student- instructor ratios. (E) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards. In the 1970s, California was suffering from catastrophic wildfires. Background: Management of a few smaller ammonia refrigeration facilities have started to train personnel in emergency response in several ways. Are incident commanders required to attend annual refresher training? (G) Review of the principles and practices of establishing exposure zones and proper decontamination, monitoring and medical surveillance stations and procedures. What makes a company qualified to train incident commanders? (f) Review of newly developed air and contaminant monitoring equipment. Training providers should maintain records listing the dates courses were presented, the names of the individual course attenders, the names of those students successfully completing each course, and the number of training certificates issued to each successful student. If a skills demonstration is used, the tasks chosen and the means to rate successful completion should be fully documented by the Training Director. Note: In several of your questions you use the term "defensive" (e.g., "defensive response steps"). (6) Work practices to minimize employee risk from site hazards. An office is still filled with people, and people are prone to mistakes that can lead to minor or severe accidents. An incident commander's position should be occupied by the most senior, appropriately trained individual present at the response site. Training requirements for all classifications of responders are based on "the duties and function to be performed by each responder" and the standard sets forth five general categories of responders and the training requirements for each. 2. (14) Community relations. Sincerely, Post Office Box 209 TRAINING REQUIREMENTS. Answer: Yes. Training Plan. Process operators who shut down processes or close valves outside the hot zone or danger area before evacuating are not under the ICS. 7. General Hazardous Waste Operations 2. Adequacy and appropriateness of the quality control and evaluations program to account for instructor performance. This course is designed to meet the requirements of OSHA for Incident Commander training of emergency response personnel who will respond to leaks or spills of chemicals for the purpose of stopping the leak or spill. These proficiency assessment methods must reflect the additional responsibilities borne by supervisory personnel in hazardous waste operations or emergency response. 7. (3) Safe work practices and general site safety. (7) Safe use of engineering controls, equipment, and any new relevant safety technology or safety procedures. General Industry Training Requirements. Dear Ms. Harmon: (l) A review of the criteria and programs for proper selection and use of personal protective equipment, including respirators. (1) An review of 29 CFR 1910.120 and the core elements of an occupational safety and health program. (f) Emergency response plan and procedures including first aid meeting the requirements of paragraph (p)(8). This course is designed to meet the requirements of OSHA for Incident Commander training of emergency response personnel who will respond to leaks or spills of chemicals for the purpose of stopping the leak or spill. Note that our enforcement guidance may be affected by changes to OSHA rules. The written test and skill demonstration should be updated as necessary to reflect changes in the curriculum and any update should be approved by the Training Director. All facilities have an outside agency delineated in their Emergency Response Plan (ERP) that will act as hazardous material technicians in the event of an incident requiring an emergency response. 2. B. Issues such as qualifications of instructors, training certification, and similar criteria appropriate to all categories of operations addressed in 1910.120 have been covered in the preceding section and are not re-addressed in each of the generic guidelines. The applicable EPA regulations are identical to those under OSHA, but are administered and enforced by the EPA. 1. Incident Commander (IC) Training as Required by OSHA. F. Institutional Environment and Administrative Support The adequacy and appropriateness of the institutional environment and administrative support system for the training program should be considered, including: 1. Incident commanders, who will assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify: Scenario A: The first scenario requires all personnel to evacuate, although refrigeration maintenance operators are allowed to start the process of shut-down according to the CPL 02-02-059 [formerly CPL 2-2.59A], Appendix D, Section E.2. National Environmental Trainers Suggested core criteria: 1. This risk was estimated using a scale adapted from the Hospital Corporation of America (HCA, undated): Key Treatment Centers Hospitals in large urban areas. (12) Rights and responsibilities of employees under OSHA and other related laws concerning right-to-know, safety and health, compensations and liability. 311 requirements. Proficiency assessment. However, OSHA recognizes that first receivers have somewhat different training and personal protective equipment (PPE) needs than workers in the hazardous substance Release Zone, a point clarified through letters of interpretation (OSHA, 2002a). We hope you find this information helpful. January 2, 1990, Mr. Michael G. Connors 3. Review and compliance with any medical clearance policy. Course title. (13) Methods of communication including those used while wearing respiratory protection. The process for the development of curriculum, which includes appropriate technical input, outside review, evaluation, program pretesting. Evidence that the training organizational structure suits the needs of the training program. (7) Elements of the site emergency response plan, including: (A) Pre-emergency planning. 10470 W. Devils Den Road Training Requirements by Standard; The required training also includes instruction on how to accurately and fully report the necessary information to an "alarm dispatcher" so that subsequent emergency responders are fully informed. 9. Manager of Consulting Services Insurance Restoration Specialists 77 New Durham Road Edison, New Jersey 08817 Dear Dr. Kleckner: This is in response to your inquiry of May 21, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). (5) Incident commander. Written documentation should be provided to each student who satisfactorily completes the training course. In those circumstances where the facility IC relinquishes command to an outside IC, the lines of authority must be clearly defined and procedures delineated in the facility's ERP. Is the evaluation tool current and appropriate for the program content? The individual employer should provide hazardous waste employees with information and training prior to an employee's initial assignment into a work area. Mr. Michael H. Fagel Students. If a written test is used in combination with a skills demonstration, a minimum of 25 questions should be used. Know how to implement the employer's emergency response plan. One or more of the peer reviewers should be an employee experienced in the work activities to which the training is directed. The mandatory result of the training, regardless of its duration, is that the trained employees be able "to objectively demonstrate competency" in the six areas of knowledge listed in the standard. Incident Commander Training, Essential for Everyone, The Critical Elements of Incident Response. How Long Does 40-Hour HAZWOPER Certification Last. 6. (12) Procedures for safe and healthful preparation of containers for shipping and transport. For example, Type 1 qualifications include the qualifications in Type 2, plus an increase in capability. 2. See 1910.120(q)(6)(ii). Adequacy and appropriateness of the administrative structure and administrative support. Please contact us with questions at 402.483.2511 or email nesc@nesafetycouncil.org. (F) Evacuation routes and procedures. (4) Work practices by which the employee can minimize risks from hazards. (D) Review of the principles and practices for identification of the types of hazardous substance transportation containers, vessels and vehicles involved in the release; selecting and using the various types of equipment available for plugging or patching transportation containers, vessels or vehicles; organizing and directing the use of multiple teams of hazardous material technicians and selecting the appropriate strategy for approaching release sites and containing or stopping the release. C. Training facilities and resources. Section 1. Is my facility required to train incident commanders? The training facility should have available sufficient resources, equipment, and site locations to perform didactic and hands-on training when appropriate. Companies will ultimately be responsible for all actions taken. Program modifications to address deficiencies, if any, should be documented, approved, and implemented by the training provider. The level of minimum achievement necessary for proficiency shall be specified in writing by the Training Director. (i) A review of medical surveillance programs meeting the requirements of 29 CFR 1910.120(p)(3) including the recognition of signs and symptoms of overexposure to hazardous substance including known synergistic interactions. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. 6, 1898, as amended at 55 FR 14073, Apr. 5. All written and audio-visual materials in training curricula should be peer reviewed by technically competent outside reviewers or by a standing advisory committee. Question 3: Can defensive action begin if the IC's presence is imminent? 1910.119 - Process Safety Management of Highly Hazardous Chemicals. (c) General safety hazards including those associated with electrical hazards, powered equipment hazards, lock-out-tag-out procedures, motor vehicle hazards and walking-working surface hazards. (j) Names of personnel and alternates responsible for safety and health. (2) Fundamentals of chemical hazards including but not limited to vapor pressure, boiling points, flash points, ph, other physical and chemical properties. are limited to their responsibilities and current training levels. A unified approach to training at the community level between emergency response organizations covered by Federal OSHA and those not covered directly by Federal OSHA can help ensure an effective community response to the release or potential release of hazardous substances in the community. "Lecture" means an interactive discourse with a class lead by an instructor. Additionally, he/she must have the competency to implement the employers incident command system, emergency response plan, understand hazard risk, know how local emergency responders will interact and know how state emergency response works. b. (A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q). Adequate monitoring of student safety, progress, and performance during the training. These are generic guidelines and they are not presented as a complete training curriculum for any specific employer. Ready to get started? (8) Review of other applicable standards including but not limited to those in the construction standards (29 CFR Part 1926). (4) The physical and health hazards of substances known or potentially present in the work area. (2) Principles of toxicology, biological monitoring, and risk assessment. Our online training certifies you to be an OSHA Incident Commander, which is a position required at every emergency hazardous or chemical incident response, and fulfills your OSHA training requirement under 29 CFR 1910.120 (q) for Incident/Scene Commander. Does your employer store or use hazardous chemicals? North Aurora Fire Department This cause Self-Contained Breathing Apparatus (SCBA), Understanding Ammonia Refrigeration Systems. Some of the smaller facilities have decided on training to a higher level to allow their members to be part of a team. 13, 1990; 56 FR 15832, Apr. Training facility. The incident commander shall be trained to meet all requirements indicated for the first responder at the awareness and operational levels and the requirements of this chapter. (6) An explanation of the labeling system and safety data sheets and how employees can obtain and use appropriate hazard information. 4. The standard does not set a mandatory minimum number of hours for this training, but such courses often run from 4 to 12 hours. The proficiency assessment methods, regardless of the approach or combination of approaches used, should be justified, documented and approved by the Training Director. States with OSHA state plans must cover their employees with regulations at least as effective as the Federal OSHA standards. Recordkeeping. OSHA establishes the following training requirements for incident commanders: a minimum of 24 hours of training at the first responder operations level plus training to the competencies described below or certification of sufficient experience as an alternative. Adequacy and appropriateness of staff performance and delivering an effective training program should be considered, including: 1. (b) Update on developments with respect to material covered in the 40-hour course. The proficiency of those taking the additional courses for supervisors should be evaluated and documented by using proficiency assessment methods acceptable to the Training Director. (E) Review of the principles and practice for proper selection and use of personal protective equipment. (I) Emergency equipment and procedures for handling emergency incidents. 10. This documentation may include a certificate and an appropriate wallet-sized laminated card with a photograph of the student and the above information. OSHA logo and review of website do not imply endorsement or approval. What are the program's main weaknesses? Training and competency requirements for on scene incident commanders who will assume control of the incident scene beyond the first responder awareness level are delineated in 29 CFR 1910.120(q) (6) (v). Demonstration of the training director's leadership in assuring quality of health and safety training. (B) Personnel roles and lines of authority and communication. 6. Training Director. 2. The required training for Emergency Response Workers is HAZWOPER First Responder Operations (FRO) Annual Refresher, HAZMAT Specialist 29 CFR, and 8-Hour HAZWOPER Incident Command. However, if the process operator takes action beyond that for which they are trained, and the action is comparable to the active role that a hazardous materials technician (offensive action within the hot zone or danger area) would take, such action would be a training violation under 1910.120(q)(6)(iii). (D) Review of procedures for implementing actions consistent with the local emergency response plan, the organization's standard operating procedures, and the current edition of DOT's ERG including emergency notification procedures and follow-up communications. (6) PPE maintenance and storage. (6) Sanitation recommendation and equipment. During mass casualty emergencies, hospitals can anticipate little or no warning before victims begin arriving.5 Additionally, first receivers can anticipate that information regarding the hazardous agent(s) would not be available immediately. Also, the standard says sufficient training or personal experience for specific competencies". Minimum Risk Hospitals Hospitals with populations less than 500,000 within a 50-mile radius and without a high-visibility potential target within that distance. (4) General safety hazards such as but not limited to electrical hazards, powered equipment hazards, motor vehicle hazards, walking-working surface hazards, excavation hazards, and hazards associated with working in hot and cold temperature extremes.
