If you have the potential for a hazmat incident in your facility, it’s important that you know the difference between awareness, operations, and technician level responses. Allowing employees to operate at a higher level than their training and PPE allows can get you in trouble. Additionally, the 4th level is specialist. Specialist is not so much a level of operations as it is a level of competency. So somebody that is a specialist isn’t just trained to respond, but would be able to assess more complex potential chemical reactions, and wouldn’t be applicable to most facilities.
Hazmat operations are primarily regulated by 29 CFR 1910.120 (OSHA regulations).
First, you need to determine if an incident is an emergency, or incidental (non-emergency) situation. So, with a chemical spill or reaction, ask the following questions. If ANY of them answer no, it is an emergency:
1. Is the material identifiable?
2. Has the employee been trained to handle the material?
3. Is the hazard like normal working conditions?
4. Can the situation safely be handled without outside resources?
5. Does normal PPE apply?
6. There is no imminent danger to the employees?
7. There is no imminent danger of fire, explosion, or damage?
8. There is no significant threat to the environmental?
Here’s the lowdown. If you have hazardous materials, such as anhydrous ammonia, hazardous waste, large quantities of caustics, and so on, you need to train employees who handle, or may be exposed to, these hazards BEFORE they are at risk. Employees must be trained to the level of their risk or response.
Awareness means they may recognize there is a leak or an emergency, initiate an alarm and/or evacuation, gather information OUTSIDE of the danger zone (such as getting an SDS), and other activities that are well away from the danger. Employees who may be exposed to hazards and take these actions should be trained under HAZWOPER (hazardous waste operations and emergency response) to the 8-hour level.
Operations is designated for someone who has the training to determine how far to evacuate and assess the initial dangers without entry. They may only enter to perform a rescue, not to shutdown or contain a leak. The keyword here is DEFENSIVE. They may take defensive actions to alleviate the dangers while remaining outside the danger zone, such as turning on ventilation, closing valves remotely, gathering information, and so forth. Operations level employees must be trained to the 24-hour HAZWOPER level and may not exceed the PPE and conditions they were trained for.
Technician level operations may perform OFFENSIVE actions, meaning they may shutdown and contain a leak, in addition to performing rescues, gathering information, and taking other defensive actions, if appropriate. They also must be trained to at least the 24-hour HAZWOPER level, but it’s important they’re trained in all the information they need to wear PPE, assess risks, mitigate hazards, etc., so 24-hours is often not sufficient for facilities with more complex risks. Managers and site supervisors are required to have 40-hours of training.
Why are operations and technician training (and the additional level of specialist training) all 24-hours? OSHA inserts the mandate that the training is 24-hours AND the employee is trained for the PPE and hazards and other tasks, so it leaves it up to the trainer to assess the skill level needed and adapt the training, also taking into consideration an employee’s background.
For example, even though OSHA calls out that a specialist needs 24-hours of training, unless a facility has a very simple chemical and process with limited risks, almost no employee could accurately be called a specialist with just 24-hours of training without a chemistry background. Typically, someone trained as a specialist is going to have extensive training, such as being a chemical engineer, and the HAZWOPER training is simply training them to respond in an emergency. 24-hours may be enough for that person to accurately be called a specialist. Most employees could not accurately be called a specialist with even 80-hours of training.
Let’s look at a few scenarios. Bob is trained to the operations level. Jane is trained at the operations level. Dave is trained to technician level.
If they work in a facility with anhydrous ammonia, and Bob sees a leak, he must immediately evacuate and sound the alarm and meet EMS when they arrive. Jane would be able to make initial determinations on how far to evacuate until an incident commander takes over. Jane could also go to a part of the facility that is not contaminated and turn on ventilation. Dave and Jane could enter in proper PPE to pull out an exposed coworker but could not take any other action inside the leak area, and there would need to be a backup team in case they got into trouble. Dave could make entry with another technician while wearing proper PPE to shut down the leak, and Jane could run the decontamination station.
Now, we look at another scenario. Bob is working with isopropyl alcohol, which he does every day. He spills a cup on the counter. He has proper PPE, there is no immediate danger of ignition, he has a respirator, and has the proper materials to clean it up. It is not considered a hazmat emergency, and therefore Bob may clean it up.
Later, Bob is driving a forklift and it runs out of propane. He is replacing the propane cylinders and drops one (we’re starting to see that Bob is careless!). The cylinder pierces and begins to leak. Bob initiates an evacuation. Because no amount of PPE can protect the employees against a potential explosion, no employees enter the building. Dave is the incident commander and based on information Bob told him about the leak, he has ordered an evacuation and decides to make entry after 30-minutes because several exterior doors were left open at ground level on the building with no basement. He uses a 4-gas monitor to test the air as he makes entry into the building, again with another technician and a backup team waiting. The monitor never goes above 10% LEL and he’s able to open several more doors to ventilate the facility. After checking in numerous parts of the facility to determining that there are no pools of propane gas and the readings have been consistently 0% LEL, Dave clears the facility to resume operations after removing the pierced cylinder.
Obviously, these scenarios are simplified, but make the points of the difference between awareness, operations, and technician levels, and emergency vs. incidental spills.