In today’s climate of austere budgets, federal, state, local, tribal, and private sector training managers need to get the most out of the scarce dollars that are available. A risk-based approach and assessment will help discern who needs what training, the specific levels of that training, and refresher training requirements.
There is no reasonable expectation that every jurisdiction will be capable of doing everything – the resources are just not there. In light of this, communities must often pool or share resources on a regional basis to meet today’s all-threat/all-hazard environment.
One veteran hazardous materials (hazmat) responder once described weapons of mass destruction (WMDs) as “hazardous materials with attitude.” The basis for any effective training program that addresses response to either WMDs or chemical, biological, radiological, nuclear, and explosive (CBRNE) incident response is training in building a solid foundation in hazardous materials response. This basic training provides the basic concepts that will serve as critical building blocks for more advanced tactics, techniques, and procedures. There are two principle guidelines in use in the United States today on which to base specific hazardous materials training:
- The federal regulations – Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response Standard (HAZWOPER); and
- The internationally recognized voluntary consensus standard – Voluntary consensus standards managed through the National Fire Protection Association (NFPA), particularly NFPA-472.
The OSHA’s HAZWOPER can be found in 29CFR1910.120. Although initially published on 6 May 1990, these regulations have not been updated in over 25 years. The HAZWOPER regulations apply to five distinct response areas. The first four all fall under the training requirements set forth in 29CFR1910.120(e). The easy way to think of this is the “HAZWOP” portion of HAZWOPER. These training guidelines pertain to:
- Cleanup operations involving hazardous substances at uncontrolled waste sites;
- Corrective actions conducted at sites covered by the Resource Conservation and Recovery Act (RCRA) of 1976;
- Voluntary cleanup operations at sites recognized by governmental bodies as uncontrolled hazardous waste sites; and
- Operations conducted at treatment, storage, and disposal facilities regulated under 40CFR264-265 pursuant to RCRA or under agreement with the Environmental Protection Agency.
Personnel performing these tasks are referred to as “General Site Workers” and require 40 hours of initial training (colloquially called “40-Hour HAZWOPER”), three days of supervised “hands-on” training, and eight hours of refresher training annually. If the workers are performing a specific limited task or on work sites fully characterized with no hazardous substance levels above acceptable exposure limits, limited task, then 24 hours of initial training and one day of hands-on training is acceptable (the eight hours of annual refresher still applies).
Personnel performing tasks at transportation, storage, and disposal facilities that are dealing with RCRA waste also only need 24 hours of initial training (there is no hands-on training requirement, although the eight hours of annual refresher training applies). Training for site workers typically includes review of safety and health hazards associated with a particular site, use of personal protective equipment, work practices to minimize overall risk, engineering controls and equipment on site, medical surveillance requirements, and a review of the site safety and health plan. Managers and supervisors of these activities are required to attend an additional eight hours of training that covers topics such as the applicable safety and health program, personal protective equipment program, spill containment, and health monitoring. Finally, there is a provision for “equivalent training” if the employer can document work experience or training that meets this standard. A site-specific review is still required.
The last category of training requirements are listed in 29CFR1910.120(q) and apply to emergency response operations for releases (or substantial threat of releases) of hazardous substances, regardless of the location (this is the “ER” portion of HAZWOPER). There are five levels of training under the emergency response guidelines along with a designation of “specialist employee.” As CBRNE or WMD incidents are, by their very nature, emergency response operations, the following focuses on that portion of the regulation.
The first level, known as First Responder-Awareness (FRA), is for persons likely to witness an actual or potential hazardous materials incident and who can initiate notification procedures. No further actions are expected by personnel at the First Responder-Awareness level. There is no training time requirements associated with the First Responder-Awareness level. Training at this level includes:
- An understanding, recognition, and identification of what hazardous substances are, along with their associated risks;
- Potential outcomes associated with hazardous materials incidents;
- Roles and responsibilities of personnel trained at this level; and
- Notification requirements.
The next level is First Responder-Operations (FRO). These personnel are generally among those first responders to releases or potential releases of hazardous substances to protect life, property, and the environment. They operate in a defensive fashion, meaning that they do not actively try to stop the release, and attempt to control it from a safe distance and try to minimize the spread of the release. This is the level for most members of the fire service as well as specially trained personnel from law enforcement, emergency medical services (EMS), public works and engineering, and entities with similar response duties. A minimum of eight hours of training (above the First Responder-Awareness level) is required to complete this level of training and topics should include:
- Hazard and risk assessment techniques;
- Selection and use of personal protective equipment;
- Hazardous materials terminology;
- Basic containment, confinement, and control techniques;
- Decontamination procedures;
- Working understanding of chemical toxicology; and
- Incident termination procedures.
Hazardous Materials Technicians are personnel who respond with the actual intention of stopping the release, operating in a more aggressive fashion than those at the FRO level. These are personnel such as public safety hazardous materials response teams or industrial emergency response teams. They have a minimum of 24 hours training over and above the FRO level training. This training addresses:
- Implementation of a response plan;
- Classification, identification, and verification of unknown materials using field survey equipment;
- Operating with the incident command system;
- Use of personal protective equipment;
- Hazard and risk assessment techniques;
- Skills to perform advance control, containment, and confinement techniques;
- Decontamination techniques and procedures; and
- Termination of the incident.
Within 29CFR1910.120(q), Hazardous Materials Specialists support Hazardous Materials Technicians. They have specialized knowledge, typically of various substances (such as chlorine or ammonia). They can also serve as liaisons or agency representatives to governmental response and/or regulatory authorities. They have a minimum of 24 hours of additional training equal to or above that of the Hazardous Materials Technician. They need to:
- Know how to implement the local response plan;
- Be familiar with the state response plan;
- Understand how to select and use personal protective equipment;
- Know hazard and risk techniques;
- Be able to perform specialized control, containment, and confinement techniques;
- Know how to implement decontamination procedures;
- Know how to develop a site safety and health plan; and
- Have a working knowledge of chemical, radiological, and toxicological terminology and behavior.
On-Scene Incident Commanders are persons designated by the authority having jurisdiction to take management control of actual incidents. They need to be trained and current to at least the FRO level before being designated as On-Scene Incident Commanders. This additional training, at least 24 hours beyond the FRO level, should include:
- Details on how to implement and operate within their employer’s incident command system;
- Details on the emergency response plan as well as the local and state emergency response plans;
- Information on the hazards and risks associated with response operations in chemical protective clothing; and
- How to implement and direct decontamination operations.
The National Fire Protection Association (NFPA) is the internationally recognized body that develops voluntary consensus standards for the fire protection, safety, and emergency response communities. There are currently about 380 codes and standards maintained by the NFPA. The main advantage that these standards have over regulations such as 29CFR1910.120 is that they are not only more comprehensive in scope, but are updated on a far more regular basis, typically every four to six years, to provide for greater currency. Additionally, there are far more details on actual performance tasks to be demonstrated as part of NFPA-compliant training, some of which are exceptionally specific.
Another major difference is that NFPA-472 establishes no training hour requirements or durations. As a competency-based standard, it is entirely up to the authority having jurisdiction and training provider or authority having jurisdiction to establish the requirements for competency and certification. However, they need sufficient time to effectively cover the material. For example, the Hazardous Materials Technician course is often 80 hours in length, using the International Association of Fire Fighters curriculum. This extra time gives trainers more freedom to properly cover course materials while also giving the participants enough time to demonstrate knowledge and skills.
NFPA has several standards pertaining to hazardous materials response and weapons of mass destruction training, including:
- NFPA-472: Standards for Professional Competence of Responders to Hazardous Materials and Weapons of Mass Destruction Incidents
- NFPA-473: Standard for Professional Competence of EMS Personnel Responding to Hazardous Material Incidents
- NFPA-475: Recommended Practice for Responding to Hazardous Material Incidents/Weapons of Mass Destruction Incidents
- NFPA-1072: Standard for Hazardous Materials/Weapons of Mass Destruction Emergency Response Personnel Professional Qualifications
NFPA-472 forms the foundation for all of these, and this is the standard examined here. Like 29CFR1910.120, NFPA-472 has similar levels of training, from “First Responder at the Awareness Level” through “Incident Commander,” along with some additional ones. First Responder at the Awareness Level is for personnel who may discover actual or potential hazardous materials incidents, call for assistance, and isolate the area and deny entry until relieved by higher authorities. These personnel are expected to be able to:
- Detect the presence of actual or potential hazardous materials and weapons of mass destruction;
- Survey incidents from a safe location to identify potential hazardous materials and weapons of mass destruction;
- Collect hazard information; and
- Implement protective actions, such as evacuation or shelter-in-place.
The next level is First Responders at the Operations Level. These personnel are trained to respond to protect life, property, and the environment from an actual or potential release. In addition to meeting all of the requirements at the First Responder at the Awareness Level, all personnel at this level must be trained to meet specific competencies, including:
- Surveying for hazardous materials or weapons of mass destruction;
- Predicting likely behavior of a materials and its container;
- Collecting and analyzing hazard and response information;
- Estimating potential harm;
- Developing response objectives;
- Reviewing and selecting response options;
- Determining need for and use of personal protective clothing (chemical protective clothing and respiratory protection);
- Reviewing decontamination concerns;
- Establishing and enforcing scene control;
- Preserving evidence;
- Implementing the incident command system;
- Evaluating the progress of a response; and
- Communicating response status; and terminating the incident.
Unlike OSHA, the NFPA Technical Committee believes that First Responder-Operations should be the minimum level for hazardous materials responders. In addition, the Technical Committee believes that personnel should be trained to perform their assigned tasks as determined by the authority having jurisdiction – no more and no less. To meet this challenge, NFPA-472 also outlines mission-specific competencies for the First Responder-Operations level responder. They include:
- The use of personal protective equipment;
- Mass decontamination procedures;
- Technical decontamination procedures;
- Evidence preservation and sampling;
- Product control skills;
- Air monitoring and sampling;
- Victim rescue and recovery; and
- Response to illicit laboratory incidents.
Next is Hazardous Materials Technician, who are those persons who respond to hazmat/WMD incidents with the intention of controlling the release. These persons must meet the competencies at the First Responders at the Operations Level as well as the following:
- Surveying for hazardous materials and/or weapons of mass destruction;
- Collecting and interpreting hazard and response information;
- Describing the condition of a container involved in an incident;
- Predicting likely behavior of materials and their containers where multiple materials are involved;
- Estimating the likely size of an endangered area;
- Identifying response objectives and potential response outcomes;
- Selecting and using personal protective equipment (chemical protective clothing and respiratory protection);
- Selecting and implementing decontamination procedures;
- Developing and implementing a plan of action;
- Performing incident command duties;
- Conducting control functions identified in an incident action plan;
- Evaluating the effectiveness of control functions and decontamination efforts; and
- Terminating the incident (including assisting with a debrief/incident critique and documenting the incident.
Here is where NFPA diverges slightly from 29CFR1910.120. Rather than having Hazards Materials Specialists, NFPA recognizes the next level as “Hazardous Materials Technician with a Specialty.” Within the 2013 Edition of NFPA-472, these include specialties for tank cars (rail cars), cargo tank (tank truck), intermodal tank, marine tank and non-tank vessel, flammable liquids bulk storage facility, flammable gases bulk storage facility, and radioactive material. Additional specialties proposed by the NFPA-472 Technical Committee for inclusion in the 2018 update are currently under consideration. Each of these specialties has various competencies associated with them.
Incident Commander’s in NFPA are similar to their HAZWOPER counterparts in that they are persons designated to assume control of and manage incidents to a successful conclusion. Their competencies include:
- Collecting and interpreting hazard and response information;
- Estimating potential outcomes;
- Identifying response objectives and potential response outcomes;
- Approving the level of personal protective equipment;
- Developing and implementing an incident action plan;
- Implementing and working within the incident command system;
- Directing resources (both public sector and private sector);
- Serving as the focal point for information exchange with the media and elected officials;
- Evaluating incident progress;
- Transferring command and control and/or terminating the incident;
- Conducting a debrief and/or critique of the incident; and finally,
- Documenting the response.
Private Sector Specialist Employees are persons designated by their private sector employer to aid in a response (both onsite and offsite) by providing technical expertise to the authority having jurisdiction. These are the equivalent to the OSHA Specialist Employee and, under the National Incident Management System (NIMS), may be referred to as Technical Specialists. There are three levels, designated as Specialist Employee C, Specialist Employee B, and Specialist Employee A. Specialist Employee Cs work in the support/cold zone and are trained to the Awareness level. Specialist Employee Bs are trained to at least the Awareness level as well as to the Specialist Employee C level and may work in the hot/exclusion zone. Specialist Employee As are trained to at least the Awareness level as well as to the Specialist Employee B level. They are expected to be able to perform to the Hazardous Materials Technician level on their company’s property.
Finally, there are standards of competence for Hazardous Materials Officer and Hazardous Materials Branch Safety Officer, both of which are tactically oriented within the incident management system.
In today’s austere environment where training budgets are limited, those who oversee required training need to make some hard decisions on where to commit scarce resources. This simple concept is true for a Fortune 500 company or a small, municipal government. In order to best meet a jurisdiction’s needs, ask some basic questions:
- What tasks am I required (by law, regulation, policy, etc.) to do and to what level?
- Are my personnel trained and equipped to do these tasks? Are they current and proficient?
- If the answer is “No” to the second question, then what do I need to do to be in compliance with the laws, regulations, policies, etc. discussed in the first question?
Equipped with this knowledge, members of the public and private sectors can conduct training and gap analyses and review what they need to do to attain appropriate compliance. If no personnel will be entering a “hot zone,” then there is no need to go beyond the First Responder-Awareness Level described in 29CFR1910.120(q) for the vast majority of staff. There may be a need for a few at the First Responder-Operations Level to conduct some defensive actions and others at the On-Scene Commander Level, but that is generally sufficient for the vast majority of entities in the public and private sector.
Likewise, training managers for large municipal fire departments may need to ensure that their entire compliment of firefighters are trained to the First Responder-Operations Level as described in NFPA-472. All Chief Officers and other key field supervisors will likely be trained to the On-Scene Commander Level. Still more may be trained to the Hazardous Materials Technician or Specialist levels, based on the specific needs of the community.
A private sector response contractor may have to be more diverse. Personnel working on hazardous waste sites should be trained in accordance with 29CFR1910.120(e), while those who participate in emergency response activities should be trained to at least 29CFR1910.120(q). If the company specializes in a particular aspect of response, such as tank cars, then perhaps it would be appropriate to train emergency response personnel as Hazardous Materials Technician with a Tank Car Specialty as described in NFPA-472.
“CBRNE – Part 2” will look at more specific training requirements and opportunities for chemical and biological response training.
For additional information:
Hazardous Materials Managing the Incident, Fourth Edition (Noll and Hildebrand with Rudner & Schnepp).
Acknowledgement and thanks to Greg Noll, CSP, CEM, Mike Hildebrand, CSP, CFPS, CHMM, CAPT Ray Meyer, CEM (USCG, ret.), and Robert Bradley for their assistance in reviewing this article.
Joseph J. Leonard Jr.
CDR Joseph J. Leonard Jr. (USCG, ret.) is a 30-year veteran of the Coast Guard and is a Principal Consultant with the PENTA Consortium, LLC. He serves as the chair of the Greater Harris County Local Emergency Planning Committee and actively serves in the U.S. Coast Guard Auxiliary. He holds designations as a Master Exercise Practitioner, Master Continuity Practitioner, Certified Emergency Manager, Certified Homeland Protection Professional, and Certified Port Executive. He has a BA in History from the Virginia Military Institute and an MS in Engineering Technology from Murray State University.