Libro Fire Engineering HazMat Incidents Surviving The Initial Response

HAZARDOUS MATERIALS INCIDENTS:
SURVIVING THE INITIAL RESPONSE
Steven M. De Lisi
Disclaimer
The recommendations, advice, descriptions, and the methods in this book are presented solely for
educational purposes. The author and publisher assume no liability whatsoever for any loss or damage
that results from the use of any of the material in this book. Use of the material in this book is solely at
the risk of the user.
Copyright © 2006 by
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Library of Congress Cataloging-in-Publication Data

DeLisi, Steven M.
Hazardous materials incidents : surviving the initial response / by Steven M. DeLisi.
p. cm.
Includes bibliographical references.
ISBN-13: 978-1-59370-071-3 (hardcover)
ISBN-10: 1-59370-071-7 (hardcover)
1. Hazardous substances--Safety measures. 2. Incident command systems. I. Title.
T55.3.H3D447 2006
363.17--dc22
2006010310
All rights reserved. No part of this book may be reproduced, stored in a retrieval system, or transcribed in any
form or by any means, electronic or mechanical, including photocopying and recording, without the prior written
permission of the publisher.
Printed in the United States of America

1 2 3 4 5 10 09 08 07 06
Contents
Acknowledgements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii
1 Beyond the Rule of Thumb . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Chapter Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2 What Is a Hazardous Material?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Types of Hazardous Materials. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Code of Federal Regulations—Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
OSHA Hazard Communication. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
OSHA Hazardous Waste Operations and Emergency Response . . . . . . . . . . . . . . . . . . . . . . . . . 13
The Emergency Planning and Community Right-to-Know Act . . . . . . . . . . . . . . . . . . . . . . . . . 13
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Chapter Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3 The Role of First Responders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Who Are First Responders? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Suggested Roles for First Responders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
4 Planning for a Hazardous Materials Incident. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Emergency Planning and Reporting Requirements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Emergency Release Notification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Emergency Planning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
HAZARDOUS MATERIALS INCIDENTS: SURVIVING THE INITIAL RESPONSE
5 How Not to Become Part of the Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Dispatching Hazardous Material Incidents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Response and Arrival at the Scene . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
The Material, the Container, and the Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
Stages of a Hazardous Materials Incident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
Containers That Have Released Their Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
Containers with an Ongoing Release . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
Containers That Have Not Released Their Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
Defensive Actions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
6 Who First Responders Should Call to Get Help . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Learning the Characteristics of a Hazardous Material . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
Contacting Those Who Can Help . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
Support during a Hazardous Materials Incident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
7 Documents First Responders Can Use for Effective Decision Making. . . . . . . . . . . . . . . . . . . . . . 61

Emergency Response Guidebook . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
Material Safety Data Sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
Chemical and Physical Properties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
Health Hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
Obtaining a Material Safety Data Sheet . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69
Hazardous Materials Guide for First Responders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74
8 Identifying the Material . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75

The Name of the Material . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75
Four-Digit Identification Numbers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
Hazard Classes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78
Hierarchy of Material Identification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
viii
CONTENTS
9 Characteristics of Containers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85
General Characteristics of Containers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85
Special Characteristics of Containers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88
Temperature and Pressure of Materials Related to Container Storage . . . . . . . . . . . . . . . . . . . . . 94
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99
10 Evaluating the Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101

Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101
Weather . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103
Time of Day. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104
Taking Care of First Responders. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107
Chapter Questions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108
11 Defensive Actions for First Responders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

Preventing a Release . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110
Containing the Release of a Liquid. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 114
Containing the Release of Gases and Vapors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 121
Containing the Release of a Solid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123
Protective Actions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 124
Decontamination of First Responders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 132
12 Highway Transportation Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133

Characteristics of Labels and Placards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133
Use of Labels and Placards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 136
Display of Four-Digit Identification Numbers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 140
Use of the DANGEROUS Placard. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141
Interpreting Labels, Placards, and Markings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 142
Shipping Papers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144
Additional Highway Transportation Hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 149
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 151
ix
13 Railroad Transportation Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 153

Preparing for a Railroad Transportation Incident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 154
Responding to Railroad Transportation Incidents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 155
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 158
14 Fixed Facility Incidents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161

Responding to Fixed Facility Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161
NFPA 704 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 163
The Reality of Fixed Facility Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 166
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 168
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 170
15 “Routine” Hazardous Materials Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 171

Spills from Home Heating Oil Tanks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 172
Residential Carbon Monoxide Detectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 173
“Fuming” Trash Containers and Trash Collection Trucks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 174
Suspicious Odors in Buildings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 175
Defensive Fire Suppression Strategies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 176
Contaminated Patients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 177
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 180
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 181
16 Understanding Atmospheric Monitors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 183

Basic Operation of Atmospheric Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 184
Functional (Bump) and Full Calibrations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 185
General Use of Atmospheric Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 186
Readings as a Basis for Decision Making . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 187
Multiple Hazards during an Incident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 188
Potential for Inaccurate Readings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 189
Interpreting “Zero” Readings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 192
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 193
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 195
x
CONTENTS
17 Understanding Class B Foam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197

What Is Class B Foam?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197
Polar Versus Nonpolar Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 198
Types of Class B Foam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199
Producing Class B Foam Solutions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 201
Determining the Amount of Foam Needed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 204
Preplanning Foam Fire Suppression Capabilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 206
Applying Class B Foam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 210
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 211
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 213
18 Managing the Initial Phase of a Hazardous Materials Incident . . . . . . . . . . . . . . . . . . . . . . . . . 215

Command Structure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 215
Action Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 219
The Thinking Mode. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 219
The Action Mode. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 220
The Waiting Mode . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 222
Safe Work Practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 223
“What Are We Doing, and Why Are We Doing It?”. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 225
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 228
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 230
19 Is the Incident a Crime Scene? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 231

Detecting Possible Criminal Activity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 231
Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 233
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 235
20 Cleanup, Recovery, Reimbursement, and Scene Restoration . . . . . . . . . . . . . . . . . . . . . . . . . . . 237

Cleanup of a Hazardous Materials Incident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 237
Recovery of Vehicles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 239
Reimbursement for Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 240
Scene Restoration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 241
Key Points . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 243
xi
Appendix A Incident Command Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 245
Appendix B Hazardous Materials Warning Labels and Placards . . . . . . . . . . . . . . . . . . . . . . . . . . 247
Appendix C Acronyms and Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 249
Index. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 251
xii
1
BEYOND THE RULE OF T HUMB
The purpose of this book is to provide first responders with the knowledge and skills to safely
and effectively respond to incidents that involve hazardous materials. Some of these incidents
may require the assistance of personnel who are members of organized hazardous materials teams.
Other incidents may be managed safely by first responders with assistance from groups such as
environmental cleanup contractors, regulatory agencies, or those who manufacture, transport, or
use hazardous materials.
Regardless of the level of expertise of those who ultimately respond to a hazardous materials
incident, the first on the scene will usually be firefighter or EMS personnel who are not members
of a hazardous materials team. More than likely they have not received any highly specialized or
technical training related to hazardous materials. Yet these first responders are the ones who can
ultimately set the stage for the success or failure of the entire operation.
It is important to remember that while some hazardous materials incidents are catastrophic events
from the very beginning, many more start out as minor events and escalate only when something
goes terribly wrong. Quite often, first responders are dispatched to hazardous materials incidents
with limited or erroneous information. At other times, first responders may fail to recognize the
involvement of hazardous materials in what may appear to be a routine call. If they do identify
something suspicious, they may simply underestimate the potential threats to themselves, the public,
and the environment. These threats are not limited to those that can affect the health and safety of
first responders, but also include those that can embroil them in lengthy legal battles if their actions
are inappropriate.
During any hazardous materials incident, first responders can quickly become part of the
problem. This could include the following types of events:
• Rear-end collision involving two passenger vehicles
• EMS call at a residence for difficulty breathing
• Garage fire or shed fire
• Trash fire
• Car fire
Most departments would not dispatch these calls as hazardous materials incidents. Yet what may
appear to be a relatively minor motor vehicle accident involving two cars takes on a whole new meaning
when a clear liquid with a pungent odor is discovered leaking from the trunk of one of the vehicles.
Likewise, first responders dispatched to an EMS call involving a patient with difficulty breathing at a
private residence may discover the patient’s medical problems are related to exposure to a pesticide during
routine yard maintenance. And perhaps an effort to extinguish what appears to be a small trash fire on a
vacant lot results in a violent reaction when water is applied.
What should a first responder do? When asked about their strategy for dealing with any incident
that could involve hazardous materials, many first responders use the so-called Rule of Thumb. This rule
suggests that when first responders can cover the view of the incident with a thumb, they are far enough
away. This approach may work well for major events when it is known that hazardous materials are
involved or there are clues to warn first responders of impending danger. Yet the reality is that many more
incidents involving hazardous materials are dispatched as routine events that offer few clues, if any, to first
responders. These can be difficult to distinguish from other types of incidents.
Does this mean that when responding to every EMS call, car fire, or trash fire that a first responder
must park his apparatus down the street, raise his thumb, and proclaim, “This is all I need to know about
hazardous materials”? One hopes not.
Should first responders instead aggressively approach every incident? No, they should not. Rather, they
must temper their natural aggressive tendencies that cause them to rush into every scene with an answer
for all occasions. This tendency must be weighed against the stay-far-away and paralyzed mentality all too
often associated with the Rule of Thumb.
The solution is to move beyond the Rule of Thumb. First responders should instead approach all
incidents with a level of concern that anticipates the involvement of hazardous materials and recognizes
the potential problems these materials can cause. They can then determine appropriate actions that will
achieve a positive outcome. Whenever possible, the first responder should take care not to become part
of the problem or make the problem worse. Rather, the first responder should know who to call for help
and how to reach them.
What if the first responder responds to a report of an overturned cargo tank or a train derailment?
Would it be a good idea to stay back from the incident? It probably would be, especially if the first
responder wants to go home alive. However, those who simply apply the Rule of Thumb to these types of
incidents may assume their role is to do nothing until help arrives. Moving beyond this rule allows a first
responder to make effective decisions during even catastrophic events and take actions that can make a
difference, while minimizing personal exposure.
What if the first responder responds on a call to a residence where a mercury thermometer or a bottle
of pesticide concentrate has been broken, or a container of muriatic acid has leaked? Perhaps a citizen
brings a box of old chemicals to a fire station for disposal, or what appears to be a pipe bomb is discovered
while overhauling a trash fire.
2
BEYOND THE RULE OF THUMB
What does a first responder do when several containers of caustic swimming pool cleaner stored in the
back of a pickup truck break open when the vehicle strikes a tree? What if he does not realize they have
been contaminated with some of these chemicals until after the occupants of that vehicle are loaded into
the ambulance? What does he do when arriving on scene of an EMS call for a “man down” to discover
three people unconscious in the building, with no obvious signs of trauma?
How should a first responder handle a commercial vehicle fire that “blows up” when water is
applied? How should he handle a fire that involves numerous discarded tires, or a spill fire that involves
flammable liquids?
How does a first responder handle a red bag with suspected medical waste found on the side of
a highway? Should he look inside? What if he is dispatched to a report of a suspicious container or
substance in the middle of the road? All fire department and EMS personnel will be dispatched to these
types of incidents at some point in their careers.
How should a first responder handle a gas leak? Just what kind of gas is leaking? Chances are the
dispatcher does not know, and neither will the responder until arriving on the scene. A first responder
cannot assume anything!
During a hazardous materials incident, moving beyond the Rule of Thumb means that what the first
responder does becomes as important as what he does not do. The first responder’s success depends upon
his level of planning before an incident, his training, and his ingenuity. It also depends on the capabilities
and limitations of any equipment available to him, and his ability to use this equipment correctly. Much
attention has been paid to state-of-the-art response equipment, such as sophisticated chemical detection
devices, decontamination shelters with heated water, and chemical protective suits. Even so, the reality
is that this equipment will rarely arrive with the first responder. Instead, he likely will be assigned to an
engine, tanker, ladder truck, or ambulance with very little hazardous materials (HAZMAT) gear.
Moving beyond the Rule of Thumb also means that first responders should never feel obligated to
have an answer for every occasion. Instead, first responders must accept the fact that they most likely
lack the experience and training to handle all hazardous materials incidents safely. Therefore, any action
undertaken without first consulting those with the necessary experience and perhaps the legal authority
to make defensible decisions could come back to haunt the first responder, despite his best intentions.
First responders should remember that it is acceptable to say, “I don’t know, but I do know who to call
for help.”
Throughout this book, first responders can learn to become part of an effective system for managing
hazardous materials incidents. This will include planning, initial response considerations, risk assessment,
defensive practices, incident management, and cleanup. They will also discover the reality about numerous
assumptions and myths related to hazardous materials response that plague first responders. They will learn,
as well, just how the many rules and regulations intended to ensure the safe handling and transportation
of hazardous materials are applied in the real world. In addition, readers will find suggestions to deal with
common problems, including misleading dispatch messages. They will also learn how to deal with difficulties
in contacting those who ship and manufacture chemicals when more traditional measures fail to work.
Additional suggestions include how to make the best use of equipment normally carried on fire apparatus in
order to successfully deal with a hazardous materials incident, and how to improvise when necessary.
3
A firefighter once referred to a hazardous materials

An engine company was incident as boring, almost like watching paint dry. The
dispatched in predawn hours explanation was that once the first responders determine
that the incident requires additional assistance, they
to a trash fire. Upon arrival, first often wait for the hazardous materials team to arrive
responders discovered a small on the scene. Next they wait for the team to make an
entry and complete their mission, and then wait for a
fire at the curb in front of a single- cleanup contractor.
family residence. Attempts at While this statement may oversimplify the world
of hazardous materials response, the firefighter failed
using water to extinguish the fire to realize an important point. The extent to which
were met with what appeared to be the incident was boring was dependent in large part
on what first responders did or did not do upon their
small explosions. First responders arrival. The fact that the first responder was able
retreated to safety. They soon to make such a statement, rather than being dead,
injured, or contaminated as a result of exposure to
discovered that other homeowners the hazardous material, spoke highly of his skill level.
First responders have the opportunity to make every
in the same block had placed hazardous material incident exciting. They just may
their large plastic trash cans for not like the outcomes.
pickup later that day and that the Again, whenever possible, a first responder does
not become part of the problem and does not make
“trash fire” was actually a burning the problem worse. But he does know who to call
trash can that had transformed for help.
into a pool of molten plastic, thus

leading to the reaction when water
was applied. The homeowner later
admitted to disposing of hot coals
from a cooking grill into the trash.
4
BEYOND THE RULE OF THUMB
Key Points
• First responders can encounter hazardous materials during any incident.
• First responders will rarely have sophisticated HAZMAT gear on their apparatus. Instead,
they will usually need to improvise using standard firefighting equipment.
• First responders are part of a larger system required to manage hazardous materials incidents
safely and effectively.
• It is acceptable for first responders to say, “I don’t know, but I do know who to call
for help.”
• The actions of first responders should never cause them to become part of the problem.
5
Chapter Questions
1. What is meant by the phrase “beyond the Rule of Thumb”?
2. List ten household hazardous materials that could be stored in a garage at a residence or
that could be discarded in household trash.
3. List ten household hazardous materials that, if used improperly, could result in personal
injury. For each item, include a likely mechanism of injury.
4. List five initial actions that first responders should undertake once they know or suspect
that hazardous materials are involved in an incident.
5. List the types of HAZMAT gear (such as atmospheric monitors, granular absorbents, or
Class B foam) that is provided to those assigned to fire suppression companies in the
community. Have first responders received training on this equipment?
6
2
WHAT IS A HAZARDOUS MATERIAL?
For first responders, a hazardous material can be defined as anything that can harm people,
property, or the environment. These materials may be present in various forms, including liquids,
solids, gases, vapors, fumes, and mists, and they can include chemicals, radiological materials, and
biological agents. Despite volumes of regulations and safeguards designed to prevent mishaps,
hazardous materials incidents do occur, and they can include situations that involve the transportation,
handling, use, and storage of these materials. As such, the potential for exposure to these products
with subsequent loss of life, significant personal injury, and serious environmental impacts is a daily
threat. Of sometimes greater concern is that the negative effects of exposure to hazardous materials
can remain seemingly dormant for years. However, these effects may appear later with devastating
consequences that include fatal human illnesses or the elimination of an entire animal species.
With this frightening potential, some might ask if the hazards posed by chemicals, radiological
materials, and biological agents used today are worth the risk. In an effort to answer this question,
one should consider that on a good day, hazardous materials that are used and stored properly
generally provide for a vast number of products and services. These products and services help
define the quality of life all of us have come to expect.
Virtually all aspects of everyday life are in some way dependent upon materials with inherent risks
to people, property, and the environment. This includes information technology, transportation,
agriculture, clothing, building construction, health care, and communications. Consumers are
forced to accept these risks in order to reap the desired benefits. Some may argue for better or safer
alternatives to hazardous materials. However, the unfortunate reality is that economic and political
factors all too often influence the use of products that are more profitable rather than safer.
On a bad day, problems arise for first responders when hazardous materials are released from their
containers in an undesirable manner. The result is that people, property, and the environment could
be exposed to situations where there may be a zero tolerance for contamination (such as oil spilled
into environmentally sensitive areas). They may also be exposed to quantities that exceed what has
previously been determined as acceptable exposure limits by various regulatory or research agencies.
These undesirable releases from containers may be the result of accidents, improper maintenance,
or intentional acts of sabotage or even terrorism. There may also be situations when first responders
are faced with containers that have not yet released their contents, but have the potential to do so
as a result of damage. This damage could be from excessive heat, a blow by a foreign object, or a chemical
reaction inside the container that threatens the container’s integrity.
Knowledge of the extent to which any hazardous material can cause harm when released from its
container in an undesirable manner is often dependent upon prior research conducted by any number
of individuals. These may be the people who manufacture, use, or transport the material, or research
organizations that study the effects of exposure. They may also be regulatory agencies whose responsibility
it is to provide guidelines for the safe storage, transport, and use of a material.
First responders should never forget that defined exposure limits and the results of research on the
effects of exposure to chemicals can change during the course of several years. This can result in a serious
dilemma for those exposed to a material once believed safe when they suddenly learn that this same
material now presents significant risks.
Governmental regulatory agencies give rise to terms such as hazardous material, hazardous chemical,
hazardous substance, and hazardous waste. One should be aware, however, that there are serious limits
and precise criteria that determine the extent to which these agencies regulate and define hazardous
materials. As a result, materials that do not meet any established definitions may not be regulated as
hazardous, yet there may still be potential for harm. Suffice it to say that regulatory agencies are subject to
political and economic influences, and that these influences may not necessarily be in the best interest of
first responders.
First responders must never be lulled into a false sense of security when told that a material is not
hazardous. Just what does a statement such as that mean to the first responder? It may mean only that
the material is not regulated by any government agency, since it does not meet any of the available
defining criteria.
As for materials that are regulated, it may be difficult to immediately identify the degree or extent of
hazard present, since different agencies use different criteria to define the term hazardous. In addition,
products that meet multiple definitions for hazardous characteristics may be regulated only on the basis
of what a regulatory agency defines as the highest threat.
As an example, gasoline is defined by the Code of Federal Regulations governing transportation as a
flammable liquid when transported in commerce. There is no mention of its health hazards, although
exposure to extremely low levels of gasoline vapors can be harmful, not to mention the potential health
risks from ingestion of even a small amount of the liquid.
Likewise, peanut oil and milk are edible foodstuffs that are not regulated for transportation as
hazardous materials. Yet an incident involving a highway cargo tank carrying either of these items that
overturns and releases its contents into a body of water such as a creek, pond, or sewer system has the
potential to create significant environmental harm.
In addition to legal definitions, one should remember that any attempt to define a hazardous material
should also consider its form, whether liquid, gas, solid, vapor, mist, or dust. While liquids and solids may
at first appear to present limited threats beyond a localized area, vapors from liquids and dusts from solids
can create potential inhalation and fire hazards, sometimes far from the source of the release.
8
A first responder is responsible for protecting himself and the public. The only way that he can
determine the extent to which a material released from its container can harm people, property, or the
environment is to evaluate its hazardous characteristics using all available resources. These resources include
material safety data sheets (MSDS), contacts with a chemical manufacturer or shipper, and representatives
from local, state, and federal regulatory agencies. Medical professionals, especially those from government
health departments and even poison control centers, can offer valuable information when first responders
are attempting to determine the extent to which a material is hazardous.
The persons responsible for the release of any material or those who are in possession of the container
from which the release originates are usually referred to as the responsible party. First responders should
always remember that some responsible parties will have an interest in downplaying the severity of an
incident. While most will attempt to assist first responders in their efforts to resolve the incident, some
may claim that the situation is “no big deal.” In order to do so, they may use the fact that the product
released is not regulated as a hazardous material and is therefore not dangerous. These same individuals
may also make statements such as, “We work with the material all the time and have never had any
problems from exposure.” Of course, they may conveniently ignore the reality of delayed health effects.
Under these circumstances, first responders must be extremely careful, and they should never forgo
their obligation to protect themselves and the public. First responders are the ones who will likely be held
responsible if a decision that a material is not hazardous goes bad, not the responsible party. Thus the first
responder should get plenty of help when making this decision. Certain government officials may also
have a legal responsibility in assessing the incident. Furthermore, property owners will be very interested
in speaking to individuals who make the decision of whether a material released on their property was
hazardous or not.
A first responder might decide what actions to take for dealing with any material released from its
container on the basis of limited information, such as using only the defining criteria from one regulatory
agency. He might forget that materials such as liquids and solids can produce vapors and dusts, respectively.
Also, he might listen to the guy who owns a leaking tank truck that is upside down in the middle of
the road, running the risk of believing statements such as, “There is nothing to worry about.” For first
responders, there may be plenty to worry about.
For the purposes of this book, all materials that could potentially harm people, property, or the
environment are referred to collectively as hazardous materials. Although this term is often associated
with precise legal definitions, its use here is simply a matter of convenience, and it has become part of the
jargon of first responders.
Definitions include those found in the Code of Federal Regulations as well as those promulgated by
individual states, all of which influence the transportation of hazardous materials, workplace exposure,
and the environment. Prior to a review of these legal definitions, it is useful for first responders to become
familiar with the various types of hazardous materials they may encounter.
9
Types of Hazardous Materials

The following definitions are excerpts from The Common Sense Approach to Hazardous Materials,
written by Frank L. Fire and published by PennWell. As stated by Mr. Fire, the book “is written so that
when you do encounter a hazardous material, you will recognize it as such and also recognize the hazard
class to which it belongs.”1 First responders are encouraged to refer to this text for additional information
regarding the nature of hazardous materials.
Explosives. An explosive is a material or device created specifically to explode on demand. An explosion
is a sudden, violent release of mechanical, chemical, or nuclear energy from a confined region.2
Compressed gases. Compressed gases have certain hazards associated with them. No one particular
gas poses all the following hazards, but many of them pose more than one hazard. These include hazards
associated with being under pressure, flammable, unstable, toxic, corrosive, and oxidizing agents.3
Flammable and combustible liquids. A flammable liquid is a liquid with a flash point below 100ºF.
A combustible liquid is a liquid with a flash point of 100ºF or higher. Flash point is the minimum
temperature of the liquid at which it gives off vapors sufficient to form an ignitable mixture with the
air near the surface of the liquid or the container. The controlling factor in considering flashpoint is the
temperature of the liquid itself. The sun or the presence nearby of some other heat source radiating energy
may have heated the liquid or its container, which will pass the heat along to the liquid.4
Flammable solids. A flammable solid is any solid material, other than an explosive, that is likely
to cause fire through friction or through retained heat from manufacturing or processing, or that can
be readily ignited. When ignited, it burns vigorously and persistently.5 Some flammable solids may be
water reactive.
Oxidizers. An oxidizing agent is a substance containing oxygen that gives it up readily. Oxidizing
agents readily decompose to yield oxygen when heated and therefore may react easily with other hazardous
materials. Because of oxidizing agents’ ability to provide oxygen when heated, their hazard is greatly
increased at higher temperatures. There may even be very violent reactions when they are intimately
mixed with ordinary combustible materials.6
Poisons. A poison is any substance that causes injury, illness, or death to living tissue by chemical
activity. These materials enter the body in one of four ways: inhalation, ingestion, absorption through the
skin, and entry through a wound. The method of entry may determine how rapidly the poison produces
its effects.7
Radioactive materials. Ionizing radiation involves particles traveling in wavelike motions. When these
particles or rays collide with matter, the particles of that matter’s atoms with which they collide are the
electrons. When the particles collide with an electron, the tendency is to remove that electron from the
atom, thus leaving a particle that is now an ion. This is where the term ionizing radiation originates.
Whenever an ion is created, it must have another ion of electrically opposite charge with which to react.
However, if the ion created by the collision of a radioactive particle is within a molecule of living tissue
inside the human body, it is trapped there and cannot seek another ion with which to react. This causes
changes within the human body to accommodate this unnatural presence. The changes that occur, if they
grow large enough and are plentiful enough, cause radiation sickness and/or cancer and eventually death.8
10
Corrosives. A corrosive is any material that will attack and destroy by chemical action any living tissue
with which it comes in contact. Even if there is no direct contact between a human and the corrosive
material, the chemical action on steel or any other material can have serious consequences for people.
This could occur due to the catastrophic collapse of a structure because of corrosion, or from the toxic
by-products of a chemical reaction between a corrosive material and some other material.9
Code of Federal Regulations—Transportation

In the Code of Federal Regulations governing transportation, 49 CFR 171.8 defines a hazardous
material in part as, “A substance or material that the Secretary of Transportation has determined is capable
of posing an unreasonable risk to health, safety, and property when transported in commerce.”10 Many of
these materials are assigned to one of nine hazard classes on the basis of definitional criteria that include
characteristics such as flash point, inhalation or oral toxicity, or the ability of a liquid or solid to cause “full
thickness destruction of human skin at the site of contact within a specified period of time.”11
It is vital for first responders to understand that the transportation regulations generally apply only
to those materials that meet these specific definitional criteria, and then only when these materials are
“transported in commerce.” There are many more materials and products not addressed by the transportation
regulations that can still pose potential hazards to first responders during a transportation mishap.
In addition, materials considered hazardous for the purposes of transportation may not be identified
with transportation labels, placards, or markings when used or stored at a fixed facility. Therefore, first
responders must use caution when attempting to associate the absence of a label, placard, or marking with
the absence of a hazard.
According to the 49 CFR 171.8, the term hazard class means “the category of hazard assigned to a
hazardous material.” Hazard classes and their associated hazard class number as assigned by the federal
transportation regulations include the following:
1. Explosives
2. Gases
3. Flammable and combustible liquids
4. Flammable solids, spontaneously combustible materials, and dangerous when wet materials
5. Oxidizers and organic peroxides
6. Poisonous materials and infectious substances
7. Radioactive materials
8. Corrosive materials
9. Miscellaneous hazardous materials
It is important to note that “a material may meet the defining criteria for more than one hazard class, but
is assigned to only one hazard class” (italics added).12 This is done using a predetermined criterion known
11
as the Precedence of Hazard Table found in 49 CFR 173.2(a). This assigned hazard class is also referred
to as the primary hazard, while any additional dangers are generally referred to as subsidiary hazards. This
may sound like nothing more than a bureaucratic word jumble. However, one should remember that for
the purposes of the transportation of hazardous materials, the transportation regulations determine the
defining criteria for primary and subsidiary hazards. These definitions subsequently influence the amount
of information made available to first responders through labels, placards, and markings. Only in limited
circumstances will information on subsidiary hazards be displayed.
For example, consider that while gasoline is an obvious flammable liquid, it is also harmful if ingested.
Yet, according to the Precedence of Hazard Table, the primary hazard of gasoline is its flammability rather
than its health hazard. As such, first responders will not receive any warnings from labels or placards
regarding the latter threat.
The same holds true for materials classified as corrosive. For some, in addition to their potential
to destroy living tissue, they may also have the characteristics of an oxidizer with the ability to readily
decompose and yield oxygen. However, being classified only as a corrosive material may lead first
responders to erroneously conclude there are no other hazards present. It may cause them great surprise
when these oxidizing characteristics suddenly make themselves known, perhaps as the result of a serious
chemical reaction. First responders must therefore always use caution when assessing the potential harm
from a hazardous material classified by the transportation regulations. They must anticipate that subsidiary
hazards may exist and take the necessary precautions until additional information regarding the material
is obtained.
Items designated as Class 9, or miscellaneous hazardous materials, present a unique challenge to first
responders. These materials are those “which present a hazard during transportation but which do not
meet the definition of any other hazard class.”13 For example, these materials could include those with
“noxious or other similar properties which could cause extreme annoyance or discomfort to a flight crew
member so as to prevent the correct performance of assigned duties.”14 It is important to remember that
these same properties could affect first responders as well!
OSHA Hazard Communication

The Occupational Safety and Health Administration (OSHA) Standard 29 CFR 1910.1200 entitled
“Hazard Communication” uses the term hazardous chemical, which is defined as “any chemical which is
a physical hazard or health hazard.”15 Physical hazards, as defined by the standard, include “chemicals
for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive,
flammable, organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water reactive.”16 Health
hazards mean a “chemical for which there is statistically significant evidence based on at least one study
conducted in accordance with established scientific principles that acute or chronic health effects may
occur in exposed employees.”17
It should be noted that the requirements of 29 CFR 1910.1200 apply to “any chemical which is
known to be present in the workplace in such a manner that employees may be exposed under normal
conditions of use or in a foreseeable emergency” (italics added).18 Therefore, an employer at a fixed
12
facility is not required by the OSHA Hazard Communication Standard to provide a first responder with
an MSDS, since he is not an employee of that facility.
Whether regulations govern transportation or the workplace, the legal definitions used for hazardous
materials will influence the format as well as the amount of information made available to first responders.
OSHA Hazardous Waste Operations

and Emergency Response
OSHA Standard 29 CFR 1910.120 is entitled “Hazardous Waste Operations and Emergency
Response.” In this standard, first responders can find direction for “emergency response operations for
releases of, or substantial threats of releases of, hazardous substances without regard to the location of the
hazard.”19 This regulation, which includes training standards for first responders as well as requirements
for on-scene emergency operations, uses the term hazardous substance. This term has several definitions,
including “any substance listed by the U.S. Department of Transportation as hazardous materials in 49
CFR 172.101.”20 When referring to this particular definition, first responders should remember that the
substances listed in 49 CFR 172.101 include only those materials “which the Department [of Transportation]
has designated as hazardous materials for the purposes of transportation” (italics added).21
An additional definition for the term hazardous substance includes “any biologic agent and other
disease causing agent which after release into the environment and upon exposure, ingestion, inhalation,
or assimilation into any person, either directly from the environment or indirectly by ingestion through
food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities,
cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or
physical deformations in such persons or their offspring.”22 While this particular definition of a hazardous
substance appears to encompass many different hazardous materials, one must remember the earlier
warning found in this chapter. The results of research on the known effects of exposure to chemicals and
related exposure limits can change. Some materials not considered to be hazardous substances today could
suddenly become classified as such tomorrow.
The Emergency Planning and Community

Right-to-Know Act
Under the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), owners or
operators of facilities that use certain chemicals are required to submit copies of MSDS to local emergency
planning committees and fire departments with jurisdiction for the facility.
This law uses the term hazardous chemical and defines this term using the same reference found
earlier in the OSHA Hazard Communication Standard. But it then adds exceptions to the definition.
These include “any food, food additive, color additive, drug, or cosmetic regulated by the Food and Drug
13
Administration” and “any substance present as a solid in any

A large dump trailer traveled manufactured item to the extent exposure to the substance
down an embankment resulting does not occur under normal conditions of use.”23
in the loss of its entire load. Additional exceptions to the EPCRA definition
for hazardous chemicals include “any substance to the
The spilled material consisted extent it is used in a research laboratory or a hospital or
of a granular substance used other medical facility under the direct supervision of a
technically qualified individual.”24 It also includes “any
as a food additive for livestock, substance to the extent it is used in routine agricultural
and the driver reported that the operations or is a fertilizer held for sale by a retailer to the
ultimate customer.”25
material was not hazardous. The
As with previous definitions of hazardous materials
owner of the truck confirmed that use precise criteria, the impact of exceptions to the
the material was not a regulated definition of the term hazardous chemical in EPCRA is to
reduce the number of materials covered by the law. As such,
hazardous material and he it reduces the frequency with which owners or operators of
therefore expressed an interest facilities that use certain chemicals are required to submit
copies of MSDS to local emergency planning committees
in hiring a local contractor to and fire departments with jurisdiction for the facility.
remove the material with a Using nothing more than local, state, or federal
front-end loader. However, the regulations that include precise definitions with a narrow
focus has the potential to surprise first responders who put
material safety data sheet for their full faith in these definitions when determining the
the product revealed that it was seriousness of an incident. Failure to thoroughly explore
the potential harm posed by hazardous materials, regulated
capable of producing severe eye or not, may leave the first responder with little defense.
irritation, including burns to the First responders must always remember their
cornea. Despite the owner’s responsibility to make the determination of whether a
material is actually hazardous to themselves and to their
claim that the substance was community, and to get plenty of help when making
not a hazardous material, a this decision. The results of making uninformed
decisions involving hazardous materials could have
cleanup contractor was hired serious consequences.
to remove the product using a
vacuum truck equipped with a
high-efficiency air filter, thereby
minimizing the potential for
personal injury.
14
Key Points
• Hazardous materials are those things that can harm people, property, or the environment.
• Undesirable releases of hazardous materials can expose first responders to dangerous
consequences during any incident. The effects of exposure can be immediate or delayed.
• First responders should be the ones to determine if a material that is released from its
container has the potential to harm themselves or their community.
• It is important for first responders to know the general characteristics and effects of
different types of hazardous materials.
• Materials that are not regulated as hazardous materials can still harm first responders.
• Some hazardous materials are defined and regulated only on the basis of their primary
hazard. There may be additional (subsidiary) hazards that could harm first responders.
• U.S. Department of Transportation regulations apply only when hazardous materials are
being “transported in commerce.”
• The OSHA Hazard Communication Standard provides safeguards for employees in
the workplace and defines a hazardous chemical on the basis of its physical hazards and
health hazards.
• The OSHA Hazardous Waste Operations and Emergency Response Standard uses the
term hazardous substance.
• The Emergency Planning and Community Right-to-Know Act of 1986 requires owners
or operators of facilities that use certain chemicals to submit copies of MSDS to local
emergency planning committees and fire departments.
• Definitions of hazardous materials will influence the amount of information provided to
first responders as well as when this information is available and in what form.
15
Chapter Questions
1. Explain why a person responsible for the release of a hazardous material or someone
who works with a chemical on a regular basis may not appear to be concerned about its
negative effects.
2. Who is responsible to determine if a material is hazardous, and who should be contacted
when making this determination?
3. What three forms of energy can be released during an explosion?
4. Identify three potentially hazardous characteristics of compressed gases.
5. Define the term flash point.
6. According to the information provided in this chapter, a flammable liquid is a liquid with
a flash point below ________ºF.
7. Identify four means by which a hazardous material can enter the human body.
8. What is meant by the term ionizing radiation?
9. Define the term hazard class according to 49 CFR.
10. How many hazard classes are listed in 49 CFR?
11. What is the difference between a primary hazard and a subsidiary hazard?
12. Identify two definitions for the term hazardous substance as found in OSHA Standard
1910.120.
13. How is the term health hazard defined in OSHA Standard 1910.1200?
14. How is the term physical hazard defined in OSHA Standard 1910.1200?
15. Define the term hazardous chemical as found in the Emergency Planning and Community
Right-to-Know Act of 1986.
16
References
1 Fire, Frank L. The Common Sense Approach to Hazardous Materials. New Jersey: PennWell Publishing, 1996, p. xv.
2 Ibid., p. 307.
3 Ibid., pp. 157–158.
4 Ibid., pp. 126–128.
5 Ibid, p. 175.
6 Ibid., p. 199 - 200.
7 Ibid., pp. 271–272.
8 Ibid., p. 295.
9 Ibid., p. 235.
10 Code of Federal Regulations. 49 CFR § 171.8, http://www.myregs.com/dotrspa/.
11 Code of Federal Regulations. 49 CFR § 173.136(a), http://www.myregs.com/dotrspa/.
12 Code of Federal Regulations. 49 CFR § 171.8, definition for “hazard class,” http://www.myregs.com/dotrspa/.
14 Ibid.
15 Code of Federal Regulations. 29 CFR § 1910.1200(c), http://www.osha.gov.
16 Ibid.
17 Ibid.
18 Code of Federal Regulations. 29 CFR § 1910.1200(b)(2), http://www.osha.gov.
19 Code of Federal Regulations. 29 CFR § 1910.120(a)(1)(v), http://www.osha.gov.
20 Code of Federal Regulations. 29 CFR § 1910.120(a)(3), http://www.osha.gov.
22 Code of Federal Regulations. 49 CFR § 1910.120(a)(3), http://www.myregs.com/dotrspa/.
23 U.S. Code, Title 42, Chapter 116, Subchapter II, Section 11021(e).
24 Ibid.
25 Ibid.
17
3
T HE ROLE OF F IRST RESPONDERS
Just what is the role of first responders during a hazardous materials incident? A lot depends
upon if the first responder is one of the first units to arrive on scene or perhaps the only unit to
respond. The first responder’s role may change significantly if a hazardous materials response team is
on-site, and the first responder is assigned to a support function. But chances are, at some point in a
first responder’s career, he will be first on the scene of an incident that involves a hazardous material.
What should the first responder do in this situation?
The roles of first responders and their related training levels have been defined in part by federal
occupational safety and health regulations. The Occupational Safety and Health Administration
(OSHA) Standard 29 CFR 1910.120, entitled “Hazardous Waste Operations and Emergency
Response,” describes the actions of first responders according to various levels. For example, at the
Awareness level are first responders “who are likely to witness or discover a hazardous substance
release and who have been trained to initiate an emergency response sequence by notifying proper
authorities of the release.”1
At the Operations level are first responders “who respond to releases or potential releases of
hazardous substances as part of the initial response to the site for the purpose of protecting nearby
persons, property, or the environment from the effects of the release. They are trained to respond
in a defensive fashion without actually trying to stop the release. Their function is to contain the
release from a safe distance, keep it from spreading, and prevent exposures.”2
The next higher level, Technician, is intended for individuals who are trained to “respond to
releases or potential releases for the purpose of stopping the release. They assume a more aggressive
role than a first responder at the operations level.”3 The standard also includes reference to a Specialist
level, or those who “respond with and provide support to hazardous materials technicians.”4
Most firefighter and EMS personnel assigned to traditional engines, ladders, rescue vehicles, and
ambulances are not trained or equipped with sophisticated hazardous materials response tools in
order to function at the Technician or Specialist levels. As such, Technician and Specialist levels of
training are typically reserved for members of organized hazardous materials teams who have their
own equipment and operate their own vehicles.
Despite a lack of specialized hazardous materials equipment, most first responders should still
be trained to at least the Awareness level, preferably the Operations level. They should be capable of
using the equipment normally available on their assigned apparatus for the “purposes of protecting nearby
persons, property, or the environment from the effects of the release and to contain the release from a safe
distance, keep it from spreading, and prevent exposures.”5
When determining if the emergency response training requirements of 29 CFR 1910.120 apply to
all employees, first responders must remember the federal environmental protection regulations found
in 40 CFR 311.1. These regulations state, “The substantive provisions found at 29 CFR 1910.120 …
apply to State and local government employees engaged in hazardous waste operations, as defined in 29
CFR 1910.120(a), in States that do not have a State [OSHA] plan approved under section 18 of the
Occupational Safety and Health Act of 1970.”6
In determining just who is a “government employee,” 40 CFR 311.2 states that an “employee is defined
as a compensated or non-compensated worker who is controlled directly by a State or local government.”7
Who Are First Responders?

This book refers to firefighters and EMS personnel who are not members of a hazardous materials
team as first responders. The actions of first responders may be defensive and lack the excitement of making
a dangerous entry to repair a leaking valve on a rail tank car while wearing a fully encapsulating chemical
protective suit. However, first responders must never forget that as the ones who are usually first on scene,
they often set the stage for the success or failure of the entire operation, long before a hazardous materials
team ever arrives.
Suggested Roles for First Responders

In order for first responders to fully understand the concept of defensive operations, they should
remember that the process of containing a release may be passive or active. Sometimes the first responders
may need to do something, such as build a temporary containment barrier, while at other times they may
just need to close the door to a room or building or just stay back. The decision to intervene and the
extent to which the first responder does so should take into consideration not just the resources available
at the moment, but also the extent of a release and whether the actions will really make a difference. The
first responder must always remember that any active intervention (including his natural curiosity) has
the potential to expose him to a hazardous material.
20
THE ROLE OF FIRST RESPONDERS
Of course, before first responders can even consider containing a release from a safe distance, they
must first take other important actions, including:
• Identifying the material(s) involved and assessing potential for harm
• Isolating affected areas and denying entry to others
• Accounting for all personnel who may have been exposed to the material
• Providing medical care and decontamination to those exposed
• Protecting persons from potential for exposure (including other first responders)
Remember, if at all possible, these tasks must be accomplished without exposing the first responder
to any of the materials that have been released or that have the potential for a release. Furthermore, a first
responder has a responsibility to maintain vigilance to avoid being drawn into complacency and to believe
that a spilled material is not hazardous or that material in abandoned drums is “just oil.” This complacent
attitude will likely affect a first responder’s actions on scene. If he does not realize that a product is
hazardous until after he has been on the scene for awhile, someone is probably going to the hospital.
While the need for the actions listed earlier may be obvious for a major event, such as an overturned
gasoline tanker, they may not be obvious for an EMS call or a request to assist a resident with a suspicious
odor in his home. Yet all of these incidents involve two things: the first responder and possibly some
material that could potentially harm the first responder.
First responders must make every effort to avoid having tunnel vision and instead must pay attention
to hazards on scene that, while unrelated to a hazardous material, are nonetheless dangerous. These include
hazards associated with motor vehicle accidents, such as downed power lines and unstable vehicles, and
fires or the potential for fires or explosions to occur. They could also include buildings that may have been
damaged with the possibility of collapse, and the dangers associated simply from the incident’s location,
such as construction sites, high traffic areas, or industrial plants.
What about the use of water? Some first responders incorrectly view water as the “aspirin” for all
incidents. They incorrectly assume that whenever they have a problem, their role is to just put water on it
and the problem will go away. Unfortunately, some incidents will only get worse with this response.
Remember that some hazardous materials react violently with water. In addition, water mixing with
certain chemicals can create a hazardous “broth” with the potential to harm the environment from water
runoff as well as to produce dangerous gases and vapors. Even latex paint, which some may not consider
to be a hazardous material, can create environmental havoc when first responders attempt to wash away
a few gallons of this spilled material with hundreds of gallons of water. When a first responder “solves”
problems in this manner, the problems are really just beginning.
Does this mean that as a first responder one should never use water on any fire? No, it certainly does
not. What it does mean is that there are incidents when the use of water is discouraged because of obvious
signs. It could mean that the use of water is questionable since the first responder does not know what is
burning (such as a truck fire on an interstate route), and he is afraid to find out what will happen if he
does use water. It could also mean that the use of water will likely produce potentially hazardous runoff,
and there are environmentally sensitive areas nearby.
21
Yet there are other situations in which the application of water may appear to be the appropriate
tactic, such as house fires and trash fires. Under these circumstances, the important consideration for first
responders is to recognize how the fire reacts when water is used.
For example, efforts to extinguish a fire in a trash bin that are met with small explosions and strange
colored smoke should be enough to cause the first responder to back up and reconsider. Is this a hazardous
materials incident? Recalling the earlier definition of hazardous materials, it certainly is, and the actions
identified earlier now apply. Of course, during this scenario, the first responder should have been wearing
his self-contained breathing apparatus (SCBA). It is important for first responders to remember that all
fires have the potential to produce toxic materials.
A first responder may be sent to some incidents that could involve criminal acts related to improper or
illegal disposal of hazardous materials, or more appropriately, hazardous waste. In situations such as these,
a first responder’s role may suddenly place him as a witness in criminal proceedings, and his actions on
the scene may inadvertently destroy evidence. Regardless of the source of a suspicious substance spilled
in the roadway or a suspicious container discovered in a remote area, first responders certainly have an
obligation to protect themselves and the public. However, they must do so in a manner that does not
jeopardize the success of any future efforts at criminal prosecution for those responsible.
For example, it is important to remember that removing the top from a suspicious 55-gallon (gal)
drum to look at and sniff the contents is a potentially dangerous action. It could also be dangerous to
touch a suspicious substance leaking from a container that fell from a moving vehicle. Furthermore, these
actions would probably do little to bolster one’s credibility as a knowledgeable witness during a criminal
trial involving the improper handling of hazardous materials.
What about cleaning up during the aftermath of a hazardous materials incident? Is this a role for first
responders? In deciding this, one should consider that cleanup usually involves at least three distinct steps.
These are:
• Removal of the waste material
• Disposal of the waste material
• Restoration of the contaminated area
Are all first responders prepared to deal with these issues? Some believe they are, since some incidents
may involve “routine” products, such as muriatic acid or diesel fuel. But a first responder should remember
that once he undertakes cleanup, he is moving far beyond the Rule of Thumb. This is far beyond isolating
and denying entry to an area and treating those exposed to a hazardous material. Instead, at the point
22
when cleanup becomes necessary, the role of the first responder should be coming to a close. There are
several reasons for this:
• Cleanup activities can be labor intensive.
• Equipment requirements (such as absorbents to soak up spilled liquids) can be extensive.
• Cost recovery for one’s equipment may be difficult.
• There may be concerns regarding the responsibility to decide if the scene is clean and to
what standard.
• There may be concerns regarding the responsibility for the safety of anyone exposed to the
site if one’s cleanup is ineffective.
• Removal of the waste material may require permits for transport and disposal.
• Restoration of property may require property owner or insurance company approval.
For reasons such as these, cleanup of most spills of hazardous materials is probably not something that
first responders would choose to include as one of their roles.
One role that first responders will likely have is to assist a hazardous materials team on scene should one
be needed. These teams may be from local government, such as local fire departments, state agencies, or
perhaps commercial companies that specialize in emergency response. The most likely support functions
include water supply, fire suppression backup for entry teams, and providing prehospital medical treatment
for those on the scene. Activities such as scene control, including directing traffic or contacting residents
in affected areas, may also be assigned to first responders. Other support functions may include providing
food and lighting.
Depending upon applicable codes and ordinances at the state and local levels, first responders may
legally be in charge of a hazardous materials incident. This may be true even though their level of training
is less than that of individuals from hazardous materials teams or cleanup contractors who are operating
at the scene. Incidents such as these are usually a good time for most fire chiefs to put their egos aside and
cooperate with those who can help take care of the situation.
A valuable role for first responders is to locate essential resources that may be needed by teams and
contractors who respond from outside the local area. These resources may include heavy equipment, such
as dump trucks and backhoes, large quantities of absorbent or neutralizing materials, or construction
materials. The familiarity of first responders with their locality can usually expedite filling requests for
these items.
23
But the first responders must beware! While

First responders were on scene of most contractors and equipment suppliers will
a hazardous materials incident gladly send anything that a first responder requests,
the first responder’s role should never be to pay
that involved an overturned tractor for it. Therefore, before a first responder agrees to
trailer. There was a light rain at the help locate anything, whether it is hamburgers or
a construction crane, he must make sure he knows
time and the driver had lost control who is going to pay for it, and that it is not the
first responder or his local fire department. For
in a curve on a two-lane road. The many departments, paying a $5,000 bill for heavy
vehicle left the pavement, coming equipment rental would require a lot of bake sales
and bingo!
to rest in an open field, with the
First responders assisting a hazardous materials
force of the impact destroying the team or cleanup contractor should always be
trailer and spilling its contents. This prepared for an incident that is measured in days
rather than hours. This is a fact of life that may
material was now on fire. Despite place an unreasonable burden on other activities,
whether they involve maintaining response coverage
extensive damage to the trailer, first elsewhere or replacing volunteer firefighters who
responders were able to detect a need to work their regular jobs. But rushing to get
the job done, or operating with too few people, is a
placard indicating that the load recipe for disaster.
was a “spontaneously combustible” By far the most valuable role of a first responder
material with a 4-digit identification during an incident that involves hazardous materials
is to ensure that everyone goes home. This conclusion
number of “1384.” Using the is never by chance, but instead is the result of first
responders who have moved beyond the Rule of
Emergency Response Guidebook, Thumb. They have learned that any incident can
they determined the use of water involve hazardous materials, and they know that
what they do is just as important as what they do
was NOT recommended. Had they not do.
failed to heed this warning and
instead attempted to extinguish
the fire using a hose line from their
apparatus, they would have learned
the hard way that the material would
react violently with water.
24
Key Points
• First responders at the operations level should be capable of responding to a hazardous
materials incident in a defensive manner.
• Defensive practices include actions to contain the release of a hazardous material and to
protect people, property, and the environment from the effects of the material.
• First responders should be aware of dangers on scene that are unrelated to those posed by
hazardous materials. These include downed power lines and unstable structures.
• First responders should refrain from applying water to hazardous materials.
• Application of water to a hazardous material fire could produce toxic runoff.
• Cleanup of a hazardous materials release should not be a role for first responders.
• First responders may need to locate necessary equipment and supplies for use during a
hazardous materials incident. First responders should never pay for these items.
• The most important role for first responders is to ensure that everyone goes home!
25
Chapter Questions
1. Define at least two roles of first responders during a hazardous materials incident.
2. List five hazardous conditions that could be present during a hazardous materials incident
and that are likely unrelated to the hazardous material.
3. Identify two considerations for first responders when deciding the extent to which they
should intervene during a hazardous materials incident.
4. List five initial actions first responders should take during any hazardous materials
incident.
5. Describe potential hazards associated with the application of water to hazardous materials
that have spilled or that are burning.
6. List five reasons why first responders should not undertake cleanup of spilled hazardous
materials.
7. List five possible support functions that first responders could provide during a hazardous
materials incident.
8. Identify who in the first responder’s locality is legally in charge of a hazardous materials
incident.
9. If a first responder is requested to locate local resources to support operations during a
hazardous materials incident, what is one question he first needs to ask?
10. What is the most valuable role of a first responder during a hazardous materials incident?
26
References
1 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(i), http://www.osha.gov.
2 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(ii), http://www.osha.gov.
3 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(iii), http://www.osha.gov.
4 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(iv), http://www.osha.gov.
5 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(ii), http://www.osha.gov.
6 Code of Federal Regulations. 40 CFR § 311.1, http://www.access.gpo.gov/nara/cfr/waisidx_04/40cfr311_04.html.
7 Code of Federal Regulations. 40 CFR § 311.2, http://www.access.gpo.gov/nara/cfr/waisidx_04/40cfr311_04.html.
27
4
PLANNING FOR A HAZARDOUS MATERIALS INCIDENT
When first responders stand on the apparatus ramp of their station and look towards the horizon
of their community, do they really know what hazardous materials are out there? Do they know
what is stored and used at fixed facilities, including factories, warehouses, and retail outlets? Are
they aware of hazardous materials that could be at transportation terminals or on highway interstate
routes and railroads? What would they do if an incident were to occur at these locations?
In an effort to gain a better understanding of what hazards they may face, first responders should
be familiar with a federal law that can help them. Title III of the Superfund Amendments and
Reauthorization Act (SARA) of 1986 is also known as the Emergency Planning and Community
Right-to-Know Act (EPCRA). The purpose of EPCRA is to “encourage and support emergency
planning efforts at the State and local levels and provide the public and local governments with
information concerning potential chemical hazards present in their communities.”1 Furthermore,
EPCRA “does not place limits on which chemicals can be stored, used, released, disposed, or
transferred at a facility. It only requires a facility to document, notify, and report information.”2 The
law includes four major sections:
• Emergency Planning
• Community Right-to-Know Reporting Requirements
• Emergency Release Notification
• Toxic Chemical Release Reporting
Emergency Planning and Reporting Requirements

The Emergency Planning section requires establishment of a Local Emergency Planning Committee
(LEPC), whose responsibilities include the development of a local emergency plan to prepare for and
respond to chemical emergencies. Members of each LEPC should include representatives from a number
of different entities, including:
• Local government
• Fire and law enforcement
• Hospitals and health departments
• Community groups
• News media
• Representatives from facilities subject to EPCRA emergency planning requirements
Under the Community Right-to-Know reporting requirements, the LEPC, as well as the local fire
department, should receive information relative to hazardous chemical inventories from various facilities
in the community. As a result, first responders can learn important details about many of the hazardous
materials they may face.
The information received is normally available as MSDS and tier reports. In particular, tier reports
are known as Tier I, which identify hazards by categories, and Tier II, which provide greater detail and
identify materials by a specific chemical name. For example, a Tier I report might indicate that a facility
stores 10,000 pounds of substances that cause chronic health effects. A Tier II report might indicate that
a facility has 500 pounds of benzene, along with the physical and health hazards associated with benzene.
Figure 4–1 provides an example of a Tier II report. Details regarding the information available from an
MSDS are included in chapter 7.
30
Fig. 4-1 Page of pages
Form Approved OMB No. 2050-0072
Facility Identification Owner/Operator Name

Name Name Phone ( )
Example of a Tier II Report
Tier Two Street Mail Address

EMERGENCY City County State Zip
AND Emergency Contact
HAZARDOUS SIC Code Dun & Brad Number
CHEMICAL Name Title
INVENTORY Phone ( ) 24 Hr. Phone ( )
FOR ID #
Specific OFFICIAL Name Title
Information USE Date Received Phone ( ) 24 Hr. Phone ( )
by Chemical ONLY
Important: Read all instructions before completing form Reporting Period From January 1 to December 31, 20 [ ] Check if information below is identical to the information submitted last year.
Physical Storage Codes and Locations

Chemical Description and Health Inventory (Non-Confidential)
Hazards
(check all that apply) Storage Locations
Trade
CAS Secret [ ] Fire Max. Daily
Chem. Name [ ] Sudden Release Amount (code)
of Pressure
Check all [] [] [] [] [] [] [ ] Reactivity Avg. Daily Amount
that apply Pure Mix Solid Liquid Gas EHS [ ] Immediate (acute) (code)
EHS Name [ ] Delayed (chronic) No. of Days []
On-site (days)
Trade
Source: U.S. Environmental Protection Agency
of Pressure
On-site (days)
Trade

of Pressure
On-site (days)
Certification (Read and sign after completing all sections) Optional Attachments
I certify under penalty of law that I have personally examined and am familiar with the information submitted in pages one through , and that based [ ] I have attached a site plan
on my inquiry of those individuals responsible for obtaining the information, I believe that the submitted information is true, accurate, and complete. [ ] I have attached a list of site coordinate abbreviations
[ ] I have attached a description of dikes and other
Name and official title of owner/operator OR owner/operatorÕs Signature Date signed safeguards measures
authorized representative
31
Submission of various MSDS is required when a product is first present at a facility and then whenever
any changes occur regarding these materials. While submission of a Tier I report is the minimum required
law, facilities can submit Tier II reports voluntarily but must also submit them upon request of an LEPC.
Tier reports must be submitted annually.
Despite the apparent benefits of receiving this type of planning information, it is important for first
responders to realize that there are exceptions to EPCRA reporting requirements. For example, facilities
that store “hazardous chemicals” as defined by the 29 CFR 1910.1200, but in amounts that do not exceed
a threshold quantity, such as 10,000 pounds, may be exempt from reporting requirements. In 1999, the
U.S. Environmental Protection Agency (EPA) excluded gasoline stored at most retail gas stations from
EPCRA reporting requirements.3
EPCRA also references “threshold planning quantities” (TPQ) for various materials known as
“extremely hazardous substances.” Facilities may be exempt from reporting the presence of these materials
if the amounts on-site do not exceed the established TPQ.
First responders should know who from their department is a member of their local LEPC in order
to learn more about EPCRA reporting requirements, any applicable exceptions, and to determine how
MSDS and tier reports are received and maintained. For most first responders, the challenge is usually
getting the information from MSDS and tier reports to the front seat of their apparatus!
Emergency Release Notification

Another requirement of EPCRA is notification to the LEPC of “accidental releases.” However, the
requirement to report these releases is limited to materials such as “hazardous substances” or “extremely
hazardous substances” and only when the amounts of these substances that have been released exceed
what is known as a “reportable quantity.”4 As with TPQ, reportable quantities are measured in pounds
rather than gallons. First responders must also be aware that facilities are exempt from notifying the LEPC
whenever an accidental release results in an exposure “solely within the site or sites on which a facility
is located.”5
Perhaps a facility is required to make an emergency notification of a release because the release exceeds
a reportable quantity. If the release results in exposure beyond the facility boundaries, notifying the LEPC
as required by EPCRA may not necessarily trigger an immediate response by first responders. This is
because EPCRA does not require this same facility to notify 9-1-1.
Therefore, a factor in just when first responders will learn of any emergency notification is dependent
upon how information regarding that notification is sent to the LEPC, who receives it, and how that
information is then processed. If an emergency notification report ends up in someone’s in-basket, it
could be days before first responders learn of the incident. A first responder should check with local
emergency managers and LEPC representatives to learn how emergency notifications mandated by
EPCRA are managed in the community.
Of course, while EPCRA does not require fixed facilities to notify 9-1-1, the reality is that not all
chemical releases at these facilities are catastrophic to the community. Furthermore, many facilities have
32
in-house procedures to deal with hazardous material releases, whether through their own personnel or
standing contacts with cleanup contractors.
Yet first responders are probably in the best position to deal with what could become an immediate
threat to public safety, regardless of EPCRA notification exceptions. Therefore, a first responder should
always remember the benefits of conducting pre-incident surveys and becoming familiar with facilities in
his response area. There are also benefits to developing good working relationships with representatives
from these facilities. This could serve to encourage notification of first responders directly through 9-1-1
for any incident involving the release or potential release of hazardous materials.
Emergency Planning
As a first responder, one way to plan for a hazardous material emergency is to maintain on each
emergency response apparatus copies of selected MSDS and tier reports submitted to the LEPC and fire
department. In addition, first responders may wish to consider maintaining copies of MSDS for products
that could be routinely transported through their community, such as ammonia, gasoline, propane,
chlorine, and sulfuric acid.
First responders with access to onboard computers for their apparatus may be capable of maintaining
electronic copies of every MSDS and tier report available, while those without this equipment may need
to keep paper copies in a notebook. Since space is usually limited for paper copies of anything on most
apparatus, an LEPC may be able to assist first responders with assembling a “top ten” list of hazardous
materials in each community. Regardless of how first responders store MSDS and tier reports, they should
always remember to update this information at least once a year.
A first responder should also have some knowledge of not only what chemicals are stored and used in
the community, but also the likely exposures and subsequent response strategies. First responders should
consider a situation in which there is a major waterway that provides for marine transportation and
recreational activities as well as water intakes for domestic water supplies.
If an accidental chemical release were to reach this body of water, how would the first responder
need to respond? Are there means available to contain a spill, such as floating booms? If so, how would
these booms be deployed? Who would the first responder notify about any hazards to marine traffic and
recreational boaters? How would he keep these people out of harm’s way? How could the first responder
notify facilities with water intakes downstream about a potential threat?
Answers to these questions may be available through the LEPC or various regulatory agencies that
have prepared emergency response plans for these types of events. These agencies may include those
responsible for environmental regulations or agencies that employ game wardens or police who specialize
in marine law enforcement. Depending upon the location, the U.S. Coast Guard or the EPA may also be
involved in planning for emergency response.
The first responder should know how to access emergency response information and make it work
not just during normal business hours, but also on a Sunday morning or on Thanksgiving or Christmas
Eve. If a catastrophic incident occurs at such a time, there will be no one available from the LEPC or
33
regulatory agencies to answer the phone at the office. What should a first responder do during these
worst-case scenarios?
The answer once again is planning. Using the information made available to them, each LEPC is
required by EPCRA to develop an emergency response plan. These emergency plans should include
components such as:
• Emergency response procedures
• Evacuation plans
• Notification procedures
• Determination of the severity of a release and populations likely to be affected
• Ways to notify the public when a release occurs
• Identification of emergency equipment and resources available
• Determination of training for local responders6
In addition to developing an emergency response plan, each LEPC is then responsible for conducting
an annual evaluation of the plan.7 Any evaluation should be a realistic exercise that engages all likely
stakeholders These stakeholders should include representatives from local, state, and federal agencies,
and they should all be invited to participate in the exercise. These could be tabletop exercises, with the
incident unfolding on a projector screen, or they could be full-scale exercises, with an actual response of
apparatus and personnel.
One should use caution, though, when participating in an exercise. Some may approach the event
simply as a means to “punch their ticket” so they can claim they satisfied a legal requirement for an annual
drill. As a result, they may not take the event seriously. As participants, first responders should attempt to
learn something and make improvements where needed.
Most exercises end with a briefing or hot wash, when problems are identified and solutions are
suggested. These will be merely words unless they are put into practice.
First responders must demand results and demand change for the better. If necessary, they should
conduct follow-up mini-exercises that test only various components of emergency response plans that
were revised based upon outcomes from the original exercise. First responders should remember that
while a lack of funding may be understandable as to why some changes are not made, a lack of interest is
never acceptable.
34
First responders should be wary of exercise

briefings that include critiques from in-house
A full-scale emergency response
personnel, who may be hesitant to identify exercise was conducted for first
deficiencies among their own ranks. Exercises
with in-house evaluators are easily swayed by responders that involved a simulated
a groupthink mentality that suggests that if the release of hazardous materials along
group agrees what they did was great, they cannot
possibly be wrong! Evaluators from outside the with several “contaminated” patients.
participating agencies may be willing to offer
more objective and realistic observations.
Fire and EMS personnel were required
A first responder should also be suspicious
to conduct an initial assessment of
of briefings that include statements such as, the incident, initiate protective actions,
“Everyone did an outstanding job.” People who
make such claims either did not participate in the contain the released material, and
exercise or are running for political office. They perform decontamination of patients, all
certainly are not there to help first responders.
while not becoming part of the problem
First responders should also remember
that any exercise briefing that fails to energize themselves. The exercise was scheduled
people to see the need for change and that is
done without some means to hold stakeholders
for the morning hours and then during
accountable within a specified period of time lunch, and a briefing was held to discuss
is doomed. It will wind up as nothing more
than a useless report stuffed into a file cabinet the outcomes. Suggested changes
somewhere while everyone goes back to their were debated, but rather than have
normal routines. They will be content with the
knowledge that they have met their exercise participants disband afterwards, the
requirements for another year, at least until the
“big one” hits and the response is no better than
exercise was repeated that afternoon
before, or perhaps even worse. so as to incorporate many of the
desired improvements. This second
session allowed exercise controllers
an opportunity to reinforce desirable
behaviors and enabled participants to
complete their training with a sense
of accomplishment and pride in a job
well done.
35
Key Points
• The Emergency Planning and Community Right-to-Know Act (EPCRA) requires
establishment of a Local Emergency Planning Committee (LEPC).
• First responders should know which person from their department is a member of their
LEPC.
• Tier II reports and MSDS submitted by fixed facilities can help first responders plan for
hazardous material incidents.
• EPCRA does not require fixed facilities to make notifications for releases that occur “solely
within the site or sites on which a facility is located.”8
• Fixed facilities that experience a reportable release under EPCRA are required to notify the
LEPC, not first responders through 9-1-1.
• EPCRA requires each LEPC to develop an emergency response plan.
• Emergency response plans must be evaluated on an annual basis.
• Briefings conducted after any exercise should include milestone dates for progress reports
on efforts to solve problems identified during the exercise.
36
Chapter Questions
1. Identify which person from your department is a member of the community’s LEPC.
2. Obtain a copy of the community’s emergency response plan and identify at least five
separate agencies that are included in the plan for hazardous materials emergencies. Provide
a brief description of each agency’s responsibilities.
3. Review the report from the community’s most recent emergency response exercise and list
five of the “lessons learned.”
4. How are notifications of accidental releases as required by federal law managed in the
community, and by whom?
5. Why should first responders keep copies of some MSDS on their apparatus?
6. Why is it important to know about potential exposures that exist along bodies of water
in one’s community? Who should be contacted for help in the event a spill of a hazardous
material has the potential to reach a body of water such as a lake, stream, or river? How
can they be contacted outside of normal working hours?
7. Select a business in the community that uses or stores hazardous materials and prepare an
emergency response plan that includes at least the following items:
• Name and quantities of hazardous materials used or stored
• Types of containers used
• Nearby exposures
• Means to contact a representative of the business outside of normal working hours
• What actions the employees will take in the event of an emergency involving
hazardous materials
37
References
1 U.S. Environmental Protection Agency. “Fact Sheet: Emergency Planning and Community Right-to-Know Act of
1986.” August 1994, http://es.epa.gov/techinfo/facts/pro-act6.html.
2 Ibid.
3 The Emergency Planning and Community Right-to-Know Act. March 2000, http://yosemite.epa.gov/oswer/ceppoweb.
nsf/vwResourcesByFilename/epcra.pdf/$File/epcra.pdf.
4 Ibid.
5 Ibid.
6 Ibid.
7 Ibid.
8 Ibid.
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5
HOW NOT TO BECOME PART OF THE PROBLEM
It is 4:30 p.m., and a first responder is preparing dinner in the fire station when he receives
an EMS call. He is the officer assigned to an engine company along with two firefighters. An
ambulance has also been dispatched on the call, but based upon their location, it is likely that the first
responder’s unit will be the first to arrive. He listens to the dispatcher and learns that an individual
at a chemical manufacturing plant nearby has been exposed to a product known as fluoroacetic acid.
No additional information about the product or the incident is immediately available.
While en route to the scene, the first responder refers to the latest edition of the Emergency
Response Guidebook (ERG) carried on his apparatus. He discovers a listing for a product known as
fluoroacetic acid and instructions to use Guide 154. The medic unit contacts the first responder via
radio to inform him that they have already notified the receiving hospital to expect a patient with
exposure to fluoroacetic acid.
Upon arrival, the first responder is stopped by security personnel at the entrance to the plant
and told that the patient is in the clinic and that he has been exposed to bromoacetic acid following
a break of an overhead pipe. While traveling to the clinic, the first responder now learns that the
ERG refers him to Guide 156 for incidents involving bromoacetic acid. When he finally reaches the
clinic, a well-trained plant employee knows that the first responder is going to want the MSDS, and
he promptly hands him an MSDS for chloroacetic acid.
Did this incident have the potential for life-threatening mistakes? It certainly did. The chemical
prefixes bromo, chloro, and fluoro all sound similar, especially when relayed verbally during the
heightened anxiety associated with most incidents. Providing the wrong patient care is often worse
than a delay in patient care. There are numerous other examples of potential confusion from similar
sounding words such as methyl and ethyl, or chlorine and fluorine. These and several other chemical
names and prefixes sound similar enough to cause problems for first responders.
During another incident, a first responder’s engine company is dispatched at 3:00 a.m. to a report
of a “gas” leak following a motor vehicle accident. While en route, the first responder anticipates
a minor leak from the vehicle’s gasoline tank. Upon his arrival, he discovers that the incident is
anything but minor. It instead involves a vehicle that has struck an apartment building. The front
half of a passenger car is buried inside the kitchen of a first floor apartment, having sheared off a
natural gas meter at its base and allowing natural gas to fill the building.
The first responder frantically requests a full assignment with upgrades for a rescue company but
realizes that the delayed dispatch of additional resources will cost him precious time. It will significantly
decrease his ability to evacuate the building and deal with the occupants of the vehicle who are trapped
inside. Had the extent of the incident been known at the time of dispatch, along with the type of gas
involved, many of these additional resources would have arrived along with the first responder.
Both incidents serve to reinforce the fact that a first responder’s response begins with dispatch, and
this particular phase of the incident can determine subsequent success or failure. This is especially true
with hazardous materials incidents, where precious time can be lost conducting research on the wrong
product. Furthermore there are the potential dangers associated with selecting inappropriate strategies
and tactics for dealing with a product based upon false information.
Dispatching Hazardous Material Incidents

One of the best recommendations for solving dispatch problems is to ensure that individuals
responsible for receiving requests for emergency assistance know to ask appropriate questions. They must
clarify both the nature of the incident and the spelling of any known chemicals that are involved.
When relaying chemical names, whether during dispatch or during communications with others
involved in the response such as hospitals, the message should be accomplished by spelling the name. This
should preferably be done using some form of phonetic alphabet. The difference between the letters B
and D may be difficult to distinguish while using a radio or telephone, but saying “B-Bravo” or “B-Boy”
helps to distinguish a message from “D-Delta” or “D-Dog.” It probably does not matter what words are
used to identify individual letters unless one’s agency has adopted a specific system. However, what does
matter is the use of a word to which others can immediately relate. Table 5–1 provides examples of a
phonetic alphabet.
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Table 5–1 Example of a Phonetic Alphabet
A Alpha J Juliet S Sierra
B Bravo K Kilo T Tango
C Charlie L Lima U Uniform
D Delta M Mike V Victor
E Echo N November W Whiskey
F Foxtrot O Oscar X X-Ray
G Golf P Papa Y Yankee
H Hotel Q Quebec Z Zulu
I India R Romeo
Understanding the nature of an event provides first responders with considerable information on
which to base their initial actions and also ensures an adequate and appropriate response of apparatus and
personnel. Calls that involve difficulty breathing may be due to an asthma attack, chemical exposure, or a
gunshot wound. All three incidents require a different approach by first responders, and their dispatchers
are often the first link in a series of events. Efforts should be coordinated so that this critical step is not
the weak link.
If a first responder believes the information received upon dispatch is inadequate, he should not
hesitate to request a clarification. Of course, some dispatch centers operate with minimum staffing, and
if there is only one dispatcher on duty, that individual may be too busy to contact the complainant for an
update. However, the first responder may be able to obtain a callback number, providing the dispatcher got
that number in the first place or the system automatically provides a callback number. The first responder
then may be able to contact the complainant himself while en route using a cellular telephone.
If the call for assistance was received via radio from another emergency response agency, chances are
there may be problems relaying information, since that agency may operate on a different frequency
that the first responder cannot access. If this is the case, the first responder will be dependent upon the
dispatcher to relay information about the incident. Use caution since the more times information is relayed
between individuals the more likely it is that an error will be introduced into the communications.
41
Response and Arrival at the Scene

To avoid becoming part of the problem during any incident, the first responder must remember that
there could always be a hazardous material involved. He must never let down his guard and instead must
be alert for clues. A first responder should recall that an EMS call for difficulty breathing could be the
result of chemical exposure. Every motor vehicle accident has the potential for a release of a dangerous
chemical from containers that may be in the trunk of a car, the back of a pickup truck, or the cargo area
of a truck. There is also a potential hazard from spilled gasoline or diesel fuel.
While first responders often hear about upwind and uphill response, this may not always be practical,
and sometimes it may just be impossible, since there may be only one way in to the scene. However,
first responders must make every effort to stay upwind of the incident once on scene and remember that
distance from the scene is just as important.
First responders who pile onto any incident in close proximity to the source of a hazardous materials
release are certain victims if things go bad. A first responder should never forget that whatever he is doing
while parked on top of the incident can almost certainly be done several hundred feet back. The first responder
can drive forward to the scene after stopping at a safe distance and taking the time to check things out
while using binoculars. This is safer and easier than rushing in and then having to back up once he realizes
he is in trouble. Not only is backing up difficult due to limited visibility, chances are the first responder
has the rest of his fire department right behind him. So he should stay back!
If a first responder is not the first unit on scene, he should never assume that just because others have
rolled in for a closer look that it is safe for him to do so also. To avoid becoming part of the problem, a first
responder must consider that whenever he thinks he is too close, he probably is! So a first responder should
not park in front of a building with a reported leak of natural gas or propane, and he should not stop his
engine in the smoke plume from a trash fire or car fire. He must remember to use common sense.
For example, a first responder usually does not need to assess a minor rear-end motor vehicle accident
involving two passenger vehicles from 1,000 feet (ft) away unless there are some obvious signs that indicate
the involvement of hazardous materials. But once on the scene, the first responder should walk around
the vehicles involved to see if there is anything leaking from the trunk or if there are containers in the
passenger compartment.
Should the first responder check in the back of a pickup truck for possible containers of hazardous
materials before he jumps into the passenger compartment to provide for C-spine control? Without
a doubt, he should do so! Such containers may have broken on impact. However, if he does see an
unknown substance leaking to the ground from a vehicle, he must resist the urge to reach down and feel
the material. Nothing will be more likely to ruin his day, and his fingertips, any quicker.
With larger commercial vehicles, the absence of placards is no assurance that they do not contain
hazardous materials. So what should a first responder do to avoid becoming part of the problem when
42
dealing with a delivery truck with no placards or any other clearly stated warning about the presence of
hazardous materials? There are several steps a first responder should take:
• Be alert for leaks from the cargo area while approaching the vehicle.
• Look for the company name. A name like ABC Pest Control should be attention-getting.
• Be alert for suspicious odors.
• Talk to the passenger(s) and ask what is on board.
• Look for shipping papers in the cab of a vehicle, but only if it can be approached safely.
If everything appears to be okay upon arrival, the first responder still must avoid complacency. Instead,
he must always look for conditions to change. If at some point during the incident he suddenly sees a liquid
leak, hears a vapor release, or detects an unusual odor, he must be prepared to react and change plans.
The Material, the Container, and the Environment

First responders can avoid becoming part of the problem during a hazardous materials incident by
making a thorough hazard assessment. This includes several factors:
• The material. Health and fire hazards must be assessed.
• The container. Whether or not the materials are under pressure must be considered.
• The environment. Any people and property involved must be considered.
An assessment of the hazardous material(s) involved takes into consideration its health effects and
the potential for fire or explosion. Health effects include those from inhalation of dangerous gases and
vapors, skin contact, and possible ingestion. Hazards from skin contact include materials that can damage
the skin as well as those that can be absorbed through intact skin. First responders should remember that
wounds, such as cuts and abrasions, can also allow chemicals to enter the body.
The threat from fire can include explosions, with resultant injuries from burns and physical trauma
from flying debris. Once on scene, explosions and fire can occur without warning and can be triggered by
the actions of first responders, such as using road flares to block traffic.
Another aspect of assessing any hazardous material is its physical state. This can determine how a
product will move once released from its container and what means first responders can use to control this
spread. The physical state of a material will determine if it will spread downwind as a gas, vapor, or dust,
or perhaps be absorbed into the ground as a liquid.
The importance of assessing the hazards of a container is based in large part on whether or not the
container is pressurized. Pressurized containers with compressed liquefied or nonliquefied gases present
first responders with not only the hazards of the contents, but also the potential for the container to
become a flying missile. Containers that rupture can spread debris in all directions that can injure first
responders and bystanders.
43
As a general rule, pressurized containers will present first responders with greater hazards than will
nonpressurized containers. However, nonpressurized containers with liquids or solids may act like pressurized
containers when subjected to heating or chemical stress. First responders who fail to realize the potential
for catastrophic failure of nonpressurized containers under these circumstances are likely candidates for
serious injuries or death.
Assessing the environment determines what may be exposed to a released hazardous material and the
means by which first responders can protect these exposures. For example, a spill of a hazardous material
in an isolated wooded area may at first appear to have minor exposures, until the first responder learns
that the spill has entered a nearby waterway. Alternately, it may have contaminated an underground well
that serves as a source of drinking water for a nearby community.
On a body of water, the first responder may be able to deploy floating booms to contain a hazardous
material, or he may place bales of straw in a stream to absorb releases of products such as latex paint. The
first responder should always remember that a body of water can serve not only as a source of drinking
water, but also as a site for recreational activities. In addition, hazardous materials that leak into rivers,
creeks, streams, and ponds can kill fish, contaminate waterfowl, and poison animals that may drink the
water, such as deer or even household pets.
Hazardous materials that become airborne, whether as a dust, gas, vapor, or mist, may require first
responders to control the vapor with fog streams. First responders may need to evacuate citizens or perhaps
advise those affected by the release to remain inside buildings until the threat has passed. These types of
releases may also require air sampling to determine the safety of the atmosphere.
Specific information on dealing with materials, containers, and the environment are provided in
chapters 8 through 10.
Stages of a Hazardous Materials Incident

Knowing that hazardous materials are usually safe unless released from their containers, first responders
can avoid becoming part of the problem by also assessing the stage of an incident upon their arrival. There
are several stages of a hazardous material incident:
• Containers that have released their contents
• Containers that have an ongoing release
• Containers that have not released their contents (but that have the potential to do so)
The actions of first responders should take into consideration these stages and whether the incident
may have the potential to get worse. They must also remember that any action taken during these stages,
especially defensive practices to contain the spread of a material, can expose them to a hazardous material.
Therefore, to avoid becoming part of any problem, a first responder’s decisions on what actions to take
regarding the stage of an incident should be always based upon whether those actions will really make
a difference.
44
Containers That Have Released Their Contents

Any incident involving containers that have released their contents means that the leak is not ongoing.
However, it is important to remember that liquids will not leak below the level of an opening on a
container. Thus a drum that has been punctured halfway from the bottom will likely stop leaking when
the level of the liquid is at the level of the breach. However, first responders must be careful. Even though
the release has stopped, the container may still contain product up to that level.
If a leak has stopped on its own, first responders should then have some idea of how much product
they may be required to contain and make sure that any defensive containment areas are large enough.
Some releases may not require any defensive actions on the part of first responders, such as if a liquid is
not migrating downhill from the site of a spill as would be the case if a release occurs on a flat earthen
surface. Remember that while this could potentially contaminate the ground beneath the spill site, there is
little that first responders could do to prevent this from occurring. Instead, prompt cleanup and removal
of the hazardous material by a cleanup contractor would be the best means to alleviate this situation.
This is very different from a release that occurs on a sloped, hard surface, when there is nothing to
absorb the spilled material, and gravity is forcing the liquid to move. Aggressive action on the part of first
responders is necessary only if the material is moving to an area where it may cause additional harm. If,
instead, the material collects in a low-lying area with no exposures, there may be little that first responders
can do to improve the situation.
At other times, such as when a 5-gal bucket tips over with loss of the lid, the potential exists for all
the contents of the container to be released even before someone makes the first call for help. Similar
incidents include small packages that have broken open at retail stores and private residences.
When this occurs, is there really a need for first responders to rush in and do something? Could it
be that these first responders just want to survey the scene to confirm what reportedly took place or
perhaps look for other hazards? Perhaps the first responders just want to determine if the material might
be entering a nearby drain.
While these may be worthwhile causes, first responders must remember that they typically only have
structural firefighters’ protective clothing available. Once near a spill, they might be exposed or become
contaminated, or might destroy their turnout gear. Ultimately, their scouting mission might have more
risks than benefits. In most circumstances, it is probably a lot safer to stay away until the first responders
can contact someone who can provide advice on how best to proceed.
First responders who are a safe distance from any incident remain unharmed and uncontaminated.
A first responder can learn a lot by asking questions of those involved as opposed to intervening directly.
A first responder should never risk his health and safety just because of curiosity!
45
Containers with an Ongoing Release

Incidents that involve containers with an ongoing release present first responders with some significant
threats. Obviously there is a potential for exposure to a first responder and bystanders. However, the first
responder also may need to estimate the total amount of material that could ultimately be released when
planning for containment strategies. Defensive measures that include building makeshift containment
areas will do little if the capacity is too small.
An ongoing release of a gas presents first responders with a similar challenge of attempting to
determine how much of the material will continue to leak. The size of a compressed gas cylinder is
not the only consideration when determining the amount of gas that could be released. The pressure
at which the material is stored will also determine the volume of gas inside the container. Also, the
rate at which any gas is released will depend upon this internal pressure. This pressure can change due
to environmental conditions such as heating of the gas by sunlight or natural cooling of the gas as the
contents are released.
First responders can quickly become part of any problem involving hazardous materials by attempting
to stop an ongoing release. Any effort to plug a punctured drum, operate a valve on a compressed gas
cylinder, or reposition a damaged container puts the first responders at risk of contacting the hazardous
material. This creates the potential for disastrous consequences. First responders should never forget the
limits of their structural protective clothing related to chemical exposure.
Containers That Have Not Released Their Contents

Dealing with containers that have not released their contents but that may have the potential to do so
are just one more way for first responders to become part of the problem. These containers may be stressed
by heat, chemical reactions, or physical damage. First responders may need to place considerable distance
between themselves and the container should the container experience a sudden catastrophic failure. First
responders who encounter a container that has not yet released its contents must continuously evaluate
the situation. There are many situations in which this could occur:
• A metal drum contains a flammable liquid that is exposed to a structure fire.
• A metal tank containing a corrosive liquid has a damaged lining, exposing the container to
the effects of corrosion.
• A compressed gas highway cargo tank falls from a highway overpass to the roadway below,
resulting in a large dent to the tank shell. The incident occurred at 3:00 a.m., with a
temperature of 60ºF, but the predicted high temperature by 3:00 p.m. is 105ºF.
First responders need to decide whether they can safely eliminate a source of stress, such as extinguishing
a nearby fire, or reduce the effects of stress, perhaps by cooling a heated container with water. Use of
hand lines as opposed to master streams may place first responders in a dangerous situation should any
container suddenly fail.
46
Containers that have not released their contents may invite first responders to relocate these containers
in order to lessen the threat to exposures. This could include moving containers stored in direct sunlight
into a building or into a shaded area. However, handling certain types of containers may prove dangerous,
since some materials may be shock sensitive and explode when moved, or containers could be damaged
during attempts to move them. If first responders cannot safely eliminate any ongoing stress applied to a
container, evacuation of areas that potentially could be affected by a release may be necessary.
Defensive Actions
As stated in chapter 3, defensive actions for first responders include protecting nearby persons,
property, or the environment from the effects of a hazardous material. This could be done by containing
the release from a safe distance while preventing exposures. Specific guidelines for accomplishing these
defensive actions are provided in chapter 11.
When reading about these guidelines, particular attention should be paid to those recommendations
aimed at preventing first responders from becoming part of the problem. Included are suggestions to
build containment barriers with materials that will not react with the released hazardous material. There
are also suggestions to take steps to protect personnel from contamination and to have the means to
decontaminate first responders readily available on scene.
A spill could involve a residential occupancy with a worried homeowner or a prominent commercial
building with perhaps hundreds of employees, who are evacuated at a cost of thousands of dollars an
hour in lost revenue. It could also involve the closure of a major highway. Regardless, certain situations
may appear to demand solutions, which can present first responders with moral, financial, or political
pressures. These can stress the boundaries of their social contract with their communities and force them
into making uninformed decisions that can allow them to become part of the problem.
Personal relationships with the victim can magnify the pressure for a “quick fix.” A first responder
should remember that while on scene of an incident, he should view himself not as a friend of the victim,
but rather as a representative of a government agency. Casual, off-the-record suggestions for cleanup and
disposal, such as, “If I were you ...” can come back to haunt a first responder. A first responder should
also remember that traditional remedies such as flushing a spill with large amounts of water or covering
the spill with sand may only worsen the problem.
47
Of course, a first responder may forget the

An EMS crew responded to an boundaries of his relationship with the victim, provide
incident that involved an adult improper advice on cleanup and disposal, and exceed
the legal limits of his authority. He could also allow
male who reportedly did not feel people to reenter a building following a chemical spill,
well. The patient had arrived home and these people may subsequently experience medical
problems. In these cases, there will no doubt be plenty
from work when he became ill. An of lawyers willing to remind the first responder of his
misdeeds. Furthermore, if a first responder operates
assessment by EMS personnel did outside his scope of authority, will his department
not reveal any reason for the illness be willing to defend his decision, or will he suddenly
be on his own and out of luck? First responders
and so a decision was made to should remember that the road to hell is paved with
transport the patient to a hospital good intentions.
for further evaluation. Upon arrival Regardless of what first responders do or do not
do, their decisions must be defensible and based upon
at the hospital, the attending reliable information. Sources of information include
the ERG, MSDS, shipping papers, and consultation
medic was nauseous and vomiting. with manufacturer representatives, regulatory agencies,
It was then learned that the patient medical professionals, and others with expertise related
to the incident.
had been spraying a chemical
Finally, first responders should remember to
at work earlier in the day in a always use caution when assessing the potential harm
manner that required an overhead of a material based upon information provided by
the party responsible for the release. While most will
application of the material and that provide accurate and unbiased advice, some may have
a tendency to downplay the severity of an incident. Use
his clothing had been exposed to caution and if in doubt, do not hesitate to get a second
significant amounts of overspray in opinion. Remember, if the first responder agrees with
the assessment that “everything is okay,” he just may
the process. This information had become part of the problem.
not been revealed to the medics
prior to transport. The patient was
still wearing his contaminated
work clothing when he arrived at
the hospital.
48
Key Points
• Individuals responsible for receiving requests for emergency assistance should determine
the nature of the incident and the spelling of any known chemicals that are involved.
• When relaying a chemical name verbally, first responders should spell the name of the
material using a phonetic alphabet.
• Upon arrival at any incident, first responders should always look for clues that could
indicate the involvement of hazardous materials.
• First responders must make every effort to stay upwind, uphill, and a safe distance away
from a release of hazardous materials.
• The material, container, and the environment where the incident is located must all be
considered by first responders attempting to decide how to best manage any incident.
• The stages of a hazardous materials incident include those with containers that have already
released their contents, those with an ongoing release, and containers that have not yet
released their contents but could do so.
• Incidents where a small package of a hazardous material has broken at a retail store or
private residence may mean that there is little that first responders need to do in order to
contain the release.
• First responders can quickly become part of any problem involving hazardous materials by
attempting to stop an ongoing release.
• Containers that have not yet released their contents should be evaluated by first responders
to determine if there is any stress on the container that could result in a release after
their arrival.
• First responders can become part of any problem by making uninformed decisions.
49
Chapter Questions
1. Determine if those in the community responsible to receive emergency calls use any
form of a checklist to obtain information when dealing with incidents that may involve
hazardous materials. Obtain a copy of a phonetic alphabet that they may use when relaying
information via radio, telephone, or in person.
2. Determine the radio frequencies for first responders from the following agencies:
• The community’s fire department
• The community’s law enforcement agency
• The community’s public works department
• State law enforcement
• State emergency management agency
3. Determine if any of the agencies identified in question 2 have any means to communicate
by radio with the others, and if so, how. If not, what alternatives are available?
4. List five things that can be done to assess potential threats when responding to an accident
involving a commercial vehicle that does not display any warning signs specific to
hazardous materials.
5. List the three components of a hazardous materials incident.
6. List three stages of a hazardous materials incident.
7. List five sources of information that can provide assistance during a hazardous materials
incident.
8. Why should first responders use caution when assessing the potential harm of a material
based solely on information provided by some responsible parties?
50
6
WHO F IRST RESPONDERS SHOULD CALL TO GET HELP
The belief that “when you don’t know who to call, you call the fire department” has become a
sort of unwritten social contract within most communities. People rarely contact the fire department
unless they are in trouble, and then the personnel at the fire department just assume it is their
responsibility to fix whatever is broken. Whether the need to have an answer for every occasion is
driven by the public’s perception of a fire department’s innate abilities or by the department’s sense
of pride, it generally works to the department’s advantage. The department’s personnel leave the
scene heroes, with the belief in their own invincibility bolstered once more. Yet, while this approach
might work in most instances, some incidents involving hazardous materials pose special challenges
that can very easily put well-intentioned firefighters on the defensive.
When dealing with any hazardous materials incident, first responders will never have all of
the answers. While for some this may strike a blow to their egos, the reality is that the world of
hazardous materials response is very complex, both from a technical and legal perspective. First
responders must accept the fact that they need to ask for help. So whom should they call?
Learning the Characteristics of a Hazardous Material

When attempting to learn about a hazardous material involved in an incident, the person who
usually knows the most about the material likely works for the company that makes it. Despite what
can be learned from people who sell, use, or otherwise handle the product, the guy in the laboratory
who brought the product to market knows what makes it tick. And he probably already knows what
makes it blow up and how it can make someone sick.
A first responder must never believe that he is the first person to ever call a manufacturer to
request assistance. Most likely, the manufacturer has fielded numerous calls in the past. Some of
the manufacturer’s employees are very experienced. When a first responder describes a characteristic
of the product, they will likely respond with something such as, “Oh yeah, you’re dealing with our
XYZ product. OK, here’s what you need to do.” During incidents at a facility where a material is
manufactured, the source of information is probably available through technical personnel on-site.
If these individuals are unavailable at the scene, someone there probably knows how to contact them.
When dealing with a facility where a product is used, there may be an MSDS available (either in
written form or electronically), and there may be someone there who knows something about the product.
However, during these incidents, first responders will probably still need to contact the manufacturer of
the material to learn the characteristics of the material, especially if there is any concern regarding medical
treatment following exposure. Most MSDS will include an emergency response telephone number.
At fixed facilities where materials are only stored or sold, such as warehouses and retail outlets, a first
responder’s efforts to learn the characteristics about a hazardous material may be limited. The employees
at these sites often merely stock shelves and perform sales transactions. A first responder also should
not expect to find MSDS, since these documents are usually required only when employees are using
a product, not just moving the containers around with a forklift or hand truck. Chapter 7 provides
additional information on the availability of MSDS.
During transportation incidents, shippers and carriers play major roles as well. A shipper is the point
of origin, and a carrier is the transporter. Usually the manufacturer, shipper, and carrier are all different.
On some occasions, a chemical manufacturing company may be the shipper and the carrier. Once a
first responder has contacted shippers and carriers, they may send technical representatives to the scene.
These individuals can help him learn the characteristics of a hazardous material, especially if the incident
involves a highway cargo tank or rail tank car of some type. First responders should always remember
that while most technical representatives will provide accurate and unbiased advice, some may have a
tendency to downplay the severity of an incident. Use caution and if in doubt, do not hesitate to get a
second opinion.
On some occasions when the shipper and carrier are the same, drivers may know something about
the material involved, and they may have even received specific training on how to handle emergency
incidents. This is especially true for those who operate highway cargo tank trucks. A first responder must
use caution, though, not to allow any driver free reign during an incident, since they may sometimes take
unnecessary risks in attempting to resolve the problem.
A first responder should remember that while the tank truck driver may know how to operate a valve
on his vehicle, he may not have available appropriate protective clothing. In addition, he may not be
as trained as a first responder in performing a thorough risk assessment, and he may therefore overlook
other hazards at the scene. Furthermore, a first responder should never invite a driver into a vehicle for a
conversation about the incident until it is confirmed that he is not wearing some of the product. A first
responder should avoid shaking hands with these individuals as well. It may seem impolite, but it is a
good way to avoid contamination.
During transportation incidents that involve box trucks, especially those used to transport general
freight (all types of mixed cargo), a first responder should not expect information from the driver for a
carrier. He will likely not know anything about the materials being shipped. Chances are the driver may
have never even seen the inside of the truck once it was loaded.
52
WHO FIRST RESPONDERS SHOULD CALL TO GET HELP
Contacting Those Who Can Help

If representatives from a manufacturer, shipper, or carrier can provide information relative to the
characteristics of a hazardous material, just how does a first responder contact them during an emergency?
One solution is that the Code of Federal Regulations governing transportation found in 49 CFR 172.604
requires an emergency telephone number to be included on shipping papers for hazardous materials
during transport.
This telephone number must be “monitored at all times the hazardous material is in transportation,
including storage incidental to transportation.”1 The number must be for a “person who is either
knowledgeable of the hazardous material being shipped and has comprehensive emergency response and
incident mitigation information for that material, or has immediate access to a person who possesses such
knowledge and information.”2
A first responder may reach a company representative directly using the phone number found on
shipping papers. However, many shippers instead register with the Chemical Transportation Emergency
Center (CHEMTREC) in order to comply with this section of the federal transportation regulations.
CHEMTREC is a service of the American Chemistry Council that is available to first responders
without charge. Representatives of CHEMTREC known as emergency service specialists (ESS) can be
contacted 24 hours a day, seven days a week at (800) 424-9300 from anywhere in the United States,
Canada, Puerto Rico, and the Virgin Islands.3 This number may be found on shipping papers and may
also be displayed on bulk containers transporting regulated hazardous materials.
According to CHEMTREC, the ESS will “provide the scene/caller with immediate technical emergency
response information concerning the product(s) involved.”4 In addition, the ESS will put the shipper “in
contact with the incident scene to provide further technical advice and assistance, which may include
sending personnel to the scene.”5 These specialists also have the ability to “establish direct communications
between these experts, CHEMTREC personnel, and the responders at the scene of an incident.”6
Experience has proven that this technical expertise is not just required at the scene of an incident. In one
instance, CHEMTREC was known to establish a conference call between doctors and nurses at a medical
facility and representatives from a chemical manufacturer. This allowed the chemical representatives to
provide direction on treating patients following chemical exposure.
Sometimes shipping papers are unavailable during an incident, perhaps because they have been
destroyed or because it may not be safe to approach a vehicle in order to retrieve these documents.
CHEMTREC representatives may still be able to locate assistance if first responders are able to provide
the ESS with the name of a manufacturer, shipper, or carrier, or other markings that may be displayed on
a vehicle or container. During these types of situations, any vehicle identification numbers that can be
obtained are likely to be important.
CHEMTREC also has available a mutual aid network that can provide assistance in incidents involving
certain types of basic chemicals, as well as CHEMNET, which is a “nationwide network of response
contractors.”7 For additional information on this valuable resource, first responders are encouraged to
refer to the CHEMTREC Web site at www.chemtrec.org. They can also contact the CHEMTREC
business office at its nonemergency phone number: (800) 262-8200.
53
But what should first responders do if an emergency contact phone number provided by a shipper does
not work? Or what if the first responders are dealing with a material that is not a “regulated” hazardous
material? Although the shipper is not required to provide any emergency contact information on the
shipping papers for nonregulated materials, the first responders may still have a problem involving the
shipment. Perhaps a container is leaking and the first responders want to know what is inside, and the
shipping paper includes nothing more than a generic description. Perhaps the first responders do not even
have any shipping papers. What should they do?
Under these circumstances, first responders may be able to locate a phone number on a transport
vehicle or perhaps on the outside of the container in question. However, at 3:00 a.m. the only answer
first responders are likely to get is a cheery voice mail greeting suggesting that they call back later during
normal business hours.
When this occurs, first responders should next attempt to determine a city and state for the shipper,
manufacturer, or carrier. This information may also be found displayed on transport vehicles or the outside
of containers. Using this information, first responders may be able to locate a company representative in
the following manner:
• Call 4-1-1 (directory assistance).
• For the town or city where the shipper, manufacturer, or carrier is located, request the
phone number of the emergency dispatch center. This may be listed as a separate office, or
for smaller localities, it may simply be the local sheriff’s office.
• Call the emergency dispatch center. Many of these locations have 24-hour contacts for
businesses in their locality. They would normally call these contacts for emergencies such
as if the business was on fire or if there had been a burglary.
• If a number is available for a representative from the shipper, manufacturer, or carrier, most
dispatchers will not release it. Rather they will likely contact the representative themselves
and request that this individual then contact the first responders as soon as possible.
Support During a Hazardous Materials Incident

In addition to learning the characteristics of hazardous materials, first responders will usually need
to obtain various forms of support in order to make informed and defensible decisions and to survive
the initial response. As a general rule, contacts for support during hazardous materials incidents can be
divided into the following three categories:
• Technical support
• Legal support
• Logistical support
These are not distinct categories, and some individuals may provide one or all of the support functions
listed above. As stated earlier, in addition to knowing who to call, first responders should know how to
54
reach these individuals outside of normal working hours and know who can take their place if they are
unavailable. Nothing will create problems as quickly for first responders as calling a government agency
for assistance during a crisis and getting a voice mail greeting stating, “Hi, I’ll be out of the office until
next week, but please leave a message.” For first responders, any delay in getting assistance during an
emergency may be too long.
At the local and state level, first responders should know how to contact individuals from at least the
following agencies:
• Emergency management
• Public works
• Highway department
• Health department
• Game department (effects of hazardous materials on wildlife)
• Environmental regulatory and enforcement
• Motor carrier law enforcement
• Occupational safety
• Public affairs (media relations)
Representatives from these agencies can provide both technical and legal advice, and they may also
have legal authority over issues that first responders are unable to deal with.
Examples of organizations that can provide technical and logistical support functions include:
• Hospitals (emergency department)
• Poison control centers
• Underground utility locator services
• Wrecker and recovery services
• Construction equipment (e.g., dump truck, cranes, or front-end loaders)
• Portable toilets
Of course, first responders should never forget to contact local government officials as well. Depending
upon the severity of an incident, the last thing any first responder needs is for the city manager, county
administrator, or mayor to learn about an incident the day after by reading about it in the local newspaper.
55
Once first responders have assembled

First responders were on scene of a information on support contacts, it is
late night incident involving a box trailer important to determine a means to store
and retrieve this information when needed.
with a small but steady leak of a clear While handheld computers or those located in
liquid at the rear doors. The shipping apparatus cabs are effective ways of doing so,
a laminated index card may work just as well.
papers indicated that the material was The important thing is not how impressive the
information storage and retrieval system is, but
not a regulated hazardous material and whether it actually works when needed.
described its physical state as a solid. First responders will rarely need to contact
There was an obvious need to learn everyone on this list, but they should remember
that notifying someone even if they are not
more about this shipment, yet there was sure that person has a stake in the incident is a
no emergency contact number available, lot better than not calling him at all. The first
responder should let each individual decide
since the material was not regulated. if he is interested in the incident rather than
deciding on that person’s behalf.
Despite having a business telephone
While some notifications may be nothing
number for the shipper obtained through more than “courtesy calls,” they are still a good
directory assistance, the time of day means to foster trust in the fire department’s
operations. A lack of communication is especially
prevented first responders from getting troublesome if certain types of damage from a
any answer. They contacted directory hazardous materials incident go undetected for
a period of time, including contamination to
assistance again, this time obtaining drinking wells or underground utilities. A first
responder should never hesitate to make the call.
a number for the emergency dispatch
center where the shipper was located.
A dispatcher there agreed to contact
the shipper at home and this individual
called back to the scene within minutes.
He confirmed there was in fact a small
liquid component to the shipment that
was the most likely the source of the
leak. The shipper then responded to the
scene to assist first responders.
56
Case study
For the purposes of discussing management responsibilities during a hazardous materials incident,
one could consider a “routine” motor vehicle accident involving a tractor trailer. This tractor with a box
van trailer left the highway and crashed into the front yard of a house, resulting in a spill of approximately
200 gal of diesel fuel. The van was empty at the time. The incident occurred in a rural area, and due to
the current soil conditions, much of the spilled fuel soaked into the ground.
Who would have an interest in this incident, and why? What people should the first responder contact?
Would he just have the wrecker driver tow the vehicle away and let the trucking company personnel do their
own cleanup of the spilled fuel because they claim they are qualified? Before doing so, the first responder
should consider inviting the following groups to this incident for at least the following reasons:
• Property owner. The occupant of any building may not necessarily be the owner of the
property, but both the owner and the occupant have an interest. If their interest is not one
and the same, the interest of the property owner is usually longer term, as any problems
resulting from an incident can ultimately impact property values.
• Responsible party. This is usually the owner of the vehicle or his insurance company.
The responsible party normally pays for the cleanup and removal of the vehicle.
• Environmental regulatory agencies. Representatives from these agencies have an interest
in the extent of cleanup required at the site, the qualifications of those doing the cleanup,
and the location and method of disposal of any contaminated material.
• Underground utilities. Underground utilities (e.g., pipes, cables, and wires) can be
damaged not only from efforts to dig up contaminated soil, but also by hazardous materials
that soak into the ground. Underground utilities are often located in highway right-of-ways or
road shoulders, which just happen to be the same places where a lot of vehicle accidents end up.
• Health departments. Many homes, especially those in rural areas, depend upon wells and
septic systems. Hazardous material spills can lead to contamination of ground water and
septic systems, with negative health effects.
• Highway departments. Any removal of soil on or near roadways can affect the engineering
(such as the slope and stability) of the road shoulder. Therefore, efforts to rebuild road shoulders
should be supervised by representatives from highway or public works departments.
• Motor carrier officers. Most law enforcement officers will conduct an investigation as
to the cause of a motor vehicle accident and are trained to write a summons for speeding
or reckless driving. However, motor carrier officers are further trained to detect specific
conditions of the vehicle (such as brake operation). They may also be trained to determine
a driver’s compliance with federal regulations that govern the operation of commercial
vehicles.
Would a first responder normally consider making all these calls just for a routine vehicle accident?
When a first responder is deciding what calls to make, he should remember that his role is usually limited
to dealing with immediate threats to public safety. He should never overstep his bounds unless he is
willing to take the responsibility that goes along with it. It would be wiser to make any necessary calls.
57
Key Points
• First responders will never have all of the answers when dealing with a hazardous materials
incident, and they must therefore not hesitate to ask for help.
• A representative of the company that manufactures a hazardous material likely knows a lot
about the product.
• Shippers and carriers of hazardous materials may be sources of technical information.
• Shipping papers for hazardous materials include the telephone number that first responders
can call to speak with someone knowledgeable about the product.
• Many shippers of hazardous materials register with CHEMTREC in order to satisfy the
Department of Transportation requirements for an emergency contact.
• CHEMTREC can be contacted around-the-clock to provide first responders with
immediate technical emergency response information concerning hazardous materials.
• Contacts for support during hazardous materials incidents include agencies and
organizations that provide technical, legal, and logistical support.
• First responders should know how to reach individuals from support agencies and
organizations outside of normal working hours.
• First responders should never hesitate to notify those individuals who may have an interest
in the outcome of the incident. This includes local government officials.
• Appropriate notifications should be made during even “routine” incidents.
58
Chapter Questions
1. Identify three general categories of contacts first responders should have available prior to
any hazardous materials incident.
2. Develop an emergency contact list for all of the contacts discussed in this chapter. Include a
means to contact these individuals after normal working hours and also identify individuals
who can substitute for them if they are unavailable.
3. Describe the differences between a manufacturer, a shipper, and a carrier as they relate to a
hazardous materials incident.
4. Why is the manufacturer the preferred source of information regarding a hazardous
material?
5. Will first responders usually be able to locate MSDS at locations where hazardous materials
are used? Will they be able to locate this information at warehouses where hazardous
materials are only stored? Explain your answer.
6. When would drivers of commercial vehicles likely be familiar with the materials being
transported?
7. What two requirements are included in 49 CFR 172.604 regarding an emergency
telephone number on shipping documents?
8. Identify the telephone number for CHEMTREC and describe the services available.
9. What is a generally accepted definition of the term responsible party? What is one of the
more important responsibilities of a responsible party during the course of a hazardous
materials incident?
10. Contact representatives from your locality’s emergency dispatch office and determine if
they have available after-hour contacts for local businesses.
59
References
3 Chemical Transportation Emergency Center. “Guide to CHEMTREC for Emergency Responders,” www.chemtrec.org,
p. 3.
4 Ibid., p. 4.
5 Ibid.
6 Ibid., p. 2.
7 Ibid., p. 6.
60
DOCUMENTS F IRST RESPONDERS CAN USE
7
FOR EFFECTIVE DECISION MAKING
There are a number of information sources available that, if used properly, will enable a first
responder to make effective and defensible decisions. Some of these may be as simple as a hazardous
material placard on a delivery truck or the name of a chemical stenciled on a rail tank car. However,
there are three documents capable of providing first responders with specific information about
products that may be involved in a hazardous materials incident, along with recommendations
for emergency action during the initial response. These documents are the Emergency Response
Guidebook, MSDS, and the Hazardous Materials Guide for First Responders.
Emergency Response Guidebook

The latest edition of the ERG was published in 2004 and was “developed jointly by Transport
Canada, the U.S. Department of Transportation, and the Secretariat of Transport Communication
of Mexico.”1 Referred to as ERG2004, this edition states its intent is to serve as a “guide to aid
first responders in quickly identifying the specific or generic hazards of the material(s) involved in
a [transportation incident involving dangerous goods] and protecting themselves and the general
public during the initial response phase of the incident.”2
The ERG is normally provided free of charge to local and state emergency service officials
through individual state emergency management agencies. First responders should check with
representatives of these agencies to determine the book’s availability.
While most copies distributed in this manner have a rigid binding, spiral-bound formats are
usually available for purchase by first responders from commercial vendors. The spiral-bound format
has the advantage of allowing the book to lay flat once opened.
The latest edition of the ERG should always be readily available in every vehicle operated by
first responders. This includes vehicles of individuals from departments that have a protocol allowing
them to respond from home directly to incidents. It is true that new and sophisticated computer
software programs provide substantial amounts of information and are worthwhile additions to any
first responder’s information arsenal. However, there is no substitute for a handheld copy of the ERG.
First responders should recognize that ERG2004 contains only 61 individual guides, and they should
therefore not assume that any one guide pertains solely to a particular material. In fact, the publishers
remind first responders to “seek additional specific information about any material in question as soon
as possible.”3
While the lack of specificity regarding hazardous materials information may at first appear to be
detrimental, this concern is offset by knowing that the information provided is for use during only the
initial phase of the incident. Furthermore, by limiting the amount of information provided, the publishers
are able to provide all first responders with a reference source that is easy-to-use, cost-effective, and easily
stored on most apparatus. Even the most sophisticated hazardous material specialists can benefit from
using the ERG during the early stages of an incident.
The ERG2004 contains “dangerous goods lists from the most recent United Nations Recommendations
as well as from other international and national regulations.”4 These terms generally are not the name
under which a product is sold, otherwise known as its product name or trade name. Therefore, the specific
trade name of a product, such as ABC Super Drain Cleaner, usually cannot be found in the ERG. What
is available is information based upon a material’s proper shipping name as defined in transportation
regulations for shipments of hazardous materials. The proper shipping name may be found on shipping
documents or perhaps even stenciled on the exterior of certain cargo tanks.
On some occasions, the proper shipping name may be specific, such as chlorine or 2-methyl-2-butene,
or it could be more generic, such as corrosive liquid, n.o.s. (referring to not otherwise specified). According
to the ERG2004, n.o.s. “means that the actual chemical name is not listed in the regulations; therefore a
generic name must be used to describe it on shipping papers.”5 This is often the result of a product that is
manufactured using a specific chemical formula that does not meet the definitions of any specific proper
shipping names but which still represents some hazard when transported. Examples include compounds
that are made from several different chemicals.
In addition to the proper shipping name, the ERG allows first responders to locate information using
a product’s four-digit identification number. They can also get product information by matching the
placards found on the exterior of some transport vehicles with those in the book. When using placards as a
means of reference, the ERG2004 provides a reminder to first responders that “when specific information,
such as ID number or shipping name becomes available, the more specific guide recommended for that
material must be consulted.”6 The ERG2004 also allows first responders to get information based upon
the shape of highway and rail containers. However, first responders are warned that “The recommended
guides should be considered as last resort if product cannot be identified by any other means.”7 Additional
information on using four-digit identification numbers and placards for material identification is provided
in chapter 8.
A distinct advantage provided by the ERG2004 is that each of the 61 individual guides (orange-
bordered pages of the guidebook) provides recommendations for the size of immediate isolation areas in
the vicinity of a spill or leak. It also provides recommendations for evacuation areas for incidents involving
spill or fire scenarios. Having this information available can take some of the guesswork out of efforts to
protect first responders and the public during hazardous materials emergencies.
The ERG2004 also provides additional recommendations for protecting the public from certain spills.
These spills involve “dangerous goods which are considered toxic by inhalation (TIH), including certain
62
DOCUMENTS FIRST RESPONDERS CAN USE FOR EFFECTIVE DECISION MAKING
chemical warfare agents, or which produce toxic gases upon contact with water.”8 This information is
found in the “Table of Initial Isolation and Protective Action Distances” (green-bordered pages of the
guidebook), and is intended to provide “first responders with initial guidance until technically qualified
emergency response personnel are available.”9
Protective actions include not only evacuation but also sheltering-in-place, and the means to decide
which option is more appropriate are explained in detail in the ERG2004. Products included in the “Table
of Initial Isolation and Protective Action Distances” are indicated when the entries for these products are
highlighted in either the numerical index that includes four-digit identification numbers (yellow-bordered
pages of the guidebook) or the alphabetical index that includes the name of the material (blue-bordered
pages of the guidebook). It is important to remember that use of this table requires first responders to take
into consideration not only the size and type of spill encountered, but also the time of day (whether it is
day or night). This latter distinction is necessary since according to the ERG2004, “atmospheric mixing
is less effective at dispersing vapor plumes during nighttime.”10 The result is that most recommended
protective action distances increase during nighttime hours.
While the decision to isolate and evacuate an area should be one of the first made, it is usually one
of the more challenging when deciding just how far is far enough. Isolation and evacuation distances are
rarely provided with MSDS, so the ERG is one of the few sources first responders can rely on for direction
when making these decisions.
Determining isolation and evacuation distances is especially difficult during transportation incidents,
since establishing isolation areas often means closing highways. Yet decisions by first responders that
result in the evacuation of businesses, especially those involved in retail sales, are not any easier. Operators
of these businesses may seek to recover business revenue lost during the time they were forced to close.
Even though the party responsible for the incident may be held accountable to provide reimbursement for
this lost revenue, this individual may claim in defense that first responders “overreacted.” They may claim
that the first responders did not need to evacuate as large an area as they did. First responders may then
find themselves potentially liable for the lost revenue. A first responder will likely be better able to defend
his actions if he can demonstrate that his decisions on isolation and evacuation distances were based upon
a recognized emergency response document such as the ERG.
The ERG2004 also provides first responders with information on potential fire and health hazards
and ranks these hazards accordingly for different materials. Of the 61 guides in ERG2004, those used
for materials with health hazards deemed higher than their fire hazards will have HEALTH listed
first. Materials with fire or explosion hazards greater than associated health hazards will have FIRE or
EXPLOSION listed first.
On occasion, first responders are met upon arrival at an incident by individuals who have been
potentially contaminated with a hazardous material and who require immediate attention. Information
on first aid and decontamination is readily available in each guide.
The best way to learn how to use the ERG2004 is to refer to the book itself. There are numerous pages
that explain its use and limitations, as well as a glossary of terms. First responders should remember that
the publishers of the ERG2004 state that “it is primarily designed for use at a dangerous goods incident
occurring on a highway or railroad.”11 Its users should be “mindful that there may be limited value in its
application at fixed facility locations.”12
63
Finally, despite what first responders may think they know about the ERG from using previous
editions, each new version contains updated information and revised formatting. First responders should
remember to always take the time to become familiar with these updated editions whenever they become
available, which is usually every four years.
Material Safety Data Sheets

Ask most first responders if they know about the existence of MSDS, and the answer will almost
always be the same—“Yes!” Beyond that, there are a number of misconceptions and myths that surround
the use and availability of MSDS that can create unwanted surprises.
The MSDS most often used are based upon requirements found in 29 CFR 1910.1200, entitled
“Hazard Communication.” This standard lists several general categories of information that must be
included, but it does not require a standard format. Therefore, while most any MSDS will contain
information relative to each required category, first responders may find that the formats appear different
and somewhat confusing. Each MSDS prepared for use to comply with OSHA 1910.1200 must be
written in English “and shall contain at least the following information” excerpted here:
• The identity used on the label, and except as provided for in paragraph (i) of this section
on trade secrets: (paragraph (i) allows specific chemical identity to be withheld for certain
“trade secrets”)
- If the hazardous chemical is a single substance, its chemical and common name(s);
- If the hazardous chemical is a mixture which has been tested as a whole to determine
its hazards, the chemical and common name(s) of the ingredients which contribute to
these known hazards, and the common name(s) of the mixture itself; or,
- If the hazardous chemical is a mixture which has not been tested as a whole:
• The chemical and common name(s) of all ingredients which have been determined
to be health hazards and that comprise 1% or greater of the composition, except
that chemicals identified as carcinogens under paragraph (d) of this section shall be
listed if the concentrations are 0.1% or greater; and,
to be health hazards and which comprise less than 1% (0.1% for carcinogens) of
the mixture, if there is evidence that the ingredient(s) could be released from the
mixture in concentrations which would exceed an established OSHA permissible
exposure limit or ACGIH Threshold Limit Value, or could present a health risk to
employees; and,
to present a physical hazard when present in the mixture;
64
• Physical and chemical characteristics of the hazardous chemical (such as vapor pressure,
flash point);
• The physical hazards of the hazardous chemical, including the potential for fire, explosion,
and reactivity;
• The health hazards of the hazardous chemical, including signs and symptoms of exposure,
and any medical conditions which are generally recognized as being aggravated by exposure
to the chemical;
• The primary route(s) of entry;
• The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other
exposure limit used or recommended by the chemical manufacturer, importer, or employer
preparing the material safety data sheet, where available;
• Whether the hazardous chemical is listed in the National Toxicology Program (NTP)
Annual Report on Carcinogens (latest edition) or has been found to be a potential
carcinogen in the International Agency for Research on Cancer (IARC) Monographs
(latest editions), or by OSHA;
• Any generally applicable precautions for safe handling and use that are known to the
chemical manufacturer, importer or employer preparing the material safety data sheet,
including appropriate hygienic practices, protective measures during repair and maintenance
of contaminated equipment, and procedures for clean-up of spills and leaks;
• Any generally applicable control measures that are known to the chemical manufacturer,
importer, or employer preparing the material safety data sheet, such as appropriate
engineering controls, work practices, or personal protective equipment;
• Emergency and first aid procedures;
• The date of preparation of the material safety data sheet or the last change to it;
• The name, address, and telephone number of the chemical manufacturer, importer,
employer, or other responsible party preparing or distributing the material safety data
sheet, who can provide additional information on the hazardous chemical and appropriate
emergency procedures, if necessary.13
It is further stated in 29 CFR 1910.1200 that “if no relevant information is found for any given
category, the MSDS shall be marked to indicate no applicable information was found.”14 In situations
such as this, first responders may see a notation for N/A. A first responder must never associate N/A with
not applicable, as if the hazard does not exist. It may mean that information on the hazard is not available
at this time, especially related to long-term health effects.
A distinct advantage of 29 CFR 1910.1200 and its influence on the availability of MSDS in the
workplace is that the definition of what constitutes a hazard is broader than those found for hazardous
materials in the federal transportation regulations. As a result, many more chemicals are required to have
an MSDS than those that require some form of notification using labels and placards. In general, MSDS
are required for products known to have either a health hazard or physical hazard. Health hazards include
65
chemicals that are carcinogens (known to cause cancer), toxic agents, irritants, corrosives, sensitizers, and
agents that damage the lungs, skin, or eyes.15 Physical hazards include chemicals that are a compressed
gas, flammable, an oxidizer, or water reactive.16 Using these broad definitions of health hazards and
physical hazards, MSDS are required for thousands of products.
Some of the information from an MSDS is presented in a text format that describes the material and
explains its potential hazards. Often included in this description is reference to a product’s appearance
and odor. This information is of particular importance if first responders are attempting to determine the
source of release from a commercial vehicle that contains several different products. For example, first
responders may encounter a situation when a liquid is leaking from box truck that contains three different
hazardous materials. Perhaps an MSDS for each one of these materials is available, and the liquid that
has leaked is observed to be a “brown viscous liquid.” Hopefully, only one of the three MSDS will have a
similar description, thereby helping to identify the leaking material.
Chemical and Physical Properties

Information from an MSDS will often refer to a material’s chemical and physical properties. Those
usually of importance to first responders attempting to contain a release of hazardous materials are
as follows:
• Specific gravity. Will a liquid or solid material sink or float when released in water?
• Vapor density. Will a gas or vapor sink or rise when released to the atmosphere?
• Miscibility. Will a material mix with another material, such as water?
• Solubility. Is it capable of being dissolved or liquefied?
Both specific gravity and vapor density are usually expressed in numerical terms. Materials with a
specific gravity of less than 1 will float on water, while a material with a specific gravity greater than 1
will sink in water. Likewise, a material with a vapor density less than 1 indicates a gas or vapor that will
rise into the atmosphere. A material with a vapor density greater than 1 will sink and possibly collect in
low-lying areas.
When dealing with releases of hazardous materials that reach bodies of water, first responders should
be particularly concerned with information from an MSDS that references miscibility and solubility. For
example, liquids that are immiscible (not miscible) generally will not mix with the water, while those that
are miscible likely will mix. Why is this important?
Consider that if a liquid material released into a pond is water miscible, attempting to contain it using
absorbent booms that float on water is probably a waste of resources. Instead, the only way to remove this
material may be to drain the pond. However, perhaps a material is not water miscible and has a specific
gravity of less than 1 (meaning it will float on water). Then first responders may be able to use floating
booms to contain the spilled material. Once contained, cleanup will then usually involve a device to
vacuum the material from the surface of the water. First responders can use this information from an
MSDS on the specific gravity, miscibility, and solubility of the material involved. This will allow them to
66
make informed and defensible decisions on whether they can effectively contain a liquid spill on a body
of water and how to best accomplish this task.
An MSDS will also provide information relative to a product’s flash point and explosive limits. Flash
point is the minimum temperature of the liquid at which it gives off vapors sufficient to form an ignitable
mixture with the air near the surface of the liquid or the container. The term explosive limits describes the
minimum (lower explosive limit, or LEL) and maximum (upper explosive limit, or UEL) concentrations
of gases and vapors expressed as a percentage in air that will support combustion. The flammable range is
the distance between the LEL and the UEL. As an example, a material may have a LEL of 5% and a UEL
of 15%, indicating that the gas or vapor will usually burn only when mixed with air in concentrations
from 5% to 15%.
Health Hazards
First responders using an MSDS will find information that defines exposure limits. These limits
express the maximum concentration of chemical to which an individual can be exposed during various
periods of time without suffering adverse health effects. They include periods such as an eight-hour work
day and 15-minute short-term exposures. A first responder should always remember that these values
apply to a workplace environment dealing with healthy adult employees. They may not be suitable when
applied to the general public for determining the public’s safe exposure limits.
In order to understand what is meant by exposure limits, first responders should know that these limits
are often expressed as a numerical value in terms of parts per million (ppm). As a simple explanation, one
could imagine a box filled with 1 million balls, with white balls representing air.
Using red balls to represent a dangerous airborne material, an exposure limit value of 100 ppm would
mean that of the 1 million balls, 100 would be red in color, while the rest would be white. Likewise, a
material with an exposure limit value of 10 ppm would indicate that of the 1million balls, only 10 would
now be red.
It is important for first responders to remember that the lower the ppm for any exposure limit, the
more harmful the material. Using the example above, a material that is fatal when a person is exposed to a
concentration of 10 ppm or greater is more dangerous than a material that is fatal only when a person is
exposed to a concentration of 100 ppm or greater.
While numerical values for exposure limits can provide first responders with a relative comparison
to judge the hazards of a materials, first responders should themselves refrain from attempting to decide
whether a particular chemical concentration is safe to breathe. Instead, they should rely on guidance
from OSHA Standard 29 CFR 1910.134, entitled “Respiratory Protection,” which makes reference to an
IDLH atmosphere, or an atmosphere that is Immediately Dangerous to Life and Health.
According to this OSHA standard, IDLH is defined as “an atmosphere that poses an immediate
threat to life, would cause irreversible adverse health effects, or would impair an individual’s ability to
escape from a dangerous atmosphere.”17 It is usually expressed in parts per million. It also states, “Where
the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider
67
the atmosphere to be IDLH.”18 The use of a “full facepiece pressure demand SCBA”19 or a”combination
full facepiece pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply”
is required.20
The reality is that most first responders usually cannot accurately determine whether the concentration
of most contaminants is above or below the established IDLH level. Because first responders cannot easily
or accurately determine such “employee exposure,” the safest action when dealing with most hazardous
materials incidents is for first responders to use SCBA.
First responders should also take note of information from MSDS regarding the means by which
hazardous materials can enter the body, whether by skin absorption, inhalation, or ingestion. A first
responder should never forget that while some hazardous materials may not be capable of skin absorption,
these same materials may still enter the body at the site of a wound on otherwise intact skin. Remember
too a warning found in ERG2004 that states, “Structural fire fighters’ protective clothing provides limited
protection from heat and cold, but may not provide adequate protection from the harmful vapors or
liquids that are encountered during dangerous goods [hazardous materials] incidents.”21
Another aspect of MSDS is that 29 CFR 1910.1200(i)(1), allows chemical manufacturers and
employers to withhold specific chemical identities from an MSDS. This includes the chemical name and
other specific identification of a hazardous chemical, if the manufacturer claims that this information is
considered to be a trade secret. However, relative to patient care, the standard also states that “where a
treating physician or nurse determines that a medical emergency exists and the specific chemical identity
of a hazardous chemical is necessary for emergency or first-aid treatment, the chemical manufacturer,
importer, or employer shall immediately disclose the specific chemical identity of a trade secret chemical to
that treating physician or nurse, regardless of the existence of a written statement of need or a confidentiality
agreement.”22 The standard does allow the chemical manufacturer to request a confidentially agreement
“as soon as circumstances permit”23 in order to protect trade secrets.
First responders should always be concerned about any reference to delayed health effects. This
characteristic of hazardous materials may play a role for first responders as well as others exposed to
hazardous materials who may refuse medical care because they do not appear to suffer any ill effects
immediately after the exposure.
Some hazardous materials can have negative health effects that could be delayed for 24 to 72 hours or
longer, and those exposed to these materials must be made aware of this dangerous potential. Sometimes
victims choose to ignore these warnings. However, any “patient refusal” statement on prehospital care
reports should include a commentary relating the efforts of first responders to provide information relative
to delayed health effects. First responders may also wish to consider attaching a copy of the MSDS to
their prehospital care report.
68
Obtaining a Material Safety Data Sheet

An MSDS is generally not prepared for the benefit of first responders, but rather for employees who use
chemicals in the workplace. Specifically, 29 CFR 1910.1200 requires “all employers to provide information
to their employees about the hazardous chemicals to which they are exposed” (italics added).24 The use of
MSDS is just one option employers have to transmit this information, in addition to warning labels and
training programs.
Since the emphasis regarding hazard communication is on employees, first responders should not expect
to see an MSDS attached to shipping papers for regulated hazardous materials during a transportation
incident. While 49 CFR 172.602 states that some form of emergency response information must
be available with shipping papers, the use of an MSDS to meet this requirement is optional rather
than mandatory.
The emphasis on the term employees also applies to retail stores where hazardous materials are sold. In
particular, 29 CFR 1910.1200 (b) (4) states in part that “in work operations where employees only handle
chemicals in sealed containers which are not opened under normal conditions of use (such as are found
in marine cargo handling, warehousing, or retail sales) ... employers ... shall obtain a material safety data
sheet as soon as possible for sealed containers of hazardous chemicals received without a material safety
data sheet if an employee requests the material safety data sheet”(italics added).25 According to this section
of the standard, there is no requirement to provide the MSDS except when an employee requests one.
There is another exemption found in 29 CFR 1910.1200 regarding the availability of MSDS.
Employers are generally not required to provide an MSDS for products when the “duration and frequency
of exposure is not greater than the range of exposures that could reasonably be experienced by consumers
when used for the purpose intended.”26
Another common misconception of first responders is that there are hundreds of MSDS sitting in a
book at all fixed facilities just waiting for their arrival, and the MSDS are all up-to-date. Unfortunately, 29
CFR 1910.1200 requires only that an MSDS be “readily accessible during each work shift to employees
when they are in their work area.”27 It states that “electronic access and other alternatives to maintaining
paper copies of the MSDS are permitted as long as no barriers to immediate employee access in each
workplace are created by such options.”28
Immediate access to the employee and immediate access by first responders can mean two different
things. Rather than maintain copies of MSDS on-site, some employers may rely on subscription services
that provide MSDS on demand. This demand might be driven by an employee with a question on personal
protective equipment or by the first responder during an emergency incident.
As a general rule, a first responder should not expect to be met by someone who is waving an MSDS
in anticipation of the first responder’s arrival. And while there is the likelihood that a first responder can
access MSDS at some fixed facilities, he should remember that electronic access requires computers or fax
machines. Of course, once a first responder evacuates a building, the MSDS are inside, along with any
means of electronic transmission, while the first responder and everyone else are outside. What does a first
responder do in this situation?
69
Despite preplanning that may require certain fixed facilities to provide a community’s LEPC with
copies of various MSDS for products they use or store on-site, the requirements for these are limited
at best. Even when MSDS are sent to the first responder’s locality, copies may never make their way to
the front seat of his apparatus. Therefore, without access to a hard copy or some means of electronic
transmission within the building just evacuated, the first responder’s only option may be to obtain a copy
of the MSDS from a remote source.
A first responder could contact the same MSDS subscription service used by the facility, call
CHEMTREC, or perhaps contact the manufacturer of the product directly. If a first responder is able to
locate an MSDS from a remote source, getting it to the scene may be difficult. Most emergency response
apparatus do not have Internet access or fax machines in the front seat. Instead, the first responder may
need to request that the MSDS be faxed to a nearby location such as a fire station, police station, or a
neighboring business.
Once an MSDS is received, the first responder should request that several copies be made of the
document rather than just bringing the original to the incident scene. Besides not wanting to lose the
original, another reason for extra copies is that hazardous materials teams, medical personnel on-site,
hospitals, and cleanup contractors should all have a copy of the MSDS.
Finally, first responders should be aware that paper copies of MSDS on site at a facility could be
out-of-date. It is therefore recommended that the first responder check with the manufacturer (whose
telephone number should be on the MSDS) to make sure that any MSDS being used is current. Of
course, when making these calls, he should be prepared to hear, “We no longer make that product. We
sold that product line to the XYZ Company. You will have to call them for help.”
A brief summary regarding the availability of MSDS based upon 29 CFR 1910.1200 is as follows:
• Required access. This includes employees who use chemicals in the workplace, retail
vendors who sell to employers, and the LEPC (for materials based upon federal reporting
requirements).
• Exemptions. These include retail vendors who do not sell to employers and operations where
employees only handle chemicals in sealed containers that are not opened under normal use,
or situations in which employee exposure is no greater than normal consumer use.
• Means of access. These include paper copies and electronic access (e.g. fax or computer).
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Hazardous Materials Guide for First Responders

A document available in CD-ROM format from the United States Fire Administration (USFA) is the
Hazardous Materials Guide for First Responders. According to the publishers, the book “provides important
information for the initial response to both transportation and fixed facility incidents.”29 The intended
users are those first responders trained at either the Awareness or Operations level as defined in 29 CFR
1910.120.
The book provides detailed response An EMS crew responded to an
information for several hundred different materials
using specific material guides. Each guide provides a incident that involved an adult
brief description of important chemical and physical male who had been exposed
properties, along with a list of expected hazards
that could be encountered. Additional information to chloropicrin. Following
is provided regarding appropriate tactics for first
responders, including dealing with releases that decontamination, the patient
occur without fire as well as situations that involve was transported to a local
fires. Tactics also include first aid measures with
a special emphasis on situations when rescue of hospital. EMS personnel provided
those contaminated with the hazardous material pre-hospital care based upon
is discouraged. Each specific material guide is
referenced by both material name and four-digit recommendations from a poison
identification number.
control center. Knowing that
First responders are also provided with detailed
information on bulk transportation containers emergency department personnel
that include silhouettes of various cargo tanks would want additional definitive
and tank cars. This information is supplemented
with a glossary of terms and abbreviations information on patient care,
common to hazardous materials response, along CHEMTREC was contacted and
with telephone numbers for CHEMTREC and
the National Response Center. The page of the their representative agreed to fax
document that includes these telephone numbers
also provides space for first responders to record a copy of the materials safety data
important telephone numbers of their various sheet (MSDS) for chloropicrin to
local and state agencies. This could include those
with responsibility for emergency management, the hospital. The MSDS was in
environmental regulations, and community health. the hands of the treating physician
First responders can obtain a free copy of this
document by accessing the USFA Web site at www. upon arrival of the patient.
usfa.fema.gov and ordering publication Item #9-
1678.
71
Key Points
• Appropriate information sources allow first responders to make defensible decisions.
• The latest edition of the ERG should always be readily available on every emergency
response vehicle.
• The ERG is an easy-to-use document that provides first responders with immediate
information response for use during the initial phase of a hazardous materials incident.
• Information can be found in the ERG by knowing a hazardous material’s proper shipping
name, four-digit identification number, or hazard class.
• Information available from an MSDS includes chemical and physical properties of
hazardous materials and recommendations for medical treatment.
• In order to select appropriate response tactics, first responders should always pay attention
to the specific gravity, miscibility, and solubility of materials that spill into bodies of water.
• When reviewing health hazard information, first responders should remember that the
lower the ppm value for any exposure limit, the more harmful the material.
• First responders should not expect to find MSDS attached to shipping papers. Nor will
MSDS likely be available at locations where hazardous materials are only stored or sold.
• A treating physician is authorized to obtain trade secret information excluded on an MSDS
during situations when it is needed in order to provide emergency medical care.
• All first responders should have access to the Hazardous Materials Guide for First Responders,
which is available from the United States Fire Administration.
72
Chapter Questions
1. What is the best way to learn how to use the ERG2004?
2. Define the meaning of the term n.o.s.
3. Using ERG2004, identify three ways that first responders can determine the appropriate
guide for information about a hazardous material.
4. Each guide from ERG2004 lists information relative to fire and explosion hazards along
with health hazards. What is the significance to first responders when one of these hazard
categories is displayed above or below the other in any guide?
5. List the 12 categories of information for an MSDS.
6. What is meant by the notation N/A found on some MSDS?
7. Are warehouses and retail establishments required to provide first responders with
an MSDS? Explain the answer and cite the appropriate supporting sections of OSHA
1910.1200.
8. Identify at least three ways that first responders can locate an MSDS.
9. Why should a first responder make extra copies of an MSDS during a hazardous materials
emergency? Who should be provided a copy of the MSDS?
10. Are treating physicians entitled to trade secret information in order to provide medical care?
Explain the answer and cite the appropriate supporting sections of OSHA 1910.1200.
73
References
1 U.S. Department of Transportation. 2004 Emergency Response Guidebook, p. 2.
2 Ibid.
3 Ibid.
4 Ibid.
5 Ibid., p. 362.
6 Ibid., p. 15.
7 Ibid., p. 19.
8 Ibid., p. 295.
9 Ibid.
10 Ibid., p. 299.
11 Ibid.
12 Ibid.
13 Code of Federal Regulations. 29 CFR § 1910.1200(g)(2), http://www.osha.gov.
15 Code of Federal Regulations. 29 CFR § 1910.1200(c), http://www.osha.gov.
16 Ibid.
17 Code of Federal Regulations. 29 CFR § 1910.134(b), http://www.osha.gov.
18 Code of Federal Regulations. 29 CFR § 1910.134(d)(1)(iii), http://www.osha.gov.
19 Code of Federal Regulations. 29 CFR § 1910.134(d)(2)(i)(A), http://www.osha.gov.
20 Code of Federal Regulations. 29 CFR § 1910.134(d)(2)(i)(B), http://www.osha.gov.
22 Code of Federal Regulations. 29 CFR § 1910.1200(i) (2), http://www.osha.gov.
23 Ibid.
24 Code of Federal Regulations. 29 CFR § 1910.1200(b)(1), http://www.osha.gov.
25 Code of Federal Regulations. 29 CFR § 1910.1200(b)(4) and (b)(4)(ii), http://www.osha.gov.
26 Code of Federal Regulations. 29 CFR § 1910.1200(b)(6)(ix), http://www.osha.gov.
28 Ibid.
29 Federal Emergency Management Agency, U.S. Fire Administration. Hazardous Materials Guide for First Responders,
1998, p. 1.
74
8
IDENTIFYING THE MATERIAL
For first responders, one of the best ways to determine how to effectively manage any hazardous
materials incident is to identify the material(s) involved by name. By having the name of the material,
a first responder will be better able to learn detailed information about its specific characteristics.
This information is critical for safely managing patient care for anyone exposed to the material,
containing its release, estimating environmental impacts, and determining the best methods for
cleanup. Hazardous materials teams will use the name of a material when selecting appropriate
chemical protective clothing, as well as when determining the equipment needed to monitor the
surrounding atmosphere. In addition to a name, first responders may also be able to identify a
material by its assigned four-digit identification number or hazard class.
The Name of the Material

First responders should remember that the name of a material may refer to its trade name or
its product name (the name a consumer would use). It could also include its chemical name and
its proper shipping name (the description found on shipping papers). Each of these names may be
different, even though they refer to the same material. There may also be multiple chemical names,
known as synonyms, by which materials are known. Various reference sources, including MSDS, can
provide details regarding the different names that may be encountered for a particular material.
Obtaining a material name is not always simple, nor is spelling or pronouncing these names.
There are many sources from which first responders can determine the name of materials involved
in an incident. However, the important thing for a first responder to remember is to have the correct
spelling, including any letters, numbers, hyphens, and commas, as well as any special symbols.
For example, spelling butane may not appear to present any significant challenges to first
responders. In contrast, 2-methyl-1-butene may be more difficult to comprehend and relay to others
involved in the incident. A first responder should also consider that a reference to a material known
as sulfuric acid, with more than 51% acid is different than sulfuric acid, with NOT more than 51%
acid. First responders must be careful!
Proper shipping names of some materials may be stenciled on the outside of large containers (such as
transport tanks or fixed storage tanks). Trade names or chemical names may be printed on labels found on
individual containers such as drums, cans, boxes, or bags.
Proper shipping names may be effective for identifying shipments of products such as chlorine or
hydrochloric acid. However, some materials may be described on shipping papers using only a generic
proper shipping name, such as flammable liquid, n.o.s. These products are often manufactured using
a specific chemical formula that does not meet the definitions of any specific proper shipping names
available from the Code of Federal Regulations. Nevertheless, they still could represent some hazard when
transported. As an example, a drain cleaner may be sold under the trade name ABC Super Drain Cleaner,
but this same material may be shipped using only a proper shipping name of corrosive liquid, n.o.s.
Individual containers may have only the trade name readily visible, since the actual chemical
components may be in much smaller print where details of ingredients are listed on the container label.
A first responder may be able to learn these details using containers identical to those involved in an
incident, but only if they are accessible without creating hazardous exposures.
First responders may also learn the name of a material from those who initially report an incident,
or from persons at the scene. A first responder should remember, however, that any verbal transmission
of material names can be easily misunderstood with disastrous consequences. Therefore, when relaying
chemical names, whether during dispatch or during communications with others involved in the response
such as hospital staff, the message should be accomplished by spelling the name. This is preferably done
using some form of phonetic alphabet, as detailed in chapter 5.
Another source to determine the name of a material relies on the material’s physical description.
For example, first responders may respond to the scene of a box truck that has a liquid with a milky,
white appearance leaking from the rear door. This same truck may contain one or more additional liquid
materials in individual containers. Based upon the physical descriptions of these different liquids, first
responders may be able to determine which is involved in the incident through a process of elimination.
Information on the physical description of the materials may be available from the shipper whose name
appears on the shipping documents or from MSDS.
There are additional physical descriptions that can be used to determine the name of a material, such
as odor. For example, a first responder may encounter a leak of a clear liquid that at first appears to be
only water. Perhaps bystanders near the liquid prior to the first responder’s arrival describe a pungent odor
from this liquid. A similar physical description on an MSDS could be used to confirm the identity of
the material.
Of course, it is important for first responders to remember that anyone on the scene who can describe
the odor of a hazardous material (or worse, how it feels) may be a victim of exposure. This person could
be in need of immediate decontamination and medical treatment.
Finally, a first responder may also encounter materials leaking from containers that do not display any
product name. In these situations the hazardous materials may be extremely difficult to identify, especially
if they involve abandoned materials. Even if abandoned containers do display some information, the
fact that they are abandoned may mean that whatever information is available could be incorrect. The
76
person who discarded the items may have had little regard for the type of container used. Under these
circumstances, laboratory analysis may be the only means to determine the name of the material.
Four-Digit Identification Numbers

If a name is not available, first responders may be able to identify a material involved using its four-
digit identification number. This number is generally assigned to each proper shipping name used when
hazardous materials are transported. First responders should remember that while there are many instances
when several different materials share the same number, these materials are also likely share similar
characteristics. Therefore, while knowing a product’s four-digit identification will not always identify the
product, it will at least enable first responders to narrow the field to a short list of possibilities.
Use of a material’s identification number is referred to as a marking in the federal transportation
regulations. It is required in various circumstances that include display on some individual packages,
on transport vehicles that contain large shipments of small packages, and vehicles intended for bulk
shipments such as cargo tanks. On vehicles, this number may be displayed in the center of a hazardous
materials placard or on an orange rectangular-shaped panel.1 A four-digit identification number will also
be found on most shipping papers for shipments of regulated hazardous materials.
It should be noted that identification numbers may be preceded by the letters UN or NA. According
to 49 CFR 172.101 (e), identification numbers “preceded by the letters UN are associated with proper
shipping names considered appropriate for international transportation as well as domestic transportation
while those preceded by the letters NA are associated with proper shipping names not recognized for
international transportation, except to and from Canada” (italics added).2
77
Hazard Classes
If first responders are unable to learn the name of a material or its four-digit identification number,
they may still be able to learn the material’s assigned hazard class as defined in 49 CFR. According to the 49
CFR 171.8, the term hazard class means “the category of hazard assigned to a hazardous material.” Hazard
classes and their associated hazard class number as assigned by the federal transportation regulations
include the following:
1. Explosives
2. Gases
3. Flammable and combustible liquids
4. Flammable solids, spontaneously combustible materials, and dangerous when wet materials
5. Oxidizers and organic peroxides
6. Poisonous materials and infectious substances
7. Radioactive materials
8. Corrosive materials
9. Miscellaneous hazardous materials
As stated in chapter 2, “a material may meet the defining criteria for more than one hazard class, but
is assigned to only one hazard class” (italics added).3 This is done using predetermined criteria known as
the Precedence of Hazard Table found in 49 CFR 173.2(a). This assigned hazard class is also referred
to as the primary hazard, while additional hazards are referred to as subsidiary hazards. Only in limited
circumstances will information on subsidiary hazards be displayed.
Therefore, a first responder should remember that while gasoline is an obvious flammable liquid, it is
also harmful if ingested. Yet according to the Precedence of Hazard Table, the primary hazard of gasoline
is its flammability rather than its health hazard. As such, first responders will not receive any warnings
from labels or placards regarding the latter threat. First responders must be careful!
Table 8–1 provides a comparison of descriptive terms used for hazardous materials based upon the
name of a material, its four-digit identification number, and its hazard class. In the three examples listed,
the hazard class reamins the same. In examples 1 and 2 the four-digit identification number is also the
same, meaning these materials share similar hazardous characteristics. In example 3, while the hazard class
is still the same, the four-digit identification number and the name of the material are both different.
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Table 8–1 Comparison of Descriptive Terms used for Hazardous Materials
Example 1
Name of the material Diesel fuel
4-digit identification number 1993
Hazard class 3 (flammable liquid)
Example 2
Name of the material Compound, cleaning liquid (flammable)
Hazard class 3 (flammable Liquid)
Example 3
Name of the material Diethyl ketone
Hazard class 3 (flammable liquid)
In the three examples above, the hazard class remains the same. In examples 1 and 2, the 4-digit
identification number is also the same, meaning these materials share similar hazardous characteristics.
In example 3, while the hazard class is the still same as in previous examples, the 4-digit identification
number and the name of the material are all different.
Table 8–2 provides a comparison of various names used for a hazardous material. The example used
is known by its trade name, chamical name, and proper shipping name. Each name is different, but they
all refer to the same material.
Table 8–2 Comparison of Various Names used for Hazardous Materials
Trade name household bleach (the name consumers use)
sodium hypochlorite (from the container label)

Chemical name
(6% concentration, yields 5.7% available chlorine)
hypochlorite solution, with more than 5% available

Proper shipping name
chlorine (from the shipping papers)
4-digit identification number UN1791
Hazard class corrosive
The example used is known by its trade name, chemical name, and proper shpping name. Each name is
different, but they refer to the same material.
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A plastic drum fell from a Hierarchy of Material

moving vehicle traveling along Identification
a curved Interstate exit ramp. For first responders, it may be best to know that
Within minutes, a motorist the material leaking from an overturned highway cargo
tank is isobutylene. However, knowing the four-digit
stopped to pick up the drum identification number of 1075 found on the outside of
and attempted to load it into his the container will at least narrow the field to no more than
12 different materials, all with similar characteristics. Of
vehicle. He ignored the poison course, if a first responder knows only that a material is a
label and the liquid leaking compressed flammable gas, he will still be able to make
defensible decisions during the early stages of an incident.
from a crack in the bottom of Table 8–3 provides a hierarchy of material identification
the container. A passing state as it benefits first responders.
trooper took notice of these Table 8–3 Hierarchy of Hazardous Materials Identification
events. First responders called Name — includes trade name, chemical
BEST
to the scene decontaminated name, or proper shipping name (*)
the motorist and then contacted BETTER

4-digit identification number
— narrows the field of possibilities
the manufacturer, whose
Hazard class — one characteristic
name and telephone numbers GOOD
(there could be others)
were visible on the container. (*)

There may also be synonyms for
various names
There was a concern that the
drum, being abandoned, may
not have held the material
whose name was stenciled on
the outside. The motorist, when
asked earlier what the material
smelled like, responded,
“Ammonia.” This identity was
later confirmed when the
manufacturer representative
stated the product had an
“ammonia-like” odor.
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Key Points
• One of the best ways to determine how to effectively manage an incident involving
hazardous materials is to identify the material(s) by name.
• The name of a material may include its trade name or product name, its chemical name,
and its proper shipping name. These names may all be different, yet they refer to the
same material.
• Synonyms are different chemical names that refer to the same material.
• The name of a hazardous material involved in an incident may be obtained from shipping
papers or shipping containers.
• The letters n.o.s. on shipping papers are an abbreviation for “not otherwise specified” and
indicate a generic entry for a product that does not meet the definitions of any specific
proper shipping name.
• The physical description of a hazardous material may be helpful in identifying the product.
• An identification number is a four-digit number generally assigned to each proper shipping
name for hazardous materials. More than one material can use the same number, but they
each have similar characteristics.
• The four-digit identification number will be found on most shipping papers for shipment
of regulated hazardous materials and on the exterior of some transport vehicles.
• By knowing a material’s hazard class, first responders will at least have some knowledge
about one characteristic of the material.
• Under the federal transportation regulations, a hazardous material may meet the defining
criteria for more than one hazard class, but it is usually assigned to only one hazard class.
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Chapter Questions
1. List three ways that can be used to identify hazardous materials.
2. When identifying hazardous materials, can a four-digit identification number be used to
identify more than one material? Are materials that use the same number similar?
3. How is a proper shipping name different from a trade name?
4. In addition to shipping papers, where else can first responders learn the name of a hazardous
material?
5. Will the trade name of a hazardous material be used on shipping papers?
6. Can first responders use the ERG2004 to locate information based upon a hazardous
material’s trade name?
7. Upon arrival at a hazardous materials incident, first responders may encounter individuals
who are witnesses to what has occurred. When dealing with these individuals, what
precautions should first responders take for their own safety?
8. Should first responders depend upon the information displayed on the outside of
abandoned containers for the purposes of identifying the material inside? Explain
your answer.
9. If a material is assigned to only one hazard class by the federal transportation regulations,
could the material still possess additional hazardous properties?
10. The table from the federal transportation regulations that provides defining criteria
for determining the hazard class to which a material is assigned is known as the
___________________________________________.
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References
2 Code of Federal Regulations. 49 CFR § 172.101(e), http://www.myregs.com/dotrspa/.
3 Code of Federal Regulations. 49 CFR § 171.8, definition for “hazard class,” http://www.myregs.com/dotrspa/.
83
9
CHARACTERISTICS OF CONTAINERS
Containers that store hazardous materials are important considerations when assessing the
potential problems faced by first responders, since hazardous materials are usually safe unless they
are released from their containers. Any assessment of containers involved in a hazardous materials
incident must include whether the containers have an ongoing release upon arrival or perhaps have
already released all of their contents. There is also concern for containers that have not yet released
their contents, since they may have the potential to do so when exposed to stress. Sources of such
stress could include external heating, a chemical reaction inside the container that creates excessive
pressure or that weakens the container, or perhaps physical damage as a result of being struck by a
foreign object.
Several characteristics of containers must be evaluated by first responders during the course
of a hazardous materials incident. These include both general and special characteristics. General
characteristics of containers include:
• The size of the container
• Whether the container is used for transportation or for fixed storage
Special characteristics of containers include:
• What the container is constructed from (metal, glass, plastic, cardboard, etc.)
• Whether the container is pressurized or not
• Type and configuration of intended openings
• Whether the container has any means to relieve internal pressure
General Characteristics of Containers

The size of any container has an obvious importance in hazard assessment, since it determines
the potential amount of material that can be released. Federal transportation regulations provide
specific capacities for containers defined as bulk or nonbulk. However, any effort to contain
liquid material released from its container must be capable of holding all of the material from the
container should a complete release occur. This is important for first responders to remember, and it is true
whether containment consists of dikes that surround fixed storage tanks or temporary barriers built by first
responders during a transportation accident.
When dealing with containers that store gases and vapors, the size of the container will naturally
influence the size of an area likely to be affected in the event the container explodes. However, large
containers with a minor leak, perhaps at a valve or fitting, could leak for several hours, or perhaps even days
in the event that efforts to stop the release are in vain. First responders on the scene of a minor release from
a bulk container could find themselves there for a long time.
Containers used to transport hazardous materials in bulk form include highway cargo tanks and rail
tank cars. These containers may have several individual compartments separated by bulkheads, so that
damage to one compartment with a subsequent release may not necessarily affect all compartments.
However, some bulk containers that transport liquids may be open on the inside from end to end except
for a few perforated baffles designed to control movement of the liquid during transportation. Therefore,
containers without bulkheads (and therefore without individual compartments) have the potential to
release all of their contents from damage that occurs anywhere on the tank. First responders will usually be
unable to visually determine if a container is outfitted with bulkheads and thus multiple compartments.
Figure 9–1 provides a further explanation of the difference between a baffle and a bulkhead.
PERFORATED
BAFFLE USED TO
REDUCE LIQUID BULKHEAD USED
MOVEMENT IN TO CREATE TWO
ONE SEPARATE
COMPARTMENT COMPARTMENTS
Fig. 9-1 Difference between a “Bulkhead” and a “Baffle”
Bulk containers can be used to transport materials in various forms, including liquids, solids, and
gases. Some bulk highway cargo tanks, such as those designed to haul products that include gasoline
and diesel fuel, may hold as much as 9,000 gal of liquid product. High-pressure containers intended
to transport products such as liquefied petroleum gas or anhydrous ammonia may contain more than
11,000 gal of material.
The capacities for bulk rail tank cars are even greater, with quantities for some nonpressurized cars
ranging from 10,000 to 26,000 gal. First responders could encounter pressurized rail tank cars containing
liquefied petroleum gas with loads in excess of 30,000 gal, while chlorine tank cars could contain as much
as 90 tons of material.
First responders will also encounter a vast assortment of nonbulk containers that include drums,
barrels, crates, and cylinders. These could range in capacity from several ounces to more than 100 gal of
86
product. Anyone who responds to incidents that involve hazardous materials will also deal with containers
intended for use by consumers, including spray cans, paper bags, glass or plastic bottles, and even propane
cylinders used on backyard grills. These containers do not represent significant volumes when compared
to those used for transportation. If released, however, certain materials still present significant threats to
first responders, including pesticides, corrosives, and flammable liquids and gases.
Another word of caution for first responders is that a large number of nonbulk containers stored
together, whether in a building or in a delivery truck, can have nearly the same impact as a bulk container.
First responders should remember that small containers intended for ease of handling by consumers also
invite numerous opportunities for mishaps, including containers that are dropped, punctured by forklift
blades, or crushed. Furthermore, aerosol cans disposed along with household trash can become missiles
whenever a trash receptacle is on fire.
Overhaul operations during a structure fire present the potential for first responders to encounter
damaged and leaking nonbulk containers. Damage to these containers may have occurred before or
during a fire. Additionally, first responders may themselves cause damage through carelessness, such
as indiscriminate washing down of walls that contain shelving units. Any attempts during overhaul to
move a container without first evaluating its condition may result in a sudden release of contents, with
disastrous consequences.
Bulk fixed storage tanks can contain materials in quantities that range from several hundred to several
thousand gallons of product. These containers include aboveground home heating oil tanks, propane
tanks at residential and commercial occupancies, and underground gasoline storage tanks at service
stations. They also include a vast assortment of storage tanks found at businesses, including those that
engage in retail, manufacturing, and warehouse operations.
First responders should be aware of areas within their response district where they are likely to
encounter aboveground tanks at residential occupancies. Some neighborhoods are served by natural gas,
so the likelihood of encountering a large propane tank in the backyard of a single family residence there is
rare. However, a resident may have installed a tank for use with a propane gas fireplace.
First responders in rural areas are more likely to encounter large aboveground propane tanks and
heating oil tanks. These containers present problems not only from leaks caused by physical damage, but
also from their potential as exposures during structure fires. Of course, first responders should expect to
find small propane cylinders used with gas grills at almost any residence. They should not be surprised if
they encounter these containers stored inside sheds, garages, and even basements.
For commercial occupancies, first responders should make an effort to learn the type of materials and
quantities stored on-site. Potential sites for hazardous materials include retail, manufacturing, warehouse
operations, construction yards, and petroleum terminals.
It is important for first responders to remember that not all fixed facilities are required by federal law
to report all hazardous materials stored or used on-site. Thus preplanning may be the only way to learn
about these items as well as to get an MSDS before an incident. Additional information on preplanning
for a hazardous materials emergency at fixed facilities was given in chapter 4.
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Special Characteristics of Containers

Special characteristics of containers include what the container is made from and whether the container
is pressurized or not. The material from which a container is made is important to manufacturers and
shippers from a cost perspective. Inexpensive nonbulk packaging can provide manufacturers with the
potential for higher profits, while lightweight bulk packaging reduces the overall weight of transport
vehicles so that more materials can be shipped with each load.
Most nonbulk containers are made from materials that include various metals, glass, cardboard, paper,
and plastic. First responders may encounter bulk storage tanks made of plastic. Lightweight containers
that reduce expense and provide for ease of handling may offer little protection from physical impacts
encountered during vehicle accidents or from excessive heat during exposure to fire.
Bulk containers can be made from aluminum alloys or various types of steel, such as mild steel,
high strength steel, or stainless steel. While aluminum may offer a lightweight material for containers
that is more economical than steel (remember the lighter the container, the more product that can be
transported), first responders should remember that aluminum containers impinged by fire at the vapor
space above the liquid level will often melt with the potential for a release of a hazardous material. Many
highway cargo tanks that transport hazardous materials include external ring stiffeners spaced several
feet apart along the external tank wall to provide for increased strength and durability. The placement of
baffles and bulkheads discussed earlier also provide for increased container strength.
Highway cargo tanks used to transport petroleum products are sometimes constructed of steel, while
most are constructed of .25-inch thick aluminum alloy.1 These cargo tanks can often be identified by
their distinctive oval shape when viewed from the rear.
Metal containers used to store corrosive liquids are often lined internally with a material such as
rubber to protect the metal from the effects of corrosion. In the event this lining is damaged, the corrosive
material may begin to weaken the container to the point that the container can begin to leak. Once a leak
occurs, first responders should be prepared for an opening that gets progressively larger as the chemical
continues to attack the container wall.
Some bulk transport containers are designed for materials that require heating in order to allow the
product to liquefy for loading and offloading. In order to retain this heat, these tanks are sometimes
constructed with a layer of insulation around the tank as a means of temperature control. Other bulk
transportation containers, especially rail tank cars, may use insulation as a means of protecting the
container from the effects of impinging fire. Most forms of insulation applied to bulk containers are
protected by an outer protective layer of metal, resulting in a tank within a tank. Insulated highway cargo
tanks will often have a distinctive horseshoe shape when viewed from the rear. Figure 9-2 provides details
of how some insulated containers are constructed.
88
SOLID LINES INDICATE OUTER LAYER USED TO PROTECT

INSULATION APPLIED TO INNER CONTAINER
INSULATION PLACED
BETWEEN THE INNER
CONTAINER AND THE
OUTER LAYER IN
ORDER TO CONTROL
THE TEMPERATURE OF
INNER CONTAINER THE MATERIAL BEING
(BROKEN LINES) SHIPPED
Fig. 9-2 Example of an Insulated Container
With many insulated containers, of importance to first responders is that damage apparent to the outer
protective layer may not necessarily mean that the inner container is damaged. However, the presence of
this outer layer along with the insulation will make evaluation of damage to the inner container difficult.
In Figure 9-3, minor damage (in the form of a dent) is visible to the outer layer of the container near the
center of the photograph. However, the inner container remains intact.
Fig. 9-3 A typical insulated highway cargo tank Courtesy of Gary V. Gesling
89
An evaluation of containers during a hazardous materials incident also includes whether the containers
involved are pressurized or not. First responders should always remember that pressurized containers usually
present the greatest danger. However, they should also remember that the term nonpressurized does not
necessarily mean an absence of pressure. Instead, the materials may be stored above atmospheric pressure
but below levels defined by regulatory agencies for pressurized containers.
For example, bulk transportation containers for gasoline are designed to withstand very low pressures,
sometimes as low as 3 pounds per square inch (psi). Low-pressure containers used to transport some
liquid hazardous materials, such as flammable inks and solvents, corrosives, oxidizers, and poisons may
have operating pressures that range from 25 to 75 psi. This could be compared to high-pressure bulk
transport containers used for products such as liquefied petroleum gas, which may store this material at
pressures as high as 300 psi.
Visual clues that can assist first responders to identify high pressure containers include rounded ends
that are designed to distribute the higher internal pressures. However, as discussed earlier, some containers
may be insulated, and an outer layer of material used to protect the insulation may obscure the rounded
ends. This could make it difficult for the first responder to identify these as pressurized containers. Figure
9-4 identifies two primary characteristics for most compressed gas cylinders, and first responders should
always be aware of them.
PRESSURE RELIEF DEVICE
ROUNDED TANK ENDS
Fig. 9-4 Typical Pressure Container
During an accident, any container can be suffer damage that can cause the tank to begin to leak
immediately. Other forms of damage, such as a crease, dent, or gouge, may weaken a container and
make it more dangerous for first responders by increasing the potential for a later release of product
during the course of an incident. This damage is especially troublesome when it occurs at the weld lines
on high pressure metal containers, since these areas are usually weaker due to the effects of the welding
process on most metals. Weakened containers that have overturned may also present first responders with
a possibility for a release of product during efforts to upright the container.
First responders should always remember that bulk transport containers involved in rollover accidents
will make it difficult to evaluate all sides of the container for damage. Figure 9-5 shows a bulk compressed
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gas cargo tank that has overturned. What degree of damage has occurred on the portion of the tank that
first responders cannot see?
Fig. 9-5 Overturned bulk compressed gas container Courtesy of Gary V. Gesling
Container openings
All containers include openings, whether as a means to load and unload product or to allow workers to
enter large tanks for maintenance. These openings include outlets, valves, and manholes. Some openings
have covers that screw on and off or that operate with a hinge while others are pressed or bolted into
place. Of importance to first responders is how many openings are present, and if there are any means to
protect these openings from damage.
Another consideration for first responders is the location of these openings. On liquid containers,
openings below the level of the liquid usually mean that the liquid can leak to at least that level. Thus if
an opening is on the bottom of the container, a first responder should expect most of the material to be
released. For pressurized containers that contain liquefied gases, such as propane, an opening below the
liquid level will release propane in liquid form (which will quickly vaporize). An opening above the liquid
level will release propane as a gas.
Any openings, including loading and unloading accessories such as valves and piping, located on
the bottom of bulk transport containers are more likely to be damaged during accidents as compared to
openings located on the top of containers. While it might therefore seem logical to place all openings on
the top of containers used to store and transport materials such as liquids and solids, one should remember
that many of these materials, such as gasoline, are often offloaded by gravity. Thus any top-mounted
91
opening would instead require use of a pump. Of course some bulk transportation containers do have their
openings located on top, such as rail tank cars that transport liquefied petroleum gases or some highway
cargo tanks that transport corrosive liquids. However, these openings can suddenly find themselves on the
bottom in the event the container rolls over during an accident. Figure 9-6 provides an example of loading
and unloading accessories located on the bottom of a container designed to transport liquids.
Fig. 9-6 Example of bottom mounted loading and unloading accessories Courtesy of Gary V. Gesling
Many transport containers with top-mounted openings include devices intended to protect the
openings during a rollover accident. These devices usually include stiff metal walls that surround openings
and that are designed to support at least twice the weight of the loaded cargo tank motor vehicle.2 Figure
9-7 provides an example of a typical rollover damage protection device.
Figure 9-8 shows four manhole openings in the top of a bulk container. These openings can allow for
release of product during a rollover accident. Notice that the “rollover damage protection device” consists
of stiff walls that run parallel to the long axis of the container along both sides of the manhole openings.
These walls are designed to protect the manhole covers should the container completely overturn.
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ROLLOVER DAMAGE
PROTECTION DEVICE
DESIGNED TO PROTECT
TANK OPENINGS
TANK VALVES
Fig. 9-7 A typical rollover damage protection device
Fig. 9-8 Example of rollover damage protection on an overturned cargo tank Courtesy of Gary V. Gesling
93
As an additional precaution, some valves on bulk transportation containers are designed to break
away if struck, thereby limiting the amount of damage that could occur if the valve was instead allowed
to tear away from the container. Other types of valves include those designed to shut if an excess flow is
detected, as may occur during an unintended and uncontrolled release of product should a hose being
used to load or offload material suddenly burst.
Many bulk transport containers will also include emergency switches that allow for valves to be closed
both manually or through heat activation (such as when a container is exposed to fire). First responders
may even encounter some of these containers equipped with remote control devices that allow valves to
be closed at a point several feet from the container.
Pressure relief devices

Most bulk containers include some form of a pressure relief device designed to minimize the likelihood
of a rupture from excessive internal pressure. These can be spring-loaded devices designed to open and
close, frangible disks that break open under extreme pressure, or fusible plugs that melt at a pre-determined
temperature. It is important to remember that frangible disks and fusible plugs are not designed to close
once opened. Problems with pressure relief devices can occur when frangible disks break during rough
handling of containers, or when fusible plugs leak at the threads where they are attached to the container.
In addition, some spring-loaded pressure relief devices may become stuck in the open position and not
close, despite a reduction of the internal pressure to safe levels.
First responders must always remember that if a pressure relief device is open, there is probably a good
reason. Any effort made to close or restrict the flow of a pressure relief device could result in a container
that is then subject to pressure extremes, with serious consequences.
Nonbulk compressed gas cylinders often include pressure relief devices similar to those used on
bulk containers. However, nonbulk containers such as metal or plastic drums often do not have any
pressure relief device. Thus internal pressure, whether from excessive heat or a chemical reaction inside,
can cause the container to burst. First responders should also be aware that a pressure relief device is
prohibited on compressed gas cylinders that contain certain types of hazardous materials that are classified
as poisonous.3
Temperature and Pressure of Materials

Related to Container Storage
Hazardous materials may be stored at normal temperatures and atmospheric pressures in their
containers. Examples include liquids such as gasoline, paint, and drain cleaners, as well as solid materials
such as granular fertilizers and pesticides. Gases, however, are normally compressed under pressure inside
their containers as a means of increasing the volume of material stored. The internal pressures of these
containers can range from several hundred to several thousand pounds of pressure per square inch.
Despite efforts to compress a gas as a means of increasing the volume of material inside a container, this
volume can be increased several hundred times more if the material is in the form of a liquid. Therefore,
94
those who ship and store gases have an interest in liquefying gases in order to allow for a more economical
handling of these materials.
When discussing materials that are liquids, gases, and vapors, the same molecules of the material are
involved. The difference is that as a gas or vapor, these molecules have more energy and are therefore more
active and move farther apart from each other. In a liquid form, these same molecules have less energy and
therefore move in closer proximity to each other than they would as a gas or vapor.
Liquefied gases
One means to liquefy a gas is simply by exerting pressure that then forces the molecules of the gas
closer together. Some gases may be liquefied with the application of only a few hundred pounds of
pressure, and these materials are often referred to as liquefied gases. As an example, when pumped into the
appropriate container, propane becomes a liquid stored under pressure. Once released from its container,
propane has an expansion ratio of 270 to 1, meaning that 1 cubic foot (ft3) of liquid will vaporize to 270
ft3 of gas.4 Always remember that this rapidly expanding vapor cloud can quickly engulf unsuspecting
first responders!
Despite now being a liquefied gas under pressure, propane is still stored at normal temperatures,
therefore no special container is needed other than one that will withstand the higher internal pressures.
A first responder should remember that all containers of liquefied gases will include a space above the
liquid level that contains the material as a vapor. This vapor space is sometimes as high as 15%–20% of
the capacity of the container and is intended to allow for expansion of the liquid during normal handling
and storage.
Overfilling these containers with liquid can sometimes result in premature activation of its pressure
relief device. Therefore many new propane cylinders, especially those intended for sale to consumers at
retail outlets for use with gas cooking grills, are now outfitted with an overfill protection device (OPD).
The presence of a container with an OPD is usually indicated by a triobular hand wheel (one that has
three distinct points), as opposed to a traditional round hand wheel found on tanks without an OPD.
Nonliquefied gases
In contrast to liquefied gases, some materials are considered to be nonliquefied gases. These
nonliquefied gases consist of molecules with extremely high levels of energy at normal temperatures,
so that no reasonable amount of pressure is capable of compressing these molecules into a liquid state.
Examples of nonliquefied gases include oxygen and nitrogen.
First responders should remember that the SCBA cylinders and oxygen cylinders they use contain
gases that are nonliquefied, despite these gases being stored at pressures in excess of 2,000 psi. However,
one way to liquefy these gases and thereby increase the amount stored in a container is to cool the liquid,
thereby reducing the energy of the molecules.
A process known as cryogenics can reduce the temperature of the material to lower than –150ºF.
However, while cryogenics can increase the volume of material stored in a container, it can do so only as
long as the extremely low temperatures can be maintained. Therefore, cryogenic liquids are usually stored
and shipped in insulated containers, with lower internal pressures than containers that transport liquefied
gases such as propane.
95
Despite the lower internal pressures, containers of

Just after midnight, a highway cryogenic liquids still present first responders with a
cargo tank containing hydrochloric significant potential for serious injuries. Such injuries
may occur due to frostbite should first responders
acid was found to be leaking while encounter any of the extremely cold liquid. Furthermore,
parked at an interstate highway the expansion ratios of cryogenic liquids are generally
much greater than for liquefied gases. As an example,
rest area. First responders at the liquid nitrogen has an expansion ratio of 694 to 1, while
liquid oxygen has an expansion ratio of 857 to 1.5
scene reported a finger-size hole
Another potential hazard is that the insulation
in the left rear side of the tank applied to these containers is never 100% effective.
and at that time the origin of the Thus, as the contents absorb heat from the ambient (or
surrounding) air, the temperature and pressure of the
breech was unknown. However, cryogenic cargo will increase. For cryogenic liquids that
within two hours, as members of a are flammable, there is often a limited amount of time
during which the material can be transported to ensure
hazardous materials team began that the internal pressure of the container does not
increase to a point where it would activate the pressure
attempts to stop the release, relief device. However, highway cargo tanks designed to
the breech had expanded to an transport atmospheric cryogenic liquids, such as oxygen
and nitrogen, are designed to bleed off excess pressure
approximate 12-in. long opening during transport.
that ran parallel to the long axis A first responder should be prepared for this when
of the tank. Later it was learned called to an incident involving a highway cargo tank
containing liquid nitrogen or liquid oxygen with obvious
that the interior lining of the tank venting of the contents. These incidents are often
reported by citizens unaware of special characteristics
had failed at the point where the for this type of container.
original hole had occurred and that While the release of any product under these
continued exposure of the metal circumstances might appear dangerous to the
community, it is helpful to remember that the Earth’s
tank wall to the corrosive affects atmosphere contains these same gases. Of course, while
of hydrochloric acid had resulted on the scene, first responders are cautioned against
assuming that there are no other problems associated
in the hole continuing to increase with this release of material. It is therefore highly
recommended that the vehicle’s driver or a representative
in size. of the transportation company be consulted.
96
Key Points
• Characteristics of containers that must be evaluated during the course of a hazardous
materials incident include both general and special characteristics.
• General characteristics of containers include the size of the container and whether the
container is used for transportation or for fixed storage.
• Special characteristics of containers include what the container is constructed from, whether
the container is pressurized or not, the type and configuration of intended openings, and
whether the container has any means to relieve internal pressure.
• Bulkheads are used to create separate compartments, while baffles are used within
compartments in order to reduce the movement of liquids during transportation.
• Containers that carry liquid petroleum products may be constructed of aluminum that is
approximately 1/4 in. thick. Containers that carry liquefied petroleum gas stored at high
pressures are usually made of steel with a wall that is sometimes 1/2 in. thick.
• Visual clues that can assist first responders to identify pressure containers include rounded
ends that are designed to distribute the higher internal pressures.
• Metal containers used to store corrosive materials often have a protective inner liner.
• If a pressure relief device is open, there is probably a good reason, and any effort to close or
restrict the flow of this device could result in pressure extremes, with serious consequences.
• When released from its container, propane has an expansion ratio of 270 to 1. This means
that 1 ft3 of liquid vaporizes to 270 ft3 of gas.
• Expansion ratios of cryogenic materials are generally much greater than for gases liquefied
by exerting pressure. Liquefied oxygen has an expansion ratio of 857 to 1.
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Chapter Questions
1. List five characteristics of containers used to store hazardous materials that first responders
should consider when assessing potential hazards during a hazardous materials incident.
2. Describe the difference between a bulkhead and a baffle as they are used inside bulk
transportation containers.
3. What is sometimes used to protect the inside of metal tanks used to transport corrosive
materials? What can happen if this protection fails?
4. Describe three characteristics of nonbulk containers that can present hazards to
first responders.
5. How does the behavior of storage tanks made of steel compare to those made of aluminum
when these tanks are exposed to fire?
6. Identify three types of pressure relief devices. Why should responders never attempt to
close an operating relief valve?
7. Identify two means used to liquefy gases.
8. How can the presence of an OPD on a propane gas cylinder be determined?
9. Why should the expansion ratio of an escaping liquefied gas be of concern to
first responders?
10. Should first responders ever be concerned about venting that appears from a cargo tank
containing liquid oxygen or liquid nitrogen?
98
References
1 Highway Emergency Response Manual, American Association of Railroads., 1996.
2 Code of Federal Regulations. 49 CFR § 178.345-8(c)(1), http://www.myregs.com/dotrspa/.
3 Code of Federal Regulations. 49 CFR § 173.301(f )(6), http://www.myregs.com/dotrspa/.
4 Fire, Frank L. The Common Sense Approach to Hazardous Materials. New Jersey: PennWell Publishing, 1996, p. 154.
5 Ibid., p. 188.
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10
EVALUATING THE ENVIRONMENT
First responders evaluating the environment during a hazardous materials incident must always
consider the location of the incident. They also must consider any exposures in proximity to the
scene that could be adversely affected by a chemical release. Factors include population density, the
location of highways, waterways, and railroads, as well as environmentally sensitive areas.
Additional environmental factors include the weather and time of day. The time of day will
likely influence the number of people potentially exposed to a hazardous material, while weather,
especially temperature, can influence the behavior of hazardous materials. Both weather and time of
day will determine working conditions for first responders.
Location
The location of an incident has a tremendous influence on just how serious the incident really
is. A first responder should remember that the location of an incident is not just the immediate
area, but any area that can be affected if a released hazardous material migrates from the scene. This
migration can occur in several ways, including:
• Downhill on a slope, especially on a hard, paved surface
• Seepage underground on a soft surface such as soil
• Liquids or solids entering a body of water, such as a creek or pond
• Liquids or solids entering a storm drain or sewer system
• Vapors, gases, mists, and dusts affected by air currents (natural or manmade)
Exposures include not only water, soil, and air, but also activities that can be affected by the
release of a hazardous material. Some of these activities could qualify as critical, meaning that a
disruption can severely impact a community’s quality of life or create serious financial impacts. Critical
systems include, but are not limited to:
• Highways
• Waterways
• Utilities (gas, electric, communication, water, or sewer)
• Industrial or commercial areas
For example, while spills of a chemical on a body of water can kill and injure wildlife, the same spill
may also interfere with recreational activities. It could limit or eliminate commercial maritime activities
and also contaminate sources of drinking water. These incidents represent the potential for serious
consequences or situations in which the actions of first responders can really make a difference.
During the early stages of a hazardous materials incident, representatives from local and state
environmental agencies as well as health departments can provide assistance in assessing potential
environmental threats. They can also provide suggestions for dealing with these problems, and the first
responder should not hesitate to contact them. Local and state game wardens can also provide valuable
input when first responders are assessing whether specific types of wildlife may be affected by a release.
Additional information on contacting these individuals was presented in chapter 6.
Public works officials may be able to provide information relative to the location of storm drains and
other utility lines. These same individuals may also have maps and charts that they can provide to local
first responders to have available in command vehicles.
When considering the location of a hazardous materials incident, first responders should be aware of
small conduits used for utility lines. These conduits may also serve as a means for hazardous vapors and
gases to move between buildings or perhaps between underground utility vaults. As a result, a release
of natural gas that enters an underground conduit could ultimately travel to the basement of a nearby
building, with disastrous consequences.
First responders must also remember that cracks in underground pipes can allow for the migration
of liquid hazardous materials. For example, a leaking underground storage tank containing a petroleum
product can easily discharge its contents into the surrounding soil. It could ultimately enter nearby sewer
or storm drain lines through cracks in those lines. Soon after, local residents may complain of a petroleum
odor from their toilets with a very real fire and explosion hazard. This type of situation may be especially
noticeable after heavy rains that may increase the movement of hazardous materials through soil.
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Weather
Besides daily changes in weather related to temperature and precipitation, weather conditions are
influenced by factors that include the time of year and the time of day. Some situations for first responders
to consider include:
• A release of a hazardous material as either a gas or vapor that occurs outdoors at 3:00
a.m. during the summer may affect people who are asleep with windows open in their
bedrooms. This could be compared to a similar release that occurs at 3:00 a.m. on a cold,
rainy day during the winter, when most people will likely have their windows shut.
• An incident involving a liquid capable of producing large quantities of a toxic vapor is
released outdoors in a downtown urban area during lunch time on a warm spring day.
There are likely to be large number of people outdoors, and they are potential casualties.
If a similar incident were to occur at midnight, there would likely be fewer casualties.
Weather will play a role in determining the extent of problems faced by first responders, since problems
associated with a spill of a liquid or solid material outdoors becomes magnified during a rainstorm due to
water runoff. For example, rain can fill temporary outdoor containment basins, causing them to overflow
and release any hazardous materials that may have been otherwise contained. While most first responders
are capable of building temporary barriers on land to contain a spill of a hazardous material, few of these
barriers can withstand the impact of heavy rain.
When containment basins and temporary barriers fail due to heavy rains, attempts to contain the
material will likely be in vain. Much of the product will likely be washed away and become unrecoverable.
However, first responders should at least attempt to locate the direction and ultimate destination of any
contaminated runoff, since this material may still impact waterways or water intakes, or it may affect
treatment plants that manage storm water.
Weather also plays a role in the safety of personnel. Extreme heat or cold as well as hazards from
lightning should be considered. During hot weather, first responders may decide to wear less protective
clothing for reasons of comfort, but these decisions can increase the potential for personal injury.
Fluid intake to prevent dehydration along with efforts to prevent heat-related illnesses must be
considered early into an incident, rather than later. During any operation that involves weather extremes,
first responders should never hesitate to request to have medical personnel on-site in anticipation of
weather-related illnesses. Ambulances can also provide a cool place for members of hazardous materials
teams to stage prior to making an entry using chemical protective clothing.
Wind currents can easily move dangerous gases and vapors. While this movement may increase the
size of an area affected by a release, it may also dilute the concentration of a hazardous material by mixing
it with air, thereby reducing the hazard level. While a strong wind may have some benefits, there are
still downwind exposures to consider, including those outdoors as well as air intake systems of nearby
buildings. Furthermore, air movement will not only affect gases and vapors, but also dusts from finely
ground solid materials. These dusts can present as great an inhalation hazard as any gas or vapor.
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First responders should also keep in mind that wind speed and direction are subject to change with
little warning. While first responders should always operate upwind of where a hazardous material has
been released, they must be prepared to relocate if they suddenly find themselves downwind of a chemical
release. They must stay alert for unusual odors at the scene.
First responders should also be prepared for any type of weather. They must make an effort to get
weather forecasts from a reliable source to anticipate thunderstorms or significant shifts in temperature.
They should never rely solely on portable weather stations at the incident site. Hazardous material
incidents are sometimes measured in days rather than hours. Depending upon the location and the time
of year, changes in the weather can occur during the course of an incident, especially during the spring
and fall. First responders should always make arrangements to provide for the shelter of those on the
scene, using nearby buildings or perhaps even a school bus if necessary.
Time of Day
The time of day has numerous potential impacts. One of the most critical for first responders is that
higher outdoor temperatures generally associated with daylight hours can potentially raise the internal
pressures of containers. This holds true whether these containers are outdoors or inside buildings without
some means of temperature control. Containers with high internal pressure are more likely to burst or
cause relief valves to operate, thereby releasing their contents.
First responders using the “Table of Initial Isolation and Protective Action Distances” found in the
Emergency Response Guidebook always need to pay attention to the time of day. This is because the suggested
distances found in that table usually increase for incidents that occur at night.
Nighttime operations also expose first responders to problems that include limited visibility and
fatigue. Personnel operating at 3:00 a.m. with disrupted sleep are far greater candidates for injury. This
remains true despite the adrenaline rush and caffeine fix that propels some into what appears to be a state
of perpetual motion.
One of the best ways to provide for safe working conditions during nighttime operations is with
portable lighting. It is true that some fire departments may have vehicles with sufficient overhead lighting.
However, there are times during a hazardous materials incident when first responders may not want to
park their $500,000 rescue or ladder truck close to a leaking cargo tank. Exposure to the hazardous
material vapors could subsequently destroy the vehicle’s chrome, body paint, and hydraulic lines.
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One solution is to rent overhead lighting units. But there are a few words of caution for
first responders:
• Order these units long before it gets dark. If the first responders are at the scene of a
hazardous materials incident of any magnitude, they should always anticipate that they
will be there for several hours.
• Make sure the responsible party pays for these units—not the fire department.
• Start and run all rental lighting units before the rental delivery truck leaves the scene and
before it gets dark.
• Know how to refuel the portable lights and how long the units will run before refueling is
required. Once again, check with the rental company representatives before they leave.
105
Taking Care of First Responders

Another very real aspect of hazardous materials incidents related to the environment and the incident
location is some means to provide first responders with meals and restroom facilities. While nearby
businesses may offer their facilities for the purposes of shelter, providing for meals is another story. Of
course, most fire departments probably already have arrangements with auxiliary units and local public
service organizations that may be able to provide these meals.
During a hazardous materials incident, it is
During a period of heavy rain, first important to keep any food and rehab station far
responders were forced to deal with away from areas of potential danger. Also, first
responders must be provided with some means
a leaking aboveground storage tank to wash their hands prior to eating. Depending
that contained approximately 300,000 upon the incident location, running water
might be unavailable. Therefore, a waterless-
gallons of Number 2 fuel oil. The tank type hand cleaner may be needed.
was surrounded by a dike constructed It is never the highlight of any first
of concrete block that was quickly filling responder’s career to order portable toilets
for delivery to the scene. However, the days
with fuel oil as well as rainwater. First of relieving oneself in the median strip of an
responders soon discovered that several interstate highway during a hazardous materials
incident are long gone. After a few hours,
of the mortar joints in the block wall had the environment will play a role in the basic
failed thus allowing significant amounts of needs of all first responders, so they should be
prepared for it.
the product to escape with the potential
to contaminate nearby waterways. Large
retention basins were constructed in
proximity of the dike, yet these began
to fill faster than anticipated due to
the rain. The inclement weather forced
first responders to have the contents
of the retention basins continuously
emptied using several vacuum trucks
that traveled between the site and
a nearby tank used to hold the
spilled material.
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Key Points
• The location of an incident is not just the immediate area, but any area that can be affected
if a released hazardous material migrates from the scene.
• Critical systems include, but are not limited to, highways, waterways, and utilities that
include gas, electric, communication, water, and sewer service.
• Representatives from local and state environmental agencies and health departments can
provide assistance in assessing potential environmental threats.
• Heavy rains can destroy the efforts of first responders to contain a spill of a hazardous
material in liquid or solid form.
• An underground release of natural gas that then enters an underground conduit could
ultimately travel to the basement of a nearby building, with disastrous consequences.
• While wind currents can increase the size of an area affected by a release of hazardous
materials, wind may also dilute the concentration of these materials by mixing with air.
• First responders should be prepared to relocate if they suddenly find themselves downwind
of a hazardous materials release due to a change in wind direction.
• High outdoor temperatures can raise the internal pressures of containers.
• When using the “Table of Initial Isolation and Protective Action Distances” found in
the Emergency Response Guidebook, first responders should remember that these distances
usually increase at night.
• One of the best ways to provide for safety during nighttime operations at a hazardous
materials incident is with portable lighting.
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Chapter Questions
1. Identify at least five critical systems within the local community and describe the potential
impacts if these systems were to be placed out of service.
2. How can first responders determine the direction of travel for underground storm drain
and sewer lines?
3. What hazards can a leaking underground storage tank pose to underground utilities and
nearby buildings?
4. How could a leak of natural gas from an underground line enter nearby buildings?
5. Identify at least five different types of weather that first responders may have to deal with
during a hazardous materials incident. How could these weather types adversely affect first
responders, and what actions could they take to protect themselves?
6. What advantage can wind have during a hazardous materials incident?
7. Identify at least two things for first responders to consider when assessing the impact of
wind during a hazardous materials incident. Why are these important?
8. Identify at least four considerations when using portable lighting units.
9. Describe how to manage personal hygiene needs during a hazardous materials incident.
10. Identify the types of portable shelters available to first responders in the community.
What arrangements would have to be made to get these to the scene of a hazardous
materials incident?
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11
DEFENSIVE ACTIONS FOR F IRST RESPONDERS
Upon arrival at the scene of any hazardous materials incident, first responders should always
adhere to guidelines provided by 29 CFR 1910.120 (“Hazardous Waste Operations and Emergency
Response”). These guidelines state that first responders at the Operations level are those who
respond in a defensive fashion without actually trying to stop the release. Defensive actions that first
responders can undertake include:
• Preventing a release
• Containing the release of a liquid
• Containing the release of gases and vapors
• Containing the release of a solid
• Protective actions (evacuation and in-place protection)
The dangers associated with hazardous materials increase once these materials are released from
their containers. Thus first responders should constantly assess the status of any containers that may
be involved. This status will likely influence the type and extent of defensive practices undertaken.
An assessment of containers should attempt to determine:
• Containers that have already released their contents
• Containers that have not released their contents
Additional considerations should include the material from which the container is constructed,
the volume of the container, and the identity and physical state of the material contained. First
responders must also evaluate the environment where the container is located and any stress that
may be applied to containers. First responders should keep in mind that types of stress include
thermal, mechanical, and chemical.
Preventing a Release
When attempting to prevent a release of hazardous materials, first responders should always remember
that pressurized containers usually present the greatest danger. Regardless of contents, containers under
pressure have the potential to cause significant physical harm if the container ruptures and flies apart, or
if a damaged valve assembly results in a sudden release of hazardous materials.
Pressurized containers
If the valve on a compressed gas cylinder is damaged, gas or vapor may be released at a rate and
volume faster than it would be from a pressure relief device. This rapid release of gas could then propel
the cylinder at a high speed toward any people or property in its path. The direction of travel is often
uncertain, and the consequences are potentially fatal.
First responders must remember that cylinders used to store liquefied or nonliquefied gases contain
highly compressed materials. When these materials are no longer under pressure, their volume greatly
exceeds the physical size of the container that previously contained them. When released, the gases or
vapors will expand in large proportions that can quickly engulf first responders. As mentioned previously,
propane has an expansion ratio of 270 to 1, meaning that 1 ft3 of liquid vaporizes to 270 ft3of gas.1
The rapid expansion of these gases and vapors absorbs heat energy from surrounding surfaces, which
can then lead to frostbite injuries to first responders who may be near the source of the release. In addition,
first responders engulfed in gases and vapors that are flammable may suddenly find themselves trapped in
a deadly fireball.
Many compressed gas cylinders include a pressure relief device that is designed to automatically prevent
a release from catastrophic failure of the container to due excessive internal pressure. When attempting to
prevent a release, any activities conducted in proximity to containers with pressure relief devices must be
done with extreme caution. These devices will open without warning, possibly exposing first responders
and the public to a hazardous material. Once open, some of these devices may not close, either because
the device is not designed to close or because it malfunctions. In addition, some pressure relief devices
may not operate properly if the container is not in an upright position.
An important point that first responders should remember about pressure relief devices is that they can
protect a container only as long as they are the weak link in the container wall. For example, a container
built to withstand an internal pressure of 400 psi may have a pressure relief device designed to activate at
only 300 psi. Thus it is designed to open up before the internal pressure reaches the maximum allowed.
However, this same container may have been damaged due to physical impact suffered during a
vehicle accident. In consequence, the ability of the container wall to withstand internal pressure at the
site of damage may have been reduced to less than the 300-psi setting of the pressure relief device. The
damaged container wall may now become a weak link, allowing the container to rupture at the site of
the damage even before the pressure relief device would operate. Physical damage to a container wall may
appear as a crease, dent, or gouge, and the extent of the damage will influence the extent to which the
integrity of the container has been weakened. Damage is especially troublesome when it occurs at weld
lines, or places where pieces of metal are joined when building the containers. These areas are weaker due
to the effects of the welding process on most metals.
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DEFENSIVE ACTIONS FOR FIRST RESPONDERS
If a damaged (and therefore weakened) container cannot withstand its internal pressure immediately
after an accident, the container will likely explode prior to the arrival of first responders. However, if the
container wall has been weakened, yet is still able to contain the internal pressure immediately after an
accident, first responders may underestimate the potential for serious consequences later.
As discussed earlier, internal pressures of containers can increase as daytime temperatures on the scene
rise throughout the course of an incident. As a result, if the internal pressure increases sufficiently to
a point just above that which the weakened container wall can resist, the container may fail without
warning. This could occur even before the operation of a pressure relief device. First responders who fail
to recognize this potential may be in for an unwelcome surprise several hours or perhaps even days into an
incident that involves damaged pressure containers.
Containers exposed to a fire present first responders with an even greater danger. The fire not only
weakens the container wall, but heating of the container also rapidly increases the internal pressure exerted
by the contents. First responders should remember that liquefied gases stored at normal atmospheric
temperatures and pressures are already boiling inside their containers. Materials that are liquids at
normal temperatures and pressures need heat from an outside source in order to boil. Either way, once a
liquid inside is above its boiling point, the containers become pressure cookers, with the potential for
The release of a hazardous material from a pressurized container due to fire exposure may occur with
the opening of a pressure relief device, or it could occur when a weakened container wall can no longer
resist increasing internal pressure. The weakening of a container wall from flame impingement usually
occurs where the flame contacts the vapor space, which is usually the upper portion of a container. Much
of the heat applied at this location is absorbed by the container wall, which results in its rapid weakening.
In contrast, the heat applied to portions of the container at the liquid level is mostly absorbed by the
liquid itself, which while it reduces the weakening effects of fire on the container wall, also causes internal
pressure to increase.
Whenever containers are exposed to fire with a both a decrease in container strength and increase
of internal pressure, first responders must remember that the operation of a pressure relief valve is no
guarantee that the container will not explode. Relating a previous example, a container built to withstand
an internal pressure of 400 psi may have a pressure relief device designed to activate at 300 psi, which
will allow it to open up before the internal pressure reaches the maximum allowed. However, if the flame
impingement is directed to the upper portions of the container where there is a vapor space, the container
wall may weaken. As a result, the ability of the container wall to withstand increasing internal pressure
may soon be reduced to less than the 300-psi setting of the pressure relief device. As with physical damage,
the container wall will now become the weak link, with the potential for an explosion of the container
likely, despite the operation of the pressure relief device.
There is a difference between pressurized containers weakened by exposure to fire and those weakened
by physical impact. With the former, the effects of fire rapidly weaken the tank wall, while also rapidly
increasing the internal pressure due to large volumes of heat energy. This pace of events may provide first
responders will very little time to evacuate nearby areas or make attempts to safely cool the affected areas
of the container by setting up hose streams.
111
The sound of gas and vapor escaping from an operating pressure relief device during a fire will increase
in both volume and pitch as internal pressure continues to rise due to external heating. This change in
sound should serve as a warning to first responders that they may need to immediately evacuate the area.
The failure of any pressurized container can have devastating consequences that can include flying
debris. This problem is only magnified when dealing with flammable materials, where the ignition
of rapidly expanding gases and vapors creates huge fireballs that can extend for thousands of feet in
all directions.
Nonpressurized containers
Containers intended to store liquids at normal temperatures and pressures usually do not present a
danger from excessive internal pressure. This is true unless there is some form of external heating or a
chemical reaction of the contents inside the container, either of which can increase the internal pressure.
External heating can occur from exposure to direct sunlight or fire, and the influence of sunlight on
internal container pressure can change throughout the course of an incident.
For example, an incident that occurs outdoors at 3:00 p.m. during August will likely result in far
more external heating of the contents of containers than if the same incident occurred at 3:00 a.m. First
responders should consider this fact when assessing containers that have not yet released their contents.
This is because long-term incidents have a potential for the internal pressure of these containers to
fluctuate due to changes in weather conditions and the time of day.
Nonpressure containers with liquid or solid materials may also be subject to excessive internal pressure
from chemical reactions that occur as a result of improper handling of unstable materials. These reactions
may also occur from the mixing of incompatible chemicals (as when industrial workers accidentally fill a
tank with the wrong material). Additionally, they could occur if a material is placed into the wrong type
of container, resulting in a reaction between the material and the container wall itself.
Under these circumstances, these containers may then present first responders with both audible and
visual clues. For example, there may be obvious bulges on the sides and ends, while metal containers may
develop a metallic pinging sound as the internal pressure increases and stresses the container wall. The
ends of nonpressure containers are usually the weakest locations, and therefore the most dangerous. If a
container of liquid bursts, it will usually do so at one of the ends, which may then cause the container to
travel in the opposite direction at a high rate of speed.
As with compressed gas cylinders, the consequences of a flying liquid container are potentially deadly.
Under many circumstances, there may be little first responders can do to prevent a release from a container
that is already under pressure or when the internal pressure is steadily increasing. Evacuating the area a
safe distance may be the only option.
First responders may also encounter open containers with materials that are experiencing a violent
chemical reaction. This situation could involve a trash can or a 55-gal container with incompatible
materials that have been mixed by accident.
Because the container is open, it will eliminate the potential for the container to burst from an increase
of pressure. However, these situations can expose first responders to the hazardous vapors and fumes
produced by the reaction. It also invites first responders with the opportunity to flood the container with
112
water, thinking that they are solving the problem. However, despite what some believe, adding water to
an open-top container with an unknown substance undergoing a violent chemical reaction could make
the problem a lot worse.
Using water to cool containers

If an increase of internal pressure of a container is due to external heating, cooling the container or
moving the containers from the source of the heat are options that are dangerous, at best. First responders
should remember that containers under pressure can release their contents without warning, and they
cannot time this release!
Master streams used to cool containers usually present a lesser danger to personnel than do handheld
lines. However, unmanned master streams must still first be set up close enough to the containers during
the height of the incident to have an effective reach. Use of elevated streams from apparatus to cool
containers (even if the vehicle not staffed) potentially could expose a $500,000 piece of equipment to
destruction from an explosion. It may also expose it to the effects of chemical vapors. Large amounts
of water may be required, and the ability of fire departments to meet these demands could be limited,
especially if operations involve the use of water shuttles.
Remember that any attempt to cool a large propane tank exposed to fire using water from a 1¾-in.
hose line held by two firefighters standing near the tank could have disastrous consequences. They might
learn the hard way that this container can still explode, despite the operation of the relief valve, and
despite their best intentions.
Vehicle accidents and structure fires

During vehicle accidents involving hazardous materials, first responders should attempt to learn not
only what materials are present, but also the type of containers involved. First responders should keep
in mind that containers made of glass, cardboard, or plastic generally have less structural integrity than
metal containers.
A first responder should never assume that no evidence of an external leak from a box truck involved in
an accident is actually an indication that no containers in the truck have been damaged. First responders
who make this assumption may get an unwelcome surprise hours later when a wrecker driver attempts to
recover the vehicle.
If containers of hazardous materials are undamaged, they often need to be unloaded before attempting
to recover a damaged vehicle in order to prevent these containers from leaking during the recovery process.
Efforts to remove containers of hazardous materials will likely require a hazardous materials team or
cleanup contractor to assess the conditions of the containers and conduct the transfer of the containers to
another vehicle. This is usually not a role for first responders.
Sometimes during structure fires there may not be a hazardous materials incident upon the arrival
of firefighters. However, the careless washing down of areas known or suspected of storing hazardous
materials (such as garages, work sheds, and hardware stores) can create one. In some situations, preventing
the release of hazardous materials may require overhaul to be conducted in conjunction with cleanup
contractors. These contractors can safely remove containers of hazardous materials from the building,
113
rather than having firefighters dig through, hose down, and potentially damage these containers. Preventing
the release of hazardous materials during overhaul of structure fires requires extreme care!
Containing the Release of a Liquid

When dealing with releases of liquids, any attempt by first responders to control and contain the
movement of these materials should be done only if their actions will not expose personnel to the hazards
of the material. In addition to materials that cause skin damage or that can be absorbed through the skin
(despite wearing firefighter protective clothing), some materials present fire and explosion hazards through
the production of vapors and mists. These same vapors and mists may also present first responders with
potential inhalation hazards.
In some situations first responders may need to construct a makeshift barrier to contain the release
of a liquid. In other situations, first responders will be faced with a leaking fixed storage tank that is
surrounded by an earthen dike, or perhaps one constructed of concrete or cement blocks. The dike should
be capable of holding the entire contents of the container, but first responders should be prepared in the
event that the dike fails.
This failure may not be catastrophic, but it could consist of minor leaks in mortar joints of a block
wall that can still leak hundreds of gallons of product. Therefore, during incidents involving leaking
bulk liquid storage containers, first responders should always monitor the integrity of any dikes and be
prepared to react should they suspect impending failure.
First responders also should remember that dikes, whether used outdoors or inside buildings, will allow
hazardous materials to form into a pool, which may result in a large surface area. Depending upon the
nature of the material, this surface area may then produce potentially hazardous vapors, including those
that are flammable. First responders should therefore never assume that just because a spill is contained
within a dike that there are no additional hazards present.
Temporary containment barriers on land

If a liquid material is moving from the site of a release, there will be several considerations that will
influence the decision of first responders to intervene. These include the nature of the spilled material, the
quantity released, the speed at which the liquid is moving, and whether or not the release is ongoing. A
small spill of a thick liquid on a flat, porous surface will present less of a challenge for containment than
will a large spill of gasoline rapidly traveling downhill on a hard surface.
Some liquid spills may encounter natural barriers that will subsequently contain the release and
thereby minimize the amount of effort needed by first responders to construct temporary barriers. An
example could involve a spill of a small amount of diesel fuel from the fuel tank of a commercial vehicle
stopped on a highway. The spill may travel from the roadway and collect in a small depression along the
edge of the road.
At other times, a first responder may need to build temporary barriers to contain a spilled liquid.
These barriers can be built from soil dug from nearby areas or brought to the scene in a dump truck
114
or bags. Additional materials that can be used include absorbents carried on the apparatus in either
bags or buckets. Figure 11–1 provides an example of how to build a containment barrier around a
leaking drum.
CONTAINMENT AREA
LARGE ENOUGH TO
HOLD ALL CONTENTS
OF THE CONTAINER
ABSORBANT COMPATIBLE
WITH THE LEAKING MATERIAL
Fig. 11-1 Containment Barrier for a Leaking Drum
First responders should always remember that any temporary barrier must be large enough to contain
the amount of material released. In addition, anything used to build temporary barriers must be compatible
with the hazardous material released. Specifically, the product first responders are attempting to contain
must not result in a violent chemical reaction when it contacts the temporary barrier. For example, the
ERG2004 suggests the use of dry earth, dry sand, or other noncombustible material when dealing with
spills of certain types of hazardous materials.2
First responders may be able to control the flow of a liquid spill moving downhill using a diversion
wall that directs the material to an area where it can be contained or result in less harm. Containment
areas could be a depression along a road shoulder or a large hole, sometimes referred to as a retention
115
basin, dug by first responders for the purpose of containing the runoff. Figure 11–2 provides an example
of a diversion wall.
ROADSIDE CULVERT USED

TO COLLECT MATERIAL
DIVERSION WALL MADE

OF SOIL OR ABSORBANT
Fig. 11-2 Diversion Wall to Direct Travel of a Leaking Material
Locating underground utilities

When preparing to dig a retention basin, first responders must always remember that any effort to
excavate a containment area must take into consideration the presence of underground utilities. This is
especially important when working to contain spills that occur on the shoulders of highways or railroad
right-of-ways, since these areas are often the site of underground utilities.
The location of some underground utilities may be marked using aboveground signs that include an
emergency telephone number. However, many more utilities are not marked, and first responders must
pay attention to obvious indicators that underground utilities are nearby. These include pad-mounted
transformers, manhole covers, valve boxes, and utility poles outfitted with an attached cable that runs
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from the top of the pole to an underground connection at its base. Figure 11– 3 provides an example of
typical utility locating signs.
W
WARNING A
R
N
UNDERGROUND I
UTILITY N
G
G
EMERGENCIES A
(000) 000-0000 S
P
I
P
E
L
I
N
E
Fig 11-3 Typical Utility Locator Signs
Most areas of the United States are served by companies whose job it is to locate underground utilities
for construction contractors, usually within 48 hours of notification. Of course, a first responder will not
have 48 hours to wait, and so many of these companies will instead provide some form of emergency
utility locating service for first responders.
To request this emergency service, the first responder will usually need to contact the utility locating
company at the telephone number normally used by those requesting a 48-hour notification. He must
then inform the operator of a need for immediate assistance. He should be prepared to provide the
operator with his location and a callback number where he can be reached.
The locating company will then determine those utilities in the affected area and contact their
representatives. These individuals will then contact the first responder using the callback number provided
earlier. They will state either that their utilities are not involved or that they will respond to the scene to
assist in locating and marking their utilities. The response time of utility representatives will vary, so a first
responder should remind them that they are dealing with an emergency situation.
First responders should learn the details of local and state laws in their area that govern locating services
for underground utilities. Some laws may release first responders from criminal liability for damage they
cause to underground utilities. However, there is always the possibility of civil lawsuits claiming negligence
on the part of the first responders should any damage occur.
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Use of absorbent booms on water

On bodies of water, first responders may be able to contain liquids by using absorbent booms designed
to float on water. Before using these booms, first responders must remember that the material they are
attempting to contain will need to have the following characteristics:
• It cannot be miscible with water (meaning that it cannot mix with water).
• It must float on the surface of the water (meaning that it has a specific gravity of less than 1).
For example, a floating absorbent boom would likely be effective to contain a release of diesel fuel on
water, since diesel fuel is not miscible, and it floats on water. In contrast, this same boom would be useless
when attempting to contain a spill of antifreeze solutions, since antifreeze mixes well with water. It would
therefore not be contained by an absorbent boom floating on the surface.
Absorbent booms are generally not intended for use on large bodies of water where there may be
significant wave action or strong currents. They usually work well in small creeks, streams, and ponds.
Most absorbent booms are manufactured in 10-ft sections, but they are designed to be hooked together
if needed to cover a greater distance. It is important to recall that the ends of absorbent booms must be
secured to the shoreline. This can be accomplished using wood or metal stakes driven through metal rings
normally attached to each end of the boom. Figure 11– 4 provides an example of boom placement in a
body of water.
DIRECTION OF FLOW ABSORBANT BOOMS ANCHORED

ON SHORE USING WOOD OR
METAL STAKES
Fig. 11-4 Redundant Use of Absorbent Booms
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Underflow dams
Another means by which first responders can contain liquids with characteristics similar to the previous
example is through use of an underflow dam. These containment devices are best used in narrow creeks
and streams with flowing water. The term underflow refers to the fact that clean water is allowed to flow
freely under the dam, while hazardous materials that float on the surface of the water are contained.
While first responders may be able to build an underflow dam using plastic pipe, most fire apparatus
that arrive on the scene during the initial phase of a hazardous materials incident will not have this pipe
available. However, most apparatus will have hard suction hose used for drafting, and these sections of
hose can prove effective when building underflow dams.
To begin construction of an underflow dam, objects such as rocks or tree limbs are placed on the
bottom of the creek or stream in order to elevate the discharge end of the hard suction hose slightly. The
hose is then placed in the water with only about 2 ft of the hose in front of where the dam will be built.
Soil is then placed around the pipe between each shoreline in order to prepare a barrier that will then
contain the hazardous material as it floats on the water.
When building an underflow dam, any pipe used must be large enough to allow the water to flow
freely. Larger flows will require larger, or perhaps multiple, pipes. A first responder must remember that
these containment devices are subject to erosion from the force of the moving water, and they must
therefore be monitored at all times. Figure 11–5 provides details of how to build an underflow dam using
a section of hard suction hose, while figure 11–6 shows one of these dams in operation.
EARTHEN DAM BUILT AROUND

HARD SUCTION HOSE
HAZARDOUS MATERIAL FLOATS ON WATER AND

DOES NOT GO THROUGH HARD SUCTION HOSE
HARD SUCTION HOSE BASE MATERIAL MADE OF

ROCKS OR TREE LIMBS TO CLEAN WATER
ELEVATE END OF HARD EXITS HARD
SUCTION HOSE SUCTION HOSE
Fig. 11-5 Construction of an Underflow Dam
119
Fig. 11-6 Example of an Underflow Dam in Operation Courtesy of Patrick M. Collins
Considerations when building containment barriers

An important consideration for first responders to remember when attempting to contain the release
of a spilled liquid is that of redundancy. Redundancy in this situation means that whenever possible,
temporary containment barriers should be backed up by additional barriers. These additional barriers
should be further away from the site of the release so that if the primary containment device fails, or if it
is less than 100% effective, there are still opportunities to contain the released material.
In addition, the location of any containment device used in a body of water should always take into
consideration the eventual removal of the material. Removal of a hazardous material that is floating on the
surface of water may involve the use of absorbent pads. However, removal of large amounts of material
may require use of a commercial truck equipped with a vacuum device. Therefore, when choosing the
location for placement of absorbent booms or underflow dams (especially for releases that involve large
quantities of product), first responders should consider the means by which a large vehicle can approach
the site.
As an example, a containment barrier placed in a creek beneath a highway overpass would provide
reasonable access for removal of product by a vacuum truck. This access would be better than if the same
containment barrier were placed 200 ft downstream into a wooded area. The latter option may then
require the construction of a temporary access road for the truck to use.
First responders who have contained any liquid material must continuously monitor temporary
barriers to ensure their integrity. In addition, first responders should never forget that actions to contain
a liquid will allow hazardous materials to pool, which may then result in a large surface area. Depending
120
upon the nature of the material, this surface area can produce potentially hazardous vapors, including
those that are flammable.
Diluting hazardous materials releases with water

In addition to containing releases of liquid materials, some releases may be rendered safe by diluting
them with water. In particular, when dealing with small spills involving some types of oxidizers, the
ERG2004 recommends applying “flooding quantities of water.” 3 While applying large quantities of
water can dilute a spill to a safer and more stable concentration, before doing so, a first responder should
remember to first check with local and state environmental officials and conduct research to determine
potential outcomes.
With few exceptions, adding water to a spill of hazardous materials will move the material to another
location, creating a larger cleanup problem. This could create a more dangerous situation if the material
is water reactive. First responders should never apply water to a spill of hazardous materials unless they are
confident that doing so will not cause their efforts to become part of the problem.
Containing the Release of Gases and Vapors

For first responders, dealing with gases and vapors always presents significant challenges, since many
of these materials are odorless and colorless. There may be few visual clues as to whether a release is
ongoing, so first responders may need to instead rely on audible clues, such as the sound of venting from a
compressed gas cylinder. This sound will increase in both volume and pitch as internal pressure increases.
First responders may also be able to identify compressed gas cylinders suspected of leaking since these
may display frosting near the discharge opening. This occurs as moisture in the surrounding atmosphere is
cooled by the escaping gas or vapor.
The type of material released, as well as the quantity, speed, and duration of the release, are all factors
to consider when first responders are deciding what steps they may take to control a release of gases
and vapors. First responders should remember that airborne hazards pose inhalation hazards as well as
a greater threat from fire or explosion, since gases and vapors are easily ignited. In additions, the most
difficult form of material to control is a gas or vapor, since when a material is in this physical state, it may
travel unimpeded.
Increased temperature can accelerate the activity of gases and vapors, and for liquids, it can increase the
rate at which the surface area produces vapors. Airborne materials can quickly fill a void space, depending
upon whether the material is heavier or lighter than the surrounding air.
Controlling vapors and gases within buildings

Within a building, airborne hazards may be carried by internal air handling systems, thereby exposing
occupants far from the source of a release. Controlling the movement of gases and vapors indoors can
be as simple as closing a door to a room along with shutting down ventilation systems. However, while
controlling ventilation systems in a single-family residence is a simple task, doing so in a commercial
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building is more challenging. It may require the assistance of someone knowledgeable of the system, such
as a building engineer.
Whenever operating ventilation systems, first responders must remember not to expose anyone
assigned this task to the hazardous material vapors they are attempting to control. If the area where the
ventilation controls are located is not safe to enter, it may be better instead to have electric power to the
building terminated from a remote site. Of course, first responders must determine in advance whether
terminating electrical power will then cause an emergency power generator to start.
Once vapors and gases are contained inside a building, those that are flammable could be ignited
by an ignition source as simple as a light switch. Furthermore, natural gas released indoors can migrate
upwards into an attic space, only to be ignited later by an attic fan. Propane can seep into the crawl space
of a house and explode once ignited by a floor furnace.
Operation of gas control valves

Releases of natural gas or propane may be controlled if there is an external valve that can be operated
safely by first responders. This valve must be remote from the source of release to avoid contamination
and must clearly indicate the position of the valve. First responders should usually not operate below-
grade street valves for natural gas service unless instructed to do so by the local utility company that
manages that service.
Without proper training and equipment, first responders may not be assured of the position of
underground valves. Closing or opening these valves could create serious problems elsewhere within
the gas distribution system. First responders could also unknowingly damage the valve. If a little force
applied to operate something does not work, some people will instinctively apply more force, usually
until something breaks.
Controlling vapors and gases with fog streams

First responders may decide to use water spray from hand lines or master streams outdoors to control
the spread of vapors and gases. They should do this only if their intervention will make a difference, such
as when attempting to move vapors and gases away from people who are seriously threatened. Also, before
applying water to a gas or vapor, first responders should make sure they know what to expect, since some
will produce a hazardous water runoff. For example, attempting to control a release of chlorine gas with
water spray may produce a corrosive runoff. This water runoff could create significant environmental
damage if it enters a waterway.
The water patterns available from most fog nozzles are capable of moving large volumes of gases and
vapor. Therefore, first responders must use caution to ensure that any gases and vapors are moving from
an area of greater harm to lesser harm.
First responders should also keep in mind that water spray applied to flammable gases and vapors will
not always prevent ignition. Instead, air entrained in a fog stream could actually mix with these materials
and cause some to reach their flammable range. During freezing weather, they should be mindful that
large volumes of water spray can produce icy conditions that may require the application of an abrasive
such as sand to minimize hazards to personnel.
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Containing the Release of a Solid

Releases of solid hazardous materials usually occur in the form of a powder or a granular substance.
While many of these releases are the result of damage to small bags, larger containers constructed of metal
or plastic have the potential to release several hundred pounds of material. Some hazardous materials may
be transported in solid form by dump trucks or dry bulk hopper cars that can each release thousands of
pounds of powder or granular material.
Releases of these materials can present health and fire hazards similar to any gas or vapor. Wind speed
and direction will play a role in determining the actions of first responders. They should always resist
the urge to wet a spill of a powder or granular material in order to “hold down the dust,” unless doing
so is recommended. The addition of water to a spill of solid hazardous materials may only create more
problems. This is especially important for first responders to remember if the material is soluble with
water (meaning that it will dissolve in water). This newly created solution of hazardous materials may
now be difficult to contain and clean up.
The ERG2004 recommends covering spills of some materials with a plastic sheet or tarp to reduce
the potential for the material to spread and to keep the material dry.4 If an approach can be made safely,
first responders can accomplish this task by having a minimum of four first responders, each wearing full
protective clothing and SCBA, approach the spill area while holding one of the four corners of the sheet
or tarp. A road cone or similar object should be held in the free hand.
The approach to the spill site should be made from upwind (meaning that the wind should be at the
back of first responders). While they are straddling the spill area, the sheet or tarp is gently lowered onto the
spilled material, and a road cone is placed on each corner of the cover to secure it in place. Depending upon
the size of the spill and wind conditions, use of additional road cones or other objects to hold the cover in
place may be needed. Figure 11–7 shows a small spill of a solid material covered with a plastic sheet.
Fig. 11-7 Small Spill of Solid Material Covered with a Plastic Sheet Courtesy of Patrick M. Collins
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Protective Actions
Protective actions are defensive tactics that can be used by first responders to minimize the exposure
of people to hazardous materials. These actions include isolating and denying entry to affected areas,
evacuation of these areas, and in-place protection in nearby structures.
Upon arrival at most hazardous material incidents, first responders will often be faced with the task of
isolating affected areas. This may include closing roadways, blocking entrances to parking lots, securing
doors to buildings or rooms, and advising bystanders to move away from potentially dangerous areas.
When dealing with transportation emergencies, first responders can consult the ERG. They should
remember that each orange-boarded page of the ERG provides recommended distances for immediate
isolation of spill or leak areas under the heading “Public Safety.” In particular, the ERG2004 also provides
additional recommendations for protecting the public from spills that involve “dangerous goods which
are considered toxic by inhalation (TIH), including certain chemical warfare agents, or which produce
toxic gases upon contact with water.”5 This information is found in the “Table of Initial Isolation and
Protective Action Distances” (green-borderd pages) and is intended to “show areas likely to be affected
during the first 30 minutes after materials are spilled.”6
When attempting to determine the size of an initial isolation area, first responders should resist the
urge to overreact and instead establish a reasonable area. When in doubt though, they should remember
that a large isolation area is easier to reduce during the later stages of an incident. This is preferable to
having to constantly increase the size of an area if conditions continue to deteriorate.
Defining and maintaining isolation areas

In order to define isolation areas, first responders may be able to use existing physical barriers such as
highway guardrails or median strips during highway accidents, or by closing doors to isolate certain areas
inside buildings. On some occasions, they may elect to use barrier tape.
On windy days outdoors, the use of barrier tape is easier said than done. Furthermore, in spite of
whatever warning is printed on barrier tape, some people will always believe the Keep Out sign does
not apply to them. First responders should never rely on barrier tape as the only means to define an area
affected by a hazardous materials release. Instead, the use of barrier tape should be monitored by first
responders, including law enforcement officers, to ensure compliance.
Law enforcement officers may also be requested to block roads and detour traffic. When doing so, first
responders must remember not to place these individuals in areas where they can be affected by airborne
hazards. More than one law enforcement officer has been hospitalized during a hazardous materials
incident due to chemical exposure while conducting traffic control.
Furthermore, vehicle traffic is not the first responder’s only concern. Pedestrians have a way of getting
involved, including by walking, jogging, or riding a bicycle through the incident scene. Camera crews
from media outlets may attempt to enter hazardous areas unnoticed in order to obtain film footage for the
evening newscast. First responders must be prepared!
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Evacuation and in-place protection

Efforts to isolate affected areas and deny entry are effective defensive tactics for most hazardous
materials incidents. However, those incidents associated with airborne hazards usually require additional
defensive tactics in order to protect the public. Two generally accepted practices used by first responders
are evacuation and in-place protection.
Evacuation involves the removal of people from an area. The intent of in-place protection is to have
individuals remain in an affected area while inside structures with doors and windows closed and sealed,
and ventilation equipment switched off.
When time allows, evacuation of buildings in an affected area may be the best protective action. In
that manner, it is usually possible to account for individuals and to provide for their well-being in shelters.
This may be preferable to allowing them to remain in buildings in areas potentially contaminated with
an airborne hazardous material.
Evacuation may also be a preferred method of defensive protective actions if a material released is
flammable or if it will likely take a long time for the material to dissipate, such as when a heavier-than-air
gas is released on a day with very little wind. However, serious considerations when deciding on evacuation
include where to shelter evacuees, how to get these individuals to shelters, and how to care for them once
they arrive. Someone will usually forget to bring his medication, and in addition, the normal function of
any shelter (such as a school, church, or fire station) will be disrupted while the shelter is in operation.
It is entirely possible for first responders to use both evacuation and in-place protection simultaneously
as a defensive protection action. For example, if a vapor cloud resulting from a hazardous materials release
spreads suddenly over an area, there may not be enough time for individuals in nearby buildings to
evacuate without becoming exposed to the material. They may therefore need to take immediate shelter
indoors. However, those further away from the incident site may still have ample time to evacuate the area
safely.
Once first responders decide on either in-place protection or evacuation, their next challenge is often
to notify individuals in the affected area of suggested actions to take. First responders may need to go door-
to-door, or use public address systems on emergency vehicles or news bulletins on radio and television.
All of these techniques are easier to accomplish during daylight and evening hours as opposed to late
night or early morning, when most people are likely asleep. Some localities have technology that allows
emergency officials to contact people in affected areas by telephone using a special modification to an
already established 9-1-1 system. They can deliver a recorded message with emergency information.
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A first responder should always know which people to contact in his local emergency management
office regarding any actions he may wish to take regarding evacuation or in-place protection. These
emergency management officials are often prepared with the knowledge of:
• How to request that local media transmit emergency messages
• Available shelters, shelter operations, and transportation
• How to operate shelters in a safe and efficient manner
First responders should remember that accountability for evacuees is a serious concern, especially
when dealing with children. Confusion will be unavoidable during the initial phase of any evacuation,
and local emergency management officials can provide valuable assistance here. Accountability is even
more challenging when more than one sheltering site is used.
When attempting to document notification of citizens in affected areas while going door-to-door, one
suggestion is to mark the front door of each building or perhaps a mailbox with a small piece of triage
tape. This indicates that a public safety official has already visited that location. Some first responders
may elect to use two different colors, one to indicate contact with the occupants and another to signify
no response.
A first responder will quickly discover that some occupants will refuse to answer the door, especially
if these individuals are young children who are told to never open the door when they are home alone.
Therefore, just because someone does not answer the door to a residence is no assurance that the building
is unoccupied.
Will some challenge the decisions of first responders to evacuate citizens? Will some complain if first
responders close a portion of a highway, especially an interstate route? Will business owners become angry
if their stores, restaurants, or factories are evacuated? They certainly will!
However, a first responder should always remember that citizens will complain more if they are
not evacuated and are subsequently injured than they will if they are forced to leave and are merely
inconvenienced. When challenged regarding decisions that involve defensive protective actions, first
responders should always remember: An inconvenience is temporary. Dead is forever.
Decontamination of First Responders

First responders conducting any defensive actions to contain or control the release of a hazardous
material should always consider the use of full protective clothing and SCBA. They should remember the
following regarding the use of this protective clothing during a hazardous materials incident:
• Firefighter protective clothing offers limited protection from hazardous materials.
• The best way to decontaminate any protective clothing is to avoid contamination.
Despite the efforts of first responders to use their protective clothing properly and avoid
contamination, they should always be prepared to decontaminate this clothing. According to the
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ERG2004, decontamination is “The removal of dangerous goods [hazardous materials] from personnel
and equipment to the extent necessary to prevent potential adverse health effects.”7 This should be done
with at least a gross wash prior to leaving the scene of most hazardous material incidents, especially when
they have been engaged in certain defensive actions.
In addition to a gross wash, first responders may need to scrub protective clothing with a soap solution
prior to removing the garment if there is any concern regarding contamination from some chemicals. Since
even this form of decontamination may not be 100% effective, removal of protective clothing should
be done in a manner that turns the garment inside out. Direct contact with the surface of potentially
contaminated clothing is thus avoided.
Any garments in need of additional cleaning off-site should be placed into large, clear trash bags. The
purpose of using clear bags is to assist with the identification of a bag’s contents. The manufacturer of
the protective clothing should then be consulted to determine the best method to clean the garment and
whether the garment can be returned to service. The garment may be taken to a vendor for cleaning (such
as a fire equipment supplier who offers this service). If so, the first responder must remember to provide
them with a copy of the MSDS for the material that is the source of the contamination.
Water supply for decontamination can be provided by hose lines from fire apparatus. Some first
responders may have access to “garden hose adapters” that attach to discharge outlets on their apparatus,
while others may simply use a 1¾-in. hose line or a booster hose.
First responders should attempt to contain runoff water during decontamination of protective clothing
at the scene of a hazardous materials incident. Some departments may use specially designed containment
basins (including small plastic swimming pools intended for use by young children). Alternately, a
temporary containment basin can be constructed using two sections of hard suction hose, pike poles or
attic ladders, and sheets of clear plastic or tarps.
An example of how to build a framework for a containment basin is provided in Figure 11–8.
PLASTIC SHEET OR TARP IS LAID

OVER THE FRAME AND TUCKED
UNDERNEATH EACH OF THE
FOUR CROSS MEMBERS
PIKE POLE
HARD SUCTION HOSE

(1 each side)
ATTIC LADDER
(collapsed)
Fig. 11-8 Construction of a Containment Basin
127
The task of disposing of decontamination runoff

First responders had just learned water is usually done in conjunction with the disposal
how to request immediate of other hazardous waste generated during the incident.
First responders may be able to dispose of this water on-
assistance from utility locating site, but representatives from environmental regulatory
companies during a hazardous agencies should first be consulted to determine if this
action is appropriate.
materials emergency when a call
was received just after midnight
about an overturned tractor trailer
hauling a cargo tank containing
diesel fuel. The vehicle had come
to rest on its side on the road
shoulder. Anticipating the use
of grounding rods to reduce the
hazards of static electricity during
efforts later that night to transfer
the product to another tank, utility
locators were called to the scene
and determined that the vehicle
was positioned directly above
a buried high-pressure natural
gas pipeline. Any effort to place
grounding rods in proximity of the
tank without prior knowledge of the
pipeline’s location could have had
128
Key Points
• When deciding upon defensive practices, first responders must assess the status of
containers that have already released their contents. They must also assess the status of
those containers with an ongoing release and those that have not released their contents
but that have the potential to do so.
• While a gas is usually the most difficult form of a material to control, vapors from liquids
and dusts from solids will present first responders with hazards similar to a gas.
• Pressurized containers usually present the greatest danger to first responders.
• First responders engulfed by rapidly expanding flammable gases and vapors released from
pressurized containers may suddenly find themselves trapped in a deadly fireball.
• Attempts to contain a liquid that has spilled onto a body of water must take into
consideration the material’s specific gravity and miscibility with water.
• First responders who contain the release of a liquid hazardous material may then need to
deal with a surface area capable of producing large amounts of hazardous vapors.
• Any item used to build temporary barriers to control the release of a liquid hazardous
material must be compatible with the material released.
• First responders must always remember that any effort to excavate a containment area
must first take into consideration the presence of underground utilities.
• The release of gases and vapors from containers may be difficult to detect since some of
these materials may be odorless and colorless.
• Attempts to contain the release of gases and vapors with water may produce a hazardous
water runoff.
• First responders should not operate below-grade street valves for natural gas service unless
instructed to do so by the local utility company.
• First responders should resist the urge to wet down or wash away spills of hazardous
materials in solid form.
• Individuals assigned the task of traffic control should not be placed in areas where they can
be affected by airborne hazards.
• Protective actions used by first responders include isolating and denying entry to affected
areas, evacuation of these areas, and in-place protection in nearby structures.
• First responders should contact their local emergency management office for assistance
when conducting operations that involve evacuation or in-place protection.
• Safe work practices include efforts to minimize contamination by avoiding spilled materials
and resisting the urge to touch or otherwise handle containers.
• Firefighter protective clothing offers limited protection from hazardous materials.
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• The best way to decontaminate any protective clothing is to avoid contamination.

• First responders should always be prepared to decontaminate their protective clothing
with at least a gross wash prior to leaving the scene of most hazardous material incidents.
• When dealing with citizen complaints regarding decisions to evacuate people during a
hazardous materials incident, first responders should always remember:
An inconvenience is temporary. Dead is forever.
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Chapter Questions
1. What type of container usually presents the greatest risk to first responders, and why?
2. Identify two means by which the internal pressure of containers used to store liquids at
normal temperatures and pressures can increase.
3. Will a container shell exposed to fire weaken quicker when the fire contacts the vapor
space or the liquid level in the container? Explain your answer.
4. Can a container exposed to fire with an operating relief valve still explode? Explain
your answer.
5. Why is overhaul of a structure fire dangerous with regards to hazardous materials?
6. What form of a material is the most difficult for first responders to control?
7. Can liquid and solid materials present first responders with physical properties and hazards
similar to a gas? Explain your answer.
8. What potential problems could first responders face if they attempt to operate below-
grade control valves for natural gas distribution systems?
9. Identify at least three potential hazards of applying water to a spilled chemical. Are
there any situations when water application to a spilled chemical is acceptable? Explain
your answer.
10. Identify at least two considerations when deciding what materials to use when attempting
to build a containment barrier for a spilled hazardous material.
11. Identify two considerations when deciding whether to use a floating boom to contain a
spill of a hazardous material on a body of water.
12. What underground hazard can be present when attempting to dig a containment area,
and what actions can first responders take to protect themselves?
13. Explain the term redundancy as it relates to building containment barriers.
14. Describe a procedure to cover a small spill of a granular substance.
15. Why is the use of a road flare a potential problem during a hazardous materials incident?
16. Identify two means to protect the public during the release of a hazardous material and
explain how to execute each.
17. When is in-place protection the preferred means of protecting the public?
18. What local government official should first responders contact whenever there is a need to
evacuate citizens? Identify this individual in the local community.
19. Review the community’s plan for the operation of evacuation shelters. List sites included
in the plan and determine what provisions exist for food and medical care for evacuees.
20. Describe how a first responder could contain runoff water during operations to
decontaminate protective clothing at the scene of a hazardous materials incident. Describe
the department’s plans for containing runoff from these operations.
131
References
1 Fire, Frank L. The Common Sense Approach to Hazardous Materials. New Jersey: PennWell Publishing, 1996, p. 154.
3, Ibid., p. 235.
4 Ibid. p. 251.
5 Ibid., p. 295.
6 Ibid.
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12
HIGHWAY TRANSPORTATION INCIDENTS
As first responders sit in the kitchen of their firehouses, they are likely to hear the roar of trucks
pass by on nearby streets throughout the day. Some of these vehicles are transporting hazardous
materials, many of which are regulated as hazardous, and most deliver their goods without incident.
Unfortunately for first responders, there are mishaps and accidents involving commercial highway
vehicles along with their potentially hazardous contents. Many of these vehicles carry large volumes
of fuel. Even a bobtail tractor (one without the trailer) has the potential for a spill of several hundred
gallons of diesel fuel from its fuel tanks.
When responding to a highway transportation incident, first responders must determine if
hazardous materials are involved and if there is a release or potential release of these materials.
Detecting the presence of hazardous materials during a highway transportation incident and
determining the potential for harm from these products requires knowledge specific to information
sources that first responders will encounter during these events.
Characteristics of Labels and Placards

Included in the Code of Federal Regulations - Transportation are identification tools known
as labels and placards. Labels and placards often allow first responders to detect the presence of a
hazardous material from a safe distance. However, the information provided is usually limited to
a material’s hazard class rather than the name of the material. This is generally due to the fact that
many highway transportation incidents involve vehicles that could each contain numerous types of
hazardous material packages. This makes the display of each individual product name on the outside
of the vehicle difficult. Large containers, such as cargo tanks, are the exception. They may contain
only one or two commodities and therefore it may be easier to provide more specific information
regarding the identity of hazardous materials being transported.
Labels are normally applied to nonbulk containers such as drums, cartons, crates, pails, and
compressed gas cylinders. Labels usually measure at least 3.9 in. on each side1, and they can be
printed on the exterior surface of a package or placed on a securely affixed tag. Another means to
affix labels includes adhesive backings.
Placards are normally affixed to the front, rear, and both sides of transport vehicles such as vans, cargo
tanks, straight body trucks, and semi-trailers. The required placement of placards of the front of a motor
vehicle may be on the front of a truck-tractor instead of, or in addition to, the placement of placards on
the front of the cargo body to which the truck tractor is attached.2
The first responder should be aware that the aerodynamic design of some truck tractors may incorporate
a cab configuration intended to direct air flow around the trailer. As such, the front of the cargo body may
be blocked, thereby making it difficult to see a placard placed there. Placards may also be found on certain
large individual packages, such as large portable tanks.
Placards usually measure at least 10.8 in. on each side3 and are generally made of plastic or tag board
designed for placement in a metal frame, or vinyl with an adhesive backing. There are also devices mounted
on the sides of some transport vehicles with hinged metal panels that allow for selection of the appropriate
placard. Examples of labels and placards are provided in appendix B.
Labels and placards function primarily as an information system designed to alert first responders to a
material’s assigned hazard class. As discussed earlier, knowing the name of a material will allow research of
information specific to that material. Knowing at least the hazard class will still enable first responders to
make better informed decisions during the early stages of an incident involving a transportation mishap.
The label and placard information system includes the following components:
• Background color(s)
• Hazard class name (displayed in the center)
• Hazard class number (single-digit number displayed in the lower corner)
• Symbol (displayed in the upper corner)
The determination of a background color, hazard class number, and symbol is usually dependent upon
the primary hazard class of a material. For example, materials whose primary hazard class is poisonous are
usually identified by labels and placards with a white background color. Materials whose primary hazard
class is flammable (liquid or gas) are usually identified with a red background color. Materials whose primary
hazard class is flammable (whether solid, liquid, or gas) will usually be identified with a flame symbol.
As will be discussed later in this chapter, the display of a hazardous material’s four-digit identification
number is sometimes required on transport vehicles for various shipments of hazardous materials. In
the federal transportation regulations, this number is usually referred to as a marking. The identification
number can help determine the name of the product (or at least several products that share similar
characteristics). However, this number is often displayed in the center of the placard and as such, the
name of the hazard class will not be immediately available. Nevertheless, first responders can still use the
background color, hazard class number, and symbol to their advantage to determine the hazard class.
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For example, a red placard with a flame symbol may display either a 2 or 3 as the hazard class number.
In this situation, a red placard with flame symbol and a hazard class number 3 would represent a flammable
liquid (see fig. 12–1). A red placard with a flame symbol and a hazard class number 2 would represent a
flammable gas (see fig. 12–2).
Fig. 12-1 Flammable Liquid Placard Courtesy of J. J. Keller & Associates, Inc. www.jjkeller.com
Fig. 12-2 Flammable Gas Placard Courtesy of J. J. Keller & Associates, Inc. www.jjkeller.com
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A placard for a gas that is poisonous by inhalation will also display a hazard class number 2. However,
the placard for this material would use a white background color and a skull and crossbones symbol, so as
to differentiate it from a flammable gas placard (see fig. 12–3).
Fig. 12-3 Poison Gas Placard Courtesy of J. J. Keller & Associates, Inc. www.jjkeller.com
Use of Labels and Placards

General requirements regarding use of labels and placards are provided by 49 CFR, parts 100–185.
Most of these requirements stipulate when labels and placards must be used. Remember that labels are
applied to nonbulk containers such as drums, cartons, crates, pails, and compressed gas cylinders and that
placards are normally affixed to transport vehicles.
Most label and placard requirements are based upon a material’s primary hazard class. The potential
for subsidiary hazards to pose risks to personnel still exists. On limited occasions these subsidiary hazards
will be displayed. Usually though, the determination of any subsidiary hazards will require additional
research using information sources such as an MSDS.
In addition to requirements for use of labels and placards, first responders should also be aware of
regulations that prohibit their use. As an example, the use of labels or placards are prohibited unless the
label or placard actually “represents a hazard of the hazardous material being transported.”4
In another example, the use of a four-digit identification number on a radioactive placard is prohibited.5
Thus if a four-digit number is required to be displayed along with a placard during the transportation of
a radioactive hazardous material, it must done so in a manner that does not replace the hazard class name
displayed on the placard. This is typically accomplished by displaying the four-digit identification number
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on an orange rectangular panel or a white square-on-point configuration. This requirement allows for
both the hazard class name and the four-digit identification number to be displayed simultaneously. This
differs from other situations as stated earlier when the four-digit identification number could be used in
lieu of the hazard class name on the placard.
There are also exceptions to the use of labels and placards based upon the type of material and the
amount being shipped. Details of these exceptions will be discussed later in this chapter. In addition to
these exceptions, there is also an allowance for permissive placarding, meaning that placards can be used
even though an exception may exist. While the intent of permissive placarding is admirable, in reality
those responsible for the transportation of hazardous materials may be reluctant to placard transport
vehicles unless absolutely necessary. Among other things, doing so may attract unwanted attention from
law enforcement officials.
First responders should remember that any exception constitutes a potential danger. They may
erroneously equate the absence of a label or placard on a package or transport vehicle with the absence
of a threat from a hazardous material. Furthermore, first responders should never forget that labels and
placards are used only during the transportation of a regulated hazardous material. Therefore, they are
not required by federal transportation regulations for use when transporting nonregulated materials or
on transport vehicles used as on-site storage containers (such as at construction sites). Nor are labels and
placards generally required for use at fixed facilities on storage tanks or buildings.
Placarding of vehicles transporting nonbulk containers

Transportation of nonbulk containers is usually accomplished through use of box trucks or flatbed
trucks. Once individual nonbulk containers are loaded onto a transport vehicle of this type, the decision
to display placards is based upon Tables 1 and 2 found in 49 CFR 172.504(e).
Hazard classes from Table 1 include certain types of organic peroxides, materials that are poisonous
inhalation hazards, and various types of radioactive materials. Placards for materials from Table 1 must be
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affixed to a transport vehicle whenever that vehicle contains any amount of these materials, regardless of
weight. Table 12–1 provides a list of materials found in Table 1 of the federal transportation regulations.
Table 12–1 Placard Required for any Quantity of Hazardous Materials
Table 1 from 49 CFR 172.504(e)
Category of material (Hazard class or division number and

Placard name
additional description, as appropriate)
1.1 EXPLOSIVES 1.1
1.2 EXPLOSIVES 1.2
1.3 EXPLOSIVES 1.3
2.3 POISON GAS
4.3 DANGEROUS WHEN WET
5.2 (Organic peroxide, Type B, liquid or solid, temperature

ORGANIC PEROXIDE
controlled)
6.1 (Material poisonous by inhalation) POISON INHALATION HAZARD
7 (Radioactive Yellow III label only) RADIOACTIVE
Shipments of other classes of hazardous materials are exempt from placarding requirements if the
“aggregate gross weight of hazardous materials” is less than 1,001 pounds. 6 These hazard classes are
found in Table 2 and include categories such as flammable liquids, flammable solids, corrosives, and
some oxidizers. As an example, a transport vehicle containing individual packages with an aggregate gross
weight of 999 pounds of a material whose primary hazard class is corrosive is exempt from displaying
corrosive placards.
It should be remembered that the term aggregate gross weight includes the weight of a package and
the weight of its contents. This is an advantage to first responders, since the weight of a container counts
towards the total weight required to placard a transport vehicle as opposed to just the weight of the
material itself.
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Table 12–2 provides a list of materials found in Table 2 of the federal transportation regulations.
Table 12–2 Placard Exception for Quantities of Hazardous Materials Less Than 1,001 Pounds
Table 2 from 49 CFR 172.504(e)
Category of material (Hazard class or division number and

Placard name
additional description, as appropriate)
1.4 EXPLOSIVES 1.4
1.5 EXPLOSIVES 1.5
1.6 EXPLOSIVES 1.6
2.1 FLAMMABLE GAS
2.2 NON-FLAMMABLE GAS
3 FLAMMABLE
Combustible liquid COMBUSTIBLE
4.1 FLAMMABLE SOLID
SPONTANEOUSLY
4.2
COMBUSTIBLE
5.1 OXIDIZER
5.2 (Other than organic peroxide, Type B, liquid or solid,

ORGANIC PEROXIDE
temperature controlled)
6.1 (Other than material poisonous by inhalation) POISON
6.2 (None)
8 CORROSIVE
9 Class 9
ORM-D (None)
Once hazardous materials are no longer loaded on vehicles transporting individual nonbulk containers,
the placards must be removed. Again, it is prohibited to display a placard for a hazard class that is not
represented on the vehicle.
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Display of Four-Digit Identification Numbers

Most placards used with individual shipments on box trucks and flatbed trucks display the name of
the hazard class. However, there are certain situations when materials shipped in large packages or a large
quantity of small packages may instead require that the transport vehicle be marked with the material’s four-
digit identification number. One example involves shipments of large individual containers, sometimes
referred to as intermediate bulk containers, which are rigid or flexible packaging (other than a cylinder
or portable tank) that contain several hundred gallons of product. These intermediate bulk containers
are designed for mechanical handling (such as by a forklift) and when transported, generally require the
product’s identification number to be displayed on the vehicle.7
In another example, there are various circumstances when transport vehicles contain large quantities
(usually in excess of 8,820 pounds) of a single hazardous material shipped in nonbulk containers 8
An example could be when a vehicle is loaded with numerous 55-gal. drums containing a regulated
hazardous material and whose aggregate gross weight is 10,000 pounds. In this situation, the vehicle may
need to be marked with the product’s identification number. However, the specific requirements for this
type of marking include several provisions and limitations that must be taken into consideration, so first
responders may not always see it used.
As was discussed earlier, display of an identification number is typically accomplished by displaying
the four-digit identification number in the center of the hazard class placard (see fig. 12–4). However, in
some circumstances, the four-digit identification number can also be displayed on an orange rectangular
panel located near the placard, or using a white square-on-point configuration.
Fig. 12-4 Poison Gas Placard with a 4-Digit Identification Number Courtesy of J. J. Keller & Associates, Inc. www.jjkeller.com
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Placarding of cargo tanks

Bulk shipments that involve cargo tanks, such as those intended to transport liquids or compressed
gases, are subject to placarding requirements similar to those for vehicles that transport nonbulk
containers. One difference involves the fact that there is no exemption for materials based upon weight.
(As mentioned previously, Table 1 and Table 2 do not apply to bulk cargo tanks.) Another difference is
that placards usually cannot be removed from a cargo tank until it is “sufficiently cleaned of residue and
purged of vapors to remove any potential hazard.”9
In addition, cargo tanks are normally required to display the four-digit identification number along
with the appropriate hazard class placard, regardless of the amount of material being shipped.10 Once
again, the four-digit identification number can be displayed in the center of the hazard class placard, on
an orange rectangular panel, or on a white square-on-point configuration.
There are some exceptions to the display of identification numbers on cargo tanks. This includes one
that states that identification numbers are not required on the ends of a cargo tank having more than
one compartment if hazardous materials having different identification numbers are being transported
therein.11 However, in situations such as this, transportation regulations generally require that the
identification numbers on the sides of the tank be displayed in the same sequence as the compartments
containing the materials they identify.12
Another exception involves situations when a cargo tank with multiple compartments contains different
liquid petroleum distillate fuels (such as gasoline and gasohol). In this case, the identification number for
the distillate having the lowest flash point (and thus the more dangerous commodity) may be displayed
instead of the individual number for each material.13 As an example, a cargo tank containing gasoline and
diesel fuel in two separate compartments could legally display only the four-digit identification number
for gasoline, since gasoline has a lower flash point than diesel fuel.
Use of the DANGEROUS Placard

One exception to placarding requirements affects shipments of nonbulk containers with two or
more categories of hazard classes found in Table 2 of the transportation regulations. For example, one
could consider a shipment of a flammable material with a gross weight of 800 pounds that would be
exempt from placarding requirements. If an additional shipment consisting of a corrosive material with
a gross weight of 600 pounds were to be added to the transport vehicle, the aggregate gross weight of
these materials would now be 1,400 pounds. This would exceed the weight exemption for placarding of
Table 2 materials.
One option available is to apply both CORROSIVE and FLAMMABLE placards. However, an
exception allows the use of a DANGEROUS placard in lieu of the individual placards for each hazardous
class on board the transport vehicle (see fig. 12–5).14 Use of this placard usually indicates a mixed load of
materials from Table 2. A first responder should remember that it is entirely possible for a local delivery
truck to leave a freight terminal in the morning containing various hazardous materials that allow use of
the DANGEROUS placard. It may, however, return later the same day with a totally different load of
hazardous materials, yet still be using the same DANGEROUS placard.
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Fig. 12-5 Dangerous Placard Courtesy of J. J. Keller & Associates, Inc. www.jjkeller.com
Interpreting Labels, Placards, and Markings

Clearly an understanding of the transportation regulations as they relate to the application of labels,
placards, and markings is beneficial to first responders. However, of greater importance is their ability to
interpret the message from labels, placards, and markings when they are displayed as well as when they are
absent. One should consider the following scenarios.
When transport vehicles such as vans or flatbed trucks display a placard, the following situations
could exist:
• There could be any quantity of a material that meets the definitional criteria of a hazard
class found in Table 1 (such as “dangerous when wet” materials).
• There could be 1,001 pounds or more aggregate gross weight of a material that meets
the definitional criteria of a hazard class from Table 2 (such as a corrosive material or a
flammable gas).
• There could be any amount of a material from Table 2. Permissive placarding does exist,
though it may not always be used.
• Display of the DANGEROUS placard likely indicates a mixed load of materials from
Table 2.
• There could be a display of a four-digit identification number either in the center of a
placard (in lieu of the hazard class name) or on orange panels on a van or flatbed. This
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could indicate the presence of materials shipped in intermediate bulk containers or a large
number of nonbulk containers.
When transport vehicles such as box trucks and flatbed trucks do not display a placard, the following
situations could exist:
• The material being transported does not meet the transportation regulations’
definitional criteria of a hazardous material. This material may still pose potential threats to
first responders.
• The material meets the definitional criteria of a hazard class found in Table 2, but the
aggregate gross weight is less than 1,001 pounds.
• The transport vehicle is empty.
When transport vehicles such as cargo tanks display the four-digit identification number, the following
situations could exist:
• The presence of only the material assigned the displayed 4-digit identification number.
• When a cargo tank with multiple compartments contains different liquid petroleum
distillate fuels (such as gasoline and gasohol), the identification number for the distillate
having the lowest flash point (and thus the more dangerous commodity) may be displayed
instead of the individual number for each material.15
• Placards usually cannot be removed from a cargo tank unless it is “sufficiently cleaned
of residue and purged of vapors to remove any potential hazard.”16 Therefore it may be
difficult initially to determine the quantity of material loaded.
In all likelihood, carriers and shippers will make every effort to comply with applicable transportation
regulations. However, there are always real-world situations of which first responders should be aware. And
whether these situations are the result human error or intentional misuse, the impact to first responders
is the same regardless. The result can be a serious lack of information (or perhaps even worse, the wrong
information) for making appropriate and defensible decisions.
There are some examples of placards not being displayed when required. These include:
• Desire to avoid unwanted attention to the vehicle, such as when entering truck weigh
stations or traveling on routes that prohibit the transportation of hazardous materials.
• Misunderstanding of placarding requirements.
• Placards that are damaged, stolen, or otherwise vandalized.
• Shippers understating the weight of materials. This can occur whenever they estimate the
weight of a shipment. However, there are some shippers who intentionally understate the
weight, since this can reduce shipping costs. Regardless, first responders may encounter
situations when placards are not displayed due to understatement of a shipment’s weight.
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Placards may be displayed when prohibited, due to causes such as:

• Vandalism.
• Misunderstanding of placarding requirements.
• Failure to remove placards from a transport vehicle, such as a van or flatbed, following the
unloading of the hazardous material.
• Desire to scare away potential thieves who may be hesitant to open a transport vehicle
that displays a hazardous material placard, even though the vehicle does not contain any
hazardous materials. An example would be placing EXPLOSIVE placards on a transport
vehicle containing valuable electronic merchandise while parked at a truck stop.
Shipping Papers
Shipping papers are documents that can be used by first responders to learn about materials that may
be loaded aboard a transport vehicle. Shipping papers for items regulated by the federal transportation
regulations as hazardous materials will include very specific types of information. Shipments of unregulated
materials may not be accompanied by documentation of any kind, or the information available may be
limited. There may be only one or two shipping papers on a truck when transporting bulk shipments
intended for one or two deliveries. Alternately, there may be numerous shipping papers on trucks that
contain miscellaneous shipments intended for delivery to several different locations.
Shipping papers for shipments of hazardous materials regulated by the federal transportation
regulations will usually include the following types of information for each regulated item:
• Proper shipping name of the material
• Hazard class and four-digit identification number
• Total quantity of materials
• Number and type of packages
• Packing group
• Emergency response telephone number
In addition to this information for each regulated hazardous material shipment, shipping papers will
also include:
• Shipper (origin)
• Consignee (destination)
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Figure 12–6 provides an example of a typical shipping paper for highway transportation.
NAME OF CARRIER DATE
TO FROM
CONSIGNEE SHIPPER
STREET STREET
DESTINATION ORIGIN
NO.
SHIPPING HM DESCRIPTION OF ARTICLES WEIGHT RATE CHARGES
UNITS
15 X 5 GALLON POLY DRUM WITH SCREW CAP 765 LB

ENVIRONMENTALLY HAZARDOUS SUBSTANCE, (347 KG)
LIQUID, N.O.S.
(SODIUM NITRITE AND SODIUM TETRABORATE
PENTAHYDRATE)
CLASS 9, UN3082, PG III, RQ
EMERGENCY RESPONSE TELEPHONE

NUMBER (000) 000-0000
Received the above-named materials in good condition COD AMT: $
By: Date: Total Charges: $
This is to certify that the above-named materials are properly classified, described, packaged, marked, and labeled, and are in proper
condition for transportation according to the applicable regulations of the Department of Transportation.
SHIPPER: CARRIER:
PER: PER:
Fig. 12-6 Typical Shipping Paper for Highway Transportation
There may be circumstances when both regulated and nonregulated materials are included on the same
document. Thus federal transportation regulations require that the information for hazardous materials
be listed in such a way as to get the reader’s attention. This can be accomplished in several ways:
• The information for all shipments of hazardous materials can be listed first.
• The information can be entered in a color that contrasts with that of information for other
types of shipments.
• The information for shipments of hazardous materials can be identified with an X in
a column on the shipping paper captioned “HM” that appears before the proper
shipping name.17
During a highway transportation incident, how can first responders use shipping papers to identify
materials while assessing the potential hazards? First, they should attempt to determine if any of the
shipping papers are for shipments that may have already been delivered. These shipping papers will likely
have a receiving signature. However, first responders must always remember that some of the items in the
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shipment may have been refused due to damage (such as leaking containers). These leaking containers
may still be loaded on the vehicle. These refused shipments are usually indicated on the shipping papers as
exceptions, with handwritten notations.
Once first responders have gathered shipping papers for materials believed to be still loaded on a
vehicle, they must then determine if any of these documents contain entries for hazardous materials. As
stated previously, these entries may be listed first, the entries may be marked with an X, or the entries may
be highlighted. In addition, shipping papers that contain hazardous material entries may be flagged with
an attached tag. First responders should remember that these rules apply only to a regulated hazardous
material. There may be other items loaded that could still pose potential problems to first responders.
Entries for regulated hazardous materials will include the proper shipping name, four-digit
identification number, and hazard class. With this information, a first responder can quickly research
emergency response information using the ERG or the Hazardous Materials Guide for First Responders.
When reading shipping papers, first responders should pay attention to the packing group. According
to 49 CFR172.101 (f ), “Packing Groups I, II, and III indicate the degree of danger presented by the
material is either great, medium or minor, respectively.”18 Not all hazardous material entries will include
reference to a packing group. However, there is benefit to first responders when it is available. Without
any additional information about a hazardous material other than its packing group, first responders
know at least that a material listed as Packing Group I is probably bad stuff!
Shipping papers should also provide information regarding the type and number of containers. This
can be helpful in attempting to assess the magnitude of the incident and how first responders can expect
the containers to react. Again, hazardous materials become a problem only when released from their
containers or when the containers are stressed with a potential for a release. A shipping paper indicating
“compressed gas cylinders” can signal danger if the transport vehicle is on fire. Likewise, a vehicle that
has overturned down an embankment and that contains materials packaged in bags, boxes, or glass jars
likely has spilled some of its contents simply due to the force of the impact. The first responders should
remember too that this assessment does not take into account the subsequent effects of fire or water on
these containers.
Probably some of the most important information contained on shipping papers is an “emergency
response telephone number.” This number must be provided by the person who offers a regulated
hazardous material for shipment (the shipper). According to 49 CFR 172.604(a), this telephone number
must be “monitored at all times the hazardous material is in transportation, including storage incidental
to transportation.”19 The number must be for someone who is “either knowledgeable of the hazardous
material being shipped and has comprehensive emergency response and incident mitigation information
for that material, or has immediate access to a person who possesses such knowledge and information.”20
Chapter 6 provides additional information on these emergency contacts.
There are some myths about shipping papers that often plague first responders. The first is that an
MSDS be must be attached to shipping papers. While 49 CFR 172.602 states that emergency response
information must be available, the use of an MSDS to meet this requirement is optional rather than
mandatory. This same section of the transportation regulations also states that “an emergency response
guidance document” (such as the ERG) can be used.21
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Some first responders also believe that if there is more than one shipping paper, then the position of
the papers if stacked together indicates the relative position of the shipment on the vehicle. For example,
shipping papers on top of a stack would be for shipments towards the rear of the truck, and papers on the
bottom of the stack are for those near the nose of the vehicle. While this may apply in some circumstances,
there is no way to assure first responders that this will always be the case. Instead, a driver may have freight
loaded down one side of the vehicle, and the potential is for the last stop to be on the back of the vehicle.
This may occur if this shipment is on a pallet that needs to be near the rear of the trailer so a forklift can
reach it from the ground.
Despite the first responder’s ability to use shipping papers to his advantage, he must remember that
he must first get the shipping papers. This is not always easy, since these documents are usually carried in
the vehicle with the driver. The best scenario is when the driver presents the first responder with all of the
shipping papers. However, the first responder should not count on this happening. A number of things
can occur to complicate this, including:
• Shipping papers are in the vehicle, but dangerous conditions prevent anyone from
approaching the vehicle. These include situations when the driver is either in the vehicle
(but incapacitated in some way) or away from the vehicle.
• The driver presents the first responder with shipping papers, but there may be some
missing.
• The vehicle is loaded with numerous small shipments, and the driver has delivered some of
these shipments already. The first responder needs to figure out which ones are no longer
on the truck.
• In the aftermath of a vehicle accident, the driver presents the first responder with the
shipping papers, but they contain blood stains from injuries that the driver suffered in the
crash. This is a very real biohazard threat to a first responder, and he should avoid touching
any body fluids on the shipping papers and instead perhaps seal them in a clear plastic bag.
If the first responder cannot safely approach a vehicle to get the shipping papers, he may be able to
contact someone who can provide him with a duplicate set of shipping papers. Or perhaps the contact
person can tell the first responder what was loaded onto the vehicle. (Information on contacting shippers
and carriers to obtain duplicate copies of shipping papers was presented in chapter 6.)
If a trailer is disconnected from its tractor, and the trailer contains certain types of regulated hazardous
materials, the transport vehicle may sometimes be marked with the telephone number of the motor
carrier. Alternately, the shipping papers may sometimes be readily available on these vehicles.22
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Additional Highway Transportation Hazards

Besides the dangers posed by hazardous materials transported on commercial vehicles, there are other
problems associated with these types of incidents of which first responders must always be aware. These
include the potential for fire, downed power lines when vehicles have struck utility poles, and even large
truck tires under extreme pressure that pose potential explosion hazards, especially during fires.
In addition, first responders often deal with
First responders were at a truck stop incidents involving commercial vehicles that
during an incident that involved a box are located down roadside embankments or in
highway medians. The final resting place for
trailer displaying flammable liquid these vehicles following an accident could be
placards with a small but steady leak upright, on one side, or completely overturned.
Regardless of the vehicle’s position, stability
from the rear door. Efforts to identify should always be suspect, especially since any
loaded material may have shifted.
the material and stop the release were
This hazard is especially important during
conducted by a hazardous materials incidents that involve flatbed trucks, since these
team and concluded safely. However, loads are often secured with nothing more than
straps or chains that could have been damaged.
during the incident it was determined The potential for a large vehicle and its contents
there was no flammable liquid placard on to suddenly tip over with little warning and crush
unsuspecting first responders is all too real! At
the rear of the trailer. When questioned, that point, the dangers of hazardous materials
may pale in comparison to the crushing force of
the driver denied having any knowledge an 80,000-pound truck.
as to the whereabouts of this placard. A
witness later informed first responders
that the trailer had been parked at the
truck stop without any placards prior to
the incident, and only when the driver
realized there was a leak did he attempt
to placard the vehicle. He was unable
to placard the rear door for fear of
contamination by the liquid. The driver
eventually confessed his misdeeds
to police.
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Key Points
• Federal transportation regulations include identification tools known as labels, placards,
and markings.
• Labels are normally applied to nonbulk containers such as drums, cartons, crates, pails,
and compressed gas cylinders.
• Placards are normally affixed to the front and rear and both sides of transport vehicles such
as vans, cargo tanks, straight body trucks, and semi-trailers.
• The determination of the background color, hazard class number, and symbol used on
labels and placards is usually dependent upon the primary hazard class of a material.
• Certain hazard classes are exempt from placarding requirements if the aggregate gross
weight of materials shipped in nonbulk containers is less than 1,001 pounds.
• Cargo tanks are normally required to display the four-digit identification number along
with the appropriate hazard class placard.
• A DANGEROUS placard may be used instead of individual placards for a mixed load of
hazardous materials found in Table 2 of the federal transportation regulations.
• Information from shipping papers, including the proper shipping name or four-digit
identification number, can be used to research emergency response information from the
ERG or the Hazardous Materials Guide for First Responders.
• A packing group number can provide a relative assessment of the danger posed by a
hazardous material. Packing Group I materials are the most dangerous.
• First responders should be alert for hazards at highway transportation incidents that
include the potential for fire, downed power lines, and large tires that pose potential
explosion hazards.
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Chapter Questions
1. Identify specific situations in which first responders are likely to see labels and placards.
2. Labels and placards are an information system. Identify four components of this system.
3. Will labels and placards always warn first responders about all dangers associated with a
hazardous material? Explain your answer.
4. Explain the difference between prohibited and permissive placarding regulations. Provide
at least one example of each.
5. How do references to Table 1 and Table 2 contained in the federal transportation regulations
influence decisions to apply placards to transport vehicles?
6. Describe use of the DANGEROUS placard.
7. When can placards applied to bulk cargo tanks be removed?
8. In situations in which bulk cargo tanks with separate compartments each contain a
different hazardous material, is the shipper always required to display a placard for each
material? Explain your answer.
9. Identify at least three situations that could exist when commercial vehicles do not display
any placards or markings.
10. Identify at least five items that will be included on all shipping papers for shipment of
regulated hazardous materials.
11. Identify three ways in which a shipper can distinguish the entry for a shipment of a regulated
hazardous material on a shipping paper from entries for materials that are nonregulated.
12. Describe the benefit of knowing the assigned packing group of a regulated hazardous
material.
13. Identify two requirements related to an emergency response telephone number with which
shippers of regulated hazardous materials must comply.
14. Identify at least three situations in which first responders may be unable to access shipping
papers during a highway transportation incident. Identify solutions for each.
15. If a trailer containing certain regulated hazardous materials is disconnected from its tractor,
what information regarding the shipment might be available to first responders?
150
References
1 Code of Federal Regulations. 49 CFR § 172.407(c), http://www.myregs.com/dotrspa/.
2 Code of Federal Regulations. 49 CFR § 172.516(b), http://www.myregs.com/dotrspa/.
4 Code of Federal Regulations. 49 CFR § 172.502(a)(1)(ii), http://www.myregs.com/dotrspa/.
5 Code of Federal Regulations. 49 CFR § 172.334(a), http://www.myregs.com/dotrspa/.
8 Code of Federal Regulations. 49 CFR § 172.301(3)(ii), http://www.myregs.com/dotrspa/.

9 Code of Federal Regulations. 49 CFR § 172.514(b)(1), http://www.myregs.com/dotrspa/.
10 Code of Federal Regulations. 49 CFR § 172.328 (a)(2), http://www.myregs.com/dotrspa/.
11 Code of Federal Regulations. 49 CFR § 172.336(c)(1), http://www.myregs.com/dotrspa/.
12 Ibid.
14 Code of Federal Regulations. 49 CFR § 172.504 (b), http://www.myregs.com/dotrspa/.
16 Code of Federal Regulations. 49 CFR § 172.514(b)(1), http://www.myregs.com/dotrspa/.
18 Code of Federal Regulations. 49 CFR § 172.101(f ), http://www.myregs.com/dotrspa/.
21 Code of Federal Regulations. 49 CFR § 172.602(b)(3)(iii), http://www.myregs.com/dotrspa/.
22 Code of Federal Regulations. 49 CFR § 172.606(b), http://www.myregs.com/dotrspa/.
151
13
RAILROAD TRANSPORTATION INCIDENTS
When first responders think about a railroad incident that involves hazardous materials, they
likely imagine a massive jumble of leaking and burning tank cars, followed by explosions and plumes
of hazardous chemical vapors that travel for miles. While this type of scenario is entirely possible,
it overshadows the potential for several other types of railroad hazardous materials incidents. While
reports of these events may not appear on national news, they are nonetheless important.
In addition to trains containing more than 100 cars that could travel through the first responder’s
community, there may be numerous rail sidings. At these sidings railroad cars are staged, and
individual cars are loaded and offloaded at industrial facilities. These industrial facilities include
those where chemicals are transferred between rail tank cars to fixed storage tanks. They also include
those that involve the transfer of chemicals between rail tank cars and highway cargo tanks. There
may also be sites in the community where railroad cars and locomotives are repaired and classification
yards where railroad cars are sorted to become part of trains headed for numerous destinations.
During any type of transfer operation, there is always the potential for a tank containing a
chemical residue from a previous load to be mistakenly loaded with a different and incompatible
material. The result could be a chemical reaction with dangerous consequences. There may also
be incidents that result from leaks in transfer hoses or from damage to tank fittings that occur
while handling rail cars. Each of these situations represents a potential site for a hazardous materials
incident. While they may not be catastrophic in the sense of a major derailment, they can still pose
significant threats to a community in the event of a release of product.
Another type of railroad incident first responders may encounter is a running leak, which can
occur when a rail tank car is leaking while the train is moving. This type of leak will most likely be
observed by those waiting at a rail crossing for a train to pass. Unfortunately, by the time these same
individuals call 9-1-1 to report the incident, the train may have already traveled several miles. It may
be far beyond the original location where the problem was first noticed.
The first responder may also respond to a report of a suspicious substance found in between
railroad tracks. This material may be a solid or liquid, and the first responder knows it most likely
came from a rail car. Of course, the questions are, “Which one?” and “Is it still leaking?”
First responders should never forget that regardless of a train’s cargo, each locomotive likely has
the capacity to carry several thousand gallons of diesel fuel, with the potential to create a major fuel
spill. Another hazard is that diesel locomotives operate with large alternators or generators that produce
electricity to operate traction motors that transfer power to axles of the locomotive. These alternators and
generators can present the threat of electrocution to first responders.
Preparing for a Railroad Transportation Incident

When preparing for a railroad transportation incident, first responders should know that while in
most circumstances a single company owns and maintains the tracks, more than one rail company may
use them. First responders should therefore learn which companies are involved with any rail operations
in their area and then make contact with each company’s safety representative for the purposes of
preplanning. They should remember that companies using railroads include not only freight carriers, but
also those that transport passengers. Therefore each rail incident will present its own unique challenges.
Preplanning with railroad safety officials will allow first responders to learn what commodities are
usually transported. First responders may also learn where shipping papers are located on a train and how
to retrieve and properly use these documents as a reference source during an incident. First responders
should remember that there may be differences between the paperwork carried on trains that travel
through their community and those trains that are involved with switching cars at local rail sidings.
In addition to using shipping papers to identify hazardous materials, placards and markings similar to
those for highway transportation are used to identify hazardous materials. These are used for hazardous
materials transported in rail tank cars, box cars, and even highway containers loaded onto rail flatcars.
Markings include the four-digit identification number for various shipments as well as the display
of shipping names for certain materials that are stenciled onto the sides of rail tank cars. Additional
information on placards and markings was given in chapter 12.
Meeting with railroad representatives in advance of an incident allows them an opportunity to learn
about the emergency response capabilities available in their community. In addition to assisting with
preplanning, these representatives are a valuable resource during any incident that involves railroad cars.
As such, first responders should know how to contact them for an emergency, especially one that occurs in
the middle of the night. These individuals can provide the expertise for managing an event. In addition,
they can also provide documentation of what was loaded on individual railroad cars (in the event that the
shipping papers are destroyed or inaccessible during an incident). They can also make arrangements for
cleanup of spilled hazardous materials.
These emergency contacts are also important if a first responder needs to speak with the railroad’s
dispatchers. The first responder may need to inform them of a running leak or to stop a train in the event
that the tracks are blocked, or if he wants to avoid having trains proceed through an area. First responders
must always anticipate that tracks could be active, regardless of the time of day, and never forget that
it may require several thousand feet for a train to stop. Early notification to train dispatchers is of
critical importance.
Vehicle access to railroad right-of-ways with fire apparatus and ambulances is often difficult. First
responders will also face challenges when attempting to gain access to water supplies such as hydrants
154
when operating on railroad right-of-ways. Therefore, it is important to preplan access points for apparatus
and water sources, as well as apparatus staging areas. The ability to effectively use water and to ensure an
adequate supply with limited access points along rail lines may require relay operations for moving water
several thousand feet from its source.
One of the best ways to preplan for rail emergencies is to make arrangements with the owner of the
railroad for first responders to ride in one of the railroad’s highway vehicles specifically designed to drive
on rail tracks. These vehicles will allow the first responders to gain valuable knowledge about railroad
right-of-ways and the location of rail sidings. It will also provide first responders with an opportunity to
observe the railroad operation from the company’s perspective.
During this trip, in addition to noting access points for apparatus and water supplies, the first
responder should attempt to coordinate these points with the railroad mile markers. These markers will
likely be used by train personnel to report an incident. It is much simpler if first responders can plan their
response based upon a railroad mile marker. Not all incidents will occur at rail crossings where there is a
named cross street to serve as a reference point.
Responding to Railroad Transportation Incidents

When responding to a railroad incident involving hazardous materials, many of the rules apply that
also apply to highway incidents. First responders should remember too that pressurized tank cars usually
present greater threats to safety than do nonpressurized tank cars. In addition, rail tank cars may carry
in excess of 30,000 gal of product. Thus there is always the potential for these large volumes of materials
to be released during a derailment and to react violently when mixed with other products. At first these
reactions may be totally unpredictable, since early on first responders may not know exactly what materials
are involved.
When notified of a railroad incident involving hazardous materials, first responders should rely on the
ERG for assistance in determining what actions to take. The suggested isolation and evacuation distances
found in the ERG for incidents involving rail cars are greater than for incidents involving smaller,
individual containers. These distances usually increase if the rail cars are involved in a fire. Therefore, early
and prompt efforts to notify and protect the public during rail incidents are essential.
It may also be determined that it is too dangerous for first responders to operate in proximity to the
incident, and that their evacuation is required as well. First responders who work from a firehouse located
next to railroad tracks should not be surprised if an incident places their station in a dangerous area. As
a result, they may not be able to get to their apparatus. First responders must make sure they have an
alternate plan when this situation occurs.
Railroad safety personnel may instruct first responders on how to safely shut off a locomotive from
the outside of the vehicle. However, when performing this task, first responders must always assess the
stability of the vehicle and whether there are other hazards at the scene. These could include downed
power lines that may be resting on the vehicle. For individual rail cars that are upright on the tracks, there
are still concerns regarding stability. These include whether the cars will begin to move on their own along
155
the tracks in the event the brake is not set or does not
A rail tank car with an approximate operate properly.
20,000-gallon capacity that Stability is also a concern for incidents involving
contained more than 1,000 gallons highway freight containers that have been stacked on
a rail flat car. These containers may be in a position to
of toluene diisocyanate was parked fall and crush first responders who approach too close
inside a factory building. The tank to the scene before a thorough safety assessment has
been completed.
was connected to hose lines that
As with preplanning involving railroad tracks, first
provided pressure to offload the responders should also learn about the sites in their
liquid product. While the tank car was community where rail cars, especially tank cars, are
used. Incidents at these sites may not directly involve
still under pressure and connected the rail car, but may instead involve leaks in transfer
to the hoselines, a locomotive hoses and pumps. Regardless of how a release occurs,
there is always the potential for a large volume release
hooked to the car and proceeded to occur when rail tank cars are involved.
to remove it from the building. For incidents that occur at fixed facilities, a
representative from that facility should be able to
Within seconds after the car began provide information relative to product identification.
to move, the hoseline connections This individual should also be familiar with exposures
and the location of drains and other avenues for the
broke at the tank fittings, allowing spill to travel off-site. They should have access to the
the product to be released under product’s MSDS.
great pressure. The car was outside When attempting to contain hazardous materials
during an incident that occurs on a railroad right-of-
of the building when the forceful way, first responders must always remember that these
spray of liquid was noticed and at locations are often used by utility companies to bury
their facilities underground. It might seem logical
which time the locomotive stopped. to have a backhoe dig a containment area next to a
Unfortunately, the car had come leaking rail tank car. However, the potential exists for
mechanical damage to occur to underground utilities,
to rest directly over a storm drain. with serious consequences.
This then allowed several hundred Damage to underground facilities can also occur
from large quantities of spilled liquid materials
gallons of the product to enter a that saturate soil at the site. Furthermore, damage
nearby creek with contamination could occur from the impact of rail cars during a
derailment that gouge a path along the railroad right-
that eventually extended for several of-way and subsequently strike buried utilities. These
miles through a residential area. underground utilities could include electric power
lines that may then present a hidden electrocution
hazard to first responders. Prompt contact with utility
156
locating companies in the first responders’ area is critical during any incident that occurs along a railroad
right-of-way. Chapter 11 provides information on how to contact these utilities.
First responders should always be mindful that while some communities do not have rail lines, the
possibility exists for the first responders from these localities to assist those who do. Therefore, all first
responders should be prepared for railroad incidents that could involve hazardous materials and know
who to call for help. First responders need to have a simple appreciation for the large volumes of materials
carried on rail cars. This should be combined with the knowledge that an incident involving nothing
more than an overturned locomotive can still have the potential for a large release of diesel fuel. Together
they will help to ensure the safety of first responders.
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Key Points
• Most locomotives have the capacity to carry several thousand gallons of diesel fuel, which
gives them the potential to create a major fuel spill.
• Diesel locomotives operate with large alternators or generators that produce electricity
to operate traction motors. These alternators and generators can present a threat of
electrocution to first responders.
• First responders should consider meeting with railroad safety officials in order to plan for
incidents that involve rail transportation.
• All rail tracks should be considered active, regardless of the time of day.
• It may require several thousand feet for a train to stop.
• It is important to preplan access points for apparatus to railroad right-of-ways and nearby
water sources using railroad mile markers.
• First responders can plan for rail emergencies by riding in railroad highway vehicles
specifically designed to drive on railroad tracks.
• Concerns regarding stability of rail cars should include whether the cars will begin to
move on their own in the event the brake is not set or does not operate properly.
• First responders must remember that a railroad right-of-way may be the site of
underground utilities.
• Railroad grade crossings not only have the potential for motor vehicle accidents involving
trains, but they can also impede your response to emergencies if blocked.
158
Chapter Questions
1. Identify at least two sites within the community where rail lines operate, and determine the
name of the companies that maintain and use these lines. Provide the name and contact
numbers for at least one representative from each company identified. Obtain a telephone
number for each contact person for after-hours emergencies.
2. Describe how first responders can plan for rail emergencies and learn about access points
to railroad right-of-ways.
3. When contacting railroad dispatchers to request they halt train traffic, why is early
notification essential? How would first responders in your community make this request?
4. What numbering system should first responders use to identify specific sites along
railroad tracks?
5. Identify at least three physical hazards that locomotive and rail cars can present to
first responders.
6. What hazards to first responders might be present underground along railroad right-
of-ways?
7. Obtain examples of shipping papers used by railroad companies operating in the
community. Determine how shipments of hazardous materials are described on
these documents.
8. Identify at least 10 commodities that are normally transported through or to your
community on rail.
9. Identify the location of railroad sidings as well as any railroad repair facilities and
classification yards in the community.
10. Identify the location of railroad grade crossings in the community.
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14
F IXED FACILITY INCIDENTS
Fixed facilities include buildings where hazardous materials may be manufactured, used,
stored, or sold. These include warehouses, chemical manufacturing plants, medical offices, retail
establishments, and buildings that house light industry ranging from vehicle repair to welding
shops. The extent of knowledge related to hazardous materials at fixed facilities by the people who
occupy these sites is dependent upon a number of factors, including whether they are employees
or customers. As for employees, it may depend on the extent of any training provided to them
regarding the management of hazardous materials and related emergencies.
Responding to Fixed Facility Incidents

When responding to a reported hazardous materials incident at a fixed facility, first responders
should remember the following rules. These rules are designed to prevent first responders from
becoming part of the problem:
• Identify the material(s) involved and assess potential for harm from a safe distance.
• Isolate affected areas and deny entry to others.
• Account for all personnel who may have been exposed to the material.
• Provide medical care and decontamination to those exposed.
• Protect persons from potential for exposure (including other first responders).
When dealing with a release of hazardous materials at most fixed facilities, first responders should
remember that rescue of anyone trapped inside or unaccounted for can create dangerous situations.
First responders may react instinctively and enter contaminated areas without first considering the
potential dangers. In contrast, for incidents when all occupants have been evacuated and none
have been exposed to the material, first responders should probably just stay back and evaluate the
situation from a distance. Maintaining a safe distance from any building that is the site of a hazardous
materials release is even more important if the items are potentially flammable or explosive.
The decision by first responders to enter any fixed facility is often a risky one. Interiors of buildings
present situations where vapors and gases can accumulate in high concentrations and in void spaces that
defy detection. Ignition sources may be plentiful. Furthermore, depending upon the size and configuration
of interior layouts, especially large industrial complexes, first responders can easily become disoriented.
They could travel too far inside of a building, and the capacity of their air supply might not allow for
a safe exit. Before entering any building that is the site of a hazardous materials release, first responders
should always ask themselves if doing so will really make a difference.
For incidents that occur at fixed facilities, an occupant or representative may be able to provide
information relative to the material(s) known or suspected of being involved. However, the extent
of information, such as the availability of MSDS, will likely depend upon whether the material is
manufactured, stored, used, or sold at the facility. Chapter 7 gave additional information on the availability
of MSDS at fixed facilities.
Representatives at fixed facilities may also be familiar with interior and exterior exposures. They
may be familiar with the operation of ventilation systems and electrical service, and the location of any
floor drains or other avenues for liquid spills to travel off-site. However, any decision to operate switches
for control of ventilation systems or electrical service should be made carefully. First responders should
take into consideration whether this will expose anyone to a hazardous environment or perhaps ignite a
flammable atmosphere.
Likewise, attempts to enter a building to block a floor drain could prove extremely dangerous. Even
so, first responders should remember that vapors from flammable liquids that enter floor drains can reach
explosive concentrations at the site or perhaps even several miles away.
At some industrial facilities, floor drains may be directed to outdoor holding areas specifically designed
to contain spills of liquid hazardous materials. Under these circumstances, there may be little that first
responders need to do in order to contain a release. However, first responders should still be aware that
vapor clouds could develop from these holding areas or from other areas where liquid product has pooled.
They may need to take protective measures to suppress these vapors.
Some products from fixed facilities may escape as gases or vapors directly from the source of the release
without any evidence of a liquid spill. As mentioned previously, actions to protect people from exposure
to gases and vapors include not only evacuations, but also in-place protection. Those in the immediate
vicinity of a release may not always have time to evacuate. Chapter 11 provides detailed information on
these types of protective actions.
First responders also must remember that the potential for exposure to gases and vapors includes not
only people on-site at the facility, but also the public who live, work, and travel nearby. Therefore, when
preplanning a response to fixed facilities, especially large industrial complexes, first responders should
always be aware of these potential exposures. They must be prepared to react accordingly and request the
necessary resources for assistance as soon as possible.
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FIXED FACILITY INCIDENTS
NFPA 704
In addition to plans and MSDS, another way for first responders to learn about the hazards of
materials at fixed facilities is through use of the National Fire Protection Association (NFPA)’s 704
Standard. This publication is entitled the “Standard System for the Identification of the Hazards of
Materials for Emergency Response.” This standard “addresses the health, flammability, instability, and
related hazards that are presented by short-term, acute exposure to a material under conditions of fire,
spill, or similar emergencies.”1 The standard applies to “industrial, commercial, and institutional facilities
that manufacture, process, use, or store hazardous materials.”2 NFPA 704 signs may be displayed in a
number of ways, including affixed to the exterior of buildings, on fences that surround outdoor storage
areas, at access points to rooms or indoor storage areas, or on aboveground storage tanks. However, NFPA
cautions that the standard “shall not apply to transportation or use by the general public.”3 Therefore, first
responders should not expect to see signs associated with NFPA 704 displayed on transport vehicles such as box
trucks, cargo tanks, or rail tank cars.
In order to identify the hazards of a material, this identification system indicates the “degree
of severity by a numerical rating that ranges from four, indicating severe hazard, to zero, indicating
minimal hazard”4
Table 14–1, 14–2, and 14–3 provide a summary of each numerical rating used.
Table 14–1 NFPA 704 Degrees of Health Hazards (Blue)
4 Materials that, under emergency conditions, can be lethal.
3 Materials that, under emergency conditions, can cause serious or permanent injury.
Materials that, under emergency conditions, can cause temporary incapacitations

2
or residual injury.
1 Materials that, under emergency conditions, can cause significant irritation.
Materials that, under emergency conditions, would offer no hazard beyond that of ordinary
0
combustible materials.
Information obtained from NFPA 704 (2001 edition), Section 5.2
163
Table 14–2 NFPA 704 Degrees of Flammability Hazards (Red)
Materials that will rapidly or completely vaporize at atmospheric pressure and normal ambient
4
temperature or that are readily dispersed in air and will burn readily.
3 Liquids and solids that can be ignited under almost all ambient temperature conditions.
Materials that must be moderately heated or exposed to relatively high ambient temperatures
2
before ignition can occur.
1 Materials that must be preheated before ignition can occur.
Materials that will not burn under typical fire conditions, including intrinsically noncombustible
0
materials such as concrete, stone, and sand.
Table 14–3 NFPA 704 Degrees of Instability Hazards (Yellow)
Materials that in themselves are readily capable of detonation or explosive decomposition or

4
explosive reaction at normal temperatures and pressures.
Materials that in themselves are capable of detonation or explosive decomposition or explosive

3 reaction, but that require a strong initiating source or that must be heated under confinement
before initiation.
2 Materials that readily undergo violent chemical change at elevated temperatures and pressures.
Materials that in themselves are normally stable, but that can become unstable at elevated
1
temperatures and pressures.
0 Materials that in themselves are normally stable, even under fire conditions.
Each numerical rating for health, flammability, and instability is displayed on a diamond-shaped sign
with four individual quadrants, each with the following background colors and position:5
• Health hazard Blue 9:00 position
• Fire hazard Red 12:00 position
• Instability hazard Yellow 3:00 position
• Special hazards No color assigned 6:00 position
Indicators of special hazards include the letter W with a horizontal line through the center for materials
that react violently or explosively with water. The letters OX are used for materials that possess oxidizing
164
properties.6 Figure 14–1 shows how the different components of an NFPA 704 sign are arranged.
Figure 14–2 shows an example of an NFPA sign.
Fig. 14-1 Components of NFPA 704 Sign
Fig. 14-2 Example of an NFPA 704 Sign
165
According to the NFPA, the signs shall be in locations “approved by the authority having jurisdiction”
(usually the local government).7 The NFPA says that as a minimum, the signs shall be posted at the
following locations:
• Two exterior walls or enclosures containing a means of access to a building or facility
• Each access to a room or area
• Each principal means of access to an exterior storage area
When more than one chemical is stored at a fixed facility in either a building or a particular area,
NFPA 704 allows three ways to identify the hazards present:
1. Composite method. Where many chemicals are present, a single sign shall summarize the
maximum ratings contributed by the materials(s) in each category and the special hazard
category for the building and/or the area.
2. Individual method. Where only a few chemicals are present or where only a few chemicals
are of concern to emergency responders (taking into account factors including physical
form, hazard rating, and quantity), individual signs shall be displayed. The chemical name
shall be displayed below each sign.
3. Composite/individual combined method. A single sign shall be used to summarize the
ratings via the Composite Method for buildings or other areas containing numerous
chemicals. Signs based on the Individual Method shall be used for rooms or smaller areas
within the building containing small numbers of chemicals. 8
The unfortunate reality is that despite the benefits of this system, legal authority to enforce use of
NFPA 704, like all other NFPA standards, is not possible unless adopted as law by some governing body.
This could occur either at the local or state level. Therefore, first responders should determine if their
local or state governments provide for enforcement of this standard. If not, they should at least suggest to
owners and operators of fixed facilities that they consider use of NFPA 704. Of course for some owners
and operators, the use of NFPA 704 may be influenced by their desire to provide a means of effective
emergency preparedness. For others, the use of NFPA 704 may be required by their insurance company.
The Reality of Fixed Facility Incidents

First responders who arrive at the scene of a hazardous materials incident at a fixed facility may
determine that a hazardous materials team is necessary in order to stop a release. During other incidents,
there may only be a need to clean up spilled material. Once in the cleanup phase, first responders should
remember that whoever owns or occupies the building also owns the problem. First responders should
not inherit this problem by attempting cleanup themselves.
At some fixed facilities, the assistance of first responders may not be requested or even desired. Instead
some sites may have a response plan that calls for their own personnel or a cleanup contractor to stop any
release and to clean up spilled material. In situations such as these, first responders may never learn of a
hazardous materials incident. If they do learn of the event, perhaps from a third party, they may be denied
166
entry, with facility representatives confident in their An emergency services official

ability to manage the incident safely.
received a call from a factory
In reality, not all hazardous material incidents
at fixed facilities are catastrophic to the community. employee requesting to know
However, first responders are probably in the where he could rent a stainless
best position to deal with what could become an
immediate threat to public safety. Therefore, first steel pump. While questioning
responders should always remember the benefits the employee, the official detected
of developing good working relationships with
representatives from fixed facilities. Good working a growing sense of urgency in
relationships should encourage notification of the caller’s voice accompanied
first responders directly through 9-1-1 for any
incident involving the release or potential release of by frantic conversations by other
hazardous materials. factory employees overheard in the
First responders should also remember that background. The caller denied there
some fixed facility representatives possess a time-
is-money mentality. This can derail good judgment being any emergency, despite his
and force first responders and cleanup contractors to insistence on obtaining a pump as
make quick, uninformed decisions and take careless
steps they later regret. Some facilities do have the soon as possible. Concerned about
potential for serious consequences due to service
interruptions, such as water treatment plants.
an immediate threat to public safety
For most, however, the expense of downtime is from an as yet unknown material,
usually nothing more than an inconvenience. First
responders must remain firm in their commitment
the official notified the local fire
to public safety. department that responded to
the scene. Upon their arrival, they
discovered a large tank inside the
factory containing a glycol-based
substance that had begun to leak.
While a dike surrounding the tank
had contained most of the product,
one side of the dike was cracked
which had allowed several gallons
of the spilled material to exit the
building and enter a nearby creek.
167
Key Points
• Fixed facilities that can be the site of a hazardous materials incident include warehouses,
chemical manufacturing plants, medical offices, retail stores, and buildings that house
light industry.
• First responders should maintain a safe distance from any building that is the site of a
hazardous materials release, especially if the materials are flammable or explosive.
• First responders can easily become disoriented in large buildings.
• Occupants of fixed facilities may be able to provide first responders with information on
hazardous materials involved in an incident. However, they may not always have immediate
access to MSDS.
• Hazardous materials entering floor drains can pose potential environmental and safety
hazards.
• NFPA 704 indicates the degree of severity by a numerical rating that ranges from four,
indicating severe hazard, to zero, indicating minimal hazard
• NFPA 704 signs may be found on the exterior of buildings, on fences that surround
outdoor storage areas, at access points to rooms or indoor storage areas, or on above ground
storage tanks.
• When more than one chemical is stored at a fixed facility in either a building or a particular
area, NFPA 704 allows three ways to identify the hazards present, including the composite
method. One sign is used that summarizes the maximum ratings contributed by the
materials in each category.
• Legal authority to enforce use of NFPA 704 is not possible unless the standard is adopted
as law by some governing body, either at the local or state level.
168
Chapter Questions
1. Identify at least five different categories of fixed facilities.
2. Why should first responders refrain from entering fixed facilities during a hazardous
materials incident?
3. Some spills at industrial facilities may be directed to outdoor holding ponds. While
these materials are contained on-site, what hazard can these materials still present to
first responders?
4. What three hazard categories are addressed using NFPA 704?
5. NFPA 704 indicates the “degree of severity” using a numerical rating scale. Identify the
range of this scale as well as the numbers that represent the highest and lowest degree
of hazard.
6. Identify the positions of the hazard categories as found on an NFPA 704 diamond-shaped
sign.
7. Identify the three means of displaying the NFPA diamond-shaped sign when more than
one chemical is stored at a fixed facility in either a building or a particular area.
8. Is use of NFPA 704 intended for transportation as well as fixed facilities?
9. Is the use of NFPA 704 required by law in your locality?
10. Determine at least two locations of fixed facilities in your community where NFPA 704 is
used, and identify the numerical ratings and any special hazards displayed.
169
References
1 National Fire Protection Association. “Standard System for the Identification of the Hazards of Materials for Emergency
Response,” 2001, Section 1.1.
2 Ibid., Section 1.3.1.
4 Ibid., Section 4.1.2
5 Ibid., Section 4.13, 4.1.4 and 4.1.5.
6 Ibid., Section 8.2.1 AND 8.2.2
7 Ibid., Section 4.3.
8 Ibid., Section 4.2.3.3.
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15
“ROUTINE” HAZARDOUS MATERIALS INCIDENTS
First responders should always remember that there is no such thing as a routine incident,
especially when dealing with hazardous materials. However, while some hazardous materials
incidents are catastrophic events from the very beginning, most begin as seemingly routine events
and escalate only when something goes terribly wrong.
At other times, first responders may fail to recognize the involvement of hazardous materials
in what may appear to be a routine call. If they do identify something suspicious, they may simply
underestimate the potential threats to themselves, the public, and the environment, and rely on
standard firefighter tactics. These threats are not limited to those that can affect only the health and
safety of first responders. There are also those that can embroil them in legal battles if their actions
are inappropriate.
First responders may be dispatched to what appears to be a routine vehicle fire, trash fire, motor
vehicle accident, suspicious odor, or public service call. Upon arrival, they may discover that they
have actually responded to a hazardous materials incident. They may also respond to an apparently
routine call for “difficulty breathing.” Once there, they may encounter a patient contaminated with
a hazardous material, or even worse, the need to rescue this person from an area where chemical
exposure to first responders is likely.
This chapter provides first responders with information for dealing with various “routine”
incidents, all of which could involve hazardous materials. Those incidents selected represent
situations when first responders have been known to ignore warning signs or perhaps make critical
decisions with only limited knowledge of potential risks. Suggested actions, especially for those
involving rescue and fire suppression, are intended to provide first responders with at least some
considerations when faced with these situations. They are also intended to encourage discussion and
debate among first responders regarding how they would choose to manage these events. Incidents
discussed in this chapter include:
• Spills from home heating oil tanks
• Residential carbon monoxide detectors
• Fuming trash containers and trash collection trucks
• Suspicious odors in buildings
• Defensive fire suppression strategies
• Contaminated patients
Spills from Home Heating Oil Tanks

Spills from home heating oil tanks are common, especially during winter months. These types of
incidents may involve an overfilling of a tank or a tank that falls over. Perhaps a situation involves an
effort to fill a tank located inside of a basement, only to learn that the tank had previously been removed,
resulting in several hundred gallons of spilled oil inside of a building.
During any incident that involves home heating oil spilled inside of a residence or even in a crawl
space underneath the residence, first responders should give careful consideration to any decision that
allows residents to remain inside. Besides the potential for a fire hazard, the vapors produced by the oil
can have varying health effects on the occupants.
First responders should contact local health officials, representatives from environmental agencies,
local codes and compliance officials, and perhaps even the fire marshal. And they should not be surprised
if the owners of the company delivering the heating oil either attempt to downplay the severity of the
incident or attempt their own cleanup, or perhaps both.
For spills that occur outdoors, first responders should remember that cleanup related to this type of
spill will likely require removal of several inches of soil. Representatives from the previously mentioned
regulatory agencies, not first responders, should be the ones responsible for determining the extent of
cleanup required. First responders should also remember that any delay in cleanup may allow the product
to soak into surrounding soil and possibly affect drinking water wells and septic systems. Spills of heating
oil outdoors may migrate from the affected area in the event of rain. Indoor spills can enter floor drains.
When this occurs, first responders must determine if these drains are connected to local sewer systems or
perhaps nearby septic tanks.
The role of first responders during these types of incidents should be to ensure the safety of individuals
potentially exposed to the material and to contain the spread of the material. They should never assume
responsibility for cleanup but instead should contact representatives of local and state agencies with the
financial resources and legal authority to ensure these situations are managed correctly.
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Residential Carbon Monoxide Detectors

Many first responders are called to investigate incidents that involve alarms from carbon monoxide
detectors in residential occupancies. In addition to treating occupants of these buildings who may have
been exposed to dangerous levels of carbon monoxide, first responders must protect themselves from
potential exposure. They may also be requested to determine a source of the carbon monoxide and to
decide if a building is safe for reentry.
During situations dealing with the general public, first responders using atmospheric monitors should
always remember that any numerical values related to occupational exposure levels for carbon monoxide
will not apply. Thus decisions to allow reentry to homes based upon these levels may present the first
responder with potential legal challenges.
While a zero exposure to carbon monoxide is desirable, this may not be possible in all situations. The
first responder will then be faced with the task of determining just what exposure level is acceptable. In
addition, first responders using atmospheric monitors will always need to consider whether their efforts
to use these instruments while evaluating affected areas were appropriate in order to allow them to obtain
accurate readings.
There are sources of information available to first responders for use in developing procedures for
managing these types of incidents. One such source is a document entitled, “Responding to Residential
Carbon Monoxide Incidents—Guidelines for Fire and Other Emergency Response Personnel.”1 This
document provides recommended techniques for conducting atmospheric monitoring of residential
occupancies using handheld carbon monoxide detectors, as well as suggestions for acceptable exposure
levels. It also includes a checklist for use by first responders and a form for recording advice they provide to
residents whose home may be affected by a release of carbon monoxide. This publication can be accessed
by visiting the U.S. Consumer Product Safety Commission Web site http://www.cpsc.gov/cpscpub/pubs/
coguide.pdf.
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“Fuming” Trash Containers and Trash Collection Trucks

“Fuming” trash trucks or trash containers, or those with detectable chemical odors or visible plumes
of smoke, are usually opportunities for first responders to exceed their level of training. They could make a
minor situation a lot worse. Most of these incidents involve the disposal of household hazardous materials
that then react when mixed with other items or when rain water enters the container.
Incidents involving trash bins can occur at transfer stations and fixed facilities. Fixed facilities usually
rent trash containers for their own use and should therefore have some idea of what has been disposed of.
However, it is not uncommon for the public or other businesses, while looking for a quick means to get
rid of their hazardous waste, to use these same containers, resulting in the disposal of unknown items.
Trash vehicles that compress their loads with a hydraulic device may experience problems when the
force of compression causes containers of hazardous materials to burst. In addition to these materials
reacting with other items, some hazardous materials may splash when their containers are crushed and
possibly contaminate anyone nearby.
Other types of trash vehicles include those that transport roll-off containers with open tops. Most
containers such as these are labeled with signs prohibiting the disposal of hazardous materials. However,
first responders should use caution when investigating any incident that involves a leak from a container
such as this. The material leaking may be rain water, or it could be fatal.
If called to a scene that involves a fuming or leaking trash container, first responders should remember
that a company not only owns the trash truck or the trash bin—they also own the problem. That is of course,
unless first responders attempt to resolve the incident on their own and therefore inherit the problem.
First responders should not dig through any fuming trash bin looking for clues, nor should they
request that a fuming trash truck be driven through town in order to get to the local landfill. Instead,
first responders should treat this situation like any other involving hazardous materials, including steps
to isolate and deny entry to the affected area. Then notify the company that owns the truck or trash
bin and inform them that they have a problem, and let them manage it. The preferred response from
these companies includes those trained and equipped to investigate and resolve the incident, or perhaps
a hazardous materials team or even a cleanup contractor. The preferred response should not include any
remediation activities performed by first responders.
When notifying the owners of the truck or trash bin, first responders can take comfort in knowing
that this will likely not be the first incident such as this that they have handled, nor will it be the last. But
when first responders intervene, they shift much of the burden from the trash company to themselves
and their department. Furthermore, any initial actions taken by first responders, such as dumping the
material on the ground, may cause the owner of the truck or trash bin to claim that first responders only
worsened the incident. The owner may claim that first responders added to the expense of the cleanup.
This additional expense could then become the burden of the first responders.
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Suspicious Odors in Buildings

When called to an incident that involves a report of a suspicious odor in a building, the one thing first
responders should not do is jump off their apparatus, run inside, and sniff around. While some may claim
that this is the only way to determine the source of the problem, it is also an opportunity for disaster.
Besides presenting a potential health hazard, suspicious odors could originate from hazardous materials
that are potentially flammable.
As always, first responders should assess the scene, evacuate affected buildings, account for all personnel,
and treat anyone who may be symptomatic. First responders should remember that these symptoms may
be from exposure, or they could be psychological. Some individuals may also have evidence of chemical
contamination and require decontamination prior to receiving medical care. First responders should
anticipate that any response to investigate a suspicious odor at a large building can quickly escalate into a
mass casualty incident.
In addition to securing the scene and providing for medical care, first responders should attempt
to control any ongoing release of a suspected hazardous material that may be the source of the odor.
However, they should do so only if it can be done safely. This action most often involves control of natural
gas or propane supplies to buildings at the metering device. Natural gas or propane emergencies may also
require the control of ignition sources.
In order to determine the source of an odor in a building, first responders are encouraged to first speak
with occupants, building owners, and those responsible for maintenance. At a private residence, these will
likely all be the same person. For buildings such as apartments, there are likely to be three separate parties
involved.
First responders should request to know if any activities have taken place recently that involve the use
of chemicals. These activities could include those related to plumbing repairs, floor refinishing, painting,
or pest control. A few simple questions posed to occupants, owners, or maintenance personnel outside of a
building could likely yield the source of the odor without having exposed first responders to a potentially
dangerous environment inside. The time to learn that the source of a suspicious odor is related to a “bug
bomb” is not after first responders have inhaled the material for 30 minutes while attempting to “sniff
around” the scene.
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Defensive Fire Suppression Strategies

For first responders, the decision to act defensively during a fire and allow the fuel load to burn away
rather than attempt to extinguish it may be reached only because water is unavailable. Yet during certain
fire situations involving hazardous materials, this may be the best approach when it comes to long-term
outcomes. These include incidents that involve fertilizers, pesticides, and tire piles, as well as spills of
flammable liquids that occur at fixed facilities or during transportation accidents.
First responders should remember that water or foam application presents the threat of a potential
reaction with some hazardous materials. Furthermore, the resultant runoff can spread pollution downstream
with a negative effect on the environment and critical systems, such as water treatment plants. In addition,
materials consumed by fire usually produce less runoff, if any. The elimination of water application from
fire streams may allow for a hotter and thus more complete combustion, with fewer airborne hazards and
less cleanup of a hazardous waste.
For example, one could consider a gasoline tanker fire that occurs in a rural area. Allowing the fuel
load to completely burn away minimizes cleanup and eliminates a potentially dangerous situation from
flammable fuel vapors that would remain had the fire been extinguished. It may prevent leaving several
thousand gallons of hot gasoline exposed to the environment. Efforts to prevent re-ignition of the
remaining fuel would likely require the application of hundreds of gallons of foam. In addition to the
expense of the foam concentrate, the potential for environmental harm from the foam runoff is likely.
While it is impossible to suggest a defensive fire attack strategy for all occasions, first responders should
at least consider this option and rely on consultation with others. Representatives from environmental
regulatory agencies and manufacturers of the materials should be consulted as to the best course of action.
When deciding on a defensive strategy for fires involving hazardous materials, the presence of nearby
exposures must be a consideration, along with the anticipated impact of any smoke plumes.
For exposures that involve wooded areas, cutting a fire line with a tractor may be one way to limit
the spread of a fire. However, care should be taken to ensure that the operators of this equipment are not
exposed to hazardous atmospheres.
Any decision to allow a fire to burn can have political implications as well, especially if the fire requires
several days to extinguish. Therefore, first responders should inform government officials and the public
of their efforts. They should be prepared to offer an explanation as to why the fire department did not
extinguish the fire as the public expected them to do. First responders should also be prepared to deal with
complaints from citizens that range from those forced to remain indoors for an extended period of time
to protect them from toxic vapors to those whose cars and swimming pools are covered with particulate
matter from the smoke.
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Contaminated Patients
Nothing will get a first responder’s attention more or change the scope of an incident as quickly as will
learning that someone has been contaminated with a hazardous material. Not only does this “speed things
up,” but it also presents first responders with more of an urge to respond based upon raw emotion.
Regardless of the material, the best course of action for anyone contaminated by a hazardous material
is to be moved away from the source of contamination. Most exposures are the result of skin contact or
inhalation, and putting distance between the product and people likely reduces those levels of exposure.
The safest scenario is when victims can move away from the source of contamination without physical
assistance. First responders may need to encourage contaminated individuals in a dangerous area to
retreat to safety by providing voice directions. The victims may be disoriented, or their sight could be
compromised due to chemical injuries. First responders should always resist the urge to rush in to attempt
a rescue.
During industrial accidents, the likelihood is that anyone exposed to a hazardous material will be
brought to safety by their coworkers. While this will normally result in more than one contaminated
patient, the need for a rescue by first responders will be lessened. First responders should remember that
even though these coworkers may have moved the initial victim away from the source of contamination,
they may still be too close. The first responders may need to encourage the victim and any coworkers to
move even further away. First responders should decide how far away any exposed patients need to be from
the source. First responders should recall that it is their incident, their patient, and their safety at stake!
Any first responder considering rescue of a victim with suspected hazardous material contamination
must determine if their attempts at rescue will expose them to contamination, both from what is already
on the victim and from any chemical released to the air or the ground. There are other considerations
for first responders. Will the rescue attempt allow for quick entry and exit, or will it require a belabored
effort that involves freeing the victim from some form of entrapment? If the presence of a vapor or gas is
threatening the victim, can the first responders safely use a fog stream to divert these materials away from
the victim? Can they minimize their exposure by using a long pike pole to grab hold of a victim’s clothing
to move them to safety?
When conducting a rescue during a hazardous materials incident, first responders must always
acknowledge the potential for serious injury or death to themselves and any others they may contact. They must
also consider the effects of the material on the victim. They should remember that if structural firefighter
protective clothing and SCBA is inadequate to provide for their own safety, then the chance for survival of
a victim who is likely wearing no protective clothing may be marginal. This can quickly turn a rescue into
nothing more than a body recovery mission.
When deciding whether to enter a contaminated area for rescue, first responders can refer to the
ERG for assistance. In particular, the ERG2004 states, “Each guide (orange-bordered page) includes a
statement about the use of structural fire fighters’ protective clothing (SFPC) in incidents involving those
materials referenced by that guide. Some guides state that SFPC provides limited protection. In those
cases, the responder wearing SFPC and SCBA may be able to perform an expedient (quick “in-and-out”)
operation (such as an immediate rescue).”2
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First responders can also use the information contained in the Hazardous Materials Guide for First
Responders referred to in chapter 7. Several of the specific material guides include the statement, “Do not
put yourself in danger by entering a contaminated area to rescue a victim.”3
Whether or not first responders perform a rescue, they must never forget that anyone with known or
suspected contamination by a hazardous material must be subject to decontamination, especially before
receiving any level of medical care. The Hazardous Materials Guide for First Responders states that “Removal
of hazardous material from the skin, eyes or clothing of a victim (decontamination) is usually the most
important first aid action that can be initiated.”4 It further states that “in general, using large quantities of
water to rinse off materials is almost always the first choice for decontamination in the field.”5 However,
this document also cautions first responders that some materials “are so toxic that first aid should not be
performed on contaminated victims because of the risk of serious injury to the responder.”6
Water used for victim decontamination can be from fire apparatus or even a garden hose. Before ever
attempting a rescue during a hazardous materials incident, first responders should always ensure that a
reliable water supply for gross decontamination is available and located in a safe area before making entry.
If using fire apparatus for a water source, the pump should be engaged before making entry.
Another word of caution is in order when using fire apparatus as a source of water for victim
decontamination, especially during a rescue effort. Pump operators should remember that it may be
several minutes after a pump is engaged until water is needed. During that time, some operators may
forget to recirculate water through the pump, which can result in extreme heating of this water, especially
if the pump is operated at a high speed. Superheated water will then be some of the first to be delivered
from the nozzle, and the potential for burn injuries to the victim is a real possibility. Therefore, during
these situations, pump operators should be reminded to recirculate pump water, even if this requires the
opening of a discharge outlet or nozzle. First responders should not let anyone get burned!
When using water for victim decontamination, first responders should attempt to construct a means
to contain runoff water, but only if time allows. If not, then whenever possible these operations should
avoid paved surfaces and should instead be conducted on porous surfaces, such as grass or soil, which
are less likely to result in the escape of this runoff. It is also easier to remove contaminated soil or grass
afterward as compared to removing contamination from paved areas.
Other types of victim decontamination may be required. For some materials, the ERG2004 states
“removal of solidified molten material from skin requires medical assistance”7 or “in case of contact
with substance, wipe from skin immediately, then flush skin or eyes with running water for at least
20 minutes.”8 First responders are encouraged to obtain advice from information sources such as the
ERG, the Hazardous Materials Guide for First Responders, applicable MSDS, and perhaps even poison
control centers to determine appropriate methods for decontamination and patient care following
chemical contamination.
First responders should remember that efforts to decontaminate anyone with water during extremely
cold weather will add to the patient’s medical problems due to the potential for hypothermia. Whenever
possible, if an indoor shower facility is available, especially during cold weather, the first responders may
wish to consider its use, while acknowledging that this could potentially contaminate the facility.
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Remember too that thorough decontamination First responders were on scene for a
requires removal of contaminated clothing. These
items should be isolated and not allowed to remain report of a suspicious odor inside of
in areas where someone else can encounter them an apartment at a housing complex.
and become contaminated themselves. Ambulatory
victims should be instructed to remove contaminated The occupant was severely agitated
clothing but first responders should have some
means to cover these individuals, such as disposable and threatened first responders to
coveralls or bed linen from an ambulance. quickly determine the source and to
Anyone administering medical care, including make certain it was safe for him and
prehospital and hospital providers, should be
made aware that the patient had been previously his family to return home. Rather
contaminated, along with the name of the than succumb to the demands for an
material(s) involved. References should be made to
the applicable MSDS, if available, and copies of this immediate solution, first responders
document should accompany any patients when
transported to medical facilities. resisted the urge to enter the
Notifications regarding contaminated patients building to “sniff around.” Instead,
should include the crews of medical helicopters. they asked the resident if he had
Some of these crews may refuse to transport these
patients due to the potential for flight crews to be knowledge of any activity that could
affected by the hazardous materials. First responders have resulted in the odor, which he
should check with services that operate medical
helicopters in their area to learn about their policies denied having. First responders then
for dealing with these situations.
contacted building maintenance
First responders should also remember that
any attempt at victim decontamination in the field and learned that workers had earlier
does not always eliminate the need for additional attempted to alleviate a clogged
decontamination upon arrival at a medical
facility. Furthermore, some victims of hazardous drain in a neighboring apartment by
materials contamination may arrive at a medical using large quantities of a caustic
facility in a private vehicle without ever having
been decontaminated. If the facility does not have chemical. The likely source of the
the means to decontaminate these victims, first
responders may find themselves responding to the odor had been determined without
facility to provide this service. first responders ever entering
Situations involving rescue and victim the building.
decontamination are extremely rare, but when they
do occur, they present first responders with both
technical and moral decisions. When making these
decisions, first responders should remember to use
their hearts and their heads.
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Key Points
• Besides the potential for a fire hazard, vapors produced by spills of home heating oil can
have varying health effects on the occupants of a building where a spill has occurred.
• Delays in cleaning up a spill of home heating oil may allow the product to soak into the
surrounding soil and possibly affect drinking wells and septic systems.
• First responders should not use numerical values related to occupational exposure levels
for carbon monoxide when dealing with citizens in residential occupancies.
• A document entitled, “Responding to Residential Carbon Monoxide Incidents—
Guidelines for Fire and Other Emergency Response Personnel,” was published in November
2003 by the U.S. Consumer Product Safety Commission. It provides guidelines for first
responders.
• A trash truck or trash bin that is the site of a hazardous materials release is owned by some
company. First responders should remember that company also owns the problem.
• First responders should refrain from allowing a fuming trash truck to be driven through
town in order to get to the local landfill.
• In order to determine the source of an odor in a building, first responders are encouraged
to first speak with occupants, building owners, and those responsible for maintenance.
• When deciding on a defensive strategy for fires involving hazardous materials, the presence
of nearby exposures must be a consideration.
• When dealing with victims of hazardous materials contamination, the safest scenario is
when these individuals can move away from the source of contamination without needing
physical assistance.
• Any first responder considering rescue of a victim from hazardous material contamination
must determine whether the attempt is a rescue or a body recovery.
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References
1 U.S. Consumer Product Safety Commission. “Responding to Residential Carbon Monoxide Incidents—Guidelines for
Fire and Other Emergency Response Personnel,” November 2003.
3 Federal Emergency Management Agency, U.S. Fire Administration. Hazardous Materials Guide for First Responders, 1998.
4 Ibid., p.8.
5 Ibid.
6 Ibid.
8 Ibid., p. 225.
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16
UNDERSTANDING ATMOSPHERIC MONITORS
Many first responders are now using various types of portable atmospheric monitors to detect
and measure the presence of gases and vapors that could be hazardous to themselves and the public.
Some devices in this new arsenal can detect and measure one type of hazard, such as the concentration
of an explosive or toxic gas. There are also multigas monitors that can detect and simultaneously
measure three or four different hazardous atmospheres.
First responders who have recently had an opportunity to use one of these devices should ask
themselves the following questions:
• Was the device calibrated as required?
• If the device was intended to measure combustible gases, what type of gas was used
to perform the calibration?
• What was the vapor density of the gas or vapor being measured? Was this substance
heavier or lighter than air?
• What was the response time of the device? In other words, how long did it take to
see results?
• Was there a need to use a relative response curve or correction factor to determine
accurate readings for combustible gases? If so, where was this information located?
• Based upon the readings obtained, what actions were taken, and why?
Portable atmospheric monitors can provide first responders with valuable information. However,
the proper use of each instrument according to manufacturer instructions, along with full recognition
of the capabilities and limitations of each device, is vital to ensure the safety of personnel and
the public. Furthermore, atmospheric monitors generally do not offer users with suggested actions
to take when confronted with a dangerous environment. This might include whether or not to
evacuate, the type of personal protective equipment required, or whether or not a building is safe for
reentry following an incident.
Instead, the information made available from these devices is often nothing more than a
numerical value along with an audible signal. It is the responsibility of first responders to then
compare this value to a known standard as the basis for effective decision-making. The failure to properly
interpret the results provided by atmospheric monitors could prove disastrous.
First responders should consider the following before ever using one of these devices:
• Basic operations of atmospheric monitors
• Functional (bump) and full calibrations
• General use of atmospheric monitors
• Readings as a basis for decision making
• Multiple hazards during an incident
• Potential for inaccurate readings
• Interpreting “zero” readings
Basic Operation of Atmospheric Monitors

The operation for most types of atmospheric monitors used by first responders is usually dependent
upon electric currents produced or altered by exposing the device to various gases and vapors. The
monitor then interprets and displays a change in the electric current as a numerical value to indicate the
concentration of gases and vapors present.
The individual components of atmospheric monitors directly exposed to these gases and vapors are
normally referred to as sensors. Samples of the atmosphere are usually drawn into each sensor using a
small electric pump. First responders should remember that atmospheric monitors may not be capable of
detecting the presence of dusts or mists.
The concentration of toxic gases and vapors present is generally determined through use of an
electrochemical sensor. Each type of sensor is intended for a different type of gas or vapor. Most contain a
special chemical substance that, when combined with a specific material in the atmosphere, produces an
electrical current.
In order to determine the concentration of combustible gases and vapors, a sensor containing an electric
circuit with a heated filament is often used. By exposing a combustible gas or vapor to the filament, these
gases or vapors burn, and the heat produced by the combustion process alters the resistance in the circuit.
The heated filament is usually coated with a special type of catalyst that allows the mixture to burn below
its normal lower flammable limits. The concentration of gas or vapor is a function of the amount by
which the resistance changes.
Portable atmospheric monitors operate using either nonrechargeable or rechargeable batteries. First
responders should consider purchasing both options whenever available, since problems with rechargeable
batteries can often be quickly resolved by inserting a nonrechargeable battery pack. First responders should
always remember to install batteries in an area known to be safe from airborne hazards and to check the
battery charge level before making an entry with the monitor. Also, if they decide to use nonrechargeable
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batteries, they should have a fresh supply available to prevent the need for an emergency visit to the local
convenience store during the height of an incident.
Functional (Bump) and Full Calibrations

A functional calibration, often referred to as a bump test, is a process of exposing the sensors of an
atmospheric monitor to a known concentration of gas. This is done to ensure that the monitor works
properly and that the readings displayed are within an accepted tolerance as defined by the manufacturer
of the instrument. For example, a sensor intended to detect the presence of hydrogen sulfide may be
exposed to a calibration gas known to contain 25 ppm hydrogen sulfide. As a result, the numerical reading
displayed should either be identical or within allowable limits of difference. First responders should also
ensure that any calibration gas used is capable of triggering the instrument’s alarms to be certain that these
components function as intended.
There is generally no special equipment required for a bump test other than a device to direct the
calibration gas to the sensors. During a bump test, there is usually no means to adjust the atmospheric
monitor if the readings are unacceptable.
If readings obtained during a bump test do not meet the defined tolerances provided by the
manufacturer, a full calibration is usually necessary. Full calibration is similar to a bump test, except that
during a full calibration, there is normally a procedure to adjust the readings.
A number of factors determine the frequency of bump tests and calibrations. These include instructions
provided by the manufacturer of the device, specific policies and procedures of individual organizations
using these devices, and any regulations that may apply to specific tasks to be performed.
As a general rule, a bump test should be conducted before each use of the instrument. This should
require only a few minutes, and doing so provides those using the device with the peace of mind that
the instrument is operating properly. First responders never want to be in a position where they interpret
readings to be safe, only to learn later that the device was not working properly, if at all. They do not
want to discover problems with the instrument after devastating consequences, such as an explosion of a
flammable atmosphere that they had failed to detect.
A full calibration should be performed on a scheduled basis (such as every 30 days) or whenever the
instrument fails a bump test. The need for a full calibration is sometimes the result of a condition known
as calibration drift. This refers to a change in signal output of sensors resulting from use and normal
degradation of sensors over time. A full calibration should also be performed after any repairs are made,
including replacement of sensors.
Proper training of personnel who conduct any calibration activities is essential, as is having access
to the correct calibration equipment, which is usually available from the manufacturer. Thorough
documentation of test results is a must. It is also important that any calibration be conducted in an
environment similar to the one where the instrument will be used. Such considerations include altitude,
temperature, and humidity. Instruments should also be “zeroed” before calibration to provide for more
accurate results.
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The specific concentration of calibration gas used can vary depending upon the manufacturer
of the gas. If a different supplier of this gas is used, first responders should be sure to check the new
concentration and adjust the monitor accordingly. This is important because a monitor must recognize
the concentration of each calibration gas used in order to determine if the monitor either passes or fails
the calibration process.
First responders should remember that most calibration gas is sold with an expiration date. Any
attempts at calibration after that date may provide inaccurate results. It could also subject the first
responders’ organization to legal problems should the performance of the device be called into question.
If the gas cylinder does not display an expiration date, it will likely display a production date, and the
manufacturer of the calibration gas should then be able to advise first responders on how to calculate the
expiration date.
Finally, first responders should remember that only persons with proper training and equipment should
conduct any repairs to atmospheric monitors. While some repairs will require return of the monitor to a
factory-authorized site, in-house personnel should be able to perform routine maintenance, such as sensor
replacement. Therefore when purchasing atmospheric monitors, consideration should be given to the
average life expectancy of sensors. The degree of difficulty associated with sensor replacement, the cost
to replace these items, and their delivery time should also be considered. Instruments that sit on a shelf
waiting for repair or replacement parts serve no one.
For additional information on calibration, first responders may wish to consult a document from the
U.S. Occupational Safety and Health Administration entitled Verification of Calibration for Direct-Reading
Portable Gas Monitors. This document is available at http://www.osha.gov/dts/shib/shib050404.html.
General Use of Atmospheric Monitors

When using atmospheric monitors, personnel must first take steps necessary to protect themselves
from potential threats posed by hazardous atmospheres. First responders should keep in mind that standard
firefighter protective clothing may be inadequate for protection against some chemical atmospheres.
There may be additional hazards at the scene beyond just chemical exposure. These hazards include the
potential for structural collapse or becoming trapped while conducting air monitoring near an overturned
vehicle should the vehicle’s position shift. There may also be trip hazards that may not be obvious during
nighttime operations with limited visibility.
While SCBA may offer considerable protection against airborne hazards, first responders must
remember that air supplies are limited. They should not get so far inside of a building that they do not
have time to get out. Explosive atmospheres may require additional precautions, including hose lines for
protection of personnel, utility control, and proper ventilation techniques.
When attempting to detect and measure the presence of any gas or vapor, first responders must first
know which gases or vapors their atmospheric monitor can read. While a combustible gas indicator may
detect and measure the presence of many types of flammable materials, sensors intended to detect and
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measure a toxic material are capable of detecting only that material. Unfortunately, there are no “magic
meters” that detect and measure all types of hazardous atmospheres.
As such, a multigas atmospheric monitor (such as a four-gas monitor) can generally detect and
measure two types of toxic materials. These are usually carbon monoxide and hydrogen sulfide. The two
remaining sensors usually detect and measure oxygen content and the concentration of combustible gases
and vapors. The selection of the two toxic sensors for most multigas monitors is usually based upon the
requirements for confined space entry. In reality, few first responders will ever have the need to detect the
presence of hydrogen sulfide during a hazardous materials incident. However, it can be helpful to detect
the presence of flammable materials or carbon monoxide, as well as to determine oxygen content.
With the knowledge of what materials can be read by their instrument, first responders must then
know the vapor density of the material. Simply holding an atmospheric monitor at waist level may not
provide an accurate reading. This is because gases and vapors heavier than air tend to collect in low-
lying areas, while those lighter than air will rise into the atmosphere. First responders must remember
that heavier-than-air gases may also collect in physical depressions, such as storm drains or crawl spaces.
Lighter-than-air gas can enter concealed spaces such as drop ceilings or attics.
As discussed in chapter 7, vapor densities are usually expressed as a relative numerical value when
compared to air, with air assigned a value of 1. A gas or vapor with a density of less than 1 will rise, while
a gas or vapor with a density of greater than 1 will sink. The vapor densities for two of the most common
fuel gases used today, natural gas and propane, are often confused. Firefighters responding to incidents
involving a possible release of these products should remember that natural gas is lighter than air, with a
vapor density of about 0.55.1 Propane is heavier than air, at approximately 1.56.2 Gasoline vapors also are
heavier than air, and gasoline has a vapor density of approximately 3–4.3
When using an atmospheric monitor, first responders should consult the manufacturer’s instructions
to determine the response time of the device. Response time is the amount of time necessary to obtain a
reading, usually measured in seconds. Use of a monitor by suspending it momentarily over a suspected
spill site or by carrying it while walking briskly through an area may not allow the device the amount of
time necessary to provide accurate results.
Lastly, sensor damage can result from exposure to various types of atmospheres, including those that
contain corrosive vapors. Manufacturers of air monitors will generally describe types of environments to
avoid, as well as any filters that can lessen potential damage to sensors. These include filters to trap water.
Readings as a Basis for Decision Making

As stated earlier, the information made available from atmospheric monitors is often nothing more
than a numerical value, usually measured in ppm or percent of the LEL. It is the responsibility of first
responders to use this value as the basis of effective decision making by comparing it to a known standard.
However, it is important to know which standard to refer to and how to apply the results of atmospheric
monitoring to this standard. Regardless of the standard used, the alarm thresholds of the atmospheric
187
monitor should be set to these values. (An alarm threshold is the point at which the monitor will alert the
user to a dangerous condition through visual or audible means, or a combination of both.)
As an example, when dealing with combustible gases and vapors, concentrations that exceed 10%
of the LEL are defined as a “hazardous atmosphere” by OSHA Standard 29 CFR 1910.146, entitled
“Permit-Required Confined Spaces.” Therefore, at this concentration, the atmospheric monitor should
alert the user to the potential danger present.
This same standard also considers a hazardous atmosphere as one that has a “concentration of any
substance…which could result in employee exposure in excess of its dose or permissible exposure limit”
(italics added).4 These concentrations are available from various sources, such as an MSDS or technical
documents. One such resource is The NIOSH Pocket Guide to Chemical Hazards, published by the
National Institute for Occupational Safety and Health (NIOSH).5 It should be remembered, however,
that these values are intended for employees in a workplace setting. They may not be appropriate for the
average citizen.
Multiple Hazards during an Incident

When interpreting results from a multigas atmospheric monitor, first responders should remember
that the capability of the monitor is limited to the types of sensors installed. These are usually for explosive
atmospheres, oxygen content, and one or more types of toxic gases depending upon the selection made
by the user. However, other components of a toxic atmosphere may be present. Based upon the situation,
such as a structure fire or chemical spill, these may go unnoticed and thus provide first responders
with a false sense of security. Again, there is no single meter that can detect and measure all types of
hazardous atmospheres.
Another situation involves products that present both fire and inhalation hazards. For example, one
could consider an MSDS for regular unleaded gasoline that lists a permissible short-term exposure limit
(STEL or a 15-minute exposure) for gasoline vapors as 500 ppm. The LEL is given as 1.4%.6 Next,
consider an incident involving a spill of this product and a surrounding atmosphere that, according to the
first responder’s atmospheric monitor, contains 4% of the LEL for gasoline.
With a reading of 4% of the LEL, which is below the normal alarm threshold for 10% of LEL, the first
responder may believe the atmosphere to be relatively safe. In fact, it is safe only from the potential for fire
or explosion. With a reading of 4% of the LEL, the concentration of gasoline vapors in the atmosphere is
approximately 560 ppm, which is in excess of the permissible STEL exposure limit. Therefore, while the
monitor may not provide any warnings for the presence of an explosive concentration of gasoline vapors,
personnel working in that atmosphere still face a potential inhalation hazard.
Finally, first responders should remember that if the oxygen content in a room is below normal
concentrations, something else must be present in the atmosphere. That other vapor or gas could
be dangerous!
188
Potential for Inaccurate Readings

There are some easily overlooked aspects to using an atmospheric monitor to determine the
concentration of combustible gases and vapors. One of these is a failure to recognize that readings
provided by the monitor are accurate only when attempting to detect and measure the same combustible
gas or vapor as used during calibration procedures. The sensitivity of combustible gas sensors varies with
exposure to different types of atmospheres. Thus any attempt to measure the concentration of gases
other than that used during calibration will result in a reading that is likely greater or less than the actual
concentration. Remedying this situation will require the use of a correction factor or relative response
curve specific to the gas or vapor measured in order to obtain more accurate results.
To better understand this, one could consider an analogy to time zones, where a clock set to Eastern
Standard Time in New York is accurate only in that time zone. In order to use the same clock in California,
an adjustment would be necessary by subtracting three hours from the time displayed.
Some atmospheric monitors are capable of performing these adjustments internally based upon the
appropriate relative response or correction factor. However, there may be a need with other monitors
for the user to compare the displayed reading to a chart or graph, which is normally provided by the
manufacturer. The user then manually calculates the actual reading.
For example, if a combustible gas indicator of an atmospheric monitor is calibrated with methane,
readings when the instrument is used to detect methane will be the same as those displayed. However, if
this same instrument is used to detect the presence of gasoline vapors or propane gas, use of a correction
factor becomes necessary.
The correction factors provided by instrument manufacturers are usually numbers by which readings
must be multiplied or divided. Using the example above, if the correction factor for propane is 1.5, all
readings obtained with the atmospheric monitor when measuring propane must then be multiplied by
1.5. Therefore, a reading of 1% LEL is actually 1.5% of the LEL, while a reading of 6% LEL is actually
9% of the LEL, determined by multiplying 6% x 1.5.
There is an issue of critical importance in this example. Perhaps the instrument reads anywhere
from 7% to 9% of the LEL, but the alarm threshold for combustible gases is set at 10% of the LEL
(in accordance with 29 OSHA 1910.146). In this case, first responders may already be operating in an
environment above 10% of the LEL. However, because the alarm activates based only upon displayed
readings, the first responders will likely not receive any warning until the actual concentrations are far
beyond hazardous levels.
Table 16–1 provides a summary of this phenomenon. When using a correction factor of 1.5 for
propane, first responders could be operating in an environment that contains an actual concentration of
12% LEL. However, the alarm does not sound, because the displayed reading is only 8% LEL, and the
alarm threshold is set at a reading of 10% LEL. When the alarm finally does alert users to a hazardous
189
atmosphere with a displayed reading of 10% of the LEL, the atmosphere will already contain 15% LEL,
which is above dangerous levels.
Table 16-1 Influence of Correction Factors on Alarm Activations
Consider the following atmospheric monitor:
• Calibrated to methane
• Alarm set point of 10% LEL concentration for methane
If this instrument is used to measure the concentration of propane, all readings must be adjusted
using a correction factor of 1.5 in order to obtain an accurate reading. However, consider the following
example as it relates to the use of this correction factor on the ability of the instrument to alert users
to a hazardous atmosphere through activation of the alarm.
METHANE PROPANE
2% LEL reading 3% LEL concentration

A. =
(Safe) (Safe)
8% LEL reading 12% LEL concentration

B. =
(NO Alarm) (NO Alarm, yet a hazardous atmosphere exists) (*)
10% LEL reading 15% LEL concentration (hazardous atmosphere)

C. =
(ALARM) (ALARM)
NOTES:
A. With a reading of 2% LEL, the concentration of propane is 3% LEL (still safe)
With a reading of 8% LEL, the alarm does not activate, even though the actual concentration of
B.
propane gas is 12% LEL, which is a hazardous atmosphere (*)
When the instrument reading reaches 10% LEL, the audible alarm will sound, yet the actual
C.
concentration of propane gas is already at 15% LEL
(*) According to 29 CFR 1910.146
When using instruments that require the user to manually calculate the correction factor, first
responders must remember not to rely solely on the instrument alarms to warn of the presence of a
hazardous atmosphere. Instead they must continuously read the instrument display, calculate the actual
concentration, and know when these concentrations reach hazardous levels.
Charts can be prepared in advance to allow quick and accurate conversion of readings based upon
correction factors. These can be helpful when first responders know that they will likely be required to
measure certain gases and vapors other than that for which the instrument is calibrated. For example, they
may have an atmospheric monitor calibrated with methane. However, since they could also respond to
incidents involving propane, they may want to know in advance the results of any adjustments to readings
that would be obtained with the instrument. Table 16–2 provides examples of a chart that contains actual
readings based upon instrument readings that have been adjusted using a correction factor of 1.5.
190
Table 16–2 Actual Reading from Instrument Reading (Correction Factor = 1.5)
% LEL % LEL % LEL % LEL % LEL % LEL

READING ACTUAL READING ACTUAL READING ACTUAL
1 1.5 11 16.5 21 31.5
2 3 12 18 22 33
3 4.5 13 19.5 23 34.5
4 6 14 21 24 36
5 7.5 15 22.5 25 37.5
6 9 16 24 26 39
7 10.5 17 25.5 27 40.5
8 12 18 27 28 42
9 13.5 19 28.5 29 43.5
10 15 20 30 30 45
First responders should also be aware that inaccurate readings can be influenced by oxygen content.
An oxygen content of below 19.5% is in itself a hazardous atmosphere as defined by 29 CFR 1910.146,
with the potential for asphyxiation. Yet another cause for concern is that low oxygen levels can interfere
with the performance of combustible gas sensors. Likewise, oxygen concentrations in excess of 23.5%
are also defined as a hazardous atmosphere in the same standard. These concentrations present a greater
potential for fire or explosion, along with the potential for inaccurate readings when using a combustible
gas sensor.
When using atmospheric monitors to detect and measure the presence of toxic atmospheres, there
is also the potential for cross-sensitivity. This occurs when some gases and vapors other than those first
responders are attempting to read interfere with the operation of electrochemical sensors. This can result in
false positive readings or an otherwise inaccurate response. Most manufacturers can provide some indication
of potential problems from cross-sensitivity and the types of atmospheres in which this will occur.
191
Interpreting “Zero” Readings

When interpreting a reading of “zero” from any sensor, first responders should remember that this
reading does not necessarily mean that there is no hazardous gas or vapor present in the atmosphere.
Instead, it may simply mean that the gas or vapor is present but at a concentration below the capability,
or the detectable limits, of the monitor.
First responders had been issued For example, if the lowest reading capable with
an atmospheric monitor is 1 ppm, a concentration
their first atmospheric monitor. After of 0.4 ppm could then be displayed as 0 ppm. In this
initial training and a review of the situation, there is a hazardous atmosphere present,
yet the reading is below the detectable limits of the
manufacturer’s instruction manual, it monitor. Therefore, interpreting 0 ppm as a “zero”
became obvious that skills retention reading, would mean that there is no material present,
which is incorrect. In contrast, stating that 0 ppm is
would be difficult due to the unique “below detectable limits” provides for a more accurate
characteristics of the device and the and defensible interpretation. Recording a reading
of 0 ppm or 0% LEL as “below detectable limits”
lack of frequency regarding its use. states that there may be some of the material present,
First responders decided to prepare but the instrument is not sensitive enough to
quick reference cards containing detect it.
key operating characteristics of As stated earlier, a “zero” reading may also mean
that other gases are present, some of which are not
the monitor, including the types detectable with the atmospheric monitor in use. It
of sensors installed, startup could also mean that there are substances present
that can interfere with the ability of the monitor to
procedures, response times, provide for accurate readings.
and alarm thresholds. They also Finally, when obtaining a “zero” reading, first
laminated a chart provided by responders should always resist the urge to state,
“There was no reading.” Remember that from a legal
the manufacturer that included perspective, the statement, “There was no reading”
correction factors along with a chart could be interpreted as meaning that the monitor
they had developed themselves that was not operating properly, if at all.
included actual corrected readings

based upon instrument readings.
These charts along with the quick
reference cards were stored in the
carrying case, thereby allowing
ready access when needed.
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Key Points
• Atmospheric monitors usually provide nothing more than a numerical value, and it is the
responsibility of first responders to then compare this value to a known standard.
• The concentration of toxic gases and vapors present is generally determined through use of
an electrochemical sensor.
• In order to determine the concentration of combustible gases and vapors, a sensor
containing an electric circuit with a heated filament is often used.
• A bump test of an atmospheric monitor is a process of exposing sensors to a known
concentration of gas to ensure that the monitor works.
• A bump test should be conducted before each use of the instrument.
• Full calibration is similar to a bump test, except during a full calibration, there is normally
a means to adjust the readings. A full calibration should be performed on a regular basis.
• Response time is the time necessary to obtain a reading, usually measured in seconds.
• If the oxygen content in a room is below normal concentrations, something else must be
present in the atmosphere, and it could be dangerous!
• When faced with a reading of “zero,” first responders should resist the urge to state, “There
was no reading.”
• When using an atmospheric monitor to determine the concentration of combustible gases
and vapors, readings are accurate only when attempting to measure the same gas as used
during calibration procedures. Otherwise, use of a correction factor is necessary.
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Chapter Questions
1. Describe the operation of an electrochemical sensor.
2. Describe the operation of a sensor designed to detect combustible gases and vapors.
3. Describe the difference between a bump test and full calibration.
4. Why is it important to know the expiration date of calibration gas?
5. Why is it important to know the vapor density of gases and vapors when using atmospheric
monitors?
6. Why is it important to know the response time of an instrument? Where can first responders
find this information?
7. Describe what is meant by the term alarm threshold.
8. Describe the use of a correction factor.
9. Explain how the alarm of an atmospheric monitor can operate too early or too late if
first responders are required to manually calculate the instrument’s reading using a
correction factor.
10. How should first responders interpret a reading of “zero”?
194
References
1 Praxair Technology, Inc. Material safety data sheet for natural gas, May 1999.
2 BOC Gases. Material safety data sheet for propane, April 5, 2001.
3 Chevron. Material safety data sheet for regular unleaded gasoline, December 31, 2002.
4 Code of Federal Regulations. 29 CFR § 1910.146(b), http://www.osha.gov.
5 National Institute for Occupational Safety and Health. The NIOSH Pocket Guide to Chemical Hazards, 2005, http://www.
cdc.gov/niosh/npg/pgintrod.html.
6 Chevron. Material safety data sheet for regular unleaded gasoline, December 31, 2002.
195
17
UNDERSTANDING CLASS B FOAM
Fire suppression foam is sometimes a mystery to first responders. Most probably know that
foam is carried on fire apparatus and that it can be used to extinguish fires involving flammable
liquids. However, knowledge about dilution ratios, application rates, and application techniques
essential to ensure the safe and effective use of foam may be harder to come by.
When dealing with hazardous materials, it is important to remember that in addition to foam that
can be used on flammable liquids, or Class B fires, there are also specialty foams. These can be used
to suppress vapors from spills of certain chemicals, such as corrosive liquids. These types of foam are
normally used only by members of hazardous materials teams who have the training to apply them
safely and effectively. In addition, many fire departments are now using foam designed for fighting
fires in ordinary combustible materials, or Class A fires, such as brush fires and structure fires.
What Is Class B Foam?

Class B foam is a material that allows water to be used on fires that would otherwise not respond
well to water application. Firefighters have likely witnessed the disastrous results and subsequent
structure fire when a homeowner attempted to use water to extinguish a burning pan of hot oil on
a stovetop.
To use foam, a foam concentrate is first mixed with water to create a foam solution. This solution
is then mixed with air or aspirated to produce a lightweight foam with air bubbles. These bubbles
allow the foam to form a blanket on the surface of flammable liquids.
First responders should always remember that flammable liquids themselves do not burn,
but rather the vapors produced on the surface of the liquid burn once the liquid reaches its flash
point. With a material such as gasoline, which has a flash point of approximately –45ºF, vapors are
produced almost any time this material is handled. All that is usually needed for a fire to occur once
gasoline is released from its container is an ignition source.
First responders must also remember that heat that can generate vapor production may originate
not only from the temperature of the ambient (outside) air, but also from hot surfaces. For example,
diesel fuel has a relatively high flash point, usually above 100ºF. As such, some first responders may not
consider the possibility of vapor production from a spill of diesel fuel that occurs outdoors on a cold day.
Yet diesel fuel may contact a hot surface, such as a component of a vehicle exhaust system on a
commercial truck following a rollover accident. Then there could be sufficient heat from this surface to
raise the temperature of the fuel to its flash point, despite the cold air surrounding the spill site.
Class B foam works on the surface of a burning flammable liquid in several ways:
• It can smother a fire by eliminating the oxygen supply.
• It can separate flames from the fuel surface.
• It can cover the surface of the fuel to suppress vapor production.
• It can cool surrounding surfaces to decrease vapor production.
An advantage of using foam as opposed to dry chemical extinguishers is that once a fire is burning,
the temperature of surrounding surfaces increases. If extinguished using dry chemical extinguishers, there
may still be sufficient retained heat nearby to keep the temperature of the liquid fuel above its flash point.
This heat also can cause fuel vapors to re-ignite without an outside ignition source. First responders should
remember that foam will suppress vapor production from flammable liquids spills that have yet to ignite.
Polar Versus Nonpolar Solvents

There are two major categories of flammable liquids. These are liquids that will not mix with water,
such as hydrocarbon fuels including gasoline and diesel fuel, and those that will mix with water, such as
alcohol. Flammable liquids that will not mix with water are referred to as nonpolar solvents, while liquids
that will mix with water are referred to as polar solvents.
The problem for first responders is that using certain types of foam on polar solvents will allow this
material to mix with the water that is used to produce the foam. This can result in destruction of the foam
blanket. Applying the wrong foam to a flammable liquid fire may look impressive, but it may be nothing
more than a waste of an expensive resource.
A first responder should therefore make an effort to determine the correct type of foam needed. For
example, the ERG2004 refers to foam for polar solvents as “alcohol resistant” foam and foam for nonpolar
solvents (such as hydrocarbon fuels) as “regular foam.” This same information may also be available from
an MSDS or a representative from the company that manufactures, transports, or ships the flammable
liquid involved in an incident.
198
Types of Class B Foam

While Class B foam may be referred to as either regular or alcohol resistant, there are additional
variations when dealing with foam. These include protein and fluoroprotein foams, as well as aqueous
film–forming foam, also known as AFFF. Each product has its own unique characteristics.
Protein and fluoroprotein foams consist of “products from a protein hydrolysate.”1 They produce
relatively thick foam blankets, while AFFF products often produce a thinner, more fluid blanket. This
characteristic of AFFF usually allows for a quick knockdown of a fire as the foam spreads more rapidly
across the burning fuel surface. Yet this same feature may render it not as effective in preventing re-
ignition as the thicker protein and fluoroprotein foams.
First responders should be aware that foam for suppression of flammable liquid spill fires is usually
referred to as low expansion foam. Low expansion foam is expanded with less than a foam-solution volume
ratio of 20:1 after being mixed with air.2 However, there are also products available known as medium
and high expansion foam, with expansion ratios that range from 20:1 to approximately 1,000:1.3 This
latter type of foam is designed to expand rapidly and can be used to fill burning void spaces in buildings
to smother and cool Class A fires. High expansion foam is generally not intended for use outdoors on
flammable liquid spill fires. First responders should always check with the manufacturer or supplier of any
foam concentrate used by their department to learn information relative to specific expansion ratios and
appropriate applications.
In addition to being referred to as protein, fluoroprotein, or AFFF, Class B foam concentrates are also
classified on the basis of the percentages for which they are to be diluted or proportioned with water. These
percentages are generally 1%, 3%, and 6%, and they indicate the ratio of foam concentrate to water.
For example, 3% foam means that every 100 gal of foam solution will require 3 gal of foam concentrate
diluted with 97 gal of water. Using the ratio of 3%, 15 gal of foam concentrate diluted with 485 gal of
water will produce 500 gal of foam solution. A foam concentrate with a dilution ratio of 1% means that
1 gal of concentrate is diluted with 99 gal of water. Using this lower ratio, only 5 gal of foam concentrate
would be diluted with 495 gal of water in order to produce 500 gal of foam solution.
199
Lower dilution ratios require less foam concentrate to produce equal amounts of foam solution.
Table 17–1 provides examples of requirements for water and foam concentrate with dilution ratios of 1%
and 3%.
Table 17–1 Requirements for Water and Foam Concentrate for Dilution Ratios of 1% and 3%
At a dilution ratio of 3%
3 gal of foam concentrate diluted with 97 gal of water will produce 100 gal of foam solution
At a dilution ratio of 1%
First responders must remember that the dilution ratio for any foam concentrate used is determined
by the manufacturer of the foam concentrate. Some AFFF products are referred to by their manufacturer
as 3%/6%, meaning that the foam can be used at either dilution ratio, depending upon the type of
application. For example, a manufacturer of foam concentrate may recommend a dilution ratio of 3%
for fires involving nonpolar solvents, such as gasoline or diesel fuel. The manufacturer may recommend a
higher dilution ratio of 6% for fires involving polar solvents, such as alcohol.
First responders should also be aware that at higher ratios, the consumption of foam concentrate is
increased. Their decision to use foam at higher concentrations than that recommended by the manufacturer
may not reduce the time required for extinguishing a fire.
Foam concentrate can be stored using a built-in tank when foam producing equipment is specified
with apparatus, or in portable plastic containers, usually of 5-gal capacity. Foam concentrate may also be
brought to an incident scene in any number of configurations, from 5-gal containers to 55-gal drums.
Large plastic or metal containers containing several hundred gallons of concentrate can also be used.
However, first responders should not forget that larger containers also require some means to move them
once they arrive at an incident scene. When purchasing foam concentrate, it is important to check with
the manufacturer in order to determine storage requirements, including references to storage temperature
and shelf life.
200
Producing Class B Foam Solutions

As stated earlier, foam solutions are produced by diluting a concentrate with water and then aerating
it, or mixing that solution with air. Equipment used to produce foam solutions can be built into fire
apparatus along with the storage tank mentioned earlier. This equipment also can include various handheld
appliances that require assembly when needed.
The handheld appliance most critical to production of foam is typically referred to as an inline eductor.
This device includes both female and male thread connections, a siphon tube, and a metering valve that
allows for variable dilution ratios, usually in the range of 1%, 3%, or 6%. The siphon tube is designed to
be inserted into a container of foam concentrate and moved rapidly in succession to fresh containers as
each is emptied of its contents.
The discharge or male thread of an inline eductor is normally 1½ in. in diameter, while the intake or
female coupling may be 2½ in. or 1½ in. in diameter, depending upon the requirements of the user. The
female coupling of the inline eductor is usually attached to a discharge outlet on fire apparatus, and a hose
line is then attached to the male coupling.
There are two important points for first responders to remember when selecting the discharge outlet
to which the inline eductor will be attached. The first is to ensure that the siphon tube from the eductor
will reach to the bottom of foam concentrate containers used (usually these containers are placed on the
ground). The second is that someone must be available to switch the siphon tube as each container of
foam concentrate is emptied. This switch needs to be quick, and since extra personnel on the fire ground
are rare, this task is normally assigned to a pump operator.
If this is the case, the discharge outlet selected to attach the inline eductor is probably best located
in proximity to the pump control panel. First responders should remember that apparatus with top-
mounted pump panels may require two people to perform foam operations successfully. The alternative
is that the pump operator has to abandon the pump panel in order to stand on the ground and switch
201
the siphon tube of the inline eductor. Figure 17–1 First responders should also remember that
shows an example of an inline eductor connected whenever attempting to remove the lid from a 5-gal
to a discharge outlet at a pump panel. container of foam concentrate, it is always helpful
to have available a wrench specifically designed
for this purpose. Using this type of wrench can
prevent delays when first responders encounter a
stubborn lid during the heat of battle. Any delay
in switching the siphon tube to a fresh container
of foam concentrate can result in a decreased
concentration of foam solution at the nozzle.
Two characteristics of inline eductors are
often overlooked by first responders. Most of
these appliances have a required minimum inlet
pressure, as well as a maximum length of hose
that can be used. The decision for maximum hose
length takes into consideration friction loss, so
this length will change based upon the diameter
of the hose used. The maximum length for a 1¾-
in. diameter hose is thus generally longer than
that of a 1½-in. diameter hose. For some inline
eductors, this maximum length may range from
500 to 700 ft when using 1¾-in. diameter hose.
The manufacturer of this appliance will provide
first responders with the necessary inlet pressures
and maximum hose lengths to be used.
Another appliance important to the production
of foam is the nozzle. The nozzle not only provides
for an effective pattern but is also responsible for
mixing the foam solution with air to produce the
desired expansion. Depending upon the type of
foam concentrate, use of a standard fog nozzle
may work, while other types of concentrates may
require use of a special foam nozzle.
The gallon-per-minute flow rate of the nozzle
may need to match the flow rate of the inline
eductor used. Therefore, when selecting foam
producing equipment, whether foam concentrate,
inline eductors, or nozzles, one suggestion is to
first check with the manufacturers of these items
to ensure their compatibility. This should be done
before any equipment is purchased. Incompatible
Fig. 17-1 In-Line Eductor Connected to a Pump Panel foam equipment may not produce desired results.
Courtesy of E. Wayne Lawhorn
202
Table 17–2 provides a summary of important characteristics for foam producing appliances. Figure
17–2 provides a summary of how Class B foam is produced.
Table 17–2 Characteristics of In-Line Eductors and Nozzles
GPM flow rating (may need to match nozzle)

Metering valve adjustments available (for dilution of concentrate)
In-Line Eductor
Required inlet pressure
Maximum hose length (depending upon diameter of hose used)
GPM flow rating (may need to match in-line eductor)

Nozzle
Ability to aerate and expand foam solution as required
WATER FOAM SOLUTION EXPANDED FOAM

THROUGH HOSE SOLUTION
EDUCTOR NOZZLE
APPLIED TO SPILL
FOAM AIR EXPANDS

CONCENTRATE FOAM
SOLUTION
Fig. 17-2 How Class B Foam is Produced
Once the correct inline eductor and foam nozzle are on the apparatus, the unfortunate reality is
that these items may become buried in the back of a compartment rather than hooked up and ready for
action. And while hooking up an inline eductor to a pump panel is relatively easy, the hard part for most
first responders is attaching the attack line to the inline eductor.
Problems occur here because most 1¾-in. and 1½-in. diameter hoses used for foam applications are
usually preconnected attack lines. They must first be disconnected from their discharge outlet and then
connected to the inline eductor. Most preconnected lines are approximately 150 ft to 200 ft in length.
If access to the preconnected discharge outlet on apparatus is difficult to reach, first responders may be
forced to break the attack line at the first coupling out of the hose bed. This would result in no more than
100 ft to 150 ft of usable hose for the foam attack line.
If the inline eductor used can accommodate several hundred feet of 1¾-in. hose, it becomes obvious
that additional hose from other preconnected lines will be required. Once all of the necessary hose is
broken down from individual preconnected lines, first responders must then make numerous connections
in order to assemble the attack line. This process is labor intensive. However, taking a shortcut and using
less hose than the maximum allowed by the manufacturer also places less distance between the apparatus
and the fire.
203
Built-in foam systems on apparatus offer numerous advantages. These include eliminating the need
to assemble foam producing appliances and the fact that the foam concentrate is readily available by
simply operating switches on the pump panel. However, as with anything else on fire apparatus, first
responders should refer to the manufacturer’s instructions to ensure that all foam producing equipment
is compatible.
First responders should also remember that all hose and appliances must be thoroughly flushed after
each use. This is especially important with built-in foam systems. Of course, this is a task that some first
responders prefer to leave for the next shift.
Determining the Amount of Foam Needed

Determining the amount of foam needed is a function of minimum application rates for foam
solutions and the dilution rate for foam concentrates. As stated earlier, the dilution rate determines the
amount of foam concentrate that is diluted with every gallon of water to produce a foam solution.
The minimum application rate determines the rate at which this foam solution is applied to the surface
of the flammable liquid, usually measured in gallons per minute per square foot of spill surface. Minimum
application rates provide first responders with information regarding how much foam concentrate and
water is needed to control and extinguish a fire. It also tells them the minimum nozzle flow rate required
when applying the foam solution.
Rates discussed here apply only to spill fires involving flammable liquids. A spill fire is defined as a
spill that is not contained in a dike with an average depth that does not exceed 1 in., and that is bound
only by the contour of the surface on which it is lying.4 Minimum application rates for other types of
flammable liquid fires, including those involving fixed fuel storage tanks and dikes, should be determined
through preplanning at these sites.
The dilution ratio of foam is determined by the manufacturer of the foam concentrate used. Minimum
application rates are available from the NFPA Standard 11, entitled “Low, Medium, and High-Expansion
Foam.” These application rates are dependent upon the type of foam concentrate used. For example,
when using AFFF products for nondiked spill fires, the recommended minimum application rate is 0.1
gal per minute (gpm) per square foot (ft2) of spill surface.5 Other types of foam concentrates, such as
protein and fluoroprotein foams, require higher minimum application rates of 0.16 gpm/ ft2 of spill
surface.6 NFPA 11 recommends that first responders using some types of alcohol-resistant foams check
with the manufacturer of these concentrates in order to determine correct application rates.7
Armed with the knowledge of minimum application rates, how much foam concentrate and
water would first responders need for certain size of spill fire? Furthermore, what would be the largest
spill fire that first responders could likely extinguish with the foam concentrate and water carried on
their apparatus?
For example, as stated earlier, use of AFFF concentrate requires a minimum application rate of 0.1
gpm/ft2 of spill surface. Therefore, a 600-ft2 spill fire would require the application of 60 gal of foam
204
solution (600 multiplied at 0.1) for every minute of application. But how many minutes of application
are required?
According to NFPA 11, first responders attempting to extinguish a spill fire should be prepared for a
minimum discharge time of 15 minutes.8 Therefore, this same scenario would now require a minimum
application rate of 60 gpm for 15 minutes, or a total application of 900 gal of foam solution. First
responders could easily meet the minimum recommended application requirements from NFPA 11 using
apparatus with a 1,000-gal water tank.
Since foam solution is a product of water and foam concentrate, the question then becomes, “How
much concentrate is needed?” That answer depends upon the dilution ratio of the concentrate used.
When using 3% foam concentrate, every 100 gal of foam solution will require 3 gal of foam concentrate
diluted with 97 gal of water. The previously mentioned scenario requires 900 gal of foam solution for 15
minutes of application. With this scenario, first responders would need 873 gal of water (97 x 9, or 97 gal
of water for every 100 gal of foam solution) and 27 gal of foam concentrate (3 x 9, or 3 gal of concentrate
for every 100 gal of foam solution). Table 17–3 provides details of calculations to determine minimum
amounts of water and foam concentrate needed to extinguish a 600-ft2 spill fire.
Table 17-3 Requirements for Foam Concentrate and Water Needed to Extinguish a 600 Square Foot Spill Fire
1. .1 gpm / sq ft x 600 sq ft = 60 gpm of foam solution (application rate)
2. 60 gpm x 15 min (*) = 900 gal of foam solution (total amount of foam solution)
3. 900 gal of foam solution x .03 (3% concentrate) = 27 gal of foam concentrate
4. 900 gal of foam solution x .97 (97% water) = 873 gal of water
(*) Minimum discharge time required by NFPA 11 (2005 edition)
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Preplanning Foam Fire Suppression Capabilities

It is beneficial to calculate the requirements for fire fighting foam upon arrival at an incident. However,
first responders should also be capable of preplanning the maximum fire suppression capability of their
apparatus and the foam equipment before an incident occurs. Development of this preplan is based on
the premise that most fire apparatus normally carry only a few containers of foam concentrate along with
500 to 1,000 gal of water. Therefore, each fire apparatus essentially operates as a self-contained unit with a
defined limit to its capabilities for foam application. This is true unless the decision is reached to combine
resources from different apparatus.
The critical point is to know whether or not to initiate a quick attack with available foam resources
in hopes of being able to extinguish a spill fire involving flammable liquids. In some cases, it might be
better to wait until help arrives with additional resources. Any attempt by first responders to extinguish a
flammable liquid spill fire could exceed their capabilities (either in terms of water, foam concentrate, or
application rate). This could result in them being unable to gain control of the fire.
Once their limited foam supplies are exhausted, the fire may regain its intensity. If each apparatus that
arrives in succession with similar capabilities attempts the same, first responders may never extinguish the
fire. However, perhaps personnel on the first apparatus to arrive on scene determine that the fire is beyond
their capabilities. They may decide to wait for additional supplies (foam concentrate and water) to arrive
on other apparatus while working to protect exposures. They can then launch a successful attack by
combining their foam supplies to make one uninterrupted attack with the required minimum application
rate for the required minimum discharge time.
Knowing when to delay fire attack is the key to foam preplanning. Armed with this information, first
responders will be able to estimate the maximum size spill fire that could likely be extinguished. This will
be based upon the type of foam concentrate used, the amount of foam concentrate carried, the amount of
water immediately available from a water tank, and the flow rate of the foam nozzle.
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In order to preplan foam fire fighting capabilities, first responders will need the following
information:
1. Foam concentrate dilution ratio (based upon manufacturer’s recommendation)
2. Minimum application rate (from NFPA 11, based upon type of foam used)
3. Capacity of the apparatus water tank
4. Amount of foam concentrate carried on the apparatus
As an example, using foam concentrate with a 3% dilution ratio and an apparatus with a 500-gal
water tank, 15 gal of foam concentrate would be required to produce 500 gal of foam solution. Table
17–4 provides the requirements for water using a 3% foam concentrate.
Table 17–4 Requirements for Water and Foam Concentrate using a Dilution Ratio of 3%
If 3 gal of foam concentrate diluted with 97 gal of water will produce 100 gal of
foam solution then,
15 gal of foam concentrate diluted with 485 gal of water will produce 500 gal of
foam solution.
All foam solutions must provide for a minimum discharge time of 15 minutes. Dividing this 500 gal
of foam solution by 15 minutes yields a minimum flow rate of 33 gpm at the nozzle. If the minimum
application rate of the foam solution to the surface of the spill fire is 0.1 gpm/ft2, then 33 gpm will cover
330 ft2 (33 divided by 0.1). This represents an area approximately 20 ft in diameter, or about the size of
an average two-car garage.
First responders may instead be faced with a spill fire larger than 330 ft2 and with immediate access
to no more than 500 gal of water and 15 gal of 3% foam concentrate. They may then consider protecting
exposures while waiting for additional resources to extinguish the spill fire.
First responders should remember that the minimum flow rate from this example of approximately
33 gpm will deliver the required minimum application rate of 0.1 gpm/ft2. Most nozzles carried on
fire apparatus will have higher flow rates. Increasing the foam application rate above the minimum
recommended by NFPA 11 will not allow first responders to extinguish a larger fire, but it can reduce the
time required to achieve control and extinguish the fire.
But first responders must remember not to confuse application rate with dilution ratio. Increasing the
application rate (by using a larger nozzle) can reduce the time to control and extinguish a fire. However,
increasing the dilution ratio (adding more concentrate to less water) will usually not decrease this time
but rather will waste foam concentrate.
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Tables 17–5 through 17–10 provide details of preplan calculations using foam concentrates with
dilution ratios of 1%, 3%, and 6%, and apparatus water tanks of 500- and 1,000-gal capacities.
Table 17–5 Foam Pre-Plan Calculations for AFFF
Concentrate Dilution Rate 1%
Capacity of Water Tank 500 gal
Minimum Amount of Foam Concentrate 5 gal [one 5-gal container]
Minimum Application Rate .1 gpm / sq ft
Minimum Application Time 15 min
Maximum Square Feet of Surface Area 333 sq ft
Capacity of Water Tank 1,000 gal
Minimum Amount of Foam Concentrate 10 gal [two 5-gal containers]
Minimum Amount of Foam Concentrate 15 gal [three 5-gal containers]
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Minimum Amount of Foam Concentrate 30 gal [six 5-gal containers]
Minimum Amount of Foam Concentrate 30 gal [six 5-gal containers]
Minimum Amount of Foam Concentrate 60 gal [twelve 5-gal containers]
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Applying Class B Foam

Most first responders attempting to extinguish a flammable liquid spill fire with a hose line will
achieve satisfactory results by aiming the nozzle to just in front of the leading edge of the fire. They will
then attempt to “roll” or “push” the foam onto the surface of the fire from that point. Foam may also be
sprayed lightly overhead of the fire and allowed to drift down onto the fuel surface.
A passenger vehicle had just The stream from a foam nozzle should never be
directed into burning fuel. First responders should
entered an interstate highway rest also be prepared to direct the nozzle away from the
area when its occupants discovered spill fire in the event that they no longer see foam
a fast moving leak from the vehicle’s being discharged from the nozzle, but rather only
water. This situation can sometimes occur if there is
gasoline tank. The vehicle was a delay in switching containers of foam concentrate
parked near a storm drain and at an in-line eductor.
several gallons of spilled material Once a fire is extinguished, the integrity of
had entered the drain prior to the the blanket must be maintained, since it may
break down over time as water drains from the
arrival of first responders. Managers foam solution. This breakdown may also occur
of the rest area who were contacted whenever a foam blanket is applied to a fuel spill
were unsure of the exact path of in an effort to suppress flammable vapors and thus
prevent ignition. Maintenance of a foam blanket
the drains, and so first responders, will likely require additional foam concentrate
concerned about a possible and water at the scene for an extended period
of time.
explosion hazard, discharged several
hundred gallons of a Class B foam To ensure the effectiveness of any foam blanket,
it is vital that first responders refrain from walking
solution into the drain. Besides through or otherwise disturbing a foam blanket once
minimizing the explosion hazard, it is in place. Atmospheric monitors should be used
the foam traveled through the storm to detect the presence of flammable vapors that will
likely indicate the need to reapply foam.
drain system to an outfall pipe
When dealing with a flammable liquid spill,
located nearby. Once the resulting despite the presence of what appears to be an effective
foam blanket was detected at the foam blanket along with acceptable readings from
outfall pipe, efforts were made by atmospheric monitors, the elimination of ignition
sources is a necessity. This includes preventing the
first responders to contain the foam use of road flares and being vigilant regarding efforts
solution at that point. A clean up to prevent the use of lit tobacco products by those
contractor responded to remove the operating at the scene.
spilled gasoline and foam solution
with a vacuum truck.
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Key Points
• Foam concentrates are mixed with water to create a foam solution, and the solution is then
aspirated or mixed with air.
• Class B foam works on the surface of a burning liquid. It extinguishes a fire by smothering
the fire, separating flames from the fuel surface, covering the surface to suppress vapor
production, and cooling surrounding surfaces.
• Flammable liquids that will not mix with water are referred to as nonpolar solvents, while
liquids that will mix with water are referred to as polar solvents.
• Class B foam may be referred to as either regular or alcohol resistant.
• Classifications of Class B foam concentrates include the percentages for which they are to
be proportioned or diluted with water.
• Most inline eductors have both a required minimum inlet pressure as well as a maximum
length of hose that can be used.
• The minimum application rate determines the rate at which a foam solution is applied to
the surface of the flammable liquid, usually in gallons per minute per square foot.
• Any attempt by first responders to extinguish a fire that exceeds their capabilities may
result in them being unable to gain control of the fire.
• Increasing the foam dilution ratio will only increase the consumption rate of the
concentrate, while not decreasing the amount of time required to extinguish a spill fire.
• The stream from a foam nozzle should never be directed into burning fuel.
• Atmospheric monitors should be used to determine the effectiveness of foam blankets.
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Chapter Questions
1. Identify the four ways that foam works on the surface of a burning liquid to extinguish a fire.
2. What is the difference between a polar and nonpolar solvent?
3. Explain the difference between foam concentrate and foam solution.
4. What are two often overlooked characteristics of in-line foam eductors?
5. Should the flow rate of an in-line eductor match that of the nozzle used?
6. What is the difference between an application rate and dilution ratio?
7. Why should first responders preplan the maximum capabilities of their apparatus and
foam equipment carried on board before an incident occurs?
8. What information is needed to preplan fire fighting foam capabilities?
9. Calculate the potential fire fighting foam capabilities of at least two different apparatus in
your department.
10. If your department uses handheld appliances to produce fire fighting foam, describe
the following:
• Inlet pressure of the in-line eductor
• Maximum length of hose that can be used with the eductor
• Flow rate of the in-line eductor
• Type of foam nozzle used and its flow rate
11. Identify two techniques to apply foam.
12. What instrument should be used to determine the effectiveness of a foam blanket?
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References
1 National Fire Protection Association. “Standard 11, Low, Medium, and High-Expansion Foam,” 2005, Section 3.3.12.5.
3 Ibid. , Section 3.3.12.4
4 Ibid., Section A.5.8.
5 Ibid., Table 5.8.2.2.
6 Ibid.
7 Ibid.
8 Ibid.
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MANAGING THE INITIAL PHASE OF A HAZARDOUS
18
MATERIALS INCIDENT
One of the most important things for first responders to remember about managing the initial
phase of a hazardous materials incident is that they may not know that the incident involves
hazardous materials. While this may seem unusual, it is simply a reality check.
Whether first responders respond to a structure fire, vehicle accident with entrapment, or EMS
call for an unconscious patient, their department’s normal procedures for incident management
should always apply. But so should an appreciation for knowing that the presence of hazardous
materials can surprise even the most experienced first responders. These hazardous materials can
quickly overwhelm those who ignore warning signs or who are otherwise unsuspecting, overconfident,
or complacent. Hazardous materials change the rules of the game.
The department’s incident management procedures likely include some form of an Incident
Command System (ICS). There will be someone in charge and some means to account for all
personnel and to eliminate freelancing. There are a number of components of ICS that all first
responders should be familiar with. Those likely to be most important to first responders during the
initial phase of a hazardous materials incident are command structure and action plans.
Command Structure
The command structure for first responders during the initial phase of a hazardous materials
incident should include no less than an incident commander (IC) and a safety officer. The safety
officer should determine the site safety practices that are appropriate for the incident and have
the authority to enforce these. This on-scene enforcement action should never result in a political
showdown with the IC or anyone else who at the time may believe that being too safe is unnecessary
or an inconvenience. Remember there is no such thing as too safe!
The IC should delegate authority by assigning available personnel to manage key functional areas.
During the initial phase a hazardous materials incident, these areas could include the following:
• Scene control (isolate and deny entry)
• Research (learn the characteristics of the hazardous material)
• Protective actions (evacuation and/or in-place protection)
• Fire control (foam or water application—but only if appropriate)
• Product containment (defensive actions such as underflow dams)
• Decontamination (for both first responders and victims)
• Patient care (only after decontamination has been performed)
Due to the limited number of personnel typically available during the initial phase of most incidents,
first responders may need to wear multiple “ICS hats.” For example, the IC may also need to act as the
safety officer. However, as additional personnel arrive on scene, responsibilities for functional areas should
be delegated to individuals who are capable of managing them effectively. This delegation can include
individual groups that can each be responsible for various functional areas. For example, an operations
group can include functions such as product containment and fire control, while a medical group can
include functions such as decontamination and patient care. Figure 18–1 provides an example of an ICS
organization that can be used effectively during the initial phase of a hazardous materials incident.
INCIDENT
COMMANDER
SAFETY OFFICER
and
RESEARCH
OPERATIO NS MEDICAL GROUP SCENE CONTROL

GROUP (Law enforc ement)
FIRE CONTROL PRODUCT DECONTAMINATION PATIENT CARE

CONTAINMENT
Fig. 18-1 Typical Incident Command Structure during the Initial Phase of a Hazardous Materials Incident
First responders should not forget that a law enforcement agency can be tasked to manage the scene
control function. However, when doing so, police officers should know something about how your
incident command system works. In addition, these individuals must know to coordinate their activities
with the person who has been given leadership responsibility for this functional area. When given the
opportunity, police officers will freelance, just like firefighters.
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MANAGING THE INITIAL PHASE OF A HAZARDOUS MATERIALS INCIDENT
First responders must also remember that when a police officer is tasked to close a roadway, use of
road flares is often a standard practice. Therefore, it is usually a good idea for those managing an incident
that involves a potentially flammable atmosphere to warn all personnel assigned to traffic control near the
scene not to use road flares.
Key to the survival of any additional resources that respond is to ensure that the IC informs them
of the safest route to get to the scene. They should not let later-arriving apparatus drive through vapor
clouds or liquid spills. They should also ensure that additional resources are aware of the staging area that
is located upwind and uphill at a safe distance from the incident. One of the last things first responders
need is to have all of their apparatus loaded onto the scene with the likelihood of becoming contaminated.
All personnel responding should know where the command post is located, and they should be required
to check in with the command post upon their arrival. This includes representatives from any support
agencies that may respond.
As additional personnel arrive on scene, transfer of command will likely occur. Therefore, while a
company officer may be the initial IC, a battalion chief may arrive later and assume command. The
company officer would then likely be delegated authority for one of the functional areas discussed earlier.
The transfer of command should be communicated to all personnel on scene. Most important, first
responders must avoid having more than one person in charge. Anyone intent on assuming command
must upon their arrival at the scene communicate their intentions to the person who has command at the
time. First responders should be especially concerned whenever someone attempts to assume command
while still en route to the scene. The ability of this individual to really know what is going on is usually
limited, and his actions indicate a serious lack of trust in the IC already there.
Another aspect of ICS that can apply during even minor hazardous materials incidents is Unified
Command (UC). “Unified Command is an expansion of basic incident command that provides a
structured process by which several or many agencies or localities can integrate the decision-making
process for a single, unified set of objectives that effectively reflect the needs, authorities, concerns and
capabilities of all under one command function.”1
In addition, first responders should know that “the primary difference between the single command
structure and the UC structure is that in a single command structure, the IC is solely responsible for
establishing incident management objectives and strategies. In a UC structure, the individuals designated
by their jurisdictional authorities jointly determine objectives, plans, and priorities and work together to
execute them.”2
217
First responders should never believe that use of a UC structure is reserved for the “big one.” Instead,
they should consider that stakeholders during most hazardous materials incidents could include at least
the following agencies:
• Fire department
• Police department
• Local government officials
• Environmental regulatory agencies
• Health departments and hospitals
• Responsible party
• Property owner
• Cleanup contractor
• Recovery service (such as a wrecker)
Representatives from these groups may be involved not only in conducting certain activities that take
place at the scene, but also in deciding which of these activities are appropriate. For example, decisions on
how to upright an overturned cargo tank should include representatives from at least the recovery service,
environmental agencies, cleanup contractor, hazardous materials team, fire department, and the property
involved. All should agree on the recovery process and provide input regarding their interests. This is
especially important should the recovery go bad, i.e., the cargo tank splits open, the hazardous material in
the tank escapes, and the finger-pointing begins as to who was at fault for an “unexpected” catastrophe.
Unified Command helps prevent the IC from making decisions in an information vacuum. Remember
that a first responder likely does not have the experience and training to make all of the right decisions all
of the time. He should ask for help, and a UC system is one of the best ways to make sure this happens
in an organized manner.
As an incident progresses and more personnel arrive on scene, responsibility for additional functional
areas beyond those mentioned earlier can be delegated. These can include functions such as resource
management and rehab of personnel. Resources can include everything from heavy equipment, portable
lighting, toilets, food, and shelter.
Whenever first responders consider obtaining any resource, they must also consider who will pay for
it. While this aspect of incident management may seem insignificant during the early stages of an event,
it will become a major issue later on.
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Action Plans
Whether a first responder operates as the lone incident commander or as part of a UC structure,
decisions on incident strategies, tactics, and task assignments serve as the basis for developing the action
plan. Before beginning, first responders should remember that once they know or at least have a reason
to believe that hazardous materials are involved in an incident, distance is always their best defense. That
should be the underlying premise in all that first responders do during a hazardous materials incident. It
must be kept in mind when first responders develop their action plan using the following modes:
• Thinking mode
• Action mode
• Waiting mode
The Thinking Mode

Of all three modes, the thinking mode must come first. It allows first responders to select correct and
defensible tactics, as opposed to just taking action because they have always done it that way. By thinking,
first responders avoid rushing in and engaging in actions they will later regret.
While in the thinking mode, first responders do not need to sit next to any incident. Despite those
who may say otherwise, first responders do not need to touch, taste, smell, or feel the effects of hazardous
materials in order to make good decisions about how to handle the event. They should stay back and think!
The thinking mode allows first responders to conduct the following hazard assessments:
• The material. They should consider health and fire hazards.
• The container. They should consider whether or not the container is pressurized.
• The environment. They should consider any people and property involved.
The thinking mode also allows first responders to decide if their actions will make a difference and
determine if there is an immediate threat. This mode allows first responders to identify the material and
retrieve appropriate information from reliable sources. The first responders know who to call for help
and are not intimidated by those who would prefer to make decisions on their own, with limited training
and experience.
219
While in the thinking mode, additional hazard assessment considerations involve determining the
stage of the incident, including:
• Containers that have released their contents
• Containers that have not released their contents (but that have the potential to do so)
If first responders approach the incident scene without thinking, they may reach a point where they
can smell or taste the product. This probably indicates that they are too close, and if they are not wearing
their SCBA, they likely are getting ready to visit the hospital. It may also mean that they have forgotten
their binoculars or they have seriously underestimated the potential for harm. Any action taken at this
point could prove to be fatal.
First responders must remember that an incident is never “just a trash fire” or “just an oil spill.” If first
responders approach an incident scene without thinking about what could happen during the next few
minutes or few hours, their inappropriate actions may allow them to find out the hard way.
If there is an immediate threat to public safety, the thinking mode needs to progress promptly, but not
carelessly. The means to do so include knowing how to use the ERG effectively, knowing about hazards
stored and used in the community, and knowing in advance who to call for help and how to reach them.
The Action Mode

The result of the thinking mode will be the action mode. This mode includes incident strategies,
tactics, and task assignments. Remember, the action mode should be used only when the first responders
know that their actions can be done safely and will result in a positive outcome. Always remember that
any time first responders are in the action mode, they are likely to be closer to the incident than they
would be otherwise.
The actions of first responders should be limited to public safety, such as evacuations, preventing a
released material from spreading, or attempting to prevent a container from releasing its contents. It is
important to recall that most first responders are not trained or equipped to take actions to stop leaks
from containers, operate valves on cargo tanks or to overpack a leaking container by placing it into a
larger container.
The actions of first responders while in the action mode must conform to the action plan. This plan
should include answers to the following questions:
• What do the first responders plan to do? (Strategy)
• How do they plan to do it? (Tactics)
• Who will do it? (Task assignments)
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Strategy
Examples of what to do include:
• Identifying the material(s) involved and assess potential for harm from a safe distance.
• Assessing both the fire hazards and health hazards of the material(s) involved.
• Isolating affected areas and deny entry to others.
• Accounting for all personnel who may have been exposed to the material.
• Providing medical care and decontamination to victims.
• Protecting persons from potential for exposure (including other first responders).
• Minimizing the potential for containers to release their contents.
• Containing the spread of any released material.
Tactics
How first responders plan to do any of the above tasks takes into consideration the resources that are
immediately available to them as well as those that could be available later. For example, their strategy
may call for first responders to contain a spill of diesel fuel that has entered a nearby creek. Their tactics
may involve first responders putting absorbent booms into place. However, if these booms have not yet
arrived on scene, this will require that they select an alternative tactic. Perhaps first responders instead will
construct an underflow dam while using a section of hard suction hose from the fire apparatus.
Task assignments
The decision of who will do any task relies on the level of training of personnel at the scene and the
availability of protective clothing and equipment. While first responders will usually know the capabilities
of personnel from their department, they may be unaware of the level of training for personnel from
support agencies.
For example, perhaps an individual from the public works department has been assigned to operate
one of the front-end loaders in a hazardous atmosphere while digging a retention basin. He would
require more than just a one-minute orientation session on the use of SCBA, especially since this would
obviously ignore the strict requirements of OSHA’s Respiratory Protection Standard. Unless persons are
properly trained and equipped to perform an assigned task, including compliance with applicable OSHA
standards, they are usually more of a liability to the IC than an asset. This applies to employees of cleanup
contractors and recovery companies as well.
Remember that when determining strategies, tactics, and task assignments, first responders working
within a UC system should develop a consolidated action plan that takes into consideration the needs and
concerns of all affected stakeholders who are members of the UC group.
221
The Waiting Mode

Whenever the results of the thinking mode caution against action, first responders should employ the
waiting mode. Waiting means that first responders have determined that they cannot solve the problem
alone, if at all. They need to wait for assistance or perhaps wait for the incident to stabilize on its own.
Assistance during a hazardous materials incident can include all of the resources discussed earlier in this
book. This could involve hazardous material teams, cleanup contractors, technical and legal advisors,
responsible party representatives, and property owners. Regardless of who has been summoned to help,
first responders in the waiting mode have determined that any action they take may only make the
situation worse. It might also expose them to situations where any benefits to be gained are far outweighed
by the potential risks.
Unfortunately, the concept of waiting is one with which first responders are probably the least
comfortable. It goes without saying that first responders are action oriented, and those who possess this
personality trait are usually aggressive, determined, and willing to make sacrifices when necessary. They
are the kind of people most emergency response organizations hope to recruit. Yet when dealing with
hazardous materials, this same aggressiveness and determination can get first responders, along with many
others, killed or seriously injured, and all too often for little gain.
If first responders decide to select the waiting mode, it should be because:
• There is no immediate threat, and the incident is not getting any worse.
• The incident is getting worse, and there is nothing that first responders can do to stop it.
• They realize that any action on their part could make the situation worse.
• They recognize that they have done all they can with the resources available.
• They have isolated and denied entry to any affected areas.
• People in any affected areas are protected (evacuation/in-place protection).
• They have called the right people for assistance.
First responders while in the waiting mode should be far away from the immediate site of any release
and potential sources of exposure. If they stand in or near a spill site or a contaminated area while waiting
for help to arrive, they are nothing more than an accident waiting to happen.
During the waiting mode, the natural curiosity of first responders often takes over, and they soon get
closer to the incident just to “get a good look.” They may approach so close that they see boot prints made
from a spilled chemical or from spilled diesel fuel, and chances are those prints are from boots worn by
somebody in their department. They should always remember that whatever they do while waiting can be
done a lot safer while they are a lot farther away.
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Safe Work Practices

Any action plan must include safe work practices, such as:
• Selection of protective clothing (usually limited to structural firefighter protective clothing
and SCBA for first responders)
• Decontamination of first responders
• Limitations on the number of personnel operating in hazardous areas
• Use of a buddy system for personnel operating in hazardous areas
• Detection and monitoring of airborne contaminants
• Avoidance of contamination (First responders should not walk through or touch stuff.)
• Evacuation signal with an area for safe refuge
• Rehab and shelter for personnel
• Roadway safety (See the following sidebar for additional information.)
During the initial phase of a hazardous materials incident, the incident commander may not have
an opportunity or even the resources to write down all the aspects of his action plans. However, as time
allows, putting the plan to paper becomes a necessity. An “Incident Command Checklist” that can serve
as a guideline for incident commanders is provided in appendix A.
223
One of the scene hazards encountered 1. Establish, implement and enforce standard operating
by emergency personnel responding to procedures (SOP’s) regarding emergency operations
hazardous materials incidents is that of at highway incidents.
being struck by a vehicle while working 2. Position apparatus to take advantage of topography
on a roadway near moving traffic. and weather conditions (uphill/upwind) and protect
Unfortunately, this type of incident is not firefighters from traffic. Apparatus should be placed
that unusual. Firefighters, emergency at a 45-degree angle about 100 ft ahead of the
medical personnel and law enforcement work area. The truck should be angled to provide
officers are all vulnerable while working at a protected area for pump operators or command
accident scenes and hazardous material posts whenever possible.
incidents anytime there is moving 3. First control oncoming vehicles before addressing
traffic nearby. the emergency event, in the event the police have
not arrived to control traffic. Advance warning
Many of these struck-by incidents involve using cones, signs, vehicles or flaggers should be
drivers who are impaired by drugs, implemented as soon as possible. While flares are
effective at helping to channel traffic around an
alcohol, medication, or lack of sleep.
incident scene, their use may not be advisable due
There are also drivers who are distracted to other scene hazards. Do not use flares where the
by cell phones, GPS navigation systems, additional fire hazard would complicate the incident.
screaming children, their lunch, their
morning coffee, and/or sun glare. 4. Ensure that personnel position themselves and
Like every other aspect of emergency victims in a secure area, when it’s not possible to
protect the incident scene.
response, there are certain inherent risks
associated with hazardous materials 5. Coordinate with local transportation department
response. Highway emergencies present officials on the use of variable message signs to
dangerous hazards that can lead to inform motorists in advance of hazardous conditions
fatalities for firefighters. or roadway incidents.
6. Ensure that personnel park or stage unneeded
There are several proactive actions vehicles off the roadway whenever possible.
responders can employ to help prevent 7. Ensure that personnel wear personal protective
struck-by incidents. There have been clothing that is suitable for the incident while
several NIOSH Firefighter Fatality operating at an emergency scene, including high-
Investigations involving struck-by-vehicle visibility vest (retro-reflective and florescent yellow,
incidents. Your emergency personnel green and/or orange).
should know about and review the 8. Ensure that any personnel involved with traffic control
recommendations that were developed measures use a highly visible traffic control device
as a result of those investigations. like a flag or stop/slow sign.
The following points are a summary of 9. Establish pre-incident plans for areas that have a
the recommendations: higher rate of automobile incidents.
Courtesy of Jack Sullivan, (CSP, CFPS) Loss Control Innovations, Richmond, Virginia. www.LCInnovations.com
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“What Are We Doing, and Why Are We Doing It?”

During a hazardous materials incident, first responders must always take the time to ask themselves,
“What are we doing, and why are we doing it?” Of course, the time to do this is not when first responders
are ankle deep in a swirling broth of chemical-
tainted water or when they are setting out
First responders should always ask
road flares during an incident that involves an themselves what they are doing and why
overturned gasoline tanker. they are doing it. Consider that while
These questions should certainly not be aggressively attacking a commercial
asked after first responders have decided to
clean up a chemical spill at a residence and then vehicle fire containing hazardous
inform the occupants that they think it is safe to materials, a first responder may only
go back inside (when it is not). These questions
should not be asked after they have loaded a
be creating a toxic water runoff. The
contaminated patient into their ambulance only remains of the material he extinguishes
to develop headaches and eye irritation while will now require days to remove safely
traveling to the hospital. The time for these
questions is also not after they decide to wash along with thousands of dollars of
down a spill of latex paint and turn a minor 5- expense for disposal. Meanwhile, the
gal release into a 500-gal nightmare. By then
it is too late, and the first responders will have owner of the truck has already written
become part of the problem! off all hopes of recovering any of the
Effective use of the thinking mode leads material or the vehicle. The following
to safety in the action mode. As such, first day, as the first responder lies in a
responders will wear appropriate protective
clothing because they realize their safety could hospital bed with scorched lungs and
be compromised as a result of proximity to the blistered skin from chemical exposure,
material. Yet they also know the capabilities
and limitations of their protective clothing. the company’s driver is already on the
They know that many hazardous materials road in a new truck with a replacement
present inhalation hazards. Many are odorless,
with physical effects that may not be evident
load and the first responder’s lifelong
for several hours, if not days, after exposure. suffering is nothing more than a
Knowing this, first responders will always wear footnote in history. Nearby waterways
their SCBA.
are forever contaminated and hundreds
Safety in the action mode becomes apparent
in many ways. If first responders use water of dollars worth of fire suppression
from a hose line, they know that doing so will equipment was destroyed. Left on its
not make the situation worse. If they attempt
to rescue someone potentially exposed to a
own, the fire would have gone out while
hazardous material, they know that emergency first responders sat a safe distance
decontamination equipment is ready. They are away and watched unharmed.
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confident that their efforts are for more than just

In March 2004, the Secretary of body recovery, and that they have researched and
Homeland Security, at the request of evaluated the risks involved.
the President, released the National Before progressing to the action mode, first
Incident Management System responders should have answers to the questions of
what, how, and who regarding actions on the scene.
(NIMS). The NIMS is a comprehensive If first responders do not have specific answers for
system that will improve response these questions, if they cannot answer, “What are
we doing, and why are we doing it?” then they may
operations through the use of the need to remain in the thinking mode or perhaps
Incident Command System (ICS) consider the waiting mode.
and other standard procedures During the action mode of a hazardous materials
incident, all incident commanders must remember
and preparedness measures. It another important consideration. Although they
will also promote development of could be doing the right thing for the situation
cross-jurisdictional, statewide, and they thought they had, if conditions change or
deteriorate, whatever they are doing probably needs
interstate regional mechanisms for to change. These changes can include an unexpected
coordinating incident management wind shift that results in first responders suddenly
detecting a metallic taste or perhaps a pungent
and obtaining assistance during odor. They should know that these are not good
large-scale or complex incidents. signs and that they need to react quickly.
States play an important role in An incident commander must continue to
ask the right questions of the right people at the
ensuring the effective implementation right time, and he should never take anything
of the NIMS. They must ensure that for granted. It is the only way he will know that
hazardous materials are involved in an incident and
the systems and processes are in be able to appreciate the potential for all things on
place to communicate the NIMS the scene to go really bad, really fast.
requirements to local jurisdictions The IC must remember that accountability
and support them in implementing of all personnel is vital. But it is not enough to
just know who is on the scene and where they are
the NIMS.1 First responders should supposed to be. Personnel on scene must truly be
check with their local and state accountable to the incident commander in terms of
their ability to accomplish assigned tasks safely.
emergency management officials to
Incident commanders must in turn be
learn more about the use of NIMS in accountable by providing for a safe work
their community. environment. They know that injuries can occur,
and they must have the personnel and resources
1 Excerpt of a document from the NIMS Integration ready to react. Medical personnel must have copies
Center, October 4, 2005 at www.fema.gov. of all MSDS, decontamination must be available for
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first responders, and local medical facilities must be made aware of the incident. Remember, emergency
room doctors do not like surprises. During a hazardous materials incident, the incident commander must
take care of his people and do everything in his power to ensure that everyone goes home.
Sometimes incident commanders think they have all the answers and that their action plans are airtight.
Whenever this is the case, they should stop and ask themselves or someone they trust the question, “What
are we doing and why are we doing it?” Overconfidence along with huge egos can contribute to the death
or serious injury of even the most experienced responder!
The IC should be aware that if he does not ask appropriate questions during the initial phase of a
hazardous materials incident, someone else probably will later. These questions could come from a lawyer,
a reporter, an OSHA inspector, or even a victim’s family. Of course, first responders can always play the
exciting game of “rush-in” roulette and take their chances. Good luck to those who do!
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Key Points
• The command structure during the initial phase of a hazardous materials incident should
include no less than an incident commander (IC) and a safety officer.
• During the initial phase of most hazardous material incidents, first responders may need
to wear multiple ICS hats.
• Unified command provides a process by which several or many agencies or localities can
integrate their decision-making process during a hazardous materials incident.
• First responders should develop an action plan using the thinking mode, the action mode,
and the waiting mode.
• By thinking first, first responders avoid rushing in and engaging in actions they will
later regret.
• Hazard assessment includes determining the status of the materials and containers involved,
along with the environment.
• Additional hazard assessments include determining the status of containers that have
already released their contents, those that have an ongoing release, and containers that
have not released their contents but have the potential to do so.
• An action plan should include what the first responders plan to do, how they plan to do it,
and who will do it.
• Any action plan must take into consideration safe work practices.
• When in the waiting mode, first responders have accepted the fact that they cannot solve
the problem alone, if at all, and that they need to wait for help.
• When dealing with hazardous materials, first responders should avoid playing the exciting
and dangerous game of “rush-in” roulette.
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Chapter Questions
1. What two positions should be included at a minimum in the command structure during
any hazardous materials incident?
2. Identify at least five key ICS functional areas that should be in place during the initial
phase of a hazardous materials incident.
3. What important information should the IC relay to all units responding to a hazardous
materials incident?
4. How should transfer of command be accomplished?
5. Define the meaning of the term Unified Command.
6. Besides the fire department, identify at least five agencies that could be involved in a
hazardous materials incident.
7. Identify the three modes that should be used when developing an action plan.
8. Identify at least five considerations while operating in the thinking mode.
9. Identify the three primary considerations of the action mode.
10. Describe a consolidated action plan.
11. Identify at least five tasks that can be incorporated into an action plan.
12. Identify at least five safe work practices.
13. Where should the waiting mode take place?
14. Identify two reasons why first responders would elect to operate in the waiting mode.
15. Using the ICS checklist as a guide found in appendix A, identify the names and telephone
numbers for at least 10 notifications at the state or local level that may be necessary during
a hazardous materials incident. Be sure to include a way to contact representatives from
these agencies outside of normal working hours.
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References
1 “National Incident Management System (NIMS) Overview,” http://www.vdfp.state.va.us/nims.htm.
2 “NIMS and the Incident Command System,” http://www.fema.gov/txt/nims/nims_ics_position_paper.txt.
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19
IS THE INCIDENT A CRIME SCENE?
One of the questions first responders should ask themselves while operating during any incident
that involves hazardous materials is if there has been any criminal activity that could have contributed
to its cause. While no one expects first responders to conduct a thorough criminal investigation,
they should accept the responsibility to identify evidence, preserve evidence, and notify appropriate
authorities of their concerns.
Detecting Possible Criminal Activity

First responders may become aware of possible criminal activity related to inconsistencies
between shipping papers, placards, and markings displayed on the outside of transport vehicles.
For example, the shipping papers for a shipment involved in a motor vehicle accident may state
that the proper shipping name for the product is “nitrocellulose with not less than 25% alcohol.”
The product identification number is 2556. Yet the first responders notice that the identification
number displayed on the outside of the transport vehicle is 2555, which would indicate a shipment
of nitrocellulose with water, not less than 25% water. While this situation undoubtedly presents first
responders with erroneous and dangerous information, it may also represent a violation of law.
During another incident, first responders could encounter several containers that appear to be
abandoned on a vacant lot. If in fact the containers are abandoned, is this now an environmental
crime scene? Were the containers disposed of illegally in an effort to avoid the cost of proper disposal?
If so, who is responsible, and who will pay for the cleanup?
Perhaps first responders arrive at an industrial facility where an employee has been injured. While
on the scene they observe unsafe acts or are told by witnesses that the company intentionally violated
workplace safety regulations that led to the incident. What actions should first responders take?
Without a doubt, safety is a primary mission for all first responders. Yet preserving potential
criminal evidence, whether from arson or environmental crimes, should be given strong consideration
whenever doing so will not jeopardize this safety.
For example, during a vehicle accident, shipping papers and driver logbooks may become evidence, as
would photographs of what are believed to be improper placards and marking. First responders should use
caution to avoid any actions that could disturb potential evidence. Such an action could include moving
the vehicles prior to photographing their position. It could also include washing down the interior of a
smoldering truck cab with hundreds of gallons of water before law enforcement or fire investigators have
had an opportunity to retrieve any evidence. This could include log books and shipping papers.
When dealing with abandoned materials or containers, preserving evidence is usually best accomplished
by staying away from it. In that way, first responders can avoid destroying any physical evidence on or
near the containers, such as fingerprints, footprints, or tire tracks. They are also less inclined to open the
container to see what is inside.
Opening a container under these circumstances is not only dangerous, but it also complicates the
job of a prosecutor. Later in court the prosecutor may have to explain to a jury why a suspect should be
charged with a felony for illegal disposal of dangerous hazardous waste. This could be difficult if the local
fire chief is reported to have opened one of the containers, stuck his hand in the stuff, and proclaimed,
“It’s just oil.”
Prompt notification of appropriate authorities when faced with potential crime scenes is vital. Most
police officers are not trained to enforce motor carrier safety regulations, and first responders may need
to request those who are. Likewise, obtaining samples of criminal evidence from containers suspected
of containing hazardous waste requires specialized training to ensure that the evidence is reliable and
defensible. It is not permissible to just pour some of the stuff into a jar and take it to court.
First responders may also have an obligation to contact representatives from their state or local office
of occupational safety to report their suspicions of workplace safety violations. In addition, they may have
an obligation to notify officials who have authority for enforcing environmental regulations should they
believe that an incident involves the improper disposal of hazardous waste. These latter incidents could
involve bags that contain suspected asbestos material or medical waste.
First responders should remember that an incident involving a suspicious odor could be evidence
of a drug lab, storage of hazardous waste without a permit, or improper use of hazardous materials. For
example, a commercial building could house several different types of businesses. Those who work in an
office may complain about a noxious odor from a neighbor who stores and ships chemicals. Investigation
of this complaint may need to include officials with responsibility for zoning, code enforcement, or
law enforcement.
There are always opportunities for first responders to become involved in civil litigation, whether as a
witness or defendant. As with most emergency incidents, the actions of first responders may be called into
question. The impact of decisions they were forced to make within seconds can be debated in court over
weeks, months, and maybe even years.
First responders may be challenged by business owners for lost revenue due to evacuation orders, or
they may be questioned as to why they let a fire burn itself out or why they used water to extinguish it.
They may be challenged because they reportedly delayed patient care for a victim exposed to a hazardous
material. This could occur even though the “delay” was the result of efforts to decontaminate the patient
and thus eliminate the potential for exposure of all those involved.
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During any emergency incident, first responders

should base their actions on their experience, accepted
A first responder was one day
practices, their training, and applicable industry the recipient of a subpoena to
standards. They must also base their actions on the
rules and regulations of their agencies. But they must appear in court as a witness for
remember that regardless of the level of diligence they the prosecution regarding an
display, there will always be an expert witness willing to
challenge their actions in court. incident that involved the use of
several homemade incendiary
devices. Several glass soft drink
Documentation
bottles had been filled with a
Agencies whose policies state first responders “shall” flammable liquid and outfitted
or “will” in reference to accomplishing certain tasks may
leave little room for discretion and judgment during with rags stuffed into the bottle
emergency incidents. It may be determined that first
responders knowingly violated the “shall” or “will” part
openings. The rags were then
of the rule, despite their reasons for doing so. Some ignited and thrown at a single-
organizations have recently developed standard operating
guidelines. These emphasize guidelines as a means of family residence. The devices
providing suggested actions for first responders, thereby failed to work as intended and
leaving room for discretion. However, first responders
should remember that “discretion” is not an open first responders needed only to
invitation for careless or reckless behavior.
extinguish small grass fires in
Documentation of actions taken during a hazardous
materials incident is one way for first responders to
the areas where the devices had
prepare for their defense before a subpoena comes their landed. The prosecuting attorney
way several months later. While on the scene, they should
record what was done and why. They must be certain had learned from a police officer
to include names, dates, and times for various events. that the first responder had
These include such items as the time a certain agency or
organization was called for assistance, and the name of positively identified the material
the representative spoken to.
inside the devices as gasoline.
Another important item to maintain as a permanent
record is a copy of any MSDS used as the basis for
When the prosecutor asked how
decisions. First responders should remember that the data this determination had been
sheet used during an incident may have been updated
by the time they go to court. Another suggestion is to made, the first responder replied
keep a photocopy of pages from any reference books that he had “sniffed it.” The
used, including the ERG. As new editions of books are
first responder did not appear
in court.
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published, information may change. First responders will always want to go to court with the same
information that was used during an incident.
Most of all, first responders must accept the fact that they do not have all of the answers all of
the time. They should know not to overstep the boundaries of their authority and training.
Even the best lawyer will have a difficult time preparing a defense for first responders when
their only response to questioning is, “I didn’t know, but I didn’t ask for help,” or even worse, “I
didn’t think.”
234
Key Points
• First responders should ask themselves during any hazardous materials incident if there
has been any criminal activity that could have contributed to its cause.
• While safety is a primary mission for all first responders, preserving potential criminal
evidence should be considered whenever possible.
• When dealing with abandoned materials or containers, preserving evidence is usually best
accomplished by staying away from the containers.
• An incident involving a suspicious odor could be evidence of a drug lab, storage of
hazardous waste without a permit, or improper use of hazardous materials.
• Documentation of their actions on scene is one way for first responders to prepare for
their defense before a subpoena comes their way several months following an incident.
• Use of “discretion” by first responders during a hazardous materials incident is not an open
invitation for careless or reckless behavior.
• Even the best lawyer will have a difficult time preparing a defense when the only response
to questioning is, “I didn’t know, but I also didn’t ask for help.”
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Chapter Questions
1. Describe the role of first responders when they suspect that there may be criminal activity
involved with a hazardous materials incident.
2. Identify a representative from your state occupational safety and health agency and
determine what suggestions they have for first responders who may suspect the presence of
unsafe work practices during their response to an industrial facility.
3. Identify a motor carrier safety representative from either a local or state law enforcement
agency. Determine what suggestions they have for first responders who may suspect the
presence of improper documentation or an unsafe vehicle during a hazardous materials
transportation incident.
4. Identify a building code or fire official from either a local or state agency and determine
what suggestions they have for first responders who may suspect improper storage and use
of hazardous materials.
5. Identify at least three items of importance that first responders could maintain as a written
record regarding their response to a hazardous materials incident.
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CLEANUP, RECOVERY, REIMBURSEMENT,
20
AND S CENE R ESTORATION
When dealing with a hazardous materials incident, first responders should always remember their
primary mission is to protect public safety. First responders may isolate an area and protect those
who may be exposed, contain a material that may have been released, and provide decontamination
and medical care for any victims. Having done these tasks, first responders will have met most
expectations for their level of training. There is no rule that first responders must then conduct a
cleanup of hazardous material spills. Doing so may only provide opportunities for first responders
to become part of the problem they were attempting to resolve. They can easily transform a success
story into a disaster.
Cleanup of a Hazardous Materials Incident

Is the individual responsible for the release of a hazardous material required to conduct cleanup
operations? The answer is usually, “Only if they are trained and equipped to do so.”
Some hazardous material incidents involve transportation companies. Perhaps a company that
delivers home heating oil spills 100 gal of product into a customer’s backyard. First responders
should not be surprised if this company suddenly claims to be a qualified cleanup contractor.
The same holds true for trucking companies. They may claim that their personnel, including
the driver, are qualified to conduct cleanup operations right there on the side of the road or in the
parking lot of a truck stop. Could this be true? Are members of an industrial fire brigade at a factory
also trained and equipped to conduct cleanup operations?
First responders will likely be in charge of the incident. However, they should remember that
after the emergency is over, they could still be liable if they just walk away without any interest
in who conducts cleanup operations. Therefore, they should get help when determining who is
qualified and make sure they know who will be responsible for this phase of the incident.
For example, representatives from local or state environmental regulatory agencies should be
the ones who decide who is qualified to conduct cleanup and when the cleanup is complete. First
responders should remember that protecting the environment from hazardous materials is the job
of these agencies. Likewise, there may be situations when officials from local or state occupational safety
and health agencies should get involved to ensure that any individual conducting cleanup operations
is properly trained and certified. This may require a cleanup contractor to produce documentation to
support the claim that its employees are qualified. It may even involve faxing copies of employee training
certifications to the scene.
Should first responders ever conduct cleanup operations themselves? For what may appear to be
minor incidents, some may already do so, and they probably consider this to be a routine service to their
community. However, first responders should consider some potential problems with this approach.
First, removal of any waste material involves efforts to package it in some sort of container. Afterwards,
the container must be transported away from the site and then disposed of properly. These actions are
easier said than done. Depending upon the type and amount of material involved, local, state, and federal
laws may place strict controls on the movement of this material and require various permits for its storage
and transport.
Has there ever been an abandoned compressed gas cylinder removed from the side of a road and
transported to the local landfill or highway department yard in the back of a public works pickup truck?
Has an ambulance crew ever transported a bag of abandoned medical waste found on a highway median
back to their fire station for disposal in their own medical waste disposal container? Has a fire department
engine company crew ever carried a pipe bomb discovered in a trash fire back to their fire station? The
answer is yes, these situations certainly have occurred before.
It could be due to a natural urge for firefighters or others involved in public service to quickly solve
a problem so that it is not “blown out of proportion” (likely their words). It could also be due to a lack
of understanding related to the potential hazards, rules, and regulations involved. It could even be an
attempt to minimize costs (knowing that use of a cleanup contractor may be expensive). Nevertheless, the
removal of hazardous materials by those who are not trained and authorized to do so is dangerous and
possibly illegal.
Why do some first responders believe they are responsible for cleaning up small spills of chemicals
at a private residence or a doctor’s office? Is this just another public service? Perhaps, but when they
begin taking on the challenge of cleaning up spills from a container of pesticide concentrate or a broken
mercury thermometer, they are likely venturing into uncharted territory.
Whenever first responders attempt to clean up even a small chemical spill, how do they know where
to begin? Then, how do they determine when the site is clean enough? Even if they manage to obtain a
mercury spill kit, would they know how to use it? What if a pesticide concentrate soaks into a concrete
floor in the basement of a residence? After attempting cleanup, at what point do they decide it is clean
and safe? What if in this situation they allow the residents to return home, but the next day the residents
become ill due to chemical exposure?
And even if the first responders do clean up a spill, what will they do with the waste material afterwards?
They should remember that even though a homeowner may have an exemption that allows disposal of
certain types of “household hazardous wastes,” this same exemption may not apply to first responders.
They cannot just carry the stuff back to the firehouse and throw it in the trash.
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CLEANUP, RECOVERY, REIMBURSEMENT, AND SCENE RESTORATION
Consequently, first responders should always remember that whoever owns the property where the spill
occurs also owns the problem associated with cleanup. First responders should never inherit this problem.
If anything goes wrong and their lack of training and experience regarding cleanup operations are called
into question, they may be defenseless, despite their best intentions.
Of course, there will be situations when the responsible party for a spill or the property owner is
unknown, or is unwilling or unable to pay for cleanup. When this occurs, local or state government
agencies may need to fund cleanup operations, but not the local fire department.
With this said, are there any situations when first responders can safely clean up small spills? Perhaps,
but usually only those involving small spills of hydrocarbon fuels, such as gasoline or diesel that result
from minor motor vehicle accidents. Of course, one consideration when performing even this limited
type of operation is removal and disposal of any contaminated absorbent materials.
Representatives of companies that sell absorbents will make claims regarding the allowable means of
disposal for their absorbents. However, the reality is that disposal of contaminated absorbent materials
is governed by local and state environmental regulatory agencies. It may be helpful to research local and
state laws to determine if wrecker drivers are required to remove this type of waste in conjunction with
removal of a damaged vehicle following a highway accident.
If it is decided that a cleanup contactor is needed at the scene, who should make the call, and who
should pay the cleanup bill? Once again, for first responders the simple answer should be, “Not us!” As a
general rule, responsibility for hiring a cleanup contractor rests with the responsible party. This could be a
property owner, the person responsible for the release, or perhaps even the tenant of a fixed facility.
Recovery of Vehicles
Some accidents involve commercial vehicles transporting hazardous materials, and these large vehicles
may not be capable of leaving the scene under their own power. However, vehicles that have overturned
will need to be recovered. This latter situation presents lots of opportunities for disasters to occur. It may
be then when attempts to “cut corners” and save money during the cleanup phase of the incident can have
serious consequences.
Recovery operations involving commercial vehicles require the right equipment, the right skills, and
the right experience. No part of this equation can be safely eliminated. First responders should remember
this the next time they watch two underpowered tow trucks operated by two inexperienced individuals
who are attempting to upright a large overturned propane cargo tank. They only think they know what
they are doing.
There is also a right time and place for a crane and perhaps even large air bags that can be used to
lift vehicles. But first responders should make sure they know how to contact those who can provide this
service and that these individuals are capable of performing the required tasks. First responders should
keep in mind that some large cranes may need a police escort while traveling to the scene.
239
First responders should also remember that during transportation emergencies, the assessment of any
vehicles involved must be ongoing. Leaks can appear hours into an incident, and containers can move due
to the instability of the surface on which they are resting.
During efforts to transfer product from a damaged cargo tank, first responders should be prepared for
the container to shift position as the level of material drops and subsequently changes the tank’s center
of gravity. If during this situation the tank is not yet secured by either wrecker trucks or cranes, the first
responders may be unprepared for a sudden movement of the tank. They may find themselves the target
of a very large object that has no regard for people or property in its way.
First responders should also remember that most wrecker companies that respond to the scene of a
motor vehicle accident are selected from a rotation list maintained by police officers. Regardless of which
wrecker driver shows up, someone on scene should understand that there is a big difference between a Kia
and a Kenworth, especially when the latter is upside down.
Therefore, whenever possible during highway transportation incidents involving overturned vehicles
containing hazardous materials, first responders should consult with the law enforcement officers on the
scene. This should be done before the decision is made on contacting a wrecker service. First responders
should keep in mind that once the next wrecker crew on the rotation list is on the scene, they may be
reluctant to give the job to someone else. They may either attempt to complete the job themselves, despite
being unprepared to do so, or they may subcontract the recovery process to another company. This would
increase the cost for the entire operation.
Reimbursement for Costs

During a hazardous materials incident, first responders may incur costs related to personnel, as well
as fuel, food, and drinks provided to first responders during rehab. They may also incur the cost of
replacement of damaged equipment. Some may never consider seeking reimbursement for these types
of activities, referring to them instead as the “cost of doing business.” Others may believe that the costs
associated with the long-term nature of some hazardous materials incidents are excessive and therefore
worthy of reimbursement. Most often, reimbursement is sought directly from the responsible party or
their insurance company.
Whenever first responders decide to request reimbursement, they should itemize all expenses and
gather receipts where available. When preparing an invoice, they should not list charges for “potato chips
and soda.” Instead, they will likely increase their chances of getting paid with fewer questions from the
responsible party if they request reimbursement for “rehab supplies.”
First responders should also consult with their local government attorneys to determine if there are
local or state laws that can be used as a means to enforce their reimbursement claim. First responders may
decide to have these attorneys prepare a cover letter and submit the invoice on their behalf. This will be
sent using an envelope with the return address of the local government attorney’s office rather than that
of the local fire department. In this manner, a responsible party is less likely to mistake the invoice for just
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another unsolicited request for a donation, tossing it in the trash unopened. Most people respond to mail
they receive from a lawyer.
Scene Restoration
Scene restoration includes restoring the safety, appearance, and function of affected property and
surrounding areas. Every incident scene belongs to someone, and that person will definitely have an
interest in its future.
While on the scene of a hazardous materials incident, first responders may need to initiate the process
of notifying property owners. For example, there may be a spill from a home heating oil tank in the
backyard of rental property, or there may be a fuel spill in a highway intersection following a motor
vehicle accident.
During incidents such as these, the property owner is usually not at the scene initially. However, first
responders are on scene and are aware of the problem, and they should therefore consider notifying the
property owner of any potential hazards. This is especially true if these hazards present an imminent threat
or could likely get worse if left unattended. If a problem occurs later, it may be easy for a first responder
to say that scene restoration was not his job. But it may be harder for him to defend his decision later in
civil court, when a property owner claims that the first responder was negligent for not notifying him of
the problem.
For example, one could consider a roadway fuel spill that covers an entire lane of traffic. Cleanup efforts
can easily remove free product (material that has some depth to it) from the road surface, yet despite these
efforts, a stain or sheen will usually remain. This stain will normally diminish during a period of several
weeks following exposure to weather and traffic. Yet if it rains immediately after removal of the free product
(especially just a light rain), the potential exists for this sheen to now create a slippery surface.
If the highway department is notified, they may be able to take corrective actions, including applying
an abrasive such as sand to the road surface. But first responders should remember that the highway
department cannot begin to do this unless first responders call them. A citizen whose car skids on the slick
road surface created by an earlier fuel spill could attempt to blame the first responders for failing to make
the appropriate notifications.
Another safety consideration regarding highway incidents is restoration of the road shoulder. This
may be necessary following excavation by a cleanup contractor of soil that may have been contaminated
by a spilled material, such as diesel fuel from a motor vehicle accident. If the road shoulder is not repaired
properly, the first person whose tire drifts off the roadway will probably come looking for whoever it was
that allowed a large hole to remain as a hazard on the side of the road. That someone could be the first
responders, unless they notify the property owner (such as the highway department) and transfer the
liability for restoration of the road shoulder to them.
Safety in scene restoration also includes the quality of drinking water if underground wells could
be affected by a spill of a hazardous material. First responders may need to notify local and state health
officials of their concerns. Likewise, large spills of materials such as fuel oil can easily contaminate
241
underground utility cables. When these incidents

A highway cargo tank overturned occur, first responders should always notify the utility
while traveling along an interstate locating company in their area.
highway exit ramp. The vehicle Once first responders make notifications to
appropriate individuals, whether or not they elect to
came to rest on its side. Prior to take action is their choice, but at least the first responders
any effort to upright the vehicle, a will have made the proper calls. They should always
remember to document their efforts at notification and
decision was made to offload the include this information with their run report. They
product. However, after learning must be sure to record the date and time of the call and
the names of any individuals they spoke with.
that the material would need to
Another aspect in scene restoration is related
be heated in order for this to be to decisions to allow persons to return to areas or
accomplished, it was determined buildings previously contaminated by a chemical spill.
Under most circumstances, the best advice for first
that the vehicle would be recovered responders is to defer the question of, “Is it safe to go
while still fully loaded. The first home?” to industrial hygienists or others with similar
training and experience. First responders who choose
wrecker driver on scene was not to make decisions regarding reentry by occupants
capable of conducting a vehicle assume the liability for any subsequent health effects
that may occur later.
recovery of this magnitude but
On occasion, despite a decision to deny reentry,
rather than relinquish the job, he first responders may have reason to believe that the
subcontracted to another company occupants will attempt to return anyway. When this
occurs, first responders may have no choice but to
who owned inflatable recovery air condemn the property. While this is not a foolproof
bags. However this company had method of preventing reentry, it does protect first
responders from a legal perspective. Remember
just received this equipment and that the fire service routinely condemns buildings
was unsure of how to use them. following damage from fire or structural problems,
and chemical contamination should be no exception.
Like the first wrecker driver, he was First responders should check with their local building
unwilling to give up the job, and officials to determine their willingness to provide
this type of support during a hazardous materials
so he in turn subcontracted with incident.
another company for an individual When first responders leave the scene of a
who could provide on-scene hazardous materials incident and transmit a message
to their dispatch center that all units are “clear and in
direction for use of the new air service,” what they are really saying is that the scene is
safe. Let’s hope so.
bags. Total cost for the recovery bill
was in excess of $10,000.
242
Key Points
• There is no rule that first responders must clean up a hazardous materials spill, since doing
so may only provide opportunities for them to become part of the problem.
• Trucking companies may claim that their personnel, including their driver, are qualified to
conduct cleanup operations on the side of the road or in the parking lot of a truck stop.
• First responders cannot carry hazardous waste back to their firehouse and throw it in
the trash.
• Responsibility for hiring a cleanup contractor should rest with individuals such as the
property owner, the person responsible for the release, or the tenant of a fixed facility.
• Recovery operations involving commercial vehicles require the right equipment, the right
skills, and the right experience, and no part of this equation can be safely eliminated.
• First responders should consult with law enforcement officers before a decision is made on
contacting a wrecker service to ensure the right equipment is brought to the scene.
• First responders may decide that the costs associated with the long-term nature of some
hazardous materials incidents are excessive and therefore worthy of reimbursement.
• There may be local or state laws that can be used as a means for first responders to enforce
their reimbursement claims with responsible parties.
• Scene restoration includes the safety, appearance, and function of affected property and
surrounding areas.
• Safety in scene restoration includes the quality of drinking water if underground wells
could be affected by a spill of a hazardous material.
• First responders may be forced to condemn a structure in order to prevent occupants from
returning to a dangerous environment.
243
Chapter Questions
1. What regulatory agencies should play a role in determining if a cleanup contractor is
qualified? What information might these agencies request from the contractor?
2. Determine if your department has any written procedures or guidelines for conducting
cleanup operations following a hazardous materials incident.
3. What problems could first responders encounter if they attempt to remove waste material
from the scene of a hazardous materials incident?
4. What three things should first responders consider regarding selection of a wrecker service
to upright an overturned vehicle?
5. Explain why first responders should attempt to contact individuals whose property has
been affected by a hazardous materials spill.
6. How could underground drinking wells and utility cables be affected by a chemical spill?
Explain your answer.
7. Identify at least one industrial hygienist in the area who could be hired to assess the safety
of a building prior to reentry of the occupants.
8. What actions can first responders take for the safety of occupants if they decide that a
structure is unsafe for reentry following a spill of a hazardous material?
9. Identify at least one cleanup contractor and one wrecker service from the area with
the training, equipment, and experience to safely manage hazardous material incidents
involving large commercial vehicles. Meet with a representative from each of these
companies and provide a list of the resources they have available.
10. What implied message is transmitted when first responders inform their dispatcher that all
units are “clear and in service” following a hazardous materials incident?
244
Acknowledgements
My fire service career would not have been possible without the support of my wife, Deborah, and my
children, Michael and Kaitlyn. You have endured my full-time shift work, part-time teaching, volunteer duty
crews, around-the-clock pages, weekend schools, late night meetings, four career moves, two college degrees, and
of course, my writing this book.
Thank you for your patience.
xiii
This book is dedicated to first responders, who leave their homes and families every day
with the desire to make their communities a safer and better place in which to live. Sadly, some
never return.
In support of the National Fallen Firefighter Foundation’s efforts to reduce line-of-duty deaths
through its Life Safety Initiatives, all proceeds from this publication will be donated to the Foundation.
Please visit their Web site at www.firehero.org to learn more about the mission of this valuable fire
service organization and how you can help.
Remember, everyone goes home.
MANAGING T HE INITIAL PHASE OF A
HAZARDOUS MATERIALS INCIDENT:
Aix
end
app
INCIDENT COMMAND SYSTEM CHECKLIST
COMMAND STRUCTURE ACTION PLAN

COMMAND THINKING MODE
• Single Incident Commander or • The material—health and fire hazards
Unified Command • The container—pressurized or
nonpressurized containers
SAFETY OFFICER
• The environment—people and property
FUNCTIONAL AREAS • Containers that have released
their contents
• Scene control
• Research
• Containers that have not released
• Protective actions their contents
• Fire control • Safe work practices
• Product containment
• Decontamination
ACTION MODE
• What first responders plan to do (Strategy)
• Patient care
• How they plan to do it (Tactics)
• Who will do it (Task assignments)
WAITING MODE
• There is no immediate threat, and the incident is not getting any worse.
• The incident is getting worse, and there is nothing first responders can do to stop it.
• First responders realize that their actions could make the situation worse.
• They recognize that they have done all they can with the available resources.
• They have isolated and denied entry to any affected areas.
• People in any affected areas are protected (evacuation/in-place protection).
• They have called the right people for assistance.
MANAGING T HE INITIAL PHASE OF A HAZARDOUS MATERIALS INCIDENT:

INCIDENT COMMAND SYSTEM CHECKLIST
When responding to a reported release of known or suspected hazardous materials, first responders
should consider the following:
✓ Approach the scene from upwind and uphill. Keep the first responder vehicle at a safe distance.
✓ Look for other hazards at the scene, such as fires, potential for explosions, downed power lines,
and unstable vehicles, etc.
✓ Identify the material(s) involved and assess potential harm from a safe distance.
✓ Do not enter areas of known or suspected contamination. Isolate affected areas and deny entry
to others.
✓ Obtain immediate emergency response information. Use the Emergency Response Guidebook,
Hazardous Materials Guide for First Responders, shipping papers, or a material safety data sheet.
✓ Look for exposures: people, property, and the environment.
✓ Consider the need to evacuate citizens or protect them inside their homes, schools, or businesses.
✓ Isolate contaminated people away from the material(s) and away from other people.
✓ Decontaminate patients before medical treatment and transport.
✓ Contain the spread of any released material, if trained and equipped to do so safely.
HAZARDOUS MATERIAL INCIDENTS

SUGGESTED NOTIFICATIONS FOR FIRST RESPONDERS
Property owner Public works department

Responsible party Highway department
Health department Game departments (effects on wildlife)
Hospitals Environmental regulatory agencies
Motor carrier law enforcement Occupational safety agencies
Underground utilities Government officials
246
HAZARDOUS MATERIALS WARNING LABELS
Hazardous Materials Warning Labels
Actual la
abel size: 10
00 mm
m (3.9 in
nches) on alll siides
CLASS 1 Explosives: CLASS 2 Gases: CLASS 3 Flammable Liquid CLASS 4 Flammable Solid, CLASS 5 Oxidizer, Organic
Divisions 1.1, 1.2, 1.3, 1.4, 1.5, 1.6 Divisions 2.1, 2.2, 2.3 Spontaneously Combustible, and Peroxide: Divisions 5.1 and 5.2
Dangerous When Wet:
Divisions 4.1, 4.2, 4.3
§172.411
* Include compatibilitygroup letter.
** Include division number and compatibilitygroup letter. §172.405(b),§172.415,§172.416,§172.417 §172.419 §172.420,§172.422,§172.423 §172.426,§172.427
CLASS 6 Poison (Toxic), Poison Inhalation Hazard, CLASS 7 Radioactive CLASS 8 Corrosive CLASS 9 Miscellaneous Subsidiary Risk For Aircraft
Infectious Substance: Divisions 6.1 and 6.2 Hazardous Material Label Only
Cargo Aircraft
Only
Empty Label
E MPT Y
For Regulated Medical Waste (RMW),an Infectious Substance label is not required on
an outer packaging, if the OSHA Biohazardmarking is used as prescribedin
29 CFR 1910.1030(g).CDC Etiologic Agent label must be used as prescribedin
42 CFR 72.3 and 72.6. A bulk package of RMWmust displaya BIOHAZARDmarking. §172.436, §172.438, §172.440, §172.441,
§172.323,§172.405(c),§172.429,§172.430,§172.432 §172.450 §172.442 §172.446 §172.411 §172.448
HAZARDOUS MATERIALS MARKINGS

Fumigant Marking
§173.25(a)(4)
§172.312(a) §172.322 §172.325 §172.332(a) §172.302(g) and §173.9 §172.313(a) §172.316(a)
Keep a copy of the Emergency Response Guidebook handy!

app
end
ix B
248
HAZARDOUS MATERIALS INCIDENTS:

HAZARDOUS MATERIALS WARNING PLACARDS
Hazardous Materials Warning Placards
Actual pllacard siize: 27
73 mm (10.8 in
nches) on
n alll siides
CLASS 1 Explosives CLASS 2 Gases CLASS 3 Flammable Liquid and Combustible Liquid CLASS 4 Flammable Solid,
SURVIVING THE INITIAL RESPONSE

SpontaneouslyCombustible, and
Dangerous When Wet
§172.522 §172.528
§172.523 §172.530
§172.542
§172.524 §172.532
§172.544 §172.546,§172.547,§172.548
§172.525 §172.540
For FLAMMABLE,placard 454 kg (1,001 lbs) or more. GASOLINEmay be used For FLAMMABLESOLID and SPONTANEOUSLY
* For Divisions 1.1, 1.2, or 1.3, enter division For NON-FLAMMABLEGAS, OXYGEN in place of FLAMMABLEplacard displayedon a cargo tank or portable tank COMBUSTIBLE, placard 454 kg (1,001 lbs) or
number and compatibilitygroup letter, when (compressed gas or refrigeratedliquid), and transporting gasoline by highway. Placard combustible liquid transported in bulk. more. For DANGEROUSWHENWET (Division 4.3),
required; placard any quantity. For Divisions 1.4, FLAMMABLEGAS, placard 454 kg (1,001 lbs) See §172.504(f)(2)for use of FLAMMABLEplacard in place of COMBUSTIBLE. placard any quantity.
1.5, and 1.6, enter compatibilitygroup letter, when or more gross weight.For POISON GAS FUEL OIL may be used in place of COMBUSTIBLE on a cargo or portable tank
required; placard 454 kg (1,001 lbs) or more. (Division 2.3), placard any quantity. transporting fuel oil not classed as a flammable liquid by highway.
CLASS 5 Oxidizer & Organic CLASS 6 Poison (Toxic) and CLASS 7 Radioactive CLASS 8 Corrosive CLASS 9 Miscellaneous Dangerous
Peroxide Poison Inhalation Hazard
§172.521
§172.556 §172.558 §172.560 A freight container, unit load device,
transport vehicle, or rail car which
Not required for contains non-bulk packagingswith
Placard any quantity - packages Placard 454 kg (1,001 lbs) or more. domestic transporta- two or more categories of hazardous
bearing RADIOACTIVE YELLOW-III tion. A bulk packaging materials that require different plac-
labels only. Certain low specific containing a Class 9 ards specified in Table 2 may be
activityradioactivematerials in material must be placardedwith DANGEROUSplac-
§172.550,§172.552 §172.504(f)(10),§172.554,§172.555 “exclusiveuse” will not bear the marked with the ards instead of the specific placards
label, but the radioactiveplacard is appropriateID number required for each of the materials in
For OXIDIZER and ORGANIC PEROXIDE For POISON (PGl or PGII, other than inhalation required for exclusiveuse shipments displayedon a Class 9 Table 2. However, when 1,000 kg
(other than TYPE B, temperature controlled), hazard)and POISON (PGIII), placard 454 kg of low specific activitymaterial and placard, an orange (2,205 lbs) or more of one category
placard 454 kg (1,001 lbs) or more. For (1,001 lbs) or more. For POISON-INHALATION surface contaminated objects panel, or a white of material is loaded at one loading
ORGANIC PEROXIDE (Division 5.2), Type B, HAZARD(Division 6.1), inhalation hazardonly, transported in accordancewith square- on-point facility, the placard specified in
temperature controlled, placard any quantity. placard any quantity. §173.427(b)(3)or (c). display. Table 2 must be applied.
PLACARDS I DENTIFICATION NUMBER DISPLAYS

Whitesquare background
required for placard for OR MUST BE DISPLAYED ON: (1) Tank Cars, Cargo Tanks, Portable
highwayroute controlled ORANGE PA
ANELS Tanks, and other Bulk Packagings; (2) Vehicles or containers
quantity radioactivematerial containing 4,000 kg (8,820 lbs) in nonbulk packages of only
and for rail shipment of certain a single hazardous material having the same proper shipping
explosivesand poisons, and
for flammable gas in a DOT and name and identification number; and (3) 1,000 kg (2,205 lbs)
113 tank car (§172.507 of materials poisonous by inhalation in Hazard Zone A or B.
and §172.510). §172.332 See §172.301(a)(3)and §172.313(c).
§172.527
Appropriateplacard must be used.
Response begins with identification!

Cix
end
ACRONYMS AND ABBREVIATIONS
app
ACGIH American Conference of Governmental Industrial Hygienists, Inc.
AFFF aqueous film-forming foam
CFR Code of Federal Regulations
CHEMTREC Chemical Transportation Emergency Center
EPCRA Emergency Planning and Community Right-to-Know Act of 1986
ERG Emergency Response Guidebook
ft2 square foot (feet)
ft3 cubic foot (feet)
gal gallons
GPM gallons per minute
IC incident commander
ICS Incident Command System
IDLH immediately dangerous to life and health
LEL lower explosive limit
LEPC Local Emergency Planning Committee
MSDS material safety data sheet(s)
NFPA National Fire Protection Association
NIOSH National Institute for Occupational Safety and Health
NTP National Toxicology Program
OPD overfill protection device
OSHA Occupational Safety and Health Administration
SARA Superfund Amendments and Reauthorization Act
SCBA self-contained breathing apparatus
SFPC structural firefighters’ protective clothing
STEL short-term exposure limit
TPQ threshold planning quantities
TWA time weighted average
UC Unified Command
UEL upper explosive limit
USFA United States Fire Administration
INDEX
Index Terms Links
Abandoned containers 231 235 238

Abbreviations 249
Absorbent booms (barriers) 44 118 131
Accidental releases 32
ACGIH threshold limit value 64
Acronyms 249
Action mode 219 245
strategy 221
tactics 221
task assignments 221
Action plans 219 225 245
thinking mode 219 225 245
action mode 219 245
waiting mode 219 222 245
Aggregate gross weight 138
Air supply 183
Air/ventilation system 121
Alarm 189 194
activation 189
threshold 189 194
Aluminum containers 97
Aqueous film-forming foam (AFFF) 199 204 208
Arrival at scene (response) 42
Assumptions/myths 3
Atmospheric hazards 188
Atmospheric monitors 183
operation 184
functional and full calibrations 185
general use 186
readings as basis for decision making 187
multiple hazards during incident 188
potential for inaccurate readings 189
This page has been reformatted by Knovel to provide easier navigation.
Index Terms Links
Atmospheric monitors (Cont.)

interpreting zero readings 192
key points 193
questions 194
references 195
Awareness level (training) 19
Battery (monitor) 184

Biohazard 147
Booms (barriers) 44 118 131
Bromoacetic acid 39
Building containment barriers 120
Building odor 172 175 179
Buildings (gas/vapor release) 121 172 175 179
Bulk/nonbulk capacity (containers) 85
Bulkheads/baffles 86 97
Bump test (monitor) 185
Burst pressure 112
Butane 75
Calibration (monitor) 185

calibration drift 185
calibration gas 186
Calibration drift 185
Calibration gas 186
Carbon monoxide detectors 172 180
Carcinogens 65
Cargo tank 88 141 149
Carrier responsibilities 52 59
Checklist (incident command system) 229 245
command structure 245
action plan 245
HAZMAT incidents 246
Checklist (incident information) 50
Chemical manufacturing/shipping 3

Index Terms Links
Chemical name 64 68 75 81
Chemical spelling 39 49 75
Chemical Transportation Emergency Center
(CHEMTREC) 53 58 70
Chemical/physical properties 66
Chloroacetic acid 39
Chloropicrin 71
Class B fires 197
Class B foam 197
description 197
polar versus
nonpolar solvents 198
types 199
producing foam solutions 201
amount needed 204
fire suppression capabilities 206
applying 210
key points 211
questions 212
references 213
Cleaning/removal/disposal (waste material) 22 237
contractors 237
Code of Federal Regulations —
Transportation (49 CFR 172) 133
Code of Federal Regulations —
Transportation (49 CFR 171.8) 11
Collision incidents 1
See also Transportation incidents.
Combined method (hazard identification) 166
Combustible gas 184
Combustible liquids 10 78
Command personnel 215 245
Command structure (incident management) 215 245
Composite method (hazard identification) 166
Compressed gas 10 46 91 112
Concentration (foam) 204 207 211
Concentration (gas) 188 193
Contact information 54

Index Terms Links
Contacting help 53
support contacts 54
information 54
Container abandonment 231 235 238
Container characteristics 85
general 85
capacity 85
special 88
openings 91
material temperature and pressure in container 94
key points 97
questions 98
references 99
Container damage 88 111
Container hazards 219
Container temperature/pressure 94 110 131
Containers 43 85 110 131
219 231 235 238
released contents 45
ongoing release 46
contents not released 46
characteristics 85
abandoned 231 235 238
Containing release (gas/vapor) 109 121
control within buildings 121
gas control valve operation 122
control with fog streams 122
Containing release (liquid) 109 114
temporary containment barriers on land 114
locating underground utilities 116
absorbent booms on water 118
underflow dams 119
building containment barriers 120
diluting releases with water 121
Containing release (solid) 109 123
Containment barriers 44 114 131
land 114
underground utilities 116

Index Terms Links
Containment barriers (Cont.)

water 118
underflow dams 119
building 120
diluting releases 121
construction materials 131
Containment basin (decontamination) 127
Contamination/decontamination 1 21 47 126
130 161 172 177
victims 1 47 172 177
first responders 126
Contents (containers) 43 49 109
released 44 49 109
ongoing release 44 46 49 109
not released 44 46 49 109
Contractors (cleanup) 237
Control valve operation 122
Corrosives 11 46 76 78
88 97 141
Cost reimbursement 240 243
Crime scene 231
detecting criminal activity 231
documentation 233
key points 235
questions 236
Criminal activity (detection) 231
Cryogenic temperature 95
Dams (barriers) 119

DANGEROUS placard 141 149
Dangerous-when-wet materials 78
Decision-making documents 61
Emergency Response Guidebook 61
Material Safety Data Sheet 64 69
chemical and physical properties 66
health hazards 67
obtaining MSDS 69
Index Terms Links
Decision-making documents (Cont.)

Hazardous Materials Guide for First Responders 71
key points 72
questions 73
references 74
Decontamination (personal exposure) 1 21 47 126
130 161 172 177
victims 1 47 172 177
Defensive actions/practices 3 25 47 109
preventing release 110
containing release of
liquid 114
containing release of gases/vapors 121
containing release of solid 123
protective actions 124
decontamination of first responders 126
key points 129
questions 131
references 132
Defining criteria (hazard class) 78
Definition/identification (HAZMAT) 7 75
types 10 75
Code of Federal Regulations—Transportation 11
OSHA Hazard Communication Standard 12
and Emergency Response Standard 13
Emergency Planning and Community
Right-to-Know Act of 1986 13
key points 15
questions 16
references 17
Diesel fuel 128 153 158
Diluting releases with water 121
Dilution ratio (foam) 204 207 211
Dispatching HAZMAT incidents 3 39 54 56
59
messages 3

Index Terms Links
Diversion wall 116

Documentation (crime scene) 233
Documents for decision-making 61
Emergency
Response Guidebook 61
Material Safety Data Sheet 64 69
chemical and physical properties 66
health hazards 67
obtaining MSDS 69
Hazardous Materials Guide for First Responders 71
key points 72
questions 73
references 74
Effluent/seepage control 101 127 131

Electrochemical sensors 183
Electrocution hazard 154 158
Emergencies 3 13 29 48
53 56 59 61
68 72 104 107
109 112 115 121
123 129 146 149
154 177
planning and
reporting requirements 30
release notification 32
planning 33
Emergency contacts 154
Emergency dispatch center 54 56 59
Emergency information 53
Emergency messages 126
Emergency Planning and Community Right-to-Know Act of
1986 (EPCRA) 13 29 36
Emergency planning 13 29
EPCRA 13 29 36
reporting requirements 30
Emergency release notification 29 32
Index Terms Links
Emergency Response Guidebook (ERG2004) 39 48 61 68

72 104 107 115
121 123 146 149
155 177
Emergency response 13 61 146
guidelines 61
telephone number 146
Environment evaluation 101
location 101
weather 103
time of day 104
taking care of
key points 107
questions 108
Environment of incident 43 101 219
evaluation 101
impacts 101 107
Environmental hazards 219
Environmental impacts 101 107
Environmental regulatory agencies 57
Evacuation 34 63 109 112
125 129
Evaluating environment 43 101 219
location 101
weather 103
time of day 104
taking care of first responders 106
key points 107
questions 108
Event escalation 1
collisions 1
patients 1
fires 1
Exception (placard) 137
Exempt facilities 32
Exemptions (MSDS) 70
Expansion ratio (gas) 95 110

Index Terms Links
Explosives 10 78
Exposure limits 8 64 67
Extremely hazardous substances 32
Facility entry 162 169

Fire hazard 164
Fire incidents 1 46 113 131
164 172 176 180
197 204
equipment 3 5
structure 113
hazard 164
suppression strategies 172 176 180
spill 204
Fire suppression foam 197
description 197
polar versus nonpolar solvents 198
types of Class B foam 199
producing Class B foam solutions 201
determining amount of foam needed 204
preplanning foam fire suppression capabilities 206
applying Class B foam 210
key points 211
questions 212
references 213
Fire suppression strategies 172 176 180
Firefighting equipment 3 5 126 129
177
protective
clothing 126 129 177
First responder facilities 106 108
First responder roles 19
non-HAZMAT team 20
suggested roles 20
key points 25
questions 26
references 27
Index Terms Links
First responders 1 19 106 108

126
rule of
thumb 1
key points 5
questions 6
roles 19
personal hygiene 106 108
facilities 106 108
contamination/decontamination 126
protective clothing 126 129 177
Fixed facility incidents 161
response 161
National Fire Protection
Association Standard 704 163
reality of incidents 166
key points 168
questions 169
references 170
Flammability hazards 10 16 46 76
78 135 141 148
164 175
Flammable gas 135
Flammable liquids 10 46 76 78
135 148 197 211
Flammable materials 10 46 76 78
135 141 148 197
211
Flammable solids 10 78
Flash point 10 16
Foam (Class B) 197
description 197
polar versus nonpolar solvents 198
types 199
producing solutions 201
amount needed 204
fire suppression capabilities 206
applying

Index Terms Links
Foam (Class B) (Cont.)

Class B foam 210
key points 211
questions 212
references 213
Foam amount needed (calculating) 210
Foam application 210
Foam dilution 199 204 207 211
dilution ratio 204 207 211
Foam solutions (producing) 201
Foam types (Class B) 199
Fog streams control (gas/vapor release) 122
Foodstuff 8
Four–digit identification number 77 80 136 140
144 149
display 80 140
Frosting (leak indicator) 121
Fuming trash incidents 172 174 180
Functional areas (command structure) 245
Functional calibration (monitor) 185
Gas control valve operation 122 131

Gas leak 11 39 121 172
175 179
buildings 121 172 175 179
Gas/vapor release containment 11 39 121 131
172 175 179
control within buildings 121
gas control valve operation 122
control with fog streams 122
Gases 11 39 78 121
131 172 175 179
Gasoline 8 12 90 94
187
Glycol leak 167

Index Terms Links
Handling/transportation (materials) 1 133 153

highway 133
railroad 153
Hazard classes (material) 11 78 81 137
144 149
Hazard identification process 166
Hazardous atmosphere 183
atmospheric monitors 183
Hazardous chemical 12 16 64 68
Hazardous Materials Guide
for First Responders 61 71 146 149
178
Hazardous materials. See HAZMAT.
Hazardous substance 13 15 32
HAZMAT characteristics 51 75
material identification 75
HAZMAT definition/identification 7 75 166
types 10 75
Code of Federal Regulations—Transportation 11
OSHA Hazard Communication Standard 12
and Emergency Response Standard 13
Emergency Planning and Community
Right-to-Know Act of 1986 13
key points 15
questions 16
references 17
HAZMAT gear 3 6
HAZMAT help 51
HAZMAT characteristics 51
contacting help 53
support contacts 54
key points 58
questions 59
references 60

Index Terms Links
HAZMAT incident dispatching 3 39 54 56

59
messages 3
HAZMAT incident management 1 39 51 215
245
dispatching 3 39 54 56
59
contacts 51
initial phase 215
command
structure 215
action plans 219 225
thinking mode 219 225
action mode 219
waiting mode 219 222
safe work practices 223
key points 228
questions 229
references 230
HAZMAT incident stages 44 49
HAZMAT incidents 1 40 44 49
215 245
stages 44 49
HAZMAT warning labels/placards 247
Health departments 57
Health hazards 16 67 163
Heating oil tank spills 172
Hierarchy (material identification) 80
Highway departments 57
Highway system 102
Highway transportation incidents 133
characteristics
of labels and placards 133
use of labels and placards 136
four-digit identification numbers 140
use of DANGEROUS placard 141
interpreting labels, placards, and markings 142
shipping papers 144

Index Terms Links
Highway transportation incidents (Cont.)

additional hazards 148
key points 149
questions 150
references 151
Home heating oil tank spills 172 180
Hot wash session (training) 34
Household hazardous materials 2 6
Hydrochloric acid 96
Identification number (display) 140

cargo tanks 141
Identification number (material) 77 80 136 140
144 149
display 80 140
Identifying material 21 43 64 71
75 136 140 144
149 161 166
name of material 75
identification number 77 80 136 140
144 149
hazard classes 78
hierarchy of material identification 80
key points 81
questions 82
references 83
Ignition sources 175
Immediately dangerous to
life and health (IDLH) 67
Incendiary devices 233
Incident command system (ICS) 215 228 245
checklist 229 245
Incident command system checklist 229 245
action plan 245
HAZMAT incidents 246
Incident commander (IC) 215 228
Index Terms Links
Incident crime scene 231

detecting criminal activity 231
documentation 233
key points 235
questions 236
Incident management 1 57 215
initial phase 215
action plans 219 225
thinking mode 219 225
action mode 219
waiting mode 219 222
safe work practices 223
key points 228
questions 229
references 230
Individual method
(hazard identification) 166
Industrial/commercial areas 102
Information system 134 149
Inhalation hazard 103 107
Initial phase
(incident management) 215 245
Inline foam eductors 201 211
In–place protection 109 125
Instability hazards 148 155 164
Insulated container 88 96
Insulation effectiveness 96
Interpretation
(labels/placards/markings) 142
Intervention risk 20
Ionizing radiation 10
Isobutylene 80
Isolation (incident) 21 63 107 124
129 161
defining area 124
maintaining area 124

Index Terms Links
Labels and placards 77 80 133 149

247
four–digit identification numbers 77 80 136 140
144 149
display 80 134 140
characteristics 133
placement 133 141
usage 136
nonbulk containers 137
cargo tanks 141
DANGEROUS placard 141
interpretation 142
Land containment barriers 114
Leak retention basin 115
Legal support 54
Lighting (portable) 104 108
Liquefied gases 95
Liquid release containment 114
temporary containment
barriers on land 114
locating underground utilities 116
absorbent booms on water 118
underflow dams 119
building containment barriers 120
diluting releases with water 121
Loading/unloading accessories 92
Local Emergency Planning
Committee (LEPC) 30 36
Locating underground utilities 116
Location evaluation 101
Logistical support 54
Lower explosive limit (LEL) 187
Manufacturer information 51 58
Manufacturer responsibilities 59

Index Terms Links
Marking (number) 134

See also Four–digit
identification number AND Labels and placards.
Material guides 71
Material hazards 219
Material identification 21 43 64 71
75 136 140 144
149 161 166
name of material 75
identification number 77 80 136 140
144 149
hazard classes 78
hierarchy 80
key points 81
questions 82
references 83
Material Safety Data Sheet (MSDS) 9 13 30 32
36 39 48 52
61 64 75 136
146 156 162 168
179
obtaining 69
means of access 70
required access 70
exemptions 70
means of access 70
Materials handling/transportation 1 133 153
highway 133
railroad 153
Medical care 21 161 179
See also Personal exposure.
Mile markers (railroad) 155 158
Miscibility 66
Monitor readings 187
basis for decision making 187
potential for inaccuracy 189

Index Terms Links
Monitors (atmospheric) 183

operation 184
functional and full calibrations 185
general use 186
readings as basis for decision making 187
multiple hazards during incident 188
potential for inaccurate readings 189
zero readings 192
key points 193
questions 194
references 195
Motor carrier officers 57
Myths/assumptions 3
Name (material) 64 68 75
National Fire Protection
Association Standard 704 163 168
NFPA sign/symbols 163 169
National Incident Management System (NIMS) 226
National Institute for Occupational
Safety and Health (NIOSH) 188
NIOSH Pocket Guide to Chemical Hazards 188
Nitrogen 96 98
Nonbulk containers 133 137 149
Nonliquefied gases 95
Nonpolar solvents 198 211
Nonpressurized containers 112
Nonregulated materials 137
Not otherwise specified (product) 76 81
Notification procedures 29 32 36 246
required 246
Notifications required 246
Nozzle (foam) 202 210
Occupational Safety and Health Act of 1970 20

Index Terms Links
Occupational Safety and Health Administration. SEE

OSHA.
Odors 103 172 175 179
in buildings 172 175 179
Oil spills 172 180
Ongoing release 44 46 49 109
Operations level (training) 19
Organic peroxides 11 78
OSHA Hazard Communication Standard
(29 CFR 1910.1200) 12 15 64 68
73
OSHA Hazardous Waste Operations and Emergency
Response Standard (29 CFR 1910.120) 13 15 19
109
OSHA Respiratory Protection Standard (29 CFR 1910.134) 67
Overfill protection device (OPD) 95 98
Oxidizers/oxidizing agents 10 78 121
Oxygen 10 12 95 98
191 193
Packing group 149

Passive/active response 20
Patient breathing incidents 1
Patient/victim contamination 1 47 172 177
breathing incidents 1
clothing 179
Permissible exposure limit 64
Permissive placarding 137 150
Personal exposure 1 15 21 37
39 47 64 67
71 80 126 161
168 172 172 177
188
victims 1 47 172 177
Personal hygiene (first responders) 106 108
Phonetic alphabet 41 49
Index Terms Links
Physical hazards 12 16 65
Physical/chemical properties 66
Placard exception 137
Placard placement 134
Placarding cargo tanks 141
Plan evaluation 34
Planning (response) 3 29
emergency planning and reporting requirements 30
emergency release notification 32
emergency planning 33
evaluation 34
key points 36
questions 37
references 38
Poisons 10 78 136 140
Polar solvents 198 211
versus nonpolar solvents 198
Portable gas monitors 183
Potential problems 1 25 39 148
166
collisions 1
patients 1
fires 1
responder
involvement 39
Precedence of Hazard Table
(49 CFR 173.2(a)) 12
Pressure relief device 90 94 97 110
Pressure/temperature (container) 94
liquefied gases 95
nonliquefied gases 95
Pressurized containers 44 90 97 110
129
pressure relief device 90 94 97 110
Preventing release 109
pressurized containers 110
nonpressurized containers 112
water cooling of containers 113

Index Terms Links
Preventing release (Cont.)

vehicle accidents 113
structure fires 113
Primary hazard 12 136
Propane 95 110 175 187
Property owner 57
Protective action distances 63 107
Protective actions 63 107 109 124
161
distances 63 107
defining/maintaining isolation areas 124
evacuation and in–place protection 125
Protective clothing 126 129 177
Public relations/communication 13 34 124 131
Radio frequencies (responders) 50

Radioactive materials 10 78
Railroad highway vehicles 155 158
Railroad transportation incidents 153
preparation 154
right of way 154 158
response 155
vehicles 155 158
key points 158
questions 159
Readings (atmospheric monitors) 187
basis for decision making 187
potential for inaccuracy 189
Recovery of vehicles
(HAZMAT incident) 239 243
Redundancy (containment barriers) 120 131
Regulations/rules 3 8 11 29
57 61 136 150
163
decision-making documents 61
Reimbursement (costs) 240 243
Index Terms Links
Release notification 29 32 36
exempt facilities 32
Release prevention 110
pressurized containers 110
nonpressurized containers 112
water cooling of containers 113
vehicle accidents 113
structure fires 113
Reporting requirements 29
Required access (MSDS) 70
Required notifications 246
Rescue 177
Residential carbon monoxide detectors 172 180
Resource location 23 25 34 54
contacts 54
Responder involvement/actions 1 39
event escalation 1
dispatching HAZMAT incidents 40
response and arrival at scene 42
material, container, and environment 43
stages of HAZMAT incident 44
released contents 45
ongoing release 46
not released contents 46
defensive actions 47
key points 49
questions 50
Response and arrival at scene 3 42
considerations 3
equipment 3
Response equipment 3
Response procedures 34 42 155
Responsible party 9 48 50 57
59
Restoration/remediation (scene) 22 237 241
Right-of-way (railroad) 154 158

Index Terms Links
Risk/risk assessment 3 7 20 26
34 43 67 188
219 224 228
Rollover damage 91
Routine HAZMAT incidents 171
home heating oil tank spills 172
residential carbon monoxide detectors 173
fuming trash containers/collection trucks 174
suspicious odors in buildings 175
defensive fire suppression strategies 176
contaminated patients 177
key points 180
references 181
Rule of thumb 1
Rules/regulations 3 8 11 29
57 61 136 150
163
decision-making documents 61
Running leak (railroad) 153
Safe work practices 223

Safety officer 215 228 245
Scene response and arrival 42
Scene restoration
(HAZMAT incident) 22 237 241
Self-contained breathing
apparatus (SCBA) 68 95 177 186
221 223
Shipper responsibilities 52 59
Shipping name 62 144
Shipping papers 43 48 53 56
58 62 69 76
144 154 159
access 147
Short-term exposure limit (STEL) 188
Solid release containment 14 123
Solubility 66
Index Terms Links
Special characteristics (containers) 88

container openings 91
pressure relief devices 94
Specific gravity 66
Spill fire 204
Spontaneously combustible materials 78
Stages (HAZMAT incident) 44 49
Standard operating procedures (SOP) 224
Standard System for the Identification
of the Hazards of
Materials for Emergency
Response (NFPA Standard 704) 163
Steel containers 97
Strategy (action mode) 221
Strategy 220
Structural firefighters protective clothing (SFPC) 126 129 177
Structure fires 113
Subsidiary hazard 12 136
Sulfuric acid 75
Superfund Amendments and
Reauthorization Act of 1986 (SARA) 29
Supplied-air respirator (SAR) 68
Support contacts 54
case study 57
Synonyms (names) 75 81
Systems effects 101 107
Tactics (action mode) 220

Taking care of responders 106
Tank car (railroad) 155
Tank-within-tank 88
Task assignments (action mode) 220
Technical support 54
Temperature/pressure (container) 94
liquefied gases 95
nonliquefied gases 95
Temporary containment barriers (land) 114
Index Terms Links
Thinking mode 219 225 245

Threshold limit value 64
Threshold planning quantity (TPQ) 32
Tier reports 30
Tier I 30
Tier II 30
Time of day evaluation 104
Toxic by inhalation (TIH) 62 124
Toxic chemical release reporting 29
Training 19 34 122 185
221 237
Transfer leak (railroad) 153
Transportation (materials) 1 133 153
highway 133
railroad 153
Transportation incidents (highway) 133
characteristics
of labels and placards 133
use of labels and placards 136
four-digit identification numbers 140
use of DANGEROUS placard 141
interpreting labels, placards, and markings 142
shipping papers 144
additional hazards 148
key points 149
questions 150
references 151
Transportation incidents (railroad) 153
preparation 154
right of way 154 158
response 155
vehicles 155 158
key points 158
questions 159
Trash containers/collection trucks 172 174 180
2-methyl–1-butene 75
Types (HAZMAT) 10
explosives 10

Index Terms Links
Types (HAZMAT) (Cont.)

compressed gases 10
flammable/combustible liquids 10
flammable solids 10
oxidizers 10
poisons 10
radioactive materials 10
corrosives 11
U.S. Consumer Product Safety Commission 180

U.S. Department of Transportation
49 CFR 172.101 13 15
U.S. Fire Administration (USFA) 71
Underflow dams 119
Underground utilities 57 102 108 116
locating 116
Unified Command (UC) 217 229
Usage (labels and placards) 136
vehicles transporting nonbulk containers 137
display 140
identification numbers 140
cargo tanks 141
Utility system 102
Vapor density 66
Vehicle accidents 113 239 243
recovery 239 243
Vehicle labels and placards 77 80 133 149
247
four-digit identification number 77 80 136 140
144 149
display 80 134 140
characteristics 133
placement 133 141

Index Terms Links
Vehicle labels and placards (Cont.)

usage 136
nonbulk containers 137
cargo tanks 141
interpretation 142
Vehicle recovery 239 243
Vehicular hazards 224
Venting (gas) 95 110
Verification of Calibration for
Direct-Reading Portable Gas Monitors 186
Victim contamination/decontamination 1 47 172
177
See also Personal exposure.
Victim relationship 47
Waiting mode 219 245

Waste removal/cleaning/disposal 22 237
contractors 237
Water containment barriers 118
Water cooling (containers) 46 113
Water decontamination 178
Water dilution (releases) 121
Water reactions 21 24
Waterways system 102
Weather evaluation 103 106
Wind 103 107
Workplace chemical 12
Zero readings (interpretation) 192

Libro Fire Engineering HazMat Incidents Surviving The Initial Response

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Libro Fire Engineering HazMat Incidents Surviving The Initial Response

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HAZARDOUS MATERIALS INCIDENTS:

SURVIVING THE INITIAL RESPONSE

Director: Mary McGee

Library of Congress Cataloging-in-Publication Data

Printed in the United States of America

1 Beyond the Rule of Thumb . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2 What Is a Hazardous Material?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3 The Role of First Responders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

4 Planning for a Hazardous Materials Incident. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

5 How Not to Become Part of the Problem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

6 Who First Responders Should Call to Get Help . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

7 Documents First Responders Can Use for Effective Decision Making. . . . . . . . . . . . . . . . . . . . . . 61

8 Identifying the Material . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75

10 Evaluating the Environment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101

11 Defensive Actions for First Responders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

12 Highway Transportation Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133

13 Railroad Transportation Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 153

14 Fixed Facility Incidents. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 161

15 “Routine” Hazardous Materials Incidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 171

16 Understanding Atmospheric Monitors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 183

17 Understanding Class B Foam . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197

18 Managing the Initial Phase of a Hazardous Materials Incident . . . . . . . . . . . . . . . . . . . . . . . . . 215

19 Is the Incident a Crime Scene? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 231

20 Cleanup, Recovery, Reimbursement, and Scene Restoration . . . . . . . . . . . . . . . . . . . . . . . . . . . 237

Appendix A Incident Command Checklist . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 245

Appendix B Hazardous Materials Warning Labels and Placards . . . . . . . . . . . . . . . . . . . . . . . . . . 247

Appendix C Acronyms and Abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 249

A firefighter once referred to a hazardous materials

into a pool of molten plastic, thus

Types of Hazardous Materials

Code of Federal Regulations—Transportation

OSHA Hazard Communication

OSHA Hazardous Waste Operations

The Emergency Planning and Community

Administration” and “any substance present as a solid in any

3 Ibid., pp. 157–158.

4 Ibid., pp. 126–128.

6 Ibid., p. 199 - 200.

7 Ibid., pp. 271–272.

10 Code of Federal Regulations. 49 CFR § 171.8, http://www.myregs.com/dotrspa/.

11 Code of Federal Regulations. 49 CFR § 173.136(a), http://www.myregs.com/dotrspa/.

13 Code of Federal Regulations. 49 CFR § 173.140, http://www.myregs.com/dotrspa/.

15 Code of Federal Regulations. 29 CFR § 1910.1200(c), http://www.osha.gov.

18 Code of Federal Regulations. 29 CFR § 1910.1200(b)(2), http://www.osha.gov.

19 Code of Federal Regulations. 29 CFR § 1910.120(a)(1)(v), http://www.osha.gov.

20 Code of Federal Regulations. 29 CFR § 1910.120(a)(3), http://www.osha.gov.

21 Code of Federal Regulations. 49 CFR § 172.1, http://www.myregs.com/dotrspa/.

22 Code of Federal Regulations. 49 CFR § 1910.120(a)(3), http://www.myregs.com/dotrspa/.

Who Are First Responders?

Suggested Roles for First Responders

But the first responders must beware! While

2 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(ii), http://www.osha.gov.

3 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(iii), http://www.osha.gov.

4 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(iv), http://www.osha.gov.

5 Code of Federal Regulations. 29 CFR § 1910.120(q)(6)(ii), http://www.osha.gov.

6 Code of Federal Regulations. 40 CFR § 311.1, http://www.access.gpo.gov/nara/cfr/waisidx_04/40cfr311_04.html.

7 Code of Federal Regulations. 40 CFR § 311.2, http://www.access.gpo.gov/nara/cfr/waisidx_04/40cfr311_04.html.

Emergency Planning and Reporting Requirements

Facility Identification Owner/Operator Name

Tier Two Street Mail Address

Physical Storage Codes and Locations

PLANNING FOR A HAZARDOUS MATERIALS INCIDENT

Emergency Release Notiﬁcation