Chapter 8

HAZWOPER

Section1 Presentation
Section 2 Narrative
 HAZWOPER
29 CFR 1910.120
Hazardous Waste
Operations and
Emergency
Response

This presentation is intended to be only an overview of HAZWOPER. It would

take at least 40 hours and practical training for you to become qualified to
work near HAZMATs under this standard. When you complete this chapter
you will have an understanding of the application of the HAZWOPER
standard.

There are some topics like Chemical Terms and Concepts for example, that
would normally be a part of HAZWOPER but in this course you cover them
somewhere else.
 HAZWOPER
HAZWOPER Application
Application
¾When Conflicts With Any
Other Federal Regulation
ƒ Higher level of employee
safety prevails

HAZWOPER sometimes applies along with EPA standards. When there is a

conflict use the regulation that provides the higher level of employee safety.
 HAZWOPER
HAZWOPER Application
Application
¾Hazardous Waste
Sites
¾Treatment Storage &
Disposal Facilities
¾Emergency Response
The standard applies primarily to these three areas.
 ¾29 CFR 1910.120(e)
ƒ General
Site Workers
¾29 CFR 1910.120(p)
ƒ TSD Facilities
¾29 CFR 1910.120(q)
ƒ Emergency Response
¾Most industry under (q)

If the HAZWOPER standard applies to you it is most likely to be under section

q.

This standard would be much simpler if it were divided into three separate
standards as illustrated above. Take care when reading the standard that you
are reading the correct section.
Emergency Response
Vs.
Incidental Release
 Emergency
Emergency Response
Response Vs.
Vs.
Incidental
Incidental Release
Release
¾Incidental Release -
controlled by employees in
immediate work area; poses
no threat to life/health; no
special PPE required
¾Emergency Response -
Controlled by workers outside
work area or using special
PPE
These definitions are important in determining whether or not the
HAZWOPER standard applies to you. If the only spills or leaks that your
employees clean up are incidental releases and you leave emergency response
to the public sector then this standard has little impact on you. But first let’s be
sure we understand the definition of incidental release. The definition is clear
enough when it says the spill or leak can pose absolutely no threat to life or
health. It is also fairly clear when it says if the person who cleans it up has to
put on any PPE first then it is an emergency response and you must comply
with all requirements of the HAZWOPER standard. It’s a little less clear to say
that the spill has to be controlled by employees in the immediate work
area. This means that the people that work around this material all the time are
the ones who clean it up. If anyone from another part of the facility or your
maintenance crew has to respond for the cleanup then that is emergency
response.
 Uncontrolled
Uncontrolled Release
Release
¾ Accidental release of
a hazardous
substance from its
container

Where the standard mentions uncontrolled release, it simply means an accidental

release of a hazardous substance from its container.
 HAZWOPER
HAZWOPER Applies
Applies to
to Spills
Spills
and
and Leaks
Leaks of
of Hazardous
Hazardous Wastes
Wastes
and
and Hazardous
Hazardous Substances
Substances

Hazardous Wastes
Vs.
Hazardous
Substances
Hazardous waste, hazardous substance, hazardous material, and HAZMATs
are often used interchangeably. The standard applies if you contain or cleanup
a spill or leak of any material that may be hazardous to people or to the
environment.
 OSHA
OSHA defines
defines hazardous
hazardous
substances
substances in
in terms
terms of
of situations
situations
or
or conditions
conditions

¾Any chemical
that will harm a
person
 HAZWOPER
Training
Requirements
 Site
Site Workers
Workers or
or TSD
TSD TRAINING
TRAINING

¾ 24 hour
¾ 40 hour
¾ Supervisor
¾ Refresher

The timeline for HAZWOPER training is confusing as it is written in the

standard. It is explained in all three sections. Since we’re most interested in
emergency response we will look at the normally accepted 24 hour, 40 hour,
supervisor, and refresher training requirements.
 Emergency
Emergency Responders
Responders
¾Awareness Level - 4 to 8 hrs.
ƒ recognition
¾Operations Level - min. 24 hrs.
ƒ defensive operation

¾Technician Level - min. 40 hrs.

ƒ offensive operations
¾Specialist Level - 40+ hrs.
ƒ various specialized areas

¾Incident Commander - 48+ hrs.

ƒ special training in ICS and termination
¾Refresher - min. 8 hrs.
ƒ at least annual

These are the normally accepted minimum training requirements. But they are
far less than they need to be. It is impossible to properly train a Hazmat
Technician in 40 hours unless he’s been trained to respond to only one or two
types of chemical spills with neither being very dangerous. Professional
hazmat teams have hundreds of hours of training. Don’t let HAZWOPER
training give your emergency responders a false sense of security that may get
them hurt or killed.
 ¾(q)(6)(ii) operations level are trained to
respond in a defensive fashion without
actually trying to stop the release and shall
have received at least eight hours of
training or competency in:
- what hazardous substances and risks
- potential results of HAZMAT incidents
- recognize hazardous substances
- identify the hazardous substances
- the role of the first awareness level
- emergency response plan
- DOT Emergency Response Guidebook
- ability to make
abilitymake appropriate
appropriate notifications
notifications
- basic hazard/risk assessment
- personal protective equipment
- basic hazardous materials terms
- basic control, contain/confine operations
- decontamination procedures
- relevant SOPs and termination

Here the standard seems to say that operations level only requires eight hours
of training.
 ¾(q)(6)(iii) Technicians respond for the
purpose of stopping the release and shall
have received at least 24 hours of training
equal to the first responder operations level
AND in addition have competency in:
- emergency response plan
- field survey instruments
- Incident Command System.
- personal protective equipment
- hazard and risk assessment techniques
- control, containment, confinement ops
- decontamination procedures
- termination procedures
- chemical/toxicological behavior

But here it requires the technician to have at least “24 hours of training equal
to the first responder operations level” and competency in the other areas
listed. So here the standard seems to say that operations level requires 24 hours
and that is the generally accepted minimum. Nowhere does it actually say that
a technician requires a minimum of 40 hours, but it is generally accepted that
the basic 24 hours would require an additional 16 hours to attain competency
in the listed areas. But remember the safety of your people comes first so give
them the training that they need, even if it takes 200 hours.
 Emergency Plans
¾Emergency Action Plans
ƒ Only one needed if there is no
response and everyone
evacuates!
¾Emergency Response Plans
ƒ Procedures to Intercede in the
emergency
¾Site Safety & Health Plan
ƒ Ensures on site safety
There are three different plans required if you have emergency responders as
listed above. If you have no emergency responders and everyone evacuates in
the event of a spill or leak then you only have to have the Emergency Action
Plan
 Site Safety Plan
Requirements
Requirements
- Name Key Personnel,
Alternates, Health & Safety
Personnel
- Task/Operation Safety &
Health Risk Analysis
- Employee Training
- Personal Protective
Equipment

This plan, like other safety plans and programs, must be site-specific. Do not
use the standard as a fill in the blank document. For example, you will actually
name your key personnel and all of your responders in the plan. You will
explain how you will perform a safety and health risk analysis. You will
explain what is covered in your employee training, when training is provided,
provisions for refresher training, and whose responsibility it is to train.
 - Air Monitoring Equipment
- Sampling Techniques
- Personnel Medical
Monitoring
- Site Control Measures
- Decontamination
Procedures
- Emergency
Planning/Medical Facilities
Each of these requirements – site-specific.
- Confined Space Procedures
- Medical Surveillance
Program
- Weather-Related Problems
- Buddy System
- Communications
(Visual/Verbal)
- Spill Containment
 HAZWOPER
EXERCISE

Use a copy of the HAZWOPER standard (if you do not have one you can find
one at www.OSHA.gov) and complete the following exercise. It will give you
a general understanding of the standard. The answers follow the questions, so
don’t cheat. Look up the answer first before you go to the next slide.
1. The scope and application of 29
CFR 1910.120 indicates the
standard applies to five distinct
groups of workers. Any employees
who are exposed or potentially
exposed to hazardous substances
including hazardous waste and
who are engaged in one of what
five operations are covered by the
Hazardous Waste Operations and
Emergency Response final rule?
 HAZWOPER
HAZWOPER Scope
Scope
(1) Clean-up
(2) Corrective Actions
RCRA
(3) Voluntary Clean- up
(4) Operations at TSDF,
pursuant to RCRA
(5) Emergency Response
Operations
2. 29 CFR 1910.120
specifically states that in
the event of an overlap
between itself and
another standard, which
standard will apply?
 HAZWOPER
HAZWOPER Application
Application
¾When Conflicts With Any
Other Federal Regulation
ƒ Higher level of employee
safety prevails
3. Define "Emergency
Response" vs.
"Incidental Release."
 Emergency
Emergency Response
Response vs.vs.
Incidental
Incidental Release
Release
¾Incidental Release -
controlled by employees in
immediate work area (who
normally handle the material);
poses no threat to life/health;
no special PPE required
¾Emergency Response -
controlled by workers outside
work area or using special PPE
 Factors
Factors to
to Consider
Consider
¾Quantity
¾Exposure Potential
¾Toxicity, flammability,
reactivity, corrositivity
¾Confined spaces or
ventilation
¾PPE knowledge/other
training
¾Do these employees
normally handle
4. Explain
"Uncontrolled
Release."
Uncontrolled
Uncontrolled Release
Release
¾ Any accidental
release of a hazardous
substance from its
container
5. Define "Hazardous
Waste" and "Hazardous
Substance" as per 29
CFR 1910.120.
OSHA
OSHA Defines
Defines Hazwaste
Hazwaste in
in terms
terms
of
of EPA
EPA and
and DOT
DOT
¾Two categories
ƒ Listed Wastes
• over 400 listed in four lists in
RCRA regulations
ƒ Characteristic Wastes
• Ignitable
• Corrosive
• Reactive
• Toxic
 OSHA
OSHA defines
defines hazardous
hazardous
substances
substances in
in terms
terms of
of situations
situations
or
or conditions
conditions

¾Any chemical
that will harm a
person
 Hazardous
Hazardous Atmospheres
Atmospheres

¾Atmospheric Testing
¾Atmospheric Monitoring
What’s the difference?
 Hazardous
Hazardous Atmospheres
Atmospheres

¾Atmospheric Testing
ƒ priorto entry
¾Atmospheric Monitoring
ƒ during entry
 Atmospheric
Atmospheric Testing
Testing
1st Oxygen
ƒ OSHA Limits?
2nd Flammability
ƒ OSHA Limits?
3rd Toxics
ƒ OSHA Limits?
4Stratified Atmospheres?

You must test the atmosphere in this order. One reason is that your meter is
calibrated in the normal atmosphere. If the atmosphere contains more or less
oxygen it will nullify your flammability test and some of your toxics test.

A stratified atmosphere simply means that because of different vapor densities

gases or vapors could be in layers in the area you are testing so you must test
at various heights.
 Atmospheric
Atmospheric Testing
Testing
1st Oxygen
ƒ 19.5% to 23.5%
2nd Flammability
ƒ 10% LEL
3rd Toxics
ƒ PEL
4Stratified Atmospheres
 Atmospheric
Atmospheric Testing
Testing

“The absence of
evidence is not
evidence of
absence”
 Atmospheric
Atmospheric Monitoring
Monitoring

¾Periodic Vs Continual
¾Periodic Logging
ƒ why?

The standard only requires periodic monitoring and it doesn’t designate the
period of time. However, employees are much much safer with continual
monitoring. That means that you put a meter that continually monitors
the atmosphere on the employees who are entering the hazardous area .
 Atmospheric
Atmospheric Monitoring
Monitoring
Trends
Trends
Oxygen 21% 20.4% 19.9% 19.7%
Flammable 0 2% 4% 7%
CO 0 0 0 0
H2 S 0 0 0 0

Having the workers inside the hazardous area call out by portable radio
periodically allows the attendant or supervisor to log the readings and watch
for trends. In the example above when the entrants entered you had 21%
oxygen, zero flammables, and zero toxics of the toxics you tested for. You can
see in the table something flammable is beginning to enter the space and
displace oxygen. You should not wait until the flammable level reaches the
OSHA limit at around 10% of LEL. As soon as you see this occurring you should
immediately pull your entrants back to a safe area.
¾Decontamination
 DECONTAMINATION
DECONTAMINATION
¾Removing Potentially
Harmful Contaminants From
Individuals & Equipment to:
ƒ Reduce the spread of
contamination from work area
ƒ Prevent inadvertent and
unnecessary contact with
contaminated materials
 FACTORS
FACTORS THAT
THAT DETERMINE
DETERMINE
NATURE
NATURE OF
OF DECONTAMINATION
DECONTAMINATION
¾Type of Contaminants
¾Level of Contaminants
¾Level of PPE Required
¾Work Function
¾Location of Contaminants
¾Written Decon Plan
 DECONTAMINATION
DECONTAMINATION
PROCEDURES
PROCEDURES
¾Assume Personnel Grossly
Contaminated
¾Determine Level of PPE and
Specific Equipment to be Worn
by Decon Personnel
¾Determine Means of Decon
ƒ Flushwith water?
ƒ Chemical Altering?

Be careful in flushing with water. You must contain the water and treat it as a
hazardous waste. Sometimes decontamination of PPE is not possible or not
feasible. In these cases, the PPE should be placed in drums and treated as
hazardous waste.
 DECONTAMINATION
DECONTAMINATION
PROCEDURES
PROCEDURES
¾Properly Decontaminate
ƒ Each Contaminated Person
ƒ Each Piece of Protective Clothing
ƒ Each Piece of Equipment

¾Separate Each Operation by

a Minimum of 3 ft.
¾Adapt Original Decon Plan
to Actual Conditions
 DECONTAMINATION
DECONTAMINATION
PROCEDURES
PROCEDURES
¾Decontamination of
Personnel
ƒ Remove Protective Clothing
• Starting with the Most
Heavily Contaminated
• Ending with the Least
Contaminated
 DECONTAMINATION
DECONTAMINATION
PROCEDURES
PROCEDURES
¾Disposal of
Decontamination Materials
¾Appropriate Decon Methods
ƒ Typeof Contaminant and
Associated Respiratory and
Skin Hazards
¾Suitable Location
 DECON
DECON ZONE
ZONE

COLD WARM HOT

ZONE ZONE ZONE

1 2 3
The decontamination zone is a secure area to which only entrants and the
decontamination workers are allowed. HAZMATs leave the hot zone and enter
the warm zone but they do not proceed from there.
 THREE
THREE WORK
WORK ZONES
ZONES
¾SUPPORT
#1 ZONE
ƒ Command Post
“COLD” ƒ No
Contamination
ƒ Normal Work
Clothes
The cold zone is completely safe from any HAZMAT exposure and may be
very remote from your hot zone.
 THREE
THREE WORK
WORK ZONES
ZONES

#2 ¾CONTAMINATION
REDUCTION ZONE
PPE Required
“WARM”
THREE
THREE WORK
WORK ZONES
ZONES

#3 ¾EXCLUSION ZONE
ƒ Contamination
ƒ PPE Required
“HOT”
 Incident
Incident Command
Command and
and
Termination
Termination
¾Ensuring the Safety of
Operating Forces
¾Ensuring That Someone Is
Always in Charge
¾Conforming to Laws and
Standards
¾Efficiently Utilizing Resources
We are going to do a very quick overview of Incident Command and
Termination. This is far from sufficient to qualify you as an incident
commander. FEMA offers some excellent online courses that we would
encourage you to take.
Management
Management Concepts
Concepts of
of the
the ICS
ICS
‰Division of Labor
‰Lines of Authority
‰Delegation
‰Unity of Command
‰Span of Control
‰Line/staff Functions
‰Coordination
88 Major
Major Components
Components of
of the
the ICS
ICS

¾Common Terminology
¾Modular Organization
¾Comprehensive Resource
Command
¾Unified Command
Structure
88 Major
Major Components
Components of
of the
the ICS
ICS
¾Consolidated Action Plans
¾Manageable Span of
Control
¾Designated Incident
Facilities
¾Integrated
Communications
Incident
Incident Command
Command System
System
Functions
Functions and
and Structures:
Structures:
¾the Ultimate
Responsibility for
Executing These
Functions Rests with the
Incident Commander
 Incident
Incident Command
Command System
System
Functions
Functions and
and Structures:
Structures:
¾The Nature and Complexity
of the Incident Determines:
ƒ Specific Development of an
Organizational Structure
and
ƒ the Level of Delegation of
Authority/Responsibility
Within this ICS Organization Are
Five Major Functional Areas of
Responsibility:
ƒCommand
ƒOperations
ƒPlanning
ƒLogistics
ƒFinance
‰Command Staff:
uSafety
uLiaison
uPublic Information
 COMMAND

Sample
Sample Safety LIASON
ICS
ICS PIO LOGISTICS

Structure
Structure FINANCE PLANNING

OPERATIONS

SAFETY OPS SECTOR COM

DECON SECTOR COM

SECTOR COM SECTOR COM

SECTOR COM SECTOR COM

 Incident
Incident Termination
Termination
¾Command Activities That Take
Place After Incident Stabilized:
ƒ Disengagement and Termination Can
Take Considerable Time
• Functions Such as Logistics and
Finance May Increase in Importance
ƒ Rotating Personnel
• the initial response personnel should
be relieved ASAP
ƒ Decontamination of Personnel
ƒ Decontamination of Equipment
 ¾Medical
Surveillance

The medical surveillance program does not apply to everyone in your facility,
but for those to whom it does apply it can be cumbersome. It can also be a life
saver. The HAZWOPER standard will give you guidance on what areas have
to be covered by your plan.
 Medical
Medical Surveillance
Surveillance Required
Required
¾Employees exposed at or
above PELs 30 days or more
¾Employees wearing respirators
30 days or more per year
¾Employees who are injured, or
become ill from contamination
ƒ example - Bloodborne Pathogens
¾Members of HAZMAT teams

All HAZMAT team members must be under a medical surveillance program.

That means your emergency responders must be under a medical surveillance
program.

Any employee who is exposed at or above the PEL of any chemical for 30
days or more per year must be under a medical surveillance program.

Any employee who wears a respirator for 30 days or more per year must be
under a medical surveillance program.

Any employee who is injured or becomes ill from contamination to a HAZMAT

must be under a medical surveillance program.
 Medical
Medical Surveillance
Surveillance Program
Program
¾Content
ƒ Depends upon potential
exposures
¾Baseline Monitoring
¾Annual Physical
¾Exposure Physical
¾Signs/Symptoms Physical
¾Exit Physical
The content of your medical surveillance program will depend upon the types
of potential exposures that you have in your facility. Each potential HAZMAT
spill or leak would be included.

The concept of a medical surveillance program is to provide a physical

examination that tests for any damage from any of your potential exposures.
This initial physical is called the baseline. By providing subsequent physicals
and comparing them back to the baseline we can tell if an employee is being
damaged by exposure. Each year you provide them another physical which is
compared to the baseline. If they are exposed to any HAZMAT, you provide
them another physical, which is compared to the baseline. If they show any
signs or symptoms of exposure to a HAZMAT, you provide them another
physical which is compared to the baseline. And then when they leave your
employment, you provide them another physical which is compared to the
baseline, and also is kept to help prove that you are not responsible for
future exposures to HAZMATs for this individual.
 Chapter 8 Hazardous Waste
Operations and Emergency Response
(HAZWOPER) -1910.120

HAZWOPER Overview 1

OSHA’s Narrative Explanation of the HAZWOPER Standard 8

Incident Command and Termination 21

Medical Surveillance Program 45

An Overview of Hazardous Waste Operations and
Emergency Response (HAZWOPER)
Scope

This standard regulates hazardous waste clean-up, treatment, and emergency

response for general industry.

Employees involved in:

! Clean-up operations

1. Clean-up
operations required by a
governmental body,
whether federal, state,
local or other, involving
hazardous substances
that are conducted at
uncontrolled hazardous
waste sites;

2. Corrective actions involving clean-up operations at

sites covered by Resource Conservation and Recovery Act
(RCRA);

3. Voluntary clean-up operations at sites recognized

by federal, state, local or other governmental bodies as
uncontrolled hazardous waste sites;

! Treatment, storage and disposal of hazardous wastes -

Operations involving hazardous wastes that are conducted at
treatment, storage and disposal facilities licensed under RCRA;

! Emergency response operations - Emergency response

operations for release of, or substantial threats of release of,
hazardous substances. This is the type of operation with which the
majority of employers will be
concerned.

Exceptions to the above are permitted if the

employer can demonstrate that the
operation does not involve employee
exposure or a reasonable possibility of
such exposure to hazards.

1
General Requirements

A. Development by each hazardous waste site employer of a safety and

health program designed to identify, evaluate, and control safety and
health hazards, and provide for emergency response.

B. A preliminary evaluation of the site's characteristics prior to entry by a

trained person to identify potential site hazards and to aid in the selection
of appropriate employee protection methods. Included would be all
suspected conditions immediately dangerous to life or health, or which
may cause serious harm.

C. Implementation of a site control program to protect employees against

hazardous contamination of employees. At a minimum it must have a site
map, site work zones, site communications, safe work practices and
identification of the nearest medical assistance. Also required is the use
of a "buddy system" as a protective measure in particularly hazardous
situations so that employees can keep watch on one another to provide
quick aid if needed.

D. Training of employees before they are allowed to engage in hazardous

waste operations or emergency response that could expose them to
safety and health hazards. However, experienced workers will be allowed
to continue operations and then be given refresher courses when
appropriate. Specific training requirements are listed for clean-up
personnel, equipment operators, general laborers and supervisory
employees and for various levels of emergency response personnel.
Persons completing specified training for hazardous waste operations
shall be certified; those neither certified nor with proper experience shall
be prohibited from engaging in those operations specified by the standard.

Training requirements will vary with the type of operation involved. The
various operations and their dependent training requirements are:

Uncontrolled hazardous waste operations mandated by various

levels of government. These workers must have 40 hours of initial
training before entering a site and at least three days of actual field
experience under a trained, experienced supervisor. Employees
visiting the site occasionally need only 24 hours of prior training and
one day of supervised field experience. Managers and supervisors
directly responsible for clean-up operations must have an additional
eight hours of specialized training in waste management. Annual
refresher training of eight hours is required for regular site workers
and the managers.

2
 Sites licensed under RCRA. Employees must have 24 hours of
training plus eight hours of annual refresher training.

For emergency response operations at other than RCRA sites or

uncontrolled hazardous waste clean site clean-ups, see the following
section on Emergency Response.

E. Medical surveillance at least annually and at the end of employment for all
employees exposed to any particular hazardous substance at or above
established exposure levels and/or those who wear approved respirators
for 30 days or more on site. Such surveillance also will be conducted if a
worker is exposed by unexpected or emergency releases.

F. Engineering controls, work practices, and personal protective equipment,

or a combination of these methods, must be implemented to reduce
exposure below established exposure levels for the hazardous substance
involved.

G. Air monitoring to identify and quantify levels of hazardous substances with

periodic monitoring to assure that proper protective equipment is being
used.

H. An informational program with the names of key personnel and their

alternates responsible for site safety and health; and the listing of these
requirements of the standard.

I. Implementation of a decontamination procedure before any employee or

equipment may leave an area of potential hazardous exposure; operating
procedures to minimize exposure through contact with exposed
equipment, other employees, or used clothing; and showers and change
rooms where needed.

J. An emergency response plan to handle possible on-site emergencies prior

to beginning hazardous waste operations. Such plans must address:
personnel roles; lines of authority, training and communications;
emergency recognition and prevention; safe places of refuge; site security;
evacuation routes and procedures; emergency medical treatment; and
emergency alerting.

K. An off-site emergency response plan to better

coordinate emergency action by the local
services and to implement appropriate control
action.

3
Emergency Response to Hazardous Substance Releases

Response to emergency, or potential emergency, releases of hazardous

substances is covered by paragraph (q) of the standard. It is this section that will
concern more employers than any other part of the standard.

The standard defines "emergency response" or "responding to emergencies" as

"a response effort by employees from outside the immediate release area or by
other designated responders (i.e., mutual-aid groups, local fire departments, etc.)
to an occurrence which results or is likely to result, in an uncontrolled release of a
hazardous substance. Responses to incidental releases of hazardous
substances where the substance can be absorbed, neutralized, or otherwise
controlled at the time of release by employees in the immediate release area, or
by maintenance personnel are not considered to be emergency releases within
the scope of this standard. Responses to releases of hazardous substances
where there is no potential safety or health hazard (i.e., fire, explosion, or
chemical exposure) are not considered to be emergency responses."

In determining what is an emergency response, the following points should be

kept in mind:

1. If there is no potential safety or health hazard, there is no emergency.

This applies whether the release is cleaned up by personnel within the
immediate work area or from outside the work area. Generally,
employees will be trained under the hazard communication standard to
deal with such incidental releases.

2. If there is a potential safety or health hazard, there may be an

emergency and hence an emergency response. This applies whether the
release is responded to by employees from outside the work area, by
outside groups such as the fire department, or by employees from the
immediate work area who have been designated by the employer to
respond to emergencies.

Additional considerations that generally make a response an emergency

response are shown in Table 1 on the next page.

Employers whose employees will be engaged in emergency responses must

develop and implement an Emergency Response Plan. The following exceptions
and exemptions apply:

Employers who will evacuate their employees from the danger area when
an emergency occurs, and who do not permit any of their employees to
assist in handling the emergency, are exempt from the requirements if
they provide an Emergency Action Plan in accordance with OSHA
requirements.

4
 Emergency response organizations that have developed programs for
handling releases of hazardous substances in order to meet requirements
of the Superfund Amendments and Reauthorization Act of 1986
(Emergency Planning and Community Right-to-Know Act of 1986), may
use those programs to meet the requirements of 1910.120 to the extent that
they are equivalent. They may use the local emergency response plan or
the state emergency response plan or both, as part of their emergency
response plan to avoid duplication.

Table 1.
Situations Generally Resulting in Emergency Responses

! The response comes from outside the immediate release area.

! The release requires evacuation of employees in the area.
! The release poses, or has the potential to pose, conditions that are
immediately dangerous to life and health (IDLH).
! The release poses a serious threat of fire or explosion (exceeds or has the
potential to exceed the lower explosive limit or lower flammable limit).
! The release requires immediate attention because of imminent danger.
! The release may cause high levels of exposure to toxic substances.
! There is uncertainty that the employee in the work area can handle the
severity of the hazard with the PPE and equipment that has been provided
and the exposure limit could easily be exceeded.
! The situation is unclear, or data is lacking on important factors.

5
A. Elements of an Emergency Response Plan

! Pre-emergency planning and coordination with outside

parties.
! Personnel roles, lines of authority, training, and
communication.
! Emergency recognition and prevention.
! Safe distances and places of refuge.
! Site security and control.
! Evacuation routes and procedures.
! Decontamination.
! Emergency medical treatment and first aid.
! Emergency alerting and response procedures.
! Critique of response and follow-up.
! PPE and emergency equipment.

B. Procedures for handling emergency response

The senior emergency response official responding to an emergency

becomes the individual in charge of a site-specific Incident Command
System (ICS). All emergency responders and their communications must
be coordinated and controlled through the individual in charge of the ICS
assisted by the senior official present for each employer.

Operations in hazardous areas must be performed using the buddy

system in groups of two or more.

Back-up personnel must stand by with equipment ready to provide

assistance or rescue. Advanced first aid support personnel, as a
minimum, must also stand by with medical equipment and transportation
capability.

C. Training

Different levels of initial training are required depending on the duties and
functions of each responder plus demonstrated competence or annual
refresher training sufficient to maintain competence.

! First responders at the "awareness level" (individuals likely

to witness or discover a hazardous substance release and initiate
the emergency response) must demonstrate competency in such
areas as recognizing the presence of hazardous materials in an
emergency, the risks involved, and the role they should perform.

! First responders at the "operations level" (individuals who

respond for the purpose of protecting property, persons, or the

6
 nearby environment without actually trying to stop the release) must
have eight hours of training plus "awareness level" competency or
demonstrate competence in their role.

! Hazardous materials technicians (individuals who respond to

stop the release) must have 24 hours of training
equal to the "operations level" and demonstrate
competence in several specific areas.

! Hazardous materials specialists (those who

support the technicians but require a more
specific knowledge of the substances to be
contained) must have 24 hours of training equal to
the technical level and demonstrate competence
in certain areas.

! On-scene incident commanders (who assume control of the

incident scene beyond the "awareness level") must have 24 hours
of training equal to the "operations level" and demonstrate
competence in specific areas.

Skilled support personnel (e.g., heavy earth-moving equipment operators)

who are needed on a temporary basis are not required to meet the training
required for an employer's regular employees. They must, however, be
given an initial briefing at the site prior to their participation in any
emergency response. The briefing must include instruction in the wearing
of appropriate personal protective equipment, what chemical hazards are
involved, and what duties are to be performed.

Specialist employees who regularly work with and are trained in the
hazards of specific hazardous substances and will provide technical
advice or assistance at a hazardous substance release incident must
receive training or demonstrate competency in the area of their
specialization annually.

Employees who receive the training for the various levels must have
annual refresher training to maintain their competencies, or must
demonstrate competency in those areas at least yearly.

D. Medical surveillance and consultation

Members of designated HAZMAT teams and hazardous materials

specialists must have a baseline physical examination and be provided
with medical surveillance as required for employees at uncontrolled
hazardous waste sites.

7
 Any emergency response employees who exhibit signs or symptoms that
may have resulted from exposure during the course of an emergency
incident must be provided with medical consultation.

E. Post-emergency response operations

After the emergency response is over, clean-up of released hazardous

substances or health hazards or materials contaminated with them may be
necessary. In this case, the employer may either comply with all of the
requirements for uncontrolled hazardous waste sites, or, if the clean-up is done
on plant property using plant or workplace employees, make sure that such
employees have completed the training requirements as follows: Emergency
Action Plan training; respirator training; hazard communication training, and other
appropriate safety and health training made necessary by the tasks that they are
expected to perform, such as personal protective equipment and
decontamination procedures.

OSHA’s Narrative Explanation of the HAZWOPER Standard

The dumping of hazardous waste poses a significant threat to the environment.

The Environmental Protection Agency's (EPA) 1995 data show that EPA
managed about 277 million metric tons of hazardous waste at licensed
Resource Conservation and Recovery Act (RCRA) sites. Hazardous waste is
a serious safety and health problem that continues to endanger human and
animal life and environmental quality. Hazardous waste -- discarded chemicals
that are toxic, flammable or corrosive -- can cause fires, explosions, and pollution
of air, water, and land. Unless hazardous waste is properly treated, stored, or
disposed of, it will continue to do great harm to all living things that come into
contact with it now or in the future.

Because of the seriousness of the safety and health hazards related to

hazardous waste operations, the Occupational Safety and Health Administration
(OSHA) issued its Hazardous Waste Operations and Emergency Response
Standard, Title 29 Code of Federal Regulations (CFR) Part 1910.120 and
1926.65 to protect workers in this environment and to help them handle
hazardous wastes safely and effectively.

8
This booklet discusses OSHA's requirements for hazardous waste
operations and emergency response at uncontrolled hazardous waste sites
and treatment, storage, and disposal (TSD) facilities and summarizes the
steps an employer must take to protect the health and safety of workers in
these environments.

Scope and Application

The standard covers workers in cleanup operations at uncontrolled hazardous

waste sites and at EPA-licensed waste TSD facilities; as well as workers
responding to emergencies involving hazardous materials (e.g., spills).

Provisions of the Standard

Safety and Health Program

An effective and comprehensive safety and health program

is essential in reducing work-related injuries and illnesses
and in maintaining a safe and healthful work environment.
The standard, therefore, requires each employer to develop and implement a
written safety and health program that identifies, evaluates, and controls safety
and health hazards and provides emergency response procedures for each
hazardous waste site or treatment, storage, and disposal facility. This written
program must include specific and detailed information on the following topics:

• An organizational workplan,
• Site evaluation and control,
• A site-specific program,
• Information and training program,
• Personal protective equipment program,
• Monitoring,
• Medical surveillance program,
• Decontamination procedures, and
• Emergency response program.

The written safety and health program must be periodically updated and made
available to all affected employees, contractors, and subcontractors. The
employer also must inform contractors and subcontractors, or their
representatives, of any identifiable safety and health hazards or potential fire or
explosion hazards before they enter the work site.

Each of the components of the safety and health program is discussed in the

9
following paragraphs.

Workplan
Planning is the key element in a hazardous waste control program. Proper
planning will greatly reduce worker hazards at waste sites. A workplan should
support the overall objectives of the control program and provide procedures for
implementation and should incorporate the employer's standard operating
procedures for safety and health. Establishing a chain of command will specify
employer and employee responsibilities in carrying out the safety and health
program. For example, the plan should include the following:
• Supervisor and employee responsibilities and means of communication,
• Name of person who supervises all of the hazardous waste operations,
and
• The site supervisor with responsibility for and authority to develop and
implement the site safety and health program and to verify compliance.

In addition to this organizational structure, the plan should define the tasks and
objectives of site operation as well as the logistics and resources required to fulfill
these tasks. For example, the following topics should be addressed:

• The anticipated clean-up and/or operating procedures;

• A definition of work tasks and objectives and methods of accomplishment;
• The established personnel requirements for implementing the plan; and
• Procedures for implementing training, informational programs, and
medical surveillance requirements.

Necessary coordination between the general program and site-specific activities

also should be included in the actual operations workplan.

Site Evaluation and Control

Site evaluation, both initial and periodic, is crucial to the safety and health of
workers. Site evaluation provides employers with the information needed to
identify site hazards so they can select appropriate protection methods for
employees.

It is extremely important, and a requirement of the standard, that a trained person

conduct a preliminary evaluation of an uncontrolled hazardous waste site before
entering the site. The evaluation must include all suspected conditions that are
immediately dangerous to life or health or that may cause serious harm to
employees (e.g., confined space entry, potentially explosive or flammable
situations, visible vapor clouds, etc.). As available, the evaluation must include

10
the location and size of the site, site topography, site accessibility by air and
roads, pathways for hazardous substances to disperse, a description of worker
duties, and the time needed to perform a given task, as well as the present status
and capabilities of the emergency response teams.

Periodic reevaluations should also be conducted for treatment, storage, and

disposal facilities, as conditions or operations change.

Controlling the activities of workers and the movement of equipment is an

important aspect of the overall safety and health program. Effective control of the
site will minimize potential contamination of workers, protect the public from
hazards, and prevent vandalism. The following information is useful in
implementing the site control program: a site map, site work zones, site
communication, safe work practices, and the name, location and phone number
of the nearest medical assistance.

The use of a "buddy system" also is required as a protective measure to assist in

the rescue of an employee who becomes unconscious, trapped, or seriously
disabled on site. In the buddy system, two employees must keep an eye on each
other and only one should be in a specific dangerous area at one time, so that if
one gets in trouble, the second can call for help.

Site-Specific Safety and Health Plan

A site-specific safety and health plan is a complementary program element that

aids in eliminating or effectively controlling anticipated safety and health hazards.
The site-specific plan must include all of the basic requirements of the overall
safety and health program, but with attention to those characteristics unique to
the particular site. For example, the site-specific plan may outline procedures for
confined space entry, air and personal monitoring and environmental sampling,
and a spill containment program to address the particular hazards present at the
site.

The site safety and health plan must identify the hazards of each phase of the
specific site operation and must be kept at the work site. Pre-entry briefings must
be conducted prior to site entry and at other times as necessary to ensure that
employees are aware of the site safety and health plan and its implementation.
The employer also must ensure that periodic safety and health inspections are
made of the site and that all known deficiencies are corrected prior to work at the
site.

Information and Training Program

11
As part of the safety and health program, employers are required to develop and
implement a program to inform workers (including contractors and
subcontractors) performing hazardous waste operations of the level and degree
of exposure they are likely to encounter.

Employers also are required to develop and implement procedures for

introducing effective new technologies that provide improved worker protection in
hazardous waste operations. Examples include foams, absorbents, adsorbents,
and neutralizers.

Training makes workers aware of the potential hazards they may encounter and
provides the necessary knowledge and skills to perform their work with minimal
risk to their safety and health. The employer must develop a training program for
all employees exposed to safety and health hazards during hazardous waste
operations. Both supervisors and workers must be trained to recognize hazards
and to prevent them; to select, care for and use respirators properly as well as
other types of personal protective equipment; to understand engineering controls
and their use; to use proper decontamination procedures; to understand the
emergency response plan, medical surveillance requirements, confined space
entry procedures, spill containment program, and any appropriate work practices.
Workers also must know the names of personnel and their alternates responsible
for site safety and health. The amount of instruction differs with the nature of the
work operations, as indicated in Tables 1 and 2.

Employees at all sites must not perform any hazardous waste operations unless
they have been trained to the level required by their job function and
responsibility and have been certified by their instructor as having completed the
necessary training. All emergency responders must receive refresher training,
sufficient to maintain or demonstrate competency, annually. Employee training
requirements are further defined by the nature of the work (e.g., temporary
emergency response personnel, firefighters, safety officers, HAZMAT personnel,
and incident commanders). These requirements may include recognizing and
knowing the hazardous materials and their risks, knowing how to select and use
appropriate personal protective equipment, and knowing the appropriate control,
containment, or confinement procedures and how to implement them. The
specific training and competency requirements for each personnel category are
explained fully in the standard. For a brief summary of training requirements, see
Tables 1 and 2.

12
13
Employees who receive the training specified (see Table 1) must receive a
written certificate upon successful completion of that training. That training need
not be repeated if the employee goes to work at a new site; however, the
employee must receive whatever additional training is needed to work safely at
the new site. Employees who worked at hazardous waste sites before 1987 and
received equivalent training need not repeat the initial training specified in Table
1, if the employer can demonstrate that in writing and certify that the employee
has received such training.

Personal Protective Equipment Program

The standard further requires the employer to develop a written

personal protective equipment program for all employees
involved in hazardous waste operations. As mentioned earlier,
this program also is part of the site-specific safety and health
program. The personal protective equipment program must
include an explanation of equipment selection and use,
maintenance and storage, decontamination and disposal, training
and proper fit, donning and doffing procedures, inspection, in-use
monitoring, program evaluation, and equipment limitations.

The employer also must provide and require the use of personal
protective equipment where engineering control methods are
infeasible to reduce worker exposures at or below the permissible
exposure limit. Personal protective equipment must be selected that is
appropriate to the requirements and limitations of the site, the task-specific
conditions and duration, and the hazards and potential hazards identified at the
site. As necessary, the employer must furnish the employee with positive-
pressure self-contained breathing apparatus or positive-pressure air-line
respirators equipped with an escape air supply, and with totally encapsulating
chemical protective suits.

Monitoring

Airborne contaminants can present a significant threat to employee safety and

health, thus making air monitoring an important component of an effective safety
and health program. The employer must conduct monitoring before site entry at
uncontrolled hazardous waste sites to identify conditions immediately dangerous
to life and health, such as oxygen-deficient atmospheres and areas where toxic
substance exposures are above permissible limits. Accurate information on the
identification and quantification of airborne contaminants is useful for the
following:

• Selecting personal protective equipment,

14
• Delineating areas where protection and controls are needed,
• Assessing the potential health effects of exposure, and
• Determining the need for specific medical monitoring.

After a hazardous waste cleanup operation

begins, the employer must periodically
monitor those employees who are likely to
have higher exposures to determine if they
have been exposed to hazardous substances
in excess of permissible exposure limits. The
employer also must monitor for any potential
condition that is immediately dangerous to
life and health or for higher exposures that
may occur as a result of new work
operations.

Medical Surveillance
A medical surveillance program will help to assess and monitor the health and
fitness of employees working with hazardous substances. The employer must
establish a medical surveillance program for the following:
• All employees exposed or potentially exposed to hazardous substances or
health hazards above permissible exposure limits for more than 30 days per
year;
• Workers exposed above the published exposure levels (if there is no
permissible exposure limit for these substances) for 30 days or more a year;
• Workers who wear approved respirators for 30 or more days per year on
site;
• Workers who are exposed to unexpected or emergency releases of
hazardous wastes above exposure limits (without wearing appropriate protective
equipment) or who show signs, symptoms, or illness that may have resulted from
exposure to hazardous substances; and
• Members of hazardous materials (HAZMAT) teams.

All examinations must be performed under the supervision of a licensed

physician, without cost to the employee, without loss of pay and at a reasonable
time and place. Examinations must include a medical and work history with
special emphasis on symptoms related to the handling of hazardous
substances and health hazards and to fitness for duty including the ability to
wear any required personal protective equipment under conditions that may be
expected at the work site. These examinations must be given as follows:

• Prior to job assignment and annually thereafter (or every 2 years if a

physician determines that is sufficient),
• At the termination of employment

15
• Before reassignment to an area where medical examinations are not
required,
• If the examining physician believes that a periodic followup is medically
necessary, and
• As soon as possible for employees injured or becoming ill from exposure
to hazardous substances during an emergency, or who develop signs or
symptoms of overexposure from hazardous substances.

The employer must give the examining physician a copy of the standard and its
appendices, a description of the employee's duties relating to his or her
exposure, the exposure level or anticipated exposure level, a description of any
personal protective and respiratory equipment used or to be used, and any
information from previous medical examinations. The employer must obtain a
written opinion from the physician that contains the results of the medical
examination and any detected medical conditions that would place the employee
at an increased risk from exposure, any recommended limitations on the
employee or upon the use of personal protective equipment, and a statement
that the employee has been informed by the physician of the medical
examination. The physician is not to reveal, in the written opinion given to the
employer, specific findings or diagnoses unrelated to employment.

Decontamination Procedures

Decontamination procedures are a component of the site-specific safety and

health plan and, consequently, must be developed, communicated to employees,
and implemented before workers enter a hazardous waste site. As necessary,
the site safety and health officer must require and monitor decontamination of the
employee or decontamination and disposal of the employee's clothing and
equipment, as well as the solvents used for decontamination, before the
employee leaves the work area. If an employee's non-impermeable clothing
becomes grossly contaminated with hazardous substances, the employee must
immediately remove that clothing and take a shower. Impermeable protective
clothing must be decontaminated before being removed by the employee.

Protective clothing and equipment must be decontaminated, cleaned, laundered,

maintained, or replaced to retain effectiveness. The employer must inform any
person who launders or cleans such clothing or equipment of the potentially
harmful effects of exposure to hazardous substances.

Employees who are required to shower must be provided showers and change
rooms. In addition, unauthorized employees must not remove their protective
clothing or equipment from change rooms unless authorized to do so.

16
Emergency Response

Proper emergency planning and response are important elements of the safety
and health program that help minimize employee exposure and injury. The
standard requires that the employer develop and implement a written emergency
response plan to handle possible emergencies before performing hazardous
waste operations. The plan must include, at uncontrolled hazardous waste sites
(3)
and at treatment, storage, and disposal facilities, the following elements:

• Personnel roles, lines of authority, and communication procedures,

• Pre-emergency planning,
• Emergency recognition and prevention,
• Emergency medical and first-aid treatment,
• Methods or procedures for alerting onsite employees,
• Safe distances and places of refuge,
• Site security and control,
• Decontamination procedures,
• Critique of response and followup,
• Personal protective and emergency equipment, and
• Evacuation routes and procedures.

In addition to the above requirements, the plan must include site topography,
layout, and prevailing weather conditions; and procedures for reporting incidents
to local, state, and federal government agencies.

The procedures must be compatible with and integrated into the disaster, fire
and/or emergency response plans of the site's nearest local, state, and federal
agencies. Emergency response organizations may use the local or state
emergency response plans, or both, as part of their emergency response plan
to avoid duplication of federal regulations.

The plan requirements also must be rehearsed regularly, reviewed periodically,

and amended, as necessary, to keep them current with new or changing site
conditions or information. A distinguishable and distinct alarm system must be in
operation to notify employees of emergencies. The emergency plan also must be
made available for inspection and copying by employees, their representatives,
OSHA personnel, and other governmental agencies with relevant responsibilities.

When deemed necessary, employees must wear positive-pressure self-

contained breathing apparatus and approved self-contained compressed-air
breathing apparatus with approved cylinders. In addition, back-up and first-aid
support personnel must be available for assistance or rescue.

Other Provisions

17
As already indicated, as part of an effective safety and health program, the
employer must institute control methods and work practices that are
appropriate to the specific characteristics of the site. Such controls are
essential to successful worker protection. Some control methods are
described in the following paragraphs.

Engineering Controls and Work Practices

To the extent feasible, the employer must institute engineering controls and work
practices to help reduce and maintain employee exposure at or below
permissible exposure limits. To the extent not feasible, engineering and work
practice controls may be supplemented with personal protective equipment.
Examples of suitable and feasible engineering controls include the use or
pressurized cabs or control booths on equipment, and/or remotely operated
materials handling equipment. Examples of safe work practices include removing
all non-essential employees from potential exposure while opening drums,
wetting down dusty operations, and placing employees upwind of potential
hazards.

Handling and Labeling Drums and Containers

Prior to handling a drum or

container, the employer must
assure that drums or containers
meet the required OSHA, EPA (40
CFR Parts 264-265 and 300), and
Department of Transportation
(DOT) regulations (49 CFR Parts
171-178), and are properly
inspected and labeled. Damaged
drums or containers must be
emptied of their contents, using a
device classified for the material
being transferred, and must be
properly discarded. In areas where
spills, leaks or ruptures occur, the
employer must furnish employees
with salvage drums or containers,
a suitable quantity of absorbent material, and approved fire-extinguishing
equipment in the event of small fires. The employer also must inform employees
of the appropriate hazard warnings of labeled drums, the removal of soil or
coverings, and the dangers of handling unlabeled drums or containers without
prior identification of their contents. To the extent feasible, the moving of drums
or containers must be kept to a minimum, and a program must be implemented
to contain and isolate hazardous substances being transferred into drums or

18
containers. In addition, an approved EPA ground-penetrating device must be
used to determine the location and depth of any improperly discarded drums or
containers.

The employer also must ensure that safe work practices are instituted before
opening a drum or container. For example, air-line respirators and approved
electrical equipment must be protected from possible contamination, and all
equipment must be kept behind any existing explosion barrier

Only tools or equipment that prevent ignition shall be used. All employees not
performing the operation shall be located at a safe distance and behind a
suitable barrier to protect them from accidental explosions. In addition,
standing on or working from drums or containers is prohibited. Special care
also must be given when an employee handles containers of shock-sensitive
waste, explosive materials, or laboratory waste packs. Where an emergency
exists, the employer must ensure the following:

• Evacuate non-essential employees from the transfer area;

• Protect equipment operators from exploding containers by using a barrier,
and
• Make available a continuous means of communication (e.g., suitable
radios or telephones), and a distinguishable and distinct alarm system to signal
the beginning and end of activities where explosive wastes are handled.

If drums or containers bulge or swell or show crystalline material on the outside,

they must not be moved onto or from the site unless appropriate containment
procedures have been implemented. In addition, lab packs must be opened only
when necessary and only by a qualified person. Prior to shipment to a licensed
disposal facility, all drums or containers must be properly labeled and packaged
for shipment. Staging areas also must be kept to a minimum and provided with
adequate access and egress routes.

Sanitation of Temporary Workplaces

Each temporary worksite must have a supply of potable water that is stored in
tightly closed and clearly labeled containers and equipped with a tap.
Disposable cups and a receptacle for cup disposal also must be provided. The
employer also must clearly mark all water outlets that are unsafe for drinking,
washing, or cooking. Temporary worksites must be equipped with toilet
facilities. If there are no sanitary sewers close to or on the hazardous waste
site, the employer must provide the following toilet facilities unless prohibited
by local codes:

• Privies,
• Chemical toilets,

19
• Recirculating toilets, or
• Combustion toilets.

Heated, well-ventilated, and well-lighted sleeping quarters must be provided for

workers who guard the worksite. In addition, washing facilities for all workers
must be near the worksite, within controlled work zones, and so equipped to
enable employees to remove hazardous substances. The employer also must
ensure that food service facilities are licensed.

Recordkeeping

In 1988, OSHA revised the standard requiring employers to provide employees

with information to assist in the management of their own safety and health. The
standard, Access to Employee Exposure and Medical Records, permits direct
access to these records by employees exposed to hazardous materials, or by
their designated representatives, and by OSHA. The rule applies to, but does not
require, medical and exposure records maintained by the employer.

The employer must keep exposure records for 30 years and medical records for
at least the duration of employment plus 30 years. Records of employees who
have worked for less than 1 year need not be retained after employment, but the
employer must provide these records to the employee upon termination of
employment. First-aid records of one-time treatment need not be retained for any
specified period.

The employer must inform each employee of the existence, location, and
availability of these records. Whenever an employer plans to stop doing
business and there is no successor employer to receive and maintain these
records, the employer must notify employees of their right to access to records
at least 3 months before the employer ceases to do business. At the same
time, employers also must notify the National Institute for Occupational Safety
and Health.

Under the hazardous waste standard, at a minimum, medical records must

include the following information:

• Employee's name and social security number

• Physicians' written opinions,
• Employee's medical complaints related to exposure to hazardous substances,
and
• Information provided to the treating physician.

Hazard Communication Standard (HCS)

20
Hazard Communication Standard (HCS)
Title III of the Superfund Amendments and Reauthorization Act of 1986
(SARA) requires employers covered by the Hazard Communication Standard
to maintain Material Safety Data Sheets (MSDSs) and submit such information to
State emergency response commissions, local emergency planning committees,
and the local fire department. Under this requirement, employers covered by
HCS must provide chemical hazard information to both employees and
surrounding communities. Consequently, in the case of an emergency response
situation to hazardous substances at a site, the local fire department may already
be aware of the of the chemicals present at the site since data may have been
provided through MSDSs.

Summary
Hazardous wastes, when not handled properly, can pose a significant safety and
health risk. OSHA recognizes the need to improve the quality of the hazardous
waste work environment and has, therefore, issued this standard. This standard
provides employers and employees with the information and training necessary
to improve workplace safety and health, thereby greatly reducing the number of
injuries and illnesses resulting from exposure to hazardous waste.

INCIDENT COMMAND AND TERMINATION

WHY USE AN INCIDENT COMMAND SYSTEM?

There are a number of sound reasons for using an Incident Command

System when dealing with hazardous materials emergencies. Above all,
an Incident Command System provides a clear structure for the diverse
activities necessary to successfully control a hazardous materials incident.
A discussion of more specific reasons for utilizing an Incident Command
System follows.

21
A. Ensuring the Safety of Operating Forces

Emergency response personnel are confronted by a number of

safety hazards during an emergency. An Incident Command
System helps ensure that actions taken at an incident are
effectively controlled and that the risks and benefits of various
alternative courses of action are evaluated on an ongoing basis.
This organized, considered approach helps to ensure that the
safety of forces operating at an emergency is not compromised. An
integral part of ensuring the safety of operating forces is the
implementation of an accountability mechanism so that the status
of units and personnel operating at the incident is known at all
times.

B. Ensuring that Someone is Always in Charge

A key element of any Incident Command model is that a single

person is on charge at each incident. This person is responsible for
overall command of the emergency response and for establishing
operational goals and objectives at the incident scene. This
person, typically called the Incident Commander, has a number of
other important functions that will be discussed later in this unit.

By having one person in charge, two major pitfalls are avoided.

One of these is having no one in charge. When there is no one in
charge of an emergency response, the incident scene quickly
deteriorates into chaos. A second major problem prevented by an
Incident Command System is that of too many people taking
charge. When more than one person acts as the Incident
Commander, conflicting orders and directives may be issued and
the actions of emergency response forces are likely to be poorly
coordinated.

In addition, when one individual is in charge of an incident, all

responders recognize that information must be passed along to this
individual. While the individual in charge may not be an expert
regarding hazardous materials involved, all information flows
through the Incident Commander if the system is operating
effectively.

C. Conforming to Laws and Standards

Another significant reason for implementing an Incident Command

System when dealing with hazardous materials emergencies is that
laws require it and consensus standards encourage it. The
Superfund Amendments and Reauthorization Act of 1968 (SARA)

22
 requires that emergency response organizations handling
hazardous materials incidents operate with an Incident Command
System. Regulations from the Occupational Safety and Health
Administration(OSHA) and Environmental Protection Agency (EPA)
mandate use of Incident Command Systems as well.

Two important consensus standards developed by the National Fire

Protection Association (NFPA) encourage use of Incident
Command Systems. These standards are NFPA 1500 and 1561,
entitled "Fire Department Occupational Safety and Health Program"
and Fire Department Incident Management Systems", respectively.

These laws and standards specify the use of Incident Command

Systems because they improve the safety and effectiveness of
response to all emergency incidents, especially hazardous
materials emergencies.

D. Efficiently Utilizing Resources

When dealing with any emergency, it is important that the

resources for stabilizing and controlling the incident be used
efficiently. Incident Command Systems provide the structure for
managing these resources and ensuring that they are deployed
effectively. These resources include personnel, apparatus,
specialized equipment, materials, and facilities required to deal with
the emergency.

In summary, there are many reasons for using an Incident

Command System in hazardous materials emergencies. All of
these reasons evolve from an underlying rationale: the response to
an emergency should be controlled and well-organized. Resources
used to stabilize the emergency should be used to maximum
benefit. Finally, and most importantly, the risks to which Team
Members and other emergency response personnel are subjected
should be minimized whenever possible.

MANAGEMENT CONCEPTS

There are a number of management concepts that are considered basic,

mandatory, and universal to all organized efforts. These management
principles form the framework of effective, well-directed, efforts and are
equally applicable to hazardous materials emergency response.

These basic management principles include

! Division of labor

23
! Lines of authority

! Delegation

! Unity of Command

! Span of control

! Line/staff functions

! Coordination

A. Division of Labor

Work is assigned to individuals or units based on a well-arranged

plan. Careful consideration is given to the functions to be
performed, as well as to the training and capabilities of the
individuals who will be performing the work.

There are hundreds of different tasks that need to be performed in

hazardous materials emergencies. These tasks include damming
and diking, decontamination, operation of specialized equipment,
and emergency care. Few people are trained to perform all of
these diverse tasks, Even if such trained people were available,
assigning a single person or group of people to handle multiple
responsibilities is extremely inefficient and unsafe. Incident
Command Systems provide for a structured division of labor along
functional or geographic lines and avoid overextending personnel.
It becomes the responsibility of the Incident Commander to match
personnel and units to the specific tasks that need to be
accomplished.

B. Lines of Authority

Individuals must be aware of their roles within the organization and

their relationships to other individuals. This principle applies to
functional units within an organization as well.

In any management setting, it is essential that people know how

and where they fit into the overall structure. The Incident
Command System accomplishes this by providing a well-defined,
modular and function-oriented structure. Within this structure,
individual personnel as well as functional units are aware of their

24
 place in the structure and their reporting relationships to other
people and units in this system.

C. Delegation

A higher level of authority gives an individual or unit an assignment

to accomplish or a task to execute. These assignments or tasks
are called responsibilities. When a responsibility is delegated, it is
equally important that the appropriate authority be delegated as
well, Authority is generally described as the bona-fide or
institutionalized right to complete or carry out the delegated
responsibility.

Incident Command Systems use delegation extensively. It is

impossible for a single person to make all decisions and directly
control all operations at a hazardous material emergency. Through
effective use of delegation, the Incident Commander is able to
distribute responsibility for carrying out specific assignments. For
example, the Incident Commander has the responsibility to inform
the public and interact with the media. In most situations, however,
the specific assignment of dealing with the press is delegated to a
Public Information Officer. This approach to delegation is best
described as centralized command and control with decentralized
execution.

D. Unity of Command

Every person within an organization should have only one person

to whom he or she reports at any one time. This is the principle of
unity of command. Without it, individuals or units could receive
multiple and conflicting directives from higher levels of authority.

By establishing organizational relationships and a management

structure at hazardous materials incidents, Incident Command
Systems help to ensure that each individual and unit has only one
person from whom they are receiving directives and to whom they
are reporting conditions and progress. While the specific person or
position may change during the course of an incident, the problem
of multiple reporting relationships is avoided.

E. Span of Control

One person can only oversee a limited number of persons or units.

In emergency operations, the generally accepted span of control is
four to seven persons or units. The span of control for a specific
commander or officer is determined by a number of factors that are

25
 unique to each situation. Examples of these factors include the
degree of difficulty or danger associated with tasks being
performed, and the amount of discretion or latitude given to the
person or units undertaking the task. The amount of latitude or
discretion extended to individuals and units is typically a function of
their training, education, and experience.

Through effective use of delegation and division of labor, Incident

Command Systems maintain effective span of control. Their
modular, expandable format is particularly well-suited to
implementation at a wide variety of incidents.

F. Line and Staff Functions

Line functions are those directly associated with the actual

implementation of the incident operations. Staff functions are those
functions associated with the support of incident operations.

The Incident Command System distinguishes line functions from

staff functions. This ensures that operational resources are brought
together and properly focused in one part of the organization. At
the same time, the system ensures that the large number of
support functions required at an emergency incident are properly
addressed and effectively organized.

G. Coordination

A hazardous materials incident involves hundreds of interactions

among many different response units and personnel. Coordination
of these interactions is essential to the efficient operation of the
Incident Command System. These interactions may cross the
sometimes rigid "lines" of an organization; however, Incident
Command Systems should organize the overall flow of these
interactions.

INCIDENT COMMAND SYSTEM; MAJOR COMPONENTS

There are eight major components of an Incident Command System. These

components are:

! Common terminology

! Modular organization

26
! Comprehensive resource command

! Unified command structure

! Consolidated action plans

! Manageable span of control

! Designated incident facilities

! Integrated communications

A description of each of these essential components follows.

A. Common Terminology

The Incident Command System provides pre-designated, function-based

names and titles for personnel, equipment, and responsibilities at the
emergency incident. Examples of this common terminology at a
hazardous materials incident include: "Entry Officer," "Decontamination,"
"Hot Zone," and "Staging". Use of standard terminology is especially
important in multi-agency or multi-jurisdiction operations. All responders
must identify and understand the terminology used by their own
departments and among other departments involved in mutual aid
responses.

B. Modular Organization

The organizational structure of the Incident Command System develops

on an as-needed, top-down basis. Command is a function that is
established at all incidents. Other functional modules of organization are
put into place as the management needs of the incident dictate. See
figures below.

A comparison can be drawn between the tools found in a tool box and the
tools provided by an Incident Command System. Several tools or
functions are necessary for more complex jobs. Smaller, simpler
responses may not need all of the same tools or functions. For example,
a Public Information Officer may not be needed at a relatively small

Major
Major Command

Commander
Commander and
and Staff
Staff Incidents
Incidents
Info
Safety
Liaison

Command Ops Plans Logistics

Finance
Admin.

Information Staging Service

Situation Time

Comms
Safety Branch Branch Air Resources Procure
Medical
Liaison Comp.
Divisons Divisons Tactical Document. Claims
Food
Groups Groups

Strike Strike Support Demobil. Support Cost

Finance
27
Teams Teams
Ops Plans Logistics
Admin. Task Task Techs
Supply
Forces Forces
Facilities
Single Single
Resources Resources Ground
Support
 incident. The Incident Commander must know what tools are available
and use the appropriate tools, in the correct combinations, to successfully
complete the job at hand.

C. Comprehensive Resource Command

When attempting to stabilize and control a hazardous materials

emergency, it is important that the personnel, equipment, and other
resources dedicated to the incident be effectively deployed and utilized.
The Incident Command System provides a mechanism for analyzing
overall incident resource requirements and using these resources in a
well-coordinated fashion.

D. Unified Command Structure

Since the stabilization and control of many hazardous materials incidents

require the efforts of a number of agencies and firms, the Incident
Command System provides a mechanism for integrating responsible
persons from these entities into a single command structure.

E. Consolidated Action Plans

Sufficient resources and personnel must be deployed in a single, carefully

planned and considered course of action. Consolidated action plans
ensure that efforts undertaken at the incident are conducted in a unified
manner. This prevents problems such as duplication of tasks and
contradictory work assignments.

F. Manageable Span of Control

The management and technical demands generated by hazardous

materials emergencies can quickly become overwhelming. The process
of "building down" the Incident Command structure provides a mechanism
for delegating and maintaining an effective span of control.

G. Designated Incident Facilities

The Incident Command System provides for standard facilities at the

scene. Most commonly, these include a Command Post and staging area.
When appropriate, other facilities can be designated.

The Command Post is the stationary physical location from which the
Incident Commander operates. It represents the headquarters of the
Incident Command System. Staging areas are those locations adjacent to
the incident scene where unassigned personnel and apparatus are
assembled for prompt deployment to the scene.

28
H. Integrated Communications

Effective communications are essential in all emergency operations and

are particularly important when dealing with hazardous materials
emergencies. Incident Command Systems provide for an organized
approach to the coordination, personnel, and hardware associated with
the incident communications network.

These eight components form the essential elements of an Incident

Command System. They also form the basis for the function-driven
organizational structure that evolves when implementing the Incident
Command System.

INCIDENT COMMAND SYSTEM: FUNCTIONS AND STRUCTURES

As described in Section II, effective incident management involves a system

using fundamental management principles as a basis for forming an
organization. The organization at hazardous materials incidents must include the
components described in Section III. Section IV covers the functions that are
carried out through this organizational framework.

The ultimate responsibility for executing these functions rests with the Incident
Commander. Specific development of an organizational structure and the level
of delegation depends on the nature and complexity of the incident as judged by
the Incident Commander.

Incident Command Systems generally employ a classic pyramid-type

organization. Within this organization exist five major functional areas of
responsibility: Command, and its associated functions, Operations, Planning,
Logistics, and Finance. In an Incident Command System, as shown in Figure
11.1, the Command function has overall responsibility for the incident and its
outcome. The Incident Commander is assisted by the Command Staff in the
areas of Safety, Liaison, and Public Information, shown to the right. Four
functional areas focus on emergency scene operations, as well as the support
activities needed to keep the operation supplied and functioning.

A. The Command Function

Regardless of size or complexity, the Command function is established at

every hazardous materials incident. This function is filled by an individual
known as the Incident Commander. When warranted, the Incident
Commander can receive assistance in carrying out the Command function

29
by placing individuals in positions directly responsible for Safety, Liaison,
and Information. These positions are called Command Staff Officers.
The Command function, an thus the Incident Commander, has a
number of important responsibilities including the following.

1. Overall Management of the incident

In exercising the Command function, the Incident Commander

assumes overall responsibility for incident management. In doing
so, a major responsibility is to assess or "size up" the problems
presented by the incident and to consider priority tasks, available
resources, and other relevant factors. Based on this assessment,
the Incident Commander considers various potential courses of
action, makes key strategic decisions, and establishes overall goals
and objectives for the operation to stabilize and control the incident.

2. Development of an Organizational Structure

In order to delegate and maintain an effective span of control, the

Incident Commander must establish an organization that is tailored
to the size, type, and management demands of the incident. In the
Incident Command System, this organizational structure can be
composed of up to four major divisions: Operations, Planning,
Logistics, and Finance.

3. Resource Management

Resources include the personnel, equipment, and materials needed

to stabilize, control, and terminate an emergency incident. The
Incident Commander has the responsibility for assessing resource
needs, summoning these resources, deploying them at the
emergency incident, and then releasing them from the scene.

4. Safety and Risk Management

Ultimate responsibility for the safety of civilians and forces

operating at an emergency incident rests with the Incident
Commander. In carrying out this responsibility, the Incident
Commander must maintain a constant awareness of the status of
the emergency situation and the hazards to which the Team
Members and others may be exposed. Based on an ongoing
evaluation of the situation, the Incident Commander must assess
the potential benefits of various courses of action and modify
incident goals and objectives when appropriate.

30
 At all serious incidents, the Incident Commander should appoint a
Safety Officer. The Safety Officer assists the Incident Commander
by providing appropriate advice and by specifically focusing on
safety and risk management concerns.

5. Coordination of Outside Agencies and Firms

Stabilization, control, and termination of many hazardous materials

incidents requires the combined efforts of numerous government
entities and private firms. The Incident Commander has the
responsibility for effectively coordinating the actions of these
organizations. When a number of organizations are involved in the
response, the Incident Commander usually appoints a Liaison
Officer to interact directly with representatives of these
organizations.

6. Media Relations

The Incident Commander has a responsibility for keeping the public

informed as to what is happening at the emergency incident scene.
Typically, the Incident Commander appoints a Public Information
Officer to deal directly with the media and make appropriate
releases of information to the public. This position can become
particularly important when the media's assistance is solicited
because an evacuation is required.

B. The Operations Function

The Operations function is responsible for management of the

tactical operations undertaken to stabilize, control and terminate the
incident. In smaller incidents, the Incident Commander often
retains direct control of the Operations function. In larger or more
complex incidents, an Operations Officer is generally appointed.
This allows the Incident Commander to maintain an effective span
of control and provide a degree of focus and direct oversight to
tactical operations that the Incident Commander is unable to
provide.

The Operations function is discussed in more detail in Section V.

C. The Planning Function

The Planning function has responsibility for planning, securing

information, and managing resources. Specific examples of
activities performed by the Planning function include the following:

31
! Collecting and analyzing information on the incident from
appropriate resources, including researching materials involved in
the incident and their hazardous properties

! Filtering and capsuling information so that it can be used as

an effective aid in decision-making

! Developing action plans and alternatives

! Projecting long-term incident resource needs

! Tracking the status of the situation and monitoring control

efforts

! Developing and managing incident records, including

relevant reports, logs, and claims

D. The Logistics Function

The process of stabilizing, controlling, and terminating a hazardous

materials emergency is usually time-consuming and resource
intensive. The Logistics function is responsible for materials, and
where applicable, facilities for the duration of the incident.

There are a number of important logistics-related activities that

must be considered and acted upon by the Logistics function early
in the incident; These include:

1. Communication

A reliable and effective means of communication is essential

in any operation. In a hazardous materials emergency, this
need is particularly acute. Many hazardous materials
incidents are of long duration and require the combined
efforts of a number of different agencies and firms. This
translates into intense communications demands. The
Logistics function ensures that there is an organized
communication plan and that appropriate communications
hardware is both sufficient and available for the duration of
the incident. This function is also responsible for operating
the communications network.

No discussion of communications would be complete without

mention of the problems that are often associated with on-
scene communications. Radio systems are prone to
overload. In multi-agency or multi-jurisdiction responses,

32
 there are often problems with coordinating frequencies used
for communication. Telephones, including cellular systems,
provide a more discreet means of communication but lack
the ability to connect multiple locations simultaneously.
Computer data exchanges via modem and facsimile are
becoming more common forms of emergency incident
communication, but also have limitations. Face-to-face
communication is always considered one of the best ways to
communicate, but is often not practical.

For these reasons, it is important that the Logistics function

establish a multi-faceted communications system early in the
incident and devote the organizational resources needed to
keep it operating effectively.

2. Rest and Rehabilitation

The Logistics function is responsible for developing and

operating a system of rest and rehabilitation for personnel
operating at the scene. The functions most often associated
with this effort include: basic physiological monitoring, fluid
replenishment, rest, and relief from weather conditions.
Often overlooked aspects of this function include food and
sanitary facilities. It is unreasonable to expect personnel to
engage in the physically demanding work associated with
hazardous materials response without making basic facilities
available. The department should develop a list of items to
be made available at every rest station.

It is important to highlight that basic health monitoring of fire

department personnel should always be a component of rest
and rehabilitation at hazardous materials incidents.

3. Operations Support

At any hazardous materials incident, there are a large

number of activities with direct and on-going support of
operating forces. Some examples of these operations
support activities include supplying breathing air, spill and
leak control materials, fuel, and miscellaneous operating
supplies, as well as coordinating on-scene movement of
materials and equipment. Each department should develop
and utilize a checklist that provides Logistics with a complete
list of possible support functions.

4. Facilities

33
 During incidents of long duration, the Logistics function has
the responsibility for implementing and operating the fixed
facilities needed to support stabilization and control efforts.
These facilities include Command Post and, in lengthy
operations, on-scene eating and sleeping areas. Again, a
checklist will provide Logistics with a complete list of
possible facility needs.

E. The Finance Function

The Finance function is usually activated during complex, long-

duration incidents, although its use is becoming more common as
fire departments seek to recover the costs of dealing with
hazardous materials emergencies. Effective management of the
financial aspects of the incident are an integral part of the Incident
Command System and should not be overlooked.

The Finance function is responsible for the control and

management of money used for, and in support of, incident control,
stabilization, and termination efforts. Typical tasks performed by
the Finance function include:

! Timekeeping for personnel operating at the incident

! Purchasing of materials and services required for the operation

! Handling claims and compensation requests

! Gathering and evaluating information on the costs associated with

the emergency response.

Computerized records can be used to assist in these tasks. Some

departments charge the cost of the response to the owner of the
facility or location to which they respond. If this is done, records of
financial expenditures are particularly important.

HAZARDOUS MATERIALS OPERATIONS AND THE INCIDENT

COMMAND SYSTEM (ICS)

A. The Operations Function

34
 The Operations function was introduced earlier and will be covered
in more detail in this section. The Operations function is headed by
a designated Operations Officer who is responsible for directing
and managing all activities directly involved with stabilizing and
controlling the incident. The Operations Officer works closely with
the Incident Commander in developing action plans for the incident.

B. Sectors

Within the Operations function there is a need for additional

delegation and decentralization. This is accomplished through the
use of Sectors. Sectors are geographic or functional areas of
operation. Each Sector is headed by a Sector Officer who
assumes responsibility for actions that occur within the assigned
Sector.

In a serious structure fire, for example, the Incident Commander

appoints an Operations Officer to provide direct oversight of the
tactical operations carried out to control the fire. In order to
maintain effective span of control, the Operations Officer divides
the tactical operation along logical functional and geographic lines
by using Sectors. Examples of functional Sectors might include
ventilation and water supply. Geographic Sectors could include
interior and rear Sectors. Each Sector has specific personnel and
equipment resources assigned to it. The Sector Officer's
responsibilities include: managing the resources assigned to the
Sector, making decisions concerning operations within the Sector,
requesting additional resources as needed, and apprising the
Operations Officer of status and progress.

A similar approach is applied in a hazardous materials incident;

however, the nature of hazardous materials operations dictates a
somewhat more involved organizational structure. The Hazardous
Materials Sector communicates with the Operations Sector or the
Incident Commander and fulfills a number of important
responsibilities, including:

! Assessing the risks and hazards associated with control operations

and with the materials involved

! Establishing specific objectives for the hazardous materials

component of emergency scene operations

! Selecting the type of personal protective equipment to be worn by

Hazardous Materials Team Members

35
! Ensuring that Hazardous Materials Team Members are fully briefed
on the situation, reporting relationships, hazards, and all other
appropriate information

! Identifying isolation, evacuation, and decontamination areas

! Providing direct oversight for hazardous materials stabilization and

control efforts

! Delegating tasks and maintaining effective span of control by

establishing appropriate subordinate positions and functions

Within the Hazardous Materials Sector, there are a number of

specific functions that may be activated to facilitate effective control
and stabilization of an incident.

1. Hazardous Materials Safety

Earlier in this unit, Safety was identified as a function of Command.

While this remains true in the hazardous materials environment, the
hazards and risks associated with the Hazardous Materials Sector
dictate that in many cases a specific Hazardous Materials Safety
function should be established. The Hazardous Materials Safety
Officer is in charge of this function and reports directly to the
Hazardous Materials Sector Officer. Responsibilities include:

! Monitoring and observing safety factors specifically associated with

the hazardous materials operation

! Advising the Hazardous Material Sector Officer of relevant safety

issues and concerns

! Ensuring correct and complete utilization of personal protective

equipment designated by the Hazardous Materials Sector

! Coordinating efforts with the Hazardous Materials Sector

! Monitoring the exact amount of time that entry team personnel have
been on air or operating in controlled areas

2. Hazardous Materials Liaison

This function is responsible for coordination with representatives of

other emergency responses and private sector response and
cleanup organizations. Examples of these agencies include law

36
 enforcement, environmental protection agencies, and cleanup
contractors.

3. Hazardous Materials Control

This function directly oversees and controls the entry,

decontamination, and emergency medical services component of
the hazardous materials response

4. Hazardous Materials Research

The responsibilities of this function include identifying products

involved, associated hazards, strategies for control,
recommendations on appropriate personal protective equipment,
and decontamination procedures.

5. Hazardous Materials Resources

It is the responsibility of this function to provide the equipment,

materials, and supplies needed for the hazardous materials
element of the emergency scene operation.

6. Hazardous Materials Entry

The Entry Team Officer in charge of this function provides close,

direct supervision of entry team personnel. This supervision
includes: briefing Team Members prior to entry and ensuring that
appropriate personal protective equipment is in use and that
backup and safety provisions are in order. The Entry Team Officer
also communicates with Team Members during the entry and
monitors all activities in the Hot Zone.

7. Hazardous Materials Decontamination

Entry into a Hot Zone means that personnel and equipment risk
contamination by hazardous materials. As a result,
decontamination is an integral part of most hazardous materials
incidents. Preparation of the decontamination area and the
decontamination process is supervised by a Hazardous Materials
Decontamination Officer. This function includes operating the
decontamination area, maintaining records of personnel and
equipment that have been decontaminated, and providing direction
to personnel assigned to the decontamination effort.

37
 ASSUMING COMMAND OF THE HAZARDOUS MATERIALS
EMERGENCY

Every Hazardous Materials Team Member may, at some point, be placed in a

position of having to assume initial command of a hazardous materials incident.
As noted in previous sections, the Command function is a requirement at all
hazardous materials incidents. As the individual in charge, the Incident
Commander must temper the desire to take immediate action and focus instead
on activities that are well-planned and considered. In addition, the Incident
Commander must maintain a broad, future-oriented outlook and make a
concerted effort to consider the entire incident, all the factors affecting it, and the
likely course of events in the future.

A. Implementing the Command Function

Command should be implemented as early in the incident as possible. In

general, the person in charge of the first arriving fore department unit
should assume command of the incident. The underlying rationale for
establishing command as promptly as possible is that the response should
be organized and controlled from start to finish. It is very difficult to
recover from initial errors that were made because the Command function
was not implemented at the earliest possible stage of the incident.

Many people are under the mistaken impression that assumption of

command is a responsibility for senior or chief level officers. This is not
the case. Often, the most important decisions concerning effective
stabilization and control of an incident must be made in the first few
minutes after arrival of initial responding units. It is essential that
command be promptly assumed by the person in charge of the first
arriving unit.

Early implementation of the Command function ensures that life saving

and incident stabilization efforts are coordinated from the start, that unity
of command is maintained, and that initial responding resources are
deployed efficiently. The safety of operating forces is also improved by
early implementation of the Command function.

B. Responsibilities of the Initial Incident Commander

In Section IV, the Command function was discussed in general. This

section focuses on specific responsibilities of the initial Incident
Commander.

There are six specific responsibilities assumed by the initial Incident

Commander. A description of each follows:

38
 1. Make an Initial On-Scene Assessment and Evaluation

Upon arrival on the scene, the initial Incident Commander must

carefully evaluate the situation. There are several questions that
should be asked during this evaluation: Are lives in jeopardy?
What property is at risk? What is the hazard? What resources are
available to deal with the incident? What can be done safely to
control it? The answers to these and other questions must be
carefully considered in the earliest stages of a response.

2. Determine Action

After an initial evaluation of the emergency has been made, the Incident
Commander must make a fundamental decision: whether to approach
stabilization and control of the incident from an offensive or defensive
mode. There are a number of factors that must be considered in making
the offensive/defensive decision. Among the most important factors that
affect this decision are life hazard, size and complexity of the incident,
materials involved, and the relative strength (or weakness) of resources
that can be placed into action.

In situations where viable lives are at risk or where prompt, safe stabilization and
control of the incident are considered probable, offensive actions are appropriate.
At incidents involving little or no life risk or where the size of the incident,
materials involved, or lack of appropriate resources preclude prompt stabilization,
defensive action is warranted.

OFFENSIVE ACTION DEFENSIVE ACTION

Viable Lives At Risk No Life Hazard

Manageable Size Large Incident

Material Involved And Associated Hazards

Materials Involved And Hazards Not Known
Known

Needed Resources Available Resources Unavailable

Prompt Stabilization Probable Stabilization Unlikely

3. Establish Initial Goals and Objectives

After making an assessment of the situation and deciding on an

offensive or defensive approach, the Incident Commander must
establish initial goals and objectives. These goals and objectives
should always be realistic and focused on saving lives, stabilizing
the incident, and minimizing economic and environmental impact
caused by the incident. The Incident Commander should consider

39
 a "best case" end result of the incident when developing initial
goals and objectives.

4. Determine Additional Resource Requirements

In most serious hazardous materials emergencies, initial response

resources will not be adequate to stabilize, control, and terminate
the incident. One of the most important functions of the initial
Incident Commander is to determine resources needed and
promptly initiate the appropriate requests for additional personnel,
apparatus, material, equipment, and other assistance required.

5. Deploy Personnel and Units

One of the responsibilities of the initial Incident Commander is to

establish goals and objectives. Closely related to this function is
the deployment of units and personnel in support of these goals
and objectives. An integral element of deploying personnel and
units is issuing specific, objective-oriented assignments.

6. Establish a Command Post

During initial evaluation, it is not unusual for the initial Incident

Commander to move around the scene of an incident in an effort to
obtain complete information. However, in all but the most minor
incidents, it is important that a formal, stationary Command Post be
established promptly. In addition to being located in a safe area,
the Command Post should be easily visible.

C. The Command Post

The Command Post serves as the headquarters for incident operations.

Establishing a Command Post ensured that the Incident Commander is in
a designated area and is, therefore, accessible. An established
Command Post also facilitates gathering and evaluating information,
planning, decision-making, and communications.

The Command Post should be located outside the vulnerable area. Yet, it
should be visible so that personnel and units can see and identify the
command area. Whenever possible, the initial Command Post should
also afford the Incident Commander with a view of the incident scene.

D. Passing Command

While Incident Command Systems recommend that the person in charge

of the first arriving unit establish initial incident command, a practice

40
 known as passing command is used by some fire departments. Passing
command takes place when the person in charge of the first arriving unit
passes the responsibility for command to another individual who is
expected to arrive later. This person is typically notified by radio while in
transit. No member of the first arriving unit takes overall command, so
there is no face-to-face transfer of command as described below.

The principal reason for passing command is that the person in charge of
the first arriving unit is compelled to take an active, hands-on role in
tactical operations immediately upon arrival. This makes it impossible to
fill the Command function,

Passing command is not recommended when dealing with hazardous

materials incidents. The primary and generally overriding responsibility of
the person in charge of the first arriving unit is to assume the Command
function. During a hazardous materials incident, command should be
passed to another individual only in situations where the immediate,
hands-on involvement of the first arriving officer is needed to save a life or
lead to immediate stabilization of the incident.

E. Transfers of Command

As a hazardous materials incident evolves, it is likely that transfers of

command will take place. The most critical transfers of command occur
while the incident is still escalating. Typically, ranking or more highly
trained officers arrive on the scene and subsequently assume the function
of Incident Commander. The transfer of command is a transaction
between two parties. The responsibility for initiating the transaction rests
with the person who desires to assume command. Once this request has
been made, it is the responsibility of the incumbent Incident Commander
to brief the new Incident Commander on the incident situation, the action
plan in effect, the status of resources at the scene, and any unusual safety
problems. After this exchange of information, the new Incident
Commander then assumes the Command function.

Transfer of command is also likely to occur as an incident winds down. In

this case, ranking officers may wish to leave the scene and turn over
incident termination activities to others. Here, it is the responsibility of the
Incident Commander to state the intent to relinquish command and to
designate the person to whom the Command function will be transferred.

INCIDENT TERMINATION
An often overlooked but essential element of incident management deals with
those actions that take place after the incident has been stabilized. This section

41
discusses some general command activities during disengagement and
termination, and provides an overview of issues that are unique to hazardous
materials emergencies.

A. Command Activities During Termination

Even after an incident has been stabilized, the job of the Incident
Commander remains essential. The key functions and structure of an
Incident Command System, including the Operations, Planning, Logistics,
and Finance functions, must be maintained throughout the incident. In
fact, since disengagement and termination can take place over a
considerable period of time, functions such as Logistics and Finance may
increase in importance.

The Incident Commander should also implement an organized plan for

rotating personnel. The plan should ensure that personnel subjected to
the stresses of the initial response and control efforts are rotated to
rehabilitation areas. A sufficient number of trained teams must be
available to ensure that personnel are not overworked. As soon as
feasible, initial responders should be released from duty at the scene
altogether. All too often, the First Responders arriving first on the scene of
an emergency are the last to leave. This practice is not appropriate.
Fatigued personnel are particularly vulnerable to injuries and exposures.

Transfer of command will continue to take place during the termination

phase of an incident. These are typically transfers "down" rather than the
transfers "up" that occur in the initial phase of an incident. Also, the
process of sizeup must continue after the incident has been stabilized. On
an ongoing basis, the Incident Commander must assess incident goals
and objectives, resources, risks and benefits, among other factors that
continue to have an effect on the incident.

B. Considerations Specific to Hazardous Materials Incidents

The command activities described above must be carried out while

considering several issues that are unique to hazardous materials
incidents. First, there are likely to be ongoing hazards to operating forces
and civilians. Typically, hazardous materials incidents are considered
stabilized or "under control" when the leak, spill, or fire has been
contained. However, this may not indicate that the danger to operating
forces or others has passed. There may be continued risk of ignition or
explosion. And, there is likely to be ongoing potential for exposure to the
materials involved.

42
 Decontamination of personnel and equipment exposed at a hazardous
materials incident mar major issues. An obvious concern is the health of
exposed individuals. There is the additional concern that contaminated
individuals or equipment could result in additional exposures.
Considerable organizational and material resources are necessary for
decontamination through disengagement and termination.

A major goal of decontamination during the termination phase is to make a

strong final effort to ensure that secondary contamination does not occur.
In order to meet this objective, a comprehensive plan must be used to
identify all equipment that requires decontamination. Equipment that
cannot be decontaminated at the incident scene must be properly and
safely contained so that it can be decontaminated at an appropriate facility
using approved methods. The interests of the community are not served
when contaminated equipment is returned to service.

There is no escaping the fact that hazardous materials raise legal and
political concerns. In addition to the cleanup issue discussed below, a
number of other issues may arise, such as jurisdiction disputes, the length
of the time a major highway should remain closed, and the status of
persons displaced from their homes or places of business. There may be
a great deal of pressure on the Incident Commander to remove
restrictions on an area before it is appropriate to do so.

Finally, a complete accounting of the response effort is necessary,

particularly for extensive operations. While recording of financial and
other response data should be started early in the incident and continued
throughout, special attention can be given to this task during the
termination phase.

C. Cleanup Activities

Among the most sensitive issues in hazardous materials response is

cleanup. At the heart of the cleanup issue is the question of where the
responsibility of emergency response personnel ends and where that of
manufacturers, shippers, and processors begins. Pre-incident planning
can help establish the responsibilities of the parties involved as well as the
responsibilities of any cleanup contractors.

In general, the role of HazMat Responders and fire department Hazardous

Materials Teams focuses on emergency response and public safety. Most
Hazardous Materials Teams are neither equipped or trained to engage in
extensive cleanup efforts. Whenever possible, responsibility for cleanup
should be assumed by those responsible for the initial release. These
efforts should be undertaken by a qualified cleanup contractor. Oversight

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 and supervision of these activities should be retained by Hazardous
Materials Teams as part of their role in ensuring public safety.

In some cases, the party responsible for a release may not be known or
may be incapable of providing the resources required to clean up the site
following stabilization of the incident. In such cases, the role of the
Hazardous Materials Team may be broader, though outside contractors
and other public agencies should be available for support and assistance.

Regardless of the specifics of a particular incident, it is the function of the

Incident Command System and the specific role of the Incident
Commander to ensure that cleanup efforts proceed safely as part of the
termination phase of the incident. The appropriate degree of management
and command process must be maintained as cleanup efforts are
undertaken.

INCIDENT COMMAND SYSTEMS AND THE INTEGRATED

EMERGENCY MANAGEMENT SYSTEM
Fire departments, as community-based organizations, do not exist in a
vacuum. They interact with a number of other government and private
entities in carrying out the fire service's mission to protect lives and
property. For example, most fire departments interact with police
agencies and hospitals on an ongoing basis.

Since the stabilization and control of hazardous materials emergencies

often require the combined efforts of a number of agencies and
organizations, it is necessary that the Incident Command Systems of the
fire service be able to interact effectively with similar plans and systems
used by other emergency response and relief organizations.

Acknowledging that there is a need for community-wide planning to deal

with emergencies, the Federal Emergency Management Agency (FEMA)
has sponsored an effort called the Integral Emergency Management
System (IEMS). The goal of IEMS is to develop and maintain a credible
emergency management capability nationwide by ensuring that all levels
of government carefully plan for major emergencies and disasters. IEMS
is applicable to all jurisdictions regardless of size, sophistication, potential
hazards, and current emergency response capabilities. FEMA should be
contacted for more detailed information on IEMS.

IEMS was developed on the assumption that there are certain

requirements common to all major emergencies and disasters. Examples
of these common elements include immediate emergency response,
evacuation, shelter, and medical care.

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 How does IEMS relate to a fire department Incident Command System?
First, fire department members responsible for the development of
Incident Command Systems must consider not only their own concerns
and capabilities, but also those of other organizations in the community.
From a larger perspective, it is vitally important that fire departments be
active participants in community-wide planning for large scale
emergencies and disasters.

Fire department Incident Command Systems and IEMS efforts should be

considered complementary in that Incident Command Systems should be
capable of being integrated into IEMS and vice versa.

SUMMARY
An Incident Command System is essential for all aspects of emergency response
to hazardous materials incidents. A well-structured Incident Command System
applies to small, local incidents as well as to large, regional responses.
Hazardous materials incidents are characterized by unexpected events. The
effects of such events can be minimized only through the use of this coordinated
structure for organizing and directing resources.

Outline of the Requirements of a Medical

Surveillance Program
A. Introduction

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 1. Identify Specific Site Hazards

a. chemical

b. other

2. Define Workers' Exposure

a. exposure - 29 CFR 1910.1200 defines as "any employee

subjected to a hazardous chemical in the course of
employment through any route of entry

b. routes of entry

(1) inhalation

(2) absorption

(3) ingestion

3. Determine Physical Effects

a. acute

b. chronic

c. types

(1) irritants

(2) anesthetic or narcotic

(3) carcinogens

(4) teratogens

(5) systemic problems

B. Basic Requirements

1. Employees That Must be Covered are Those Who:

a. are exposed to a health hazard more than 30 days per

46
 year

b. wear a respirator for 30 days or more a year

c. have been injured due to overexposure

2. Required Frequency of Medical Exams

a. prior to assignment

b. annually

c. termination of employment/assignment

d. reassignment

e. development of signs or symptoms of a medical condition

f. emergency situations

g. as determined by a physician

3. Medical Provider

a. list qualifications

b. define services

c. reports - records

(1) access

(2) maintenance

(3) annual reports

4. Content of Medical Evaluation

a. Detailed Work/Medical History

b. medical testing

c. physical examination

d. physician's report

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 5. Designate and Empower Site Safety Officer

a. responsible to employer

b. authority to develop and implement site safety and health

programs

C. Pre-Employment/Pre-Assignment Physicals

1. Work/Medical history

2. History of respiratory or cardiovascular diseases

3. Past and current use of medication

4. Any known physical abnormality or deformity

5. Previous occupations

6. Problems associated with breathing difficulty during normal

work activities

7. past problems with respirator use

D. Fitness to Work

1. identify potential exposures

2. routine job tasks

3. personal protective equipment

4. physical condition

E. Baseline Monitoring

1. acute exposure

2. comparison of sequential medical testing

3. biological trend analysis

F. Required Frequency of Medical Exams

1. prior to assignment

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 2. annually

3. termination of employment/assignment

4. reassignment

5. development of signs or symptoms of a medical condition

6. emergency situations

7. as determined by a physician

8. exposure to toxic hazard

9. change in health status

10. change in site hazard

11. change in exposure

12. biological trend analysis

G. Routine Medical Test Frequently Performed for Medial

Surveillance

1. Audiogram

a. test ears to include test frequencies 500, 1000, 2000,

3000, 4000 & 6000 Hertz.

2. Pulmonary function test

a. test lungs to include a FVC (Forced Vital Capacity at 1

second). Determines amount of air lungs are able to hold
and expire in one second.

3. Electrocardiogram

a. test heart to include a 12-lead tracing at rest. A "stress

test" may be indicated when heat stress may occur or if a
history of heart disease exists.

4. Vision test

a. to include near and far results.

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 5. Chest x-ray

a. chest x-ray to include a two view (anterior/posterior) 14 x

17" film.

6. Laboratory studies

a. cardiac profile - blood test to include cholesterol-LDL/HDL

& triglycerides

b. kidney- blood tests to include a total protein, albumin,

globulin, total bilirubin, alkaline, phosphatase, GGTP, LDH,
SGOT, & SGPT.

c. complete blood count (CBC) to include a hematocrit,

hemoglobin white cell count, red cell count, differential, and
platelet evaluation with erythrocyte indices.

d. multiple urinalysis to include color, appearance, specific

gravity, pH, glucose, protein, bile, acetone, occult blood, and
microscopic.

H. Termination Medical Exam

1. Work/medical history

2. Medical testing and physical exam

I. Post-Exposure to Health Hazard

1. Acute exposure at worksite

2. Change in health status

3. Periodic monitoring indicates biological change

J. Criteria for Limited Medical Exam

1. Last full medical exam within the last six months

2. No exposure occurred since last exam

3. No symptoms associated with exposure occurred since the last

exam

K. Medical Records

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 1. Record Keeping

a. future reference for long-term health monitoring

b. may be used to conduct future epidemiological studies

c. to report worker's medical conditions

2. Regulatory Requirements for Medical Records

a. protect workers confidentiality

b. make available to workers the results of medical testing

and physical exam

c. maintain and preserve medical records on exposed

workers for 30 years after they leave employment

d. maintain records on occupational injuries and illnesses

and post a yearly summary report (29 CFR Part 1910.20)

DRUG SCREEN TESTING

A. Employer Responsibility - Employers have the legal responsibility to

maintain a safe workplace for all employees (OSHA General Duty
Clause). Recent studies show that substance abuse takes its toll on the
health and safety of the employees and cost U.S. industry tens of billions
of dollars each year in reduced productivity, product quality, employee
injuries, damaged equipment, theft, and increased medical costs.

Employers who are considering action to combat drug abuse

problems must realize that substance abuse is a complex problem
that has generated a minimal amount of case law for guidance.

B. Liabilities/Cost-Why Test?

1. Potential Liabilities-Employers "right to test" has been the focus

of concern regarding potential liability but it is important to realize
that certain employers may be at greater risk for NOT testing.

TO TEST NOT TO TEST

a. Right to privacy a. Public safety

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b. Confidentiality b. Public trust

c. Discrimination c. Safe workplace

d. Negligence d. Negligence

e. Handicap Law

f. Rehabilitation Act

g. Employment-at-will doctrine

2. Public Safety-Certain employers have a legal duty to ensure

public safety, such as, airline pilots, air-traffic controllers, bus
drivers, etc.

3. Public Trust-Certain employers have a legal duty to ensure

public trust, such as policemen, firemen, hospital workers, etc.

4. Fitness for Duty-Employers have the right to expect employees

to report to work free from the effects of alcohol or drugs.

5. Cost of Drug Screen Testing-Employers need to recognize that

the cost of drug screening will be far more that the charge for the
drug screen test itself. Many company practices will be effected and
require change, i.e., hiring practices, pre-employment physicals,
policies, procedures, employee assistance, etc.

C. Policies and Procedures-What to do?

1. The drug abuse problem should be addressed by top

management in company health and safety directives and
employee manuals. Policy Statement - Need to perform drug
screen testing

a. ensure a safe workplace

b. ensure public safety

c. ensure public trust

d. ensure fitness for duty

2. Procedures - There are methods for reducing or preventing drug

abuse which, if implemented in a reasonable way, are legal.

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 a. inform employees of drug screen testing policy and
procedures.

b. identify employees to be tested-consent form.

c. method for specimen collection, handling, storage,

transportation, retention, and record-keeping.

d. chain-of-custody form must accompany specimens to

maintain integrity of the specimen.

e. provisions for confidentiality

f. test results-negative/positive

g. action if policy is violated

h. provisions for rehabilitation/EAP.

3. Drug Screening-When to test

a. Pre-employment/Pre-assignment Physicals

(1) advise applicant of drug screen testing-signed

consent form

(2) document any medications taken within the last

thirty days

b. Post-accident drug screen testing-urine and blood

samples collected within a reasonable time.

c. "For Cause" drug screen testing-urine and blood samples

collected with consent from employee.

D. Laboratory Selection-Who does testing

1. Credentials/license/qualifications.

2. Testing procedures/quality control/experience.

3. Chain-of-Custody.

4. Specimen collection/handling/transportation.

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 5. Test results/confidentiality/record-keeping.

6. Test results turn-around-time.

E. Drug Screen Testing Techniques-How to do testing

1. Specimen collection

2. Substances to test.

3. Screen/confirmation-RIA/EMIT/GC MS.

4. Chain-of-Custody.

5. Legal/Illegal drugs detected.

6. Test reliability.

7. Limits of detection (LOD).

DRUGS FREQUENTLY TESTED

Approximate retention times of drugs in urine.

DRUG/CLASS RETENTION TIME

Amphetamines (Speed) 1-2 days

Barbiturates (Sleeping pills) short-acting(secobarbital):1-3 days

long-acting(phenobarbital):1-3 wks.

Benzodiazepines (Valium) 1-14 days

Cannabinoids (Marijuana) occasional use: 1-7 days

chronic use: 1-4 weeks

Cocaine (Coke, Crack) 12-48 hours

Methadone 1-3 days

Methaqualone (Quaaludes) 1-7 days

Opiates (Opium) 1-3 days

Phencyclidine (PCP,angel dust) occasional use: 1-8 days

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 chronic use: up to 30 days

Propoxyphene (Darvon) 1-3 days

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