BY GREGORY G. NOLL
The threat of terrorism involving weapons of mass destruction (WMD), combined with the increasing use of hazardous materials in criminal activities, has significantly altered the traditional philosophies of hazmat emergency response. Today, the classic distinctions between offensive and defensive tactics, the cornerstones of national hazmat operations standards since the 1980s, are blurred by the development of newer tactical and operational procedures designed to meet these emerging threats and demands.
The information below is intended to provide emergency response personnel with background information to assist them in assessing their current hazmat/WMD training program and to provide an overview of those regulations and voluntary consensus standards that should be consulted to ensure that their personnel have the requisite skills and competencies to perform their expected tasks. Specific emphasis is placed on the recently revised National Fire Protection Association (NFPA) Technical Standard 472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents (2008 edition).
The NFPA is a voluntary consensus standards writing organization. Although commonly associated with the fire service, the NFPA develops and publishes voluntary consensus standards on a wide range of fire protection and safety topics. NFPA standards are developed through more than 200 technical committees, each comprised of representatives from manufacturing, research and testing, regulatory enforcement, users, and subject matter experts. NFPA standards are also developed in accordance with and accredited by the American National Standards Institute (ANSI).
(1) Tactical team personnel receive decon support. (Photos by author.)
Under NFPA policies, a technical committee’s membership must reflect the “community” that the standard impacts. Although commonly seen as a fire service standard, NFPA 472 is actually an emergency responder standard, and its technical committee reflects the multidisciplinary nature of hazmat/WMD emergency response. The current NFPA 472 Technical Committee consists of 33 members from the following disciplines: fire service; law enforcement; emergency medical services (EMS); industry, including hazmat manufacturing and transportation; training and education community; research and testing laboratories; federal government agencies; and subject matter experts.
NFPA 472 is not a procedures-based “how to respond” technical standard. Rather, it addresses the minimum competencies required for those who may respond to hazmat/WMD incidents and are necessary for a risk-based response. Although NFPA 472 is not a fire service professional qualification standard, it is adopted by reference by NFPA 1001, Standard for Firefighter Professional Qualifications.
EMERGENCY RESPONDER HEALTH AND SAFETY: HAZMAT VS. WMD
During the past decade, hazmat/WMD training philosophies have evolved into two schools of thought: (1) WMDs are distinctly different from hazmats and should be viewed as a separate and distinct field; and (2) you cannot safely respond to WMD events if you don’t first understand hazmat response and safety. According to the NFPA 472 Technical Committee’s philosophy, an emergency responder cannot safely and effectively respond to an incident involving the criminal use of hazardous materials/WMDs without first understanding the basic hazmat emergency response principles that have existed for the past 30 years.
What are the differences between a hazmat and a WMD incident? From a health and safety viewpoint, very little. Hazmats can be any matter (solid, liquid, gas, or energy) that, when released into the environment, can be harmful to people, property, or the environment. Weapons of mass destruction, as defined by Title 18 U.S. Code, describe the same materials and effects but in measurable quantities. The primary difference between these two lies in the events leading up to the releasewhether it was an accidental release or done with criminal intent. In summary, although the events that lead each response discipline to a hazmat/WMD incident may vary, the actions that responders implement on arrival are typically the same.
As emergency responders and agency administrators, many of us have been tasked with developing or improving our agency’s hazmat/WMD response capabilities. The U.S. Occupational Safety and Health Administration (OSHA) provides guidance to public and private entities that are responsible for hazmat emergency and postemergency response operations, through 29 CFR 1910.120 Hazardous Waste Operations and Emergency Response. In addition, the U.S. Environmental Protection Agency also provides comparable regulations through 40 CFR 311. It is important to recognize that although originally promulgated to improve hazmat safety, they are also applicable to incidents involving WMD threats and agents.
Both the OSHA 1910.120 and EPA 40 CFR Part 311 regulations provide specific requirements for the skills and competencies required for personnel who will respond to or work at hazardous materials incidents. From a historical perspective, the OSHA 1910.120 requirements were originally derived from early drafts of NFPA 472 as the OSHA regulation was being developed in the late 1980s.
Regardless of response discipline, the personnel skills and competencies to respond to hazmat/WMD incidents must meet the requirements of OSHA 1910.120(q). Although OSHA 1910.120(q) tells you what you must do, NFPA 472 provides the authority having jurisdiction (AHJ) with specific guidance on the skills and competencies for personnel to perform their expected tasks as outlined by their organizational concept of operations.
NFPA 472: A TOOL TO TRAIN YOUR PERSONNEL
The NFPA 472 Technical Committee was formed in 1986, and the first edition of NFPA 472 was published in 1989. Although some nonfire responders view it as a “fire service only” standard, the scope of NFPA 472 specifies minimum competencies for those who will respond to hazmat/WMD incidents, regardless of their agency or response discipline. Since its initial release, NFPA 472 has gone through five revisions; 2008 is the most recent. In contrast, OSHA 1910.120 has not been revised since its initial promulgation in 1989. Most would agree that the world is significantly different today than it was in 1989.
(2) Tactical team personnel operating in contaminated environments are now routinely provided with personal protective clothing and air-monitoring equipment.
In developing the 2008 edition, the NFPA 472 Technical Committee decided to take a “holistic approach” during the revision process and reexamine the philosophy and framework on which the standard was developed. In simple terms, everything was on the table for discussion. As part of this process, the Technical Committee focused on (1) the blurred distinction between “traditional hazmat response” and its relationship to the growing hazmat/WMD terrorism response issues and (2) a perception that the current standard does not address the needs of the emergency response community as a whole and is merely a “fire service” document. Ultimately, the NFPA 472 Technical Committee wanted the standard to focus on responders being trained to perform their expected tasks, regardless of their discipline.
As a result, NFPA 472 (2008 ed.) has been revised with several key operational philosophies in mind:
- Emergency response operations to a terrorism or criminal scenario using hazmats are based on the basic concepts of hazmat response. In simple terms, responders cannot safely and effectively respond to a terrorism or criminal scenario involving hazmats/WMDs if they don’t first understand the basic principles and concepts of hazmat response.
- The scope of NFPA 472 applies to all emergency responders, regardless of response discipline, who may respond to the emergency phase of a hazmat/WMD incident. In simple terms, if you are ‘called or tasked to respond’ to a hazmat/WMD incident, you fall within the scope of the standard.
- It provides a vehicle by which an AHJ can meet the training requirements of OSHA 1910.120(q). Emergency responders, regardless of their discipline and organizational affiliation, should be trained to perform their expected tasks. Given the real-world demands of limited time and resources, training should focus on an individual’s expected duties and tasks.
NFPA 472 KEY REVISIONS
Traditionally, any discussion on hazmat emergency responder training requirements has always focused on the responder level of the individual (i.e., awareness, operations, technician, and so forth), instead of addressing the follow-up OSHA 1910.120 (q)(6) requirement that “… training shall be based on the duties and function to be performed by each responder of an emergency response organization.”
The net result is that responders have often received training in areas that clearly do not fall within their concept of operations or response capabilities. Examples include all first responder-operations personnel being trained to perform defensive product control measures and the use of self-contained breathing apparatus when some are not issued SCBA or expected to perform product control or technical decon tasks. A major goal of the NFPA 472 (2008 ed.) revision was to facilitate matching required skills and competencies with expected duties and tasks.
The following summarizes the NFPA 472 (2008 ed.) changes that will potentially have an impact on hazmat/WMD emergency response operations.
Standard Scope and Purpose. The scope and purpose of NFPA 472 (2008) are based on the following basic principles:
- Emergency responders, regardless of their discipline and organizational affiliation, should be trained to perform their expected tasks.
- Required competencies are necessary for the delivery of a risk-based response process at a hazmat/WMD incident. Note: Risk-based response process is defined as a systematic process by which responders analyze a problem involving hazmat/WMD, assess the hazards, evaluate the potential consequences, and determine appropriate response actions based on the facts, science, and circumstances of the incident.
- Personnel not directly involved in providing on-scene emergency response services (e.g., hospital first receivers) are not covered under the scope of NFPA 472. Likewise, competencies for EMS personnel remain in NFPA 473, Standard for Competence of EMS Responders Responding to Hazardous Materials/Weapons of Mass Destruction Incidents (2008 ed.).
Hazmat vs. WMD vs. CBRNE.A variety of terms have been used to describe terrorism agents and the criminal use of hazmats, including NBC, B-NICE, CBRN, and CBRNE. However, these terms do not have a regulatory basis and continue to change fairly regularly.
(3) US&R hazmat specialists practice the responder extraction and technical decon.
The NFPA 472 Technical Committee ultimately chose to define hazardous materials as “Matter (solid, liquid or gas) that when released is capable of creating harm to people, the environment, and property. This includes Weapons of Mass Destruction (WMD), as defined in 18 US Code Section 2332A, as well as other criminal use of hazardous materials, such as drug labs, environmental crimes, or industrial sabotage, etc.” This incorporates both hazmats and WMDs into a single definition and allows for hazmat and WMD competencies to be combined into a single document.
Awareness-Level Personnel.There is a major departure in how awareness-level responders have traditionally been viewed. A significant change is dropping the term “responder” from the awareness level, as these individuals are typically not emergency responders. Examples of awareness level personnel would include plant security, public works, facility maintenance personnel, and others who require OSHA Hazard Communications (OSHA 1910.1200) training.
(4) Law enforcement personnel conducting sampling operations at a simulated clandestine lab.
Awareness-level personnel are now defined as “persons who, in the course of their normal duties, could be the first on the scene of an emergency involving a hazmat/WMD and who are expected to recognize the presence of hazmat/WMD, protect themselves, call for trained personnel, and secure the area.” In simple terms, they are the “first to discover” rather than the “first to respond.”
Historically, some have viewed firefighters and EMS personnel as awareness-level responders who would be able to recognize a hazmat release from a safe distance and then activate the local emergency response plan. Today, however, with the threat of terrorism and the growing trend of illicit drug labs, firefighters, law enforcement, and EMS personnel are now expected to do far more than observe from a safe distance. In addition, a large number of law enforcement and EMS personnel are now being provided with personal protective clothing as a result of potential WMD threats. As a result, these respondersas per OSHA 1910.120(q)are now expected to perform tasks that go far beyond the traditional awareness-level tasks of recognition, notification, and self-protection.
Operations-Level Responder. The most substantial revisions to NFPA 472 (2008 ed.) pertain to the operations-level responder, and these reflect the changes in the hazmat response community created by the WMD and criminal use of hazmat threats. These revisions will also facilitate the adoption and use of NFPA 472 by nonfire service disciplines. There are no significant changes for fire service personnel who were previously trained to NFPA 472 (2002 ed.) operations-level requirements.
If an individual is tasked to respond to the scene of a hazmat/WMD incident during the emergency phase, that person is now viewed as an operations-level responder. In simple terms, if the local emergency response system is activated (e.g., by a 911 call) and an agency is tasked to respond to the scene to provide on-scene emergency services, members of that agency are viewed as operations-level responders. This would include fire, rescue, law enforcement, emergency medical services, private industry, and other allied professionals.
To better address the issue of matching requisite skills and competencies with expected duties at the operations-level, NFPA 472 (2008 ed.) breaks the operations-level competencies into two categories:
Core competencies would be required of all emergency responders who are tasked to respond to a hazmat/WMD incident. However, these core competencies do not include any product control and personal protective clothing and equipment competencies, and decon is limited to the ability to perform emergency decon. Although there are clearly some additional requirements pertaining to initial incident analysis, these new proposed core competencies are not significantly greater than the NFPA 472 (2002 ed.) awareness competencies.
Mission-specific competencies are optional and are provided so that the AHJ can match the expected tasks and duties of its personnel with the required competencies. Mission-specific competencies are not mandated and should be viewed as optional at the discretion of the AHJ based on an assessment of local risks.
Mission-specific competencies were developed by (1) combining NFPA 472 (2002 ed.) hazardous materials technician competencies in a specific area (e.g., use of PPE, product control, technical decon, and so forth) and (2) developing new competencies where needed (e.g., victim rescue and recovery, evidence preservation). They allow emergency responders to perform mission-specific tasks without being fully trained to the hazardous materials technician level.
Mission-specific competencies include the following:
- use of personal protective equipment as provided by the AHJ,
- technical decontamination,
- mass decontamination,
- product control,
- air monitoring and sampling,
- victim rescue and recovery operations,
- evidence preservation and sampling, and
- response to illicit laboratory incidents.
This shift to operations-level core and mission-specific competencies more accurately describes the tasks currently being performed by all emergency response disciplines in light of current threats.
Some individuals have legitimately questioned the ability of operations-level responders to perform traditional hazardous materials technician tasks. To ensure the safety of personnel performing mission-specific competencies, NFPA 472 (2008 ed.) also requires that the optional mission-specific competencies be performed under the guidance of either a (1) hazardous materials technician; (2) an allied professional (e.g., certified industrial hygienist, subject matter expert, product specialist, etc., as determined by the AHJ); or (3) standard operating procedures.
Although there are minimal changes for the fire service, this does represent a change for the law enforcement and EMS community. Historically, many law enforcement and EMS providers have viewed themselves as awareness-level personnel. Under the revised NFPA 472 (2008 ed.), most law enforcement patrol officers would be trained to the operations core competencies, while law enforcement specialized operations, including SWAT, explosive ordnance disposal (EOD), mobile field force, and forensic units with a higher probability of hazmat/WMD exposure, would be trained to those mission-specific competencies based on their concept of operations and expected duties.
NFPA 1001 (2008 ed.)Firefighter I. Historically, NFPA 1001 Firefighter I candidates were only required to be trained to the awareness level. To resolve conflicts between NFPA 472 and NFPA 1001 and ensure consistency with OSHA interpretations that firefighters should be trained to the operations level, NFPA 1001 (2008 ed.) has also been revised so that a Firefighter I shall now be required to meet the NFPA 472 core competencies for operations-level responders and the mission-specific competencies: product control.
There are minimal differences between fire service personnel who were previously trained to NFPA 472 (2002 ed.) operations-level requirements and those who will be trained to the NFPA 472 (2008 ed.) core competencies for operations-level responders and the mission-specific competencies: product control. As a result, few changes should be required to those fire service training curriculums that previously certified firefighters to the NFPA 472 (2002 ed.) competencies for operations-level responders.
EMS personnel.Competencies for EMS personnel are published in NFPA 473, Standard for Competence for EMS Personnel Responding to Hazardous Materials/Weapons of Mass Destruction Incidents (2008 ed.). NFPA 473 (2008 ed.) has been completely rewritten to address the hazards that EMS personnel encounter from hazmats/WMDs.
Under NFPA 473 (2008 ed.), all EMS personnel operating at hazmat/WMD incidents shall be trained to meet the NFPA 472 (2008 ed.) operations-level core competencies. Remaining competencies are based on whether the individual is a basic life support (BLS) responder (e.g., EMT-A/B, emergency care first responder) or an advanced life support (ALS) responder (e.g., EMT-I, EMT-P, medical director, medical team specialist).
Hazardous Materials Technician.There are no significant changes to hazardous materials technician competencies. However, the definition has been revised to better clarify the expected competencies. A hazardous materials technician is a person who responds to hazmat/WMD incidents using a risk-based response process by which they
- analyze a problem involving hazmat/WMD,
- select applicable decontamination procedures, and
- control a release using specialized protective clothing and equipment.
Similarly, the definition of a hazardous materials response team (HMRT) has been modified to specifically reference that HMRTs perform hazardous materials technician-level skills and must be staffed with personnel trained to the hazardous materials technician level.
Given that hazardous materials entry units are a typed resource under the National Incident Management System (NIMS), the NFPA 472 Technical Committee believes that this will ensure consistency in operational capabilities. In addition, the NIMS Resource Typing Standards reference NFPA 472 as the basis for hazardous materials entry unit training.
The revision of NFPA 472 (2008 ed.) is another step in the growth and maturation of the hazmat/WMD response community. Changes to the 2008 edition can be summarized as follows:
- The technical standard better reflects competencies for all responders to hazmat/WMD incidents and provides more flexibility in meeting discipline-specific mission requirements while maintaining a high standard.
- The technical standard integrates WMD issues and removes the need for two stand-alone documents.
- Awareness-level personnel are no longer viewed as emergency responders.
- Operations-level responders can be trained in mission-specific tasks without being fully trained to the hazardous materials technician level.
- There are no major changes to other training levels.
Rather than trying to fit emergency responders into a regulatory box, NFPA 472 (2008 ed.) provides emergency response agencies with a competency-based framework to ensure that emergency responders are trained to perform their expected tasks and assigned duties. In addition, training programs designed to meet the requirements of NFPA 472 (2008 ed.) will far surpass the regulatory requirements of OSHA 1910.120 (q).
GREGORY G. NOLL, CSP, CHMM, has 37 years of experience in the fire service and emergency response community and is a senior partner with Hildebrand and Noll Associates, Inc., a consulting firm specializing in emergency planning, response, and incident management issues. He is the program manager for the South Central Task Force, one of nine regional task forces established throughout Pennsylvania. He is also the hazmat/WMD manager for PA-TF1, US&R. He is the coauthor of nine textbooks on hazmat emergency response and management topics and is the chairperson of NFPA 472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents. He is a certified safety professional and hazmat manager and a member of the Fire Engineering editorial advisory board and the FDIC Educational Advisory Board.