HAZARDOUS-MATERIALS RESPONSE: KNOW YOUR LIMITATIONS

BY DAVID F. PETERSON

As emergency responders, we know there are many gray areas when it comes to our decision making, especially when it comes to hazardous-materials (haz-mat) incidents. Standard operating guidelines or procedures help to clarify our actions, but what we should do in certain situations is still unclear. Some responders seem to be unclear about two issues especially: (1) the limitations of the First Responder-Operations and the Technician levels of haz-mat response as designated by the U.S. Occupational Safety and Health Administration (OSHA) and (2) the use of structural firefighting protective clothing (SFPC) for haz-mat response.

A clarification of these issues, which are related, will enable responders to operate with increased safety at future haz-mat incidents. To start, the first thing responders must keep in mind in relation to haz-mat response is this statement of “Dirty Harry” (the well-known Clint Eastwood character): “A good man has to realize his limitations.”

THE OSHA REGULATION

A review of OSHA’s Hazardous Waste Operations and Emergency Response regulation, commonly referred to as “HAZWOPER,” [29 CFR 1910.120(q)] is in order. This law, which became final in March 1990, applies to all firefighters and haz-mat response team personnel. The U.S. Environmental Protection Agency (EPA) has issued a similar requirement to cover non-OSHA states.

Paragraph (q) directs agencies to formulate an emergency response plan (ERP) that describes how haz-mat incidents will be handled. The plan must be written and understood by each responder and includes items such as how scene safety will be maintained, how personal protective equipment will be selected, and how decontamination activities will be conducted. Although this regulation and these requirements have been law for nearly 10 years, many agencies are still being cited by OSHA for noncompliance, usually after the incident is terminated.

Paragraph (q) also mandates that response agencies use an incident command system and that an incident commander (IC) oversee all operations at a haz-mat incident. The IC must also ensure that many conditions are met at these emergencies, including the following:

  • safety officer be appointed,
  • the correct personal protective equipment be used,
  • self-contained breathing apparatus (SCBA) be used initially,
  • a buddy system be used,
  • a backup team be present,
  • medical capability with the ability to transport injured responders be on-scene, and
  • a decontamination (decon) capability be established. Many response agencies have been cited for inadequate decontamination efforts.

You had better hit the books or make some calls if you are not doing the above, because these regulations are centered around safety! To avoid responders’ injuries and deaths, and even citations by OSHA, you need to comply. Remember, OSHA has a job to do and will do it, especially when it finds out about your incident. It is very important to realize that you have the power to prevent OSHA from coming to your town!

The HAZWOPER regulation also outlines the limitations of each response level as well as the specific competencies required. The levels range from a very basic responder who needs very little training to very complex levels that require much in-depth training. Keep in mind that the competencies constitute the minimum training OSHA requires. Also, prudent administrators should provide effective ongoing training to maintain personnel competencies and even enhance them. All training should be well documented.

OSHA TRAINING LEVELS
First Responder Level

A first responder is defined as one who, by job description, would initially respond to haz-mat emergencies. This level of responder is by definition a defensive responder, which means that responders should not contact the hazardous material or go near the release area. They should attempt to safely clear the area, keep others out of the area, and call for better-trained and better-equipped personnel to handle the release.

First Responder-Awareness Level
This level of responder would do no more than what is described above and includes law enforcement and emergency medical personnel. No minimum training is prescribed for this front-line responder, but many training programs offer a four-hour class.

First Responder-Operations Level
Firefighters are included in this level. Responders would proceed as described in the first-responder and first-responder-awareness levels. However, because of their equipment, they may also decide to control or divert a haz-mat release while working outside of the danger area. They might take actions such as building a berm to confine a liquid. These actions may be termed “proactive-defensive,” because responders do not come in contact with the released material but can actively control where the product migrates. The main point here, again, is that all first responders should never contact the released hazardous material, at least knowingly. There may, however, be unavoidable and accidental contact with hazardous materials at times; firefighters’ equipment, such as SCBA, should limit any haz-mat exposure. HAZWOPER mandates a minimum of eight hours of initial training for the Operations level.

In addition to HAZWOPER, another document that reinforces a defensive approach for firefighters is National Fire Protection Association (NFPA) 472, Standard on Professional Competence of Responders to Hazardous Materials Incidents, 1997, which states:

“First Responders at the operational level are those persons who respond to releases or potential releases of hazardous materials as part of the initial response to the incident for the purpose of protecting nearby persons, the environment, or property from the effects of the release. They shall be trained to respond in a defensive fashion to control the release from a safe distance and keep it from spreading.” This national consensus standard comes from a committee of our peers and is a very good guideline.

These guidelines seem to be very clear concerning first-responder limitations, yet at many incidents, First Responder-Operations personnel have exceeded their limitations. You may have even witnessed improper haz-mat responses in your own area of the country. This type of response can be very dangerous, and the odds of injury or death may eventually catch up with those responders. To be standing in product releases or conducting offensive operations in the hot or exclusion zone is inviting catastrophe. Not only are these personnel in danger, but the people in charge may be subject to scrutiny by OSHA. This type of situation may fetch a handsome fine, and the possibility of criminal actions through negligence is not totally out of the question. Scary? It should be to the people who respond beyond their limitations.

According to OSHA, the only time First Responder-Operations personnel may be justified in going into a dangerous area (hot zone) at a haz-mat emergency is when people injured at the haz-mat incident need to be rescued. Note, however, that OSHA still considers this a technical violation-a “di mimimas” -which means there would be no fine levied or citation issued. OSHA issued this clarification in 1993 in its interpretive quips (IQs), which are available on the Internet at ; then go to “interpretations.”

Case study after case study shows first responders getting injured or killed as a result of exceeding their limitations. Consider the following actual events.

  • Firefighters responded to an accident involving an overturned tractor trailer. Fire department members found a box-type trailer on its side with paper drums and other containers lying in and around the trailer. A white granular powder was spilling from the damaged containers in the area around the trailer. Fire department members were wearing structural firefighting clothing with three-quarter-length boots and demand-type SCBA.

    Without researching the health effects or other pertinent information about the material, firefighters entered the cargo area of the overturned trailer and began to remove the damaged drums and to upright drums that were still intact. During the incident, members began to complain of a burning sensation around their wrists and ankles. On removing their gloves and boots, several firefighters were found to have first- and second-degree chemical burns caused by exposure to sodium hydroxide.

  • In another haz-mat incident, a fire department was dispatched to a metal-plating facility in which a number of workers were trapped in an open-topped metal tank used for metal processing. Plant workers were engaged in cleaning the tanks and were employing a process using a 15 percent solution of muriatic acid that had not been used before. A worker entered the tank without respiratory protection and was seen shortly thereafter attempting unsuccessfully to exit the tank. Four other workers entered the tank to attempt a rescue. They were also in the tank without respiratory protection. They subsequently collapsed because of the vapors being produced in the tank. More plant workers attempted unsuccessful rescues until the entire plating room was untenable from the fumes.

    Eventually, the fire department was notified. About 15 minutes after notification, firefighters arrived and entered the tank wearing structural firefighting clothing and SCBA. Firefighters were initially unaware that hydrogen cyanide vapor was being produced in the tank. The hydrogen cyanide vapor permeated the exposed skin and their structural firefighting gear when they removed the victims from the tank. Reportedly, 13 firefighters received toxic exposures, and their protective clothing was contaminated. All the plant workers in the tank died of exposure to hydrogen cyanide.

    The National Institute of Occupational Safety and Health (NIOSH) in its Fatal Accident Circumstances and Epidemiology Report concluded that “… a totally encapsulated protective suit should have been worn in the rescue effort. Additionally, adequate means of exit from the confined space (such as life lines, harnesses, or man lifts) were not incorporated into the attempts. The conventional leather turnout gear worn by the firefighters did not give adequate protection against hydrogen cyanide vapor.”

    Now, do you see why we have regulations pertaining to haz-mat response? Obviously, OSHA did not think we did a good enough job of protecting our safety on our own, so it intervened. Actually, one man, Thomas H. Seymour, PE, from OSHA, wrote the entire draft of the original HAZWOPER. The law we see today has changed very little since this wise man compiled this standard to maintain and enhance haz-mat responder safety.

    One last thought concerning the training requirements for each responder level is that job responsibilities define training requirements; training does not define job responsibility. HAZWOPER states that “training shall be based on the duties and functions to be performed by each responder of an emergency response organization.” Therefore, if an emergency responder has not been trained in a specific procedure, he cannot do it during an emergency. For this reason, OSHA has issued clarifications regarding haz-mat responses by Operations Level personnel that may be regarded as offensive.

    OSHA will allow Operations Level personnel to respond offensively to haz-mat incidents, provided each person on-site has had specific training in the task that is required. OSHA calls this “Operations Level-plus specific training,” but it may be called “Operations Level-Enhanced.” This is important for fire departments because of the number of flammable gas and liquid emergencies they respond to each year. Without special training on the hazards of propane and gasoline, for example, responders could not respond offensively to these emergencies. Because this is a special case, OSHA would consider the shutting of a valve or the extinguishment of a propane or gasoline fire by Operations Level firefighters to be a technical violation of HAZWOPER, but a citation would not be issued. So, it behooves first-responder organizations to conduct comprehensive training on how to handle petrochemical emergencies.

    With this special training requirement in mind, one major petrochemical producer has been training firefighters in how to respond to rolled-over fuel tankers. This training consists of drilling holes into these aluminum fuel tanks to facilitate off-loading. Because this type of incident is a haz-mat incident, every responder on-site should be trained in the correct procedures and have the appropriate equipment. Still, in light of HAZWOPER and its training requirements, what fire department would want to respond to these types of emergencies offensively? Since these events do not happen very frequently and the initial training may be a distant memory to the responders, it may be more prudent to have a contractor conduct this procedure.

    Hazardous Material Technician Level

    The Hazardous Materials Technician level responder has been properly trained and is equipped to conduct offensive action. Just like the two previous levels, technicians must possess many competencies to safely operate in the hot and warm zones. Obviously, the closer a person gets to the hazardous material, the more training he will need. Also, technicians are the personnel who make up haz-mat response teams.

    An interesting observation is that there is a glut of technicians across the country; some are not even affiliated with a haz-mat team. These people have taken technician courses at various places, such as technical colleges or through some other institution, and became certified by an institution or their employers. This is fine, as it will help to make a responder safer and more aware of the dangers of haz-mat incidents. The problem with a person’s having technician-based training comes when that person responds to a haz-mat incident outside of his role on a haz-mat team.

    Technician training may confuse responders when they are in a role other than that of a member of a haz-mat team, such as a firefighter (Operations level). The confusion stems from what they can and cannot do based on their role. In other words, a responder must remember which hat he has on when responding. If responding as a firefighter, by definition, the responder must be defensive at haz-mat incidents, despite his previous technician training. Also, a haz-mat technician is only a technician when responding as part of a haz-mat response team and with other technicians.

    To conduct offensive operations at a haz-mat incident, the components mentioned earlier must be in place and overseen by an IC. Briefly, some of those components are the use of the buddy system, a backup team, a safety officer, and a decontamination capability. Most of those positions require technician training. Again, these response guidelines are all part of the HAZWOPER regulation.

    The HAZWOPER regulation lists approximately 24 competencies at the Technician level and requires at least 24 hours for completion. As a minimum standard, it is woefully inadequate. With this minimal amount of training, a person may get a false sense of security pertaining to his haz-mat skills. Even the EPA’s 40-hour Emergency Response to Hazardous Materials Incidents (165.15) course is not enough training for a person to be competent at the Technician level. By contrast, the state of California requires a person to successfully complete a 240-hour course to become a state-certified hazardous material technician. This requirement seems to be more realistic, given the complexity of offensive haz-mat response. Obviously, inadequate or insufficient training imposes a limitation on responders.

    On top of the training limitations at the Technician level is the fact that most public agency haz-mat emergency response teams do not respond to enough haz-mat emergencies to develop and maintain proficiency. Unless you respond on a busy haz-mat team (like the Houston Fire Department haz-mat response team, which responds to more than 1,200 haz-mat emergencies per year), your skills, assuming they were adequate to begin with, will deteriorate over time. Very little training coupled with very little practical or “real world” experience should make some administrators very nervous, especially when the big incident occurs. Experience is a painful teacher, and it is easy to see why this would be a recipe for disaster.

    These were the thoughts of a wise man, Captain Harry White from Nashville, when he said, “Most haz-mat teams are put together with good intentions and little else.” White wondered if departments really knew what they were getting into by diving into the haz-mat response business. He did not see the purchase of equipment and response suits and big trucks as a panacea for the growing haz-mat problem. Nor did he think that some training given to excited and enthusiastic people would solve all the problems. White saw a real need to identify a haz-mat team’s role at haz-mat emergencies to overcome these limitations.

    DEFINE THE TEAM’S ROLE

    Indeed, haz-mat response teams need a clear vision on just what it is the team will do on haz-mat emergencies. Every team should have a mission statement that clearly defines the team’s role and that was formulated with all training and equipment limitations in mind. This mission statement should be posted for all personnel to see, and it should be reviewed often to maintain a focus. Equally important is that all responders have a clear understanding of what they will not do at haz-mat emergencies. In other words, what is outside of the scope of the team’s mission needs to be clear. For instance, many teams have identified that they will not conduct spill cleanup. That role would usually be filled by a licensed and competent contractor.

    A clarification on who does what is extremely important so that responders do not get themselves into precarious positions. As an example, a contractor from a major Midwestern environmental remediation company related an incident at which a local haz-mat team was preparing to “cold tap” an overturned fuel tanker filled with gasoline. (Cold tapping is a process in which a hole is drilled through the outside of an aluminum tank filled with product to off-load the product.) This procedure is an alternative to other methods when the off-loading valves are damaged or cannot be accessed. Cold tapping requires extensive training and is usually a last resort. (The contractor relating this incident has used this procedure only once in his career.)

    The contractor arrived on-scene just before the operation was to begin, but he was able to convince the IC to stop the operation. After discussing the alternatives, a vacuum truck was summoned to the scene, and the contractor’s crew unbolted a sump on the overturned tank and off-loaded the product. The on-site haz-mat team was very surprised that the technique was viable and, furthermore, had never been taught the procedure. To make matters worse, the team had never conducted the cold tap procedure in real life. It did not have the proper equipment, such as fire entry or proximity suits or nitrogen-powered pneumatic tools, and the tanker was not even leaking! To the haz-mat team’s credit, a foam line was pulled and ready.

    Clearly, this team exceeded its limitations; fortunately, its misguided actions were corrected by a knowledgeable, experienced contractor. Also, this team probably was acting outside of its scope or mission. Since no product was leaking from the tanker, it was no longer an emergency or a threat to the public, or even the environment. Off-loading product and uprighting tankers usually are done by a contractor. Few teams in our country do more than stand by and assist the contractor in similar circumstances.

    AVOIDING DANGERS

    Since public agency emergency haz-mat response teams have an important role, what can responders do to avoid dangerous situations in which limitations can be exceeded? The following thoughts should provide assistance.

    During the emergency phase, responders need to do the following:

    • Respond to and set up at the scene safely. Respond from upwind; set up the appropriate hot, warm, and cold zones and the isolation perimeter.
    • Secure the area, and protect the public. “Secure the scene, then think!” Keep this advice given by Stephen L. Hermann from the Arizona Department of Public Safety in mind. Reroute or shut off traffic. Consider evacuations of the area or possibly sheltering people in place. Call for assistance for these tasks.
    • Strive to positively identify the product(s) being released. Do so as safely as possible. Exhaust all resources.
    • Identify the responsible party, and get him to the scene.
    • Perform rescue, if possible.
    • Ask yourself, “Can we favorably change the outcome of this incident?” It is important to answer this question, posed by Gregory G. Noll, Michael S. Hildebrand, and James G. Yvorra, authors of Hazardous Materials: Managing the Incident. Keep your mission and your team’s limitations in mind.
    • Avoid conducting operations for which you have not been trained or are not equipped.

    After the emergency has been stabilized, responders need to stand by and provide assistance to specialists and rely on the expertise that has arrived on-scene.

    Another item to note concerning responder level and training requirements as outlined in HAZWOPER is that there is also an IC level and a level called “Specialties.” Both also have minimum competencies for those who fill these roles.

    MAINTAINING COMPETENCY

    Finally, the HAZWOPER regulation outlines the minimum training each level of responder must receive initially. But what about ongoing or refresher training? HAZWOPER states that “all personnel who have been trained shall receive annual refresher training of sufficient content and duration to maintain their competencies, or they shall demonstrate their competency at least yearly.” HAZWOPER, however, does not provide guidance on how to conduct the refresher training.

    Most departments recognize the need for continual training to maintain and update skills. This is a prudent practice to maintain efficiency and safety and is the same concept as being prepared for structural firefighting. How much haz-mat training should be conducted to maintain skills? According to a study I made of 60 major U.S. haz-mat teams, the average is eight hours per person per month.

    LIMITATIONS OF STRUCTURAL FIREFIGHTING PROTECTIVE CLOTHING

    All responders should be aware of the limitations of SFPC, since it is another reason Operations personnel should not conduct offensive operations at haz-mat incidents. Firefighter gear is not designed to protect the wearer from hazardous materials. The limitations of SFPC are addressed in the following resources:

  • NFPA 471, Standard on Recommended Practice for Responding to Hazardous Materials Incidents. This document states: “Structural fire fighting protective clothing is not intended to provide chemical protection to the user.” Operations level personnel should not handle hazardous materials while wearing this clothing. To do so risks injury.

  • North American Emergency Response Guidebook (NAERG), 1996. On page 343, different levels of protection are defined. Under the SFPC section is stated:

    “Structural fire fighters’ protective clothing provides limited protection from heat, but may not provide adequate protection from the harmful vapors or liquids that are encountered during dangerous goods (hazardous materials) incidents.”

    It also states the following:

    “Each guide includes a statement about the use of SFPC in incidents involving those materials referenced by that guide. Some guides state that SFPC provides limited protection in respect to the chemical that the guide references. In those cases, the responder wearing SFPC and SCBA may be able to perform an expedient-that is, quick-“in and out” operation. However, this type of operation can place the responder at risk of exposure, injury, or death.” (SFPC includes helmet, coat, pants, boots, gloves, hood, and SCBA.)

    In further examination of the NAERG, all but two (#161 and #162) of the 61 total guides state that SFPC will provide only “limited protection” from the materials the guide encompasses. In 28 of the 59 other guides (47 percent), SFPC may be used in fire situations involving the same chemicals but is not effective in spill situations. Finally, 39 guides out of the same 59 (66 percent) state that the chemical protective clothing specifically recommended by the manufacturer should be worn in those chemical releases.

  • The last reference concerning SFPC limitations comes from the manufacturers of SFPC. Every garment produced will have an inside label that states the following:

    “Warning-This garment alone may not provide protection for proximity or fire entry applications or for protection from chemical, radiological, or biological agents.”

    This label exists only if the garment is produced according to specifications in NFPA 1971, Standard for Protective Ensemble for Structural Firefighting, 1997.

    The research concerning the limitations of SFPC is very clear. Using this protective clothing for purposes other than for what it was designed is inviting trouble. In combination with the HAZWOPER regulation, which says Operations level personnel should respond defensively, and the information concerning SFPC’s hazardous-materials limitations, it should be very apparent that firefighters should never be in the hot zone or conducting offensive actions at haz-mat incidents (except for the two situations mentioned earlier).

    In addition to the above, technicians should reconsider the use of SFPC for haz-mat operations. There is an overreliance on SFPC by haz-mat response teams at haz-mat emergencies. As an example, review the November 1997 cover of Fire Engineering. Haz-mat team personnel can be seen wearing their structural firefighting helmets in combination with chemical protective garments. Additionally, many haz-mat teams allow decontamination personnel to wear SFPC. This practice should be prohibited, as decon personnel commonly receive overspray and oversplash during this activity. Not only do we risk injury, but we risk the possibility of becoming contaminated and then spreading the contamination by using SFPC at haz-mat incidents. The use of SFPC at haz-mat emergencies should be reserved for a very short list of situations, and then with several qualifications.

    WHEN TO USE SFPC

    SFPC should be used only for the following reasons:

    • For creature comfort. When the weather is cold, personnel need to keep warm by using their SFPC. However, the SFPC should be covered with proper protection, such as a disposable chemical resistant suit, to prevent contamination. Think of it this way: Would you want to throw away, because of contamination, a $900 SFPC ensemble or an $80 chemical suit?
    • For possible flash fire situations. If there is a possibility of a fire at a haz-mat emergency, then SFPC under a chemical protective garment may be justified. The two or three seconds of protection the SFPC provides may save the responder’s life.
    • For rapid rescue of viable victims by initial responders. This is a judgment call, but do so only with the following precautions. Approach the danger area in teams of two with fully protective equipment-all buttoned and zipped up. Enter only with your SCBA activated and the facepiece on your face. If possible, approach from upwind, get in and out of the area as quickly as possible, and consider decontamination after exiting the hot zone-and before doffing protective equipment. Remember to also consider decontaminating the victims.
    • For possible reconnaissance (recon) missions where contact with hazardous materials is avoided and prohibited.

    The reasons many responders wear SFPC at haz-mat incidents are many. It is what we have readily available, it is easy to get into, we get a sense of security while in it, and it is habit. We should rethink our habits. Is it safe? Evidence and research indicate otherwise. One other reason to avoid wearing SFPC to haz-mat incidents may be to practice for the big incident where our actions are especially critical. How do we practice for the big incidents? By taking advantage of and practicing on the little incidents. This is also how we break old habits and form new ones.

    My intention is to motivate you to rethink how we respond to haz-mat incidents-how you respond, what you do, and what you should not do to keep your health and safety intact. Revisit the regulations from time to time, and conduct a self-inventory to see how you and your organization measure up. It is all about safety. The best way to be safe is to know your limitations.

    References

    • National Fire Protection Association (NFPA) 471, Standard for Recommended Practice for Responding to Hazardous Materials Incidents, 1997.
    • NFPA 472, Standard on Professional Competence of Responders to Hazardous Materials Incidents, 1997.
    • Noll, G.S., M.S. Hildebrand, J.G. Yvorra. Hazardous Materials: Managing the Incident. (Fire Protection Publications, 1988).
    • North American Emergency Response Guidebook, 1996.
    • OSHA 29 CFR 1910.120, HAZWOPER.
    • “OSHA Compliance: A Word to the Wise,” Kenneth Jeffery and Nicholas A. DeLia, Fire Engineering, March 1992, 75
    • “Surviving a Hazardous Materials Incident,” International Association of Fire Fighters, 41,45.

    DAVID F. PETERSON, a 20-year veteran of the fire service, is a lieutenant in a career fire department and owner of Americhem Safety & Environmental, LLC, a training and consulting firm in Janesville, Wisconsin. Previously, he was a training officer and hazardous materials response team member. He is an adjunct instructor at the National Fire Academy and the Emergency Management Institute and a frequent lecturer. He is the founder and a past president of the Wisconsin Association of Hazardous Materials Responders, Inc.

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