Beyond the Rule of Thumb
Survival Tip 39
By Steven De Lisi
As part first responders’ hazardous materials Awareness and Operations training, almost all classes include instruction on using the Emergency Response Guidebook (ERG). Most lessons probably last no more than an hour and likely include a skill session in which students must identify the appropriate guide to use during a simulated hazmat incident, based on the chemical name, the product identification number, and the placard. Unfortunately, some instructors teach only what they learned years ago in using earlier versions of the book; if there were errors or omissions then, their lessons are likely no better today.
In my experience, too many first responders are unaware of important aspects of using the ERG. There is more to it than just looking up a guide in the blue or yellow-bordered pages and checking the green-bordered pages if the entry is highlighted. This edition of Hazardous Materials Survival Tips provides an overview of some important aspects that are all too often glossed over during training.
If the name of a material is highlighted in either the blue- or yellow-bordered pages, first responders are usually taught that they should refer to the green-bordered pages for information on initial isolation and protective action distances. However, often overlooked are the instructions provided on page 26 of the 2008 edition of the Emergency Response Guidebook (ERG2008), which state that readers should go directly to the green bordered pages ONLY if there is no fire. If there is a fire, the instructions state that first responders, “ALSO CONSULT the assigned guide (orange-bordered pages) and apply as appropriate the evacuation information shown under PUBLIC SAFETY.”1 As an example, an incident involving a large spill from a rail tank car containing anhydrous ammonia would require a daytime protective action distance downwind of one-half mile. However, if a fire was involved in the incident, the minimum isolation distance, regardless of time of day, is one mile in all directions.
The guides also provide information on potential hazards related to fire/explosion and health effects. However, many are unaware that the listed position of fire/explosion and health effects changes depending on the guide and that the highest potential is listed first.2 As an example, compare the listings of potential hazards for guides 125 and 126. For materials assigned to guide 125, the health hazard is greater than its fire hazard, whereas for those materials assigned to guide 126, the fire hazard is of greater concern to first responders than its health hazards.
Many first responders learn early in their basic training that structural firefighters’ protective clothing (SFPC) is not designed for exposure to dangerous chemicals. With this knowledge, they believe that a rescue attempt during a hazardous materials incident is impossible. Some will watch as a viable victim dies while waiting two hours for a hazardous materials team to arrive and conduct a body recovery. However, the ERG2008 states in some guides that “SFPC provides limited protection, and in those cases, the responder wearing SFPC and SCBA may be able to perform an expedient, that is quick ‘in-and-out’ operation.” The ERG2008 continues that “this type of operation can place the responder at risk of exposure, injury, or death” and that “the incident commander makes the decision to perform this operation only if an overriding benefit can be gained.”3 The net result is that the ERG2008 provides that rescue during a hazardous materials incident is an option, albeit a limited one with inherent risks. Remember that this applies only to those guides that state “Structural firefighters’ protective clothing will only provide limited protection.”4
Another issue involves Table 1 of the Initial Isolation and Protective Action Distances (green-bordered pages), which recommends greater distances for downwind protective action distances during nighttime. Some instructors explain that the greater distance is necessary because usually there are more people home at night and therefore you need to deal with a larger area. Unfortunately, this is incorrect. The ERG2008 clearly states that “atmospheric mixing is less effective at dispersing vapor plumes during nighttime.”5 As a result, during nighttime these vapor plumes are likely to travel greater distances while lower to the ground, without regard to population densities.
In this same table, there is often debate over what is meant by “small” and “large” spills. Despite the intensity of these discussions, the answer is clearly stated in the ERG2008, with a “small spill” defined as “one which involves a single, small package (e.g., a drum containing up to approximately 200 liters), a small cylinder, or a small leak from a large package.”6 The small package definition of 200 liters equals about 52 gallons, or roughly the contents of a 55-gallon drum. A large spill of a solid material is defined as one “greater than 300 kilograms, or approximately 660 pounds.7
Another source of debate is the amount of time meant by the term “initial” as used in Table 1. According to the ERG2008, distances shown in the table are those areas “likely to be affected during the first 30 minutes after materials are spilled and could increase with time.”8 Remember, however, that this is 30 minutes after materials are spilled, not 30 minutes after you get to the scene.
In addition to the chemical response information contained in the ERG2008, instructors usually make sure that students are aware of the telephone number for the Chemical Transportation Emergency Center (CHEMTREC). This information is provided on the inside of the back cover of the ERG2008. However, some instructors elect to tell their students that CHEMTREC will have copies of every material safety data sheet ever written and information on every chemical ever produced. Although CHEMTREC is without a doubt a valuable service for first responders, with vast resources and experienced employees, unless the shipper or carrier provides this emergency response telephone number on their shipping papers or shipping container, there may be a limit to how much assistance CHEMTREC can provide regarding a particular incident.
The latest edition of the emergency response guidebook should always be readily available in every vehicle first responders operate. This includes private vehicles of individuals from departments with a protocol allowing them to respond from home directly to incidents. It is true that new and sophisticated computer software programs provide substantial amounts of information and are worthwhile additions to any first responder’s information arsenal. However, there is no substitute for a handheld copy of the ERG2008.
Despite these benefits, users should be mindful of the book’s limitations. In particular, the ERG2008 is “not intended to provide information on the physical or chemical properties of dangerous goods.” In addition, first responders are reminded that the ERG2008 is “primarily designed for use at a dangerous goods incident occurring on a highway or railroad” and “to be mindful that there may be limited value in its application at fixed facility locations.”9
The simple solution for these and other issues involving the ERG2008 is for all first responders to thoroughly read all the “white” pages of the book. Furthermore, I believe it is safe to say that a minimum of four hours is required to develop a comprehensive working knowledge of what is probably one of the most important emergency response documents for first responders. Unfortunately, most hazardous material Awareness and Operation class schedules won’t allow for this, so the burden falls to in-service training afterwards in the fire station. Consider this when you’re trying to figure out what to do during your next daily, weekly, or monthly training session. I can assure you it will be time well spent.
Questions or comments on this or any other monthly Hazardous Materials Survival Tip can be directed to Steven De Lisi at HazMatSurvivalTip@comcast.net.
1. U.S. Department of Transportation. 2008 Emergency Response Guidebook, 26.
2. Ibid., 3.
3. Ibid., 348.
5. Ibid., 297.
6. Ibid., 298.
7. Ibid., 360.
8. Ibid., 293.
9. Ibid., 2.
Click here for more info on Steven De Lisi’s book, Hazardous Materials Incidents: Surviving the Initial Response.
Steven M. De Lisi is employed by Tetra Tech EM Inc. as a program manager responsible for planning, training, and exercise activities related to hazardous materials response. He recently retired from the fire service following a 27-year career that included serving as the deputy chief for the Virginia Air Guard Fire Rescue and a division chief for the Virginia Department of Fire Programs (VDFP). De Lisi is a hazardous materials specialist and as an adjunct instructor for VDFP, he continues to conduct hazardous materials Awareness and Operations-level training for fire suppression and EMS personnel. De Lisi began his career in hazardous materials response in 1982 as a member of the hazmat team with the Newport News (VA) Fire Department. Since then he has also served as a hazardous materials officer for the Virginia Department of Emergency Management; in that capacity, he provided on-scene assistance to first responders dealing with hazardous materials incidents in a region that included more than 20 local jurisdictions. De Lisi holds a master’s degree in public safety leadership and is the author of the textbook entitled Hazardous Material Incidents: Surviving the Initial Response, published by PennWell.
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Subjects: Emergency Response Guidebook recommendations, hazardous materials response, firefighter hazmat training