How To Develop and Manage
An Industrial Hazardous Materials
Emergency Response Team

Starting a team and managing the operations of the team are critical tasks. During a start up we must organize resources, plan for handling emergencies, evaluate and purchase equipment, and train response personnel. These tasks must also be part of a cont inuing management program to keep the team ready for emergencies. This article will look at the basics of starting and running an industrial hazardous materials response team. We will identify some of the essential elements that must be handled to maintai n a quality team.

Do You Need A Team?

The first consideration in developing a haz mat response team is whether you need one. These teams can be costly and maintaining one involves compliance with additional regulatory requirements that would not need covered if you did not have a team. There are many benefits to having a team, but not every organization can benefit enough to be worth the cost. You should make a thorough analysis of the risks present in your facility.

Risk and Hazard Analysis

1) chemicals,
2) processes,
3) uses, and
4) potential incidents.

Chemical risks can be evaluated by considering the type of chemicals used in your operation, the quantity of chemicals regularly stored on site, and the types of containers used. An evaluation of the types of chemicals should center on the inherent hazards associated with each material.

High risk chemicals include poisons and other toxic hazard products, unstable materials, and highly flammable items. Both your raw materials, finished products, and intermediate components need to be considered.

The use of hazardous materials may have a major affect on the risks involved with a particular material. A flammable liquid used in a closed process system usually poses less risk than that same chemical would if used in a spray coating process.

In analyzing your potential for incidents you must be pessimistic in looking at your operations. This is a "what if..." process. Ask yourself what if that container ruptured, what if a forklift hit this drum, what if this material got into the stor m drain, etc. The incidents you consider should range from likely to next to impossible. By viewing the broad perspective we gain a better understanding of where the most realistic potential actually falls.

Resources

Analyzing your resources is also a critical part of determining the need for an in-house team. Resources include the systems, equipment, personnel, and procedures designed to prevent, minimize, or control a hazardous materials release.

Engineering Controls

Engineering controls are the systems designed into our facilities to avoid or minimize both the potential for a release and the seriousness of a release should one occur. Prevention items are another resource area including general employee trainin g, policies, procedures, and other specific measures aimed at preventing releases. Detection capability is also an important area. Our ability to detect a release promptly can have a significant role in determining our ability to handle the release. If di scovery is delayed the problem may become larger than we can handle with our resources.

Off-Site Response Capability

Off-site response must be considered when you evaluate the need for your own team. If excellent off-site resources are available in your area you have less of a need for an in-house team. If, however, limited off-site capability is available you ma y have an urgent need for an in-house team.

Off-site response teams should be evaluated in at least three primary areas:

1) response time,
2) training, and
3) equipment

The training of off-site response personnel is critical. You should examine their training program and evaluate how well it is preparing the teams personnel for responses to the types of hazards and potential releases at your facility. Good general training is not enough. Many public response teams are more geared to transportation incidents. For them this makes sense because they may respond to many more of this type of incident than they do to industrial incidents. This emphasis on transportation incidents may be a weakness in the off-site groups training from the industrial site perspective. Industrial incidents may pose many different challenges than a transportation incident.

Equipment is another essential area of your evaluation. Start with a general evaluation of whether the off-site group is well or poorly equipped. After a general evaluation focus on the equipment that may be needed for your specific situation. For example, will the chemical protective clothing and equipment that the off-site group uses provide adequate protection against the hazards of the chemicals used on your site.

Commitment of Your Organization

The commitment of your organization is a major issue in starting a haz mat response team. The team requires continuing training, equipment must be purchased and maintained, and many other items need addressed. If the personnel in your organization lack th e commitment to the team, it will not be effective. It is worse to have a team on paper only than not have a team at all. Top management must understand the role and responsibilities of this type of team and commit the necessary support.

If you have determined that you need a team the next major decision is what level of response your team will provide. Teams can vary from initial first response only up through a capability to handle large scale incidents. Most teams in industry fall in t he mid to low range of response. Each increase in the level of response carries with it the need for additional training and equipment. The evaluation criteria covered previously in this section can be used as a guide to determining the level of response you will need.

Organization

Organizing the response group requires that you prepare several structures. OSHA regulations require that incident management use the Incident Command System (ICS). The ICS is a method for organizing and managing emergency response resources that p ermits more effective control of the operations and insures greater safety for response personnel.

An emergency operations center (EOC) should be organized. The EOC provides command and control of the actual emergency response. It is a central clearinghouse for information, resources, and decision making personnel. It functions as a command post and provides the control point for all operations directly linked to the emergency.

Another group that should be available is a crisis team (CT). The crisis team includes upper level management personnel and other resource people that may be needed to handle the larger, long-term aspects of the emergency.

For example, during an incident involving a leak of chlorine from a 150 pound cylinder both groups would have different responsibilities. The EOC would control the operations involving evacuation if needed, stopping the leak, and other emergency specific items. The CT would evaluate and make decisions in areas affecting business operations, public relations, and return to production. The larger the emergency the more involved the CT will become. On many small emergencies the CT may not be needed. The EOC, however, should always be used.

Selecting Personnel

Organizing your team will also involve selecting the personnel who will respond to incidents. Ideally all members of your team should be volunteers. They should come from work groups that allow them to leave their normal jobs immediately when an em ergency occurs.

Consider the primary job skills and look for personnel that already have knowledge and skills that may benefit the team. For example, maintenance personnel will often know the facility better than other employees and have a mechanical aptitude that will b e beneficial during leak control operations.

If you already have a fire brigade, members of this group are good candidates for the haz mat team. Their previous emergency response training will help them in learning haz mat incident response. The physical condition of members is also important. Respo nse activities, particularly those requiring chemical protective clothing, can be physically demanding. OSHA regulations require that emergency response personnel receive a medical examination at least biennially.

Planning

Planning falls into two categories;

1) plans required by regulations and
2) internal planning to improve response.

Regulatory Plans

Plans required by regulations include the Superfund Amendment and Reauthorization Act (SARA) emergency response plan, state level environmental regulations also usually require some type of plan, and local governments are frequently beginning to require p lans. A well prepared SARA emergency response plan will usually cover the requirements of the other types of plans.

SARA and OSHA regulations require that you cover certain essential elements in your emergency response plan. These items include;

1. Pre-emergency planning,
2. Personnel roles, lines of authority, and communication,
3. Emergency recognition and prevention,
4. Safe distances and places of refuge,
5. Site security and control,
6. Evacuation routes and procedures,
7. Decontamination procedures,
8. Emergency medical treatment and first aid,
9. Emergency alerting and response procedures,
10. Critique of response and follow-up,
11. PPE and emergency equipment,
12. Site topography, layout, and prevailing weather conditions,
13. Procedures for reporting incidents to local, state, and federal governmental agencies.

This required planning will cover most of the items needed for internal planning. The primary difference will be the level of detail and the presentation format. Although compliance with federal planning requirements will usually cover the essentia l elements of a state required plan, you should check your own state regulations because some requirements vary.

Internal Plans

Internal planning should focus on improving your emergency response. These plans should be brief and easy to use. A checklist format is often best. Much of the descriptive and explanatory material required in compliance plans can be deleted. You may need to add detail to some critical response areas of the plan. Plans are not instructions that anyone can use but guides intended to help trained personnel.

A few areas that often generate problems should be covered in detail in internal plans. The decision regarding what constitutes an emergency is subject to individual judgment. Specific guidelines should be developed in this area and communicated to all pe rsonnel so that appropriate notification and response occur. All employees must understand their role and the actions they must take when discovering a haz mat emergency.

Standard Operating Procedures

Standard operating procedures (SOP) should be developed for critical team operations. SOP’s are usually developed for activities that remain similar on any incident. For example, an SOP regarding the selection and use of personal protective clothin g and equipment will help your personnel to make this important decision.

Equipment

The capabilities of your team will be determined to a large extent by the equipment which is available to them. There is a wide variety of equipment that may be used for hazardous materials response. This equipment is usually costly and decisions c oncerning your needs should be thoroughly analyzed and well planned.

It is easy to purchase the wrong type of equipment for your needs. The analysis and planning covered last month should be finished before you make decisions on your equipment needs. Purchasing decisions must be based on a clear understanding of your hazar ds and planned response capability.

It is not uncommon to find equipment in industrial operations that do not have level A protective clothing which would require this level of protective clothing to be used effectively. This is a waste of financial resources. It also creates a safety probl em because personnel will be tempted to use the equipment even though they do not have the proper protective clothing. Frequently in equipping your team you will be more effective if you obtain less equipment but, insure that the equipment fits your needs and is high quality.

Equipment advice can be obtained from many sources. Your local fire department or hazardous materials response team will generally be glad to help you evaluate your equipment needs and make recommendations. You may contact your Local Emergency Planning Co mmittee. Suppliers can also be a source of useful information. Caution must be exercised when relying on supplier recommendations, however, because their primary interest is to sell you equipment. Most supplier personnel are reputable but, they may not be familiar with the broad spectrum of equipment available.

Basic Types

Equipment is available in many categories. We will only briefly introduce some of the types that are available and the essential basics that most teams should have.

Personnel Protection

Personal protective equipment (PPE) and clothing must top any list of items for an effective response team. This category of equipment will determine more than all the rest what the team can do at an incident. If the members cannot adequately prote ct themselves from the hazards present at the emergency they cannot engage in control activities in the hazardous area.

Respiratory protection is available in three basic types; filter type respirators, self-contained breathing apparatus (SCBA), and airline breathing apparatus (ABA). Filter type units have limited applicability for emergency response and should usua lly not be used. SCBA provides the wearer with a pure source of breathing air but, is limited by a short duration air supply. ABA provides an indefinite duration but, may limit mobility because of the air hose.

PPE is available in a wide variety of types, styles, and materials of construction. No one type of PPE can provide protection from all possible hazards. This requires that a selection of items be available so the team can choose the most effective protect ion for the specific incident.

The EPA uses a level system to identify the protection offered by PPE. We will only discuss level A and B. Level A protection is provided by a totally encapsulated chemical protective suit. These suits completely seal the wearer from the outside environme nt and are used to provide protection from maximum hazards and unknowns. These suits are expensive to purchase and require advanced training for effective use. Level B protection is provided by non-encapsulating chemical protective clothing, typically ref erred to as splash suits. These garments will provide protection against known liquid and solid hazards but, are not usually adequate for gas and vapor hazards or unknown materials. Techniques can be used to enhance the protection offered by level B garme nts but, total exclusion from the outside environment cannot be achieved. Most industrial teams rely on level B clothing and equipment.

Within the category of level B clothing you will need to decide between disposable or reusable garments. Disposable garments eliminate the need for extensive decontamination and maintenance. Reusable garments are usually more substantial in their construc tion. For most teams it is beneficial to have some of each type.

The next decision is the most difficult and critical. You must determine, based on a thorough evaluation of your chemical hazards, the specific materials from which the garments should be made to provide adequate protection. Most chemical protective cloth ing materials provide protection against a range of chemical hazards but, no material provides protection against all hazards. You will need to select construction materials that provide adequate protection with the fewest number of different materials. T his will keep the cost of the garments and the storage problems to a minimum. Having fewer different suits also makes the selection process easier for response personnel during an incident.

For maximum protection a one-piece coverall with attached hood is usually best but, many other styles are available. Your individual needs will determine which style is best.

PPE must also provide protection from non-chemical hazards, such as, flash fires, high temperatures, falling objects, etc. These items must be part of the evaluation process both when purchasing PPE and when selecting the appropriate items for wear at an incident.

Response Equipment

Absorbents are a common category of equipment used for the containment and control of spilled liquids. Absorbent like PPE are made from many different materials. You will have to evaluate the chemical compatibility and absorbent effectiveness to de termine the types of materials you need. Many styles of absorbents are also available, these include; granular, pillow, sheet, sock, boom, and several others. It is usually most effective to have several styles available so the most effective for the spec ific incident can be selected by response personnel. A large supply should be kept in stock. Incidents almost always require more of these materials than are initially anticipated. Application equipment must be available particularly for granular material s. Items like shovels and scoops will be necessary for effective application.

Containment equipment may include salvage drums, lab packs, leak plugs and patches, water surface booms, storm drain covers, and many other items. This category of equipment is difficult to generalize but, certain basics need to be available. Salva ge drums are needed to overpack leaking containers of the 55-gallon drum size and smaller. These drums may also be used for disposal of used absorbents and other contaminated materials. Even a basic response team should have some equipment for plugging an d patching leaking containers. Putty, tape, wooden plugs, and basic tools should be available in any leak kit. Product transfer equipment such as drum pumps is also useful.

Specialized agents such as firefighting foam, hazardous materials foam, neutralizing solutions, and emulsifiers may be needed depending on your hazards.

Decontamination equipment will be essential for any team that allows personnel to operate in contaminated areas. This category will include scrub brushes, buckets, water run-off containment, and garden hoses with spray nozzles.

Storage

Storage should provide a secure yet readily available location for equipment. It is often better to have a number of storage areas located strategically throughout your facility rather than a single large storage area. To the extent possible equipm ent should be portable, either stored on vehicles, carts, trailers or palletized. A combination of storage arrangements is often best.

For example, you may establish several areas throughout your facility which have initial containment equipment and supplies and store the higher level response equipment in a central, portable location. Storage of equipment designed for use on a specific hazard can be near the hazard. Use caution that the equipment is placed far enough from the hazard that it will not be contaminated should an emergency occur.

Inspection and Maintenance

The team equipment will only be ready for use and in satisfactory condition if it is properly inspected and maintained. An individual should be assigned the responsibility and provided with adequate time and resources to regularly inspect and maintain all team equipment. All equipment and supplies should be checked at a minimum on a monthly basis and after each use. Records of all inspection and maintenance should be kept.

Replacement Program

All supplies may be consumed during responses and equipment will wear out over time. To insure that the team continues to have a full complement of equipment a replacement program should be established. For supplies a reorder quantity should be establishe d. For example, if 100 absorbent sheets is the minimum you feel you may need to handle an emergency a reorder quantity of 200 may be established to insure that an adequate supply is always available.

The estimated useful life of a piece of equipment should be established at the time of initial purchase and provisions made to have funds available for replacement. A staggered schedule is often best. For example, if the team requires eight SCBA wh ich must all be purchased at the during initial development of the team this is a major expense. The replacement program can be established to avoid the need to replace all these units at the same time. For example, if the life of the SCBA is determined t o be ten years, two units could be purchase in six years, two in seven years, etc. so that all eight units will be replaced in the ten years but only two units will have been purchased in any given year.

Training

Training is the most critical individual area when developing an effective team. All the other steps we have discussed will be completed for nothing if training is not effective.

Training can be divided into two main phases; initial and continuing. Initial training will need to bring response personnel from a baseline of little or no knowledge of haz mat response up to the point of being able to handle, at least the first phase of incidents, effectively. Continuing training is required to maintain proficiency in skills and cope with changes in operations. Training is also required by regulation.

Properly trained personnel can perform many activities at a hazardous materials release. They can have a major affect on the outcome of the incident and the risk to fellow employees, company assets, and the environment. Without the proper training your te am is a risk to itself and everyone else. There is no substitute for adequate training.

Minimum initial training should cover all the functions that the team will be expected to perform. Training must provide sufficient competence that response personnel can safely perform their tasks.

OSHA regulations [1910.120] divide responders into four levels:

1) first responder awareness,
2) first responder operations,
3) hazardous materials technician, and
4) hazardous materials specialist.

The two levels we will discuss are the first responder operations and hazardous materials technician as these are the most common for industrial response teams.

First responder operations personnel must receive at least eight hours of training annually. The eight hours comes from the regulations, it should not be considered to be automatically the maximum training time. It is the minimum training time requ ired by OSHA. These personnel only engage in defensive techniques at incidents such as, evacuation of personnel and containment activities that can be conducted outside the hazard area. This is a very basic level of response and should only be selected wh en more highly trained personnel are readily available within a short time period.

Hazardous materials technicians require twenty four hours of training annually. Twenty four hours should be viewed as the minimum starting level for training. In most industrial settings forty hours is more appropriate and in some situations more m ay be needed. These personnel engage in offensive operations that involve attempting to contain and stop the release and will often require entry into the hazardous area. This option involves more time and commitment but, is usually the best selection if you have determined that a team is necessary.

Training for both groups must cover; hazard identification, selection and use of PPE, understanding of hazardous materials terms, confinement and containment operations, familiarization with plans and procedures, and basic decontamination.

In addition to these items the technician level personnel must receive training on; the incident command system, advanced containment and control techniques, and the use of survey instruments and equipment.

Several items not specifically mentioned in the regulations but, important to team operations are; working with outside resources, facility familiarization, and scene control.

A catch-all statement in the regulations puts the responsibility for a complete and comprehensive training program solely on the employer, "Training shall be based on the duties and function to be performed by each responder of an emergency response organ ization". This statement makes it clear that if you are going to have your personnel operating at haz mat emergencies they must have had sufficient training to work properly and safely.

Incident command personnel should receive additional training specifically aimed at developing their command abilities. This training is required for all personnel that will function in a command role. The minimum training time should be considered eight hours beyond the level of responder training. For example, if your response personnel have been trained to the technician level with forty hours of training your command personnel should have had the forty hour training program plus another eight h ours of command training.

Scheduling training can be challenging at best. If you have a multiple shift operation it is usually more effective to allow personnel to take training on their normal shift. If shifts rotate this is not a problem and all shifts can receive training durin g day shift. For individuals that are not accustomed to working in an office environment long sessions can be a disadvantage. Session lengths of two to four hours often provide the best time frame.

During initial training these sessions should be scheduled close together so trainees can place one session into context with the others. The training will need to be a mix of classroom and hands-on training. More classroom training will be necessary duri ng initial training than in subsequent years. Once the basic concepts are established training can focus more on skill retention and development.

Training records should be maintained on all team members. These records should contain sufficient detail to establish what topics were covered, time spent, who instructed the program, and demonstration of competency. Training records should be kep t on file for anyone that was involved in the team, even if the individual is not now active. This can help avoid long-term problems arising from incident activities that may have not appeared to be a problem initially. For example, an individual begins to complain of symptoms that may indicate an exposure to a chemical long after an incident, you may be required to produce records proving adequate training at the time of the exposure.

An exercise to test the teams readiness should be part of the annual training program. A realistic situation can be simulated in your facility and the team allowed to respond. The exercise should then be critiqued looking for areas where improvement may b e needed or additional training required.

Instructors must be able to demonstrate competence in the subject matter to be covered and in instructional techniques. You may use in-house personnel or outside resources.

Summary

The development of an effective industrial hazardous materials response team is a challenging project. Many things must be evaluated. You must analyze your hazards, risks, and resources to determine if you need a team. An organization and plans must be pr epared. Equipment must be selected and purchased. Personnel must be trained. All this effort and expense may seem too much to ask but, we are responsible for the safe handling of the chemicals we use and effective emergency response is a critical part of that responsibility.

This information is a compilation based on a three article series written by Craig Schroll for Industrial Safety & Hygiene News. The articles were originally published in the August, September and October 1989 issues of the magazine.

If you would like additional information on industrial haz mat response teams or FIRECON please contact Craig Schroll at 800-222-8841. Or fax to 717-354-7233. Or e-mail at Craig@FIRECON.com