Just calling emergency responders may require HAZWOPER training

If you expect workers to respond to hazardous substance releases, they may need training under OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation. The type of release and the expected response determines the level of training. Even if most employees evacuate, you might expect one person to sound an alarm before evacuating, and that person needs HAZWOPER training.

Training levels

Employers generally look under 1910.120(q)(6) which describes the following training levels:

• First responder awareness level
• First responder operations level
• Hazardous materials technician
• Hazardous materials specialist
• On scene incident commander

At the awareness level, the person can recognize an emergency but takes no action beyond notifying the authorities. This level does not require a specific number of training hours, but the worker must have sufficient training or experience to understand certain hazards. Among other things, the training must cover hazardous substances and risks, an understanding of potential outcomes, and the ability to recognize an emergency.

The operations level requires 8 hours of training. These workers may respond in a defensive manner to contain the release from a safe distance and prevent exposures. They might keep it from spreading by placing sorbent, constructing dykes, shutting off valves outside the danger area, or activating emergency control systems. They do not, however, attempt to stop the release.

The hazardous materials technician requires 24 hours of training that includes “operations level” material. A technician may approach the point of release and attempt to stop the release.

Hazardous materials specialists and On-scene commanders would assist the technician, coordinate with outside emergency responders, and assume control of the scene, among other duties.

Evaluating releases

Not every chemical spill creates an emergency. OSHA recognizes a difference between an incidental spill and an emergency release.

An incidental spill does not pose a significant safety or health hazard to employees in the immediate area, or to the employee cleaning it up. Also, it does not have the potential to become an emergency in a short time frame. It could be safely cleaned up by employees with Hazard Communication training. OSHA provides an example of workers repairing a small leak caused by routine maintenance, where the release can be addressed without threatening the safety or health of employees.

An emergency response generally involves employees outside the immediate release area, and the responders need HAZWOPER training.

The quantity of the substance released does not distinguish an incidental spill from an emergency release. Rather, the substance’s properties such as toxicity, volatility, or flammability as well as the circumstances (confined spaces, ventilation, etc.) will impact whether employees can safely handle the release. Mitigating factors might include the knowledge of workers in the immediate area, the availability of personal protective equipment, and the employer’s established procedures. Even a relatively small release could be an emergency in the right (or wrong) circumstances.

Evaluate the hazardous substances at your facility and consider how you expect workers to respond; that will determine the training level needed. If the potential for an emergency release exists, you might want someone who can recognize the situation and notify authorities, but even that response requires “awareness level” training.

Determining training needs

If all workers simply evacuate, they do not need HAZWOPER training. They may have received training under the Hazard Communication standard, but would otherwise follow your emergency plan under 1910.38.

Still, employees who witness a hazardous substance release might be expected to notify the proper authorities. For example, a security guard might be expected to recognize an emergency and contact authorities. Under the HAZWOPER standard, those employees require training at the first responder awareness level, even if they take no action beyond notification.

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