As emergency response personnel, we should all be familiar with the need to staff a dedicated Safety Officer position within the Incident Command System at all applicable incidents as quickly as possible to “take the heat” off of the Incident Commander by ensuring that one person has overall responsibility for all safety matters and that said person is only tasked with that responsibility. As a member of the Command Staff, the Safety Officer has the unique authority to stop all incident operations in the event a safety concern is noted. While the Safety Officer position should be familiar to us all, at hazmat incidents of a significant nature the need for a dedicated position to ensure the safety of all personnel within the Hazmat Branch or performing hazmat response duties arises. This position--which is not as well known to most emergency responders--is titled the Assistant Safety Officer for Hazmat and is responsible for the monitoring of all hazmat operations to ensure the safety of involved personnel.
In the hazardous materials response community, the “playbook” that guides us in a regulatory manner is OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, formally known as 29 CFR 1910.120. In 29 CFR 1910.120(q)(3)(vii), it is stated that the Incident Commander shall “designate a Safety Officer, who is knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety of operations for the emergency at hand.” This requirement can also be extended to the position of Assistant Safety Officer for Hazmat, who reports to the overall Safety Officer. At hazmat incidents involving Technician-level response actions, the requirements above stipulated by OSHA should lead to the appointment of an Assistant Safety Officer for hazmat that is trained and certified to at least the Hazmat Technician level to ensure that he or she is well-versed in hazmat response techniques, regulations, and the hazards of the products involved.
The HAZWOPER Standard also underscores the authority of the Safety Officer at a hazmat incident by stating in 29 CFR 1910.120(q)(viii) — “When activities are judged by the safety officer to be an IDLH and/or to involve an imminent danger condition, the safety officer shall have the authority to alter, suspend, or terminate those activities. The safety official shall immediately inform the individual in charge of the ICS of any actions needed to be taken to correct these hazards at the emergency scene.”
Oftentimes emergency response personnel may think that paragraph q of 29 CFR 1910.120 only applies to employers such as industries with employees that perform hazardous materials emergency response functions, however we need to remember that paragraph q pertains to “us” (meaning emergency response personnel) also in that it “covers employers whose employees are engaged in emergency response no matter where it occurs.” As Paragraph q requires that an emergency response plan be “developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations,” it can now be realized that the requirement to develop and utilize an emergency response plan applies also to emergency response agencies.
While we cannot pre-determine some of the response variables that a fixed facility can, we can pre-plan hazmat facilities in our response area to acquire information needed to formulate elements of an emergency response plan prior to the occurrence of an incident so that we only have to “flesh out” the remainder of the plan with incident-specific details.
Our site-specific emergency response plan for a hazardous materials response in which offensive actions are undertaken should detail the following elements:
- Site Information
- Incident Organization
- Hazards of Products Involved
- Hazard Monitoring
- Decontamination Procedures
- Medical Aid Procedures
- A Site Map
- Entry Objectives
- Safe Work Practices
- Emergency Procedures
- Documentation of a Safety Briefing
In my full-time department, we use a modified version of the ICS-208 HM Site Safety and Control Plan form — which has somewhat fallen out of use as of late across the country — to serve as a template for the completion of our emergency response plan at an incident. The last element stated above- — the conduction and documentation of a safety briefing — is imperative anytime we send personnel downrange into a “Hot Zone” or suspected area of contamination to ensure that all are aware of the hazards presented, safety procedures to be utilized, and any other pertinent safety information.
Following such an incident, we should also conduct a critique so that we can evaluate our response actions to assure continual improvement. Our documentation of the emergency response plan proves our due diligence in ensuring the safety of our personnel and our commitment as an organization to safety.
Standard 29 CFR 1910.120 also addresses the requirement of another item directly related to safety — the development of a site-specific Incident Command System (ICS). All emergency responders should be thoroughly familiar with Incident Command System principles and practices through both required training and practical use, however the HAZWOPER Standard stipulates certain requirements regarding the ICS. For example, OSHA requires that in addition to appointing a Safety Officer, the “individual in charge of the ICS” (namely the Incident Commander or “Spokesperson” within a Unified Command) shall:
- “Identify, to the extent possible, all hazardous substances or conditions present and shall address as appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures, and use of any new technologies.
- “Implement appropriate emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards to be encountered.
- “Limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure to incident or site hazards, to those who are actively performing emergency operations.
- “Implement appropriate decontamination procedures following the termination of emergency operations.
- In addition to ICS-specific requirements, OSHA also mandates other safety measures at hazmat incidents, including the following:
- The use of positive pressure SCBA’s for respiratory protection until it is determined that the level of respiratory protection can be reduced.
- The provision of back-up personnel for rescue or assistance to responders in a hazard area.
- The requirement for personnel making entry into a hazardous area to enter in groups of two or more.
- The presence of personnel trained to at least the Basic Life Support level with proper equipment and the capability for the transportation of personnel and/or victims to appropriate medical care.
In terms of the adequacy of our safety measures utilized at hazmat incidents, I often ask myself prior to personnel traveling downrange to enter the “Hot Zone” this question. “If I were one of the personnel ‘in the suits’, would I feel that our safety measures were adequate and our entry ensured to be as safe as possible given the conditions presented?”
If I can answer yes and the safety measures correspond with the requirements mandated by OSHA, other regulations, and industry best practices; then I can rest easy that we have performed our duty as leaders in the hazmat community to ensure the safety of our personnel and the citizens we serve.
In summation, the response to a hazardous materials incident of any significance should engender a heightened sense of safety awareness due to the unique and dynamic nature of the hazards presented; as well as the establishment of an Assistant Safety Officer for hazmat and the adherence to the additional safety requirements inherent in such a response.
As the last thing I ever want to do is visit the hospital to see an injured colleague or even more importantly attend the funeral of a fellow emergency responder, I will take time to ingrain in my memory that it is not only “safety first,” but rather “safety first, last, and always” at hazmat incidents.
As always, stay safe out there and be sure to visit the North Carolina Association of Hazardous Materials Responders website at www.nchazmat.com.
Glenn Clapp is Past President of the North Carolina Association of Hazardous Materials Responders and is a Fire Training Commander (Special Operations) for the High Point Fire Department. He is a Technician-Level Hazmat Instructor, a Law Enforcement Hazmat Instructor, and is a Certified Hazardous Materials Manager and Certified Fire Protection Specialist.