Let us first take a look at hazmat training, namely what level of training is needed and what recurrent or refresher training is required. In my home state of North Carolina, fire service personnel are required to be certified as operations level responders as a prerequisite for certification as a firefighter. Just what does such a level of training allow us to do? In a nutshell, personnel trained to the operations level of hazmat certification as stipulated in the 2008 Edition of NFPA 472 can perform defensive actions such as damming and diking ahead of the actual product so that the responder is not exposed to the product and remains outside of the “hot zone.” Operations level responders can also perform the usual actions of identifying the product with the use of the DOT Emergency Response Guidebook, shipping papers, or other information; and applying sound protective action measures for the public.
While such a definition may seem cut and dried, there have been several “gray areas” that have cropped up in the recent past. One such gray area is that of air monitoring at the scenes of natural and LP gas leaks, as well as at suspected carbon monoxide exposures. Thanks to various grant funding streams and proactive thinking, many fire departments that operate at the operations level of hazmat response now have single sensor or even four-gas air monitors to assist in the detection of such atmospheric contaminants. Departments conducting air monitoring of the aforementioned type should — at a minimum — ensure that personnel are adequately trained in the use of the appropriate air monitoring equipment and the personal protective equipment that is utilized. An even better approach is to train personnel that will be performing air monitoring to the Air Monitoring and Sampling Operations Level Mission Specific Competency to ensure an adequate level of familiarity with the performance of air monitoring functions.
In North Carolina, a level of certification exists that bridges a specific gap between the operations and technician levels of emergency responder hazmat certification. Termed hazardous materials operations plus, the certification is awarded by the employer and allows an operations level responder that has received the training outlined in 13 North Carolina Administrative Code 07F .0103 to plug, patch, or otherwise mitigate a leak emanating from a fuel tank of a hydrocarbon fuel that powers the vehicle the tank is affixed to. This level of certification arose from the realization that technician level hazmat teams were often being dispatched to fuel leaks that could be safely and successfully controlled by operations level personnel who have received the aforementioned additional training.
In terms of training, we now come to what we hazmat aficionados regard as the truly “fun” arena of hazmat training — hazmat technician. Technician level certification allows emergency responders to perform offensive actions in the “hot zone,” such as plugging, patching, or otherwise controlling leaks and releases. The progression from operations level responder to hazmat technician is the largest jump in knowledge, competencies and capabilities in the entire spectrum of hazmat certification.
In North Carolina, certification as a hazmat technician requires the applicant to be certified to the operations level, have successfully completed a prescribed hazmat technician class, have successfully completed a chemistry of hazardous materials class, have completed 12 hours of incident command system training, be a member of a hazmat team, and participate in a medical monitoring program.
We next need to examine one of the most important facets of hazmat training, which is the need for recurrent or refresher training. The ability of a department to competently respond to a hazmat incident is directly related to the adequate provision or lack thereof of such training.
In my home state of North Carolina, emergency responders no longer are required to recertify their hazardous materials certifications on a recurring basis through the Office of the State Fire Marshal. In lieu of such recertification at the state level, emergency responders now are required to meet the recurrent hazmat training requirements set by their authority having jurisdiction (AHJ). Additional recurrent training requirements are detailed in OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard as promulgated in 29 CFR 1910.120. As specified in 29 CFR 1910.120 (q); emergency responders shall “receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.”
In a practical sense, the OSHA requirements for refresher training do not specify a particular duration for the training to span, but more importantly specify that emergency responders are required to receive hazmat refresher training on an annual basis to their highest level of certification and that the training content is relevant to the response actions conducted. In North Carolina, most annual operations level refresher training is eight hours in length as an “industry standard” and many AHJ’s set the requirement for technician level recurrent training at 24 hours per year.
Another key element in determining the readiness of our department in terms of hazardous materials response is a sound program of pre-planning our hazardous materials fixed facilities and transportation routes. As firefighters, we spend (or should spend) a considerable amount of our time “out in the territory” getting acquainted with the structures in our response area. By devoting a portion of our time prior to the occurrence of a structure fire to such pursuits, we can more effectively combat a fire when the alarm sounds because we have knowledge of the fire protection systems, building construction features and hazards of the structure.
Pre-planning for a hazmat response is just as imperative. As competent hazmat responders, we should regularly and with proper permission enter such facilities for the purposes of familiarizing ourselves with the “enemy” — the hazards posed by the hazardous materials in particular and the structure in general.
As mentioned above, an additional area in which we can conduct pre-planning efforts focuses on our transportation corridors. It behooves us to familiarize ourselves with the types of hazardous materials that are being transported through our jurisdiction, the amounts transported, and the routes such shipments traverse — highway, rail, etc. You may then ask “How in the world do we conduct a pre-plan on a transportation artery?”
The answer is not as complicated as one would think. Your local Emergency Management Agency (EMA) can be an excellent source for such information, as many EMAs have conducted commodity flow studies pinpointing major hazmat transportation routes and giving responders a snapshot of the materials transported. In terms of the transportation of hazardous materials by rail, emergency response agencies can contact the railroad or railroads within their jurisdiction for such information.
In the case of both fixed facility and transportation pre-planning, additional benefits are realized in addition to information regarding the hazardous materials themselves. One such benefit is the development of a relationship with facility representatives prior to the occurrence of an incident. It is far better to become acquainted and develop an understanding of the capabilities of facility personnel in a low-stress environment so that when an incident occurs, you can “put names with the faces” and communicate effectively with facility personnel. Another benefit is the ability to apply the knowledge gained in practical areas.
For instance, if we know the nature of the major hazardous threats in our jurisdiction, we can generate informational packets on each major threat denoting the physical and chemical properties of the products, the type of personal protective equipment (PPE) needed and the compatibility of same; and other response considerations in a proactive manner prior to the occurrence of an incident.
The readiness of a response agency in regard to hazardous materials response capabilities also greatly hinges on the equipment the agency has or has access to. As many hazardous materials responders know, the acquisition of hazmat response equipment is an expensive proposition, not only in the direct purchase price but also in terms of the costs of equipment sustainment (such as meter sensors, calibration gas, replacement reagents in classification kits, etc.). These purchase and recurring costs are especially weighty during these tough economic times that have been compounded by dwindling grant funds, forcing us to “choose wisely” in terms of equipment purchases.
Methods by which we can maintain our operational readiness in the equipment arena include partnering or developing relationships with other nearby hazmat teams that may possess specialized equipment items, developing a knowledge of the equipment that private sector facilities may have on hand for incidents at their facility, and by utilizing sound resource management processes by knowing what is present in surrounding areas in both public and private sector equipment caches for possible use.
Historically, facilities that possess or utilize chemicals that present specific hazards have sometimes eased the burden on local responders by either purchasing or assisting with the purchase of specialized equipment.
We can now come “full circle” in our discussion by relating back to the comments on pre-planning. If we know the hazards presented by the chemicals present in or being transported through our jurisdictions, we can then tailor our specialized hazmat response equipment to the threats presented. We know that if we have a railroad traversing our jurisdiction that transports chlorine, our technician level hazmat team should have and be able to competently use a Chlorine C-Kit, or if we have DOT 407 highway tank trailers prevalent in our jurisdictions with a high rate of roll-overs, we should possess a product recovery valve.
With the aforementioned being said, how about facilities that may have specialized fittings in their process lines or similar “challenges” that may be presented to us? Pre-planning and the development of relationships with these facilities are also imperative in this area. A successful example of the above that I have encountered was during a site visit to a facility utilizing anhydrous ammonia, in which local response personnel noticed the use of a specialized wrench for process line valves and fittings. All it took was the mere mention by response personnel that such specialized wrenches would be useful on the hazmat unit, and facility personnel then promptly provided a couple of the wrenches for departmental use.
The technique of applying pre-planning information to response equipment selection is also imperative in the selection of PPE, enabling response personnel to select items that are compatible with the chemical hazards and the environment presented.
The final area of our discussion is a timely one — personnel. In an era of tight budgets and tough economic times, many career departments are trying to “hold their own” in terms of just sustaining their response forces, while many volunteer agencies face the ever-increasing challenges of volunteer recruitment and retention. These conditions compound our efforts to provide sufficient numbers of adequately trained and competent personnel in response to a hazardous materials incident. In addition, the fact that a significant hazmat incident is very personnel-intensive is without question.
How do we handle this challenge and ensure the continuity and adequacy of service provision? One possible answer is the use of mutual aid agreements and the building of relationships with other hazmat teams and service providers, as mentioned earlier--the concept of regionalization, if you will.
Another possible answer centers on a very labor- and personnel-intensive facet of hazardous materials response — decontamination.
If operations level responders are properly trained in decontamination procedures, have been properly trained in the use of appropriate PPE, and are led by an appropriately trained hazmat technician, they can become an effective force multiplier by serving as members of the Decontamination Group.
Such outreach pays huge dividends, as witnessed in an incident in which a local hazmat team had trained the operations level personnel of another department at a night training session, and — as luck would have it — an incident occurred the next morning in which the hazmat team responded to the same jurisdiction for a technician level entry. Due to the training and outreach provided the night before, some of the operations level personnel functioned seamlessly as members of the Decontamination Group.
All emergency responders and emergency response agency leaders should indeed take an introspective look at their organization to determine if they are truly ready and adequately prepared for a hazardous materials incident. This reflective analysis should include the areas of training, pre-planning, equipment, and personnel. Such an analysis will allow us to determine our readiness — at the individual, organizational, and regional levels — and even more importantly will provide us with an effective roadmap addressing the areas in which improvement is needed so that we as a hazmat response community can provide the highest level of service provision to our customers — the citizens of our communities and jurisdictions.
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.