As emergency responders, we are all familiar, or should be, with the need for assigning a Safety Officer at all incident scenes. In the context of a small-scale incident such as a two-vehicle accident or a small outside fire, the Incident Commander often inherently performs Safety Officer duties as such duties do not detract from their Incident Commander responsibilities at that scale and scope of incident and due to the fact, that in the Incident Command System if a position is not staffed, the next higher position in the ICS organization is tasked with performing those functions.
If the focus of our discussion is an incident that is of greater scale and scope than that just previously discussed — such as a room and contents fire, a vehicle extrication more involved than just “popping a door” — or greater, a dedicated Safety Officer should be appointed. The Safety Officer should then not be saddled with any other duties — such as Accountability Officer — as those duties would detract from their safety responsibilities. The importance of the Safety Officer position is underscored in the very Incident Command System itself by virtue of the position residing within the Command Staff. We also remember from the genesis of our emergency service careers that the one unique aspect of the Safety Officer position is the authority to halt all pertinent operations if a safety issue occurs.
Safety Officer at Hazardous Materials Incidents
All of our discussion above is well and good; however, let us now turn our focus to the Safety Officer position at hazardous materials incidents. The staffing of the Safety Officer position on a hazmat incident scene is not only an “industry best practice,” but is also a requirement as per the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard promulgated by the Occupational Safety and Health Administration (OSHA).
The HAZWOPER Standard is formally known as 29 CFR 1910.120 and is found in OSHA’s General Industry Standards. Specifically, 29 CFR 1910.120(q)(3)(vii) states that “The individual in charge of the Incident Command System 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.” Simply stated, a designated Safety Officer is required to be in place at a hazmat incident. If the incident requires response at the hazmat technician level or above, the Safety Officer should be certified to at least the technician level in order for them to be cognizant of the unique hazards presented.
One might then think about the possibility of a hazardous materials incident occurring within the realm of another type of incident. Examples of this would be a structure fire at an industrial facility that also involves a hazardous materials release; or a hazardous materials release at a fixed facility due to structural compromise from a tornado. We would of course designate an overall Safety Officer for the incident. An Assistant Safety Officer — or officers if more than one is needed due to the size of the incident scene, line of sight limitations, etc. — for Hazmat would then be designated with responsibility for safety in the hazmat arena. The Assistant Safety Officer for Hazmat would then be located with hazmat personnel in the Hazmat Branch but would report to the overall Safety Officer and maintain constant communications with them.
Throughout the remainder of our discussion, we will refer to either the Safety Officer at a dedicated hazmat incident or the Assistant Safety Officer for Hazmat at an incident also involving other operations or disciplines present collectively as the “Hazmat Safety Officer” to avoid confusion.
Duties of Hazmat Safety Officer
OSHA also stipulates the exact duties of the Hazmat Safety Officer in the HAZWOPER Standard 29 CFR 1910.120(q)(3)(viii). It states that “When activities are judged by the Safety Officer to be an immediate danger to life and health (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.”
The HAZWOPER Standard also requires the implementation of the Incident Command System at a hazardous materials incident (29 CFR 1910.120(q)(3)(i)). As emergency responders, we are held to the same standard as general industry for having our own emergency response plan in place for responses to hazardous materials incidents. This plan should be an integral part of the standard operating guidelines of our department and should meet the requirements stipulated in 29 CFR 1910.120(q)(1 and 2). The emergency response plan is then modified as needed on-scene to fit the specific circumstances of the incident.
While those duties just mentioned are the “big ticket” items, there are many other less explicitly mentioned actions that the Hazmat Safety Officer should perform. The Hazmat Safety Officer should develop a safety briefing specific to the incident at hand and should brief all involved personnel on the specifics of same prior to Entry Group personnel making entry into the hot zone. Items to be covered include the material or materials involved; personal protective equipment (PPE) utilized, position assignments, emergency procedures, decontamination procedures and other pertinent items. The safety briefing should be documented since — as the old saying goes — “If it isn’t documented, it didn’t happen.”
The Hazmat Safety Officer should also not exist in a vacuum in that he or she should communicate with other hazmat team personnel regarding pertinent matters. Just as in all facets of emergency response, communication is a wonderful thing! One such matter is the identification of the product or products that the hazmat team will be encountering. The Hazmat Safety Officer should communicate with and observe the actions of the Research Group to make sure the products are properly identified.
Another area of involvement of the Hazmat Safety Officer should be that of the selection of the proper level and type of PPE. The Hazmat Safety Officer should be an integral player in deciding upon the appropriate PPE to be utilized that is compatible with the products involved. The selection of a proper location for the decontamination area and an appropriate decontamination process should also be monitored by the Hazmat Safety Officer to ensure that the level of contamination remaining on personnel and objects returning from the hot zone is reduced to acceptable levels. This is not to say that the Hazmat Safety Officer is to infringe on the responsibilities of Group Supervisors and other hazmat team personnel but is rather to say that the Hazmat Safety Officer is a vital check and balance in our hazmat response process that exists to protect the well-being of our personnel.
Being assigned as a Hazmat Safety Officer is closely akin to being assigned as a Rapid Intervention Team (RIT) member at a structure fire. Such an assignment is not the most glamorous of positions on the incident scene; however, I can think of no more important an assignment than protecting the safety of our personnel. In addition, it can be seen that the Hazmat Safety Officer has far more responsibilities than one could imagine when first taking a look at the position. Personnel being assigned to the position should be seasoned hazmat professionals that are certified to the appropriate level and are knowledgeable in all facets of hazmat response. It is also imperative that Incident Commanders, Operations Section Chiefs, and/or Hazmat Branch Directors evaluate the need for multiple Hazmat Safety Officers when appropriate and adjust staffing levels coincide. The Hazmat Safety Officer is truly a position that is essential but often overlooked, however it is hoped that following our discussion the need for staffing that position will be an integral part of our future hazmat response operations. As always, stay safe out there and be sure to visit the North Carolina Association of Hazardous Materials Responders website at www.nchazmat.com.