By Glenn Clapp CSP, EFO, CHMM, CFPS
As hazardous materials responders, we all receive training in the levels of certification stipulated by the National Fire Protection Association and the certifying entities in our state. Most hazardous materials responders are easily able to recall the certification levels of operations and technicians, and oftentimes, even specialists and the functions personnel at each level are able to perform. There is one level of certification existing solely within the State of North Carolina. However, that is often overlooked but is very important from both capability and legal liability standpoints.
Back in the 1990s, it was noted in the State of North Carolina that we were dispatching technician and specialist-level assets and personnel to fuel leaks from cars, light or heavy trucks; and even tractor-trailers on a regular basis. While those resources undoubtedly could easily handle such situations, the thought was posed as to whether both we and the citizens we serve could be best served in such situations by operations-level responders who have received additional specialized instruction in the control of hydrocarbon fuel leaks and are properly equipped to do so. Thus, the unique certification level of operations plus was developed. The concept of operations plus is delineated in the North Carolina Administrative Code at 13 NCAC 07F .0103, in which responders at the operations plus level are defined as “Individuals who respond to hydrocarbon fuel tank leaks where the leaking tanks contain a hydrocarbon fuel which is used to propel the vehicle on which the tank is located. Only those vehicles designed for highway use or those used for industrial, agricultural, or construction purposes are covered.” In short, personnel trailed to the operations plus level are able to plug, patch, or otherwise mitigate hydrocarbon fuel tank leaks on cars, light or heavy trucks, and tractor-trailers in situations where the fuel powers the vehicle. Some hazardous materials responders may also interpret the regulation to also allow operations plus responders to stop releases of LP Gas from a bobtail or straight MC 331 delivery truck in which the LP Gas in the large tank powers the vehicle, however practically, that is usually exceeding the scope of operations for those personnel trained at the operations plus level.
Our next point of discussion will be that of the specific training required at the operations plus level. Personnel are first required to be certified to the operations level of hazmat certification and then receive training or demonstrate competency in several topical areas. The first topical area is that of the knowledge, and use of the personal protective equipment (PPE) utilized at the operations plus level, namely the structural firefighting PPE used for thermal protection in case of an ignition of the product and the chemical protective clothing (such as Tychem suits; and Viton or nitrile gloves used for chemical protection). I do remember approximately twenty-five years ago when we were provided with Tychem suits for just that purpose and were told that “one size fits all.” I will say that I found out that was not the case the first time I tried to scoot under a small car to stop a fuel leak and proceeded to hear the Tychem suit rip. Potential operations plus level responders are also required to acquire a knowledge of the hazmat terminology that applies to hydrocarbon fuels, such as flash point, ignition temperature, vapor density, and specific gravity.
An additional topic covered during operations plus training is that of the hazard and risk assessment techniques used with hydrocarbon fuels. Personnel are required to be able to recognize the flammability and chemical hazards of hydrocarbon fuels, as well as the on-scene hazards in areas such as possible ignition sources (hot exhaust components, etc.). The core tenet of operations plus training that is also required to be addressed is that of control, containment, and confinement of hydrocarbon fuels. There are many options available to utilize in product control, including plugs or wedges, fabricated stoppers such as those found in Cromwell Kits, granular products that form a putty when mixed with water, and binary putties consisting of two components that are mixed together on scene. One of the simplest and easiest methods of product control is the use of a portion of a wax toilet gasket (the same as used to seal your toilet at home) to patch a leak. Other items discussed within product control consist of tightening fuel filler caps to help slow a leak, rotating ejected saddle tanks so that the hole or compromise is at the top of the tank, how to properly use a spill pool to catch leaking products, and the use of crossover valves on older heavy trucks to isolate leaking saddle tanks so that they do not draw fuel from an intact saddle tank on the other side of the vehicle. The final operations plus topical training area that is required to be addressed is that of the proper decontamination procedures used with hydrocarbon fuels. Personnel should be reminded that a detergent and water decontamination solution is usually the most appropriate choice and a suitable decontamination setup should be developed and discussed that allows for a quick setup time with minimal equipment.
As we have discussed above, the operations plus level of certification is very unique in the hazmat world. An additional item regarding this level of certification is that personnel will not receive a certificate from the North Carolina Office of the State Fire Marshal (NCOSFM), nor will the training show up on an NCOSFM Transcript as the operations plus certification is granted by the employer. With the above having been stated, the next logical question is that of how to conduct the training at your own department. The best method that I have found is to use a qualified hazmat instructor to deliver the operations plus training program at the end of annual operations level hazmat refresher training sessions for those personnel that have completed hazmat operations certification in the preceding year. A short classroom session is followed by a practical evolution in which personnel stops a simulated release of a hydrocarbon fuel (a suitable vessel and water are used for the simulation). Personnel who successfully complete the training are then awarded certificates by the department.
Many responders will also question the need for operations plus training, especially since the very existence of the training is often not known by responders. One driving factor underscoring the need for such training centers on our departmental capabilities. As most fire departments respond to vehicle accidents, it behooves us as a department and for our personnel individually to be able to competently plug, patch, or otherwise stop fuel tank leaks ad releases that often occur at accident scenes. As fire departments are also the “go-to” agency for many types of incidents, fire departments in the State of North Carolina are also likely to be dispatched to fuel leaks emanating from parked or stored vehicles. A second driving factor is that of liability. If personnel in your department may even possibly attempt to stop a leak or release from a vehicular fuel tank, that personnel should be trained to the operations plus level in order to reduce departmental liability and ensure the safety of personnel. The last thing any Fire Chief wants is to be in court after an incident involving a leak or release from a fuel tank head south and then be asked by an attorney why departmental personnel were not trained to an existing required level of certification to perform the actions that were undertaken.
In conclusion, the operations plus level of hazardous materials certification that exists solely within the State of North Carolina is an often overlooked but vitally important area of hazardous materials training and certification. If your department does not provide the additional training that was discussed above, the department and its leadership may be facing unanticipated roadblocks in terms of departmental capabilities and the liabilities that may arise from personnel not meeting defined training requirements. It also is a great benefit that operations plus training is neither time-consuming nor overly complicated. As always, stay safe out there prior to, during, and after hazmat responses.
Glenn Clapp is a past president of the North Carolina Association of Hazardous Materials Responders and has over 24 years of fire service and emergency management experience. He is currently an Improvement Specialist with the Industry Expansion Solutions Division of North Carolina State University and is a volunteer firefighter with the Fairview Fire Department. He is also a Technician-Level Hazmat Instructor, an Executive Fire Officer, a Certified Hazardous Materials Manager and a Certified Fire Protection Specialist.