1. Determine spill types. It’s important to first determine which spill types you anticipate at your location before deciding your training requirements. The good news is there are only two types to consider: incidental spills and emergency response releases.
Responses to incidental spills involve hazardous substances that can be absorbed, neutralized or otherwise controlled at the time of release by employees in the immediate spill area or by maintenance personnel. OSHA states, “An incidental release does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employee cleaning it up, nor does it have the potential to become an emergency within a short time frame.” Incidental releases are often limited in quantity, exposure potential or toxicity and may present only minor hazards to employees.
Like incidental spills, emergency response releases involve a hazardous substance(s), but emergency response releases are uncontrolled or are likely to be uncontrolled. A definition at §1910.120(a)(3) says OSHA also calls for a response effort by employees outside the immediate area or by designated responders. While OSHA does not specify a quantity that makes a spill an emergency, the agency offers examples of release conditions that would normally prompt an emergency response effort:
- High concentrations of a toxic substance
- Situation that is life or injury threatening
- Oxygen deficient atmosphere
- Fire or explosion hazard
- Situation that requires an evacuation
2. Determine training requirements. Employees who participate, or are expected to participate, in emergency response operations must be given emergency response training under §1910.120(q). Covered employees generally include first responders, such as Haz-Mat team members, but also fire and rescue personnel, police and medical personnel who may respond to emergency releases.
Paragraph (q) divides emergency response training into five basic levels, based on the functions and duties your responders will be expected to perform:
- Awareness — Witnesses or discovers a release and notifies authorities
- Operations — Responds to the release in a defensive manner
- Technician — Responds aggressively to stop the release
- Specialist — Responds aggressively to stop the release but also has specific knowledge of hazardous substances
- Commander — Assumes control of the incident scene
Note if you have the potential for emergency response type releases, but you do not allow any of your employees to handle them, you must then implement and train employees in your facility emergency action plan (also known as an evacuation plan) for release situations in accordance with §1910.38.
As stated earlier, not all spill responders need HAZWOPER training. An incidental spill may be safely cleaned up by employees who are familiar with the hazards of the chemicals with which they are working. If your employees are to respond to incidental spills, then you must offer training under other applicable regulations, such as those for hazard communication (§1910.1200) and PPE (29 CFR 1910 Subpart I).
For more information, visit www.JJKeller.com or call (877) 564-2333.
