One of the first questions you need to ask is whether or not you will be performing emergency response. If your facility does perform emergency response, you must determine who is responsible for emergency response and to what level. The existence of a "spill team" does not necessarily mean the team performs emergency response.

For the protection of your employees, the facility and the community/environment, the capabilities and limitations of your spill team should be defined. No matter how sophisticated your spill response operations, it is essential to recognize your limitations.

A key factor in determining whether a release, or potential release, is an emergency is the degree of danger to employees. Examples of emergency situations include those that require evacuation, create conditions that might present an immediate danger to health and safety, pose a fire or explosion hazard or require immediate action because of the potential for additional damage. Nuisance spills and minor releases that do not require immediate attention are not considered emergencies.

You must consider several factors to determine whether or not an emergency exists. These include, but are not limited to, the quantity of the material; physical hazards posed by compressed gases, flammables, explosives, or oxidizers; and health hazards associated with poisons, corrosives or radioactive materials.

The nature of the operation and the operator's training and experience also should be considered. In a facility that routinely handles acids and that has trained and equipped its employees to safely handle incidental spills, many small acid spills might not be considered an emergency. In another facility with less training, equipment or experience, an identical spill might present an immediate hazard to employees. In this facility, therefore, spill response would be considered an emergency response.

Training requirements

The HAZWOPER standard establishes five basic training requirements related to chemical emergency response: the First Responder Awareness Level, First Responder Operations Level, Hazardous Materials Technician, Hazardous Materials Specialist, and On-Scene Incident Commander training. These training levels are based on an emergency response. A summary of HAZWOPER emergency response requirements is provided in Table 2.

First Responder Awareness Level training is required for individuals who are likely to witness or discover a hazardous substance release and who would take no action beyond notification of the proper authorities. Even if you do not have a spill team and do not plan to respond to spill emergencies, your employees might need First Responder Awareness Level training. This training potentially could include everyone from the chemical operator to the security guard, mail clerk and salesperson. The standard specifies six areas of competency that must be achieved either through training or experience, including understanding the risks associated with a hazardous substance incident.

Elements of First Responder Awareness Level training are similar to Hazard Communication, DOT General Awareness, and Resource Conservation and Recovery Act (RCRA) Spill Prevention Control and Countermeasures (SPCC) training. Many elements of these training programs can be integrated to avoid duplicate training.

However, facilities must address the elements unique to each regulation. Important elements of First Responder Awareness Level training are the ability to determine the need for additional resources and the ability to make appropriate notification to the communication center.

First Responder Operations Level training is required for individuals who respond to releases or potential releases as part of the initial response. They are trained to respond in a defensive manner to protect people, property and the environment.

Defensive actions are those taken from a safe distance to keep the spill from spreading and to prevent exposures. Examples include covering drains, placing spill booms or barriers and barricading access points ," all from safe distances.

Eight hours of training or sufficient experience to demonstrate competency is required. The areas of required competency include hazard and risk assessment techniques, selection and use of personal protective equipment, spill control and containment, decontamination and standard operating procedures.

Hazardous Materials Technician training is required for individuals who will respond to the release or potential release for the purpose of stopping the release. They usually will be close to the source of the release and, therefore, have a high potential for harmful exposures. Examples include overpacking a leaking drum or collecting contaminated absorbents.

The investment in training, as well as in procedures and equipment, substantially increases when moving up to this level of response. The facility will need to train and equip enough people, including hazardous materials specialists and an incident commander, to meet a variety of requirements.

The Hazardous Materials Technician level calls for 24 hours of training. Personnel also must demonstrate competency in several areas, including the emergency response plan, instrumentation, the incident command system, selection and use of personal protective equipment, hazard and risk assessment, containment and control, decontamination, termination procedures and basic chemistry and toxicology.

Hazardous Materials Specialist training is similar to the Hazardous Materials Technician training. However, the specialist is required to have greater knowledge of the chemicals to which he or she might respond, as well as to act as a liaison with governmental authorities. He or she also provides support to the hazardous materials technician.

Twenty-four hours of training is required. Areas of required competency include those required of the hazardous materials technician, plus an understanding of the state emergency plan and in-depth hazard and risk assessment techniques. He or she also must be able to determine decontamination procedures, develop a site safety and control plan and demonstrate a greater knowledge of chemistry and toxicology.