On-Scene Incident Commander training is required for response beyond the First Responder Awareness Level. The role of the incident commander is to assume control of the incident scene. The incident commander must be someone on-site who is designated and trained to be in charge of the incident.

The required training will vary with the level and complexity of the response. The minimum required training is 24 hours, including at least First Responder Operations Level training. Competency must be demonstrated in implementation of the incident command system, the employer's emergency plan and the local emergency plan. He or she must understand the hazards and risks of working in personal protective equipment and the importance of decontamination.

The OSHA training requirements are a minimum. Based on the nature of your facility and its hazards, additional training could be necessary.

All levels of training require annual refresher training or a demonstration of competency. Drills and other activities can be used to demonstrate competency.

By allowing a HazMat team to respond to nonemergency spills, a facility provides an excellent way to maintain skills that would be needed in an emergency. Whatever you choose to do, you must remember to document the training and competency evaluations.

 

On-Scene Incident Commander Training includes details about the hazards and risks of working in personal protective equipment.

Assessing risks

Risk assessment is used to evaluate the severity and probability of potential incidents. Although many sophisticated risk assessment techniques are available, you do not need to have extensive training or education to apply the principles.

A simple method for risk assessment is to develop a list of potential scenarios and their probability (high, medium, low, improbable) and severity (high, medium, low, minor/none). This will enable you to quickly answer important questions.

A variety of resources are available for conducting more sophisticated risk assessments. They include EPA's Chemical Emergency Preparedness and Prevention Office, www.epa.gov/ceppo, and the National Safety Council's Crossroads Web site, www.crossroads.nsc.org.

What are your worst-case scenarios and how likely are they to occur? What incidents would have the greatest impact to your employees, the community and environment, or your business?

The risks and costs then can be compared to the costs and benefits of various levels of spill response. Maintaining a well-trained and equipped HazMat team is a considerable investment ," an investment that might be a bargain compared to the potential costs.

A variety of options exist between "everything" and "nothing." Evaluate the availability of outside resources. Are local spill response organizations available? What is their cost vs. the cost of maintaining an internal team? The outside spill team could perform the entire response, or support your internal capabilities.

An internal team could be trained to the First Responder Operations Level, taking only defensive measures to contain the spill. The outside service then could take offensive measures to control and collect the spill. This type of option allows rapid containment, cutting risk and losses, and reduces the amount of internal time and resources that must be used to maintain preparedness.

Satisfying your spill response needs is not about simple answers. It is about asking the right questions.

Burgess is a certified safety professional with Chatham, N.J. -based Emilcott Associates Inc., which specializes in industrial hygiene, health, safety and environmental consulting and training services. He can be reached at tburgess@emilcott.com.