First Responder Awareness Level Training EPA Region 6 Superfund Division, Prevention & Response Branch Steve Mason EPA Region 6 [email protected] 1|Region 6 HAZWOPER Awareness Training Preface Welcome to the Region 6 Hazardous Materials - Awareness course. This course is based on criteria found in OSHA’s HAZWOPER Standard (29 CFR 1910.120(q)(6)) as well as the National Fire Protection Association (NFPA 472) standard. This manual, and the accompanying course, is designed for local, state, and federal personnel, as well as private employees who are required to meet the training requirements for the HAZWOPER standard (29 CFR 1910.120), but may not have the time to take the training in a traditional classroom setting. Remember, annual refresher training is required for all persons trained under the HAZWOPER Standard (29 CFR 1910.120(q)(8) to maintain their responder competency. Contents UNIT 1 . . . . . . . . . . UNIT 2 . . . . . . . . . . UNIT 3 . . . . . . . . . . UNIT 4 . . . . . . . . . . UNIT 5 . . . . . . . . . . UNIT 6 . . . . . . . . . . APPENDIX A . . . . . . APPENDIX B . . . . . . APPENDIX C . . . . . . THE BASICS OF HAZARDOUS MATERIALS REQUIRED TRAINING FOR AWARENESS LEVEL RESPONSES REQUIREMENTS OF HAZMAT TRAINING DETECTION / IDENTIFICATION OF HAZARDOUS MATERIALS USING THE EMERGENCY RESPONSE GUIDEBOOK PUTTING IT ALL TOGETHER OSHA HAZWOPER STANDARD (29 CFR 1910.120) OSHA INTERPRETATION LETTERS ON HAZWOPER AWARENESS CONTAINER IDENTIFICATION Acknowledgements EPA Region 6 gratefully acknowledges the following organizations in providing input to this effort or reviewing the information for accuracy and effectiveness. Arkansas Department of Emergency Management Oklahoma Department of Emergency Management Texas Division of Emergency Management New Mexico Department of Public Safety / Emergency Management TAS Environmental Services Region 6 RRT Industry Liaison Committee FEMA Region VI Florida Division of Emergency Management Disclaimer EPA Region 6 disclaims liability for any personal injury, property or other damages of any nature whatsoever, whether special, indirect, consequential or compensatory, directly or indirectly resulting from the publication, use of, or reliance on this document. The reader of this document is warned to consider and use any and all safety precautions that might be indicated by the activities herein and to avoid potential hazards whenever possible. The reader willingly assumes all risks in connection with activities undertaken which may be referenced in this document. EPA makes no guaranty or warranty as to the accuracy or completeness of any information published herein. 2|Region 6 HAZWOPER Awareness Training Unit 1: The Basics of Hazardous Materials 1. INTRODUCTION What if a public works team, while collecting trash from a neighborhood, came across bags containing muriatic acid, bleach, and other cleaning materials? In transit, the acid and bleach begin to react with one another and the other chemicals, producing fumes that could be harmful or fatal to the team members. Do they know how to handle the situation, including who to call for assistance? Public and private employees may be expected to deal with the potential of a chemical accident. Employers may expect employees to learn how to deal with hazardous materials emergencies. Employees need a fundamental awareness of the workplace and the chemicals encountered and how to properly respond to a potential chemical incident. Regardless of the motivation; whether you are volunteer or a paid fire fighter, an EMT or paramedic, a public utilities worker, law enforcement, a LEPC member, an industry worker, or a concerned citizen, it’s important to learn about hazardous materials and the possible threats posed to humans, the community, and the environment. Each day, by highway, waterway, air or rail, there are hazardous material and chemical substances being transported. DOT presently estimates the number of hazardous materials shipments in the United States at more than 800,000 per day. Approximately 500,000 daily shipments involve chemical and allied products (SIC 28); about 300,000 involve petroleum products; and at least 10,000 other shipments involve waste hazardous materials, medical wastes and various other hazardous materials. These substances generally move safely by highway, waterway, air or rail without any problems. However, when a spill occurs, the results can pose a serious threat to human health, the environment, and to property. There are hazardous material events daily throughout the United States. DOT estimates there are approximately 15,000 hazardous materials incidents each year. Transportation incidents may cost hundreds of thousands of dollars for response and clean-up activities. A hazardous materials incident, or hazmat emergency, is an emergency incident that involves the release or potential release of a substance that is damaging to health, the environment, or property. 2. HAZARDOUS MATERIALS DEFINED A hazardous material, as defined by DOT, is a material that poses an unreasonable risk to the health and safety of operating or emergency personnel, the public, and/or the environment if not properly controlled during handling, storage, manufacturing, processing, use, disposal, or transportation. However, the Secretary of Transportation can designate something as a hazardous material when it poses an unreasonable risk to health and safety or property. Another definition is: "A material or materials accidentally released from the original container and used in a manner not originally intended. Hazardous materials can be unintentionally contaminated or mixed with other chemicals or involve some outside reactive sources such as heat light, liquids, shock or pressure.” EPA uses the term “hazardous substances” to describe the “elements, compounds, mixtures, solutions, and substances which, when released into the environment may present substantial danger to the public health or welfare or the environment.” OSHA uses the term “hazardous chemical,” and “hazardous substance” to define any chemical that would be a risk to an employee’s health if exposed in their workplace. When a hazardous chemical or substance is involved in an emergency, it may cause short-term health effects or long-term health effects. Depending on the chemical involved in the accident, a fire, explosion, or other reaction may occur, causing injuries or other hazards to employees. 3|Region 6 HAZWOPER Awareness Training Each term has a legal meaning and is important to understand. However, for recognition and identification, a hazardous material is defined as any substance that has a potential, when released, to cause harm to the health of people or the environment or damage to property. These substances could range from industrial products like chlorine and muriatic (pool) acids to everyday substances such as milk. 3. WHY ARE HAZARDOUS MATERIALS INCIDENTS DIFFERENT FROM OTHER INCIDENTS? Hazardous materials can increase risk and potential danger more than other hazards on an emergency scene. There are many factors that contribute to the challenges of hazardous materials incidents. Among these factors are the characteristics of the hazardous material encountered,, the increased presence of these materials in our everyday lives, and the inadequacy, or lack of training. a. Wide Ranging Characteristics A hazardous material does not have any uniform characteristics other than they can be in any form: solid, liquid, or gas. Solid: Solid materials, such as metals or explosives, can be hazardous when heated or if they come into contact with other substances. In addition, solid objects may produce dusts that you can breathe into your lungs. Liquid: When hazardous liquids are spilled, they may damage the living things they touch, or they can turn into harmful gases, depending on surrounding conditions and other materials present. Gases: If a hazardous substance is in a gaseous state, it becomes easier to breathe and more difficult to control. These materials can be odorless, colorless, and very potent. In essence, some hazardous materials can go completely undetected until it is too late. There are signs that you can use to help verify the presence of hazardous materials, and tools that you can use to help determine the hazards. Occupancy / location Colors / markings Placards / labels MSDS (Material Safety Data Sheets) Senses/Sensors (Your Body or alarm instrumentation) Container shapes Shipping papers By using these signs and tools, you will be able to determine the immediate actions to take to protect yourself and the general public. Trained at the Awareness level, you need to be able to identify the type of release which you have witnessed. Your notification of this information to the proper authorities will allow organizations to determine the appropriate response actions to control the emergency and protect lives. b. Prevalence of Hazardous Materials As our technology advances, chemicals are being manufactured in greater quantities and in more powerful concentrations. A review of the Chemical Abstract Service's (CAS) list indicated 24 million organic and inorganic substances, with up to 63,000 of them considered hazardous. Many of these are known by several names, synonyms, or differing trade names. Hazardous materials are present in almost every setting. Between 1990 - 2009, the Agency for 4|Region 6 HAZWOPER Awareness Training Toxic Substances and Disease Registry (ASTDR) maintained a state-based Hazardous Substances Emergency Events Surveillance (HSEES) system to explain the public and environmental health costs and property damage associated with the release of hazardous substances. HSEES captured data for more than 8,000 events annually. Over the years, the national database remained fairly consistent. Fixed-facility events represent 70-75%, and transportation related events about 25-30% of all reported events. Events tend to increase in spring and summer when agricultural activities are at a peak. The most frequent causal factors for fixed-facility events are equipment failure and human error. Most fixed-facility releases involve a vessel used for processing. An EPA study reviewed commonly released hazardous chemicals. This national study indicates the most commonly released chemical is vehicle fuel. If you do not consider vehicle fuels, the study covered 6,928 major chemical incidents. The key findings were as follows: Release Locations 74.8% occurred in facilities (production, storage, uses) 25.2% occurred in transportation. Commonly released chemicals 49.5% of the incidents involved only 8 chemicals, including chlorine, ammonia, caustics, acids, benzene, hydrogen sulfide, and toluene. 35.7% of the death and injury events involved the same 8 chemicals Think about driving down the interstate highways or any of the parkways in your community. How many tank trucks have you seen? Of the transportation accidents, over eighty percent (80%) of these accidents happened on the roads. It is important to realize that fifty-nine percent (59%) of these incidents were due to equipment failure, including safety devices. In many cases the chemicals are produced at a manufacturing facility and then transported in bulk to other sites. This transportation takes place over the road, rails, water, or by way of pipelines. Many of those trucks can carry up to 9,000 gallons of liquid. From 1990-2013, over 60,000 accidents involving trucks carrying hazardous cargo were reported to the National Response Center (NRC). However, it is important to note that of these accidents, only a limited percentage took place on Interstates. The remainder of these accidents involving trucks carrying hazardous cargo took place on county roads, city streets, US, or state numbered routes. This is why all response organizations should be trained in hazardous materials response. All of these statistics point to one fact: the transportation and use of hazardous materials is growing every day, bringing an increased potential for hazardous materials incidents. c. Overcoming the Challenges of Past Training Past training has stressed taking immediate action for all types of incidents, including hazardous materials. That approach however, can be deadly. Response to hazardous materials incidents requires a deliberate and informed response. This is why the consideration of the safety aspects of hazardous materials response is so important to the responder. d. Uniqueness of Hazardous Materials May require the use of personal protective equipment (PPE), not available to the on-scene first responder and which he may not be trained to use 5|Region 6 HAZWOPER Awareness Training Usually requires different operational approaches from “normal” or “routine” duties and different skills and attitudes Differs from routine incidents in that it may pose a significant risk to the first responder Intentional chemical releases may be used to cause injury or death to first responders and persons in the vicinity of a release Those most susceptible to the effects of a hazardous material are the ones who treat the incident as routine First responders are injured by hazardous materials due to complacency and lack of recognition Greater potential for long term health issues May require multiple response agencies May involve unseen or unpredictable hazards 4. WHAT ARE THE THREATS POSED BY HAZARDOUS MATERIALS? Before we can discuss the threats presented by hazardous materials, you need to understand the classes of hazardous materials. DOT has made your job easier by dividing thousands and thousands of chemicals into nine categories (with many chemicals falling under several different classifications). DOT has classified hazardous materials according to their primary danger and assigned standardized symbols to identify the classes. Materials are grouped by their major hazardous characteristic and many materials will have other hazards as well. Example: A material may be poisonous, corrosive and flammable but will only be grouped with whichever is considered the worst. A list of all the categories is included in Appendix 3. 5. WHAT IS AN EMERGENCY OSHA has provided information in various interpretation letters on what is considered an emergency and what is not. Not every release of a hazardous substance is considered an emergency. To be an emergency, three various conditions need to be present: First, the release of a material must pose a potential safety or health hazard Second, the release requires response efforts from outside the immediate release area or by other designated responders – in other words, the response is carried out by others than those who were working with material. Third, the release results in, or is likely to result in, a larger uncontrolled release of the substance. 6. RISKS AND ROUTES OF EXPOSURE Once a chemical is identified into its class, it is easier to discuss the risks one may encounter when facing a hazardous materials incident. Why do you really care about the risks associated with hazardous materials? You should care because hazardous materials can cause death or severe harm to individuals in a number of ways. There are physical hazards such as thermal hazards, caused by exposure to heat. There is mechanical trauma that is caused by the body being hit by debris or an explosive pressure wave. There are health hazards such as chemical hazards, often caused by corrosives destroying the skin. Other chemical hazards are caused by poison/toxins that create a systemic reaction in the human body. Finally, there are chemicals that asphyxiate by displacing or absorbing oxygen, leaving no oxygen for the body to use. There are radiation hazards that can cause burns or severe internal damage. Also, there are etiologic effects caused by microorganisms or toxins produced by microorganisms that cause disease in humans. 6|Region 6 HAZWOPER Awareness Training As stated before, there are several routes of exposure. These routes are oral (ingestion), inhalation, injection, and contact absorption (dermal) through skin or eye contact. 7. HAZARDOUS MATERIALS AND THE ENVIRONMENT Do you remember the definition of a hazardous material? Hazardous materials are any substances that present a danger to people, the environment, or property. So far, you have heard about how hazardous materials affect the human body, but you need to remember that a hazardous material can damage the environment. The concern for the environment during and after a hazardous materials spill is how this substance will affect the living creatures in the air, water, and soil. Pollution, which may be described as a prolonged release of hazardous materials into the environment, causes different concerns. Hazardous materials can contaminate the water table and the soil irreparably. What is worse is that the severity of the damage may not be fully known for decades after the spill. If a tract of land were contaminated and considered to be unsuitable for agriculture, it could literally ruin a farm family. There are three main concerns that you should have for the environment as it relates to hazardous materials releases, the air, water, and the soil. At the awareness level of first response you should remember your responsibilities, notifying the proper personnel of the release. 8. THE HAZARDOUS MATERIALS RESPONDER HAZMAT responders are all persons directly or indirectly involved in the response, including dispatchers, planners, police, Emergency Medical Service (EMS), industrial spill teams, and fire fighters. Emergency service personnel must act as a team to insure the most effective response to hazmat situations. That assurance only comes though proper training. Title First Responder Awareness Hazardous Materials Responders at the Awareness Level Action Who Recognize the problem Identify (if possible) Police, some Fire Fighters, Public Notify more qualified responders works, EMS / Hospital, Industry Safely isolate area workers, Emergency Management Do nothing else Once someone has completed the HAZWOPER Awareness training program, that person should be able to demonstrate the following: 1. An understanding of what hazardous substances are, and the risks associated with them in an incident; 2. An understanding of the potential outcomes associated with an emergency created when hazardous substances are present; 3. The ability to recognize the presence of hazardous substances in an emergency. 4. The ability to identify the hazardous substances, if possible. 5. An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control, and the Emergency Response Guidebook. 6. The ability to realize the need for additional resources, and to make appropriate notifications to the communication center. 7|Region 6 HAZWOPER Awareness Training 9. DUTY TO ACT a. Standard of Care There is a level of competency anticipated during the performance of a service or a duty. The concept of the “Standard of Care” dictates that responders act appropriately when serving the public. Numerous laws, regulations and standards are in place and influence the responder’s actions at hazardous materials incidents. Each responder should be knowledgeable of these. Failure to follow these standards would result in violation of the “Standard of Care”. b. Duty to Act Only local public safety responders can provide the critical first decisions at a hazardous materials incident. Past experience has shown that decisions made during the first critical minutes which are based upon safety and public protection, greatly reduce the risk of first responder injury. Normally, no other agency (state or federal) is in a position to make the critical first decisions. All responders should be familiar with their organization’s Emergency Response Plan. This Plan should address their specific rules or policies on the “duty to act.” The organization’s response plan and standard operating guidelines should have defined procedures in the event of an emergency. Most communities agree that local responders and public employees can provide this service. First responders’ actions should not exceed the level to which they are trained and equipped. 10. TYPES OF RELEASES When a hazardous material is released, response organizations may have several goals to achieve to mitigate the consequences of the release. Goals Actions Spill Control The process by which the spread of a product through the environment is either limited or completely stopped Leak Control The process by which a breach or failure of a container is either directly or indirectly controlled Fire Control The process by which the potential impact of fire is reduced or prevented Making the proper notifications to the appropriate organizations can help officials complete the goals above. 11. ROLES OF PERSONNEL AT THE AWARENESS LEVEL Personnel, trained at the awareness level have four responsibilities, which are expressed as goals: ability to recognize incident involves hazardous material(s), and if possible, to identify Recognition / Identification material(s) (if it can be done at no risk) ability to isolate involved area, restrict access to area and remove un-injured and unIsolation contaminated persons from area (if it can be done at no risk) ability to ensure personal safety and safety of uninvolved public (if it can be done at Protection no risk) Notification ability to notify next level of response as defined in organization’s response plan If you complete these goals using sound decision making, the outcome of the incident can be greatly enhanced. 8|Region 6 HAZWOPER Awareness Training 12. INTERVENTION From the beginning you have heard and read that a hazardous material is any substance that presents a danger to people, the environment, or property. Your goal is to remove the threat(s) to the general public, the environment and property that a hazardous materials incident may pose, staying within the parameters of the training you have received and working within the guidelines established by your employer. All local response organizations should review protocols based on the following: “Response teams to a disaster scene have a responsibility to first protect themselves and their team members. If you or your team is injured, not only are the number of victims increased, but the response is now delayed, resulting in additional resource utilization. This delay and need for additional resources due to your inability to keep yourself and your team protected could cost other victims their lives. Don’t be selfish - protect yourself. “ 1. 2. 3. 4. Scene priorities: Protect yourself and your team members first Protect the public Protect the patients Protect the environment At an incident, safety should be the first concern of any responder. When fire fighters, police officers or emergency medical technicians become injured or contaminated, they become part of the problem, instead of a solution. It’s unfair to ask responders to risk their life, health, or health of their families by becoming contaminated at an incident. Difficult decisions need to be made and risks taken should be weighed against the possibility of a positive outcome. 13. SUMMARY Hazardous materials are defined in different ways by various agencies. However, for the first responder, hazardous materials are defined as any substance that has a potential, when released, to cause harm to the health of people or the environment or damage to property. Incidents involving hazardous materials differ from other incidents due to the wide range of characteristics, the prevalence in the U.S., and the challenges presented by past training that have taught responders to rush in. Hazardous materials response requires a careful and deliberate approach. There are 3 different forms in which a hazardous material might exist: gas, liquid, or solid. There are 9 classifications defined by DOT. Some of these classifications are broken down further into divisions based on unique hazards within the classifications. Hazardous materials not only present dangers to the health of humans, but also to the environment and property. Although substances are not chemically hazardous, they may present danger to humans, the environment, and property because of temperature, packaging, or quantity. Hazardous materials incidents may be harmful in many ways. The acronym TEAM CPR (see below) explains the type of hazards that may be encountered. The goal of the competencies at the awareness level shall be to provide first responders with the knowledge and skills necessary to perform the following tasks safely. Therefore, when first on the scene of an emergency involving hazardous materials, the first responder at the awareness level shall be able to: a) Analyze the incident to determine both the hazardous materials present and the basic response information by completing the following tasks: 1) Detect the presence of hazardous materials. 9|Region 6 HAZWOPER Awareness Training 2) Survey a hazardous materials incident, from a safe location, to identify the name, United Nations/North American (UN/NA) identification number, or type placard applied for any hazardous materials involved. 3) Collect hazard information from the current edition of the Emergency Response Guidebook (ERG). b) Implement actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of the ERG by completing the following tasks: 1) Initiate protective actions. 2) Initiate the notification process. T.E.A.M. C.P.R. T Thermal a Exposure to extremes in temperature b Heat from fires or releasing chemical reactions c Extremes in cold such as those identified with liquefied gases and cryogenic liquids E Etiological a Injury or harm caused by human disease causing agents b Bacteria and viruses A Asphyxiation (divided into simple or chemical) a Simple - oxygen deficient atmosphere, can be caused by displacement of ambient oxygen Chemical - many toxic substances, such as carbon monoxide, cause pathological changes within the b body by preventing the body from properly using oxygen M Mechanical a Flying debris from explosions b Trips and falls on uneven ground c Excessive noise conditions resulting in loss of hearing C Chemical Negative effects from exposure to chemicals or toxic materials include: poisoning from pesticides a and biological toxins, respiratory system injury from a substance such as chlorine and corrosive damage from contact with acids and alkaline materials P Psychological a Mental harm caused by fear of the unknown and/or witnessing a violent death R Radiological a Exposure to materials which spontaneously emit ionizing radiation Unit 2: Physical / Chemical Properties for Awareness Level Response 1. CHEMICAL HAZARDS – BASIC TOXICOLOGY First, we must balance the beliefs from both ends of the spectrum. On one end, just because a chemical is involved in a response does not mean that it will explode, or kill us from a minor exposure. At the other end, it is a big mistake to have the attitude nothing can harm you, the chemicals are not benign, or you are invincible. 10 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Toxicology is the study of the adverse effects of chemicals on living organisms. It is a broad science because of the variety of potential effects and diversity of chemicals. Toxicity is an inherent characteristic of all chemicals and a certain dose of any substance may cause illness, injury or death. As Paracelsus, the father of toxicology, said: "All things are poison and nothing is without poison, only the dose permits something not to be poisonous." So, how does a hazardous material harm someone, and how much does it take to cause real harm? For a chemical (or substance) to affect a person, it must enter the body in a dose large enough to cause an effect. When you take medicine for a headache, blood pressure, or other ailment, it is important to take the appropriate dose. At the recommended level (dosage), the medicine can provide relief; below the proper dosage, it may not have any effect; above the proper amount may cause acute damage. a. Routes of Exposure In order for a chemical to exert its toxic effect, it must get into the body and reach its target. There are four major routes of exposure for chemicals to enter the body: • • • • Inhalation Dermal absorption Ingestion Injection i. Inhalation Inhalation is the primary route of exposure and the most rapid and efficient route of entry for chemical vapors, gases, mists or particulates. Inhalation of a chemical can cause local effects of irritation when the chemical reaches the nose, throat, and upper respiratory tract. The chemical action can cause damage to tissues of the throat and bronchi. Systemic effects occur when the chemical reaches the alveoli where gases are exchanged. Once the chemical reaches this point, it can enter the bloodstream and cause adverse effects in target organ systems. This can be a very rapid process, and cause major problems in a very short time-frame. Please remember that just because you cannot smell the chemical does not mean it is harmless. Many toxic substances can be fatal, or cause significant injuries below its odor threshold (the amount needed for you to notice). ii. Skin / Dermal Absorption Your skin is considered the largest organ of your body. Overall, your skin can provide a fair amount of exposure protection. Exposure can occur from a spill or splash and from hand-to-eye contact. Local effects occur when the chemical causes irritation, burns or dermatitis. Systemic effects occur when the chemical is absorbed through the skin into the bloodstream and distributed to other parts of the body. Broken skin can increase the absorption rate. Examples of chemicals that can be absorbed into the skin include: • • • • Benzene Carbon disulfide Carbon tetrachloride Toluene 11 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g The two categories of chemicals that usually present the largest threat to your skin through exposure are corrosives and solvents. Corrosives will destroy the skin and underlying tissue. Solvents will de-solve (melt) away tissue, including the fats and oils in your skin. iii. Ingestion Ingestion is usually less of a concern because it is a less common route for chemicals to enter the bloodstream. Accidental ingestion occurs from contaminated food and drink and poor personal hygiene. For example, washing your hands can help prevent accidental ingestion. Exposure can be local (nausea, vomiting) or systemic (affecting target organ systems). Once ingested, the hazardous material will enter your digestive system, along with the carrier (food or drink). From there, it can enter the bloodstream, or cause local distress to the different portions of the digestive system. iv. Injection If your skin is accidentally pierced or otherwise damaged, hazardous substances can pass through and enter your body. It can be as simple as a wound, cut, scrape, scab, or other small opening. Additionally, situations that can lead to accidental injection include misuse of contaminated tools or equipment, misuse or improper disposal of contaminated needles/sharps, improper handling or disposal of contaminated glass/metal objects, or accidentally stepping on nails or other sharp, rusty objects Remember, although a chemical may be considered hazardous, many times it may only be harmful if it enters the body in a high enough dose. b. Dose In toxicological studies, the dose rate is the concentration of a contaminant multiplied by the duration of human exposure. Concentration is the amount administered, usually expressed in units that are based on the route of exposure. Duration of exposure or period of time over which the dose has been administered depends on how rapidly and often a substance is given. There are several classifications of duration: • Acute: Refers to a single exposure over a short period of time (less than 24 hours). In the field, examples include exposure from chemical releases or splashes • Subacute: Refers to single or multiple doses delivered within 30 days • Subchronic: Refers to single or multiple doses delivered within 1 to 3 months in animals • Chronic: Refers to repeated or continuous exposure over long periods of time (more than 3 months and up to 2 years) in animals. Exposure from long-term remedial site work would be a chronic exposure situation c. Response / Effects Before a dose-response relationship can be evaluated, the type of effect or endpoint that is being measured must be identified and defined. The following are usual toxic effects seen following a chemical exposure. • Local Effects: A local effect refers to an adverse health effect that takes place at the point or area of contact. The site may be skin, mucous membranes, respiratory tract, eyes, etc. For example, if a chemical comes in contact with the skin, it may cause a rash or burn. 12 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g • • • Systemic Effects: A systemic effect refers to an adverse health effect that takes place at a location distant from the body’s initial point of contact and presupposes absorption has taken place. Substances with systemic effects often have “target organs” in which they accumulate and exert their toxic effect. For example, some chemicals (e.g., arsenic) when ingested may travel through the body and exert their toxic effect on the liver. Immediate vs. Delayed Effects: Immediate effects are those effects that develop rapidly after a single administration of a substance. Delayed effects occur after some time has passed since administration or after repeated exposure to a chemical. Reversible vs. Irreversible Effects: Some toxic effects are reversible, such as a rash or nausea. However, effects such as corrosion of eye tissue or induction of cancer are irreversible. The ability of tissue to regenerate usually determines whether the effect is reversible or irreversible. d. Dose / Response Relationship The dose-response relationship describes the change in effect on an organism caused by differing levels of dose (or exposure) to a chemical. In general, a given amount of toxic agent (chemical) will elicit a given type and intensity of response. However, each person’s tolerance level or response to a toxic agent is influenced by many factors, including genetic makeup, work habits, age, gender, body weight, physical health, and medication being taken. The dose-response relationship is the basis for measurement of the relative harmfulness of a chemical. 2. HAZARD CLASSES OF TOXICS Toxic hazards include a wide range of categories, or classes of substances that are based on the type of effects produced from acute and chronic exposure. The following are considered hazard classes: • Irritants • Sensitizers • Systemic Poisons • Carcinogens/Mutagens/Teratogens • Asphyxiants a. Irritants Irritants are chemicals that cause a reversible inflammatory effect on living tissue by chemical action at the site of contact, usually following acute exposure to high concentrations of a substance. • Primary Irritants: Primary irritants may cause dermatitis within hours of exposure. Most organic solvents and detergents are considered to be primary irritants. • Strong Irritants: Strong irritants produce observable effects, including ulceration and tissue destruction, within minutes of exposure. Corrosive agents (e.g., acids and bases) are examples of strong irritants. • Respiratory Irritants: Respiratory irritants cause slight to severe irritation of the nose, mouth, throat and lungs. • Lacrimators: Some chemicals irritate the mucous membranes, stimulating lacrimation (excessive watering of the eyes). Examples include acrolein, chlorine, ethyl iodoacetate, and tear gas (benzyl bromide). 13 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g b. Systemic Poisons Systemic poisons are chemical agents that exert their toxic effect on specific organs or organ systems following exposure by any of the four major routes of exposure. These toxic hazards can be grouped in categories based on the organ or organ system targeted or on the effect produced, such as: • Central Nervous System Depressants: These toxic substances cause symptoms such as headache, nausea, impaired coordination, lethargy, and confusion in the short term. Long-term exposure may lead to more pronounced nervous system disorders, such as spasms, tremors, impairment of speech, vision, or memory. Examples include toluene, methanol, and benzene. • Neurotoxins: Neurotoxins affect the nervous system. The symptoms may begin with lethargy, vomiting, irritability, and dizziness, and then progress to ataxia and reduced level of consciousness, which may lead to coma and death. Examples include n-hexane, mercury, lead, chlordane, and DDT. • Hepatotoxins: Hepatotoxins affect the liver. Liver disorders are sometimes marked by jaundice. Examples include carbon tetrachloride, nitro-hydrocarbons, chlordane, and chloroform. • Hemolytic Agents: These agents affect blood and blood components. Symptoms may include fatigue, pale skin, rapid heart rate, nosebleeds, or frequent or prolonged infections. Examples include arsine, benzene, and lead. • Nephrotoxins: Nephrotoxins are toxic agents that inhibit, damage or destroy the cells and/or tissues of the kidneys. Symptoms may include edema, kidney stones, headache, or nausea. Examples include lead, chloroform, mercury and parathion. • Reproductive System Toxins: These affect the male and female reproductive system. Symptoms may include infertility or enlarged reproductive organs. Examples include steroids, cadmium chloride, and alkylating agents. • Convulsants: Cause convulsions and possible coma. Examples include parathion, malathion, and phenol. c. Carcinogens/Mutagens/Teratogens • • Some groupings of physical or chemical agents that may be harmful are carcinogens, mutagens and teratogens. • Carcinogens: A carcinogen is a substance or agent capable of causing or producing cancer in mammals, including humans. A chemical is considered to be a carcinogen if: 1) it has been evaluated by IARC and found to be a carcinogen or possible carcinogen; 2) it is listed as a carcinogen or possible carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program; or 3) it is regulated by OSHA as a carcinogen. Examples include asbestos, kepone, benzene, and coal tar pitch volatiles. Mutagens: A substance or agent capable of altering the genetic material in a cell. The parent is unaffected, but the offspring suffers consequences. Examples include ionizing radiation, sodium azide, and bromine. Teratogens: A teratogen is a substance that causes birth defects in the developing fetus. Examples include thalidomide, ethanol, diethylstilbestrol, and ionizing radiation. d. Asphyxiants Asphyxiants are materials that deprive the body of oxygen. Simple Asphyxiants: Are typically non-toxic gases that may cause injury by inhalation only if present in air in such high concentrations that they reduce oxygen in the air (normally about 21%) to dangerous levels (18% or lower). This may result in headaches, unconsciousness and eventually death. Examples include carbon dioxide, nitrogen, helium, and methane. Chemical Asphyxiants: Are substances that chemically interfere with the body’s ability to take up and transport oxygen. Examples include carbon monoxide, hydrogen sulfide, nitrobenzene, and hydrogen cyanide. 14 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g 3. CHEMICAL HAZARDS -- RECOGNITION The degree of hazard associated with a particular chemical will depend on: its physical properties its toxicity the way it is used the environment in which it is encountered 4. PHYSICAL CLASSIFICATION – SOLIDS AND LIQUIDS Chemicals may be found in solid, liquid, aerosol, gas and vapor forms. The degree of danger varies according to the form of the chemical and the factors previously discussed. a. Solids Not all forms of a chemical pose a health hazard. For example, a lead pipe is not a significant health hazard. However, the lead can become a human health hazard if the pipe is sanded or welded, producing lead dust or fumes. The dust or fumes can become airborne and be inhaled, or lead can leach into water and be ingested. A chemical may be hazardous even in solid form. For example, individuals who are sensitized to nickel may develop dermatitis from skin contact with the metal. Fuming solids emit toxic vapors that may be inhaled. Some materials, such as pesticides, can evaporate directly from solid form. Some solids are not a hazard alone but become hazardous when they come into contact with other chemicals (e.g., acid in contact with iron can release hydrogen gas). b. Liquids Many liquids are hazardous when they come in contact with the skin. They either damage the skin or they are easily absorbed through the skin. It is important to remember that chemicals that can damage or be absorbed through the skin will have this effect on all skin, not just the hands. The degree of hazard associated with a liquid depends on its characteristics and how it is handled. For example, inhalation is the primary route by which chemicals enter the body. A liquid’s vapor pressure is important in determining its degree of hazard. Liquids with a low vapor pressure may create a low airborne concentration. Liquids with a high vapor pressure may produce high airborne concentrations. The hazard level of an airborne concentration depends in part on the chemical’s toxicity. 5. PHYSICAL CLASSIFICATION – GASES, VAPORS, AEROSOLS Chemicals may be found in solid, liquid, aerosol, gas and vapor forms. The degree of danger varies according to the form of the chemical and the factors previously discussed. a. Aerosols Aerosol is a term used to describe fine particles (solid or liquid) suspended in air. Examples of aerosols include dust, fumes, mist, fog, smoke and smog. Knowing how various aerosols are generated will help you anticipate where aerosol hazards may exist in the field. Aerosols may be a hazard to the eyes, skin and respiratory system. 15 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g b. Gases and Vapors A gas is a state of matter in which the molecules are unrestricted by cohesive forces. Vapors are the evaporation products of chemicals that are normally liquid or solid at room temperature. Routes of entry associated with gases and vapors are inhalation, and eye or skin exposure. 6. PHYSICAL AND CHEMICAL CHARACTERISTICS Knowing the physical and chemical characteristics of the chemicals you anticipate finding during a field activity can help you recognize potential hazards and appropriately protect yourself. You can find the details on the physical and chemical characteristics by referring to the chemical’s Material Safety Data Sheet (MSDS). MSDSs must be readily available in areas where hazardous materials are being used. More information about Material Safety Data Sheets is found in the Hazard Communication module. a. Solubility The ability of a given substance (solid, liquid, gas or vapor) to dissolve in a solvent is solubility. An insoluble substance can be physically mixed or blended in a solvent for a short time but is unchanged when it finally separates. The solubility of a substance is independent of its density or specific gravity. Solubility is important when determining health effects, reactivity, dispersion, and methods of cleanup and treatment. Solubility is generally expressed in parts per million (ppm) or as a percentage (0-100%). b. Specific Gravity / Density Specific gravity (SpG) is the ratio of the mass of a unit volume of a substance to the mass of the same volume of a standard substance at a standard temperature. Water is the standard for liquids and dry air is the standard for gases. Numerically, SpG is equal to the density in g/cc, but is expressed as a pure number without units. If the SpG of a substance is greater than 1 (the SpG of water), it will sink in water (e.g., methylene chloride). The substance will float on water if its SpG is less than 1 (e.g., oil/petroleum products). This is important when considering containment, cleanup, disposal, and treatment alternatives. Density of a substance is its mass per unit volume, commonly expressed in grams per cubic centimeter (g/cc). The density of water is usually accepted as 1 g/cc since 1 cc has a mass of 1 g for water at 4ºC. Note: This information only applies to the insoluble portion of the material. c. Vapor Density The density of a gas or vapor can be compared to the density of the ambient atmosphere. Vapor or gas that is greater in density than the ambient air tends to settle in the lowest point. Vapor with density close to the density of air or lower tends to disperse in the atmosphere. In settling, dense vapor (v.d.>1) creates many hazards. If the vapor displaces enough air to reduce the atmospheric concentration of oxygen below 18%, asphyxia may result. If the vapor is toxic, inhalation problems predominate even if the atmosphere is not oxygen deficient. If a substance is explosive and very dense, the fire/explosive hazard may be in the form of vapor trails which can spread far from the liquid. Flashback can occur if an ignition source is present. 16 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g d. Vapor Pressure The pressure exerted by a vapor against the sides of a closed container is called vapor pressure. Vapor pressure is temperature dependent. As temperature increases, so does the vapor pressure. Thus, more liquid evaporates, vaporizes or volatilizes. The lower the boiling point of the liquid, the greater the vapor pressure will be at a given temperature. Values for vapor pressure are most often given as millimeters of mercury (mm Hg) at a specific temperature. Usually the higher the vapor pressure, the more volatile the substance. e. Boiling Point Boiling point is the temperature at which a liquid changes to a vapor, or the temperature at which the vapor pressure of the liquid equals the atmospheric pressure. The opposite change in phase is the condensation point. A major consideration with toxic substances is how they enter the body. With high-boiling-point liquids, the most common entry is by body contact (skin absorption). Low-boiling-point liquids are most commonly inhaled. f. Melting Point Melting point is the temperature at which a solid, when heated, changes to a liquid. This temperature is also the freezing point, the temperature at which a substance will solidify or freeze upon removal of heat. The proper terminology depends on the direction of the phase change. If a substance has been transported at a temperature that maintains a solid phase then a change in temperature may cause the solid to melt. A particular substance may exhibit totally different properties depending on the phase. One phase could be inert while the other is highly reactive. Thus, it is imperative to recognize the possibility of a substance changing phase due to changes in the ambient temperature. g. Flash Point Flashpoint is the lowest temperature at which a liquid gives off enough vapor to form an ignitable mixture with air and produce a flame when an ignition source is present. If the temperature is right, the material may give off enough vapors at its surface to allow ignition by an open flame or spark. When a vapor does ignite, combustion can continue as long as the temperature remains at or above the flashpoint. Remember, only the vapors burn. Solid materials and liquids do not burn. It is only materials convert to vapors that they can burn. In order to burn, vapors must be present. h. Autoignition Temperature The lowest temperature at which a product will ignite from its own heat source or a contacted heated surface without necessity of spark or flame is called the autoignition temperature. This temperature is very high – commonly in the hundreds of degrees. i. Explosive Limits The range of concentration of gases in air that will support the explosive process is bounded by measurable limits called Upper Explosive Limit (UEL) or Upper Flammable Limit (UFL) and Lower Explosive Limit (LEL) or Lower Flammable Limit (LFL). The flammable range is the optimal chemical fuel concentration in air for the ignition and the sustenance of 17 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g combustion. The lowest concentration of fuel in this range is the LEL/LFL. The highest ratio that is flammable is the UEL/UFL. Concentrations less than the LEL/LFL are not flammable because there is too little fuel, that is, the mixture is too “lean” to burn. Concentrations greater than the UEL/UFL are not flammable because there is too much fuel displacing the oxygen (resulting in too little oxygen). The mixture is too “rich” to burn. 7. WARNING PROPERTIES Warning properties, such as those shown below, are examples of characteristics that could alert you to the presence of a chemical in the air: Odor threshold Color of product Other senses (taste and irritation) 8. REDUCING EXPOSURE Once you have a recognized that a hazardous materials emergency exists, you have 3 ways to limit your exposure and the potential for harm. Limit Your Time: Do not stay in the danger area. By reducing the amount of time you are exposed to the chemical, you can lower the chance that you will experience health effects. Increase Your Distance: Move upwind and uphill of the release. By moving further away and in a direction away from the release, you can lower the risk of serious problems occurring. This method is the primary way a person trained at the Awareness Level reduces their exposure. Use Shielding: (physical barriers or protective clothing) If you can, position yourself between the hazard and some sort of shielding. Shielding can be a physical barrier or protective clothing. However, at the Awareness Level, you should be far enough away from the release that you should not need protective equipment. Unit 3: Regulatory Overview of HazMat Training 1. INTRODUCTION In the 1970's and 80's, after events such as the deadly chemical release in Bhopal, India, the federal government saw a need to intervene on behalf of citizens and emergency responders and passed the Superfund Amendments and Reauthorization Act (SARA). This legislation greatly reduced the number of responders killed or injured in response to hazmat incidents. One provision of SARA directed OSHA to develop hazmat worker safety standards and regulations. As a result, Occupational Safety and Health Administration (OSHA) developed 29 Code of Federal Regulations (CFR) 1910.120, the Hazardous Waste and Emergency Response (HAZWOPER) standard. EPA and OSHA promulgated identical health and safety standards to protect workers engaged in hazardous waste operations and emergency response. The OSHA standards, placed at 29 Code of Federal Regulations (CFR) § 1910.120 became effective on March 6, 1990, contain requirements to minimize the health and safety hazards to workers performing emergency response actions. The EPA regulations, developed in June, 1990, incorporate the OSHA standards by reference and are located at 40 CFR Part 311. 18 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Part 311 states ... “The substantive provisions found at 29 CFR 1910.120 apply to State and local government employees engaged in hazardous waste operations, as defined in 29 CFR 1910.120(a), in States that do not have a State plan approved under section 18 of the Occupational Safety and Health Act of 1970.” ... “Employee is defined as a compensated or non-compensated worker who is controlled directly by a State or local government ...” The OSHA worker protection standards and EPA’s corresponding rule for emergency response (HAZWOPER) apply to five groups of workers, including “Emergency Response Operations Without Regard to Location.” 2. LEVELS OF TRAINING Under the HAZWOPER regulation, OSHA requires training for all emergency response personnel, sufficient to meet the person’s expected responsibilities during an emergency. OSHA’s five levels of hazardous materials training are: Awareness Operations Technician Specialist On-Scene Incident Commander a. OSHA 29 CFR 1910.120(q)(6)(i) First Responder Awareness Level Persons at the awareness level may be employed by public-or private sector organizations, such as fire or emergency medical services, law enforcement, emergency management, public works, public health, dispatchers, utilities, and transportation, as well as volunteer agencies and manufacturers, guard and security services, and contractors. Persons at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the authorities of the release. Persons at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas: An understanding of what hazardous substances are, and the risks associated with them in an incident (1910.120(q)(6)(i)(A)) An understanding of the potential outcomes associated with an emergency created when hazardous substances are present (1910.120(q)(6)(i)(B)) The ability to recognize the presence of hazardous substances in an emergency (1910.120(q)(6)(i)(C)) The ability to identify the hazardous substance, if possible (1910.120(q)(6)(i)(D)) An understanding of the individual’s role in the employer’s emergency response plan including site security and control, and the U.S. DOT’s Emergency Response Guidebook (ERG) (1910.120(q)(6)(i)(E)) The ability to realize the need for additional resources, and to make appropriate notifications to the communications center (1910.120(q)(6)(i)(F)) In addition to the 1910.120 standard and 311 regulations, several professional organizations have developed their own standards for competencies at the different levels of training. For example, the National Fire Protection Association (NFPA) has developed “Standard for Professional Competence of Responders to Hazardous Materials Incidents,” known as “NFPA 472.” 19 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g b. Under the NFPA 472: 1) Personnel at the awareness level are persons who, in the normal course of their duties, could be the first on scene of an emergency involving hazardous materials. They are expected to recognize the presence of hazardous materials, protect themselves, call for trained personnel, and secure the area (3.3.25). Persons at the awareness level are not expected to take any action that would require a great deal of training and experience. Rather, their actions will be defensive, and limited. 2) Further, the first responder at the awareness level shall be able to: a) Analyze the incident to determine both the hazardous materials present and the basic hazard and response information for each hazardous material by completing the following tasks: 1. Detect the presence of hazardous materials 2. Survey a hazardous materials incident from a safe location to identify the name, United Nations/North American Hazardous Materials Code (UN/NA) identification number, or type placard applied for any hazardous materials involved 3. Collect hazard information from the current edition of the North American Emergency Response Guidebook (ERG) b) Implement actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of the North American Emergency Response Guidebook by completing the following tasks: 1. Initiate protective actions 2. Initiate the notification process 3) Competencies under the NFPA 472 for the First Responder at the Awareness Level include: 4.2 Competencies — Analyzing the Incident. 4.2.1 Detecting the Presence of Hazardous Materials. 4.2.2 Surveying the Hazardous Materials Incident from a Safe Location. 4.2.3 Collecting Hazard Information. 4.3 Competencies — Planning the Response. (Reserved) 4.4 Competencies — Implementing the Planned Response. 4.4.1 Initiating Protective Actions. 4.4.2 Initiating the Notification Process. 4.5 Competencies — Evaluating Progress. (Reserved) 4.6 Competencies — Terminating the Incident. (Reserved) To review a complete copy of NFPA 472, “Professional Competence of Responders to Hazardous Materials,” go to: www.nfpa.com For more information on OSHA regulations and programs concerning emergency response training, go to: http://www.osha.gov/SLTC/emergencypreparedness/responder.html Response personnel should check with their respective professional organization, or State Training Officer, for other relevant standards pertaining to hazardous materials training and competencies. In Region 6: Arkansas Department of Emergency Management Camp Robinson, North Little Rock, AR 72199 (501) 683-6752 www.adem.arkansas.gov Louisiana Governor’s Office of Homeland Security and Emergency Preparedness 7667 Independence Blvd, Baton Rouge, LA 70806 (225) 925-7500 www.gohsep.la.gov 20 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g New Mexico Department of Public Safety / Emergency Management P.O. Box 27111, Santa Fe, NM 87502 (505) 476-9600 Oklahoma Department of Emergency Management P.O. Box 53365, Oklahoma City, OK 73152 (405) 521-2481 Texas Division of Emergency Management / DPS P.O. Box 4087, Austin, TX 78773 (512) 424-2195 http://www.nmdhsem.org/ http://www.ok.gov/OEM/ www.txdps.state.tx.us/dem Unit 4: Identification of Hazardous Materials 1. INTRODUCTION Hazardous materials are not only widely used, but many are hard to detect. Learn how to spot clues that can be used to detect the presence of hazardous materials. Agencies such as OSHA, EPA, NFPA, and DOT have developed regulations and guidelines for placarding and labeling hazardous materials located in fixed facilities and during transportation. However, you will not be able to solely rely on these placards and labels. Recognize clues that use your senses of sight, hearing and smell that indicate the presence of hazardous materials. However, using your senses can be extremely hazardous to your health and even deadly. Informational tools such as the ERG, MSDSs, and shipping papers will be essential for your quickly identifying a hazardous materials incident. Routine Hazardous Materials Incident ?? As an emergency responder, you need to use great caution when approaching a potential or known hazardous materials incident. Very little is known about the long-lasting health effects of the vast majority of chemicals in use. There is no such thing as the “routine” hazardous materials incident. Regardless of how harmless an incident looks; whether you know the chemical, or it appears to be a small amount, a hazardous material is marked “hazardous” for a reason. For example, consider the number of people who never expected to be injured or killed when improperly using small amounts of gasoline. Treat each incident as your first, approach it cautiously, plan carefully, and always keep safety as the primary focus. Finally, some common chemicals will react with one another when they are mixed. In addition, certain substances can be more dangerous depending on their form. For example, when powdered non-dairy coffee creamer is ignited, it can burn with explosive force. When ammonia and bleach are mixed, they form a toxic gas that can severely injure responders. Finally, smoke from rubber backed carpeting can produce deadly vapors such as hydrochloric gas. Therefore, safety “vigilance and discipline” must be maintained, even if the scene seems to present little or no risk. 2. GENERAL CLUES The safe handling of a hazardous materials incident begins long before your arrival. Detecting the presence of hazardous materials is the first step in having a successful outcome. For example, common sense will tell you if you approach a gas station, there is a hazardous material present. 21 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g What happens, however, when you roll up on a scene and find a black glass building with a large parking lot? Can you be certain that hazardous materials are not present? Too often emergency responders will assume that if the presence of hazardous materials is not outwardly apparent they are not present. Unfortunately, many of those same emergency responders are injured, disabled or killed. If you are responding to the scene of a hazardous materials incident, use the outward signs that may suggest the presence of hazardous materials. a. Collapsed Victims If you see persons who are collapsed, vomiting, have severely watering eyes, uncontrollable coughing or other signs of respiratory distress in or around the hazardous area, it could be indicative of exposure to hazardous materials. b. People Running from the Scene People running from the scene of an incident almost always raise a red flag, especially to law enforcement personnel. However, this may be an indicator of a hazardous materials spill and should alert you to approach the scene with caution. c. Flames or Smoke Smoke is a mixture of hot gases, carbon, and particulate materials. As stated above, a fire can alter the chemical composition of a material. Therefore, if smoke or fire is observed, the potential for exposure to emergency responders is greatly increased. d. Rising Sound from a Venting Safety Device As the pressure builds in a container, materials can be forced out of the container or the container can fail. A loud roar or high pitch from a container’s safety device is an indicator of increasing pressure. This should alert you and increase your caution. e. Hissing Sound Leaking vapors may cause a hissing sound, much like air escaping a tire. This should alert you that the dangers presented by leaking vapors might be present. f. Dead Birds, Fish, Animals, and Insects Birds falling out of the sky, fish kills, and the absence of insects are often indicative of a hazardous materials spill. g. Other Clues Although most hazardous materials incidents are unintentional and accidental, there is an increasing frequency of chemical, biological, ordinance and radiological – Chemical Ordinance, Biological, and Radiological (COBRA) terrorism and clandestine drug manufacturing facilities. Each of these pose serious threats to emergency responders. 22 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g In some instances, there are explosive (ordinance) devices and other Weapons of Mass Destruction (WMD) placed to injure or kill responders and the general public. However, there are clues that can alert you to their presence. Unusual security locks, bars on the windows, covered windows, barbed wire, and surveillance equipment that appears inappropriate for the surroundings, can be warning signs. Approach the scene with extreme caution. Be alert of the possibility of secondary devices. These devices are detonated or released after an initial detonation or the release is intended to injure a specific target(s), often emergency responders. Also, keep in mind the potential targets of a terrorist. Public areas with high traffic or volume, such as convention centers, churches, theaters, stadiums, are targets for a would-be terrorist. Mass transit systems, such as a bus depot or the buses themselves, and places with high economic impact are also targets. Government buildings, such as the federal courthouses, are probable targets for a terrorist attack. Telecommunications centers also should be considered potential targets of a terrorist. Hazardous materials and laboratory equipment that are not appropriate for the occupancy are also indicators of the presence of hazardous materials. Unexplained vapor clouds, mists, and plumes may indicate a release of a gaseous substance. Unusual tastes and odors may also indicate a hazardous materials release. Throughout the nation, there is a substantial number of clandestine methamphetamine manufacturing facilities, often referred to as “meth labs.” These labs can be found in urban, rural and inner city areas, in fixed facilities and in car trunks. They use a dangerous mix of chemicals with improvised formulas that create extremely toxic gases. The persons surrounding a hazardous materials release area can also provide clues that may help your response efforts. If you encounter persons who have a sudden onset of multiple illnesses; unexplained signs of skin, eye, and / or airway irritation; or twitching, tightness in the chest, sweating, pinpoint pupils, runny nose, and / or vomiting may indicate exposure to a hazardous material. Although initial responders may not see these signs, they may be helpful to law enforcement personnel who are gathering intelligence on a particular site. h. Using Your Senses Throughout the previous section, you have learned of ways to use your senses to detect the presence of hazardous materials. However, using your senses to detect the presence of hazardous materials is a dangerous, potentially deadly method of detection. Using the clues mentioned above are helpful, however, by the time you are close enough to hear or see these clues, you may already be in an area considered to be “Immediately Dangerous to Life and Health (IDLH).” This designation means there is a concentration that is high enough to cause significant damage to your health. Although using your senses can be helpful, it can also be dangerous. How often have you heard the story of the old leather lung fire chief, the crusty police sergeant, or the wetbehind-the-ears rookie that walks up to spill, touches the substance and then smells it or tastes it? This method of detecting hazardous materials is not only foolish ... it can have deadly consequences. The use of taste, smell and touch are not accurate or effective methods of identifying a substance. They will result in exposure to the substance. Remember the routes of exposure mentioned earlier in this text. They are ingestion, inhalation, injection, and absorption through skin or eye contact. Look at these closely; ingestion is accomplished through tasting a substance. 23 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Absorption is as easy as touching a substance and inhalation is as easy as smelling. The bottom line is that your safety and the safety of your team are of the utmost importance. Do not approach, taste, smell, or touch any substance, known or unknown, without wearing the proper personal protective equipment (PPE) and level of training. In addition, certain materials can cause damage to your sight. Chlorine can burn the eyes and burning magnesium can burn the retinas of the eyes. When trained to the awareness level, approaching or sampling a substance goes well beyond your scope of training. i. Location and Occupancy The location of an incident may provide clues as to the possible presence of hazardous materials. For example, if you respond to an incident at a water treatment plant, and see a greenish-yellow cloud rising from the facility, you would expect that hazardous materials would be involved more than if you saw one rising over a fast-food restaurant. Likewise, if you made a response in the mid-summer to a man reported down in a field beside an ammonia nurse tank, you might suspect that farm chemicals are involved. Occupancy also plays an important part in determining the presence of hazardous materials. Commercial laboratories, lawn and garden centers, manufacturing facilities, rail yards, storage sheds, disposal sites, etc., can have hazardous materials present. Another source probably not considered to house hazardous materials are large stores, such as a wholesale warehouse or consumer club store, and other consumer goods retailers. These stores often have pool chemicals, automotive supplies, and sometimes propane gas cylinders. As you can imagine, these stores can pose serious threats to emergency responders during a fire or hazardous materials release. Pre-planning and routine inspections can provide information about the location of hazardous materials throughout the community. As you approach a scene take notice of whether the occupancy is a confined space, or the location is below grade. These factors can affect the concentration of toxic vapors and breathable air. Unfortunately, there are exceptions to the rule. Clandestine drug labs are meant to be disguised. These labs may be in abandoned houses, basements, apartments, and numerous other spaces, including car trunks and trailers. In addition, the persons who operate these labs may place devices meant to injure or kill anyone who may not be welcome. Therefore, if you respond to a suspected lab, be alert for trip wires, bombs, things hanging from trees, and other items that may seem inappropriate. Except for these labs, the occupancy and location is a reliable clue to identify the presence of hazardous materials. It may be helpful to ask yourself as you approach a scene, “what is the likelihood that hazardous materials are being manufactured, used, transported into, or disposed of at this site?” 3. CONTAINER SHAPES Once you arrive at the scene, another valuable clue is the container shape. Your experience tells you that there are containers of all shapes and sizes that hold hazardous materials. Sitting by the railroad tracks watching a train pass or on a highway watching traffic go by provides a simple reminder of the variety of containers that carry hazardous materials. In addition, think about all of the smaller containers that you have come across that hold hazardous materials. From syringes to the million gallon oil tanks, there are many different sizes of containers for hazardous materials. Your ability to recognize and identify these packaging types should alert you to the likely presence of hazardous materials. In addition, the specific shape of a container may also provide clues to the dangers the contents of the container may present. 24 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g For example, containers with rounded ends and made from heavy gauge metal usually contain contents under high pressure. Containers with flat ends usually indicate low pressure or non-pressurized containers. a. Bulk Packaging There are basically two types of bulk packaging: that which is an integral part of the transport vehicle, and that which is placed inside or on a transport vehicle. These include railroad freight cars, such as hopper cars, boxcars and tank cars, as well as tank trucks and semitrailers. Packages that are placed in or on a transport vehicle include ton containers, intermodal tanks (See Appendix C), palletized non-bulk packages, and protective overpacks for radioactive materials called “casks.” b. Non-Bulk Packaging Non-bulk packaging also comes in two basic types: single packaging and combination packaging. Examples of single packaging would be pails, barrels, drums, carboys (see Appendix C), and cylinders. An example of combination packaging is fiberboard boxes containing multiple sacks or jars. Determining the presence of hazardous materials in non-bulk packaging is more difficult. Most vehicles that transport these types of packages are not placarded to alert first responders of the presence of hazardous materials. These vehicles are also enclosed, requiring the vehicles to be opened to determine the presence of the hazardous materials. The exception to this is a flatbed truck. Another difficulty in determining the presence of hazardous materials in non-bulk packaging is that these materials are often not placarded or labeled because they are shipped just below the threshold quantity. An example of this may be small parcel shipping service that may deliver 100 pounds of sulfuric acid. This is below the placarding and labeling thresholds; however, the threat of the acid is still present. The best policy is to proceed as though hazardous materials are present. A significant problem facing emergency responders is that hazardous materials in small container shipments can be found everywhere. Again, be alert for mobile drug labs in vehicles and the potential for farm chemical spills. ASSUME HAZARDOUS MATERIALS ARE ALWAYS PRESENT IN VEHICULAR OR TRUCK ACCIDENTS. 4. MARKINGS AND COLORS Markings and colors are important clues for detection of hazardous materials. However, they may not be present, especially if they have been burned or scraped off of the container. Business names, proper shipping names, and marking systems can provide you with a great amount of information from a safe distance. a. Placards and Labels Placards and labels are designed to alert you to presence of hazardous materials in transportation. Placards are used on bulk containers, such as trucks or rail cars. Labels are found on small packages, up to 640 cubic feet in size. Both placards and labels use the same system to warn you about hazards. The DOT developed this system to provide emergency responders with information about the hazards that may be present during an incident. Each placard or label has 4 codes that indicate the primary hazard for that material, as determined by the DOT. On each placard or label you will find a color code, a word code, a symbol code, and a number code. 25 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g b. Business Names “Markings” refer to the name of the businesses known to deal with chemicals such as large chemical manufacturers, refineries, and chemical distributors. These markings can be observed on the outside of transport vehicles, buildings, and even single containers from great distances by using binoculars. In many cases the Department of Transportation requires certain markings on containers that can identify, or at least help identify the specific hazardous materials being shipped. c. Proper Shipping Names The “proper shipping name” is the chemical or common name that the US Department of Transportation has authorized for a hazardous material. The proper shipping name must be listed on shipping papers and may be listed on the container. It is also the name referred to by the UN/NA number. It is important to understand that the shipper selects the proper shipping name that is used on the container and shipping papers. Many times the shipper will use a generic name such as “Flammable Liquid” with the initials “n.o.s.,” not otherwise specified. In such cases you will likely find the technical name on shipping papers after the annotation n.o.s. You may find the common or shipping name stenciled on the side of the container. This is a common practice for containers that are dedicated to carrying that particular material. If this is the case then your job has been made easier. However, this is the exception not the rule. Most often, you will find that the proper hazard class name has been used to satisfy the proper shipping name requirement. d. UN/NA Numbers United Nations/North American identification numbers are four digit numbers assigned to hazardous materials/dangerous substances. The numbers are used in Mexico, Canada, the United States, and in many of the United Nation member countries. Therefore, many foreign shipments will use this numerical system of identifying hazardous materials. These numbers can be found on shipping papers, material safety data sheets (MSDS) and on placards. They serve as quick identification of the substance, provided that the container is labeled correctly. Also, these four-digit numbers are numerically indexed in the yellow-bordered section of the Emergency Response Guidebook (ERG). e. Other Markings For certain chemicals shipped by rail, the US Department of Transportation requires that the proper shipping name be stenciled on the side of the railcar. For example, railcars shipping anhydrous ammonia, ammonia solutions with more than 50% ammonia and Division 2.1 and 2.3 materials require this marking. Again, these cars are dedicated to transporting this material as long as the name is stenciled on the car. Every container that is in service has numbers stenciled or stamped in certain areas on the container. These numbers mean simply that the container has been constructed to certain specifications to transport the specific hazard class. Containers may also have exemption numbers to signify the US DOT’s approval that allows the transport of certain hazardous materials in non-specific containers. An emergency response network, such as the Chemical Transportation Emergency Center (CHEMTREC) may use these numbers to help identify the materials involved. 26 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g 5. NFPA 704 SYSTEM If you are a fire fighter, you are aware of the NFPA, National Fire Protection Association. The NFPA develops standards and guidelines for use by fire departments across the nation, including standard 704. NFPA 704 is a marking system developed for use at fixed facilities. This system provides you with an immediate assessment of the relative hazards of dangerous chemicals at a fixed facility that stores, manufactures, or uses hazardous chemicals. This standard provides you with information concerning the health, flammability, reactivity, and other related hazards created by short-term exposure that might occur under conditions such as fire or other related emergency conditions. As mentioned above, the system identifies the hazards of three principal areas; “health,” “flammability,” and “reactivity” or the instability of a material. The system indicates the degree of severity numerically by five divisions ranging from “zero (0),” indicating no special hazard to “four (4),” which indicates a severe hazard. There are two ways each category is marked, by position and by background color. Health is always on the left and is blue. Flammability is on top and is red. Reactivity is on the right and is yellow. The fourth space located on the bottom of the diagram is used for special hazards such as water reactivity, radioactivity, corrosivity, or special protective equipment required in case of a fire or emergency. How the system provides you information is based in terms of the hazards for each of the three areas. For example, a material which is very hazardous as a health threat, such as chlorine, would receive a 3 or 4 in the blue box, denoting an extreme health hazard. The flammability of a material is classified based on its flash point. Thus: Materials that do not burn would have a 0 in the red box, indicating no flammability issue. Materials with a flash point over 200F would have 1 in the red box. Materials with a flash point between 100F and 200F would have 2 in the red box. Materials with a flash point below 100F and a boiling point above 100F would have a 3. Materials with a flash point below 100F and a boiling point below 100F would have a 4 in the red box. The reactivity or stability classification is denoted in the yellow box. Stable materials are those which normally would not react with other materials or water. Unstable materials will produce heat and/or energy when mixed with other materials. Stable materials would be denoted with a 0. Very unstable materials would have a 4 in the box. It is important to remember that the NFPA 704 system is normally used on fixed facilities and its use is voluntary, unless required by State law or local codes. 6. HAZARD CLASSIFICATION SYSTEM During transportation of hazardous materials, the rules are very different. The US Department of Transportation, Transport Canada, and the Mexican Secretariat of Transport and Communications mandate the use of the hazard classification system in transportation. You have already learned about the nine categories of hazardous materials. If you see one of these placards or labels on a container or vehicle, you should consider it an indicator of the presence of hazardous materials. a. Standard Transportation Commodity Code (STCC) The railroad industry uses a seven-digit code called a Hazmat code to identify hazardous materials. The code known as a Standard Transportation Commodity Code, or STCC (pronounced “stick”) code, is assigned to several hazardous commodities. STCC codes are still used for other commodities. 27 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g The Hazmat code is organized and coded to convey information about the primary hazard of a commodity and also about many potential additional hazards. Each set of numbers assigned to a commodity represents specific information about the commodity. However, you need to know that Hazmat codes or STCC codes that begin with 48 or 49 indicate that this is a hazardous material. b. Biomedical Hazard Symbol This symbol, which is also the symbol for the Centers for Disease Control, is frequently used to mark the shipments of biotoxins such as yellow fever, tetanus and polio, as well as containers of medical waste such as blood-soaked gauze or significant quantities of bodily fluids, or even tissues such as organs intended for transplant. Recognizing this marking or symbol on a container or building should warn you of the presence of hazardous materials. c. Pipeline Markings There are very few counties in Region 6 that do not have pipelines. Therefore, you need to be aware of the different markings associated with pipelines that you may encounter. Warning markings are probably the most common, since they are required by the U.S. Department of Transportation. They are round signs with a yellow background. The sign states “Warning,” in black letters on a red background. Below this on a black background in yellow letters is a description of the pipeline, the pipeline company name, city, state, and the phone number. This information is uniform for all pipeline companies. You may also see “Call before you dig” signs or “Toll free numbers” markings on a post with the telephone number of the company. d. Emergency Response Guidebook (ERG) As a first responder to hazardous materials incidents, one of the best tools you will ever use is the Emergency Response Guidebook, commonly known as the ERG. This small orange book can be found on nearly every piece of fire apparatus, in most police cars, in many public works vehicles, and in every emergency management office throughout the state. The initial phase is defined as the period following the arrival at the scene during which the presence and/or identification of a hazardous material is confirmed, protective actions and area securement are initiated, and assistance of qualified personnel is requested, in other words, about the first 30 minutes of an incident. This book is not meant to replace training nor is this book meant to be a replacement for technical reference materials. The book provides general information that may be useful to the first responder. Refer to Unit 4: EMERGENCY RESPONSE GUIDE BOOK for more information. e. Shipping Papers Inside the front cover of the ERG is a generic diagram of shipping papers. These documents can provide information to the first responder that will assist in determining the vital information of the materials involved. The locations of shipping papers will vary depending on the mode of transportation involved. For trucks, the shipping paper, or “Bill of Lading” is located in the cab of the truck, usually in the driver side pouch if the truck is occupied, or on the driver’s seat if the truck is unoccupied. For trains, the “CONSIST” or “waybill” is located in the locomotive or on with a member of the train crew. 28 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g On a ship or barge, the “Dangerous Cargo Manifest” is located in the wheelhouse, or in the case of barges, in a small mailbox on the barge. In airplanes, the “Airbill” is in the cockpit with the pilot. Vehicle Truck Train Barge or Ship Airplane Where Kept Cab Engine Car Wheelhouse Cockpit Name Bill of Lading Waybills, Consists, Wheel Reports Dangerous Cargo Manifest Air Bill Person Driver Conductor Captain, Master Pilot In a hazardous materials emergency, if you can safely find the shipping papers and who may have them with them, you can help the response organizations better understand the hazards they are facing. f. Material Safety Data Sheets (MSDS) Employers are required to maintain any Material Safety Data Sheet, commonly known as an MSDS, by OSHA 29 CFR 1910.1200. This regulation, known as Hazard Communication (HAZCOM) standard, mandates that workers who deal with a hazardous material be given information describing the dangers of the material. This transmission of information is through labels, placards, MSDS, and other forms of warning. This program has an added benefit to first responders by providing them with the vital information of the materials on the site. As mentioned above, MSDSs provide useful information to responders at a hazardous materials incident. At minimum, MSDSs will have the following information: The identity used on the label, except for trade secrets. The chemical and common names of the material or all of the ingredients which comprise 1% or more, or .1% of a chemical known to be a carcinogen. Physical and chemical characteristics, such as vapor pressure and flash point. The physical hazards of the hazardous chemical, including the potential for fire, explosion, and reactivity. The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical. The primary routes of entry. The date of preparation or the date of the last change to the MSDS. The name, address and telephone number of the chemical manufacturer or responsible party preparing or distributing the MSDS. The OSHA permissible exposure limit (PEL), ACGIH Threshold Limit Value (TLV) and other exposure limits used or recommended by the chemical manufacturer. Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens or has been found to be a potential carcinogen. Any generally applicable precautions for safe handling and use that are known. This includes appropriate hygienic practices; protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks. Emergency first aid procedures. In addition, there is a listing of who can provide additional information on the hazardous chemical and appropriate emergency procedures. More descriptive illustrations and details on container identifications are contained in Appendix B. 29 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g 7. GLOBALLY HARMONIZED SYSTEM (GHS) OSHA has revised its Hazard Communication Standard (HCS), aligning it with the United Nations’ Globally Harmonized System (GHS) of chemical classification and labeling. This GHS alignment is an international method of hazard communication, and it standardizing the criteria for classification of chemical hazards, as well as labels and MSDS, across international boundaries. The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations, and stakeholder groups. It is based on major existing systems around the world, including OSHA's Hazard Communication Standard and the chemical classification and labeling systems of other US agencies. a. Why Change Now? The original OSHA HAZCOM standard allowed chemical manufacturers and importers to convey information on labels and material safety data sheets in whatever format they choose. OSHA feels that adopting the GHS format will: Improve the quality and consistency of hazard information in the workplace Improve/standardize chemical information received from other countries Reduce trade barriers Increase productivity for American businesses who use the HAZCOM standard. This means that labeling on chemicals which cross international borders will have a harmonious, consistent labeling system across the globe. b. What’s Really Changing? Major changes to the Hazard Communication Standard Include: Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures. Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. MSDS Changing to SDS – What we all have been calling Material Safety Data Sheets (MSDS’s), have been renamed Safety Data Sheets (SDS’s). These SDS will now have a specified and uniform 16-section format. Information and training: Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding. Changes on MSDS SDS The information contained in the SDS is largely the same as the MSDS, except now the SDSs are required to be presented in a consistent user-friendly, 16-section format. • Section 1, Identification o Includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use. • Section 2, Hazard(s) identification o Includes all hazards regarding the chemical; required label elements. • Section 3, Composition/information on ingredients o Includes information on chemical ingredients; trade secret claims. • Section 4, First-aid measures 30 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g • • • • • • • • • • • • o Includes important symptoms/ effects, acute, delayed; required treatment. Section 5, Fire-fighting measures o Lists suitable extinguishing techniques, equipment; chemical hazards from fire. Section 6, Accidental release measures o Lists emergency procedures; PPE; proper methods of containment and cleanup. Section 7, Handling and storage o Lists precautions for safe handling and storage, including incompatibilities. Section 8, Exposure controls/personal protection o Lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE). Section 9, Physical and chemical properties o Lists the chemical’s characteristics. Section 10, Stability and reactivity o Lists chemical stability and possibility of hazardous reactions. Section 11, Toxicological information o Includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity. Section 12, Ecological information o Optional under HazCom 2012. o Includes ecotoxicity; persistence/degradability; bioaccumulation potential; mobility in soil. Section 13, Disposal considerations o Optional under HazCom 2012. o Description of wastes and information on their safe handling and methods of disposal. Section 14, Transport information o Optional under HazCom 2012. o Hazardous Materials or Dangerous Goods shipping information according to 49CFR, IATA, etc. Section 15, Regulatory information o Optional under HazCom 2012. o Safety, health and environmental regulations specific to the product. Section 16, Other information c. Changes in Labels The original standard allowed label preparers to convey hazard information in a variety of ways. Under the new GHS standard, each label must contain six specific elements, so that the information conveyed is consistent. The six required elements of a label are: Product Identifier Manufacturer Information Signal Word Pictogram Hazard Statements Precautionary Statements d. GHS, the NFPA Fire Diamond, and HMIS Labels The OSHA GHS standard does not dis-allow the use of NFPA or HMIS labels. However, it does not allow the NFPA or HMIS labels to substitute for the standardized GHS label elements such as pictograms and signal words. A summary offered by MSDSonline explains “When it comes to NFPA/HMIS vs. GHS, it’s important to note that there is 31 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g one key difference in the way each ranks hazard severity. For GHS labels, the greater the severity, the lower the hazard number; whereas with NFPA/HMIS labels, the greater the severity, the higher the hazard number.” When it comes down to it, OSHA is the regulatory body with jurisdiction over hazard communication, and determines the laws of the HazCom standard. NFPA and HMIS are valuable, but voluntary compliance systems, which may or may not make adjustments to their systems once OSHA publishes their final rule. e. What Does This Mean for Communities? The new GHS system means that labels and Safety Data Sheets will begin conveying more consistent information, but it is a new system to learn. LEPCs, local first responders, and reporting facilities within the community will all need to understand the new GHS system, before they can maximize the system’s effectiveness. Responders On-Scene should know how to recognize GHS standard labels, and know how they are different from the NFPA fire diamond Tier II Reporting will begin utilizing SDS sheet Transport labels will remain the same, according to USDOT regulations. However, individual containers such as drums and totes will begin sporting the new GHS labels. f. When Is All This Happening?? All hazardous materials shipped after June 1st, 2015 must be labeled according to the new standard. However, manufacturers, importers, and distributors may start using the new labeling system in the revised HCS as soon as they like. So you community may already be seeing these new labels and SDSs very soon. Unit 5: Using the Emergency Response Guidebook 1. INTRODUCTION The 2012 Emergency Response Guidebook (ERG2012) was developed jointly by Transport Canada (TC), the U.S. Department of Transportation (DOT) and the Secretariat of Transport and Communications of Mexico (SCT) for use by fire fighters, police, and other emergency services personnel who may be the first to arrive at the scene of a transportation incident involving dangerous goods. It is primarily a guide to aid first responders in quickly identifying the specific or generic hazards of the material(s) involved in the incident, and protecting themselves and the general public during the initial response phase of the incident. The next several areas deal with the ERG2012 and its use. It helps to have the book out and follow along with the examples for better understanding. The key areas of the book are: 32 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g White Pages: Provides instructions on how to use the ERG2012, Guidebook Contents, Safety Precautions, Who to Call for Assistance, Table of Placards, Rail Car and Road Trailer Identification Charts, Intermodal Markings, Background Information, Definitions of Protective Actions and Protective Clothing, Fire and Spill Control, Chemical/Biological Agents, and a Glossary. Yellow Pages: Lists dangerous goods in numerical order of ID number. This section quickly identifies the three-digit emergency response guide, if a polymerization hazard (“P”) exists with the dangerous good, and the material’s name. Orange Pages: Comprises a total of 62 individual guides, presented in a two-page format. Each guide provides safety recommendations and emergency response information to protect yourself and the public. Each guide is designed to cover a group of materials which possess similar chemical and toxicological characteristics. Blue Pages: Lists dangerous goods in alphabetical order of material name. This section quickly identifies the three-digit emergency response guide, if a polymerization hazard (“P”) exists with the dangerous good, and the material’s four-digit ID number. Green Pages: Contains a table, which lists, by four-digit ID number, Toxic Inhalation Hazard (TIH) materials, including chemical warfare agents, and water-reactive materials, which produce toxic gases upon contact with water. The table provides two different types of recommended safe distances which are “Initial isolation distances” and “Protective action distances.” 2. DETERMINING THE APPROPRIATE GUIDE PAGE The goal of using the ERG2012 is to get guidance for the incident. Guidance is found in the orange or “guide” pages, so the first step is to determine which guide page to use. There are three primary methods to get to the appropriate guide page. Four-digit ID number in the yellow pages (numerical index) Name of the material in the blue pages (alphabetical index) Associated Placard from the Table of Placards If the information in the three primary methods cannot be located, there are two alternative methods to locate the appropriate guide page in the ERG2012. Guide 111 for mixed load/unidentified cargo. As a last resort, consult the Table of Rail Car and Road Trailer Identification Chart. Let’s looks at the primary methods. 1. A four-digit ID number can be obtained from a placard, an orange panel, a shipping document, or off a container. Look up the ID number in the yellow pages, and find the three-digit guide number in bold print to the right. Notice if a “P” follows the guide page number indicating a polymerization hazard exists. The name of the material is listed in the next column. 33 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g In this example, the four-digit ID number (1203) leads you to guide page 128, and the material may be Gasohol, Gasoline, Motor Spirit, or Petrol. 2. If you have the name of the material, use the blue pages and look it up in the alphabetical listing. “Cyanogen” looked up in this manner should lead you to guide 119. Notice if a “P” follows the guide page number indicating a polymerization hazard exists for this material. “Magnesium” takes you to guide 138 and its ID number is 1869. Always make sure of the material’s correct spelling and the similar materials in the group. When you looked up the ID number 1203, all entries fell under one guide page. However, when looking up the word “Cyanogen”, you see that there are 5 different entries that lead to 3 different guide pages. Is the material just “Cyanogen”, or is it “Cyanogen Bromide”? Make sure of the complete name and spelling. 3. The third way to determine the appropriate guide page is by using the Table of Placards on pages 16-17. If you are using this, you are working with limited information and should consult more specific guidance when information is available (i.e. you obtain the shipping papers). If you see this placard, use the Table of Placards to determine the correct guide page. The book sends you to guide 127. To emphasize the need to obtain more specific information, look up the word “Combustible” in the blue pages. You will find an entry “Combustible liquid, n.o.s.” The “n.o.s.” stands for “not otherwise specified”; meaning the material is not specifically listed in the Code of Federal Regulations. Therefore, the generic name of “Combustible liquid, n.o.s.” is used when shipped. You will also see that it sends you to guide 128, not guide 127. Reading through the guidance provides little differences in this example, but you get the idea. You should strive to obtain the ID number or the name of the specific material, through the shipping papers or by phone with CHEMTREC or the shipper/manufacturer. If we cannot find the ID number, name, or placard for a material, we have two secondary methods that can lead us to the guide pages. 4. If a reference to a guide cannot be found and the incident is believed to involve hazardous materials/dangerous goods, turn to Guide 111, and use it UNTIL additional information becomes available. If the shipping documents are not available, or no emergency response telephone number is listed, immediately call the appropriate emergency response agency listed on the inside back cover of the ERG2012. Provide as much information as possible, such as the name of the carrier (trucking company or railroad) and vehicle number. Remember, the guide is temporary and it is vital to obtain more specific information about what dangerous goods are involved. As a last resort, the ERG2012 contains a Table of Rail Car and Road Trailer ID Charts (pages 8-9). The chart applies only to the rail and the highway modes of transportation. The recommended guides given by the charts should be considered as a last resort if the product cannot be identified by any other means. Personnel must be aware that rail tank cars vary widely in construction, fittings, and purpose. Tank cars could transport products that may be solids, liquids, or gases. The products may be under pressure. It is essential that products are identified by consulting shipping documents, such as the train consist, or the information stenciled on the sides or ends of tank cars. Just the same as rail cars, personnel must be aware that there are many variations of road trailers that are used for shipping chemical 34 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g products. The chart depicts the most general shapes of road trailers. The suggested guides for these trailers are for the most hazardous products that may be transported in these trailer types. Again, it is essential that products be identified by consulting shipping documents, such as the trailer’s freight bill/bill of lading, or the information found on the sides or ends of trailer. Once again, this is a last resort. Hazards On Each Page: In the orange guide pages, there are two general types of Potential Hazards to be found in each Guide: Fire and Explosion hazards Health hazards Turn to guide 126 and you will see under “Fire or Explosion”: Some may burn, but none ignite readily Containers may explode when heated Ruptured cylinders may rocket “Health” hazards listed are: Vapors may cause dizziness or asphyxiation without warning. Vapors from liquefied gas are initially heavier than air and spread along ground Contact with gas or liquefied gas may cause burns, severe injury and/or frostbite. Fire may produce irritating, corrosive and/or toxic gases. The properties of the material that are considered more hazardous are listed first; in this case “Fire or Explosion”. If you look at 125 on the previous page, this material’s “Health” hazards are more dangerous than the “Fire or Explosion” hazards. Response Information: The response information in the guide pages vital to a successful response is: Emergency Response (fire, spill or leak, and first aid) Protective Clothing necessary Evacuation Protective clothing is found on under the Public Safety Section of the guide, and makes reference to four types. Positive Pressure Self-Contained Breathing Apparatus (SCBA) Chemical Protective Clothing and Equipment Street Clothing and Work Uniforms Structural Fire Fighters’ Protective Clothing To gain a better understanding of the protective clothing, look at page 362 of the book. Each type is explained in detail. As an Awareness level responder, remember that you may only have the first type (street clothing) available. Emergency Response is on the second page of each guide. Look at guide 140. If you had a large fire, take the appropriate action from the list. 35 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Depending on the incident, one or more of these actions should help to stabilize the situation. There’s also information for spills or leaks and first aid measures. Initial isolation and protective action distances are found under the “Public Safety” Section. The first two entries on these are almost always the same: “CALL the Emergency Response Telephone Number on the Shipping Paper first. If the Shipping Paper is not available, or no answer, refer to the appropriate telephone number listed on the inside back cover.” “Isolate the spill or leak area immediately for at least XX meters (XX feet) in all directions.” 3. DEFINITIONS OF PROTECTIVE ACTIONS The protective actions listed in the ERG2012 include Isolate the Hazard Area and deny entry, evacuate, and Shelter-in-place protection. Isolate the hazard area and deny entry means keep everybody away from the area if they are not directly involved in emergency response operations. Unprotected emergency responders should not be allowed to enter the isolation zone. The “isolation” task is done first to establish control over the area of operations. This is the first step for any protective actions that may follow. Evacuate means move all people from a threatened area to a safer place. To perform an evacuation, there must be enough time for people to be warned, to get ready, and to leave an area. If there is enough time, evacuation is the best protective action. Begin evacuating people nearby and those outdoors in direct view of the scene. When additional help arrives, expand the area to be evacuated downwind and crosswind to at least the extent recommended in the ERG2012 Even after people move to the distances recommended, they may not be completely safe from harm. They should not be permitted to congregate at such distances. Send evacuees to a definite place, by a specific route, far enough away so they will not have to be moved again if the wind shifts. Shelter In-Place means people should seek shelter inside a building and remain inside until the danger passes. Sheltering in-place is used when evacuating the public would cause greater risk than staying where they are, or when an evacuation cannot be performed. Direct the people inside to close all doors and windows and to shut off all ventilating, heating, and cooling systems. Shelter-in-place protection may not be the best option if (a) the vapors are flammable; (b) if it will take a long time for the gas to clear the area; or (c) if buildings cannot be closed tightly. Vehicles can offer some protection for a short period if the windows are closed and the ventilating systems are shut off. Vehicles are not as effective as buildings for shelter-in-place protection. It is vital to maintain communications with competent persons inside the building so that they are advised about changing conditions. Person’s protected-in-place should be warned to stay far from windows because of the danger from glass and projected metal fragments in a fire and/or explosion. Every dangerous goods incident is different. Each will have special problems and concerns. Action to protect the public must be selected carefully. Officials must continue to gather information and monitor the situation until the threat is removed. 36 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g UNIT 6: PUTTING IT ALL TOGETHER 1. INTRODUCTION To effectively understand how to respond to hazardous materials incident is to recognize the incident may have hazardous materials involved. Responders should always assume hazardous materials are present at the incident, unless the presence of chemicals is ruled out. Thus, responders should look for hints or clues which may indicate the presence of hazardous materials. When looking for the presence of hazardous materials, certain hints can be found immediately which indicate hazards. An overturned container or drum, or a valve broken off may be the clue. In other instances, a person may need to use other senses to determine the presence of a hazardous material. Maybe the smell of something burning, or an odd smell that is normal in the area. For appropriate personnel to attempt defensive or offensive actions, further investigation is needed to determine if a hazard is present. Individuals should enter a building or other incident with caution if they suspect a hazardous material has been released, or a threat of a release is imminent. With this in mind, responders have to slow and down and consider all the factors involved. Actions need to be taken, but only in a very common sense approach, which include: Keeping themselves, other responders, and others safe Organizing appropriate response actions, and taking command if appropriate Evaluating the hazards present, and the risk each hazard poses Securing the area to prevent accidental exposures or loss of life Make notifications to the appropriate organizations who will respond At the Awareness level, you may observe a hazardous materials release. Your function may include starting the emergency response procedure by alerting the right people to handle the release – this does not include any offensive or defensive actions on your part. To conduct the actions listed above, you must know the following: The potential hazards and risks of chemicals Potential outcomes from the release, and the actions taken by others How to identify the materials released, safely What your role is in the community / facility emergency response plan How to make the appropriate notifications For a responder, safety has to be the first and primary priority. As a responder trained to the Awareness level, your options to an effective response are limited, but there are several considerations which may help control or reduce exposure to hazardous materials during an incident. To protect yourself: Resist the temptation to rush into the incident Stay a safe distance from the incident Always try to stay upwind and upstream from an incident Stay a safe distance from all spills, vapors, fumes, clouds, or other signs of a release Stay in constant communication with others who are not near the incident as a safety line Before any type action is initiated, ensure you have an adequate escape route and plan 37 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g 2. FIND A SAFE SPOT As an individual witnessing an emergency incident, the first instinct may be to initiate emergency response and mitigation actions. Responders are trained everyday to do just that in most situations. But incidents involving hazardous materials are very different, and must be treated as such. Taking the improper actions may be fatal. You may be exposed to a fatal condition before you even recognize it. If evidence at the scene indicate a potential hazardous materials situation, then assume there is such a situation, and take appropriate actions. If you cannot safely identify the material from a safe distance and position, then do not attempt to do so. Remember the simple rule of thumb: “If you cannot visually cover the incident with your thumb at arm’s length, you are too close.” It would be nice if you could find the perfect distance to be from an incident – but that’s just not very realistic. So the best option is to be farther away; this is much better than being too close. The Emergency Response Guidebook can help you determine the safe distance to position yourself. 3. THE THREE UP’S While you are observing the scene, to identify the material, or to assess the situation, you should move upwind, upstream, and uphill to a release. Materials which are in the liquid or solid state will move downhill. Most vapors will also drift downhill. Gases and vapors will normally be carried with the prevailing winds. But no one can control the winds. Be aware of wind shifts which bring the vapors or gases in your direction. Plan ahead for such a consequence, and be far enough away that such a shift will still not overcome you. Stay away from all spills, or other signs of releases. A visible cloud normally means a high enough concentration to be a hazard to your health. It should go without saying, but never, ever use your sense of smell or taste to determine what material may have been released. 4. STAY IN TOUCH While assessing a situation, it is imperative to stay in touch with someone outside of the situation. This can be the command post, your own office, or a communication center. The purpose of constant communication is obvious – if you somehow become overcome in the situation, or need additional assistance, the contact to the outside world may be your life line. Establish regular reporting periods, as well as simplified communications to convey your message. 5. WHERE’S THE BACK DOOR? Anytime someone is responding or witnesses to a release of a hazardous material, it is imperative to have an escape plan for the unexpected. Ensure your vehicle is positioned to escape quickly. The plan should be in place before any actions or assessments is initiated, and continually updated throughout the incident. 6. WHO’S IN CHARGE ? As stated over and over again, in a hazardous materials incident, your first priority is to protect yourself. Once you have accomplished this, then you can initiate the appropriate actions to help mitigate the incident to reduce the consequences. This may include being part of the command structure of the incident, or some cases, taking command yourself. This is necessary to ensure all personnel responding to the incident are working together. It is also a requirement under the OSHA HAZWOPER Standard. 38 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Local policies, as well as the local emergency operations plan will dictate who is in charge of the incident. Once the command is established, objectives must be determined and conveyed to all the responders. This would include the assessment of the situation (to size it up). This will include identifying the hazards of the incident, evaluating the risks, and determining appropriate actions to those hazards. 7. SIZING UP THE INCIDENT The release or threat of a release of a hazardous material is an acute, or timesensitive incident. While the chances of the release may be smaller, the consequences of a release could be catastrophic. Since personnel trained at the Awareness level are not to take offensive actions with the hazardous materials, it may be their responsibility to make the initial decisions about how to manage the risk. Using the MSDSs, Emergency Response Guidebook, and other critical information concerning the material released will help ensure all personnel have a reduced risk to being exposed. Once the hazards have been appropriately identified, the next step is to determine the risks those hazards pose. The risks can then be minimized by taking proper measures. As before, use the Emergency Response Guidebook and other tools to assist in identification, evaluation of the consequences posed, and the potential severity of the release. 8. HOW TO MANAGE THE RISK Do not just assess the risk from the materials released, but look at the overall risks within the situation – falling debris, traffic, bystanders, and other factors that may need to be dealt with. Once again, a responder at the Awareness level does not have appropriate training, or personal protective equipment to try and mitigate the release, or reduce the severity of the risk from the release of a hazardous material. However, such a responder may be able to take appropriate steps to keep the incident from getting worse (helping to stop traffic, removing ignition sources). Usually, the best action a responder at the Awareness level can take is to ensure the area is cordoned off to keep others from being hurt. Keep people away from the hazard, and they won’t get hurt. This bears repeating. One of the most important actions you may take is to isolate the area, and deny the entry of persons into the area. Keeping people out of an area may include establishing “exclusion” or “safe” zones, which you can assist in developing. The Emergency Response Guidebook can help in determining how far out a safe zone should be set up. Use other responders or other officials to help enforce this zone. Once the area is secured, you may need to notify other appropriate organizations of the incident to get proper personnel to the scene. This may include fire, police, EMS, public works, transportation, utilities, and even private assistance, depending on the incident. Your local emergency response plan will spell out the procedures for notifying these organizations, but will normally be done through your community 24-hour communications network, such as 911. 9. LEST WE FORGET The HAZWOPER Standard requires everyone trained and engaged in response activities at any of the levels of certification "shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least annually." Your employer will determine how you should meet this requirement. At the Awareness level, the refresher training may mean simply reviewing the competencies listed in the Standard for this level of training, and the appropriate methods of meeting those competencies. 39 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g 10. SUMMARY So, while a responder at the Awareness level will not be responsible for stopping or cleaning up a release of a hazardous material, you can play a vital role in the response to such an incident. If you discover or are sent to an emergency situation involving a hazardous material, you can: Ensure the safety of yourself and others Help in establishing command, including setting objectives for the response Assess the hazard, and make a positive identification of the material, safely Isolate the hazard (safely remove people from the area) Deny entry to the area Notify appropriate response personnel who can handle the material itself. Remember, at the Awareness level, you should only take those actions which are within your capabilities. Do not go beyond the training you have received, and be aware of the limits of your capabilities. Many organizations use the acronym SIN to help responders at the Awareness level remember their role. You can use this simple reminder also. S: Self safety is the first and most important step. If you are injured during the response, you are not much use to others, and tie up resources that could helping others. Use all available resources to protect yourself. I: Isolate the area to ensure the safety of others. Follow protocols of your community or organization on how to best accomplish this. I: Identify the product, if this can be done safely. N: Notify appropriate organizations which can respond to the incident and mitigate the hazard of the material. This notification initiates the process of responding to the release. 40 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g APPENDIX A: 1910.120 Hazardous Waste Operations and Emergency Response (HAZWOPER) Subpart q Training 1910.120(q)(6): Training. Training shall be based on the duties and function to be performed by each responder of an emergency response organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, shall be conveyed to them through training before they are permitted to take part in actual emergency operations on an incident. Employees who participate, or are expected to participate, in emergency response, shall be given training in accordance with the following paragraphs: o 1910.120(q)(6)(i): First responder awareness level. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release. First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas: 1910.120(q)(6)(i)(A): An understanding of what hazardous substances are, and the risks associated with them in an incident. 1910.120(q)(6)(i)(B): An understanding of the potential outcomes associated with an emergency created when hazardous substances are present. 1910.120(q)(6)(i)(C): The ability to recognize the presence of hazardous substances in an emergency. 1910.120(q)(6)(i)(D): The ability to identify the hazardous substances, if possible. 1910.120(q)(6)(i)(E): An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook. 1910.120(q)(6)(i)(F): The ability to realize the need for additional resources, and to make appropriate notifications to the communication center. o 1910.120(q)(6)(ii): First responder operations level. First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level and the employer shall so certify: 1910.120(q)(6)(ii)(A): Knowledge of the basic hazard and risk assessment techniques. 1910.120(q)(6)(ii)(B): Know how to select and use proper personal protective equipment provided to the first responder operational level. 1910.120(q)(6)(ii)(C): An understanding of basic hazardous materials terms. 1910.120(q)(6)(ii)(D): Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit. 1910.120(q)(6)(ii)(E): Know how to implement basic decontamination procedures. 1910.120(q)(6)(ii)(F): An understanding of the relevant standard operating procedures and termination procedures. o 1910.120(q)(6)(iii): Hazardous materials technician. Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations level in that they will approach the point of release in order to plug, patch or otherwise stop the release of a hazardous substance. Hazardous materials technicians shall have received at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify: 1910.120(q)(6)(iii)(A): Know how to implement the employer's emergency response plan. 1910.120(q)(6)(iii)(B): Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment. 1910.120(q)(6)(iii)(C): Be able to function within an assigned role in the Incident Command System. 41 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g 1910.120(q)(6)(iii)(D): Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician. 1910.120(q)(6)(iii)(E): Understand hazard and risk assessment techniques. 1910.120(q)(6)(iii)(F): Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit. 1910.120(q)(6)(iii)(G): Understand and implement decontamination procedures. 1910.120(q)(6)(iii)(H): Understand termination procedures. 1910.120(q)(6)(iii)(I): Understand basic chemical and toxicological terminology and behavior. o 1910.120(q)(6)(iv): Hazardous materials specialist. Hazardous materials specialists are individuals who respond with and provide support to hazardous materials technicians. Their duties parallel those of the hazardous materials technician, however, those duties require a more directed or specific knowledge of the various substances they may be called upon to contain. The hazardous materials specialist would also act as the site liaison with Federal, state, local and other government authorities in regards to site activities. Hazardous materials specialists shall have received at least 24 hours of training equal to the technician level and in addition have competency in the following areas and the employer shall so certify: 1910.120(q)(6)(iv)(A): Know how to implement the local emergency response plan. 1910.120(q)(6)(iv)(B): Understand classification, identification and verification of known and unknown materials by using advanced survey instruments and equipment. 1910.120(q)(6)(iv)(C): Know the state emergency response plan. 1910.120(q)(6)(iv)(D): Be able to select and use proper specialized chemical personal protective equipment provided to the hazardous materials specialist. 1910.120(q)(6)(iv)(E): Understand in-depth hazard and risk techniques. 1910.120(q)(6)(iv)(F): Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available. 1910.120(q)(6)(iv)(G): Be able to determine and implement decontamination procedures. 1910.120(q)(6)(iv)(H): Have the ability to develop a site safety and control plan. 1910.120(q)(6)(iv)(I): Understand chemical, radiological and toxicological terminology and behavior. o 1910.120(q)(6)(v): On scene incident commander. Incident commanders, who will assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify: 1910.120(q)(6)(v)(A): Know and be able to implement the employer's incident command system. 1910.120(q)(6)(v)(B): Know how to implement the employer's emergency response plan. 1910.120(q)(6)(v)(C): Know and understand the hazards and risks associated with employees working in chemical protective clothing. 1910.120(q)(6)(v)(D): Know how to implement the local emergency response plan. 1910.120(q)(6)(v)(E): Know of the state emergency response plan and of the Federal Regional Response Team. 1910.120(q)(6)(v)(F): Know and understand the importance of decontamination procedures. 1910.120(q)(7): Trainers. Trainers who teach any of the above training subjects shall have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as the courses offered by the U.S. National Fire Academy, or they shall have the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they are to teach. 1910.120(q)(8): Refresher training. o 1910.120(q)(8)(i): Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly. o 1910.120(q)(8)(ii): A statement shall be made of the training or competency, and if a statement of competency is made, the employer shall keep a record of the methodology used to demonstrate competency. Appendix B: OSHA Interpretation Letters August 1, 2003 42 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Mr. Daniel Graham, Director Bureau of Field Operations Division of Safety and Buildings Post Office Box 2538 Madison, Wisconsin 53701-2538 Dear Mr. Graham: Thank you for your February 3, 2003 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any scenarios or situations not delineated within your original correspondence. You had specific questions regarding the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR 1910.120, and the level of training required for fire fighters. Please excuse the delay in our response. Your questions are re-stated below, followed by our responses. Question 1: If the fire department dispatcher receives an emergency call reporting a suspected release of a hazardous material, could an Awareness Level fire fighter respond to the scene to confirm the existence of a hazardous material release and then notify another agency with a Hazardous Materials Response Team? Response: No. If a fire department receives an emergency call reporting a suspected release of a hazardous substance, this would be considered sufficient information to warrant an emergency response. The fire department should not knowingly dispatch an "Awareness Level" fire fighter to respond to a hazardous substance emergency response. As the scenario you presented in your letter to us explains, a police officer reports the discovery of three 55-gallon drums on the side of a road and the officer believes the drums may be the result of an illegal methamphetamine laboratory "meth lab" operation in the area. These facts provide enough information to classify the situation as a potential emergency release of a hazardous substance and thus require it to be treated as an emergency response. 29 CFR 1910.120(q)(6)(ii) states, "First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of an initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release." Training requirements for all classifications of emergency responders are based on the "duties and functions to be performed by each responder" and are found at 29 CFR 1910.120(q)(6)(i)-(v). Fire fighters who respond to emergency releases or potential emergency releases of hazardous substances must be trained to at least the first responder operations level. Question 2: How close could the Awareness Level fire fighter get to the scene and what level of PPE is appropriate? Response: Fire fighters trained at the first responder awareness level are trained to identify the release of a hazardous substance and to notify the proper authorities of the release without approaching the point of release. To further explain this role, OSHA has provided a possible emergency response scenario in the Summary and Explanation of the Preamble to the Hazardous Waste Operations and Emergency Response Standard. In this scenario, a state trooper assumes the role of first responder at the awareness level: "A state trooper is on routine patrol along a highway passing through a residential and light industrial area of a large metropolitan city. Ahead in his path of travel, the trooper notices a multi-vehicle accident involving a large overturned tank trunk. Immediately the trooper uses his radio to contact his dispatcher to report the accident. After letting the dispatcher know the location and type of accident, the trooper places his vehicle across the travel lanes of the highway approaching the accident site to stop traffic. While he is doing this, the dispatcher is alerting the fire and rescue companies in the immediate area and dispatching an established number of fire and rescue vehicles. The trooper then surveys the accident scene from his vehicle trying to identify the type of cargo on the overturned truck. Seeing three different U.S. DOT placards on the vehicle the trooper makes note of the four digit numbers and checks his DOT Emergency Response Guide for a summary of actions to be taken for the chemicals identified on the placards. After determining his next on-site responsibility, he recontacts his dispatcher with the additional information and secures the scene. He stays away from the immediate accident site and does not become involved in rescue or site mitigation. As described above, personnel trained to the first responder awareness level can make an effort to identify hazardous substances, but must do so from a distance. Since they are not permitted to approach the point of release to either contain or stop the release, they are not trained to select and use appropriate PPE. They are also not trained to establish perimeters or boundaries designating 43 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g safe and unsafe areas. These actions are to be deferred to more highly trained personnel, such as those trained to the operations or technician/specialist level. You had three additional questions in reference to the scenario below. Your scenario is re-stated for clarity, and your questions and our responses follow. Scenario: "A police officer contacts dispatch to report the discovery of three 55-gallon drums located in a drainage ditch on the side of a road. The police officer believes the drums may be the result of an illegal meth lab operation in the area. The drums have no labels, but have a pungent odor. The police officer requests a response by the local fire department. The local fire department is composed of volunteers, and all of the fire fighters are trained to the Awareness Level. The fire department responds to the call and establishes a perimeter around the barrels. In surveying the scene, the fire department determines that one barrel has the odor of acetone, another barrel has the odor of ammonia, the third barrel is leaking, and the paint near the leak is discolored. The fire department contacts a regional hazmat team based on a mutual aid agreement. The senior fire officer for the volunteer fire department is the Incident Commander. Under the direction of the Incident Commander, the Hazardous Materials team isolates the barrels for removal, believing that the barrels are hazardous. The volunteer fire fighters establish and maintain a secure perimeter and assist the hazmat team in staging materials. The barrels are recovered and tested. The lab indicates that the barrels contain mixtures of acetone, lye, ammonia and other compounds associated with the manufacture of meth." Question 3: Would the actions of the fire department based upon the level of training constitute a violation of the rule? Response: Dispatching awareness level fire fighters to respond to a suspected hazardous substance emergency response would constitute a violation of 29 CFR 1910.120. For more information, please see the responses to questions #1 and #2. Question 4: What would the minimum level of training be in order to comply with the rule? Response: Fire fighters responding to a suspected hazardous substance emergency response must be trained to at least the first responder operations level. For more information, please see the responses to questions #1 and #2. Questions 5: Would the violations be considered as de minimis? Response: De minimis violations occur when an employer complies with the clear intent of the standard but deviates from its particular requirements in a manner that has no direct or immediate relationship to employee safety or health. In your scenario, awareness level trained fire fighters are dispatched to respond to "survey the scene" and as a result make close approach to the point of release exceeding their level of training. These actions do not comply with the clear intent of the standard and have a direct relationship to employee safety and health (e.g., breathing in vapors emanating from the drums). As a result, the violations would not be considered de minimis. Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190. Sincerely, Richard E. Fairfax, Director Directorate of Enforcement Programs November 8, 1991 Mr. Joseph Green Occupational Health and Hygiene Corporation of America Downers Grove, Illinois 60515 44 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g This is in further response to your letter of September 25, to the Occupational Safety and Health Administration (OSHA). Your letter requested an interpretation of the Hazardous Waste Operations Emergency Response standard (29 CFR 1910.120). It is not the intent of the Agency to define an emergency condition in terms of an arbitrary quantity of material released due to the diversity of workplace conditions, conditions of chemical use, and types of chemicals used. When, as a consequence of a release of a hazardous substance the following conditions, or similar conditions, may develop, such situations would normally be considered emergency situations requiring an emergency response effort: • High concentrations of toxic substances. • Situation that is life or injury threatening. • Imminent Danger to Life and Health (IDLH) environments. • Situation that presents an oxygen deficient atmosphere. • Condition that poses a fire or explosion hazard. • Situation that required an evacuation of the area. • A situation that requires immediate attention because of the danger posed to employees in the area. Incidental releases that can be handled safely by employees in the immediate area, without the aid of a coordinated response effort from employees outside the area, would not be considered an emergency incident under 29 CFR 1910.120. Employers, who intend to evacuate employees from the danger zone when an emergency situation occurs and who do not expect employees to assist in handling the emergency, are exempt from developing an emergency response plan provided an emergency action plan is developed in accordance with 29 CFR 1910.38(a). The intent of the standard is to protect employees from exposure to the health and physical hazards of hazardous substances associated with hazardous waste operations and emergency response activities. Absent testing data on the mixture as a whole, the hazards of a mixture containing hazardous substances would be expected to be treated as a hazardous substance for compliance purposes. When the concentration of the mixture as a whole or the concentration of the component parts poses a condition previously described, an emergency situation would be anticipated requiring an emergency response. Gerard F. Scannell Assistant Secretary Whether firefighters trained to the HAZWOPER awareness level can respond to emergency releases of hazardous substances. OSHA Standard Interpretation March 14, 2007 Mr. Robert Minter Fire and Emergency Service Instructor I Wallingford, Vermont 05773 Thank you for your November 20, 2006 letter to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs (DEP), regarding training required by the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR 1910.120. Your specific question relates to whether firefighters trained to the awareness level can respond to hazardous substance releases. We have paraphrased your issue below, followed by your question and our response. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. Background: The Wallingford Volunteer Fire Department responds to many known materials/hazardous waste incidents. Some involved responding to gasoline spills (usually less than 5 gallons), diesel fuel spills exceeding 15 gallons, leaking fluids from motor vehicle accidents, [and] leaking 500-gallon propane tanks. Question: Can fire departments respond to known hazardous materials or hazardous waste incidents when personnel are only trained to the hazmat awareness level? Response: No. If a fire department receives an emergency call reporting a suspected release of a hazardous substance that is potentially beyond an "incidental release," it would be considered sufficient information to warrant an emergency response. In these cases, fire departments should not knowingly dispatch an "awareness level" fire fighter to respond to a hazardous substance emergency response. 29 CFR 1910.120(q)(6)(i) of the HAZWOPER standard states, 45 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g "First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release." Thus, fire fighters who respond to emergency releases or potential emergency releases of hazardous substances must be trained to at least the first responder operations level. Training requirements for all classifications of emergency responders are based on the "duties and functions to be performed by each responder" and are found at 29 CFR 1910.120(q)(6)(i)-(v). Further, 29 CFR 1910.120(q) covers emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. However, responses to releases of hazardous substances where there is no potential safety or health hazard are not considered to be emergency responses. "Incidental releases" of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of the release, are not considered to be emergency responses within the scope of the standard. Appendix E of OSHA Directive CPL 02-02-059 [formerly CPL 2-2.59A] - Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Release of (copy enclosed) provides a more thorough discussion of the distinction between incidental releases of hazardous substances and releases that require an emergency response, and hence, compliance with the provisions of 1910.120(q). Richard E. Fairfax Director, Directorate of Enforcement Programs October 11, 2006 Ms. Brandi DeCracker 21 East Main Street Sodus, NY 14551 This letter is in response to your request of August 28, 2006, addressed to the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), regarding a fire truck operator's ability to safely respond during emergencies. Your letter has been referred to the Directorate of Enforcement Programs (DEP) for a response. You want to know whether Federal OSHA has any regulations that pertain to fire truck operators in a fire department. Please be advised that Federal OSHA neither has regulations, nor jurisdiction, over State, municipal, or volunteer fire departments. Section (3)(5) of the Occupational Safety and Health Act of 1970 specifically excludes Federal OSHA's authority over employees of State and local government. The Act provides for States to assume responsibility for occupational safety and health programs under the State's own plan, which must be approved by the U.S. Department of Labor. Each State-plan must include coverage of public employees of the State, and it must be "at least as effective" as Federal OSHA's protection of private sector employees. Richard E. Fairfax, Director Directorate of Enforcement Programs Appendix C: Container Identification DOT Placard Colors and Symbols The color of the DOT placard, as well as symbols used, will provide you with a general sense of the chemical hazard stored inside the vessel or container 46 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Yellow = oxidizer Orange = explosive Red = flammable White = health hazard (poison, corrosive) Blue = water reactive Green = non-flammable gas Explosive Oxidizer Radioactive Flammable Poison Corrosive Nonflammable gas There are 9 DOT Hazard Classes with divisions under the Classes. These are: Class 1: Explosives Division 1.1 Explosives with a mass explosion hazard Examples: Dynamite, mines, wetted mercury fulminate Division 1.2 Explosives with a projection hazard Examples: Detonation cords, rockets, flares, fireworks Division 1.3 Explosives with predominantly a fire hazard Examples: Liquid-fueled rocket motors, smokeless powder, practice grenades, aerial flares Division 1.4 Explosives with a minor explosion hazard Examples: Signal cartridges, cap-type primers, igniter fuses, fireworks Division 1.5 Substances that have a mass explosion hazard but are very insensitive Example: Prilled ammonium nitrate Division 1.6 Extremely insensitive detonating articles Example: Wetted cellulose nitrate, explosive squib devices Division 2.1 Flammable gases Examples: Compressed hydrogen, isobutene, methane, propane Division 2.2 Nonflammable, nonpoisonous compressed gases Examples: Carbon dioxide, helium, compressed neon, refrigerated liquid nitrogen, cryogenic argon, anhydrous ammonia Class 2: Gases 47 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Division 2.3 Gases toxic by inhalation Examples: Cyanide, diphosgene, germane, phosphine, selenium hexafluoride, hydrocyanic acid Oxygen is not a separate division under Class 2, may be on containers with 1,001 lbs (454 kg) or more gross weight of either compressed gas or refrigerated liquid Oxygen placard Class 3: Flammable and combustible liquids Flammable placard Example: Gasoline Gasoline placard May be used in the place of a flammable placard on a cargo tank or a portable tank being used to transport gasoline by highway Combustible placard Example: Diesel fuel Fuel oil placard May be used in place of a combustible placard on a cargo tank or portable tank being used to transport fuel oil by highway Class 4: Flammable Solids, Spontaneously Combustible Materials, and Dangerous-when-wet Materials Division 4.1 Flammable solids. Examples: Phosphorus, heptasulfate, paraformaldehyde, magnesium Division 4.2 Spontaneously combustible materials. Examples: Sodium sulfide, potassium sulfide, white, yellow, or dry phosphorus, aluminum and magnesium alkyls, charcoal briquettes Division 4.3 Dangerous-when-wet materials Examples: Magnesium powder, lithium, ethyldichlorosilane, calcium carbide, potassium Class 5: Oxidizers and Organic Peroxides Division 5.1 Oxidizers Examples: Chromium nitrate, copper chlorate, calcium permanganate, ammonium nitrate, fertilizer 48 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Division 5.2 Organic peroxides Example: Type B liquid organic peroxide Class 6: Poison (toxic) Materials and Infectious Substances Division 6.1 Toxic materials Examples: Aniline, arsenic, liquid tetraethyl lead Division 6.2 Infectious substances Examples: HIV, anthrax, smallpox PG III For Division 6.1, packing group III materials, “PG III” may be used below mid line of placard rather than “POISON” Inhalation hazard placard Used for any quantity of Division 6.1 Zones A or B inhalation hazard only Harmful placard Used to indicate materials that should be kept away from food Class 7: Radioactive Materials Examples: Solid thorium nitrate, uranium, hexafluoride Class 8: Corrosive Materials Examples: Battery fluid, chromic acid solution, soda lime, sulfuric acid, hydrochloric acid (muriatic acid), sodium hydroxide, potassium hydroxide Class 9: Miscellaneous Dangerous Goods Miscellaneous Dangerous Goods Examples: Blue asbestos, polychlorinated biphenyls (PCBs), solid carbon dioxide (dry ice) Miscellaneous Placard Miscellaneous Dangers Goods Dangerous Placard 49 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Pipeline Color Codes Yellow —High-hazard materials Examples: Corrosives, toxics, explosives and flammable materials, radioactive substances, and materials if released would be dangerous Green — Low-hazard liquids or liquid mixtures Blue — Low hazard gases or gaseous mixtures Examples: Products not inherently hazardous with small chance of harming employees through mild temperatures and low pressures Red — Fire-suppression materials Examples: Carbon dioxide, foam, Halon, and water sprinkler systems Safety Color Codes ANSI Z535.1 sets forth the following safety color code that is recommended for use Red Means Danger or Stop; is used on containers of flammable liquids, emergency stop bars, stop buttons, and fireprotection equipment Green Marks safety equipment such as first-aid stations, safety showers, and exit routes Yellow Means Caution; solid yellow, yellow and black stripes, or yellow and black checkers may be used to indicate physical hazards such as tripping hazards; also used on containers of corrosive or unstable materials Blue Marks safety information signage such as labels or markings indicating the type of required personal protective equipment (PPE) Orange Means Warning; is used on hazardous machinery with parts that can crush or cut or energized equipment Container Sizes and Shapes The shape, size, and design of containers used in transportation and storage may give you clues about the type of material in the container. A compressed gas, for example, is easily identifiable by a cylindrical container with rounded ends. It is therefore critical that you learn what clues the shapes and sizes of containers can give you about the hazardous materials that they carry. Bulk Containers Both bulk and non-bulk containers are used to transport hazardous materials. Bulk containers hold the hazardous materials directly, without any intermediate form of containment. These types of containers include highway cargo tanks, tank cars that transport materials by rail, and other containers (except watercraft) with: A maximum capacity of more than 119 gallons (450 liters) for containers of liquids A maximum net capacity of more than 882 pounds (401 kilograms) for containers of solids A water capacity greater than 1,001 pounds (454 kilograms) for containers of gases Highway Carriers Each type of highway carrier, or cargo tank, is shown on the following pages, along with a general description of the tank and its common cargo. 50 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Non-Pressure Cargo Tank MC306 / DOT406 Classified as “non-pressure” (less than 3 psi) Carries low volatility liquids: gasoline, diesel, fuel oil, etc. Under ambient temperature and pressure Oval cross section and flat ends Carries up to 8,000 gallons Compartments – can be several products Low Pressure Cargo Tank MC307 / DOT307 Classified as “low-pressure” Made of stainless steel, steel, or aluminum Carries high volatility liquids or mild corrosives, asphalt, sulfuric acid, and almost all other types of liquid chemicals Carries up to 7,000 gallons Round cross section or horseshoe shaped cross section and flat ends May have rollover protection Insulated for hot or cold Pressure Cargo Tank MC330 / MC331 Rounded ends Transports Liquefied compressed gases Construction: Steel, HSLA Classified as “high-pressure” 100 to 250 psi Liquefied compressed gases: propane, butane, anhydrous ammonia Gas under ambient temperatures BLEVE potential if tank involved in fire Carries from 2,500 gallons to 11,500 gallons Large expansion ratio – (propane 270:1) Cryogenic Liquid Cargo Tank MC338 Refrigerated liquids (- 150 to – 450 F.) Liquid oxygen, liquid nitrogen Low pressure- under 25 psi Huge expansion ratio – up to 800:1 Large, insulated thermos bottle on wheels Vapor may discharge because of normal operation of pressure-relief valve Construction: Specialized with annular space and unique venting characteristics One of the elements of tank construction refers to the tank’s shape as it looks from behind, or its cross section. Cargo tanks are either circular or elliptical in cross-section, depending on their intended use. In some cases, insulation is used on tanks and may change the appearance of the tank shape, making circular tanks appear elliptical. It is important to note that low pressure cargo tanks have circular cross-sections and flat ends, though from behind, some of these tanks may appear to have a horseshoe shaped cross-section. Tube Trailers Classified as “ultra-high pressure” Compressed gases: oxygen, nitrogen, hydrogen Carries many of same gases as cryogenic, but in a true gaseous state – under high pressure Stack cylinders 2,000 to 5,000 psi DOT does not class tube trailers as cargo tanks 51 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Dry Bulk Carriers Large, heavy, sloping V-shaped unloading compartments located at the bottom of the trailer and its rear-mounted air compressor Use: Hazardous and non-hazardous powdered and granular materials, such as fertilizers, oxidizers, and plastics Pneumatically off-loaded Some materials carried by this tanker may be water reactive Railroad Cars Railroad tank cars are bulk containers used to carry both hazardous and non-hazardous materials by rail. The specific type of materials carried in a tank car determines how the tank is constructed, as well as its size, fittings, linings, and other features. Although there are exceptions, most rail cars carry only a single commodity. In general, they all look very similar, with circular cross-sections and rounded heads. Because of their similar design, you must learn to identify specific rail car characteristics for clues about the nature of the commodity being transported. Tank cars can be divided into several different categories, each with its own distinct characteristics. The most common categories are discussed in this section. Key Point: When a rail incident occurs, railroad personnel are often the best source of information. They are the experts on rail car design and use, and can provide you with information that could save your life. Becoming familiar with the railroad companies operating in the community before an incident occurs is essential. Pressurized Rail Car Transports flammable and non-flammable compressed gases or poisonous compressed gases (e.g., chlorine, propane) Construction: Fittings inside a protective housing on top of car, no underside piping Designed for pressures from 100 to 600 psig Carry 4,000 to 45,000 gallons Non-Pressurized Rail Car Valve assemblies on top of car not normally covered May also have visible valve assemblies under car for off-loading Carry from 4,000 to 45,000 gallons at less than 100 psi Do not always transport hazardous materials Carry liquids or solids that can be liquefied (Flammable liquids, Corrosives, Poisons, Molten sulfur Cryogenic Liquid Rail Car Low-pressure cars (below 25 psi) Large “thermos bottle” Designed as a tank - within - a - tank for insulation Product is –130 degrees F. or lower Most cars have no top fittings Carries liquid nitrogen, liquid oxygen, etc. Product may vent under normal conditions Corrosive Liquid Rail Car Similar to non-pressure tank cars Can be distinguished by staining around manway Some painted with vertical stripe of corrosion-resistant paint Transports corrosive materials (e.g., sodium hydroxide, hydrofluoric acid) 52 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Box Car Enclosed cars with steel or wooden interiors Used for general freight Carries drums, boxes, cylinders, or other non-bulk containers Gondola Car Uncovered, with low sides and ends Transports bulk ores and other solid materials Often used to carry low-activity radioactive materials Container on Flat Car Loaded on specifically designed flatcars in various configurations, including single and double stacks No FRA restrictions specifying what hazard classes may be shipped INTERMODALS / INTERMEDIATE BULK CONTAINERS (IBCS) Ton Containers Ton containers are cylindrical in shape with rounded heads welded to the cylinder. They range in liquid capacity from 180 to 320 gallons. Tank test pressures ranges from 500 to 1,000 psig. When shipped by rail, ton containers are carried on special flat cars, in boxcars, or gondola cars, and in trailer-on-flat-cars, or container-on-flatcars. All fittings are located in the heads, including fusible plugs and / or springloaded safety relief valves. Safety relief devices are prohibited for certain poisonous or noxious materials. Ton containers transport gases such as: Anhydrous ammonia Butadiene Sulfur dioxide Chlorine Phosgene Refrigerant or dispersant gases INTERMODAL TANK CONTAINERS Intermodal tank containers consist of a single metal tank mounted inside a sturdy metal supporting frame. This unique frame structure means that they can be used in two or more modes of transport, such as rail, highway, or water. The tank is generally built as a cylinder enclosed at the ends by heads. Its capacity is generally less than 6,340 gallons. Other tank shapes and configurations are rare, as are tanks with multiple compartments. Non-pressure intermodal tank containers comprise over 90 % of the total number of tank containers. They generally transport liquid and solid materials at maximum allowable working pressures of up to 100 psig. INTERMEDIATE BULK CONTAINERS Intermediate bulk containers are rigid or flexible portable packaging other than cylinders or portable tanks, which are designed for mechanical handling. These containers have been designed mainly to replace steel and plastic drums and most are reusable and dedicated to single product usage. They are used to transport the same materials you would find in drums, in greater quantities. NON-BULK CONTAINERS Non-bulk packaging includes: A maximum capacity of less than 119 gallons for containers of liquids 53 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g A maximum net capacity of less than 882 pounds for containers of solids A water capacity of less than 1,001 pounds for containers of gases. It is difficult to determine the contents of non-bulk containers based on the shape and design of the container. Non-bulk packaging for hazardous (as well as non-hazardous) materials include: Drums Cylinders Dewars Carboys Bottles Bags Aerosol cans Fiberboard and wooden boxes Multi-cell packages Other containers of similar size These containers are in wide use for a variety of products. Newer plastic containers can hold 400 to 1,000 pounds of liquid. In addition, you can find these containers virtually anywhere – around warehouses, retail outlets, homes, in boxcars, cargo vans, and semi-trailers. Often, there is no way to determine whether or not the contents of such containers are hazardous without getting close to the materials. In most cases, people have to rely on proper markings and shipping papers to determine the contents. When labels and other markings are missing or not legible on these containers, the following descriptions and guidelines may give you some general information about the possible contents. Drums The clues to the contents of drums come from the material the drum is made of and whether or not the drum is closed-top or open-top. Closed-top drums are sealed and have small openings in the top through which liquids can be poured. Closed-top metal drums normally contain non-corrosive products in liquid form. Closed-top plastic, plastic inslde metal, or cardboard drums usually contain corrosive liquids. Open-top drums have removable lids and do not have the small openings typical of closed-top drums. Open-top metal drums usually contain non-corrosive solids or sludge. Open-top plastic drums usually contain corrosive solids or sludge. Cylinders Cylinders usually contain liquefied gases, non-liquefied gases, dissolved gases, or various combinations of the three. They may also contain liquids or solids. Cylinders range in size from aerosol containers to cylinders for liquid nitrogen that are approximately 24 inches in diameter and five feet high. The contents of cylinders can be toxic, flammable or explosive. For this reason, cylinders can become hazardous if the contents leak. In addition, since the contents are stored under pressure, cylinders may become projectiles if the valve at the top is damaged. They can create enough force to penetrate a concrete wall. Container Construction Drums Metal Fiberboard Plastic Bottles and Jars Content Other than gases and etiologic agents, drums may contain almost any form of hazardous material, including powders, liquids, pastes, and slurries Glass Plastic Occasionally made of ceramic or metal Liquid and solid hazardous and non-hazardous materials Bags Plastic Paper Dry corrosives Blasting agents Explosives Flammable solids Multi-cell Packages Polystyrene fitted form containers Acids 54 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Oxidizers Poisons ORMs Boxes Carboys Dewars DOT limits to no more than 6 bottles and maximum of 4 liters Bases Corrosives Wooden Fiberboard Wooden and fiberboard boxes may be used for every type of hazardous material except compressed gases Glass Plastic Encased in specially cushioned boxes made of wood or fiberboard Corrosive liquids Flammable liquids Poison or toxic liquids Non-pressurized, heavily insulated containers Usually with a vacuum space between the inner and outer shells Cryogenic materials such as liquefied nitrogen, helium, and oxygen Compressed gases Flammable or combustible liquids Poisons Radioactive materials Corrosives Cylinders Short, broad cylinders are generally used for low pressure materials Tall, thin cylinders are usually used for high pressure materials BULK CONTAINERS AT FIXED SITES Most storage tanks are designed to meet the specific needs of certain commodities. Tank size, shape, and design do not occur by chance, tanks are built to withstand the properties of their intended contents. Vertical Flat Roof Tank Cone Roof Tank Open Floating Roof Tank Covered Floating Roof Tank Flammable liquids Combustible liquids Corrosives Non-hazardous materials Circular, with flat roof Similar to flat roof tank except for fixed cone shaped roof Roof floats on contents and moves up and down with varying levels May have a ladder along the side Fixed cone-shaped roof covers inner floating roof Large vents at top of tank Flammable liquids Combustible liquids Corrosive liquids Flammable liquids Combustible liquids Flammable liquids Combustible liquids Dome Roof Tanks Vertical rather than horizontal Fixed dome-shaped roof Internal pressure up to 15 psi 55 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Flammable liquids Combustible liquids Corrosive liquids Fertilizers Chemical Solvents Non-hazardous materials Horizontal Tank Underground Storage Tank Pressurized Horizontal Tank Horizontal tank on legs or blocks Use is restricted or banned because of susceptibility to tank / leg failure Gauges and controls are above ground Horizontal tanks with rounded ends Usually set on legs or blocks Usually painted white or reflective color Pressure relief devices on top of tank 56 | R e g i o n 6 H A Z W O P E R A w a r e n e s s T r a i n i n g Liquids and gases Usually contains petroleum products Flammable liquids Combustible liquids Corrosives Poisons Processing chemicals Octane boosters Anhydrous ammonia Liquid petroleum products (e.g., propane)
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