Competency for HAZWOPER Emergency Response
With the single exception of the Skilled Support Personnel, everyone at a facility with any possible role in recognizing and responding to hazardous substance releases must be certified competent by the employer. This includes persons with specific training hours--such as the Incident Commander, the Hazardous Materials Technicians and Specialists, and the First Responder Operations personnel--as well as two categories of personnel who do not require specific training, namely, the Specialist Employees and the First Responder Awareness personnel. Let's deal with these first two categories first.
Specialist Employees. OSHA recognizes that there are some people at your facility who have technical knowledge that exceeds yours as the team organizer. Thus, "competency" for these people means listing them on your Emergency Response Team Call-up Roster and indicating the specific areas of knowledge for which they are being called up. Note that OSHA says that you must renew this decision on an annual basis, so update your roster at least once each year.
First Responder Awareness Personnel. Here the "competency" judgment should be part of the initial OSHA Hazard Communication training (and you might consider refresher training, although it is not required) of plant personnel. Does your training agenda include the information and the delegation of responsibility which would enable each employee at your facility to notice that a release had occurred and to know who to tell about their discovery? If not, you should fix the system and then declare the properly trained and empowered employees competent.
Trained Personnel. Just as for the Specialist Employees, the competency decision for these persons should be related to your Call-up Roster. What roles can each person play?
- What does their training allow?
- Within those constraints, what experience do they have?
- Within those constraints, what technical and personal characteristics do they have?
An emergency response is a team effort. Mere technical information and training are not enough.
- Can thon function within the command structure?
- Can thon work effectively in a small group or would a sole responsibility task be better?
- Does thon require someone else as a "steadying" influence in rapidly changing circumstances?
- Does thon have any medical or physical limitations that must be considered?
Only put someone on the roster who will be a positive contributor to the response effort, and define the parts of the response thon would be most effective at performing.