OSHA HAZWOPER Emergency Response Team Organization

(Per OSHA 29 CFR 1910.120(q))

The table below summarizes the requirements of a HAZWOPER Emergency Response Team and the training they need. It may be useful to note that the OSHA HAZWOPER requirements mean that if you do any response other than to incidental releases cleaned up at the time of release by employees in the immediate work area or by maintenance personnel you must have a minimum of five trained people in the following roles:

  1. Incident Commander (doubling as the Safety Officer);
  2. Entry personnel (trained at the HazMat technician level);
  3. Backups (trained at the First Responder Awareness or the HazMat technician level).

To get a more complete description of the role and function at each level, click on that entry in the table.
To determine the appropriate Institute course, click on the job title.

Job Title

Role / Function

OSHA Minimum Training

On-Scene Incident Commander

(HAZWOPER Emergency Response -
First Responders Initial
)

Person- in-charge

24 Hours & Competency

Hazardous Materials Specialist

(HAZWOPER Emergency Response -
First Responders Initial
)

Senior technician, liaison officer

24 Hours & Competency

Hazardous Materials Technician

(HAZWOPER Emergency Response -
HazMat Tech Initial
)

Responds offensively to contain and control release

24 Hours & Competency

First Responder - Operations

(HAZWOPER Emergency Response -
First Responders Initial
)

Responds defensively to protect people and equipment

8 Hours & Competency

First Responder - Awareness

Discovers release and notifies appropriately

Competency (HazComm)

Specialist Employee

Provides technical assistance

Competency (specialized knowledge)

Skilled Support Personnel

Operates equipment

On-site briefing (tasks, hazards, PPE)

On-Scene Incident Commander. The OSC has responsibility for overall direction and coordination of the scene. By definition there can only be one, although at larger incidents various specialties may have representatives at the command post.

Hazardous Materials Specialist. It is no accident that the Hazardous Materials Specialist is not listed on the required response personnel at the scene, because the position is ill-defined. Some teams consider there Lead Technician to have this responsibility, while most do not have such a post. The OSHA training hour requirement is the same for both Technicians and Specialists, and the NFPA (National Fire Protection Association) dropped this specialty from its table of organization for hazardous materials emergency response teams.

Hazardous Materials Technician. These persons actually enter the release zone to contain or control the materials being released. Under OSHA rules the initial response must be conducted in SCBA (self-contained breathing apparatus) unless the employer has definite knowledge that no hazardous air contaminants are present in the release zone. The TECP (totally-encapsulating chemically protective) suit may be required if there are materials which pose a vapor phase skin hazard to responders. These employees must be provided with annual medical surveillance.

First Responder Operations. These employees are allowed to conduct defensive actions only. If they have been provided with adequate instruction and equipment, they can enter the release zone, but only for the purpose of protecting people and equipment. If your backup team is at this level, they can assist the entry team with leaving the area, but they cannot assist in containing or controlling the release in the actual release zone.

Typical actions include:

  • Covering drains.
  • Assisting with evacuation.
  • Shutting down critical processes.
  • Conducting decontamination.
  • Serving as coordinators of logistics, communications, security, etc.

First Responder Awareness. This should be every employee at your facility. During Hazard Communication training (29 CFR 1910.1200) you are required to provide training on hazard recognition and emergency response. The job of an awareness level employee is to identify that a release may have occurred and then to take the necessary steps to inform the area supervisor or site security. If your employees can't do this, you need to rethink your HazComm training.

Specialist Employee. A specialist employee is someone with valuable technical knowledge who should be on the team call-up list to assist the On-Scene Incident Commander.

Specialist employees might include:

  • the plant engineer (who knows where all the shutoffs are),
  • the plant chemist (who knows how to best deal with the materials and the wastes created by the response)
  • or the plant doctor (who can recognize unusual symptoms and spot signs of stress or fatigue, and can know when to call in outside emergency assistance.

Safety Officer. OSHA mandates that there always be a safety officer at the scene, but there is no training specified in the standard. Thus, your Safety Officer could (and probably be someone with HazMat Technician or Incident Commander training, or thon could be a specialist employee. Regardless of thon's training, OSHA mandates that the Safety Officer has the responsibility of observing the response and "the authority to terminate, alter, or suspend operations" if the response cannot be done safely.

Skilled Support Personnel. This category allows the On-Scene Incident Commander to recruit persons to assist by operating equipment such as bulldozers, man-lifts, and front-end loaders. If the operator is not previously certified competent for response, and if the task needed can only be done with the operator's assistance, the Incident Commander can use them in the response after briefing the operator on:

  • The specific task to be performed;
  • The hazards of the task and of the released materials, and
  • The nature of any special work practices and personal protective equipment (PPE) to be used in performing the task.