So Where Did This Stuff Come From Anyway?
Hazmat—The Book of Genesis
We’ve all been there. You’re sitting in some hazmat training, the instructor is
passing on some bit of wisdom and you find yourself wondering, “Just where
did this guy come up with this stuff anyway?”. If you ask you will probably get
an answer along the lines of, “…we came up with this after years of experience
and research…yada, yada, yada…” (English language translation: “I have no
idea where this comes from.”)
Would you like the real answer?
In the beginning the hazmat world was without form and void. Darkness was
upon the face of the land. The federal government said, “Let there be guidance!”
and the spirit of the federal government moved upon the land. The federal
bureaucrats met and brought forth the Hazmat Book of Genesis, also known by
its more prosaic title, Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities.
This manual, first published in 1985, was the product of a collaboration
between several federal agencies, most prominently, the National Institute of
Occupational Safety and Health (NIOSH), the Occupational Safety and Health
Administration (OSHA), the U. S. Coast Guard (USCG) and the Environmental
Protection Agency (EPA). It is still available from the Government Printing
Office and from the NIOSH website.
Although this publication was intended to provide guidance on waste site
cleanup activities it quickly became the gold standard in hazmat emergency
response as well. The guidelines it recommended about levels of protection,
decontamination procedures, air monitoring and emergency procedures formed
the basis of virtually all hazmat training programs that now exist. OSHA used
this document when it drafted the Hazardous Waste Operations and Emergency
Response (Hazwoper) regulation, the EPA wrote their training programs and
operating guides using this as one of the primary references and the National
Fire Protection Association used this in drafting their recommendations for
hazmat response. In summary, it has become the backbone of hazmat training
today. Surprisingly, even though this is the foundation of much of what we do in
hazmat response, many people have no idea it even exists.
So what things that we now take for granted first appeared in this book?
“You must use at least three sources of information!”
“The decon team can use a level of PPE that is one level down from that used
by the entry team.”
“Exclusion Zone!?!? Who named it that? I call it the Hot Zone and so does
“Level B is the minimum level for initial entry.”
Let’s take a look at what this book says about some of these bromides.
Initial entry—“Level B protection is generally the minimum level
recommended for an initial entry…” (paragraph 6-2). The rationale for this is
fairly simple. If you don’t quite know what hazards are present then you can’t
use Level C since you haven’t yet identified and measured the contaminants. If
you think there is something hazardous there then forget about Level D. That
leaves Levels A and B. If there is no visible vapor or aerosol, you aren’t entering
a confined space and there are no apparent conditions that would present severe
hazards (e.g. potential fire or explosion) they Level B will often provide adequate
protection for an initial survey.
Decon PPE—“…decontamination personnel may be sufficiently protected by
wearing one level lower protection…” (paragraph 10-6). In most incidents, the
decon team is exposed to a lower level of hazard than the entry team. Because of
this, they can wear a lower level of protection.
Exclusion Zone—“The Exclusion Zone is the area where the contamination
does or could occur.” (paragraph 9-2). Although many people prefer to use the
more common terms and many training programs teach their use, the fact
remains; the terms “exclusion zone”, “contamination reduction zone” and
“support zone” appear in this document and the OSHA regulations. The other
terms don’t. Any credible training program will teach the correct terminology.
(Of course, responders are free to use any terms they choose. I have yet to see
anyone go to jail for calling the Exclusion Zone the Hot Zone.)
Three Sources—“As many reference sources as possible should be used…”
Hey, not everything came from this book! The oldest reference for this that I can
find is the EPA Standard Operating Safety Guide. If you can find an older one
source for this let me know.
Anyone involved in developing or delivering hazmat training should have a
copy of this book. Not only does it provide the source for many of things we now
accept as articles of faith, it contains nearly all the information you need to train
people to safely respond to a hazmat release. Things like Site Safety Plans, PPE
selection criteria, decontamination procedures, medical programs and site
control are all here. Get a copy, you won’t be disappointed.
Where can you get a copy? You can download if from the NIOSH website at
the following URL: http://www.cdc.gov/niosh/publistc.html. Look for “85-115,
NIOSH/OSHA/USCG/EPA/ OCCUPATIONAL SAFETY AND HEALTH
GUIDANCE MANUAL FOR HAZARDOUS WASTE SITE ACTIVITIES, PB 87-
162-855” and click there. They have it available as a PDF file.