JUSTIFYING A MINIMUM STANDARDIZED COMPETENCY FOR TYPE II HAZARDOUS

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					JUSTIFYING A MINIMUM STANDARDIZED COMPETENCY FOR TYPE II HAZARDOUS
               MATERIALS RESOURCES IN NORTH CAROLINA



EXECUTIVE ANALYSIS OF FIRE SERVICE OPERATIONS IN EMERGENCY
                       MANAGEMENT




                           BY:     Derrick S. Clouston
                                   North Carolina Office of State Fire Marshal
                                   Raleigh, North Carolina




 An applied research project submitted to the National Fire Academy as part of the
                         Executive Fire Officer Program.



                                  October 2003
                                                                                                 1


                                             Abstract

       The problem was that the State of North Carolina (NC) needed to justify why a minimum

standardized competency should be required when training Type II Hazardous Materials Teams

(HMT). The purpose of this research was to justify the need for a minimum competency

standard for Type II HMT in NC. This was a descriptive research project. The research

questions were:

       1. What does a minimum competency standard provide an occupation?

       2. What ways can International Fire Service Accreditation Congress (IFSAC)

           accreditation of a HMT training program help standardize competencies for Type II

           HMT?

       3. How will minimum competency standards for Type II HMT benefit the citizens of

           NC?

       The procedures involved studying how a minimum standardized competency ensures
responders that are certified have obtained the required knowledge, skills, and abilities to
perform given tasks. The impact of the ways IFSAC accreditation helps to standardize
competencies was also researched. The last area that was reviewed was the impact of a
standardized training program for Type II Hazardous Materials Teams on the citizens of North
Carolina. The findings in this research were that standardized competencies benefited
responders by ensuring that all were exposed to the same baseline level of knowledge.
Accreditation ensured to the responders participating in the program that a standard was being
followed, and that it met a minimum set of requirements. The research showed that the citizens
would benefit from standardized training due to less negative impact to property and the
environment and that standardized training would result in fewer lawsuits.
       The recommendations were as follows: North Carolina needed to adopt the National Fire
Protection Association 472 standard, the new program should then be accredited, and finally, for
the benefit of the citizens, the state should ensure all responders on Type II Hazardous Materials
units are trained to the same standard.
                                                       2




                              Table of Contents


Abstract                                          1

Table of Contents                                 2

Introduction                                      3

Background and Significance                       3

Literature Review                                 4

Procedures                                        7

Results                                           9

Discussion                                        12

Recommendations                                   14

References                                        16

Appendix A                                        18

Appendix B                                        24

Appendix C                                        25
                                                                                                 3


                                              Introduction

       The problem is that the State of North Carolina (NC) has not justified why a minimum

standardized competency is needed when training Type II Hazardous Materials Teams (HMT).

The purpose of this research is to justify the need for a minimum competency standard for Type

II HMT in NC. This is a descriptive research project. The research questions are:

       4. What does a minimum competency standard provide an occupation?

       5. What ways can International Fire Service Accreditation Congress (IFSAC)

           accreditation of a HMT training program help standardize competencies for Type II

           HMT?

       6. How will minimum competency standards for Type II HMT benefit the citizens of

           NC?

                                     Background and Significance

       Changes are currently taking place in the realm of hazardous materials response and

funding, but there is no standardized competency level that is required of HMT in the state

(North Carolina Fire and Rescue Commission [NCFRC], 1992, 4-1.1). These changes are

occurring due to the expanding roles of emergency responders in NC. Concerns such as

environmental protection, conservation, acts of terrorism, and increased federal funding for

emergency response to Hazardous Materials (Haz Mat) incidents are spawning changes as well.

These concerns are being addressed by typing (categorizing) HMT within the state. At the

present time a HMT may certify its members by using one of four different methods outlined by

the North Carolina Department of Insurance Office of State Fire Marshal (OSFM). This causes

many problems for OSFM because IFSAC accreditation cannot be achieved, all the courses do

not cover the same competencies, and four different programs must be maintained. This study
                                                                                                     4


will help justify the need for one minimum competency standard. This will help OSFM in

preparing HMT to respond to the many challenges they face now and in the future, and allow

OSFM to be more effective in ensuring that the training program will teach the modern response

procedures.

       This Applied Research Project (ARP) relates to the Executive Analysis of Fire Service

Operations in Emergency Management (EAFSOEM) objective of typing resources to meet

challenges, and training to accepted standards nationally, regionally, and statewide (National Fire

Academy [NFA], 2001, 6-5). This research will determine if there is a need for minimum

competencies for Type II HMT in NC.

       This ARP meets the United States Fire Administrations fourth operational objective of

promoting within communities a comprehensive, multi-hazard, risk reduction plan led by the fire

service organization.

                                            Literature Review

       The purpose of this literature review is to set the practical foundation of this study. The

three areas that need to be addressed to complete this research are defined as follows: What do

minimum competency standards provide to an occupation? Does IFSAC accreditation help

standardize competencies within a training program? Lastly, what were the effects of a

standardized competency on the citizens within NC?

       First, what do minimum competency standards provide an occupation? The sole purpose

of The National Fire Protection Association (NFPA) standard 472 is to define the competencies

of those individuals who respond to hazardous materials incidents (National Fire Protection

Association [NFPA], 2002)(NFPA, 472-6). This statement provides the author an insight into

the intent of the NFPA standard, which is to set a minimum competency requirement to which all
                                                                                                      5


responders should be trained. NFPA is a national consensus standard that derives its basis for

the materials it produces by being driven by the people within the profession. In a position paper

filed by Disaster etc., a strong case is made that in order for a profession to grow, flourish, and

gain credibility we must do more than have a certified program. The program must also meet a

standard for completion (Centella, 1994, 277). IFSAC states in its criteria for accreditation that a

minimum competency standard such as NFPA, or a more stringent standard, shall be used to set

a minimum competency level for a certification that is being awarded by an accredited

organization (International Fire Service Accreditation Congress [IFSAC], 1998, 13.4.1). IFSAC

as well states that a minimum competency shall be used to certify any individual within a

certification system. It is IFSAC’s assertion that a minimum basis is needed within a system to

ensure a level of competency is reached and that the person being certified meets that criterion

(T. L. Bradley personal communications, July 17, 2003). The American Psychological

Association also states that any profession should have clearly defined competencies for people

within the profession to meet to ensure quality and competency within its related functions

(American Psychological Association [APA], 2003).

       IFSAC, within their mission statement and objectives, maintains that the intent of the

organization is to administer high quality, uniformly delivered accreditation systems for

emergency personnel according to various professional competency standards (International Fire

Service Accreditation Congress [IFSAC], 1998, 10.5). This indicates that accreditation would be

valuable in standardizing competencies within a given subject area, as long as there is a standard

available by which a person may be certified. The American Educational Research

Association’s (AERA) stance on standards indicates they are a reference to assure that relevant
                                                                                                      6


issues are addressed within a given subject or area (American Educational Research Association

[AERA], 1999, 2).

       The potential effects of standardized competencies for HMT were explored from the

standpoint of customer service. HMT customers are ultimately the citizens of NC. Gordon

Graham states that the public deserves from its’ emergency responders individuals who have

strength, skill, integrity, and fitness to do the job. Graham also states that the public deserves an

organization that recognizes the five pillars, which are people, policy, training, supervision, and

discipline. In order for responders on Type II HMT to be effective they must have training, and,

according to Graham, training should take place every day employees come to work. To avoid

injury, deaths, and lawsuits employers must ensure that each of these five pillars are in place

(Graham, 2002). A minimum competency standard could provide a starting point for this

training to avoid the injuries, deaths, and lawsuits Graham discusses in his paper. NC

Emergency Management’s Typing Guide states the following (Appendix A):

       This guide is designed to provide standards and guidance for typing of hazardous

       material response teams (HMT’s) into levels of functionality. This will establish

       minimum criteria for designation as a “HMT” and provide assistance to incident

       commanders when requesting additional appropriately trained and equipped resources

       (North Carolina Emergency Management [NCEM], 2002, 2).

       This guideline also sets a minimum level of training and competency to ensure that all

teams summoned by an incident commander are trained to a minimum specific competency.
                                                                                                    7


                                            Procedures

Feedback Form

       A feedback form (Appendix B) was given to the nine members of the Hazardous

Materials Certification Sub-Committee of the NC Fire and Rescue Commission. The form was

given to this group since they have the responsibility of setting procedures and developing

guidance in training NC’s HMTs. The purpose of the feedback form was to gain insight on the

opinions of these individuals regarding the direction NC should take and to evaluate if we could,

in fact, justify a single competency.

Population

       The population for the Hazardous Materials Certification Sub-Committee of the NC Fire

and Rescue Commission was seven people. These individuals represent areas all across the state

and are selected from the various professional associations that are part of the fire and

emergency services.

General Research

       The author also explored what industry standards were set for the use of standardized

competencies for HMT’s. The area that was researched was NFPA 472 Standard for

Professional Competence of Responders to Hazardous Materials Incidents Chapter 6. IFSAC

was another aspect that was studied to see the effects of accreditation and if it would assist in

standardizing competencies for HMT’s within the state and its Type II teams. Agencies that are

typically not associated with emergency response were also studied, such as the American

Education Research Association, to determine their perspective on standards in education and

how they affect learning in all aspects of society.
                                                                                                        8


       The author obtained a copy of the IFSAC Handbook and researched the policies and

standards to see what requirements of standardization IFSAC has. The last area that was

researched was that of the impact of standardization of training on the citizens. This portion of

the study was done from a perspective of response efficiency and liability if responders were not

properly trained. The web site of Gordon Graham, a noted lecturer on emergency response

liability and customer satisfaction principles, was thoroughly reviewed. Private industry

procedures were also researched to define the procedures and training standards that are utilized

by private sector employers and to see if standardized training has been explored. Visiting the

National Fire Academy Learning Resource Center and searching their card catalogs using key

words such as occupational, health, and safety completed this portion of the research.

Limitations and Assumptions

       The limiting factor of both feedback forms that were distributed is the limited number

within the population from which the feedback was solicited. It is also assumed that the

individuals on these committees are indeed knowledgeable of the needs of the responders within

their respective areas of the state. A limiting factor within the general research is that the author

found very few resources that were written on the use of standards within a given competency to

determine its efficiency within the profession, accreditation, or the effects on citizens. It is also

evident that the areas that were studied were from the perspective of individuals within the

emergency response community. This fact could lead to bias as it relates to the training of

members within the community.

Definitions

       Accreditation – to certify a school or college as meeting official requirements for

academic excellence, curriculum, facilities, etc.
                                                                                                      9


        Hazardous Materials Response Team- an organized group of employees, designated by

the employer, who are expected to perform work to handle and control actual or potential leaks

or spills of hazardous substances requiring possible close approach to the substance.

        Hazardous Materials Technician- person who responds to releases or potential releases of

hazardous materials for the purpose of controlling the releases using specialized protective

clothing and control equipment.

        International Fire Service Accreditation Congress - a non-profit accrediting body that

provides accreditation to those entities that wish to voluntarily participate in the IFSAC process.

        Level II Incident – Incidents that require special resources (technician level of

certification) for control/stabilization.

        National Fire Protection Association – non-profit standards-making body that is

considered to be a consensus standard for the fire service.

        Type II Hazardous Materials Team (Medium) - shall be capable of response to incidents

up to Level II, which may involve hazardous materials incidents only.

                                              Results

        In examining the first research question, what does a minimum competency standard

provide an occupation, the author found that NFPA defines a minimum competency standard,

what a Haz Mat Technician does, and what competencies he must have (NFPA, 2002, 3.3.34).

NFPA indicates within their standard that the minimum competency benchmark is not designed

to set the maximum amount of training but the minimum.

        NFPA also states that it is up to the authority having jurisdiction (AHJ) to decide what

the maximum level of training should be (Appendix C). The Occupational Safety and Health

Administration (OSHA) also defines what minimum competencies a HMT should have and
                                                                                                   10


states that the reason for these competencies is to provide employers of responders a baseline by

which to train their personnel (Occupational Safety and Health Administration [OSHA], 1991,

28). While researching the effects of NFPA and OSHA, the author noted that the NFPA is a

standard and OSHA is law (Appendix D). The feedback forms from the Hazardous Materials

Certification Sub-Committee of the NC Fire and Rescue Commission indicated that out of the

seven members of the committee, all seven indicated that they felt a standardized competency

would improve the training that was given. Also all seven committee members indicated on their

feedback form that OSFM should adopt NFPA 472 as the standardized competency for all

responders in the state. As this research indicates above, NFPA leaves the decision up to the

AHJ to determine if they are going to adopt a particular standard. In the instance of the

Hazardous Materials Certification Sub-Committee, this sub-committee is the AHJ due to the way

the North Carolina Fire and Rescue Commission governs its certification programs.

       The second question to be answered is in what ways can (IFSAC) accreditation of an

HMT training program help standardize competencies for Type II HMT. IFSAC states in its

accreditation handbook that an accredited entity shall certify personnel to the current edition of

the NFPA Professional Qualification Standard or other standards accepted by the Certificate

Assembly ((IFSAC, 1998, 13.4.1). IFSAC’s intent for using a standardized competency is to

ensure that at least a minimum level of competency has been achieved, and the student has

demonstrated competency before being issued a certification. Accreditation would help OSFM

standardize its HMT program due to this requirement to use NFPA 472. NFPA 1000 Standard

for Fire Service Professional Qualifications Accreditation and Certification Systems states that

any accredited entity within the United States shall use NFPA standards to certify to (National

Fire Protection Association [NFPA], 2000, 4.1.4.1). This indicates that if OSFM wants to obtain
                                                                                                11


IFSAC accreditation for its HMT program it must adopt NFPA 472 to do so. Accreditation will

help OSFM justify why NFPA 472 needs to be used. If it is not, IFSAC accreditation cannot be

obtained. This assures that a single, standardized competency will be used as a minimum to

certify Type II HMT.

       How will minimum competency standards for Type II HMT benefit the citizens of NC?

The third research question was studied from a customer service viewpoint. In the feedback

form given to the Hazardous Materials Certification Sub-Committee, one question asked if a

standardized competency would help in mitigating incidents when multiple HMT’s were

dispatched. Figure one shows that four committee members felt that standardized competencies

would help mitigate incidents where multiple teams were operating, and three indicated that they

did not feel it would help. As indicated by research of Gordon Graham’s information, any time

incidents occur and emergency responders fail to perform to a competent level, a lawsuit will

incur (Graham, 2002). The people that pay for these lawsuits will be the citizens of NC.

Figure 1

Do you think training all responders to the same standard will improve the way incidents are

mitigated when multiple teams are dispatched? N=7


      2


                                                                                      No
      1
                                                                                      Yes


      0
             Member Member Member Member Member Member Member
               1      2      3      4      5      6      7
                                                                                                   12


       Another aspect that is important to the citizens is that of life safety and environmental

impact. Lives will be lost if responders do not possess the necessary skills to effectively respond

to these types of emergencies. Environmental impact could be more effectively controlled if

responders are prepared and trained to protect natural resources such as water, forests, land, and

property. A standardized minimum competency that is established on a statewide basis could

have a positive impact according to this feedback instrument.

                                            Discussion

       The first research question of what does a minimum competency standard provide an

occupation was clearly answered. The researcher noted many professions where standardized

competencies were utilized. OSHA is law, and since it is a federal law states must follow it as a

minimum (OSHA, 1991, 1). Since NC operates its own OSHA program, responders must, by

law, meet the intent of this law. OSHA can also use nationally recognized professional

consensus standards. NFPA 472 represents such a standard, and OSHA can judge jurisdictions

using this standardized competency. A standardized competency also ensures that at least a

baseline knowledge was achieved by students, and that all students who participate in the course

will be given the same information each time (NFPA, 2002, 1.1.2). NFPA also states that one

purpose of the competencies contained shall be to reduce the number of accidents, injuries, and

illnesses during response emergencies (NFPA, 2002, 1.2.2). Gordon Graham also states in his

material that it is imperative that responders train every day, using verifiable means and

professional standards as a guide to follow (Graham, 2002). It is clear that NC needs to

standardize competencies and adopt NFPA 472 according to the analysis that this researcher has

completed. This standardization will assist responders in the state by ensuring that all are trained

to a minimum competency and that training will be based on federal law and a nationally
                                                                                                  13


recognized consensus standard. Implications for not adopting a standard competency for Type II

HMT’s are far reaching. Concerns include responder safety and competency to do the job, as

well as legal ramifications.

       The ways (IFSAC) accreditation of a HMT training program can help standardize

competencies for Type II HMT were clear to the author. Bradley states that IFSAC requires a

minimum competency be used to certify any individual within a certification system (T.L.

Bradley personal communication July 17, 2003). It is IFSAC assertion that a minimum basis is

needed within a system to ensure a level of competency is reached and that the person being

certified meets those criteria. Bradley also says that even though minimum criteria for the job

classification is an evaluation instrument for certification to a job standard, IFSAC fully

recognizes that some certifying entities, as well as local authorities having jurisdiction, may well

exceed any minimum criteria in the job requirements (T.L. Bradley personal communication July

17, 2003). Accreditation will help standardize competencies by demanding that a nationally

recognized professional competency be used (NFPA, 2000, 1.1.2). The American Educational

Research Association’s (AERA) stance on standards indicates they are a reference to assure that

relevant issues are addressed within a given subject or area (American Educational Research

Association [AERA], 1999, 2). This portion of the research indicates that IFSAC will ensure

that any program that is accredited will follow a standard. Accreditation will not be granted if a

entity does not meet the minimum criteria with a selected professional competency and all other

mandates of the accrediting body. The implications of not obtaining IFSAC accreditation are

that the program will lack credibility, and a minimum baseline of knowledge will not be

delivered, learned, and tested.
                                                                                                   14


       Minimum competency standards for Type II HMT will benefit the citizens of NC by

ensuring responders are adequately trained. Gordon Graham states that every employer has a

duty to train and that any training that is done should occur every day, to a standard, and when

mistakes are made they should be shared in a non-punitive atmosphere with others (Graham,

2002). Graham indicates that this should be done so that others can learn from mistakes and

changes can occur to prevent them in the future. This question is simply answered using the

facts that were researched. That answer is those responders must be trained to effectively

respond to incidents and minimize damage to life, property, and the environment. This training

must be comprehensive, obtainable, and available. The benefits to the citizens of NC are

obvious—trained, competent responders protect their lives, property, and environment. Also, it

reduces the chances of litigation against a public service entity that ultimately costs the taxpayer.

If NC does not adopt a standardized competency, we cannot ensure that the responders we train

will have adequate knowledge to respond to the needs of the citizens.

                                             Recommendations

       With the results from this study, it is obvious why a minimum standardized competency

is needed when training HMT. First, there would be a standard competency taught to all

members of a HMT. Second, through the use of IFSAC accreditation, NC can assure the

responders being trained that the competencies being taught are standardized and meet a

minimum nationally recognized standard. Finally, the citizens can be assured that adequate

service delivery from the use of a standardized competency will help in protecting them from the

impact of lawsuits and damage to their property and the environment.

       OSFM now needs to write a curriculum using the nationally recognized NFPA 472

standard and have this program accredited by IFSAC. The need for this can be justified through
                                                                                                 15


the findings of this research. IFSAC accreditation also needs to be obtained so that NC citizens

have the assurance that the members of HMT have obtained a baseline knowledge, and all

functioning members on the team have successfully completed a standardized, structured

program. The above changes will be valuable, in that all aspects of the state’s training for HMT

personnel will be standardized and accredited, and the citizens of this state will have protection

from these incidents involving hazardous materials.

       Future readers need to study what effect standardized competencies for HMT’s has had

on incident response from the standpoint of how effective the mitigation efforts were, and if they

met recommended practices due to training received in the IFSAC program. Another area of

study should be whether or not the occurrences of negative environmental impact decreased or

increased. Have the number of lawsuits due to responder negligence declined? College transfer

credits also need to be considered for those students who have been awarded certification from

an accredited agency.
                                                                                               16


                                          References

American Educational Research Association (1999). Standards for Educational and

       Psychological Testing. Washington, DC: Author.

American Psychological Association (2003, July 17, 2003). Standards for Education. Retrieved

       July 17, 2003, www.apa.org/science/standards.htm

Centella, T. D. (1994). Position Paper for Consistency in Training Standards. ASPEP Journal,

       275-278.

Graham, G. (2002). Non-Punitive Close-Call Reporting. Retrieved July 17, 2003,

       www.gordongraham.com/cgi-bin/sitenav.cgi?

International Fire Service Accreditation Congress (1998). IFSAC Handbook (6th ed.). Stillwater,

       OK: Author.

International Fire Service Accreditation Congress (1998). IFSAC Handbook (6th ed.). Stillwater,

       OK: Author.

National Fire Academy (2001). Executive Analysis of Fire Service Operations in Emergency

       Management. Emmitsburg Maryland: Author.

National Fire Protection Association (2000). Standard for Fire Service Professional

       Qualifications Accreditation and Certification Systems (2000 ed.). Quincy, MA: Author.

National Fire Protection Association (2002). NFPA 472 Standard for Professional Competence

       of Responders to Hazardous Materials Incidents (2002 ed.). Quincy, MA: Author.

North Carolina Emergency Management (2002). Hazardous Materials Team Typing Guide.

       Raleigh, NC: Author.

North Carolina Fire and Rescue Commission (1992). Hazardous Materials Certification

       Guidelines. Raleigh, NC: Author.
                                                                                        17


Occupational Safety and Health Administration (1991). Hazardous Waste Operations and

      Emergency Response Standard (Final Rule). Raleigh, NC: Division of Occupational

      Safety and Health.
                                                                                          18


                                         Appendix A
                                       NCEM Typing Guide

       Guide for the Typing of Hazardous Materials Emergency Response Teams in
                                     North Carolina

I.        Purpose

          To provide standards and guidance for typing of hazardous material response
          teams (HazMat teams) into levels of functionality. This will establish minimum
          criteria for designation as a “HazMat Team,” and provide assistance to incident
          commanders when requesting additional appropriately-trained and equipped
          resources.


II.       Authority and References

          A. North Carolina General Statute 166A, Article 2
          B. Occupational Safety and Health Administration (OSHA) standard for
                Hazardous Waste Operations and Emergency Response, 29 C.F.R.
                1910.120
          C. Environmental Protection Agency (EPA) Worker Protection Standards for
                Hazardous Waste Operations and Emergency Response, 40 C.F.R. 311
          D. National Fire Protection Association (NFPA) Standard 471, Recommended
                Practice for Responding to Hazardous Materials Incidents
          E. National Fire Protection Association Standard 472, Professional Competence
                of Responders to Hazardous Materials Incidents
          F. National Fire Protection Association Standard 473, Competencies for EMS
                Personnel Responding to Hazardous Materials Incidents.
          G. North Carolina Division of Emergency Management, Regional Response
                Team Standard Operating Guidelines.


III.      Training Of HazMat Team Members

          A.    HazMat Awareness

                1.     The HazMat Awareness certification consists of a minimum of 14
                       hours of course work. Subjects that will be covered are recognition,
                       identification, notifying proper resources, public and self-protection
                       measures. In order to be certified at this level, a person must
                       successfully pass a practical and written exam with a minimum
                       score of 70%. This program meets all the requirements of NFPA
                       472 1997 edition and is IFSAC Accredited.
                                                                                       19


      B.     HazMat Operations

             1.      The HazMat Operations certification consists of a minimum of 32
                     hours of course work. A person must have already completed the
                     HazMat Awareness before taking Operations. Advanced
                     recognition, identification, decontamination, and defensive
                     measures are covered in the course. In order to be certified at this
                     level, a person must successfully pass a practical and written exam
                     with a minimum score of 70%. This program meets all the
                     requirements of NFPA 472 1997 edition and is IFSAC Accredited.

             2.      The State of North Carolina Fire and Rescue Commission has
                     adopted a stricter amount of training to be certified as a “State
                     HazMat Technician.” Before a person can be certified at this level
                     all components of the certification must be met and approved by
                     the NC Fire and Rescue Commission’s HazMat Sub-Committee
                     This level of certification requires, in addition to paragraph 1
                     (above):

                     a.    NC DOI HazMat Technician
                     b.    NFA Chemistry of Hazardous Materials or Equivalent

             3.      Several federal agencies offer a track of training for hazardous
                     materials responders to WMD incidents. In addition to certification
                     as a State HazMat Technician, personnel assigned to HazMat
                     teams which will respond to WMD incidents shall also be trained to
                     the WMD Technician-level, under courses administered by the US
                     Departments of Defense or Justice, or FEMA’s National Fire
                     Academy

IV.   HazMat Team Structure

      A.   General

           1. A Hazardous Material Response Team shall consist of the following
              number and categories of personnel in order to receive and maintain
              typing. A HazMat team should have more than these minimum numbers
              of personnel available for potential dispatch.

           2. Hazardous material response team specialization is needed to mitigate
              most hazardous material incidents. Specially trained personnel with
              appropriate personal protective equipment, special monitoring
              equipment, full decontamination capabilities, and demonstrated
              experience and ability are needed. Personnel must be able to adequately
              understand chemical, radiological and toxicological hazards safety and
              mitigation information. The HazMat team must have available special,
              advanced containment and control equipment. Personnel must also be
                                                                                 20


        trained to a level of competency to perform mechanical tasks to
        successfully stop leaks and deal with related situations. Access to
        additional resources, such as licensed physicians, chemists, radiologists
        and toxicologists, and backup equipment and supplies must be
        immediately available.

     3. It must be understood that an undetermined number of support personnel
        from private or public sector emergency response organizations may also
        be needed to bring a hazardous material incident to a successful and
        safe conclusion. Additional considerations may include public protective
        action for threatened persons near a spill or leak (i.e. evacuation or
        sheltering in place), and advising the public of the potential threat from
        the hazardous material release. These various emergency response
        actions notwithstanding, a hazardous material response team must
        consist of the following number and categories of personnel in order to
        be typed as a HazMat Team.

B.     The minimum required personnel complement a HazMat team must be
       able to dispatch to a HazMat incident as a team is:

                    1. HazMat Team Leader - Technician Level
                    2. HazMat Operations Officer - Technician Level
                    3. Site Entry Persons - Technician Level
                    4. Back-up Site Entry Persons - Technician Level
                    5. Decontamination Persons - Operations or Technician
                       Level
                    6. Medical Surveillance Person - EMT or greater, and
                       Operations Level
                    7. HazMat Safety Person - Technician Level

       NOTE: Medical personnel serving as part of or in support of a HazMat
       team should be trained and qualified in accordance with NFPA Standard
       473, Competencies for EMS Personnel Responding to Hazardous
       Materials Incidents.

C.     Additional Support and Resource Personnel for HazMat Teams

                    1. On-call decontamination persons, operations level

                    2. Specialist Employees: explosives specialist, metallurgical
                       specialists, toxicological specialists, engineering
                       specialists, chemical specialists, biological specialists.
                       List any of these specialists on the team roster.
                    3. Radiological specialist employees (must be available on
                       call, reside in the county of operation, or be a skill level
                                                                                       21


                              attained by one of the dispatched team members and
                              listed on the HazMat team roster)

                           4. Qualified Radiological Officer (RO)

                           5. Qualified Radiological Response Team members
                              (separate from RO)

                           6. NCOEMS-licensed EMT-Paramedic available through
                              local, county or Advanced Life Support (ALS) service.

       C.     Specific Staffing Requirements Based on Type (see attachment 1)


V.     HazMat Team Dispatch And Response

       A.   Response Time of a Team

            Under normal circumstances and weather conditions a team must be able to
            respond, with required minimum personnel complement, within 30 minutes
            from dispatch.


VI.    Incident Command System (ICS)

       A.   Incident Command Structure.

            In accordance with federal regulations, an Incident Command System must
            be activated at the scene of all hazardous material incidents. There are
            several national and numerous local incident command systems. The federal
            regulation (29 CFR 1910.120) calls for an "On-Scene Incident Commander."

VII.   HazMat Team Equipment List

       The following is a list of equipment required to be typed as a HazMat Team in
       North Carolina. Specific types and quantities are described in attachment 2.

       A.     References

       B.     Personal Protective Equipment

       C.     Leak Control Equipment

       D.     Fire Suppression Equipment

       D.     Tools
                                                                                        22



      E.    Containment Equipment

      G.    Monitoring and Detection Equipment

      H.    Decontamination Equipment

      I.    Communications Equipment

      J.    Special Equipment

      K.    Miscellaneous Equipment

      L.    Vehicles


XI.   HazMat Team Typing

      A.    HazMat teams shall be typed according to the following format

            1.    Type I - shall be capable of response to incidents up to Level 3
                  incidents, which may involve weapons of mass destruction and
                  hazardous materials.
            2.    Type II - shall be capable of response to incidents up to Level 3,
                  which may involve hazardous materials incidents only.
            3.    Type III - shall be capable of response to incidents up to Level 1,
                  which may involve oil/petroleum products only.

      B.    HazMat teams shall type themselves, based on the following criteria:

            1. Training requirements for team members, including medical
               surveillance program
            2. Staffing patterns
            3. HazMat equipment


X.    Glossary Of Terms And Abbreviations

      EMI - Emergency Management Institute

      EOC - Emergency Operations Center

      EPA - U. S. Environmental Protection Agency

      FEMA - Federal Emergency Management Agency

      ICS - Incident Command System based on NMIS.
                                                                                  23



INCIDENT - Any occurrence which causes the use of emergency resources.

INCIDENT COMMANDER (ON-SCENE) - The person responsible for overall
coordinating of all response operations at a hazardous material emergency
scene.

LEVEL III INCIDENT - Incidents which require special resources (technician level
of certification) and other outside resources for support.

LEVEL II INCIDENT - Incidents which require special resources (technician level
of certification) for control/stabilization.

LEVEL I INCIDENT - Incidents which can be readily controlled/stabilized by
trained and equipped first responders at the operations level of certification.

MINIMUM REQUIRED PERSONNEL COMPLEMENT - The number and
categories of personnel necessary for a HazMat team to function as a HazMat
Team in North Carolina.

NFA - National Fire Academy

NFPA - National Fire Protection Association

NCEM - North Carolina Division of Emergency Management

NC DOI - North Carolina Department of Insurance.

OSHA - Occupational Safety and Health Administration.

RRT - North Carolina Hazardous Materials Regional Response Team

SAFETY OFFICER - The Hazardous Materials Team Safety Officer as described
in NFPA 472.

SARA TITLE III - Title III of the Superfund Amendments and Reauthorization Act
of 1986, entitled "Emergency Planning and Community Right-to-Know Act.”
Specifies requirements for an organizing and planning process at state and local
levels for specified extremely hazardous substances, minimum plan content,
requirements for fixed facility owners and operators to inform officials about
extremely hazardous substances present at the facility and mechanisms for
making information about extremely hazardous substances available to citizens.

     WMD - Weapon of mass destruction; used in terrorist incidents.
                                                                                                   24


                                           Appendix B
           The Need for Standardized Hazardous Materials Technician Competencies

             Questionnaire for NC Hazardous Materials Certification Sub Committee


1.     Do you as a member of the certification sub committee feel that it is beneficial to train
       responders to the same competencies? Yes / No

2.     Do you think training all responders to the same standard will improve the way incidents
       are mitigated when multiple teams are dispatched? Yes / No

3.     Should the sub-committee adopt the current NFPA 472 standard as its standardized
       competency for Hazardous Materials Technicians? Yes / No

Thank you for your time.
                                                                           25


                                                          Appendix C

                                            NFPA 472 Scope and Chapter 6

Chapter 1 Administration
1.1 Scope.
1.1.1 This standard shall identify the levels of competence required
of responders to hazardous materials incidents.
1.1.2 This standard shall cover the competencies for first responders
at the awareness level, first responders at the operational
level, hazardous materials technicians, incident commanders,
hazardous materials branch officers, hazardous materials
branch safety officers, and other specialist employees.
1.2 Purpose.
1.2.1 The purpose of this standard shall be to specify minimum
competencies for those who will respond to hazardous
materials incidents.
1.2.2 One purpose of the competencies contained herein
shall be to reduce the numbers of accidents, injuries, and illnesses
during response to hazardous materials incidents and
to help prevent exposure to hazardous materials to reduce the
possibility of fatalities, illness, and disabilities affecting emergency
response personnel.
1.3 Application. It shall not be the intent of this standard to
restrict any jurisdiction from exceeding these minimum requirements.
                                                                                                                    26


                                                   Appendix D

                    OSHA Scope, Application, Definitions, and Training Sections

Sec. 1910.120 Hazardous waste operations and emergency response.

(a) Scope, application, and definitions--

    (1) Scope. This section covers the following operations, unless the employer can demonstrate that the operation
does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards:

        (i) Clean-up operations required by a governmental body, whether Federal, state, local or other involving
        hazardous substances that are conducted at uncontrolled hazardous waste sites (including, but not limited
        to, the EPA's National Priority Site List (NPL), state priority site lists, sites recommended for the EPA
        NPL, and initial investigations of government identified sites which are conducted before the presence or
        absence of hazardous substances has been ascertained);

        (ii) Corrective actions involving clean-up operations at sites covered by the Resource conservation and
        Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);

        (iii) Voluntary clean-up operations at sites recognized by Federal, state, local or other governmental bodies
        as uncontrolled hazardous waste sites;

        (iv) Operations involving hazardous wastes that are conducted at treatment, storage, and disposal (TSD)
        facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with
        U.S.E.P.A. to implement RCRA regulations; and

        (v) Emergency response operations for releases of, or substantial threats of releases of, hazardous
        substances without regard to the location of the hazard.

        (2) Application.

        (i) All requirements of Part 1910 and Part 1926 of Title 29 of the Code of Federal Regulations apply
        pursuant to their terms to hazardous waste and emergency response operations whether covered by this
        section or not. If there is a conflict or overlap, the provision more protective of employee safety and health
        shall apply without regard to 29 CFR 1910.5(c)(1)

        (ii) Hazardous substance clean-up operations within the scope of paragraphs (a)(1)(i) through (a)(1)(iii) of
        this section must comply with all paragraphs of this section except paragraphs (p) and (q).

        (iii) Operations within the scope of paragraph (a)(1)(iv) of this section must comply only with the
        requirements of paragraph (p) of this section.

Notes and Exceptions:

        (A) All provisions of paragraph (p) of this section cover any treatment, storage or disposal (TSD) operation
        regulated by 40 CFR parts 264 and 265 or by state law authorized under RCRA, and required to have a
        permit or interim status from EPA pursuant to 40 CFR 270.1 or from a state agency pursuant to RCRA.

        (B) Employers who are not required to have a permit or interim status because they are conditionally
        exempt small quantity generators under 40 CFR 261.5 or are generators who qualify under 40 CFR 262.34
        for exemptions from regulation under 40 CFR parts 264, 265 and 270 ("excepted employers") are not
        covered by paragraphs (p)(1) through (p)(7) of this section. Excepted employers who are required by the
        EPA or state agency to have their employees engage in emergency response or who direct their employees
        to engage in emergency response are covered by paragraph (p)(8) of this section, and cannot be exempted
                                                                                                            27

by (p)(8)(i) of this section. Excepted employers who are not required to have employees engage in
emergency response, who direct their employees to evacuate in the case of such emergencies and who meet
the requirements of paragraph (p)(8)(i) of this section are exempt from the balance of paragraph (p)(8) of
this section.

(C) If an area is used primarily for treatment, storage or disposal, any emergency response operations in
that area shall comply with paragraph (p)(8) of this section. In other areas not used primarily for treatment,
storage, or disposal, any emergency response operations shall comply with paragraph (q) of this section.
Compliance with the requirements of paragraph (q) of this section shall be deemed to be in compliance
with the requirements of paragraph (p)(8) of this section.

(iv) Emergency response operations for releases of, or substantial threats of releases of, hazardous
substances which are not covered by paragraphs (a)(1)(i) through (a)(1)(iv) of this section must only
comply with the requirements of paragraph (q) of this section.

(3) Definitions--"Buddy system" means a system of organizing employees into work groups in such a
manner that each employee of the work group is designated to be observed by at least one other employee
in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the
event of an emergency.
"Clean-up operation" means an operation where hazardous substances are removed, contained, incinerated,
neutralized, stabilized, cleared-up, or in any other manner processed or handled with the ultimate goal of
making the site safer for people or the environment.
"Decontamination" means the removal of hazardous substances from employees and their equipment to the
extent necessary to preclude the occurrence of foreseeable adverse health affects.
"Emergency response" or "responding to emergencies" means a response effort by employees from
outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local
fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release
of a hazardous substance. Responses to incidental releases of hazardous substances where the
substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in
the immediate release area, or by maintenance personnel are not considered to be emergency
responses within the scope of this standard. Responses to releases of hazardous substances where
there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not
considered to be emergency responses.
"Facility" means (A) any building, structure, installation, equipment, pipe or pipeline (including any pipe
into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment, ditch, storage
container, motor vehicle, rolling stock, or aircraft, or (B) any site or area where a hazardous substance has
been deposited, stored, disposed of, or placed, or
otherwise come to be located; but does not include any consumer product in consumer use or any water-
borne vessel.
"Hazardous materials response (HAZMAT) team" means an organized group of employees,
designated by the employer, who are expected to perform work to handle and control actual or
potential leaks or spills of hazardous substances requiring possible close approach to the substance.
The team members perform responses to releases or potential releases of hazardous substances for
the purpose of control or stabilization of the incident. A HAZMAT team is not a fire brigade nor is a
typical fire brigade a HAZMAT team. A HAZMAT team, however, may be a separate component of
a fire brigade or fire department.

"Hazardous substance" means any substance designated or listed under paragraphs (A) through (D) of this
definition, exposure to which results or may result in adverse affects on the health or safety of employees:
(A) Any substance defined under section 101(14) of CERCLA;
(B) Any biological agent and other disease-causing agent which after release into the environment and
upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment
or indirectly by ingestion through food chains, will or may reasonably be anticipated to cause death,
disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including
malfunctions in reproduction) or physical deformations in such persons or their offspring;
                                                                                                                   28

         (C) Any substance listed by the U.S. Department of Transportation as hazardous materials under 49 CFR
         172.101 and appendices; and
         (D) Hazardous waste as herein defined.

         "Hazardous waste" means--
         (A) A waste or combination of wastes as defined in 40 CFR 261.3, or
         (B) Those substances defined as hazardous wastes in 49 CFR 171.8.
         "Hazardous waste operation" means any operation conducted within the scope of this standard.
         "Hazardous waste site" or "Site" means any facility or location within the scope of this standard at which
         hazardous waste operations take place.
“Health hazard" means a chemical, mixture of chemicals or a pathogen for which there is statistically significant
evidence based on at least one study conducted in accordance with established scientific principles that acute or
chronic health effects may occur in exposed employees.

The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive
toxins, irritants, corrosives, sensitizers, heptaotoxins, nephrotoxins, neurotoxins, agents which act on the
hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. It also includes stress
due to temperature extremes. Further definition of the terms used above can be found in Appendix A to 29 CFR
1910.1200.

"IDLH" or "Immediately dangerous to life or health" means an atmospheric concentration of any toxic, corrosive or
asphyxiant substance that poses an immediate threat to life or would cause irreversible or delayed adverse health
effects or would interfere with an individual's ability to escape from a dangerous atmosphere.

"Oxygen deficiency" means that concentration of oxygen by volume below which atmosphere supplying respiratory
protection must be provided. It exists in atmospheres where the percentage of oxygen by volume is less than 19.5
percent oxygen.

"Permissible exposure limit" means the exposure, inhalation or dermal permissible exposure limit specified in 29
CFR Part 1910, Subparts G and Z.

"Published exposure level" means the exposure limits published in "NIOSH Recommendations for Occupational
Health Standards" dated 1986 incorporated by reference, or if none is specified, the exposure limits published in the
standards specified by the American Conference of Governmental Industrial Hygienists in their publication

"Threshold Limit Values and Biological Exposure Indices for 1987-88" dated 1987 incorporated by reference.

"Post emergency response" means that portion of an emergency response performed after the immediate
threat of a release has been stabilized or eliminated and clean-up of the site has begun. If post emergency
response is performed by an employer's own employees who were part of the initial emergency response, it is
considered to be part of the initial response and not post emergency response. However, if a group of an
employer's own employees, separate from the group providing initial response, performs the clean-up
operation, then the separate group of employees would be considered to be performing post-emergency
response and subject to paragraph (q)(11) of this section.

"Qualified person" means a person with specific training, knowledge and experience in the area for which the person
has the responsibility and the authority to control.

"Site safety and health supervisor (or official)" means the individual located on a hazardous waste site who is
responsible to the employer and has the authority and knowledge necessary to implement the site safety and health
plan and verify compliance with applicable safety and health requirements.

"Small quantity generator" means a generator of hazardous wastes who in any calendar month generates no more
than 1,000 kilograms (2,205 pounds) of hazardous waste in that month.
                                                                                                                      29

"Uncontrolled hazardous waste site," means an area identified as an uncontrolled hazardous waste site by a
governmental body, whether Federal, state, local or other where an accumulation of hazardous substances creates a
threat to the health and safety of individuals or the environment or both.
Some sites are found on public lands such as those created by former municipal, county or state landfills where
illegal or poorly managed waste disposal has taken place. Other sites are found on private property, often belonging
to generators or former generators of hazardous substance wastes.
Examples of such sites include, but are not limited to, surface impoundments, landfills, dumps, and tank or drum
farms. Normal operations at TSD sites are not covered by this definition.

(b) Safety and health program.
Note to (b): Safety and health programs developed and implemented to meet other Federal, state, or local
regulations are considered acceptable in meeting this requirement if they cover or are modified to cover the topics
required in this paragraph. An additional or separate safety and health program is not required by this paragraph.

(1) General.
        (i) Employers shall develop and implement a written safety and health program for their employees
        involved in hazardous waste operations. The program shall be designed to identify, evaluate, and control
        safety and health hazards, and provide for emergency response for hazardous waste operations.
        (ii) The written safety and health program shall incorporate the following:
                            (A) An organizational structure;
                            (B) A comprehensive workplan;
                            (C) A site-specific safety and health plan which need not repeat the employer's standard
                            operating procedures required in paragraph (b)(1)(ii)(F) of this section;
                            (D) The safety and health training program;
                            (E) The medical surveillance program;
                            (F) The employer's standard operating procedures for safety and health; and
                            (G) Any necessary interface between general program and site specific activities.
        (iii) Site excavation. Site excavations created during initial site preparation or during hazardous waste
        operations shall be shored or sloped as appropriate to prevent accidental collapse in accordance with
        Subpart P of 29 CFR Part 1926.
        (iv) Contractors and sub-contractors. An employer who retains contractor or sub-contractor services for
        work in hazardous waste operations shall inform those contractors, sub-contractors, or their representatives
        of the site emergency response procedures and any potential fire, explosion, health, safety or other hazards
        of the hazardous waste operation that have been identified by the employer, including those identified in
        the employer's information program.
        (v) Program availability. The written safety and health program shall be made available to any contractor or
        subcontractor or their representative who will be involved with the hazardous waste operation; to
        employees; to employee designated representatives; to OSHA personnel, and to personnel of other Federal,
        state, or local agencies with regulatory authority over the site.
        (2) Organizational structure part of the site program.--
        (i) The organizationa1 structure part of the program shall establish the specific chain of command and
        specify the overall responsibilities of supervisors and employees. It shall include, at a minimum, the
        following elements:
                            (A) A general supervisor who has the responsibility and authority to direct all hazardous
                            waste operations.
                            (B) A site safety and health supervisor who has the responsibility and authority to
                            develop and implement the site safety and health plan and verify compliance.
                            (C) All other personnel needed for hazardous waste site operations and emergency
                            response and their general functions and responsibilities.
                            (D) The lines of authority, responsibility, and communication.
        (ii) The organizational structure shall be reviewed and updated as necessary to reflect the current status of
        waste site operations.
        (3) Comprehensive workplan part of the site program. The comprehensive workplan part of the program
        shall address the tasks and objectives of the site operations and the logistics and resources required to reach
        those tasks and objectives.
                                                                                                                  30

       (i) The comprehensive workplan shall address anticipated clean-up activities as well as normal operating
       procedures which need not repeat the employer's procedures available elsewhere.
       (ii) The comprehensive workplan shall define work tasks and objectives and identify the methods for
       accomplishing those tasks and objectives.
       (iii) The comprehensive workplan shall establish personnel requirements for implementing the plan.
       (iv) The comprehensive workplan shall provide for the implementation of the training required in
       paragraph (e) of this section.
       (v) The comprehensive workplan shall provide for the implementation of the required informational
       programs required in paragraph (i) of this section.
       (vi) The comprehensive workplan shall provide for the implementation of the medical surveillance program
       described in paragraph (f) of this section.
       (4) Site-specific safety and health plan part of the program.--
                 (i) General. The site safety and health plan, which must be kept on site, shall address the safety
                 and health hazards of each phase of site operation and include the requirements and procedures for
                 employee protection.
                 (ii) Elements. The site safety and health plan, as a minimum, shall address the following:
                            (A) A safety and health risk or hazard analysis for each site task and operation found in
                            the workplan.
                            (B) Employee training assignments to assure compliance with paragraph (e) of this
                            section.
                            (C) Personal protective equipment to be used by employees for each of the site tasks and
                            operations being conducted as required by the personal protective equipment program in
                            paragraph (g)(5) of this section.
                            (D) Medical surveillance requirements in accordance with the program in paragraph (f) of
                            this section.
                            (E) Frequency and types of air monitoring, personnel monitoring, and environmental
                            sampling techniques and instrumentation to be used, including methods of maintenance
                            and calibration of monitoring and sampling equipment to be used.
                            (F) Site control measures in accordance with the site control program required in
                            paragraph (d) of this section.
                            (G) Decontamination procedures in accordance with paragraph (k) of this section.
                            (H) An emergency response plan meeting the requirements of paragraph (l) of this
                            section for safe and effective responses to emergencies, including the necessary PPE and
                            other equipment.
                            (I) Confined space entry procedures.
                            (J) A spill containment program meeting the requirements of paragraph (j) of this section.
                  (iii) Pre-entry briefing. The site specific safety and health plan shall provide for pre-entry
                 briefings o be held prior to initiating any site activity, and at such other times as necessary to
                 ensure that employees are apprised of the site safety and health plan and that this plan is being
                 followed. The information and data obtained from site characterization and analysis work
                 required in paragraph (c) of this section shall be used to prepare and update the site safety and
                 health plan.
                 (iv) Effectiveness of site safety and health plan. Inspections shall be conducted by the site safety
                 and health supervisor or, in the absence of that individual, another individual who is
                 knowledgeable in occupational safety and health, acting on behalf of the employer as necessary to
                 determine the effectiveness of the site safety and health plan. Any deficiencies in the
                 effectiveness of the site safety and health plan shall be corrected by the employer.

(e) Training--
        (1) General.
                (i) All employees working on site (such as but not limited to equipment operators, general laborers
                and others) exposed to hazardous substances, health hazards, or safety hazards and their
                supervisors and management responsible for the site shall receive training meeting the
                requirements of this paragraph before they are permitted to engage in hazardous waste operations
                that could expose them to hazardous substances, safety, or health hazards, and they shall receive
                review training as specified in this paragraph.
                                                                                                             31

          (ii) Employees shall not be permitted to participate in or supervise field activities until they have
          been trained to a level required by their job function and responsibility.
(2) Elements to be covered. The training shall thoroughly cover the
following:
          (i) Names of personnel and alternates responsible for site safety and health;
          (ii) Safety, health and other hazards present on the site;
          (iii) Use of personal protective equipment;
          (iv) Work practices by which the employee can minimize risks from hazards;
          (v) Safe use of engineering controls and equipment on the site;
          vi) Medical surveillance requirements, including recognition of symptoms and signs which might
          indicate overexposure to hazards; and
          (vii) The contents of paragraphs (G) through (J) of the site safety and health plan set forth in
          paragraph (b)(4)(ii) of this section.
(3) Initial training.
            (i) General site workers (such as equipment operators, general laborers and supervisory
            personnel) engaged in hazardous substance removal or other activities which expose or
            potentially expose workers to hazardous substances and health hazards shall receive a minimum
            of 40 hours of instruction off the site, and a minimum of three days actual field experience under
            the direct supervision of a trained, experienced supervisor.
           (ii) Workers on site only occasionally for a specific limited task (such as, but not limited to,
          ground water monitoring, land surveying, or geo- physical surveying) and who are unlikely to be
          exposed over permissible exposure limits and published exposure limits shall receive a minimum
          of 24 hours of instruction off the site, and the minimum of one day actual field
          experience under the direct supervision of a trained, experienced supervisor.
          (iii) Workers regularly on site who work in areas which have been monitored and fully
          characterized indicating that exposures are under permissible exposure limits and published
          exposure limits where respirators are not necessary, and the characterization indicates that there
          are no health hazards or the possibility of an emergency developing, shall receive a minimum of
          24 hours of instruction off the site and the minimum of one day actual field experience under the
          direct supervision of a trained, experienced supervisor.
          (iv) Workers with 24 hours of training who are covered by paragraphs (e)(3)(ii) and (e)(3)(iii) of
          this section, and who become general site workers or who are required to wear respirators, shall
          have the additional 16 hours and two days of training necessary to total the training specified in
          paragraph (e)(3)(i).
(4) Management and supervisor training. On-site management and supervisors directly responsible for, or
who supervise employees engaged in, hazardous waste operations shall receive 40 hours initial training,
and three days of supervised field experience (the training may be reduced to 24 hours and one day if the
only area of their responsibility is employees covered by paragraphs (e)(3)(ii) and (e)(3)(iii)) and at least
eight additional hours of specialized training at the time of job assignment on such topics as, but not
limited to, the employer's safety and health program and the associated employee training program,
personal protective equipment program, spill containment program, and health hazard monitoring
procedure and techniques.
(5) Qualifications for trainers. Trainers shall be qualified to instruct employees about the subject matter that
is being presented in training. Such trainers shall have satisfactorily completed a training program for
teaching the subjects they are expected to teach, or they shall have the academic credentials and
instructional experience necessary for teaching the subjects. Instructors shall demonstrate competent
instructional skills and knowledge of the applicable subject matter.
(6) Training certification. Employees and supervisors that have received and successfully completed the
training and field experience specified in paragraphs (e)(1) through (e)(4) of this section shall be certified
by their instructor or the head instructor and trained supervisor as having successfully completed the
necessary training. A written certificate shall be given to each person so certified. Any person who has not
been so certified or who does not meet the requirements of paragraph (e)(9) of this section
shall be prohibited from engaging in hazardous waste operations.
(7) Emergency response. Employees who are engaged in responding to hazardous emergency
situations at hazardous waste clean-up sites that may expose them to hazardous substances shall be
trained in how to respond to such expected emergencies.
                                                                                                              32

(8) Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and
supervisors specified in paragraph (e)(4) of this section, shall receive eight hours of refresher training
annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, any critique of incidents
that have occurred in the past year that can serve as training examples of related work, and other relevant
topics.
(9) Equivalent training. Employers who can show by documentation or certification that an employee's
work experience and/or training has resulted in training equivalent to that training required in paragraphs
(e)(1) through (e)(4) of this section shall not be required to provide the initial training requirements of those
paragraphs to such employees and shall provide a copy of the certification or documentation to the
employee upon request. However, certified employees or employees with equivalent training new to a site
shall receive appropriate, site specific training before site entry and have appropriate supervised field
experience at the new site. Equivalent training includes any academic training or the training that existing
employees might have already received from actual hazardous waste site work experience.