Title 29 of the Code of Federal Regulations, Section 1910.38 (29 CFR 1910.38) requires an employee emergency plan and fire prevention plan. This requires specific information such as emergency escape plans, procedures for employees who remain to operate critical plant equipment, accountability procedures, reporting a plant fire, and an alarm system to notify employees of an emergency and alert emergency team members.

Section 1910.156 describes minimum requirements for the organization, training and personal protective equipment for fire brigades. Each industry must have a statement or written policy establishing what type fire brigade and fire emergency plan it has. The employer with a fire brigade must have an organizational statement which establishes the basic organizational structure, the type, amount and frequency of training to be provided to the brigade, the expected number of members, and the function the fire brigade is to perform in the workplace.

OSHA regulations outline fire brigade requirements but do not require emergency response and the type fire brigade an industry can provide:

1. No fire brigade. Should a fire occur, procedures outline who is to be notified to sound the alarm, and employees will evacuate the plant in accordance with the plant emergency evacuation plan. The off-site fire department will be promptly notified. No employees will fight the fire evacuation plan. The off-site fire department will be promptly notified. No employees will fight the fire.

2. Incipient fire brigade. Those employees who have been properly trained to use fire extinguishers and/or small hoses up to 1 1/2" to fight small incipient stage fires. These employees must be trained to recognize when a fire is larger than an incipient fire or when smoke creates a safety hazard to personnel, and they must not fight the fire but shall evacuate the area. The employer is not required to provide protective clothing and SCBA for the incipient fire brigade members, and the incipient brigade members shall not use protective clothing or SCBA when fighting a fire because they have not been trained to do so. An initial training and education program commensurate with those duties and functions members are expected to perform shall be provided before they perform fire brigade emergency activities. The fire brigade team leader and instructors shall be provided with training and education more comprehensive than that of the general membership of the brigade. Training must be performed frequently enough to assure each member is able to perform the members¹ assigned duties and functions satisfactorily and in a safe manner to not endanger fire brigade members or other employees. All incipient brigade members shall be provided with training at least annually. Plant policy must designate the incipient brigade and its duties and responsibilities.

3. Interior fire brigade. Employees have been properly trained to fight fires inside buildings. Training must be provided as outlined in item 2 above, except quarterly training sessions are required and the annual training should include interior live firefighting. This training shall also include an initial training program that includes basic firefighter training and operating under strenuous conditions and fighting live fires. The employer must ensure that employees on the fire brigade are physically capable of performing the duties which may be assigned. Training must be adequate to ensure employees can safely function and perform their brigade responsibilities. Brigade members must be trained on the hazards of the facility and be made aware of changes to the plant. Firefighting protective clothing and SCBA shall be provided for interior fire brigade members and shall be worn when fighting fires. This personal protective clothing and SCBA equipment shall meet the requirements for firefighting as outlined in the regulation.

Title 29 of the Federal Code of Regulation, Section 1910.146 (29 CFR 1910.146) requires employers to establish a Permit Required Confined Space Entry Program, and provide trained rescue personnel when required. There are 14 specific areas that must be included in this program. One element of this program is to develop procedures for providing and summoning authorized rescue and emergency services. (Section K of the standard) Providing properly trained response teams may be accomplished in various ways.

1. On-Site Response Teams

There are numerous training considerations in complying with the rescue requirements of CFR 1910.146. Employees must be trained in the proper use of PPE and rescue equipment. Each rescue team member must be trained as an authorized entrant and should be trained in attendant duties as well. Employers must provide these in-house teams with the necessary training and equipment to perform these rescues.

2. Off-Site Response Teams

Any employer who retains and off-site rescue service must ensure that the designated service has equipment, training, and overall ability to respond in a timely fashion. The employer must also give the outside agency access to confined spaces in his facility in order for this outside service to preplan these confined spaces.

Managing hazardous materials training is a complex task. The challenge is to conduct training that meets the requirements of OSHA 29 CFR 1910.120 and EPA 40 CFR 311 (EPA311). Both of these standards require that emergency responders be completely trained before they perform their task. Employers¹ responsibilities under these regulations fall into four primary areas:

• Development of an emergency response plan
• Development of specific procedures for handling hazardous materials incidents (SOPs)
• Employee Training Requirements
• Health and safety requirements (medical monitoring and exposure records)

Employers must ensure that employees receive training in emergency response to hazardous materials incidents, based on their expected duties and functions.

• An employer is responsible for determining the appropriate level of training required based on actions expected of employees.
• An employer is responsible for implementing the required training. Emphasis should be on achieving the required competencies for the appropriate level of response rather than on minimal requirements for the length of training.
• An employer is responsible for selecting qualified and competent instructors.
• An employer must provide annual refresher training sufficient to maintain competencies, or the employee must demonstrate the required competencies annually.
• An employer must maintain a record of demonstrated competencies explaining how each competency was completed. Training records must contain dates, student rosters, curriculum outlines, demonstration checklist or performance records and evaluation tools, and scores.

OSHA has defined the minimum number of hours for training at operations, technician, specialist and incident commander level. However, each employer is responsible for their employees being trained to meet the competency. Industry often exceeds the minimum hours of training above those by outlined OSHA. The training needed to reach competency depends on the preexisting skills and experience of the trainees. Agencies frequently discover that training needs exceed the minimum required hours by law. On the other hand, employees of a response agency who have sufficient skills and experience may require minimal time to attain the competency level desired. An effective response is based on the competency of the responders, not the number of training hours they receive.

OSHA realizes that it will not take as many hours to cover the information in a review as during the initial presentation; therefore, there is no hour requirement for competencies through refresher training.

First Responder Awareness Level Training

First responders at the awareness level are those individuals who are likely to witness or discover a release of hazardous materials. No hourly training requirement is listed in either OSHA 1910.120 or EPA 311, but these documents indicate that first responders must have sufficient training or experience to demonstrate competency in the following areas:

• An understanding of what the hazards are and their associated risks.
• An understanding of potential outcomes when hazardous materials are present.
• The ability to recognize the presence of hazardous materials.
• An understanding of the first responder¹s role and use of the DOT Emergency Response Guidebook.
• The ability to recognize the need for additional resources and the knowledge of the company¹s procedures to make appropriate notifications.

First Responder Operations Level Training

First responders at the operations level are those individuals who respond to release, or potential release, as part of the initial response to protect people, property, and the environment. Operations-level first responders are trained to take defensive actions rather than trying to physically stop the release. Their functions are to contain the release from a safe distance, keep it from spreading, and prevent any additional exposures. OSHA 1910.120 requires the first responder at the operations level receive at least 8 hours of training or have sufficient experience to demonstrate competencies objectively. First responders must have the knowledge of awareness level plus the following competencies:

• Know basic hazard and risk assessment
• Know how to select and use protective equipment available
• Understand basic hazardous materials terms
• Know how to perform the basic control, containment and confinement operations within the capabilities of their resources and protective equipment
• Know basic decontamination procedures
• Understand relevant SOPs and termination procedures

Hazardous Materials Technician Training

Hazardous Materials technicians are those who respond to releases or the potential releases for the purpose of stopping the leak. This level requires at least 24 hours of training at the operations level or training equal to the competencies at the technician level. Hazardous materials technicians assume a more aggressive role than first responders at the operations level. They approach to plug, patch, or otherwise stop the release of the hazardous substance. They must be trained at the first responder operations level, plus the following competencies, and the employer must so certify:

• Know how to implement the employer¹s emergency response plan
• Know how to identify materials by using field survey instruments
• Be able to function in an assigned role in the incident command system
• Know how to select and use specialized personal protective equipment
• Understand hazard and risk assessment techniques
• Be able to perform advanced control and containment operations with the available equipment and resources
• Understand and implement decontamination procedures

On-scene Incident Commander Training

Incident commanders who 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. In addition, the employer must certify that personnel are able to meet the following competencies:

• Be able to implement the employer's incident command system
• Be able to implement the employer's emergency response plan
• Understand the risk associated with working in chemical protective clothing
• Know how to implement the local emergency response plan
• Understand the importance of decontamination and be able to implement the company's decontamination plan

Hazardous Materials Refresher Training

Employers must certify on an annual basis that employees continue to meet the performance objectives as defined in OSHA 1910-120. This may be accomplished through refresher training or demonstration of the competency.

Refresher training or competency retesting requirements may vary for each of the response levels. In general, refresher training should include critical practical skills, technical information updates, and refinement of incident scene coordination through team field exercises. At a minimum, competency should be demonstrated for the skills directly affecting the safety of responding personnel.