technical committee for hazardous materials response … · 2016-03-30 · title 29 49, code of...

Technical Committee for Hazardous Materials Response Personnel First Draft Meeting (NFPA 1072 and 475)

February 23-26, 2015

8:00am ET - 5:00pm ET

Hilton St. Petersburg Carillon Park 950 Lake Carillon Drive

St. Petersburg, FL 33716 Conference Call/Adobe Connect Connections will be provided

Agenda

NFPA 1072 First Draft will be addressed on February 23 and 24 NFPA 475 First Draft will be addressed on February 25 and 26

1. Call to Order – Chair Greg Noll

2. Introduction of Members and Guests

3. Chair’s Brief Remarks and Purpose of Meeting

4. Review of Minutes from Previous Meeting

a. Initial Draft Meeting for NFPA 475 - September 24-25, 2014 b. Pre-First Draft Meeting – November 10, 2014 (Conference Call)

5. Committee Procedures – Staff Liaison Tom McGowan

a. Document Cycle Information b. NFPA New Process – First Draft

i. TC Actions

6. Report from Tasks Group

7. Technical Committee Actions a. Review of Public Inputs b. First Revisions

8. Other Business

9. Adjourn at the Close of Business

Technical Committee for Hazardous Materials Response Personnel Pre-First Draft Meeting (NFPA 1072 and 475)

November 10, 201410:00am ET

Conference Call/Adobe Connect

Minutes

Greg Noll - ChairDonald BeckeringRichard EdingerSteven HergenreterKevin JohnsonTroy LilleyThomas MillerLawrence PrestonTimothy RehakRobert RoyallDanny SimpsonChristopher TracyCharles WrightJorge CarrascoRichard HopkinsKristina KreutzerMark LinsleyTony MussorfitiRobert PottsKevin QuinnLibby SnyderJimmy Van CleveBill PetersonAndy GutackerTom McGowan - Staff

Chair Greg Noll called the meeting to order at 10:10am ET.

Introduction of Members and Guests

Chair briefed TC and purpose of the meeting

Staff Liaison presented a PPT on the process and items for the TC to consider including a review of expectations of First Draft Meeting.

Chair Noll asked the Task Group Chairs to summarize each of their TG’s progress.

Other business – Task Group Chairs Bob Royall and Tony Mussorfiti, TC Chair Greg Noll and TG Chair 1072 Charles Wright continued a conversation as to next TG NFPA 475 conference call/Adobe Connect. The group set November 12 at 8:00am ET was established. Materials from the TG NPFA 475 will follow.

Next Meeting – First Draft Meeting February 23-26, 2015, St. Petersburg FL (details when meeting notice is completed)

Chair adjourned the meeting at approximately 10:50am ET.

Public Input No. 79-NFPA 1072-2015 [ Global Input ]

Any "Requisite Skills" should be "in accordance with the policies and procedures of the AHJ;”

Additional Proposed Changes

File Name Description Approved_22as_per_AHJ_22.docx

Statement of Problem and Substantiation for Public Input

An AHJ is required to develop a policy and procedure (ERP, IAP, SOP or SOG) for response to a hazardous material/WMD incident. Members need to be trained to perform their expected tasks as per the plan. This needs to be specified in the document.

Submitter Information Verification

Submitter Full Name: Tony MussorfitiOrganization: Pacific Northwest National Lab

Street Address:City:State:Zip:Submittal Date: Sun Jan 04 13:53:58 EST 2015

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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7.2.1* Detection, Monitoring, and Sampling.

Classify hazardous materials/WMD by Basic hazard categories and verify the presence and concentrations of hazardous materials through detection, monitoring, and sampling at a hazardous materials/WMD incident, given a hazardous materials/WMD incident with released identified and unidentified hazardous materials, an assignment in an incident action plan (IAP), policies and procedures, and approved resources, detection and monitoring equipment, and personal protective equipment (PPE), so that PPE is selected and used; hazardous materials/WMD are classified by their Basic hazard categories the presence of hazardous materials is verified; the concentrations of hazardous materials in the atmosphere are determined; samples of solids, liquids, and gases are collected; results of detection and monitoring equipment are read, interpreted, recorded, and communicated; exposures and personnel are protected; safety procedures are followed; hazards are avoided or minimized; personnel using the detection and monitoring equipment, as well as the equipment, are decontaminated; field maintenance and testing are performed; detection and monitoring equipment are maintained; and all reports and documentation pertaining to use of detection and monitoring equipment are completed.

(A) Requisite Knowledge. Basic hazard categories and their definitions; policies and procedures; monitoring technologies; analysis process for classifying the Basic hazard categories of identified solid and liquid materials and unidentified contaminants in the atmosphere; process for determining radiation dose rates from radioactive material labels; process for monitoring lighter-‐than-‐air gases and vapors, heavier-‐than-‐air gases and vapors in a confined area, and heavier-‐than-‐air gases and vapors in an unconfined area; capabilities and limiting factors of detection and monitoring equipment; detection and monitoring equipment required to identify the basic hazard categories; techniques used to identify unidentified contaminants in the atmosphere; methods for collecting samples of solids, liquids, and gases; reading, interpreting, recording, and communicating test results of detection and monitoring equipment; and field maintenance and testing procedures for approved detection and monitoring equipment.

(B) Requisite Skills. Selecting and using PPE; classifying hazardous materials by Basic hazard categories verifying the presence of hazardous materials; determining the concentration of hazardous materials; determining radiation dose rates from radioactive material labels; collecting samples of gases, liquids, and solids; reading, interpreting, recording, and communicating readings from detection and monitoring equipment; going through decontamination while wearing PPE; decontaminating detection and monitoring equipment; performing field maintenance and testing for detection and monitoring equipment; and completing required reporting and documentation for detection, monitoring, and sampling activities


The terms "approved" and "as determined by the AHJ" are used repeatedly throughout the document and, in most cases, appear to be saying the same thing. Please reviewusage of term/phrase to reduce confusion.

Type your content here ...


The definition of "approved" (see 3.2.1) incorporates the AHJ definition. By using the clause "as determined by the AHJ" in other locations, it creates confusion as to whether or not the "approved" is referring to the AHJ.


Submitter Full Name: Christina BaxterOrganization: US Department of DefenseStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 11:04:04 EST 2015


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Public Input No. 27-NFPA 1072-2014 [ Section No. 1.1 ]

1.1* Scope.This standard identifies the minimum job performance requirements (JPRs) for personnel at the scene of a hazardous materials/weapons of mass destruction (WMD) incident at the followinglevels: awareness, operations, operations mission-specific, hazardous materials technician, and incident commander.


First use of term in chapter so the acronym needs to be shown.


Submitter Full Name: Charles WrightOrganization: RetiredStreet Address:City:State:Zip:Submittal Date: Tue Nov 18 10:48:35 EST 2014


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2.3 Other Publications.2.3.1 U.S. Government Publications.U.S. Government Printing Office, Superintendent of Documents, Washington, DC 20402.

Emergency Planning and Community Right-to-Know Act, Public Law 99–499, 1986.

Title 18, U.S. Code, Section 2332a, “Use of Weapons of Mass Destruction.”

Title 46, Code of Federal Regulations, “Shipping.”

Title 29 Code of Federal Regulations Part 1910.120, “Hazardous Waste Operations and Emergency Response.

U.S. Department of Transportation, Emergency Response Guidebook (ERG), 2012 edition.

2.3.2 Other Publications.Merriam-Webster's Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003.

2.3.3 16 Firefighter Life Safety Initiatives, published by the National Fallen Firefighters Foundation, 2004


The 16 Firefighter Life Safety Initiatives were developed more than a decade ago and should be part of the basis for fire service training and education. A location that make sense is to embed these initiatives in the professional qualification standards with the NFPA.


Submitter Full Name: Richard Mason

Organization: National Fallen Firefighters FoundationStreet Address:City:State:Zip:Submittal Date: Sat Jan 03 16:00:01 EST 2015


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Public Input No. 29-NFPA 1072-2014 [ Section No. 2.3.1 ]

2.3.1 U.S. Government Publications.U.S. Government Printing Office, Superintendent of Documents, Washington, DC 20402.



Title 29, Code of Federal Regulations Part 1910.120, “Hazardous Waste Operations and Emergency Response."

Title 46, Code of Federal Regulations, “Shipping.”

Title 29 49, Code of Federal Regulations Part 1910.120, “Hazardous Waste Operations and Emergency Response. , "Transportation."

U.S. Department of Transportation, Emergency Response Guidebook (ERG), 2012 edition.


Add Title 49 as a reference and correct minor editorial issues; please items in alphabetical order.


Submitter Full Name: Charles Wright

Organization: RetiredStreet Address:City:State:Zip:Submittal Date: Tue Nov 18 10:59:13 EST 2014


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3.3.1* Allied Professional.That person who possesses the knowledge, skills, and technical competence to provide assistance in the selection, implementation, and evaluation of mission-specific tasks at a hazardousmaterials/weapons of mass destruction (WMD) incident. [472, 2013]


Is the term mission-specific too limiting when addressing allied professions as they may be call to assist with any issue at any incident? Suggest deleting mission-specific . . .




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3.3.4 CANUTEC.The Canadian Transport Emergency Center, operated by Transport Canada, which that provides emergency response information and assistance on a 24-hour basis for responders tohazardous materials/weapons of mass destruction (WMD) incidents.


Grammar "which" or "that" . . . needs to be consistent with 3.3.4 CHEMTREC and 3.3.62 SETIQ




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3.3.13 Control.The procedures, techniques, and methods used in the mitigation of hazardous materials/weapons of mass destruction (WMD) incidents, including containment, extinguishment, andconfinement. [472, 2013]

3.3.13.1 Confinement. (0ld 3.3.8)

Those procedures taken to keep a material, once released, in a defined or local area. [ 472, 2013]

3.3.13.2 Containment. (old 3.3.10)

The actions taken to keep a material in its container (e.g., stop a release of the material or reduce the amount being released). [ 472, 2013]3.3.13.1 Extinguishment. (old 3.3.29)

To cause to cease burning.


Place the definitions of containment (3.3.10), extinguishment (3.3.29), and confinement under 3,3,13 Control. . . . to be consistent with control zones, decontamination, etc


Submitter Full Name: Charles WrightOrganization: Retired

Street Address:City:State:Zip:Submittal Date: Tue Nov 18 11:19:19 EST 2014


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Public Input No. 71-NFPA 1072-2015 [ Section No. 3.3.16.2 ]

3.3.16.2 * Mass Decontamination.The physical process of reducing or removing surface contaminants from large numbers of victims in potentially life threatening situations in the fastest time possible. [ 472, 2013]


File Name Description ApprovedMass_Decontamination_Definition.docx


Include this definition for clarification of the term used within this document. A couple of examples of events that are a "Technical" Mass Decontamination are:- Radiological Dispersal Device where after having gone through a Emergency Mass Decontamination, it is determined through monitoring that victims are still contaminated and will require a more formal technical decontamination.- USPS Bio Detection System (BDS): a Mass Decontamination at a USPS BDS will dictate a Technical Mass Decontamination due to the need to assure the decontamination process has been effective.


Submitter Full Name: Tony Mussorfiti

Organization: Pacific Northwest National LabStreet Address:City:State:Zip:Submittal Date: Fri Jan 02 16:41:12 EST 2015


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Mass Decontamination. The physical process of reducing or removing surface contaminants from large numbers of victims in potentially life-‐threatening situations in the fastest time possible through an emergency or technical process.

ANNEX:

Mass decontamination is initiated where the number of victims and time constraints may not allow the establishment of an in-‐depth decontamination process. Mass decontamination should be established quickly to reduce the harm being done to the victims by the contaminants. Initial operations will likely be an emergency decontamination, through handheld hose lines or master streams supplied from fire apparatus while a more formal process is being set up. This may need to be followed up by a formal technical decontamination when the initial emergency decontamination has been determined to not be effective through detection, observation or concern. For example, victims exposed to a Radiological Dispersal Device (RDD) or an aerosolized biological agent.


3.3.20 Detection and Monitoring Equipment.Instruments and devices used to detect, identify, or quantify materials.


Definition is in Chapter 3 as Detection and Monitoring Equipment and again as Monitoring and Detection Equipment (3.3.45) . . . recommend keeping Detection and Monitoring with the addition of the word "identify" from 3.3.45 and deleting 3.3.45.




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Public Input No. 65-NFPA 1072-2015 [ New Section after 3.3.31 ]

Hazardous (adjective): indicates hazards are present.


NFPA does not have a definition. It is combined with Hazard. I believe they are different Include this definition for clarification of the term used within this document.



Street Address:City:State:Zip:Submittal Date: Fri Jan 02 16:31:07 EST 2015


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Harm: Possible adverse outcomes to people, property or the environment, caused by being exposed to a hazard. Types of harm include injury, illness and death, environmental or property damage, system disruption, and psychological.


NFPA does not have a definition for "Harm". Include this definition for clarification of the term used within this document.


Submitter Full Name: Tony MussorfitiOrganization: Pacific Northwest National LabStreet Address:City:State:Zip:Submittal Date: Fri Jan 02 16:33:07 EST 2015


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3.3.31 Hazard/Hazardous.Capable of posing an unreasonable risk to health, safety, or the environment; capable of causing harm. [ 472, 2013]Hazard: a situation or material capable of causing harm, to life, health, property, or environment


include this definition for clarification of the term used within this document.





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3.3.40 Incident AnalysisThe process of analyzing a hazardous materials/weapons of mass destruction (WMD) incident to identify risks and determine likely behavior and potential harm within the training andcapabilities of the emergency responder.


The phrase "results of the incident analysis" is used in Chapter 7, sections 7.3.1, 7.3.2, 7.3.3, 7.3.4, 7.4.1, 7.4.2, 7.4.3.1. This is a new term and does not have a corresponding definition in Chapter 3.

Of special note, a similar phrase is used in Chapter 5, section 5.3. There the phrase refers to "results of the incident size up".

If "results of the incident size up" is a better term then the references in Chapter 7 "results of the incident analysis" should be changed for consistency. If the phrases in Chapter 7 are changed then there will be no need to add this definition to Chapter 3.


Submitter Full Name: ROBERT ROYALLOrganization: HARRIS COUNTY FIRE MARSHAL'S OFFICEStreet Address:City:State:Zip:Submittal Date: Wed Dec 31 17:25:20 EST 2014


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3.3.50* Personal Protective Equipment (PPE).The equipment provided to shield or isolate a person from the chemical, physical, and thermal hazards that can be encountered at hazardous materials/weapons of mass destruction (WMD)incidents. [472, 2013]


Delete the words "that can be" . . . they are unnecessary in terms of the intent of the definition.




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Risk: The probability or threat that will result in or cause damage, injury, liability, loss, or any other negative occurrence that is caused by external or internal vulnerabilities, andthat may be avoided through preemptive action."


NFPA does not have a definition for Risk. Include this definition for clarification of the term used within this document.




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3.3.62 SETIQ.The Emergency Transportation System for the Chemical Industry in Mexico that provides emergency response information and assistance on a 24-hour basis for responders to emergenciesinvolving hazardous materials/weapons of mass destruction (WMD) .. [472, 2013]


Need an explanation of what SETIQ does . . . to be consistent with CHEMTREC and CANUTEC




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3.4.1 Core Competencies.The knowledge, skills, and judgment needed by operations level responders who respond to releases or potential releases of hazardous materials/weapons of mass destruction (WMD). [ 472,2013] Delete and renumber rest


Delete and renumber rest of section . . . term is not used in the document currently.




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4.1.2* Awareness personnel shall be are those persons who, in the course of their normal duties, could encounter an emergency involving hazardous materials/weapons of mass destruction (WMD)and who are expected to recognize the presence of the hazardous materials/WMD, protect themselves, call for trained personnel, and secure the area scene but not take actions that requirea higher level of training.


To make consistent with Chapter 5 Operations (5.1.3)





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4.1.3 General Knowledge Requirements.Role of awareness personnel at a hazardous materials/WMD incident, location and contents of local emergency response plan, and standard operating procedures for awareness personnel.

4.1.3.1 Safety

The awareness personnel will be familiar with scope and breadth of the the 16 Firefighter Life Safety Initiatives published by the National Fallen Firefighters Foundation.




Submitter Full Name: Richard MasonOrganization: National Fallen Firefighters FoundationStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 11:39:23 EST 2015


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Public Input No. 107-NFPA 1072-2015 [ Sections 4.2, 4.3, 4.4 ]

Sections 4.2, 4.3, 4.44.2 * Recognition and Identification.Recognize and identify the hazardous materials/WMD and hazards involved in a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, and approvedreference sources, so that the presence of hazardous materials/WMD is recognized and the materials and their hazards are identified.(A) *

Requisite Knowledge. What hazardous materials and WMD are; hazard classes and divisions; hazards associated with various hazardous materials/WMD; indicators of the presence ofhazardous materials/WMD; information available in transportation to and from facilities to identify hazardous materials/WMD; and hazard information available from the U.S. Department ofTransportation (DOT) Emergency Response Guidebook (ERG) or an equivalent document, safety data sheets (SDS), and manufacturer, shipper, and transporter documents (including shippingpapers) and contacts, and how to access manufacturer, shipper, and transporter resources.

(B) Requisite Skills. Recognizing the presence of hazardous materials/WMD; identifying hazardous materials involved; and identifying the potential hazards associated with the material(s)involved, using the ERG or equivalent guide, SDS, and manufacturer, shipper, and transporter documents (including shipping papers) and contacts.4.3 * Initiate Protective Actions.Isolate the hazard area and deny entry at a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, policies and procedures, and approved referencesources, so that the incident is isolated and secured, personal safety procedures are followed, hazards are avoided or minimized, and additional people are not exposed to further harm.(A) *

Requisite Knowledge. Use of approved documents to identify recommended precautions to be taken to protect responders and the public; policies and procedures for isolating the hazardarea and denying entry; and the purpose of and methods for isolating the hazard area and denying entry.

(B) Requisite Skills. Identifying recommended precautions for protecting responders and the public, isolating the hazard area, and denying entry while avoiding or minimizing hazards.4.4 Notification.Initiate required notifications at a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, policies and procedures, and approved communicationsequipment, so that the notification process is initiated and the necessary information is communicated.(A)

Requisite Knowledge. Policies and procedures for notification, reporting, and communications; types of approved communications equipment; and the operation of that equipment.(B)

Requisite Skills. Operating approved communication equipment and communicating in accordance with policies and procedures.

IAFF proposal to move sections 4.2 through 4.4 to Chapter 5 Operations:

With the fact that the scope of NFPA 472 and 1072 applies as a document for “Emergency Responders” to known, or potential hazardous materials releases we propose moving the requisiteknowledge and skills items 4.2 through 4.4 to chapter 5 Operations. Chapter 4 then be deletedSince 2008 the NFPA 472 committee concluded that: "The term responders was dropped from the definition of awareness level and replaced with awareness level personnel. TheCommittee views these individuals as those who, in the course of their normal duties, might be first on-scene. However, they might not be emergency responders."

If the AHJ does have personnel that meet the definition of awareness personnel (i.e. public works) they should refer to OSHA 1910.120(q)(6)(i) and OSHA 1910.1200 for the appropriatetraining requirements.


Justification Statement: Removing Chapter 4 will have several impacts. First it will reduce a level of certification and have a monetary savings for jurisdictions that have to pay for the awareness and operations certification. Second it will eliminate waste and confusion in the process of certification, instructional design, course and textbook development.

This reduction will have a cost savings in the instructional design process by reducing this redundant training and materials.

This will also make the learning process less confusing to instructors and responders seeking certification.


Submitter Full Name: ELIZABETH HARMANOrganization: INTL ASSOC OF FIREFIGHTERS

Street Address:City:State:Zip:Submittal Date: Mon Jan 05 14:18:08 EST 2015


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Public Input No. 23-NFPA 1072-2014 [ Section No. 4.2(A) ]

(A)* Requisite Knowledge. What hazardous materials and WMD are; hazard classes and divisions; hazards associated with various hazardous materials/WMD; indicators of typical constainershapes that can indicate the presence of hazardous materials/WMD; information available in transportation to and from facilities to identify NFPA 704 markings; other indicators of thepresence of hazardous materials/WMD; and hazard information available from the U.S. Department of Transportation (DOT) Emergency Response Guidebook (ERG) or an equivalentdocument, safety data sheets (SDS), and manufacturer, shipper, and transporter documents (including shipping papers) and contacts, and how to access manufacturer, shipper, andtransporter resources.


It is my understanding that agencies such as IFSAC do not consider annex material in their certification process. In other words, by moving most of the bullet items in NFPA 472 4.2.1(6) to the annex in NFPA 1072, agencies certifying to 1072 may not include that material in their curriculum, and Awareness Level personnel being trained to 1072 may not be taught that information.

Justification for adding container recognition:1) NFPA 472 4.2.1(6) Requires container shape recognition, so this addition will keep the documents consistent.2) Container shape recognition is important for recognizing and identifying hazardous materials if containers are missing placards, labels, and/or markings, or other documents.3) Container shape recognition is part of using the ERG, a required element of Awareness Level training. The ERG provides a "Rail Car Identification Chart" and "Road Trailer Identification Chart" that use container shapes. While it is theoretically possible to teach a student to use these charts without knowing anything about the containers depicted, additional information will increase student understanding of the potential hazards associated with the various containers.4) Increased understanding of the potential hazards associated with various containers depicted in the ERG should translate to increased safety at an actual emergency, even for Awareness Level personnel.5) NFPA 472 4.2.1(6) requires container shape recognition, so this information is already being taught in Awareness Level classes and will not place an "additional" burden on certifying agencies that switch from NFPA 472 to 1072.

Justification for adding NFPA 704 markings:1) NFPA 704 is a very common marking system that will help Awareness personnel identify the presence of hazardous materials in non-transportation situations.2) NFPA 472 4.2.1(6) requires understanding the NFPA 704 system, so this will addition will keep the documents consistent.3) This information is already being taught in Awareness Level classes taught to NFPA 472 and will not place an "additional" burden on certifying agencies that switch from NFPA 472 to 1072.

Justification for removing "information available in transportation and at facilities to identify hazardous materials/WMD"1) What does this mean? There is no annex explanation. I think it is covered by "shipping papers" and "SDSs"2) It is not one of the items listed in NFPA 472 4.2.1(6), so this will be new material added to existing training programs, and it will create a divergence from NFPA 472.


Submitter Full Name: Leslie MillerOrganization: Fire Protection Publications



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(A)* Requisite Knowledge. What hazardous materials and WMD are; hazard classes and divisions; hazards associated with various hazardous materials/WMD; indicators of the presence ofhazardous materials/WMD; information available in transportation to and from at facilities to identify hazardous materials/WMD; and hazard information available from the U.S. Department ofTransportation (DOT) Emergency Response Guidebook (ERG) or an equivalent document, safety data sheets (SDS), and manufacturer, shipper, and transporter documents (including shippingpapers) and contacts, and how to access manufacturer, shipper, and transporter resources.


The intent of this phrase was to require knowledge of "information available in transportation and at facilities . . . " Editor changed the wording.





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(A) * Requisite Knowledge. What hazardous materials and WMD are; hazard classes and divisions; hazards associated with various hazardous materials/WMD; indicators of the presence ofhazardous materials/WMD; information available in from hazardous material owner/operator in transportation to and from facilities to identify hazardous materials/WMD; and hazardinformation available from the U.S. Department of Transportation (DOT) Emergency Response Guidebook (ERG) or an equivalent document, safety data sheets (SDS), and manufacturer,shipper, and transporter documents (including shipping papers) and contacts, and how to access manufacturer, shipper, and transporter resources.


Signifies the ongoing communication and relationship that should exist between hazardous liquid operators and first responders; that communication is key and that operators should supply information/responders should seek information specific to the owner/operator's incident.


Submitter Full Name: DREW LOHOFFOrganization: Colonial Pipeline Company

Affilliation: American Petroleum Institute/Association of Oil Pipe LinesStreet Address:City:State:Zip:Submittal Date: Tue Dec 16 08:58:39 EST 2014


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(A)* Requisite Knowledge. Use of approved documents reference sources to identify recommended precautions to be taken to protect responders and the public; policies and procedures forisolating the hazard area and denying entry; and the purpose of and methods for isolating the hazard area and denying entry.


Change to correspond with terminology in 4.3


Submitter Full Name: Charles WrightOrganization: [ Not Specified ]Street Address:City:State:Zip:Submittal Date: Mon Jan 05 13:09:57 EST 2015


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5.1.1 Operations level responders shall meet the job performance requirements defined in Sections 4.2 through 4.4.5.1.2, 5.1.3, 5.1.4 all need to be changed accordinaly adding the word "level"


Adding level makes the use consistent with 5.1.5 . . . if change is not made, then 5.1.5 will need to be changed.





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(A)* Requisite Knowledge. Definitions of hazard classes and divisions; types of containers; container identification markings, including piping and pipeline markings; types of information to becollected during the hazardous materials/WMD incident survey; availability of shipping papers in transportation and of safety data sheets (SDS) at facilities; contacting types of hazardinformation available from, and how to contact CHEMTREC, CANUTEC, and/or SETIQ, local, state and federal governmental authorities, and manufacturers, shippers, and transporters forthe types of hazard information available from these sources ; basic physical and chemical properties including boiling point, chemical reactivity, corrosivity (pH), flammable (explosive) range[LFL (LEL) and UFL(UEL)], flash point, ignition (autoignition) temperature, particle size, persistence, physical state (solid, liquid, gas), radiation (ionizing and nonionizing), specific gravity, toxicproducts of combustion, vapor density, vapor pressure, and water solubility ; how to identify the behavior of a material and its container based on the material's physical and chemicalproperties, the hazards associated with the identified behavior , including additional hazards associated with terrorist or criminal activities, and the subsequent harm associated with theidentified behavior; and how to estimate outcomes.


It would seem that a person at the operations level who is trained to "identify the behavior of a material and its container based on the material's physical and chemical properties" should be taught to understand certain specific physical and chemical properties. The list of basic physical and chemical properties is found in the Annex; however, since the Annex is not part of the requirements, adding these properties from the Annex to the requisite knowledge of this JPR will insure that a person at this level is able to interpret these properties so that they are able "identify the behavior of a material and its container based on the material's physical and chemical properties". Generally clarifies the intent of the TG.



Street Address:City:State:Zip:Submittal Date: Mon Nov 24 15:06:42 EST 2014


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(A) * Requisite Knowledge. Definitions of hazard classes and divisions; types of containers; container identification markings, including piping and pipeline markings and contact information ; typesof information to be collected during the hazardous materials/WMD incident survey; availability of shipping papers in transportation and of safety data sheets (SDS) at facilities; contactingCHEMTREC, CANUTEC, and SETIQ, local, state and federal governmental authorities, and manufacturers, shippers, and transporters for the types of hazard information available from thesesources; how to communicate with transporters to reduce impact (i.e. pipeline control center shutting down a line); how to identify the behavior of a material and its container based on thematerial's physical and chemical properties, the hazards, including additional hazards associated with terrorist or criminal activities, and subsequent harm associated with the identifiedbehavior; and how to estimate outcomes.


This adds further clarity to the important information received from pipeline markers

This adds a key element to the knowledge base - that communication with transporters is key and that operators can often remotely control a source


Submitter Full Name: DREW LOHOFF

Organization: Colonial PipelineAffilliation: American Petroleum Institute/Association of Oil Pipe LinesStreet Address:City:State:Zip:Submittal Date: Tue Dec 16 09:02:25 EST 2014


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Public Input No. 51-NFPA 1072-2014 [ Section No. 5.2(B) ]

(B) * Requisite Skills. Identifying container types, materials, location of release, and surrounding conditions at a hazardous materials/WMD incident; collecting and interpreting hazard information;communicating with pipeline or utility HAZMAT response team or control center; describing the likely behavior of the hazardous materials or WMD and its container; and describing thepotential hazards, harm, and outcomes associated with that behavior.


This adds a critical skill that first responders communicate effectively and immediately with the owner/operator so that their response can begin and source control can be initiated.


Submitter Full Name: DREW LOHOFFOrganization: Colonial Pipeline



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5.3* Identify Response Options.Identify the response options for a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, policies and procedures, approved reference sources, andthe results of the incident size-up, so that response objectives, response options, safety precautions, suitability of approved personal protective equipment (PPE) available, and emergencydecontamination needs are identified.(A) Requisite Knowledge. Policies and procedures for hazardous materials/WMD incident operations; basic components of an incident action plan (IAP); modes of operation; types of responseobjectives; types of response options; safety procedures; risk analysis concepts; purpose, advantages, limitations, uses, and operational components of approved PPE to determine if PPE issuitable for the incident conditions; difference between exposure and contamination; contamination types; routes of exposure; methods of contamination; and purpose, advantages, andlimitations of emergency decontamination.(B) Requisite Skills. Identifying response objectives and response options based on known incident conditions and available resources; identifying whether approved PPE is suitable for theincident conditions; and identifying emergency decontamination needs.


Fire Service Hazardous Materials Core Operations level personnel perform duties under the supervision of an Incident Commander, Hazardous Materials Technician or Allied Professional. Fire Service personnel at this level (Fire Fighter I) would not and should not be making decisions relating to response objectives as this would require them to operate at a level beyond their training and responsibility. Non-fire service personnel may be even less qualified to be make these strategic decisions and therefore further justifying the removal of this requirement.


Submitter Full Name: Lawrence PrestonOrganization: Maryland Fire and Rescue Institute, University of MarylandAffilliation: Maryland Fire and Rescue Institute, University of MarylandStreet Address:City:State:Zip:Submittal Date: Tue Nov 18 11:13:35 EST 2014


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5.3* Identify Response Options.Identify the response options for a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, policies and procedures, approved reference sources, andthe results of the incident size-up, so that response objectives, response response options, safety precautions, suitability of approved personal protective equipment (PPE) available, andemergency decontamination needs are identified.(A) Requisite Knowledge. Policies and procedures for hazardous materials/WMD incident operations; basic components of an incident action plan (IAP); modes of operation; types of responseobjectives; types of response options; safety procedures; risk analysis concepts; purpose, advantages, limitations, uses, and operational components of approved PPE to determine if PPE issuitable for the incident conditions; difference between exposure and contamination; contamination types; routes of exposure; methods of contamination; and purpose, advantages, andlimitations of emergency decontamination.(B) Requisite Skills. Identifying response objectives and response response options based on known incident conditions and available resources; identifying whether approved PPE is suitablefor the incident conditions; and identifying emergency decontamination needs.


Hazardous Materials Core Operations level personnel perform duties under the supervision of Incident Commander, Hazardous Materials Technician or Allied Professional. Personnel at this level would not and should not be making decisions relating to response objectives as this would require them to operate at a level beyond their training and responsibility.


Submitter Full Name: laura corn

Organization: TEEXStreet Address:City:State:Zip:Submittal Date: Mon Dec 22 13:55:56 EST 2014


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Public Input No. 2-NFPA 1072-2014 [ Section No. 5.3 [Excluding any Sub-Sections] ]

Identify the response options for a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, policies and procedures, approved reference sources, andthe results of the incident size-up, so that response objectives, response options, safety precautions, suitability of approved personal protective equipment (PPE) available, and emergencydecontamination needs are identified.


Justification – Hazardous Materials Core Operations level personnel perform duties under the supervision of Incident Commander, Hazardous Materials Technician or Allied Professional. Personnel at this level would not and should not be making decisions relating to response objectives as this would require them to operate at a level beyond their training and responsibility.


Submitter Full Name: ALLAN RICEOrganization: North American Fire Training DirectorsAffilliation: President

Street Address:City:State:Zip:Submittal Date: Thu Oct 16 15:42:29 EDT 2014


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Identify the response options for a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, policies and procedures, approved reference sources, andthe results scope of the incident size-up problem , so that response objectives, response options, safety precautions, suitability of approved personal protective equipment (PPE) available, andemergency decontamination needs are identified.


5.2 addresses identifying the scope of the problem and does not mention size-up, therefore the given in 5.3 should be "scope of the problem" not "results of the incident size-up" to be consistent with 5.2. The term "size-up" is only mentioned at this point in the document. If you accept this recommendation, you can delete the definition of "size-up" in 3.3.63.


Submitter Full Name: Charles WrightOrganization: RetiredStreet Address:City:State:Zip:Submittal Date: Mon Nov 24 14:50:22 EST 2014


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(A) Requisite Knowledge. Policies and procedures for hazardous materials/WMD incident operations; basic components of an incident action plan (IAP); modes of operation; types types ofresponse objectives; types of response options; safety procedures; risk analysis concepts; purpose, advantages, limitations, uses, and operational components of approved PPE to determineif PPE is suitable for the incident conditions; difference between exposure and contamination; contamination types; routes of exposure; methods of contamination; and purpose, advantages,and limitations of emergency decontamination.




Submitter Full Name: ALLAN RICEOrganization: North American Fire Training Directors

Affilliation: PresidentStreet Address:City:State:Zip:Submittal Date: Thu Oct 16 15:47:44 EDT 2014


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(B) Requisite Skills. Identifying response objectives and response options based on known incident conditions and available resources; identifying whether approved PPE is suitable for theincident conditions; and identifying emergency decontamination needs.







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(A) * Requisite Knowledge. Scene control procedures; procedures for protective actions, including evacuation and sheltering-in-place; procedures for ensuring coordinated communicationsbetween responders and to the public; evidence recognition and preservation procedures; IMS/ICS organization and procedures; capabilities, limitations, inspection, donning, working in,doffing, and maintenance of approved PPE according to manufacturers' specifications and recommendations; signs and symptoms of heat/cold stress; safety precautions when working athazardous materials/WMD incidents; and cleaning, disinfecting, and inspecting tools, equipment, and PPE.


Add asterisk to note Annex material added to clarify intent. See A.5.4.(A) comment (am suggesting that you put evidence preservation Annex note down in A.5.4(A) for clarification.


Submitter Full Name: Charles WrightOrganization: [ Not Specified ]



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Evaluate and report the progress of the assigned tasks for a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment, policies and procedures, status ofassigned tasks, and approved communication tools and equipment, so that the effectiveness of the assigned tasks is evaluated and communicated to the supervisor, who can adjust the IAP asneeded so that appropriate actions are taken .


Add phrase to explain purpose . . .




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6.2* Personal Protective Equipment.Select, don, work in, and doff approved specialized PPE at a hazardous materials/WMD incident, given a hazardous materials/WMD incident; a mission-specific assignment in an IAP thatrequires use of PPE; the scope of the incident; response objectives and options options for the incident; access to a hazardous materials technician, an allied professional, an emergencyresponse plan, or standard operating procedures; approved PPE; and policies and procedures, so that under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures, approved PPE is selected, inspected, donned, worked in, decontaminated, and doffed; safety procedures are followed; hazardsare avoided or minimized; and all reports and documentation pertaining to PPE use are completed.(A)* Requisite Knowledge. Policies and procedures for PPE selection and use; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures when selecting and using PPE; the capabilities and limitations of and specialized donning, doffing, and usage procedures forapproved PPE; components of an incident action plan (IAP); procedures for decontamination, inspection, maintenance, and storage of approved PPE; process for going throughdecontamination while wearing PPE; and procedures for reporting and documenting the use of PPE.(B) Requisite Skills. Selecting PPE for the assignment; inspecting, maintaining, storing, donning, working in, and doffing PPE; going through decontamination (emergency and technical) whilewearing the PPE; and reporting and documenting the use of PPE.


Hazardous Materials Operations level personnel perform duties under the supervision of Incident Commander, Hazardous Materials Technician or Allied Professional. Personnel at this level would not and should not be making decisions relating to response objectives as this would require them to operate at a level beyond their training and responsibility.


Submitter Full Name: laura cornOrganization: TEEXStreet Address:City:State:Zip:Submittal Date: Mon Dec 22 14:00:26 EST 2014


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6.2* Personal Protective Equipment.Select, don, work in, and doff approved specialized PPE at a hazardous materials/WMD incident, given a hazardous materials/WMD incident; a mission-specific assignment in an IAP thatrequires use of PPE; the scope of the incident; response objectives and options for the incident; access to a hazardous materials technician, an allied professional, an emergency responseplan, or standard operating procedures; approved PPE; and policies and procedures, so that under the guidance of a hazardous materials technician, an allied professional, an emergencyresponse plan, or standard operating procedures, approved PPE is selected, inspected, donned, worked in, decontaminated, and doffed; safety procedures are followed; hazards are avoidedor minimized; and all reports and documentation pertaining to PPE use are completed.(A)* Requisite Knowledge. Policies and procedures for PPE selection and use; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures when selecting and using PPE; the capabilities and limitations of and specialized donning, doffing, and usage procedures forapproved PPE including describing the types of personal protective equipment that are available for response based on NFPA standards and the personal protective equipment options forthermal hazards, radiological hazards, asphyxiating hazards, chemical hazards, etiological/biological hazards and mechanical hazards ; components of an incident action plan (IAP);procedures for decontamination, inspection, maintenance, and storage of approved PPE; process for going through decontamination while wearing PPE; and procedures for reporting anddocumenting the use of PPE.(B) Requisite Skills. Selecting PPE for the assignment; inspecting, maintaining, storing, donning, working in, and doffing PPE; going through decontamination (emergency and technical) whilewearing the PPE; and reporting and documenting the use of PPE.


Although the AHJ may be limited in the types of personal protective equipment given to response personnel, it is important for the Hazardous Materials Operations level personnel to have knowledge of the specific types of personal protective equipment and the capabilities and limitations of each.


Submitter Full Name: laura cornOrganization: TEEX

Street Address:City:State:Zip:Submittal Date: Mon Dec 22 14:01:52 EST 2014


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Select, don, work in, and doff approved specialized PPE at a hazardous materials/WMD incident, given a hazardous materials/WMD incident; a mission-specific assignment in an IAP thatrequires use of PPE; the scope of the incident; response objectives and options for the incident; access to a hazardous materials technician, an allied professional, an emergency responseplan, or standard operating procedures; approved PPE; and policies and procedures, so that under the guidance of a hazardous materials technician, an allied professional, an emergencyresponse plan, or standard operating procedures, approved PPE is selected, inspected, donned, worked in, decontaminated, and doffed; safety procedures are followed; hazards are avoidedor minimized; and all reports and documentation pertaining to PPE use are completed.


Do you mean anything specific by "Specialized" PPE versus the PPE that is used? If not, the word specialized should be removed. If so, the term should be further defined.


Submitter Full Name: Christina BaxterOrganization: US Department of Defense



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(A)* Requisite Knowledge. Policies and procedures for PPE selection and use; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures when selecting and using PPE; the capabilities and limitations of and specialized donning, doffing, and usage procedures forapproved PPE; components of an incident action plan (IAP); procedures for decontamination, inspection, maintenance, and storage of approved PPE; process for going throughdecontamination being decontaminated while wearing PPE; and procedures for reporting and documenting the use of PPE.


Clarify intent of statement . . . does not need to be able to perform decontamination, just be able to go through decontamination process.





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(A)* Requisite Knowledge. Policies and procedures for PPE selection and use; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures when selecting and using PPE; the capabilities and limitations of and specialized donning, doffing, and usage procedures forapproved PPE including describing the types of personal protective equipment that are available for response based on NFPA standards and the personal protective equipment options forthermal hazards, radialogical hazards, asphyxiating hazards, chemical hazards, etiological/biological hazards and mechanical hazards ; components of an incident action plan (IAP);procedures for decontamination, inspection, maintenance, and storage of approved PPE; process for going through decontamination while wearing PPE; and procedures for reporting anddocumenting the use of PPE.


Although the Authority Having Jurisdiction may be limited in the types of personal protective equipment issued to response personnel, it is important for Hazardous Materials Operations level personnel to have knowledge of the specific types of personal protective equipment that exist and the capabilities and limitations of each.


Submitter Full Name: Lawrence Preston

Organization: Maryland Fire and Rescue Institute, University of MarylandAffilliation: Maryland Fire and Rescue Institute, University of MarylandStreet Address:City:State:Zip:Submittal Date: Tue Nov 18 11:18:35 EST 2014


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(A) * Requisite Knowledge. Policies and procedures for PPE selection and use; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures when selecting and using PPE; the capabilities and limitations of and specialized donning, doffing, and usage procedures forapproved PPE including describing the types of personal protec ve equipment that are available for response based on NFPA standards and the personal protec ve equipment op ons for thermal hazards,

radiological hazards, asphyxia ng hazards, chemical hazards, e ological/biological hazards and mechanical hazards ; components of an incident action plan (IAP); procedures for decontamination,inspection, maintenance, and storage of approved PPE; process for going through decontamination while wearing PPE; and procedures for reporting and documenting the use of PPE.


Justification – Although the AHJ may be limited in the types of personal protective equipment given to response personnel, it is important for the Hazardous Materials Operations level personnel to have knowledge of the specific types of personal protective equipment and the capabilities and limitations of each.


Submitter Full Name: ALLAN RICE

Organization: North American Fire Training DirectorsAffilliation: PresidentStreet Address:City:State:Zip:Submittal Date: Thu Oct 16 15:51:35 EDT 2014


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(A) Requisite Knowledge. Types of PPE and the hazards for which they are used; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures as well as law enforcement agencies; unique aspects of a suspicious letter, a suspicious package or device, an illicit laboratory, ora release/attack with a WMD agent; potential violations of criminal statutes or governmental regulations; agencies having response authority to collect evidence and public safety samples;agencies having investigative law enforcement authority to collect evidence or public safety samples; notification procedures for agencies having investigative law enforcement authority andhazardous explosive device responsibility; chain-of-custody procedures; securing, characterization, and preservation of the scene and potential forensic evidence; approved documentationprocedures; types of evidence; use and limitations of equipment to conduct field screening of samples for admission into the Laboratory Response Network or other forensic laboratory system;use of collection kits; collection and packaging of public safety samples; decontamination of packaging; prevention of secondary contamination; protection and transportation requirements forsample packaging; and procedures for going through decontamination being decontaminated while wearing PPE.


To make consistent with previous comment 6.2(A) for consistency and clarification.



Organization: [ Not Specified ]Street Address:City:State:Zip:Submittal Date: Mon Jan 05 14:09:32 EST 2015


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(B) Requisite Skills. Identifying incidents with a potential violation of criminal statutes or governmental regulations; identifying the agency having investigative jurisdiction over an incident that ispotentially criminal in nature or a violation of government regulations; operating field screening and sampling equipment; securing, characterizing, and preserving the scene; identifying andprotecting potential evidence until it can be collected by an agency with investigative authority; following chain-of-custody procedures; characterizing hazards; performing protocols for fieldscreening samples for admission into the Laboratory Response Network or other forensic laboratory system; protecting evidence from secondary contamination; determining agency havingresponse authority to collect public safety samples; determining agency having investigative law enforcement authority to collect evidence and public safety samples; collecting public safetysamples; packaging and labeling samples; decontaminating samples; going through decontamination while wearing PPE ; and preparing samples for protection and transportation to alaboratory.


Clarification and consistency.





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6.6* Product Control.Perform product control techniques with a limited risk of personal exposure at a hazardous materials/WMD incident, given a hazardous materials/WMD incident with release of product; anassignment in an IAP; policies and procedures; approved tools, equipment, control agents, and PPE; and access to a hazardous materials technician, an allied professional, an emergencyresponse plan, or standard operating procedures, so that under the guidance of a hazardous materials technician, an allied professional, an emergency response plan, or standard operatingprocedures, a product control technique is selected and implemented, the product is controlled, approved PPE is selected and used, exposures and personnel are protected, safety proceduresare followed, hazards are avoided or minimized, and, if contaminated, personnel, tools, and equipment are decontaminated.(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures; definitions of control, confinement, containment, and extinguishment; policies and procedures; product control techniques forcontrolling a release with limited risk of personal exposure; safety precautions associated with each product control technique; location and operation of remote/emergency shutoff devices incargo tanks and at fixed facilities; characteristics and applicability of approved product control agents; use of approved tools and equipment and procedures for going through technicaldecontamination when wearing PPE.(B) Requisite Skills. Selecting and using PPE; selecting and performing product control techniques to confine/contain the release with limited risk of personal exposure; using approved controlagents and equipment on a release involving hazardous materials/WMD; using remote control valves and emergency shutoff devices on cargo tanks and at fixed facilities; performing productcontrol techniques; and going through technical decontamination while wearing PPE .


It is important to know how to set up decontamination as indicated in the JPR and Requisite Knowledge however, there is no connection between product control and having personnel going through technical decontamination while wearing PPE. This requisite skill is extraneous to the JPR.


Submitter Full Name: laura cornOrganization: TEEX



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(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures; definitions of control, confinement, containment, and extinguishment; policies and procedures; product control techniques forcontrolling a release with limited risk of personal exposure; safety precautions associated with each product control technique; location and operation of remote/emergency shutoff devices incargo tanks and at fixed facilities; characteristics and applicability of approved product control agents; use of approved tools and equipment and procedures for going through technicaldecontamination when being decontaminated while wearing PPE.







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(B) Requisite Skills. Selecting and using PPE; selecting and performing product control techniques to confine/contain the release with limited risk of personal exposure; using approved controlagents and equipment on a release involving hazardous materials/WMD; using remote control valves and emergency shutoff devices on cargo tanks and at fixed facilities; performing productcontrol techniques; and going through technical decontamination while wearing PPE .


It is important to know how to set up and perform decontamination as indicated in the JPR and Requisite Knowledge however, there is no connection between product control and having personnel going through technical decontamination while wearing PPE. This requisite skill is extraneous to the JPR.


Submitter Full Name: Lawrence PrestonOrganization: Maryland Fire and Rescue Institute, University of Maryland

Affilliation: Maryland Fire and Rescue Institute, University of MarylandStreet Address:City:State:Zip:Submittal Date: Tue Nov 18 11:23:40 EST 2014


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(B) Requisite Skills. Selecting and using PPE; selecting and performing product control techniques to confine/contain the release with limited risk of personal exposure; using approved controlagents and equipment on a release involving hazardous materials/WMD; using remote control valves and emergency shutoff devices on cargo tanks and at fixed facilities; performing productcontrol techniques; and going through technical decontamination while wearing PPE .


Justification – It is important to know how to set up decontamination as indicated in the JPR and Requisite Knowledge however, there is no connection between product control and having personnel going through technical decontamination while wearing PPE. This requisite skill is extraneous to the JPR.





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(A) Requisite Knowledge. Types of PPE and the hazards for which they are used; capabilities and limitations of approved PPE; importance of working under the guidance of a hazardousmaterials technician, an allied professional, an emergency response plan, or standard operating procedures; approved detection, monitoring, and sampling equipment; policies and proceduresfor detection, monitoring, and sampling; process for selection of detection, monitoring, and sampling equipment for an assigned task; operation of approved detection, monitoring, and samplingequipment; capabilities, limitations, and local monitoring procedures, including action levels and field testing; how to read and interpret results; methods for decontaminating detection,monitoring, and sampling equipment according to manufacturers' recommendations or local policies and procedures; procedures for going through technical decontamination when beingdecontaminated while wearing PPE; maintenance procedures for detection, monitoring, and sampling equipment according to manufacturers' recommendations or local policies andprocedures; and required reporting and documentation for detection, monitoring, and sampling activities.







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(B) Requisite Skills. Selecting and using PPE; field testing and operating approved detection, monitoring, and sampling equipment; reading, interpreting, and documenting the readings fromdetection, monitoring, and sampling equipment; communicating results of detection, monitoring, and sampling; going through technical decontamination while wearing PPE ; decontaminatingdetection, monitoring, and sampling equipment; maintaining detection, monitoring, and sampling equipment according to manufacturers' specifications or local policies and procedures; andcompleting required reporting and documentation for detection, monitoring, and sampling activities.







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(A) Requisite Knowledge. Types of PPE and the hazards for which they are used; capabilities and limitations of approved PPE; importance of working under the guidance of a hazardousmaterials technician, an allied professional, an emergency response plan, or standard operating procedures; the difference between victim rescue and victim recovery; victim triage methods;considerations for determining the feasibility of rescue or recovery operations; policies and procedures for implementing rescue and recovery; safety issues; procedures, tactical guidelines,specialized rescue equipment required, and incident response considerations for rescue and recovery in the following situations: (1) line-of-sight with ambulatory victims, (2) line-of-sight withnonambulatory victims, (3) non-line-of- sight with ambulatory victims, (4) non-line-of-sight with nonambulatory victims, and (5) victim rescue operations versus victim recovery operations;rescue team positions and their functions; capabilities and limitations of approved PPE; procedures for going through technical decontamination being decontaminated while wearing PPE;and required reporting and documentation requirements for victim rescue and recovery.







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6.9* Response to Illicit Laboratories.Perform response operations at an illicit laboratory at a hazardous materials/WMD incident, given a hazardous materials/WMD incident involving an illicit laboratory; an assignment in an IAP;policies and procedures; approved tools, equipment, and PPE; and access to a hazardous materials technician, an allied professional, an emergency response plan, or standard operatingprocedures as well as law enforcement personnel, so that under the guidance of a hazardous materials technician, an allied professional, an emergency response plan, standard operatingprocedures, and law enforcement personnel, the scene is secured; the type of laboratory is identified; potential hazards are identified; control procedures are implemented; evidence ispreserved; approved PPE is selected and used; safety procedures are followed; exposures and personnel are protected; hazards are avoided or minimized; if contaminated, personnel,victims, tools, and equipment are decontaminated; and all required reports and documentation pertaining to illicit laboratory response operations are completed.(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures as well as law enforcement agencies; types of illicit laboratories and how to identify them; operational considerations at illicitlaboratories; hazards and products at illicit laboratories; potential booby traps often found at illicit laboratories; law enforcement agencies with investigative authority and responsibilities at illicitlaboratories; crime coordination with law enforcement agencies; securing and preserving evidence; procedures for conducting a joint hazardous materials/hazardous devices sitereconnaissance and hazard identification; procedures for determining atmospheric hazards through detection, monitoring, and sampling; procedures to mitigate immediate hazards; safetyprocedures and tactics; factors to be considered in the selection of decontamination, in the selection of detection devices, in the development of a remediation plan, and in decontaminatingtactical law enforcement personnel; procedures for going through technical decontamination while wearing PPE; and required reporting and documentation requirements for illicit laboratoryresponse operations.(B) Requisite Skills. Selecting and using PPE; selecting detection, monitoring, and sampling equipment; implementing technical decontamination for personnel; securing an illicit laboratory; goingthrough technical decontamination for law enforcement personnel and equipment ; identifying and isolating hazards; identifying safety hazards; conducting a joint hazardousmaterials/hazardous devices operation to mitigate hazards; implementing scene control procedures; and completing required reports and documentation pertaining to illicit laboratory responseoperations.


Because this specialty area requires interaction with law enforcement personnel, the technical decontamination component should be specific because the equipment is specialized.



Organization: TEEXStreet Address:City:State:Zip:Submittal Date: Mon Dec 22 14:10:17 EST 2014


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(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used; importance of working under the guidance of a hazardous materials technician, an allied professional, anemergency response plan, or standard operating procedures as well as law enforcement agencies; types of illicit laboratories and how to identify them; operational considerations at illicitlaboratories; hazards and products at illicit laboratories; potential booby traps often found at illicit laboratories; law enforcement agencies with investigative authority and responsibilities at illicitlaboratories; crime coordination with law enforcement agencies; securing and preserving evidence; procedures for conducting a joint hazardous materials/hazardous devices sitereconnaissance and hazard identification; procedures for determining atmospheric hazards through detection, monitoring, and sampling; procedures to mitigate immediate hazards; safetyprocedures and tactics; factors to be considered in the selection of decontamination, in the selection of detection devices, in the development of a remediation plan, and in decontaminatingtactical law enforcement personnel; procedures for going through technical decontamination being decontaminated while wearing PPE; and required reporting and documentationrequirements for illicit laboratory response operations.







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(B) Requisite Skills. Selecting and using PPE; selecting detection, monitoring, and sampling equipment; implementing technical decontamination for personnel; securing an illicit laboratory; goingthrough technical decontamination; identifying and isolating hazards; identifying safety hazards; conducting a joint hazardous materials/hazardous devices operation to mitigate hazards;implementing scene control procedures; and completing required reports and documentation pertaining to illicit laboratory response operations.







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RADIOLOGICAL DETECTION AND MONITORING Create new section to seperate radiological detection and monitoring seperate for other air monitoring and detection. Include competencies for determining background, rate vs dose, anddetermining if a radiological pacakge is leaking/breached by A) comparing meter readings to Transportation Index (TI) or B) Taking a wipe sample.


Separating radiological detection/monitoring from detection/monitoring would ensure technicians are competent in the unique aspects of radiological detection.


Submitter Full Name: Gary SharpOrganization: Independence Fire Department



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7.2.1* Detection, Monitoring, and Sampling.Classify hazardous materials/WMD by basic hazard categories and and verify the presence and concentrations of hazardous materials through detection, monitoring, and sampling at ahazardous materials/WMD incident, given a hazardous materials/WMD incident with released identified and unidentified hazardous materials, an assignment in an incident action plan (IAP),policies and procedures, and approved resources, detection and monitoring equipment, and personal protective equipment (PPE), so that PPE is selected and used; hazardousmaterials/WMD are classified by their basic hazard categories ; the presence of hazardous materials is verified; the concentrations of hazardous materials in the atmosphere are determined;samples of solids, liquids, and gases are collected; results of detection and monitoring equipment are read, interpreted, recorded, and communicated; exposures and personnel are protected;safety procedures are followed; hazards are avoided or minimized; personnel using the detection and monitoring equipment, as well as the equipment, are decontaminated; field maintenanceand testing are performed; detection and monitoring equipment are maintained; and all reports and documentation pertaining to use of detection and monitoring equipment are completed.(A) Requisite Knowledge. Basic hazard categories and and their definitions; policies and procedures; monitoring technologies; analysis process for classifying the basic hazard categories of of identified solid and liquid materials and unidentified contaminants in the atmosphere; process for determining radiation dose rates from radioactive material labels; process for monitoringlighter-than-air gases and vapors, heavier-than-air gases and vapors in a confined area, and heavier-than-air gases and vapors in an unconfined area; capabilities and limiting factors ofdetection and monitoring equipment; detection and monitoring equipment required to identify the basic hazard categories; techniques used to identify unidentified contaminants in theatmosphere; methods for collecting samples of solids, liquids, and gases; reading, interpreting, recording, and communicating test results of detection and monitoring equipment; and fieldmaintenance and testing procedures for approved detection and monitoring equipment.(B) Requisite Skills. Selecting and using PPE; classifying hazardous materials by hazard category ; verifying the presence of hazardous materials; determining the concentration of hazardousmaterials; determining radiation dose rates from radioactive material labels; collecting samples of gases, liquids, and solids; reading, interpreting, recording, and communicating readings fromdetection and monitoring equipment; going through decontamination while wearing PPE; decontaminating detection and monitoring equipment; performing field maintenance and testing fordetection and monitoring equipment; and completing required reporting and documentation for detection, monitoring, and sampling activities.


File Name Description Approved1072_DOT_Nine_Hazard_Classes.docx


“Basic Hazard Categories” is subjective. DOT Nine Hazard Classes has a defined description that lists the primary hazard that each class presents.


Submitter Full Name: Tony MussorfitiOrganization: Pacific Northwest National LabStreet Address:City:State:Zip:Submittal Date: Sun Jan 04 13:43:00 EST 2015


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7.2.1* Detection, Monitoring, and Sampling.

Classify hazardous materials/WMD by DOT Nine Classes of Hazardous Material and verify the presence and concentrations of hazardous materials through detection, monitoring, and sampling at a hazardous materials/WMD incident, given a hazardous materials/WMD incident with released identified and unidentified hazardous materials, an assignment in an incident action plan (IAP), policies and procedures, and approved resources, detection and monitoring equipment, and personal protective equipment (PPE), so that PPE is selected and used; hazardous materials/WMD are classified by their DOT Nine Classes of Hazardous Material; the presence of hazardous materials is verified; the concentrations of hazardous materials in the atmosphere are determined; samples of solids, liquids, and gases are collected; results of detection and monitoring equipment are read, interpreted, recorded, and communicated; exposures and personnel are protected; safety procedures are followed; hazards are avoided or minimized; personnel using the detection and monitoring equipment, as well as the equipment, are decontaminated; field maintenance and testing are performed; detection and monitoring equipment are maintained; and all reports and documentation pertaining to use of detection and monitoring equipment are completed.

(A) Requisite Knowledge. DOT Nine Classes of Hazardous Material and their definitions; policies and procedures; monitoring technologies; analysis process for classifying the DOT Nine Classes of Hazardous Material of identified solid and liquid materials and unidentified contaminants in the atmosphere; process for determining radiation dose rates from radioactive material labels; process for monitoring lighter-‐than-‐air gases and vapors, heavier-‐than-‐air gases and vapors in a confined area, and heavier-‐than-‐air gases and vapors in an unconfined area; capabilities and limiting factors of detection and monitoring equipment; detection and monitoring equipment required to identify the basic hazard categories; techniques used to identify unidentified contaminants in the atmosphere; methods for collecting samples of solids, liquids, and gases; reading, interpreting, recording, and communicating test results of detection and monitoring equipment; and field maintenance and testing procedures for approved detection and monitoring equipment.

(B) Requisite Skills. Selecting and using PPE; classifying hazardous materials by DOT Nine Classes of Hazardous Material; verifying the presence of hazardous materials; determining the concentration of hazardous materials; determining radiation dose rates from radioactive material labels; collecting samples of gases, liquids, and solids; reading, interpreting, recording, and communicating readings from detection and monitoring equipment; going through decontamination while wearing PPE; decontaminating detection and monitoring equipment; performing field maintenance and testing for detection and monitoring equipment; and completing required reporting and documentation for detection, monitoring, and sampling activities.

Public Input No. 111-NFPA 1072-2015 [ Section No. 7.2.1 [Excluding any Sub-Sections] ]

Classify hazardous materials/WMD by basic hazard categories and verify the presence and concentrations of hazardous materials through detection, monitoring, and sampling at a hazardousmaterials/WMD incident, given a hazardous materials/WMD incident with released identified and unidentified hazardous materials, an assignment in an incident action plan (IAP), policies andprocedures, and approved resources, detection and monitoring equipment, and personal protective equipment (PPE), so that PPE is selected and used; hazardous materials/WMD areclassified by their basic hazard categories; the presence of hazardous materials is verified; the concentrations of hazardous materials in the atmosphere are determined; samples of solids,liquids, and gases are collected; results of detection and monitoring equipment are read, interpreted, recorded, and communicated; exposures and personnel are protected; safety proceduresare followed; hazards are avoided or minimized; personnel using the detection and monitoring equipment, as well as the equipment, are decontaminated; field maintenance and testing areperformed; detection and monitoring equipment are maintained; and all reports and documentation pertaining to use of detection and monitoring equipment are completed. Minimum detection and monitoring equipment provided by the AHJ shall include: Flammable gas/LEL, oxygen level, radiation detection and monitoring, pH indicators, infraredtemperature gun, photoionization detector (PID), toxic gas sensor(s) and colorimetric sampling.


Justification Statement: Adding these monitoring and sampling technologies will define a minimum baseline of equipment for the technician necessary to identify potential hazards that responders face during responses.


Submitter Full Name: ELIZABETH HARMANOrganization: INTL ASSOC OF FIREFIGHTERSStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 14:26:55 EST 2015


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Public Input No. 147-NFPA 1072-2015 [ Section No. 7.2.1(A) ]

(A) Requisite Knowledge. Basic hazard categories and their definitions; policies and procedures; monitoring technologies; analysis process for classifying the basic hazard categories of identifiedsolid and liquid materials and unidentified contaminants in the atmosphere; process for determining radiation dose rates from radioactive material labels; process for monitoring lighter-than-airgases and vapors, heavier-than-air gases and vapors in a confined area, and heavier-than-air gases and vapors in an unconfined area; capabilities and limiting factors of detection andmonitoring equipment; detection and monitoring equipment required to identify the basic hazard categories; techniques used to identify unidentified contaminants in the atmosphere; methodsfor collecting samples of solids, liquids, and gases; reading, interpreting, recording, and communicating test results of detection and monitoring equipment; and field maintenance and testingprocedures for approved detection and monitoring equipment.


Identifying unknown materials may be more appropriate in a specialist level competency.


Submitter Full Name: Gary Sharp

Organization: Independence Fire DepartmentStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 17:10:46 EST 2015


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(A) Requisite Knowledge. Basic hazard categories and their definitions; policies and procedures; monitoring technologies; analysis process for classifying the basic hazard categories of identifiedsolid and liquid materials and unidentified contaminants in the atmosphere; process for determining radiation dose rates from radioactive material labels; process for monitoring lighter-than-airgases and vapors, heavier-than-air gases and vapors in a confined area, and heavier-than-air gases and vapors in an unconfined area; capabilities and limiting factors of detection andmonitoring equipment; detection and monitoring equipment required to presumptively identify the basic hazard categories; techniques used to identify presumptively identify unidentifiedcontaminants in the atmosphere; methods for collecting samples of solids, liquids, and gases; reading, interpreting, recording, and communicating test presumptive test results of detectionand monitoring equipment; and field maintenance and testing procedures for approved detection and monitoring equipment.


Field testing and the use of detection device do not allow for true identification. Only laboratory analysis can determine a true identification. I would suggest using presumptive identification, or eliminate the term identification altogether. The use of the term identification or identifying is implying that a technician can actually identify an unidentified material, which is not the case. They are making an assumption that they have identified a material.


Submitter Full Name: Christopher Hawley

Organization: Cecil County Department of Emergency ServicesStreet Address:City:State:Zip:Submittal Date: Sun Jan 04 16:44:38 EST 2015


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(A)* Requisite Knowledge. Types, advantages, and limitations of hazard and response information available from approved reference sources; significance and application of hazard andresponse terms; chemical and physical properties, principles of heat transfer associated with cryogenic liquid spills; signs and symptoms and target organ effects of exposure to hazardousmaterials/WMD; methods for determining the pressure and amount of lading in bulk packaging and facility containers; and hazard and response information to be communicated.


Chemical/physical properties play an important role in hazard assessment.





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(A)* Requisite Knowledge. Policies and procedures for assessing container condition; basic design and construction features, including closures for bulk and nonbulk containers, fixed facilitycontainers, DOT highway cargo tank trucks, radioactive material packaging, and piping and pipelines; process for assessing container damage; types of damage and their level of risk; types ofstress; specification markings; and methods for determining the pressure and quantity of lading remaining in containers.


Hazmat spills and fires involving DOT highway cargo tank trucks are a common hazardous materials emergency. All hazmat technicians should have basic knowledge about DOT tank truck features and characteristics.





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(A)* Requisite Knowledge. Policies and procedures for assessing container condition; basic design and construction features, including closures for bulk and nonbulk containers, fixed facilitycontainers, radioactive material packaging, and piping and pipelines; process for assessing container damage; types of damage and their level of risk; types of stress; specification markings;and methods for determining the pressure and quantity of lading remaining in containers. and


File Name Description Approved7.2.3Assessing_Container_Condition.docx


In the current edition of NFPA 472 a technician is not required to know the "methods for determining the pressure". This Requisite Knowledge is for a specialist not a Core Technician.



Organization: Pacific Northwest National LabStreet Address:City:State:Zip:Submittal Date: Sun Jan 04 14:18:00 EST 2015


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7.2.3* Assessing Container Condition.

Assess the condition of a container and its closures at a hazardous materials/WMD incident, given an incident involving hazardous materials/WMD; an assignment in an IAP; policies and procedures; the scope of the incident, including results of detection, monitoring, and sampling; a container with required markings; and approved resource and PPE, so that PPE is selected and used; the container and its closures are inspected; type of damage to the container and closures is identified; the type stress on the container is identified; the level of risk associated with container and closure damage and stress is identified; safety procedures are followed; hazards are avoided or minimized; if contaminated, personnel, tools, and equipment are decontaminated; and a description of the condition of the container and its closures is communicated.

(A)*

Requisite Knowledge. Policies and procedures for assessing container condition; basic design and construction features, including closures for bulk and nonbulk containers, fixed facility containers, radioactive material packaging, and piping and pipelines; process for assessing container damage; types of damage and their level of risk; types of stress; specification markings; and factors of and indicators for an increase in pressure.


Predict the behavior of the hazardous materials/WMD involved in a hazardous materials/WMD incident, given an incident involving multiple a hazardous materials/WMD; an assignment in anIAP; policies and procedures; physical and chemical properties of the materials involved; results of detection, monitoring, and sampling; condition of the container (damage and stress);surrounding conditions; and approved reference sources, so that the behavior of each hazardous materials/WMD container and its contents is identified, the reactivity issues and hazards of thecombined materials are identified, and a description of the likely behavior is communicated.


Consider asking a technician to predict the behavior of only a single hazardous materials. Estimating the behavior of multiple hazardous materials is likely a specialist level skill.


Submitter Full Name: Gary SharpOrganization: Independence Fire DepartmentStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 17:00:33 EST 2015


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(A)* Requisite Knowledge. Process for predicting behavior, resources that indicate the reactivity issues of mixing various hazardous materials/WMD, impact of fire, and safety features on thebehavior of products at facilities, heat transfer processes that occur as a result of a cryogenic liquid spill, and methods for communicating the results of predicting behavior.


Consider estimating behavior of multiple chemicals including mixing of chemicals to a specialist level skill




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Develop Recommend to the incident commander or hazmat officer, response objectives and response options at a hazardous materials/WMD incident, given a hazardous materials/WMDincident; an assignment in an IAP; results of the incident analysis, including incident-related information, life safety risks, environmental risks, and property risks; available resources; andpolicies and procedures, so that response objectives are identified for the incident and response options are identified for each response objective.


Developing response objectives to be included in the IAP occurs at the command (IC) or Branch/Group Level. Including the ability to "Develop" objectives in the knowledge and skills required of new hazmat technician seems beyond a technicians scope.

Emphasis for hazmat technician knowledge/skills should be in the Implement phase (such as air monitoring and product control) and not in the Plan of APIE. Technicians should have the knowledge and skills to Implement (including dome clamps and chlorine kits) after they have been briefed on a Plan developed by the IC with input from the Hazmat Officer.





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(A)* Requisite Knowledge. Four Five levels of PPE; types of PPE available for various hazards; factors to be considered in selecting respiratory protection; factors to be considered in selectingchemical-protective clothing (CPC) or structural fire fighting protective clothing (SFFPC) ; significance of degradation, penetration, and permeation on the selection of CPC and SFFPC ;indications of material degradation of CPC and SFFPC ; different designs of vapor-protective clothing and splash-protective clothing and their advantages and disadvantages; types,advantages, and disadvantages of heat exchange units used for cooling personnel who are wearing PPE; information provided on chemical compatibility charts; and effects of physiologicaland psychological stresses on users of PPE.


A large percentage of hazardous materials spills involve flammable liquids and gases. In many cases, structural or other fire protective clothing may be the most appropriate PPE for the hazard. Hazmat technicians should be able to determine when fire protective clothing is, and is not, is the safest PPE selection.

Hazmat technicians may supervise operations responders performing mission specific competencies, including rescue/recovery. The technician should be familiar with the use and limitation of fire fighter structural protective clothing that will be used by a majority of first responders conducting rescue/recovery operations.




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(A) * Requisite Knowledge. Four NFPA PPE standards, certification levels, and advantages of using certified PPE; Four levels of PPE; types of PPE available for various hazards; factors to beconsidered in selecting respiratory protection; factors to be considered in selecting chemical-protective clothing (CPC); significance of degradation, penetration, and permeation on theselection of CPC; indications of material degradation of CPC; different designs of vapor-protective clothing and splash-protective clothing and their advantages and disadvantages; types,advantages, and disadvantages of heat exchange units used for cooling personnel who are wearing PPE; information provided on chemical compatibility charts; and effects of physiologicaland psychological stresses on users of PPE.


NFPA 1991, 1992, 1994 and 1999 (and others) should be considered in both the text and the annex materials. All efforts should be made to move towards the incorporation of relevant standards into the JPRs.


Submitter Full Name: Christina Baxter

Organization: US Department of DefenseStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 11:17:08 EST 2015


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Public Input No. 77-NFPA 1072-2015 [ Section No. 7.3.2(B) ]

(B) Requisite Skills. Selecting PPE ensemble (both respiratory protection and CPC) for a specified response option and determining effectiveness of protective clothing construction materialusing chemical compatibility charts.


A PPE Ensemble is inclusive of respiratory protection and does not need to be delineated by the standard. An ensemble consists of the elements required to offer protection to the responder. Adding the term effectiveness regarding chemical compatibility would spur the thought to compare one type of fabric over another and would add additional thoughts that the responder would have to check. The change simplifies the language.


Submitter Full Name: Christopher HawleyOrganization: Cecil County Department of Emergency Services



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(B) Requisite Skills. Selecting PPE ensemble (both respiratory protection and CPC) for a specified response option and determining protective clothing construction material using chemicalcompatibility charts.


I deleted (both respiratory and CPC) because there are other types of PPE not included such as Thermal, Multi-threat. I would suggest not listing any specific types of PPE and just use the generic term PPE.





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Develop a plan of action for a Determine the tasks and equipment required to meet the response objectives at hazardous materials/WMD incident, given a hazardous materials/WMD incident,an assignment in an IAP, results of the incident analysis, response objectives and options for the given incident, available resources, and policies and procedures, so that a plan of action isdeveloped, specified response objectives and response options are addressed, plan is consistent with the emergency response plan and policies and procedures, and plan is within thecapability of available personnel, PPE, and control equipment.


Proposed language did not make sense, asking a technician to develop a plan of action, given an IAP and incident analysis, response objectives. (Develop a plan, given a plan).

Response objectives and IAPs (plans) are developed higher in the ICS structure. A technician may determine the tasks required to meet and assigned objective when properly briefed on the IAP.

Consider also including language on a the knowledge/skill to "Conduct a briefing" given an IAP, objectives, etc. Conducting or participating in a tactical level briefing is a NIMS 100 student objective. Developing a plan would be a NIMS 200 or 300 level skill depending on the incident size or complexity.





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Develop a Development of a plan of action for , when time allows, for a hazardous materials/WMD incident, given a hazardous materials/WMD incident, an assignment in an IAP, results ofthe incident analysis, response objectives and options for initial incident size-up, preliminary response objectives and any potential options (if any present themselves) for the given incident,available resources, and policies and procedures, with the best available information at the time of the development so that a plan of action is developed, specified response objectives andresponse options are addressed, plan is consistent with the emergency response plan and policies and procedures, and plan is within the capability of available personnel, PPE, and controlequipment.


The language presented is only for intent and should be scrubbed, however the language that was present reads as if the IC or the HZMT/WMD Branch had 100% of the information during size-up. This will lead to a rigid plan and prevent entry teams ability to make that split second call. Unknowns will be encountered, and won't be outliers. an IAP should start with the hazard assessment and move towards developing a rough out plan to prevent delaying or paralyzing first recon and entry.

it is said that the first 10 minutes of a HZMT Scene sets the pace of the first hour, which determines the outcome. establishing the IAP as described would lead to restrained response, and liable responders.

please consider the intent to allow for the planning to be done by on IC and HZMT Branch on scene, based on what they have for resources what they can determine/see, but also what they cannot not. it should not be a dissertation to the IC who would typically need an interpreter, the IC needs short quick recommendations with probable outcomes of IDed offensive vs non-intervention, not 50 "what-Ifs". Training, resources and experience of the HZMT Branch should be allow to fluidly attack and adjust mitigation measures of the actions w/o hand-cuffing already limited resources with additional written documentation.


Submitter Full Name: michael kleckerOrganization:Street Address:City:State:Zip:Submittal Date: Sun Nov 09 19:57:20 EST 2014


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(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used; capabilities, limitations, selection, and use of PPE; components of an IAP; safety procedures for personnelworking in CPC PPE ; additional safety concerns of working in the hot zone; procedures for decontamination, maintenance, inspection, and storage of PPE; procedures for maintenance,testing, inspection, and storage of PPE according to manufacturers' specifications or local policies and procedures; and forms and procedures for reporting and documenting PPE use.


This JPR seems to be talking about PPE, but CPC limits the intent at this point. Therefore, the change to PPE for clarification of intent.





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(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used; capabilities, limitations, selection, and use of PPE; components of an IAP; safety procedures for personnelworking in CPC; additional safety concerns of working in the hot zone; procedures for decontamination, maintenance, inspection, and storage of PPE; procedures for maintenance, testing,inspection, procedures for being decontaminated while wearing PPE, and storage of PPE according to manufacturers' specifications or local policies and procedures; and forms andprocedures for reporting and documenting PPE use.


Important step in the use of PPE.





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(B) Requisite Skills. Inspecting, donning, working in, going through technical decontamination while wearing PPE , and doffing liquid splash–protective and vapor-protective–chemical-protectiveclothing ensembles (including respiratory protection) and any other approved specialized personal protective equipment; going through technical decontamination while wearing PPE;completing required reports and documents for the use of CPC PPE ; and repairing and testing of CPC PPE according to manufacturers' specifications or local policies and procedures.


Need to clarify need to function with any approved PPE not just CPC. Consistency with decontamination - while wearing PPE.





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(B) Requisite Skills. Inspecting, donning, working in, going through technical decontamination, and doffing liquid splash–protective and vapor-protective–chemical-protective clothing ensembles(including respiratory protection) and and any other approved specialized personal protective equipment; going through technical decontamination while wearing PPE; completing requiredreports and documents for the use of CPC; and repairing and testing of CPC according to manufacturers' specifications or local policies and procedures.


A PPE Ensemble is inclusive of respiratory protection and does not need to be delineated by the standard. An ensemble consists of the elements required to offer protection to the responder. The change simplifies the language.





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Public Input No. 76-NFPA 1072-2015 [ New Section after 7.4.3.1 ]

Bulk ContainersI have been a Hazmat Tech on a dedicated hazmat team for over 20 years and in this document I do not see anything about highway cargo tanks, railcar tanks, IMO, and storage tanks. It isvery important that these subject matters be in the core of hazmat technician training since these type of containers are used about 99% of the time in shipments. And a technician canencounter these at any time. I feel that this document is trying to dumb down the technician training and this will hurt our service that we need to provide to the citizens in the communities thatwe serve. I have been teaching technician for several years and feel that what NFPA is doing is not serving the fire service hazardous materials response teams. I know that the committee hasworked very hard on this but I think you missed the boat on what we need for training technicians for there basic training. We can not take away the core that has been there for years just tosatisfy other agencies NFPA was set up for the Firefighters to have a set standard to follow. So please put back the bulk containers in the core of technician.


This would resolve not having to retrain our tech's after their initial training and keep all technician training the same across the country.


Submitter Full Name: Butch Hayes

Organization: Houston Fire DepartmentStreet Address:City:State:Zip:Submittal Date: Sun Jan 04 10:10:37 EST 2015


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Public Input No. 115-NFPA 1072-2015 [ Section No. 7.4.3.1(A) ]

(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used; policies and procedures for product control; purpose of, procedures for, required tools and equipment for, andsafety precautions for hazardous materials/WMD control techniques; location and operation of remote emergency shutoff devices in cargo tanks and at fixed facilities; characteristics,applicability, and use of approved product control agents; use of approved tools and equipment; and procedures for inspection and maintenance of tools and equipment.


Do we want to add "dome clamps" as part of Product Control? It was specifically mentioned in NFPA 472 . . .





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Public Input No. 139-NFPA 1072-2015 [ Section No. 7.4.3.1(B) ]

(B)* Requisite Skills. Selecting and using PPE, selecting and using approved control agents and equipment on a release involving hazardous materials/WMD, using container control valves andremote emergency shutoff devices on cargo tanks and at fixed facilities, performing product control techniques, and inspecting and maintaining tools and equipment.

Add language to include leak control on DOT cargo tank trucks including applicaiton of dome clamps to MC306/DOT 406. Add language to include application of specialized emergnecyresposne kits used by the AHJ, such as the Chlorine A or B kit.


Would keep current hazmat technician skill set from being degraded by new language.





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(B)* Requisite Skills. Selecting and using PPE, selecting and using approved control agents and equipment on a release involving hazardous materials/WMD, using container control valves andremote emergency shutoff devices on cargo tanks and at fixed facilities, performing product control techniques, and inspecting and maintaining tools and equipment.

Add language to include skills required to apply dome clamps and apply specialized leak control kits such as chlorine A/B kits.


Adding additional language would prevent current hazmat technician skill set from being degraded by new language.





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7.4.3.2* Controlling Container Leaks.Control leaks from various containers and and their closures at a hazardous materials/WMD incident, given a hazardous materials/WMD incident; an assignment in an IAP; a leak from acontainer or its closures; policies and procedures; and approved tools, equipment, and PPE, so that an approved product control technique is selected and used; leaks are controlled;approved PPE is selected and used; exposures and personnel are protected; safety procedures are followed; hazards are avoided or minimized; if contaminated, emergency responders, tools,and equipment used are decontaminated; and tools and equipment are inspected and maintained.(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for controlling leaks in nonbulk and radioactive material packaging and ton andintermediate bulk containers, types of containers and and their closures, ways in which containers and their closures develop leaks, hazards associated with container/closure leaks andcontrolling those leaks, techniques to control container/closure leaks, approved tools and equipment used to control container/closure leaks, and equipment and maintenance procedures.(B)* Requisite Skills. Selecting and using PPE, controlling leaks on containers and their closures, closing open valves, replacing missing plugs and tightening loose plugs, following safetyprocedures, avoiding or minimizing hazards, going through technical decontamination while wearing PPE, decontaminating tools and equipment, and inspecting and maintaining tools andequipment.


File Name Description Approved7.4.3.2_Controlling_Container_Leaks.docx


"Various Containers" is too generic.


Submitter Full Name: Tony MussorfitiOrganization: Pacific Northwest National LabStreet Address:City:State:Zip:Submittal Date: Sun Jan 04 14:50:52 EST 2015


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7.4.3.2* Controlling Container Leaks.

Control leaks from non-‐bulk and intermediate bulk containers, radioactive material packaging and their closures at a hazardous materials/WMD incident, given a hazardous materials/WMD incident; an assignment in an IAP; a leak from a container or its closures; policies and procedures; and approved tools, equipment, and PPE, so that an approved product control technique is selected and used; leaks are controlled; approved PPE is selected and used; exposures and personnel are protected; safety procedures are followed; hazards are avoided or minimized; if contaminated, emergency responders, tools, and equipment used are decontaminated; and tools and equipment are inspected and maintained.

(A)*

Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for controlling leaks in non-‐bulk and intermediate bulk containers, radioactive material packaging and their closures, ways in which containers and their closures develop leaks, hazards associated with container/closure leaks and controlling those leaks, techniques to control container/closure leaks, approved tools and equipment used to control container/closure leaks, and equipment and maintenance procedures.

Public Input No. 116-NFPA 1072-2015 [ Section No. 7.4.3.2 [Excluding any Sub-Sections] ]

Control leaks from various nonbulk bulk and radioactive material packaging and ton and intermediate bulk containers and their closures at a hazardous materials/WMD incident, given ahazardous materials/WMD incident; an assignment in an IAP; a leak from a container or its closures; policies and procedures; and approved tools, equipment, and PPE, so that an approvedproduct control technique is selected and used; leaks are controlled (contined or contained) ; approved PPE is selected and used; exposures and personnel are protected; safety proceduresare followed; hazards are avoided or minimized; if contaminated, emergency responders, tools, and equipment used are decontaminated; and tools and equipment are inspected andmaintained.


Clarification of intent.





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(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for controlling leaks in nonbulk and radioactive material packaging and ton andintermediate bulk containers, highway cargo tanks, types of containers and their closures, ways in which containers and their closures develop leaks, hazards associated withcontainer/closure leaks and controlling those leaks, techniques to control container/closure leaks, approved tools and equipment used to control container/closure leaks, and equipment andmaintenance procedures. procedure

* Justification

In a review of data found on the US Department of Transportation website, 13,249 incidents were reported to US DOT involving highway cargo equipment. With respect to incidents involvingbulk packages, almost two-thirds (64%) of those reported to US DOT involved highway bulk packages. With almost every jurisdiction having roads and highways present within their borders,anyone trained to the Hazardous Materials Technician-level should have the required knowledge and skills to respond to incidents involving these containers. This includes have a basicknowledge of construction and design features, appliances and safety equipment, basic commodity access, and emergency leak control (such as basic plugging/patching, application of domeclamps, and basic container stabilization) and off-loading considerations (such as the applicability of grounding and bonding, container compatibility, need for specialized assistance...)


* Justification

In a review of data found on the US Department of Transportation website, 13,249 incidents were reported to US DOT involving highway cargo equipment. With respect to incidents involving bulk packages, almost two-thirds (64%) of those reported to US DOT involved highway bulk packages. With almost every jurisdiction having roads and highways present within their borders, anyone trained to the Hazardous Materials Technician-level should have the required knowledge and skills to respond to incidents involving these containers. This includes have a basic knowledge of construction and design features, appliances and safety equipment, basic commodity access, and emergency leak control (such as basic plugging/patching, application of dome clamps, and basic container stabilization) and off-loading considerations (such as the applicability of grounding and bonding, container compatibility, need for specialized assistance...)


Submitter Full Name: Thomas Jordan

Organization: Virginia Department of Emergency ManagementStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 14:52:57 EST 2015


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(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for controlling leaks in nonbulk and radioactive material packaging and , ton andintermediate bulk containers and tank trucks , types of containers and their closures, ways in which containers and their closures develop leaks, hazards associated with container/closureleaks and controlling those leaks, techniques to control container/closure leaks, approved tools and equipment used to control container/closure leaks, and equipment and maintenanceprocedures.


The deliniation of skills is too low at the non-bulk level. Cargo tank trucks are a common response for many haz mat teams and need to be included in the standard as a Technician level skill. While there may be some jurisdictions who do not respond to many cargo tanker incidents, there are many more that do. For example, gasoline is transported into every community.


Submitter Full Name: Richard EmeryOrganization: Emery & Associates, Inc.



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(A)* Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for controlling leaks in nonbulk and radioactive material packaging and ton andintermediate bulk containers and cargo tanks , types of containers and their closures, ways in which containers and their closures develop leaks, hazards associated with container/closureleaks and controlling those leaks, techniques to control container/closure leaks, approved tools and equipment used to control container/closure leaks, and equipment and maintenanceprocedures.


Addressing leaks in containers/closures on cargo tank trucks should be a basic or minimum requirement for the Technician. There is not a single jurisdiction that does not have a roadway that traverses the community. While a jurisdiction may not have a rail or maritime interface, every community has over the road transportation of hazardous materials through their jurisdiction. MC306/DOT406 gasoline tank trucks travel those roadways making deliveries to distribution points (Fuel Stations). Accidents occur often with these types of cargo tanks and overturned gasoline tank trucks are common. A very basic skill of applying dome clamps to leaking closures on top of those tanks is critical to controlling the leaking container and stabilizing the situation until the products can be transferred.


Submitter Full Name: ROBERT ROYALL

Organization: HARRIS COUNTY FIRE MARSHAL'S OFFICEStreet Address:City:State:Zip:Submittal Date: Wed Dec 31 18:31:13 EST 2014


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(A) * Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for controlling leaks in nonbulk and radioactive material packaging and ton andintermediate bulk containers, highway cargo tanks , types of containers and their closures, ways in which containers and their closures develop leaks, hazards associated withcontainer/closure leaks and controlling those leaks, techniques to control container/closure leaks, approved tools and equipment used to control container/closure leaks, and equipment andmaintenance procedures.

Justification

*It is our belief that at the technician level hazmat responder's should have the requisite knowledge and ability to respond to highway cargo tanks. Every jurisdiction has the potential for aMC306/DOT407 incident involving diesel or gasoline. The hazmat technician should have the ability to apply dome clamps for product control and prepare the container for transfer.


*It is our belief that at the technician level hazmat responder's should have the requisite knowledge and ability to respond to highway cargo tanks. Every jurisdiction has the potential for a MC306/DOT407 incident involving diesel or gasoline. The hazmat technician should have the ability to apply dome clamps for product control and prepare the container for transfer.


Submitter Full Name: K. Collins

Organization: Virginia Department of EmergenStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 11:05:50 EST 2015


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(A) * Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for controlling leaks in nonbulk and radioactive material packaging and , ton andintermediate bulk containers and cargo tanks , types of containers and their closures, ways in which containers and their closures develop leaks, hazards associated with container/closureleaks and controlling those leaks, techniques to control container/closure leaks, approved tools and equipment used to control container/closure leaks, and equipment and maintenanceprocedures.


Cargo tanks are too common of a response element to not be included in the basic Hazmat Technician requirements.


Submitter Full Name: Christina BaxterOrganization: US Department of Defense



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(B)* Requisite Skills. Selecting and using PPE, controlling leaks on containers and their closures, closing open valves, replacing missing plugs and tightening loose plugs, and applying domeclamps, following safety procedures, avoiding or minimizing hazards, going through technical decontamination while wearing PPE, decontaminating tools and equipment, and inspecting andmaintaining tools and equipment.


Addressing leaks in containers/closures on cargo tank trucks should be a basic or minimum requirement for the Technician. There is not a single jurisdiction that does not have a roadway that traverses the community. While a jurisdiction may not have a rail or maritime interface, every community has over the road transportation of hazardous materials through their jurisdiction. MC306/DOT406 gasoline tank trucks travel those roadways making deliveries to distribution points (Fuel Stations). Accidents occur often with these types of cargo tanks and overturned gasoline tank trucks are common. A very basic skill of applying dome clamps to leaking closures on top of those tanks is critical to controlling the leaking container and stabilizing the situation until the products can be transferred.


Submitter Full Name: ROBERT ROYALL

Organization: HARRIS COUNTY FIRE MARSHAL'S OFFICEStreet Address:City:State:Zip:Submittal Date: Wed Dec 31 18:42:56 EST 2014


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(B)* Requisite Skills. Selecting and using PPE, controlling leaks on containers and their closures, closing open valves, replacing missing plugs and tightening loose plugs, applying dome clampsor other devices to control a release, following safety procedures, avoiding or minimizing hazards, going through technical decontamination while wearing PPE, decontaminating tools andequipment, and inspecting and maintaining tools and equipment.


The bread and butter response for a HazMat team is a response to a 306/406 tank, and one of the most common methods to handle a release is a dome clamp, or other device that can be used to control a tank truck release. A HazMat technician should be well versed in handling the common incidents involving tank trucks. In the 2014 DOT reporting of incidents shows there were a total of 1034 incidents reported. 327 were involving 307/407 tanks, 213 were from 306/406, 67 from 312/412 and 23 from MC331 tanks. A quick look at the 307/407 data shows that many of those incidents involved flammable and combustible liquids. Gasoline tank trucks, fuel trucks travel in every community and present risk.



Organization: Cecil County Department of Emergency ServicesStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 09:01:51 EST 2015


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(B) * Requisite Skills. Selecting and using PPE, controlling leaks on containers and their closures, closing open valves, replacing missing plugs and tightening loose plugs, following applyingdome clamps , following safety procedures, avoiding or minimizing hazards, going through technical decontamination while wearing PPE, decontaminating tools and equipment, andinspecting and maintaining tools and equipment.Justification

*It is our belief that at the technician level hazmat responder's should have the requisite knowledge and ability to respond to highway cargo tanks. Every jurisdiction has thepotential for a MC306/DOT407 incident involving diesel or gasoline. The hazmat technician should have the ability to apply dome clamps for product control and prepare thecontainer for transfer.


*It is our belief that at the technician level hazmat responder's should have the requisite knowledge and ability to respond to highway cargo tanks. Every jurisdiction has the potential for a MC306/DOT407 incident involving diesel or gasoline. The hazmat technician should have the ability to apply dome clamps for product control and prepare the container for transfer.


Submitter Full Name: K. CollinsOrganization: Virginia Department of Emergen



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(A) Requisite Knowledge. Types of PPE and the hazards for which they are used, policies and procedures for overpacking damaged or leaking nonbulk and radioactive materials packaging,ways in which nonbulk, cargo tanks and radioactive material packaging are damaged, hazards associated with overpacking damaged or leaking nonbulk and radioactive materials packaging,methods to overpack damaged or leaking nonbulk and radioactive materials packaging, marking and labeling overpack containers, the tools and equipment used to overpack damaged orleaking nonbulk and radioactive materials packaging, and equipment and maintenance procedures.


One of the most common responses for a HazMat team is a saddle tank release or transfer operations. Every tractor trailer has a saddle tank carrying hundreds of gallons of fuel and the HazMat Tech should be able to handle these types of releases and other common tank truck incidents. Another bread and butter response for a HazMat team is a response to a 306/406 tank, and one of the most common methods to handle a release is a dome clamp, or other device that can be used to control a tank truck release. A HazMat technician should be well versed in handling the common incidents involving tank trucks. In the 2014 DOT reporting of incidents shows there were a total of 1034 incidents reported. 327 were involving 307/407 tanks, 213 were from 306/406, 67 from 312/412 and 23 from MC331 tanks. A quick look at the 307/407 data shows that many of those incidents involved flammable and combustible liquids. Gasoline tank trucks, fuel trucks, LPG and other common tanks travel in every community and present risk.


Submitter Full Name: Christopher HawleyOrganization: Cecil County Department of Emergency ServicesStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 09:13:20 EST 2015


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Public Input No. 83-NFPA 1072-2015 [ New Section after 7.4.3.3(B) ]

Requisite Skills. Product Transfer: Transfer products from non-bulk and intermediate bulk containers, radioactive material packaging into approved containers, at a hazardous materials/WMD incident, as perthe AHJ’s policies and procedures; and approved tools, grounding and bonding equipment, and PPE, so that an approved product transfer and grounding and bonding technique is selectedand used; leaks are controlled; approved PPE is selected and used; exposures and personnel are protected; safety procedures are followed; hazards are avoided or minimized; ifcontaminated, emergency responders, tools, and equipment used are decontaminated; and tools and equipment are inspected and maintained.


Product Transfer and Grounding and Bounding was not addressed in the document. This needs to be a required competency for a Core Technician for a safe and effective response.





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(B) Requisite Skills. Selecting and using PPE, placing a damaged or leaking nonbulk and radioactive materials packaging into the overpack container, controlling a relesase from a cargo tank,following safety procedures, minimizing and avoiding hazards, decontaminating tools and equipment, and inspecting and maintaining tools and equipment.


One of the most common responses for a HazMat team is a saddle tank release or transfer operations. Every tractor trailer has a saddle tank carrying hundreds of gallons of fuel and the HazMat Tech should be able to handle these types of releases and other common tank truck incidents. Another bread and butter response for a HazMat team is a response to a 306/406 tank, and one of the most common methods to handle a release is a dome clamp, or other device that can be used to control a tank truck release. A HazMat technician should be well versed in handling the common incidents involving tank trucks. In the 2014 DOT reporting of incidents shows there were a total of 1034 incidents reported. 327 were involving 307/407 tanks, 213 were from 306/406, 67 from 312/412 and 23 from MC331 tanks. A quick look at the 307/407 data shows that many of those incidents involved flammable and combustible liquids. Gasoline tank trucks, fuel trucks, LPG and other common tanks travel in every community and present risk.



Organization: Cecil County Department of Emergency ServicesStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 09:18:11 EST 2015


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Perform Research, establish, and implement technical decontamination in support of entry operations and for ambulatory and nonambulatory victims at a hazardous materials/WMDincident, given a hazardous materials/WMD incident requiring technical decontamination; an assignment in an IAP; policies and procedures; and approved PPE, tools, and equipment, so thatapproved PPE is selected and used; a technical decontamination procedure is selected, set up, implemented, evaluated, and terminated; victims are decontaminated; safety procedures arefollowed; hazards are avoided or minimized; if contaminated, personnel, tools, and equipment are decontaminated; and all reports and documentation of technical decontamination operationsare completed.* Justification

Decontamination is a skill that can be performed by hazardous materials operations-level responders. In 6.4 of this document, operations-level responders can perform technical decon under"...the guidance of a hazardous materials technician...". It appears if the Technician may be called into the role of "guiding" responders in how to perform the function, the higher-order analysisand knowledge are the most important piece. The questions this section should answer is can the technician-level responder research and select the appropriate technical decontaminationpractice, can the process be set-up correctly to minimize secondary contamination and reduce the risk to the responder, and can it be implemented safely and effectively.


* Justification

Decontamination is a skill that can be performed by hazardous materials operations-level responders. In 6.4 of this document, operations-level responders can perform technical decon under "...the guidance of a hazardous materials technician...". It appears if the Technician may be called into the role of "guiding" responders in how to perform the function, the higher-order analysis and knowledge are the most important piece. The questions this section should answer is can the technician-level responder research and select the appropriate technical decontamination practice, can the process be set-up correctly to minimize secondary contamination and reduce the risk to the responder, and can it be implemented safely and effectively.


Submitter Full Name: Thomas JordanOrganization: Virginia Department of Emergency ManagementStreet Address:City:State:Zip:Submittal Date: Mon Jan 05 15:17:47 EST 2015


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Perform Demonstrate the ability to setup and implement technical decontamination in support of entry operations and for ambulatory and nonambulatory victims at a hazardousmaterials/WMD incident, given a hazardous materials/WMD incident requiring technical decontamination; an assignment in an IAP; policies and procedures; and approved PPE, tools, andequipment, so that approved PPE is selected and used; a technical decontamination procedure is selected, set up, implemented, evaluated, and terminated; victims are decontaminated; safetyprocedures are followed; hazards are avoided or minimized; if contaminated, personnel, tools, and equipment are decontaminated; and all reports and documentation of technicaldecontamination operations are completed.


Performing decontamination is not a Technician requirement. According to 7.4.5 in 472, “The hazardous materials technician shall demonstrate the ability to set up and implement the following types of decontamination.”(1) Technical decon in support of entry operations(2) Technical decon operations for ambulatory and non-ambulatory victims(3) Mass decon for ambulatory and non-ambulatory victims.

It doesn’t say the Technician has to perform decon. In fact the Technician may even act as the Decon Officer or Assistant Safety Officer – HazMat. Performing decon is not a Technician level skill.


Submitter Full Name: ROBERT ROYALLOrganization: HARRIS COUNTY FIRE MARSHAL'S OFFICEStreet Address:City:State:Zip:Submittal Date: Wed Dec 31 18:04:14 EST 2014


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Perform Implement technical decontamination in support of entry operations and for ambulatory and nonambulatory victims at a hazardous materials/WMD incident, given a hazardousmaterials/WMD incident requiring technical decontamination; an assignment in an IAP; policies and procedures; and approved PPE, tools, and equipment, so that approved PPE is selectedand used; a technical decontamination procedure is selected, set up, implemented, evaluated, and terminated; victims are decontaminated; safety procedures are followed; hazards areavoided or minimized; if contaminated, personnel, tools, and equipment are decontaminated; and all reports and documentation of technical decontamination operations are completed.


7.4.4.2 should be consistent with 472 in 7.4.5, “The hazardous materials technician shall demonstrate the ability to set up and implement the following types of decontamination.” The language should be the same, and the performing the act of decontamination is an operations level skill not a technician level skill. The technician may determine the type and scope of decontamination and may even direct the effort but they do not perform the skill.





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Perform Demonstrate the ability to set up and implement technical decontamination in support of entry operations and for ambulatory and nonambulatory victims at a hazardousmaterials/WMD incident, given a hazardous materials/WMD incident requiring technical decontamination; an assignment in an IAP; policies and procedures; and approved PPE, tools, andequipment, so that approved PPE is selected and used; a technical decontamination procedure is selected, set up, implemented, evaluated, and terminated; victims are decontaminated; safetyprocedures are followed; hazards are avoided or minimized; if contaminated, personnel, tools, and equipment are decontaminated; and all reports and documentation of technicaldecontamination operations are completed.

Justification

To be consistent with NFPA 472 7.4.5 "The hazardous materials technician shall demonstrate the ability to set up and implement the following types of decontamination..."


JustificationTo be consistent with NFPA 472 7.4.5 "The hazardous materials technician shall demonstrate the ability to set up and implement the following types of decontamination..."


Submitter Full Name: K. CollinsOrganization: Virginia Department of Emergen



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Public Input No. 74-NFPA 1072-2015 [ Chapter A [Excluding any Sub-Sections] ]

Annex A is not a part of the requirements of this NFPA document but is included for informational purposes only. This annex contains explanatory material, numbered to correspond with theapplicable text paragraphs.

A 2.3 The National Fallen Firefighters Foundation sponsored a symposium in 2004 in Tampa, FL. At this milestone event more than 200 fire service leaders assembled and discussed thenation's fire problem and how to drastically reduce the number of firefighter line of duty deaths. This event was the birth of the 16 Firefighter Life Safety Initiatives which should be the catalystfor fire service training and education, and the foundation for strategic level policies and procedures. Particular interest would be initiatives:

1. Define and advocate the need for a cultural change within the fire service relating to safety; incorporating leadership, management, supervision, accountability and personal responsibility.

2. Enhance the personal and organizational accountability for health and safety throughout the fire service.

3. Focus greater attention on the integration of risk management with incident management at all levels, including strategic, tactical, and planning responsibilities.

4. All firefighters must be empowered to stop unsafe practices.

6. Develop and implement national medical and physical fitness standards that are equally applicable to all firefighters, based on the duties they are expected to perform.

7. Create a national research agenda and data collection system that relates to the initiatives.

8. Utilize available technology wherever it can produce higher levels of health and safety.

9. Thoroughly investigate all firefighter fatalities, injuries, and near misses.

11. National standards for emergency response policies and procedures should be developed and championed


This statement further explains the request to add the 16 Firefighter Life Safety Initiatives to section 2.3


Submitter Full Name: Richard MasonOrganization: National Fallen Firefighters FoundationStreet Address:City:State:Zip:Submittal Date: Sat Jan 03 16:04:05 EST 2015


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Public Input No. 117-NFPA 1072-2015 [ Section No. A.1.1 ]

A.1.1 The committee recognizes that emergency services organizations might have to invest considerable resources to provide the equipment and training needed to respond to incidents involvinghazardous materials or weapons of mass destruction (WMD) safely and efficiently. The committee does not mean to imply that organizations with limited resources cannot provide responseservices, only that the individuals charged with responsibilities are qualified to specific levels according to this standard.


Consistency editorial.l





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Public Input No. 72-NFPA 1072-2015 [ Section No. A.3.3.16.2 ]

A.3.3.16.2 Mass Decontamination. Mass decontamination is initiated where the number of victims and time constraints do not allow the establishment of an in-depth decontamination process. Mass decontamination is a grossdecontamination process utilizing large volumes of low-pressure water to reduce the level of contamination. A soap-and-water solution or universal decontamination solution would be moreeffective; however, availability of such solutions in sufficient quantities cannot always be ensured. [ 472, 2013]

Extensive research into mass decontamination operations at terrorist incidents involving hazardous materials and chemical warfare agents has been conducted by the U.S. Army's Research,Development, and Engineering Command (RDECOM), and the resulting guidelines and documents are available on the Internet. [ 472, 2013]

Mass decontamination should be established quickly to reduce the harm being done to the victims by the contaminants. Initial operations will likely be through handheld hose lines or masterstreams supplied from fire apparatus while a more formal process is being set up. Examples of mass decontamination methods are the ladder pipe decontamination system and theemergency decontamination corridor system, both of which are described in RDECOM's guidelines. [ 472, 2013]


File Name Description ApprovedMass_Decontamination_Definition.docx


Include this definition for clarification of the term used within this document and does not include information on a Technical Mass Decontamination.




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Mass Decontamination. The physical process of reducing or removing surface contaminants from large numbers of victims in potentially life-‐threatening situations in the fastest time possible through an emergency or technical process.

ANNEX:

Mass decontamination is initiated where the number of victims and time constraints may not allow the establishment of an in-‐depth decontamination process. Mass decontamination should be established quickly to reduce the harm being done to the victims by the contaminants. Initial operations will likely be an emergency decontamination, through handheld hose lines or master streams supplied from fire apparatus while a more formal process is being set up. This may need to be followed up by a formal technical decontamination when the initial emergency decontamination has been determined to not be effective through detection, observation or concern. For example, victims exposed to a Radiological Dispersal Device (RDD) or an aerosolized biological agent.

Public Input No. 118-NFPA 1072-2015 [ Section No. A.3.3.36 ]

A.3.3.36 Hazardous Materials Safety Officer. This individual might also serve as a technical specialist for incidents that involve hazardous materials/WMD. The National Incident Management System (NIMS) identifies this person as theAssistant Safety Officer — Hazardous Material.


Clarify intent by correcting omission.




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A.3.3.36 Hazardous Materials Safety Officer. This individual might also serve as a technical specialist for incidents that involve hazardous materials/WMD. The National Incident Management System (NIMS) identifies this person as theAssistant Safety Officer — Hazardous Material.


Corrects typo


Submitter Full Name: Garuy SharpOrganization: Independence Fire DepartmentStreet Address:City:State:Zip:Submittal Date: Tue Oct 28 15:06:25 EDT 2014


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A.3.3.54.2 Liquid Splash–Protective Clothing. This type of protective clothing is a component of OSHA/ EPA Level B chemical protection. Liquid splash–protective clothing should meet the requirements of NFPA 1992, Standard on LiquidSplash–Protective Ensembles and Clothing for Hazardous Materials Emergencies. [472, 2013]


The Levels of Protection are identified within OSHA 29 CFR 1010.120, Hazardous Waste Operations and Emergency Response. EPA 40 CFR 311, Worker Protection, is a mirror of OSHA 29 CFR 1910.120 and applies to all employees within states that do not have a state-specific OSHA plan. Therefore, the Levels of Protection should be identified as either OSHA or OSHA/EPA, but not only as EPA.

Related Public Inputs for This Document

Related Input RelationshipPublic Input No. 133-NFPA 1072-2015 [Section No. A.3.3.54.3]





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A.3.3.54.3 Vapor-Protective Clothing. This type of protective clothing is a component of OSHA/ EPA Level A chemical protection. Vapor-protective clothing should meet the requirements of NFPA 1991. [472, 2013]


The Levels of Protection are identified within OSHA 29 CFR 1010.120, Hazardous Waste Operations and Emergency Response. EPA 40 CFR 311, Worker Protection, is a mirror of OSHA 29 CFR 1910.120 and applies to all employees within states that do not have a state-specific OSHA plan. Therefore, the Levels of Protection should be identified as either OSHA or OSHA/EPA, but not only as EPA.

Related Public Inputs for This Document

Related Input RelationshipPublic Input No. 130-NFPA 1072-2015 [Section No. A.3.3.54.2] EPA versus OSHA/EPA





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A.3.3.67 Weapon of Mass Destruction (WMD). The source of this definition is 18 USC 2332a. [472, 2013]

Weapons of mass destruction (WMD) are known by many different abbreviations and acronyms, the most common of which is CBRN, which is the acronym for chemical, biological, andradiological/nuclear particulate agents that could be released as the result of a terrorist attack. CBRN agents are further categorized as follows:

(1) Chemical terrorism agents are materials used to inflict lethal or incapacitating casualties, generally on a civilian population, and include chemical warfare agents and toxic industrialchemicals:

(a) Chemical warfare agents are solid, liquid, gaseous, and vapor agents, including, but not limited to, GB (Sarin), GD (Soman), HD (sulfur mustard), and VX.

(b) Toxic industrial chemicals include chlorine and ammonia, which have been identified as mass casualty threats.

(2) Biological terrorism agents are liquid or particulate agents that can consist of a biologically derived toxin or pathogen to inflict lethal or incapacitating casualties, such as bacteria, viruses,or the toxins derived from biological material.

(3) Radiological particulate terrorism agents are particles that emit ionizing radiation in excess of normal background levels used to inflict lethal or incapacitating casualties, generally on acivilian population, as the result of a terrorist attack.


Clarify to reader the purpose of the N in CBRN.





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A.4.2 At the awareness level, approved resources include the ERG or an equivalent guide; manufacturer, shipper, and transporter documents (including shipping papers) and contacts; the U.S. DOTHazardous Materials Marking, Labeling and Placarding Guide; and Safety Data Sheets ( SDS) .

In transportation, the name, placard applied, or identification number of the material provides access to information in the ERG or an equivalent document.


Consistent with standard listing throughout document.





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Public Input No. 122-NFPA 1072-2015 [ Section No. A.4.2(A) ]

A.4.2(A) Instructors should include indicators of terrorist attacks and other potentials, emphasizing that “if you can smell it, taste it, or feel it, you are now (or might be) part of the problem.”

While this is a minimum requirement, the AHJ has the option to select additional information from the operations chapter (Chapter 5) regarding container and hazard information as necessary,based on local conditions and circumstances.

Awareness level personnel should be able to match the hazard classes and divisions with the primary hazards and examples.

Indicators of the presence of hazardous materials include occupancy and locations, including fixed facilities and transportation; container shape (general shape of the container); placardsand labels; markings, including NFPA 704 markings, military markings, transportation markings such as identification number marks, marine pollutant marks, elevated temperature marks,commodity markings, inhalation hazard marks, and pipe and pipeline markings and colors; shipping documents and SDS; and sensory clues (dead birds or fish, color of vapors, unusualodors, etc.). Other items, such as fume hood exhaust stacks and vents on the exterior of a building, could indicate hazardous materials and can be identified in advance through pre-incidentsurvey activities.


I personally like the bolded heading for each of the lists of explanatory items, making them easy to identify. But this is not done consistently throughout the Annex. I think a decision on how to handle this issue should be made with a review of the Annex items to identify changes to be made. I realize that some sentences will need to be slightly rewritten to bring the actual topic to the front of the sentence, but that can easily be handled editorially.





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A.4.2(A) Instructors should include indicators of terrorist attacks and other potentials, emphasizing that “if you can smell it, taste it, or feel it, you are now (or might be) part of the problem.”

While this is a minimum requirement, the AHJ has the option to select additional information from the operations chapter (Chapter 5) regarding container and hazard information as necessary,based on local conditions and circumstances.

Awareness level personnel should be able to match the hazard classes and divisions with the primary hazards and examples.

Indicators of the presence of hazardous materials include occupancy and locations, including fixed facilities and transportation; container shape (general shape of the container); containerowner/operator signage; placards and labels; markings, including NFPA 704 markings, military markings, transportation markings such as identification number marks, marine pollutant marks,elevated temperature marks, commodity markings, inhalation hazard marks, and pipe and pipeline markings and colors; shipping documents and SDS; and sensory clues (dead birds or fish,color of vapors, unusual odors, etc sheen, hissing noise, dead vegetation etc .). Other items, such as fume hood exhaust stacks and vents on the exterior of a building, could indicatehazardous materials and can be identified in advance through pre-incident survey activities.


Included additional examples of sensory cluesIncluded an additional type clue for the presence of hazardous materials (signage/markers)


Submitter Full Name: DREW LOHOFFOrganization: Colonial PipelineAffilliation: American Petroleum Institute/Association of Oil Pipe Lines

Street Address:City:State:Zip:Submittal Date: Tue Dec 16 09:08:33 EST 2014


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A.4.3 People not directly involved in emergency response operations should be kept away from the hazard area, and control should be established over the area of operations. Unprotectedemergency responders should not be allowed to enter the isolation zone.

At the awareness level, approved resources reference sources include the ERG or an equivalent guide; manufacturer, shipper, and transporter documents (including shipping papers) andcontacts; and Safety Data Sheets ( SDS) .


The stem of the JPR specifies "approved reference sources" so it seems logical for the Annex to use the term "approved reference sources" rather than approved documents when listing what these items are. May reduce some confusion.




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A.4.3(A) Basic Recommended precautions found on numbered guides in the ERG include public safety issues; recommended protective clothing; evacuation, emergency response to fire, spill, andleak; and first aid sections.

Examples of required knowledge include precautions for providing emergency medical care to victims; typical ignition sources; ways hazardous materials/WMD are harmful to people, theenvironment, and property; general routes of entry for human exposure; emergency action (fire, spill, or leak; first aid); protective actions (isolation of area and denial of entry, evacuation,shelter-in-place); size and shape of recommended initial isolation and protective action distances; difference between small and large spills; conditions requiring the use of the Table of InitialIsolation and Protective Action Distances, which is found in the ERG, and the isolation distances in the numbered guide in the ERG; techniques for isolating the hazard area and denying entryto unauthorized persons; how to recognize and protect evidence; and use of approved tools and equipment.


Consistency with statement in A.4.3(A) . . . replace "basic" with "recommended".





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A.4.3(A) Basic precautions found on numbered guides in the ERG include public safety issues; recommended protective clothing; evacuation, emergency response to fire, spill, and leak; and first aidsections.

Examples of required knowledge include precautions for providing emergency medical care to victims; typical ignition sources; ways hazardous materials/WMD are harmful to people, theenvironment, and property; general routes of entry for human exposure; emergency action (fire, spill, or leak; first aid); protective recommended actions not to be performed (i.e. closing ofpipeline valves); protective actions ( isolation of area and denial of entry, evacuation, shelter-in-place); size and shape of recommended initial isolation and protective action distances;difference between small and large spills; conditions requiring the use of the Table of Initial Isolation and Protective Action Distances, which is found in the ERG, and the isolation distances inthe numbered guide in the ERG; techniques for isolating the hazard area and denying entry to unauthorized persons; how to recognize and protect evidence; and use of approved tools andequipment.


Included a key element of response to pipeline incidents that can reduce possibly expanding a disaster or creating a worse condition - shutting a pipeline valve.


Submitter Full Name: DREW LOHOFFOrganization: Colonial Pipeline



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A.5.2 Approved reference sources. At the operations level, resources approved reference sources should include a minimum of ERG, SDS, and CHEMTREC, CANUTEC, and SETIQ; local, state, and governmental authorities;and manufacturer, shipper, and transporter documents (including shipping papers) and contacts.

Surrounding conditions include topography; land use, including utilities and fiber optic cables; accessibility; weather condition; bodies of water, including recharge ponds; public exposurepotential; patient presentation; overhead and underground wires and pipelines; storm and sewer drains; possible ignition sources; adjacent land use such as rail lines, highways, and airports;and the nature and extent of injuries. Building information, such as floor drains, ventilation ducts, and air returns, also should be included where appropriate.


Consistency again!




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A.5.3 At the operations level, resources approved information sources should include a minimum of ERG; SDS; CHEMTREC, CANUTEC, or SETIQ; local, state, and governmental authorities; andmanufacturers', shippers', and transporters' documents (shipping papers) and contacts.


Consistent use of terminology. Editorial issue.




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A.5.4 Protective actions include isolating the hazard area, denying entry, evacuation, and shelter-in-place.

Scene control includes establishing control zones, performing emergency decontamination, and communicating to the public.

[[Move this information to A.5.4(A) where the term evidence preservation is used]]

Evidence preservation. Preservation of evidence is essential to the integrity and credibility of an incident investigation. Preservation techniques must be acceptable to the law enforcementagency having jurisdiction; therefore, it is important to get that agency's input ahead of time on the techniques specified in the local emergency response plan or the organization's standardoperating procedures.

General procedures for preserving evidence include the following:

(1) Secure and isolate any incident area where evidence is located. This can include discarded personal protection equipment, specialized packaging (shipping or workplace labels andplacards), biohazard containers, glass or metal fragments, containers (e.g., plastic, pipes, cylinders, bottles, fuel containers), and other materials that appear relevant to the occurrence,such as roadway flares, electrical components, fluids, and chemicals.

(2) Leave fatalities and body parts in place and secure the area in which they are located.

(3) Isolate any apparent source location of the event (e.g., blast area, spill release point).

(4) Leave in place any explosive components or housing materials.

(5) Place light-colored tarpaulins on the ground of access and exit corridors, decontamination zones, treatment areas, and rehabilitation sectors to allow possible evidence that might dropduring decontamination and doffing of clothes to be spotted and collected.

(6) Secure and isolate all food vending locations in the immediate area. Contaminated food products will qualify as primary or secondary evidence in the event of a chemical or biologicalincident.

The collection (as opposed to preservation) of evidence is usually conducted by law enforcement personnel, unless other protocols are in place. If law enforcement personnel are not equippedor trained to enter the hot zone, hazardous materials technicians should be trained to collect samples in such a manner as to maintain the integrity of the samples for evidentiary purposes andto document the chain of evidence. Safety precautions. Safety precautions should include buddy systems, backup systems, accountability systems, safety briefing, and evacuation/escapeprocedures. The following items should be considered in a safety briefing prior to allowing personnel to work at hazardous materials/WMD incidents:

(1) Preliminary evaluation

(2) Hazard identification

(3) Description of the site

(4) Task(s) to be performed

(5) Length of time for task(s)

(6) Required PPE

(7) Monitoring requirements

(8) Notification of identified risks


Place the explanation where it would be help the reader understand the concept - this is a knowledge issue so I suggest creating an A.5.4(A) using the deleted information.





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A.5.4 Protective actions include isolating the hazard area, denying entry, evacuation, and shelter-in-place.

Scene control includes establishing control zones, performing emergency decontamination, and communicating to the public.

Evidence preservation. Preservation of evidence is essential to the integrity and credibility of an incident investigation. Preservation techniques must be acceptable to the law enforcementagency having jurisdiction; therefore, it is important to get that agency's input ahead of time on the techniques specified in the local emergency response plan or the organization's standardoperating procedures.

General procedures for preserving evidence include the following:

(1) Secure and isolate any incident area where evidence is located. This can include discarded personal protection equipment, specialized packaging (shipping or workplace labels andplacards), biohazard containers, glass or metal fragments, containers (e.g., plastic, pipes, cylinders, bottles, fuel containers), and other materials that appear relevant to the occurrence,such as roadway flares, electrical components, fluids, and chemicals.

(2) Leave fatalities and body parts in place and secure the area in which they are located.

(3) Isolate any apparent source location of the event (e.g., blast area, spill release point).

(4) Leave in place any explosive components or housing materials.

(5) Place light-colored tarpaulins on the ground of access and exit corridors, decontamination zones, treatment areas, and rehabilitation sectors to allow possible evidence that might dropduring decontamination and doffing of clothes to be spotted and collected.

(6) Secure and isolate all food vending locations in the immediate area. Contaminated food products will qualify as primary or secondary evidence in the event of a chemical or biologicalincident.

The collection (as opposed to preservation) of evidence is usually conducted by law enforcement personnel, unless other protocols are in place. If law enforcement personnel are not equippedor trained to enter the hot zone, hazardous materials technicians should be trained to collect samples in such a manner as to maintain the integrity of the samples for evidentiary purposes andto document the chain of evidence.

[[Separate safety precautions as a separate statement.]]

Safety precautions. Safety precautions should include buddy systems, backup systems, accountability systems, safety briefing, and evacuation/escape procedures. The following items shouldbe considered in a safety briefing prior to allowing personnel to work at hazardous materials/WMD incidents:

(1) Preliminary evaluation

(2) Hazard identification

(3) Description of the site

(4) Task(s) to be performed

(5) Length of time for task(s)

(6) Required PPE

(7) Monitoring requirements

(8) Notification of identified risks


Separate sentence from paragraph since the subject is different.




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Public Input No. 125-NFPA 1072-2015 [ Section No. A.7.3.2(A) ]

A.7.3.2(A) Levels of protection specified by the EPA and the National Institute for Occupational Safety and Health Health Administration (NIOSH OSHA ) are are Level A, Level B, Level C, and LevelD with explanations.

Hazards include thermal, radiological, asphyxiating, chemical (liquids and vapors), etiological (biological), and mechanical (explosives).


OSHA designates that Levels of CPC, not NIOSH (regulates the respiratory protection).





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Public Input No. 75-NFPA 1072-2015 [ Section No. C.1.2 ]

C.1.2 Other Publications.C.1.2.1 American Chemistry Council Publications.American Chemistry Council, 700 Second St., NE, Washington, DC 20002.

Recommended Terms for Personal Protective Equipment, 1985.

C.1.2.2 API Publications.American Petroleum Institute, 1220 L Street, N.W., Washington, DC 20005-4070.

API 2021, Guide for Fighting Fires in and Around Flammable and Combustible Liquid Atmospheric Petroleum Storage Tanks, 2001.

API 2510-A, Fire Protection Considerations for the Design and Operation of Liquefied Petroleum Gas (LPG) Storage Facilities, 1996.

C.1.2.3 ASTM Publications.ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM E 2770, Standard Guide for Operational Guidelines for Initial Response to a Suspected Biothreat Agent, 2010.

ASTM E 2458, Standard Practices for Bulk Sample Collection and Swab Sample Collection of Visible Powders Suspected of Being Biothreat Agents from Nonporous Surfaces, 2010.

C.1.2.4 IMO Publications.International Maritime Organization, 4 Albert Embankment, London SEI 7SR, UK.

Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk, (BCH Code).

International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code).

International Code for the Construction and Equipment of Ships Carrying Dangerous Liquefied Gases in Bulk (IGC Code).

International Maritime Dangerous Goods Code (IMDG Code).

MARPOL 73/78.

Safety of Life at Sea (SOLAS).

C.1.2.5 NRT Publications.U.S. National Response Team, Washington, DC 20593, www.nrt.org.

NRT-1, Hazardous Materials Emergency Planning Guide, 2001.

C.1.2.6 U.S. Government Publications.U.S. Government Printing Office, Washington, DC 20402.

Department of Homeland Security (DHS), Responder Knowledge Base. http://www.rkb.mipt.org

Environmental Protection Agency, Standard Operating Safety Guides, June 1992.

National Incident Management System (NIMS), Site Safety and Control Plan (formerly ICS 208 HM)

National Toxicology Program, U.S. Department of Health and Human Services, 9th Report on Carcinogens, Washington, DC, 2011.

National Incident Management System (NIMS), March 2004, http://www.fema.gov/nims/nims_compliance.shtm#nimsdocument.

National Preparedness Goal, March 2005, https://www.llis.dhs.gov.

National Preparedness Guidance, April 2005, https://www.llis.dhs.gov.

National Response Plan, December 2004, http://www.dhs.gov/Xprepresp/committees/editorial_0566.shtm.

NIOSH/OSHA/USCG/EPA, Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, October 1985.

NIOSH Pocket Guide to Chemical Hazards, DHHS (NIOSH) Publication No. 2007-149, September 2007: http://www.cdc.gov/niosh.npg.

Target Capabilities List, May, 2005, https://www.llis.dhs.gov.


Title 29, Code of Federal Regulations, Parts 1910.119–1910.120.

Title 29, Code of Federal Regulations, Part 1910.134.

Title 33, Code of Federal Regulations, “Navigation and Navigable Waters.”


Title 40, Code of Federal Regulations, Part 302.

Title 40, Code of Federal Regulations, Part 355.

Title 46, Code of federal Regulations, “Shipping.”

Title 49, Code of Federal Regulations, Parts 170–180.


Universal Task List, May 2005, https://www.llis.dhs.gov.

U.S. Department of Transportation, Emergency Response Guidebook, 2008 edition.

U.S. Department of Transportation, Hazardous Materials Marking, Labeling and Placarding Guide.

C.1.2.7 Additional Publications.International Safety Guide for Oil Tankers and Terminals, Witherby Seamanship International, 5th edition, 2006.

International Chamber of Shipping Tanker Safety Guide (chemicals), 3rd edition, Witherby and Co., London, 1990.

International Chamber of Shipping Tanker Safety Guide (liquefied gases), 2nd edition, Witherby and Co., London, 1996.

OCIMF Ship to Ship- Transfer Safety Guide (petroleum) (liquefied gases), 3rd edition, International Chamber of Shipping OCIMF, London, 1997.

SIGTTO Liquefied Gas Handling Principles on Ships and in Terminals, 3rd edition, McGuire and White (Authors) London, 2000, Witherby Seamanship International.

Provisional Categorization of Liquid Substances, MEPC.2/Circ.10 2004, International Maritime Organization, London.

C.1.2.8 16 Firefighter Life Safety Initiatives, published by the National Fallen Firefighters Foundation, 2004




Submitter Full Name: Richard MasonOrganization: National Fallen Firefighters Foundation

Street Address:City:State:


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Zip:Submittal Date: Sat Jan 03 16:10:35 EST 2015


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I share a concern regarding NFPA 475 - The chapter does not make any reference to a variety ofexisting material regarding training and testing that state and provincial training agencies alreadyhave in place.

The chapter covers instructor qualifications but does not make reference to NFPA 1041 thatthoroughly covers this topic.

The chapter also omits any discussion of accreditation and certification as outlined in NFPA 1000 orthe long-standing National Board on Fire Service Professional Qualifications (Pro-Board),the International Fire Service Accreditation Congress (IFSAC), or state systems such as are in placein Oregon and California.

Many state and provincial entities have programs accredited by one or both of these organizations(IFSAC or Pro-Board) that demonstrate the validity and reliability of our testing programs and theseprograms deserve mention.

Eriks Gabliks - Director - Oregon Department of Public Safety Standards and Training


I share a concern regarding NFPA 475 - The chapter does not make any reference to a variety of existing material regarding training and testing that state and provincial training agencies already have in place.

The chapter covers instructor qualifications but does not make reference to NFPA 1041 that thoroughly covers this topic.

The chapter also omits any discussion of accreditation and certification as outlined in NFPA 1000 or the long-standing National Board on Fire Service Professional Qualifications (Pro-Board), the International Fire Service Accreditation Congress (IFSAC), or state systems such as are in place in Oregon and California.

Many state and provincial entities have programs accredited by one or both of these organizations (IFSAC or Pro-Board) that demonstrate the validity and reliability of our testing programs and these programs deserve mention.

Eriks Gabliks - Director - Oregon Department of Public Safety Standards and Training


Submitter Full Name: ERIKS GABLIKS

Organization: OREGON PUB SFTY STAN TRNG DEPT

Street Address:City:State:Zip:Submittal Date: Wed Dec 24 18:52:03 EST 2014

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?comm...

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Title Global Input PI

Change title from:

NFPA 475 Recommended Practice for Responding to Hazardous Materials Incidents/Weapons ofMass Destruction

to:

NFPA 475 Recommended Practice for Organizing, Managing, and Sustaining a HazardousMaterials/Weapons of Mass Destruction Response Program


Substantiation:On behalf of the Task Group, the recommendation to the Technical Committee is to change the current title of the document to better reflect the technical nature of the proposed changes for the entire document.



Organization: Pacific Northwest National Lab



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Public Input No. 119-NFPA 475-2014 [ Chapter 1 ]

Chapter 1 Administration1.1 Scope.This recommended practice applies to all entities having responsibility for responding to hazardousmaterials/weapons of mass destruction (WMD) incidents and establishes guidelines for the organizationand management of the program based on the authority having jurisdiction’s (AHJ) expected function andassessed level of risk. Preparedness and response functions are specifically covered in this recommendedpractice.1.2* Purpose.The purpose of this document is to recommend the minimum program elements necessary for theorganization and management of a hazardous material/WMD emergency response program and to specifyguidelines for planning and responding to hazardous material/WMD incidents. These recommendedpractices are not intended to restrict the AHJ from exceeding these requisite elements1.3 Application.The recommendations contained in this document apply to those organizations that respond to hazardousmaterials/WMD incidents in accordance with the AHJ’s functional responsibilities and an acceptable levelof response.


This is not a problem, but rather a statement of what the comments submitted by this reviewer represent- I could not find anywhere else to include this information.

The public input provided by this reviewer (Jim Cornish) has been reviewed by, and represents the official submission of, the Alberta Fire Commissioner. The Alberta Office of the Fire Commissioner is the entity responsible for the coordination of CBRNe issues within the province of Alberta, Canada.

The reviewer was trained within the Canadian military, NATO and the UK MInistry of Defence to the level of CBRN specialist, and for three years was the CBRN advisor and senior instructor to the Royal Navy in the UK.


Submitter Full Name: Jim Cornish

Organization: Alberta Fire Commissioner

Street Address:City:State:Zip:Submittal Date: Fri Nov 21 13:09:17 EST 2014


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Chapter 1 Administration1.1 Scope.

This recommended practice applies to all entities having responsibility for responding to hazardousmaterials/weapons of mass destruction (WMD) incidents and establishes guidelines for the organizationand management of the program based on the authority having jurisdiction’s (AHJ) expected function andassessed level of risk. Preparedness and response functions are specifically covered in this recommendedpractice.1.2 * Purpose.

The purpose of this document is to recommend the minimum program elements necessary for theorganization and management of a hazardous material/WMD emergency response program and to specifyguidelines for planning and responding to hazardous material/WMD incidents. These recommendedpractices are not intended to restrict the AHJ from exceeding these requisite elements1.3 Application.

The recommendations contained in this document apply to those organizations that respond to hazardousmaterials/WMD incidents in accordance with the AHJ’s functional responsibilities and an acceptable level ofresponse.


File Name Description ApprovedChapter_1_PI.docx


On behalf of the Task Group, this Public Input is being recommended to the Technical Committee for consideration to modify the existing chapter text. The Task Group believes that these changes, while substantive, bettering reflect the technical minimum requirements for organizing, managing and sustaining a HMRP based on an assessed risk level for an AHJ.






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1.3 Application.The recommendations contained in this document apply to those organizations that respond to hazardousmaterials/WMD incidents in accordance with the AHJ’s functional responsibilities and an acceptable level ofresponse.

Reviewer Comment: Throughout this standard document, it refers to "hazardous materials/WMD,"which seems to imply that "CBRNe" only refers to actual C, B, R or N weapons. In actual fact,CBRN includes not only the use of WMD, but also (and more likely) the deliberate release of anexisting hazardous material by a criminal or terrorist organization (or even a radical environmentalorganization). This distinction is extremely important, for a number of reasons:

(1) It is far more likely that a criminal or terrorist organization will take advantage of an existinghazardous material to cause a CBRN incident, rather than going to the trouble, expense andrisk of detection of obtaining/developing a "classic" WMD. If this is not well understood andappreciated, responders might assume that a "normal" hazardous material spill is due tonatural causes, human error, or mechanical failures; as opposed to being deliberate. Inmaking this assumption, the responder may not consider the possibility of additional hazardsassociated with a deliberate release, such as secondary devices designed to harmresponders.

(2) If an assumption is made that CBRN is only associated with WMD, the risk of the deliberateuse of a hazardous material may be understimated in both probability (occurence andlocality) and scope.

(3) Agents which can cause serious disruption to the economy or environment tend not to beconsidered under the definition of "WMD," however they can have huge impacts. For examplethe deliberate use of "foot and mouth" disease to cause disruption to the livestock industrywould not cause direct human injuries, but could have huge effects on the economy; andwould in fact not be particularly hard to accomplish due to the highly infectious nature of thedisease.

The points mentioned above are considered by this reviewer to be a significant part of theeducation process necessary to increase awareness and therefore preparedness for a CBRNeevent .

***Having new reviewed the entire document, the distinction above is made clear towards the end ofthe definition section. I recommend that this definition be moved to this "Application" section sothat it is clear from the very start what is being referred to .


People at all levels need to be cognizant of the broad spectrum of threats represented by the term CBRNe. This standard has in its title the term "WMD," and that term is not really defined until near the end of the definitions section- which is something not all people even read if they think they know the definition of the terms being used. "WMD" is most commonly thought of as military, or militarized, weapons, as opposed to the more mundane but equally dangerous hazardous materials. By using the term "WMD" without highlighting its definition early in the document, you run the risk of people underestimating the probability, scope and type of possible CBRNe attack.




Affilliation: Alberta Fire Commissioner- CBRN specialist


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Street Address:City:State:Zip:Submittal Date: Wed Sep 24 12:18:37 EDT 2014


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2.1 General.The documents or portions thereof listed in this chapter are referenced within this standard recommendedpractice and shall be considered part of the requirements of this document.


Document is a recommended practice, not a standard.



Organization: [ Not Specified ]

Street Address:City:State:Zip:Submittal Date: Mon Sep 15 16:18:23 EDT 2014


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2.2 NFPA Publications.National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response,2012 edition.


Correct missing part of cite NFPA 704.






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Emergency Response Guidebook, U.S. Department of Transportation, 2012 edition.

FBI Bomb Data Center, Special Technicians Bulletin 2010-1, A Model for Bomb Squad Standard OperatingProcedures, Washington, D.C. July 22, 2011.

Hazardous Waste Operations and Emergency Response, 29 CFR 1910, . 120, Washington, D.C.: UnitedStates Department of Labor, 1994 2013 .


Title 46, Code of Federal Regulations, Office of Federal Register, National Archives and RecordsAdministration, Washington DC 2011.


Referenced current editions.


Submitter Full Name: Aaron Adamczyk


Street Address:City:State:Zip:Submittal Date: Thu Aug 21 15:53:32 EDT 2014


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Hazardous Waste Operations and Emergency Response, 29 CFR 1910, 120, Washington, D.C.: UnitedStates Department of Labor, 1994.



Reviewer Comment: This NFPA standard is likely to be used by organizations outside of the US(my organization, for example, is in Alberta, Canada). Are these references all available toforeigners? If so it would be useful to provide links to them .


International users of the standard may not be able to access the references for the standard.




Street Address:City:State:Zip:Submittal Date: Tue Sep 23 18:06:28 EDT 2014


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Hazardous Waste Operations and Emergency Response, 29 CFR 1910, . 120, Washington, D.C.: UnitedStates Department of Labor, 1994.




Correct cit for HAZWOPER reference 29 CFR 1910-120 not 1910, 120






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Hazardous Waste Operations and Emergency Response, 29 CFR 1910, . 120, Washington, D.C.: UnitedStates Department of Labor, 1994.


Title 46 49 , Code of Federal Regulations, Office of Federal Register, National Archives and RecordsAdministration, Washington DC 2011. “Transportation."


The issues addressed in this recommended practice refer to Transportation instead of shipping. Transportation is found in 49 CFR. You may want to reference specific parts of the regulations to correspond to information presented in Chapter 4 of NFPA 475.






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3.1 General.The definitions contained in this chapter shall apply to the terms used in this standard recommendedpractice . Where terms are not defined in this chapter or within another chapter, they shall be defined usingtheir ordinarily accepted meanings within the context in which they are used. Merriam-Webster's CollegiateDictionary, 11th edition, shall be the source for the ordinarily accepted meaning.


The document is a recommended practice not a standard.



Organization: Retired

Affilliation: None



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3.2.6 Standard.A document An NFPA Standard , the main text of which contains only mandatory provisions using the word“shall” to indicate requirements and which that is in a form generally suitable for mandatory reference byanother standard or code or for adoption into law. Nonmandatory provisions are not to be considered a partof the requirements of a standard and shall be located in an appendix or , annex, footnote, or fine-printnote and are not to be considered a part of the requirements of a standard informational note, or othermeans as permitted in the NFPA Manuals of Style. When used in a generic sense, such as in the phrase“standards development process” or “standards development activities,” the term “standards” includes allNFPA Standards, including Codes, Standards, Recommended Practices, and Guides .


Change is the definition that NFPA editorial staff required in NFPA 1072.




Affilliation: None



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3.3.1* Allied Professional.That person who possesses the knowledge, skills, and technical competence to provide assistance in theselection, implementation, and evaluation of mission-specific tasks at a hazardous materials weapons ofmass destruction (WMD) incident. [472, 2013]


Allied professional may be used to assist in tasks at any level of response personnel . . . therefore this should be be limited to mission-specific tasks.






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3.3.6 CHEMTREC.The Chemical Transportation Emergency Response Center, a A public service of the American ChemistryCouncil, which provides emergency response information and assistance on a 24-hour basis for respondersto hazardous materials/weapons of mass destruction (WMD) incidents. [ 472 , 2013]


Request made by CHEMTREC to change wording as noted . . . change is now consistent with NFPA 1072. ALso, if the change is made, the definition would not be consistent to NFPA 472, 2013.




Affilliation: None



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3.3.10 Container.A receptacle, piping, or pipeline used for storing or transporting material of any kind. [ 472 , 2013]


Consistency between this document and NFPA 1072.






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The process of transferring a /deposition of a hazardous material, or the hazardous component of aweapon of mass destruction (WMD), from its source to people, animals, the environment, or equipment, thatcan act as a carrier. [472, 2013]


Contamination does not just refer to "transferring" of a hazardous material, but also to its initial deposition (such as when radioactive fallout falls to the ground).






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3.3.14 Control.The procedures, techniques, and methods used in the mitigation of hazardous material/weapons of massdestruction (WMD) incidents, including containment, extinguishment, and confinement. [472, 2013]

Add 3.3.8 Confinement, 3.3.10 Containment, and 3.3.29 as subsets of Control


Document is inconsistent in terms of how definitions are grouped - it seems appropriate to include the definitions of confinement, containment, and extinguishment under "Control" in a manner similar to "Control Zones". Once that decision is made, check other definitions with subsets and handle them consistently.






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The areas at hazardous materials/weapons of mass destruction incidents within an established/a controlledperimeter that are designated based upon safety and the degree of hazard. [472, 2013]


Editorial correction to match other documents.






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The physical and/or chemical process of reducing and preventing /or neutralizing, or preventing the spreadof, contaminants from people, animals, the environment, or equipment involved at hazardousmaterials/weapons of mass destruction (WMD) incidents. [472, 2013]


Neutralization is also a possibility- this should be included in all definitions of decontamination.






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3.3.18.3 * Mass Decontamination.The physical process or chemical process of reducing, removing or removing surface neutralizing surfacecontaminants from large numbers of victims in potentially life-threatening situations in the fastest timepossible. [472, 2013]


I have added "or chemical" to this definition as there are some chemical methods of reducing/removing contamination from people, such as the use of Reactive Skin Decontamination Lotion (RSDL) or chemical antiseptics.I have also added "neutralization" as it is not always necessary to remove contaminants if they can be neutralized.






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Extinguishment.To cause to cease burning.


Definition was added to NFPA 1072.






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ExposuresExposures. The people, animals, environment, property,and equipment that might potentially become exposed ata hazardous materials/weapons of mass destruction (WMD)incident.


To be consistent with NFPA 1072.






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3.3.28 * Fissile Material.Material whose atoms are capable of nuclear fission (capable of being split). sustained nuclear fission[472, 2013]


"Fissile material" normally refers to material which could be used, or could be modified in order to be used, in a sustained nuclear reaction- i.e. a nuclear reactor or a nuclear weapon- including U233, U235 and P238 (and theoretically some isotopes of americium and neptunium). The term is NOT normally used to describe radiological materials which could not be used in a sustained nuclear reaction, but are capable of being "split." There are many radioactive isotopes which undergo some splitting of the atom as they decay into other substances, but which are NOT useable as afuel in a nuclear reactor or nuclear weapon, and are therefore not normally included in the definition of "fissile material."






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Hazardous Materials Emergency Response Program (HMERP)Term is used in document and not defined, especially when acronym is used for other in other venues suchas hazardous materials emergency response plan or hazardous materials emergency response personnel.


Need definition and consideration of use of acronym that has other connotations.






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3.3.XX Hazardous Materials Response Program (HMRP)A program designed to address response issues associated with emergencies involving hazardousmaterials/weapons of mass destruction found within a jurisdiction.


It seems that there should be a definition of "hazardous materials response program" to limit the purpose of this document as designed by the technical committee. I would hope that a program for handling the hazardous material problem within a jurisdiction would address prevention, preparedness, response, and recovery activities.






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3.3.39 Incident Command System.A specific component of an incident management system designed to enable effective and efficienton-scene incident management by integrating a combination of facilities, equipment, personnel, procedures,and communications operating within a common organizational structure. [ 472 , 2013]


To be consistent with NFPA 1072 definition.






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3.3.40* Incident Management System (IMS).A plan process that defines the roles and responsibilities to be assumed by personnel and the operatingprocedures to be used in the management and direction of emergency operations to include the incidentcommand system, multi-agency coordination system, training, and management of resources. [472, 2013]


Process seems like a better word when discussing this issue . . . NFPA 1072 change already made.






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3.3.XX Jurisdiction.Jurisdiction is the geographic area over which authority extends - an area of responsibility - be it local,regional, provincial, tribal, territorial, state, federal, or international whether private (business, industry,transportation, etc.), public, or governmental in nature.


The addition of this definition would make it easier to address AHJ issues by including all of the entities that are meant to be involved when talking about jurisdiction. If you decide to use this definition, you might want to consider its use by itself throughout the document - particularly when mentioning "organization and jurisdiction" - since jurisdiction by this definition would be all inclusive.






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3.3.42* Material Safety Data Sheet (MSDS SDS ).A form, provided by manufacturers and compounders (blenders) of chemicals, containing information aboutchemical composition, physical and chemical properties, health and safety hazards, emergency response,and waste disposal of the material. [472, 2013]


Correct term to current usage, put in alphabetical order, and renumber as necessary. May want to make reference to MSDS to eliminate confusion, either in Annex or in definition.






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3.3.42 * Material Safety Data Sheet (MSDS).A form, provided by manufacturers and compounders (blenders) of chemicals, containing biologicalsamples/products and radio-isotopes containing information about chemical composition, physical andchemical properties, health and safety hazards, emergency response, and waste disposal of the material.[472, 2013]


MSDS are not only for chemical substances- they are also used for biological and radiological substances.






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3.3.43 Monitoring and Detection Equipment.Instruments and devices used to detect, identify and quantify contaminants. [ 472 , 2013]


In discussions of this definition when addressing NFPA1072, the TC agreed on this change as more accurately defining monitoring and detection equipment.






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3.3.43 Monitoring Equipment.Instruments and devices used to identify and quantify contaminants and/or to monitor the levels ofcontaminants over time . [472, 2013]


Monitoring equipment is not just used to detect and identify hazardous materials, but also to monitor them over a period of time.






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3.3.44 Objective.1. A goal that is achieved through the attainment of a skill, knowledge, or both, that can be observed ormeasured. [472, 2013] 2. In the context of ICS planning, broad descriptions or statements of the desiredincident outcomes or actions needed to achieve them in a manner consistent with the priorities.


As stated, the definition of "objective" applies to the learning requirements of the standard, but the definition of "objective" in the context of an ICS system should also be included.






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3.3.46 Penetration.1. The movement of a material through a suit's closures, such as zippers, buttonholes, seams, flaps, orother design features of chemical-protective clothing, and through punctures, cuts, and tears. [472, 2013] 2. In the context of radioactive substances, the movement of radiation through materials (such as airor shielding) and the body.


The current definition statement is very specific to the penetration of chemical agents through PPE. Some statement regarding the penetration characteristics of radiation should also be included.






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3.3.48* Personal Protective Equipment (PPE) .The equipment provided to shield or isolate a person from the chemical, physical, and thermal hazards thatcan be encountered at hazardous materials/weapons of mass destruction (WMD) incidents. [ 472 , 2013]


To correspond with definition in NFPA 472 and NFPA 1072. Editorial deletion to simplify the definition.






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3.3.48 * Personal Protective Equipment.The equipment provided to shield or isolate a person from the chemical, physical, thermal and thermalhazards radiation hazards that can be encountered at hazardous materials/weapons of mass destruction(WMD) incidents. [472, 2013]


The definition of PPE should include protection against radiation or exposure to radioactive substances- for example using a respirator to prevent inhalation of an alpha or beta particle emitter, or bunker gear to protect agains the external hazard of beta radiation.






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3.3.49.3 Site Safety and Control Plan.A site safety and control plan should be completed and approved -specific tactical document used by thehazardous materials officer, the hazardous materials safety officer, and the incident commander forinclusion in the incident action plan. The plan must be briefed to personnel operating within the hot zone bythe hazardous materials safety officer or the hazardous materials officer prior to entry mission initiation. Theinitial site safety and control plan for the first operational period can be written or oral. The plan should bedocumented as soon as resources allow. [ 472 , 2013] branch under the incident command system (ICS) toorganize information important to hazardous materials response operations.


Change definition to better reflect the purpose/function of a site safety and control plan. Current definition not formatted well.






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3.3.X Productivity of life. Productivity of life is a multi-dimensional concept that includes domainsrelated to physical, mental, emotional and social functioning. It focuses on the impact that healthstatus as on quality of life.


On behalf of the Task Group, a recommendation to the Technical Committee to include this definition for clarification of the term used within this document.






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3.3.52* Protective Clothing.Equipment designed to protect the wearer from heat and/or from hazardous materials , or from thehazardous component of a weapon of mass destruction (WMD) contacting the skin or eyes. [ 472 ,2013] There are several types of protective clothing: chemical-protective clothing (CPC), which includesliquid splash–protective clothing and vapor-protective clothing; high temperature–protective clothing; andstructural fire-fighting protective clothing.3.3.52.1* Chemical-Protective Clothing.Items made from chemical-resistive materials, such as clothing, hood, boots, and gloves, that aredesigned and configured to protect the wearer's torso, head, arms, legs, hands, and feet from hazardousmaterials. [ 472 , 2013]

3.3.52.

21.1 *

High Temperature–ProtectiveLiquid Splash–Protective Clothing.

Protective clothing designedThe garment portion of a chemical-protective clothing ensemble that is designed and configured toprotect the wearerfor short-term high temperature exposuresagainst chemical liquid splashes but not against chemical vapors or gases . [ 472 , 2013]

3.3.52.

351.2 * Liquid Splash–ProtectiveVapor-Protective Clothing.

The garment portion of a chemical-protective clothing ensemble that is designed and configured toprotect the wearer against chemical

liquid splashes but not against chemicalvapors or gases. [ 472 , 2013]3.3.52.4 * 2 * High Temperature–Protective Clothing.Protective clothing designed to protect the wearer for short-term high temperature exposures. [ 472 , 2013]3.3.52.3 * Structural Fire-Fighting Protective Clothing.

The fire resistant protective clothing normally worn by fire fighters during structural fire-fighting operations,which includes a helmet, coat, pants, boots, gloves, PASS device, and a fire resistant hood to cover parts ofthe head and neck not protected by the helmet and respirator facepiece. [472, 2013]3.3.52.5 * Vapor-Protective Clothing.

The garment portion of a chemical-protective clothing ensemble that is designed and configured to protectthe wearer against chemical vapors or gases. [ 472 , 2013]


To be consistent with NFPA 1072 wording . . . by reflecting that vapor-protective clothing and liquid splash-protective clothing are subsets of chemical-protective clothing.



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3.3.X Standard Operating Guidelines (SOG). A written directive that establishes recommendedstrategies/concepts of emergency response to an incident.

3.3.X Standard Operating Procedure (SOP). A written directive that establishes specific operationalor administrative methods to be followed routinely for the performance of a task or for the use ofequipment.


On behalf of the Task Group, a recommendation to the Technical Committee to include this definition for clarification of the term used within this document.






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(1) Any destructive device, such as any explosive, incendiary, or poison gas bomb, grenade, rocket having apropellant charge of more than four ounces, missile having an explosive or incendiary charge of more thanone quarter ounce (7 grams), mine, or device similar to the above; (2) any weapon involving (includingimprovised weapons) involving toxic or poisonous chemicals; (3) any weapon involving (includingimprovised weapons) involving a disease organism; or (4) any weapon that (including improvisedweapons) that is designed to release radiation or radioactivity at a level dangerous to human life. [472,2013]


I stated in an earlier comment that the term "WMD" does not normally include improvised weapons, such as the deliberate release of a toxic chemical from a transport or storage container. The definition you are using is now clearer, and on further research is very close to the definition now used by the US military, however it is not in the common lexicon, and therefore will not be readily understood until a person reads your actual definition- something which does not always happen when documents are reviewed- many people skip the definitions of terms with which they believe they are already familiar. I would argue that in the context of this standard the term "CBRNe weapon" or "intentional CBRNe release" would be more readily understood. At the very least, if you are going to stick with "WMD" throughout the standard, this definition, including the statement "including improvised weapons," should be placed at the very beginning of the document, or at the beginning of the definitions section, so as to highlight the definition and set the stage for all further references to WMD. In my opinion, this is a critical education piece- people need to understand that intentional releases are far more likely to be readily available substances (such as industrial chemicals or medical radioisotopes) than what has been traditionally considered as Weapons of Mass Destruction (i.e. chemical warfare agents, weaponized biological agents and/or nuclear weapons).


Submitter Full Name: [ Not Specified ]


Street Address:City:State:Zip:Submittal Date: Thu Sep 25 10:42:36 EDT 2014


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3.3.64.1* Radiological Weapons of Mass Destruction[ 472 , 2013]3.3.64.1.1 *

Radiation ExposureImprovised Nuclear Device (

REDIND )— anRED, used interchangeably with the term “radiological exposure device” or “radiation emitting device”,consists of radioactive material, either as a sealed source or as material within some type of container, or aradiation-generating device, such as an X-ray device, that directly exposes people to ionizing radiationIND is an illicit nuclear weapon that is bought, stolen, or otherwise obtained from a nuclear State (that is,a national government with nuclear weapons), or a weapon fabricated from fissile material that is capableof producing a nuclear explosion . [ 472 , 2013

])

3.3.64.1.2 * Radiation Dispersal Device (RDD)

— an RDD, also as referred to as a “dirty bomb”, is a device designed to spread radioactive materialthrough a detonation of conventional explosives or other (non-nuclear) means. [ 472 , 2013]

3.3.64.1.3* Improvised Nuclear Radiation Exposure Device (IND RED )— an IND is an illicit nuclear weapon that is bought, stolen, or otherwise obtained from a nuclear State (thatis, a national government with nuclear weapons), or a weapon fabricated from fissile material that iscapable of producing a nuclear explosion RED, used interchangeably with the term “radiological exposuredevice” or “radiation emitting device”, consists of radioactive material, either as a sealed source or asmaterial within some type of container, or a radiation-generating device, such as an X-ray device, thatdirectly exposes people to ionizing radiation . [472, 2013]


Editorial change similar to that made in NFPA 1972.






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Public Input No. 58-NFPA 475-2014 [ Section No. 3.3.64.1.1 ]

3.3.64.1.1 * Radiation Exposure Device (RED)— an RED, used interchangeably with the term “radiological exposure device” or “radiation emitting device”,consists of radioactive material, either as a sealed source or as material within some type of container, or aradiation-generating device, such as an X-ray device, that directly exposes people to , animals, plants orother materials to ionizing radiation. [472, 2013]


The term "radiation exposure device" would not be limited to devices designed to expose people. For example, radiation exposure devices are used to sterilize meat products, sterilize plant products, etc. These REDs, though not designed to expose people, could be used by a criminal or terrorist organization to expose humans.






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3.3.64.1.2 * Radiation Radiological Dispersal Device (RDD)— an RDD, also as referred to as a “dirty bomb” "dirty bomb ," is a device designed to spread radioactivematerial through a detonation of conventional explosives or other (non-nuclear) means. [472, 2013]


"Radiation Dispersion Device" is a misnomer- you don't disperse radiation itself, what you disperse is radioactive substances which then emit radiation.






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3.4.8 Operations Level Responders Assigned to Perform Mass Decontamination During HazardousMaterials/Weapons of Mass Destruction (WMD) Incidents .Persons, competent at the operations level, who are assigned to implement mass decontaminationoperations at hazardous materials/weapons of mass destruction (WMD) incidents. [472, 2013]


To make consistent with other titles . . . and in NFPA 1072






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3.4.8 Operations Level Responders Assigned to Perform Mass Decontamination During HazardousMaterials/Weapons of Mass Destruction (WMD) Incidents .Persons, competent at the operations level, who are assigned to implement mass decontaminationoperations at hazardous materials/weapons of mass destruction (WMD) incidents. [472, 2013]








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3.4.10 Operations Level Responders Assigned to Perform Technical Decontamination During HazardousMaterials/Weapons of Mass Destruction (WMD) Incidents .Persons, competent at the operations level, who are assigned to implement technical decontaminationoperations at hazardous materials/weapons of mass destruction (WMD) incidents. [472, 2013]








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3.4.11 Operations Level Responders Assigned to Perform Victim Rescue/Recovery During HazardousMaterials/Weapons of Mass Destruction (WMD) Incidents .Persons, competent at the operations level, who are assigned to rescue and/or recover exposed andcontaminated victims at hazardous materials/weapons of mass destruction (WMD) incidents. [472, 2013]








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3.4.16 Operations Level Responders Assigned to Use Personal Protective Equipment During HazardousMaterials/Weapons of Mass Destruction (WMD) Incidents .Persons, competent at the operations level, who are assigned to use of personal protective equipment athazardous materials/weapons of mass destruction (WMD) incidents. [472, 2013]








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Chapter 4 Laws and Regulations4.1 General.

The laws, regulations, standards, and guidance documents or portions thereof listed in this chapter arereferenced within this recommended practice and should be considered part of the recommendations ofthis document.4.2 Laws.4.2.1 General.

Over the years, U.S. Congress has passed major pieces of legislation concerning hazardous materials andpublic safety. This has resulted in seven major federal agency regulations that contain no fewer than sixdifferent legal definitions of hazardous material. Each state will have its own laws regulating hazardousmaterials that must be taken into consideration when responding to an incident. In addition, there are over70 different voluntary consensus standards. Of all areas concerning hazmat response teams (HMRT), thisarea is one of the most confusing and, at the same time, an area that must be completely understood whensupporting operations of an HMRT. Subsections 4.2.2 through 4.5.3 discuss some of the more importantlaws impacting hazardous materials emergency planning and response that will be of particular interest toHMRTs. The brief summaries are designed to highlight only the provisions that have the potential to impactHMRTs.4.2.2 Environmental Protection Agency (EPA).4.2.2.1 The Resource Conservation and Recovery Act (RCRA).Passed by Congress in 1976, the RCRA established a uniform national policy for hazardous and solidwaste disposal. It is intended to provide general oversight to state programs, which can be more stringentbut not less stringent. It contains the four major programs discussed in 4.2.2.1.1 through 4.2.2.1.4 .4.2.2.1.1 Solid Waste.

Subtitle D of the act encourages states to develop and implement solid waste management plans.4.2.2.1.2 Medical Waste.

Subtitle J addresses medical waste pertaining to generation, treatment, destruction, and disposal.4.2.2.1.3 Hazardous Waste.

Subtitle C establishes a program to manage hazardous waste from “cradle-to-grave.” The objective of theprogram is to ensure that hazardous waste is handled in a manner that protects human health and theenvironment. The regulation covers the generation, transportation, treatment, storage, or disposal ofhazardous wastes.4.2.2.1.4 Underground Storage Tanks.

Subtitle I regulates petroleum products and hazardous substances stored in underground tanks. Theobjective of this section is to prevent leakage to groundwater from tanks and to clean up past releases. Italso contains standards on new tanks and regulation for leak detection and prevention.4.2.2.2 The Clean Air Act (CAA).Passed by Congress in 1970 and last amended in 1990, the CAA covers a wide range of activities frommanufacturing and processing, transportation, and management of hazardous chemicals.4.2.2.2.1

In Section 112(r) of the CAA, the Chemical Accident Prevention Provisions require facilities that produce,handle, process, distribute, or store certain chemicals to develop a risk management program, prepare arisk management plan (RMP), and submit the RMP to the EPA.4.2.2.3 Superfund Amendments and Reauthorization Act (SARA).


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Also known as “Superfund,” SARA, passed in 1986, addresses hazardous substance releases into theenvironment and cleanup of inactive hazardous waste disposal sites. It also requires those individualsresponsible for the release of hazardous materials (commonly referred to as the responsible parties) abovea specified “reportable quantity” to notify the National Response Center. SARA has had perhaps thegreatest impact on hazardous materials emergency planning and response operations. SARA amendedthe Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 andprovided a national baseline with regard to hazardous materials planning, preparedness, training, andresponse.4.2.2.3.1

Title I of this act required OSHA to develop health and safety standards covering numerous worker groupswho handle or respond to chemical emergencies and led to the development of OSHA 1910.120,Hazardous Waste Operations and Emergency Response (HAZWOPER).4.2.2.3.2 Title III is perhaps the most familiar to the emergency response community. It is also known as theEmergency Planning and Community Right-to-Know Act (EPCRA). Title III led to the establishment of theState Emergency Response Commissions (SERC) and the Local Emergency Planning Committees(LEPC). Passed in 1986, it includes the four major sections pertaining to public safety that are discussed in4.2.2.3.2.1 through 4.2.2.3.2.4 .4.2.2.3.2.1 Sections 301-303: Emergency Planning.

These sections are to ensure that state and local communities are prepared to respond to potentialchemical accidents. As a first step, each state had to establish a SERC. In turn, the SERC designated localemergency planning districts. For each district, the SERC appoints, supervises, and coordinates theactivities of an LEPC. The LEPC must, in turn, develop an emergency response plan for its district andreview it annually.4.2.2.3.2.2 Section 304: Emergency Release Notification.

This section applies to any facility that stores, produces, or uses a hazardous chemical (any chemical thatis a physical hazard or a health hazard) and releases a reportable quantity (RQ) of a substance containedin either of the following two tables published by the EPA in the Code of Federal Regulations:

(1) List of extremely hazardous substances

(2) List of CERCLA hazardous substances

4.2.2.3.2.3 Sections 311-312: Community Right-to-Know.The purpose of these requirements is to increase community awareness of chemical hazards and tofacilitate emergency planning.4.2.2.3.2.4 Section 313: Toxic Chemical Release Inventory.

The data gathered will assist in research and development of regulations, guidelines, and standards. Underthis section, The EPA is required to establish the Toxic Release Inventory (TRI), an inventory of routinetoxic chemical emissions from certain facilities. The original data requirements for the TRI, specified inSARA Title III, have been greatly expanded by the Pollution Prevention Act of 1990. The TRI must nowalso include information on source reduction, recycling, and treatment.4.2.2.4 Federal Water Pollution Control Act (FWPCA).

The FWPCA was passed in 1972 and amended in 1977 to become the Clean Water Act (CWA). This actrequires the EPA and U.S. Coast Guard to regulate the spills of oil and/or other hazardous substances thatthreaten coastal waters and inland waterways.4.2.2.5 Clean Water Act (CWA).

The CWA aims to protect the health of our nation's waters by establishing water quality goals as well as theplans and permits needed to achieve these goals. The CWA aims to protect the waters of the United Statesby preventing, reducing, and eliminating pollution. The term waters of the United States include navigablewater, ground water, surface water, and underground waters. Title III of the CWA establishes responserequirements for discharges of oil and hazardous substances from ships and on- or off-shore facilities.


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4.2.2.6 Oil Pollution Act (OPA).This act was signed into law in 1990 to cover both facilities and carriers of oil and related liquid product,including deepwater marine terminals, marine vessels, pipelines, and railcars. Requirements include thedevelopment of emergency response plans, regular training and exercise sessions, and verification of spillresources and contractor capabilities. The OPA addresses development of a national planning andresponse system on four levels: national, area, local, and facility. In the event of an oil spill, the facilityresponse plan (FRP) is immediately activated with other plans activated as needed. Owners or operators ofa regulated facility must have a spill prevention, control, and countermeasures (SPCC) program.4.2.2.7 Spill Prevention, Control, and Countermeasure Plan (SPCC).

This regulation applies to facilities engaged in drilling, producing, gathering, storing, processing, refining,transferring, distributing, or consuming oil and oil product that due to location could reasonably be expectedto discharge oil in quantities that could be harmful into or upon navigable waterways or adjoining shoreline,or upon the water on the contiguous zone.4.2.2.8 National Contingency Plan.

The National Contingency Plan (NCP) is the federal government's blueprint for responding to both oil spillsand hazardous substance releases. The NCP is required by Section 105 of the CERCLA of 1980, asamended by the SARA of 1986 and by Section 311(d) of the CWA, as amended by the OPA of 1990. TheNCP has been revised over the years to include a framework for responding to oil discharges andhazardous substance spills to water as well as releases at hazardous waste sites requiring emergencyremoval actions.4.2.3 Department of Homeland Security — The Stafford Act.

The Stafford Act is the central legislation governing the federal response to disasters within the UnitedStates with the Federal Emergency Management Agency designated as the primary federal agencyresponsible for responding to disasters.4.3 Regulatory Agencies.4.3.1 U.S. Occupational Safety and Health Administration (OSHA).Title 29, Labor, Subtitle B, Regulations Relating to Labor, Chapter XVII, Occupational Safety And HealthAdministration, Department Of Labor, Part 1910 “Occupational Safety and Health Standards,” Subpart H.“Hazardous Materials,” section 120, "Hazardous Waste Operations and Emergency Response” refers toOSHA regulations governing hazardous materials emergency response.4.3.1.1

29 CFR 1910.120 and 1926.65 covers emergency response operations for release of, or substantial threatsof release of, hazardous substances without regard to the location of the hazard. Paragraph (q) of theHazardous Waste Operations and Emergency Response Standard (HAZWOPER) provides inspectionprocedures for 29 CFR 1910.120 and 1926.65, relative to emergency response to hazardous substancerelease.4.3.1.2

The following OSHA references cover specific regulations as guidance for the emergency response:

(1) Subpart H — Hazardous Materials 29 CFR 1910.120 Hazardous Waste Operations and EmergencyResponse

(2) Subpart I — Personal Protective Equipment 29 CFR 1910.134 Respiratory Protection

(3) Subpart J General Environmental Controls 29 CFR 1910.146 Permits Required Confined Spaces29 CFR 1910.147 The Control of Hazardous Energy (Lock Out/Tag Out).

(4) Subpart Z Toxic and Hazardous Substances 29 CFR 1910.1030 Blood borne Pathogens.

(5) OSHA Hazard Communication 29 CFR 1910.1200.

4.3.2 The U.S. Environmental Protection Agency (EPA).Title 40 — Protection of the Environment, Chapter I — Environmental Protection Agency, Subchapter J —Superfund, Emergency Planning, And Community Right-To-Know Programs sets forth requirements for thesubmission of information relating to the release of toxic chemicals under section 313 of Title III of theSuperfund Amendments and Reauthorization Act of 1986.


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4.3.2.1 Part 311 “Worker Safety.” 29 CFR Part 1910 is incorporated by reference and is in place for those states,without OSHA-approved state plans and is the lead agency for response.4.3.2.2 SARA Title III and the EPCRA created a method and standard practice for a local community tounderstand and be aware of the requirements businesses that handle chemicals have to report storagetype, quantity, and storage methods to the fire department and the local emergency planning committee.4.3.2.2.1

LEPCs gather and disseminate information about hazardous materials to the public.4.3.2.2.2

Each State has a SERC. The SERC is the liaison between local and state levels of authority.4.3.3 U.S. Department of Transportation (DOT).49 CFR, a comprehensive set of transportation regulations, enforces and publicizes laws and regulationsthat govern the transportation of goods by highway, rail, air, and, in some cases, marine transport. Whenspills occur while the material is on the vehicle or otherwise “in transportation,” OSHA's HAZWOPERstandard [29 CFR 1910.120(q)]covers the emergency response personnel who respond to the incident.4.3.3.1

Subchapter B (Hazardous Materials and Oil Transportation), Part 130 (Oil Spill Prevention and ResponsePlans) prescribes prevention, containment, and response planning requirements applicable totransportation of oil by motor vehicles and rolling stock.4.3.3.2 Subchapter C (Hazardous Materials Regulations).4.3.3.2.1

Part 172 lists and classifies those materials that the department has designated as hazardous materials forpurposes of transportation and prescribes the requirements for shipping papers, package marking, labeling,and transport vehicle placarding applicable to the shipment and transportation of those hazardousmaterials.4.3.3.2.2

Part 174 (Carriage by Rail) prescribes requirements to be observed with respect to the transportation ofhazardous materials in or on rail cars.4.3.3.2.3

Part 175 (Carriage by Aircraft) prescribes requirements that apply to the transportation of hazardousmaterials in commerce aboard (including attached to or suspended from) aircraft.4.3.3.2.4

Part 176 (Carriage by Vessel) prescribes requirements to be observed with respect to the transportation ofhazardous materials by vessel.4.3.3.2.5

Part 177 (Carriage by Public Highway) prescribes requirements that are applicable to the acceptance andtransportation of hazardous materials by private, common, or contract carriers by motor vehicle.4.3.3.3 Subchapter D (Pipeline Safety).4.3.3.3.1

Part 193 (Liquefied Natural Gas Facilities: Federal Safety Standards) prescribes safety standards for LNGfacilities used in the transportation of gas by pipeline that is subject to the pipeline safety laws.4.3.3.3.2

Part 194 (Response Plans for Onshore Oil Pipelines) contains requirements for oil spill response plans toreduce the environmental impact of oil discharged from onshore oil pipelines.4.3.3.3.3

Part 195 (Transportation of Hazardous Liquids by Pipelines) prescribes safety standards and reportingrequirements for pipeline facilities used in the transportation of hazardous liquids or carbon dioxide.4.3.4 U.S. Department of Energy (DOE).

Title 10 Chapter 10 CFR 1021 Subpart C, Implementing Procedures of the Department of Energy, outlinethe manner in which nuclear materials will be assessed and handled.4.4 Standards — General.


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The documents or portions thereof listed in this chapter are referenced within this recommended practiceand should be considered part of the recommendations of this document.4.4.1 * NFPA Standards.National Fire Protection Association, 1 Batterymarch Park, P.O. Box 9101, Quincy, MA 02269-9101.4.4.1.1 NFPA Standards for Hazardous Materials.

NFPA 472, Standard for Competence of Responders to Hazardous Materials/Weapons of MassDestruction Incidents , 2008 edition, provides a framework by which an organization can meet therequirements of the OSHA HAZWHOPER regulation. By meeting this standard, compliance with OSHA1910.120 is met or exceeded.

(1) NFPA 473, Standard for Competencies for EMS Personnel Responding to HazardousMaterials/Weapons of Mass Destruction Incidents , 2008 edition, identifies the levels of competencerequired of emergency medical services (EMS) personnel who respond to incidents involvinghazardous materials or WMD.

(2) NFPA 600, Standard on Industrial Fire Brigades , contains minimum requirements for organizing,operating, training, and equipping industrial fire brigades. It also contains minimum requirements forthe occupational safety and health of industrial fire brigade members while performing fire fightingand related activities.

(3) NFPA 1072, Standard for Hazardous Materials/Weapons of Mass Destruction EmergencyResponse Personnel Professional Qualifications.

(4) NFPA 1500, Standard on Fire Department Occupational Safety and Health Program , 2007 edition,contains minimum requirements for a fire service–related safety and health program. Items coveredinclude PPE, staffing, medical requirements, and physical requirements.

(5) NFPA 1521, Standard for Fire Department Safety Officer , 2008 edition, contains minimumrequirements for the assignment, duties, and responsibilities of a health and safety officer (HSO) andan incident safety officer (ISO) for a fire department.

(6) NFPA 1582, Standard on Comprehensive Occupational Medical Program for Fire Departments ,provides guidance on annual physicals for fire fighters and members of hazardous materialsresponse teams.

(7) NFPA 1584, Standard on the Rehabilitation Process for Members During Emergency Operationsand Training Exercises , establishes the minimum criteria for developing and implementing arehabilitation process for fire department members at incident scene operations and trainingexercises.

4.4.1.2 NFPA Standards for PPE.

(1) NFPA 1981, Standard on Open-Circuit Self-Contained Breathing Apparatus (SCBA) for EmergencyServices , 2013 edition.

(2) NFPA 1982, Standard on Personal Alert Safety Systems (PASS) , 2013 edition.

(3) NFPA 1991, Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies , 2013edition.

(4) NFPA 1992, Standard on Liquid Splash–Protective Ensembles and Clothing for Hazardous MaterialsEmergencies , 2012 edition.

(5) NFPA 1994, Standard on Protective Ensembles for First Responders to CBRN Terrorism Incidents ,2012 edition.


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4.4.1.3 NFPA Standards on Rescue Operations.

(1) NFPA 1006, Standard for Technical Rescuer Professional Qualifications , 2013 edition, establishesthe minimum job performance requirements necessary for fire service and other emergency responsepersonnel who perform technical rescue operations.

(2) NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents , 2009edition, is comprehensive and covers all types of rescue situations.

(3) NFPA 1983, Standard on Life Safety Rope and Equipment for Emergency Services , 2012 edition,specifies minimum design, performance, testing, and certifications requirements for life safety rope,escape rope, water rescue throw lines, life safety harnesses, belts, and auxiliary equipment foremergency services personnel.

(4) NFPA 1951, Standard on Protective Ensembles for Technical Rescue Incidents , 2013 edition,specifies the minimum design, performance, testing, and certification requirements for utility technicalrescue, rescue and recovery technical rescue, and chemicals, biological agents, and radiologicalparticulate [also known as chemical, biological, radiological, and nuclear (CBRN) technical rescue]protective ensembles for use by emergency services personnel during technical rescue incidents.

4.4.2 UL Standards.Underwriters Laboratory, 2600 N.W. Lake Road, Camas, WA 98607-8542. UL Classified PPE has beentested to levels of safety determined by NFPA standards for: fire fighters, hazardous materials responseteams, and other emergency responders.4.4.3 ASTM Standards.

American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959.The following is only a partial list of the ASTM standards. Review the complete list of the ASTM standardsat the following link to determine if any others apply to your operations (www.astm.org/).

(1) ASTM F 716, Method of Testing Sorbent Performance of Absorbents , 1993, covers thedevelopment of laboratory test data that describe the performance of absorbent materials used toremove oils and other compatible fluids from water. This standard should be used to measure anddescribe the properties of materials, products, or assemblies in response to heat and flame undercontrolled laboratory conditions and should not be used to describe or appraise the fire hazard or firerisk of materials, products, or assemblies under actual fire conditions. However, results of this testcan be used as elements of a fire risk assessment that takes into account all of the factors that arepertinent to an assessment of the fire hazard of a particular end use.

(2) ASTM F 726, Method of Testing Sorbent Performance of Adsorbents , 1999, describes theperformance of adsorbents in removing nonemulsified oils and other floating, immiscible liquids fromthe surface of water.

(3) ASTM F1127, Standard Guide for Containment of Hazardous Material Spill by EmergencyResponse Personnel , is the standard of care for hazardous materials response personnel.

(4) ASTM E 2458, Procedures for Sample Collection , covers bulk and onsite sampling.

(5) ASTM E 2601, Standard Practice for Radiological Emergency Response , provides decision-making considerations for response to incidents that involve radioactive materials. It providesinformation and guidance for what to include in response planning and what activities to conductduring a response.

(6) ASTM E 2770, Standard Guide for Operational Guidelines for Initial Response to a SuspectedBiothreat Agent , provides considerations for decision-makers when responding to incidents thatcould involve biothreats.


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4.4.4 ANSI Standards.

American National Standards Institute, Inc., 25 West 43 rd Street, 4 th Floor, New York, NY 10036. Thefollowing is only a partial list of the ANSI standards. Review the complete list of the ANSI standards at thefollowing link to determine if any others apply to your operations (www.ansi.org/).

(1) ANSI Z88.2, American National Standard Practices for Respiratory Protection, 2013 edition, setsforth accepted practices for respirator users; provides information and guidance on the properselection, use, and care of respirators; and contains requirements for establishing and regulatingrespirator programs.

(2) ANSI Z88.10, Fit Test Method, 2012 edition, provides guidance on how to conduct fit testing oftight-fitting respirators and appropriate methods to be used.

4.5 Guidance Documents.4.5.1 OSHA.4.5.1.1

Best practices are the most efficient and effective way to accomplish a task or function. Standards of careare established from best practices.4.5.1.2

Standard operating procedures (SOP) or standard operating guides are documents that define and codifyyour best practices. SOPs take the guesswork out of the job because they allow everyone to understandwhat his or her job entails.4.5.2 FEMA.4.5.2.1

The National Response Framework (NRF) is a comprehensive how-to guide that spells out how the nationshould conduct an all-hazard response. It is intended to capture all levels of government and all incidentlevels. Local plans feed into state plans, which feed into the NRF.4.5.2.2

National preparedness guidelines are coordinated capabilities to prevent, protect against, respond to, andrecover from all hazards in a way that balances risk with resources and need.4.5.2.3

The target capabilities list (TCL) supports an all-hazards approach to building capabilities and is a tool forplanning and responding (https://www.rkb.us/hspd8.cfm). The TCL describes the capabilities related to thefour homeland security mission areas: prevent, protect, respond, and recover. It defines and provides thebasis for assessing preparedness. It also establishes national guidance for preparing the nation for majorall-hazards events, such as those defined by the national planning scenarios. The current version of theTCL contains 37 core capabilities.4.5.2.4

Resource typing is the categorization and description of resources that are commonly exchanged indisasters via mutual aid, by capacity and/or capability, for the purpose of facilitating ordering and tracking.Typed Resource Definitions, Emergency Medical Services Resources, FEMA 508-3, U.S. Department ofHomeland Security Federal Emergency Management Agency, May 2005.4.5.3 Presidential Directives.4.5.3.1 Presidential Policy Directive 8 (PPD 8: National Preparedness).

This directive is aimed at strengthening the security and resilience of the United States through systematicpreparation for the threats that pose the greatest risk to the security of the nation, including acts ofterrorism, cyber attacks, pandemics, and catastrophic natural disasters. Our national preparedness is theshared responsibility of all levels of government, the private and nonprofit sectors, and individual citizens.Everyone can contribute to safeguarding the nation from harm. As such, while this directive is intended togalvanize action by the federal government, it is also aimed at facilitating an integrated, all-of-nation,capabilities-based approach to preparedness.


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4.5.3.2 National Security Presidential Directive 33 (NSPD 33: Biodefense for the 21 st Century).This directive includes response planning, mass casualty care, risk communication, medicalcountermeasures, and decontamination. New initiatives will strengthen our ability to provide mass casualtycare and to decontaminate the site of an attack.4.5.4 Other Resources.

(1) U.S. Chemical Safety Board www.csb.gov

(2) National Transportation Safety Board www.ntsb.gov

(3) Lessons Learned Information Sharing www.llis.dhs.gov

(4) FEMA's National Training and Education Division www.firstrespondertraining.gov

(5) The National Fire Fighter Near-Miss Reporting System www.firefighternearmiss.com



(8) Responder Knowledge Base https://www.rkb.us/










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4.1 General.The laws, regulations, standards, and guidance documents or portions thereof listed in this chapter arereferenced within this recommended practice and should be considered part of the recommendations of thisdocument - either here or when you begin to discuss each word .

It may be beneficial to define the words "law", "regulation", and "consensus standard".

4.1.1 Laws are enacted by legislative action of governmental bodies - Congress, individual states, and localgovernment. They typically provide broad goals and objectives, mandatory dates for compliance, andestablish penalties for noncompliance. or at 4.2.1

4.1.2 Regulations are official rules created by government agencies that says how something should bedone. or at 4.3.1

4.1.3 A consensus standard is a standard which has been adopted and promulgated by a nationallyrecognized standards-producing organization under procedures whereby it can be determined that personsinterested and affected by the scope or provisions of the standard have reached substantial agreement onits adoption; was formulated in a manner which afforded an opportunity for diverse views to be considered;and has been designated as such. or at 4.4.1


To develop the relationship between law, regulation, and consensus standard.






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4.1 General.The laws, regulations, standards, and guidance documents or portions thereof listed in this chapter arereferenced within this recommended practice and should be considered part of the recommendations of thisdocument.

Reviewer Comment: This chapter is U.S. Centric, even though this standard will likely be usedinternationally. It would be useful to have tailored, nation-specific, chapters developed by nationalSMEs and included in the standard.


This section only applies to US regulation and legislation, whereas this standard will be used internationally.






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4.5.4 Other Resources.

(1) U.S. Chemical Safety Board www.csb.gov

(2) National Transportation Safety Board www.ntsb.gov

(3) Lessons Learned Information Sharing www.llis.dhs.gov





(8) Responder Knowledge Base https://www.rkb.us/

(9) U.S. Coast Guard https://www.uscg.mil


The US Coast Guard is active in response activities to hazardous materials incidents on navigable waterways and their tributaries. They are also active in the maritime enforcment of rules and regulations pertaining to the transportation of hazardous materials and substances. The US Coast Guard, in some jurisdictions, is part of the Regional response Team effort(s) to hazardous materials incidents.


Submitter Full Name: Dave Finger

Organization: National Volunteer Fire Council



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Chapter 5 Risk Analysis5.1 Introduction.5.1.1 Purpose.

The purpose of this chapter is to provide information and guidance for hazardous materials/weapons ofmass destruction response team program managers in understanding how a risk analysis can be used toidentify the presence of hazards and risks within a jurisdiction, the estimated impact of a potentialhazardous materials release, the probability of an incident occurring, and the types, kinds, and causes ofhazardous materials releases.5.1.2 Scope.5.2 Hazard Identification and Risk Assessment (HIRA).HIRA is a process for conducting a risk assessment, identifying vulnerabilities, and estimating the potentialfor a release of hazardous materials within a given area or jurisdiction. Hazardous materials have apotential to effect life, environment, or property. The purpose of the HIRA process is to reduce thelikelihood of an accidental or intentional release.5.2.1

HIRA analytical methods will vary from jurisdiction to jurisdiction, and the assessment will be specific toeach hazard.5.2.2

Identifying locations that could present a hazard that would affect the stability of life, the environment,and/or property should be accomplished using various systems that have been well established. SARATitle III and the EPCRA, along with the EPA’s RMP can be used to identify facilities within a given area thatmanufacture or store extremely hazardous substances (EHS). 49 CFR Subchapter B, Subchapter C, andSubchapter D can also help identify substances that are considered regulated materials duringtransportation. With this information an HMRT can plan, prepare for, and prioritize those facilities with thegreatest potential for harm.5.2.3

Identification of hazardous locations, the hazards present, and the facility’s internal emergency responsecapabilities will greatly influence the jurisdiction’s decision of whether or not an HMRT is needed and whattype of the equipment will be needed to mitigate a hazardous materials incident.5.2.4

Historical information regarding chemicals and releases from other similar facilities can be a valuable toolwhen assessing the risks of a given facility and the response resources needed by the jurisdiction.5.3 Hazard Identification.

Identifying the areas within a jurisdiction that could be affected by a hazardous material/weapons of massdestruction (HazMat/WMD) event is crucial to planning a well-organized and effective response. Theseverity of the event, probability, frequency, causation factors, and other locations affected should beconsidered when identifying potential locations.5.4 Types of Events.Events that can cause a release or a potential for release can be categorized as natural or manmade.Manmade events can include intentional or deliberate acts.5.4.1

Special attention should be given to facilities that could have a profound economic impact on thecommunity should a major release or loss occur. The majority of the population within any given area couldbe either directly or indirectly employed by a facility that manufactures, stores, or ships certain regulatedmaterials. Some could be employed by the stricken facility itself while others could work for companies thatsupport or depend on those facilities.


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5.4.2 If commercial and economic interdependencies exist at the time of a catastrophic event, the impact willmost likely affect not only the nearby community but also the economy and/or life safety of the entireregion.5.4.3

Specialized response resources can be limited within a given jurisdiction. Scares resources need to beidentified and mutual aid agreements or memorandums of understanding need to be developed foradditional resource prior to an Incident. A list of outside resources and how they can be obtained should bemaintained by the jurisdiction to expedite procurement when needed.5.4.4

Once facilities have been identified, a risk assessment should be performed using the information obtainedfrom EPCRA, RMP, and 49 CFR5.4.5

Vulnerable populations that could be impacted include residences, hospitals, nursing homes, businesses,or other occupancies.5.4.6

Environmental concerns could include waterways, estuaries, parks, floodplains, wetlands, or borderingfacilities.5.4.7

Other areas of concern could include critical infrastructure such as roadways, power plants, and watersupplies.5.4.8 Naturally Occurring Hazardous Materials Incidents.

Naturally occurring events have the potential to cause hazardous materials releases at fixed facilities orduring the transportation of hazardous materials. Unforeseen hazards from naturally occurring events canhamper response efforts. The responding jurisdiction could be faced with difficult decisions such asdetermining alternate routes for access and egress, availability of specialized equipment needed to supportthe response, and specialized resources to overcome obstacles encountered. Naturally occurring eventsthat could affect a response include the following:

(1) Floods

(2) Hurricanes

(3) Earthquakes

(4) Tornadoes

(5) Wildfires

(6) Landslides

(7) Winter storms

(8) Drought

(9) Lightning


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5.4.9 Manmade Hazardous Material Incidents:Manmade events have the potential to cause hazardous material releases at fixed facilities or during thetransportation of hazardous materials. During day-to-day operations, personnel at fixed facilities can causeaccidental releases by their actions or the lack thereof. Manmade releases that are more common thannatural occurring events can be classified into two categories, accidental or intentional. The cause of therelease can change the response. Intentional releases constitute a crime and will require investigativeassistance from law enforcement agencies. Although the protection of life and the environment areparamount, steps should be taken to preserve any evidence. Causes of manmade hazardous materialsreleases include the following:

(1) Poor maintenance of equipment, faulty engineering and design, human error, or mechanical failure

(2) Transportation accidents

(3) Terrorist activities

(4) Fire or explosion

(5) Sabotage or intentional releases

5.5 Severity.The severity and magnitude of a hazardous materials incident is dependent upon the type of facilityinvolved or mode of transportation, the amount released, and the hazards of the material involved. Thecommunity’s resources and ability to respond can also affect the severity. Factors that can contribute to theseverity of the incident include the following:

(1) Type of container (atmospheric pressure or high pressure)

(2) Type of breach (puncture, tear, detonation, or deflagration)

(3) Rate of release (spill, leak, vent, engulfment)

(4) Matter released (matter or energy)

(5) State of matter (solid, liquid, or gas)

(6) Type of dispersion (driving force, path or movement, dispersion pattern, and distance traveled)

(7) Type of impingement (transient, lingering, or permanent)

(8) Type of harm (thermal, radiation, asphyxiating , etiologic, or mechanical)

5.6 Probability.Probability is the process of determining how likely it is that a hazardous materials incident could occur.Probability can reasonably be determined by subjectively examining historical data that might indicate thefrequency of incidents and what type of hazardous materials have been involved in accidents in the past.National databases can be consulted to determine the most common types of materials involved in otherincidents. This data can then be compared to the hazards identified within your community to determine ifyou have a high or low probability of an incident occurring. Probability can also be determined objectivelythrough the use of mathematics and models that measure the ratio of the favorable cases to the wholenumber of cases possible.5.7 Frequency

: Frequency is the process of determining how often hazardous material incidents occur in your community,the state, or the region. Frequency can be determined by asking the following questions:

(1) Has a hazardous materials incident ever occurred in your jurisdiction?

(2) Have similar types of incidents ever occurred within your jurisdiction?

(3) What was the magnitude of the incidents that occurred?

(4) How did the event impact the community in terms of loss of life, injuries, property damage,environmental impact, and disruption of infrastructure or the economy?


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5.8 Causation Factors.Causation factors examine the probable cause of known incidents that have occurred. Issues that shouldbe examined include the following:

(1) Were the events from natural causes such as flood, lightening strike, tornado, hurricane,earthquake, and so forth?

(2) Was the event manmade such as accidental, sabotage, vandalism, or a terrorist incident?

5.9 Locations.Determining the locations of potential incidents is the process of identifying specific locations wherehazardous materials are stored, manufactured, used, or transported. This can also include locations wherehazardous waste is disposed of or processed. When evaluating incident locations, the following factorsshould be considered:

(1) What will the primary impact to the community be if a credible worst-case scenario were to happen?Can the hazardous material go beyond the fence line of the facility and impact people, property, orthe environment?

(2) Will a major incident at a fixed facility have a significant impact on the local economy? Is the facilitya primary employer in the community? Are there interdependencies with other facilities?

(3) Is the location of a potential incident a critical infrastructure node? If a major incident were to occurat this location, would it have a significant impact on transportation, communications, or energysupplies?

(4) Does the location have significance to national security? Will an incident have a negative impact onnational defense or intelligence missions?

(5) Would a major incident at the location likely require additional regional, state, or federal resources tomitigate?

(6) Is the facility a one of a kind resource that cannot be quickly replaced if destroyed?


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5.10 Risk Assessment.Risk assessment is a process used to determine the probability of a hazardous materials incident withinyour jurisdiction along with the associated impact. Risk assessment considers various factors includingseverity, frequency, causes, and the location of the threat. Assessing the risk includes examining the localresponse history and comparing it to regional, state, and national historical data. In addition to the issuesalready covered, the following factors should be examined:

(1) HMRT should examine previous events that have occurred in their local area. DOT, OSHA, andNIOSH accident data involving the most common hazardous materials can be valuable in conductinglocal risk assessments. When a catastrophic event occurs in some other area and the AHJ has acomparable facility in their area, the local HMRT should ensure that its response plans and trainingprograms include information about that type of facility.

(2) The HMRT should maintain a list of the Tier 2 facilities, including those facilities that have EHS andthe ones that are covered by EPA RMP regulations. At a minimum, HMRT response plans should bedeveloped and reviewed with both the facility and the nearby community. The review should identifyvulnerable populations such as schools, day cares, retirement centers, assisted living/nursinghomes, hospitals, and other facilities that cannot be quickly evacuated and might have to shelter inplace. HMRT plans should include atmospheric air monitoring and protection strategies for thosevulnerable populations. Outreach efforts between the facility and the vulnerable populations shouldbe conducted on a regular basis so that all parties are aware of emergency response plans prior to arelease.

(3) Fuel stations, liquefied gas facilities (LPG/LNG), and their respective storage present a likely risk inmany communities. The number, frequency, and method of delivery make incidents at theselocations a likely scenario. Conducting a commodity flow study that identifies the delivery routes canassist in the development of pre-incident plans.

(4) The transportation system should be analyzed for potential threats. The railroad that operates in theAHJ can be contacted for information concerning the number and frequency of hazardous cargoshipments. The Port Authority can be contacted to determine the number and frequency of maritimeshipments. The DOT Pipeline and Hazardous Materials Safety Administration PHMSA pipelinemapping system can be researched to determine what pipelines are located in the AHJ’s area ofresponsibility. A challenging threat area includes highway transportation. One method of determiningthe potential threat is to conduct a community flow study where HMRT personnel track the number oftruck shipments in their area along with the type and quantity of materials being shipped. Peek trucktraffic can vary greatly so a community flow study should encompass a variety of times and shouldbe done over a period of days to reveal trends. If a weigh station is present, law enforcementagencies who conduct truck inspections can help identify cargos by examining the shipping papers.

(5) The impact of natural events and their interaction with at-risk facilities should be considered. Whennatural events occur elsewhere, the HMRT should identify comparable facilities within their regionand plan for the possibility of a similar event. Examining historical weather data can determine thefrequency of unusual weather related events.

(6) Emergency response plans should include expected accidental releases, including the frequencyand impact. Events can be categorized as frequent or infrequent and have a low or high impact. Theimpact to the local community should be considered as well as the potential impact to adjacentfacilities. Fixed facilities should have safety systems in place with redundant backups to preventaccidental releases.

(7) Intentional releases are criminal in nature and could be an attempted terrorist attack. Although bothacts are criminal, it is the purpose and intent of the release that makes the difference. Releases atfixed facilities should be considered criminal acts until proven otherwise. While it can be difficult todetermine whether a release is accidental or intentional, the HMRT team along with trainedinvestigators should try to determine the root cause. In cases where terrorism is suspected, theappropriate law enforcement officials should be notified.

(8) Explosions also require an investigation, including the root cause. The bomb squad can be used todetermine the cause of an explosion. The HMRT should be used to determine if there are flammablegases or other hazardous materials present.


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5.11 Threat.The threat becomes the analysis of the potential hazards as identified by the community risk assessment.Factoring in the facilities, the materials, and the community provides a total hazard assessment. Thisanalysis includes the hazard identification combined with an assessment of the risk based on thecommunity and available resources.5.11.1

The components of the threat include the facility, the hazardous materials present, the location of thefacility, and the jurisdiction’s response capabilities. The facility should have engineering controls in place tominimize the potential for a release and should have plans in place to control a release if one occurs. TheHMRT should have an emergency response plan in place. Plans should include both realistic worst-casescenarios with a special emphasis on those high frequency type events.5.11.2

The amount of material and the concentration is another aspect of the threat. The Threshold PlanningQuantities (TPQs) have been established under the Emergency Planning and Community Right to KnowAct (EPCRA). For instance the TPQ for ammonia is 500 pounds. Ammonia however, can be found in ananhydrous or aqueous (mixed with water) state. The potential impact from a release of anhydrous andaqueous ammonia can be very different. If a fixed facility stores more than 500 pounds of ammonia it isconsidered an EHS facility. Some materials that are not considered EHSs may create situations wherethere is substantial risk to the facility and the community. Gasoline for instance, if allowed to enter a stormdrain system can migrate and spread flammability and contamination risk a considerable distance.5.11.3

The ability of a fixed facility to prevent, detect, and mitigate a potential release is an important part of athreat assessment. HMRT’s capability to detect, control, and mitigate a potential release is a vital part ofthe threat assessment process. In the event of a terrorist attack there is potential for the terrorist to try andexploit weaknesses in the system for maximum impact. Having a well prepared facility focused on securityand a properly trained and equipped HMRT is critical for the safety of the community.5.12 Vulnerability.Assessing the vulnerability combines the potential for an event to happen, an estimation of the probabilityof an event, and the potential impact to life and property should an event occur. The vulnerability of ajurisdiction should be assessed from both the accidental and intentional release perspective.5.12.1 Potential.

The potential for an event to happen is an important part of the planning process. In some cases, releasesmay be fairly common and will most likely result in a low impact to the community and facility. Thechallenge is being prepared for low frequency events that have a potential for high impact effects. A highimpact event typically extends beyond the facility and may result in road closures or a neighborhood beingevacuated or sheltered in place. Other situations may impact businesses, community buildings, or areasthat inconvenience the community. Releases from pipelines may disrupt gas, power, water, sewer systemsand can have a community-wide effect.5.12.2 Probability.

Probability estimates the potential for an event to take place and should include the previous history basedon the process and facility. To estimate the probability the following questions should be asked:

(1) Has an event ever occurred with this type of process or storage system anywhere in the world?

(2) Has the company ever experienced an event with this process or storage system?

(3) Has the facility ever experienced an event with this process or storage system?

(4) Is there is an affirmative answer to any of the previous questions? If so, the frequency should bedetermined. Is this a 20+ year event, a less than 20 year event, an annual event, a weekly event, ora daily event?

(5) What were the consequences and circumstances of the event?

(6) What additional preventative steps were taken by the facilities after each of the events?


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5.12.3 Once potential events have been determined they should be ranked by risk level. Having the resources inplace to handle potential events should be a high priority. If the AHJ does not have the required resourcesand capabilities, then planning should take place to determine the best way to obtain those resources whenneeded. A cost benefit analysis should be conducted by the AHJ to decide whether or not to invest in thenecessary training and/or equipment or to simply rely on mutual aid. Cooperative planning betweenfacilities can help with equipment acquisitions and response training.5.12.4

In each potential scenario the HMRT should develop rescue plans based on the potential for humanimpact. The HMRT should focus their planning efforts on two fronts. The first should include thosehigh-frequency/low-impact events and the second should address the low-frequency/high-impact events.5.12.5

Specific HMRT activities will vary depending on the material released and any potential for off-siteconsequences. Other factors can include the ability of the stricken facility to self-evacuate and the amountof protection offered by the facility’s buildings. It could be that the facility’s structures have been designed toprotect the occupants by offering an internal shelter in place as a viable option.5.12.6

Certainly the preference would be that the AHJ would prohibit a facility from being located next to avulnerable population. Another preference would be that occupancies located adjacent to a facility beconstructed and designed to offer protection for vulnerable populations during shelter in place scenarios.5.12.7

As a release occurs, HMRT members should be assigned to conduct atmospheric air monitoring andsampling in and around the stricken facility. Establishing a central point of contact where information can bedisseminated to the community and the facility involved is beneficial. The sooner scene data is obtainedand disseminated, the quicker the public’s fears can be addressed.5.12.8

In each potential scenario the HMRT should estimate the economic impact to the community, region, state,and, in some cases, the nation. Land, equipment, infrastructure, and key resources might have to berepaired, decontaminated, or replaced.5.12.9

The HMRT should survey and preplan fixed facilities where hazardous materials could be released. HMRTshould determine if property beyond the facility will be impacted and then plan accordingly. Planning fortransportation incidents can present a challenge. However, surveying areas where incidents are likely tooccur and developing plans for safe access and protection of nearby vulnerable populations can bebeneficial.5.12.10

Vulnerable areas can include waterways, sewer systems, environmentally sensitive areas, roads, bridges,water treatment facilities, and other sensitive areas.5.12.11

Researching the chemical and physical properties of the materials that could be involved and pre-planningfor the use of specialized equipment should help HMRT prepare for the possible contamination or damageof that equipment. When such equipment will be out of service for decontamination, repair, or replacement,the HMRT should plan for its quick replacement or have other contingency plans in place.5.12.12

The HMRT should identify those fixed facilities that might cause off-site impact and develop pre-incidentplans with the assistance from the facility to minimize those effects.5.12.13

Potential scenarios that might lead to a catastrophic release and impact to a major highway ortransportation corridor should be discussed with the local emergency management agency, transportationagency, local elected officials, and other stakeholders.5.12.14

The HMRT should develop a relationship with other local, regional, and state emergency responseagencies so assistance can be quickly obtained when catastrophic events result in major impact to thecommunity.


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5.13 Risk Characterization.Risk characterization combines the results of the hazard identification and risk assessment to define theprobability and severity of adverse social, economic, environmental, infrastructure, and/or health risk to thecommunity. When characterizing risks, the following types of impacts should be considered:

(1) Social impact: How can the identified risk impact the life safety and security of the community?

(2) Economic impact: How can the identified risk affect the local, regional, or national economy?

(3) Environmental impact: How can the identified risk affect the environmental quality? Is the facilitylocated next to a critical aquifer, navigable waterway, or sensitive environmental area?

(4) Infrastructure impact: How can the identified risk impact local or regional energy supplies,communications, or national security?

(5) Public health impact: How can the identified risk impact public health? Will potential incidents havean acute or chronic effect? Are special/functional needs populations potentially at risk?

5.14 Cascading Events.Cascading events are incidents that compound the stresses placed on the response system as a whole.For instance, a single manmade event occurring simultaneously along with a natural disaster cancompound the intensity by virtue of the sheer magnitude. Likewise, a natural disaster such as anearthquake can cause multiple incidents at multiple locations that can spiral out of control and havesecondary or tertiary impacts to life safety, public health, or the environment. When evaluating cascadingevent potential, each event location should be viewed as an individual event within the context of a largerdisaster complex.5.15 Geographic-Based Threat Assessment.

Geographic threat assessment utilizes geographic information systems (GIS) allowing the user to bettervisualize, question, analyze, interpret, and understand interdependencies, patterns, and trends. GISprovides layers of information that can be used to map locations and assess potential impact. This allowsplanners to identify the relationships between the hazards, predict outcomes, visualize scenarios, and planstrategies.5.16 Computer-Based Assessment.

Computer-based assessments use a variety of computer-based modeling to determine the potential impactof a hazardous materials release. Computer models are designed to evaluate specific issues such ashazardous substances releases, migrating toxic gas plumes, oil spill migration, blast effects, and weather.When computer data is combined with geographic information systems data, the consolidation ofinformation can give planners a clearer picture of the potential vulnerabilities within the community, region,or state.


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5.17 Strategic Plan.A strategic plan is the final work product that incorporates all of the hazard and risk assessment workproducts into a cogent document for elected officials and public safety agencies. When done properly, astrategic plan provides clear direction for decision makers. The plan summarizes the hazardous materialsproblems within the community, prioritizes the most significant issues that need to be addressed, andallocates resources required to reduce risks to the community at large. A key component of the strategicplan is the identification of the different levels of emergency services needed to safely mitigate a hazardousmaterials incident. The key elements of a strategic plan should include the following:

(1) Purpose: States the purpose and goals of the plan.

(2) Scope: Identifies the AHJ and its geographic boundaries.

(3) Situation: Describes the hazardous materials problems within the defined jurisdiction.

(4) Concept of operations: Describes the general concept of operation for addressing the hazardousmaterials problem and the desired outcomes that will lower risks to the community.

(5) Administration and logistics: Describes who has ownership of the plan and who is responsible forproviding funding and tracking costs.

(6) Plan maintenance: Describes who is responsible for managing change and ensuring action itemsare closed out.

(7) Emergency support functions (ESF): Defines what ESF are needed to implement parts of the planand the names of the specific agencies that are required to staff those respective functions. Forexample, during an evacuation, ESF-1 (transportation) and ESF-6 (sheltering) will be activated. EachESF within the plan is responsible for determining how it will support the strategic plan as it isimplemented.

(8) References: A list of applicable laws, regulations, or plans that provide authority or direction for theplan.



Chapter_5_Annex_PI.docx








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HIRA THIRA is a process for conducting a risk assessment, identifying vulnerabilities, and estimating thepotential for a release of hazardous materials within a given area or jurisdiction. Hazardous materials have apotential to effect life, environment, or property. The purpose of the HIRA THIRA process is to reduce thelikelihood of an accidental or intentional release.


Changing HIRA to THIRA would keep NFPA 475 consistent with NFPA 1616, section 5.5 which uses THIRA.


Submitter Full Name: Garuy Sharp

Organization: Independence Fire Department

Street Address:City:State:Zip:Submittal Date: Tue Oct 28 20:59:22 EDT 2014


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HIRA is a process for conducting a risk assessment, identifying vulnerabilities, and estimating the potentialfor a release of hazardous materials hazards (things which can cause harm), their potential frequency ofoccurrence (probability), and their potential to cause harm (vulnerability), within a given area or jurisdiction.Hazardous materials have a potential to effect life, environment, or property. The purpose of the HIRAprocess is to reduce the likelihood of identify and quantify risks, thereby allowing planners to prioritize thepotential threats and best allocate available resources to the implemententation of prevention, mitigationand/or preparation tactics to deal with an accidental or intentional release.


The statement as written does not include the full scope, nor does it well describe the purpose, of an HIRA. The amended wording makes the scope and intent more clear.






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5.4.1 Special attention should be given to facilities that could have a profound human health, or economic impacton the community, should a major release or loss occur. The majority of the population within any givenarea could be either directly or indirectly employed by a facility that manufactures, stores, or ships certainregulated materials. Some could be employed by the stricken facility itself while others could work forcompanies that support or depend on those facilities.


The human health effects are not considered in the original definition.






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5.4.3 Specialized response resources can be limited within a given jurisdiction. Scares Limited resources needto be identified and mutual aid agreements or memorandums of understanding need to be developed foradditional resource prior to an Incident. A list of outside resources and how they can be obtained should bemaintained by the jurisdiction to expedite procurement when needed.


Scares is a typo and should scarce, but the word limited is a better fit. The use of limited simplifies the language and corrects and error.



Organization: Cecil County Department of Emergency Services



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5.4.3 Specialized response resources can be limited within a given jurisdiction. Scares Scarce resources needto be identified and mutual aid agreements or memorandums of understanding need to be developed foradditional resource prior to an Incident. A list of outside resources and how they can be obtained should bemaintained by the jurisdiction to expedite procurement when needed.


Suspected typo






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5.4.8 Naturally Occurring Hazardous Materials Incidents.Naturally occurring events have the potential to cause hazardous materials releases at fixed facilities orduring the transportation of hazardous materials. Unforeseen hazards from naturally occurring events canhamper response efforts. The responding jurisdiction could be faced with difficult decisions such asdetermining alternate routes for access and egress, availability of specialized equipment needed to supportthe response, and specialized resources to overcome obstacles encountered. Naturally occurring eventsthat could affect a response include the following:

(1) Floods

(2) Hurricanes

(3) Earthquakes and/or associated tsunamis

(4) Tornadoes

(5) Plough winds

(6) Wildfires

(7) Landslides

(8) Winter storms

(9) Drought

(10) Lightning

(11) Hail

(12) Tidal forces (for example spring tides can complicate spill response due to large tidal range)

(13) Space weather (i.e solar storms) (can cause disruption in space- based communications systems)

(14) Temperature extremes


Added some natural events which could impact hazmat/wmd response.






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5.4.9 Manmade Hazardous Material Incidents:Manmade events have the potential to cause hazardous material releases at fixed facilities or during thetransportation of hazardous materials. During day-to-day operations, personnel at fixed facilities can causeaccidental releases by their actions or the lack thereof. Manmade releases that are more common thannatural occurring events can be classified into two categories, accidental or intentional. The cause of therelease can change the response. Intentional releases constitute a crime and will require investigativeassistance from law enforcement agencies. Although the protection of life and the environment areparamount, steps should be taken to preserve any evidence. Intentional man-made releases also implyother complications to response, such as the location (intentional releases likely caused in areas wherethere will be the most impact) and/or the potential for secondary devices/releases designed to cause harmto responders. Causes of manmade hazardous materials releases include the following:

(1) Poor maintenance of equipment, faulty engineering and design, human error, or mechanical failure

(2) Transportation accidents

(3) Terrorist activities, including eco-terrorism

(4) Fire or explosion

(5) Sabotage or intentional releases


I have added some additonal complications which could be associated with intentional, mand-made releases.






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5.5 Severity.The severity and magnitude of a hazardous materials incident is dependent upon the type of facilityinvolved or mode of transportation, the amount released, and the hazards of the material involved. Thecommunity’s resources and ability to respond can also affect the severity. Factors that can contribute to theseverity of the incident include the following:

(1) Type of container (atmospheric pressure or high pressure)

(2) Type of breach (puncture, tear, detonation, or deflagration)

(3) Rate of release (spill, leak, vent, engulfment)

(4) Matter released (matter or energy)

(5) State of matter (solid, liquid, or gas)

(6) Type of dispersion (driving force, path or movement, dispersion pattern, and distance traveled)

(7) Type of impingement (transient, lingering, or permanent)

(8) Type of harm (thermal, chemical, biological, radiation, asphyxiating, etiologic, or mechanical)


Added chemical and biological as possible sources of harm. Deleted "etiologic" as the term is used out of context here.






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5.7 Frequency: Frequency is the process of determining how often hazardous material incidents occur in your community,the state, or the region. Frequency can be determined by asking the following questions:

(1) Has a hazardous materials incident ever occurred in your jurisdiction?

(2) Have similar types of incidents ever occurred within your jurisdiction?

(3) What was the magnitude of the incidents that occurred?

(4) How did the event impact the community in terms of loss of life, injuries, property damage,environmental impact, and disruption of infrastructure or the economy?


Corrects a formatting error and removes the colon.






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5.9 Locations.Determining the locations of potential incidents is the process of identifying specific locations wherehazardous materials are stored, manufactured, used, or transported; or where they could be deliberatelyreleased . This can also include locations where hazardous waste is disposed of or processed. Whenevaluating incident locations, the following factors should be considered:

(1) What will the primary impact to the community be if a credible worst-case scenario were to happen?Can the hazardous material go beyond the fence line of the facility and impact people, property, or theenvironment?

(2) Will a major incident at a fixed facility have a significant impact on the local economy? Is the facility aprimary employer in the community? Are there interdependencies with other facilities?

(3) Is the location of a potential incident a critical infrastructure node? If a major incident were to occur atthis location, would it have a significant impact on transportation, communications, or energy supplies?

(4) Does the location have significance to national security? Will an incident have a negative impact onnational defense or intelligence missions?

(5) Would a major incident at the location likely require additional regional, state, or federal resources tomitigate?

(6) Is the facility a one of a kind resource that cannot be quickly replaced if destroyed?


The statement as written deals with locations for accidental or deliberate "in situ" releases, but does not deal with the potential for a deliberate release of hazmat at a location other than one where they are stored, used, transported or disposed of. In other words, it is possible that someone deliberately releasing a substance would transport it to a location where it could do more harm than it would otherwise do in situ.






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5.10 Risk Assessment.Risk assessment is a process used to determine the probability of a hazardous materials incident withinyour jurisdiction along with the associated impact. Risk assessment considers various factors includingseverity, frequency, causes, and the location of the threat and the community/organization's vulnerability tothe threat . Assessing the risk includes examining the local response history and comparing it to regional,state, and national historical data. In addition to the issues already covered, the following factors should beexamined:

(1) HMRT should examine previous events that have occurred in their local area. DOT, OSHA, andNIOSH accident data involving the most common hazardous materials can be valuable in conductinglocal risk assessments. When a catastrophic event occurs in some other area and the AHJ has acomparable facility in their area, the local HMRT should ensure that its response plans and trainingprograms include information about that type of facility.

(2) The HMRT should maintain a list of the Tier 2 facilities, including those facilities that have EHS andthe ones that are covered by EPA RMP regulations. At a minimum, HMRT response plans should bedeveloped and reviewed with both the facility and the nearby community. The review should identifyvulnerable populations such as schools, day cares, retirement centers, assisted living/nursing homes,hospitals, and other facilities that cannot be quickly evacuated and might have to shelter in place.HMRT plans should include atmospheric air monitoring and protection strategies for those vulnerablepopulations. Outreach efforts between the facility and the vulnerable populations should be conductedon a regular basis so that all parties are aware of emergency response plans prior to a release.

(3) Fuel stations, liquefied gas facilities (LPG/LNG), and their respective storage present a likely risk inmany communities. The number, frequency, and method of delivery make incidents at these locationsa likely scenario. Conducting a commodity flow study that identifies the delivery routes can assist inthe development of pre-incident plans.

(4) The transportation system should be analyzed for potential threats. The railroad that operates in theAHJ can be contacted for information concerning the number and frequency of hazardous cargoshipments. The Port Authority can be contacted to determine the number and frequency of maritimeshipments. The DOT Pipeline and Hazardous Materials Safety Administration PHMSA pipelinemapping system can be researched to determine what pipelines are located in the AHJ’s area ofresponsibility. A challenging threat area includes highway transportation. One method of determiningthe potential threat is to conduct a community flow study where HMRT personnel track the number oftruck shipments in their area along with the type and quantity of materials being shipped. Peek trucktraffic can vary greatly so a community flow study should encompass a variety of times and should bedone over a period of days to reveal trends. If a weigh station is present, law enforcement agencieswho conduct truck inspections can help identify cargos by examining the shipping papers.

(5) The impact of natural events and their interaction with at-risk facilities should be considered. Whennatural events occur elsewhere, the HMRT should identify comparable facilities within their region andplan for the possibility of a similar event. Examining historical weather data can determine thefrequency of unusual weather related events.

(6) Emergency response plans should include expected accidental releases, including the frequency andimpact. Events can be categorized as frequent or infrequent and have a low or high impact. Theimpact to the local community should be considered as well as the potential impact to adjacentfacilities. Fixed facilities should have safety systems in place with redundant backups to preventaccidental releases.

(7) Intentional releases are criminal in nature and could be an attempted terrorist attack. Although bothacts are criminal, it is the purpose and intent of the release that makes the difference. Releases atfixed facilities should be considered criminal acts until proven otherwise. While it can be difficult todetermine whether a release is accidental or intentional, the HMRT team along with trainedinvestigators should try to determine the root cause. In cases where terrorism is suspected, theappropriate law enforcement officials should be notified.

(8) Explosions also require an investigation, including the root cause. The bomb squad can be used todetermine the cause of an explosion. The HMRT should be used to determine if there are flammablegases or other hazardous materials present.


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I have added the requirement for an assessment of vulnerability. It is rare that an HIRA is conducted from a zero baseline- i.e. there is almost always some capability already existing which can impact the vulnerability of the community/organization to a particular hazard. If a community/organization is already well prepared for a particular event, the threat level is reduced.






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Chapter 6 Community and Organizational Influences6.1 Introduction.6.1.1 Purpose.

The purpose of this chapter is to provide information and guidance for hazardous materials/WMD responseteam program managers in understanding and managing the internal, external, and planning influencesthat can affect HMRTs. HMRT program managers must assess conditions specific to their jurisdiction andremain aware of these influences and how they affect the management and operation of HMRTs.6.1.2 Scope.6.1.3 Internal Influences.Internal influences are intra-organizational (i.e., response agency), local, and/or regional jurisdictionalconditions or circumstances that can influence, control, and/or affect how HMRTs prepare for and respondto hazardous materials and WMD incidents.6.1.3.1 Internal organizational influences are issues, conditions, and or constraints that affect how a jurisdictionprepares for, responds to, and manages a hazardous materials/WMD incident.6.1.3.1.1

Organizational influences can include political, financial, resource allocation, and response capabilityconsiderations.6.1.3.1.2

The level of response capability in a given community can range from a well-trained and equippedhazardous materials response team to no local hazmat response capability at all.6.1.3.1.3

HMRT program managers must assess and adapt to various opportunities, conditions, and constraintsassociated with internal organizational influences.6.1.3.2 The local AHJ can and often does influence how HMRTs respond to and manage hazardousmaterials/WMD incidents.6.1.3.2.1

Decisions on HMRT preparation and response are influenced by community hazard identification,vulnerability analysis, risk assessment, and response capabilities, as well as economic and politicalconsiderations.6.1.3.2.2

HMRT program managers should gain an understanding of local AHJ influences and develop teamcapabilities based on these conditions and constraints.6.1.3.3 Internal economic considerations can include internal funding sources, financial liabilities, local or regionaltax bases that fund the HMRT, organizational budgeting priorities, and financial resource allocationdecisions.6.1.3.3.1

HMRT program managers must constantly be prepared to justify program costs and budget requests.Internal competition for funding is often fierce, and low frequency, high-risk response resources (e.g.,HMRTs) can be forgotten if the HMRT does not have a champion during budget discussions.6.1.3.3.2

Internal budget allocations and priorities often change with each budget cycle. HMRT program managersfrequently find that they must re-justify HMRT needs with each new cycle. Ongoing cost-benefit analysisand performance tracking are important components of program management.6.1.3.4


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Internal political influences can include local and regional business considerations such as industries thatcontribute to the tax base and are of value to the community, labor agreements within response agencies,citizen groups, activists, and environmentalists, as well as inter-jurisdictional mutual aid agreements,political edicts and directives, and local regulatory requirements. (See Chapter 12 for relatedinformation.)6.1.3.4.1

Preparation for and response to hazmat incidents can become highly political. Frequently, industrial plantsand chemical facilities that present the greatest perceived risk to a community are also large employersthat generate significant tax revenues for the same community.6.1.3.4.2

HMRT program managers must develop an awareness of the political sensitivities associated with hazmatfacilities and understand the ramifications of incidents at such facilities. Program managers must avoidbe ing drawn into a battle between environmental or community activists and industry.6.1.3.5 Internal environmental influences can include local and regional land use and zoning, prevailing weatherconditions, and atmospheric and topographical conditions that can affect the preparation for and responseto hazardous materials/WMD incidents.6.1.3.5.1

Planning and zoning regulations can cluster high-risk industrial occupancies and hazmat transportationmodes (e.g., pipelines) near each other. HMRT program managers should ensure that such areas aresubject to pre-incident planning to ensure familiarity with the occupancies and related hazards and risks.6.1.3.5.2

HMRT program managers should develop atmospheric air monitoring capabilities utilizing advancedtechnology and computer software programs to evaluate the effects of environmental conditions duringresponses to hazmat and WMD incidents.6.1.3.6

Cultural influences can include inter- or intra-jurisdictional response priorities, organizational history, andperceived community needs that influence an organization’s preparation and response to hazardousmaterials/WMD incidents. (See Chapter 12 for related information.)6.1.4 External Influences– External influences are inter and or extra-organizational relations, conditions, and/or circumstanceswhich may influence, control or affect how HMRTs prepare for and respond to hazardous materials andweapons of mass destruction (WMD) incidents.6.1.4.1 External economic influences include the overall economic condition of the country, funding streams fromexternal sources (e.g., grant programs, government programs, and donations), and the ability to recovercosts associated with response to hazmat incidents.6.1.4.1.1

HMRT program managers must monitor and take advantage of federally funded training programs. Thereare numerous programs that provide funded training for hazmat response personnel.6.1.4.1.2

HMRTs can benefit from and share in cost recovery from expenditures at hazmat incidents. Programmanagers should become aware of the administrative and financial processes associated with costrecovery and ensure that the HMRT is properly reimbursed as permitted by established cost recoverypractices in their communities.6.1.4.2 External political influences include adjacent jurisdictions or agency mandates; federal, state, and localhazmat laws, regulations, and consensus standards that affect the chemical and related industries;interstate commerce; and the management of HMRTs (See Chapter 4 ) . Laws, regulations, andstandards can include the following:6.1.4.2.1

Hazardous materials laws such as the RCRA of 1976, the Comprehensive Environmental Response,CERCLA of 1980, the SARA of 1986, and the Oil Pollution Act of 1990.


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6.1.4.2.2 Hazardous materials regulations such as Hazardous Waste Operations and Emergency Response (29CFR 1910.120); Community Emergency Planning Regulations (40 CFR 300–400); Hazard CommunicationRegulation (29 CFR 1910.1200); Hazardous Materials Transportation Regulations (49 CFR 100–199); andthe National Contingency Plan (40 CFR 300).6.1.4.2.3

Voluntary consensus standards that affect HMRTs include NFPA 472, Standard for Competence ofResponders to Hazardous Materials/Weapons of Mass Destruction Incidents , NFPA 473, Standard forCompetencies for EMS Personnel Responding to Hazardous Materials/Weapons of Mass DestructionIncidents , and various other industry-specific standards (e.g., American Petroleum Institute).6.1.4.2.4

Laws, regulations, and consensus standards all directly affect the operation of an HMRT. Programmanagers must be familiar with and guided by the requirements set forth in these documents.6.1.4.3

Existing external services, agencies, and organizations can influence the operation of HMRTs and caninclude the following:

(1) Relations with private industry can provide funding, training support, team participation, and expertconsultation resources.

(2) Interaction with LEPCs can provide funding and training support and interaction.

(3) Developing relationships with state and federal agencies, including state emergency managementagencies, the FBI HMRT, the Coast Guard, the EPA, and like agencies with common hazmatresponse and mitigation missions can offer a better work environment between agencies.

(4) Cooperative relationships with external services, agencies, and organizations can have a mutuallybeneficial effect on HMRT operations and should be cultivated and maintained by the programmanager.

6.1.5 HMRT Planning Considerations.Planning and preparedness for hazardous materials and weapons of mass destruction incidents is aprimary component of a hazmat response system. HMRT program managers must be aware of, utilize, andintegrate a number of planning considerations including the following:

(1) Community hazards analysis that identifies the specific hazardous materials and associated riskspresent in a community

(2) Community emergency or contingency planning that outlines a comprehensive and integratedapproach to the defined local hazmat problem

(3) Local and state emergency operations plan(s) that address roles and responsibilities forpreparation, response, and mitigation of hazardous materials and weapons of mass destructionincidents within a locality or region

(4) Local planning and zoning standards and industrial regulations that can dictate where hazardousmaterials are located in a community, the containers or vessels that store hazardous materials, theamount that can be stored at a given site, and the reporting requirements for chemical releases

(5) Jurisdictional charters, directives, interagency agreements, and so forth that support the responseand mitigation considerations of the various plans in place within a community.





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Internal organizational influences are issues, conditions, and or constraints that affect how a jurisdictionprevents/mitigates, prepares for, responds to, and manages a hazardous materials/WMD incident.


As written, the statement does not include one of the pillars of emergency management- prevention/mitigation.






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6.1.3.3.1 HMRT program managers must constantly should be prepared to justify program costs and budgetrequests. Internal competition for funding is often fierce, and low frequency, high-risk response resources(e.g., HMRTs) can be forgotten if the HMRT does not have a champion during budget discussions.


Must is too strong of a word.

"Constantly" implies this level of justification occurs daily.






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– External influences are inter and or extra-organizational relations, conditions, and/or circumstances whichmay influence, control or affect how HMRTs prepare for and respond to hazardous materials and weaponsof mass destruction (WMD) incidents.


removing the dash corrects a formatting error






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6.1.4.1.1 HMRT program managers must monitor and should take advantage of federally funded training programs,if eligible . There are numerous programs that provide funded training for hazmat response personnel.


Must implies it is required.

Federal agencies such as FBI, EPA, US Coast Guard are not eligible to attend courses funded by DHS grant funds offered by the NDPC. If they attend they must do so at their agencies expense.






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Chapter 7 Training7.1 Introduction.7.1.1 Purpose.

The purpose of this chapter is to provide information and guidance for hazardous materials/WMD responseteam program managers in understanding the importance of initial and ongoing training to develop thepersonal competence of HMRT response personnel as required by established regulations and therecommendations set forth in NFPA standards.7.1.2 Scope.The development of a comprehensive training program is an essential component of a hazardous materialsprogram. The training program should serve as a source of initial and ongoing team training but should alsoaccommodate the evaluation of personnel competence as required by both OSHA regulations and NFPAstandards. The training program should produce products that provide accurate, timely, and engagingtraining that are both challenging and worthwhile for the members of the hazmat team.7.1.2.1

Failure to provide sufficient training for hazmat team personnel can have disastrous consequences,including mission failure, violation of OSHA regulations, and injury or death to team members or the public.The training program must not be viewed as a burden or afterthought, nor should an assignment to thetraining program be viewed as a reprimand. In contrast, progressive hazmat team leaders place their bestand brightest team members in the training program in order to ensure quality of instruction and improveteam efficiency.7.1.2.2

The goal of any hazmat training program should be to encourage the transfer of knowledge to the teammembers, modify the behavior of the team to ensure their health and safety, and prepare the team tomanage incidents in an efficient manner. Field work should reflect the outcomes that are described,discussed, and demonstrated during a training event. A professionally prepared training program will delivermeasurable performance outcomes as they relate to the tasks required during operational missions.7.2 Training Delivery Methodologies and Models.7.2.1 Competency Based Training.OSHA federal regulations and NFPA both reference the term competency throughout their respectivedocuments. Hazmat team leaders must embrace the intent of the term as is relates to the evaluation ofhazmat team personnel. OSHA 29CFR 1910.120 states under each of the response levels in Paragraph (q)(6) that the responder must demonstrate competency in each of the skill areas referenced. NFPA 472defines competence as “Possessing knowledge, skills, and judgment needed to perform indicatedobjectives.”


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7.2.1.1 Hazmat team leaders should choose a methodology to measure the competency of their team. Attendanceat classroom training sessions, watching videos, or the donning of chemical protective clothing do notbecome measures of competency until the learner’s knowledge, skill, or judgment is evaluated anddocumented. The evaluation of learning can be accomplished by various methods. A following popularmethod for evaluating learning has been published by Dr. Donald Kirkpatrick:

(1) Level 1 Evaluation — This evaluation level measures the reaction of the learner to the trainingdelivered. This reaction is typically measured by the completion of an evaluation form by the learner.These forms provide the training program manager with a snapshot of the training’s effectivenessfrom the perspective of the learner and should include questions on the content, delivery, andrelevance of the training material. Evaluation sheets on their own do not prove competence but theydo assist with validation of the training delivery.

(2) Level 2 Evaluation — This evaluation level measures the learning of the learner. The learning istypically measured by a metric based, quantifiable evaluation tool such as written tests, skills testing,or observation of performance. There are many techniques available to enhance the measurement oflearning, such as pre-testing prior to the training delivery and then measuring the improvement inknowledge with post-test evaluations.

(3) Level 3 Evaluation — This evaluation level measures the changes in behavior from the learner. Theevaluation of behavior change is typically performed over time to ensure that the knowledge, skills,and judgment of the learner is retained and used as a matter of routine. The evaluation of behaviorchange can be accomplished through techniques such as retesting the learner after a period of timeor direct observation of the learner’s performance.

7.2.1.2 It should be noted that Kirkpatrick’s evaluation model includes a fourth level evaluation based upon ameasurement of the ratio of the cost of the training project in comparison to the return of investment to theorganization. While a valid business model and a financial consideration for hazmat team leaders, themeasurement of return of investment does not impact the measurement of competency for hazmat teampersonnel and will not be discussed further.7.3 Selection and Competence of Instructors.Hazmat team leaders should carefully select the instructors who will deliver training to the members of thehazardous materials program. OSHA gives general guidance for the competence of instructors in 29 CFR1910.120 (q) (8), stating that instructors delivering instruction on hazmat topics should have the following:

(1) Satisfactorily completed a course in the delivery of training (educational methodology), or

(2) Have the training and/or academic credentials and instructional experience necessary todemonstrate competent instructional skills, and

(3) Have a good command of the subject matter to be delivered

7.3.1 The completion of an educational methodology course, although optional under OSHA, is an importantbenchmark in the overall validation of a training program. Completion of an educational methodology coursewill allow training program personnel to develop programs of instruction that follow a methodical validatedprocess that is more likely to withstand scrutiny if the quality of the team’s instructional program is evercalled into question.7.3.2

Hazmat team members who are chosen to be hazmat instructors should thoroughly prepare for the trainingprograms they will deliver. As OSHA recommends, instructors should have a good command of the subjectmatter and should be able to deliver the material with confidence. Hazmat team members should beencouraged to deliver team training. Course preparation transfers a great deal of knowledge to the instructoras well.


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7.3.3 Hazmat team training should be lively and engaging. One of the pioneers of adult learning, MalcolmKnowles, theorized that adults only learn when the following certain criteria are met:

(1) Adult learners want to make decisions regarding their learning ( self-direction ).

(2) Adult learners’ life experiences provide a foundation for their learning.

(3) Adult learners must be ready to learn ( desire to learn).

(4) Adult learners want to learn things they can apply to their life ( application of learning).

(5) Adult learners are more internally, rather than externally, motivated to learn.

(6) Adult learners must understand the reason they are learning ( need to know).

7.3.4 Instructors should facilitate learning based on the above principles rather than simply lecturing to theirlearner. The key to a successful transfer of knowledge is achieved by providing an environment thatencourages the participants to learn.7.4 Training Program Development.The development of training programs should be based upon an analysis of the needs of the organization.Hazmat team leaders should ensure that training programs meet both the regulatory requirements andoperational needs of the team. A decision must be made whether to use external, internal, electronic, or acombination of these programs for the delivery of training.7.4.1 External Training Programs.External training programs are programs that are developed and typically delivered by agencies orindividuals from outside of the AHJ.7.4.1.1 External Training Program Advantages.

External training programs offer several advantages for hazmat teams. The curriculum developmentprocess is typically borne by the external provider, and external instructors can provide a fresh insight andperspective to course topics. External instruction is often preferred when introducing new equipment orprocedures. External training programs where the team members physically travel at a remote location addsadditional advantages. The remote location can include training equipment not available in the homejurisdiction. A physical separation from the normal workplace also reduces distractions associated withnormal work activities such as administrative tasks and on-call duties.7.4.1.2 External Training Program Disadvantages.

External training has several disadvantages that must be considered. Costs incurred by bringing in outsideinstructors, outside course development, locating training with sufficient expertise, personnel travel, coursefees, and backfilling personnel to replace trainees all have to be factored in. The costs and reliance onexternal training are significant, and hazmat team leaders should consider internal training programs as analternative.7.4.2 Internal Training Programs.Internal training programs are programs that are developed and delivered by individuals within the AHJ or“packaged” instructional curricula that can be delivered by individuals within the AHJ.7.4.2.1 Internal Training Program Advantages.

Internal training programs offer several advantages including efficient use of training funds, training productsthat are uniquely tailored for the AHJ, administrative control over course content, convenient access to thetraining program by team members, and repeatability of course deliveries for multiple shifts of personnel.


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7.4.2.2 Internal Training Program Disadvantages.The primary disadvantages of internal training programs revolve around quality. The quality of thecurriculum development, course materials, training equipment, facilities, instructors, and evaluation oflearning are the responsibility of the hazmat team leader and must be closely monitored. Leaders mustrealize that the delivery of training in the classroom is only a small component of the curriculum process.The analysis, design, development, and evaluation of training will require a great deal of time and effortcompared to the actual delivery of the training itself. Other disadvantages of internal training includecomplacency, apathy, and internalization when the same instructor is used over and over. Encouraging teammembers to take over training duties can enhance instruction and increase the knowledge of the guestinstructor as they prepare to deliver the course.7.4.3 Electronic Learning Programs.E-learning (electronic learning) can provide a low cost alternative for external training deliveries. Whenproperly designed, these programs can evaluate competency and the transfer of learning. E-learning canprovide either individual or group instruction on topics that would otherwise be difficult to provide. Deliverytimes are often more convenient for the learner. E-learning deliveries include computer-based training,web-based training, and simulation training. It is recommended that E-learning techniques be followed bypractical application exercises to reinforce the transfer of knowledge to the learner.7.4.3.1 Computer-Based Training (CBT).

CBT is an E-learning method that is comprised of a software program loaded onto a standalone computer orlocal area net (LAN) and runs independent of the internet. These software programs are either purchased orobtained at little or no cost and can be taken by team members at their convenience. The AHJ must providea computer station and allow sufficient time for the learner to complete the training. It is recommended thatthe CBT program be reviewed in advance by the training officer to ensure the content meets several factors,including technical accuracy, applicability to the AHJ’s mission, and an evaluation of competency followingthe training.7.4.3.2 Web-Based Training (WBT).WBT is an E-learning method that is comprised of a program accessed through a remote internet server.The entire content of the program can reside on a third-party system with access by the AHJ through aninternet site. These programs are either purchased or obtained at little or no cost and can be taken by teammembers at their convenience. The AHJ must provide a computer station in order to complete the WBT,and that station must have an internet connection with sufficient speed to participate in the training withoutdelays. The AHJ must allow sufficient time for learner to complete the training.7.4.3.2.1

It is recommended that the WBT program be reviewed in advance by the training officer to ensure thecontent meets several factors, including technical accuracy, applicability to the AHJ’s mission, and anevaluation of competency following the training.7.4.3.3 Simulation Training.Simulation training is an E-learning method that is comprised of a program that is either loaded on astandalone computer, or LAN, or is accessed through the internet. Simulation training is unique in that thesimulation program places the learner in situations where operational decisions dictate the outcome ofscripted scenarios. Satisfactory responses are generally rewarded with favorable scenario outcomes, andunsatisfactory responses are generally rewarded with deterioration of the scenario. The AHJ must provide acomputer station to participate in the training and if the course is web-based that computer must have aninternet connection with sufficient speed to take the training without delays. The AHJ must allow sufficienttime for learners to complete the training.7.4.3.3.1

It is recommended that the simulation program be reviewed in advance by the training officer to ensure thecontent meets several factors, including technical accuracy, applicability to the AHJ’s mission, and anevaluation of competency following the training.7.5 Curriculum Development.Proper development of training curricula is the cornerstone of a successful training program. Putting aPowerPoint presentation together and showing it to the team can satisfy the training requirement; however,there can be little expectation of the quality and retention of that training. The field of adult education orandragogy focuses on the concept that all training developed for adults should emphasize the transfer ofknowledge to the learner and that adult education is a professional process.


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7.5.1 The development of training curricula should follow a consistent process that will meet the instructionalneeds of the AHJ and withstand scrutiny for the validity of the training for regulatory and accreditationpurposes. Often, a group of training specialists can work together as a curriculum development team toimprove the process. There are numerous instructional design models available, and no one method isnecessarily better than the other. A common example widely used in adult learning is the ADDIE model. TheADDIE acronym stands for analysis, design, development, implementation, and evaluation.7.5.2

The ADDIE model has been adopted and further enhanced by the Federal Emergency ManagementAgency’s Responder Training Development Center by adding a planning phase, turning ADDIE intoPADDIE. The use of the curriculum development tool on the Responder Training Development Center’swebsite will assist course developers through the instructional design process and ensure that the coursedevelopment is in line with DHS standards.7.5.3 Planning.

The planning phase looks at the project from a strategic level, assessing the AHJ needs, the training scope,developmental resource needs, and program scheduling and budgets. Team leaders must weigh thebenefits of internal course development against available financial, staffing, and logistical resources.7.5.4 Analysis.

Every training project should contain an analysis of factors that will impact course development. Analysisshould concentrate on identifying existing gaps in the hazmat team’s capabilities, the current relevant andavailable instruction, and the knowledge, skills, and abilities of the learner who will be attending the training.Examples of the analysis process should include tools such as the following:

(1) Audience analysis: An analysis of which personnel within the organization should attend the trainingand any challenges that exist getting those personnel to the training event

(2) Job task analysis (sometimes referred to as a work analysis): An analysis of the learner’s job tasksand how the training delivered will apply to the learner’s job

(3) Learner analysis (sometimes referred to as a learner gap analysis): An analysis of the learner’scurrent knowledge, skills, and abilities as they relate to the subject to be delivered

7.5.5 Performance of an analysis can be accomplished using a variety of tools, including surveys, interviews,group sessions, and other similar techniques. It is often beneficial to include agency stakeholders(supervisors, administrators, external peers, etc.) when performing audience and job task analysis. Whenperforming the learner analysis, the curriculum designer should ensure that a statistically significant numberof potential learners is included in the discussion.


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7.5.6 Design.Once the analysis tools have been completed the design of the training product can begin. During thedesign phase decisions are made regarding the components of the training and the best methods fordelivery in order to bridge the gaps discovered during the analysis phase. Often, the design phase iscaptured in a design document. Design document elements include items such as the following:

(1) The goal of the training

(2) The objectives or desired accomplishments of the training

(3) The performance targets of the training

(4) Results of all analysis tools

(5) Statutory and regulatory requirements

(6) Training course prerequisites

(7) A list of deliverable course materials (visuals, handouts, evaluation tools)

(8) Instructional strategies and models (classroom, practical sessions, group sessions, etc.)

(9) Evaluation strategies

(10) Plan for implementation of the training

7.5.7 The design phase is complete when the curriculum development team has a grasp on how the trainingproduct will look, who will attend, what is needed to deliver the training, how it will be delivered, and how thetransfer of knowledge to the learner will be measured.7.5.8 Development.

Once the design phase has been completed, the development of the training product can begin. During thedevelopment phase course materials are researched and written, visual aids are created, practical skillsessions are developed, training aids and props are built, evaluation tools are written and validated, studentand instructor handbooks are designed, and any courses destined for computer or web-based delivery areloaded into an electronic format.7.5.9

A plan of instruction or lesson plan should be developed that will act as the playbook for the delivery of thecourse, to include the goal and objectives for the course, course material requirements, and guidance forthe instructor to maintain flow. The lesson plan should be written so that any instructor knowledgeable in thetopic can pick it up and deliver the course. As the development phase proceeds, the curriculumdevelopment team should continually refer back to the design document to ensure that the vision phasetransitions from the development phase.7.5.10 Implementation.

Once the course materials have been developed, the implementation phase begins. The curriculumdevelopment team can decide to deliver an initial course offering called a pilot before a select audience forthe purpose of evaluating the course. Delivering a pilot course is a good opportunity to proofread the coursematerial, look at visual aids, conduct practical sessions, develop evaluation tools, and check the overall flowof the material.7.5.11

The delivery of the training course should be coordinated so that all team members are allowed to attendand participate in all classroom and practical sessions. The instructional team must ensure that all tools andmaterials identified during the design and development phases are available for implementation. The learnershould be given course materials such as student manuals and reference sheets to assist them in reviewingthe material after delivery. The instructors should continually assess the ratio of learners to instructors tomaintain control of the learning environment.


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7.5.12 Evaluation.Once the training program has been implemented the evaluation phase can begin. As discussed earlier,leaders of the hazmat team should determine the appropriate methodology to measure competency. Duringthe design phase the curriculum development team should have identified the level of evaluation needed toassess the transfer of knowledge to the learner.7.6 Training Delivery Models.

During the design phase the curriculum development team must determine the best model of delivery for thelearner. Although each type of training delivery has its own unique advantages, successful training programsoften use a blended format comprised of several different models to offer a variety to the learner. The mostcommon types of training delivery models are as follows:

(1) Instructor-led classroom lecture: This model is suited for large group delivery of technical material.However, it is not very useful for evaluating competency.

(2) Instructor-facilitated discussion: This model is suited for large group delivery of material when thereis a desire for immediate feedback from the learner. However, it is not very efficient for evaluatingcompetency.

(3) Instructor-led demonstration: This model is suited for large group demonstrations of visual conceptssuch as chemical and physical property demonstrations. However, it is not very useful for evaluatingcompetency.

(4) Self-paced learning: This model is suited for research type work by the learner. Using theEmergency Response Guidebook and NIOSH Pocket Guide to Chemical Hazards are examples ofthis method. This model can be used for competency skills evaluation.

(5) Small group lecture: This model is suited for delivery of technical information where a more intimateinstructor-learner ratio is desired. However, it is not very efficient for evaluating competency.

(6) Small group demonstration: This model is suited for demonstration of equipment that requires closeproximity of the learner to the instructor. This model can be used for evaluation if properly planned bythe instructor team.

(7) Practical skill sessions: This model is suited for hands-on experience by the learner and can be usedfor evaluation if properly planned by the instructor team.

(8) E-learning (web-based or computer-based): This model is suited for individual delivery of writtenmaterial and can be used for evaluation of written competency.

(9) Simulation: This model is suited for either individual or group training and involves the use ofelectronic aids to present the learner with unique problem solving and critical thinking exercises.

(10) Scenario-based practical sessions: This model is suited for maximum transfer of learning to thelearner and can be used for evaluating competency.

(11) Table-top exercises: This model is suited for transfer of learning on administrative tasks such as theincident command system or strategic management training and can be used for evaluation ofcompetency if properly planned by the instructor team.

(12) Full-scale exercises: This model is suited for maximum transfer of learning and can be used forevaluating competency. Real-time, unannounced exercises are beneficial for maximum evaluation.

(13) One-on-one evaluation: This model is best suited for evaluating individual skill competencies.

7.7 Physical Training Facilities.Well-designed training facilities can dramatically enhance the transfer of knowledge to the learner.Conversely, poorly designed training facilities can dramatically detract from the transfer of knowledge.Hazmat team leaders should work within their AHJ’s budget to develop training facilities that provide plentyof space to learn the tradecraft.


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7.7.1 Classrooms:Classrooms should be designed with the needs of the learner in mind. The following is a list of desirablefeatures in a modern classroom. Hazmat team leaders should consider the following features during newconstruction or refurbishment of training facilities:

(1) The classroom should ideally have a minimum number of windows to maximize the visibility ofpresentations and to minimize distractions for the learner.

(2) The classroom should have a projector capable of projecting a bright image even in ambient lightconditions. Ideally it should be suspended from the ceiling or set up for rear projection.

(3) The classroom lighting should allow for ample lighting at the learner’s desks.

(4) The classroom should have ample desk space for each learner.

(5) The classroom should be sufficient in size to allow for flexibility and multiple seating configurations.

(6) The classroom should have isolated environmental controls for learner comfort.

(7) Each learner should have a clear view of the screen.

(8) The classroom should have an audio system capable of playing sound from video presentations andamplifying the instructor’s voice.

(9) The classroom should have a computer for PowerPoint presentations and/or a connection for laptopcomputers.

(10) The classroom should be capable of playing multi-media presentations.

(11) Consideration should be given to adding an instructor preparation room allowing instructors todiscuss the course away from the learner.

7.7.2 Training Props.Meeting the NFPA 472 hazardous materials competencies requires a demonstration of skills as they relateto many subject areas including personal protective equipment, product control, decontamination, anddetection and monitoring. Hazmat team leaders must ensure that training programs have access tosufficient equipment and training props for team training and evaluation. Training props can be expensiveand in many cases too large for existing training facilities. Hazmat team leaders should considerdevelopment of regional training centers for larger props such as rail tank cars and tank trucks so theexpenses for those props can be shared. Training equipment to be considered for acquisition by trainingprograms can include the following:

(1) Self -contained breathing apparatus and spare cylinders

(2) Air purifying respirators

(3) Powered air purifying respirators

(4) Fully encapsulating chemical garments

(5) Encapsulating chemical splash garments

(6) Chemical splash garments

(7) Chemical resistant boots

(8) Chemical resistant gloves

(9) Multiple gas chemical monitors

(10) Single gas chemical monitors

(11) Alpha, beta, gamma, neutron radiation detectors

(12) Reagent papers

(13) Advanced detection equipment per the AHJ

(14) Product control kits per the AHJ


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7.7.2.1 Training props might include the following:

(1) Chlorine, 100 lb and 150 lb cylinders

(2) Chlorine, ton container ends

(3) Chlorine, DOT-105 tank car dome

(4) Propane tank burn prop

(5) MC306/DOT406 highway cargo tank truck

(6) MC307/DOT407 chemical cargo tank truck

(7) MC312/DOT 412 corrosive tank truck

(8) MC331 pressure highway cargo tank truck

(9) MC338 cryogenic tank truck

(10) DOT111 (low pressure) railroad tank car

(11) DOT105 or DOT112 (high pressure) railroad tank car

(12) Drum leak simulators

(13) Pipe leak “trees”

7.7.2.2 Electronic simulation devices might include the following:

(1) Air monitoring and detection simulators

(2) Incident command simulators

(3) Virtual reality simulators

7.8 Levels of Hazardous Materials Training.A critical component of hazmat team management is determining the level of training needed for your team.That decision should be based on an assessment of the expected tasks to be performed by the team, thetime available for initial and recertification training, and the financial commitment from the AHJ.7.8.1

There are three distinct sources for determining the desired hazmat training level, the Occupational Safety &Health Administration (OSHA), the Environmental Protection Agency (EPA), and the National Fire ProtectionAssociation (NFPA). OSHA 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response , isa regulation that is enforceable by OSHA investigators. Violations of the regulation can result in fines leviedagainst the AHJ and/or individuals within the AHJ. EPA 40 CFR 311, Worker Protection , is essentially amirror of OSHA 29 CFR 1910.120 and applies to all employees within states that do not have a state-specific OSHA plan. 40 CFR 311.2 specifically defines an employee as either a compensated ornon-compensated worker controlled by a state or local government, which includes most volunteer publicsafety agencies. As 40 CFR 311 is essentially the same document as OSHA, all further reference will be to29 CFR 1910.120 and inferred to include 40 CFR 311.7.8.2

NFPA 472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass DestructionIncidents , is a voluntary consensus standard defining minimum competencies for personnel who respond tohazmat incidents. There is no enforcement body for NFPA 472. However, the 2008 edition of the standardhas been adopted by the Department of Homeland Security as a minimum requirement for all hazmatresponders.7.8.3

Essentially, OSHA 29 CFR 1910.120 is the law and NFPA 472 is a standard for the hazmat emergencyresponse community. Hazmat teams that train to the competencies set forth in NFPA 472 will far exceedOSHA 29 CFR 1910.120.


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7.8.4 Hazmat Responder Training Levels per OSHA 1910.120.OSHA 29 CFR 1910.120 defines the levels of training for hazmat emergency responders in paragraph(q)(6). Promulgated in 1990, the regulation recognizes five levels of training: first responder awarenesslevel, first responder operations level, hazardous materials technician, hazardous materials specialist, andon-scene incident commander.7.8.5 Key points with the OSHA levels of training include the following:

(1) The language is very clear. If you are part of the response then you must train your personnel to firstresponder operations level as a minimum.

(2) If the mission of the team is to take offensive actions to perform product control you must train yourpersonnel to hazardous materials technician as a minimum.

(3) OSHA requires that all responders be trained prior to responding to an incident and requires that theAHJ certify that the responder has shown competency in each area.

7.8.5.1 First Responder Awareness Level (OSHA 29 CFR 1910.120 (q)(6)).First responders at the awareness level are individuals who are likely to witness or discover a hazardoussubstance release and who have been trained to initiate an emergency response sequence by notifying theproper authorities of the release. They would take no further action beyond notifying the authorities of therelease. First responders at the awareness level shall have sufficient training or have had sufficientexperience to objectively demonstrate competency in the following areas:

(1) An understanding of what hazardous substances are and the risks associated with them in anincident.

(2) An understanding of the potential outcomes associated with an emergency created when hazardoussubstances are present.

(3) The ability to recognize the presence of hazardous substances in an emergency.

(4) The ability to identify the hazardous substances, if possible.

(5) An understanding of the role of the first responder awareness individual in the employer's emergencyresponse plan, including site security and control and the U.S. Department of Transportation'sEmergency Response Guidebook .

(6) The ability to realize the need for additional resources and to make appropriate notifications to thecommunication center.


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7.8.5.2 First Responder Operations Level (OSHA 29 CFR1910.120 (q)(6)).First responders at the operations level are individuals who respond to releases or potential releases ofhazardous substances as part of the initial response to the site for the purpose of protecting nearbypersons, property, or the environment from the effects of the release. They are trained to respond in adefensive fashion without actually trying to stop the release. Their function is to contain the release from asafe distance, keep it from spreading, and prevent exposures. First responders at the operational level shallhave received at least 8 hours of training or have had sufficient experience to objectively demonstratecompetency in the following areas in addition to those listed for the awareness level and the employershould so certify:

(1) Knowledge of the basic hazard and risk assessment techniques

(2) Knowledge of how to select and use proper personal protective equipment provided to the firstresponder operational level

(3) An understanding of basic hazardous materials terms

(4) Knowledge of how to perform basic control, containment, and/or confinement operations within thecapabilities of the resources and personal protective equipment available with their unit

(5) Knowledge of how to implement basic decontamination procedures

(6) An understanding of the relevant standard operating procedures and termination procedures

7.8.5.3 Hazardous Materials Technician (OSHA 29 CFR 1910.120 (q)(6).Hazardous materials technicians are individuals who respond to releases or potential releases for thepurpose of stopping the release. They assume a more aggressive role than a first responder at theoperations level in that they will approach the point of release in order to plug, patch, or otherwise stop therelease of a hazardous substance. Hazardous materials technicians shall have received at least 24 hours oftraining equal to the first responder operations level and in addition have competency in the following areasand the employer should so certify:

(1) Knowledge of how to implement the employer's emergency response plan

(2) Knowledge of the classification, identification, and verification of known and unknown materials byusing field survey instruments and equipment

(3) The ability to function within an assigned role in the incident command system

(4) Knowledge of how to select and use proper specialized chemical personal protective equipmentprovided to the hazardous materials technician

(5) An understanding of hazard and risk assessment techniques

(6) The ability to perform advance control, containment, and/or confinement operations within thecapabilities of the resources and personal protective equipment available with the unit

(7) An understanding of and ability to implement decontamination procedures

(8) An understanding of termination procedures

(9) An understanding of basic chemical and toxicological terminology and behavior


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7.8.5.4 Hazardous Materials Specialist (OSHA 29 CFR 1910.120 (q)(6).Hazardous materials specialists are individuals who respond with and provide support to hazardousmaterials technicians. Their duties parallel those of the hazardous materials technician; however, thoseduties require a more directed or specific knowledge of the various substances they can be called upon tocontain. The hazardous materials specialist would also act as the site liaison with federal, state, local andother government authorities in regards to site activities. Hazardous materials specialists shall havereceived at least 24 hours of training equal to the technician level and in addition have competency in thefollowing areas and the employer should so certify:

(1) Knowledge of how to implement the local emergency response plan

(2) An understanding of classification, identification, and verification of known and unknown materials byusing advanced survey instruments and equipment

(3) Knowledge of the state emergency response plan

(4) The ability to select and use proper specialized chemical personal protective equipment provided tothe hazardous materials specialist

(5) An understanding of in-depth hazard and risk techniques

(6) The ability to perform specialized control, containment, and/or confinement operations within thecapabilities of the resources and personal protective equipment available

(7) The ability to determine and implement decontamination procedures

(8) The ability to develop a site safety and control plan

(9) An understanding of chemical, radiological, and toxicological terminology and behavior

7.8.5.5 On-Scene Incident Commander (OSHA 29 CFR 1910.120 (q)(6).Incident commanders, who will assume control of the incident scene beyond the first responder awarenesslevel, shall receive at least 24 hours of training equal to the first responder operations level and in additionhave competency in the following areas and the employer should so certify:

(1) Knowledge of and the ability to implement the employer's incident command system


(3) Knowledge of and an understanding of the hazards and risks associated with employees working inchemical protective clothing

(4) Knowledge of how to implement the local emergency response plan

(5) Knowledge of the state emergency response plan and of the Federal Regional Response Team

(6) Knowledge of and an understanding of the importance of decontamination procedures.

7.8.6 Hazmat Responder Training Levels per NFPA 472.NFPA 472 defines the levels of training for emergency responders in essentially two categories: operationslevel responders and hazardous materials technicians. NFPA does not recognize the awareness leveltraining for responders. However, it does define an awareness level of training for non-response personnel.There are several specialty areas for hazardous materials technicians, including hazardous materialsofficer, hazardous materials safety officer, tank cars, cargo tanks, intermodal tanks, and marine tank andnon-tank vessels. NFPA 472 does not recognize a hazardous materials specialist level of training likeOSHA 29 CFR 1910.120. Additionally, NFPA 472 further divides the operations level responder traininglevel into core competencies that all responders must achieve and mission-specific competencies forunique skill competency requirements. It is important to note that the mission-specific competencies are notdesigned to be a “checkbox” requirement; rather, the operations level responder only needs to showcompetency for the mission-specific competencies chosen by the AHJ for their expected job tasks.


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7.8.6.1 Awareness Level Personnel (NFPA 472).Awareness level personnel are personnel who, in the course of their normal duties, could encounter anemergency involving hazardous materials/WMD and who are expected to recognize the presence of thehazardous materials/WMD, protect themselves, call for trained personnel, and secure the scene.7.8.6.2 Operations Level Responders (NFPA 472).

Operations level responders are persons who respond to hazardous materials/WMD incidents for thepurpose of implementing or supporting actions to protect nearby persons, the environment, or property fromthe effects of the release.7.8.6.3 Operations Level Mission-Specific Competencies (NFPA 472).

Operations level mission-specific competencies are the knowledge, skills, and judgment needed byoperations level responders who have completed the operations level competencies and who aredesignated by the authority having jurisdiction to perform mission specific tasks, such as decontamination,victim/hostage rescue and recovery, evidence preservation, and sampling.7.8.6.4 Hazardous Materials Technician (NFPA 472).

The hazardous materials technician is the person who responds to hazardous materials/WMD incidentsusing a risk-based response process by which they analyze a problem involving hazardous materials/WMD,select applicable decontamination procedures, and control a release using specialized protective clothingand control equipment.7.8.6.5 Hazardous Materials Officer (NFPA 472).

The hazardous materials officer (known by NIMS as the hazardous materials branch director/groupsupervisor) is that person who is responsible for directing and coordinating all operations involvinghazardous materials/WMD as assigned by the incident commander.7.8.6.6 Hazardous Materials Safety Officer (NFPA 472).

The hazardous materials safety officer (known by NIMS as the assistant safety officer — hazardousmaterial) is that person who works within an incident management system (IMS) (specifically, the hazardousmaterial branch/group) to ensure that recognized hazardous materials/WMD safe practices are followed athazardous materials/WMD incidents.7.8.7 Establishing Your Hazmat Team Training Level.One of the most critical decisions a hazmat team leader can make is to determine the level of trainingneeded for their team. An objective assessment must be made based on the mission, staffing levels,financial support, and training availability of team members. Team leaders must realize the tremendouscommitment necessary to train and maintain competency for a fully capable technician level team.7.8.7.1

Table 7.8.7.1 is a decision matrix designed to assist team leaders in the determination of training levels. It isbased upon the expected job tasks for team personnel. This is only a guide. Team leaders must assess theirown unique situation to determine levels of training.

Table 7.8.7.1 Decision Matrix for Haz Mat Training LevelsMission Expectation Level of Training Administrative worker, could encounter hazardous materials incidentsin workplace OSHA first responder awareness levelNFPA awareness level personnel Responder, could be sent to hazardous materials incidents, not intended todon PPE OSHA first responder operations levelNFPA operations level responder — core Responder, could be sent to hazardous materials incidents,intended to perform rescue of victims from hazardous environments OSHA first responder operations levelNFPA operations level responder — coreNFPA mission-specific competencies for personal protective equipment and victim recovery Responder, willbe sent to hazardous materials incidents, intended to perform decontamination and/or defensive productcontrol OSHA first responder operations levelNFPA operations level responder — coreNFPA mission-specific competencies (MSC) for PPE and MSC for mass decontamination, technicaldecontamination, and product control, as needed Responder, will be sent to hazardous materials incidents,intended to enter the exclusion zone to assess the situation and assist in determining a plan of action OSHAfirst responder operations levelNFPA operations level responder — core


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NFPA MSC for PPE, evidence preservation and sampling, illicit labs, air monitoring and sampling Emergencymedical technician, will be sent to hazardous materials incidents, intended to receive only decontaminatedpatients OSHA first responder operations levelNFPA operations level — core Emergency medical technician, will be sent to hazardous materials incidents,intended to perform decontamination and/or patient care for contaminated patients OSHA first responderoperations levelNFPA operations level — coreNFPA MSC for PPE, technical and mass decontaminationNFPA 473 for BLS/ALS providers as appropriate Emergency medical technician — advanced provider, will besent to hazardous materials incidents, intended for assignment to the hazardous materials team for overallteam medical care OSHA hazardous materials technicianNFPA operations level — coreNFPA MSC for PPE, technical decontamination, air monitoring and samplingNFPA 473 BLS/ALS provider recommended — NFPA hazardous materials technician Bomb technician, willbe sent to hazardous materials incidents, intended to assess and render-safe suspected explosive devicesand assess explosives laboratories OSHA hazardous materials technician**NFPA operations level responder — coreNFPA MSC for PPE, evidence preservation and sampling, illicit labs, air monitoring and sampling, WMDdispersal device disablement/disruption Law enforcement, will be sent to hazardous materials incidents,intended to conduct activities outside of exclusion zone (i.e., traffic control) OSHA first responder operationslevelNFPA operations level responder — core Law enforcement, will be sent to hazardous materials incidents,intended to assess and collect items of evidence from within the exclusion zone OSHA first responderoperations levelNFPA operations level responder — coreNFPA MSC for PPE, evidence preservation and sampling, illicit labs Law Enforcement Tactical, will be sent tohazardous materials incidents, intended to make tactical law enforcement entry into exclusion zone OSHAfirst responder operations levelNFPA operations level responder — coreNFPA MSC for PPE, illicit labs, air monitoring and sampling Hazardous Materials Technician, will be sent tohazardous materials incidents, intended to make an entry into the exclusion zone to perform offensiveactions for product control OSHA hazardous materials technicianNFPA hazardous materials technician

** Certification as an OSHA hazardous materials technician is a requirement prior to responders attendingthe FBI/DOD Hazardous Devices School.

7.8.7.2 Awareness Level Training.Awareness level training is clearly defined and includes those personnel who could encounter hazardousmaterials. There is no interpretation from OSHA, nor is there guidance within NFPA 472 that statesawareness level training is appropriate for anyone who is expected to physically respond to hazardousmaterials incidents. If your personnel answer a phone or radio and are being sent to a hazardous materialsincident, they need to be trained above the awareness level. Awareness trained personnel can include thefollowing:

(1) Administrative staff

(2) Custodial staff

(3) Maintenance staff

(4) Agency officials (mayor’s office, etc.)

(5) News media


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7.8.7.2.1 Neither OSHA nor NFPA place a time factor on awareness level training. The expectation is that upon thecompletion of training, the learner will have an understanding of the hazards associated with hazardousmaterials and know how to contact the appropriate response agency to deal with the situation. The wordunderstand is vague; therefore, the hazmat team leader should design an evaluation process that metricallycaptures the transfer of knowledge to the learner. The time required for instruction will vary based upon thelearner gap analysis and the number of learners in the class.7.8.7.2.2

As awareness level personnel are not part of the response and do not don personal protective clothing norenter the exclusion zone, there is very little equipment needed for this training. Awareness level trainingequipment can include the following:

(1) Classroom

(2) Data projector

(3) DOT emergency response guidebooks

(4) Pens/pencils

(5) Notebook paper

7.8.7.3 Operations Level Responder Training.Operations level training is clearly defined and includes those personnel who respond to hazardousmaterials incidents. If your personnel answer a phone or radio and are being sent to a hazardous materialsincident, they need to be trained at or above the operations level. Personnel trained to the operations levelare able to perform defensive actions at a hazmat incident. NFPA 472 further states that operations levelpersonnel are those who respond to hazardous materials/WMD incidents for the purpose of protectingnearby persons, the environment, or property from the effects of the release. NFPA 472 divides operationslevel personnel into the following two categories:

(1) Core competencies for operations level responders (Chapter 5 ) applies to all operations levelresponders.

(2) Competencies for operations level responders assigned mission-specific competencies (Chapter6 ) applies to operations level responders who will be wearing PPE, performing decontamination, orperforming other mission-specific tasks at incidents.

7.8.7.3.1 Personnel who should be trained to the operations level responder — core competencies include thefollowing:

(1) Fire fighters assigned to suppression or rescue duties

(2) Industrial brigade personnel assigned to suppression or rescue duties

(3) Law enforcement officers assigned to patrol duties

(4) Emergency medical service personnel

(5) Health department response personnel

(6) Public works department response personnel

(7) Emergency management agency response personnel

(8) Other response personnel


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7.8.7.3.2 OSHA 29 CFR 1910.120 places a minimum time requirement on first responder operations level training.OSHA requires that first responder operations personnel complete at least 8 hours of training or haveenough experience to demonstrate competency in the following areas, in addition to those listed for theawareness level:

(1) Knowledge of the basic hazard and risk assessment techniques

(2) Knowledge of how to select and use proper PPE provided to the first responder operational level

(3) An understanding of basic hazardous materials terms

(4) Knowledge of how to perform basic control, containment, and/or confinement operations within thecapabilities of the resources and PPE available with their unit

(5) Knowledge of how to implement basic decontamination procedures

(6) An understanding of the relevant standard operating procedures and termination procedures

7.8.7.3.3 As with OSHA first responder awareness level, the word understand is vague and the hazmat team leadershould design an evaluation process that metrically captures the transfer of knowledge to the learner. NFPA472 operations level responder — core competencies go into much more detail and specify thecompetencies that are required for all personnel who respond to hazardous materials incidents. Operationslevel training that meets the competencies of NFPA 472, Chapter 5 will by default meet OSHA firstresponder operations level as defined in 1910.120 (q)(6)(ii). To meet the NFPA 472 operations levelresponder — core competencies, an additional amount of training time beyond the 8 hours referenced inOSHA 29 CFR 1910.120 will be required. Operations level responder training equipment can include thefollowing:

(1) Classroom

(2) Data projector

(3) DOT Emergency Response Guidebook

(4) NIOSH Pocket Guide to Chemical Hazards

(5) Other reference materials as required by the AHJ

(6) Pens/pencils

(7) Notebook paper

7.8.7.4 Operations Level Responder Mission-Specific Training.In NFPA 472, the operations level mission-specific training competencies (MSC) are designed to providethe operations level responder who is assigned mission-specific responsibilities the knowledge and skills toperform those assigned responsibilities safely and effectively. Personnel that require MSC training mustachieve all the competencies listed in Chapter 4 (Awareness) and Chapter 5 (Operations — Core) priorto being trained in the MSCs. OSHA does not have an equivalency to the NFPA 472 mission-specificcompetencies; rather, they are covered in the language within 29 CFR 1910.120 (q)(6)(ii) first responderoperations level.7.8.7.4.1 Any personnel expected to perform defensive actions in the hot zone and/or any action in the warm zonemust receive operations level responder — core training and any requisite MSCs. The AHJ will determinethe appropriate MSC based upon the mission of the hazmat responder.7.8.7.4.1.1 Mission-Specific Competencies — Personal Protective Equipment.

The operations level responder assigned to use personal protective equipment should be that person,competent at the operations level, who is assigned to use PPE at hazardous materials/WMD incidents. ThisMSC is required for any responder requiring the competencies found in any of the MSCs, as all MSC levelsrequire the use of PPE.


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7.8.7.4.1.2 Mission-Specific Competencies — Mass Decontamination.The operations level responder assigned to perform mass decontamination at hazardous materials/WMDincidents should be that person, competent at the operations level, who is assigned to implement massdecontamination operations at hazardous materials/WMD incidents. Mass decontamination is defined byNFPA 472 as the physical process of reducing or removing surface contaminants from large numbers ofvictims in potentially life-threatening situations in the fastest time possible.7.8.7.4.1.3 Mission-Specific Competencies — Technical Decontamination.

The operations level responder assigned to perform technical decontamination at hazardousmaterials/WMD incidents should be that person, competent at the operations level, who is assigned toimplement technical decontamination operations at hazardous materials/WMD incidents. Technicaldecontamination can be described as the performance of contamination removal to a level that is as low asreasonably achievable on responders that are wearing personal protective clothing.7.8.7.4.1.4 Mission-Specific Competencies — Evidence Preservation and Sampling.

The operations level responder assigned to perform evidence preservation and public safety samplingshould be that person, competent at the operations level, who is assigned to preserve forensic evidence,take samples, and/or seize evidence at hazardous materials/WMD incidents involving potential violations ofcriminal statutes or governmental regulations. The collection of evidence is performed either by a lawenforcement responder, or under the guidance of law enforcement. Public safety samples can be collectedby any responder with the authority granted by the AHJ to assess incidents for potential threats to publicsafety.7.8.7.4.1.5 Mission-Specific Competencies — Product Control.

The operations level responder assigned to perform product control should be that person, competent at theoperations level, who is assigned to implement product control measures at hazardous materials/WMDincidents. This MSC is designed only to cover defensive actions, such as damming/diking and theapplication of Class B foams. Advanced product control such as application of patching kits falls under theskill requirements of hazardous materials technicians.7.8.7.4.1.6 Mission-Specific Competencies — Air Monitoring and Sampling.

The operations level responder assigned to perform air monitoring and sampling should be that person,competent at the operations level, who is assigned to implement air monitoring and sampling operations athazardous materials/WMD incidents. This MSC is designed to apply to the use of air monitoring anddetection devices that do not require direct contact with hazardous substances.7.8.7.4.1.7 Mission-Specific Competencies — Victim Rescue and Recovery.

The operations level responder assigned to perform victim rescue and recovery should be that person,competent at the operations level, who is assigned to rescue and recover exposed and contaminatedvictims at hazardous materials/WMD incidents. This MSC includes fire service and emergency medicalservice personnel that are assigned to hazmat rescue/extraction duties.7.8.7.4.1.8 Mission-Specific Competencies — Response to Illicit Laboratory Incidents.

The operations level responder assigned to respond to illicit laboratory incidents should be that person,competent at the operations level, who, at hazardous materials/WMD incidents involving potential violationsof criminal statutes specific to the illegal manufacture of methamphetamines, other drugs, or WMD, isassigned to secure the scene, identify the laboratory or process, and preserve evidence at hazardousmaterials/WMD incidents involving potential violations of criminal statutes specific to the illegal manufactureof methamphetamines, other drugs, or WMD.7.8.7.4.1.9 Mission Specific Competencies — Improvised WMD Dispersal Device Disablement/Disruptionand Operations at Improvised Explosive Laboratories.The operations level responder assigned to interrupt the functioning of an improvised WMD dispersal deviceor conduct mitigation procedures on energetic materials shall be that person, competent at the operationslevel who is assigned to perform disablement and/or disruption procedures on an improvised explosivedevice (IED) or WMD dispersal device. This MSC is designed for the responder who is already certified as ahazardous devices technician through the Federal Bureau of Investigation’s Hazardous Devices School orDepartment of Defense.7.8.7.4.2 Mission-Specific Competency Application Matrix.

Table 7.8.7.4.2 is designed to assist the hazmat team leader and training program personnel with theappropriate MSCs for team members. The matrix is a guide; the AHJ must make the determination on MSCsappropriate for the team.


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Table 7.8.7.4.2 Mission-Specific Competency Application MatrixPPE Mass Decon Technical Decon Evidence Preservation and Sampling Product Control Air Monitor andSampling Victim Rescue and Recover Illicit Lab Incidents Bomb Tech Responder expected to performdefensive product control X X X Responder assigned to perform decontamination X X X Responder assignedto perform rapid rescue X X X X X Responder providing staffing or support to hazmat team X X X X X X LEofficer involved in investigation where HM is present (including labs) X X X X X Hazardous devicestech X X X X X X LE tactical team operator X X X Public health investigating public healthemergency X X X Environmental H&S professional providing air monitoring support X X X Private or industrialpersonnel providing product control X X X X Private or industrial personnel providing producttransfer X X X EMS performing decontamination and treatment X X X Advanced EMS provider assigned tohazmat team X X X7.8.7.4.3

The mission-specific competencies set forth in NFPA 472 resemble an “Operations +” concept that isdesigned for operations-level personnel who have a mission to enter the warm or hot zone to performspecific tasks. OSHA 29 CFR 1910.120 regulations place a minimum time requirement on first responderoperations-level training. OSHA requires that first responder operations personnel receive at least 8 hours oftraining or have enough experience to demonstrate competency in the following areas, in addition to thoselisted for the awareness level:

(1) Knowledge of the basic hazard and risk assessment techniques.

(2) Knowledge of how to select and use proper PPE provided to the first responder operational level.

(3) An understanding of basic hazardous materials terms.

(4) Knowledge of how to perform basic control, containment, and/or confinement operations within thecapabilities of the resources and PPE available with their unit.

(5) Knowledge of how to implement basic decontamination procedures.

(6) An understanding of the relevant standard operating procedures and termination procedures.

7.8.7.4.4 As with OSHA awareness, the word understand is vague; therefore, the hazmat team leader should designan evaluation process that metrically captures the transfer of knowledge to the learner. The time requiredfor instruction will vary based upon the learner gap analysis and the number of learners in the class. NFPA472 operations-level responder mission-specific competency training will require an additional training timebeyond the 8 hours referenced in OSHA 29 CFR1910.120.


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7.8.7.4.4.1 Operations-level mission-specific competency training equipment can include the following:

(1) Classroom

(2) Data projector

(3) DOT Emergency Response Guidebooks



(6) Pens/pencils

(7) Notebook paper







(14) Chemical-resistant boots

(15) Chemical-resistant gloves




(19) Reagent papers



7.8.7.4.4.2 Electronic simulation devices can include the following:


(2) Incident simulators


7.8.7.5 Technician Level Responder Training.


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Any personnel expected to perform offensive actions at a hazardous materials incident will requirehazardous materials technician level training. Such persons can include the following:

(1) Members of a hazardous materials team tasked to perform product control [per OSHA 1910.120(q)(6)(iii) and NFPA 472 Chapter 7]

(2) Responders who perform advanced risk assessment and presumptive identification on hazardousmaterials within hazardous environments [per OSHA 1910.120 (q)(6)(iii)]

(3) Members of a bomb squad tasked to perform render-safe actions that can affect container integrityor change the stability of hazardous materials [per OSHA 1910.120 (q)(6)(iii)]

(4) Members of railroad, trucking, or other related industries performing product control at emergencyincidents [per OSHA 1910.120 (q)(6)(iii) and NFPA 472 Chapter 7]

(5) Members of railroad, trucking, or other related industries performing product transfer at emergencyincidents [per OSHA 1910.120 (q)(6)(iii)]

(6) Members of a fire brigade tasked to perform product control [per OSHA 1910.120 (q)(6)(iii) andNFPA 472 Chapter 7]

7.8.7.5.1 OSHA 29 CFR 1910.120 places a minimum time requirement on technician level training by requiring OSHAhazmat technicians to complete at least 24 hours at a level equal to OSHA first responder operations leveland have competency in the following areas:




(4) Knowledge of how to select and use proper specialized chemical PPE provided to the hazardousmaterials technician


(6) The ability to perform advance control, containment, and/or confinement operations within thecapabilities of the resources and PPE available with the unit

(7) An understanding and implementation of decontamination procedures



7.8.7.5.2 Additionally, OSHA 29 CFR 1910.120, Appendix E, states the hazardous materials technician should haveawareness and knowledge of the competencies for the hazardous materials technician covered in NFPA472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass DestructionIncidents . In order to meet all of the competencies required by OSHA 29 CFR 1910.120 and all of thecompetencies set forth in NFPA 472 for hazardous materials technician, considerably more than 24 hours oftraining will be needed, especially since NFPA 472 requires the hazardous materials technician to also betrained to all of the competencies in Chapters 4 (awareness), 5 (operations), and 7 (technician). The lengthof a hazardous materials technician training course is not defined by NFPA. NFPA simply states that thetraining needs to be sufficient in length for the learner to show competence.


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7.8.7.5.2.1 Technician level courses are heavily dependent on training props and equipment. The AHJ must consider allavailable regional resources when preparing for a technician level course. Technician training equipmentcan include the following:

(1) Classroom

(2) Data projector

(3) DOT emergency response guidebooks



(6) Pens/pencils

(7) Notebook paper

(8) Self-contained breathing apparatus and spare cylinders











(19) Reagent papers

(20) Advanced detection equipment in accordance with the AHJ

(21) Product control kits in accordance with the AHJ


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7.8.7.5.2.2 Training props can include the following:

(1) Chlorine 100 lb and 150 lb cylinders

(2) Chlorine ton container ends

(3) Chlorine DOT-105 dome


(5) MC306/DOT406 highway cargo tanker

(6) MC307/DOT407 chemical cargo tanker

(7) MC112 acid tanker

(8) MC331 pressure highway tanker

(9) MC338 cryogenic tanker

(10) DOT111 (low pressure) rail tank car

(11) DOT105 or DOT112 (high pressure) rail tank car

(12) Leak drums


7.8.7.5.2.3 Electronic simulation devices can include the following:


(2) Incident simulators


7.9 HEADING.NFPA 472 defines several specialty positions that are options for personnel assigned to hazardousmaterials teams. Each of these positions carries an additional mandate for training and the demonstrationof competency. The AHJ must assess the need within the organization for these specialty positions, andidentify the best method for demonstrations of competency.7.9.1 Incident Commanders.NFPA 472 Chapter 8 defines the position of incident commander as the person responsible for all incidentactivities, including the development of strategies and tactics and the ordering and release of resources asdesignated by the AHJ. OSHA states that incident commanders must have 24 hours of training equal to thefirst responder operations level and have additional competency in the areas of incident command systems,emergency response plans, hazards and risks of working in chemical protective clothing, and knowledge ofdecontamination procedures.7.9.1.1

NFPA 472 goes on in Chapter 8 to state that incident commanders should be competent in the core areasof operations level responder and be able to analyze, plan, implement, evaluate, and terminate responses tohazmat incidents.7.9.1.2

Incident commanders should consider receiving incident command system (ICS) training to the level ofICS-300, intermediate ICS for expanding incidents. ICS-300 covers the advanced use of unified command,as well as the use of incident action plans for incidents covering more than one operational period, as islikely during major hazmat incidents.7.9.2 Specialist Employees.


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NFPA Chapter 9 defines the role of specialist employees, typically those personnel who have subjectmatter expertise within an organization. NFPA 472 defines three levels of specialist employee. In manycases, demonstration of competency for these personnel might be simply documentation of their expertisein their specific area of specialty.7.9.2.1 Specialist Employee A.7.9.2.1.1

Defined as the person who is specifically trained to handle incidents involving chemicals or containers forchemicals used in the organization's area of specialization and who is able to analyze an incident involvingchemicals within his or her organization's area of specialization. The specialist employee A can then plan aresponse to that incident, implement the planned response within the capabilities of the resources available,and evaluate the progress of the planned response.7.9.2.1.2

There is a requirement in NFPA 472 for specialist employee A personnel to meet the requirements underawareness (Chapter 4), specialty employee (Chapter 9), and relevant areas of hazardous materialstechnician (Chapter 7) as they apply to the employee’s area of specialty.7.9.2.2 Specialist Employee B.7.9.2.2.1

Defined as the person who is trained in the hazards of specific chemicals or containers in the individual'sarea of specialization and who can be called on to respond to incidents involving these chemicals orcontainers. The specialist employee B can be used to gather and record information, provide technicaladvice, and provide technical assistance (including work in the hot zone) at the incident, consistent with theemergency response plan and/or standard operating procedures.7.9.2.2.2

There is a requirement in NFPA 472 for specialist employee B personnel to meet the requirements underawareness (Chapter 4) and relevant areas of specialty employee (Chapter 9) as they apply to theemployee’s area of specialty.7.9.2.3 Specialist Employee C.7.9.2.3.1

Defined as the person who responds to emergencies involving hazardous materials/WMD and/or containersin the organization's area of specialization and can be called on to gather and record information, providetechnical advice, and arrange for technical assistance. The specialist employee C does not enter the hot orwarm zone at an emergency.7.9.2.3.2

There is a requirement in NFPA 472 for specialist employee C personnel to meet the requirements underawareness (Chapter 4) and relevant areas of specialty employee (Chapter 9) as they apply to theemployee’s area of specialty.7.9.3 Hazardous Materials Officers.7.9.3.1

NFPA 472 defines the competencies of a hazardous materials officer in Chapter 10. A hazardous materialsofficer is the person who is responsible for directing and coordinating all operations involving hazardousmaterials/WMD as assigned by the incident commander. Hazardous materials officers must showcompetency for all skills defined in NFPA awareness level, operations level responder, and hazardousmaterials technician, as well as those in Chapter 10 for hazardous materials officers.7.9.3.2

Hazardous materials officers lead hazmat technicians and thus are expected to possess fluent knowledge ofthe process for analyzing, planning, implementing, evaluating, and terminating hazardous materialsincidents. There are many components of NFPA 472 that require employees to perform their tasks onlywhile in the presence of a hazardous materials officer; therefore, the competencies listed within NFPA 472are written at a level above those for a hazardous materials technician.7.9.4 Hazardous Materials Safety Officers.


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7.9.4.1 NFPA 472 defines the competencies of a hazardous materials safety officer in Chapter 11. A hazmat safetyofficer is the person who works within an incident management system (IMS) (specifically, the hazardousmaterial branch/group) to ensure that recognized hazardous materials/WMD safe practices are followed athazardous materials/WMD incidents.7.9.4.2

Hazmat safety officers within an organization must possess a working knowledge of all team capabilitiesand weaknesses and therefore are required to show competency for all skills defined in NFPA awarenesslevel, operations level responder, and hazardous materials technician, as well as those in Chapter 11 forhazardous materials safety officers.7.9.5

Hazardous Materials Technicians with a Tank Car Specialty 12.7.9.6

Hazardous Materials Technicians with a Cargo Tank Specialty 13.7.9.7

Hazardous Materials Technicians with an Intermodal Tank Specialty 14.7.9.8

Hazardous Materials Technicians with a Marine Tank and Non-Tank Specialty 15.7.9.9

Hazardous Materials Technicians with a Flammable Liquids Bulk Storage Specialty 16.7.9.10

Hazardous Materials Technicians with a Flammable Gas Bulk Storage Specialty 17.7.9.11

Hazardous Materials Technicians with a Radioactive Material Specialty.7.10 Annual Competencies and Refresher Training.The hazmat team leader must ensure that team members retain knowledge and show competency on anannual basis. A properly designed training program will make this requirement an easier process andensure that team competency does not singularly revolve around an annual requirement.7.10.1 OSHA Requirements for Refresher Training.In 29 CFR 1910.120 (q)(8), OSHA states that employees must receive training that is of sufficient contentand length to maintain competency or must demonstrate competency in their area of certification at leastannually. Agencies must resist the temptation to quantify annual refresher training based solely on thenumber of hours a learner sits in class, rather develop a process to measure competency based on the jobtask analysis for the employees.7.10.1.1

At the conclusion of annual refresher training, each learner must be evaluated on his or her abilities toperform the tasks assigned by the AHJ. The evaluation process should follow the processes outlined earlierin this chapter for evaluation of response personnel ( (See 7.8.1, 7.8.2 and 7.8.3). It is the responsibility ofthe AHJ to document and maintain records of annual training information/material based on establishedstandard operating procedures/guidelines.7.10.1.2

If training drills, workshops, and exercises are developed with a mechanism to measure competency, theprocess of validating competency for OSHA refresher requirements becomes easier.7.10.2 NFPA Requirements for Refresher Training.

NFPA 472 does not specifically state a requirement for annual refresher training. NFPA 472 definescompetence as possessing knowledge, skills, and judgment needed to perform indicated objectives. TheAHJ should develop a process to ensure that all team members maintain a steady level of competency on acontinual basis.7.11 Exercises.


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The hazmat team leader should utilize exercises to evaluate the competency of the team and responsepartners and to validate the community emergency response plans, policies, and procedures. There arenumerous resources available to the hazmat team leader when selecting and implementing exercises. Avery robust exercise and evaluation program is the DHS/FEMA Homeland Security Exercise and EvaluationProgram (HSEEP) (https://hseep.dhs.gov/pages/1001_HSEEP7.aspx). HSEEP provides several productsthat can assist with hazmat team exercise development and the evaluation of exercise play. HSEEPproducts include the following:

(1) HSEEP Volume I — HSEEP Overview and Exercise Program Management

(2) HSEEP Volume II — Exercise Planning and Conduct

(3) HSSEP Volume III — Exercise Evaluation and Improvement Planning

(4) HSEEP Volume V — Prevention Exercises

(5) HSEEP Toolkit

7.11.1 The following online independent study courses are also available from the FEMA/Emergency ManagementInstitute (http://training.fema.gov/EMI). These can also help with exercise planning:

(1) IS-120 — An Introduction to Exercises

(2) IS-130 — Exercise Evaluation and Improvement Planning

(3) IS-139 — Exercise Design

7.11.2 The HSEEP program lists several types of exercise tools that can be used to assist with the evaluation ofthe hazmat team and its individual team member competence, as follows:

(1) Discussion-based exercises

(2) Seminars

(3) Workshops

(4) Table-top exercises

(5) Games

(6) Operations-based exercises

(7) Drills

(8) Functional exercises

(9) Full-scale exercises

7.11.2.1 Discussion-Based Exercises.Discussion-based exercises are normally used as a starting point in the building-block approach ofescalating exercise complexity. Discussion-based exercises include seminars, workshops, tabletopexercises (TTXs), and games. These types of exercises typically highlight existing plans, policies,interagency/interjurisdictional agreements, and procedures. Discussion-based exercises are valuable toolsfor familiarizing agencies and personnel with current or expected capabilities. Discussion-based exercisestypically focus on strategic, policy-oriented issues. Facilitators and/or presenters usually lead thediscussion, keeping participants on track toward meeting the exercise objectives.


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7.11.2.1.1 Seminars.Seminars are informal discussions unconstrained by real-time portrayal of events and led by a presenter.They are generally used to orient participants to, or provide an overview of, authorities, strategies, plans,policies, procedures, protocols, response resources, and/or concepts and ideas. Seminars provide a goodstarting point for teams that are just developing or making major changes to their plans and procedures.7.11.2.1.2 Workshops.

After seminars, workshops represent the second tier of exercises in the HSEEP building-block approach.They differ from seminars in two important respects: participant interaction is increased, and the focus is onachieving or building a product (such as a draft plan or policy). Workshops are often used in conjunctionwith exercise development to determine objectives, develop scenarios, and define evaluation criteria. Aworkshop can also be used to produce new standard operating procedures (SOPs), emergency operationsplans (EOPs), multiyear plans, or improvement plans. To be effective, workshops must be highly focused ona specific issue, and the desired outcome or goal must be clearly defined.7.11.2.1.3 Table-Top Exercises.TTXs involve key personnel discussing hypothetical scenarios in an informal setting. This type of exercisecan be used to assess plans, policies, and procedures or to assess the systems needed to guide theprevention of, response to, and recovery from a defined incident. TTXs typically are aimed at facilitating anunderstanding of concepts, identifying strengths and shortfalls, and achieving changes in the approach to aparticular situation. Participants are encouraged to discuss issues in depth and develop decisions throughslow-paced problem solving, rather than the rapid, spontaneous decision making that occurs under actualor simulated emergency conditions. The effectiveness of a TTX is derived from the energetic involvement ofparticipants and their assessment of recommended revisions to current policies, procedures, and plans.7.11.2.1.3.1

TTX methods are divided into two categories: basic and advanced. In a basic TTX, the situation establishedby the scenario materials remains constant. It describes an event or emergency incident (i.e., scenario) andbrings discussion participants up to the simulated present time. Players apply their knowledge and skills to alist of problems presented by the leader/moderator, problems are discussed as a group, and the leadergenerally agrees on and summarizes the resolutions.7.11.2.1.3.2

In an advanced TTX, play revolves around delivery of prescripted messages to players that alter the originalscenario. The exercise controller or moderator usually introduces problems one at a time in the form of awritten message, simulated telephone call, videotape, or other means. Participants discuss the issuesraised by the simulated problem, applying appropriate plans and procedures.7.11.2.1.4 Games.

A game is a simulation of operations that often involves two or more teams and uses rules, data, andprocedures to depict an actual or assumed real-life situation. The goal of a game is to explore decision-making processes and the consequences of those decisions. A game does not require use of actualresources, and the sequence of events affects, and is in turn affected by, decisions made by players. Withthe evolving complexity and sophistication of current simulations, opportunities to provide enhanced realismfor game participants have increased. Computer-generated scenarios and simulations can provide a morerealistic and time-sensitive method of introducing situations for analysis. Planner decisions can be input intorealistic models to show the effects of decisions made during a game. Internet-based, multiplayer gamesoffer many additional benefits, such as saving money by reducing travel time, offering more frequent trainingopportunities, and taking less time away from primary functions. They also provide a collaborativeenvironment that reflects realistic occurrences.7.11.2.2 Operations-Based Exercises.Operations-based exercises represent the next level of the exercise cycle. They are used to validate theplans, policies, agreements, and procedures solidified in discussion-based exercises. Operations-basedexercises include drills, functional exercises (FEs), and full-scale exercises (FSEs). They can clarify rolesand responsibilities, identify gaps in resources needed to implement plans and procedures, and improveindividual and team performance. Operations-based exercises are characterized by actual reaction tosimulated intelligence, response to emergency conditions, mobilization of apparatus, resources, and/ornetworks, and commitment of personnel, usually over an extended period of time.


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7.11.2.2.1 Drills.A drill is a coordinated, supervised activity usually employed to validate a single, specific operation orfunction in a single agency or organizational entity. Drills are commonly used to provide training on newequipment, develop or validate new policies or procedures, or practice and maintain current skills. Typicalattributes of drills include the following:

(1) A narrow focus, measured against established standards

(2) Immediate feedback

(3) A realistic environment

(4) Performance in isolation

7.11.2.2.2 Functional Exercises.A functional exercise (FE) is designed to validate and evaluate individual capabilities, multiple functions,activities within a function, or interdependent groups of functions. Events are projected through an exercisescenario with event updates that drive activity at the management level. An FE simulates the reality ofoperations in a functional area by presenting complex and realistic problems that require rapid and effectiveresponses by trained personnel in a highly stressful, time-constrained environment.7.11.2.2.2.1

Response-and-recovery-focused FEs generally concentrate on exercising the plans, policies, procedures,and staffs of the direction and control branches of incident command (IC), unified command (UC), and/ormultiagency coordination centers (e.g., EOCs). Movement of personnel and equipment is simulated.7.11.2.2.2.2

Prevention-focused FEs usually concentrate on exercising the plans, policies, procedures, agreements,networks, and staffs of fusion centers or law enforcement agencies with counterterrorism missions.Adversary actions are largely simulated and delivered in the form of shared intelligence; however, some ofthese actions might be carried out by simulated adversaries, or red teams, in a separate but coordinatedcategory of exercise play. See HSEEP Volume V — Prevention Exercises, for more information onprevention-focused exercises.7.11.2.2.3 Full-Scale Exercises (FSE).The FSE is the most complex type of exercise. FSEs are multiagency, multijurisdictional, multiorganizationalexercises that validate many facets of preparedness. They focus on implementing and analyzing the plans,policies, procedures, and cooperative agreements developed in discussion-based exercises and honed inprevious, smaller, operations-based exercises. In FSEs, the reality of operations in multiple functional areaspresents complex and realistic problems that require critical thinking, rapid problem solving, and effectiveresponses by trained personnel. During FSEs, events are projected through a scripted exercise scenariowith built-in flexibility to allow updates to drive activity. FSEs are conducted in real time, creating a stressful,time-constrained environment that closely mirrors real events. The level of support needed to conduct anFSE is greater than that needed during other types of exercises.7.11.2.2.3.1

Response-focused FSEs include many first responders operating under the principles of the NationalIncident Management System (NIMS) to effectively and efficiently respond to an incident. Personnel andresources are mobilized and deployed to the scene where they conduct their activities as if a real incidenthad occurred (with minor exceptions). An FSE also can include functional play from participants not locatedat the exercise incident response site, such as multiagency coordination centers (MACCs), EOCs, orhospitals.7.12 External Influences on Training Programs.There are several external influences the hazmat team leader must consider when establishing a trainingprogram. Issues involving regulatory compliance, budgetary constraints, advances in technology, and theexpectations of external stakeholders all play a role in the training program’s scope and success.7.12.1 Regulatory Compliance.

The field of hazardous materials response is regulated by OSHA, and in many states hazmat training isfurther defined by state policy or law. The hazmat team leader must understand that regulations and lawsmust be met and are considered the minimum for hazmat response personnel. A hazmat team trainingprogram must include thorough documentation of all training activities that show compliance.


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7.12.2 Budgetary Constraints.Funding for hazmat teams can be a challenge. During times of budgetary constraints hazmat training mightbe considered extraneous to other essential AHJ funding mandates. Hazmat team leaders must besensitive to external budgetary issues and remain cognizant of the minimum training required for thehazmat team.7.12.2.1

During extreme budget crisis, hazmat team leaders might have to find alternative ways to provide trainingfor the team. If training funds are strained, the team leader should consider all internal and in-servicetraining possibilities. At no time should a team leader allow the team to function without currentcertifications.7.12.3 Technology Advances.

Hazmat team leaders should maintain awareness of advances in technology that could affect teamoperations. Improvements in computers, computer networks, software, computer-based and web-basedtraining programs, detection and monitoring equipment, PPE, and product control devices can all add to theefficiency of the team. Team leaders should identify personnel within their organization that have apropensity and interest in technological advances and allow them to assist in this area.7.12.4 Stakeholder Expectations.

Team leaders must remember that there are numerous external stakeholders that influence teamoperations. Members of the public have expectations that their personal safety will be protected duringhazardous materials releases. Other public safety agencies rely on the AHJ’s expertise and responsecapabilities and look to the hazmat team for guidance and assistance during incidents. Private sectorentities such as healthcare and industry have expectations for guidance and assistance during events thatmight affect their property. Agency representatives, elected officials, and administrators all have anexpectation that the hazmat team will be ready for whatever situation might arise.


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7.12.5 References.

(1) Clark, R.C., Mayer, R.E., e-Learning and the Science of Instruction: Proven Guidelines for

Consumers and Designers of Multimedia Learning . 2 nd Edition. 2011. Pfeiffer.

(2) Department of Homeland Security/Federal Emergency Management Agency. Homeland SecurityExercise and Evaluation Program (HSEEP) . From the internet on August 15, 2012.https://hseep.dhs.gov/pages/1001_HSEEP7.aspx

(3) Federal Emergency Management Agency. Emergency Management Institute . From the internet onAugust 15, 2012. http://training.fema.gov/EMI

(4) Federal Emergency Management Agency. Responder Training Development Center . From theinternet on August 15, 2012. https://www.firstrespondertraining.gov/rtdc/state/

(5) Kirkpatrick, D.L., Kirkpatrick, J.D. Evaluating Training Programs: The Four Levels . 3 rd Edition. 2006.Berrett-Koehler Publishers.

(6) Knowles, M.S., Holton, E. F. III, Swanson, R.A., The Adult Learner, Sixth Edition: The DefinitiveClassic in Adult Education and Human Resource Development. Butterworth-Heinemann.

(7) Lee, W.W., Owens, D.L., Multimedia -based Instructional Design: Computer-Based Training;

Web-Based Training; Distance Broadcast Training; Performance-Based Solutions . 2 nd Edition. 2004.Pfeiffer.

(8) Merriam, S.B., Caffarella, R.S., Baumgartner, L.M. Learning in Adulthood, a Comprehensive Guide

3 rd Edition. 2007. John Wiley & Sons, Inc. San Francisco, CA.

(9) National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 472,Standard for Competence of Responders to Hazardous Materials/Weapons of Mass DestructionIncidents , 2013 Edition.

(10) Occupational Safety & Health Administration, OSHA 29 Code of Federal Regulations 1910.120,Hazardous Waste Operations and Emergency Response .

(11) Occupational Safety & Health Administration, OSHA 29 Code of Federal Regulations 1910.120,Hazardous Waste Operations and Emergency Response – Appendix E Training Curriculum Guidelines- (Non-mandatory).

(12) Rothwell, W.J., Pfeiffer, R.S., Practicing Organization Development: A Guide for Consultants . 2 nd

Edition. 2005.

(13) Witkin, B.R., Altschuld, A.W., Planning and Conducting Needs Assessments: A Practical Guide. 1 st

Edition. 1995. Sage Publications, Inc.









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7.1 Introduction.7.1.1 Purpose.The purpose of this chapter is to provide information and guidance for hazardous materials/WMD responseteam program managers in understanding the importance of initial and ongoing training to develop thepersonal competence of HMRT response personnel as required by established regulations and therecommendations set forth in NFPA standards.7.1.2 Scope.The development of a comprehensive training program is an essential component of a hazardous materialsprogram. The training program should serve as a source of initial and ongoing team training but should alsoaccommodate the evaluation of personnel competence as required by both OSHA regulations and NFPAstandards. The training program should produce products that provide accurate, timely, and engagingtraining that are both challenging and worthwhile for the members of the hazmat team.7.1.2.1 Failure to provide sufficient training for hazmat team personnel can have disastrous consequences,including mission failure, violation of OSHA regulations, and injury or death to team members or the public.The training program must not be viewed as a burden or afterthought, nor should an assignment to thetraining program be viewed as a reprimand. In contrast, progressive hazmat team leaders place their bestand brightest team members in the training program in order to ensure quality of instruction and improveteam efficiency.7.1.2.2 The goal of any hazmat training program should be to encourage the transfer of knowledge to the teammembers, modify the behavior of the team to ensure their health and safety, and prepare the team tomanage incidents in an efficient manner. Field work should reflect the outcomes that are described,discussed, and demonstrated during a training event. A professionally prepared training program will delivermeasurable performance outcomes as they relate to the tasks required during operational missions.The committee should consider adding other available information, as it relates to the topic of this chapter,for emergency service training programs found in the NFPA Professional Qualification series.


This chapter includes a comprehensive overview of training programs, but does not reference the Professional Qualification standards that include similar information. For example, NFPA 1000 establishes the criteria which organizations that are nationally accredited must adhere for the assessment of certification standards. This document also sets the parameters by which accredited entities can issue certifications signifying that candidates have successfully demonstrated competency as required. The value of assessment as a form of establishing validity and reliability is not included in NFPA 475 and should be included.

Additionally, a Professional Qualifications document exists that establishes the job performance requirements for emergency services instructors. NFPA 1041 is a long-standing consensus standard that, through the NFPA process, has identified the knowledge, skills and abilities that emergency service instructors should demonstrate through a valid and reliable assessment process in order to serve in the role of instructor. Some, but not all of these job performance requirements are described in 475. NFPA 1041 should be recognized within 475 as the preferred method for establishing instructor qualifications.



Organization: TEEX

Street Address:


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City:State:Zip:Submittal Date: Mon Dec 22 13:23:38 EST 2014


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7.1.1 Purpose.The purpose of this chapter is to provide information and guidance for hazardous materials/WMD responseteam program managers in understanding the importance of initial and ongoing training to develop thepersonal competence of HMRT response personnel as required by established regulations and therecommendations set forth in NFPA standards.

Reviewer's Comment: What is missing here, although it is included later, is a discussion oftraining which should be considered for personnel outside of the formal HMRT. All first respondersneed to be trained in the recognition of a hazmat event, and particularly a deliberate CBRNe/WMDevent so that:

(1) First responders can recognize the signs of a Hazmat/CBRNe/WMD event and initiate initialprotective actions and call for assistance of HMRT.

(2) Additional casualties due to secondary devices related to an intentional event can beprevented.

Although these other first responders are not part of the formal HMRT, they are an essentialcomponent of the overall HMRT response and, as such, the requirement to consider them in anytraining program deserves mention in this introduction to the purpose of this chapter.


The initial response to an incident will not always (actually probably rarely) be from members of the formal HMRT, and other first responders need to be trained in recognizing the signs of an incident- particularly a deliberate incident.






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7.1.2.1 Failure to provide sufficient training for hazmat team personnel can , and at least awareness training forother first resonders, can have disastrous consequences, including mission failure, violation of OSHAregulations, and injury or death to team members or the public. The training program must not be viewed asa burden or afterthought, nor should an assignment to the training program be viewed as a reprimand. Incontrast, progressive hazmat team leaders place their best and brightest team members in the trainingprogram in order to ensure quality of instruction and improve team efficiency.


All first responders need training to at least the awareness level, as they are the initial "eyes and ears" of the HMRT during an incident.






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7.2.1.1 Hazmat team leaders should choose a methodology to measure the competency of their team. Attendanceat classroom training sessions, watching videos, or the donning of chemical protective clothing do notbecome measures of competency until the learner’s knowledge, skill, or judgment is evaluated anddocumented. The evaluation of learning can be accomplished by various methods. A following popularmethod for evaluating learning has been published by Dr. Donald Kirkpatrick:

(1) Level 1 Evaluation — This evaluation level measures the reaction of the learner to the trainingdelivered. This reaction is typically measured by the completion of an evaluation form by the learner.These forms provide the training program manager with a snapshot of the training’s effectivenessfrom the perspective of the learner and should include questions on the content, delivery, andrelevance of the training material. Evaluation sheets on their own do not prove competence but theydo assist with validation of the training delivery.

(2) Level 2 Evaluation — This evaluation level measures the learning of the learner. The learning istypically measured by a metric based, quantifiable evaluation tool such as written tests, skills testing,or observation of performance. There are many techniques available to enhance the measurement oflearning, such as pre-testing prior to the training delivery and then measuring the improvement inknowledge with post-test evaluations.

(3) Level 3 Evaluation — This evaluation level measures the changes in behavior from the learner.The evaluation of behavior change is typically performed over time to ensure that the knowledge,skills, and judgment of the learner is retained and used as a matter of routine. The evaluation ofbehavior change can be accomplished through techniques such as retesting the learner after aperiod of time or direct observation of the learner’s performance.

Remove this entire section or move it to the Annex.


Section is academic and provides no usable guidance to hazmat team leaders.






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7.2.1.2 It should be noted that Kirkpatrick’s evaluation model includes a fourth level evaluation based upon ameasurement of the ratio of the cost of the training project in comparison to the return of investment to theorganization. While a valid business model and a financial consideration for hazmat team leaders, themeasurement of return of investment does not impact the measurement of competency for hazmat teampersonnel and will not be discussed further.


Section is academic gibberish that provides no guidance to hazmat team leaders.






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7.3.3 Hazmat team training should be lively and engaging. One of the pioneers of adult learning, MalcolmKnowles, theorized that adults only learn when the following certain criteria are met:

(1) Adult learners want to make decisions regarding their learning ( self-direction ).

(2) Adult learners’ life experiences provide a foundation for their learning.

(3) Adult learners must be ready to learn ( desire to learn).

(4) Adult learners want to learn things they can apply to their life ( application of learning).

(5) Adult learners are more internally, rather than externally, motivated to learn.

(6) Adult learners must understand the reason they are learning ( need to know).


Remove academic theory from document.






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x.1 Instructor Qualty Assurance and Quality Improvement Instructors conducting hazardous materials/WMD emergency response training should participate in atraining Quality Assurance and Quality Improvement (QA/QI) program.

x.1.1 In order to provide quality assurance, hazmat/WMD instructors should receive written evaluationsincluding:

1. Class evaluations completed by the students attending the training session, and

2. Annual review of their instructional competence by the hazmat team leader, supervisor, instructor peer orother competent person assigned by the AHJ.

x.1.2 hazmat/WMD instructros should continue to improve their competency and training capabilities throughany combination of the following:

1. Attending relevent training courses or workshops

2. Attending annual instructor refresher courses

3. Attending industry trade shows or conferences


If you follow ugly kids home, you'll find ugly parents.

If we desire quality hazmat responders, we must ensure the quality of the instructors. I believe instructor quality assurance/improvement is a relevant and important topic that deserves at least a small inclusion in NFPA 475.






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7.4.2.2 Internal Training Program Disadvantages.The primary disadvantages of internal training programs revolve around quality. The quality of thecurriculum development, course materials, training equipment, facilities, instructors, and evaluation oflearning are the responsibility of the hazmat team leader and must be closely monitored. Leaders mustrealize that the delivery of training in the classroom is only a small component of the curriculum process.The analysis, design, development, and evaluation of training will require a great deal of time and effortcompared to the actual delivery of the training itself. Other disadvantages of internal training includecomplacency, apathy, and internalization when the same instructor is used over and over. Encouragingteam members to take over training duties can enhance instruction and increase the knowledge of theguest instructor as they prepare to deliver the course. When conducting internal training, considerationshould be given to bringing in outside evaluators for the final evaluations.


Some of the problems assocaited with internal training can be solved, or at least identified for correction, by bringing in external, unbiased evaluators for final evaluations, ensuring that the trainees have been taught, and have learned, all of the required knowledge and skills based on the standard.






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7.6 Training Delivery Models.During the design phase the curriculum development team must determine the best model of delivery forthe learner. Although each type of training delivery has its own unique advantages, successful trainingprograms often use a blended format comprised of several different models to offer a variety to the learner.The most common types of training delivery models are as follows:

(1) Instructor-led classroom lecture: This model is suited for large group delivery of technical material.However, it is not very useful for evaluating competency.

(2) Instructor-facilitated discussion: This model is suited for large group delivery of material when there isa desire for immediate feedback from the learner. However, it is not very efficient for evaluatingcompetency. It also requires close monitoring by the facilitator to ensure the discussion does not strayoff topic and waste valuable training time.

(3) Instructor-led demonstration: This model is suited for large group demonstrations of visual conceptssuch as chemical and physical property demonstrations. However, it is not very useful for evaluatingcompetency.

(4) Self-paced learning: This model is suited for research type work by the learner. Using the EmergencyResponse Guidebook and NIOSH Pocket Guide to Chemical Hazards are examples of this method.This model can be used for competency skills evaluation.

(5) Small group lecture: This model is suited for delivery of technical information where a more intimateinstructor-learner ratio is desired. However, it is not very efficient for evaluating competency.

(6) Small group demonstration: This model is suited for demonstration of equipment that requires closeproximity of the learner to the instructor. This model can be used for evaluation if properly planned bythe instructor team.

(7) Practical skill sessions: This model is suited for hands-on experience by the learner and can be usedfor evaluation if properly planned by the instructor team.

(8) E-learning (web-based or computer-based): This model is suited for individual delivery of writtenmaterial and can be used for evaluation of written competency.

(9) Simulation: This model is suited for either individual or group training and involves the use ofelectronic aids to present the learner with unique problem solving and critical thinking exercises.

(10) Scenario-based practical sessions: This model is suited for maximum transfer of learning to thelearner and can be used for evaluating competency.

(11) Table-top exercises: This model is suited for transfer of learning on administrative tasks such as theincident command system or strategic management training and can be used for evaluation ofcompetency if properly planned by the instructor team.

(12) Full-scale exercises: This model is suited for maximum transfer of learning and can be used forevaluating competency. Real-time, unannounced exercises are beneficial for maximum evaluation.

(13) One-on-one evaluation: This model is best suited for evaluating individual skill competencies.


Instructor facilitated discussions must be closely monitored to keep them on track and focused.




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7.7.2 Training Equipment, Props. , and SimulatorsMeeting the NFPA 472 hazardous materials competencies requires a demonstration of skills as they relateto many subject areas including personal protective equipment, product control, decontamination, anddetection and monitoring. Hazmat team leaders must ensure that training programs have access tosufficient equipment and training props for team training and evaluation. Training props can be expensiveand in many cases too large for existing training facilities. Hazmat team leaders should considerdevelopment of regional training centers for larger props such as rail tank cars and tank trucks so theexpenses for those props can be shared. Training equipment to be considered for acquisition by trainingprograms can include the following:












(12) Reagent papers



7.7.2.1 Training props might include the following:

(1) Chlorine, 100 lb and 150 lb cylinders

(2) Chlorine, ton container ends

(3) Chlorine, DOT-105 tank car dome


(5) MC306/DOT406 highway cargo tank truck

(6) MC307/DOT407 chemical cargo tank truck

(7) MC312/DOT 412 corrosive tank truck

(8) MC331 pressure highway cargo tank truck

(9) MC338 cryogenic tank truck

(10) DOT111 (low pressure) railroad tank car

(11) DOT105 or DOT112 (high pressure) railroad tank car

(12) Drum leak simulators



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7.7.2.2 Electronic simulation devices might include the following:


(2) Incident command simulators



Updated section title would better reflect the content of the section. The section contains three sub-sections focused on Training Equipment, Training Props, and Training Simulators, but the current title of the section is only Training Props.






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Meeting the NFPA 472 hazardous materials competencies requires a demonstration of skills as they relateto many subject areas including personal protective equipment, product control, decontamination, anddetection and monitoring. Hazmat team leaders must ensure that training programs have access tosufficient equipment and training props for team training and evaluation. Training props can be expensiveand in many cases too large for existing training facilities. Hazmat team leaders should considerdevelopment of regional training centers for (or partnering with local industry stakeholders) for larger propssuch as rail tank cars and tank trucks so the expenses for those props can be shared. Training equipment tobe considered for acquisition by training programs can include the following:












(12) Reagent papers




The statement as written overlooks a potential training partner- industrial stakeholders and their equipment.






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Key points with the OSHA levels of training include the following:

(1) The language is very clear. If you are part of the response then you must train your personnel to firstresponder operations level as a minimum.

(2) If the mission of the team is to take offensive actions to perform product control you must train yourpersonnel to hazardous materials technician as a minimum.

(3) OSHA requires that all responders be trained prior to responding to an incident and requires that theAHJ certify that the responder has shown competency in each area.

Reviewer comment: This supports my earlier comment that ALL first responders should be trainedto at least the awareness level- they are THE responders until the incident is identified as aHAZMAT/WMD event and higher trained personnel can be brought in.


Training needs to go beyond the HMRT.






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7.8.5.1 First Responder Awareness Level (OSHA 29 CFR 1910.120 (q)(6)).First responders at the awareness level are individuals who are likely to witness or discover a hazardoussubstance release and who have been trained to initiate an emergency response sequence by notifying theproper authorities of the release. They would take no further action beyond notifying the authorities of therelease , in the course of their normal duties, could encouter an emergency involving hazardousmaterials/weapons of mass destruction (WMD) and who are expected to recognize the presence of thehazardous materials/WMD, protect themselves, call for trained personnel, and secure the area . Firstresponders at the awareness level shall have sufficient training or have had sufficient experience toobjectively demonstrate competency in the following areas:





(5) An understanding of the role of the first responder awareness individual in the employer's emergencyresponse plan, including site security and control and the U.S. Department of Transportation'sEmergency Response Guidebook.



This change is necessary because the definition in the current draft conflicts with the definition of awareness level personnel from the Handbook. Many agencies that rely on the handbook utilize a composite model for HazMat response and Awareness Level first responders fill key roles during the initial phases of an emergency, as well as fill key support functions during the incident remediation and mitigation phases.






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7.8.5.1 First Responder Awareness Level (OSHA 29 CFR 1910.120 (q)(6)).First responders at the awareness level are individuals who

are likely to witness or discover a hazardous substance release and who have been trained to initiate anemergency response sequence by notifying the proper authorities of the release. They would take nofurther action beyond notifying the authorities of the release. First responders, in the course of their normal duties, could encounter an emergency involving hazardousmaterials/weapons of mass destruction (WMD) and who are expected to recognize the presence of thehazardous materials/weapons of mass destruction (WMD), protect themselves, call for trained personnel,and secure the area. First responsders at the awareness level shall have sufficient training or have hadsufficient experience to objectively demonstrate competency in the following areas:





(5) An understanding of the role of the first responder awareness individual in the employer's emergencyresponse plan, including site security and control and the U.S. Department of Transportation'sEmergency Response Guidebook .



The proposed change of language would make this language consistent with the the language in the NFPA 475 Handbook. While the meanings of the two variations of this language may be slight, the difference could be interpreted as over-ruling the NFPA 475 Handbook, and it doesn't appear that this is really the intent of the Technical Committee.


Submitter Full Name: Joseph Maruca

Organization: West Barnstable Fire Department



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7.8.5.1 First Responder Awareness Level (OSHA 29 CFR 1910.120 (q)(6)).First responders at the awareness level are individuals who are likely to witness or discover a hazardoussubstance release and who have been trained to initiate an emergency response sequence by notifying theproper authorities of the release. They would take no further action beyond notifying the authorities of therelease. First responders at the awareness level shall have sufficient training or have had sufficientexperience to objectively demonstrate competency in the following areas:





(5) An understanding of the role of the first responder awareness individual in the employer's emergencyresponse plan, including site security and control and the U.S. Department of Transportation'sEmergency Response Guidebook.


Reviewer Comment: The statement that "they (first responders at the awareness level) would takeno further action beyond notifying the authorities of the release" contradicts point (5) "the role ofthe first responder awareness individual in the employer's emergency response plan, including sitesecurity and control and...". Either the first responder does nothing more than notify, or they takeaction on site security and control- I think the latter makes more sense .


There is a contradiction in what the first responder will and will not do.






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7.8.5.3 Hazardous Materials Technician (OSHA 29 CFR 1910.120 (q)(6).Hazardous materials technicians are individuals who respond to releases or potential releases for thepurpose of stopping the release. They assume a more aggressive role than a first responder at theoperations level in that they will approach the point of release in order to plug, patch, or otherwise stop therelease of a hazardous substance. Hazardous materials technicians shall have received at least 24 hours oftraining equal to the first responder operations level and in addition have competency in the following areasand the employer should so certify:




(4) Knowledge of how to select and use proper specialized chemical personal , biological andradiological personal protective equipment provided to the hazardous materials technician


(6) The ability to perform advance control, containment, and/or confinement operations within thecapabilities of the resources and personal protective equipment available with the unit

(7) An understanding of and ability to implement decontamination procedures




As written the statement only deals with chemical PPE. The Hazmat technician must know what PPE applies to biological and radiological hazards as well- for instance N95 masks for biological and respirators (positive or negative pressure) which prevent radiological materials from entering the respiratory system.






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One of the most critical decisions a hazmat team leader can make is to determine the level of trainingneeded for their team. An objective assessment must be made based on the mission, staffing levels,financial support, and training availability of team members. Team leaders must realize the tremendouscommitment necessary to train and maintain competency for a fully capable technician level team.

Reviewer Comment: These requirements go well beyond the HMRT itself- as far beyond asadministrative staff- which validates earlier comments that this standard should apply to not onlythe HMRT but all staff in supporting roles to the HMRT such as other first responders. If this wasmade clear at the beginning, perhaps in the statement of scope for the standard, it would be useful.


This makes eminent sense, however it has gone beyond the previously defined "Scope" of the standard. I recommend the scope statement at the beginning of the standard to be broadened to include not only the HMRT but ALL personnel potentially involved in an incident.






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Public Input No. 82-NFPA 475-2014 [ Section No. 7.8.7.4.1.2 ]

7.8.7.4.1.2 Mission-Specific Competencies — Mass Decontamination.The operations level responder assigned to perform mass decontamination at hazardous materials/WMDincidents should be that person, competent at the operations level, who is assigned to implement massdecontamination operations at hazardous materials/WMD incidents. Mass decontamination is defined byNFPA 472 as the physical process or chemical process of reducing, removing or removing surfaceneutralizing surface contaminants from large numbers of victims in potentially life-threatening situations inthe fastest time possible.


Decontamination can include chemical as well as physical means, and can be accomplished through neutralization- not just through removal or reduction, for example RSDL.






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Public Input No. 83-NFPA 475-2014 [ Section No. 7.8.7.4.1.3 ]

7.8.7.4.1.3 Mission-Specific Competencies — Technical Decontamination.The operations level responder assigned to perform technical decontamination at hazardousmaterials/WMD incidents should be that person, competent at the operations level, who is assigned toimplement technical decontamination operations at hazardous materials/WMD incidents. Technicaldecontamination can be described as the performance of contamination removal to or neutralization to alevel that is as low as reasonably achievable on responders that are wearing personal protective clothing.


Decontamination can be accomplished through neutralization, not just removal.






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7.8.7.4.3 The mission-specific competencies set forth in NFPA 472 resemble an “Operations + ” concept that isdesigned for operations-level personnel who have a mission to enter the warm or hot zone to performspecific tasks. OSHA 29 CFR 1910.120 regulations place a minimum time requirement on first responderoperations-level training. OSHA requires that first responder operations personnel receive at least 8 hoursof training or have enough experience to demonstrate competency in the following areas, in addition tothose listed for the awareness level:

(1) Knowledge of the basic hazard and risk assessment techniques.

(2) Knowledge of how to select and use proper PPE provided to the first responder operational level.

(3) An understanding of basic hazardous materials terms.

(4) Knowledge of how to perform basic control, containment, and/or confinement operations within thecapabilities of the resources and PPE available with their unit.

(5) Knowledge of how to implement basic decontamination procedures.

(6) An understanding of the relevant standard operating procedures and termination procedures.

Reviewer Comment: This is redundant, as it is stipulated in 7.8.7.3.2, and all responders withMSCs must first be qualified to at least the operations core level.


This statement is redundant.






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Public Input No. 108-NFPA 475-2014 [ New Section after 7.10 ]

x.0 INTER-AGENCY TRAINING x.1 The HMRT program manager should coordinate training information sharing with all agencies,resources, and response partners participating with the AHJ's hazardous materials/WMD emergencyresponse plan. Training information sharing may include

1. Opportunities to attend training sessions hosted by response partners 2. Lessons learned and best practices 3. Participation in regional exercises

x.2.A HMRT that provides hazmat/WMD incident emergency response to multiple jurisdictions or firstresponder agencies, as part of their emergency response plan, should conduct annual training sessionswith each first responder agency, such as:

1. Capability briefings 2. Joint hazmat refrsher training sessions

3. Command level table exercises

x.3* If an HMRT's emergency response plan includes a provision for members of the HMRT to conduct jointentries into the hot zone, or serve as the back up team, for members of another response organization, theHMRT program manager should ensure joint training and exercise sessions are conducted between bothorgranizations that include the following components:

1) Authority and mission of each agency

2) Concept of operations

3) Interoperable communications including hand siginals and emergency evacuation signal

4) Equipment familiarization

5) Decon procedures

6) Emergency procedures including mayday guidelines and rapid intervention procedures

x.4 If an HMRT's emergency response plan includes a provision for members of the HMRT to receive, orprovide, technical decon for another response organization, the HMRT program manager should ensure jointtraining and exercise sessions are conducted between both organizations that include the followingcomponents:

1. Contamination corridor site selection

2. Decon set up

3. Decon procedures

4. Review of PPE/CPC used by both response organizations

5. Standard doffing procedures for PPE/CPC used by both response organizatons

6. Procedures for emergency decon and CPC removal


The current 475 language does not address inter-agency training. Most hazmat/WMD responses are inter-agency responses. If we plan to fight as we train, then we should include a section in 475 to address inter-agency training from hazmat programs.

Many regional or county based HMRT"s provide hazmat technician level services to multiple agencies. 475 should include language to support, suggest, and encourage a level of inter-agency training with all first responder agencies.


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Many HMRT's supplement reduced staffing by using a neighboring HMRT to provide additional personnel (including DOD teams responding off base). While this resource sharing can reduce costs, it is important that responders not meet each other for the first time in the hot zone. Joint training sessions must be conducted for the safety all of the HMRT members.

Some HMRT's provide decon for other HMRTs or other agencies, such a bomb squad or drug task forces. In these cases, HMRT should train and practice with the agencies they will be performing decon for. A hazmat technician should not try to figure out take off a bomb suit for the first time during an incident.

The basic rule of thumb should be if you put in your AHJ's emergency response plan that your going to respond together, you have to train together.






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Public Input No. 85-NFPA 475-2014 [ Section No. 7.11.2.1.3 [Excluding any

Sub-Sections] ]

TTXs involve key personnel discussing hypothetical scenarios in an informal setting. This type of exercisecan be used to assess plans, policies, and procedures or to assess the systems needed to guide theprevention/mitigation of, response preparedness for, response to, and recovery from a defined incident.TTXs typically are aimed at facilitating an understanding of concepts, identifying strengths and shortfalls,and achieving changes in the approach to a particular situation. Participants are encouraged to discussissues in depth and develop decisions through slow-paced problem solving, rather than the rapid,spontaneous decision making that occurs under actual or simulated emergency conditions. Theeffectiveness of a TTX is derived from the energetic involvement of participants and their assessment ofrecommended revisions to current policies, procedures, and plans.


Mitigation and preparedness can also be guided by a TTX- in fact, a TTX is, in itself, a preparedness measure.






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7.X TRAINING AND EXERCISE SAFETY 7.x.1 Instructor to Student Ratio. During hazmat/WMD training, the ratio of instructors to students shouldnot exceed 1 instructor to 30 students.

7.x.1.1 During any period of instruction when student’s don chemical protective clothing, the followinginstructor to students ratios are recommended:

1) Students don level D ensemble: 1 instructor to 15 students (1:15)

2) Students don Level C or B ensemble: 1 instructor to 10 students (1:10)

3) Students don Level A ensemble: 1 instructor to 5 students (1:5)

7.x.1.2 The instructor should adjust the instructor to student ratio as needed, based on the degree of riskand previous HMERP experience of the students involved.

7.x.2 Hands on training. Hands on training includes a simulated work environment that permits eachstudent to have experience performing tasks, making decisions, or using equipment appropriate to the jobassignment for which the training is being conducted.

7.x.2.1 When hands on training is conducted the following safety precautions are recommended:

1) All participating students should have authorization of the AHJ or employer to attend.

2) All participating students and instructors should meet the medical clearance requirements of the trainingand exercise program

3) Instructor shall be present at all times while hands on training is commencing

4) A first aid kit and automated external defibrillator (AED) should be readily accessible

5) Instructor(s) should ensure adequate rehabilitation breaks are taken based on level of activity andweather conditions

7.x.3 Use of live products. During a hazmat/WMD training session or exercise, the use of smallquantities of live chemical products or radioactive materials may be used to enhance the learningenvironment, provided the appropriate precautions are taken.

7.x.3.1 Instructors should attempt to use simulant products in place of live agents whenever possible.

7.x.3.2 Quantities of live products used for training should be kept to the minimum quantity required toachieve training objectives.

7.x.3.3 The

7.x.3.4 When live products are used, the following safety precautions are recommended:

1) All the safety recommendations of Hands on Training [7.3.2.1] should be followed

2) The use of live products should be approved by the hazmat team leader

3) Instructors or students should not use or create a product, such as a drug or WMD agent, that is aviolation of local, state, or federal law; with out authorization and close coordination of the appropriate lawenforcement or regulatory agency.

4) Live products should be shipped or transported in a manor consistent with all local, state, and federallaws and regulations.

5) Instructors should conduct a safety briefing with all students prior to the start of the period of instructionthat involves live products

6) All students and instructors should don the necessary PPE

7) An emergency shower or decontamination area should be readily available if appropriate based on thedegree of hazard. At a minimum an eye washing station and hand washing sink should be available.

8) Safety data sheets (SDS) for all products used shall be readily available. If the identify of the product(s)


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used is intentionally not reveled to student for training purposes the following additional safety proceduresshould be implemented:

a. All instructors must know the identity of all products involved

b. Each product involved should be labeled with a letter or number that can be crossreferenced with a master list to determine the identify of the product

7.x.3.4 Any live products that are not consumed in the training should be stored safely or disposed of incompliance with local, state, and federal regulations.

7.x.4 Hazardous Training Environments. When an IDLH hazmat environment is created for trainingpurposes, the training event should be treated as an actual hazardous materials emergency.

7.x.4.1 Hazardous training environments that involve live structural fires should adhere to NFPA xxxx

7.x.4.2 Only students that have completed the appropriate hazardous materials training should participatein a HMERP training that involves an IDLH environment.

7.x.4.3 All participants entering the IDLH hazmat training environment should be familiar with, and havebeen previously received training on, the protective clothing, respiratory protection, and other equipment tobe used in the IDLH environment.

7.x.4.4 When conducting a training session or exercise involving an IDLH hazmat environment, thefollowing safety precautions are recommended:

1) All the safety precautions of 7.x.2.1 Hands on Training should be adhered to

2) All the safety precautions of 7.x.3.1 Live Products should be adhered to

3) The instructor to student ratios listed in 7.x.1 should be adhered to

4) A dedicated hazmat safety officer, in addition to the required number of instructors, should be assigned

5) A written site safety plan should be developed

6) All instructors and students should participate in a safety briefing

7) Hot, warm, and cold zone should be established and clearly marked

8) Decontamination appropriate for the hazard should be established prior to entry into the IDLHenvironment

9) A rapid intervention crew (RIC) should be standing by anytime personnel are in the IDLH environment

10) Chemical protective clothing that is expired or intended for training only should not be used in the IDLHenvironment.

7.x.4.5 In the event a student or instructor suffers a hazardous materials exposure during training, theexposure should be documented and treated in accordance with the same procedures required and anexposure at an emergency incident.

7.x.5 Exercise Safety. HMERP exercises including full scale, functional, and drills are intended to closelysimulate real situations involving hazardous materials/WMD. It is possible that real and simulatedemergencies can be confused during an exercise. Additional precautions must be taken during an exercisethat involves a simulated hazardous material/WMD emergency.

7.x.5.1 Each HMERP exercise should have a pre-arranged signal to indicate a real world emergencyduring the exercise.

1) All participants should be briefed on the emergency signal prior to the start of the exercise

2) Upon notification of a real world emergency, all exercise participants should immediate stop exerciseplay and await instructors

7.x.5.2 No participant or observer should be permitted to bring real firearms or weapons should bepermitted at the exercise site. Mock weapons should be clearly identified in a red or blue color.

7.x.5.3 Training program managers should ensure due care is used when mock explosives/improvisedexplosive devices (IED) or mock weapons are included in a hazmat/WMD exercise. The following safetyguidelines are recommended:

1) All mock explosives should be clearly marked INERT.


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2) Mock explosive devices that are intentionally designed not appear as an explosive device should

3) Mock chemical containers intended as a training prop, should not contain any live product, and shouldbe conspicuously marked TRAINING.

4) A log should be maintained of all mock weapons and explosives/IEDs, including a photo of each device.

5) Mock weapons and INERT explosives devices, and training chemical containers should be securedwhen not in use.


That proposed language (or language of similar intent) would provide a baseline standardized training safety guidelines across the hazmat/WMD community.






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7.X TRAINING RECORDS MANAGMENT 7.x.1 The HMRT program manager should ensure all training sessions and exercises are appropriatelydocumented.

Each training session should be documented to include the following information:

1) Date, time(s), and duration

2) Location the training was conducted

3) Instructor(s) providing the training

4) Training topic or exercise title

5) Overview of course content

6) Students that attended

7) Competencies that were demonstrated

8) Equipment or protective clothing that was used

9) Textbooks or reference material used

10) Funding source or grant tracking information as appropriate

7.x.2 Each hazmat exercise should include all the above relevent information, and also include the following

1. ICS role each student filled

2. Lessons learned

3. Corrective actions taken

7.x.3 Each student that succesfully completes a hazmat/WMD training course for awareness, operations,technician,incident commander, a mission specific compentency, or a speicalist training course shouldreceive a printed certificate of completion. The certificate of completion should include all of the followinginformation:

1.Student's name

2. Course title

3. Course date

4. Statement that the student has successfully completed the course

5. Standard, rule, or law the training session complied with

6. Name and address of the training provider

7. Signature of the instructor, program manager, or training director

7.x.4 The HMRT program manager should maintain a record of the individual NFPA 472 competenciesdemonstrated by each HMRT member on an annual basis.

7.x.4.1 Hazmat/WMD competencies may be demonstrated during a training, exercise, or actualhazmat/WMD incident.

7.x.4.2 Methods of documenting and tracking individual Hazmat/WMD competencies may include:

1. Development of skills checklist

2. Creating of HMRT task/log books

3. Utilizing a computerized database

7.x.5 All training records should kept for a minimum of at least five years, or a period of time determinedappropriate by the AHJ (OSHA 1910.120 Appendix E).


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Documentation is an extremely important part of hazmat training.

Current draft 475 langauge addresses records retention for medical records, incident deployments, and exposures, but does not address training records.

The suggested language would provide guidance and recommendations to HMRT program managers on what type of documentation should be created after a training/exercise, what elements should be included in the documentation, and how long the training records should be maintained. The language includes recommendations listed in OSHA 1910.120 Appendix E.






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Chapter 8 Resource Management8.1 Introduction.8.1.1 Purpose.

The purpose of this chapter is to provide information and guidance for hazardous materials/WMD responseteam (HMRT) program managers in understanding the aspects of managing various resources forhazardous materials/WMD response teams.8.1.2 Scope.

The acquisition and management of the various resources associated with hazardous materials responseteams (HMRT) is a critical factor in the effective management of an overall HMRT program. Effectiveresource management ensures that HMRTs have the personnel, equipment, and supplies necessary tosafely and effectively mitigate hazardous materials/WMD incidents. HMRT program managers shoulddevelop comprehensive resource management plans and procedures to ensure that teams are properlyresourced to meet program objectives.8.1.3 References.

(1) DHS NIMS Guide NG0001, National NIMS Resource Typing Criteria

(2) DHS NIMS Guide NG0002, National Credentialing Definition and Criteria

(3) DHS Resource Typing Document FEMA508-1-FEMA 508-4, Typed Resource Definitions — Fire andHazardous Materials Resources

(4) NFPA 1561, Standard on Emergency Services Incident Management System

(5) ASTM E-2640-10, Standard Guide for Resource Management in Emergency Management andHomeland Security

(6) 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER),Occupational Health and Safety Administration (OSHA)

8.2 Personnel.The recruitment and maintenance of personnel are critical aspects of the management of an HMRT. Thesuccess of meeting the mission of an HMRT is dependent on the proper recruitment, effective retention,and appropriate maintenance of team members. HMRT program managers should ensure that properpersonnel management procedures are developed and maintained as a component of team operatingpractices.8.2.1 Recruitment.

Recruitment of team members is determined by the mission requirements of the HMRT and availablepersonnel resources. Response to hazardous materials/weapons of mass destruction incidents isconsidered a specialized discipline and might only be of interest to certain people. HMRT programmanagers should define personnel needs and assign resources to personnel for recruitment and retentionactivities as needed.8.2.2 Types of HMRTs.HMRTs can vary in size and complexity based on a team’s mission and objectives. Teams can be single ormultijurisdictional, public or private industry, and/or variations on all of the above. How an HMRT isconfigured should be driven by the overall team mission but is also influenced by the source(s) andavailability of personnel, geography, political realities, obtainable resources, funding and other intrinsicinfluences.


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8.2.2.1 Dedicated Teams.Due to the professional competencies and job performance requirements of personnel needed to safelyand effectively manage hazardous materials/WMD incidents, the training requirements needed to achieveand maintain these competencies, and the specialized equipment and practices used in responding to suchincidents, most HMRTs maintain a team of dedicated personnel. Dedicated teams are configured in variousways to include the following:

(1) Single jurisdiction/single agency or organization: HMRT team members are recruited andmaintained solely from personnel within the specific agency, jurisdiction, or organization that ismaintaining the HMRT.

(2) Private/industrial sector: HMRT team members are employees of a private business or industry thatelects to maintain hazardous materials response capabilities for business operations and continuitypurposes and/or to respond off site to incidents that involve the company’s products or services.

(3) Multijurisdictional/multiagency: HMRT team members are recruited and maintained from a pool ofpersonnel from two or more agencies, jurisdictions, and/or organizations that cover a single ormultijurisdictional geographic area. Often referred to as regional teams, these types of HMRTs oftenpool personnel, equipment, funding, and other necessary resources into a single team to mitigatehazardous materials/WMD incidents over a multijurisdictional geographic area.

(4) Combination teams: HMRTs can recruit and maintain members from both public agencies andprivate industry, forming a combination team.

8.2.3 Core Capabilities (Team).Based on the assigned mission of the HMRT, a specific set of core team capabilities should be developedbased on available personnel, resources, and funding support.8.2.3.1

Various internal and external influences shape the mission of an HMRT. HMRT program managers shouldassess these influences to determine the mission and scope of team operations and develop a plan forstaffing the HMRT based on these factors.8.2.3.2

Community support is an important influence on an HMRT’s overall mission and by relation, affectspersonnel recruitment and retention decisions when managing HMRTs.8.2.3.3

Funding has both direct and indirect effects on team personnel decisions. Personnel who are reimbursedfor team activities might be one of the largest line items in an HMRT budget. Careful planning is required inorder to match available funding to personnel resources and the overall HMRT mission.8.2.4 Core Capabilities (Members).29 CFR 1910.120, Hazardous Waste Operations and Emergency Response , is a federal regulation thatdictates personnel management and training requirements for HMRT personnel. Under this regulation,HMRT program managers have legal requirements for the training and maintenance of capabilities of theirteam members.8.2.4.1 NFPA 472, Standard for Competence of Responders to Hazardous Materials/Weapons of MassDestruction Incidents , NFPA 473, Standard for Competencies for EMS Personnel Responding toHazardous Materials/Weapons of Mass Destruction Incidents , and NFPA 1072, Standard for HazardousMaterials/Weapons of Mass Destruction Emergency Response Personnel Professional Qualifications, allprovide competencies and job performance requirements for personnel assigned to respond to hazardousmaterials/WMD incidents. HMRT program managers should be guided by these documents whendeveloping core competencies for HMRT members.8.2.4.1.1

HMRTs can recruit and maintain subject matter experts (SME) to assist them with specialized aspects ofteam responses and training. The SME might or might not be a fully trained and qualified team memberand can only be used for specific purposes. One common example is the use of a chemist to assist withresearch and planning during responses.


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8.2.4.1.2 By definition and practice, personnel are considered to be HMRT resources. In 2005, the United StatesDepartment of Homeland Security developed and published a National Mutual Aid and ResourceManagement Initiative , which was designed to support the National Incident Management System (NIMS)by establishing a comprehensive, integrated national mutual aid and resource management system thatprovides the basis to type, order, and track all federal, state, and local response assets. Within theseguidance documents resource typing for hazmat entry team personnel is defined within DHS ResourceTyping Document FEMA508-1-FEMA 508-4, Typed Resource Definitions — Fire and Hazardous MaterialsResources.8.2.4.1.3

Personnel credentialing is defined within DHS NIMS Guide NG0002, National Credentialing Definition andCriteria, which provides credentialing requirements for personnel ordered as single resources or personnelassigned to teams and crew assigned to equipment listed within the tier one NIMS national resource typingdefinitions. Credentialing of personnel is a voluntary process and only relates to deployable resources forinterstate mutual aid responses. It is recommended that HMRT program managers be familiar with NIMScredentialing requirements.8.2.4.1.4

Various federal regulations, guidance documents, voluntary standards, and recommended practicesprovide criteria for the recruitment, development, and training of HMRT personnel. Team personnel shouldbe assigned specific roles and responsibilities based on their training specialties, experience, andcapabilities. HMRT program managers should be familiar with these documents and use them in makingpersonnel management decisions.8.2.5 Deployment.As influenced by an HMRT’s mission, responsibilities, geographic cover area, regulations, and othervarious factors, HMRT program managers must anticipate and properly prepare for team deployments.HMRT deployments vary in length and complexity and require that HMRT program managers performappropriate predeployment planning.8.2.5.1

Dependant on the type and size of the HMRT, deployments present the HMRT program manager withstaffing needs and challenges. 29 CFR 1910.120, Occupational Health and Safety Administration (OSHA)Hazardous Waste Operations and Emergency Response, requires that personnel with specific training andcompetencies be present during emergency responses. HMRT program managers are responsible toensure that properly trained and qualified personnel are present in the correct numbers to meet this federalregulation.8.2.5.2

Based on the type of HMRT, staffing capabilities, compliance with regulatory requirements, budgetconsiderations, and other factors, HMRT program managers should develop deployment models to ensurethat the proper personnel resources are deployed during responses to emergency incidents. These modelsshould be published in HMRT procedural documents, and team members should be familiar with theirpersonal responsibilities within the HMRT models.8.2.5.3 Dependant on the type and size of hazardous materials/WMD incidents, HMRT program managers mustbe prepared to sustain incident operations over long periods. Incidents that are to be sustained for greaterthan one operational period will likely require relief of on-scene personnel and should be anticipated by theHMRT program manager.8.2.5.3.1

The first choice of most HMRT program managers is to relieve team personnel with other team members.Personnel rotations should be anticipated far in advance, and HMRT program managers should havesystems in place for the recall of off-duty personnel.8.2.5.3.2

Mutual aid resources are another source of relief for on-scene personnel. HMRT program managers shouldbe familiar with existing mutual aid systems and available resources prior to calling for these resources tosustain operations at an existing emergency incident. Some mutual aid relationships might require advanceagreements outlining the provision of and sharing of services prior to deploying to incidents.


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8.2.5.3.3 Local and regional resources can be another source of personnel to sustain or enhance incidentoperations. These can include other emergency services agencies, private hazardous materials teams,military units proficient in hazardous materials response, and other like resources. HMRT programmanagers should be familiar with these types of resources prior to requiring assistance from such services.8.2.5.3.4

The Emergency Management Assistance Compact (EMAC) was established by Congress in 1996 andserves as a national state-to-state mutual aid system. HMRTs are subject to EMAC requests and can berequested to deploy to large-scale events of national significance. HMRT program managers should befamiliar with the EMAC system and seek guidance from their superiors as to whether their team is to bedeployed within this compact.8.2.5.4 Demobilization: HMRT program managers should develop and maintain demobilization plans as part oftheir team practices and documentation.8.2.5.4.1

Record keeping is an important part of HMRT deployments. Based on the type, length, and complexity ofthe incident, team members might have to produce documentation after the incident including, but notlimited to, incident action plans (IAP), entry and medical records, payroll records, maintenance records, andso forth. HMRT program managers should develop record keeping requirements and systems prior to teamdeployments and maintain a system for the collection and review of such documentation followingdeployments.8.2.5.4.2

HMRT program managers should develop a process conducting a post-incident analysis followingdeployment to emergency incidents. A post-incident analysis provides HMRTs with the ability to review theirincident operations and provide for the ability to improve future team operations.8.2.6 Compensation and Benefits.When applicable, the management of HMRT personnel must include provisions for compensating teammembers and providing for their assigned benefits. HMRT program managers should develop informationon the compensation and benefit requirements of team members and budget accordingly. Budgeting forcompensation should include anticipating the deployment of team members and incurring associatedovertime costs.8.2.6.1

HMRT members can work under collective bargaining agreements that specifically outline compensationand benefit requirements, inclusive of overtime provisions and working conditions. HMRT programmanagers with personnel working within collective bargaining agreements should be familiar with theprovisions contained in these agreements and their associated responsibilities in managing thesepersonnel.8.2.6.2

Some team members might be subject to nonmonetary compensation for team activities. These caninclude compensation (comp) time and or the ability to work variable hours to meet team needs in lieu ofworking their normal assigned work schedule.8.2.6.3

Many HMRT members are covered under workers compensation regulations. If a team member suffers aduty-related injury, the HMRT program manager or his or her designee might be responsible for filing initialreporting documentation and managing the worker’s compensation case to a conclusion.8.2.7 Member Maintenance.Responses to hazardous materials and/or WMD incidents must include provisions to ensure the well-beingof responders before, during, and after their designated actions are executed. Member maintenanceincorporates a number of subcategories that in aggregate are designed to address the legal requirementsset forth in applicable standards, but beyond the letter of the law are designed to ensure the well being ofteam members. Incorporated in this topic are OSHA’s HAZWOPER Standard, 29 CFR1910.120, OSHA'srespiratory protection standard, 29 CFR1910.134, and OSHA's access to employee exposure and medicalrecords standard, 29 CFR1910.1020, as well as an employer’s internal standards regarding the subject.8.2.7.1 Respiratory Protection Program.


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29 CFR 1910.134(c) requires that an employer develop and implement a written respiratory protectionprogram when workplace conditions require the use of a respirator to protect the health of the employee;HAZMAT teams fall under this requirement. The respiratory protection program must be administered byan appropriately trained/experienced individual and must address respirator selection, annual fit testingprocedures, breathing air quality, procedures for use, care, and cleaning of respirators, training ofemployees, evaluation of program effectiveness, and medical evaluations to determine the employees’ability to don the respirator required.8.2.7.1.1

It should be noted that the requirements for use of a respirator (1910.134), (i.e., the annual respiratorevaluation) do not require the employee to perform an annual medical examination. However, OSHAplaces the responsibility on the employer and the examining health care professional to determine thefrequency and content of medical evaluations for each employee. Type and content of medical evaluationswill depend on the strenuousness of the work being performed, the type and frequency of respirator use,and the physical and medical condition of the employee (as determined by the evaluating physician), aswell as any physical and medical issues reported by the employee.8.2.7.2 Medical Surveillance.29 CFR1910.120(a)(1)(i) through (a)(1)(iv) (where no exceptions exist) define the operational arenas inwhich employees fall under the routine medical surveillance program. Section(q)(9) of the standardincorporates hazmat team members and mandates the minimum requirements for anorganization’s/employer’s medical surveillance program. It should be noted that the type of medicalsurveillance is based on roles filled during a response. Not all personnel have to have the same type ofmedical surveillance. However, this is a nonissue when all members of the team are trained to the samelevel (use of level A for example). Medical surveillance is an annual requirement, unless the attendingphysician believes a longer interval is acceptable. In no case can the period between physicals exceed 2years.8.2.7.2.1

OSHA requires anyone who leaves the hazmat team (for any reason) to have a physical examination upondeparture, unless an annual (or biennial) physical was conducted within 6 months of exiting, in which caseit can be used to fulfill the requirement.8.2.7.2.2

Medical examinations, including what might be in existence in an employee’s file (which should be regularlyupdated) must be conducted with detailed emphasis related to the handling of hazardous materials andtheir accompanying health hazards, as well as fitness for duty, including the ability to wear PPE that mightbe required.8.2.7.3 Recording Keeping.Record keeping is addressed in 1910.120(f)(8), and retention periods specified in 29 CFR 1910.1020(d)(1)(i) and (d)(1)(ii) require that medical records and exposure records, respectively, be retained for 30years beyond termination of employment (with some minor exceptions).8.2.7.3.1

The record must include at a minimum the following:

(1) Name and social security number of the employee

(2) Physician’s written opinions, recommended limitations, and results of examinations and tests

(3) Any employee medical complaints related to exposure to hazardous substances

(4) A copy of the information provided to the examining physician by the employee

(5) Place holder for example record

8.2.7.4 Personnel Exposures.In the case of exposure or injury resulting from response, employers must immediately upon notification byan employee that they are presenting with signs or symptoms of exposure (suggesting a possibleoverexposure to hazardous substances or exposure above permissible limits) provide the employee accessto additional medical surveillance.


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8.2.7.5 Treatment.Employees who undergo treatment for an exposure or injury receive said treatment at no cost to them, withno loss of pay. Treatment should be performed by or under the supervision of a licensed physician at areasonable time and place.8.2.7.6 Follow-up.

Follow-up medical surveillance and/or treatment must be provided as determined to be necessary by theexamining physician. Additional medical surveillance could also be required under 29 CFR 1910 Subpart Z(Substance Specific Standards) depending on the nature and extent of the exposure.8.3 Supply Management:Response to hazardous materials and or weapons of mass destruction incidents normally requires the useof various supplies to support incident operations. Supplies are defined as non-equipment-relatedresources (e.., pH paper or colorimetric tubes) that an HMRT needs to complete a mission.8.3.1 Acquisition and Maintenance.The acquisition and maintenance of supplies is a key aspect of managing an HMRT. It is important thatHMRTs be properly stocked with needed supplies and that these supplies be properly maintained.8.3.1.1

HMRT supplies can be significant in scope, number, and size, dependant on the HMRT size and mission.HMRT program managers should identify needed supplies and storage location(s) for those supplies anddevelop a maintenance plan for managing team supplies.8.3.1.2

Supplies can be stored and maintained in various locations including team facilities, response vehicles,vendor warehouses, and or storage buildings (e.g., sheds).8.3.1.3

Maintenance of HMRT supplies is a critical process that can be time consuming. HMRT program managersshould identify and enlist qualified team members to manage this responsibility for the team. This positionis often referred to as the team quartermaster.8.3.1.4

Some supplies might have a defined shelf life. These types of supplies should be clearly identified, and theHMRT should have a defined process for the management and restocking of such items. Supplies thathave a defined shelf life and or older stock that might be dated should be identified for first use at incidents.This permits HMRTs to avoid having to discard unused or out of date supplies. Another method of rotatingsupplies is to use dated or out of date supplies during training exercises.8.3.1.5

HMRT program managers should ensure that policies, procedures, and/or processes are developed anddocumented for the proper management of team supplies. These documents should account for vendoridentification and relations, purchasing practices, inventory management, restocking, storage, and otherpertinent information.8.3.2 Vendor Identification.Supplies related to hazardous materials and/or WMD incident response might be of a specialized naturewith a limited number of vendors available for the purchase of such items. HMRT program managersshould ensure that vendors are identified for all supplies maintained by the team and that vendorrelationships are established to provide for the quick and efficient restocking of expended supplies.8.3.2.1

The purchase of HMRT supplies might be subject to municipal and/or organizational purchasing laws,regulations, and/or processes. HMRT program managers and personnel assigned to manage teamsupplies should be familiar with the specific purchasing oversight that affects the HMRT and abide by thepertinent requirements that guide such purchases.8.3.2.2

Vendors should be identified in advance when possible. Many government regulations and industrypurchasing practices require vendors to be identified in advance and approved for use. HMRT programmanagers must be aware of such requirements and ensure that vendors are prequalified and approved toavoid delays in purchasing needed supplies.


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8.3.2.3 Various government and industry purchasing practices also require that standing purchasing agreementsbe developed and maintained with approved vendors. This process can involve competitive biddingactivities and require that formal, contractual relationships be developed with vendors. This can be atime-consuming and convoluted process. HMRT program managers should seek assistance frompurchasing professionals and ensure that such requirements are met prior to supplies needing to bereplenished.8.3.3 Resupply and Restock.HMRT program managers should develop internal processes to ensure that team supplies are properlyidentified and maintained and that restocking of supplies can be done quickly and efficiently.8.3.3.1

A standard inventory of required supplies should be developed and maintained for use by HMRTs. Thisinventory should be reviewed and updated periodically to ensure that it meets team requirements and is upto date with team practices and equipment.8.3.3.2

Various state and local laws permit HMRTs to be reimbursed for use of supplies by responsible parties.HMRT program managers should be familiar with the laws or regulations pertinent to their responsemission and maintain internal processes for documenting supplies used and billing responsible parties afterresponse to incidents.8.3.3.3

Certain supplies can be critical to the operation of the team when on a mission. These types of suppliesshould be identified and maintained in proper numbers. Critical supplies should be noted as such ininventory systems, and a process for the rapid restocking of such supplies should be developed by theHMRT.8.3.4 Record Keeping.Proper documentation of inventory and use is an important aspect of supply management. A thorough andcomplete record keeping system should be established and maintained by HMRT program managers toensure that supply management is properly documented.8.3.4.1

Computerized inventory systems can be available for use. HMRT program managers should assess suchsystems to determine suitability for their team.8.3.4.2

Some supplies could be subject to being funded through various federal, state, and or local programs.Supplies that are purchased through these funding streams can be subject to additional record keeping andauditing requirements.8.3.5 Storage.

Supplies should be stored and maintained in suitable facilities. Many HMRTs maintain their supplies in thesame facilities as team apparatus to facilitate restocking after responses or training. Regardless of location,supply storage facilities should be secure and appropriate for the type and amount of supplies beingmaintained. Some supplies can require storage in climate-controlled conditions.8.3.6 Transportation.

During some responses, HMRTs can require that additional supplies be transported to incident scenes forrestocking during an active mission. Supplies might also have to be transported from remote storagelocations to team facilities under routine circumstances. HMRT program managers should anticipate suchneeds and develop plans to manage both routine and nonroutine supply transportation needs.8.4 Equipment.8.4.1 Identify Equipment Needs.


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HMRT program managers must realize the depth and breathe of securing and maintaining the necessaryequipment in preparation for hazardous material/WMD response. The HMRT program manager mustunderstand the essential equipment, proper maintenance of equipment, and updating requirements toreflect technological changes with equipment. Providing the necessary equipment for responders is criticalbased upon hazard identification and risk assessment of the event. Field testing and detection, airmonitoring, sampling, radiation monitoring/detection, chemical protective clothing, ancillary protectiveequipment, technical reference, special capabilities, intervention, decontamination, communications,respiratory protection, and hand tools are all critical components to outfitting an HMRT response team. Thefollowing list provides some of the potential equipment needs and requirements for an incident:

(1) Field testing and detection.

(2) Color change analysis — nonelectronic

(3) Qualitative analysis, kits — nonelectronic

(4) Qualitative analysis, kits — electronic

(5) Colorimetric analysis — nonelectronic

(6) WMD biological detection — electronic

(7) Air monitoring

(8) Confined space monitoring

(9) Multiple gas monitoring, toxic

(10) Specialty as capability

(11) WMD chemical dedicated instruments

(12) Sampling

(13) Substance capture

(14) Bulk liquid transfer — mechanical

(15) Containerization, labeling, documentation

(16) Transportation

(17) Radiation detection and monitoring

(18) Gamma, beta, and alpha detection and survey

(19) Radionuclide detection

(20) Dosimeters

(21) Chemical protective clothing

(22) Vapor protective

(23) Liquid splash protective

(24) Limited use protective


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(25) Ancillary protective equipment

(26) Hand protection

(27) Foot protection

(28) Head and eye protection

(29) Support systems

(30) Technical reference

(31) Printed references, industrial and WMD chemicals

(32) Electronic references, industrial and WMD chemicals

(33) Plume air modeling, program support

(34) Computer, support hardware, software

(35) Special capabilities

(36) Advanced Technologies: vision, heat, sound

(37) Advanced technologies: weather, GPS

(38) Intervention

(39) Chemical intervention

(40) Environmental intervention

(41) Mechanical intervention

(42) Decontamination

(43) Ground protection

(44) Support tools for decontamination

(45) Water supply, distribution tools

(46) Collection

(47) Communications

(48) Radio

(49) Cellular phone

(50) Respiratory protection

(51) Self-contained


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(52) Air purifying respirator

(53) Tools and other equipment

(54) General purpose, large hand tools

(55) General purpose, small hand tools

(56) Special purpose hand tools

8.4.1.1 The HMRT program manager can also include other noncritical equipment for the response team.8.4.2 Identification of Funding Streams.

The HMRT program manager must realize the cost of acquiring the necessary equipment and effectiveresource management to properly prepare a response team. Although certain grant programs, such as theAssistance to Fire Grants, are available, the program guidance for each funding source varies from year toyear. The HMRT program manager must prepare to properly fund, maintain, and update a response team.Securing consistent funding is an important aspect of HMRT management.8.4.3 Initial Purchase/Acquisition.The HMRT program manager must understand the response team typed resource credentialing. The initialpurchase of equipment must be aligned with the recommended minimum equipment list. The standardizedequipment list (SEL) is provided for the purpose of being used as a tool by the emergency responsecommunity. The HRMT program manager should review this SEL when preparing to develop equipmentspecifications and purchase orders, creating or updating local master hazardous materials equipmentinventory lists, and reviewing requirements for hazardous materials/WMD chemical-biological responseequipment grants. The SEL is a reference document only and should be used as a guide in an attempt tomeet the minimum level of standardization.8.4.3.1

Purchasing equipment for a hazardous materials response must adhere to standardization. The HMRTprogram manager must adopt standardization and follow proper purchasing regulations to ensure thesafety of personnel, provide protection to the public, and maintain effective emergency response.8.4.3.2

The HMRT program manager must follow the recommended purchasing agreements, as covered under arecommended authority, and purchase all equipment from approved, authorized vendors.8.4.3.3

To properly maintain a response team, the HMRT program manager must secure and maintain standingpurchase agreements with approved vendors. Delays in purchasing can affect the safety and response ofthe team.8.4.4 Sustainment.In order to properly prepare and sustain a response team, the HMRT program manager must constantlymaintain the necessary equipment. Daily checks of equipment, functionality, operation, and confirmingexpiration dates is critical to the proper state of readiness of the team. Equipment must be properly stored,charged, and at the ready. Proper replacement plans must be developed and instituted. The replacementschedule must be reviewed to coordinate financial measures through the budgetary process. Maintenanceagreements must be organized and secured. Arrangements should be in place, when certain equipmentmight be out of service for calibration or other replacement or repair needs.8.4.4.1

A coordinated, scheduled replacement plan must be developed and maintained.


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8.4.4.2 Maintenance agreements must be entered and followed to maintain the proper functioning of all equipment.These agreements must be carefully scheduled in order to maintain a proper state of readiness. Planningand creative scheduling of equipment under maintenance agreements will ensure the proper responselevel.8.4.4.3

Equipment must be purchased in a timely manner and must be purchased through approved, certifiedvendors. A positive relationship with the vendor is advisable. Keeping equipment in top notch functioningorder is critical to the mission of the response team.8.4.4.4

Maintenance practices are an essential component in preparation for a response to an emergency. TheHMRT program manager must establish and maintain a checklist procedure to ensure all equipment is inworking order. Team members must take pride and ownership of the equipment, and daily routines must beadhered to and followed precisely, as outlined by the HMRT program manager.8.4.5 Purchasing.The HMRT program manager must develop and adhere to strict policies and procedures whenimplementing the purchasing of all equipment. Ensuring that the team is properly prepared with essentialresources in place maximizes the safety and security of responders and the public at large.8.4.5.1

Rating and comparing equipment are critical to the mission of the emergency response. Approvedequipment and vendor purchasing agreements should be in place and updated as necessary.8.4.5.2

There are various categories the HMRT program manager must consider while purchasing equipmentincluding motorized, prime movers, fixed, portable, disposable, date sensitive, and so forth.8.4.5.3

The HMRT program manager must gain an understanding of the coordinated effort between the use of theresponder knowledge base, training needs, and the recommended use of all equipment. Allowing forscheduled training needs, including technological updates, component add-ons, new equipment purchases,and new technologies will enhance the response readiness.8.4.5.4

It is important for the HMRT program manager to realize that the true cost of equipment goes beyond thatof the initial purchase. Maintenance procedures and manufacturer’s requirements including calibrationprocedures, equipment, and supplies, must be considered prior to purchasing the resources for the team.Maintaining a proper maintenance schedule, replacement schedule, and updates must be planned forthrough the budgetary process.8.4.6 Instruments.

The HMRT program manager must consider acquiring the required equipment and resources to maintainthe readiness of the team. This would include inventories of various instrumentation including, but notlimited to, field testing, air monitoring, detection and radiation monitoring, and detection equipment.Identification and sampling equipment, special capabilities, and field interventions must be secured.8.4.7 PPE/CPE.

The HMRT program manager is responsible for the safety of all team members and proper acquisition of allPPE, and chemical protective clothing (CPE), including all necessary ancillary protective equipment, mustbe a priority. All PPE must meet or exceed the highest standards possible, including respiratory protectiveequipment.8.4.8 Resource Typing.

In order to assure an organized approach to incidents involving hazardous materials emergencies, theHMRT program manager must adhere to certain resource typing credentialing. Standardized typedresource management is essential in developing mutual aid response plans and interagency operability.Technical reference materials, decontamination equipment, communications equipment, tools, andcomponents of an effective team are critical to the mission.8.4.9 Resupply and Restock.HMRT program managers should develop internal processes to ensure that team supplies are properlyidentified and maintained and that restocking of supplies can be done quickly and efficiently.


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8.4.9.1 Proper documentation of inventory and use is an important aspect of resource and equipmentmanagement. A thorough and complete recording keeping system should be established and maintainedby HMRT program managers to ensure that equipment management is properly documented.8.4.9.2

Some equipment can be subject to being funded through various federal, state, and or local programs.Equipment that is purchased through these funding streams can be subject to additional documentation,reporting, and auditing requirements.8.4.9.3

Decontamination equipment is designed with proper configurations of the incident in mind. Preparing forand designing a decontamination unit to fully protect the public and first responders is critical to themission.8.4.9.4

Equipment should be stored and maintained in suitable facilities, and trailers and prime movers must bededicated to the response. Many HMRTs maintain their equipment in the same facilities as team apparatusto facilitate restocking after responses or training. Regardless of location, equipment storage facilitiesshould be secure and appropriate for the type and amount of equipment being maintained. Certainequipment will require storage with charging/re-charging capabilities and climate-controlled conditions.8.5 Incident Management.8.5.1 National Incident Management System (NIMS).

The NIMS command and management component of the National Incident Management System (NIMS)stresses effective and efficient incident management and coordination through the use of a flexible,standardized incident management structure. This structure should include these three key organizationalconstructs: the incident command system, multiagency coordination systems, and public information.8.5.2 NIMS Resource Management.

NIMS also emphasizes that careful management of resources is essential before, during, and afterincidents. NIMS emphasizes standardized resource management practices such as typing, inventorying,organizing, and tracking to allow for effective sharing and integration of critical resources acrossjurisdictions.8.5.3 Preparedness and Response.

In accordance with NIMS, the resource management process can be separated into two parts: resourcemanagement as an element of preparedness and resource management during an incident. Thepreparedness activities (resource typing, credentialing, and inventorying) are conducted on a continualbasis to help ensure that resources are ready to be mobilized when called to an incident. Resourcemanagement during an incident is a finite process, as shown in Figure 8.5.3 , with a distinct beginning andending specific to the needs of the particular incident.Figure 8.5.3 Resource Management During An Incident Is A Finite Process

8.5.4 Incident Response.Hazardous materials response personnel should be proficient in the management of resources prior to,during, and following incident responses in accordance with NFPA 472, Standard for Competence ofResponders to Hazardous Materials/Weapons of Mass Destruction Incidents .


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8.1.1 Purpose.The purpose of this chapter is to provide information and guidance for hazardous materials/WMD responseteam (HMRT) program managers in understanding the aspects of managing various resources forhazardous materials/WMD response teams.

Chapter 8, Section 8.1 Training

General Comment: There is a host of information available for emergency service training programs and itwould be appropriate for this chapter to cite the Professional Qualifications series material covering thistopic.


JustificationThis chapter provides a comprehensive overview of training programs. Yet, there is no mention of the many standards and accreditation requirements already established in the NFPA professional qualifications project. For example, the validity and reliability of any training program can be measured by a system of outcome based assessment. NFPA 1000 is the Professional Qualifications document for Accreditation and Certification systems. This standard establishes the criteria organizations such as the National Board on Fire Service Professional Qualifications and the International Fire Service Accreditation Congress follow to accredit entities so that certification standards can be assessed. This document also sets the parameters by which accredited entities can issue certifications signifying that candidates have successfully demonstrated competency as required. The value of assessment as a form of establishing validity and reliability is not included in NFPA 475 and should be included.Additionally, a Professional Qualifications document exists that establishes the job performance requirements for emergency services instructors. NFPA 1041 is a long-standing consensus standard that, through the NFPA process, has identified the knowledge, skills and abilities that emergency service instructors should demonstrate through a valid and reliable assessment process in order to serve in the role of instructor. Some, but not all of these job performance requirements are described in 475. NFPA 1041 should be recognized within 475 as the preferred method for establishing instructor qualifications.Finally, there is overlap between NFPA 475 and NFPA 1041 and NFPA 475 and NFPA 1072 that should be referred to the Correlating Committee to determine under which document’s scope covers the debated material.


Submitter Full Name: ALLAN RICE

Organization:Affilliation: North American Fire Training Directors



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8.1.2 Scope.The acquisition and management of the various resources associated with hazardous materials responseteams (HMRT) is a critical factor in the effective management of an overall HMRT program. Effectiveresource management ensures that HMRTs have the personnel, equipment, and supplies necessary tosafely and effectively mitigate hazardous materials/WMD incidents. HMRT program managers shoulddevelop comprehensive resource management plans and procedures to ensure that teams are properlyresourced to meet program objectives.(There is a host of information available for emergency service training programs and it would beappropriate for this chapter to cite the Professional Qualifications series material covering this topic.)


This chapter provides a comprehensive overview of training programs. Yet, there is no mention of the many standards and accreditation requirements already established in the NFPA professional qualifications project. For example, the validity and reliability of any training program can be measured by a system of outcome based assessment. NFPA 1000 is the Professional Qualifications document for Accreditation and Certification systems. This standard establishes the criteria organizations such as the National Board on Fire Service Professional Qualifications and the International Fire Service Accreditation Congress follow to accredit entities so that certification standards can be assessed. This document also sets the parameters by which accredited entities can issue certifications signifying that candidates have successfully demonstrated competency as required. The value of assessment as a form of establishing validity and reliability is not included in NFPA 475 and should be included.Additionally, a Professional Qualifications document exists that establishes the job performance requirements for emergency services instructors. NFPA 1041 is a long-standing consensus standard that, through the NFPA process, has identified the knowledge, skills and abilities that emergency service instructors should demonstrate through a valid and reliable assessment process in order to serve in the role of instructor. Some, but not all of these job performance requirements are described in 475. NFPA 1041 should be recognized within 475 as the preferred method for establishing instructor qualifications.Finally, there is overlap between NFPA 475 and NFPA 1041 and NFPA 475 and NFPA 1072 that should be referred to the Correlating Committee to determine under which document’s scope covers the debated material.


Submitter Full Name: Lawrence Preston

Organization: Maryland Fire and Rescue Inst.

Affilliation: Maryland Fire and Rescue Institute

Street Address:City:State:Zip:Submittal Date: Fri Dec 19 11:20:14 EST 2014


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8.1.2 Scope.The acquisition and management of the various resources associated with hazardous materials responseteams (HMRT) is a critical factor in the effective management of an overall HMRT program. Effectiveresource management ensures that HMRTs have the personnel, equipment, and supplies necessary tosafely and effectively mitigate hazardous materials/WMD incidents. HMRT program managers shoulddevelop comprehensive resource management plans and procedures to ensure that teams are properlyresourced to meet program objectives.

(The State of Wisconsin Fire Service Training Office feels there is a host of information available foremergency service training programs and it would be appropriate for this chapter to cite the ProfessionalQualifications series material covering this topic.)


This chapter provides a comprehensive overview of training programs. Yet, there is no mention of the many standards and accreditation requirements already established in the NFPA professional qualifications project. For example, the validity and reliability of any training program can be measured by a system of outcome based assessment. NFPA 1000 is the Professional Qualifications document for Accreditation and Certification systems. This standard establishes the criteria organizations such as the National Board on Fire Service Professional Qualifications and the International Fire Service Accreditation Congress follow to accredit entities so that certification standards can be assessed. This document also sets the parameters by which accredited entities can issue certifications signifying that candidates have successfully demonstrated competency as required. The value of assessment as a form of establishing validity and reliability is not included in NFPA 475 and should be included.Additionally, a Professional Qualifications document exists that establishes the job performance requirements for emergency services instructors. NFPA 1041 is a long-standing consensus standard that, through the NFPA process, has identified the knowledge, skills and abilities that emergency service instructors should demonstrate through a valid and reliable assessment process in order to serve in the role of instructor. Some, but not all of these job performance requirements are described in 475. NFPA 1041 should be recognized within 475 as the preferred method for establishing instructor qualifications.Finally, there is overlap between NFPA 475 and NFPA 1041 and NFPA 475 and NFPA 1072 that should be referred to the Correlating Committee to determine under which document’s scope covers the debated material.


Submitter Full Name: PETER SILVA

Organization: WISCONSIN TECH COLLEGE SYST



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8.2.7.2.1 OSHA requires anyone who leaves the hazmat team (for any reason) to have a physical examination upondeparture, unless an annual (or biennial) physical was conducted within 6 months of months after exiting,in which case it can be used to fulfill the requirement.


The statement "within 6 months of exiting" could be interpreted as either within 6 months prior or 6 months after. A medical examination which is conducted before exiting the HMRT could miss a condition which resulted from an HMRT response after the medical but before exiting the team. The statement should be changed to "within 6 months AFTER exiting the HMRT" or be caveated with "and in all cases AFTER any HMRT response." It is understood that his may be a direct quote from the regulation; however consideration should be given to changing it.






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HMRT program managers must realize the depth and breathe of securing and maintaining the necessaryequipment in preparation for hazardous material/WMD response. The HMRT program manager mustunderstand the essential equipment, proper maintenance of equipment, and updating requirements toreflect technological changes with equipment. Providing the necessary equipment for responders is criticalbased upon hazard identification and risk assessment of the event. Field testing and detection, airmonitoring, sampling, radiation monitoring/detection, chemical protective clothing, ancillary protectiveequipment, technical reference, special capabilities, intervention, decontamination, communications,respiratory protection, and hand tools are all critical components to outfitting an HMRT response team. Thefollowing list provides some of the potential equipment needs and requirements for an incident:

(1) Field testing and detection.

(2) Color change analysis — nonelectronic

(3) Qualitative analysis, kits — nonelectronic

(4) Qualitative analysis, kits — electronic

(5) Colorimetric analysis — nonelectronic

(6) WMD biological detection — electronic and/or nonelectronic

(7) Air monitoring

(8) Confined space monitoring

(9) Multiple gas monitoring, toxic

(10) Specialty as capability

(11) WMD chemical dedicated instruments

(12) Sampling

(13) Substance capture

(14) Bulk liquid transfer — mechanical

(15) Containerization, labeling, documentation

(16) Transportation

(17) Radiation detection and monitoring

(18) Gamma, beta, and alpha detection and survey

(19) Radionuclide detection

(20) Dosimeters

(21) Chemical protective clothing

(22) Vapor protective

(23) Liquid splash protective

(24) Limited use protective

(25) Ancillary protective equipment

(26) Hand protection

(27) Foot protection

(28) Head and eye protection


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(29) Support systems

(30) Technical reference

(31) Printed references, industrial and WMD chemicals

(32) Electronic references, industrial and WMD chemicals

(33) Plume air modeling, program support

(34) Computer, support hardware, software

(35) Special capabilities

(36) Advanced Technologies: vision, heat, sound

(37) Advanced technologies: weather, GPS

(38) Intervention

(39) Chemical intervention

(40) Environmental intervention

(41) Mechanical intervention

(42) Decontamination

(43) Ground protection

(44) Support tools for decontamination

(45) Water supply, distribution tools

(46) Collection

(47) Communications

(48) Radio

(49) Cellular phone

(50) Respiratory protection

(51) Self-contained

(52) Air purifying respirator

(53) Tools and other equipment

(54) General purpose, large hand tools

(55) General purpose, small hand tools

(56) Special purpose hand tools


There are nonelectronic means of biological detection/idenification, such as bio-assays.



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8.4.5.1 Rating and comparing equipment are critical important to the mission of the emergency response.Approved equipment and vendor purchasing agreements should be in place and updated as necessary.


Critical is too strong of a word.






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8.4.6 Instruments.The HMRT program manager must consider acquiring the required equipment and resources to maintainthe readiness of the team. This would include inventories of various instrumentation including, but notlimited to, field testing, air monitoring and detection , detection and radiation and radiation monitoring , anddetection equipment. Identification and sampling equipment, special capabilities, and field interventionsmust be secured.


Typos/sentence structure errors in original statement.






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8.4.7 PPE/CPE CPC .The HMRT program manager is responsible for the safety of all team members and proper acquisition of allPPE, and chemical protective clothing (CPE CPC ), including all necessary ancillary protective equipment,must be a priority. All PPE must meet or exceed the highest standards possible, including respiratoryprotective equipment.


Corrects typo






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8.4.7 PPE/CPE.The HMRT program manager is responsible for the safety of all team members and proper acquisition of allPPE, and chemical protective clothing (CPE), including all necessary ancillary protective equipment, mustbe a priority. All PPE must meet or exceed the highest standards possible, including respiratory protectiveequipment possible standard consistent with the anticipated hazards and with the intended employment ofthe team .


The statement "All PPE must meet or exceed the highest standards possible" is a contradiction in terms- the "highest standard possible" implies that nothing could exceed the standard. If there is no standard to quote, the statement should be modified to read "the highest possible standard consistent with the anticipated hazards and with the intended employment of the team." For instance, a small town may have a team which is only intended to recognize and isolate a hazard while awaiting mutual aid or other resources






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8.4.9.4 Equipment should be stored and maintained in suitable facilities, and trailers and prime movers must bededicated to the response. Many HMRTs maintain their equipment in the same facilities as team apparatusto facilitate restocking after responses or training. Regardless of location, equipment storage facilitiesshould be secure and appropriate for the type and amount of equipment being maintained. Certainequipment will require storage with charging/re-charging capabilities and climate-controlled conditions.

Reviewer comment: This statement is repetitive of an earlier section.


This statement is redundant.






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Chapter 9 Staffing9.1 General.9.1.1 Introduction.9.1.1.1

This chapter provides information and guidance to the program manager in understanding staffingrequirements for different types of hazardous materials/WMD response teams and deployment models tomobilize those resources.9.2 General.9.2.1 Introduction.9.2.1.1

The HMRT program manager should determine the staffing levels necessary for the AHJ (locally andregionally) to determine the most effective way to deploy assets to events involving hazardousmaterials/WMD. This evaluation should include the following:

(1) Identify staffing requirements for the mission.

(2) Develop a plan for staffing.

(3) Identify requirements for sustainment of personnel.

9.2.1.2 Goal.9.2.1.2.1

The goal of this chapter is to provide guidance to the HMRT program manager to determine staffingrequirements relative to hazardous materials/WMD response. These challenges include evaluating currentand future staffing plans, deployment models, and team typing within the organization and/or regionally toassess the ability of the AHJ to meet the identified mission of hazardous materials/WMD response.


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9.2.2 Evaluating Deployment Models.


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Staffing solutions are complex, having both benefits and limitations for each staffing option. Response to ahazardous materials/WMD event requires familiarity with all resources (personnel, supplies, andequipment), including those from other jurisdictions or agencies. Deployment of these resources must takeinto consideration community risk assessment, response times, financial constraints, standard operatingprocedures/guidelines, automatic and mutual aid agreements, and other policies and procedures of theAHJ. Long-term plans for retention and recruitment should also be considered. Deployment models shouldbe developed in the best interest of the community. The deployment model can be developed by using thefollowing criteria:

(1) Determination of daily staffing levels based on community risk analysis relative to hazardousmaterials/WMD events.

(2) Assessment of deployment models:

(3) Dedicated staffing

(4) Hazardous materials responders assigned to specific unit

(5) Training might be easier to deliver and sustain

(6) Cross-staffed units

(7) Personnel with multiple response duties.

(8) Personnel assigned to more than one unit in a single location. Examples includepersonnel assigned to other response apparatus and a designated hazardous materialsresponse team. Nature of the response dictates staffing.

(9) Might allow for more flexibility in staffing.

(10) Multiple responsibilities can impact training and the ability to maintain

(11) Proficiency/competency in all required job duties.

(12) One type of response could leave the other unit (or discipline) unstaffed or on delayedresponse.

(13) Regional response teams

(14) Teams comprised of several organizations that respond to a specified geographic area,or a single organization with responsibilities for a particular geographic area.

(15) When made up of multiple organizations, personnel can respond to an assembly pointto gather tools, equipment, personnel and apparatus prior to response.

(16) Training/competency assessment can be more challenging due to interagencydynamics.

(17) Satellite units

(18) Personnel and resources assigned to a central location (fire stations, deploymentcenters, etc.) supplemented by other responders trained to various levels at nearbylocations.

(19) This deployment model places hazardous materials response personnel on scene inorder to start the size up and scene control process; however, it does not place all


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assets on scene at once. It allows for the determination of whether to call for additionalresources.

(20) Mutual aid:

(21) Agencies that provide or receive assistance to mitigate/manage hazardousmaterials/WMD incidents

(22) Contract:

(23) Private and public agencies can utilize outside contracts and/or contractors to augmentexisting response mechanisms or mitigate the incident on behalf of the community.

9.2.3 Resource Typing and Staffing.9.2.3.1

Resource typing (federal, state, or local) can have an impact on staffing in terms of daily staffing,deployment, program sustainment, and team member recruitment and retention. Team typing categorizesand describes resources by capacity and capability, includes measurable standards, and is intended toproduce an identifiable response to a hazardous materials/WMD incident.9.2.3.2

Resource typing can assist the HMRT program manager as well as on scene incident management bydoing the following:

(1) Enhancing emergency readiness

(2) Providing guidance in equipment purchasing and subsequent training

(3) Allowing incident commanders or emergency managers to identify, request, and track resources bytype

9.3 Specialty Personnel.9.3.1

HMRT program managers should be aware of other agencies (public and private) capable of providingpersonnel and/or specialized equipment to the incident or that could be otherwise available to the AHJ.These resources could come from private industry response teams military units such as Civil SupportTeams or United States Coast Guard National Strike Force, and specialized assets such as railroadresponse teams, pipeline experts, airline experts, and so forth. This pool of personnel and equipmentresources is constantly changing due to funding and/or other influences, but the HMRT program managersshould be aware of the availability of allied professionals. Chapter 9 of NFPA 472 offers detailedinformation on specialty employees and the conditions under which they could be utilized at a hazardousmaterials incident.





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9.3.1 HMRT program managers should be aware of other agencies (public and private) capable of providingspecialized personnel and/or specialized equipment to the incident or that could be otherwise available tothe AHJ. These resources could come from private industry response teams military units such as CivilSupport Teams or United States Coast Guard National Strike Force, and specialized assets such as railroadresponse teams, pipeline experts, airline experts, and so forth. This pool of personnel and equipmentresources is constantly changing due to funding and/or other influences, but the HMRT program managersshould be aware of the availability of allied professionals. Chapter 9 of NFPA 472 offers detailed informationon specialty employees and the conditions under which they could be utilized at a hazardous materialsincident.


As written, the emphasis is on specialized equipment, not personnel. As re-written, it implies both specialized equipment and specialized personnel.






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Chapter 10 Finances10.1 Overview.

Financial considerations might by one of the most challenging parts of any HMRT program. Hazardousmaterials response is costly for start-up, personnel, equipment, medical surveillance, as well as many otheraspects. The majority of cost will be personnel wages, equipment, apparatus, and training. Programmanagers will need a full understanding of their jurisdiction’s financial policies on budgets and purchasing.It will benefit every HMRT to have an internal strategic plan developed and updated regularly. The strategicplan should be the basis for budget justification and should identify current capabilities and gaps incapabilities and technology. While it need not be as lengthy or comprehensive as a department orjurisdictional strategic plan, it is recommended that it contain all the elements. The information in Chapter10 is meant to assist with financial considerations that go along with starting and sustaining a HMTR. It isfar from a complete list of every consideration for every team.10.2 Revenue Streams.Most HMRTs will find that the majority of their revenue will come from within their organizational operatingbudgets. For single jurisdiction teams, this will be part of the annual budget. For multijurisdictional teams,agreements that define the responsibilities for each jurisdiction will need to be completed. Programmanagers should be prepared to develop an annual budget request for line item funding for the revenuesto fund the required needs of the HMRT. Because of the constant competition for budget funding, programmanagers should be prepared to justify revenue request via the strategic plan. This should includepersonnel, supplies, services, capital, and non-capital cost. In addition to operational budgets, programmanagers should be looking for alternative methods of revenue streams that can assist in deferring to costof the HMRT that might be available.10.2.1 Department Operating Budgets

There are many different types of budgets in use by jurisdictions. It is imperative that the program managerbe intimately knowledgeable of the budget process that governs his or her HMRT. This source of fundingshould be the basis of the HMRT budget and cover the required funding needs. It should include allexpenditures that are required by law to operate or that have been identified as annual expenditures by theAHJ. Some common budget systems are as follows:

(1) Line-item budgets look much like a shopping list with each budget category provided on a list. Itallows for flexibility in expenditures based on needs.

(2) Zero-based budgets are best thought of as a “justification” budget. Each year the budget processstarts at zero dollars, and there is no balance brought forward from the preceding year. While itprovides a process for each program to be scrutinized and validated on a yearly basis, it is timeconsuming and difficult to forecast all expenditures.

(3) Program budgets are organized to the activities of the organization. The overall budget become asum of its programs and is a way to plan a budget and track expenditures.

10.2.2 Grant Programs.


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10.2.2.1 * Federal Grant Programs.There are a variety of grant programs available for first responders at the local, state, and federal levels.The National Preparedness Grant Program focuses on development and sustainment of capabilitiesoutlined in the National Preparedness Goal. Most grants should be tied to either local or regional strategicplans. Each grant program will have its own application and reporting processes. Most grant systems willrequire that the jurisdiction expend its own funds up front and then get reimbursed and might requirematching funds, usually as a percentage basis. It is important to remember that grant funds are for thoseitems that are used to augment or increase the capability of the operation of an HMRT. A grant can be aone time thing and should not be relied upon for the basic operation of the HMRT. The following are someof the grant programs to assist the HMRT, but the list is not all-inclusive:

(1) DHS National Preparedness Grant Program

(2) Urban Area Security Initiative grants

(3) State Homeland Security Program grants

(4) U.S. Department of Transportation Pipeline and Hazardous Materials Safety AdministrationHazardous Materials Emergency Preparedness Grant

(5) FEMA Assistance to Firefighters Grant Program

10.2.2.2 State and Local Grant Programs.State and local grant programs vary from state to state and region to region. Some grant programs can befrom private industry or from governmental agencies. Local agency and industry representatives should becontacted to see what is available in each jurisdiction.10.2.2.3 Cost Recovery Programs.

Many jurisdictions have implemented procedures to recover the cost of response to incidents. This can bea flat rate, per-hour rate, or the actual cost of time and materials. Program managers will need to work withtheir chain-of-command and department fiscal agents to determine what guidelines will be implemented forcost recovery, if any.10.3 Sustainment.As previously mentioned, three important budget considerations for any hazmat team are the costs ofequipment, apparatus, and manpower. Thirty years ago an entire hazmat rig could be equipped for$50,000 to $100,000, depending on the local target hazards that needed to be addressed. Today, oneinstrument can cost well over $50,000. Initial costs to start a hazmat team are significant, but sustainmentcosts are often even more challenging because they are ongoing for the life of the team.10.3.1

Apparatus are expensive to purchase and maintain, but managers must understand that apparatus need tobe maintained and will eventually have to be replaced. What is often overlooked is the myriad otherexpenses required to keep a team up and running efficiently and safely. A smart way to look at every newpurchase is to calculate the future costs required to sustain that item and include that information in thepurchasing decision model. It might end up that the initial purchase price is within the budget but theongoing costs are not sustainable.10.3.2

Electronic monitoring instruments are another high maintenance item. Sending these instruments out forroutine maintenance is costly. Many teams are fortunate to have individuals in-house who are qualified tocalibrate these instruments monthly and might even be able to perform light repairs. But calibration gasesare expensive, and some have expiration dates. With all the high-tech monitoring equipment teams nowcarry there is the high cost of calibrating, repairing, and replacing supplies.10.3.3

A colorimetric kit can prove invaluable, and the initial cost of this kit is fairly reasonable, but all colorimetrictubes have an expiration date. The team needs to budget for the replacement tubes so they do notexperience a large expense a year or two later when they need to replace many boxes of tubes all at once.


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10.3.4 Field biological agent detectors are relatively affordable, but there is also an annual sustainment cost toreplace test cartridges that expire.10.3.5

There are many other supplies and equipment that have lifespan issues that need to be researched prior tomaking any commitment.10.4 Personnel.A critical area of concern is personnel costs, and training personnel is one of the high ticket items,including both initial training to develop new technicians and continuing training to maintain skills. Once theteam is up and running, the members will need refresher training as well as training on new techniquesand equipment. Teams make a considerable investment in each member, and there must be a return onthat investment if the team is going to stay functional.10.4.1

Retaining response personnel is a major concern for HMRTs. It does not do any good to invest scarceresources training individuals to start a hazmat team only to have the team become dysfunctional later dueto a lack of maintaining the training. It is unsafe and a waste of resources in the long run. The number ofhours required to stay proficient will vary depending on the organizational model of the team, but safe andefficient hazmat response requires a robust training regimen. It is not possible to have a proficient hazmatteam if the training provided is minimal or even sub-par. It requires a significant buy in from the organizationbecause it is difficult to sustain adequate training from within any organization. Funding sources need to bebudgeted to send team members to outside training and specialty conferences, as well as to bring inoutside experts to deliver high quality training that is not available locally. Even dedicated hazmat teamswith a wealth of experience and knowledge need to network with the outside response world to staycurrent.10.4.2 There are several different team formats, and all have pros and cons regarding personnel training.Part-time response teams, regional response teams, co-operative response teams, mutual aid–basedresponse teams, public/private response teams, industry based response teams, multi-agency responseteams, and full-time response teams are a few of the models currently in use, but there are others. Forexample, there are very few cities with enough hazmat calls to justify a dedicated, full-time hazmat team.These teams are often very busy covering a large geographic response, and scheduling the time to keepup-to-date with all the required skills and competencies is not easy. Busy response teams gain valuableexperience during incidents but might not have enough time to spend on all the competencies.10.4.2.1

Smaller, part-time teams have the problem of having to cover a plethora of different training skills and sufferfrom a lack of actual street experience. There are many examples of competent small teams, and they allplace a premium on training to compensate for the lack of calls.10.4.2.2

Teams that draw response personnel from several different agencies might have a difficult time schedulingtraining when everyone is available. Often it is necessary to schedule repeated training classes just to geteveryone to attend. Unless the controlling authority sets firm guidelines for training, the actual trainingcontent can be open to interpretation. One agency might require their responders to attend 100 percent ofthe training sessions while another participating agency might set a lower standard. Clear team guidelinescan help eliminate these issues.10.4.2.3

Industry-based response teams often are expected to provide other services or draw responders fromemployees that have other assigned jobs when there is not an emergency.10.4.3

Individual participation as a hazmat team responder can depend on how the team is funded and whatincentives are offered. For example, it is not unusual to have a team that is entirely made of volunteersdrawn from the ranks. But there are teams that provide incentives to join and maintain competency as ateam member. This can include overtime in some organizations and/or incentive pay differential tocompensate the individual for the addition work and risk involved. There is not one right answer in thisregard; it is a decision that is based on multiple factors.10.5 Supplies.


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10.5.1 Cost associated with equipment and supplies are a significant draw upon department operating budgets.These costs should be identified prior to purchasing equipment. Many hazmat teams currently rely heavilyon grants to purchase equipment, often without taking into consideration the funds that will be needed toreplace damaged or lost equipment, upgrade older equipment, and purchase consumable replacementsupplies and for routine maintenance costs. While these grants help teams purchase equipment, a teammight not be able to afford the expense due to budget constraints, the grants might not provide for futuremaintenance, and some of this maintenance requires several thousand dollars annually to keep theequipment working properly. Unfortunately, grant opportunities are shrinking and seem to be disappearing.10.5.2 Consumables.

Consumable supplies are often overlooked when planning to fund a hazmat team. It would be great if everyitem used during a response was covered under a spiller pays regulation or some other cost recoveryprogram, but some supplies are really hard to track at times. There is also the added burden ofproportioning the cost of supplies that are used on several responses before needing to be replaced. Forexample, it is a straightforward proposition to count bags of oil dry during an incident and then chargeaccordingly. But it is a challenge to figure out how much to charge for other less obvious supplies, such asthe calibration gas used during an incident. Or, how is the cost of disposable batteries used during aparticular incident portioned? Some teams have had success charging a basic response fee in addition tosupplies used to cover all those little hidden expenses. Still others report that they are not permitted tocharge any extra for hazmat responses. It can depend on your charter and/or local/state laws.10.5.3

A comprehensive inventory system will assist with replacement of supplies used during an incident orexpired. There are computer programs available to handle this task and actually make the processrelatively easy. In addition to equipment and supplies, some programs track everything, including personnelrosters, training information, operational readiness, calibration service intervals, incident logs and reports,certification requirements, repairs, and a host of other needs.10.6 Services.

Examples of services costs are annual physical exams for members.10.7 Capital.

Capital costs are fixed, one-time expenses incurred on the purchase of land, buildings, construction, andequipment used in the production of goods or in the rendering of services. Put simply, it is the total costneeded to bring a project to a commercially operable status. Whether a particular cost is capital or notdepends on many factors, such as accounting, tax laws, and materiality.10.8 Non-Capital.

Examples of non-capital costs are computers, books, software, and office supplies. Due to the increase inrecords keeping, research, and training of the HMRT personnel and responses, consideration for additionalnon-capital cost must be considered. These are often considered hidden costs and can be absorbed intothe operational budget, but they should be identified as costs particularly when considering the start-up of anew team.10.9 Cost Recovery Analysis.Operating an HMRT is an expensive service to get into and to maintain. Once an organization starts toprovide the service, public and political demands will make it very difficult to get out of the service. Anyorganization operating an HMRT should be conducting an ongoing program analysis to track the cost ofthe program and investigate all options available to recover costs in an effort to offset overall programcosts.10.9.1 Cost Analysis.10.9.1.1

Ongoing program analysis will help HM program managers to accurately track the costs involved withoperating an HMRT. This information is needed to be able to forecast expenditures, determine inventorylimits, manage training, track staffing costs, and rationalize the program to management and politicalentities. Program cost analysis will also assist with any external billing or cost recovery initiatives that theAHJ undertakes. The final objective of an HMRT program cost analysis is to determine whether theprogram is better managed from within the AHJ or by external contract.


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10.9.1.2 Cost analysis should focus on the following areas associated with the HMRT program:

(1) Apparatus: the annual operating costs associated with vehicles including fuel, maintenance, wearand tear, and depreciation

(2) Equipment: operation and maintenance costs related to response equipment that include calibrationand bump testing, power supplies, consumable components, annual testing, licensing, andreplacement costs

(3) Staffing: all costs associated with staffing an HMRT, which can include salary and wages, benefits,overtime, backfilling, medical assessments, and personal kit assigned

(4) Supplies: a variety of consumable supplies used in daily operations

(5) Training: initial certification, continuing education or re-certification, materials, instructors, props andassociated costs for travel, lodging, meals, and backfill

(6) Miscellaneous: costs such as administrative, office costs, disposal of materials, contractors,storage, or special facilities

10.9.2 Cost Recovery.10.9.2.1

Cost recovery options are available in many formats, and opportunities vary between states, provinces,industry, and local jurisdictions. Prior to the initiation of an HMRT, the AHJ should investigate allpossibilities for cost recovery to offset program operational costs. Justification for an HMRT establishmentwill be increased when the AHJ can support even partial costs with independent funding.


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10.9.2.2 The following examples of cost recovery are provided to demonstrate some of the options that are availablefor the AHJ to pursue:

(1) Federal, state, and provincial programs in both the U.S., and Canada exist to allow localjurisdictions the ability to offset equipment purchase costs, claim for disposal and cleanup costs, orassist with training costs.

(2) CERCLA: Comprehensive Environmental Response, Compensation, and Liability Act.

(3) EPA’s local government reimbursement program (LGR)

(4) State statutes

(5) Provincial regulations

(6) Grant programs exist for a variety of HMRT components such as training, equipment, orvehicles.

(7) DHS

(8) FEMA

(9) JEPP: Joint Emergency Preparedness Program through Public Safety Canada

(10) Local ordinances or bylaws that might allow for recovery of response and/or cleanup costs.

(11) Cost sharing. Some jurisdictions might partner together to help fund the HMRT of one AHJ ifresponse is provided into the other jurisdiction.

(12) Regional HMRT

(13) Industry. Some industry and responsible partner groups will fund HMRT that respond to theirsites or might help fund training initiatives between their team and the local HMRT.

(14) Charge back or fee for service. Some HMRTs will bill for responses out of their jurisdiction oreven within if hazmat response is considered an additional service provided. Others bill back tothe originators of a response if the cause of the incident can be determined to be from theviolation of a law, regulation, ordinance, or bylaw. There is also the opportunity to set limitswithin an HMRT of what is included in a response and what is determined to be billable.

(15) Consumables. Some HMRTs bill the spiller for any consumables used in the responsebut not for the balance of the response itself.

10.10 Personnel Hidden Cost.10.10.1 As with most programs, within the staffing of a HMRT there are also some hidden costs to consider whenevaluating the establishment of a program. Some of these hidden costs are not going to occur in allsituations but can occur throughout the life of a HMRT Program.


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10.10.1.1 The following are examples of some hidden personnel costs associated with an HMRT:

(1) Staffing. Within staffing of an HMRT hidden costs can include the following:

(2) Backfilling: the cost of replacement personnel to ensure staffing levels are maintained. Thiscould be due to training, vacation, sickness and accident, and long-term disability.

(3) Medical: costs related to medical monitoring or illness. This could include annual baselinetesting for staff that could include heavy metal screen and could also include ongoing medicalcosts related to treatment and/or compensation for a work-related condition attributed to theHMRT.

(4) Equipment: costs associated with individual HMRT personnel. This can include uniforms or

special uniform considerations such as Nomex ® coveralls, safety glasses, or individualSCBA and/or respirators. The size of personnel can also incur special costs if the off the racksizing does not accommodate staff for chemical protective clothing (CPC), chemical boots, andgloves.

(5) Communications. These are costs associated with communication devices or technology thatpersonnel might need. These will vary based on the deployment and/or HMRT model utilized. Thiscan include the following:

(6) Cell phone

(7) Pager

(8) Computer, software, and data accounts

(9) Radios

(10) Tablet or smart device

(11) Sustainability. These are the ongoing costs of sustaining the HMRT based on turnover andpromotion. Consideration needs to be given in regards to costs incurred if HMRT members no longerwant to participate in the program, members are promoted up into new roles, and retirement rates toidentify how often the initial training and outfitting of members takes place. Initial costs are generallythe highest direct cost due to training, and therefore a high turnover rate can significantly increaseoverall program costs.

(12) Collective agreements. There might be costs identified within individual collective or bargainingagreements that will impact the program costs of an HMRT. Some of these might include thefollowing:

(13) Standby or callout pay: costs for those that must be available on standby or those formembers called in off duty

(14) Special duty pay: costs specific to those members that are part of a special team over andabove their normal pay

(15) Hazard pay: costs specific to those members that are put in situations that fall within specialhazards or are exposed to certain products

(16) Training pay: costs specific to any training that falls outside of regular scheduled hours ofwork or shift patterns


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10.1 Overview.Financial considerations might by one of the most challenging parts of any HMRT program. Hazardousmaterials response is costly for start-up, personnel personnel , equipment (including ongoingmaintenance) , medical surveillance, consumables and items with time expiry, as well as many otheraspects. The majority of cost will be personnel wages, equipment, apparatus, and training. Programmanagers will need a full understanding of their jurisdiction’s financial policies on budgets and purchasing. Itwill benefit every HMRT to have an internal strategic plan developed and updated regularly. The strategicplan should be the basis for budget justification and should identify current capabilities and gaps incapabilities and technology. While it need not be as lengthy or comprehensive as a department orjurisdictional strategic plan, it is recommended that it contain all the elements. The information in Chapter10 is meant to assist with financial considerations that go along with starting and sustaining a HMTR. It isfar from a complete list of every consideration for every team.

Reviewer Comment: There is a lot of repetiiont in this section- both within the section and betweenthis and other sections, and it is not always consistent.


The cost of maintenance of equipment and refreshing consumable/expired supplies can be very significant, and should be included for emphasis.






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Chapter 11 Operational Guidelines11.1 Introduction.11.1.1 Purpose.

The purpose of this chapter is to provide information and guidance for hazardous materials/WMD responseteam (HMRT) program managers in understanding the minimum requirements necessary for developingoperational guidelines for the AHJ’s hazardous materials/WMD response program. Recommendationsoffered here are not intended to restrict any jurisdiction from using more stringent guidelines or applyinggreater administrative measures or management controls. Operational guidelines should include thefollowing:

(1) An oil spill/hazardous materials annex as part of the AHJ’s basic plan

(2) Regional response plan

(3) An LEPC community emergency response plan

(4) Policies

(5) Standard operating procedures

(6) Standard operating guidelines

(7) Site specific pre-plans

(8) Pre-event incident action plans

11.1.2 Scope.This chapter should apply to all organizations that have responsibilities for developing plans, procedures,and operational guidelines for responding to hazardous materials/WMD incidents.11.1.3 Application.

The recommendations contained in this chapter are applicable to those jurisdictions that have or will bedeveloping a hazardous materials/WMD response program. Operational guidelines and emergencyresponse plans should create decision points (see definition) instead of just tactics and procedures so thatresponders can utilize a risk-based response approach to choose the appropriate response options(offensive, defensive, non-intervention). Decision points provide a systemic approach that can be applied toall phases of emergency situations.11.2 Hazardous Materials/Oil Spill Annex to the AHJ’s Basic Emergency Management Plan.


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Every state has an emergency management plan that complements the national response framework andwhen needed works in concert with the FEMA — Robert T. Stafford Act for disaster relief and emergencyassistance. Many states also require that local jurisdictions have a basic emergency management plansupported by functional annexes. Basic plans are designed to provide general guidance for emergencymanagement activities and an overview of methods to be used for mitigation, preparedness, response, andrecovery. Emergency management plans often include the following annexes:

(1) Annex A: Warning

(2) Annex B: Communications

(3) Annex C: Shelter and Mass Care

(4) Annex D: Radiological Protection

(5) Annex E: Evacuation

(6) Annex F: Fire Fighting

(7) Annex G: Law Enforcement

(8) Annex H: Health and Medical Services

(9) Annex I: Emergency Public Information

(10) Annex J: Recovery

(11) Annex K: Public Infrastructure and Engineering

(12) Annex L: Utilities

(13) Annex M: Resource Management

(14) Annex N: Direction and Control

(15) Annex O: Human Services

(16) Annex P: Hazard Mitigation

(17) Annex Q: Hazardous Materials and Oil Spill Response

(18) Annex R: Search and Rescue

(19) Annex S: Transportation

(20) Annex T: Donations Management

(21) Annex U: Legal

(22) Annex V: Terrorist Incident

(23) Annex W: Finance


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11.2.1 Some local emergency management plans can mirror the national response framework and useemergency support functions (ESFs) in lieu of annexes. ESFs can include the following:

(1) ESF #1: Transportation Annex

(2) ESF #2: Communications Annex

(3) ESF #3: Public Works and Engineering

(4) ESF #4: Fire Fighting Annex

(5) ESF #5: Emergency Management

(6) ESF #6: Mass Care, Emergency Assistance, and Human Services Annex

(7) ESF #7: Logistics Management and Resource Support Annex

(8) ESF #8: Public Health and Medical Services Annex

(9) ESF #9: Search and Rescue Annex

(10) ESF #10: Oil and Hazardous Materials Annex

(11) ESF #11: Agriculture and Natural Resources Annex

(12) ESF #12: Energy Annex

(13) ESF #13: Public Safety and Security Annex

(14) ESF #14: Long-Term Community Recovery Annex

(15) ESF #15: External Affairs Annex

11.2.2 Regional/Community Emergency Response Plan.When developing a regional or community emergency response plan, the AHJ should establish a planningteam to research all related local, state, and federal plans, federal regulations, standards, mutual aidagreements, and memoranda of understanding that might influence the jurisdiction’s final plan. Once thereview is complete the jurisdiction will need to perform a risk analysis (see Chapter 5 ) that will lead to arisk assessment that is essential in prioritizing preparedness efforts and determining the community’scapabilities compared to the potential response requirements in accordance with the NationalPreparedness Goals http://www.fema.gov/national-preparedness-goal. Emergency response plans shouldbe reviewed and updated at least annually.11.2.3 * Emergency Response Plan template (Annex) (TEXT?)11.3 Hazmat Standard Operating Guidelines/Procedures (SOG/SOP).

SOG/SOP provide general guidance of specific procedures for strategic and tactical activities at ahazardous material/WMD incident. SOG/SOP enable hazmat responders to operate in a dynamic threatenvironment where hazards are identified, risk are assessed, and response options are chosen based onthe responder’s level of training and the available resources or capabilities. Advantages of SO/SOP includethe following:

(1) Improves coordination

(2) Simplifies training

(3) Improves personnel safety

(4) Provides response consistency

(5) Serves as a guide for response actions

(6) Enhances the decision process

(7) Allows for better coordination and interoperability with other agencies and departments

11.4 Hazardous Materials Incident Levels.


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11.4.1 Level I Incident.A Level I incident is a minor incident that can be controlled by first responders or within the capabilities ofthe hazmat response team.11.4.2 Level II Incident.

A Level II incident is an incident of greater magnitude or a greater hazard than a Level I and poses apotential threat to life and property. A Level II incident will require resources beyond the capabilities of theinitial local response personnel.11.4.3 Level III Incident.

A Level III incident involves a severe hazard or a large geographical area and poses an extreme threat tolife and property and might require large-scale protective actions and resources beyond those available atthe jurisdictional level. This type of incident might require resources and expertise from regional, state,federal, and private organizations.11.5 Incident Response.The hazardous materials/WMD response will occur once a hazardous materials release has beendiscovered and the emergency response sequence has been initiated.11.5.1 First Response.

Actions taken by the initial arriving first responders will provide the framework for the progression of theevent. The first few minutes after arrival of first responders are the critical to the success of the overalloperation.11.5.2 First Responder Incident Priorities.

Actions taken by first responders should support the incident priorities of life safety, incident stabilization,and property conservation/environmental protection.11.5.3 First Responder Actions.Actions taken by first responders are defensive in nature and are intended to keep the incident frombecoming worse. First responder actions can include the following:

(1) Isolating the area

(2) Denying entry into the area

(3) Protecting people, structures, and other exposures

(4) Extinguishment

(5) Emergency decontamination

(6) Vapor suppression

(7) Confining and controlling the release

(8) Shutting off a remotely located valve

(9) Protecting the environment

11.5.3.1 The first responder actions listed in 11.5.3 should be performed by responders who have been trained to allof the competencies at the awareness level (NFPA 472, Chapter 4) and the competencies set forth inChapter 5 of NFPA 472, First Responder Operations Level — Core.


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11.5.4 First Responder Actions — Mission Specific.Mission-specific first responder actions are actions taken by first responders who have received additionaltraining beyond the first responder operations level – core and are based on the responder’s mission asdefined by the AHJ. These actions should be taken under the direction of a hazardous materials technicianor an allied professional or with direction from a strong SOP. First responders operations level — missionspecific responders should be trained to all of the competencies at the awareness level (NFPA 472,Chapter 4), first responder operations — core (NFPA 472, Chapter 5), and the applicable sections andcompetencies in Chapter 6 of NFPA 472. First responder operations level — mission-specific activitiesinclude the following:

(1) Personal protective equipment

(2) Mass decontamination

(3) Technical decontamination

(4) Evidence preservation and sampling

(5) Product control

(6) Air monitoring and sampling

(7) Product control

(8) Victim rescue

(9) Illicit lab response

(10) Bomb technician

11.6 Hazardous Materials Technician.The hazardous materials technician should be that person who responds to hazardous materials/WMDincidents using a risk-based response process by which he or she analyzes a problem involving hazardousmaterials/WMD, selects applicable decontamination procedures, and controls a release using specializedprotective clothing and control equipment. Hazardous materials technicians should be trained to meet allthe competencies at the awareness level (NFPA 472, Chapter 4), all the core competencies at theoperations level (NFPA 472, Chapter 5), and Chapter 7 of NFPA 472.11.7 Scene Safety.

Scene safety at a hazardous materials/WMD incident is of the utmost importance. Hazardous materialsoperations require the use of a hazardous materials safety officer. According to OSHA 29 CFR 1910.120,the hazardous materials safety officer must be trained to the same level of the tasks being performed. Thehazardous materials safety officer (NIMS: assistant safety officer – hazardous materials) should be thatperson who works within the incident management system (IMS) (specifically, the hazardous materialsbranch/group) to ensure that recognized hazardous materials/WMD safe practices are followed athazardous materials/WMD incidents. Hazardous materials safety officers should be trained to meet all thecompetencies at the awareness level (NFPA 472, Chapter 4), all the core competencies at the operationslevel (NFPA 472, Chapter 5), all competencies at the hazardous materials technician level (NFPA 472,Chapter 7), and Chapter 11 of NFPA 472.11.8 Personnel Accountability.

A jurisdiction’s emergency response plan should include a personnel accountability system that canaccount for each member engaged in emergency activities at an incident scene. A personnel accountabilitysystem should have the ability to provide a rapid accounting of all members on the incident scene at anygiven time. Personnel accountability systems can be either electronic or manual and should be capable ofspecifically identifying and keeping track of all members entering and leaving the hot zone or those who areworking in high-hazard areas where special protective equipment is required.11.9 * Emergency Response Operations.

Emergency response operations should be conducted in accordance with NFPA 472, Standard forCompetence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents , NFPA 1500,Standard on Fire Department Occupational Safety and Health Program , and the applicable federalregulation: OSHA 29 CFR 1910.120 or the EPA 40 CFR 311.


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11.10 Resource Typing and Personnel Credentialing.When a jurisdiction decides to establish a hazardous materials/WMD response program, a risk analysisshould be conducted followed by a needs assessment. By evaluating the hazards and risk and determiningthe resources and capabilities needed to respond to and mitigate a potential hazardous materials release,the jurisdiction can consult the FEMA resource typing recommendations and make a decision about whatlevel of hazardous materials response is needed for their respective jurisdiction. For individuals, thecredentialing process entails the objective evaluation and documentation of an individual’s currentcertification, license, or degree; training and experience; and competence or proficiency to meet nationallyaccepted standards, and their ability to perform certain specific tasks during an incident. For the NationalIncident Management System, credentialing is the administrative process for validating a person’squalifications and providing authorization to perform specific functions in an ICS. Information aboutresource typing can be found on the FEMA website: http://www.fema.gov/emergency/nims/ResourceMngmnt.shtm.11.11 Terminating the Incident.During the termination phase, the incident transitions from emergency response to recovery. Incidentbriefings are in order and help maintain the command and control functions during this transition.


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11.11.1 Termination activities are divided into the following three phases:

(1) The incident debriefing that is conducted at the incident during the termination phase.

(2) Inform personnel of the signs and symptoms of exposure to hazardous materials at theincident and receive instructions on what to do if they become symptomatic after leaving thescene.

(3) Identify any damaged equipment and items requiring immediate attention.

(4) Review hazmat incident strategies and contingencies.

(5) Summarize the activities performed by the specialized teams on scene.

(6) Identify any unsafe acts that took place during the incident.

(7) Identify a point of contact for each branch/group.

(8) Identify any follow-up activities that need to be addressed.

(9) The post-incident analysis is scheduled as soon as practical after the incident and is used to reviewthe incident in order to establish a clear picture of the events that took place and provide informationfor future incidents. A post-incident analysis usually includes the following:

(10) Reconstruct the incident to establish a clear picture of what events took place.

(11) Identify action items to improve tactics and SOG/SOP.

(12) Document safety guidelines, site operations, hazards encountered, and lessons learned.

(13) The critique is a more formal process and can be combined with the post-incident analysis orconducted separately. Information obtained in the critique can be used to improve performance byidentifying weaknesses and providing assurance that those weaknesses will be corrected. Items thatmight be address in a critique include the following:

(14) Were SOG/SOP utilized?

(15) What equipment was used?

(16) What steps were taken to minimize contamination and cross contamination?

(17) Was decontamination performed properly?

(18) Identify immediate corrective actions that need to be taken.





On behalf of the Task Group, this Public Input is being recommended to the Technical Committee for consideration to modify the existing chapter text. The Task Group believes that these changes, while substantive, bettering


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reflect the technical minimum requirements for organizing, managing and sustaining a HMRP based on an assessed risk level for an AHJ.






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11.3 Hazmat Standard Operating Guidelines/Procedures (SOG/SOP).SOG/SOP provide general guidance of specific procedures for strategic and tactical activities at ahazardous material/WMD incident. SOG/SOP enable hazmat responders to operate in a dynamic threatenvironment where hazards are identified, risk are assessed, and response options are chosen based onthe responder’s level of training and the available resources or capabilities.

11.3.1 Advantages of

SOSOG /SOP include the following:

(1) Improves coordination

(2) Simplifies training

(3) Improves personnel safety

(4) Provides response consistency

(5) Serves as a guide for response actions

(6) Enhances the decision process

(7) Allows for better coordination and interoperability with other agencies and departments

11.3.2 HazMat/WMD response teams should consider developing SOGs with incident specfic safetyconcerns and tactical considerations for emerging hazards and threats such as:

1. Clandesdine drug labs, including

a. Methamphetamine production

b. Indoor marajuana grow operations

c. Marajuna hash oil extraction operations

2. Explosive Post blast response

3. Suspicous substances

4. Bulk flammable liquid fires include crude oil and ethanol blended fuels

5. Transportation incidents including train derailments and non-accidental releases

6. WMD labs including,

a. Chemical agent labs

b. Biological agent labs

c. Homemade explosive (HME) labs

11.3.3 HazMat/WMD response teams should consider developing (SOPs) to serve as job aids for technicalprocedures such as:

1. Sampling procdures including chain of custody

2. Grounding/bonding procedures

3. Transfer operations

4. PPE/CPC donning and doffing

5. Hazard characterization and presumptive field testing of unknown materials


Provides detailed recommendations and guidance to HMRT program managers on suggested SOP/SOGS.


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Actions taken by first responders are defensive in nature and are intended to keep the incident frombecoming worse. First responder actions can include the following:

(1) Isolating the area

(2) Denying entry into the areaProtecting people, structures, and

(3) Peforming rescues and providing medical treatment

(4) Warning the public and implementing pubic protective actions, including:

(5) ?Shelter in place

(6) Evacuation

(7) Protecting structures and other exposures

(8) Extinguishment

(9) Emergency decontamination

(10) Vapor suppression

(11) Confining and controlling the release

(12) Shutting off a remotely located valve

(13) Protecting the environment


Reinforce the need for first responders to conduct rescue operations and begin public protective actions.






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11.7 Scene HazMat/WMD Safety.Scene safety Safety at a hazardous materials/WMD incident is of the utmost importance. As a result, allresponders operating at a HazMat/WMD incident share in the responsiblity for safety.

11.7.1 Personal safety includes all responders adhering the following:

1. Maintain situational awarness

2. Always maintain contact with assigned team members in the hot or warm zone

3. Follow rule of air managment (ROAM) practices with operating in SCBA or re-breathers

4. Wear correct PPE/CPC for the assigned task

5. Notify supervisor or safety officer of unsafe conditions

11.7.1.1 All responders are empowered to stop unsafe acts

11.7.2 Tactical safety includes assignment of a Hazmat Safety Officer to serve as the Assistant SafetyOfficer - Hazmat/WMD reponsible to:

1. Support the HazMat Branch Director/Group supervisor

2. Ensure recognized hazardous materials/WMD safe practices are followed at a hazardousmaterials/WMD incident.

3. Review the Site Safety and Control Plan

11.7.2.1 Hazardous materials operations require the use of a hazardous materials safety officer. Accordingto OSHA 29 CFR 1910.120, the hazardous materials safety officer must be trained to the same level of thetasks being performed. The hazardous materials safety officer (NIMS: assistant safety officer – hazardousmaterials) should be that person who works within the incident management system (IMS) (specifically, thehazardous materials branch/group) to ensure that recognized hazardous materials/WMD safe practices arefollowed at hazardous materials/WMD incidents.

11.7.2.2 Hazardous materials safety officers should be trained to meet all the competencies at theawareness level (NFPA 472, Chapter 4), all the core competencies at the operations level (NFPA 472,Chapter 5), all competencies at the hazardous materials technician level (NFPA 472, Chapter 7), andChapter 11 of NFPA 472.

11.7.3 Incident Safety includes assignment of an a safet officer to serve as the Incident Safety Officer(ISO) to

1. Support the incident commander ensure overall scene safe

2. Maintain overall incident scene safety

3. Review the incident action plan for safety implications

11.7.4 Strategic safety includes selection of an appropriate strategy by the incident commander based on asound risk/benefit analysis.

11.7.4.1 Strategic options include offensive, defensive, or non-intervention

11.7.4.2 The risk/benefit analysis should based on weighting the positive results that can be acheivedagainst the probability and severity of potential negative consequances.

11.7.4.3 The incident commander should constantly re-asses the strategy as conditions change andincident objectives are completed.


It takes a village to raise a child. It's unrealistic that a Hazmat Safety Officer can solely be responsible for safety


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on a HazMat/WMD incident. Safety needs to be embedded in all levels of the incident management structure. Everyone needs to do their part. (task level, tactical, incident, and strategic)

The suggested language would codify that safety is everyones responsibility. The days that only the safety officer and the IC were capable of stopping unsafe acts are gone. All responders need to be empowered to stop unsafe acts.

The proposed changes would align with the risk/benefit analysis included in NFPA 1500 and in the Firefighter Life Safety Initiatives.






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11.X OPERATIONAL SECURITY Operational Security (OPSEC) includes safeguarding sensitive information that an adversary could use totheir advantage.

x.x.1 While all hazmat response programs should consider the need for OPSEC, HMR teams shoulddevelop a formal OPSEC plan if their team’s area of responsibility includes any of the following:

1. CBRNE response or consequence management

2. Assisting with law enforcement operations include illicit lab or bomb squad responses

3. Providing hazmat/WMD response assistance to assist with dignitary protection

4. Special event planning or participating in joint hazard assessment team (JHAT)

x.x.2 The OPSEC planning process includes the following steps:

1. Identify sensitive information

2. Analyze threat

3. Analyze vulnerability

4. Assess risk

5. Apply countermeasures

x.x.3 Examples of sensitive information that a HM program may need to protect include:

1. Current and future operations

2. Information about law enforcement investigations

3. Official access or identification cards

4. User names and passwords

5. Team capabilities and limitations

6. Entry/exit or checkpoint security procedures

7. Incident Action Plans (IAP) for special events

8. Critical communications via phone or radios

9. Facility pre-plans or hazmat storage information

10. Proprietary industrial information

x.x.4 Examples of HMR program vulnerabilities that adversaries may exploit include:

1. Unsecured e-mails accounts

2. Use of home e-mail for official business

3. User names or password reminders written in public view

4. Sensitive documents left in vehicles

5. Information shared on websites and social media (official and unofficial)

6. Information discussed in public chat forums.

7. Documents disposed of un-shredded

8. Lost electronic devices such as smart phones, computers, or flash drives


File Name Description Approved


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OPSEC_cycle.jpg US Army OPSEC Cycle


Hazmat response teams are a counter-CBRN asset and often partner with law enforcement for drug lab raids or during Presidential visits. As a result, HMRTs need to exercise increased vigilance to protect sensitive information.

Information technology is a powerful tool that help hazmat response teams. However if basic pre-cautions are not taken, it can also provide considerable information to bad guys.

The proposed language would provide encouragement, guidance, and examples to HMRT program managers to implement basic OPSEC precautions.



Organization: Gary Sharp - Oakland County Hazmat

Street Address:City:State:Zip:Submittal Date: Wed Oct 29 12:32:15 EDT 2014


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11.11.1


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Termination activities

are divided intomay include the following

three phases: The incidentcomponents:

(1) Transfer to Post-emergency Response Operations (PERO) by formally handing off incident commandand site managment responsibilities to the agencies or contractors responsible for recovery,restoration, or environmental remediation.

(2) May include a formal announcment on the radio

(3) Should include a transfer briefing with senior representatives of the agencies or contractors tobegin operations. The briefing should include:

(4) The nature of the initial emergency

(5) Actions takens and incident objectives completed

(6) Hazards and risks that were mitigated, and those that still exists

(7) Safety procedures, including a copy of the most recent site safety and control plancompleted

(8) Relevent documentation and points of contact

(9) Hazmat Team Demobilzation is the formal process of releasing the HMRT from anincident and restoring the team to service. The HMRT demobilization process may include:

(10) Transfering samples and chain of custody to appropriate agency

(11) Turning in completed documentation and any issued equipment

(12) Ensuring a plan exists for disposal of any waste generate by the HMRT such as contaminatedsuits or decon waste water.

(13) Check out with the appropriate ICS/IMS representatives

(14) Identify any damaged equipment or items that require immediate attention

(15) Restock any consumables used on during the incident

(16) The incident debriefing that is conducted at the incident during the termination phase.

(17) Confirm with HMRT personnel no injuries, illnesses, or exposures occured

(18) Inform personnel of the signs and symptoms of exposure to hazardous materials at the incidentand receive instructions on what to do if they become symptomatic after leaving the scene.

(19) Identify any damaged equipment and items requiring immediate attention.

(a) Review hazmat incident strategies and contingencies.

(b) Summarize the activities performed by the specialized teams on scene.

(c) Identify any unsafe acts that took place during the incident.

(d) Identify a point of contact for each branch/group.

(e) Identify any follow-up activities that need to be addressed.

(20) The post-incident analysis is scheduled as soon as practical after the incident and is used to reviewthe incident in order to establish a clear picture of the events that took place and provide informationfor future incidents. A post-incident analysis usually includes the following:


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(21) Reconstruct the incident to establish a clear picture of what events took place.

(22) Identify action items to improve tactics and SOG/SOP.

(23) Document safety guidelines, site operations, hazards encountered, and lessons learned.

(24) The critique is a more formal process formal process and can be combined with the post-incidentanalysis or conducted separately. Information obtained in the critique can be used to improveperformance by identifying weaknesses and providing assurance that those weaknesses will becorrected. Items that might be address in a critique include the following:

(25) Were SOG/SOP utilized?

(26) What equipment was used?

(27) What steps were taken to minimize contamination and cross contamination?

(28) Was decontamination performed properly?

(29) Identify immediate corrective actions that need to be taken.


The initial language closely mirrored Step 8, Terminating the Incident, from the 8 Step Process included in the text Managing the Incident, but did not include NIMS language on demobilization.

In addition, consideration should be given to combining Post Incident Analysis and Post Incident Critique as the terms are often used interchangeably now.






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Chapter 12 Community Outreach and Marketing12.1 Introduction.12.1.1 Purpose.

The purpose of this chapter is to provide guidance and suggestions for program managers on theopportunities to perform community outreach and marketing of the hazardous materials/WMD emergencyresponse team. The program manager will have the opportunity to conduct external and internal outreach.12.1.2 Definition.

Community outreach and marketing are interrelated and are not mutually exclusive. Both involve theeducation of the hazardous materials/WMD emergency response teams’ capabilities and potential servicesto customers within their own agency and to a range of outside agencies.12.1.3 Objectives.12.1.3.1

Identify methodology to market the hazardous materials response (HMR) services with their own agency.12.1.3.2

Identify methodology to market the HMR services with other emergency response organizations, such asfire, police, emergency medical services, emergency management, and others.12.1.3.3

Identify potential external customers for community outreach and marketing.12.1.3.4

Identify potential programs that could be developed and utilized in a community outreach and marketingprogram.


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12.1.4 HMR has special capabilities and expertise, which should be utilized within their own agency. The programmanager should explore areas where the HMR services can showcase their capabilities to their peerswithin their agency. Some suggestions include the following:

(1) The specialized skills and equipment of the HMR provide the ability for the HMR team to act ashealth and safety officials, which can be specifically targeted towards responder safety, including thefollowing:

(2) Develop response profiles that would allow for HMR teams to monitor for toxic gases andother potentially hazardous situations at fires

(3) Assist with the pre-planning of target hazards, such as EHS and Tier 2 facilities

(4) Assist with air monitoring during USAR operations

(5) Assist with air monitoring during flammable gas releases

(6) Assist with CO alarms and investigations, which can also include odor investigations (sickbuildings)

(7) Develop training programs and policies that integrate the first responders into HMR activities,including the following:

(8) Develop training programs and policies that allow for first responders to perform mission-specific activities prior to the arrival of the HMRT, which results in more efficient responses andlessens on-scene time.

(9) Develop training programs that permit first responders to perform mission-specific activitiesand tasks (assist with decon, EMS, fire suppression, standbys, etc.) in support of the HMRTduring incident operations.

(10) Explore potential equipment that could be supplied to first response agencies that could beutilized prior to the HMR team’s arrival.

12.1.5 The program manager should evaluate response profiles that would allow for safe and efficient responsesand minimize the impact to the first response community.12.1.6 The program manager should be familiar with the local FBI Division and the WMD and hazmat responseteam coordinators. A relationship should be developed between the HMRT and the FBI resources.12.1.6.1

Training efforts and exercises can be coordinated.12.1.6.2

The FBI HMRT might need assistance from the local jurisdiction when operating at a high hazard crimescene. Having coordinating a relationship prior to the event ensures an efficient response.12.1.7

The program manager should develop a relationship with the local bomb squad and local, state, andfederal bomb technicians. There are many HMRT activities that can be supported by the bomb squad andthere are many bomb squad activities, that can be supported by the HMRT. Having the two units worktogether on a regular basis is key to success at larger or more complex incidents. Bomb squads aretypically short staffed, and the process to set up for an explosive device entry is very similar. The HMRT, ifproperly trained and the relationship is developed, can assist with many set-up activities. The bomb squadhas unique tools, which can be useful in a variety of hazardous situations. Most bomb technicians are alsohazmat technicians and can assist with HMRT activities.


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12.2 HEADING.The program manager should become familiar with the state emergency response commission (SERC)and should attend the scheduled meetings as available. The SERC influences and in some casesdetermines the statewide response to hazardous materials/WMD incidents. All of the agencies that areinvolved in HM/WMD incidents attend the meetings.12.2.1

It is always best to meet the people and agencies that would be involved in a large-scale incident, beforethe incident occurs.12.2.2

The SERC can have the ability to sponsor, coordinate, and/or deliver training programs, some on the locallevel and some at the statewide level.12.2.3

The SERC is also a source of planning and training grant funding, and in most cases funding distribution isdone at the SERC level. Most federal grant money is provided to the SERC for distribution at the locallevel.12.3 HEADING.The program manager should be familiar with and participate actively with the local emergency planningcommittee (LEPC). The LEPC is usually set up on a countywide or city basis depending on the size of thejurisdiction. The LEPC is a requirement of the SARA Title III law and emergency services is one of therequired members of the LEPC.12.3.1 In many locations the HMRT program manager is also the chairman of the LEPC or plays a majorleadership role. The program manager can provide administrative support to the LEPC. Many activities ofthe LEPC involve the HMRT, and it is highly recommended that the program manager play a very activerole in this organization.12.3.1.1

The main focus of the LEPC is to ensure that there is an emergency plan for the community and that thelocal community is prepared for a HM/WMD emergency. If the local response agencies are not prepared,the LEPC should develop a plan to ensure the local community is prepared.12.3.1.2

The LEPC is a forum for facility-emergency responder interface and relationship building. The key contactsfor EHS and Tier 2 facilities are usually involved with the LEPC, along with other emergency response andmanagement agencies. The public is also represented at the LEPC, and it brings facilities, emergencyresponse, and the public together to ensure that the local jurisdiction is prepared for an HM/WMD event.12.3.1.3

The LEPC is required to have an annual exercise for hazardous materials response, which would involvethe local HMR team. These exercises can take the form of tabletop or full-scale exercises. EHS and Tier 2facilities can be used for the exercises, or transportation containers can be used from a facility. Realisticexercises can be developed to enhance HMR capabilities.12.3.1.4

One of the best ways to test a local jurisdiction’s capability is to conduct an unannounced exercise, whichinvolves a select group of planners.12.3.1.5

At the conclusion of the exercise an after action report (AAR) is developed and delivered to the LEPC,which includes a plan to correct deficiencies.12.3.2

The LEPC is a potential source of training, as local industry can offer their expertise to the local responseagencies by providing training at their facilities and/or referencing their products and services.12.3.3 The LEPC is also eligible for planning funding, which comes from the SERC and which can assist with theplanning and delivery of the annual exercise. There are a number of planning functions, which are eligiblefor funding through the LEPC.


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12.3.3.1 On occasions the EPA levies environmental fines against facilities, and in some instances the facility isrequired to provide funding to the LEPC for their activities. In some cases, response equipment is providedto the HMR team through the LEPC.12.3.3.2

The LEPC can also be the source of industry funding and support for HMRTs.12.3.4

EPA regional activities are coordinated through the LEPC, which can include training, funding, andenforcement actions.12.3.5 Some LEPCs provide outreach to the local EHS and Tier 2 facilities by providing regulatory educationsessions. These sessions can relate to laws and regulations directly under the purview of the LEPC or canbe safety related. When new regulations are issued, the LEPC (assisted by the HMRT) can be deliveringoutreach programs, which can help the local facilities.12.3.5.1

In some jurisdictions the program manager or members of the HMRT are the ones providing the training, orthey assist with the training. Hosting the training at the HMRT station is great community outreach andmarketing.12.4 HEADING.Local facilities that use and store hazardous materials should be known to the HMRT. Typically theinformation about these facilities is obtained through EHS, RMP, and Tier 2 reporting. The programmanager should establish a program to have the HMRT conduct familiarization tours of all EHS facilities inthe jurisdiction.12.4.1

Depending on the number of EHS facilities, the HMRT should also conduct familiarization tours of high-riskTier 2 facilities. The program should include the frequency these tours should take place.12.5 HEADING.

Program managers in jurisdictions with industrial mutual aid groups should become involved with thosegroups. Industrial mutual aid groups are typically found in areas of the country where there are largenumbers of chemical facilities. Where a group does not exist, the program manager should explore thefeasibility of forming one. Some of the benefits of an industrial mutual aid group include the following:

(1) Access to firefighting foam, which can include specialized foam

(2) Large quantities of neutralizing materials or agents

(3) Access to chemists, chemical engineers, industrial hygienists, and product/material experts. Insome cases HMRT had the benefit of on-scene assistance with these experts.

(4) Access to specialized equipment and response vehicles

(5) Access to facility-based response teams and other trained personnel

12.6 HEADING.The HMR program manager should develop a program that markets the skills of the HMR team within theiragency. This program should include other emergency response agencies within their own jurisdiction.Policies and programs should be established so that the customers within their own agencies see a benefitto coordinating efforts with the HMR team.12.6.1

Develop response profiles in which the HMR can reduce on-scene time of the first responding companies12.6.2

Develop training for the first responding companies so that they serve a purpose during a hazardousmaterials response other than their initial efforts. Any training that can be provided that enables the firstresponding companies to assist the HMR can be of benefit.


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12.6.3 The HMR team should develop a relationship with the local bomb squad and develop a dual responseprofile. Cross training should be coordinated with both teams. The program should encourage dualresponse profiles so that both teams respond together, and become familiar with each other’s capabilityand personnel.12.6.4

Training programs and exercises should be developed with emergency management councils and groupsto coordinate activities and training opportunities. Many grants and training programs are coordinated at thestate emergency management level and distributed to the local level. Developing and maintaining goodrelationships and communications with emergency management agencies can assist with funding andtraining.12.6.5

Partnering with emergency management agencies, environmental agencies, and hazardous wastecompanies to hold household hazardous waste days is an excellent method of marketing to the generalpublic. Using the HMR team as the safety and characterization group reinforces valuable skills andprovides training with real materials. Having contact with the public and other government agencies wherethe public is receiving a valuable service brings substantial benefits.12.6.6

Developing a relationship with the local health department is recommended so that suspected materialscan be analyzed for a biological threat. Health laboratories, especially those in the Laboratory ReferralNetwork (LRN) system, have established procedures for the handling of materials suspected of being abiological threat. Knowing how the laboratory desires to receive samples is essential to a good relationship.Understanding the laboratory process and the procedures that they follow assists in the coordination to apotential threat.12.6.7

Radiological incidents occur at a low frequency but can be high profile events. Developing a relationshipwith a radiological specialist can assist with the challenges of a radiological response. At the state levelthere are radiological specialists responsible for radiological licensing and response. Some larger cities andin facilities that use or store radiological materials often have specialists who can assist with planning,training, and response issues.12.6.8

Specialists, such as chemistry instructors, are usually available from local colleges and universities and canhelp in their respective fields. These specialists are helpful in responses outside their facilities, buteducational institutions can also be locations of frequent hazmat responses. Having an establishedrelationship with the facility enables the response to be well coordinated.12.6.9

Having advocates in the business community can reap benefits with the local government officials. Theymight not be actual recipients of hazmat response mitigation activities but their business might be impactedby a potential release or spill. Developing a relationship with the local Chamber of Commerce or other localbusiness groups can provide benefits when evacuations require businesses to be closed. Demonstratingcompetency and having a relationship can reduce the impact from an evacuation or business closurestandpoint.12.6.10

With all of the groups mentioned above and also for elected officials, HMRT demonstrations and exercisesshould be scheduled. These demonstrations should showcase the HMRT capabilities and provide anoverview of the equipment, which can show how the local government funds have been allocated. Theseexercises should be well rehearsed and different from an evaluative exercise where the players shouldn’tknow the training scenario in advance. Using facilities that can be controversial and demonstrating acooperative response can often ease community fears. Having a community activist participate in theplanning can also work benefits as they are working to make sure the community response is appropriate.12.7 HEADING.The HMRT should engage in public education activities that include pre-planning, emergency shelteringand evacuations, and providing for overall public awareness of chemical emergencies.


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12.7.1 The HMRT should develop school training programs that cover sheltering and evacuation procedures andchemical safety. These programs should be age appropriate. There are a number of existing programssuch as Safe Schools™ that are available and provide a number of appropriate course templates.12.7.2

A number of law enforcement, fire agencies, and emergency management agencies conduct public trainingacademies. In some communities there are community emergency response teams (CERT) that aretrained to assist with disaster response activities. The HMRT should integrate into these academies andprovide training on their specific activities. A standalone program should also be considered to providetraining for the general public.12.7.3

Outreach print materials and web-based information should be developed to provide an overview ofcitizens’ response to chemical emergencies, including pre-incident planning and community events.Informational documents that provide an overview of response capabilities is also helpful forcommunicating with chemical facilities and community groups. Calendars, which provide helpful tips,contact numbers, and local history, are popular items. Teaming with local artists and photographers canassist with the design of the materials and increases the popularity of the material.12.7.4

Conducting awareness training and response activity overviews for homeowner associations,neighborhood groups, and community activity groups can provide benefits relating to the communityreaction to a chemical release. The more outreach that is conducted prior to a release reduces the impactof a release. Using Tier 2 data, the HMRT can discuss potential impacts to the surrounding community, andpartnering with facilities to discuss these issues develops positive relationships.12.7.5

Developing materials and programs with toxic release inventory (TRI) 313 data is helpful. It is best to informlocal elected officials of the data as soon as possible, especially if the data shows a number of releases orincludes a serious release. Bad news never gets better with time. Getting out in front of the information isbetter than ignoring it.12.8 HEADING.There are a number of regulations that mandate HMRT interactions. Certain facilities and some operationsare required by various OSHA, DOT, and EPA regulations to hold training, exercises, and informationalsessions. Given the inherent risks that are present, HMRT should already have developed a relationshipwith these facilities but should also use these regulatory requirements to enhance the required interaction.12.8.1

The EPA Risk Management Program (RMP) requires the facilities covered by RMP to conduct annualexercises with the local HMRT and the LEPC. These facilities, which store or use high-risk materials that ifreleased could impact the community, are required to notify the LEPC that they are an RMP facility.12.8.2

The DOT PHMSA requires owners of pipelines to conduct awareness and informational training sessionsfor response agencies where the pipelines runs. HMRT should be aware of all pipelines and operators whooperate these pipelines and should be educated on their operation and risks.12.8.3

HMRT should be aligned with the AHJ fire code enforcement division. In many jurisdictions theresponsibility to conduct fire inspections and chemical storage inspections falls to the HMRT.12.8.4

The HMRT or designated persons on the HMRT should be the subject matter experts with regard to theapplicable chemical storage and use codes. The balance between outreach and code enforcement is a fineline, and the objective should be to ensure proper storage and use of dangerous materials. The more theHMRT knows about a facility, the better prepared they are. When a facility stores and uses dangerousmaterials according to the code, the less likely there is to be a release.12.8.5

In some instances the AHJ fire marshal also has investigatory and enforcement responsibilities forhazardous materials releases and chemical-related facilities. The HMRT should be familiar with localjurisdictional requirements and develop and maintain a working relationship with these personnel.


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12.1.6.2 The FBI HMRT might need local, state, or federal law enforcement agencies may require assistance fromthe local jurisdiction when operating at a high hazard crime scene. Having coordinating a relationship priorto the event ensures an efficient response.


FBI HMRT has changed names and is to narrow in scope. An HMRT may assist a local/state drug task force, ATF, FBI, etc.






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12.X INTELLIGENCE SHARING The HMR team should develop, and actively maintain, relationships that will help facilitate intelligence andinformation sharing; including formal relationships with regional, State, and National Intelligence Fusioncenters.

12.8.1

The HMR team can be a consumer of intelligence products distributed by fusions centers, such as officersafety bulletins, threats against chemical facilities, or missing/stolen hazardous materials.

12.8.2

The HMR team can be a contributor or producer of intelligence products that are distributed by fusion centerby providing technical analysis, hazmat/WMD threat assesments, or creating hazmat/WMD focusedbulletins on emerging trends or hazards.

12.8.3

The HMR should enroll and participate in Department of Homeland Security online intelligence portals andthe IAFC Hazmat Fusion center to receive and share hazmat/WMD best practices, case studies, andlessons learned.

12.8.4

Hazmat/WMD responders should maintain a wide professional network of other hazmat/WMD professionalsto exchange best practices, response options, training information, and technical advice.


In a world of rapidly growing CBRN threats and emerging technical hazards, hazmat teams have a need for intelligence and have resources and knowledge that can be shared to increase the preparedness level and safety of other responders.

The proposed language would encourage and recommend HMRTs take advantage of the intelligence sharing opportunities that exist by establishing the needed relationships to open the exchange of information.



Organization: Oakland County Hazmat Team



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A.3.3.18.4 Technical Decontamination. Technical decontamination is the process subsequent to gross decontamination designed to removecontaminants from responders (or neutralize contaminants on) responders , their equipment, and victims. Itis intended to minimize the spread of contamination and ensure responder safety. Technicaldecontamination is normally established in support of emergency responder entry operations at ahazardous materials incident, with the scope and level of technical decontamination based on the type andproperties of the contaminants involved. In non life-threatening contamination incidents, technicaldecontamination can also be used on victims of the initial release. Examples of technical decontaminationmethods are the following:

(1) Absorption

(2) Adsorption

(3) Chemical degradation

(4) Dilution

(5) Disinfecting

(6) Evaporation

(7) Isolation and disposal

(8) Neutralization

(9) Solidification

(10) Sterilization

(11) Vacuuming

(12) Washing

The specific decontamination procedure to be used at an incident is typically selected by a hazardousmaterials technician (see 7.3.4) and is subject to the approval of the incident commander. [472, 2013]


Decontamination can be accomplished through neutralization, not just removal.






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A.3.3.28 Fissile Material. Department of Transportation (DOT) regulations define fissile material as plutonium-239, plutonium-242,uranium-233, uranium-235, or any combination of these radionuclides. This material is usually transportedwith additional shipping controls that limit the quantity of material in any one shipment. Packaging used forfissile material is designed and tested to prevent a fission reaction from occurring during normal transportconditions as well as hypothetical accident conditions. [472, 2013]

Reviewer comment: This is a more restrictive, and more accurate, statement of definition for fissilematerial than the one found in the definitions section (where the definition would include manyradioactive isotopes which are not considered fissile materials).


This definition of "fissile material" is different from, and more accurate than, the one quoted in the definitions section of the standard.






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A.3.3.30 Hazardous Material. The following are explanations of several CBRN-related terms:

(1) CBRN. An abbreviation for chemicals, biological agents, and radiological particulatehazards radioactive hazards and nuclear (fission or fission/fusion, conventional or improvised)weapons .

(2) CBRN terrorism agents. Chemicals, biological agents, and radiological particulates that radioactivehazards or improvised nuclear weapons that could be released as the result of a terrorist attack.Chemical terrorism agents include solid, liquid, and gaseous chemical warfare agents and toxicindustrial chemicals. Chemical warfare agents include, but are not limited to, GB (Sarin), GD (Soman),HD (sulfur mustard), VX, and specific toxic industrial chemicals. Many toxic industrial chemicals (e.g.,chlorine and ammonia) are identified as potential chemical terrorism agents because of theiravailability and the degree of injury they could inflict. Biological agents are bacteria, viruses, or thetoxins derived from biological material. Radioactive agents are substances which emit radioactivity(alpha particles, beta particles or gamma rays), no matter what system is used for dispersal, but NOTnuclear weapons. Nuclear weapons produce massive amounts of energy from the destruction(conversion to energy) of matter in a fission or a fision/fusion reaction according the the formula

e=mc 2 . An an "improvised" nuclear weapon, a fission/fusion reaction, or even a "boosted fission"reaction is extremely unlikely to be employed due to the technology required, thus limiting the powerof an improvised nuclear agent to approximately 20 kT, or about the power of the bomb dropped onNagasaki, Japan at the end of World War II.

(3) Chemical terrorism agents. Liquid, solid, gaseous, and vapor chemical warfare agents and toxicindustrial chemicals used to inflict lethal or incapacitating casualties, generally on a civilian populationas a result of a terrorist attack.

(4) Biological terrorism agents. Liquid or particulate agents that can consist of a biologically derived toxinor pathogen to inflict lethal or incapacitating casualties.

(5) Radiological particulate terrorism agents. Particles that emit ionizing radiation in excess of normalbackground levels used to inflict lethal or incapacitating casualties, generally on a civilian population,as the result of a terrorist attack.

(6) Toxic industrial chemicals. Highly toxic solid, liquid, or gaseous chemicals, which have been identifiedas mass casualty threats that could be used to inflict casualties, generally on a civilian population,during a terrorist attack. [472, 2013]


In the original, the "N" in CBRN was ignored, and the "R" was not adequately explained.






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A.3.3.45.3 Radioactive Materials Packaging. Excepted packaging is packaging used to transport materials with extremely low levels of radioactivity thatmeet only general design requirements for any hazardous material. Excepted packaging ranges from aproduct's fiberboard box to a sturdy wooden or steel crate, and typical shipments include limited quantitiesof materials, instruments, and articles such as smoke detectors. Excepted packaging will contain non-life-endangering amounts of radioactive material.

Industrial packaging is packaging used to transport materials that present limited hazard to the public andenvironment. Examples of these materials are contaminated equipment and radioactive waste solidified inmaterials such as concrete. This packaging is grouped into three categories (IP-I, IP-2, IP-3), based on thestrength of packaging. Industrial packaging will contain non-life-endangering amounts of radioactivematerial.

Type A packaging is used to transport radioactive materials with concentrations of radioactivity notexceeding the limits established in 49, CFR, Part 173.431. Typically, Type A packaging has an innercontainment vessel made of glass, plastic, or metal and packing material made of polyethylene, rubber, orvermiculite. Examples of materials shipped in Type A packaging include radiopharmaceuticals and low-levelradioactive waste. Type A packaging will contain non-life-endangering amounts of radioactive material.

Type B packaging is used to transport radioactive materials with radioactivity levels higher than thoseallowed in Type A packaging, such as spent fuel and high-level radioactive waste. Limits on activitycontained in a Type B packaging are provided in Title 49, CFR 173.431. Type B packaging ranges fromsmall drums [55 gal (208 L)], to heavily shielded steel casks that sometimes weigh more than 98 than 125tons (100 114 metric tons tonnes ). Type B packaging can contain potentially life-endangering amounts ofradioactive material.

Type C packaging is used for consignments, transported by aircraft, of high-activity radioactive materialsthat have not been certified as “low dispersible radioactive material” (including plutonium). They aredesigned to withstand severe accident conditions associated with air transport without loss of containmentor significant increase in external radiation levels. The Type C packaging performance requirements aresignificantly more stringent than those for Type B packaging. Type C packaging is not authorized fordomestic use but can be authorized for international shipments of these high-activity radioactive materialconsignments. Regulations require that both Type B and Type C packaging be marked with a trefoil symbolto ensure that the package can be positively identified as carrying radioactive material. The trefoil symbolmust be resistant to the effects of both fire and water so that it will be likely to survive a severe accident andserve as a warning to emergency responders.

The performance requirements for Type C packaging include those applicable to Type B packaging withenhancements on some tests that are significantly more stringent than those for Type B packaging. Forexample, a 200 mph (321.8 km/hr) impact onto an unyielding target is required instead of the 30 ft (9.1 m)drop test required of a Type B packaging; a 60-minute fire test is required instead of the 30-minute test forType B packaging; and a puncture/tearing test is required. These stringent tests are expected to result inpackaging designs that will survive more severe aircraft accidents than Type B packaging designs. [472,2013]


A Metric tonne (spelled tonne, not ton) is larger than a ton- it is the equivalent of 2200 lbs, or 1.1 ton.





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A.11.9 (Appears to be wrong section number. 11.9 is Emergency Response Operations) The below paragraph starts off talking about NIMS personnel credentialing, but then goes into handling amutual aid request????Recommended NIMS personnel credentialing process: When a request for mutual aid is received by ajurisdiction, the potential supporting department or agency evaluates its capacity to absorb the anticipatedloss of resources that would be deployed. The assisting agency should not compromise their own mission.For example, can a fire department allow 20 percent of its equipment and personnel to be deployed toanother jurisdiction for 30 days and still meet its own community’s needs?

If the assisting department or agency determines that it can accommodate the request for resources, it mustnext identify specific personnel who will be deployed. The assisting department or agency should thenselect members for deployment. Some states have an authorized accrediting agency that will verify theresponder’s credentials and clear those who can provide mutual aid. The accrediting agency evaluateseach person’s credentials and determines whether the applicant meets the established criteria for thepositions required by the mission. For responders that are approved by the authorized accrediting agency,the following steps are taken:

(1) The applicant’s department or agency is notified.

(2) A record is created on the individual in the official credentialing database.

(3) An identification card or other credential is issued to the individual. (The identification card orcredential should include an expiration date and be reissued as appropriate.)

(4) Information on the applicant is uploaded to the incident management infrastructure.

The Figure A.11.9 illustrates the recommended credentialing process.

(This is given in Chapter 11. Is this figure from FEMA? If yes, then we should add a source line. Also, thefigure needs a caption.)

Figure A.11.9 An Illustration of the Recommended Credentialing Process.


Section appears to be a typo.



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Public Input No. 123-NFPA 475-2014 [ Section No. B.1.2.7 ]

B.1.2.7 Additional Publications.U.S. Coast Guard, 2703 Martin Luther King Jr. Ave, SE, Washington, DC 20593-7000, www.uscg.mil

Hazardous Materials Response Special Teams Capabilities and Contact Handbook , 2005

Chemical Hazards Response Information System (CHRIS)


The US Coast Guard is active in response activities to hazardous materials incidents on navigable waterways and their tributaries. They are also active in the maritime enforcment of rules and regulations pertaining to the transportation of hazardous materials and substances. The US Coast Guard, in some jurisdictions, is part of the Regional response Team effort(s) to hazardous materials incidents.






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