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What training requirements exist for workers involved in anthrax response and remediation?


Anthrax CollageA site-specific training program ensures that workers receive the hazard awareness training they need to work safely. The level of training required will depend on the types of activities that workers are performing. For anthrax response and remediation activities, training requirements are categorized as follows:

Emergency Response
The five levels of training for employees who initially respond to an emergency are listed from the lowest to highest level of competency below:
 
  • First Responder awareness level: 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 an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release.
First Responder awareness level

  • First Responder operations level: First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.
First Responder operations level

  • Hazardous Materials Technician: Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations level in that they will approach the point of release in order to plug, patch, or otherwise stop the release of a hazardous substance.
Hazardous Materials Technician

  • Hazardous Materials Specialist: Hazardous materials specialists are individuals who respond with and provide support to hazardous materials technicians. Their duties parallel those of hazardous materials technicians. However, those duties require a more directed or specific knowledge of the various substances they may be called upon to contain. The hazardous materials specialist would also act as the site liaison with federal, state, local, and other government authorities in regards to site activities.
Hazardous Materials Specialist

  • On-scene Incident Commander: Incident commanders will assume control of the incident scene beyond the first responder awareness level.
On-scene Incident Commander
 
Each level requires employers to have sufficient training or to have sufficient experience to objectively demonstrate competencies listed in 29 CFR 1910.120(q)(6). Certification of training is required.


Cleanup Operations
At sites where OSHA's HAZWOPER standard applies, the safety and health training program should be based on the job hazard analysis in the Health and Safety Plan (HASP) and other relevant OSHA requirements. The training elements required by HAZWOPER include:
  • Safety and Health Training ProgramInitial anthrax hazard awareness training for site workers and supervisors,

  • Exceptions to initial training requirements,

  • Site-specific anthrax hazard awareness briefings for visitors and workers,

  • Refresher training,

  • Qualification of trainers,

  • Training certification, and

  • Emergency response training.
All employees who work on a HAZWOPER cleanup site (not limited to cleanup crew) where they are exposed to hazardous substances, health hazards, or safety hazards, must have training that meets the requirement of 29 CFR 1910.120(e) or have equivalent experience and/or training. The four levels of training for employees who work on cleanup operations are listed below:
  • General site workers,

  • Workers on site only occasionally for a specific limited task (unlikely to be exposed over limits and not required to wear respirators),

  • Workers regularly on site in monitored and fully characterized task areas (unlikely to be exposed over limits and not required to wear respirators), and

  • Managers and supervisors.
Each level requires employees to have sufficient training or to have equivalent experience. Certification of training is required. The required elements of training are:
  • Names of personnel and alternates responsible for site safety and health,

  • Safety, health, and other hazards present on the site,

  • Use of personal protective equipment (PPE),

  • Work practices by which the employer can minimize risks from hazards,

  • Safe use of engineering controls and equipment on the site,

  • Medical surveillance requirements including recognition of the symptoms and signs that might indicate exposure to hazards,

  • Contents of the site safety and health plan including:

    • Decontamination procedures in accordance with 29 CFR 1910.120(k),

    • An emergency response plan meeting the requirements of 29 CFR 1910.120(l) for safe and effective responses to emergencies including the necessary PPE and other equipment,

    • Confined space entry procedures, and

    • A spill containment program meeting the requirements of 29 CFR 1910.120(j).


Post-Emergency Cleanup
Where the cleanup is done on plant property using plant or workplace employees, these employees must have completed the training requirements of the following:


Appropriate Safety and Health Training
A site-specific training program ensures that workers receive the training they need to work safely. Workers must receive all training required by applicable OSHA standards. This training may be included in the HAZWOPER curriculum. Examples of relevant training required by other standards may be found on the following pages:


Anthrax-Specific Hazard Awareness Training
Anthrax-specific hazard awareness training should help workers understand the health hazards of anthrax and how to protect themselves from exposure to spores. Specific topics might include:
  • How workers might be exposed to spores, the signs and symptoms of infection, and medical conditions that could place them at increased risk (such as compromised immune systems),

  • Where contamination has been identified in the facility, and the status of decontamination of those areas, and

  • How to minimize the risk of disease through specific standard operating procedures and controls (such as engineering controls, work practices, housekeeping, or PPE), and whether specific measures are expected to be temporary or permanent.
There are additional training requirements for workers preparing contaminated materials or other hazardous materials for transportation to a treatment or disposal facility. These requirements can be found in the federal hazardous materials transportation regulations at 49 CFR Part 172, Subpart H.


Additional Training Information

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