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A 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.
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- 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.
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- 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.
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- 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.
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- On-scene Incident
Commander: Incident commanders
will assume control of the incident
scene beyond the first responder awareness
level.
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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:
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Initial 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).
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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:
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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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