OSHA HAZWOPER Incident Command System Criteria

Occupational Safety and Health Administration (OSHA) outlines employer compliance requirements regarding Hazardous Waste Operations and Emergency Response (HAZWOPER) contained within 29 CFR 1910.120.

Contained within the HAZWOPER standard is the topic of Emergency Response Program to Hazardous Substance Releases, and the requirements and elements of an Emergency Response Plan, specifically outlined in section 1910.120(q).

A critical element of emergency response planning is the implementation of an Incident Command System (ICS), further outlined in paragraph 1910.120(q)(3)(i). The ICS is an organized approach to effectively control and manage operations at an emergency incident.

For example, an emergency response involving hazardous substances may include a fire condition. Anyone who has ever served as a firefighter knows that responding to a fire requires strategic training, planning, communication and coordination of personnel and equipment, implemented through a specific chain of command. The ICS is not much different than the "command post" approach used for many years by the fire service. During large complex fires involving several companies and many pieces of apparatus, a command post is established. This enables one individual to be in charge of managing the incident, rather than having several officers from different companies making separate, and sometimes conflicting, decisions. The individual in charge of the command post would delegate responsibility for performing various tasks to subordinate officers. Additionally, all communications are routed through the command post to reduce the number of radio transmissions and eliminate confusion. Strategy, tactics, and all decisions are made by one individual. The ICS is a very similar system, except it is implemented for emergency response to all incidents, both large and small, that involve hazardous substances.

ICS Criteria.

Some of the emergency response elements of the ICS to be implemented by senior emergency response official(s) shall include and address:

• Emergency communications
• Site analysis
• Use of engineering controls
• Maximum exposure limits
• Hazardous substance handling procedures
• Use of any new technologies
• Specific personal protective equipment (PPE) requirements such as respirators
• Limiting the number of emergency response personnel at the emergency site
• Assigning qualified back-up personnel ready to provide assistance, such as rescue or other life saving measures
• Recognition of immediately dangerous to life or health (IDLH) and/or imminent danger conditions, and the authority to alter, suspend, or terminate those activities
• Post incident decontamination procedures

Covered ICS Employees.

Specialist employees authorized and appointed for ICS operations each require specific training and include:

• First Responders
• HAZMAT Technicians
• HAZMAT Specialists
• Safety Officers
• Incident Commanders

Depending on the overall size and scope of the incident, the number of these specialist employees will vary. And often, these roles can change as needed and delegated by the individual in charge of the ICS. As we all know, emergency incidents do not always have the same outcome, but rather follow and unfold in a minute by minute, hour by hour pattern. A small controllable incident can easily become an out-of-control, larger incident due to an explosion, hazardous chemical release, and casualty exposures of employees and general public.

Incident Commander.

At any given time, there must be at least one person responsible for incident command operations. The Incident Commander is the individual who, at any one time, is responsible for and in control of the response effort. This individual is the person responsible for the direction and coordination of the response effort. An incident commander's position should be occupied by the most senior, appropriately trained individual present at the response site. Yet, as previously mentioned, and appropriate by the level of response provided, the position may be occupied by many individuals during a particular response as the need for greater authority, responsibility, or training increases. For example, it is possible for the first responder at the awareness level to assume the duties of incident commander until a more senior and appropriately trained individual arrives at the response site.

Any emergency responder acting as an incident commander should be trained to fulfill the obligations of the position at the level of response they will be providing, as outlined in section 1910.120(q)(6)(v):

• Know and be able to implement the employer's incident command system.
• Know how to implement the employer's emergency response plan.
• Know and understand the hazards and risks associated with employees working in chemical protective clothing.
• Know how to implement the local emergency response plan.
• Know of the state emergency response plan and of the Federal Regional Response Team.
• Know and understand the importance of decontamination procedures.

To learn more about assuming an incident command role within a HAZMAT team, check out NET's 8-Hour Incident Command course.