NFPA Journal®, March/April 2008

By Gregory G. Noll, CSP, CHMM

The threat of terrorists employing weapons of mass destruction (WMD), combined with the increasing use of hazardous materials (HM) in criminal activities, has significantly altered the traditional philosophies of hazmat emergency response. Today, the classic distinctions between offensive and defensive tactics that have been the cornerstones of national hazmat operations standards since the 1980’s are blurred by the development of newer tactical and operational procedures designed to meet these emerging threats.

The objectives of this article are to provide emergency response personnel with background information to help them assess their current HM/WMD training programs and to provide an overview of the regulations and voluntary consensus standards that they should consult to ensure that their personnel have the skills and competencies to perform the expected tasks. Specific emphasis will be placed upon the recently revised 2008 edition of NFPA 472, Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents.

NFPA 472 is a standard for all emergency responders, and the technical committee that developed it reflects the multidisciplinary nature of HM/WMD emergency response. The membership of the Technical Committee on Hazardous Materials Response Personnel currently consists of 33 members of the fire service; law enforcement; emergency medical services (EMS); industry, including hazardous materials manufacturing and transportation; the training and education community; research and testing laboratories; federal government agencies; and subject matter experts.

NFPA 472 is not a procedures-based, "how to respond" standard. Rather, it addresses the minimum competencies required for those who respond to HM/WMD incidents and are necessary for a risk-based response. Although NFPA 472 is not a fire service professional qualification standard, it is adopted by reference in NFPA 1001, Firefighter Professional Qualifications.

Emergency responder health and safety: HM vs. WMD
During the past decade, HM/WMD training philosophies have evolved into two different schools of thought. The first says that WMD is distinctly different than HM and should be viewed as a separate and distinct field, while the second says that you cannot safely respond to WMD events if you don’t first understand HM response and safety. It is the opinion and philosophy of the Technical Committee on Hazardous Materials Response Personnel that an emergency responder cannot safely and effectively respond to an incident involving the criminal use of hazardous materials or weapons of mass destruction without first understanding the basic principles of HM emergency response that have been in existence for the last 30 years.

What are the differences between an HM and a WMD incident? From a health and safety viewpoint, very little. Hazardous materials are any solid, liquid, gas, or energy that, when released into the environment, can harm people, property, or the environment. Weapons of mass destruction, as defined by Title 18 U.S. Code, describes the same materials and effects but in measurable quantities. The primary difference between these two lies in the events leading up to the release. In other words, was the release accidental or was it done with criminal intent? While the events that lead to an HM/WMD incident may vary, however, the actions responders implement upon arrival are typically the same.

As emergency responders and agency administrators, many of us have been asked to develop or improve our agency’s HM/WMD response capabilities. The U.S. Occupational Safety and Health Administration provides guidance to public and private entities that are responsible for hazardous material emergency and post-emergency response operations through 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response. The U.S. Environmental Protection Agency also provides comparable regulations through 40 CFR 311. While these regulations were originally promulgated to improve HM safety, recognizing that they are also applicable to incidents involving WMD threats and agents is important.

Both the OSHA 1910.120 and EPA 40 CFR Part 311 regulations provide specific requirements for the skills and competencies required for personnel who will respond to, or work at, HM incidents. The OSHA requirements were originally derived from early drafts of NFPA 472 as the OSHA regulation was being developed in the late 1980’s.

Regardless of response discipline, personnel who respond to HM/WMD incidents must meet the requirements of OSHA 1910.120(q). While OSHA 1910.120(q) tells you what you must do, NFPA 472 provides the authority having jurisdiction (AHJ) with specific guidance on the skills and competencies personnel need to perform their tasks as outlined in their organizational concept of operations.

A tool to train your personnel
Since its initial release in 1989, NFPA 472 has gone through five revisions, with the 2008 edition being the most recent. In contrast, OSHA 1910.120 has not been revised since its initial promulgation in 1989. Most would agree that the world is significantly different today than it was in 1989.

In developing the 2008 edition of NFPA 472, the technical committee decided to take a "holistic approach" and reexamine the philosophy and framework on which the standard was developed. In simple terms, everything was on the table for discussion.

As part of this process, the committee focused on the blurred distinction between "traditional hazmat response" and its relationship to the growing HM/WMD terrorism response issues, and the perception that the current standard does not address the needs of the emergency response community as a whole. Ultimately, the technical committee wanted the standard to focus on responders being trained to perform their expected tasks, regardless of their discipline.

As a result, the 2008 edition of NFPA 472 was revised with several key operational philosophies in mind.

First, emergency response operations to a terrorist act or a crime that uses hazardous materials are based on the concepts of hazardous materials response. In simple terms, a responder cannot safely and effectively respond to terrorism or a crime involving HM/WMD if he or she doesn’t first understand the basic principles and concepts of hazardous materials response.

Second, the scope of NFPA 472 applies to all emergency responders, regardless of discipline, who may respond to the emergency phase of an HM/WMD incident. In simple terms, if you are called to respond to an HM/WMD incident, you fall within the scope of the standard.

Finally, NFPA 472 provides a vehicle by which an AHJ can meet the training requirements of OSHA 1910.120(q). Emergency responders, regardless of discipline and organizational affiliation, should be trained to perform their expected tasks. Given the real-world demands of limited time and resources, training should focus on an individual’s expected duties and tasks.

Key revisions
Traditionally, any discussion of HM emergency responder training requirements has focused on which responder level an individual falls into, rather than the OSHA 1910.120 (q)(6) requirement that "…training shall be based on the duties and function to be performed by each responder of an emergency response organization." The result is that responders are often trained in areas that clearly do not fall within their concept of operations or response capabilities.

Under OSHA 1910.120(q), for example, first responder-operations personnel are expected to perform defensive product control measures and to use self-contained breathing apparatus, even when they are not issued SCBA or expected to perform product control or technical decontamination tasks. A major goal of the 2008 revision of NFPA 472 was to make matching required skills and competencies with expected duties and tasks easier.

The following summarizes the changes that may have an impact on HM/WMD emergency response operations.

Scope and purpose
The scope and purpose of NFPA 472 are based on the principles that emergency responders, regardless of discipline and organization, should be trained to perform their expected tasks; that required competencies are necessary for the delivery of a risk-based response process at an HM/WMD incident; and that personnel not directly involved in providing on-scene emergency response services, such as hospital first-receivers, are not covered under the scope of NFPA 472. Competencies for EMS personnel remain in the 2008 edition of NFPA 473, Competence of EMS Responders Responding to Hazardous Materials/Weapons of Mass Destruction Incidents.

The Technical Committee on Hazardous Materials Response Personnel defines the riskbased response process as a systematic process by which responders analyze a problem involving HM/WMD, assess the hazards, evaluate the potential consequences, and determine the appropriate response based on the facts, science, and circumstances of the incident.

Definitions
A variety of terms has been used to describe terrorism agents and the criminal use of hazardous materials. These include NBC, B-NICE, CBRN, and CBRNE. However, these terms do not have a regulatory basis and continue to change fairly regularly.

The technical committee ultimately chose to define hazardous materials as "Matter (solid, liquid, or gas) that, when released, is capable of creating harm to people, the environment, and property. This includes weapons of mass destruction (WMD), as defined in 18 U.S. Code Section 2332A, as well as other criminal use of hazardous materials, such as drug labs, environmental crimes or industrial sabotage, etc." This incorporates both HM and WMD into a single definition and allows HM and WMD competencies to be combined into a single document.

Awareness-level personnel
In the 2008 edition of NFPA 472, there is a major change in how awareness-level responders are viewed. The committee dropped the term "responder" from the awareness level, as these individuals are typically not emergency responders. Examples of awareness-level personnel include plant security personnel, public works and facility maintenance personnel, and others who require OSHA hazard communications (OSHA 1910.1200) training.

Awareness-level personnel are now defined as "persons who, in the course of their normal duties, could be the first on the scene of an emergency involving a HM/WMD and who are expected to recognize the presence of HM/WMD, protect themselves, call for trained personnel, and secure the area." In simple terms, they are the first to discover an incident rather than the first to respond.

Historically, some have viewed firefighters and EMS personnel as awareness-level responders who can recognize a hazardous material release from a safe distance and activate the local emergency response plan. With the threat of terrorism and the growing trend of illicit drug labs, however, firefighters and law enforcement and EMS personnel are now expected to do far more than observe from a safe distance. In addition, a large number of law enforcement and EMS personnel are now being provided with personal protective clothing because of potential WMD threats. As a result, these responders, per OSHA 1910.120(q), are now expected to perform tasks that go far beyond the traditional awareness-level tasks of recognizing the threat, notifying the proper authorities, and protecting themselves.

Operations-level responder
The most substantial revisions to NFPA 472 pertain to the operations-level responder, and these reflect the changes in the response community created by the threats of WMD and the criminal use of HM. These revisions will also facilitate the adoption and use of NFPA 472 by non-fire-service disciplines. There are no significant changes for fire service personnel who were previously trained to the operations-level requirements of the 2002 edition of NFPA 472.

Individuals responding to the scene of an HM/WMD incident during the emergency phase are now viewed as operations-level responders. These include fire and rescue personnel, law enforcement personnel, EMS personnel, individuals from private industry, and other allied professionals.

To better address the issue of matching requisite skills and competencies with expected duties at the operations level, NFPA 472 breaks operations-level competencies into two categories: core competencies and mission-specific competencies.

Core competencies are required of all emergency responders who must respond to an HM/WMD incident. However, they do not include any product control or personal protective clothing and equipment competencies, and decontamination is limited to the ability to perform emergency decontamination. While there are clearly some additional requirements pertaining to initial incident analysis, these new core competencies are not significantly greater than the awareness competencies found in the 2002 edition of NFPA 472.

Mission-specific competencies, which are optional, are provided so that the AHJ can match the expected tasks and duties of its personnel with the required competencies. They are not mandated and should be viewed as optional at the discretion of the AHJ, based upon an assessment of local risks.

Mission-specific competencies were developed by combining the hazardous materials technician competencies in specific areas, such as the use of personal protective equipment (PPE), that are found in the 2002 edition of NFPA 472 and new competencies that were developed where needed—for example, for victim rescue and recovery, and evidence preservation. They allow emergency responders to perform mission specific tasks without being fully trained to the hazmat technician level.

Mission-specific competencies include using PPE, as provided by the AHJ; performing technical and mass decontamination, product control, air monitoring and sampling, and victim rescue and recovery operations; preserving and sampling evidence; and responding to illicit laboratory incidents.

This shift to operations-level core and mission-specific competencies more accurately describes the tasks now performed by emergency response disciplines in light of current threats.

Some individuals have legitimately questioned the ability of operations-level responders to perform traditional hazardous materials technician tasks. To ensure the safety of personnel performing mission-specific competencies, the 2008 edition of NFPA 472 also requires that the optional mission-specific competencies be performed under the guidance of a hazardous materials technician; an allied professional such as a certified industrial hygienist, a subject matter expert, or a product specialist, as determined by the AHJ; or standard operating procedures.

While there are minimal changes for the fire service, this does represent a change for the law enforcement and emergency medical services community. Historically, many law enforcement and emergency medical providers have viewed themselves as awareness-level personnel. Under the revised NFPA 472, most law enforcement patrol officers would be trained to the operations core competencies, while law enforcement specialized operations with a higher probability of HM/WMD exposure, including SWAT and explosive ordnance disposal teams, mobile field forces, and forensic units, would be trained to those mission-specific competencies based on their concept of operations and expected duties.

NFPA 1001 – Firefighter I
Historically, NFPA 1001 Firefighter I candidates were only required to train to the awareness level to meet NFPA 1001, Fire Fighter Professional Qualifications. To resolve conflicts between NFPA 472 and NFPA 1001, and to ensure consistency with OSHA interpretations that firefighters should be trained to the operations level, the 2008 edition of NFPA 1001 has also been revised so that a Firefighter I must now meet the NFPA 472 core competencies for operations-level responders and the mission-specific competencies for product control.

There are minimal differences between fire service personnel who were previously trained to operations-level requirements of the 2002 edition of NFPA 1001 and those who will be trained to the core competencies for operations-level responders and the mission-specific competencies for product control in the 2008 edition of NFPA 472. As a result, few changes should be required to fire service training curricula that previously certified firefighters to the competencies for operations level responders in the 2002 edition of NFPA 472.

EMS personnel
Competencies for EMS personnel are published in NFPA 473, Competencies for EMS Personnel Responding to Hazardous Materials/WMD Incidents. The 2008 edition of the standard has been completely rewritten to address the hazards that EMS personnel encounter from HM/WMD.

Under NFPA 473, all EMS personnel operating at HM/WMD incidents must now be trained to meet the operations-level core competencies found in the 2008 edition of NFPA 472. Remaining competencies are based on whether the individual is a basic life support responder, such as an EMT-A/B or an emergency-care first responder, or an advanced life support responder, such as an EMT-I, an EMT-P, a medical director, or a medical team specialist.

Hazardous materials technician
There are no significant changes to HM technician competencies. However, the definition has been revised to clarify their expected competencies. Hazardous materials technicians respond to HM/WMD incidents using a risk-based response process by which they analyze a problem involving HM/WMD, select applicable decontamination procedures, and control a release using specialized protective clothing and equipment.

The definition of a hazardous materials response team (HMRT) was also modified to require that HMRTs perform HM technician-level skills and be staffed with personnel trained to the HM technician level. Given that hazmat entry units are a typed resource under the National Incident Management System (NIMS), members of the technical committee responsible for NPFA 472 believe that this will ensure consistency in operational capabilities. In addition, the NIMS resource typing standards reference NFPA 472 as the basis for hazmat entry unit training.

The revisions to NFPA 472 are another step in the maturation of the HM/WMD response community. Rather than trying to fit emergency responders into a regulatory box, NFPA 472 now provides emergency response agencies with a competency-based framework to ensure that responders are trained to perform their expected tasks and assigned duties. In addition, training programs designed to meet the requirements of NFPA 472 will far surpass the regulatory requirements of OSHA 1910.120 (q).