OSHA Seeks Input on Emergency Response Standard

Thursday, June 12, 2014

OSHA Seeks Input on Emergency Response StandardPrompted by the 2013 fire and explosion that killed 12 firefighters at a Texas fertilizer facility, as well as other recent incidents, OSHA is considering the development of a standard on emergency response and preparedness.

Stakeholders are invited to provide input at an informal OSHA meeting in Washington on July 30 and, if needed, on July 31. Attendees must register by July 2.

OSHA first sought public input on an emergency response and preparedness rulemaking in 2007, when the agency issued a Request for Information. In that request, OSHA noted that although several of its current standards address certain issues emergency responders face (including blood borne pathogens and confined spaces), some of those standards are decades old.

In 2012, 231 deaths occurred in the protective service industry, which includes firefighters and law enforcement personnel, according to Bureau of Labor Statistics data.

Story from The National Safety Council


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NFPA Offering More Emergency Responder Guides for EVs

Friday, April 11, 2014

NFPA Offering More Emergency Responder Guides for EVsNFPA has posted more guides to prepare firefighters and other emergency responders for incidents involving electric vehicles (EVs). The guides are part of NFPA's Electric Vehicle Safety Training project, through which the association works with automobile manufacturers to inform the fire service and other first responders as the use of EVs increases.

These free first responder guides have been added to the website, according to a May 5 post by Mike Hazell:

  • 2014 Honda Accord HEV Emergency Response Guide
  • 2014 Honda Accord PHEV Emergency Response Guide
  • First Responder's Guide for the 2014 Infiniti Q70 Hybrid
  • First Responder's Guide for the 2014 Infiniti QX60 Hybrid
  • First Responder's Guide for the 2014 Nissan Pathfinder Hybrid
  • First Responder's Guide for the 2014 Nissan LEAF
  • First Responder's Guide for the 2015 Nissan LEAF



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Hazcom 2012 & GHS: What Rescuers Need to Know

Tuesday, February 11, 2014

Hazcom 2012 & GHS: What Rescuers Need to KnowAs an emergency responder, it is important to have a good understanding of the dangers and precautions regarding hazardous chemicals. Whether you’re a member of an in-plant industrial team or a municipal fire department, chemical hazards are always a critical factor in emergency incidents. That’s why it’s imperative to identify any particularly hazardous chemicals in your response area. Learn as much as you can, before the emergency happens.

The Time is Now
The first requirement went into effect in December 2013, which means that workers who use hazardous chemicals must be trained to understand the new Safety Data Sheets (SDS), formerly known as Material Safety Data Sheets (MSDS). While employees must already have fluency, manufacturers of these products have until December 1, 2015, to switch over to the new format.

OSHA’s HazCom 2012 standard (29 CFR 1910.1200) was revised to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The changes make the information easy to understand across industries, countries and education levels. By adopting and enforcing one standard for labels and safety data sheets that accompany chemicals, employers, workers, health professionals and emergency responders will be better able to address the risks associated with these substances.

As in the past, the HazCom standard imposes certain requirements on manufacturers and importers of chemicals - as well as on employers whose employees can be exposed to chemical hazards in the workplace. The standard “applies to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.”

Note: This article addresses rescue teams that are subject to Federal OSHA requirements or State Plans operated in lieu of Federal requirements. In states that are not OSHA State Plan states, rescuers employed by a state or political subdivision of the state may not be subject to these requirements.

Q&A for Rescue Teams

Is my rescue team required to meet the HazCom standard?

For rescue services or in-house rescue teams in certain types of industrial facilities, the answer is normally yes. HazCom requirements would apply because team members are working inside the facility and can obviously be exposed to chemical hazards under normal working conditions or in a foreseeable emergency. For others, however, what appears to be a simple answer may not be that simple.Hazcom 2012 & GHS: What Rescuers Need to Know

Is compliance required if we don’t work around hazardous chemicals?
The simple answer would seemingly be no, but that answer can be, and likely is, incorrect. In fact, the rescue team often needs to look no farther than its own cache of equipment to find the “hazardous chemical.” The reason the applicability of HazCom to rescue teams is often overlooked is because of assumptions that we make - in this case, rescuers often assume that the term “chemicals” means what we commonly think it means. But, as is often the case with regulations and statutes, words may be specifically defined to include or exclude certain things that common usage does not.

For example, under the HazCom standard, “chemical” means “any substance, or mixture of substances.”  “Hazardous chemical” means “any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.”  Hazcom 2012 & GHS: What Rescuers Need to Know

As explained by OSHA in its Guidance for Hazard Determination:

The definition of a chemical in the HCS [Hazard Communication Standard] is much broader than that which is commonly used. The HCS definition of chemical is "any element, chemical compound, or mixture of elements and/or compounds."

According to this definition, virtually any product is a "chemical." By this definition, it would mean that “air” is considered a “chemical” under the standard, and OSHA includes “gas under pressure” in its definition of “physical hazards.” Consequently, as one example, the rescue team needs to look no further than its SCBA bottles or its air source for supplied air respirators and charged airlines to find a “hazardous chemical” for purposes of the HazCom standard. Even facilities with comprehensive HazCom programs sometimes overlook their rescue team’s air sources in their programs.

As a rescuer, it's important to get familiar with the new formatting of Safety Data Sheets (SDS) and the GHS symbols now. Make sure to review these standards in their entirety as well as your organization’s HazCom policies and procedures. You and your team will be more prepared as these changes are put into place.

Here's a quick guide to the new GHS symbols from OSHA, which will be required by June 1, 2015.

Note: These new OSHA pictograms do not replace the diamond-shaped DOT labels required for the transport of chemicals.

Hazcom 2012 & GHS: What Rescuers Need to Know



National Safety Council’s newsletter, “Safer Workplaces”

OSHA Fact Sheet – Hazard Communication Standard Final Rule

OSHA Quick Card – Hazard Communication Safety Data Sheets

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Input Deadline for NFPA 350 Fast Approaching!

Tuesday, December 03, 2013

Input Deadline for NFPA 350 Fast Approaching! Deadline: January 3, 2014. There's only about 30 days left to submit your input on the proposed NFPA 350 Best Practices Guide for Safe Confined Space Entry and Work. If you are involved in any kind of confined space work or rescue (municipal or industrial), now is the time to offer your comments. While it is currently listed as a “Best Practices Guide,” that does not mean that at some point in the future it won’t possibly become an NFPA Standard. So, whether you agree or disagree, the time to offer your input is NOW!

Public comment will be accepted online until January 3, 2014. Go to www.nfpa.org/350. In order to comment you must log in with your email and password - or you can quickly create an account.

Click here to download the PDF version. (Note: Download may take up to 3 minutes depending on your computer.)

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Suggested Operating Guidelines for Training

Thursday, November 07, 2013

Suggested Operating Guidelines for TrainingSuggested Operating Guidelines (SOG) - written directives that establish a standard course of action on how a department intends to operate.

Most departments have SOGs for different rescue scenarios, but often overlook the importance of establishing procedures for safe training. A look at the stats reveals that while 10% of firefighter deaths occur in the line of duty, more than 7,000 injuries occur each year during training!

SOGs for safe training operations should be developed by the Authority Having Jurisdiction (AHJ). Each department has different needs, and the type of training can vary tremendously. Even interdepartmental training varies. Start by defining the who, what, where and when for your organization. Simple, but effective in establishing a comprehensive plan for safe training.


a. The Instructor
Who is allowed to conduct training? What qualifications do they need prior to conducting training? What training have they completed to make them a subject matter expert oSuggested Operating Guidelines for Trainingn what they are about to teach? Have they been trained to identify the potential hazards involved in the training and emergency procedures? Do they have the knowledge to identify the proper and needed equipment to do the training? Have they been trained to identify safe areas to conduct the training?

b. The Student
Who is allowed to participate in the training? (i.e., department members only, full duty only, physical requirements, prerequisites, etc.)


What type of training is to be allowed, and to what extent or level of training? What will be allowed as “in-service” training vs. what is allowed at the academy only? An example of in-service training might be “patient packaging and reviewing M/A systems,” while life-loading lines may be academy only – or only conducted when a designated instructor is present. What hazards are associated with the training and what precautions need to be taken? What laws and regulations are applicable to the training?

...Suggested Operating Guidelines for Training

Where will the training be conducted? Classroom, apparatus floor, roof of firehouse, other field locations, training prop only? It is important that designated, approved, and pre-identified areas be established in order to conduct safe and effective training.


When will the training be conducted? What about refresher training? How often and when will training schedule cover all shifts and all personnel? Is weather a factor when scheduling? Off-duty training or not?


Next Steps - Organizing the Training Program

Suggested Operating Guidelines for TrainingLesson plans, outlines, and a system to qualify those who will be giving the instruction should be mandatory, especially when it comes to technical rescue training. Fire departments have a tendency to fall back on having the “experienced” guy train the “new” guy. Or, the line officer may be responsible for teaching a technique he is not totally familiar with. This works until somebody gets hurt. We all know that criminal and civil litigation issues can bury a department and its command staff.

Appoint a “Training Chief/Officer,” who can identify the department’s specific training needs, put a plan in place and keep the team on the training track. Identify risks, write solid lesson plans and operating guidelines, and create a solid schedule for training. Detailed outlines should be established for each skill/technique that is taught, and should be accessible to trainers, and trainees.

Send designated training officers to technical rescue courses that meet and issue certification to NFPA 1006. Note that most (if not all) rescue equipment comes with a warning from the manufacturer stating that “the enclosed literature on the use and care of this equipment is no substitute to receiving proper training.” Enough said.

Conducting safe rescue training procedures should be included in any good SOG. Establishing definite training protocols is the first step to avoiding injury or worse.

West Valley Fire's website has many sample Standard Operating Guidelines for download. Congrats to that department for putting their ideas out there, and sharing the info with the rest of us. 

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