Building a Fire Department Hazmat Program

By Joshua Fowler

In November 2015, I made my leap from worker bee to managing bee. After two years of studying, I promoted to the rank of district chief (our department’s equivalent to battalion chief). I found myself at the helm of our department’s special operations that included hazmat and technical rescue. Since I am not a subject matter expert (SME), I set out to learn all I could about establishing a hazmat program in my department. The next two years I researched, experimented, and learned many lessons that I share with you in this article.

If you must start your program from scratch, your work is cut out for you. However, the silver lining is that you get to customize the program to your liking. You will not have to undo policies and procedures that are irrelevant and outdated.

The following resources are helpful when beginning a hazmat program:

The Environmental Protection Agency (EPA) NRT-1: Hazardous Materials Planning Guide. The original “Orange Book” was first published in 1987 and updated in 2001. It addresses topics such as determining if there is a need for a hazardous materials response team (HMRT), hazard analysis, training, medical monitoring, equipment, cost/budget considerations, and response plans.
National Fire Protection Association (NFPA) 475, Recommended Practice for Organizing, Managing, and Sustaining a Hazardous Materials/Weapons of Mass Destruction Response Program.1 This standard addresses management of an HMRT program and many of the points as the EPA’s Guide. It is, however, more updated relative to many of the current issues you will face as a program manager (which will be addressed in more detail later).

Hazards Analysis

A hazards analysis will help you to realistically assess the potential for a hazmat incident to occur in your community. It includes determining the answers to questions such as the following: What does the community expect from such a team? What are the department’s present capabilities, and what will be its future capabilities? What would it cost to build and maintain the team?

The analysis would also involve the following areas.

Chemicals. Which are present, in what quantity, their physical and chemical properties (how they will behave, will they cause harm, what will they do if left alone or if messed with?), their locations, how are they used and stored, and which transportation routes are used to get them to and from your community.
Vulnerability. Which community areas and individuals may be affected if potentially exposed to the chemicals; which facilities, property, or environments would be susceptible to damage/harm if a release were to occur. Are there relevant past events, or is there a history of incidents? Another helpful tool is the local Tier II data compiled to meet the requirements of the U.S. EPA Section 312-Emergency Planning and Community Right to Know Act (EPCRA), known as the Superfund Amendment Reauthorization Act (SARA) Title III. Identify vulnerable community populations such as those in schools, day cares, retirement centers, assisted living/nursing homes, hospitals, and other facilities that may be impacted by an incident and alternative strategies for their protection (evacuation or sheltering in place, for example).
Natural events. Consider how natural events that may affect your community will interact with at-risk facilities. Examine historical weather data to determine the frequency of usual and unusual weather-related events. Here on the Gulf Coast, hurricanes must be anticipated. Review the types of events for your area, and plan for them.
Risk analysis. This is an assessment of the consequences that might occur, based on the estimated vulnerable zones, if a probable release of a hazardous material were to occur. It is a judgment of both the probability and severity of consequences based on incident history, local experience, and the best available current technological information. Local Emergency Response Plans (ERPs) can be helpful in making the risk analysis. The ERP should include information on the frequency and impact of expected accidental releases. Another helpful resource is the EPA’s Guides to Chemical Risk Management—New Ways to Prevent Chemical Incidents.

Training

Training literally has to be by the book. Three sources for determining training levels are the Occupational Safety and Health Administration (OSHA), which is law; the EPA; and the NFPA, which is voluntary. Hazmat training requirements are contained in two Codes of Federal Regulations (CFRs). OSHA 29 CFR 1910.120 is the hazmat standard and the primary regulatory requirement normally cited. In states where emergency responders are not covered by state OSHA requirements, EPA 40 CFR 311 takes precedence; it mirrors the OSHA 29 CFR 1910.120 requirements.

HMRTs should be familiar with NFPA 472 and NFPA 1072. NFPA 472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents, is a voluntary consensus standard that defines minimum competencies for personnel responding to hazmat/weapons of mass destruction (WMD) incidents. NFPA 1072, Standard for Hazardous Materials/Weapons of Mass Destruction Emergency Response Personnel Professional Qualifications, lists the minimum job performance requirements for personnel at the scene of a hazmat/WMD incident at the following levels: awareness, operations, operations mission-specific, hazardous materials technician, and incident commander (IC). If you or your department operates under the NFPA, hazmat personnel trained to the NFPA competencies exceed those established by OSHA or EPA regulations.

Your program should serve as the source of personnel training and should include a mechanism for evaluating personnel competence as required by OSHA regulations and NFPA standards. Program managers need to be aware that OSHA’s current regulation (CFR 1910.120, HAZWOPER) has not been updated since its inception in 1990. The hazmat world, as we know it, has changed significantly in the past 28 years. NFPA standards, however, are typically updated on a five-year cycle to reflect the ever-changing issues and paradigms affecting the hazmat response community (NFPA 472 is now in its seventh edition). Your training program should provide accurate, relevant, and engaging training, which also will help with recruitment and retention.

Base the level of training (operations vs. technician level) on the local risks assessed by the authority having jurisdiction (AHJ), the level of hazmat emergency services provided by the AHJ, the tasks to be performed (defensive vs. offensive capabilities), time sensitivity in the sense that you have the time available for training, and the financial commitment of the AHJ.

Medical Surveillance

This section will be brief, but not because it is not important. A medical surveillance program is crucial to protect your most important resource, your personnel. We are beginning to better understand the health implications incurred over the course of a career for our fire service personnel. Procedures that were once considered signs of weakness, such as wearing self-contained breathing apparatus (SCBA), are now being backed by science and data as necessary for the health of our brothers and sisters. And despite the mounds of paper that prove we are being reckless, we still shed the SCBA while in immediately dangerous to life or health atmospheres.

OSHA 29 CFR 1910.120(f) mandates that employees involved in emergency response operations for releases or substantial threats of releases of hazardous substances be covered by a medical surveillance program. Per 29 CFR 1910.120(f), medical examinations and consultations are to be made available by the AHJ to HMRT members. The program includes a baseline physical before the member is placed on the team, an annual physical for the duration of team membership, an exit physical when the member leaves the team, and any exposure-specific physicals or follow-up exams deemed necessary.

Equipment

Personal Protective Equipment (PPE). Establish a written PPE program in accordance with 29 CFR 1910.120. Elements of the program should include PPE selection and use; storage, maintenance, and inspection procedures; and training considerations. Additionally, refer to NFPA 1991, Standards on Vapor-Protective Ensembles for Hazardous Materials Emergencies; NFPA 1992, Standard on Liquid Splash-Protective Ensembles and Clothing for Hazardous Materials Emergencies; and NFPA 1994, Standard on Protective Ensembles for First Responders to CBRN Terrorism Events, before preparing requests for equipment purchases. Choose PPE according to the hazardous materials and conditions present in your jurisdiction. You cannot train or equip your team for every possible scenario; concentrate on those situations you will likely encounter in your community.
Monitoring Equipment. Although there is no set requirement for basic detection and monitoring equipment, NFPA 472 and NFPA 1072 state that HMRT members should demonstrate competence in working with the combustible gas indicator, oxygen indicators, colorimetric tubes, pH paper, and flame ionization and photoionization detectors. These are just a few suggestions to get your program started.
Decontamination (Decon) Equipment. PPE equipment and decon procedures must be consistent with the standard operating procedures (SOPs) defining their use and provisions in 29 CFR 120.110(q) (10). Decon methods vary in effectiveness. If the decon operation does not appear to be effective, implement another method. Before initiating decon, consider the type of exposure and the level of contamination, which will determine the type and nature of the decon. Determine if you can conduct decon safely and whether existing resources are adequate and immediately available to decon personnel and equipment. If not, you will have to identify in your backup plan another decon source, how to contact the source, and how long it will take before you can use the decon services. These should be part of your preplanning with contingency plans in place. Note that, in many agencies, operations-level responders support and assist in technical decon operations.
Control Equipment (nonexhaustive). I say “nonexhaustive” because there are so many gizmos and gadgets out there that you’ll get a headache trying to think of them all. Here’s the ultra-short list to get you started: nonsparking tools; overpack drums; absorbent; booms/pads; and A, B, and C kits. Build your equipment cache and resource inventory according to the potential risks your jurisdiction is likely to encounter, which can range from spill/leak control to fire control capabilities.

Cost/Budget Considerations

Costs are contingent on your local hazmat situation. Following are some questions you might ask:

What level of hazmat response service/operational capability will be provided?
If an HMRT is used, how will it be organized, staffed, and function?2
What size should the team be? (A minimum of four personnel on duty per shift is recommended.)
What degree of coverage will your needs/community require (24/7, eight hours, five days per week, for example)?
Who will cover vacations, sick leave, and other absences?
Will your team always be on duty, sometimes off duty, or subject to call?
What type of budget should you use (line-item, zero-based, or program budget)?

Program costs include initial and sustainability/maintenance costs. Personnel costs include salary/benefits, preemployment costs, uniforms, training (initial/refresher, continuing education hours, and personal development), a health and safety program, a medical surveillance program, PPE, and licensing/certifications.

Equipment costs include noncapital equipment, which has an expiration date or needs periodic replacement, and capital equipment, which necessitates an investment that could be amortized or depreciated over time.

Supply costs should include procurement and inventory sustainability.

Outside vendor support services costs would include medical exams, fleet maintenance/repair, service contracts/agreements, administrative support, bonding/insurance, waste disposal.

Fixed asset costs are incurred from the purchase or improvement of land or buildings or the construction of facilities.

Cost Recovery. Some jurisdictions have enacted cost recovery policies and procedures. Policy options include flat rate fees, per-hour rates, the cost of time and materials, or a combination thereof. Government agencies may need cost-recovery legislation before enacting the program.

Response Plans

Hazmat response is an all-hands team event. Develop your hazmat team and outside resources concurrently. Listing persons and groups as resources without including them in the planning and training phases of your development process reduces their effectiveness as resources. They must know what is expected of them and be familiar with your response SOPs and incident command system. Hazmat program managers should explore opportunities to promote program activities/capabilities, understand organizational capabilities and limitations, coordinate with other response agencies and organizations, and build professional relationships.

Before you can respond to an event, you must develop your response plans and SOPs, as required by 29 CFR 1910.120(q)(1). Remember, no plan is solid. There are and always will be weaknesses. Find them and fortify them, or find them and capitalize on them.

I was fortunate to have a program in place when I became the hazmat program manager, but I still had to have a strong team in place.

As the HMRT manager, my job is team management. I was a hazmat technician many moons ago, but skills, if not used, perish. Now, I could probably patch a leak, get a reading, or snag a sample, but that is not my job anymore. That job is relegated to the team. I need leaders in place to handle the day-to-day operations and equipment maintenance so that I can plug away on other issues like meetings, budgets, and explanations to the upper chain when things don’t go exactly according to plan.

Communication

Communication is always an issue. Maybe it’s just an issue in my department (insert sarcasm here), but communication seems to always be a problem wherever you go. As the program manager, I meet with my leadership (the three captains) once per quarter in three-hour segments. This setup is not ideal, but I’ll take what I can get. In addition, since our team3 has quarterly training sessions, the leaders and I try to meet prior to the training sessions to create the training itinerary and discuss any HMRT-related business. Because our meetings are less often than ideal, we improvise. There are many resources for keeping our team in contact. We communicate through text messages and phone calls, and Office 365 has an excellent platform for sharing information in a private group. Facebook also provides the same type of setup. There are also online conference call providers; many are free. Meet with your supervisors often. Keep them updated on what’s going on with the team. Look at it as if you were providing a CAN (Conditions, Actions, Needs) report to your IC.

Communication with outside agencies and stakeholders is also important. Explore opportunities to promote program activities/abilities and build professional relationships. Training and coordinating with industrial mutual-aid groups found in jurisdictions with large numbers of chemical/manufacturing facilities can provide the necessary opportunities to build and strengthen professional relationships. Communicating with the public is also important. The Federal Emergency Management Agency’s IS-242.b, Communicating in an Emergency, states, “Studies have shown that during an incident, information is as critically important to people as food or water. Not only can accurate information mean the difference between life and death, it can provide reassurance that response and recovery are truly underway.”4

When a disaster happens elsewhere, use it as leverage with those who ultimately make the decisions. Events that happen on a national or an international level can help when it comes to budgets and equipment. Always have a prioritized “wish list” to take advantage of short-timing purchasing/acquisition opportunities.

Participate with local business/industry training. Here on the Gulf Coast, the oil and gas industry is everywhere, not to mention that our town has the fifth largest port in the nation and the number-one strategic military outload port in the world. Do you think those folks are training? You bet they are, and we’re trying to weasel our way into the action.

Under EPCRA, Local Emergency Planning Committees (LEPCs) must develop an emergency response plan; review the plan at least annually; and provide information about chemicals to citizens in the community. LEPCs develop plans with stakeholder participation. They provide a wealth of information, which includes the following:

Identification of facilities and transportation routes of extremely hazardous substances.
Description of emergency response procedures, on and off site.
Designation of a community coordinator and facility emergency coordinator to implement the plan.
Outline of emergency notification procedures.
Description of how to determine the probable affected area and population by releases.
Description of local emergency equipment and facilities and the persons responsible for them.
Outline of evacuation plans.
A training program for emergency responders (including schedules).
Methods and schedules for exercising emergency response plans.

LEAD: Learn, Educate, Advance, Develop

Learn. We need to be learners. If we expect our team members to learn, we need to be doing the same. As the leader, you set the pace. You provide the example. A leader is always learning, always shaping, always improving. Become well-read (i.e., journals, books, publications, field guides, articles, social media). Network with the SMEs. Leaders are learners.

Educate. As we learn, we must share the knowledge. The best way to learn a subject is to teach it. Teaching and learning do not happen only in the classroom setting. They can occur anywhere: the kitchen table, the engine/truck stall, or the workout room, for example.

Become a mentor. Like communication, education is internal and external. It would be a tremendous mistake not to communicate with your customer base. The time to tell them, “Trust us, we’re here to help,” is before an event occurs.

Make sure your stakeholders understand what your operational capabilities are and what they will become in the future. As the program manager, you must educate, sell, and market your team at every opportunity. “People who make the most difference in our lives are not those with the most credentials, the most money, or the most awards. They are the ones who care.”5

Educating involves an investment of time; effort; and, above all else, patience. Time is our most valuable resource. If you want to show your personnel and your customer base that you care, give them your time by educating them.

Advance. The hazmat field is evolving daily. Keep up with the trends in our profession (equipment/training) and especially in your response area (construction/processes). When determining what type of training to invest in or what type of equipment to buy, ask: “What do we need? Why do we need it? Can we afford it? Are there alternatives?”

Develop. Develop your leaders and have them develop your members. Identify the weaknesses, and work on them. Don’t train until you get it right; train until you can’t get it wrong. Leading requires having confidence in yourself and in others. Give your members the proper tools and training. Set high expectations for yourself and for others. Lay the groundwork for future generations.

ENDNOTES

1. NFPA 475 ties back to the National Fire Academy Special Operations Program Management course, which I highly recommend for a new special operations program manager, including HMRT and US&R.

2. Local/regional risks and desired capabilities should be “drivers” in making this decision.

3. My department’s HMRT consists of one manager (me), three captains (one per shift), and 32 members (10 per shift, two-day personnel). We have a dedicated hazmat station out of which we run a quint and the hazmat truck. The caveat is that the three-person crew on the quint is also the crew on the hazmat truck.

4. FEMA (Department of Homeland Security) [US] https://training.fema.gov/emiweb/is/is242b/ Accessed 17 April 2018.

5. Kouzes, James, Z Posner. 2003. The Leadership Challenge. San Francisco, CA: Jossey-Bass, 297.

Joshua Fowler is a district chief with Beaumont (TX) Fire/Rescue. He is the program manager for the department’s hazmat team and technical response/recovery group. He has 18 years of experience and is a rescue specialist and technical information specialist with Texas Task Force 1.