Emergency Response Training

Process Technical Services (PTS) provides emergency response training for plant personnel based on the requirements of OSHA.  Emergency response training should be required and provided for all staff as part of a comprehensive effort to develop a process safety management plan for the site. OSHA regulations are provided below with a brief explanation for specific elements.

1910.38 – Emergency Action Plans.

• 1910.38(a)
• Application. An employer must have an emergency action plan whenever an OSHA standard in this part requires one. The requirements in this section apply to each such emergency action plan.

• 1910.38(b)
• Written and oral emergency action plans. An emergency action plan must be in writing, kept in the workplace, and available to employees for review. However, an employer with 10 or fewer employees may communicate the plan orally to employees.
• 1910.119 – Process safety management of highly hazardous chemicals.
• 1910.119 App A – List of Highly Hazardous Chemicals, Toxics and Reactives (Mandatory).

• 1910.119 App B – Block Flow Diagram and Simplified Process Flow Diagram (Nonmandatory).

• 1910.119 App C – Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory).
• Introduction to Process Safety Management. The major objective of process safety management of highly hazardous chemicals is to prevent unwanted releases of hazardous chemicals, especially into locations which could expose employees and others to serious hazards. An effective process safety management program requires a systematic approach to evaluating the whole process. Using this approach the process design, process technology, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programs, and other elements which impact the process are all considered in the evaluation.
• The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. This standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly to the surrounding community. To control these types of hazards, employers need to develop the necessary expertise, experiences, judgment and proactive initiative within their workforce to properly implement and maintain an effective process safety management program as envisioned in the OSHA standard. This OSHA standard is required by the Clean Air Act Amendments as is the Environmental Protection Agency’s Risk Management Plan. Employers, who merge the two sets of requirements into their process safety management program, will better assure full compliance with each as well as enhancing their relationship with the local community.

• 1910.119 App D – Sources of Further Information (Nonmandatory).
• 1910.120 – Hazardous waste operations and emergency response.
• 1910.120 App A – Personal protective equipment test methods.
• 1910.120 App B – General description and discussion of the levels of protection and protective gear.
• 1910.120 App C – Compliance guidelines.

1. The program will provide the means for identifying and controlling worksite hazards and the means for monitoring program effectiveness. …
   Each site safety and health program will need to include the following: …means to anticipate and prepare for emergency situations and; … management and employees should be trying continually to improve the effectiveness of the program thereby enhancing the protection being afforded those working on the site.For the development and implementation of the program to be the most effective, professional safety and health personnel should be used. Certified Safety Professionals, Board Certified Industrial Hygienists or Registered Professional Safety Engineers are good examples of professional stature for safety and health managers who will administer the employer’s program.
2. Training. The training programs for employees … should address: the safety and health hazards employees should expect to find

• 1910.120 App D – References.

• 1910.120 App E – Training Curriculum Guidelines – (Non-mandatory)

Emergency response training is an essential part of a comprehensive process safety management (PSM) program.  The OSHA regulations pertain mainly to release of toxic or flammable process material.  A plant PSM program needs to incorporate plant fire emergency response training.  The PSM program may also incorporate the EPA risk management program (RMP) to be in compliance all areas of government regulation.

Emergency response training is essential for the safety and well being of employees and people living near plant sites.  However, it is only a part of a PSM/RMP program to manage emergencies and provide risk management capabilities on the site.  Process Technical Services has experienced and professionally trained personnel able to manage the development of a combined PSM/RMP program with emergency response procedures and emergency response training for the entire organization.