NFPA 472

NFPA Journal, Mar/Apr 2008 by Noll, Gregory G

USING NFPA 472 TO DEVELOP A COMPETENCY-BASED HAZMAT/WMD EMERGENCY RESPONDER TRAINING PROGRAM 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 they have all 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.