(ait. moj.c. grey) - nfpanfpa 472 -- a92 tcd parti part ii (log# 1) 471- 1 - (chapter 10): accept...

S U P P L E M E N T A R Y

Report of the Committee o n

Hazardous Materials Response Personnel.

Peter A. McMahon, C~b-man Grand Island Fire Co., NY

Gerald L Grey, H u San Francisco Fire Dept.,

Pep. Int'l Society of Fire Service Instructors

Gary O. Tokle, National F'Lre Protection ,Msodation, MA .

(Nonvoting)

Donald Bedkerin& Hennepin Te , ~ i c a l Ctrs, MN Glenn P. Benm-lck, Faiffax Cnty Fire & Rescue, VA Sellnn Bendix, Bendix Environmental Research Inc., CA Stephen F. CampheH, American Trucking Association, VA W'dllam M. Can~y, Underwriters Laboratories Inc., IL C, ene P. Csrlson, Oklahoma State University, OK

Rep. Int'l Fire Service Training AS~c. Thomas F. Dalton, Consulting Services Inc., NJ

Rep. Spill Control Assoc. of America James L. Daneiter, Los Angeles City F'n-e Dept., CA Jeffrey C. Davis, Assn. of Amer Railroads, CO Richard M. Duffy, Int'l Assn. of F'we Fighters, DC

Rep. NFPA, F S ~ Committee John M. Eversole, Chicago F'we Dept., IL

Rep. Int'l Assn. of Fire O3iefs Joseph P. Gsllagher, New York City Fire Dept., NY H. Dieter Heinz, Industrial Emergency Council. CA

Rep. California State Fwefighters' Assn. john T. tFtggins, Dow Coming Corp., MI '

Rep. N~A/Zn'S W'tillam J. Keffer, US Environmental Protection Agency, KS Charles L Keller, Assn. of American Railroads, DC LouisJ. Kleln, Volunteer Firemens Insurance Services, PA M. Jo McMullen, Summit County Hazardous Materials Response Team, OH Max l-L McRae, Houston Fire Dept., TX Mary Beth Michos, Dept. of Fire & Rescue Services, MD Irving Owens, Warwick Fire Dept., RI

Rep. Fire Marshals Assn. of North America Desmond B. Pem'ce, American Cyanamid, NJ

Rep. Chemical Manufacturers Assn. Gerald E. Richards, Fort Worth Fire Dept., TX ohn F. Riley, Ansul Co., WI " teven Storment, Phoenix Fire Dept., AZ

W'dliam H. Stringfield, St. Petersburg Fire Dept., FL Joseph K. We'~ Ashland Petroleum Co., KY

Rep. American Petroleum Institute CharlesJ. Wright, Union Pacific Railroad CO., NC

Alternates ,

• TerryW. DeMmar, ¢~ty of Phoenix.Flre Dept., AZ (Aft. to S. Storment)

Michsel L. Douhue , Chemical Manufacturers Assn., DC • .(Alt. to D. Pearce)

Ralph H. HIll,/vISA Research Corp., PA (Ah. to T. F, Dalton)

G ( ~ m j t L Mathemn, American Petroleum Institute, DC • g . Wets)

regory G. NoB, Hildelxand & Noll Assoc., Inc., PA (AIt. moJ.C. Grey)

Daniel Gary Snell, Houston Fire Dept., TX (Air.. to M. LL McRae)

Paul R. Spuriln, Wayne Township Fire Dept., IN (Aft. to L Owens) . '

Nonvo~

Samuel Aledo, Sao Paulo Fire Dept, Brazil John IL Camhman, Hazardous Materials Newsletter John C. Hess, US DOT-RSPA-OHMT-DHM-51

Staff ! jaiJon: Gary O. Toide

This list kepresents the membership at the time the Committee was balloted on the.text of this edition. Since that time changes in the membership may have occurred.

The Supplementary Report of the Committee on I-l~,~rdous Response Personnel is presented for adoption in 2 parts.

Part I of the Supplementary Report was prepared by the Technical Committee on Hazardous Response Personhel, and proposes for adoption a Supplementary Repo- rt which documents-its ~:tion on the public cornments received-on its Report on NFPA 471-1992, Standard on Responding to Ha-~rdom Materials Incidents, pubibhed in theTechnical Committee Reports for the 1992 Annual Meeting. , .

Part I of this Supplementary Report has been submitted to letter ballot of the Technical Committee on H ~ r d o u s Response Personnel which consists of 30 voting members; of whom 26 voted affirmatively, and 4 ballots were not returned (Messrs. Benarick, Bendix, Campbell, Davis).

Part II of the Supplementary Report was prepared by the Technical Committee on H2r~rdous Response Personnel, and proposes for adoption a Supplementary Report which documents its action on the public comments received-on its Report on NFPA 472-1992, Standard on Professional C~m][~etence of Responders to Hazardous Materials Incidents, published m the Technical Committee Reports for the 1992 AnnualMeeting.

Part II of this Supl~lementary Report has been submitted w letter ballot of the Techmcal Committee on Ha~rdous Response Personnel which consists of SO voting members; of whom 27 voted affirmatively, 1 abstained (Ms. Bendix), and 2 ballots were not returned (Messr~ Dalton, Campbell).

Note: Edlmrlal changes will be ro~de to NFPA 471 based on changes relating to public comments on NFPA 472. This will be done to assure consts~ency in terminology.

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NFPA 472 - - A92 TCD

PARTI PART II

(Log# 1) 471- 1 - (Chapter 10): Accept SUBMrrrER: R. L Rankin, MSA Research Corp. COMMENT ON PROPOSAL NO.: 471-17 RFXIOMMENDATION: Revise textas follows: "Liquified gas spills may be rontrolled by the application of high

expansion foam blankela. Low expansion foams are not effective for liquified gas spill control." SUBSTANTIATION: TCRwording is incomplete. COMMITTEE ACTION: Accept.

( L o g # 833) 472-1 - (Entire Document): Accept SUBMrr IT .~ Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION:'Add the following new text: ,

"Identify the thi'ee ty~es of respiratory protection and the advantages and limitauons presented by the use of each at hazardous m t e r i a b inddenm." SUBSTANTIATION: Should not be omitted from existing NFPA 472 (2-3.9.4). TCR 3-5.5.1.1 to 3-3.3.1.3 imply that first responders at the Operational level use only SCBA, whereas OSHA/EPA regula- lions In fact allow them to use air purifying respirators and supplied- air respirators under the appropriate conditions. There are occmions when these types of respirators may be more advisable to me than SCBA. This standard should allow employers flexibility in ty ing to comply with 29 CFR 1910.138. COMMITri~EACTION: Accept as 5-5.1.1.

(Log # 832) 472- 2- (Entire Document): Reject SUBMITYER: Bruno Mark W'dson, Oregon State F'n'e Marshal COMMENT ON PROPOSAL NO.: 4727i RECOMMENDATION: Add the following new text:

~ldenlify the levels of chemical protective clothing and their purpose , application, and components, as defined by the federal

• Envu'onmental Protection Agency." SUBSTANTIATION: These categories are still in use throughout the country, and first responders at this level should be familiar with them. COMMITTEE ACTION: Reject. COMMITYE~ STATF.~LENT: The Committee feels that this is already covered in the definition&

(Los # ~ ) 472- $ - (Entire Document): Accept SUBMI3WER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Throughout the document, italicize all title of books and other publications. SUBSTANTIATION: Set a style for publications referenced by title. COMMI3WEE ACTION: Accept.

(Log # 247) 472- 4 - (Entire Document): ,Reject SUBMrI'ITJ~ C.J. Wright, Umon Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Use the spelling h ~ r d o u s material throughout the document when it is being used as an ~ .

Use the spelling hazardous materials throughout the document when it is being used as a noun. SUBSTANTIATION: The term b ~ r d o u s material (h~7~rdous materiab) seems to be used interchangeably and somewhat inconsistently throughout the document. To be consistent, set a standard and follow that standard. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This is an editorial comment and the final document will be consistent.

(Log # 190) 472- 5 - (Entire Docmnent): Rejea SUBMI'IWER: Michael Brady, State OES, CA Specialized Trng. Institute COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION- Basically we are in agreement with the proposed standard except for the followi/ng points:

1. The proposed standards are a departure from existing 472 regulations and 29 ~ 1910.120 section q which identify the competency . . . . levels of First Responder. Awareness,. First R e s ~ n d e r Operational, Techmcian, Speciahst, and I n a d e n t Commander.

2. The proposed standards are no longer in direct relationship with 29 CFR 1910.129 section q as it relates to the *Specialist" competendes.

3. The proposed standards deviate from and distort the distinction between the level of *Defensive" actions (First Responder Aware- neu /F i r s t Responder Operational) and ~3qt"ensive" actions

3 0 8

N F P A 472 - - A92 T C D

(Technician/SpecialisO. There is a lack of clarity as to which "level" a haz mat responder should be operating udder (Offensive or Defensive).

4. We are operating under the premise that these standards should be applicable to all responders to a haz mat incident. Many of the competendes at the First Responder Awareness and Operational level are directed solely at the Fire service ,and neglect the operational needs and mission of Law Enforcement, EMS, Health, and Public Works. The proposed competencies expect too much from the non Fire disciplines. 5. The proposed standards do not use proper recognized terries,

i.e., EPA "zones', and Incident Management System (IMS) terminol- does not reflect State of California's FIRE.SCOPE ICS.

unapter 1, Administration: 1-2 Definition of Cold Zone. Under the State Haz Mat Incident

Contingency Plan 1991 and 29 CFR 1910.120 the term "Cold Zone" was replaced by ~Support Zone'.

1-2 Definition Hazard Sector. Per FIRESC~PE'ICS, the term ~rlazard Sector" is not used. The term "Groups" (with the concept of good span of control) are used in place of 'Sectors ' .

1-2 Definition of Hazard Sector Officer. Per H ~ O P E ICS, the term ~I-Iazard Sector Officer" is replaced by the term ~rtaz Mat Group Supervisor".

1-2 Definition of Hazardous Materials. The EPA priority for effects o fa Haz Mat incident is Life, Environment, and Property. Not Life, Property, and Environment. Property is easier to replace then the . environment.

]-2 Definition of Hot Zone. Under the State Haz Mat Incident Contingency Plan 1991 and 29 CFR 1910.1 20 the term ~Hot Zone" was replaced by W_.xclusion Zone'.

• 1-2 Definition of Incident Management System. Under the State' Haz Mat Incident Contingency Plan 1991, 29 CFR 1910.120, and FIRESCOPE the term "Incident Management System" was replaced by "Incident Command System'.

1-2 Definition of Warm Zone. Under the State Haz Mat Incident Contingency Plan 1991 and 29 CFR 1910.129 the term "Warm Zone" was replaced by "Contamination Reduction Zone". Chapter 2, First Responder Awareness Leveh

2-1.3 Subsection (b) 1: The First Responder Awareness (FRA) by definition does not take "Protective Actions', they are responsible for Isolating and Denying Entry with the limited resources available to them. The term "Protective Action" is more applicable to the First Responder Operational (FRO).

2-2.1.2 Knowledge of ~Division(s)" for the DOT ha,ard elates is not critical to the safe functioning for the FRA level. Especially considering the audience of: Law Enforcement, Health, Emergency Medical, Public Works, Private Industry. Knowing the specifics of the baTard class divisions should be at the FRO level.

2-2.1.3 Knowledge of ~Division(s)" for the DOT b ~ r d ¢!~ues is not critical to the safe functioning for the FRA level. Especially considering the audience of: Law Enforcement, Health, Emergency Medical, Public Works, Private Industry. Knowing the specifics of the fiaTard class divisions should be at the FRO level.

2-2.1.8.2 Delete the term "and evacuation ~. Under the FRA level, their primary responsibility is to recognize possible haz mat, isolate and deny entry, and make notifications. Setting evacuation distances is at the FRO level under "Protective A&ions'.

2-4.1 Delete the work ~protective actions ~. Protective actions is primarily a FRO level concern. Chapter 3~ First Responder Operational Level:

3-1.3 Subsection (c) 2 Delete the term "Management" and replace it with" ~Command" for Incident Command System (ICS).

3-1.3 Subsection (c) 4 The term "control" denotes an offensive action. Recommendation is to delete the word "control ~.

3-2.1.2 Unclear competency. Give examples on what types of markings.

3-2.1.2.2 Unclear competency. Give example of types of contaln- e~.

3-2.3 Beyond the scope of the FRO, this is primarily a technical issue which needs to be addressed at the Tech or Spec level of training.

5-2.3.2 to 3-2.3.6 The knowledge gained from these competencles will help the responder in the decision making process for an offensive response. These competencies blur and make unclear the defensive nature of the FRO. These competencies are not critical at the FRO level and will not significantly enhance the FRO's ability to conduct safe and defensive actions. These competencies should be directed to the Technician and Specialist level. Additionally, these competencies are not appropriate for Law Enforcement and Health. We recommend strongly that these competencies be deleted from the proposed standards.

309

3-2.4 to 3-2.4.4 These competencies are morn appropriate for ultimate "offensive" actions which are not consistent with the defensive nature of the FRO. These comp~tendes are more appropriate for the Technician and Speaaliit level.

3-3.1.1 Not clear as to definition of %teps'. 3-3.2.2 The term "dilution" should be deleted because it is

considered an "offensive" action which entails a great deal of technical expertise to perform. This competency should be discussed in the Tecl~ician and Specialist level.

3-$.$.1 This competency deals wfth the Fire discipline only. Most FRO (law Enforcement,Health, and Private) are in level "13" protection with no SCBA. The minimum level of protection for FRO's should not SCBA, but level "13".

3-3.$.1.2 to 3-3.3.1.3 This competency should be covered in a local fire department's SCBA training program. This does not apply to Law, Health, and Private.

3-3.3.2.2 Stress overview of limitations of clothing for non-offensive actions.

3-3.5.2 What are these step? Unclear. 3-4.1.1 The FRO should be primarily responsible for establishing

"~>erimeters ~ not "control zones'. It is the responsibility of the Technician and Specialist level to set the zones (e.g., I-Iaz Mat Group Supervisor;, Site Access Control Leader;, Assistant Safety Officer;, etc.)

5-4.1.4 Need for actual "hands-on* decon training is not appropriate at this level. This can be accomplished through lecture and proper audio visuals. This is very appropriate at the Technician and Specialist level.

5-4.2 Replace the term "management" with "command" per aforementioned comments.

3-4.2.2 What qeveis" are you referring to and why is it important to have them in a competency?

3-4.2.3 Replace the term ~amnagement" with "command" per aforementioned comments.

3-4.3 to 3-4.3.9 This section is not necessary for the FRO. This level of competendes is not appropriate for offensive actions under Technician and Specialist level.

3-4.4.1 Th~ competency refers to Fae Dimpline only. Does not apply to Law Enforcement, Health, and Private.

~4.4.1.1 This competency refers to F'we Discipline only. Does not apply to Law Enforcement, Health, and Private. 5-4.4.2 Dilution is generally an offensive action which should be

administered at the Technician and Specialist level. This action is not appropriate at the FRO level.

3-4.4.3 This presumes an offensive action which is not a FRO action.

3-5.1.1 What are these step? Unclear. Chapter 4s Technician Level:

4-1.3 (c) 1 Replace the term Knmnagement" with ~command" per aforementioned comment&

4-2.2.3 This competency should be dealt with by toxicologists and emergency room workers and not be Technician level respondem

4-3.3.1 Add "adsorption" to control items. Chapter 5 t Incident Commander. 5-1.3 (c) 1 Replace the term "management" with "command" per

aforementioned comment& 5-2.1.2 (i) Unclear on which guide is being referred to. 5-2.1.4 to 5-2.1.5 We believe that the Incident Commander is a

"macro" manager more conce'med with stratesy versus tactics. The Incident Commander does not have to personally identify the steps or determine the area effected, but he /she must make a decision based on the assessment of a technician or specialist level responder.

5-3.1.1 to 5-3.1.2 The methodology and steps would be determined by the Haz Mat Group Supervisor not the IC. The IC would make a decision based on the Group Supervisor s analysis. Thus, the'IC does not have to personally know these "steps'.

55.1.2.1 Unclear. Does "~ypes of response" refer to minor/major incidents or offensive/defensive response.

5-3.2.2 Unclear. What "following techniques"? 5-3.3.1.6 This should be determined by the Haz Mat Group

Supervisor and Safety Officer trained at the Technician or Specialist level.

5-3.3.1.8 This should bedetermined by the H ~ Mat Group Supervisor and Safety Officer trained at the Technician or Specialist level.

5-3.4.1 Suggest a generic methodology or specific steps involved. 5-4.1 Replace the term "managemen-t" with "command" per

aforementioned comments. 5-4.1.6 Replace the term "management" with acommand" per

aforementioned comments. 5-5.1.1 What are the "steps'? This isundear . 5-5.1.2 This should be accompfished at the Technician l~e l and

not at the IC level. S U B S T A N T I A T I O N : A significant amount of time has been spent in the preparation of this response. The concerns of fire, law enforcement, health, emergency medical, public works, and private industry were identified in the rebuttal to the proposed standard&

N F P A 472 - - A 9 2 T C D

C O M M r r r E E ACTION: Reject. COMMITrgE STATEMENT: The submiRer did not Use the correct method for submitting comments by not inducting a recommendation and a substantiauon for each of the proposed changes. However, in most cases the submitter's comments were addressed by the committee in response to another submitter 's comment. By referencing the appropriate section it is possible to determine how the commiuee responded to other similar comments.

(Log# 115) 472- 6 - (Entire Document): Reject SUBMITrER: Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Replace "organization's standard operating procedures* with emergency resvonse vlan throughout document. S.Ulk~ANTIATION: Emergency response plan is defined as "a plan that establishes guidelines for handling hazmat incidents as req.mred by 29 CFR 1910.120." Since the document is sticking with ternunol- oh- / of federal regulations, e.g., bulk and non-bulk packa~dng , etc., using emergency response plan for SOPs keeps 472 consstent. COMMITYEE ACTION: Reject. COMMITrE]g STATEMENT: The Committee felt that the current woniin~ was dearer and that the use of the term ~Standard Operanng Procedures" was appropriate.

(Log# 114) 472- 7- (Entire Document): Reject SUBMITIT.R: Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add (or contingency plan) after "local emergency response plan" throughout the document. SUBSTANTIATION: A local emergency response plan is to a community as a contingency plan is to a facility. Since the document is for employees of the public sector and the private sector, the proposedchange will address both. COMMHWEE ACTION: Reject. GOMMITrEE STATEMENT: The Committee feels that the use of the term "contingency plan" would be confusing because of the use of, acontingency response plans" by the EPA.

(Log # 14) 472-9- (Entire Doamaent): Accept SUBMITrER: Gregory G. NoR, Hildebrand & Noll Assoc., Inc. COMMENT ON PROPOSAL NO.: 472-1. REg~MMENDATION: Print major topical areas in document BOLD PRINT. _Exmples would indude Sections 2-2.1, M)etect the presepce of the n.m. and Section 2-4.1, "Initiate protective actions cons is tent . . , current edition of the DOT Emergency Response Guidebook. ~ SUBSTANTIATION: Action would make it easier for the user to determine the major topical headings and subeections within the standard. This was done in previous committee drafu prior to

ACTION: Accept. C O M M r r r E E STATEMENT: Editorial.

(Log # 2S7) 472-10- (Entire Document, 3-2.1.2, and 3-2.1.2.2): Reject S U B ~ C.j. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 ~ M M E N D A T I O N : Change the word "container" to the words containment system ~ in 3-2.1.2 and in both places in 3-2.1.2.2 and

throughout the document where appropriate. SUBSTANTIATION: The more encompassing term is required here as defined in 1-2. COMMITrEE ACTION: Reiect. C O M M r r r E E STATEMENT: See Commilxee Action on Public Comment 472-51 (Log #394).

(Log # 246) 472-11 - (1-1.1): Accept SUBMrrTER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAl, NO.: 472-1 RECOMMENDATION: Change second sentence to read by adding the underl ined word~

"It specifically coven the requirements for First Responders at the Awareness Level t First Responders at the Operational l.Awel, Hazardous Materials Technicians, and Incident Commanders" SUBSTANTIATION: This sentence serves as a general table of -contents for the document. Therefore, it shoul~ relate direc0y to the rest of the chapters in the document. Both awareness and

rational are separate chapters in this proposal. , ACTION: AcCept.

(Log # 110) 472- 8 - (Entire Document): Accept in Part SUBMrrYER: Rem Gaade, Canadian Assn. of Fire Chiefs COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text as follows:

(a) With the exception of paragraphs 2-4.1.4.3 and 2-4.1.4.5, delete "DOT" from in front of W_.mergency Response Guidebook".

(b) Add to 1- 2 Definitions a definition for W_.mergency Response Guidebook" to read as follows: A reference book, written in plan language, to guide emergency

reSl~Onders in their initial actions at the indden t scene. In the Umted States, this book is published by the U.S. Department of Transportation. In Canada, this book is published by Transport Canada. Both books contain similar data in a ~ n i l a r format, with the exception of the table of Isolation Distances which is only found in the U.S. version. ALTERNATIVELY, IF THE ABOVE IS NOT ACCEFrABLE:

(c) With the exception of paragraphs 2-4.1.4.3 and 2-4.1.4.5 change "DOT Emergency Response Guidebook" to ~DOT/TC Emergency Response Guidebook"

(d) Add to 1-~ Definitions a defmition for "I)OTfFC Emergency Reu~_~ANTIATIse Guidebook', as per (b) above.

ON: The US ERG is almost impossible to get in Canada, whereas the Canadian version is widely available. This change will open up the use of the Transport Canada version in Canada while still complying with the Standard. COMMITTEE ACTION: Accept in Part.

Accept parts (a) and (b). COMMITTEE STATEMENT: Committee agrees with the first part of the submitters proposal. Also include Sections 2-4.1.1 and 2-4.1.4.4.

(Log # 248) 472-12 - (1-1.1): Accept SUBMITrER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1

[ R E C O ~ A T I O N : In the second sentence, change the word "requirements to "competencies'. ! SUBSTANTIATION: The standard sets forth a list of competencies that are to be met by responders at various levels. The document should empb.aAi~,the.~mL~'tency aspect of the document as is , speanea m me uue came aocument. COMMITTEE ACTION: A~.ept.

(Log # 82) 472- 13- (1-1.2"): Reject S U B M r r r E ~ Richard S. Kraus, Mobil Oil Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: A paragraph should be added to state ~minimum requirements sliall c~mprehend the types and degree of h 2 ~ d s of materiah handled. Reslx~nders need competency only for those materials incidents to which they are expeded to resvond." SUBSTANTIATION: There is &r~-at concern thai employees ~ao may handle and are therefore subject m exposure from only one or two ha,~xious materials will be r.equired to be trained in a l l

, hamrdous material& For example, a b, amline truck driver (awareness level), terminal operator (6perauonal level) Tank Truck Rollover Response Teirn Membdr (Technician level) and Supervisor (Command level) need only require training for gasoline and fuel oils ha~rds . COMMITrEE ACTION: Reiect. COMMITrEE STATEMENT: The Committee feels that the submitter's comment would significantly change the b a ~ of NFPA 472. The criteria established for the awareness level, as well as the other levels, are consistent with the rquirements contained in 29 CFR 1910.120. The submitter should see the action taken on Comment 472-473 (Log #727) which establishes competencies for specialist employees.

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N F P A 472 - - A 9 2 T C D

(Log # 249) 472- 14- (1-1.2"): Accept SUBMIT1T.R: CA]. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: In the first sentence, change the word *requirements" to "competendes". SUBSTANTIATION: The standard sets forth a list of competencies that are to be met by responders at various levels. The document should emphasize the competency aspect of the document as is specified in the title of the document. COMMITTEE ACTION: Accept.

(Log # ~05 472-15 - ( i - i .? . i ) : Accept SUBMrrTER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: In the first sentence, change the words "qualification requirements" to "competencies". SUBSTANTIATION: The standard sets forth a list of competendes that are to be met by responders at various levels. The document should emphasize the competency aspect of the document as Is specified in the title of the document. This will keep the three ~ m - ~ l - 1 General consistent.

ACTION: Accept.

(Log # 25 472- 16- (1-25: Accept SUBMrrrER: Robert A. Green, Riverside C, nty Fire Chiefs' Assn. COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Revise definition to read:

"Engulf,~ Endangered Area - The actual or potential area of exposure from a haTardous material. ~

(Delete lined out text and add underlined text). , SUBSTANTIATION: We feel the term W_.ngulfed" implies that the area has already been contaminated by the tmzardous material. Engulfed denotes the past tense. If an area has the potential of being £ontaminated but not already contaminated, then engulfed does not seem appropriate.

The term W.ndanl]ered" would seem more appropriate for either the already contaminated area or the potential area of contamination. COMMI ACTION: Accept.

(Log # 3) 472- 17 - (1-2): Accept in Principle SUBMITIT..R: Robert A. Green, Riverside Cnty Fire Chiefs' AMn. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: In the definition section, include the following in the definition of Incident Management Systen~

~Inddent Management System. An organi~Jed system of roles, responsibilities, and standard operating procedures used to manage emergency operations. Such systems are often referred to as Indden t Command Systems (ICS)."

(Add underline text). SUBSTANTIATION: Include this last line to the definition of • "Incident Management System" and it would correspond with the definition of ~Incident Management System" as found in the • proposed NFPA 1500 document. A large portion of the Fire Service in general has adopted or accepted the Incident Command System. COMMITrEEACTION: Accept in Principle. C O M M r r r E E STATEMENT: See Committee Action on Public Comment 472-27 (Log #1765.

Planned Response. The plan of action, with safety considerations, consistent with the local emergency response plan and the organizations standard operating procedures, for a specific h2r~ndous materials incident. C o M M r r r F l ~ STATEMENT: The Commiuee agrees that there is a need for a definition of planned response. .,

( t o g # ~ 5 472-19 - (1-2): Acceptt S U B ~ Kent17~ Olson, American Aun of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise definition as foilow~

~Strucmral FLre Fighting Protective Clothing . . . . means the [delete "or ~] protective c lo th ing . . , and "protection from the harmful rases, vapors, [delete ~or'] liquids, or dusts that are encountered . . . " SUBSTANTIATION: Gases and dusts should be added to the list of

nl~M~,I~AcTIOf clothing does not protect against. ON: Accept.

(Log # s3) 472- 20 - (1-2): Reject SUBMrrIT.R: Richard S. Kraus, Mobil Oil Corp. COMMFJq'r ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text as follows:

Appendix A paragraph A-1-1.2 Definitions of Responder Levels to be included in paragraph 1-2 Definitions. SUBSTANTIATION: Inclusion Of A-I-1.2 from the Appendix will daxify the responder responsibilities. In lien of induslon, a direct reference or summary of each level may be used. I had considerable trouble (when reading the standard) determining the various requirements for different levels of responders. C O M M r r r E E ACTION: Reject. C O M M r r r E E STATEMENT: Each level is defined in the text at the

~p ropriate section and therefore it is not necessary to define again the definition&

(Log#915 472- 21 - (1-2): Accept in Principle SUBMITIT-~ Kent R. Olmn, American A Jim. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise definition as follows:

ContaminenL A hazardous material that physically remains on people, animals, equipment or the environment thereby creating a continuing risk of direct injury or a risk of exposure outside of the hot zone ." SUBSTANTIATION: The existing definition is not scientifically sound. Just take carbon monoxide as an example: it fits the current definition because it is potentially harmful, but it does not create "contamination ~. "Contamination" suggests that the material is on the person's skin or clothing, and alsoimplies that it can contami- nate others who come in contact with it. This is simply not true for gases and most vapors. Although my recommended revision is lengthy, and perhaps a bit awkward, it attempts to clarify that a contaminant is something that is likely to remain on or around after removal from the hot zone, thus indicating the need for de- obntamination. COMMITrEEACTION: Accept in Principle.

Change first sentence to read: " . . . remains on or in people . . . "

C O M M r r r E E STATEMENT: Committee agrees with the recommendation and believes that the addition adds further clarification.

(Log#4) 472- 18 - (1-2): Accept in Principle SUBMITI'ER: Robert A. Green, Riverside Cnty Fire Chiefs' Assn. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Under the definitions section, include a definition for the term "Planned Response". SUBSTANTIATION: There seems to be some confusion on what is meant by the term "Planned Response" as u.~ l in Section 2-4, ~lmplementing the Planned Response". Is this the action plan your~ agency is going to use to mitigate the indden t or is it a written plan that your agency already has inplace? COMMITFEEACTION: Accept in Principle.

Add the following definition:

472- 22 - (1-2): Accept (Log # 90) • SUBMITrER: Kent R. Olson, American Assn. of Poison Control

Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise paragraph to read:

"Confmed Space . . . . could contain or produce dangerous concentrations of air contaminants . . ." SUBSTANTIATION: The space does not produce the contami-

it produces the dangerous air levels of them. COMMHWEE ACTION: Accept.

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(Log # sg) 472- 23 - (1-2): Accept in Principle S U B ~ Kent R. Olson, American Assn. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add a definition:

"Secondary Contamination. The process by which a contaminant is carried out of the hot zone and contaminates people, animals, equipment or the environment outside of the spill at~a." SUBSTANTIATION: This concept has very important consequences for decisions about the need for and extent of decontamb nation. Many substances, although highly toxic, do not create a risk for secondary contamination a n d therefore the victim does not pose a threat to downstream personnel in the support zone, in the ambulance, or at the hospital. Examples include carbon monoxide, arsine ~Ls, ethylene glycol, etc.

i C OMMITFEEACTION: Accept in Principle. Change "spill area" to "hot z o n e :

COMMITTEE STATEMF24T: Hot zone is consistent with the rest of the document.

(Log # 88) 472- 24 - (I-2): Acceptt SUBMITrER: Kent~R. Olson, American Assn. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Revise defmition:

W.xposure. The process by which people, animals, equipment, or the environment are subjected to or come in contact with a ha~rdous mater ial . . ." SUBSTANTIATION: An exposure does not necessarily produce a harmful effect; the current definition implies COMMITTEE ACTION: Accept.

(Log# 111) 472- 25 - (1-2): Accept SUBMrlWER: Rem Gaade, Canadian Assn. of Fire Chiefs COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add definition:

State. Where the noun State is used it ahall also include by implication any Outlying U.S. Areas where this standard is in effect. Use of the noun State shall imply "Provinces and Territories" in Canada. SUBSTANTIATION: This will save adding "Province" after every reference to "State" legis.lation, etc. and will make use of the standard easier in Canada.

Note: Outlying US Areas include Puerto Rico, Territories, Trust Territories, and Freely Associated States. COMMITTEE ACTION: Accept.

(Log # 116) 472- 26 - (1-2): Acceplt SUBMITrER: Max H. McRae, Houston F'we Dept., "IX COMMENT ON PROPOSAL NO.: 472-I

* RECOMMENDATION: Delete all except the first sentence from the definition of ba~rdous materials so the definition reads:

Hazardous Materials.* A substance (solid, liquid, or gas) capable of creating harm to people, property, and the environment. SUBSTANTIATION: Appendix already has a listing of the hazard dasses and divisions and they need not be repeatedhere. COMM1TrEE ACTION: Accept.

(Log # 176) 472- 27 - (1-2): Accept in Principle SUBMI ' I ' rF~ Michael E. Boyle, California Region l, Local Emergency Planning Committee COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Include in the definition section the

J following definition of "Incident Management System'. "Incident Management System. An organized system of roles,

responsibilities, and standard operating procedures used to manage emergency operations. Such systems are often referred to as Incident Command Systems (ICS)'. SUBSTANTIATION: By including this last line with the definition of "Incident Management System'~ it will correspond with the definition of "Incident Management System" found in the proposed

NFPA 1500. The te /m is also widely used and accepted by the fire service nationwide. COMMITrEEAGWION: Acceptin Principle.

Change " . . . often referred to . . . " to ".. Jometimes referred to . . . " C O M M r r r E E STATEMENT: The Committee agrees with the submRter but feels that the term "sometimes" is more appropriate.

(Log# 175) 472- 2 8 - (I-2): D i b l ~ , . . t

~h":'Zc~el Boyle, c-~.romia Region I, Local SUBMrrrER: F_. e ~ P o l a n n i n g Committee

N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise definition for "I-la~mrd Sector Officer" to read:

Hazardous Materials Group Supervisor. The person responsible for the management of the hazardous nmterials group. SUBSTANTIATION: The term "Fla-ardousMaterials Group Supervisor" is consistent with the approved terminology identified in the F I ~ P E ICS HM-120 module and the proposed terminology for the National Incident Management System. COMMrrTEE ACTION: Reject. COMMrlTEE STATEMENT: See Committee Statement on Public Comment 472-40 (Log #192).

(Log # 174) 472- 29 - (1-2): Reject S U B M r F I T ~ Michael F_. Boyle, California Region I, Local Emergency Planning Committee COMMENT ON PROPOSAL NO.: 472-1 RECOMMFJqDATION: Change term ~l-la~rd Sector" to "HaT~rdous Materials Group' . SUBSTANTIATION: The term "H~-~rdous Materials Group" is consistent with the approved terminology used in the FIRF_~COPE ICS HM-] 20 module and the proposed terminology for the National Incident Management System. COMMITTEE ACTION: Reject. C O M M r r r E E STATEMENT: See Committee Action on Public Comment 472-40 (Log #192).

(Log # 17s) 472- 30- (1-2):

~ J c ~ e l E. Boyle, California Region I, Local SUBMrI'rER: Emergency Planning Committee COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise definition for ~Warm Zone" to read:

Contamination Reduction Zone. The area where personnel and equipment decontamination and exdusion zone suj)port takes place. It includes control points for the access comdor and thus assists in reducing the spread of contamination: This is also referred to as the warm zone, decontamination, or limited access zone in other documents. SUBSTANTIATION: The terminololgy "Contamination Reduction Zone" provides a more concise, descrtpttve term for the functions which occur in this control zone and is more consistent with plain text terminology. COMMITTEE ACTION: Reject. COMMrrFEE STATEMENT: See Committee Statement on Public Comment 472-34 (Log #169).

472- 31 - (1-2): Reject (Log # 172) SUBMITrER: Michael E. Boyle, California Region I, Local M Mo nning

N PROPOSAL NO.: 472-1 RECOMMENDATION: ~ definition to read: ,

Delete the term "Cold Zone and replace with: Support Zone. This area contains the command post and such

other support functions as are deemed necessary to control the incident. This is also referred to as the dean zone or cold zone in other documents. SUBSTANTIATION: The terminology "Support Zone" provides a more concise, descriptive term for the functions which occur in this control zone and is more consistent with plain text terminology. COMMrlWEE ACTION: Reject. COMMI'IWEE STATEMENT: See Committee Statement on Public Comment 472-M (Log #169).

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(Log # 171) 472- 32 - (1-2): Rejea SUBMITIT.R: Michael E. Boyle, California Region I, Local Emergency Planning Commiuee COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise definition for "Hot Zone" to read:

Exclusion Zone. Area immediately surrounding a ha~rdous materiaLs incident, which extends far enough to prevent adverse affecta from ba,~rdous materials releases to personnel outside the zone. This zone is also referred to as the hot zone or restricted zone in other document& SUBSTANTIATION: The terminology aExdumion~ Zone" provides a more concise, descriptive term for the function which occurs in this control zone and is more consistent with plain text terminology. COMMrr rEE ACTION: Reject. C O M M I T r E £ STATEMENT: See Committee Statement on Public Comment 472-34 (Log #169).

(Log # 196) 472- 36 - (1-2): Accept in Principle SUBMrI'rER: Gerald L Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add definition for "CHF_.MTREC". SUBSTANTIATION: Term is used ifi the text (3-I.$ a. 2) and is not otherwise defined. COMMITTEE ACTION: Accel~t in Prindple.

Add the following defmition: CIdEMrREC. The Chemical Transportation Emergency Center, a

public service of the Chemical Manu~cturers ' Asmoation. CHEMTREC provides emergency response information and

assistance on a 24 hr. basis for responders to h ~ , x t o u s materials incident& COMMITTEE STATEMENT: The Committee feels that the proposed definition meet, the submitter 's intent.

i

(Log # 170) 472- 33 - (1-2): Accept in Prindple SUBMrI 'TE~ Michael E. Boyle, California Region I, Local Emergency Planning Committee COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise definition to read:

Endangered Area. The actual or potential area of ex[~osure from a ha2m~ous material.

(Delete the current word "Engulfed". ) . SUBSTANTIATION: The term W_.ngulfed implies that the area in question ha~ already been contaminated by the hazardous material. In addition, the term engulfed denotes the past. If an area has the potential for being contaminated, but has not yet been contamh nated, then the term engulfed does not seem appropriate. The term "endangered" would more appropriately describh an area already contaminated or thepotent ia l area of contamination. COMMITrEEACTION: Accept in Principle. Add Xhia is sometimes referred to as the engulfed area' .

• COMMITTEE STATEMENT: The Committee agrees with the recommendation and feels that the reference to engulfed area further clarifies the iuud.

• NOTE: ~ needs to be a global change throughout document.

(Log # 169) 472- M - (1-2): Reject SUBMITTER: Michael E. Boyle, California Region I, Local Emergency Planning Committee COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise definition to read:

Control Zones. The desigr!ation ofarea~ at haT~rdous materials incidents based upon the ~d'ety and the degre e of b a l r d . Many terms are used to describe these control zones however, for the purjpose of this standard, these zones will be defined as the exclusion, contamination reduction, and support zones". SUBSTANTIATION: The terminology hot-z~ne, warm zone and cold zone do notprovide concise, des]:riptive terminology for t h e function a n d / o r fia72rd which is prevalent in each zone. The terminology exclusion zone, contamination reduction and support zoneprovfdeplain text descriptions for each zone function. COMMrlWEE ACTION: Rei~ct. COMMITTEE STATEMENT: The definition in the document adequately addreMes the concern of the submitter.

(Log # 197) 472- 35 - (1-2): Accept in Prindple SUBMITTF.~ Gerald L Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Add definition for Wanergency Decontami- nation". SUBSTANTIATION: Term is used in the text (3-4.1.4) and is not otherwise defined. COMMITTEE ACTION: Accept in Prindple.

Add the following definition: Emergency Decontamination. The physical process of immecliately

reducing contamination of individuaIs in potentially life threaming situations wimout the formal establishment of a contamination reduction corridor. AI~, add the following Apj3_e_ ndix A-2-4.1.4, E~er~ency Decontamination - See Hazardous Material Response i - l a n ~ D O O K .

COMMrIq[qKE STATEMENT: The Committee agrees that there should be a definition of emergency decontamination and that the reference to the h ~ r d o u s mak~'iah handbook will add further clarification.

(Log # 195) 472- 37 - (1-2): Accept in Principle SUBMITrER: Gerald L Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Add definition for "CANUTEC". SUBSTANTIATION: Term is used in the text (3-1.3 au 2) and is not otherwise defined. COMMrITEE ACTION: Accept in Principle. Add the following definition: CANIfrEC. The Canadian Transportation Emergency Center

operated by Transport Canada. CANUTEC provides emergency response lnformauon and assistance on a 24hr . b a ~ for responders to hazardous materials incident& - - COMMrITEE STATEMENT: See Committee Statement on Public Comment 472-36 (Log #196).

(t~g # 194) 472- 38 - (1-2): Accept in Prindple SUBMII- | ' I~: Gerald L Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Change definition of Warm Zone to read:

is the area where the tactical command post, the Contamina- tion Control Zone, and support personnel and equipment for those working in the hot zone are staged. It includes an access control point from the cold zone and one into the hot zone which a~ist in controlling the movement of personnel between the zones." SUBSTANTIATION: The definition more accurately describes the

o f the warm z o n e ACTION: Accept in Principle.

COMMITTEE STATEMENT: See Committee Action on Public Comment 472-56 (Log #262).

(z:oS # 19s) 472- 39 - (1-2): Reject SUBMITTER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-I RFX~MMENDATION: Change ~Fla,~rd Sector Officer" to ~-h,~rd Sector Supervisor" or "Hazard Group Supervhor". SUBSTANTIATION: The word "officer J - - -tes a person of rank, when in fact in the field the person in charge of thh function may not be an officer in an organization but will be a supervisor, even if it is only for this event. ~ document is not just for the fire service but aho for industry where the term "officer" is not normal terminology for ~bo~es."

If the comment on changing the "I-la,nrd Sector" to q~la,ard Group" is accepted then this would be consistent terminology within the document. - This would be consistent with the terminology used in the incident

management systen~ COMMrIWEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-40 (Log #192).

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(Log # 192) 472- 40 - (1-2): Reject SUBMITFER: Gerald L Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change "Hazard Sector" to ~I-laz~rd Group". " .

SUBSTANTIATION: The term sector denotes a geographical area, and does not correctly describe the function we have intended or described herein. This terminology would be consistent with the terminology used in

the incident management system. COMMITI'EE ACTION: ReJect.

COMMFIWEE STATEMENT: The Committee has chosen to stay with the current terminology since there is a National Group that has been meeting to determine standardization of various incident management terms. When this b accomplished appropriate terminology will be incorporated into the standard.

(Log # 191) 472- 41 - (1-2): Accept in Principle SUBMrrIT.R: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the definition of 'Decontaminat ion Area" to ~on tamina t ion Reduction Zone' .

Change the text to read: ~"his zone is umally located within the warm zone and is where

decontamination procedures usually take place. Add the following sentence: "rhis is also referred to as the Decontamination Area in other

documents." SUBSTANTIATION: Promotes consistency within document. S e e diagram'4-4 in 471 onpage 6 which refers to the Contamination Reduction Corridor. (I have also submitted a comment that the word "Corridor" on the diagram be changed to "Zone".)

See definition of ~hot and warm" zones which have'the darifying sentence similar to suggestion. COMMITrEEACTION: Accept in Principle.

Change ~Decontamination Area" to "Contamination Reduction Corridor". COMMITTEE STATEMENT: The Committee agrees with the . I rabmitter but feels that the additional changes further clarify the

i issue.

(Log # 254) 472- 42 - (1-2): Accept SUBMITI'ER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Rearrange the definition Degradation to [ more dearly indicate multiple definitions presented: I

Degradation. (Protective Equipment) A chemical action involving the molecular breakdown of a protective clothing material due to , contact with a chemical. (Control) The molecular breakdown of the released material to render it less baT~rdous. SUBSTANTIATION: To clarify the fact that two definitions exist. COMMITTEE ACTION: Accept.

(Log # 255) 472- 43 - (1-2): Accept SUBMITTER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the word Nlse" in the definition of Demonstrate to ~pefformance ~. SUBSTANTIATION: The concept of demonstration is to perform the competency. The word use does not connot~te that fact. C O M ~ ACTION: Accept.

(Log # 256) 472- 44 - (1-2): Accept SUBMITIT.J~ C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1

I RECOMMENDATION: Change the word "of' in the definition of Hazard Sector to *~,vithin* so it reads:

~I'hat function within an overall . . ." SUBSTANTIATION: Correct grammar to clarify intent of definition. COMMrITEE ACTION: Accept.

(Log # 2 5 7 ) 472- 45 - (1-2): Accept SUBMITFER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the definition of HaT~rdom Materials to read: ~ m Materials.* A substance (solid, liquid, ot ~ gas) that when released is capable of creating harm to people, property, and the environment. SUBSTANTIATION: Clarification of the detinition. COMMITr]~E ACTION: Accept.

NOTE: Make change globally "people, ~nvironment, and property", instead of ~ o p l e , property and environment".

(Log # 25S) 472- 46 - (1-2): Accept SUBMrI-rER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the definition of Liquid Splash Protective Clothing to read:

Liquid Splash Protective Ciothing. The garment portion of a chemical protective clothing ensemble that is designed and configured to protect the wearer against chemicalliquid splashes but not against chemical vapors or gases. Liquid splash protective dothin~ must meet the requiremen t- of NFPA 1992. This type of protecuve clothing is a component of EPA Level "B" Chemical Protection. SUBSTANTIATION: To clarify the meaning of this type of chemicalprotective clothing. I believe that NFPA 1992 relates to the garment (suit) not the gloves, boots, etc., unless they are attached to the suit. COMMIIWEE ACTION: Accept.

(Log # 25S) 472- 47 - (1-2): Accept in Principle SUBMITI'ER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the definition of Containment to read:

Containment. The actions taken to keep the material in its containment system (e.g., stop a release of the material or reduce the amount being released). SUBSTANTIATION: Oarilication of the intent of containment in the document by further indicating the objectives of the competencies. COMMrlWEEACTION: Accept in Principle.

Change "container system" to container. COMMITTEE STATEMENT: See Committee Action on Public Comment 472-51 (Log #394).

472- 48 - (1-2): Accept in Principle (Log # 252) SUBMrrrER: c .J . Wright, Union pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the wording of the defmition of Cold Zone to read: The section of the baTardous material incident site which contains

the command post and such other rapport functions as are deemed necessary to control the i n d d e n t This section is also referred to as the dean zone or rapport zone in other documents. SUBSTANTIATION: A definition needs to be specific to insure understanding of concepts within the document. Cold zone is ~ ctflc to hazardous material incidents in this document, therefore,

t fact needs to be addressed in the definition. The proposed definition provided here clarifies what the cold zone is. COMMrlWEE ACTION: Accept in Principle.

Change to read: "cold Zone. The control zone at a ba-~rdous materials incident

w h i c h . . , this zone is a l so . . ? COMMITrEE STATEMENT: The Commiuee feels that the changes make the definition clearer.

314

( L o g # ~ l ) 472- 49 - (1-2): Accept SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT O N PROPOSAL NO.: 472-1 RECX)MMENDATION: Change the wording for the definition of Chemical Protective Clothing to:

Chemical Protective Clothing. Items made from chemical resistive materials, such as clothing, hood, boots, gloves, etc., that are designed and configured to protect the wearer's torso, head, arms, legs, hands, and feet from ha~rd0us materials. Chemical protective clothing (garment) can be constructed as a single oi" multi-piece Igarme. nt. The garment completely encloses the wearer either by itself or in combination with the wearer's respiratory protection, attached or detachable hood, gloves, and boots. - SUBSTANTIATION: The definition is not clear and seems to be inconsistent in style, especially when com]~ared to the definitions of High Temperature Protective Clothing, Liquid Splash Protective Clothing, and Vapor Protective Clothing. The proposed wording will provide the consistency and clarity necessary in a definition. COMMITrEE ACTION: Accept.

(Log # s54) 472- 50 - (1-2): Accept in Prindple SUBMrI'IT.R: Bruno Mark Wllsun, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Include the followings.

I W.xposure. Also used to describe a person, animal, environment or piece of equipment thus subjected." SUBSTANTIATION: This addition corresponds to actual use of the term throughout this TCR (see 3-2.4.2, 3-3.1.1, etc.) COMMITTEE ACTION: Accept in Principle.

Add the word a.property" between ~animal" and aenvironment" and delete ~laus subjected". , COMMrITEE STATEMENT: The Committee feels that the addition of the word property adds clarification.

(Log # 394) 472- 51 - (1-2): Accept in Principle SUBMrIWER: J o h n T . Higgins, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RI~__COMMENDATION: Change words "containment system" to container" in both the word to be defined and in the third sentence

of the first paragraph. Reword item (c) to read "F'uced containers - such as piping, reactors, storage bins, tanks, and storage vessels. SUBSTANTIATION: The word container is commonly used in the

• f e ld to refer to that which holds the ba,~rdous material. The words containment system are used commonly to refer to diking, impoundment ponds, etc. This wording will be bet ter understood by the b27~rdous materials community. COMMITrEEACTION: Accept in Prindple.

Chan~e definition of Containment System to read: Container. Any vessel or receptacle that holds a material, including

storage vessels, pipelines and packaging (see definition of Packag- ing). Containers include: •

(a) Same as TCR ' (b) Same as TCR (c) FLxed containers such as piping, reactors, storage bins, tanks,

and storage vessel~ • COMbflTFEE STATEMENT: Committee agrees with the submitter and feels that the additional changes further clarify the definition..

NOTE: Need to make global change of ~ o n t a i n m e n t System to ~Con~ner" .

(Log # 395) 472- 52 - (1-2): Reject SUBMITIT.R: J o h n T. Higgins, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add definition for "containment system". A system of dikes, impoundment ponds, or other devices used to contain a material which has been spilled or released from a container. SUBSTANTIATION: This definition is the more commonly used definition for containment system. System are used commonly to refer to diking. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The term Containment System is no longer used and therefore a definition is not needed.

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(Log # ~9) 472- 53 - (1-2): Accept • SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the definition of Control to read: • Control. The defensive or offensive procedures, techniques, and methods used in the mitigation o f a ha~rdous material incident, including containment, confinement, and extinguishment. SUBSTANTIATION: To clarify the defnif ion of control so that defensive options are considered control. Currendy, the document tends m indicate that control is offensive. COMMITTEE ACTION: Accept.

472- 54 - (1~2): Accept (Log# 260) SUBMITI'ER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 • RECOMMENDATION: Modify the definition of Response to read:

Response. That portion of incident management in which personnel are involved in controlling (defensively or offensively) a b ~ r d o u s material incident. The aaivities in the response portion o[ahnm=rX~us sm~nflseal " il~a~ vdl~emntn~flCnlUC~ea~n~nng the inddent, p " g po ," p " g p ned response, and evaluating progress. SUIkqTANTIATION: Clarify the intent to include both defensive as well as offensive control activities. COMMITTEE ACTION: Accept.

(Log # 261) 472- 55 - (1-2): Accept SUBMrI'rER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the definition for the word Understanding. SUBSTANTIATION: The term is not used in the revised document (to the best of my knowledge). If it is, another, more acdve, less ambiguous word should be used. One that is measurable. COMMITTEE ACTION: Accept.

(Los # ~2) 472-56- (1-2): Accept in Prindple SUBMI'IWER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Modify the definition of Warm Zone to rea&

Warm Zone. The section of the baTardous material incident site where personnel and equipment decontamination and hot zone support take place. It includes the control points for the access coifidor, ~ reduce the spread of contamination. section is aho referred to as the decontamination, contamination ~ o n , or limited access zone in other documents. SUBSTANTIATION: Oarify the definition and make it consistent with other control zone definitions. The change provides a more ~ g i i T r E g c definition-

ACTION: _Ac.c~,,ptin Prindple. In the first sentence change . . . section of t he . . . " to " . . . control

zone at a . . . ' . Also change "section" to "zone" in third sentence. COMMITTEE STATEMENT: The Committee feels that this darifies the definition.

(Log # ~3 ) 472- 57 - (1-2): Accept SUBMrI'rER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the definition of Vapor Protective Clo~in~ to rea~ Vapor Prote~:tive Clothing. The garment portion of a chemical

protective clothing ensemble thatbs designed and configured to protect the wearer against chemical vapors or gases. Vapor protective clothing must meet the requirements of NFPA 1991. type of protective clothing is a component of EPA Leve.l "A" Chemical Protection. SUBSTANTIATION: To clarify the meaning of this type of chemicalpro.tective clothing. I believe that NFPA 1991 relates to the ga rn~n t (mit) not the gloves, boots, etc., unless they are attached to the suit. COMMITTEE ACTION: Accept.

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472- 58 - (1-2): Reject S U B M r r I ' E ~ D. Christopher Cathcart, Washington, DC (I_~ # 835), I;v[ic~l L Donahue, Chemical Manufacturers Assn. (Log # 726), John T. Higgins, Dow Coming Corp. (Log # 392) COMMENTON PROPOSAL NO.: 472-I RECOMMENDATION: Add a definition for "Private Sector Specialist Employee" as follows:

Private Sector Specialist Employee. A private sector "specialist employee" who respon& to hazardous materials inddenm. These specialiat employees have demonstrated their competency in their areas of expertise. They provide technical advice and asshtance to the individual in charge of the incident.

Spe .dalist employees may include, but are not limited to the

f ° l l ~ S u c t spedalist F_~luipment spedallst

ntainer spedaliat Environmental specialist Manufacturing specialist Industrial hygiene specialist Medical spedallst Safety spedalist

These employees I~rovide assistance which indudes, when necessary, working m the hot zone. As a minimum, specialist employees should annually receive training or demonstrate competency in the area of their spectalizalion. They may be qualified by specific response trm~ning or by virtue of their regular job duties. SUBSTANTIATION: The definition is required to implement the incorporation of a new Oaapter 6 on competencies for private sector spedalist employees. " . COMMITTEE ACTION: Reject. C O ~ STATEMENT: See Committee Action and Statement on Public Comment 472-473 (Log #727).

(Log# 112) 472- 61 - (2-1.1, 3-1.1, 4-1.1, and 5-1.1): Accept SUBMrYrER: Rem Gaade, Canadian Assn. of Fire Chiefs COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: (a) Replace the word "or" before "U.S. Environmental Protection A~ency" with a comma; and

(b) Add ", or local occupauonal health and mfety regulatory'. SUBSTANTIATION: Covers those locations where neither OSHA nor EPA applies. Similar action was taken by previous addition of wording such as "or local right4o-know legislative requirements" and "or local emergency re spon/e planning lesiAation". COMMrrTEE ACTION: Accept

(Log # 264) 472- 62 - (2-l.l): Accept SUBMrrrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1

[ RFX~OMMENDATION: In the first sentence, change the word "requirementa" to "competendes'. SU3STANTIATION: The standard sets forth a list of competencies that are to be met by responders at various levels. The document should emphasize the competency aspect of the document as is spedfied in the fide of the document. COMMITYEEACTION: Accept.

(Log # 269) 472- 62- (2-1.S(a)(1) and 2-2.1): Accept SUBM]rrrElh c.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the word athe" in front of the words ~ t r d o u s materials" in both. SUBSTANTIATION: Word is unnecessary. COMMrITEE ACTION: Accept.

472- 59 - (1-2): Reject SUBMITrER: Hershell Stafford, Exxon Chemical Americas (Log # 468), Joyce A. Stra~, FMC Corp. (Log # 528), W'dliam A. Levy, Research Triangle Park, NC (Log # 608), John T. Higgins, Dow Coming Corp. (Log # 39S), Michael E. Lyden, The Chlorine Institute, Inc. (Log# SOS), John M. Cobum, Occidental Chemical Corp. (Log# 1102), Samuel A. Pearman, Martinsville, VA (Log # 1013), Raymond P. Reaudry, Du Pont Co. (Log # 873) COMMENT ON PROPOSAL NO.: 479-1 RECOMMENDATION: Add the following new text:

Hazardous Materials Response Team Leader. The person in charge of a hazardous materials response team. When not the incident commander, this person advises and a~slsts the incident commander. SUBSTANTIATION: Many community response plans and department operating procedures specify the role o f a h a m ~ t team and team leader. The incident commander may or may not be this team leader. This team leader advises and aulsts the incident commander. C O M M r r r E E ACTION: Reject. COMMITTEE STATEMEHT: The term I4a~mrdous Materials Response Team Leader is not used within the document so there Is no reason to define it.

(Log # 9s) 472- 64 - (2-1.3(a)): Accept S U B M I T r E ~ Kent IL Ohon, American Assn. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Replace "Analyze an emergency" with "Analyze the incident ' . SUBSTANTIATION: Part of the analysis obvioualy includes determining whether or not the incident actually constitutes an emergency. COMMrITEE ACTION: Accept.

(Log # 27o) 472- 65 - (2-1.3(b)): Accept SUBMrlWER: c .J . Wright, Union Pacific Railroad COMMENT O N PROPOSAL NO.: 472-1

[ RECOMMENDATION: Replace the words "a response" with the word "actions'. SUBS'I~g]3~'ATION: Oarify the intent of the objective. May not be the entire response, only a specific number of actions. COMMITTEE ACTION: Accept.

(Log # 84) 472- 60 - (2-1): Reject SUBMITrER= Richard S. Kratu, Mobil Oil Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: In the first sentence add " . . . all require- m e n u of this chapter as related specifically m those materials they are expected to handle." SUBSTANTIATION: There is no need for a responder to be trained in h ~ r d s of materiah which are not handled or stored or carried. COMMr1wEE ACTION: Reject. COMMITTEESTATEMENT: See Committee Statement on Public Comment 472-13 (Log #82).

(Log # 4oo) 472- 66 - (2-2.1.1): Reject SUBMITrER: John T. Higgtns, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: None. SUBSTANTIATION: Knowledge of these definitions will not help the awareness level person analyze the incident better and therefore is not needed at this level. Move this information to the operations level. COMMITTEE ACTION: Reject. COMMrrTEE STATEMENT: The Committee feels that this is an appropriate competency for resp0nders at thgs level. See Committee Action on Public Comment 472-67 (Log #117).

316

N F P A 472 A 9 2 T C D

( L o g s 1 z 7 ) 472- 67 - (2-2.1.1"): Accept S U B ~ Max H. McRae, Houston F'~re Dept. ,TX COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise 2-2.1.1" to read:

2-2.1.1" Identity the definition o f h a ~ r d o u s materials, or dangerous goods (in Canada). " • SUBSTANTIATION: I -hnrdous mbstano~s and har~rdous wastes . are ha~rdons mte r in i s as defined in the definitions. At this level, it should be kept simple. I see no need to get technical as to what the particular regulatory a g e n d e s call their hm'ardous materials; they all boil down to the definition of ha~rdous materials in this document, which is, "A substance capable of creating imrm to people, property, and the environment." COMMITTEE ACTION: Accept.

/ (Log# S00) 4 7 2 - 7 ~ 1 - ( 2 - 2 . 1 . 2 ) : Reject " ' SUBMITrER: John T. Higgins, Dow Coming Corp. COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Change words to read:

"Identify the DOT has=rd dasses of h~nrdons m a t e r i a l s . " SUBSTANTIATION: The awareness level person only needs to identify the fact that the material present.is ha,~rdous and to be able to find defensive actions in the DOT guidebook to take. There is no need to understand the divisions or even to be able to give examples of a h=~rdous material ,~, COMMrlWEE ACTION: Reject. COMMITrEE STATEM~rr : See Committee Statement on Public Comment 472-69 (Log #IT/) .

(t~g# 10~ ) 472- 68- (2-2.1.2): Reject " " • SUBMrrrER: Kent IL Ohon, American A..mn. of Poison Control Centers COMMENTON PROPOSALNO.: 472-1

.RECOMMENDATION: 'Combine 2-2.1 and 2-2.2 sections. ' SUBSTANTIATION: The material is essentially the same: identify;

~ the materiah ifivolved: , " MMITrEEACTION: Reject. ~ ' " -

COMMITrER STATEMENT: The Committee feels tha t there is a difference between the sections. In 2-2.1 the responder is being asked to identify situation/where ba,ardous materials may b e present and in 2-2.2 the responder is being asked to identify by name the baTardous materials that are pre~ent.

(Log # 177) 472- 69 - (2-?.1.2): R e j e c t SUBI~trITKIh Michael E. Boyle; Califomht Region I, Local Emergency Planning Committee COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Revise text as follows:

"Identify the DOT H ~ r d C:h,~es - . ~ D : . - : , . , , , of 14=~=tdous Materials and identify common examples of materials in each Hazard Oa~ v~ .~;o; . . . ." ' ' ,

(Delete lined out portion of text). " "SUBSTANTIATION: Even though this standard revision should allow for personnel growth by increasing tkLe level of competency, individuals at the First Responder Awareness Level should remain at a basic level. This level of co~hpetence is only required to identify the presence o f a ha*ardous materials in order to notify the proper a~ency to initiate a b~a rdous materials response.

osseMing the knowledge of the different divisions of the Hazard CIx*.~es is too advanced for the First Responder Awareness Level. An understanding of the general Hazard Classes will allow them to take the appropriate precautions and secure the scene until the m-rival of a higher level of response c~tpability. , COMMrrrEEACTION: Reject. . • . COMMITTEE STATEMENT: The Commit/ee feels that the inclusion of divisions is necessary. For example, ffa responder only knows the h a , ~ l class when dealing with l ~ a r d class 2 they may not understand the differences be tye~n the ha.~rds presented by poison gas and flammable gas.

(Log # 198) 472- 70 - (2-2.1.2): Reject SUBMITFEIE Gerald L Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Revise text to read:

.identify the DOT b a i r d d a s s ~ of baTanions materials and identify common examples in each haT~rd dass." SUBSTANTIATION: I request the compel~ency as written be moved to the First Responder Operational level, but revised as stated above t o r e m a i n at the First Responder Awarene~; level. ' '

The competency al presently stated g r e a t l y exceeds the goal statement requirements as stated in 2-1.$ of this document for an

ON: RejedL COMMITTEE STATEMENT: See Comr~ltee Statement on Public Comment 472-69 (Log #177).

472-72-(2-2.1.2): Reject ' : (Log#5) SUBMITIT, R: R0ben st.. Green, Riverside Cnty Fire Chiefs' Assn. COMMENT O N PROPOSAL NO.: 472-1 RFX~MMENDATION: Revise text as follows:

"Identify the DOT H a z a ~ O~tqes _ , ~ D , ~ . : , . ~ , , o f Ha~rdous Materials ml, d identify common examples of materials in each I 4 a , ~ r ( I ( : ] a M ~ , D:. ' .~: . . . . " , .

(Delete lined out text). . , , SUBSTANTIATION: Competencies for the F'n'st Responder, Awareness Level should be at a very basic level. This level of responder is only rappose to be able to identify the presence of a Ha,~rdom Material in order to notify the proper a g e n ~ to initiate a H~-~,xlous Materials Response.

Having to know the various divisions in the different H a ~ r d (]asses is too technical for the First Responder, Awareness Level. If they understand the general Hazard C~Lss, they can effectively take precautions to secure'the scene until the arrival of the appropriate level of responder. - . COMMrrrgg ACTION: Reject. COMMrlWEE STATEMENT: See Committee Statement on Public Comment 472-69 (Log #177). "

( L o g # 199 ) 472- 73- (2-2.1.3): Reject ,. SUBMrrYER: Gerald L'Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read:

"Identify the primary hazarcls associated with each of the DOT ib=~rd classes of ba~,rdous materials by h~;~rd dass`" SUBSTANTIATION: I request the competency as written be moved to the First Responder Operat ion~ level, but revised as stated above to remain at the First Responder Awareness level. The competency ai preaently Stated greatly exceeds the goal

statement requirements as stated in 2~1.3 of this document for an Awareneu person. • COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Public Comment 472-69 (Log #177).

(Log # 178) 472- 74 - (2-2.1.3): Reject SUBMrlWER: Michael E. Boyle, California R~egion I, Local Emergency Planning Committee COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text as follows:

"Identify the primary b~r~rds associated with each of the D O T

(Delete lined out portion of text). " ,, SUBSTANTIATION." Even though this standard revision should allow for personnel growth by increasing the level of competency, individuah at the First Responder Awareness Level should remain at a basic level. This level of competence is only required to identify the presence ofa ha,=rdous material in order to notify the proper,

nCy to initiate a ba~rdous materials response. ssing the knowledge of the different divisions of the Hazard

¢'la,~es is too advanced for the Firsr Responder Awareness Level. An understanding of the general I - l a i rd Classes will allow them to take the appropriate precautions and secure the scene unt ir the arrival of a higher level of response capability. '

i

3 1 7

N F P A 472 m A92 T C D

COMMrlTEg ACTION: Reject. ' COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-459 (Log #177).

' (Log# SOS) 472. 75 - (2-2.1.3): Re jea s t m M r r r ~ John T. I-Iiggins, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: O ~ a g e words to read: .

"Identify the primary hazards associated with each of the DOT h ~ r d ¢ ! ~ s of ha~ rdous mate r ia l s . " SUBSTANTIATION: The awareness level person only needs to identify the fact that the material present is ha~rdous and to be able to find defensive actions in the DOT guidebook to take. There is no need to understand the divisions or even to be able to give examples of a harardous materiaL COMMITIT..E ACTION: RejeCt. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-69 (Log #177).

(Log# 6) 472- 76 - (2-2.1.3): Reject SUBMITrER: Robert A. Green, Riverside Cnty F'ure Chiefs: Assn. COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Revise text as follows:

"Identify the primary bo-~rch associates with each o f the DOT H a ~ r d Oasses . . . . . . . . . . . . . --I • '

(Delete lined out text). SUBSTANTIATION: Competencies for the F'mst Responder, Awareness Level should be at a very basic level. This level of responder is only mppose to be able to identify the presence of a I -h~rdous Matel-hl m order to notify the proper agency to initiate a Ha-ardous Materials Response.

Having to know the various divisions in the different H~,=rd ~ a u e s is too technical for the First Responder, Awarene&s Level. If they understand the general Hazard /~I~ , they can effectively take precautions to secure the scene until the arrival of the appropriate level of responder. COMMITTEE ACTION: Reject. COMMITr]gE STATEMENT: See Committee Statement on Public Comment 472-69 (Log #177)..

(Log # 11s) 472- 77 - (2=2.1.6): Accept S U B ~ Max H. McRae, Houston Fire DepL, TX COMMENT ON PROPOSAL NO.: ,472-I

. RECOMMENDATION: Delete a(e) poison labels;" from list and reletter balance of list. SUBSTANTIATION: Labels seem out of place in this listing. If it is appropriate, then list flammable gas labels and organic peroxide labels, etc. C O M M r r r E E ACTION: Accept.

d

472- 78 - (2-2.1.6): Accept in Principle (Log# 302) SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1" RECOMMENDATION: Add the following competency as 2-2.1.6 and renumber the rest of the competencies as necessary.

2-2.1.6 Identify the basic characteristics of typical containment s/sterna, including shapes, that indicate hazardous materials. SUBSTANTIATION: There are certain basic characteristica of containment systems that may indicate the presence of ha-ardous materials. Examples include rounded ends or pressurized containment systems, protective housing on tank cars, oval shapes of DOT- 306/MC,406 cargo tanks, etc.. If known, these characteristics could alert responders from a distance of the potential involvement of h a z a r d o u s materials. COMMITYEE ACTION: Accept in Principle.

Reword as follow~ "Identify typical container shapes that may indicate b ~ r d o u s

materials." COMMITTEE STATEMENT: The Committee believes t ~ t this competency is necessary and feels that the revisions made to the submitters request further clarify the competency.

472- 79- (2-2.1.6(g)): Reject . (Log # 301) SUBMrFrEI~ .c.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add the word "containment system" in place of "container" in 2-2.1.6(g) so it reads:

(g) Conta inn~nt system markings. SUBSTANTIATION: Use of the term "containment system" by definition indicates all types of containers and packaging, inducting non-bulk and bulk packaging and facility containment syaten~ Many of the other tefrm have connotations that limit the use of that term. Containment system is defined as all indmive. COMMrlWEE ACTION: Reject. COMMITrF..E STATEMENT: See Committee Statement and Action on Public Comment 47251 (Log #~J4).

472- 80 - (2-2.1.8): Accept in Principle S U B ~ C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-I REKIOMMENDATION: Add the following competencies as part of 2-2.1.8:

2-2.1.8 Identify the basic information on facility documents • (including Material Safety Data Sheets - MSDS) and shipping papers

t h a t i nd i ca te harardOus materials. . 2-2.1.8.1 Identify where to find Material Safety Data Sheets (MSDS)

at facilities and in transportation. 2-2.1.8.2 Identify entries on a Material Safety Data Sheet that

indicate the presence of hazardous materials. 2-2.1.8.$ Identify the entries on shipping papers that indicate the

presence of hazardous ma~riah. 2-2.1.8.4 Match the name of the shipping papers found in

transportation (air, highway, rail, and water) with the mode of transportation; identify the _~l~ermn responsible for the shipping papers in each m~de; identify where the shipping papers are found in each mode of transportation; and identify where the shipping gaL~rST~iTiATifound in an emergency in each mode.

ON: Shipping papers and Material Safety Data Sheets (MSDS are primary safety instruments for responders to ha~mrdous material incidents; t h e r e f o r e , it seems prudent that responders be able to find these documents in an emergency and identify the entries that indicate the presence of ha~rdous materials. If these items are not listed at this level, they should be included in the appropriate higher level of responder. These competencies actually existed in the previous document and have only been reworded to clarify the intent from a performance standpoint. COMMITTEE ACTION: Accept in Principle.

Make the following change~ 2-2.1.8 Delete " . . . facility documents ( indud ihg . . . " 2-2.1.8.1 Delete " . . . at fadlities and in transportation." 2-2.1.8.4 End the t i n t sentence following " . . . mode of transporta-

tion." Add 2-2.1.8.5 "Identify the person responsible for the ih ipp ing

papers in each mode." ' Add 2-2.1.8.6 "Idel/tify wh~re the shipping papers are found in

each mode of u-ansportaflon." Add 2-2.1.8.7 "Identify where the papers may be found in an

emergency in each mode of transportation." COMMITTEE STATEMENT: The Commiutee generally agreei with the submitter however, the above changes should make the competency more dear.

(Log # s00) 472- 81 - (2-2.1.8): Accept S U B ~ C.J. Wright, Union Pacific RaiLroad COMMENT ON PROPOSAL NO.: 472-1

'1 RECOMMENDATION: Delete 2-2.1.8. |

SUBSTANTIATION: Not a detection step. More associated with identifying the material in murveying the b*~rdous m a t e r i a l incident. . . . . " . COMMITTEE ACTION: Accept. ' COMMITrEE STATEMENT: See Committee Action and Statement on Public Comment 472-80 (Log #297).

318

472- 82 - (2-2.1.8.1): Accept . SUBMrI ' rE~ C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete 2-2.1.8.1. ' ' SUBSTANTIATION: Not a detection step. Associated with identifying the name of the material in su~eying the b=~,xtous - material inddent. . . COMMrrIT~ ACTION: Accept. • COMMITTEE STATEMENT: See Committee Action on public Comment 472-80 (Log #297).

(Log # s97) 472-83- (2-2.1.8.1): Accept in Principle SUBMITrER: John T. Higgins0 Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Deletetext. SUBSTANTIATION: The responsibility of the person at the awareness level Is to report to a person iden tiffed in the local emergency plan the information that has I~.~en observed. This

• person does not neec] to know where to get information other than what is available at the scene. ODMMITrEEACTION: Acceptin Principle. ,. COMMITTEE STATEMENT: See Committee Action and Statement on public Comment 472-80 (Log #297).


('Log # 299) r

SUBSTANTIATION: The purpose of this competency was to provide the responder with examples of the other dues available for detecting hazardous material presence in emergendes - specifically exduding the items discussed in 2-2.1.1 to 2-2.1.8. With the addition . of shipping 15apers in previous proposal, shipping papers should be added to the list in 2-2.1.9., . C O ~ ACTION: Accept

(Log# 179) 472- 88 - (2-2.1.9): A c ~ p t in Principle SUBMITrER: Michael E. Boyle, California Region I, Local e Po nnin COm =

N PROPOSAL NO.: 472-1 RECOMMENDATION: Re-write ~ h to read: . ~Identify dues (other than occupancy/location, container shape,

markings/color, and placards/lal~is) when using the senses of sight, sound and odor to indicate h~,,~lous materials'.. ~ '- SUBSTANTIATION: The use of the human senses to detect the

~. resence of hazardous materials presents certain dangers and mitations. These limitations and considerations should be "

e~MMnWEErovided to the First Responder at any level to prevent unnecessary sure to hazardous materials.

ACTION: Accept in Principle. • COMMITFEE STATEMENT: See Committee Action on public Comment 472-87 (Log tf296), and 472-91 (Log #'294).

(Log # s96) 472- 84- (2-2.1.8.2): Reject . S U B M r r r E ~ John T.Higgins, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change words to read:

"Demonstrate ~ e use of a material safety data sheet in obtaining hazard and response actions." ' SUBSTANTIATION: Materi~l safety data sheets do not necessarily, contain information on isolation and evacuation distances, f f the information is available, it will be with the response information. COMMITrEE &CTION: Reject. COMMITTEE STATEMENT: 'See Committee Action and Statement On Public Comment 472-80 (Log #297)." . ...

(Log # 298) 472- 85 - (2-2.1.8.2): Accept . " • . • SUBM]TrER: c .J . Wright, Union Pacific Railroad COMMENT ON. PROPOSAL NO.: 472-1 RECOMMENDATION: Delete 2-2.1.8.2. SUBSTANTIATION: Not a detection step. Associated with , identifying the name of the.material in surveying the h ~ r d o u s material incident. COMMrrrEE ACTION: Accept.

i

(Los.# 2O0) 472- 86- (2-2.1.8.2): Reject ' S U B ~ Gerald L. Grey, Redwood.City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change text to read:

"Demonstrate the use of a Material Safety Data Sheet (MSDS) in obtaining hazard and response information." SUBSTANTIATION: As a committee, we aJready changed this because most MSDS s do not contain isola,JLon and evacuation distances. Also, we do not obtain hazard and response actions, we perform actions and we obtain information with which to formulate our action planl - , . , COMM]TFEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action and Statement on Public Comment 472-80 (Log #297). ,

(Log # 296) 472- 87 - (2-2.1.9"): Accept SUBMITrE~ C.]. Wright, Union Pacific l~aiiroad COMMENT ON PROPOSAL NO.: 472-1

i RECOMMENDATION: Reword 2-2.1.9" U~ read: ~Identify examples of dues (other than occupancy/location, -

containment system shape, markings/color, placards/labeis, and shipnin~ navels that use the senses of sight, sound, and odor to indicate baTardous materials presence." . •

( L o g # 9 4 ) 472- 89 - (2-2.1.9): Accept in Principle ' ' SUBMITTER: iKent IL Olson, American Assn. of Poison Control C e n t e r s /

COMMENT ON PROPOSAL NO.: 472-1 REODMMENDATION: Revise and add:

" . . . sight, sound, and odor to indicate the possible:vresence of • h ~ r d o u s materialL Identify difficulties or pitfalls is using these senses to determine the presence or absence of hazardous materials. SUBSTANTIATION: Important to make it dear that sensory detection is highly unreliable. COMMITTEE ACTION: Accept in Principle. , Add the following[ 2-2.1.10:.

~Describe the lirmtafions of using the senses in determining the presence or absence of hazardous materials. . COMMYITEE STATEMENT: The Committee a~rees that it is important for the responder to understand the liinitations in using the senses to determine the presence or absence of hazardous. materials and feels the addiuon of the above competency will addreu that concern.

, ' (Log # ~s ) 472- 90- (2-2.2): Accept in Prindple SUBMITTER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 REODMMENDATION: Replace the words "~vithout intezvention*' with the words "from a safe location ~. , ' SUBSTANTIATION: To clarify the meaning of the intent of '~vithout intervention". COMMrrrEE ACTION: Accept in Principle: ' - ' Also make the same change m Section 2-L3(a)2.

COMMITTEE STATEMENT: The Committee agrees and makes the, additional change for consistency.

472- 91 - (2-2.5, 2-4.1.4)i Accept in Principle " (Log # 294) SUBMITrER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1

i RFX:OMMENDATION: In the note to both the sections 2-2.3 and 2-4.1.4 add the phrase "sources of response information" hi place of 'Yesponse guidebooks" so that the Note r ~,y~_ds as follows: " Note: If other sources of response infoi'mation [including the

Material Safety Data Sheets (MSDSs) are provided.. ~" SUBSTANTIATION: Other resi~onse information beyond just response guidebooks may be available to some responders at this level: The purpose of this note is to insure that the responder at this level is competent to use whatevei" is provided m them. " COMMrrFEE ACTION: Accept in Prindple.

Also delete "Guidebooks" in the third sentence. COMM]'IWEE STATEMFJqT: Committee agrees and makes the other change for consistency.

319 : ., .


(Log # ~5) • 472-92- (2-2.3.4): Accept

SUBMrrrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Reword 2-2.3.4 to read:

2-2.3.4 Given the current edition of t heDOT Emergency Response Guidebook, list the two general types of h ~ r d s found on,each l~ume ~ . • ide ." ~UBb~A~I'riATION: Clarification of intent. Intent was m have responder realize that the !guide pages provide information on h e a t h and fire and explosion h~,~rds on the page with the greater

• hazard listed first. COMMITTEE ACTION: Accept.

i

(Los # 744) 472-93- (2-4.1): Accept S t m M r r l T ~ Bruno Mark W-dson, Oregon state 1 ~ Marshal COMMENT ON PROPOSAL NO.: 472=1 RECOMMENDATION: Revise text to read: . . ".,. Emergency Response Guidebook. First Responders at the

awareness level.,, actions to be taken to protect themselves and others . . .~ SUBSTANTIATION: Error in syntax: disagreement in number. The construct "themself" is not a recognized word.' COMMITrEE ACTION: Accept.

(Log # 745)' 472-'97- (2-4.1.3): Accept S U B M r r r E ~ Bruno Mark W'flson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Should read:

I ".. themselves.. ." to protect Q

SUBSTANTIATION: Error in syntax: disagreement in number. The conm'uct '~hemsell ~ is not a recognized word. COMMITTEE ACTION: Accept.

(Log # 947) 472- 98 - (2-4.1.4): Accept SUBMITIT, R: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add a new competency under 2,-4.1.1 to read:

"Given a copy of the current edition of the DOT Emergency Response Guidebook, describe the difference between the protective action distances in the orange guide pages and the green bordered

the document." . ' _ ON: Two different, sometimes conflicting, .

protective action disumces are given in these two areas of the ~locument. Responders should-be able to explain the discrepancy. COMMITrKE ACTION: Accept.

(Log # 78) 472- 94 - (2-4.1): Accept in Principle SUBMITrER: J im Litevich, NH Haz-Mat Curriculum Development Committee ' COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add appendix note to this section:

"rhcee jurisdictions which have not developed an emergency response plan should refer to the document NFT-1, I4aT~rdous Materials Emergency Planning Guide, developed by the National Response Team. The National Response Team, composed of 14 Federal a g e n d ~

having major responsibilities in environmental, transportation, -emerg-enc~, man.~gement, worker safety, and public health areas, is the national body responsible for coordinating Federal planning, preparedness, and response actions related to oil " ~ - es and hazardous substance releases. Under the Superfund Amendments and Reauthorization Act of 1986, the NFT is responsible for publishing guidance documents for the preparation and implementation of ~UT:*rdous substance emergency plans." SUBSTANTIATION: Jurisdictions without an emergency response plan should be encouraged to develop a local p l a n . T h e NTRT-a document provides guidelines for the development for such a plan.

t COMMITTEE ACTION: Accept in Principle. n ~ S [ Chancre " . . . response plan should . . , m . . . re ponse plan

I. may...-- . COMMITTEE STATEMENT: The Committee feels that "may" is a more appropriate term.

\ .

(Los # 267) 472- 95 - (2-4.1.1): Reject SUBMITI'ER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add a competency in 2-4.1.1 (renumbering others) to rea&

*Explain the purpose of an emergency resvonse effort relative to outcomes. SUBSTANTIATION: Person at operational level must understand the purpose of their emergency respon~ effort when responding to hazardous material i n c i d e n t COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that this is beyond the scope of the first responder.

(Log # 72s) 472- 96 - (2-4.1.1): Accept SUBMITIT.R: Bruno Mark W'flson, Oregon State Fire Marshal, COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Change "determine" to "identify*. SUBSTANTIATION: Make the verb for cognitive skill tasks consistent throughout the standard. "Identify" is defined in 1-2, "determine" is not. COMMITTEE ACTION: AccepL

(Log#05) 472- 99 - (2-4.1.4): Accept in Prindple SUBMITTER: Kent R. Ohon, American Assn. of Poison Control Centers • COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Replace "guidebook." with ~nater iah / information resources". SUBSTANTIATION: MSDSs are not "guidebook.' . Neither are computer programs, fact sheets, or poison conlrol center~ COMMrrrEEACTION: Accept in Prindple. COMMITTEE STATEMENT: See Committee Action and Statement on Public Comment 472-91 (Log #294).

(Log # 729) 472- I00,- (2-4.1.4(a), (b)): Reject SUBMITFER: Bruno Mark W'flson, Oregon State FLre COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: These should be moved into the Opera- tional level, Chapter 3, with the exception of "first aid" under (a). SUBSTANTIATION: Personnel at the Awareness level do not, by definition (see 2-1.2), perform fire, spill or leak control functions, and thus should not be in an area where they will need personal protective equipment. Awareness personnel are likely to perform fn'st aid activities. ~ ' COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that at the first responder awareness level there is a need for this information.

(Lo s # S42) 472- 101 - (2.4.1.4~1): ~ SUBMrIWER: Terry Bindemagel, C~eveland Fire Dept., OH COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Revise text:

(a) Street clothing (b) Structural gear (c) Po~ P r e ~ SCBA (d) C I ~

SUBSTANTIATION: You list m-ucmral gear and SCBA separately. ks wrong. At aware/te~ or operational levelJ structural gear and

SCBA are essential. COMMITTEE ACTION: Reject. COMMrlWEE STATEMENT: The Committee feels that information ls consistent with the information found in the DOT Emergency Re~onse Guide and therefore is readily available to the responder at this level.

3 2 0

/

N F P A 4 7 2 - - A92 T C D

(Log # 730) 472- 102 - (2-4.1.4.1): Reject SUBMrrI"ER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472Yl RF, COMMENDATION: Entire objective should be moved to sOI~eB~ANTIATIonal level, ( Impter $.

ON: Personnel at the Aw-,~reness level do not, by definition (see 2-1.2), perform fire, spill or leak.c0ntrol functions, and thus sfiould not b~ in an area wliere the7 wm neea personal protective .equipment. Awareness personnel are likely to'perform first aid activities. COMMITFEE ACTION: Reject. COMMI'ITEE STATEMENT: The Committee believes that it is necessary to have an understanding of the appro[~rlate protective dothinl~ available in order to understand thefinutations of protecuve clothing provided at this.level. Also see Committee

, Statement on Public Comment 472-100 (Log #729).

(Lo s # 266) 472- 103- (2-4.1.4.1): Accept in Principle SUBMI'rrER: C.J. Wright, Union Pacific ~hailcoad COMMENT ON PROPOSAL NO.: 472-1 .

i REDDMMENDATION: Add the phrase ~_ld the name of the material" to the end of the condiuons phrase so it reach ~Glven the cu----rr~"~'edition of the DOT Emergency Response Guidebook and the name of the material. . .~ SUBSTANTIATION: To clarify the conditions under which the competency is to be performed. • " COHMITrEE ACTION: Ac~p.t in Principle. ~

I Chan~e ". of the ma te r i a l . . " to " . . o f a b~,~rdous material. I O 9 O O O

COMMITTEE STATEMENT: The Commilxee feels that • provides a dearer statement.

(Log # a45) 472- I04- (24.L4.2): Reject SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Revise 2-4.1.4.2 m read:

"Given the current edition of the DOT Emergency Response • Guidebook, describe the definitions for each of the following

~UBSTANTIATIrote ctive actions:" ' ' ON: Due to the availability of the DOT Emergency

Response Guidebook, it seems that the resl:onder should be able to identify the definitions and also describe their meaning. COMMITrEE ACTION: Reject. C O M M r r r E E STATEMENT: The Committee feels that the wording in the TCR is adequate.

(Log # s46) 472- 105- (2-4.1.4.4): Accept in Principle _ SUBMrrrER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise 2-4.1.4.4 so that the competency /eact~

"Given the current edition of the DOT Emergency Response • Guidebook, describe the difference between sfnali and large spills

found on the green bordered pages in the Guidebook. ~ SUBSTANTIATION: Additions and deletions are made to clarify the intent of the competency. COMMrlWEEACTION:' Accept in Principle.

Change "identify" to "describe. , Replace " . . . on the green bordered pagel~.." with " . . . in the table

of isolation distances. . ." • COMMITrEE STATEMENT: The Committee feels that the change more appropriately identifies the portion of DOT Emergency R~sponse G u i d e b o o k . . "

(Log # ~S) 472-106 - (2-4.2): Accept in Principle SUBMITIT, R: c~J. Wright, Union Pacific ]~,ailroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change 2-4.2 to rc~l:

"Initiate the notification process specified in the local emergency response plan and the orgamzauon s standard operating procedures. The fL~ responder at the awareness level shall, given a either facility or transportation scenario involving hazardous materials, identifying the appropriate notifications to be made and how to " make them consment with the local eme~enc~ response plan or the ' ~ n ' s standard operating procedures.

SUBSTANTIATION: Clarify the intent of the competency. COMMITrF, EACTION: Accept in Principle. ,

I Make the second sentence 2-4#.1. 1. A la~ " change the definition .of Local Emergency Response Plan to

| " rhe plan promulgated by the authorityhavingjurisdiction, e.g., as | the local emergency planning committee for the community or a I faculty? ' :

COMMrlWEE STATEME.-wr: The Committee agrees with the - submitter but feels that the second sentence should be a separate competency.

(Log#7Sl) 472- 107 ~ ( 2-4.2. l ): Accept in Principle SUBMrI.IT.~ Bruno Mark Wilson, Oregon State Ftre'M~mshal COMMENT ON PROPOSAL NO.: 472-1 - RECOMMENDATION: Delete text. SUBSTANTIATION: RedundanL (See 2-4.2) COMMrIWEEACTION: Accept in Principle. COMMITTEE STATEMENT:See Committee Action and Statement on Public Comment 472-106 (Log #293).

(Log # SS) 472-108- (3-1.1): Reject SUBMI']WER: Richard S. Kram, Mobi l Off Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add to the 1st sentence:

" . . . and operational levels for those materials and produ~s which they are expected to be handling or which are transported by them or stored on premises. Responders need only to be trained in those competendes required for a proper response to incidents for materials handled." SUBSTANTIATION: There is no need to be trained to handle materials not involved in one's activities. There is no need to be trained in tank car response if one's materials are not shipped by tank car. There is no need for SCBA waining if a negative pressure respirator is mtticient etc. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action and Statement on Public Comment 472-13 (Log #82).

a

(Log# 71) 472- 109 - (3-l.l): Reject SUBMITrER: PeterM. Bryan, West End Ha~rdous Materials Assistance Team COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise paragraph to read: -

"In addition, first responders at the operational level shall meet the training requirements, and if utilized in the warm or hot zones be provided medical surveillance, in accordance with federal Occupa- " tional.. ? (same as accepted remainder of paragraph). SUBSTANTIATION: Federal OSHA in document 1910.120 hm .indicated the intent is to r~luire such medical monitoring for persons utilized in those applications. Requirements should be consistent with existing laws and other chapters of this document. COMMITTEE ACTION: Reject. COMMITTEE STATF, blENT: The submitters proposal is not a competency. The standard establishes minimum levels and it ls pore'hie for persons to be trained beyond the minimums established and therefore have to rm.,et any other applicable rlegulations.

(Log # 15) 472-110- (3-1.2 and A-l-l.2(b)): Accept in Principle SUBM1TrER: Gregory G. Noll, Hildebrand & Noll Assoc., Inc. COMMENT ON PROPOSAL NO.: 472-1 ', " RECOMMENDATION: t'~hange last line to read:

" . . . and to Drote~ (delete prevent) exposures." SUBSTANTIATION: Edito/ial correction. , COMMrrFEEAC'r lON: Accept in Principle.

Change last sentence to read: " . . . a safe distance and keep it from spreading."

C O M M r r r E E STATEMENT: The Committee feels that ~ r d i n 8 is dearer.

321 _ I

N F P A 472 m A92 T C D

(Log # 79) 472-All - (3-1.2): Accept SUBMrFrER: J im Litevich, NH Haz-Mat Curriculum Development Committee COMMENT O N P R O P O S A L NO.: 472-1

I RECOMMENDATION: Revise text: " . . . persons who respond ~ to releases or potential releases..."

• SUBSTANTIATION: -Editorial correction to iext. COMMITTEE ACTION: Accept.

(Log # 732) 472- 115 - (3-1.8(a) 2): Accept .. SUBMITI'ER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-']

• i RECOMMENDATION: Should read:

I " . . . response information from material safety data sheeu. . ." SUBSTANTIATION: Improper syntax ( d _ ~ e e m e n t in number): delete the word "a" from before "material". COMMITTEE ACTION: Accept. ..

(Log# IS), (Log# I) 472- 112- (3-1.3): Reject SUBMITrER: Stephen G. Mraz, Pensacola, FL (Log # 13), EugeneJ. Kobliska, Union Cnty HAZMAT Team (Log # I) COMMENT O N P R O P O S A L N O . : 472-1 • , RECOMMENDATION: Revise text:

"The goal of compe.tencies at the operational level shall be to provide first responders with the knowledge and skills to perform the following tasks safety. The first responder is not expected to use specialized chemical clothing or control equipment. Therefore, in addition to being competent at the awareness level, the first responder at the operational level shall be able to:" SUBSTANTIATION: Use of special chemical clothing and control equipment is the responsibility of Technician Level trained personnel. Use of special clothing and equipment by personnel not fully trained to the Technical Level may 8we a false sense of secority to a first responder and result in injury or other complications at a h~7"~rdous matertalg incident. COMMI2WEE ACTION: Reject. COMMITTEE STATEMENT: This standard establishes minimum competencies regarding protective dothing. In many cases in industry operational levelpersons will use some specialized dothing and would be c!a~dfifd as Brst responders.

472- 116- (3.1.3(a) 2): Accept .- (Log # 201) SUBMrrTER: Gerald L. Grey, Redwood City, CA COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: Correct grammar by deleting aa" in 3.1.8(a) 2. line 1. SUBSTANTIATION: Grammar correction only. COMMITTEE ACTION: Accept.

(Log # 96) 472-117- (3.1.3(a) 2): Reject SUBMrrrFJh Kent IL Olson, American Assn. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add ~ [ i o n a l poison control centers" t o the list of sources to obtain information. SUBSTANTIATION: Regional poison control centers are valuable resources for health effects information and may be able to give vital information to protect first responders as well as guidance about rescue and treatment of any victims. COMMITTEE ACTION: Reject. COMMITrEE,STATEMF..NT: The Committee believes that the information that the responder is being asked to obtain at this level is not univenmlly available from poison control centers and therefore shouldn't be included."

472-113- (3.1.3(a) 1): Accept " (Log# 292) SUBMrrYER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the word "Estimate" to "Predict" in 3.1.3(a) (1) so as to read:

"3.1.3(a) 1 Predict the likely behavior of a material and iu containment system; and" SUBSTANTIATION: The action verb in this case is predict not estimate. Webster defines estimate as "to give or form an approxi- mation (as of value, size, or cost)"). Webster defines predict as "to foretell; prophecy." The connotation of predict better fits the intent of this competency. COMMITIT.E ACTION: Accept.

(Log # 719) 472-1181- (3.1.8(a) 3 and 4): Reject SUBMrrrER: Paul R. Spurlin, Wayne Township Fire Dept., IN COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete all of Sections S-l.3(a) $ and 4 and move to Section 4-1.3. SUBbWANTIATION: The above b too advanced for the operations level, needs to be moved m the technician level. COMMITrEEACTION: Reject. " COMMrrrEE STATEMENT: See Committee Action and Statement on Public Comment 472-121 (Log #290).

472- 114- (3-1.3(a) 1): Accept in Part SUBMIWrER: Raymond P. Beaudry, Wilmington, DE (Log # 909), John T. Higgins, Dow Coming Corp. (Log # 401), .. W'dliam A. Levy, Research Triangle Park, NC (Log # 630), HersheH Stafford, Exxon Chemical Americas (Log # 490), JosephJ.Jaskot, FMC Corp., (Log # 33), Samuel A. Pearman, Martinsviile, VA (Log # 975), John M. Colmm, Occidental Chemical Corp. (Log # 1035), Michael F_. Lyden, The Chlorine Institute (Log # S04)

" COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: "Replace words "containment systems" with the words "container/packagin. g." . SUBSTANTIATION: Containment systems b not the recognized terminology used by industry, regulators or emergency responders.

I COMMHTEEACTION: Accept in Part. Change to "container:

COMMITTEE STATEMENT: See Action on Public Comment 472-51 (Log #394). The definition of container now indudes packaging. Therefore, it b not necessary to repeat it.

472-119- (3.1.3(a) 3): Accept SUBMITIT~ Michael F_. Lyden, The Chlorine Institute, Inc. (Log # S05) , JosephJ.Jaskot, FMC Corp. (Log # 34), Hershell Stafford, Exxon Chemi~d Americas (Log # 491),

• John T. Higgins, Dow Coming Corp. (Log #402), W'dliam A. Uevy, Research Triangle Park, NC (Log # 681), Samuel A. Pearman, Martinsville, VA (Log # 976), John M. Coburn, Occidental Chemical Corp. (Log# 1056), Raymond P. Beaudry, Du Pont Co. (Log #880) COMMENT O N P R O P O S A L NO.: 47~-I j REA3OMMENDATION: Replace words "containment system" with the words "container/packaging ~. ' . SUBSTANTIATION: Conta]nrfient system b not the recognized terminology used by industry, regulators or emergency responders. COMMITTEE ACTION: Accept.

(Los# 404) 472- 120- (3.1.3(a) 4): Reject SUBMrlWER: John T. Higgins, Dow Coming Corp. C O M M E N T . O N P R O P O S A L NO.: 472-1 RECOMMENDATION: Delete text. SUBSTANTIATION: This b pan of the responsibilities of the incident commander. This item should be moved to Chapter 5. COMMITTEE ACTION: Reject. • ' COMMrlWEE STATEMENT: See Committee Statement and Action on Public Comment 472-121 (Log #290).

322

N F P A 472 - - A 9 2 T C D

• 472-121 - (S-l.3(a) 4): Accept in Principle ~ " (Log # 290) SUBM1TrER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change 3-1.3(a) 4 to read:

3-1.S(a) 4 Estimate the potential outcomes at a b~,~rdous material incident. SUBSTANTIATION: The outcomes assochted with a ha~rdous rhaterial incident provide Ore basis for the decisions for handling the incident. The responder who plans to take some action must have * some idea of the [k~tential outcomes - death; injury, property damage, environmental damage, system disruption; otherwise, that responder may become p a n of the problem and not part of the ' solution, There must be something to save if an attempt Is made to save it The task at hand is for the responder to have some idea of the potential outcomes at a h~r~rdous mate~'ial incident. This may be very general and would require further =malysis by more comI~etent permnnel , but it must be accomplished. This level reqmres, at a minimum, defensive action and that action is based on the potential outcomes. " ' COMMITTEE ACTION: Accept in Principle. 'Change m W_.stimate the potential harm ai: a hazardous materials

incident." ~ . . . Also change S-2.4 W_.stimate the potential harm at a h ~ r d o u s

materials incident within the endangered area. The first responder at the operational level shall estimate the potential harm at a b2~rdous materials incident." COMM1TrEE STATEMENT: The Committee agrees With the submitter that it is important for the first responder to have some idea as to the potential harm o f a ha-~rdous materials incident. The skills at this level are fairly basic but the pe~aon should know of the potential for death, injury, etc.. . .

472- 122- (~-l.3(a) 4): Reject SUBMITI 'E~ Hershell Stafford, Exxon Chemical Americas (Log # 492) . . . . JosephJ.Jaskot, FMC Corp. (Log # ~), Michael E. Lyden, The Chlorine Institute Inc. (Log # 306), Samuel A. Pearman, Martinsville, VA (Log # 977), JohnM. Cobum, Occidental Chemical Corp. (Log # 1037), WHliam A. Levy, Research Triangle Park, NC (LOg~ # 632), Raymond P. Beau&y, Du Pont Co. (Log # 910)

• COMMENT ON PROPOSAL NO.: 479-1 RECOMMENDATION: Delete the sentence. SUBSTANTIATION: Identification of the resources should be part of the Incident Command structure. COMMITTEE ACTION: Rekct. ": , COMMITrE£ STATEMENT: See Commilxee Action and Statement on Public Comment 472-121 (Log #290).

: (Log # ~91) 472- 123 - (3-1.3(b)): Accept SUBMITrER: c . J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add the words am, initial" in place of the word "a" in 3-1.3(b) m ~s to red, i: ,

3-1.3(b) Plan an initial response. SUBSTANTIATION: Clarify the intent of the competency by

to tho of competency ON: Accept:

472- 124- (3-1.3(b)): Accept SUBMITYE~ Hershell Stafford, Exxon Chemical Americas (Log # 493),

Joseph J.Jaskot, FMC Corp. (Log# $6), Michae] E. Lyden, The Ch]orine-lnstitute Inc. (Log # 307), • Samuel A. Pearman, Martinsville, VA (l.~g_ # 978), John ~L Coburn, Occidental Chemical C6sp. (.Log# 1038), "W'dliam A. Levy, Research Triangle Park, NC (I.og # 633), Raymond P. Beau&y, Du Pont Co; (Log #,91 I), " John T. Higglns, Dow Coming Corp. (Eog # 403) ~ ) M M E N T O N PROPOSAL NO.: 472-I , RECOMMENDATION: Insert the word "initial" to read a~ follow~

"Plan an initial r e sponse . . . " SUBSTANTIATION: As originally written, statement infers that first responder is in charge and planning entire response. Also, it , conflicts with defini~on 3-1.2. COMMITYEE ACTION: A~.ept.

(L0g # 718) 472-125 - (S-1.$(b) 1): Reject ' " S U B ~ Paul R. Spurlin, Wayn eTownship Fn'e Dept., IN COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete all of Section 3-I.$(b) I. SUBbWANTIATION. Section S-l.3(b) 2 covers what the operational level should know.

Section S-1.3(b) 1 is to broad. COMMITTEE ACTION: Reject. COMMITrF.E STATEMENT: It is felt that this competency Is necessary at this level because responders at the.operational level should have some understanding of.their response objectives.

. (Log #'40S) 472-120- (3-1.3(b) 1): Reject SUBMTF]T,R: John T. Higglns, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMF,,NDATION: Change to read as follows:

~Determine the defensive ~sponse objective s for a h ~ r d o u s materials incident. ~ SUBSTANTIATION: The operations level person is m respond in a defensive mode only. This p~.sed wording will darify this competency. COMMITTEE ACTION: Reject. COMMrFrF, E STATEMENT: See Public C_~mm~nt s472-125 (Log #718) and 472-127 (Log #494). ,

472- )27- (3-1.S(b) I): Re jec t _ SUBMITYER: Hershell Stafford, Exxon Chemical Americas (Log # 494), osephJ.Jaskot, ~'MC Corp. (Log #,S~), - chae] F_. Lyden0 The Chlorine Institute Inc (Log # $08),

Samuel A. Pearman, Maninsville, VA (Log # 979); John M. Colmrn, Occidental Chemical Corp.(Log # I059), W'flliam A. Levy, Research Triangle Park, NC (Log # 6 3 4 ) , Raymond P. Beaudry, Du Pont Co. (Log # 912) COMMENT ON,PROPOSAL NO.: 472-1 RECOMMENDATION: Change first word "Describe" m "Deter- m i n e : . Also, ~ word "defensive" before response objectives m reac~ "Determine the defensive response ob '~ct ives . . . "

SUBSTANTIATION: The word "describe" would indicate a competency not a goal in this section. Thedefini t ion of a first responder at the operational level states

that '~hey shall be trained m respond in a defensive fashion to control the release from a safe distance, to keep it from spreading and to prevent exposures. . COMMrITEE ACTION: Reject. COMMrIWEE S T A ~ : The Committee feeh that S-1.2 dearly states that the responder at the operational level is trained to respond in a defensive f~b lon and that it is not necessary to. continue to point that ou t - " '

(Log # 406) 472-128 - (S-l.S(b) 2): Reject SUBMITFER: John T. Higglns, Dow Coming Corpi COMMENT ON PROI~)SAL NO.: 472-1 RECOMMENDATION: Change to readas follows: ~"

"Determine the defensive response options available for each

N: (~adfication of this competency. Response objectives are determined at the time of the response, not ahead of time. COMMrFrEE ACTION: -Reject. COMMITTEE STATEMF, JqT: The competency requires the responder to describe various response objectives available in general for a responder functionmg at this level in a defensive r~h |on . To have the responder detekmine specific response objectives would be a more advanced competency and-the Commit- , tee felt it .would not be appropriate at ~ l e v e l .

323

N F P A 472 - - A92 T C D

" (Log # 299) 472- 129- (3-1.3(b) 2): Accept S U B ~ C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the word "by" in 3-1.3(b) 2 to "for a given" so it read~

3-1.3(b) 2 Describe the defensive options for a given response objective. SUBSTANTIATION: (~uification of intent of competency. COMMITTEE ACTION: Accept.

472-130- (3-1.5(b) 2): Reject ,. SUBMrl-gld~ Henhell Stafford, Exxon Chemical Americas, (log # 495),

J o s e p h J . J ~ o t , FMC Corp. (Log # 38), Michael E. Lyden, The Chlorine Institute Inc. (Log # 309), Samuel A. Pearman, Martin~ille, VA (Log # 980), John M. Cobum, Occidental Chemical Corp. (Log# 1040), W'dliam A. Levy, Research Triangle Park, NC (Lo 8 # 635), Raymond P. Beaudry, Du Pont CO. (Log # 913) COMMENT ON PROPOSAL NO.: 475-1 RECOMMENDATION: Revise sentence to rea&

~Determine the defensive options available for each response objective." SUBSTANTIATION: The word "describe" would indicate a competency not a goal in this section.

Changing the e n d o f the'sentence to read "for each response objective', clarifies the meaning. COMMITrEE ACTION: Reject. C O M M I T E ~ STATEMENT: See Committee Statement on Public Comment 472-128 (Log #406).

472- 131 - (3-1.3(b) 5): Accept SUBMrrrER: Hershell Stafford, Exxon Chemical Americas (Log # 496),

Jose. ephJh .J;askot, FMC Corp. ( ~ # 39), " Micnae! ~ Lyden, The Chlorme Institute Inc. (Log # MO), Samuel A. Pearman, Martinsville, VA (Log # 981), John IVL Cobum, Occidental Chemical Corp. (Log # 1041); W'flllam A. Levy, Research Triangle Park;NC (Log # 636), " Raymond P. Beaudry, Du Pont CO. (Log # 914), john T. Higglns, Dow Coming Corp. (Log # 407)

,, COMMENT O N PROPOSAL NO.: 472-1 [ RECOMMENDATION: Delete entire sentence.

SUBSTANTIATION: This is covered in 3-1..3(c). " COMMITrEEACTION: Accept.

(Los#97) • 472- 132 - (3-1.3(c)): Accept SUBMrrIT.R: Kent R. Ohon, American Assn. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add "5. Perform emergency decontamination of contaminated personnel or victims if needed." ," • SUBSTANTIATION: Operational level responders ought to be aHe to perform basic decontamination if indicated on an emergency basis. COMMITTEE ACTION: Accept.

COMMrrrEE STATEMENT: See Committee Action and Statement on Public C~mment 472-114 (Log # 9 0 9 ) . .

(Log # S52) 472-134- (3-2.1.1): Reject ' SUBMrlWER: Michael P,. Rehfeld, Wesuninster Fire Dept., MD COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Delete text. , ,

Given examples of various h2-Jndous materials containment systems, identify each con~nment system byname. SUBSTA/~I~TION: This proficiency is not consistent with the knowledge needed by the average flreflghter in the course of the Operations Objectives. COMMrrrEE ACTION: Reiect. COMMrlWEE STATEMEN'I~: The Committee feels that this is consistent with the operational level. A-2-3.1.1 provides examples of what a r~ponder would be expected to have an understanding of at this level

472- 135 - (3-2.1.1"): Accept in Principle • SUBMrrrER: Hershell Stafford, Exxon Chemical Americas

(Log # 498), JosephJ.Jaskot, FMC corp. (Log # 41), Michael E. Lyden, The Chlorine Institute Inc (Log # 312), Samuel A. Pearman, Martinsville, VA (Log # 983), John M. Coburn, Occidental Chemical Corp. ( I ~ # 1043), W'flliam A. Levy, Research Triangle Park, NC (Log # 038), Raymond P. Beaudv/, Du Pont Co. (Log # 916), John T. Eliggins, Dow Coming Corp. (Log # 409) COMMENTON PROPOSAL NO.: 472-1 ~ M M E N D A T I O N : Revise sentence to read:

"Give examples of various l ~ r d o u s materials containers/ packages, identifying the general shapes of these containers/ packages containing liquids/gases/solids." SUBSTANTIATION: This sentence will make 3-2.1.1.1. through 3-2.1.1.4 unnecessary. COMMITTEE ACTION: Accept in Principle, Reword as follows: "Give examples of various b ~ r d o u s materials containers, identify

the general shapes of containers for liquids, gases, and solids. COMMITTEE STATEMENT: The Committee feels that the revised wording is dearer.

472- 138- (3-2.1.1.1 through 3-2.1.1.4): Reject SUBMITTER: Hentheli Stafford, Exxon Chemical Americas (Lo s # 499), " •

JosephJ.Jaakot, FMC'Corp. (Log # 42), Michael E. Lyden, The Chlorine Institute Inc (Log# 313), Samuel A. Pearman, Martinsville, VA (Log # 984), John I~L Colmrn, Occidental Chemical corp. (Log# 1044), William A. Levy, Research Triangle Park, NC (Log # 659), Raymond P. Beaudry, Du Pont Co. (Log # 917), JohnT. Higglns, Dow Coming Corp. (Log # 410) COMMENTON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete above sections. • SUBSTANTIATION: These sections unneces&~ry after rewrite of sentence 3-2.1.1% ' ' COMMITrEE ACTION: 'Reject. COMMFIWEE STATEMENT: The committee feels that these competencies are appropriate and because of the Action on Publi( uomrn, ent 472-135 (Log #498) requires that.these competencies remain.

472-133- (3-2.1): Accept in Part SUBMITIT.R: Hershell Stafford, Exxon Chemical Americas (Log # 497), JosephJ.Jaskot, FMC Corp. (Log # 4o), Michael F_. Lyden, The Chlorine Institute Inc. (Log# 311), Samuel A. Pearman, Martinsville, VA (Log # 982), John M. Cobum, Occidental Chemical corp. (Log # 1042), Vfdliam A. Levy, Research Triangle Park, NC (Log # 637), Raymond P. Beaudry, Du Pont CO. (Log # 915), John T. Higgins, Dow coming corp. (Log # 408) COMMENTON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "containment systems" and replace with "container/packaging'. . . SUBSTANTIATION: ~,ofitalnment systems is not the recognized

I t e r n r u ' n ~ used by industry, regulators or emergency responders. COMMrITEEACTION: Accept in ~

(Log # ~S) 472- 137- (3-2.1.1.1): Accept SUBMrrIT, R: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RE~X)MMENDATION: Add 3-2.1.1.1(c) to read:

"Ckyogenic liquid tank cars." SUBSTANTIATION: Generally lank cars are discussed in terms of three basic types: non-preuure, pressure, and c~/~genic liquid tank cars. Bein~ able to identify Which type b involved m an emergency may be criucal to the response mad~ to that emergency. Although there are only 331 of these cryogenic liquid tank cars, their behavior is.so.mewhat different than the non-pressure and pressure tank cars winch relSresent 99 percent of the tank cars in service. COMMITTEE ACTION: Accept.

3 2 4

t

(Log # 7ss) 472- 158 - (3-2.1.1.5): Reject SUBMrlWER: Bruno Mark W'flson, C~-~gon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Delete text. SUBSTANTIATION: Too detailed and not especially useful. The ability of a first responder to recall the name of the DOT classification does not in itself aid in harard analy~/ r i sk assessment. If we are looking at the ability to recognize and understand design characteristics of different contamei's and the commodities they are ' l ikely to contain, then a different objective ~ have to be written. This one does not measure that competency. " COMM1TIT.R ACTION: Reject. COMMITTEE S T A ~ : The competency requires the individual to identify the tw~e of ._cargo tank e.g., pressurized, etc. It is not the requirement that they identify them by the specific number. The specifications number providLe the trainer with the specific types that a responder should be able to identify.

(Log # 16) .' 472- 130- (3-2.1.1.3): Accept . • SUBMITIT..R: Gregory G. Noll, Hildelxand & Noll A&soc., Inc. COMMENT ON PROPOSAL NO.: 472-1 '

RECOMMENDATION: Revise to read: (a) MC-306/DOT-406 cargo tank. '

SUBSTANTIATION: Typographica! error. CO MITRE ACTION: Accept.


(Log.# 202) 472- 144- (3-2.1.2.1): Accept SUBMrI'rER: Gerald L Grey, Redwood City, CA. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: O3ange text to read: ' " "Given examples of the following transport vehicles and their

corresponding shipping papers, identifythe vehide or tank identification marki-ng hi all applicable locations." (a), (b), and (c) to remaln the mine. , " S ~ A N ' r I A T I O N : I do not believe that the vehicle identification

"' .marking is found on the shipping papers for ra H, interm0dal equipment, and highway transport vehicles. ODMMrlWEE ACTION: Accept. " '

iI~g # 2os) 472- 145 - (3-2.1.2.2): Accept SUBMITrFA~ Gerald L Grey, Redwood Qty~ CA COMMENT ON PROPOSAL NO.: 472-1

i RECOMMENDATION: Revise text to i'ead: . "Givenexamples of facility containers, Identify the markings for

container size, product contained, and/or site identification nulnberf . i - ' - - SUBSTANTIATION: This competency as written is too weak and possibly useless. COMMITrEE ACTION: Accept.

(Log # 838) ' 472- 140- (3-2.1.1.3):" Reject SUBMrI'rER: Richard G. Lusk, Gainesviile Fire Rescue, FL COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Relocate competency to appropriate section on Chapter 4. Suggest designating it as a new section 4-2.1.1.$. SUBSTANTIATION: It is important for fuefishters to recognize these types of cargo tanks by their general cJaaracte~tica (pressure vs non-presmre) and what they may carry. It is not important that they know the Motor Cartier or DOT designation of the cargo tanks. COMMrIWEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement 472-138" (Log ~SS) .

(Log # 844) 472- 141 - (3-2.1.1.3): Reject SUBMITTER: Terry Bindernagel, ~evelhnd, OH . COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text:

"Part of our training is to include 400 series tankers." SUBSTANTIATION-.- When will 400 series tankers be a realib/: We cannot address something that does not exist. COMMITTEE ACTION: Reject. ' COMMITTEE STATEMENT: The submiuer does not propose any changes.

(Los # ~s) 472- 142- (3-2.1.1.$(a)): Accept '

• SUBM1TrER: C.J. Wright, Union Pacific Railroad - COMMENT ON PROPOSAL NO.: 472-I- RECOMMENDATION: Correct 3-2.1.1.3(;0 to read:

5-2.1.1.3(a) MC-506/DOT~_..66. " SUBSTANTIATION: Correct typographical error.

C O M M r r r E E ACTION: Accept.

( u s # 11s) 472-146 - (3-2.1.$.2(c)): Accept in Principle S U B ~ Rem Gaade, Canadian Assn. of Fire.Chief~ COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION:, Change to:

3-2.1.3.2(c)* EPARegistration Number /PCP Number with Ap, pelncUx note. ' "

- A-3-2.1.S.2(c) Pestiddes can be identified from a listing of • Registration Numbers. In the U.S. this listing is produced by the

EPA. In Canada, .this listing is produced by agriculture Canada under the Pest Control Products (PCP) Act. SUBb~ANTIATION: Although not legal, EPA numbers are found in Can~la and PCP Numbers are found in the US. Someone in either country coming across the other country's Registration . Number should be able to recognize it for what it is and know what to do with iL

I COMMITr]KE&CTION: Accept in Principle. ' , Reword as follows: a3-2.1.$,2(c) Pest Control Product (PCP) NumberY

COMMrI ' rEE STATF.MENT: The EPA registration number is not readily available in Canada however, the PCP Is available.

472-147- (3-2.1.3.2(c)): Accept SUBMrrrER: Hershell Stafford, Exxon Chemical Americas

, (Log # 500), JosepbJ.Jaskot, FMC Corp. (Log # 48), Michael E. Lyden, The Chlorine Institute Inc. (Log # 314),' Samuel A. Pearman, Martinsvifie, VA (Log # 985), John M. Cobum, Occidental Chemical Corp. (Log# I045), W'dliam A. Levy, Research Triangle Park, NC (Log # 640), Raymond P. Beauchy, Do Pont Co. (l_og # 918), John T. Higgins, Dow Coming Corp. (Log # 411) COMMENTON PROPOSAL NO.: 472-I RECOMMENDATION: Delete EPA registration number. SUBSTANTIATION: Adds no value for emergency response

~ ~ ACTION: Accept.

(Los # 7s4) 472-143 - (3-2.1.2): Reject SUBMITI~R: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Recommended deledon applie-~ to 3-2.1.2.1 and' 3,-2.1.2.2 as well. SUBSTANTIATION: Whatpurpose do competency in these skills serve? This information is of marginal value to the first responder. COMMITTEE ACTION: Reject. C O M M r r r g E STATEMENT: The Committee feeh that this information is important for the responder at this level. '

472-148 - (3-2.1.5): Ac~. :pt ' ' (L°g # 286) SUBMITIT.R: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 ..

"RECOMMENDATION: Change 3-2.1.5 to read: ' 3-2.1.5 Give examples ofwa D to verify lhformaflon obtained f rom.

the mrvey o f a hazahiom material inddent." •

SUBSTANTIATION: The suggested revision clarifies the intent of

~ ~ C ~ C r l O N : Accept.

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I

N F P A 472 m A 9 2 T C D

472- 149- (3-2.1.5): Accept SUBMrrrER: Hershell Stafford, Exxon Chemical Americas (Log # 501), JosephJ.Jaskot, FMC Corp. (Log # 44), Michael F. Lyden, The Chlorine Institute Inc. (Log # S15), Samuel A. Pearman, Martinsville, VA (Log # 986), John M. CObom, Occidental Chemical Corp. (Log # 1046), W'flliam A. Levy, Research Triangle Park, NC (Log # 641), Raymond P. Beauchy, Du Pont CO. (Log # 919), John T. I-Iiggins, Dow Coming Corp. (£og # 412) COMMENTON PROPOSAL NO.: 472-1-

[ ,RF~L__MMENDATION: Revise sentence to read: Give examples of ways to ~ information obtained from the

survey o f a ha~rdous Inaterials mcident." SUBSTANTIATION: As written, the sentence is confusing. • COMMIIqT.E XCTION: Accept

(Log # 7SS) 472- 150 - (3-2.2): Reject • SuBMnWER: Brurio Mark Wllson,Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 47221 \ RECOMMENDATION: None. • SUBSTANTIATION: We understand where the Technical Committee seems to be coming from in regard to terminal objectives and enabling objectives. Given the way the standard has been restructured, however, the wording of major cate~ries such as 3-2.2, 3-5.1, 3-5.2, etc., this is most confusing to the reader and unneceLsar-

t. MITrEE ACTION: Reject.

COMMITTEE STATEMF2qT: The submitter did not make any recommendation.

(Log # 9S) 472- 151 - (3-2.2): Reject SUBMrrIT, R:' Kent R, Oison, American Assn. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add ~ i o n a l poison control centers" to the list of information resources m this paragraph. SUBSTANTIATION: Same comment as in 3-1.~5(a) 2. COMMrrrEEACTION: Reiect. • COMMr]WEE STATEMENT: The Committee feeb that because the competen.cy is requiring knowledge about hazard and response information that ~ information is not always available from many poison control centers.

SUBSTANTIATION: The First Responder Operational Level personnel must have a basic understanding of hazardous materials in order to initiate effective'defensive actions at a ba,~rdom materials incident- However, this objective can be met by the First Responder Operational Level responder without this level of technical knowledge. . . COMMrlWEE ACTION: Reject. COMMrrrEE STATEMENT: See Committee Statement on Public Comment 472-69 (Log #177)..

/

472- 1M - (3-2.2.1):" Reject SUBMrrYER: Hershell Stafford, Exxon Chemical America~ (Lo 8 # 502), . Joseph j.jaskot, FMC Corp. (Log # 45), Michael E. Lyden, The Chlorine Institute Inc. (Log # 316), Samuel A. Pearman, Martinsviile, VA (Log # 987)° John M. Cobum, Occidental Chemical COrp. (_Lo 8 # I047), William A. Levy, Research Triangle Park, NC (Log # 642), Raymond P. Beaudry, Du Pong CO. (Log # 920), John T. Higgins, Dow Coming Corp. (r, og # 413) COMMENTON PROPOSAL NO.: 472-I RECOMMENDATION: Rewrite sentence to read:

"Describe how to identify DOT b~ard classes and divisions and where this information can be found." SUBSTANTIATION: For clarity. COMMITTEE ACTION: .Reject. COMMITTEE STATEMENT: The Committee feels that the competency as written, requiring matching, is the appropriate knowledge and skill at this level. . " '

(Log# 28S) 472-155 - (3-2.2.2(h)): Accept in Principle SUBMITTER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RFJ3OMMENDATION: Change 3-2.2.2(h) by adding the parenthe- ses as indicated:

3-2.2.2(h) Precautions for safe handling (including industrial hygiene practices, protective measures, procedures for clean-up of spilis/leaks). SUBSTANTIATION: Clarify the intent of the competency. COMMITTEE ACTION: Accept in Principle.

Delete the word "industrial".. COMMrrrEE STATEMENT: The Commiaee agrees with the submitter but feels that deleting industrial is appropriate.

, (Log# 7) 472- 152- (3-2.2.1): Reject SUBMrrIT.R: Robert A. Green, Riverside Cnty Fire Chiefs' Assn. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise paragraph to read:

'~qatch the definitions auodated with ihe DOT H2~ard Classes and Di--:=iv,,- of haTardom materiaLs, including refrigerated liquefied gases and ayogenic liquids, with the class m-divisie~."

(Delete lined out text). SUBSTANTIATION: The First Responder, Operational Level personnel should have a basic understanding of ha,ardous materials m order to effectively initiate "defensive" actions at the ha~,ardous materials incident.

Havin~g to deal with the various divisions of the different hazard classes ts appropriate when dealing with Fire Prevention Codes and other such regulations. However, for field knowledge, the Fhst Resp3nder, Operational Level doesnot have to be that technical. COMMrlWEEACTION: Reject. • COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-69 (Lo s #1.77).

(Log # lS0) 472-153- (3-2.2.1): Reject SUBM]TrFA~ Michael E..Boyle, Califomia Region I, Local. Emergency Planning Committee. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text as follows:

~ la tch the definitions associated with the DOT Hazard Oa.~es and D;.'- -;.~. of ha-~rdom materials, induding refrigerated liquefied gases and cryogenic liquids, with the dam ..~ ,~2=..,.."

472-15e- (3-2.s): Accept (Log # 284) SuBMn'rER: c.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the word "Estimate" to "Predict" in bothplaces in 3-2.3 so as to read:

3-2.3 Predict the likely behavior of a material and its containment system. The first responder at the operational level shall, given examples of both facility and transportation hazardous material incidents, predict the likely behavior of the material and its containment system in each incident. . ' SUBSTANTIATION: The action verb in this case is predict not estimate. Webster defines, estimate as ~o give or form an approxi- marion (as of value, size, or cost)'). Webster defines predict as ~to foretell; prophecy. The connotation of predict better fits the intent of this cdml~etency. COMMITTEE ACTION: Accept.

/

472- 157- (3-2.$*): Accept in Part - SUBMrrrER: Hershell Stafford, Exxon Otemical Americas

• (Log # 503) . JosephJ.Jaskot, FMC Corp. (Log # 46), Michael F_. Lyden, The Chlorine Institute Inc. (_.Log# 317), Samuel A. Pearman, Martinsville, VA (Log # 988), John M. Cobom, Occldenud Chemical Corp. (Log# 1048), "W'dliam A. Levy, Research Triangle Park, NC (Log # 643), Raymond P. Beaudry, Du Pont Co. (Log # 921), John T. Higgins, Dow Coming Corp. (Log # 414) COMMENTON PROPOSAL NO.: 472-1- ~ M M E N I ) A T I O N : Delete containment system from first and second sentence and replace with. "container/packaging',

326


SUBSTANTIATION: Containment system b not the recognized terminology used by industry, regulators or emergency reiponders. COMMITrEEACTION: Accept in Part. COMMITTEE STATEMENT: See Action ~md Statement on Public Comment 472-114 (Log #909).

. . ~ c t . . (Log # sss) 4 7 2 - 158 SUBMI'rrFJ~ Michael R. Rehfeld, Wes tn~s t e r F'ure Dept., MD COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete text:

~F_~timate the likely behavior of a material and it 's 'containment • system. The first,responder at the operations level shall, given "

exar~l)les of facili'ty and t rans~r ta t ion hazardous materials incidents involving a single hazardom material, estinmte the likely behavior of the material and it's containment system." SUBSTANTIATION: The above is well o~.-r the needed ability 0f the every day l~re Service personnel for the safe operations at a Hazardous Materiah incident. COMMITTEE ACTION: Reject. ' - COMMITTEE STATEMF.NT: Section 3-2.5 establishes the overall ' '

objectives involved in carrying out the goaJ established in Section ~-1.3(a)~. The objectives listed in Sections ~-~.3.1 tilrough Section 3-2.3.7.1 all address those objectives by estal31ishing competencies designed to give the responder the netess~/ski l ls to function at this level. Skills such as identifying health and physical hazards, identifying ways that containers may breach are certainly appropriate skills for someone involved'in emergency response to ha,ardous materials incidents. " • -~" .

t ' - ,boiling point; - concentration; - corrosivity; . .

expansion ratio; fla/nmabie (explosive) range;

- flash point; form (miki, liquid, gas); ignition (autolgnition) temperature; meitht~ point; " '

reacti¢iw, - specific grayly, - temperature ofproduc~ - toxic products of combustion; - .vapor density; . ' - vapor pressure; . ., . • • .- water solubility;,

SUBSTANTIATION: The deletion of the sub headinga in the list (physical properties, chemical properties, and physical hazards) will eliminate much wasted d i ~ o n on what category aproper ty belongs in, chemical or physical. ~That is not the significance of knowing the Information, so why proliferate t h i s . .

This format also followa the format of Section 4 - ~ . 2 in the this document. , • " '

The deletion of (pH) from'concentration is recommended as the significance of concentration is much larger t h a n j m t Ph which is not necessarily appropriate here in the first place. (Note the addition of corrosivity.)

The addition of corroslvity and reactivity is recommended as both of these iterm have a significance and impact on the behavior of the containment system a n d / o r its contents: COMMITTEE ACTION: Accept.

/

(Los # 99) 472-159 - (3-~.$.1): Reject SUBMrr]'ER:, Kent R. Ohon, American Assn.'of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add " t~ iona l poison control centers" to the list of information resources m this pmagraph. ' / SUBSTANTIATION: Same comment ~ in ~ l .$ (a) 2 : COMMITrEE ACTION: RejecL COMMITTEE STATEMENT: The Committee does not believe that ~mioisOn control centers can universally pr~dde hazard and response

nnation. There are some cases where poison control centers may be equippe d and staffed to provide asmtance but this tends to vary from area to area.

472-160- (3-2.3.1): Reject . SUBM1TrER: Hershell Stafford, Exxon C~emical Americas (Log # 504), . , JosephJ.Jadmt, FMC Corp. (Log # 4 7 ) , ' Michael E. Lyden, The Chlorine Institute Xnc. (Log # 318),. Samuel A. Pearman, Martinsville, VA (Log # 989), John M. Cobum, Occidental Chemical Corp. (Log# 1049), W'flliam ~ Levy, Research Triangle Park, NC (Log # 644), Raymond P. Beaudry, Du Pont Co. (Log # 922), John T. I-Iiggins, Dow Coming Corp. (Los# 415) . COMMENTON PROPOSAL NO.: 472-1 RECOMMENDATION: Add the word "appropriate" in the t in t line to read "interpret the appropriate hazardous.. .* SUBSTANTIATION: Responden would then not have to interpret all the information contained in these source~ COMMITTEE ACTION: Reject. ' ' COMMITTEE STATEMENT: This competency is designed to determine a persons ability to interpret data from the DOT Emergency Response Guidebook and other readily available

reference materiaLs which are the most co~nunon sources available to first responders. It im' t the intent that re,;pond~rs'would have to interpret all the information contained in these murces but that they would have an understanding of the infonmation contained and what it means. ' ' "

472- 161 - (5-2.5.1.1): Accept . SUBMITrER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise the text to read:

"Match the following chemical and physical properties with their significance and impact on the behavior of the containment system a n d / o r its content~ ,

(Log # 2O4)

(log | 17) 472- 162 - (~2.3.1.1): Acx~pt in Principle SUBM]TrER: Gregow C~ Noll, Hildebrand & Noll Assoc., Inc. COMMENT ON PROPOSAL NO.: 472-1 • "

RECOMMENDATION- Revise text as follows: (b) 8. Concentration (delete pH)

9 . pH Currently listed as physical property, but are chemical prope~'es.

SUBb~ANTIATION: Concentration and pH are not one and the same. Concentration is the percentage of a mbetance' in water, while pH is indicative 0 f the strength of a corrosive mafierial.

In acM__!don, are not physical properties but are actually chemical

MMITIT~ACTION: Accept in Principle. Add the term "(pH)" following the term "corrosivity" in 472-161

~ s'rATEMENT: Became of the action taken on Public Comment 472-161 (Log #204) the appropriate place for the term "(pH)" is followingcorrosivity:

(Log # lsl) 472-163- (3-?,3.1.1): Reject S U B ~ Michael F_ Boyle, California Region I, Local Emergency Planning Committee COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Rewrite t i n t sentence of f in tparagraph to read:

"Describe the following chemical and physical pro l:)erties and their significance in a h=~rdoua materials release." SUBSTANTIATION: The l~rst Responder Operational Level permnnel must have a basic understanding of chemical and~)hysical properties in order to eafimate likely harm. The determinauon of impact on containers and containment systems is too technical for this level and should be conducted by the Hazardous Materials Technician. C O ~ ACTION: Reject. '

COMMITTEE STATEMENT: The C o n ~ i t t e e feels that the first responder at the operational level does need to have an understanding of the terms and their impact on the containers or their contents. As a first responder operational it certainly would seem appropriate to have knowledge about corrosivity, of flammable range, ignition temperatures, etc..

\ " • ' 327

N F P A 472 - - A92 T C D

(Log# 119) 472-164- (3-2.3.1.1): Accept in Principle SUBMrlWER: Max H. McRae, Houston Irn'e Dept., TX COMMENT O N P R O P O S A L N O . : 472-I RECOMMENDATION: Delete bl , b2, b3,154, cl, and c2 from 3-2.$.1.1; and move the deleted material to a new competency at the technical leveL -- SUBSTANTIATION: This is a little much at the operations level.. Granted, knowledge of the terms is needed to estimate the likely behavior of a material and its containment system but the operations level responder will not be alone. In all probability, he will have a hazmat technidan or spedalist employee aiding In the evaluation. COMMITTEE ACTION: Accept in Principle.

Delete the sections recommended. Create.a new 4-2.2.2. Describe the following chemical and physical

properties and their signifi~.mce in a har2rdous materials release: - boiling point; - concentration; - corrosiviw, - expansion ratio;

flammable (explosive) range; . flash point; - form (solid, liquid, gas); - ignition (autoignition) temperature;

meltin~ point; reactiww,

- specific gravity; ' temperature of product; toxic products of combustion;

- vapor density;, • - vapor pressure;

water solubility Renumber the existing Section 4-2.2.2.

COMMITTEE STATEMENT: The Committee agrees that there , needs to be a greater knowledge of these terms at the technician level, but it feels that they need to also be induded at the operational level but not at the higher skill level of being able to "describe" their effects but at the skill, level of being able to ~match':

472- 167- (3 -2 .3 .1 .1 (a ) , (b ) , and (c)): Reject ', SUBMrrrER: Hershell Stafford, Exxon Chemical Americas

I k

p

en, The Cldorine Institute Inc. (Log # 320), Samuel A. Pearman, Martinsville, VA (Log # 991), John M. Cobum, Occidental Chemical Corp. (Log # 1051), William A. Levy, Research Triangle Park, NC (Log # 646), Raymond P. Ikaud/y, Du Pont Co. (Log # 924), John T. Higgins, Dow Coming Corp. (~)g # 417) COMMENTON P R O P O S A L N O . : 472-1- RECOMMENDATION: Delete above sections. SUBSTANTIATION: This is beyond the scope of the responder at the operational level and is not relevant/useful to them. ODMM]TrEEACTION: Reject. " . - COMMrITEE STATEMENT: See Committee Action and Statement on Public Comment 472-161 (Log #204).

I

' - (Log # 1001 472-168. (3-2.3.1.2): Accept in Principle SuBMrrrER: Kent R. Olson, American Assn. of Poison Control Centers COMMENT O N P R O P O S A L N O . : 472-1 RECOMMENDATION: This is an important section and should 'also be induded in Section 2-2.3. I also recommend that you add to and revise the entries as follows:

"(a) Exposure and hazard (b) Exposure and contamination (c) Contamination and secondary contamination"

SUBbWANTIATION: This covers the concept of risk assessment/ b a i r d evaluation and the concept of siml31e exposure versus contamination and secondary contaminanon of downstream

rsonnel. ' MMrrrEEAL"rION: Accept in Principle

Do not add to 2-2.3 only to 3-g3.1.2. COMMITTEE STATEMENT: The Conunittee agrees with the aubmitter's recommendation but does not feel that it is appropriate at the awarenesa level.

(Log # 736) 472- 165 - (3-2~3.1.1): Reject SUBMrrlT.R: Bruno Mark Wdson, Oregon State Fire Marshal C O M M E N T O N P R O P O S A L N O . : 4 7 2 - 3 RECOMMENDATION: ~ text:

"Identify the significance of the following chemical and physical properties and ha,~krds and their impact on the behavior of the

• containment system and /o r its content~. . ." SUBSTANTIATION: The verb "identify" rather than "match" is more easily measured in this instance. COMMITTEE ACTION: Reject. " " COMM]WrEE STATEMENT: The Conunittee feels that the skill of matching is more appropriate at this level. See Committee Statement on Public Comment 472-164 (Log #119).

472- 166- (3-2.3.1.1): Accept in Part SUBMITIT~ Hersheil Stafford, Exxon Chemical Americas (Log # 505),

Corp. E. Lyden, The Chlorine Institute Inc. (Log # 319),

Samuel A. Pearman, Martin~i'lle, VA (Log # 990), John M. Cobum, Occidental Chemical Corp. (Log # 1050),

• W'dliam A. Levy, Research Triangle Park, NC (Log # 645), Raymond P. Beautify, Du Pont Co. (Log # 923), John T. Higgins, Dow Coming Corp. (Log # 416) COMMENT O N P R O P O S A L N O . : 472-1- RECOMMENDATION: Delete "containment system" and insert "container/packaging ~. . SUBSTANTIATION: Containment systems is not the recognized terminology used by industry, regulators or emergency resDonders. COMMITrEEACTION: Accept in Part. COMMITTEE STATEMENT: See Action and Statement on Public Comment 472-114 (Log #909).

472- 169 - (3-~.3.1.2): Reject SUBMrI'rER: Hershell Stafford, Exxon Chemical Americas (Log # 507), JosephJ.Jadtot, FMC Corp. (Log # 50), Michael F_. Lyden, The Chlorine Institute Inc. (Log # 3211, Samuel A. Pearman, Martinsville, VA (Log # 992), John M. Cobum, Occidental Chemical Corp. (Log # 1052)~ W'dliam A. Levy, Research Triangle Park, NC (Log # 647), Raymond P. Beaudry, Du Pont Co. (Log # 925), John T. Higglns, Dow Coming Corp. (Log # 418) C O M M E N T O N P R O P O S A L N O . : 472-I RECOMMENDATION: Delete this ~ction. SUBSTANTIATION: It is irrelevant to the responder. COMMrFrEE ACTION: Reject. COMMITFEE STATEMENT: The Committee believes that it is important at this level to have an understanding of the difference between exposure and contamination.

472- 170 -' (3-2.$.2): Reject SUBMITrER: Paul R. Spurlin, Wayne Township Fire Dept., IN COMMENT O N P R O P O S A L N O . : 472-1 RECOMMENDATION: Delete Section 3-2.3.2. SUBSTANTIATION: Above section is too advanced for the

mtional level. ACTION: Reject.

COMMYITEE STATEMENT: The Committee feels that the action taken relating to Public Comment 472-172 (Log #206) makes this an appropriate competency at this level.

328

i

t

.' N F P A 472 A92 T C D

. 472-'171 - (3-2.$.2*): Rejea " " , • • "

• SUBMrI'I"ER: Hersheli Stafford, Exxon C~emical Americas

. (Log # 508) ; ' , #51 ose h askot, FMC Co ( ), . . rp. .Lo~, .

~ ' ~ e 4 ~ Lyden, The Ciilorme In,rotate ,inc. (Log ' 322), Samuel A. Pearman, Martinsville, VA (Log # 993), John M. Cobum, Occidental Chemical Corp. (Log # 1053), William A. Levy, Research Triangle Park, NC (Log # 648), Raymond P. Beaudw, Du Pont CO. (Log # 926), "

John T. Higgins, Dow Coming Corp. (Lo 8 # 419) COMMENTON PROPOSAL NO.: 472-I . ,

•, RECOMMENDATION: Delete sentence. SUBSTANTIATION: Beyond the scope o:f the responder at operational level. The information is too lechnical. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-170 (Log #725).

• 472- 176 - (3-2.3.3"):. Rejeci SUBMITrER: Hershell Stafford, Exxon Chemical Americas

• (Log#509), Co-- ~ #5 JosephJ.Jaskot, FMC v.t,. ,Log 2), Michael E. Lyden, The C'~lorine InStitute Inc. (Log # 323), Samuel A. Pearman, MartinsvilIe, VA (Log # 994), John M. Cobum, Occidental Chemical Corp. (Log # 1054), William A. Levy, Research Triangle Park, NC (Log # 549), Raymond P. Beaudry, Do Pont Co. (Log # 927), John T. Higgim, Dow Coming Corp. (Log # 420) COMMENTON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete sentence. SUBSTANTIATION: Beyond the scope of the responder at the

rational level. Too technical. ACTION: Reject.

COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-175 (Log #724).

• ' .. ( t ~ # 2 0 0 )

472- 172- (3-2.3.2): Accept in l~incip!e SUBMITYER: Gerald L Grey, Redwood ('by, CA COMMENT.ON P R O P O S A L NO.: 472-1

'1 RECOMMENDATION: Revise text to read: ' " " "

I "Identify three types of stress that could cause a containment system to release its contents.* SUBSTANTIATION: Do not fully understand importance for

• placing radiation and etiologic as types of stress that.could came a containment.system to release its contents. Ad& confusion to an area that is supposed to be eliminating cmffmion. COMMITrEEACTION: Acceptin Principle.

In addition change A-3-2.3.2 by deleting radiation and etiological. COMMITTEE STATEMENT: T h e Committee feels that the submitter's substantiation is appropriate.

(Log # 205) 472- i7S - (8-2.8.2): Reject S U B M I T ~ R : GeraldL Grey, Redwood Oty, CA COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: Recommend this section be deleted from the First Responder.Operational level, but moved to the Technician level. S ~ A N T I A T I O N : • Exceeds the definition of First Responder O~e~-aMMiTrEEtional as stated in 3-1.2.

ACTION: RejeCt. COMMrlWEE STATEMENT: See ConunJ~ttee Action and statement o n Public Co. mment 472-172 (Log #206)i

( L o g # 854) 472- 174- (3-2.8.2): Reject ; SUBMH'IT, R: Michael R. Rehfeld, Wesmdnster Fire Depu,.MD '

COMMENT O N P R O P O S A L NO.: 472-I RECOMMENDATION: Delete text:

-identify five types of slress that could cause a containment system to release its contents." . . . . SUBSTANTIATION: This does not fit into the categoryof Ftnt . Responder. It is a suitable statement for mmeone at the Technician level of Response. COMMITTEE ACTION: Reject. , : COMMI'IWEE STATEMENT: See CommJ~ttee Action and Statement on Pu. blic Comment 472-172 (Lo 8 #206).

• (Log # 724) 472- 175 - (3-2.3.3): Reject SUBMrI'rER: Paul R. Spurlin, WayneTcr~mship Irtre Dept., IN COMMENT O N P R O P O S A L NO.: 472-I RECOMMENDATION: Delete Section 3-2.3.3. SUBSTANTIATION: Above s~-ction is too advanced for the ~Mrational level.

Mr lTEE ACTION: Reject. COMMITTEE STATEMENT: The ComnnJttee does not feel that it is beyond the responder at the operational level to have an understanding that contain" ers will breach and g, merally how this can O C C U r .

(Log # 207) 472- 177- (3-2.3.3): Reject SUBMITIT.R: Gerald L. Grey, Redwood Oty, CA COMMENT O N P R O P O S A L NO.: 472-1 / RECOMMENDATION: Recommend this section be deleted from the First Responder Operational level, but moved to the Technician level. SUBSTANTIATION: Exceeds the definition of First Responder

raM~Fonal as stated in 3-1.2. ACTION: Reject.

COMMITTEE STATEMENT: See Committee Statement On Public Comment 472-175 (Log #724).

_ -, "(L~ # 85e) 472-178, (3-2.$.$): Reject SUBMITrER: Michael R. Rehfeld, Wesuninster Fire Dept., M D COMMENT O N P R O P O S A L NO.: 472-1

, RECOMMENDATION: Delete texu , • "Identify five ways in which containment system can breach."

SUBSTANTIATION: Once again ~ is a .excellent competency for " the Technician.

t COMMITrF.I~.AG'rlON: Reject . . " COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-175 (Log #724).

"(Log # 72s) 472- 179 - (8-2.5;4): Reject S U B ~ Paul R. Spurlin, Wayne Township Fire Dept., IN COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: Delete Section 8-2.3.4. SUBSTANTIATION: Above section is too advanced for the

rattonal level. MrlWEE ACTION: Reject.

COMMrIWEE b'TATEMENT: The Committee doe's not feel that it is beyond the scope of the operational level responde r to have a n understanding of how the contents of a container may be released becamte that may very well have implications as to the appropriate

• defensive measures that may need W be t2ken. , . ,.

(Log #'208) 472-180- (8-2.8.4); Reject SUBMrI'rER: Gerald I , Grey, Redwood Oty, CA COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: Recommend this section be dele~-d from the First Responder Operational level, but moved to the Technidan level. SUBSTANTIATION: Exceeds the definition of First Responder

Onal as stated in 3-1.2. . , " ACTION: Reject.

COMMrFrEE STATEMENT: See Comnduee Statement on Public Comment 472-179 (Log #723).

3 2 9

N F P A 4 7 2 - - A 9 2 T C D

472- 181 - (3-2.3.4*): Reject S U B ~ Hershell Stafford, Exxon Chemical Americaa (Log # 510), JosephJ.Jaskot, FMC corp. (Log # 53), Michael E. Lyden, The Chlorine Institute Inc. (Log # 324), Samuel A. Pearman, Martinsville, VA (Log # 995), John M. Cobum, Occidental Chemical Corp. (Log # 1055), W'dliam A. Levy, Research Triangle Park, NC (Log # 650), Raymond P. Beaudry, Du Pont Co. (Log # 928), John T. Higgins, Dow Coming Corp. (Log.# 421) COMMENTON PROPOSAL NO.: 472-I "' RECOMMENDATION: Delete sentence. SUBSTANTIATION: Beyond scope of the responder at the operational level. Too technical. COMMITTEE ACTION: Reject. COMMI'IWEE STATEMENT: bee Committee Statement on Public Comment 472-179 (Log #723).

(Log # 18~) 472-182 - (3-2.3.5): Accept in Principle ' SUBMrrrER: Michael E~ Boyle, Cafifornia Region I, Local Emergency Planning committee COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise paragraph toread:

"Identify and match the=sevetr dispersion patterns that can be created upon release of a baT"~rdous material with a descriptive n a m e . I.

(Delete lined out portion of text.) . SUBSTANTIATION: The First Responder Operational Level personnel must have a basic understanding of the dispersion patterns that may be created u~..n the release of a material however.

objective can be satisfied without this level of technical knowledge. COMMITrEEACTION: Accept in Prindple.

Change to %.. at least four dispersion.. Y ' Delete- %.. matcJa..." and " . . . with a descriptive name." Also add a new Appendix A-3-2.3.4 as follows: ~l'he following performance objectives should be taught in a

manner and language understandable to the audience. The intent is to convey the simple concepts that containers of har~rdous materials under sti~ss will open up allowing the contents to escape. This refers to both presmrized'and nonpresmwlzed containers. This content release will vary in type and s..~-ed. A pattern will be formed by the escaping product that will possibly ex~.~ people, environment, or property doing physical or medicarhar~ This overall concept is often referred to as a general behavior model and is used to estimate container behavior under emergency conditions." COMMrrTEE STATEMENT: The committee feels that the revised wording makes this a reasonable competency at this level.

(Log # 855) 472- 183- (3-2.3.5): Rejea SUBMITrER: Michael R. Rehfeld, Wemninster Fire Dept., MD COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete text:

"Identify and match the seven dispersion patterns that can be created upon release of h~s~-dous materials in an engulfed area." SUBSTANTIATION: This is far above the needed luiowiedge of the everyday Fire'Fighter. COMMITTEE ACTION: Reject. COMMrrrEE STATEMENT: See Committee Action and Statement on Public comment 472-182 (Log #183).

(Log # 2O9) 472- 184- (3-2.3.5): Rejed SUBMITrER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Recommend this section be deleted from the First Responder Operational level, but moved m the Technldan level. SUBSTANTIATION: Exceeds the definition ofHrst Responder Operational as stated in 3-1.2. O~MMiTrEEACTION: R e j e c t . . COMMrrrEE STATEMENT: See' Committee Action and Statement on Public Comment 472-182 (Lo 8 #183).

(Los # 7s7) 472- 185 ~ (3-2.$.5): Accept ,' S U B ~ Bruno Mark W'dson, Oregon State Fh-e Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Revise text:

"Identify the ~ general time f r a m e ~ . . " SUB,~ANTIATION~." Adding the at'tide "the" makes the objective " more definitive, and thus more easily measurable. We are looking for specific time frame references, not generic. COMMITTEE ACTION: Accept.

(Log # 721) 472- 186- (3-2.3.5): Reje_ ct SUBMITrER: Paul IZ-Spmtin, Wayne Township Fire Dept., IN COMMENT ON PROPOSAL NO.: 472-1 RFX~MMENDATION: Delete Section 3-2.32L SUBSTANTIATION: Above section is too advanced for the

rational level'. " ' MrlWEE ACTION: Reject. .

COMMrlWEIg STATEMENT: See Committee Action and Statement on Public Comment 472-182 (Log #!83).

472- 187 - (3-2.3.5*): Reject SUBMrrrER: HersheH Stafford, Exxon Chemical Americas (L°8#511)'j; - - : - ~ - m t #54 ose h . askot, P M~ t.,o~p, xLog ),

~'J~hPat~ E. M e n , The Clilorine Institute Inc. (Log # 325), Samuel A. Pearman, MartinJville, VA (Log # 996), John M. Cobum, Occiden~l Chemical Corp. (Log# 1056), William A. Levy, Research Triangle Park, NC (Log # 651), Raymond P. Beaudry, Du Pont Co. (Log # 929), John T. Higgins, Dow Coming Corp. (Log # 422) COMMENTON PROPOSAL NO.: 472-1- RECOMMENDATION: Delete sentence. SUBSTANTIATION: Beyond the scope of the responder at the

rational level. Too technical. • MrlWEE ACTION: Reject.

COMMITrE£ STATEMENT: See Committee Action and Statement on Public Comment 472-182 (Log #185).

(Los # 722) 472-188 - (3-2.3.6): Reject . SUBMrrrER: Paul R.-Spurlin, Wayne Township Fire Dept., IN COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete Section 3-2.3.6. SUBSTANTIATION: Above section is too advanced for the ~:~Mrational level.

MITrEE ACTION: Reject. . ' COMMrITEE STATEMENT: See Committee Statement on Public Comment 472-191 (Log #512).

(Log # 210) 472- 189- (3-2.3.6): Reject SUBMrrTER: Gerald L. Grey, Redwood Clty, CA COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Recommend this section be deleted from the First Responder Operational level, but moved m the Technician level. SUBSTANTIATION: Exceeds the definition of First l~sponder O~eMMiTrEErational as stated in 3-1.2.

ACTION: Reject. COMMITTEE STATEMENT: bee Committee Statement on Public Comment 472-191 (Log #512).

(Log # 101) 472- 190- (3-2.$.6): Accept in Principle 8 U B M r r r F ~ Kent 1h Ohon, Amertcan Assn. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RE~MMENDATION. Revise grammar. SUBSTANTIATION: , The paragraph doesn't make 8rammatic sense. I m not certain what im intent is/was. COMMITrEEACTION: Accept in Principle. COMMITTEE STATEMENT: ~ Public ~3omment 472-185 (Logtns~). I

N F P A 472 - - A92 T C D

\ •

472- 191 - (3.2.8.6*): Reject SUBMrI'rER: HershellStafford, Exxon Chemical Americas (Log # 512), • jo!ephjose, h .J;askot, PMC Corp. (.Log, # 55), . Michael F_. Lyden, The Chlorine Institute Inc. (Log # 826), Samuel A. Pearman, Manin~l le , VA (Lo 8 # 997); John ~L Cobum, Occidental Chemical Coorp. (_Log# 1057), Wdliam A. Levy, Research Triangle Park, NC (Log # 652), Raymond P. Beaudry, Du Pont Co. (Log.# 930), -. john T. ~gglm, ~ Coming Corp. (Log ~ 423) COMMENTON PROPOSALNO.: 472-f RECOMMENDATION: Delete sentence. SUBSTANTIATION: Beyond the scope of the responder at the- operational level. Too tedmiral. . CDMMITrEE ACTION: Reject. COMMITTEE STATEMENT:,,The Committee feels that it is imL)ortant.for responders at the operational level'to have an ' unaerstanding o f the general time frames n:lating to exposure.

(Log # I02) 472- 192 - (3.2.8.7.1): Accept in Principle SUBMITTER: Kent R. O l i n , American A~m. of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise to read:

~Idenfify the health h ~ r d s associated with the following tern~ (a) simple asphyxiant (b) chemical asphyxiant ' , (c) irritant . (d) corrosive (e) narcotic/depressant (t3 oxidizing agent I ~ sensitizer

convulsant (i) carcinosen

)) mumgen teratogen

SUBSTANTIATION: The current list is to<) short - it certainly isn't representative of the types of toxic effects one is likely to see. Also, note that this list should probably be in Section 2 also. COMMHTEEACTION: Accept in Principl¢.

Reword list as foilowa: (a) asphyxiant (b) Irritant/corrosive (c) sensitizer/allergen (d) convuisant (e)* chronic health ha,~rd Add A-3-2.3.7.1 (e) Chronic health hazards would include

carcinogens, mutagens, and teratogens. COMMrrrEE STATEMENT: The-Commi'ttee believes that the revised list is more appropriate at the openLfional level.

(I~ 8 # ~0) 472- 193- (3-2.8.7): Reject : ' r

SUBMrFrER: Paul R.-Spurlin, Wayne To~n~ ip Fire Dept., I1~ COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete Section 3-2.3.7.. '- SUBSTANTIATION: Above section is too advanced for the ~Mrational level.

MITrEE ACTION: Reject. COMMITTEE STATEMENT: See action taken on Public Comment 472-185 (Log #737). The Committee also believesthat this is an appropriate competency for the op~eratiomd level. For the opera- uonal]evel responaer to not know health and ph~aical b a ~ r ~ that may be present such a~, poisonous, corro~,e, radiation, etc., would not be very wise while conducting defensive control operations at a b~-~rdous materials incident.

472-194 - (3-2.8.7*): Reject - ' " " SUBMITrER: Hershell Stafford, Exxon Chemical Americas (X~g# 513), Joseph J.Jaskot, FMC Corp. (Lo 8 # 56), 'Michael E. Lyden, The Chlorine Institute Inc. (Log # 327), Samuel A. Penman, Martinsville, VA (Log.# 998), John M. Cobum, Occidental Chemical Corp. (Log# 1058), W'dliam A. Levy, Research Triangle Park, NC (Iog # 658), - Raymond P. Beaudry, Du Pont Co. (Log # 931), " " '

• John T. Higgins, Dow Coming Corp. (Log # 424) " COMMENTON PROPOSAL NO.: 472-f . : '

RECOMMENDATION: Delete. SUBSTANTIATION: BeYond scope of responder at operational level. Too technical.

COMMrITEE ACWION: Reject. ' COMMrXTEE STATEMENT: See Committee Statement on Pubfic Comment 472-198 (Log #720).

:

(Log# 211) 472-195 - (3-2.4): Reject SI.rBMITrKR: Gerald L. Grey, Redwood City, CA

. COMMENT ON PROIN3SAL NO.: 472-I RECOMMENDATION: Delete this entire section (3-2.4, 3-2.4.l , 3-2.4.2, 3-2.4.8, and 3-2.4.4) from the F'wst Responder.Operatlonal level and move it to the Incident Commander]evel. SUBSTANTIATION: Identifying resources to estimate the ~extent of h~r~rda is something incident commanders should be doing, not all operational respondersl " COMMITrEE ACTION: Reject. ' COMMITIV.E STATEMENT: The Committeebelieves that with the

• revisions that have been made to clarify this competency (See 472- 121 (Log #290) that it is definitely within the scope of an operatiOnal level/esponder. The responder who plans to take some action, even

• defensive action, mint have some idea of the potential harm that is ~. posed by the . ~ c u l a r hazardous materials incident that they are ,

confronted w~th. ' . • .

472- 196 - (3-2.4*): Rejea SUBMITIT~ Hershell Stafford, Exxon Chemical Americas (Log# 514), • " " . • JosephJ.Jaskot, FMC Corp. (Log # 57),. Michael E. Lyden, The ~dorine Institute Inc. (Log # 328), • Samuel A. Pearman, MartinsviHe, VA (Log # 999), " John M. Cobum, Occidental Chemical Corp. (Log # i059),

- W'dliam A. Levy, Research Triangle Park, NC (Log # 654), Raymond P. Beautify, Du pont Co. (Log # 932), John T. Higglns, Dow Coming Corp. (Log # 425) C O M M O N PROPOSAL N O - 472-i- RECOMMENDATION: Delete from this section. SUBSTANTIATION: This is beyond the scopeof the responder at the operational level and is part of the IMS structure. COMMrFFEE ACTION: Reject. . " COMMITrEE STATEMENT: See Committee Statement on Public Comment 472-195 (Log #21]).

<

472- 197- (3-2.4.1): -Accept in Principle . (Log # 738) SUBMrF1T~ Bruno Mark W'dson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472d

J RECOMMENDATION: Revise text: , , : ~ "Identify a method for determining the size.. ." . '

SUBSTANTIATION: DOT Emergency Response Gulde provides only general Earameters for describing spills ( ~ l l ~ v~ qarge'). To determine the size requires more complex calculations that l~rovide more definitive answers. :

J COMMITrEEACTION: Accept in Principle. .'. Change "source" to "resource:

COMMrITEE STATEMENT: The Committee agrees with the submitter and believes that hte change to resource will be dearer.

(Lo s # 212) 472- 198 - (3-2.4.1): Reject SUBMrrrER: Gerald L. Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-1" RECOMMENDATION: Delete this from the F'trst Resp0nder Operational level and move it to the Incident Commander level. SUBSTANTIATION: Identifying resources to estimate the extent of b2r~rCis is something incident commanders should be doing, not all operational respondersl ~ o " COMMFFFF~ ACTION: Reject. • , COMMITrF~ f f r A ~ : See C6mmiuee Statement on Public Comment 472-195 (Log #211).

3 3 1

N F P A 472 - - A92 T C D

472- 199 - (3-2.4.1"): Reject SUBMITTER: Hershell Stafford, Exxon Chemical Americas (Log#SIS), --~-- ~ #Ss

JosephJ.Jaskot, ~Mu uo w. ~Log ), Michael E. Lyden, The Chlorine Institute Inc. (Log # 329), Samuel A. Pearman, Martinsville, VA (Log # 1000), John M. Coburn, Occidental Chemical Corp. (Log# I060), William A. Levy, Research Triangle Park, NC (Log # 655), Raymond P. Beaudv/, Du Pont Co. (Log # 933),

J o h n T. Higgins, Dow Coming Corp. (Log # 426) COMMENTON PROPOSAL NO.: 472-1- RECOMMENDATION: Deletesentence. SUBSTANTIATION: Beyond the scope of the responder at the operational level and is part of the IMS structure. COMMrlWEE ACTION: Reject. COMMrITEE STATEMF2¢r: See Committee Statement on Public Comment 472-195 (Log #211).

/

472- 204 - (3-2.4.3): Reject . SUBMrrrER: Het~hell Stafford, Exxon Chemical Americas (Log#5]7), JmephJ.J~,kot, FMC Corp. (Log # 60), Michael F.. Lyden, The Chlorine Institute Inc. (Log # S31), Samuel A. Pearman, Martinsville, VA (Log # I002), John M. Cobum, Occidental Chemical Corp. (Log# I062), W'dliam A. Levy, Research Triangle Park, NC (Log # 657), Raymond P. Beau&y, Du pont Co. (I.,o 8 # 935), John T. Higgins, Dow Coming Corp..~Log # 428) COMMENTON PROPOSAL NO.: 472-1- RECOMMENDATION: Delete the sentence. SUBSTANTIATION: This is beyond the scope of the reaponder at the operational level and is part of the IMS structure. COMMITTEE ACTION: Reject. COMMrlWEE STATEMENT: See Committee Statement on Public Comment 472-195 (Log #211).

472- 200 - (3-2.4.2): Reject . (Log # 213) SUBMITrER: Gerald L. Grey, Redwood ~ty , 'cA COMMENT ON PROPOSAL NO.: 472oi RECOMMENDATION: Delete this from the First Responder Operational level and move it to the Incident Commander level SUBSTANTIATION: Identifying resources to estimate the extent of baT~rd~ is something incident commanders should be doing, not all operational respondersl COMMITTEE ACTION: Reject= COMMrrrEE STATEMENT: See Committee Statement on Public Comment 472-195 (Log #211).

(Los # 215) 472- 205 - (3-2.'4.4): Reject SUBMITrER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Delete this from the First Responder . Operational level and move it to the Incident Commander level, SUBSTANTIATION: Identifying resources to estimate the extent of ha,~rds is mmething incident commanders should be doing, not all operational respondersl COMMrlWEEACTION: Reject. ' . COMMrrrEE STATEMENT: See Committee Statement on Public . Comment 472-195 (Log #211).

(Log # 739)" 472- 201 - (3-2.4.2): Reject SUBMITrER: Bruno Mark W'flson, Oregon State lrLre Marshal COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text:

"...incident, identify the probable number and type of e x p o s u r e ~ k . . m

SUBSTANTIATION: An individual's abili~ to "estimate; cannot effectively be measured. COMMITTEE ACTION: Reject. - . COMM1TrEE STATEMENT: The Commiuee believes that there h no difference between =estimate" and "probable ~. For conshtency the term "estimate" will be utilized.

472- 202 - (3-2.4.2): Reject' SUBMITrER: Hershell Stafford, Exxon Chemical Americas (Log # 516),

JosephJ.jaskot, FMC Corp. (Log # 59), Michael F_. Lyden, The Chlorine Institute Inc. (Log # 330)° Samuel A. Pearman, ~ s v i l l e , VA (Log # 1001), John M. Coburn, Occidental Chemical Corp. (Log # 1061), W'dliam A. Levy; Research Triangle Park, NC (Log # 656), Raymond P. Beaudry, Du Pont Co. (Log # 934), john T. Higgins, Dow Coming Corp. (Log # 427) COMMENTON PROPOSAL NO.: 472-i- RECOMMENDATION: Delete the sentence. SUBSTANTIATION: This is beyond the scope of the responder at

level and is part of the IMS structure. COMMrIWEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-195 (Log #211).

• (Log# 214) 472- 203 - (3-2.4.3): Reject SUBMITrER: GeraldL Grey, Redwood'City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete this from the First Responder Operational level and move it to the Incident Commander level. SUBSTANTIATION: Identifying resources to estimate the extent of hazards is something incident commanders should be doing, not all operational respondersl . . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public .Comment 472-195 (Log #211).

(Log # 21e) 472-.206- (3-2.4.4): _Accept SUBMITrER: Gerald L Grey, R~-dwood City, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text.to read:

"Identify the factors for determining the. . .~ SUBSTANTIATION: As defined in the appendix, the items listed are not resources but factors. If the oonmuttee desires to keep the word resources in the text, then the appendix should list such resources as monitoring equipment, wind speed indicators, etc. . COMMn'IT.E ACTION: Acb~t.

472- 207 - (3-2.4.4*): Reject SUBMrrrER: Hershell Stafford, Exxon Chemical America~ (LOg# 518), #

JosephJ, Jaskot, FMC Corp. (Log 61), MichaelF_. Lyden, The Chlorine Institute Inc. (Log # 332), Samuel A, Pearman, Martinsville, VA (Log # 1005), John M. Colmrn, Occidental Chemical Corp. (Log# 1063), W'flliam A. Levy, Research Triangle Park, NC (Log # 658), Raymond P. Beaudry, Du Pont Co. (Log # 936) , John T. I-Iigglns, Dow Coming Corp. (Log # 429) COMMENTON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the sentence. Sui~rANTIATION: This is beyond the scope of the responder at the operational level and is part of the IMS structure. COMMrlWEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Pubfic Comment 472-195 (Log #211).

472-208-(3-3.1): Accept . , (Log # 217) SUBMITrER: Gerald L. Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-1 REODMMENI~TION: Revise text to read: .

' ~e~- ibe theresponse objectives for hazardous materials Incidents. The first responderat the operational level shall, given simulated . facility and transportation har~rdotm materials problems, describe the first responder's response objectives for eachproblem." SUBSTANTIATION: Oariflcation of intent. -Th~ ~0difion of'~urst responder's" clarifies the committee's intent of not having a first responder describing activities that are beyond his/her scope. (X)MMITI'EE ACTI-ON: Accept.

3 3 2

472- 209- (555.1): Reject " ~SUBM1TrER: HersheH Stafford, Exxon Chemical Americas (Log#s]9),- ' , , . . '

JosephJ.Jaskot, FMC Corp. (Log # 62),

M i n i F _ . Lyden, The Chlorine Institute Inc. (Log # 838), ~ m u e l A. Pearman, MartinsviIIe, VA (Log # 1004), John M. Coburn, 'Occidental Chemical Corp. (Log # 1064), W'flliam A. Levy, Research Triangle Park, NC (Log # 659), Raymond P. Beandry, Du Pont Co. (Log # 937), John T. Higgins, Dow Coming Corp. (Log # 430) COMMENTON PROPOSAL NO.: 472-1- RECOMMENDATION: Revise first sentence to read:

"Determine the defensive response obj~cOres for hazardous materials inddenm ..--t.. ~ - - - -

Revise the second sentence to read: " "l 'he first responder at the operational level shall, given simulated

facility and transportation h~7~rdous materialproblems, determine the defensive response objectives for each p rob lem." " SUBSTANTIATION: With these changes, will be in agreement with definition of a responder at the operational level. ' C O - - A C T I O N : Reject. i.. COMMITTEE STATEMENT: The action u~ken on Public Comment 472-208 (Log #217) clarifies the i n t en to f the competency and the Committee feels will accomplish the submirters' intent.

N F P A 472 - - - #,92 T C D

(Los # 218) - _ 472- 210- (555.1.1): Accept SUBMITrER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 .

RECOMMENDATION: Revise text to read: "Identify the steps for determining the nfi |nber ofe~ >osures that

could be saved by the first responder with the resources provided by the anthority have jurisdiction and operating in a defensme fashion, ~iven an analysis o f a h2,-.,rdous materials woblem and the

• e~xposures already lost." ' " . " - SUBSTANTIATION: ClarHtcation of intent. This addition clarifies the commiuee's intent of not having a first responder describing activities that are beyond h i s /her scope and. capabilities. COMMITTEE ACTION: Accept , .

472- 211 - (553,1.1): Reject " , . SUBMITFER: Hershell Stafford, Exxon Chemical Americas (Log # 520),

~oh.sec~3he~.Jaskot, FMC Corp. (Log # 6s), . •

E. Lyden, The Chlorine Institute Inc. (Log # 534), Samuel A. Pearman, Martinsville, VA (Lo 8 # 1005), John M. Coburn, Occidental Chemical Corp. (Log # I065),

, W'dliamA. LesT,.Research Triangle Park, NC (Log # 650), • Ra]anond P. Beaudry, Du Pont Co. ( L ~ # 938),

John T. Higglns, Dow Coming Corp. (Log # 431) COMMENTON PROPOSM, NO.: 472-1- RECOMMENDATION: Delete sentence. SUBSTANTIATION: Identical to 5-3.1.1 ~ad l~longs in that section since it is part of IMS structure. COMMITTEE ACTION: Reject. COMMrlTEE STATEMENT: The Committee Action on Pubiic Comment 472-210 (Lo B #218)darif ies 553.1.1 and dearly establishes that the intent at this level is for.the fws. t responder t0 have an . understanding of this process.

J

(Log #.740) 472- 212 - (553.1.2): Reject SUBM]TrER: Bruno Mark Wilson, Oregon State Fh-e

• COMMENT ON PROPOSAL NO.: 472-] •. RECOMMENDATION: Revise text:

"Identify the steps for d e t e r m i n i n g . . . " SUBSTANTIATION: An individual's abifity m~'describe" cannot effectively be measured. COMMITTEE ACTION: Reject. COMMrlWEE STATEMENT: The Committee believes that the term "desczibe" is appropriate and the penmn's ability to describe can be measured. The term "describe" as it is defined in 1-2 means to'explain verbally or in writing using stanclard terms recognized in the h ~ r d o u s materials response conununlty. There are many ways to effectively measure a person's ability to (~plain verbally or in writing.

472-215- (555.1.2): Acceptin Pa~ ' . (L°8#219) SUBMITIT.R: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 .

RECOMMENDATION: Revise text'to read: . ' • "i)escribe the steps for determinlng (defensive, non-httervention)

response objectives given an analysis of a b a i r d # u s materials incident." . , ' SUBSTANTIATION:. C~m'iflcation of intent.

The addition of "(defensive non-intervention)" darifies the committee's in t en t of not having a first responder describing activities that are beyond h i s /her scope. , , COMMI'rrElgACTION: Accept in Part.

Delete the term ~nondmterventiOn'. ~" COMMrrrEE STATEMENT: The Committee believes that the term non-intervention is not appropriate at the operafi6nal leve l since defensive actions'do involve intervention to some d¢sree. ,.

472- 214 - (55&1.2): Rejea " " " S U B M I T r E ~ Hershell Stafford, Exxon Chemical Americas (Log.# 521), ~ josephJ.J~kot, FMC Corp. (Log # 64), " Michael F.. Lyden, The Chlorine Instimm Inc. (Log # 535), Samuel A. Pearman, Martinsville, VA (Log # 1006),

J o h n M. Coburn, Occidental Chemical Corp. (Log# I066), W'dliam A. Levy, Research Triangle Park, NC (Log # 661), Raymond P. Beauchy; Du Pont Co. (Log # 939), • • John T: Higgins, Dow Coming Corp. (Log # 432) COMMENTON PROPOSAL NO.: 472-I , . RECOMMENDATION: Delete sentence. SUBSTANTIATION: Identical to 5-3.1.2 and belonsl in that section since it is pan of the IMS structure. C O ~ ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-213 (Log #219).

(Log # s49) 472- 215- (553.2): .Ac~ . t ' ' SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1

• RECOMMENDATION: Revise 3-3.2 to mad: '~Describe the defensive options available for each response

objective. The first msponder at the operafion--o'n'~Tevel ~3alI, given simulated facility and transportation hazardous material problems, identify the defensive options for each response objective identi- fled." SUBSTANTIATION: Clarify the intent of the competency statement. C O M M r r r E E ACTION: Accept.

479- 216 - (553.2): Accept in Principle . • SUBMrI'I 'F.~ Hershell Stafford, Exxon Chemical Americas ( L o g # S 2 2 ) , ,. _ _ # . ~ , -

JosephJ.Jaskot, FMC Co~p. t t ~ 8 , ,~ , Michael F_. Lyden, The Clilorine Institute Inc. (Log # $56), Samuel A. Pearman,Martinsville, VA (Log # 1007), John M. Cobum, Occidental Chemical Corp. (Log# 1067), W'dliam A. Levy, Research Triangle Park, NC (Log # 662), RaymondP. Beaudry, Du Pont Co. (Log # 940),

John T. Higgins, Dow Coming Corp..(Log # 433) . COMMENTON PROPOSAL NO.: 472-I RECOMMENDATION: Revise first sentence to read:

'~e te rmine the defensive options available for each response

line of second sentence to read: " . . . ident~] the defensive options for each response objective."

SUBSTANTIATION:, For clarity. Present l a n g u a ~ is confusing. COMMITrEE ACTION: Accept in Principle. , ; COMMITTEE S T A ~ : See Committee Action on Public Comment 472-215 (Log #849). The Committee believes that this clarifies the competency.

t

• o q

(Log # 741) , 472- 217- (3-3.2.2): Accept S U B ~ Bruno Mark W'dson, O r ~ n State FLee Marshal

• COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Revise text:

"Identify the purpose for, and the procedures, equipment, and ~.. ety precautions used with, each of the following control techniques:...= SUBSTANTIATION: Eliminates the problem of having two separate tasks in a single objective. Alternative solution would be to m ~ e two separate objectives, one for "purpose" and the other for ~procedures, equipment, and safety precautions'. • COMMrlTEE ACTION: Accept-

(Log # s41) 472-218- (3-5.5): Accept in Part SU]~l~tfl-l'Y,,l~ Richard G. Lusk, GalnesviHe Fire Rescue, FL COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete sections 3-5.5.1.2 and 8-5.5.$.1.5 SUBSTANTIATION: The competency of 8-5.3.1.2 should be a requirement for professional and volunteer firefighters and should be addressed in the relevant standard such as NFPA 1001.

I COMMrrrEEACTION: Aceeptin Part. Delete Section 3-5.5.1.3.

COMMITYEE STATEMENT: The Committee agrees with the deletion of 3-5.8.1.5 based on the substantiation for PubHic Comment 472-220 (Log #528) that the nmtertal does not aid responders. The Committee believes that the competency contained in 3-3.5.1.2 is appropriate. It must be keprin mind that this standard is not restricted to fire fighters. If fire fighters have met this

• competency based on their training in relation to NFPA 1001 that certainly does not present any problem.

(t~#71~3 472- 219 - (3-5.3.1.3): Accept SUBMrrYER: Paul R. Spurlin, Wayne Township Fire Dept., IN COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text:

"29 CFR 1910.158 should be 29 CFR 1910.134 ~. / SUBSTANTIATION: 29 CFR 1910.1M is the Respiratory Protection Standard. COMMITTEE ACTION: Accept.

472- 220 - (3-5.8.1.3): Accept SUBMITTER: Hershell Stafford, Exxon Chemical Aniericas (Log # 525), JosephJ.Jaskot, FMC Corp. (Log # 66), Michael IL Lyden, The Chlorine Institute Inc. (Lo 8 # 357), Samuel A. Pearman, Martinsville, VA (Log # 1008), John M. Coburn, Occidental Chemical Corp. (Log# 1068), Wdliam A. Levy, Research Triangle Park, NC (Log # 668), Raymond P. Beautify, Du Pont Co. (Log # 941), John T. Higgins, Dow Coming Corp, (Log # 484) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete sentence. SUBSTANTIATION: Information is irrelevant. This information does not aid responders. COMMITTEE ACTION: Accept-

(Log # 742) 472- 221 - (3-3.3.1.2): Reject SUBMrlWER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472~ RECOMMENDATION: Delete "and limitations of", SUBSTANTIATION: Moved to new recommended objective, identical to existing NFPA 472:2-3.9.4 COMMITr I~ ACTION: Reject. " COMMITTEE STATEMENT: The Committee believes that it is important for responders to understand the limitations and that this is an appropriate place for that competency.


472- 222- (3-5.5.2): Reject SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change the word "equipment" to "cloth- i n _ ~ m o •

SUBSTANTIATION: CLarify the intent of the competency and to differentiate 3-8.8.2 from 3-$.3.1. COMMrFrEE ACTION: Reject. COMMrrrEE STATEMENT: The Committee believes that the term "equipment = is the appropriate term.

(Los # aS0)

(Log # 74S) 472-228 - (8-8.8,2.2): Accept SUBMrI-I'ER: Bruno Mark W'dson, Ckegon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Revise text:

qdentify the purpose, advantages, and limitations of the following levels of protective dothing used at b~r~rdous materials incidents:

(a) structural firefighting dothing (b) high-temperature clothing (c) chemical protective clothing 1. liquid splash protective dothin 8 " 2. vapor protective dothing."

SUBSTANTIATION: Task elements reordered from general to c, and subcategories grouped 17/ha~cl.

ACTION: Accept.

(Log# 74e) 1

472- 224 - (3-8.4): Accept in Prindple SUBMITrER: Bruno Mark W'dson, Oregon State F'we Marshal COMMENT ON PROPOSAL NO:: 472-1 RECOMMENDATION: None, SUBSTANTIATION: "Emergency" decontamination is used in 3-8.4, 3-3.4.2, 3-3.4.3, 5-4.1.3 and 3-4.1.4, but is nowhere defined. Is this different from "field ~ decontamination as currently taught in intemationaily marketed training courses? I f m, addiuonal objectives should be written to cover this concept; if not, then we reconunend using "field" instead of "emergency" throughout this document. COMMITTEE ACTION: Accept in Prindple.

See the definition for Emergency Decontamination Public Comment 472-55

~ STATEMENT: See Committee Statement on Public Comment 472-~k5 (Log #197).

472- 225- (3-3.4): Accept" (Log # i39) S UBMITrER: Kent R. Olson, American Assn. of Poison Control Centers ° C O M M E N T O N PROPOSAL NO.: 472-1 RECOMMENDATION: Add (between 8-3.4.1 and 3-3.4.2):

"Deso'ibe how the potential forsecondary contamination deter-' mines the need for emergency decontamination procedures." SUBSTANTIATION: Tlds important concept should be included in the standard. If the victim is not contaminated (i.e., was exposed to a gas) then they do not pose a risk to others and the only reason to perform decontamination pro c.edures would be ffthe victim is experiencing eye or skin irritation. COMMI'IWF~ ACTION: Accept. " •

/

(Log # 10s) 472- 226 - (8-8.4.1.4): Accept in Principle SUBMrrlqER: Kent IL Olmn, American A~m. of Polson Control Centers C O M M E N T O N PROPOSAL NO.: 472-1 REX~MMFJqllATION: Add text: "(a) victims (b) re .sl~nse personnel (c) eqmpment ' and describe how materials used in decontamination may differ for

each." S~ANTIATION: Neutralization and chemical de~tion are examples of decontamination techniques that may be used on equipment but not on people.

t .'

N F P A 4 7 2 -- A92 TCD

COMMITrEEACTION: Accept in Principle. Reword the current 3-$.4.3 as follows. ~ ~ldenfify°the advantages and limitations of emergency decontan~

nation procedures." COMMITrgg STATEMENT: The Committee beiieves that the above change makes the competency dearer and meets the Committee's intent for the responder to have an understanding of emergency decontamination.

\

(Log # 747) "472- 227 - (3-4.1(fl~): Reject - ' SUBMrrrER: Bruno Mark W'dson, Oregon State Fire COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Change "control ~nes" to "perimeters" here and in 3-4.1.1 and 3-4.1.1.1. SUBSTANTIATION: The creation of zones is a latent function of establishing perimeter~ The focus should be on the more definitive concept of perimeters, since "zones" are merely the spaces betweeh~ them and, by definition, do not exist unless and until perimeters have b~een established. • COMMITTEE ACTION: Reject. C O M ~ STATEMENT: The Committee believes that the establishment of zones does establish perir~ters and for consistency the term "control zones" will be utilized..

(Log#S0) 472- 228 - (3-4.2): Accept ' SUBMrrI'ER: J im Litevich, NH Haz-Mat Curriculum Development Committee COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Add appendix note to this Section:

~'hose jurisdictions which have not developed an emergency response plan should refer to the document NRT-I, I-h~Ious Materials Emergency Planning Guide, developed by the National - Response Team."

"The National I%esponse Team, composed of 14 Federal agencies having major responsibilities in environmental, transportation, emergency management, worker safety, and public health areas, is the national body responsible for coordinating Federal planning, vreparedness, and response actions related to oil discharges and [~cfous substance releases. Under the Superfund Amendm6n~ -' and Reauthorization Act of 1986, the NRT is responsible for " publishing guidance documents for the pn:paration and implementation of haT"~rdous subetance. . eme. rg.ency_Dlana." SUBSTANTIATION: Jurisdictions without an emergency response plan should be encouraged to develop a local plan. The NRT-1 document provides guidelines for the development for/inch a plan. COMMrIWE~ ACTION: Accept.

(Log # 220) 472- 229- (~,-4.2.2): ' Accept ' SUBMrrrER: Gerald L Grey, Redwood City, CA ' COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to reaxl:

~Identify the levels of hazardous materiah incidenta as defined in the local emergency response plan." SUBSTANTIATION: Clarification of what leveis to.identify. C O M ~ ACTION: Accept.

(Log # 120) 472- 230 - (3-4.2.2): Accept in Principle SUBMITrER: Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-I' RECOMMENDATION: Add clarification ~co THE levels of b ~ , d - ous material; e.ll.: . -

5-4.2.2 Identify the levels of b=~=rdous material incidents as defined in (the local emergency response plan--or wherever). SUBSTANTIATION: I am not aware of universally accepted !evels of hazmat incidents; if so, clarify.. COMMrlTEEACTION: Accept in Principle. COMMITrEE STATEMF2Cr: See Committee Action on Public Comment 47~-229 (Log #220).

|

472- 231- (b.4.Z2): Reject ~ SUBMrrTER: Hershell Stafford, Exxon Chemical Americas (Log # 824), - ~ - - , # 6 JosephJ.Jaakot, FM¢; t~o,t,. ,Log 7), , .Michael F_. Lyden, The Odorine Institute Inc. (Log #, 338), Samuel A. Pearman, MartinsviUe, VA (Log # I009), ' John M. Cobum, Occidental Chemical Corp. (Log# 1069), W'dliam A. Levy, Research Triangle Park, NC (Log # 664), Raymond P. BeauchT, Du Pont Co.' (Log # 942), John T. I-Iiggins, Dow Coming Corp. (Log # 435) COMMENTON PROPOSAL NO.: 472-I " RECOMMENDATION: Add words "as listed in NFPA 471 ~ at the end of the sentence. ' SUBSTANTIATION: For clarity. COMMrITEE ACTION: Reject. i COMMrrrEE STATEME~I': See Commiuee Acti9n on Public Comment 472-229 (Log #220).

(Log # 748) 472-292- (3-4.2.4): Accept in Part - ' SUBMFIWER: Bruno Nlzrk Wilson, Oregon State F'we Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change ~steps" to "consider~ations"0r "criteria".

• SUBSTANTIATION: The use of the word "steps" implies a sequential order which, in this case, ain't necessarily so . . .

I COMMITrEEACTION: Acceptin Part. , , [ Accept the term "considerations'. .

COMMrlWEE STATEMENT: The Committee agrees the term considerations is appropriate. L

472- 233- (5-4.2.6): Accept in Principle . . (Log# 182) SuBMrrrEJ~ Michael F. Boyle, t'lallfornia Region I, Local Emergency Planning Committee COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add underlined portion: " ~ " "Identify the need and i~sponsibilities of the Safety Officer".

SUBSTANTIATION: Personnel at the First Responder Operational Level should understand the responsibilities of the Safety Officer however, they should alu) understand,the need for the Incident Commander to designate an individual responsible for 'this function as identified in 29 CFR 1910.120 (q) (3) (vii). COMMITTEE ACTION: Accept in Principle. Add the following Appendix A-3-4.2.6: A-3-4.2.0 The ba~rdous material safety Qfficer should meet all the

competencies for the First Responder at the Operational Level found in Chapter 3 of NTPA 472. A hazardous material safety officer is an individual who coordinates

safety operations within the hot and warm zones. A haT~rdoua material safety officer must be designated specifically at all hazardous material incidents (29 CFR 1910.120). The b ~ l o u s material safety officer has 'the following responsibilities.

(a) obtains a briefing from file incident commander or incident . safety officer and the fiazard sector officer, ,

(b) pa~._ ".ciL~ates In the preparation of and mot~itors the iml~lemen- tation of the incident safety plan, includir/g medical monitoring of entry team personnel before and after entry;,

(c) advises the inciden~ commander/sector 6fficef of deviations from the incident safety plan and of any dangerous iituations, and; "

(d) alters, suspends, or terminates any acti~ty that may be judged' to be unsafe. " , ', ~ . COMMITTEE STATEMF2q'r: The Committee believes that if the responder understands the.responsibilities of the safety officer they would also understand the need for a safety officer..However, the Committee feelsthat the appendix material will help d m'ify the role of the baTardous material safety officer.

472- 234 - (3-4.3): Reject (Log # 839) SUBMITrER: Richard G. Lusk, Gainesville F'we Rescue, FL COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete sections 3-4.3.6 through 3-4.3.9. SUBSTANTIATION: These competencies should ~dready be met by those meeting minimum r~]uirements for professiohal or volunteer firefightera. They should be addressed by NFPA 1001, Standard for Firefighters Professional Qualifications. COMMITTEE ACTION: Reject.

N T P A 4 7 2 - - A92 TCD

COMMITTEE STATEMENT: see Committee Statement on Public Comment 472-101 (Log #842).

(Log # s4o) ,472- 23,5 - (S-4.3): Rejea SUBMrl'TER= Richard G. Link, Gainesville F'we Rescue, FL COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Relocate sections 5-4.3.] through 5-4.5.5 to section 3-5.5. SUBSTANTIATION: These competencies are out of context with the intent of section b4.3 and are more appropriately addressed under 3-3.5, addressing safe execution of ahazardous material plan of action. COMMITTEE ACTION: Reject. C O ~ STATEMENT: This is consistent with the goal established in ~b4.S.

472- ~ - (b4.4.5): Reject SUBMnWEg: Hershell Stafford;Exxon ChemicalAmericaa (Log # 525), - - - - - , # 0 s " ose h . askot, FMC uo . ~Log ),

~ ' ~ e ~ ~ Lyden, The ~ o r i n e Institute Inc.. ,Log # 339), Samuel A. Pearman, Martinsville, VA (Log # 1010), John M. Cobum, Occidental Chemical Corp. (Log# 1070), William A. Levy, Research Triangle Park, NC ( log # 665), Raymond P. Beaudry, Du Pont CO. (Log # 943), John T. Higglns, Dow Coming Corp. (Log # 436) C O ~ O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete sentence. SUBSTANTIATION: Beyond the scope of this level. Move to technician level. COMI~TrI~.Ig ACTION: Reject. COMMrrrEE STATEblENT: The Committee believes that this is an important concePt and ne6ds to be understood at this level.

(Log#a] ) 472- 236 - (S-4.$.5): Accept SUBMrFrER: Gerald L. Grey, Redwood Oty, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text m read:

"Identify the physical capabilities required for and the limitations of personnel Working in the personal protective equipment as

rovided by the authority hahn. l~jurisdiction-" ~JBSTaeaAN~ON: Ch~ificauon, as some may perceive this as

• defining the limitations of personnel working in all levels of permnal protective equipment which would not be appropriate af this level COMMITTEE ACTION: Accept. •

(Log # 749) 472 ~ 7 (~442): ~ject SUBMITrER: Bruno Mark W'flson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Change "describe" to "demonstrate ~. SUBSTANTIATION: Good defensive control skills are too inlportant to the overall operation to be let~ at the cognitive level. Operational personnel should demonstrate competency in these areas. In any case, "describe" is not an activity that can be measured. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This standard establishes minimums and therefore if someone feels that it is necessary to have these skills demonstrated that is certainly appropriate. The Committee felt that if persons were able to describe these procedures that it would be an effective determination of their abilities.

(Log # 750) 472- 238- (3-4.4.3): Accept in Principle SUBMrlWE~ Bruno Mark W'flson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read:

.identify the location and use of the mechanical, hydraulic, and air emergency remote shutoff devices as found on a MC-S06/DOT 4-6 and MC-331 f . - SUBSTANTIATION: The word "describe" should be avoided in writing objectives, as it is nearly imposaiHe to measure. Elimination of the condition, "Given. . . " obviates the inexplicable necessity to provide actual cargo vehicles for a simple cognitive skill teat that can be performed using pen and paper. COMMrlWEE ACTION: Accept in Prindple.

I Reword as follows: "...MC.S06/DOT406 and MC-331 Cargo Tanks."

C O ~ STATEbIENT:. The Committee agrbes with the submitter and feels the addition clarifies the statement.

(Log# 751) 472- 240- (~4.4.4): Reject ~ " SuBMrIWER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON'PROPOSAL NO.: 472-1 RECOMMENDATION: Change ~Describe" to .identify ". . , SUBSTANTIATION: "Describe" is not an activity that can be measured. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472.212 (Log #740).

472- 241 - (5-5.1.I): Rejea SUBMrrrER: Hersheli Stafford, Exxon Chemical Americas (Log # 526),

j o ~ p h j . j a ~ o t , ~ c Corp. (Los # 69), ,Michael E. Lyden, The Chlorine Institute Inc. (Log # 540), Samuel A. Pearman, Martinsville, VA (Log # 101 I), John M. Coburn, Occidental Chemical Corp. (Log # I071), W'flliam A. Levy, Research Triangle Park, NC (Log # 666), Raymond P. Beaudry, Du Pont Co. (Log # 944), john T. Higgins, Dow Coming Corp. (Log # 437) COMMENTON PROPOSAL NO.: 472-1 RECOMMENDATION: Rewrite sentence to read:

"Evaluate whether defensive options are effective in accompfishing objectives: SUBbWANTIATION: Rewritten for clarity. COMMITrE£ ACTION: Reject. COMMITYEE STATEMENT: The c o u n t y at this level asks for the responder to be able to identify how they would determine t i the actions undertaken are being effective. The submiuer's proposal asks that they determine whether specific actions are being effective. That would be difficult to effectively measure without extensive simulation.

(Log # 752) 472- 242 - (S-5.1.1): Accept in Part " SUBMITTER: Bruno Mark W'dson, Oregon State Irn-e Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change "steps" to "considerations" or "criteria'. SUBSTANTIATION: The use of the word "steps" implies a sequential order which may not be the case. COMMrIWEE ACTION: Accept in Part. Accept "considerations ~.

COMMIITEE STATEMENT: The Committee agrees with the term P "considerations'.

3 3 6

472- 245 ~ (3-5.1.25: A~.ept " . SUBMITTER: HersheH Stafford, Exxon Chemical An~ricaa

Lyden, The Chlorine Insfimm Inc. (Log #,$41), : Samuel A. Pearman, ~ s v i l l e , VA (Log# 10125, John M. Coburn, Occidental Chemical Co~D. (Log# I 0 ~ ) , William A. Levy, Research Triangle Park, NC (Log # 667), Raymond P. Beauchy, Du Pont Co. (Log # e45), John T. Higgins, I)ow Coming Corp. (Lo 8 # 4~8) COMMENTON PROPOSAl: NO.: 472-I

} RELX)MMENDATION: Rewrite sentence to read: .i3escribe the drcumstances when it wouhl be prudent to pull back

from a hazardousmaterial inddent ." , SUBSTANTIATION: Rewritten for clarity. COMMrIWEE ACTION: Accept.

(Log # 7ss). 472- 244 - (3-5.~1): Accept in Prindple SUBMrrrER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-~1 RECOMMENDATION: Perhaps "demonstrate the ability to communicate the statu&.." . . . SUBSTANTIATION: This psychomotor skill o~eclive is weal~ How. do we quantitatively measure the individual's ability to "communb . care" something? • _

I COMMITYEEACTION: Accept in Principle. ] Reword as follows: ". [ "Identify the methods for communicating the status of the planned I response to the incident commander through the normal chain of I ' conumnd." -

COMMITYEE STATEMENT: The Committee believes that this further clarifies the competency.

• (Log # ' ~ 4 ) 472- 245 - (3-5.2.2):" Accept . SUBMrrrER: Bruno Mark.Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.:.472-1 . ' ' RECOMMENDATION: Should read: the m e t hocb . . . " .identify SUBSTANTIATION: The word "describe" should be avoided in writing ol~ectives, aa it is nearly impossibie to measure. C0MMITI'EE ACTION: Accept. ' •

(Log # 1S95 472- 246 - (Oaapter 4): Reject S U B ~ Michael F_.Boyle, Califomht Region I, Local

n ) e ~ P o l a n n i n g Committee N P R O P O S A L N O . : 472-1

RECOMMENDATION: Delete and re-write Chapter Four to establiah a H ~ r d o m Materiab Technician l_eve[ and a Hazardous Materials Specialist Level. • " SUBSTANTIATION: The standards publi:thed by the National Fire Protection Association should meet the n~- '~ of emergency . response agendes th roughou t the country. The previous s t anda rd which identified both the Hazardous Materials Technician Level and the I4~,~rdous Materials Specialist Level w ~ better prepared to meet

• the response n e e & of the agendes. Even though the lines of demarcation which separated the Technician Level from the Specialist Level were not always dear to some, many agencies, and in some cases entire states, identified dea r lines of competency and responsibility for each of these levels.

For many response agencies, the previous Technician Level is re c0gnized as the first]evel of responder who initiates an offensive action towards, a spill orxeleate. The Technician is a responder caj)abie of at least Level B entry, but no necessarily Irain~i for more amance midge'lion techniques. ' The Specialist Level is the re- sDonder with the highest level of response capability. The Specialist po .e~faes a higher level of training, and the ability to utilize more ~ophhticated ~tnd technical equipment.

Many response agencies have selected m i,dentJfy this type of distinct demarcation between the Technician Level and the Specialist leveL For some this selection w~s based on their local response needs however, for some agencies, this fact is based on f inandal limitations. ..

The demand for the four previous levels of competency have been recognized and supported throughout the country. T h e NFPA Technical Committee should recognize the need for continue these levels and re-write the proposed chapter to identify the Hazardous Materials Technician Level and the Hazardous Materials Specialist Level. -' . ~ ' .

/ .

N F P A 472 ~ A92 T C D -7

• COMMITTEE ACTION: Reject. COMMrFrEE STATEMENT: During the process of developing the

" Techincal Committee Report for NFPA 4 7 i t h e Committee discussed the iuue of technician/specialist- A task group was established to evaluate the issue: The task group conducted a task analysis relating to the umks Involved In responding to a hazardmm materiala incident- It became appa:rent to the task group tha t i t was.

.very difiicuh to differentiate the tadm between the ~'eclmiidan level and ' the specialist level. It became apparent that the divisions that had been established pre~ou/ly did not really translate i n t o ' definable tasks and therefore did not justify the development of teparate competencies. The proposed technician level e n c o m p a e ~ mint of the ~ i l b that had been previously included in the specialist .' section. It was felt by the commtttee that became of the lack of definable skills at the specialist level the establishment of only a technician level was justified.

(Log # S6) 472- 247- (4-1.2): Reject SUBMITIT.~ Richaid S. Kraus, Mobil Oil Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add to last sentence: /

%..conlxol equipment, if required dependent u p o n the materials handled or stored or transported." SUBSTANTIATION: There is no need to use specialized chemical protective clothing when responding to many h~-2rdous materials incidents (fuel oil, for instance). ' . . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-13 (Log #82). "

3 3 7

472- 248 - (4-1.3(a) 1): Accept in Part - S U B M I T r F ~ Manuel H. Ehrlich,Jr., BASF Corp. (Log# 140), Michael E. Lyden, The Chlorine Institute; Inc. (Log # M2),

{~ hn T. Higgins, Dow Coming Corp. (Lo~ # 4395, enshelI-Stafford, Exxon Chemical Americas (Log #,5295,

ce A. Stratis, Philadelphia, PA (Log # 558), liam A. Levy, Research Triangle Park, NC (Log #668) ,

Raymond P. Beautify, l)u Pont Co. (Log # 881), Samuel A. Pearman, Martinsville, VA (Log # 946), John M. Cohum, Occidental Chemical Corp. (Log # 1073) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete words "containment systems" and euP~l~ANTiATIWith words "container/packaging' .

O N : Cxmtainment systems is new and undefined. Container/packaging is specifically defined in 472-1989 edition and follows the accepted DOT definition. COMMrrYEE ACTION: Accept in Part. C O M M r r r E E STATEM~2qT: See Action and Statement on Public. Comment 472-114 (Log #909).

472-249- (4-1.3(a5 1): Accept in Principle S U B M I T r E ~ Manuel H. Ehrlich,Jr. BASF Corp. (Log # 141),~ Michael E. Lyden, The Chlorine Institute, Inc. (Log # ~,435, J ~ h n T. Higglns, Dow Coming Corp. (Log # 440),

enhel l Stafford, Exxon Chemical Americas (Log #.5~0), J~il~e A~ Stratis, Philadelphia, PA (Lo R # 559),

iam A. Levy, Research Triangle Park, NC (Log # 669) Raymond P. Beaudry, IM, Pont Co. (Log # 882), ~. Samuel A. Pearman, Matlinsvilie, VA (Log # 947), John M. Coburn, Occidental Chemical Corp. (Log# 10745_ COMMENT ON PROPOSAL NO.: 472-1 ~ ' RECOMMENDATION:. Replace -"to verify the identity of hazardous materials, and to determine concentrations of h ~ r d o u s materialsº with "to verify...materlah by use of field survey instruments/ monitoring equipment." SUBSTANTIATION: Clarifies expectation and develops consistency with balance of standards. COMMrlWEE ACTION: Accept in Prindple. , '

Revmrd to read as follows: " ro verify .... the pretence and concentrations of hamious

materials through the me of monitoring equipmenL" COMMI' r rEE b'TATEMENT: The Committee believes that hte above wording meets the intent of the mbmitter.

t

\

N F P A 472 - - A92 T C D

472- 250- (4-1.5(a) 5): Reject SUBMITI'ER: Manuel H. Ehrlich,Jr., BASF Corp. (Log # 142), Michael E. Lyden, The Chlorine Institute, Inc. (Log # 344), John T. Higgins, Dow Coming Corp. (Lo 8 # 441), Hershel l S ~ o r d , Exxon ChemicaJ Amencas (Log # 551),

ce A. Stratis, Philadelphia, PA (Log # 560), liam A. Levy, Research Triangle Park, NC (Log # 670),

Raymond P. Beauchy, Du Pont Co. (Log # 886), Samuel A. Pearman, Martinsville, VA (Log # 948), John M. Coburo, Occidental Chemica d Corp. (Loft # 1075) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Begin statement with "Under the direction of specialist in these area~ Estimate...monitoring equipment." SUBSTANTIATION: Places the responsibility for the/ask correctly under a specialist and helps clarify expectation. COMMITTEE ACTION: Reject , COMMITYEE STATEMENT: Section 4-I.S(a)5 establishes a goal for the technician. It does not establish the competencies that are required to meet that goal. To include under the direction of a specialist would not be appropriate at this point. •

472- 251 - (4-~1): Accept in Part SUBMITrER: Manuel H. Ehrlich,Jr., BASF Corp. (Log # 143), Michael E. Lyden, The Chlorine Institute, Inc. (Lo 8 # MS), ohn T. I-Iiggins, Dow Coming Corp. (Log # 442), ershell Stafford, F.xxon Chemical Americas (Log # 532),


Raymond P. Beaudzy, Du Pont Co. (Log# 887), Samuel A. P ~ , Martinsville, VA (Log # 949), John M. Coburo, Occidental Chemical Corp. (Log# 1076) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Replace Containment systems with "container/packaging." Container/packaging is specifically defined in 472 - 1989 Edition and follows the accepted DOT definition. SUBSTANTIATION: Containment systems is new and undefined. Container/packaging is specifically defined in 472 - 1989 Edition and follows the accepted DOT definition. COMMITrEEACTION: Accept in Part. C O M ~ STATEMENT: See Action and Statement on Public Comment 472-114 (Log #909).

(Log # 222) 472- 252 - (4-2.1.1): Accept SUBMrIWER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "to" on the third line. SUBSTANTIATION: Grammatically incorrect as written. COMMITTEE ACTION: Accept.

472- 255 - (4-2.1.1): Accept , SUBMITrER: Manuel H. Ehrlich,Jr., BASF Corp. (Log# 144),

• Michael E. Lyden, The Chlorine Institute, Inc. (Log # M6), John T. Higgins, Dow Coming Corp. (Log # 443), Hershell Stafford, Exxon Chemical Americas (Log # 555),

ce A. Stratis, Philadelphia, PA (Log # 562), llam A. Levy, Research Triangle Park, NC (Log # 672),

Raymond P. Beaudry, Du Pont Co. (Log # 888), Samuel A. Pearman, Martinsville, VA (Log # 950), John I~L Coburn, Occidental Chemical Corp. (Log# 1077) COMMENT ON PROPOSAL NO.: 472-I

I RECOMMENDATION: Replace "use of containment ~systerm" in lines one, two and three with "container/packaging'. SUBSTANTIATION: Containment systems is new and undefined. Container/packaging is specifically defined in 472 - 1989 Edition and follows the accepted DOT definition. COMMITTEE ACTION: Accept.

(Log#S51) 472- 254 - (4-2.1.1.~1(c)): Accept SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise 4-2.1.1.1 (c) by deleting the ~ r d "tank" and replacing it with the word "hopper". ' SUBbWANTIATION: None. COMMITTEE ACTION: Accept.

(Log # 72) 472-255- (4-2.1.3): Accept in Principle SUBMITIT.R: Peter M. Bryan, West End H~,~rdous Materials Assistance Team COMMENT ON PROPOSAL NO.: 472-1 / RECOMMENDATION: Delete paragraph 4-~1.S. SUBSTANTIATION: No definition "classification" system is identified...'classify" into what? Unclear expectations on objectives. COMMITYEEACTION: Accept in Principle.

Reword Section 4-2.1.5 to read as follows: " . . . identify or classify by b=,z,rd each unknown material." .

COMMITTEE STATEMENT: The Committee believes that the addiiton of the phrase q3y hazard" makes this competency dearer.

(Log # 755) 472-2561- (4-2.1.5): Accept in Principle SUBMITrER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Should read: : . .and one a gas, identify or

c i . oach unknown ON: In order to be measurable, objective should

specify an acceptable classification system. UN b~:~rd classification system is the one most widely employed. COMMITrEEACTION: Accept in Principle. COMMITTEE STATEMENT: See Committee Action and Statement on Public Comment 472-255 (Log #72).

(Los # 73) 472- 257; (4-2.1.3.1): Reject ' SUBMITrF~ Peter M. Bryan, West End I42rJrdous Materials Assistance Team COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise paragraph to read:

"Demonstrate the methods in an analysis process for identifying unknown materials. Such system or method could include chemical analysis using Hazardous Categorization (Haz Cat)." SUBSTANTIATION: Identify, is not the objective which is required of those responders which ~ expected to mitigate the incident. They need to be able to demonstrate a method.- The most popular method nationally is the system ofHaz Cat'ing. COMMITTEE ACTION: Reject. COMMITIq~E STATEMENT: The Committee feels that since ~-Iaz Cat" is a proprietary system it is not appropriate to reference it.

472- 258 - (4-2.1.3.1): Accept SUBMrlWER: Manuel H. Ehrllch,Jr., BASF Corp. (Log# 145), Michael F-- Lyden, The Chlorine Institute, Inc. (Log # M7), ohn T. Higgins, Dow Coming Corp. (Log # 444L ersheil Stafford, Exxon Oaemical Americas (Log # 5M),

ce A. Strafis, Philadelphia, PA (Log # 563), _ liam A. Levy, Research Triangle Park, NC (Log # 673),

Raymond P. Beandry, Du Pont Co. (Log # 889), Samuel A. Pearman, Martinsville, VA (Log # 951), John M. Coburn, Occidental Chemical Corp. (Log# 1078) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add to the text "Identify steps...unknown materials." SUBSTANTIATION: Clarifies expectation. COMMITrEE ACTION: Accept.

(Log # 750) 472- 259 - (4-2.1.3.2): Accept SuBMrI'rER: Bruno Mark W'flson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Should read a...monitoring equipment used to determine..." SUBSTANTIATION: Error in syntax: without the word "used~ the adverbial phrase ~ determine the following hazards" modifies the verb "identify', not the noun "equipment" (and thus m~kPs little

COMMrITEE AL'rlON. Accept.


( L o g # 757) 472- 260- (4-2.i.3.3): Accept in Prindple ' ' SUBMIT]T,R: Bruno Mark Wilson, Oregon State F'we Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION:" Should read"...to .consider when choosing and usin~ the fonowin~..." , . SUBSTA]qTIATION: ]~,eversingthe order Ix~ the participles "using and "choosing" corresponds with the actualsequence o f events: you must choose the item before you can use it. COMMr1WEEACTION: AccePtin Prindple. COMMITrgE STATEMENT: ~ Committee Action and Statement on Public Commefit 472-261. (Log #146).

472- 261 - (4-2.1.3.3): Accept in Principle ' SUBMrrlT, R: Manuel H. Ehrlich,Jr., BASF Corp. (Log # 146), Michael E. Lyden, The Chlorine Institute, hic. (Log # 348), John T. Higsius, Dow Coming Corp. (Log # 445), Hershell Stafford, Exxon Chemical AmericLs (Log # 535), J ~ c e A. Swath, Philadelphia, PA (Log # 564),

A. Levy, Research Triangle Park, NC (Log # 674), Raymond P. Beau&y, Du Pont CO. (Log # 890), Samuel A. Pearman, MartinsviHe, VA (Log # 952), John M. Coburn, Occidental Chemical Corp. (Log# 1079) COMMENT ON PROPOSAL NO.: 472-1 REOOMMENDATION: Replace text with "Identify the selection and limiting factors associated with the use and selection o~ each of the following monitoring devices'. SUBSTANTIATION: More dearly defines the actual outcomes e cted. ~ ' ~ M ~ T r ~ A C T I O N : Accept in Principle.

I Reword as follows: "Identify the limiting factors associated wir.h the selection and use.

C O ~ e ~ ' T ~ ~ : The Committee feels that this clarifies the intent of the section.

COMMITTEE ACTION: Reject. ' COMMITTEE STATEMENT: The Committee feels that this Is an appropriate competency.

472- 265 - ( 4 - 2 . 1 . 4 ) : R e j e c t - " SUBMI ' r IT~ Manuel H. Ehrlich,Jr., BASF Corp. (Log# 148), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 350), John T. Higglns, Dow Coming Corp. (Log # 447), Hershefl Stafford, Exxon Chemical Americas (Log #537),

ce A. Strath, Philadelphia, PA (Log # 566), liam A. Levy, P.eseardi Triangle Park, NC (Log # 676),

Raymond P. Beaudry, Du Pont Co. (Log # 883), . Samuel A, Pearman, Martinsville, VA (Log # 954), John M. Cobum, Occidental Chemical Corp. (Log# 1081) COMMENT O N P R O P O S A L N O . : 472-I RECOMMENDATION: Delete. SUBSTANTIATION: Not a realistic expectation at the Technician level. Refer to radiation ~pecialist. COMMITTEE ACTION: Reject. COMMrrrEE STATEMENT: The Committee believes that the person at this level should be to interpret the label for radioactive materials.

• " (Log # 7e0 ) . 472- 266 - ( 4 - 2 . 2 . 1 ) : R e j e c t , . SuBMnWER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT O N P R O P O S A L N O . : 472Yl • RECOMMENDATION: Change "explain" m "identify. SUBSTANTIATION: The skill "explain" cannot be quantitatively measured. COMM1TrEE ACTION: Reject. COMMrrrEE STATEMENT: The Commit~-e feels that it is possible to measure a permn's ability W explain factual information.

472- 262 - (4-2.1.5.4(b)): Accept . ' • , (Log # 758) SUBMITI'ER: Bruno Mark W'flson, Oregon State Fire M a r ~ COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Should read: " C ~ o n monoxide meter," SUBSTANTIATION: Spell out the chemical abbreviation to ensure consistency (and comprehension). See (d), where we say "Oxygen meter" instead of "02 meter" COMMrlWEEACTIQN: Accept. (Also Se~xion 4-2.1.2.S).

. 472- 26S - (4-2.1.3.5): Reject SUBMITrER: Manuel H. Ehrlich,Jr., BASF Corp. (Log # 147), Michael F_. Lyden, The Chlorine.Institute, Inc. (Log # 349),

~ hn T. Higgim, Dow Coming Corp. (Log # 446), ershell Stafford, Exxon Chemical Americu (Log # 536),.

ce A. SWath, Philadelphia, PA (Log # 565), Ham A. Levy, Research Triangle Park, NC (Log # 675),

Raymond P. Beaudry, Du Pont Co. (Log # 891), Samuel A. Pearman, Martinsville, VA (Log # 955), John M. Cobum, Occidental Chemical Corp. (Log# 1080) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add to text: "Under the direction of an instrument specialist demonstrate..." . . SUBSTANTIATION- Specia~st area - not the expectation of a Technician. COMMITrEE ACTION: Reject. " " '. COMMITTEE STATEMENT: It is the Committees intent that the person at this level would receive the appropriate training to allow

' them to perform the skills called for in this section. That training would undoubtedly be l~rovided by a person with knowledge and skills in this area.

(Log # 759) 472- 264 - ( 4 - 2 . 1 . 4 ) : Reject SUBMITIT.R: Bruno Mark W'flson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Split objective into its components: ~identify" and "match ~. SUBSTANTIATION: A well-written objective should require only a single task.

• ( t ~ 8 # 104) 472- 267 - (4-2.2.1): Reject S U B M r r I T ~ Kent It. Olson, MD, American Association of Poison Control Centers COMMENT O N P R O P O S A L N O . : 472-1 RECOMMENDATION: Add '~egional poison control centers" to the list. SUBSTANTIATION: Regional PCCa play an increasingly important role, particularly in regards to health effects and,i~ues such aa potential for secondary contamination, recommended decontamination procedures, and emergency medical treatment. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee A£tion and Statement on Public Comment 472-151 (Lo 8 #98).

• 472- 268- (4-ZZ2): Accept S U B ~ Manuel H. Ehrlich,Jr., BASF Corp. (Log# 149), Michael E. Lyden, The Chlorine Institute, Inc. (Log.# 351), John T. Higgins, Dow Coming Corp. (Lo~ # 448), '

• Hersheli Stafford, Exxon Chemical Amencas (Log # 5S8), ce A. Strath, Philadelphia, PA (Log # 567), liam A. Levy, Research Triangle Park, NC (Log # 677),

Raymond P. Beaudry, Du Pont Co. (Log # 884), .Samuel ~. Pearman, MartinsviIIe, VA (Log # 955), John M. Cobum, Occidental Chemical Corp. (Log # 1082) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "containment system" and replace with "container/package". SUBSTANTIATION: Containment system new and undefined tenn. Container/package accepted by DOT. COMMITTEE ACTION: Accept.

3 3 9

472- 269 - (4-2.2.3): Reject SUBMITFER: Manuel H. Ehrlich, Jr., BASF Corp. (Log# 150), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 352), John T. Higglns, Dow Coming Corp. (Lo~ # 449),

"Hershell Stafford, Exxon Chemical Amencas (Log # 539), ce A. Strath, Philadelphia, PA (Log # 568), liam A. Levy, Research Triangle Park, NC (Log # 6.78),

Raymond P. Beaudry, Du Pont Co. (Log # 885), Samuel A. Pearman, Martinsville, VA (Log.# 956), John IvL Cobum, Occidental Chemical COrp. (Log# 1083)' COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Replace text "symptoms ofexpomre" with "symptonu or effects of over exposure'. SUBSTANTIATION: More appropriately focuses on desired outcome as envisioned for the Technician. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee believes that over exposure is not the only concern. There is also a concern with being exposed.

iLog # t~3) 472- 270 - (4-2.2.3): Accept SUBMITIT.R: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Revise text to read:

"Given various haT*rdous materials and appropriate reference . materials, identify the signs and symptoms 0T e~pomre to each material and the target organ effects of expo~re to that material:*.

• SUBSTANTIATION: I-la,~rdotts Materlarl Technicians should not be expected to memorize the signs and symptoms of expomre to all hazardous materials, but ahouldknow how to extract that information from reference materials. COMM1TI'EE ACTION: Accept.

(Log # 761) 472- 271 - (4-2.2.4): Reject SUBMITIT.Jh Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Recommend: "Given an example of a miRimall~-compliaJlt fixed site ha,~rdous mbetance inventory mpplied m accordance with a national, state, provincial or local legislative requirement, identify sources that can be used to obtain additional information on the mbstances stored at the site." SUBSTANTIATION: As written in the TCR, this objective would require two ~jmrate ~ i ~ "determine" (which is not measurable) and "identify. Also, other national governments using this standard may not refer to equivalent legislation as Krisht-to-know'. COMMrI'FEE ACTION: Reject. COMMITrEE STATEMENT: See Committee Action on Public Comment 472-272 (Log #121).

(Log # 121) 472- 272 - (4-2.2.4): Accept SUBMITIT.R: Max H. McRae, Houston lrwe Department COMMENT O N PROPOSAL NO.: 472-1

I RECOMMENDATION: Delete 4-2.2.4. SUBSTANTIATION: This competency seems out of place in document. Additional informauon from Tier II or similar reports is not obtained during the analysis of a hazmat incident. The additional informauon referred to in the compeiency is requested when a Tier II is received, not after.an incident occurs. -- COMMITTEE ACTION: Accept.

472- 273 - (4-2.2.4): Reject SUBMITIT.R: Manuel H. Ehriich,Jr., BASF Corp. (Log# 151), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 353), ~_~ hn T. Higglns, Dow Coming Corp. (Log # 450),

ershell Stafford, Exxon Chemical Ameflcas (Log # 540), ce A. Swath, Philadelphia, PA (Log # 569), liam A. Levy, Research Triangle Park, NC (Log # 679),

Raymond P. Beaudry, I ~ Pont Co. (Log# 892), Samuel A. Pearman, Martinsville, VA (Log # 957), John M. Coburn, Occidental Chemical Corp. (Log# 1084) COMMENT ON PROPOSAL NO.: 472-I ~ M M E N D A T I O N : Replace "determine the adequacy" with determine how the information is utiiized" and...

SUBSTANTIATION: Difficult for the Technician to determine adequacy. COMMITTEE ACTION: Reject.

NFPA 472 u A92 TCD

COMI~YrF£ STATEMFaWF: See Committee Action on Public Comment 472-272 (I_cg #121).

( . L ~ # 122) 472- 274- (4-2.3): Accept SUBMITIT~ Max H. McRae, Houston Fire Dept.,TX COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Change "first responder at the operational level" to the b ~ r d o u s materiah technician. SUBSTANTIATION: This competency is in the technician level and the level of responder should be changed ~ or the competency should be moved to the correct section of the document. COIOdr lTEE ACTION: Accept

(Log # 224) 472- 275 - (4-2.3): Accept SUBMrlWER: Gerald r Grey, ~ City, CA COMMENT ON PROPOSAl, NO.: 472-1 RECOMMENDATION: Revise text to read: "Identify the condition of the container involved in the incident. The Ha~rdous Material Technician shall, glven.~." SUBSTANTIATION:' Self explanatory. COMMrlWEE ACTION: Accept

(Log# lS) 472- 276 - (4-2.3): Accept SuBMrI'yEIh- Gregory.G. Noil, Hildebrand & Noll Assoc., Inc. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: C~ange to read: Whe h2~rdom materials technician sha!L.." SUBSTANTIATION: Editorial change to reflect correct termlnol-

472- 277- (4.2.3): Accept in Pan SUBI~TYER: Manuel H. Ehriich,Jr., BASF Corp. (Log# 152), Michael E. Lyden, The (~Iorine Institute, Inc. (Log # 354), ~.~ hn T. Higglm, Dow Coming Corp. (Log # 451),

ershell Stafford, Exxon Chemlca[Amedcm (Log # 541), ce A. Strath, Philadelphia, PA (Log # 570), llam A. Levy, Research Triangle Park, NC (Log # 680),

Raymond P. Beaudry, Du Pont Co. (Log # 893), Samuel A. Pearman, MartinsviIIe, VA (Log # 958), John M. Cobum, Occidental Chemical Corp. (Log# 1085) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "Containment system' and replace with, " c o n ~ e r / p a c k a g e ' . SUBSTANTIATION: Containment systems is new and undefined. Container/packaging is specifically defined in 472 - 1989 Edition and follows the accelSted DOT definition. ' COMMITTEE ACTION: Accept in Part. COMMITrEE STATEMENT: See Action and Statement on Public Comment 472-114 (Log #909).

472- 278- (4.2.S.1): Accept SUBMrI'rER: ManuelH. Ehrlich,Jr., BASF Corp. (Log# 153), Michael E. Lyden, The Chlorine Institute, Inc. (Log # 355), ~.~ hn T. Hlsglns, Dow Coming Corp. (Log # 452),

end3ell Stafford, Exxon chemical Americas (Log # 542), Joyce A. swath, Philadelphia, PA (Log # 571), W'dliam A. Levy, Research Triangle Park, NC (Log " # 681), Raymond P. Beau&y, Du Pont Co. (Log # 894),"

• Samuel A. Pearman, Martinsville, VA (Log # 959), ' John M. Cobum, Occidental Chemical Corp. (Log# 1086) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "Containment system" and replace with "container/package'. SUBSTANTIATION: Containment systems is new and undefined. Container/packaging is specifically defined in 472 - 1989 Edition and follows the accepted DOT definition. COMMITTEE ACTION: Accept.

34O

N F P A 472 - - A92 T C D

• (Log # ~ s ) 472- 279 - (4-2.3.1.1): Accept SUBMITIT.R: Gerald 1.2 Grey; Redwood City, CA

' COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read:

"Given DOT specification markings for non-bulk or Imlkpackaging (including tank cars, tank containers, and ctrgo tanks) and the " appropriate reference guide, identify the..." SUBSTANTIATION: Clarity and grammar. • COMMITTEE ACTION: Accept.

472- 280 - (4-2.$.1.1): Acc~-pt in Principle. " ' S U B ~ Manuel H. Ehdich, Jr., BASF Corp. (Log# 154), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 356), . ~_~ hn T.,Higgins, Dow Coming Corp. (Log # 453),

ershell Stafford, Exxon Chemical Ameri~m (Log # 543), Joyce A. Swath, Philadelphia, PA (Log # 572), Wdliam A. Levy, Research Triangle Park, NC (Log # 682), ' Raymond P. Beauthy, Du Pont CO. (Log # 895), Samuel A. Pearman, Maxtinsville, VA (Log # 960), John M. Coburn, Occidental Chemical Corp. (Log# 1087) COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Delete'..."and the :References the guide" SUBSTANTIATION: Helps clarify expectation at this level. COMM]'IWEEACTION: Accept in Pr~mdple, COMM]TrEE STA'IT~ENT: See committee Action on Public Comment 472-279 (Log #225).

" ( L o g # 762) 472- 281 - (4-2.$.2): Reject SUBMrrrER: Bruno Mark W'flson, Oregon State Fire Marshal COMMENTON PROPOSAL NO.: 472-] , RECOMMENDATION: None. SUBSTANTIATION: What is the purpose of this objective? Regardless of what one calls it (knowinlg the name of the closure • does not help one iota in analy;~ag an mcklent), all closures serve the same function: to control the flow. This knowledge seems already so patiently obvious as to beg the ~lestion: is the knowledge so specialized that It must be codified into ;m international ,, standard? COMMITrEEACTION: Reject. ' COMMITTEE STATEMENT: The submitter made no recommendation.

472- 282 - (4-2.3.2): Accept . SUBMrlWE~ Manuel H. Ehrlich,Jr., BASF corp. (Log # 155), Michael E. Lyden, The Chlorine Institute, ]inc. (Log # $57), John T. Hi88ins, Dow Coming Corp. (Lo~ # 454),. Hershell Stafford, Exxon Chemical Americas (Log # 544),

ceA. Stratis, Philadelphia, PA (Log # 573), liam A. Levy, Research Triangle Parl~, NC (Log # 083),

Raymond P. Beaudry, Du Pont Co. (Log # 396), Samuel A. Pearman, Martinsville, MA (Log # 961), John M. Colmm, Occidental Chemical Corp. (Log # 1088) COMMENT ON PROPOSAL NO.: 472-1- . " '

RECOMMENDATION: Delete "containment system" and replace with "container/package". ' ~ . ' , SUBSTANTIATION: Containment systems is new and undefined. Container/packaging is specifically defined in NFPA 472 - 1989 Edition and follows the accepted DOT definition. COMMITTEE ACTION: Accept. . "

(Lag # 74) 472- 283 - (4-2.3.2):- R e j e c t ' . . - '. SUBMITIT.R: Peter M. BtTan~ West End tlazardous MateriaLs Assistance Team COMMENT ON PROPOSAL N O . : 472-1 RECOMMENDATION: Revise text to define "dmures ~. SUBSTANTIATION: Paragraph does not dearly define what a closure" is, and as such ~ ditficolt to match "each dosure to the

name of the dosure". COMMITrEEACTION: Reject. , ' • COMMrrIT.E STATEMENT: The Committee feels that this is an , appropriate competency for this level.

472-284- (4-2.3.3): Reject •

S U B ~ ManuelH. Ehrlich,Jr., BASF Corp. (Log# 156), Michael E. Lyden, The Chlorine Institute, Inc. (Iro 8 # 358), John T. I-Iiggins, Dow'Coming Corp. (Log # 455), Hershell Stafford, Exxon Chehdcal-Amerl-cas (Log # 545), ' jW~dce A. Stratis, Philadelphia, pA (Log # 574),

liam A. Left, Research Triangle Park, NC (Log # 684), Raymond P. Beaudry, Du Pont Co. (Log # 897), ' ' Samuel A. Pearman, Mardnsville, MA (Log # 962), John I~L cobum, Occidental Chemical Corp. (Log# 1089) COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Delete. SUR~;TANTIATION: Too basic for this level. COMMrlWEE ACTION: Reject. COMMITTEE STATEMENT: The Commluee feeis that this is an appropriate level for the competency.

(Log # 763) 472- 285 - (4-2.3:4): Accept in Principle SUBMrrrElh, Bruno Mark Wllson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 47221 RECOMMENDATION: None. S ~ A N T I A T I O N : Poor 8ramma~ -identify how to identify', "Identify identification ~, "Identify checking for gas migration". Recommend also rewrite so ab to eliminate the need to indude the condition: "C.dven..." perhap6 "Identify the following in r~,ard to a domestic gas line:..." Also, do you mean natural gas, gasoline,

~)p ane or whaO MMrrIT.EACTION: Accept in Principle.

COMMITTEE STATEMF.aNT: Editorial. t

( t~ 8 # 123) 472- 286- (4-2.$.4): Accept SUBMI ' r rE~ Max H. McRae, Houaton Fire DepL, TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Gimnge "domestic 8as line" topipeline so 4-2.3.4 reach:,

4-2.3.4 Given a ruptured pipeline, Identify the following: (a) how to identify owne/ahip of the line; . (b) identification of the line; (c) checking the'ga~ or vapor migration; (d) procedure for shutting down the line or controlling the leak.

SUBSTANTIATION: There is no problem identif~ag ownership of domestic gas lines because domesuc service is genecally'provided by but one c6mpany, whereas, pipelines are not. Letters (a) and (b) of the competency relate to pipefines, not domestic 8as lines. COMMr/TEEACTION: Accept. '

t

(Log # 19) 472-,287- (4-2.S.5): Accept in Principle SUBMrrTER: ~ r y G. Noll, Hildebrand & NoH Assoc., Inc. COMMENT ONPROPOSAL N O - 472-1 RECOMMENDATION: Objective is incomplete and undear. SUBSTANTIATION: Editorial. COMMITTEE ACTION: Acceptin Principle. COMMITTEE STATEMF.NT: See Committee Action on Public Comment 472-289 (Log #124).

(Log # 764) 472- 288 - (4-2.3.5): Accept in Principle . SUBMrrIT.R: Bruno Mark W'dson, Oregon State F'Lre Ma/shal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Incomplete sentence: a...determine the area of evacuation; and" SUBSTANTIATION: ...and what? COMMFrrEEACTION:: Accept in Principle. COMMITTEE STATEMENT: See Committee Action on Public Comment 472-289 (Log #124).

341 '


(Log# 124) 472- 289 - (4-2.3.5): Accept SUBMITrER: Mark H. McRac, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1

. ] RECOMMENDATION: Insert g ~ between "domestic" and "line"

I and remove "and" (third line) so competency reads:

4-2.3.5 Given a domestic gaa line breakand the readings from a combustible gas indicator, determine the area of evacuation. SUBSTANTIATION: Gas clarifies the domestic line, and no~ing follows the ~and". COMMrlWEE ACTION: Accept.

472- 290- (4-2.3.5): Accept in Principle SUBMITrER: Manuel H. Ehrlich, Jr., BASF Corp. (Log# 157), Michael E. Lyden, The Chlorine Institute, Inc. (Log # $59), John T. Higgins, Dow Coming Corp. (Log # 456), Hershell Stafford, Exxon Chemical Americas (Log# 546), J ~ c e A. Stratis, Philadelphia, PA (Log # 575), ,

liam A. Levy, Research Triangle Park, NC (Log # 685), Raymond P. Beaudry, Du Pont Co. (Log # 898), , Samuel A. Pearman, Martinsville, VA (Log # 963), John IVL Cobum, Occidental Chemical Corp. (Log# 1090) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Requires clarification, and if the intent is to address residential gas service, should'be deleted from this standard. SUBSTANTIATION: Not relevant to Technician Level. COMMITTEE. ACTION: Accept in Principle. COMMITTEE STATEMENT: See Committee Action on Public Comment 472-289 (Log #124). The Committee also believes that the term "domestic" is not the same as "residential". Domestic has a broader connotation.

472- 293 - (4-Z3.8): Accept in Part SUBMrlWER: Manuel H. Ehrlich,Jr., BASF Corp. (Log# le0), Michael E. Lyden, The Chlorine Institute, Inc. (Log # 362), ~.~ hn T. Higglns, Dow Coming Corp. (Log # 459),

erdaell Stafford, Exxon Chemical Americas (Log # 549), ~ i l~am A. Swatis, Philadelphia, PA (Log # 578),

A. Levy, Research Triangle Park, NC (Log # 688),. Raymond P. Beaudry, Du pont Co. (Log # 901), Samuel A. Pearnmn, Martinsville, VA (Log # 9eo), John M. Cobum, Occidental Chemical Corp. (Log# 1095) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete words "containment system" and replace with words "container/packaging system ~. SUBSTANTIATION: Containment systems is new and undefined. Container/packaging is specifically defined in 472 - 1989 Edition and follows the accepted DOT definition. COMI~UTrl~ACTION: Accept in Part. COMMrrrEE STATEMENT: See Action and Statement nn Public Comment 472-114 (Log #909).

(Log # 125) 472- 294 - (4-2.3.8.2): Accept "~ : SUBMrIWER: Max H. McRae, Homton Fire Dept~, TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete (a) bags, (b) boxes, ad (c) bottles, and renumber list. SUBSTANTIATION: Fore the life of me, I cannot see any importance in identifying the basic design and construction features of bags, boxes and Ix~tties; it seems a little ridiculous. COMMITrEEACTION: Accept..

472- 291 - (4-2.E6): Accept in Part SUBMITIT~ Manuel H. Ehrlich;Jr., BASF Corp. (Log # 158), Michael E. Lyden, The Chlorine Institute, Inc. (Log # $60), John T. Higglns, Dow Coming Corp. (Lo~ # 457), Hershell Stafford, Exxon Chemical Americas (Log # 547), Joyce A. Stratis, Philadelphia, PA (Log # 576), William A. Levy, Research Triangle Park, NC (Log # 686), Raymond P. Beaudry, Du Pont Co. (Log # 899), ' Samuel A. Pearman, Martinsville, VA (Log # 964), John M. Cobum, Occidental Chemical Corp. (Log # 1091) COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "containment system" and replace ,Hith "container'packaging system". " SUBSTANTIATION: Containment systems is new and undefined. Container'packaging is specifically defined in 472-1989 edition and follows the acceptedDOT definition. COMMITIT.EACTION: Accept in Part. • COMMITTEE STATEMENT: See Action and Statement on Public Comment 472-114 (Log #909).

472-292- (4-2.3.7): Accept in Part SUBMITIT.R: Manuel H. Ehrnch,Jr., BASF Corp. (Log # 159), Michael F_. Lyden, The Chlorine Institute, Inc. (Log# 361), ~.~ hn T. Higglns, Dow Coming Corp. (Lo~ # 458),

ersheIl Stafford, Exxon Chemical Amencas (Log # 548), ce A" Stratis, Philadelphia, PA (L°g # 577), i . liam A. Levy, Research Triangle Park, NC (Log # 687),

Raymond P. Beaudry, Du Pont Co. (Log # 90.0), Samuel A. Pearman, Martinsville, VA (Log # 965), John M. Cobum, Occidental Chemical Corp. (Log# 1092) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Replace text "conudnment system" with Ucontainer/packaging system'. SUBSTANTIATION: Containment systems is new and undefined. Container/packaging is specifically defined in NFPA 472 - 1989 Edition and follows the accepted DOT definition. COMMrrrEEACTION: Accept in Part. ' COMMITTEE STATEMENT: See Action and Statement on Pubfic Comment 472-114 (Log #909).

472-295- (4-2.4): Accept In Principle SUBMITrER: Manuel H. Ehrlich,Jr., BASF Corp. (Log# 161), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 365), ~_~ hn T. Hlggius, Dow Coming Corp. (Lo~ # 460),

ersheH Stafford, Exxon ChemicaIAmencas (Log # 550), Ydce A. Strath, Philadelphia, PA (Log # 579),

liam A. Levy, Research Triangle Park, NC (Log # 689), Raymond P. Beaudry, Du Pont CO. (Log # 902) , Samuel A. Pearman, Martinsviile, VA (Log # 967), John M. Coburn, Occidental Chemical Corp. (Log# 1094) COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "containment systems" and replace with "container/packaging system" .Change wording to: . Predictllikely behavior of container/packaging system when it is

exposed to stress. The ha~rdous material technician... SUBSTANTIATION: Containment systems is new and undefined. Container/packaging !s spedfically defined in 472 - 1989 Edition and follows the accepted DOT definition. , COMMITTgEACTION: Accept in Princivle.

Change "containment systems ~" m "containers'. Reject the part relating to the wording change.

COMMrrrEE STATEMENT: The competency isn't restricted to t h e behavior of the container but relates to the behavior of the con ten t& Also see Action and Statement on Public Comment 472-114 (Log

#909).

(Log # 765) 472- 296 ~ (4-2.4.1): Accept in Principle' SUBMITrER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Recommend: "Identify two references that indicate the effects..." 'SUBSTANTIATION: "At least" is unnecessary verbiage. Also, none of our professional chemists or toxicologists have been able to identify as many as three inch sources. Two, yes; three, no. COMMrrrEE ACTION: Accept in Principle.

Reword'as follows: , ," " , "Identify at least three resources that would provide information on

the effects of mixing various chemicals." COMMITTEE STATEMENW: The Committee feels that by changing the term "references" to "resources" that it broadens the availability of such information.

342

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I

N F P A 472 - - A92 T C D

( I . ~ # 766) 472- 297- (4-2.4.2): Reject SUBMrFTE~ Bruno,Mark Wdson, Oregon State F'tre Marshal COMMENT ON PROPOSAL NO.: •472-] RECOMMENDATION: Chan~. "Describe" to "Identify'. , SUBSTANTIATION: An individdal's ability to ~descril~ ~ cannot effectively be mea~ared. COMMrYrF~E ACTION: Reject. ' -

COMMr]WEE STATEMENT: See Commi~.'e Statement on Public Comment 472-212 (Log #740).

/

COMMITrEEACTION: Ac~-,ept in Principle. COMMITYEE STATEMENT: See Committee Action Comment 472-301 (Log #L~).

472- 298- (4-2.4.3): Accept' . . (Log # 767) SUBMIT]'ER: Bruno Mark W'flson, Oregon State Fire Marghal COMMENT ON PROPOSAL NO.: 472-1 . RECOMMENDATION: None. ' .

SUBSTANTIATION: Is numbering correct here?" Objc~ctive seems out of place in this section on incidents involving multiple material~ COMMITTEE ACTION: Accept. • C O M ~ STATEMENT: Editorial.

(Log # 226) • 472- 299- (4-2.4.3): Accept

SUBMITrER: Gerald L Grey, Red~>od Ci,y, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read: . •

~Identify the impact of the following fire and safety features on the • behavior of the products during an incident at a bulk storage , -fadlity." . . ,

SUBSTANTIATION: Some of the items ha01e no impact during . normal operations. Therefore, the addition of "during an incident more dearly defines the intent of an emergency responder needing

" to know the information. COMMrrrEEACTION: Accept. "

, • )

472- 300 - (4-2.4.3): Accept in Principle SUBMITrER: Manuel H. Ehrlich,Jr., BASF Corp. (Log # 162), Michael F_= Lyden, The Chlorine Institute, Inc. (Log # 304),. John T. Higgins, Dow Coming Corp. (Log # 461), Hershell Stafford, Exxon Chemical Americas "(Log # 551),


Raymond P. Beaudry, DU Pont CO. (Log # 903), Sa~nuel A. Pesrman, MartinsviIle, PA (Log # 968), John IVL Cobum, Occidental Chemical Corp. (Log# 1095) C O M M E N T O N P R O P O S A L NO. : 472-1 RECOMMENDATION: Requires clarification. Expectation is unclear. SUBSTANTIATION: Clarifies objectives. COMMI3TEEACTION: Accept in P r i n c i p l e . COMMrFrEE STATEMENT: See Commiuee Action onPublic Comment 472-299 (Log #~6) .

(Log#20) 472- 301 - (4-2.5.2.1 and 5-2.1.2): Accept . SUBMITrER: Gregory C,. Noll, Hildelrand & NoH Assoc., Inc. COMMENT O N P R O P O S A L NO.: 472-I RECOMMENDATION: Change m read: '~a tch the following. toxicological terms and exposure values..." SUBSTANTIATION: LC and LD are toxiadogical terms/values," while the remaining terms are exposure values.

COMMITrEEACTION: Accept. " ' . .

(Log # 76s) 472- 302- (4-2.5.2-1): Accept in Principle SUBMITrER: Bruno Mark Wilson, Oregon State F'L~ Marshal COMMENT ON PROPOSAL NO.: 472--1 RECOMMENDATION: Recommend: .'~/atch the following exposure limits and units of measurement with their significance..." SUBSTANTIATION: "Parts per milfion* mid "parts per billion" are not exposure limits, but units 0f measurem~:nt used in relation to exposure limits; they themselves are not exlmsure limit&

' 3 4 3

on Public

i(Log # ~7) i 472-305- (4-2.5.2.1(b) & (c)): Accept

SUBMrrTER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read (LC60) and (LD50). SUBSTANTIATION: S e l f e x p l a n a t o r y . " ' .. COMMI'IWEE ACTION: Accept. .

(Log#21) 472- 304- (4-~5.2.1(i) and 5-~1.2(i)): Accept SUBMITrER: Greso~ C,. Noll, Hildebrand & Noll Assoc., Inc. COMMENT ON PI~OI~X~AL NO.: 472-1 " . ~ ' RECOMMENDATION: Add (ERPG) after the term "Emergency response planning guide value. - SUBSTANTIATION: Emergency rest_ nse planning guide values are commonly referred to as ~qPG ' s within theemergency management and industrial hygiene fields. COMM1TYEgACTION: Accept. • . ."

472- S05 - (4-2.5.2.2): Reject . . • (Log # 769) SUBMrrrER: Bruno ~ W'dson, Oregon State F'me Marshal COMMENT O N P R O P O S A L NO.: 472-I RECOMMENDATION: ]hecommend adding: "neutron radiation" to alpha, beta, and g-a~a~L radiation. We also recommend that objective should be moved back to the Operations level. SUBSTANTIATION: There actually is a highly destructive fourth type of radiation with which Technicians should be familiar. COMMrrrEE ACTION: Reject. COMMITTEE STATEMENT: The Committee believes,that the terms Hsted are the most significant terms relating to radioactive materials and that the likelihood of encountering neutron radiation is not very likely except in extremely specialized and rare p rgce~es.

472- 306- (4-~5.2.2): Reject SUBMrrIYR: Manuel H. Ehrflch,Jr., BASF Corp. (Log # 163), Miche l E. Lyden, The ~dor ine Institute, Inc. (Log # 365), John T. Higgins, Dow Coining Corp. (Lo~ # 462), ' Hershell Stafford, Exxon (~emical-Amencas (Log # 552),

ce A. Stratis, Philadelphia, PA (Log # 581), Ham A. Levy, Research Triangle Park, NC (Log # 691),

Raymond P. Beaudry, Du Pont Co. (Log # 904), Samuel A. Pearman, ManinsvilIe, VA (Log # 969), . John/vL Coburn, Occidental Chemical Corp. (Log # 1096) COMMENT O N P R O P O S A L NO.: 472-1 R E C O M M E N D A T I O N : Replace existing text with:

~Under the supervision of a radiation specialist, demonstrate an understanding of the' following...associa/ed with radioactive materials. Explain the relative health h ~ r d in a hazmat incident.

• SUBSTANTIATION: Anm related to radiation specialist and not really required of hazmat technician. . ' : COMMITTEE ACTION: Reject. . , , COMMrITEE STATEMENT: It is the Committee s intent that the reaponder at this level should have an understanding'of the terms Hated and their.significance. "

/

• (Log # 770) 472-307- (4-2.5.3): Accept in Principle

SUBMrr rER: Bruno Mark Wilson, Oregon State Fine Marshal COMMENT ON PROPOSAL NO.: 47221 "

RECOMMENDATION: None. ' "

SUBSTANTIATION: If this is different from 4-2.5.2it is not readily apparent.. . '

C O ~ ACTION: Accept in Principle. :

Delete 4-2.5,3 . . . . " - COMMITrEE STATEMENT: The Commitxee agrees regarding the similarity but feels that 4-2~.3 is the I~tter of the two m delete. . "

1

N F P A 472 - - A 9 2 T C D

472- 308 - (4-2.5.4): ~ e p t in Principle, SUBMrrrER: Manuel H. F_J~dich,Jr., SASV Corp. (Log # 164), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 366), John T. Hlggins, Dow Coming Corp. (Lo~ # 463), ' Hershell St~ford, Exxon Chemical Americas (Lo 8 # 553),

ce A. Swath, philadelphia, PA (Log # 582), . liam .4. Levy, Research Triangle Park, NC (Log # 692),

Raymond P. Beaudry, Du Pont Co. (Log # 905), Samuel A. Pearman, Martinsville, VA (Log # 970), John M. Coburn, Occidental Chemical Corp. (Log # 1097) COMMENT ON PROPOSAL,NO.: 472-I RECOMMENDATION: Modify as follows:

Identify methods for estimadng...glven the boundaries of the established zone& SUBSTANTIATION: Clarifies the statement and makes it more understandable.

I COMMITTEE ACTION: Accept in Principle. Reword 4-2.5.4 as foHovm: "Identify the method for estimating the outcomes within an

• endangered area of a hazardous materials inddent." C O M ~ STATEMENT: The Committee feels that the above clarifies the intent of the competency.

• (Log# 77]) 472- 309 - (4-~,.1): Reject SUBMITFEI~ Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-3 RECOMMENDATION: Move the following to Operations level: •

4-3.1.1 4-3.1.2.3 4-3.1.3.4 4-3.1.2 " 4-3.1.3 4-3.1.3.5 4-3.1.2.1 4-3.1.3.1 4-$.1'.3.6 4-3.1.2.2 4-3.1.3.2 4-3.1.3.7

SUBSTANTIATION: Operations level i~ermnnel need m be competent in these areas. Many of them will be using chemical protective clothing and respirators other than SOnde, and all are fikely to operate on an incident with hazardous materials techni- dans. They should be familiar with the purpose, advantages and fimitations, coml~onents and concepts related to thia level of personal protecuve equipment. F'trat Responders and Technicians are supposed to work together on emergency scenes, not in separate wodds. COMMrlWEE ACTION: Reject. COMMrlWEE STATEMENT: The Committee feels that the com[~tendes contained within the operational level adequately' ' provide the necessary skills needed by the responder at that level.

(Log # ~n2) 472- 310 - (4-3.1.1): Reject SUBMITFER: Bruno Mark Wdson, Oregon State Fwe Marshal ' COMMENT ON PROPOSAL NO.: 472--] RECOMMENDATION: None. SUBSTANTIATION: Incomplete sentence: match both equipment and conditions with what? COMMITTEE ACTION: Reject. COMMITFEE STATEMENT: No Recommendation.

. (tog # 773) 472- 312 - (4-3.1.3.1): Reject SUBMrrrER: BrunoMark W'flson, Oregon State FLre Marshal COMMENT ON PROPOSAL NO.: 472:i RECOMMENDATION: Change "explain" to "identify". " ' . SUBSTANTIATION: "Explain ~ cannot be measured effectively. COMMITTEE ACTION: Reiect. COMMITTEE STATEMENT: See Committee Statement on Public Comment 47~-~06 (Log #Te0).

(Log # 774) 472- 313 - (4-S.1.3.3): Reject SUBMrrsle;i~: Bruno Mark W'dson, Oregon State Fire'Marshal COMMENT ON PROPOSAL NO.: 472--1 • RECOMMENDATION: Change "describe" to "identify'. SUBSTANTIATION: ~Describe" cannot be measured effectively. COMMrFrEE ACTION: Reject. COMMITrEE STATEMENT: See Committee Statement on Public Comment 472-212 (!.,o 8 #740).

( i ~ # 22s) 472- 314 - (4-3.1.3.3): Accept SUBMrrrER: Gerald L. ~ , Redwood (~ty, CA COMMENT ON PROPOSAL NO.:. 472-1 RECOMMENDATION: Revise text to read:

"Identify the types of vapor protective and splash protective clothing and describe the advantages and disadvantages of each

~UI~YANTIATION: The intent should be to have the technician identify the correct clothing to select based on their advantages and disadvantages. Vapor and splash protection ave the updated terms - in NFPA. This definition does not eliminate the technician from identifying the types of suits described in the referenced document, but we should change the reference to the new NFPA standardsl COMMITTEE ACTION: Accept.

472- 315 - (4-$.1.3.$): Accept in Principle SUBMITIT~ Manuel H. Ehrlich,Jr., BASF Corp. (Log# 167), Michael E. Lyden, The Chlorine Institute, Inc. (Log # 369), ~.~ hn T. Higgins, Dow Coming Corp. (Lo~ # 466),

ersheH St~ford, Exxon Chemical Americas (Log # 556), ce A. Strath, Philadelphia, PA (Log # 585), liam A. Levy, ResearchTriangle Park, NC (Log # 695),

Raymond p. Beaudry, Du Pont Co. (Log # 908), Samuel A. Pearman, Martinsville, VA (_L~ # 973), John M. Coburn, Occidental Chemical Corp. (Log # 1100) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: ~ text to read:

"Describe the advantages and dimdvantages of level A Vapor protective/Chemical protective clothing."

¢ ~ y what "types" refers to. SUBb~ANTIATION: A~ it stands, we have no idea of what the original'intent constitutes 3 types of Level A CP/VP Eq. CO-MMITrEE ACTION: A c c ~ t in Principle, COMMITTEE STATEMENT: See Committee Statement on Public

" Comment 472-314 (Log #228).

472- 311 - (4-3.1.2.1): Accept SUBMITIT.R: Manuel H. Ehrlich,Jr., BASF Corp. (Log# 165), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 367), ~_~ hn T. Higglr~, Dow Coming Corp. (Log # 464),

erahell Stafford, Exxon Chemical Plant ( (Log # 554), Joyce A. Str~tts, Philadelphia, PA (Log # 588)i W'dliam A. Levy, Research Triangle Park, NC (Log # 698), - Raymond P. Beaudry, Du Pont Co. (Log # 906), Samuel A. Pearman, Martinsville, VA (Log # 971), John M. Coburn, Occident Chemical Corp. (Log # 1098) COMMENT ON PROPOSAL NO.:' 472-I RECOMMENDATION: Revise as follows:

"Describe the advantages, limitations and proper use of the..." SUBSTANTIATION: A~mres the responder undersumds from a practical standpoint what s /he is doing. COMMITTEE ACTION: Accept.

(Log # 77S) L , ,

472- 316 - (4-3.1.5.4): Accept S U B ~ Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-3 RECOMMENDATION: ~ g e '~ist" to "identify". SUBSTANTIATION: "List cannot be measured as effecfiyely as "identify". COMMITTEE ACTION: Accept.

472- $17- (4-3.1.3.4): Reject SUBMITrER: Peter M. Bryan, West End Hazardous Materials Assistance Team COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete paragraph 4-3.1.3.4. S LU~ ._AN~TION: Research conducted and published indicates only core" temperature, is critical, and that such external cooling methods have liixle or no effect on core temperature, and may be detrimental based on "making the responder feel a sense of over confidence based,on the external benefits of such cooling".

344 / .

NFPA 4 7 2 - - A92 TCD

COMMITTEE ACTION: ReJect.. C O M M r r r E E STATEMENT: The Commitum feeLs that it l~ importamt for the responder at this level to l~tve knowledge about the advantages or disadvantases of such units.

(Log # 776) _472- 318 - (4-3.1.3.6): Reject SUBMITIT.R: Bruno Mark Wilson, Oregon :State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Chan~e "de te rmine ' to -identify-. SUBSTANTIATION: "Determine" cannot I~.- measured effectively. COMMITTEE ACTION: Reject. .' COMMITTEE STATEMENT: The Commim~ feels that a persons ability to determine the appropriate protect i~ doth ing can be measured as effectively as the persons ability to identify it.

472- 319 - (4-$.2.1):" Accept in Prin~ciple SUBMITrER= Manuel H. F_.hrlich,Jr., BASF Corp. (Log # 166)0 Michael E. Lyden, The,Chlorine Institute, Inc. (Log# 368), John T. Higgins, Dow Coming Corp. (Lo~ # 465), •, • Hershell Stafford, Exxon Chemical Americas (Log # 555),

ce A. Stratis, Philadelphia, PA (Log # 584)~, " liam A. Levy, Research Triangle Park, NC (Log # 694),

Raymond P. Beaudry, Du Pont Co. (Log # 907), Samuel A. Pearman, Martinsville, VA (Log # 972), John IVL Coburn, Occidental Chemical Corp. (Log # 1099) COMMENT ON PROPOSAL NO.: 472-1 -

I RECOMMENDATION: Revise as follow~ , "Identify the advantages and limitations, and describe an example

when each of the following decon methods would be used:" Requires additional clarification as to how isolation relates to

decon. SUBSTANTIATION: A,~mres that from a practical standpoint the, responder understands what s / he is doing. COMMrrI ' t .~EACrION: Accept in Principle.

Also delete (0. C O M M r r r E E STATEMENT: The Committee agrees and feels that (f) needs to be deleted.

' .(Log # 777) 472- 320 - (4-3.3): Accept SUBMITFER: Bruno Mark Wdson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 4 7 2 - ] RECOMMENDATION: Should read: "...techniclan shall, given simulated... ~ SUBSTANTIATION: Error in syntax: dimg~-ement in number. Delete the word "a" before %imulated." COMMITTEE ACTION: Accept.

(Log # 778) 472- 321 - (4-3.3.1): Reject SUBMIT1T~ Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472--1 RECOMMENDATION: Revise as foilow~/"

"Identify the purpose for, advantages and limitations of, procedure and equipment required for, and safety precautions used with the following..." SUBSTANTIATION: "Advantages and limilations ~ are also important to know'. ~Describe" a m n o t be measured effectively. C O M M r r r E E ACTION: Rejec t . COMMITTEE STATEMENT: The Commiuee feeLs that the competency as written is appropriate and measurable. Also see 472- 212 (Log #740). "

(Log# 779) 472- 322- (4-3.3.1.1): Reject

. SUBMITrER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Revise as follows:

"Identify common methods for product transfer from each of the following types of cargo tanks:

.(a) MC-300 /DOT~06 (b) MC-S07/DOT-407 (c) MC-S12/DOT-412. (d) MC-331 (e) MC~338 ~

SUBSTANTIATION: Revision eliminates the necessity to provide actual cargo vehicles for a skill in which competency can be demofiswated simply using pen and paper. COMMITrEE ACTION: Reject. , COMMITrF~ STATEMENT: It is not the intent of the Committee that a responder would have to be given an actual vehicle in order to identify the methods for product transfer. The definition for identify states "to select or indicate verbally.. ." and this can be accomplished b? means other than having an actual vehicle present.

(Log # 127) 472- 323 - (4-3.3.2): Reject S u B M r r I T J ~ Max H. McRae, Houston Fire Dept . ,TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise "site safety plan" to read plan of action, so it r~,4~-

4-3.3.2 Develop ap l an ofaction for a h = ~ d o u s material incident. SUBSTANTIATION: The proposed revision stays wit h the terminology used in the introduction (4-3.3), which i~. I more hi rune with the terminology used in the real world; site safetyplans relate to hazardous waste sites. COMMITTEE ACTION:. Reject. COMMITIT, E STATEMENT: The Committee's intent is for the responder to develop a "site ~.fety plan', not a plan of action. The site safety plan would be part of the overall plan of action.

,, (Log # 126) 472- 324 - (4-3.3.2.1): Reject S u B M r I w E ~ Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Reviae "site safety plan" to read plan of

"action, so it reach: . 4-3.3.2.1 Describe the components of a plan of action for a I ha~rdous material incident. SUBSTANTIATION: The proposed revision stays with the terminology used in the introduction (4-3.3), which is more in tune with the terminology used in the real world; site safety plans relate to har~rdous'waste sites. . " COMMITrEEACTION: ReJect. ' COMMIT]'EE STATEMENT: See Committee Statement on'Public Comment 472-323 (Log #]27). f

(Los # 780) 472- $25- (4-3.3.2.1): Reject " '

SUBMITrER: Bruno Mark W'dson, Oregon State Fh-e Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Change "deu:r ibe ' to "identify'. Also . recommend identifying some source via foomote. SUBSTANTIATION: "Describe" cannot be measured effectively.

' COMMITTEE ACTION: Rejec~ , C O M M r r r E E STATEMENT: See Committee Statement on Public Comment 472-212 (Log #740).

(Log # 128) 472- 326 - (4-3.3.2.2): Reject SUBMrI'rER: Max H. McRae, Houston Fire De pt:, TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise "safety plan" to plan of action, so it reads: ~"

4-3.3.2.2 Given a simulated h ~ r d o u s mate "rial incident, develop a Ian of action. ' ' • '

ON: The proposed revision stays with the terminology used in the introduction (4-3.$), which is more in tune with the terminology used in thereal world. ' : . ' COMMITTEE ACTION: Reject. COMMrrrEE STATEMENT: See Committee Statement on Public Comment 472-323 (Log #127).

I . ! .

N F P A 472 - - A92 T C D

(Log # 7s]) 472- 327 - (4-$.$.2.2): Accept in Principle SUBMrrrER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMt',NDATION: Revise as follows:

"Given a simulated b ~ r d o m materiaLs incident, demonstrate the ability to develop a site safety plan." . " . SUBSTANTIATION: "Develop" is not defined in 1-2;, "demonstrate"

COMMITYEEACTION: / ~ t in Principle. • . Add the word "site" before "sa~fety'.

• COMMrITEE STATEMENT: The Committee feels that adding the word "site'. clarifies the competency.

I

(Log # 7S2) 472- 328 - (4-4.1.1): Accept SUBMITrER: Bruno Mm-k Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Revise as follows:

"Identify the role, specified in the local emergency response plan and the organization's standard operating procedures, of the . hazardous materials technician dm-l. ng an inddent involving b~-~rdous materials." SUBSTANTIATION: Better syntax. As written in TCR, the p~h~a~_. "specifled...procedures" sounds as though it modifies "incident, not "role" (i.e., that the incident, not the role, is specified in the ERP and SOPs). COMMITTEE ACTION: Accept. ""

472- 329- (4-4.L2): Reject " . ( 'IT°g # 229) SUBMITrER: Gerald L. Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Add an ~*" and reference the Incident Command System Position Manuals for the indicated position. SUBSTANTIATION: Self explanatory-need reference murcel. COMMrlWEE ACTION: Reject. COMMITTEE STATEMENT: The Committee will add reference material under the appropriate appendix for "other publications'. "

(Log # 7ss) 472- SS0 - (4-4.1.2): Accept SUBMITrER: Bruno Mark W'dson, O r ~ o n State FLee MarJha! COMMENT ON PROPOSAL NO.: 472-], RECOMM~.NDATION: Cl~ange: "ba,~rd sector personnel" to "hazard sector functions'. SUBSTANTIATION: Oftentimes agencies find themselves ~ced with insufficient personnel on scene to suet'all these functions. Nevertheless, these functions are still performed. COMMITI"EE ACTION: Accept.

(Log # 76) 472- 331 - (4-4.1.3): Reject " SUBMITTER: Peter M. Bryan, West End Hazardous Materials Assistance Team COMMENT ON PROPOSAL NO.: 472-1 RLCOMMF, NDATION: Revise pa ras r~h to read:

"responsibilities of the h2r~rdous materials group of ICS functions-. SUBSTANTIATION: "Hazards Sector Omcer" and "sector" are not universal terms utilized by NIMS or IC~.. COMMrlWEE ACTION: Reject. COMMITTEE STATEMENT: The terms are defined in 1-2.

(Log# 1~) 472- 332 - (4-4.1.3): Accept SUBMITrER: .Max H. McRae, Homton Fire Dept., TX COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Add, describe how to between "and" and "coordinate" m competency reach: '4-4.1.$ Given the local emergency response plan or organization's standard operating procedures, identify the duties and responsibilities of the b~rd sector officers, and describe how to coordinate all activities of that sector.

SUBSTANTIATION: Describe how to coordinate activities seems more practical than just coordinate activities when the given statement is not a simulated hazmat incident. COMMITTEE ACTION: Accept.

(Log # 784) 4~2- SSS- (4-4.1.S): Reject SUBMrI'rER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472=1 RFXX)MMENDATION: Delete: "...and coordifiate all activities of that sector." SUBSTANTIATION: This objective requires competency in both cognitive and psychomotor ~lciH. The latter cannot be m ~ ( 'coordinate') and should be omittecL COMMnWEE ACTION: Reject. COMMrrrF, E STATEMENT: The Committee feels that the proce~ of setting up the decontamination process and performing decontamination can be performed and measured.

(Log # 78s) 472- ~ 4 - (4-4.1.4): Accept in Principle SuBMrlWER: Bruno Mark W'flson, Oregon State Fh-e Marshal COMMENT ON PROPOSAL NO.: 472-1

I REODMMENDATION: Recommend'splitting objective: "Given a simulated hazardous materials incident, demonstrate set

up of the decontamination corridor as specified in the planned • r e s p o r l s e , m SUBSTANTIATION: "Demonstrate" is defined in 1-2, "set up" is not and is otherwise difficult to measure.

[ COMMITTEJgACTION: Accept in Principle. Change "decontamination corridor" to "contamination reduction

corridor'. COMMITTEE STATEMENT: .This maintains consistency within the d o c u m e n t .

(Log # 786) • 472- 3Xg, - (4-4.1.5 (New)): Accept SUBMITrF~ Bruno,Mark W'flson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1

I RFX:OMMENDATION: Revise as follow~ "Given a s imulat~ t~-~,dous materials incident, demonstrate

performing the decontamination process specified in the planned r e s p o n s e , m

SUIISTANT][ATION: "Demonstrate" is defined in 1-2, ~ r f o r m " is n o t COMMrrrEE ACTION: Accept.

(Log # 7s7) 472- 336- (4-4.2): Accept

• S U B M r r I T ~ Bruno Mark W'dson, Oregon State F'we Marshal COMMENT ON PROPOSAL NO.: 472-]

i REK:OMMENDATION: Should read: q3on, work in, and doff both...'. SUBSTANTIATION: Typographical error in original text. COMMITTEE ACTION: Accept.

(Log # 2S0) 472- ~7 - (4-4.2.1): Accept S U B ~ Gerald L. Grey, Redwood C~ty, CA , COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read:

"Identify the safety and eme.r~ency procedures for personnel wearing vapor protective dothing." SUBSTANTIATION: Personnel working in vapor protective - clothing (encapsulating mfita) must be knowledgeaHe in not only safety procedures, but ~lso in emergency procedures should their air mpply-malfunction or their suit tear. COMMITI'EE ACTION: Ac~pt.

3 4 6

N F P A 472 - - A92 T C D

, (Log # 788) 472- 338 - (4-4.~.1): No Action SUBMrI'YER: Bruno Mark Wdson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472-] RECOMMENDATION: None. '

SUBSTANTIATION: Did you intend "procedures" here or

- "considerationa"?

COMMITrEEACTION: No Action. C O M M r r r E E STATEMENT: No recommendation. (See Action on Public Comment 472-337 (Log #230).

472- 339 - (4-4.2.2): Accept . SUBMH'rER: Manuel H. Ehrlich,Jr., BASFCorp. (Log# 168), Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 370), John T. Higgins, Dow Coming Corp. (Log # 467)/ . ',

Hershell Stafford, Exxon ChemicaI-Americu (Log'# 557), ce A. Stratis, Philadelphia, PA ( L o g # 586), '. liam A. Levy, Research Triangle Park, N C ( L o g # ffJ6),

Raymond P. Reaudry, Du Pont Co. (Log # 879), Samuel A. Pearman, Martinsville, VA (Log # 974), John M. Cobum, Occidental Chemical Corp. (Log # 1101) COMMENT O N PROPOSAL NO.:' 472-1 RECOMMENDATION: Revise text to: "b) Air line respirator and' required e s c a F e unit.'* ' " '

SUBSTANTIATION: Most common and ~mportant of respiratory.

PP devices. " ' " "

C O M M r r r E E ACTION: Accept .

(Log # 789) "

472-340- (4-4.2.5): Accept in Prindple '

SUBMrrgER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] 'RECOMMENDATION: Change "Demona~rate" to "Identify~ SUBSTANTIATION: ~ reduces the logistical nightmare of w/tng to administer such an objective in the task performance phase. While maintenance, testing, inspection and storage are indeed important elements, they are not as equal b' critical in the overall ~ e m e of things as other items. W e need ~o exercise a certain reasonablene,A Ln the application of this sumdard. COMMrITEEACTION: Accept in Pr~" dple. • .~

Change "demonstra te ' to "describe'. COMMrr rEE STATEMENT: This maintains consistency. "

(Lo8#22) 472- 341 - (4-4.3.1 and 4-4.3.2): Accept SUBMITIT.R: Gregory G. Null, Hikfebrand &, Noli Assoc., Inc. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise as follows:

agiven a non-bulk and bulk pressure veuei /conta lnment system, select the appropriate material a n d / o r equipment, and demonstrate a method(s)-to contain the following Ieal~-- SUBSTANTIATION: The intent is to combine 4-4.3.1 and 4-4.3.2 into a "generic" pressure veuel-relatedcomp~-tency, rather than l imitingthe only-discussion on pressure vessels to chlorine. Additional information can be Inserted into the Appen'dix~ . referencing chlorine, sulfur dioxide, natu~.d gas plping, etc. COMMITrEEACTION: Accept. . " " .

(Los # 23]) 472- 342 - (4-4.3.1): Accept SUBMrlWER: Gerald L. Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 , '

RECOMMENDATION: Insert an "a" in the second line before "100 ~. SUBSTANTIATION: Grammatical correolon. COMMITFEEACTION: Accept. • ,.

(Los # 790). 472- 343 - (4-4.3.1): Accept SUBMrlWER: Bruno Mark Wdson~ Oregon State Fire Marshal " COMMENT ON PROPOSAL NO.: 472--1 RECOMMENDATION: None. SUBSTANTIATION: We should split the 'tclentify" r equ i rement . from the "demonstrate requirement and [)lace in a separate

ctive • MHTEE ACTION: Accept.

(Log # 84 s) 472- 344 - (4-4.3.2): No Action SUBMITrER: Terry Bindernagel, Cleveland, O H COMMENT ON,PROPOSAL NO.: 472-1 .

RFA3OMMENDATION: Chlorine ~C" Kit is not addressed. • SUBSTANTIATION: Are you drawing lines between Technician - and S~ ' c .~sO A better definition of Technidan vs. SpedalLst Level activities is required. Can a public sector employee acquire S l ~ e d a l i s t ~

• No Action. C o M M r r r E I~ STATEMENT: No recommendation. (See Action on Public Comment 472-341 (Log #22).

(Log # 791) 472-'345 - (4-4.3.2): Accept • •

• SUBMI'rrER: Bruno Mark Wilson, Oregon State Fh'e Marshal .

COMMENT O N PROPOSAL NO.: 472-1 . ~

RECOMMENDATION: None. SUBSTANTIATION: We should split the "identify" requirement

• from the "demonstrate" requirement and place in a separate .

ACTION: Accept.

• (Log # 77) 472- M6 - (4-4.3.2): Reject . " .

SUBMITITJ~ Peter M. Bryan, West end I-la~rdous Materials

Assistance Team

C O M M E N T O N P R O P O S A L NO.: 472-I

RECOMMENDATION: Revise tex t to include a second paragraph (or separate section) to read:

.idenfify...B;Kit..Containers: (a) - (h)" "Identify the partL..C - Kit...in chlorine tank truck on rail contain-

e r $ :

( a ) Valve gland (b) Valve seat t .. .

(c) Valve inlet threads . ~ (d) Relief device leaking ' ' . "

SUBSTANTIATION: No where else in 472, nor in the pro]~, sed 474' is it noted or required where responders shall be familiar wtth the C kit applications. These containers are frequently moving about the highways and rail and Technicians should be capable of C-Kit use if

' they are expected to udiize A & B - Ki~ ' .

- COMMrrrEE ACTION: Reject. COMMrITEE STATEMENT: See Committee Action on Public Comment 472-341 (Log #22). Neither chlorine or chlorine kits are now referenced.

i

(Log # I so) 472- 347- (44.s.s): Reject

, SUBM1TIT, R: Max H. McRae, Houston lrtreDept., TX " , -.

COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise 4-4.3.3 to read:

4-4.3.3 Given the dome of a.railroad presawe lank car, demonstrate the ability to:

(a) dine open valves; - i (b) tighten loose valve plugs; and • . '

(c) replace miuingvalve plugL SUBSTANTIATION: The proposed revision defines what fittings in the given statement of the competency. COMMITrEE ACTION: Reject. COMMrrrEJ~ STATEM~.JqT:. See Committee Action on Public Comment 472-348 (Log #23). " \

(Log # 2S) 472- 348 - (4-4.5.3): Accept in Principle SUBMI'IWER: Gregory G. Noll, Hildebrand & Null AMoC, Inc. COMMENT ON PROPOSAL NO.: 472-1

i RECOMMENDATION: t ~ a n g e to read: . "Given the fittings on a pressurized container, demonstrate..."

SUBSTANTIATION: Makes the statement more generic and broader in scope, rather than limiting discu~ion to only chlorine cylinders. " . . .

I C OMMITrEEACTION:' Accept inPrinciple. . '

Change "pressurized" to "pressure. C O M M r r r E E STATEMENT: The word pressure is more appropriate.

3 4 7 /

v


(Log # ~92) 472- 349 - (4-4.3.4): Accept SUBMITrER: Bruno Mark W'dson, Oregon State Fire Marshal ,COMMENT ON PROPOSAL NO.: 472£i . . RECOMMENDATION: Revise as follows:

"CAven a 55~allon drum, demonstrate the ability to contain the following leaks using appropriate tool, and materials:..." SUBSTANTIATION: We need to maintain the "one skill per

" rati° thr°ughout. .ACTION: Accept.

(Log # 794) 472- ~,0 - ('4-4.3.5): Accept SUBMITgER: Bruno Mark Wilson, Oregon State F'we Marshal COMMENT ON PROPOSAL NO.: 472~- RECOMMENDATION: Revise as follows:

"Given a 55-gallon drum and an overpack drum, demonstrate the ability to place the 55walion drum into the overpack drum using the following methods:..." _ SUBSTANTIATION: Condition is miming from T O t objective. COMMI'~I'EE ACTION: Accept.

(Log # 24) 472- 551 - (4-4.5.6, 4-4.8.8): Accept SUBMITYER: Gregory G. Noll, I-Iildetwand & Noll Auoc., Inc. COMMENT ON PROPOSAL NO.: 472-1 REODMMENDATION: Change order of competencies, so that the final four competencies ~ the current:

4-4.3.6 4-4.5.8 4-4.3.11 4-4.5.12

S U B S T A T I O N : Would put all competencies pertaining to cargo tang trucks together, making the document more "~tser friendly". • COMMrrrEE ACTION: Accept.

(Log-# ~s) 472- 552 - (4-4.5.6): ~ t SUBMrI'rER: Bruno MaYk W'dson, 4720~_ n State Fire Marshal COMMENT ON PROPOSAL NO.: RECOMMENDATION: Revise as follows:

"Given a MC-306/DOT-406 cargo tank and a dome cover clamp; demonstrate the ability to p,.mpeHy install the clamp on the dome." SUBSTANTIATION: Condition is missing from TCR objective. COMMITTEE ACTION: Accept.

47¢-555- (4-4.s.s): Accept SUBMITTER: Bruno Mark W'flson, Oregon State F'me Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Revise as follow~

"...when controlling a fire involving a MC-806/DOT-406..." (i.e., change "fire in" to "fire involving ~) SUBSTANTIATION: Let's not restrict ourselves to fires inside cargo tanks, but include flame impingement on exterior as well. COMMITTEE ACTION: Accept.

SUBSTANTIATION: Revision eliminates the necessity to provide actual cargo vehicles fora skill in which competency can be demonstrated simply using pen and ~a, per. COMMrrYggACTION: Accept in Principle.

Change "identify" to "describe'. COMMrrrEE STATEMENT: The Committee agrees and for consistency changes the wording to describe.

472- 556- (4-4.5.12): Accept (Log# 25) SUBl~l.-.rt.q: Gregory G. Nofl, Hildebrand & Noll Assoc., Inc. ' COMMENT ON PROPOSAl, NO.: 472-1 RECOMMENDATION: Insert MC, S06/DOT-406 cargo tanks into the competency. SUBSTANTIATION: Although these are the most conunon cargo tank, it appears that they were inadvertently letX out of the competency. COMMITrgE ACTION: Accept.

(Log # 2ss) 472- 557 - (4-4.$.12): Accept SUBMll-rLR: C~J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add MOS06/DOT-406 to the list of specifications to complete that list. SUB,~ANTIATION: All cargo tanks but the MC-306/DOT-406 were listed. Why leave out the one specifiration? COMMITTEE ACTION: Accept.

(Log # lSl) 472- 858 - (4-4.$'.12): Reject SUBMrIWER: Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete 4-4.3.12. SUBSTANTIATION: Competency has been covered in4-4.S.10. COMMrrrEE ACTION: Keject. COMMITTEE STATEMENT: The Committee feels that this .competency is different. Section 4-4.3.10 requires knowledge about the safety considerations whereas 4-4. 8.12 requires knowledi, ge about factors involved in product removal and transfer.

(Log # ~gs) 472- 559 - (4-4.$.12): Accept in Principle SUBMrI ' rF~ Bruno.lVlark Wilson, Oregon State Fh'e Marshal COMMENT ON PROPOSAL NO.: 472--1 RECOMMENDATION: Revise as follows:

"Identify product removal and transfer considerations for MC-307/ DOT-407, MC-$12/DOT-412, MC-331 and MC-338 cargo tanks, induding:..." SUBSTANTIATION: Revhion eliminates the necessity to provide actual cargo vehides for a skill in which competency Can be demon sl~rated simply using pen and paper.

[ COMMITrEEACTION: Acceptin Principle. Change ~dentlfy to "describe" and add the term "overturned"

before ' . . .MC-~07/DOT407. . ." COMMrITEE STATEMENT: The Committee agrees and feels that the changes maintain consistency.

(Log # 796) 4~2- 554- (4-4.s.9): Accept SUBMITTER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete "...at least..." S ~ ~_AI~I~,_ TION: Eliminate unnecessary verbiage. Also, are we looking for "safety" considerations or "operational" considerations? COMMrITEE ACTION: Accept.

472- 555 - (4-4.3.13): Accept in Principle SUBMI'IWER: Bruno Mark Wilson, Oregon State Fire COMMENT ON PROPOSAL NO.: 47221 RECOMMENDATION: Revise as follows:

.identify methods for containing the followihg leaks in MC-306/ DOT-406, MC-S07/DOT-407, andMC-312/DOT-412 cargo tanks:..."

(Log # 26) 472- 360 - (4-5): Accept SUBMrrrER: Gregory G. NoH, Hildebrand & N011 Assoc., Inc.

, COMMENT ON PROPOSAL NO.: 472-1 [ RECOMMENDATION: Add the following: [ "The Hazardous Materiah Technician should be capable of [ evaluating the effectiveness of any control functions ldentitied in the [ plan of action. Competencies should be developed which reflectthe [' skill and knowledge requirements."

SUBb~ANTIATION: It appears that "Evaluating Progress" competenctes w~re inadvertently omitted from the document at the H.M. Technician level, even though they are included at the First Responder Operations level (see Section ,~;), as well as the HazMat Technician goal level (see Appendix A- Evaluation Tasks). COMMITTEE ACTION: Accept

348


(Log # 8s~) 472- 361 - (Chapter 5): Reject . SUBMITTER: Richard F. Williams, Galn~-s~llle Fire Rescue° FL COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete Chapter 5. . . SUBSTANTIATION: NFPA 1021 is the standard for Fire Officer

Professional Qualification. Experience, national trends and . probability show that for any number of types of emergendes a fire . officer will be the Incident Corrmmnder. "E~is is particularly true of the four major classes of emergendes which do not involve criminal activity;, fires, ha-~rdous materials incidents, emergency medical incidents, and man-made or natural disaste:rs. While the authors of Standards 472 may se~ ha~rdous materials to

be a sufficiently technical subject that they desire to have a special Standard for Inddent Commanders, the fa(~ will dictate the opposite to be true. The primary consideration for qualification to command the expertise in a specific type of inddentbe ing handled. It is inherent in the theory of the inddent command system (ICS) that any officer in the organization can assume command at the outset of an inddent and if he / she is able to handle the increasing complexity as dae incident progresses, may continue to be the., Incident Commander throughout the incident. From a training and organizational theory standpoint, the standards and professional qualifications for comman, ding incidents should be focused on the skills and the abilities which are needed to ~erform that function. They should be incorporated in the profeusonal standards for all " fire officers. The NFP A 472 Committee has taken a different tack in trying to

specialize Incident Commanders to types o4~ incidents. Such an approach will guarantee failure, since it wil]t be wholly ignored by the fire service. , .

My second objection to NFPA 472 is also in the area of Incident Command. I have no particular objections to the othe/" technical , qualifications required for specific h ~ r d o u s materials task. I do object to these same technical qualifications being rolled into the Incident Commander requirements. I agree that it will be important for the.lncident Commander to have some generalized knowledge of haTardous materials operations indud]ng, at a minimum, the - awareness and first responder skills. There is no particular value for the IC to be required to have levels of knowledge beyond that.

Certainly there are fire officers whose car(~r path has taken them through rather extensive training in h a ~ r ~ u s materialsand it would certainly benefit them if they were in a position of IC, . however the essential functibn of an Inddent Commander is the same as that of any manager- to acquire the essential resources and apply them to the problem at hand. If technical expertise in , ha-~rdous materials is an essential resource for the particular type of emergency being handled, then it is the IC's responsibility to acquire that resource and make use of it. ,

In any given community where ha-Jrdous materials are manufac- tured, processed, stored, handled, or transported there are planning requirements for h27~rdou8 materials emeigendes required under - SARA Title III. One important ingredient of those plans is the identification of technical experts for the t3~es of ha~rds that will be encountered in the local environment. It is not necessary to burden the Incident Commander with the same requirements that • are to be found in the technical communist. To create this spedalizadon in the type of Incident Comnmnder is to ignore the theory, practice, and future of the incident commander system. • In summary, my comments reflect my; belief that NFPA Standard

472should be modified to delete the vast nmjority of technical requirements placed upon the Inddent Commander and move t h e remaining requirements along with some additional general education in planning and. commanding I~tzardous materials incidents to the NFPA Standard 1021 Fire Offic.er Professional (~alMiflcations"

MrITEE ACTION: Reject. " COMMITTEE STATEMENT: The Committee.rejects the , submitter's comment based on the fact NFPA 472 is not restricted to being used by only the fire service. In fai:t, it has always been the intent of the Committee that the document applies broadly to the area of emergency response to haT~rdous ~ t e r i a l s incidents. Although fire service personnel are key players in emergency response to ha,~rdous materials incidents in most areas, they are..by no means the only responders.

i

,. (Log# ~ 5 472- 302 - (Ompter 5): Rejea SUBMrrrER: Michael R. Rehfeld, Westminstar Fire Dept., MD COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Chapter in it's entirety. ',' ' SUlkSTANTIATION: After reviewing this entire chapter I have , found it to be far tQ much to expect of the Incident Commander that is also responsible for running a fire ground and functioning as a administrator. I am a volunteer officer that currently meets all of these competendes and also meet the requirements for Specialist under CFR 20 1910.120 Far q. Whatl see happening with this • standard is that it is going to force every officer and every fire deparunent into compliance with OCR 29 1910.120 p/ur q and ignore the NFPA standards. • " ' COMMITTEE ACTION: Reject. . . COMMITTEE STATEMENT: The Committee believes'that it is important to establish competencies for incident commanders of hamrdous materials incidents. 29 CFR 1910.120 (q) already applies to any f iRdepar tment that responds to bar~rdom materials incidents, this sumdard isnot going to change that requirement. The standard does outline.competendes that an incident commander should possess to effectively.manage a ha~ardous-materlals incident. ,

, J

(Log # s7) '

472- 563 - (5-1.1): Rejea S U B ~ Richard S. Kraus, Mobil Oil Corp. COMMENT ON PROPOSAL NO.: 472-1 • ,RECOMMENDATION: ReviSe text: • ~lnddent Commanders need only to be competent:regarding those materials and products which they are responsible for as transport- ers, handlers and /o r storers or to which they may respond.* SUBSTAWrIATION: There is no need to train people to be competent in handling response to every product on,earth. Let's recognize that there are experts in the materials and products they hand]e, and allow for ~ expertise. COMMrrrEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Statement on Public Comment 472-1S (Log #82)'..

( ~ # 232) p

472- 364 - (5-1.S(b)(S)): Accept in Principle .. S U B ~ Gerald L. Grey, Redwood City, CA ' COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION" Delete this competency. SUBSTANTIATION: This should not be a requirement of an ~cident commander, but a competency of the ~ u s materials technidan. Since by law (1910.120) the minimum level of protection for responding offensively to a ha~rdous materials incident is level B (splash protection) and first responders are defensive persons, the incident commander does not need to determine clothing requirements if all he /she has available are first responders. If technicians are available, they should be making the selection of their clothing, not some '.person that doesn' t have to'wear the dothing.

If this comment is accepted by the committee, then 5-3.3 should be deleted as it is the competency for fulfdling this goal. COMMITrEEACTION: Accept in Principle. COMMrlTEE STATEMENT: See Committee Action on Public Comment 472-~66 (Log #469).

472- 366 - (5-1.s): Accept . . . (Log # 282) SUBMI2WER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 .'

• [ RECOMb~.~k~ TION: Revise the statement 5-1.3(d) by repladn 8 the words and complete" with the words ~ , completing" to be

I consistent with the rest of this type statement. S ~ A N T I A T I O N : To be consistent with this type statement in Chapter 5 as well as the rest of the document. COMMITrEE ACTION: Accept. /

N F P A 4 7 2 - - A92 TCD

472- 366- (5-1.3(b)(3)): Accept . " " , S U B M I T I T ~ Hershell Stafford. Exxon Chemical Americas (Lo~ # 469) _ l v l~c~ l F_. Lyden, The Chlorine Institute, Inc. (Log # 571) J~ce A. swat.b, FMC Corp. (Lo 8 # 587)

liam A. Levy, Rhone-Pouienc A8 Co. (Log # 609) John T. l-Iiggins, Dow Coming Corp. (Lo 8 # 697) Samuel A. Pearman, Martinsvllle, VA (Log # 1014) John M. Cobum, Occidental Chemical Corp. (Log# 1103) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text: Approve the level ofpersunal protective equipment required for a

• given action option. , SUBSTANTIATION: The Hazmat Team Leader (HAZMAT Technician) would more appropriately select the specific protective doth ing required for responders entering the hot zone. C O M M r r r E E ACTION: Accept. "

(Los # 27) 472-567- (5-2): Accept in Principle SUBMITFFAg: Gregory C,. Noll, Hildebrand & Noll A,uoc., Inc. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Insert: Identify the types of hazard and response information available from each of the following resources and explain the advantages and disadvantages of each resource:

(a) reference manuals (b) ha~'~rdous materials data bases (c) technical information centers (d) technical information specialists (e) monitoring equipment

SUBSTANTIATION: Incident Commander must be familiar with common sources of hazard and response information in evaluating risks and selecting action options.

Competency is identical to 4-2.2.1. COMMrrFEEACTION: Accept in Principle.

Create a new 5-2.1 as follows: Collect and interpret b a i r d and response information from

printed resources, techanical resources, computer data bases and monitoring equipment. The ba~ rdons materials technician shall, given access to printed resources, technical resources, and computer data bases, and monitoring equipment, collect and interpret hN, s rd and response informtaion not available from the currenf edition of the DOTrC Emergency Response Guide Book or a Material Safety Data Sheet (MSDS).

5-2.1.1 Identify the types o f h ~ r d and response information available from each of the following resources and explain the advantages and disadvantages of each resource:

(a) reference manuals (b) ha~rdous materials data bases (c) technical information centers (d) technical information specialists (e) monitoring e~luipmfnt Renumber accordingly. Add a new 5-1.3(a) 1 as follows: 5-1.3 (a) l. Collect and interl?ret h ~ r d and response information

from printed resources, techmcal resources, computer data bases and monitoring equipment; and

Renumber accordingly. COMMYrrEE STATEMENT: The Committee agrees with the submitter regarding the need and feeLs that 5-2.1 is the appropriate section. It also becomes necessary to include in the goals contained 5-1.3.

\ /

(Log # 698) 472- 368 - (5-2.1.1):' Reject SUBM1TTER: John T. Higgins, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Reword to read:

"Describe procedures for estimating the number of exposures within the engulfed area of a hazardous materials incident given its dimensions and the surrounding conditions." SUBSTANTIATION: Use of the words ~Identffy the steps" Implies that there is one correct set of steps for this procedure. COMMITTEE ACTION: Reject. - . COMMITFEE STATEMENT: The Committee believes that the competency as written is appropriate.

(Log # ~) 472- $69 - (5-2.1.1): Accept SUBMrrrER: Bruno Mark Wilson,, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Recommend:

"Given the dimensions and the surrounding Conditions of an engulfed area of a h=~rdous materials incident, identify the steps ' for estimating the number of exposures within the engulfed area." SUBSTANTIATION: TCR wording is ambiguou¢ does "its" modify "incident" or "~'ea~?

- COMMrlTEEACTION: Accept.

472- 570- (5-2.1.1): Reject SUBMITrt;R: W'flliam A. Levy, Rhone-Poulenc Ag Co. (Log # 610) Joy= ce A. Strads, FMC Corp. (Log # 588) john Cobra, O de. ' emi ' Corp. <Log# 1104) Samuel A. Pearman, MartinsviIIe, VA (Log # 1015) Raymond P. Beaudr/, DuPont Co. (Log # 858) Hershell Stafford, Exxon Chemical Americas (Log # 470) Michael E. Lyden, The Chlorine Institute, Inc. (Log #.372) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revi~ text:

"Describe procedures for estimating the number of exposures within the engulfed area o f a hazwdons materials incident given Its dimensions and the surrounding'conditions. SUBbWANTIATION: U s e o f t h e words ~Identify the steps" Implies that there is one correct set of steps for this procedure.

• COMMITrEE ACTION: Reject. ' COMMITI'EE STATEMENT: It is not the Committee's intent that there is a certain number of specitic steps in conducting the evaluation. The incident commander would want to consider such things as the direction of the wind, time of day, day of week, type of occupandes, etc..

(Log # S00) 472- 371"- (5-2.1.2): Accept in Principle SUBMITrER: Bruno Mark Vfflson, Oregon State Fn-e Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Recommend: .

"Match the following exposure limits and units of meamrement with their significance..." SUBSTANTIATION: "Parts per million" and "parts 'per billion" are not exposure limits, but units of measurement used in relation to exposure limits; they themselves are not exposure limits. COMMITTEE ACTION: Accept in Principle.

Change to r ea~ '~Matchthe following toxicological terms and exposure values. . ."

COMMITTEE S T A ~ : This change keeps the competency consistent with similar ones in Chapter 4.

(Log # e~) 472- s~i- (5-2.1.2): Reject SUBMITrER: J o h n T. Higgins, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Reword the opening paragraph to read:

"Be familiar with the meaning of the following exposure limit terms:"

Delete sub items b and c and combine items d and g. SUBSTANTIATION: The incident commander only needs to generally understand the terms since most community emergency response plans and department operating procedurespecify that the Hazmat technician will advise on these terms and inforn~tion required involving these term& T h e deleted items have no

ificance al~ an emergency response. MITIT.E ACTION: Reject.

COMMn'TEE STATEMENT: The Committee believes that it is Important for the incident commander to have a knowledge of the terms because there will not always be a hazardous materials technician available particularly for those entities that only respond at the operational level. -

35O

N F P A 472 - - A92 T C D " '

472- 373 - (5-2.1.2): Reject SUBMITrER: W'dliam A. Levy, Rhone-Pou~ienc Ag Co. (Log # 611) John M. Coburo, Occidental Chemical Corp. (Log # 1105) Samuel A. Pearman, Martinsville, VA (Log # 1016) ' " r

Raymond P. Beaudry, DuPont Co. (Log #859) Joyce/L Swads, FMC Corp. (Log # 589) ' Hershell Stafford, Exxon Chemical Ameriam (Log # 471) Michael E. Lyden, The Chlorine Institute Inc. (Log # 373) COMMENT O N PROPOSAL NO,: 472-1 RECOMMENDATION: Revise text:

Be familiar with the meaning of the following exposure limit term~ Delete sub items b & c and combine iten~ d & g. Consider using terms and hierarchy from "BACKGROUND

INFORMATION ON "ITIE INITIAL ISOLATION AND PROTEC- TIVE ACHON DISTANCES TABI..E.S* in the U.S. DOT 1990 Emergency Response C, uideboolL . . SUBSTANTIATION: Incident commander only needs to generally understand the terms since frequently the community emergency response plan and department operating procedure specify for the response o f a hazmat technidan to advise. The deleted items have no significance at an emergency response. COMMITIT.E ACTION: Reject. COMMITrEE STATEMENT: See Committee Statement on Public Comment 472-372 (Log #699).

( L o g # 2 3 3 5 472- 374- ( 5 - 2 . 1 . 2 ( h y & ( c ) ) : A c c e p t • SUBMITIT.R: Gerald L. Grey, RedwoodCItty, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read (LCS05 and LD505. SUBSTANTIATION: Self explanatory. COMMITIT.E ACTION: Accept. -. . .

472- 375 - (5-2.1.5): Reject SUBMITFF.Jg: John T. Higgins, Dow Coming Corp. (Log # 700) W'dliam ~ Levy, Rhone-Poulenc Ag Co. ( L ~ # 612) John M. Coburn, Occidental Chemical Corp. (Log# 1106) Samuel A. Pearman, Martinsville, VA(Log #1017~ Raymond P. Beaudry, DuPont Co. (Log # 860) Joyce A. Swath, FMC Corp. (Log # 590) Hershell Stafford, Exxon Chemical Americ|s (Log # 472) Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 374) COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: Delete 5-2.1.3. SUBSTANTIATION: The indden t cornn~mder does not need to know this if the community emergency response plan and department operating procedures specify for the]~azmat mchnician to advise. ' - . ,, • COMMITTEE ACTION: Reject. COMMITIT-I~- STATEMENT: Hazardous materials technicians do not always respond particularly in the initial phases of an incident. Also in many areas the level of training may only be. to the operational level.

472- 576 - (5-2.1.4): Accept in Prindple " SUBMITIT.I~ John M. Cotmm, O c d d e n l ~ Chemical Corp.

(Log#1107) " • . . . . . sville- A tt 0 8 Samuel A. P~rman, .Mart in , V (Log: I I ) John T. Higgins, Dow Coming Corp. (I~g # 701) Raymond P. Beaudry, DuPont Co. (Log # 861) William A. Levy, Rhone-Poul~nc Ag Co. (Log # 613) Joyce A. Swath, FMC Corp. (Log # 591) ' Hershell Stafford, Exxon Chemical Americas (Log'# 473) Michael E. Lyden, The Chlorine Institute, lnc. (Log # 375) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Describe procedt~res for predicting a~reas of harm and estimating outcomes within an t~agulfed area of a haTardous materials incident given the concentration of materials. SUBSTANTIATION: Use of the words ~identify the steps" implies that diere is one correct set of steps for thin, procedure. C O M P A C T I O N : Acceptin Principle.. .

Delete~5-2:l.4 . . . . • Change 5-2.1.5 to read as follows:

"Identify the method for predict ingthe areas of potential harm within the endangered area of a hazardous materials incident." COMMITrEE STATEMENT: The Committee believes that the changes made above clarify the competencies needed by the incident commander to effectively analyze the problem.

' " (Log# 801) 472- 577- (5-2.1.5): Reject SUBMrlWER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT O N P R O P O S A L NO.: 472-] - . . RECOMMENDATION: None, SUBSTANTIATION: TCR wording Is ambiguous: is+the preposi- tional phrase "ofa hazardous materials inddent" supposed to modify the "outcomes-" or the =engulfed area'? COMMITTEE ACTION: Reject. C O M M r r r E E STATEMENT: See Committee Action and Statement on Public Comment 472-376 (Log #1107).

(Log # s02) 472- 578 - (5-5.1): Accept • : S U B M r r r E ~ Bruno Mark W'dson, Oregon State Fn'e Marshal COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: Change "determine" (both instances) to "id¢_ n ~ / ' . _ SUBSTANTIATION: "Determine" cannot objectively be mea~,red. COMMITTEE ACTION: Accept.

472- 379 - (5-5.1.1): Accept in Prindple SUBMrrrER: John T. Higgins, Dow Coming Corp. (Log # 702) W'dliam A. Levy, Rhone-Poulenc AgCo. (Log # 614) Joyce A. Su-atis. FMC Corp. (Lo~ # 592) . ~ . . . . " . Hershell Stafford, Exxon Chermeal Americas (LOg ~ e le) ' Raymond P. Beaudry, DuPont CO. (Log # 862) Samuel A. Pearman, Martinsville, VA (Log # I019) John IVl. Cobum, Ocddental Chemical Corp. (Log# 1108) Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 376) COMMENT O N P R O P O S A L NO.: 472-I RECOMMENDATION: Determine the potential alfects of exposure given an analysb of a hazardous materials problem. SUBSTANTIATION: The incident commander needs to use information from support personnel to determine what steps:to take. Part of that determination is evaluation of the potential ex t en t of an incident and the effects on the public and the environment.

[ COMMrITEEACTION: Accept in Principle. ] Delete 5-5.1.1. - ! COMMrITEE STATEMENT: This competency is already required

at theoperat ional level and the indden t commander should already have demonstrated those skilLL

472- 380- (5-3.1.2): Accept in Principle ' , S U B ~ Hershell Stafford, Exxon Chemical Americas '(Log # 475) ., Raymond P. Beaudry, DuPont Co. (Log # 863) . , Samuel A. Pearman, Mardnsville, VA (Log # 1020) John M. Colmm, Occidental Chemical Corp. (Log# 1109) John T. Higgins, Dow Coming Corp. (Log # 703) W'flliam A. Levy, Rhone-Poulenc A8 Co. (Log # 615)" . "' Joyce A. Strath, FMC Corp. (Log #~9S) Michael E. Lyden, The Chlorine Institute, Inc. (Log # 377) COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: ~ text:

~Identify the response objectives given ...." • . SUBSTANTIATION: The purpose is not to understand the steps, bu t to understand what objectives to set. .

I COMMITrEEACTION: Accept in Principle. " ~ . I Delete Section 5-3.1 through 5-3'.1.2.1. , = COMMITTEE STATEMENT: See Committee Statement on Public

Comment 472-379 (Log #702).

(Log # 803) 472- 381 - (5-3.1.2.1): Re jec t S U B ~ Bimno Mark Wdson, Oregon State FLre Marsl3al COMMENT O N P R O P O S A L NO.: 472-1 RECOMMENDATION: None. SUBSTANTIATION: Objective too vague. What d ~ s the Commit- tee mean by "types of response"? ' , COMMrr rEE ACTION: Reject.

No Recommendation was given. ' , COMMrr rEE b-TATEM~fr: See Committee Action on Public Comment 47'2-580 (Log #475).

3 5 1 I

I \

NTPA 472 - - A92 TCD I

(Log # 2s4) 472- 382 - (5-3.1.2.1): Accept in Principle SUBMrrrF .~ Gerald L. Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-1 •

• RECOMMENDATION: Revise text to read: "Identify the types of response (defensive, offensive) to ha~rdous

materials incidents and identify when each is used. SUBSTANTIATION: CZ~ification.' Without indicating'defensive or offensive', the reader cannot be sure what is meant by the types of

° M n s e -

MrrrEEACTION: Accept in Principle. COMMITTEE STATEMENT: See Committee Action and Statement on PUblic Comment 472-380 (Log#475).

(Log# 18~) 472- 383 - (5-3.1.3): Accept / SUBMrr]'ER: Michael F_. Boyle, Irvine, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the following paragraph: • "Identify at least three (3) indications of n~terial degr~da~on of

Chemical Protective Clothing after chemical contact." SUBSTANTIATION: This level of practice is outside the Incident Commander's scope of responsibility. This level of function and responsibility lies with the Hazardous Materials Technician Level. The Incident Commander is responsible for the overall management of theincident, not each technical aspect. This type of responsibility lies with the Hazardous Materials Safety Officer. COMM1WTEE ACTION: Accept.

(Log#a) 472- 384 - (5-3.1.3): Accept. SUBMITIT.R: Robert A. Green, Riverside County Fire Chlef¢ Assoc., CA COMMENT O N PROPOSAL NO.: 472-1

l RECOMMENDATION: Delete the following paragraph: "Identify at least three (3) indications of material degradation of

Chemical protective dothing after chemical contact." SUBSTANTIATION: This is outside the scope of the Incident Commander's resl3onsibilit ~ and belongs with the Hazardous Materials Technicmn Level. The Incident Commander needs to deal with the management of the incident, not the technical aspects of it. The HaTardous Matefiah Safety Officer should have the responsi-

bility of grading the integrity of the chemical protective clothing after chemical contact. COMMrrFEE ACTION: Accept.

(Log # s04)' 472- 385 - (5-3.2): Reject - SUBMITFER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472--1 RECOMMENDATION: None. SUBSTANTIATION: What is the difference between "potential action option" and "possible action option"? COMMrITEE ACTION: Reject. . No Recommendation was given. COMMITTEE STATEMENT: The Committee does not see a difference between potential and possible.

472- 386- (5-3.2.1): Reject SUBMrlWER: Raymond P. Beaudw, DuPont Co. (Log# 864) Hershell Stafford, Exxon Chemical Americas (Log # 476) John T. Higgins, Dow Coming Corp. (Log # 704) Joyce A. Stratis, FMC Corp. (Log # 594) , . Samuel A. Pearman, Martinsville, VA (Log # 1021) William A. Levy, Rhone-Poulenc Ag CO. (Log # 616) John M. Coburn, Occidental Chemical Corp. (Log# I I I0) Michael E. Lyden, The Chlorine Institute, Inc. (Log # 379) COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete 5-3.2.1. SUBSTANTIATION: This is the responsibility of the hazmat team leader or hazmat technician. COMMITTEE ACTION: Reject. COMMITFEE STATEMENT: At an operational level rlesponse it may be that neither a hazmat team nor a hazmat technician would be on the scene.

/

(Log # ~5) 472- 387 - (5-$.2.2): Accept SUBMrIWER: Gerald L Grey, R.edwuod City, CA COMMENT ON PROPOSALNO.: 472-1 '~ RECOMMENDATION: Revise text:

Revise text to read:' "Identify the purpose of each of the following techniques for

hazardous matL-fia~ control. (a) Absorption; (b) Neutralization; (c) Oveq~cking; (d) Patch and plug."

SUBSTANTIATION: The additional text is self explanatory (see 4-3.3.1). The deletion should not be a requirement of an incident com-

mander, but a competency of the b o ~ l o m materials technician. Incident commanders by definition are not hand,on personnel but ' managers of personnel. It is neither practical nor economically feasible to train our incident commanders to technician competen- deal COMMITTEE ACTION: Accept.

472- 388-~5-$.2.2): Reject SUBMITIYR: SamueFA. Pearman, Martinsville, VA (Log# 1022) William A. Levy, Rhone-Poulenc A 8 Co. (Log# 617) John T. Higgins, DowComing Co~p. ~L~g #-705) John i~ COTmm~ Occidental ~e rmca l C6rp. (I~g'# 1111') Michael;F. Lyden, The Chlorine Institute, Fnc. ( L ~ # 378) Raymond P. Beaudv/, DuPont Co. (Log # 865) oyce/L Strath, FMC Corp. (Log # 595)

~-~erahell Stafford, Exxon Chemical Americas (Log # 477) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete 5-3.2.2. SUBSTANTIATION: No technique# follow. Therefore adds nothing m standard. COMMITTEE ACTION: Reject. COMM1TFEE STATEMENT: See Committee Action on Public Comment 472-587 (Log #235).

(Log # S05) 472- 389- (5-S.~.2): Accept in Principle SUBMrlWER: Bruna Mark Wilson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: None. SUBSTANTIATION: Incomplete sentence. Objective refers to "each of the following," yet nothing follows. Is there something missing here? COMMrFrEEACTION: Accept in Principle. COMMITTEE STATEMENT: See Commi.uee Action on Public Comment 472-387 (Log #255).

( ~ # lS2) 472- ~90 - (5-$.~2): Accept in principle SUBMrI'rER: Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add the following control techniques to 5-3.2.2: "

(a) Absorption; (b) Dilution; (c) Dikes, Dams, and Retention; (d) Vapo r Disp6r~on; (e) Overpacking; (f) Plug and Patch; (g) Transfer;, (h) Vapor Suppression; (i) Venting; (D Controlled Burning; (k) Disp:ersion, Surface Active Agents, and Biological Additives; (!) Fiai'ing; (m) Gelation; (n) N'euualization; (o') Venting and Burning. SUBSTANTIATION: The compe.tency is incomplete without ~dae following techniques," which could logically come from 471. COMMIWrEE ACTION: Accept in Px~nci.ple. COMMITTEE STATEMENT: See Comnmtee Action on Public Comment 472-38 7 (Log # ~ ) .

( t . 8 # ~71) 472- 391 - (5-$.2.2): Accept in Principle SUBMITrER: c .J . W~ght, Union Pacific Raih-oad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add the list of techniques called for in the competency by the word following. SUBSTANTIATION: Need to clarify the intent of the competency. COMM1TrEEACTION: Accept in Principle. ODMM1TrEE STATEMENT: See Committee Action on Public Comment 472-387 (Log #235).

&52

N F P A 472 - - A92 T C D

(tog # ~ ) 472- 392 - (5-3.2.2): ~ t in Principle S U B ~ Gregory G. Noll~ Hildebrand & N011 Assoc., Inc. COMMENT ON PROPOSAL NO. : 472-1 ' . ' RECOMMENDATION: Revise text:

~rechniques required for harm_at control t~ be listed are not listed within theobjectfve." " ' SUBSTANTIATION: Editorial. COMMITIT.EACTION: Accept in Principle. COMMITTEE STATEMENT: See Committee Action on Public Comment 472-387 (Log #235).

(Log # 806) 472- 593 - (5-5.3): Reject S t m M r r r s ~ eruno M~k WUson, Orego. State F~e M ~ h ~ COMMENT ON PROPOSAL NO.: 472:1 RECOMMENDATION: Change "determine" to "identify'. SUBSTANTIATION: "Determine" cannot objectively be measured. COMMrrrEEACTION: Reject. • COMMITTEE STATEMENT: See Commiuee Action on Public Comment 472-394 (Log #184).

4~2- 394 - (5-3.3): Accept in Principle " (Log # 184) SUBMrrrER: Michael E. Boyle, lrvine, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the following paragraph:

"Select the Personal protective equipment required for a 8liven action option. The incident Commander shall, given situauom with known andunknown ha~rdous materials, determine the appmpri- ' ate personal protective equipment for the action options specified in the plan of action in each situation." SUBSTANTIATION: The selection of ]personal protective equipment is beyond the training and exper13se of the lnddent Com- mander who is trained to the FirstResponder Operational level p lm Incident Command Training. If specialized pmiective equipment is required to abate the h 2 ~ r d , the appropriate choice of protective equipment should be the r~ponsibility of the I4ar~rdous Materials Tean~ C O M M r r r E E A C r I O N : Ao'.ept in Principle.

Change 5-3.5 to read as follows: "Approve the level of personal protective equipment required. . . " In the second sentence change "determine" to "approve'.

COMMITTEE STATEMENT: The incident commander has a responsibility to see that personnel are pro[~rly protected. At inctdents that are being handled at the operational level that responsibility may entirely fall upon the i naden t commander. The incident commander must know whether &re protective dothin 8" and e ~ i p m e n t available at the operatiofial level is adequate or not. At Inodents where hazmat techn[dans are awailable they obviously" would be a resource to determine the appropriate level of protective clothing. The incident commander would in all likelihood depend on their recommendation in approving the protective doth ing that would be required to carry out a particular ;action option.

(Log # 2s6) 472- 395 - (5-3.3): Reject SUBMITTER: Gerald L Grey, Redwood, CA .COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Delete this competency. SUBSTANTIATION: This shouid not be a requi rementof an indden t commander, but a competency of the b ~ r d o u s materials technician. Since by law (1910.120) the minimum level of protection for responding offensively to a hazardous mter ia l s inddent is, level B (spl~h protection) and first responders are defensive Persons, the indden t commander does not need m determine clothing requiremenu flail he / she has available are first responders. ff technicians are available,.they should be making the selecuon of their dothing, not some person that doem't haveto wear the . dothing . . . . • ff this comment is accepted by the commilxee, then 5-1.3(b)(5) should be deleted as it is the 8oal for this competency. ' , COMMITTEE ACTION: Reject. COMMrIWEE STATEMENT: See CommitteeAction and Statement on Public Comment 472-594 (Log #184),

I

'(Log # 9) 472- 396- (5-3.5): Accept in Prindple SUBMrlWE~. Robert A. Green, Riverside County Fire Chiefs' Assoc., CA COMMENT ON PROIN3SAL NO.: 472-I RECOMMENDATION: Delete the following paragraph:

-'Select the personal protective equipment required for a given action option. The Indden t Commander Jhal[; given situations with known and unknown har~rdous materials, determine the appropriate personal protective equipment for the action options specified in the klan of action in each dmadon." SUBSTANTIATION: The selection of personal protective equipment is beyond the eaperdse of the Incident Commander. I f spedalized protective equipment is need as with unknown ha~rdous matedais, the appropriate choice of protective equipment should be the responsibility of the Hazmat team members .

If only regular fire fighters are being utilized, then full structural protective equipment Including SC~A's should be utilized, when

• dealing withhazardous materials. COMMITrEEACTION: Accept in Prindple. COMMITrEE STATEMENT: See the Commiuee Action and Statement on Public Comment 472-394 (Log #184).

, 0

(Log # 8o7) 472- 597- (5-3.3.1):" Accept In Prindple SUBMITrER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-~I RF.XIOMMENDATION: None. SUBSTANTIATION* Incomplete sentence. Objective states "...and match both the equipment required for each level and,the condb t ions under which each level is used. ~ Match them with what? COMMrlWEEACTION: Accept in Principle.

Delete "ooth" and change to read: " . . . each level with the condit ion&.."

COMMrlWEE STATEMENT: The Committee agreed that the statement was dot dear.

472- ~JS- (5-$.$.1.1 thru 5-$.$.8): Accept ' (Log # 272) SUBMrrrER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Correct the number ing associated with '¢.L3.3.I.I thru 5-3.3.1.8 ~ to read "5-3.3.1 thru 5-$.3.8" to correspond with its position in the standard. . SUBSTANTIATION: Correct typosraphical error. C O M M r r r E E ACTION: .Accept.

(Log # s08i 472- SO9 - (5-$.$.1.2): Accept SUBMrIWER:: Bruno Mark W'dson, Oregon State Fn'e Marshal COMMENT ON PROPOSAL NO.: 472--1 RECOMMENDATION: Delete: "...with the term ~. .' SUBSTANTIATION: Redundant. COMMrITEE ACTION: Accept.

(Log# ]SS) 472-400- (5-3.$.1.2): Reject SUBMITI]FJ~ Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: .Revise 5-3.3..1.2 to mad:

5-3.3.1.2 Define the foltowingterms assodated with chemical protective clothing:

(a) Degradation (b) Penetration' (c) Permeation

SUBSTANTIATION: Penetration is no t considered in the selection of CPC, and the proposed revision will permit the inclusion of all three terms in the competency. COMMITITJE ACTION: Reject.' COMMITTEE STATEMENT: The Committee felt the terms used did impact on the considerations for selecting CPC

NFPA 4 7 2 n A92 TCD

(Log # ~ ) 472- 401 - (5-5.3.1.1): Reject , SUBMrrTER: Gerald L Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete this competency. SUBSTANTIATION: This should not be a requirement of an incident commander, but a competency of the hazardous materials technician. Since by law (1910.120) the minimum level of protection for responding offensively to a hazardous materials incident is level B (splash protecti6n) and first responders are defensive persons, the incident commander does not need to determine clothing requirements if all he /she has available are first respondem If technlclans are available, they should be making the selection of their clothing, not some person that .doem't have to wear the clothing.

If this comment is accepted by the committee, then 5-1.5(b) (5) - should be deleted as it is the goal for this competency.

COMMFFrEE ACTION: Reject. COMMI~ STATEMENT: The Committee felt that the incident commander should have a knowledg e of the levels of chemical protection.

(Log# 258) 472- 402 - (5,5.5.1.2): Reject SUBMrI 'TE~ Gerald L Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete this competency. SUBSTANTIATION: This should not be a requirement of an incident commander, but a competency of the hazardous materials technician. Since by law (1910.120) the minimum level of protection for responding offensively to a hazardous materials incident is level B (splash protection) and first responders are defensive persons, the Incident commander does not need to determine dothing degradation..If technicians are available with splash clothing, they would be knowledgeable of the impact and sisnifi- canoe of degradation, penetration, and permeation on their dothing.

If this comment isaccepted by the committee, then 5-1.5(b)(5) should be deleted as it is the goal for this competency. COMMrrrEE ACTION: Reject. COMMITFEE STATEMENT: The Commiuee felt that the incident commander should have some knowledge of CPC and particularly of the terrm listed in 5-5.5.1.1.

(.Log# S]O) 472- 405 - (5-5.5.1.4): Accept SUBMITTER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472--1 RECOMMENDATION: Recommend: "Identify safety considerations for personnel wearing vapor protective and liquid splash proteciive clothing.* . " . - SUBSTANTIATION: "Considerations* is more appropriate here than "procedures~ incident commanders need to know the same about liquid splash protective clothing, not just about vapor - protective clothing. COMMITrgg ACTION: Accept.

(Log # 240) 472-406- (5-3.3.1.4): Reject " " " SUBMITIT.R: Gerald L. Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Delete this competency. SUBSTANTIATION: This should not be a requirement of an incident commander, but a competency of the har~rdous materials technldan and the hazardous materials safety officer.

If this comment is accepted by the committee, then 5-1.5(b)(5) should be deleted as it is the ~ for this competency. COMMITTEE ACTION: Reject. COMMITTEE STATEMF2Cr: The Committee feels that it is . important for the incdient commander to have an understanding of the safety procedures for persons wearing vapor protective clothing.

(Log # 29) 472- 407 - (5-5.3.1.4): Accept in Part $UBMrrrER: Gregory G. Noll, Hilderbrand & Noll Assoc. Inc. COMMENT O N PROPOSAL NO.: 472-1

I RECOMMENDATION: Revise to read:, "Identify the safety pmcechres for personnel wearing chemical and

high temperature protective dothing.* SUBSTANTIATION: Heat stress and related safety concerns are not limited to only vapor protective dothing. COMMIIWEEACTION: Accept in Part.

I Only add the term *high temperature'. COMMrrI 'EE STATEMENT: T h e Committee feels thatthe competency with the term high temperature is appropriate.

(Log # 809) 472- 403 - (5.3.3.1.3): Reject SUBMITrER: Bruno Mark W'dson, Oregon State gwe Marshal COMMENT O N PROPOSAL NO.: 4~2-] RECOMMENDATION: Recommend:

"Identify three indications of material.degradatlon of chemical , protective clothing after chemical contact." ' SUBSTANTIATION: Eliminates unnecessary verhiage [i.e., "at least', "(3)*]; corrects misspelling of "clohing". COMMITTEE AC'rlON: Reject. . COMMrlWEE STATEMENT: See Committee Action and Statement on Public Comment 472-383 (Log #185).

(Log # 186) 472- 408 - (5.3.3.1.5): Accept SUBMrlWER: Michael E. Boyle, h-vine, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise paragraph m read:

~ldentffy the physiological and psychological stresses that can affect users of spedalized protective clothinl~." SUBbWANTIATION: The term ~phy~ological" is a more descriptive term than "physical and may result in the reader broadening the aspects of their observation of persons utilizing chemical protective clothing. COMMIITEE ACTION: Accept

(Log # 2s9) 472- 404 - (5-3.5.1.5): Accept SUBMrrrER: Gerald L Grey, Redwood City, CA COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Delete this competency. SUBSTANTIATION: This should not be a requirement of an incident commander, but a competency of the hazardous materials technician. Since by law (I 910.I 20) the minimum level of protection for responding offensively m a hazardous ma/erlab incident is level B (splash protection) and first responders are defensive persons, the incident commander does not need to determine dothing degradation. If technicians are available with splash clothing, they would be knowledgeable of the indications of material degradation of their clothing after chemical contact.,

If this comment is accepted by the committee, then 5.1.3(b)(3) should be deleted as it is the goal for this competency.

If this comment is rejected by the committee, the word dothing is

~ g ~ ~ ACTION: Accept

(Log # 241) 472-409-(5-3.3.1.5): Reject SUBMrI ' rE~ Gerald L Grey, Redwood Oty, CA COMMENT ON PROPOSAL NO.: 472-I RECOMI~ATION: Delete this competency. SUBSTANTIATION: This should not be a requirement of an incident commander, but a competency of the hazardous materials technician and the hazardous materials safety officer.

If this comment is accepted b? the committee, then 5-1.3(b)(3) should be deleted as it is the ~ d for this competency. COMMITTEE ACTION: Reject. C O ~ STATEMENT: The Committee feels that it is important fo r the incidem commander to have an understanding of the possible impacts of wearing specialized protective clothing.

354

N F P A 4 7 2 m A 9 2 T C D

(Log# 10) 472- 410'- (5-5.5.1.5): Accept SUBMrFITJU Robert A. Green, Riverside County F'tre Chiefs' Assoc. COMMENT ON PROPOSAL NO.: 472-1

I RECOMM ATION: Revise text: Should read, "Identify the physiological and psychological stresses

that can affect users of specL~lized protective dothing:, -

SUBSTANTIATION: This we feel is only an editorial change b~, deleting the word aphyaical" and replacing i t with "Physiological'. COMMrrTEE ACTION: Accept.

(Log# S11) 472- 411 - (5-3.3.1.6): Reject Oregon State Fh'e Marshal SUBMrrIT, R= Bruno Mark Wilson, COMMENT ON PROPOSAL'NO.: 472--1 RECOMMENDATION: Move to Hrst Respnder Operations level. SUBSTANTIATION: Incident commanders should not be micro- - mana~in~g their incidents. This level of detail should be le~ to techmcal-functi0ns at the Operations level, not to the incident commander. COMMITrEE ACTION: ReJect..'

COMMITTEE STATEMENT: The Commitr~-e does not feel that it is

appropriate to move this competency to the operational level. Also . see Committee Action on Public Comment |72-41.2 (.Log #242).

t t

(Log # 242) 472- 412- (5-3.3.1.6): Accept ' "

SUBMITYER: Gerald L Grey, Redwood O~,, CA COMMENT ON PROPOSAL NO.: 472-I

I RECOMMENDATION: Delete this competency. , . ' .

SUBSTANTIATION: This should not be a requirement of an . incident commander, but a comDe.tency of the h~7"~rdous materials technician, the hazardous materials technical reference, and the ~ h27~rdous materiah safety officer.

It'this comment is accepted by the committee~ then 5-1.3(h)i3) should be deleted as it is the goal for this competency. COMMITTEE ACTION: Accept.

(Los# 187) 472- 413 - (5-3.3.1.6): Accept "~ SUBMITTER: Michael F_. Boyle, Irvine, CA COMMENT ON PROPOSAL NO.: 4724 RECOMMENDATION." Delete the following pmag~ph: '

"Given various b~=trdous materials, deter~mne the appropriate "

chemical protective clothing for a given action option using • chemical compatibility chart&" SUBSTANTIATION: Determining approplfiate chemical protective clothing exceeds the sco~. of practice and expertise of the Inrtdent Commander. The identifi,-~tion of appropj~ate chemical protective clothing should be the responsibility of individuah trained to the Hazardous Materials Technician Level. " . .

COMMITIT.E ACTION: Accept.

(Log#U) 472- 414 - (5-3.3.1.6): Accept SUBMrlWER: Robert A. Green, Riverside County Fire Chiefs' Assoc., CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the foilowin~ paragraph:

" G i v e n v a r i o u s ha~mrdo t t s m a t e r i a l $ , deterrmne the appropriate chemical protective clothing for a given a~ion option using chemical compatibility chart&" " .

SUBSTANTIATION: Determining the appropriate chemical protective clothing is beyond the scope and expertise of the Incident Commander. The determination of the appropriate chemical protective clothing that is utilized, shouldbe within the scope and responsibilities of the Hazardous Materials Technician Level. COMMITTEE ACTION: Accept.

(Log # 24s) • 472- 415 - (5-$.3.1.7): Accept SUBMrlWER: Gerald L (key, Redwood City, CA

. C O M M E N T ON PROPOSAL NO.: 472-1 I REODMMENDATION: Delete this competency. " . .

SUBSTANTIATION: ~ should not be a t~luirement ot an .. incident commander, but a competency of the h~7~rdomt materials technician, the haTJrdous materials technical reference, and the b~,~rdous materials safety officer.

If this comment is acceptedby the committee, then 5-1.3(b)($) should be deleted as it is the goal for this competency." COMMITrF~ ACTION: Accept.

, (Log # 812) 472- 416 - (5-$.$.1.8): Rejea S u B M r I ' I T ~ Bruno Mark Wdson, Oregon State Fire Marshal COMMENT ON PROPO~LL NO.: 472-] RECOMMENDATION: None. :.

SUBSTANTIATION: How is this objective significantly different from TCR 5-3.$.1.6? COMMITTEE ACTION: Reject. COMMITrE~ STATEMENT: See Committee Action on Public Comment 472-417 (Log #244).

(Log # 244) 472-417= (5-3.5.1.8): Accept S U B ~ Gerald L Grey, Redwood City, CA COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete this competency. SUIkN'TANTIATION: This should not be a requirement of an incident commander, but a coml~,tency of the b~rJrdous materials technician, the hazardous materials technical reference, and the h ~ n t o u s materials safety officer. •

If this comment is accepted by the committee, then 5-1.3(b) (3) should be deleted as it is the goal for this competency. COMMITrEEACTION: Accept. " , •

: . (Log,# 18S) 472- 418 - (5-$.$.1.8): Accept SUBMIWrER: Michael F_. Boyle, Irvine, CA COMMENT ON PROPOSAL NO.: 472-1

RECOMMENDATION: Delete the following paragraph: "Gi.'ven examples of various h ~ r d o u s m a ~ , determine t h e

appropriate personal protective clothing construction materials tor a gi,~en action option using chemical compatibility charts." S ~ A N T I A T I O N : Determining appropriate chemical protective dothing exceeds the scope of practice and expertise of the incident Commander. The identification of appropriate chemical pro~ctive dothing should be the responsibility o f individuals trainea to me I - l~rdous Materials Tedmician Level. . COMMITIT.E ACTION: Accept. "

(Log # 12) 472- 419 ~- (5-$.$.1.8): Accept . . SUBMITrF~ Robert A. Green, Riverside County Fire Chiefs' Assoc. COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the followingparagraph:

"Given examples of variotm h ~ r d o u s materials, determine the appropriate personal protective clothing construction materials for a given action option using chemichl compatibility charts." S ~ A N T I A ~ I O N : Determining the appropriate personal protective clothing construction materials by using compatibility charts is beyond the scope and expertise of the Incident Corn- ' .

mander. This determination should be within the scope and -

responsibilities of the Hazardous Materials Technician Level

COMMITIT.EACTION: Accept. "'

r

3 5 5

NFPA 472 1 A92 TCD

(Log # 81s) 472- 420- (5.5.4.5(i)): Accept S U B ~ Bruno MarkW'dson, Oregon State Fire Marst~ COMMENT ON PROPOSAL NO.: 472-1

I RF.XX)MMENDATION: Change to: "Provide fire protection services when appropriate;" SUBSTANTIATION: Provides a broader cat~ory than simply "fire suppression: Sometimes fire exting-i~bment ts the wrong action. COMMITrEL ACTION: Accept. ,

(Lo~#281) 472- 426 - (5.3.4.4): Ar.cept SUBMITrER: C.J. Wright, Unlon Pacific Railroad COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Change the word "effect" to read aeffecttve-

/

~ T A N T I A T I O N : ¢~u-ify intent of competency. COMMITrgg ACTION: Accept.

(Log # 814) 472- 421 - (5-3.4.3(o)(New)): Accept SUBlVul-s J~,,R: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Add: "Provide Operational-level ha-ard control services;" SUBSTANTIATION: Identifies who provides first-response and mutual aid resources. COMMrITEE ACTION: Accept

' (Log # 81S) 472- 422 - (5-S.4.3(p)(New)): Accept SUBMrI'rER: Bruno Mark Wilson, Oregon Slate Fire Marshal

• COMMENT ON PROPOSAL NO.: 472-] I RECOMMENDATION: Add: "Provide Technlrlan-level hazard

mitigation services;" ' SUBSTANTIATION: Identifies who provides hazardom materials

r e s o u r c e s .

COMMI3WE~ ACTION: Accept.

(Log# Sle) 472- 423 - (5.3.4.5(q)): Reject. SUBMrI'IT.R: Bruno Mark W'flson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-] .. RECOMMENDATION: Add: ~Provlde Specialist-level h~rJrd . control services;" SUBSTANTIATION: Identifies who provides harJrdous materials ~ ~aliat resources. •

MrI ' rEE ACTION: Reject. COMMrI'rEE STATEMENT: This level isnot addressed within the standard.

(t.g#S17) 472- 424 - (5.3.4.3(r) (New)): Accept SUBMITYFAh Bruno Mark Wilson, Oregon State FLre Marshal COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Add: "Provide environmental remedial action (adeanup~) servicesf SUBSTANTIATION: Identifies who provides site deanup resources. COMMITTEE ACTION: Accept. ' '

472- 425 - (5-3.4.4): Reject , SUBMITrER: HersheH Stafford, Exxon Chemical Americas (Log # 478) Raymond P. Beaudry, DuPont CO. (Log # 866) John M. Cobum, Occidental Ch~micaICorp. (Log# 1112) Michael E. Lydcn, The Chlorine Institute, Inc. (Log # 580)

~ oyce ~- Stratis, FMC Corp. (Log # 596) ohn T. Higgins, Dow Coming Corp. (Log # 706)

William A. Levy, Rhone-Poulenc Ag Co. (Log # 618) Samuel A. Pearnmn, Martinsville, VA (Log # 1023) COMMENT ON PROPOSAL NO.: 472-I RECOMMENDATION: Identify the effect of an action option on. sthI~sT~qTIATIn tial outcomes.

ON: Training should not be to determine a process but how to accomplish the competency. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that it is important for the incident commander to understand the process of ev~uating the progress of the action options that may be chosen.

(Log # 5O) 472- 427 - (53.4.4): Accept SUBMrrrER: Gregory G. Noll, Hildebrand & Noll Aa~c. Inc~ COMMENT ON PROPOSAL N O - 472-1 ' RECOMMENDATION: Change aefl'ect" to "effectivenesL" SUBSTANTIATION: Editorial correction COMMITTEE ACTION Accept

472- 428- (5-3.4.5): Reject S U B ~ Samuel A. Pearman, Martinsville, VA (Log # 1024) W'dIiam A. Levy, Rhone-Poulenc A 8 Co. (Log_# 619) Raymond P. Beandry, DuPont CO. (Log # 867) Hershell Stafford, Exxon Chemical Ameriam (Log # 479) John M. Coburn, Occidental Chemical Corp. (Log # 1113) Joyce A. SumS, FMC Corp. (Log # 597) John T. His~ins, Dow Coming Corp. (Log # 707) Michael F,, Lyden, The Chlorine Institute, Inc. (Log# 381) COMMENT ON PROPOSAL NO.: 472-1 ' ; RECOMMENDATION: Revise text:

"Understand the r,~uirements for a safety briefing ...." SUBSTANTIATION: The incident commander does not have to give the safety Ixieflng. He/she only has to know the requirements to assure a proper briefing is given by the designated safety officer.

• CoMMrXTEE ACTION: -Reject. COMMITIT.E STATEMENT: The Committee feels that the

mposed change would change the intent of the competency. The dent commander needs to understand what is involved in

relation to the safety briefing whether it is delegated to someone else or not. /

(Lo s # 280) 472-429- (5-4.1): . .Ar~pt SUBMrrTER: c .J . Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1

[ ~XX)MMENDATION: Remove the word "including" after the parenthesis in the first sentence. SUBSTANTIATION: Word seems redundant. COMMrlWEE ACTION: Accept. .

(L~g# 818) 472- 430 - (5-4.1): Accept in Principle SUBMIqWF~ Bruno Mark W'dson, Oregon State Fire MarAbal COMMENT ON PROPOSAL NO.: 472-3 RECOMMENDATION: None. SUBSTANTIATION: The phrase "local integrated emergency management plan" is not dL-fined. Is this different from Wemergency response plan" defined in 1-2?

! ¢ ~ M M r l W E E A C ~ 0 N : Accept in Principle. Add ~ e term e.g.," following resources and in 5.1.3(c) 1, and

5-4.1.1. COMMrI'IT.E STATEMENT: The Committee feels this change will clarify the competency. (ALso see Public Comment 472-451 (Log #1s4)).

(Log# IS4) 472- 4S1 - (5-4.1): Accept in Principle S U B ~ Max H. McRae, Houston Fire Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RFX:OMMEJqDATION: Change "local integrated emergency management plan" to local emergency response pla~. SUB~.ANT~. TION: Local emergency response plan has been used throughout the document and is the term ~ in SARA and I see no reason to change at this point, especially without the new term being defined in the definiuons. COMMITrgEAGWION: Accept in Principle.

&56


Also add the following appendix to 5~1.2 A-5-1.2 The following are the typical duties and responsibilities of

the Incident Commander at a b = ~ t o m material inddent . These. duties and responsibilities may be performed directly or delegated to other response personnel as nec~mry.

(a) Analysis Activides • * classify and ldentffy unknown materials • • verify known materials

• monitor changes in climatic conditions ' • identify contaminated _people and equipment " • establksh environmenuil monitoring ', • interpret the dam collected from ewvironmental monitoring

(b) Planning Activities " , • develop a plan of action for the incident • develop a plan of action for activities in the control zones '. develop an incident safety plan - ' " • seek technical advice

evaluate and recommend public pv>tective actions coordinate handling, storage, and transfer of containments determine persuna~pmtective equipment compatibility organize and supervise assigned pei'sonnel to control site

access provide required emergency medical services (c) Implementation Activities

• conduct safety briefings • implement the plan of action for the incident • implement the incident safety plan .? oversee placement of control zones, • supervise entry operations ", ; direct rescue operations

maifitain communications and coo1~iination during the incident , • p/ovide medical monitoring of enu7 personnel before and

after entry . " • protect personnel from physical, environmental and safety

hamrds/exposures • provide information for public andprlvate agencies • enforce recognized safe operationalpractices • ensure that injured or exposed ind!ividuals are decontami-

nated prior to departure from the b~rd siite , ' • . separate and keep track of potentially contaminated persons • track persons passing through the decontamination corridor • ensure proper decontamination activities are conducted • coordinate transfer of decontaminated patients

(d) Evaluation Activities • evaluate progress of the actions taken and modify as

necessary • recognize deviations from the lncictent safety plan and any

dangerous situations • alter, suspend, or terminate any activity that may be judsed

unsafe • keep required records for litigation ~nd documentation , • ensure medical related exposure n.~ords are maintained

C O M M r r r E E STATEMENT: The Committee agrees with the submitter and also feels that a list of the typical dlaties and responsibilities for the Incident Commander shou~i be added to the • Appendix.

t

472- 452 - (5-4.1.1): Accept "

SUBMrFrER: John !~L Cobum, Occidenud Chemical Corp. (Log# 1114) Raymond P. Beaudry, DuPont CO. (Log # 808) Samuel A. Pearrnan, Martlnsville, VA (Log # 1025) John T. Higgins, Dow Coming Corp. (Log# 708) W'dliam A. Levy, Rhone-Poulenc Ag Co. (Log # 620) Hershell Stafford, Exxon Chemical Amerkm (Log # 480)

A. Stratts, FMC Corp. (LOg# 598) 1 E. Lyden, The Chlorine Institute, Inc. (Log # 382)

COMMENT O N PROPOSAL NO.: 472-1 I RECOMMENDATION: Delete and renumber Items that follow. I SUBSTANTIATION: If the plans are not available, and the incident

commander is not knowledgeable of the plan, knowledge of the plans location will not help at the scene of an emergency. Imple- mentation of the plan ks covered in mbseodon 5-4.1.3. ' C o M M n w E E ACTION: Accept. . -

(Log # m9) 472- 435- (5-4.].2): Accept

4

SUBMITrER: Bruno Mark Wilson, Oregon State F'Lre Marshal COMMENT O N PROPOSAL NO.: 472-] RECOMMENDATION: Recommend: "Identify the process for o b ~ n i n 8 dean-up and restoration services in the i_ocal emergency responseplan..." ' ' SUBSTANTIATION: "Obudning" implies a greater asmwance of a response than mere ~nofification ~'. "Services* rather than ~e- sot/rces* implies the desired action, not merely assets. COMMITTEE ACTION: Ac~. pt.

(LOS# Sl) 472- 434 - (5-4.1.2): Accept SUBMrIWF~ Gregory G. NoH, Hildebrand & Noll A~ioc. Inc. COMMENT O N PROPOSAL NO.: 472-1 ' '

[ REFJDMMENDATION: Change competency/insert word to read: "Identify the process and procedures for notifying..."

SUBSTANTIATION: Individual should have knowledge of both the process and specific organizational procedures for these notifications. Knowledge of only the process may not properly access these. r e s o u r c e & C O M M n W I ~ ACTION: Accept.

(Log #820) 472- 435 - (5-4.1.5): Accept ! SUBMrlWER: Bruno Mark Wdson, Oregon State FLre Marshal COMMENT O N PROPOSAL NO.: .472:1 ' ' •

I RECOMMENDATION: Delete lines under text. Delete both uses of the word "any; SUBSTANTIATION: Use of "any" ht, re is far too indusive, and di£ficult to administer and measure. Are the lines under the text ~ e o ~ a n t s of indications of previous revisions? .

ACTION: Accept.

CL 821i 472- 436 - (5-4.1.4): Reject SUBMrrTEi~ Bruno "Mark Wilson, Oregon State Fire Manhal C O M M E N T O N PROPOSAL NO.: 472-1 RECOMMENDATION: Recommend:

"Identify the elements of the local emergency response plan." SUBbWANTIATION: Competency in this area can be shown without having to provide' the actual documents in each case. COMMI'IWEE ACTION: Reject. COMMITTEE STATEMENT: The Committee believes that it ks important for the incident commander to have an understanding of the- methods involved in implementing the local emergency response plans and any other required notifications . . . .

472- 437 - (5-4.1.4): Reject SUBMITITJ~ John M. Colmm, Occidental Chemical Cot F (Log# 1115) : Samuel A. Pearman, Martinsvilie, VA (Log # 1026) , Raymond P. Beaudt7, DuPont Co. (Log # 869) W'dliam A. Levy, Rhone-Poulenc AgCo. (Log # 621) Joyce A. strum, m c Corp. ( I ~ # 599) . ~ , . , Hershell Stafford, Exxon Chemical Americas ~Log w ~ l John T. Higgins, Dow Coming Corp. (Log # 709) Michael E. Lyden, The Chlorine Institute, Inc. (Log # 383) COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete text. Renumber sections that follow. SUBSTANTIATION: This section does not add any value to the knowledge of the incident mmmander . COMMITTEEAL'rION: Reject. , ' . COMMITrEJE STATEMENT: This is not necessary since the nothing was deleted. " '

N F P A 472 - - A92 T C D

(Log # s22) 472-438- (5-4.1.5): Accept in Principle SUBMITIT.~ Bruno Mark Wilson, O r e ~ n State Fire Marshal COMMENT ON PROPOSAL NO.: 472-~- " " RECOMMENDATION: Delete: "Given a, copy of the regional response plan," , . SUBSTANTIATION: Competency in this area can be shown without having to provide the actual documents in each case. Also, ~P~-'gional Response Team" is not defined in 1-~ is this a federal, state, provincial-, or Io~I designation - or merely generic?

I COMMrrTEEACTION: Accept in Principle. Delete Section 54.1.5.

COMMr]WEE STATEMENT: The Committee feels that it is appropriate to delete the entire section because the intent is accomplished with 5-4.1.9.

472- 443- (54.1.8): Accept • SUBMITrER: John M. Cobum, Occidental Chemical Corp.

( ~ # 1117) CO #871 Raymond P. Beaudry, DuPont . (Log # ! ) John T..Higgins, Dow Coming Corp. (Log # 710) . Samuel A. Pearman, Martinsville, VA (Log # 1028) William,A. Levy, Rhone-Poulenc Ag Co. (Log # 623) Joyce A. Stratts, FMC Corp. (Log # e0D Hershell Stafford, Exxon Chemical'Americas (Log # 483) Michael E. Lyden, The Chlorine Institute, Inc. (Log # 385) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete text. Renumber subsequent section& . SUBSTANTIATION: This has no value at an emergency response incident. The incident commander may or may not prepare subsequent reports following the incident. COMMITrEg ACTION: Accept.

472-439- (54.1.5): Rejea SUBMI'FI"ER: Rayniond P. Beaudry, DuPont CO. (Log # 870) Samuel/L P ~ , Martinsville, VA (Log # 1027) John ]VL Coburn, O ~ d e n ~ l C h e ~ l Corp. (Log# 1116) .joyce & Stratis, FMC Corp. (Log # 600) W'flliam A. Levy, Rhone-Poulenc Ag Co. (Log # 622) HersheH Stafford, Exxon Chemical Americas (Log # 482) Miciaael E. Lyden, The Chlorine Institute, Inc. (Log # 384) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Given a copy of the state, regional, and federal response plans, identify the resources available. SUBSTANTIATION: To clarify the requirement COMMIWrEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action and Statement on Public Comment 472-438 (Log #822).

472- 440 - (5-4.1.6): Reject SUBMITrER: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete text. SUBSTANTIATION: Have no idea what this means, much less how to measure an individual's competency in it. COMMIWrEE ACTION: Reject. COMMIWrEE STATEMENT: The Committee feels that the incident commander needs to have an understanding of how to implement the portions of the incident comm~nd system necessary for the control of the incident.

(Log # 824) 472- 441 - (54.1.7): Reject SUBMITIT.R: Bruno Mark Wilson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete text. SUBSTANTIATION: Not applicable to the scope of an emergency' response standard. COMMrITEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that it ls necessary for the incident commander to have knowledge of the agencies that are involved in the regulation of h~r-~rdous materials.

(Log # 82s) 472- 442- (5-4.1.8): Reject SUBMITTER: Bruno Mark Wilson, Oregon State F'n'e Marshal COMMENT ON PROPOSAL NO.- 472-] RECOMMENDATION: Recommend: ~oiven an example of a minimally-compliant fixed site hazardous substance inventory supplied in accordance with a national, state, p ~ c i a l or local legislative requirement, identify sources that can be used to obtain additional information on the substances stored at the site." SUBSTANTIATION: AJ written in the TCR, this objective would require by# separate tasks: ~determine" (which is not measurable) aria "identify." Also, other national governments using this standard may not refer to equivalent legislation as ~right-to-know". , COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Committee Action on Public Comment 472A.A. a . (Log #135). ,

(Log # 135) 472- 444- (54.1.8): A c c e p t t

H. M'cRae, Houston Fire Dept., TX SUBMrFrER: Max COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete 5-4.1.8. SUBSTANTIATION: This competency seems out of place in this document. Additional information from Tier II or similar reports is

o b t a i n ~ e analysis of a hazmat incident. The not additiorial " ~ ~informauon referred to in the competency is requested

• when a Tier II i, received, not after an incident occurs. COMMrrrEE ACTION: Accept

472- 44s- (54.Zla): Reject (Log # s2o) SUBMITIT.R: Bruno Mark W'dson, Oregon State Z ~ COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Recommend:

~ldentffy the three element~ of termination procedures." SUBSTANTIATION: AJumming the Co n ~ t t e e is here looking for "debriefings", "post-incident analy.sis', and crit ique, it should be noted that these are not necessardy sequential: post-incident analysis - a responsibility of the ICS planning function - should be ongoing throughout the incident, not beginning after the debriefings have been conducted. COMMrrrEE ACTION: Reject. C O ~ STATEMENT: It was not the Committee's intent that the steps would necessarily be sequential or that steps wouldn't be taken prior to the termination o f the incident to collect needed information.

i

(Log # S27) 472- 4461- (5-4.ZL2): Accept SUBMIT~J~ Bruno Mark Wilson, Oregon State Z ~ COMMENT ON PROPOSAL NO.: 472-] RECOMMENDATION: Recommend: ~dent i~ the procedures for conducting incident debriefings at h hazardous materials incident." SUBSTANTIATION:" t~anges ~debriefing ~ from singular to plural. Frequently response personnel are coming and going from incident scenes, usually a function of ~ changes necessitated by longer incident& Multiple debt'iefings must be conducted to meet the goals of proper terminatiofi procedures. COMMrrIv~R ACTION: Accept,. , .

(Log # 82S) 472- 447 - (5-4.~,1.$): Accept in Principle SUBMITrF.R: Bruno Mark Wilson, Oregon State F'we Marshal COMMENT ON PROPOSAL NO.: 472--1

i RLCX)MMENDATION: Recommend: qdentify the steps in transferring command as prescribed in the local emergency response plan or the organization's standard operating procedures." SUBSTANWIATION: Many response personnel on emergency incidents are given delegated "authority" by the Incident Com- mander. This is i~enerally not transferable without approval of the IC. ~ C , o ~ d " ts t ransfert~ from one individual to another. This phenomenon occurs throughout the incident, not just in "the transition from the emergency phase to the post-emergency phase".

i Recommended change aim corrects miupellin 8 of ~'anafering: COMMrrrFJgACTION: Accept in Prindple.

Chanse " c o ~ d " Ix) "authority'.

f

I

N F P A 4 7 2 - - A 9 2 T C D

COMMITTEE STATEMENT: The Committee feels that authofiW is a more appropriate term than command. "

472- 448- (5-5.1.1): Reject • . (L°g# 711) SUBMH'rER: J o h n T. Higgins, Dow Coming Corp. COMMENT ON PROPOSAL NO.: 472-1

• RECOMMENDATION: Partially reword the item as follows: -. "Identify procedures for evaluating ...." '

SUBSTANTIATION: Wording as original b, written suggests that there specific steps which must be followed. COMMITtEE.ACTION: Reject. . , COMMITTEE STATEMENT: See Commiu~.-e Action on Public Comment 472-77 (Log #118).

472- 449'- (5-5.1.1): Accept - ' SUBMITrER: John M. Cobum, Occidental Chemical Corp. (Log# 1118) -- " " ' *---n~.m " #484 Hershell Stafford, Exxon unermcm ru,,~ " ( L o g )

• W'flliam A. Levy, Rhone-Poulenc Ag Co. ( Ix~ # 624) Joyce A. Swatis, FMC Corp~ (Log # 602) Samuel b. Pearman, Martinsville, VA (Log# 1029) Raymond P. Beaudw, DuPont Co. (Log # 8'72) Michael E. Lyden, The Chlorine Institute, Inc. (Log # 386) COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text:

"Identify procedures for evaluating...." SUBSTANTIATION: Wording suggests there a ~ specific steps • which must be followed. COMMnWEE Ac ' r ION: Accept.

(Log # 712) 472- 450 - (5-5.1.2): Reject " . SUBMITTER: J o h n T. Higsins, Dow Comltng Corp. COMMENT ON PROPOSAL NO.: 472-1" RECOMMENDATION: Delete text.

Renumber iterm which follow. SUBSTANTIATION: This is the responsibility of the hazmat technidan& COMMrrTEEACTION: Reject., ' ' " COMMITTEE STATEMENT: At inddent~ involving operational level personnel only ha=mat technicians may not be present. It is t h e r e f o r necessary for the incident comr~mder to laave some understanding of how materials and containers may react.

472-451 - (5-5.1.2): Reject - " . • SUBMrrrg~ Joyce ~. Strath, FMC Corp. (Log # 6o3) Samuel A. Pearman, Martinsville, VA (Log# 10~0) Wdliam A. Levy, Rhone-Poulenc A 8 Co. (b~g # 625) .. Hershell Stafford, Exxon Chemi~".ai Americas (Log # 485) .

John M. Coburn, Occidental Chemical Corp. (Log# I I19) Raymond P. Beaudry, DuPont Co. (Log # 874) Michael E. Lyden, The Chlorine Institute, :Inc. (Log # 387) COMMENT ON PROPOSAL NO.: 472-1. RECOMMENDATION: Delete text. SUBSTANTIATION: This is the responsibility of the hazmat t e chn ic i an . . COMMnWEE ACTION: Reject. COMMITrEE STATEMENT: See Committee Statement on Public Comment 472-450 (Log #712).

(Log # 829) 472- 452 - (5-5.i.3): Reject t SUBMITrER: Bruno Mark W'dson, Oregon State Fire Marshal COMMENT ON PROPOSAL NO.: 472--1 RECOMMENDATION: Revise text:

(a) Change "determine" to "identify". (b) Move to First Re- sponder Operations level. . SUBSTANTIATION: (a) "Identify!' is more easily measured. (h) Incident commanders should not be micn~rnanat~in~ their incidents. This level of detail should be left ~ technical functions at the Operations level, not to the Incident Commander. COMMTrTEE ACTION: Reject.

COMMrr rEE STATEMENT: A hazmat technidan will not necessarily be present at all incidents.'

472- 453- (5-5.1.3): Reject . SUBMrrrER: HershelfStafford, Exxon Chemical Americas (Log # 486) , • . .

Ioyc, ce A. Strath~ FMC Corp. (Log # 6o4) . . John M. Coburn, Occidental Chemical Corp. (Log# 1129) • Samuel A. Pearman, Martinsville, VA (Log # 1 031 ) William A. Levy, Rhone-Poulenc A 8 Co. (Log # 626) John T. Higgins, Dow Coming Corp. (.Log# 71S) Raymond P. Beaudry, DuPont Co. (Log # 875) Michael F_. Lyden, The Chlorine Institute, Inc. (Log # 388) COMMENT ON PROPOSAL NO.: 472-1 ,

RECOMMENDATION: Delete text. SUBSTANTIATION: This is the responsibility of the hazmat ' technidan. COMMrrEEE ACTION: Reject. C O M M r r r E E STATEMENT: See Committee Statement on Public Comment 472-452 (LOg'#S29). -

472-454- (5-5.1.5): Reject S U B ~ Raymond P. Beaudry, DuPont Co. ( I ~ # 876) Samuel A~ Pearman, Marfimviile, VA (Log # 1032) W'dliam A. LevN, Rhone-Poulenc Ag Co. (Log # 627) John M. Colz~m, Occidental Chemical Corp. (Log # 1121) Hershell Stafford, Exxon Chemical Americas (Log # 487)

Corp. <Log# ~" Lyden, The Chlorine Institute, Inc. (Log # 389)

COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text:

Give a copy of the state, resional , and federal response plans, identify the resources available . . . . SUBSTANTIATION: To clarify the requirement. COMMITTEE ACTION: Reject. • . COMMrlWEE STATEMENT: See Committee Action and Statement on Public Comment 472-438 (Log #822).

472- 455 - (5-5.2.2): Reject - " SUBMITTER: John M~ Coburn, Occidental Chemical Corp. (Log# 1122) - . ~, ,'

~ hn T. Higgins, Dow Coming Corp. (Lo 8 # 714) ershell Smiford, Exxon ChemicaIAmencas (Log # 488)

JsamOyCe ~. Stra~, FMC Corp. (Log # 606) uel A. Pearman, Mmxinsville, VA ( L ~ # 1033)

Raymond P. Beaucby, DuPont CO. (Log # 877) W'dliam A. Levy, Phone-Poulenc Ag CO. (Log # 628) ' Michael E. Lyden, The Chlorine Institute, Inc. (Log # 390) COMMENT ON PROPOSAL NO.: 472-1 " • RECOMMENDATION: Delete.text.

Renumber subsequent sections. 'SUBSTANTIATION: This is unneeded. Subeecti0~'5-5.2.3 describes needed competency. ' COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The two sections are requiring different levels of knowledge.

472- 456- (5-5.2.3): Reject SUBMITrER: John M. Coburn, Occidental Chemical Corp. (LOg# n ~ ) Samuel A. Pearman, Martinviile, VA (Log # 1034) Raymond P. Beaudw, DuPont Co. (Log # 878) William A. Levy, Rhone-Poulenc Ag Co. (Log # 629) John T. Higsins, Dow Q)rning Corp. (_Log# 715) Joyce ~ Suath, SMC Corp. (Lo~ # ~07) Hersheil Stafford, Exxon Chenucal Americas (Log # 489) Michael E. Lyden, The Chlorine Institute, Inc. (Log # 391) COMMENT ON PROPOSAL NO.: 472-1 - RFA~MMENDATION: Revise text:

Describe an activitylog and exposure record for a ha~rclous materials incident. S ~ A N T I A T I O N : All the incident commander needs m know is what is needed in the log, not how to do it. Others wil! keep the logs.

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N F P A 472 - - A92 T C D

COMMITrEE ACTION: Reject. COMMITIT.E STATEMENT: The Committee does not intend tO indicate that the actual keeping of logs, etc. may not be accomplished by someone other than the indden t commander. However, the incident commander has the responsiHlity to see that it is ac~'omplished and should have an understanding of what is involved.

(Log # s30) 472- 457- (5-5.2.4): Reject SUBMITIT.Jh Bruno Mark W'dson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Combine with 5-5.2.5. SUBSTANTIATION: These objectives are not so different as to require their being measured separately, COMMITTEE ACTION: Reject. .. COMMIT]'EE STATEMENT: The Committee feels that it may not be necessary to measure these two separately.

(Log # SSl) 472- 458 - (5-5.2.5): Reject S U B M I T I T ~ Bruno Mark Wilson, Oregon State Fire Marshal COMMENT O N PROPOSAL NO.: 472-'] RECOMMENDATION: Combine with 5-5.2.4. SUBSTANTIATION: These objectives are not so different as to require their being measured separately. COMMITI~E ACTION: Reject. COMMITTEE STATEMENT: See Commiuee Statement on Public , Comment 472-457 (Log #830).

(Log # 273) 472-459- (A-1-1.2): Accept " . SUBMrFIT, R: c .J . Wright, Union Pacific Railroad COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: completely. Delete SUBSTANTIATION: Update ' the entire document to reflect changes made in the standard. COMMrlWEE ACTION: Accept.

(Log # 278) 472- 460 - iA-l-2(g)): Accept SUBMITrER: C.J. Wright, Union Pacific Railroad COMMENT O N PROPOSAL NO.: 472-1 .

RECOMMENDATION: Revise the sentence with the underlined words to read: A-I-2(g) Dangerom Goods. In Canadian transportation, hazard-

ous materials are called Dangerous Goods. SUBSTANTIATION: Clarify the intent of the sentence. COMMITrEE ACTION: Accept.

(Log # 276) 472- 463 - (A-2-2.1.9): Accept SUBMrlWER: C.J. Wright, Union Pacific Railroad COMMENT O N PROPOSAL NO.: 472-1

] ~ M M E N D A T I O N : Delete the one of the two words "injured" at the end of the sentence. Also add a comma "," after the word victims at the end of the sentence. SUBSTANTIATION: Grammar. " " COMMITTEE ACTION: Accept.

(Log # 106) 472- 464 - (A-2-2-3.1): Accept in Principle SUBMrI']T.R: Kent R. Olson, American Association of Poison Conuvl Centers COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Make this consistent with A-5-2.3.7: add

~ OUBSTANTiATlisonous and cormsi~.. ON: Currently inconsistent and insuffident.

COMMHTEE ACTION: Accept in Prindple. Reword as follows: "The way hazardous materials may be harmful would include

thermal, mechanical poisonous, corrosive, asphyxiation, radiation, and etiologic. There may also be psychological ha rm2 COMMITTEE STATEMENT: ThE Committee feels that the above wording clarifies the intent.

(Log # 27s) 472- 465- (A-3-2.1): Accept SUBMrlWER: c .J . Wright, Union Pacific Railroad COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Delete the "s" 6n the end of.the word "containment" in the second line of the sentence. SUBSTANTIATION: Correct typographical error. COMMrITEE ACWION: Accept.

s

(Log # 245) 472- 466 - (A-3-2.1.4): Accept SUBMrI'rER: Gerald L Grey, Redwood OW, CA COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text to read:

"List of surrounding ~onditions should include: topograp~, land use; accessibility;, weather conditions; bodies of water;, public exposure potential; overhead and underground wires and pipelines; storm and sewer d/ains; possible ignition sources; adjacentlahd use such as rail lines, hishways , and airports; and nature and extent of

- " ON: Important factors should not be eliminated

from appendix material. ' . COMMrI'rEJ~ ACTION: Accept

(Log # 279) 472- 461 - (A-1~2): Accept . SUBMITFER: C.J. Wright, Union Pacific Railroad COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise the first sentence with the addition of the underl ined words to read as follows; the rest of the paragraph to remain as is: A-l=2 Hazardous Materiah. T h e U.S. Department ofTransp0rtw '

tion (DOT) uses the term haT~rdous materials, which covers nine (9) numbered and two (~) worded ¢ia.~es. some of which have been sob-divided into divisions. ~ '~ 'e~r - ] [~T][~ON: To eliminate confusion about number of classes, since there are only nine numbered dasses. COMMITTEE ACTION: Accept.

(Log#m) ' 472- 467 - (A-3-2.3): Accept SUBMrIWER: J im Litevich, NH Haz-Mat Curriculum Development Committee COMMENT O N PROPOSAL NO.: 472-1 RECOMMENDATION: Revise text:

"... or the National Fire Academy's training program Har~rdous Materials Incident ge-~enrse ~ 1984." SUBSTANTIATION: Correction to Title of course referred m in ~enMMrl, r E E d i x note.

ACTION: Accept.

(Log# 136) 472-462- (A-2-2.i.2): Accept " SUBMrI'rER: Max H. MclL~_e, Houston Fire Dept., TX COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Revise text:

Combustible Liquid: Change Fahrenheit for 95°C (third line) from ( l O W ) to (200°F). SUBSTANTIATION: Wrong conversion. COMMITTEE ACTION: Accept.

(Los # S2) 472- 468 - (A-5-2.3): Accept ' . SUBMr]WER: Gregory G. Noll, Hilderbrand & Noll Assoc., Inc. COMMENT O N PROPOSAL NO.: 472-I RECOMMENDATION: Add as a reference source:

"Noli, Gregory G., et. al., H ~ r d o u s Material~ Managing the Inddent , , Fire Protection Publicafions,'Stillwater, OK (1988)." " SUBSTANTIATION: Information on predicting the likely behavior o f a hazmat is also contained within this reference source. COMMrYrEE ACTION: Accept.

36O

NFPA 472 A92 TCD

(Log # ~4) 472- 469 - (A-3-2.$.7.1): RejeCt SUBMrrFER: C.J. Wright, Union Pacific g~lroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete all those definitions for words not listed in 3-2.3.7.1. Add the defin~ons to the Appendix for words in 3-2.5.7.1 that are not defined in the Appendix. SUBSTANTIATION: Do not believe it neo-~ary to define terms not used in the slandard which is all this appendix item is doing with the exception of carcinogen and sensitizer. The terms asphyxiant, mutagen, and terotogen should be defined since they are mentioned in the standard. ' COMMrrrEE ACTION: Reject. COMMrITEE STATEMENT: The Commilxee feels that the list as presented is appropriate.

/

(LOg# IS~3 472-470- (A-3-2.3.7.1): Reject SUBMITYER: Max H. McRae, Houston F'ue DepL,TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete A - 3 - 2 . 5 . 7 . 1 . SUBSTANTIATION: Other than carcinogen and sensitizer, nothing seems to relate to the competency; and carcinogen is not defined but rather it merely mentions whid~ agencies evaluates, lism and regulates carcin?gens. I suggest that A-3-2.5.7.1 be deleted and the reference mark for 3-2.5.7.1-fie omitted. COMMITrEE ACTION: Reject. COMMITIT.E STATEMENT: The Committee feels that since the Appendix is for informational purposes the material contained here is appropriate.

(Log # 105) 472- 471 - (A-3-2.3.7.1): Accept in Principle " SUBMI'IWER: Kent IL Olson, American A~ociation of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 . / • RECOMMENDATION: Revise "7. Target Organ Effecta: ~ as outlinC-d below. A-3-2.5.7.1 Health Bastard Definitions 7. Target Organ Effects.... (a) Cutaneous h~m~d~ Chemicals that alter or damage the

epidermal, dermal or subcutaneous layer of the body. Signs & Symptoms: rash, irritation, chemical burns. ' Examples: solvents, chlorine, sulfuric aci(L (b) Respiratory wact h ~ , ~ l ~ Chemicals that injure the upL~er

respiratory tract or lung tissue. , . ' Signs & Symptoms: cough, wheezing, pulmonary edema. Examples: silica, chlorine, phosgene. (c) C~ntral nervous system hazards: Chemicals that caUSe.

depression or stimulation of consciousness or otherwise injure the brain., Signs & Symptoms: headache, dizziness, nausea, staggering,

euphoria, giddiness, drowsiness, coma, sebxwes. Examples: solvents, phenol, cyanide, methyl bromide. (d) Cardiotoxic ha,-~,-d~ Chemicals busing depression or

stimulation of the heart or otherwise affect the cardiovascular system. Signs & Symptonm irregular heart beat, ~ncope, cardiac arrest,

shock. Example~ chlorinatedhydrocarbons, cyanide. -(e) Gastrointestinal tract hazard~ Chemicals that injure or otherwise affect the stomach or intestinal tract. Signs & Symptoms: nausea, vomiting, dlmrhea, gastrointestinal

bleeding or perforation. . ' Examples: sulfuric acid, ammonia, lead. (f) Hepatotoxins: Chemicals that injure or otherwise affect the

function of the liver. " - Signs & Symptoms: nausea, vomiting, dark urine,jaundice. Examples: carbon tetrachlorlde, 2-nitropropane. (g) Kidney toxins: Chemicals that datable or otherwise affect the

function of the kidneys.. Signs &.Symptom~ Decreased urine flow; vomiting, delirium. Examples: chlorinated solvents, chlorates, mercury, lead. (h) Reproductive toxins: Chemicals that. affect the reproductive

organs (testes, ovaries) or the developing letus. Signs & Symptoms: Infertility, birth defects. Example~ lead, mercury, DBCP.

• ( i ) Hemoglobin-altering mxin~ Chemiads that damage or otherwiseafter the normal function of the oxygen-carryLngpigment hemoglobin, resulting in decreased oxygen delivery to cells.

Signs & Symptoms: natmea, headache, diT~ineas, loss 0f consciousness, hemolysis (breakdown of red blood celts)

Examples: carbon monoxide, agents caming methemoglobinernla (oxiders), arsine. • (j) Eye hazarcts: Chemicals that injure or otherwise after eye

function. Signs & Symptoms: conjunctivitis, corneal damage, blindness. Examples: solvents, acids, alkali.

SUBSTA.NTIATION: The current elaMiflcatton is inconsistent and insufficient and in some places completely incorrect. COMMrrrEEACTION: Accept in Principle. Reword as follows: . 7. Target Organ Effects... (C) Neutrotoxins... '1. Central Nervous System Hazards: Oaemicals that came

depression or stimulation of consciousness or otherwise injure the brain. ' ' 2. Peripheral Nervous System: Ohemii:als that d ~ a g e the nerves that transmit messages to and from the brain and the rest of the

Signs and Symptoms: Numbness, tingling, decreased sensation. • Orange in reflexes, decreased motor strength.

Examples: Arsenic, Lead, Toluene, Styrene. COMMrI'rEE STATEMENT: The Committee feels that the changes to Section C more accurately highlighted the areas of c o n c e r n °

472-"472 - (Appendix B): A~ep t . : (Log # 277) SUBMrI'rER: C.J. Wright, Union Pacific Railroad COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete Appendix B or perform a task analysis and present the competencies in a format similar m that used in this document. Possibly, this material once tasked, measurable competencies could be placed in the body of the standard as Chapter 6 as long as they relate to the rest of the standard. SUBSTANTIATION: T ~ competencies in Appendix B are too broad and flexible and are not performance onented, It appears" that a task analysis needs to be made, and then define the necessary mmpetehcies, and indude meardrable competencies in the standard, not the Appendix. COMMrrrKE ACTION: Accept.

I

(Log # SS6), (Log # 71 e), (Log # ~ 7 ) 472- 473 - (Appendix B): Accept in Principle SUBMrrrER: D. Christopher Catheast, Washington, DC (L~8 # 8 S 6 ) , -

John T. Higgins, Dow Coming Corp., (Log # 716), Michael L Donahue, Chemical Manufacutre Assoc (Log # 727.) COMMENT ON PROPOSAL NO.: 472-1 R E C O M M E N D A T I O N : Delete Appendix B and replace with a new Chal~ter 6 defining the competencies of private sector specialist employees. •

Chapter 6 Competencies of the Private Sector Specialist Employee

6-1 General

"6-1.1 Introduction. Private sector specialist employees who in the course of their regnlarjob duties work with andare trained in the hazards of specific mate r~ts, and who will be called upon to provide technical advice or assistance at an incident to the individual in charge, ,~a!!, as a minimum, receive training or demonstrate competency in the area of their speclalizationannually. Acceptable performance shall be demonstrated and documented by the specific employer. In addition private sector specialist employees s h a l l receive u-alning to meet any applicable federal Deparunent of Transportation, Occupational Safety and Health Administration or Environmental Pro~ction Agency requlrementJ in the area of their specialization.

6-1.2 Definition. Private Sector Specialist Employees are those persons who will be called upon toprovide technical advic.e or assistance at a chemical incident to a team leader or the incident commander. They may be qualified by specific response training or by~rtue of their regularjob duties. These employeesprovide a~istance which includes, ft. necessary, working in the hot zone.

6-1.8 Goal. The goal of this chapter is to define the knowledge and skills necessary for the ~private sector specialist employee" '(Special- ist Employee A, B, C) to perform the following tasks safely.

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N F P A 472 - - A92 T C D

Therefore, in addition to being co n~e. tent in their specialist areas, the "private sector specialist employee shall be able to:

(a) Analyze the har~rdotts material incident as it relates to the • material that the "specialist employee has knowledge of; through his/her training or job related duties.

(b) Assist in planning a response at the request of the incident commander for the h2r~rdous material that the "specialist ployee" has knowledge of by completing the following task~

1. Identify response objectives for responding to the specific material.

2. Identify potential options. 3. Identify personal protective equipment. 4. Assist the incident commander to develop a plan of action.

(c) Assist in implementing the plan of action agree! to by the incident commander, within the specific competencies of the "specialist employee'.

(d) Evaluate progress of the response as it relates to the material • that the "specialist employee" has knowledge of through training or job related duties. :

6-1.4 Private sector specialist employees (regardless of level) shall possess either by themselves or collectively as a team, all of the competencies listed for each level of expertise.

6-2 Specialist Employee C

6-2.1 Definition. Limited focus specialist employee who, in the course of their regular job duties, ~ r k with and /or are trained in the h ~ r d a of and /o r containers for specific materials and who will becalled upon to provide technical advice or assistance, gather and record information, or provide unique professional services at a chemical incident to a team leader or incident commander.

6-2.2 G<~. The goal of the competencies at the specialist employee C level is to a~ure the specialist employee has the knowledge ~md skills to perform the following tasks safely. Therefore, when the specialist employee C arrives at the scene, he/she lha!l be able to:

(a) Analyze the emergency to determine what h ,~cds are present bycompleting the foIIowln 8 tasks:

I. Provide information about specific chemical h=y~rds and harmful effect&

2. Provide information concerning the container or equipment used m process, store, or transport the chemical.'

(b) Advise the incident commander concerning actions which may be token to bring the incident under control by completing the following task~

1. Provide information on Personal Protective Equipment required to handle the specific chemical.

2. Provide info~nation on the federal regulations as they relate to the specific chemical.

3. Describe ~ r sonne l decontamination methods needed for the specific chermcal.-- -

4. Keep an activity of the chemical incident responders involve- menL

(c) Implement actions agreed to with the incident commander by completing the following task:

I. Implement actions consistent with the specialist employee's nonr i~job function and training. This may include, where appropriate within the competencies of the specialist employee, entering the hot zone w take direct action to mitigate the release:

(d) Evaluate the results of the actions taken in implementing the agreed upon plan by completing the following task:

I. Advise the incident commander on effects of progress o f mitigation actions consistent with the specialist employee's normal job functions. ' " "

6-2.3 Competencies - Analyzing the lnddent

6-2.3.1 Provide information about specific chemical b~r~rda and harmful effects. Given a specific product at an incident, identify the b~r~rds and harmful effects which may occur.

6-2.3.1.1 Icientify h2~rds of the spedflc chemical. '

6-2.3.1.2 Identify harmful effects of the specific chemical.

6-2.3.1.31 As an alternative, identify the method, within the specialist employee's company, to obtain the above information.

6-2.3.2 Providing information concerning the container used to .trans~rt the chemical. Given a specific container at an incident, identify the har~rcis and harmful effects which may occur.

6-2.3.2.1 Identify the types of containers used to transport the chemical.

6-2.3.2.2 As an alternative, identify the method, within the specialist employee's company, to obtain the above information.

6-2.4 Competenc les- Planning the Incident Response

6-2.4.1 Providing information on Personal Protective Equipment required to handle the specific chemical. Given a specific chemical at an incident, provide information to the incident commander on actions W take to mitigate the incident.

6-2.4.1.I Identify personal protective equipment which will be compatible with the specific chemical. •

6-2.4.1.2 Demonslrate ability to wear appropriate personal protective equipment.

6-2.4.1.3 As an alternative identify within the spedalist ejmployee's company, where information is available on materials of construction for personal protective equipment which is compatible with the specific chemical.

6-2J4.2 Provide information as contained on the MSDS on the federal regulations as they relate m the specific chemical. Given a specific chemical at an incident, provide the incident commander information on government regulations which may apply to the incident and the actions requir~ed as a result of these regulations.

6-2.4.2.1 List regulations of concern for the specific chemical.

6-2.4.2.2 List actions required as a result of the incident and who shall take those actions.

i

6-2.4.2.3 As an alternate, identify where, within the specialist employee's company, to obtain the above information.

6-2.4.3 Describe personnel decontamination methods needed for the s~p~citic chemicals. Given a specific chemical at an incident, provtde information to the incident commander on the actions required to perform decontamination.

6-2.4.3.1 Describe methods which can be used to remove or neutralize the specific chemical from the personal protective equipment or be able to identify the needto dispose of such equipment if decontamination is not possible.

6-2.4.3.2 As an alternative, identify, within the specialist employee's company, where to obtain the above information.

6-2.4.4 Ability to function within an assigned role in the IMS.

6-2.4.4.1 Identify the specialist employee's assigned role in the IMS.

6-22; Competencies - Implementation of the Response Plan

6-22;.1 Implement actions consistent with the S l~'C~.'st employee's normal job function and training. Give n a specific chemical at an incident:

6-2.5.1.1. Demonstrate abilities within specialist employee's expertise to perform the actions agreed to with the incident commander.

6-2.6 Competencies - Evaluating Progress

6-2.6.1 Advise the incident commander o n effects of progress of . mitigation actions consistent with the specialist empk~/~'e'Vs normal " job functions. Given an incident and a specific chemical:

3 6 2

NFPA 472 A92 TCD

6-2.6.1.1 Demonstrate abilities within the sp:dalist employee's expertise to provide the incident commander with an ev~uation of thepro~ress of the tasks which have been completed by the responoers. .

• r - "

6-2.6.1.2 Identify the steps in keeping an. activity log of the Chemical Incident l~sponders involvement.

• 6-3 Specialist Employee B

6-3.1 Description. C~neral f ~ u s specialist employees who,, in the course of their regnlar job duties are trained to work with s~ectflc chemicals and /o r to perform work on specliic containers. These employees have the ability to assist in controlling, or performing the functions necessary to mitigate the inddent and bring it to a sati~ctory conclusion.

6-3.1.1 The Person at this level will possess ~dl of the competendes required of the Specialist Employee C I~el :rod the addiuonal competencies that are indicated in this section.

6.3.2 Goal~ The goal of the competencie, at the Specialist Employee B level i~s to provide the incident commander assistance in repairing the container, transferring chemi¢~s or other similar a~,ivities. Therefore, this responder shalibeabie to: " . • .

(a) Analyze the incident tO determine the actions that the . specialist employee can safely iake to mitigate the incident. "

1. Understand the specific chemical's phy~sical, chemical and toxicological properties. • "

2. "Identify container types normally used for chemical transport by the spedalist mp ioyee ' s company.

(b) Plan the response by working with the incident commander and providing information on the actions which are within the capabilities o f the specialist employee. " " -

I. Know how to implement the specialist ¢.~nployee's company • emergency response plan.

2. Ability to function within an assigned role in the IMS.

3. Understand basic standard safe operating procedures including personnel and operational issues.

4. Ability to identify and use proper personal protective equipment for the chemlcal involved in the inddent.

(c) Implement the actions that have been agreed to with the incident commander.

1. Know how to me personal protective equipment needed to accomplish agreed to actions.

2. Has skills andknowiedge necessary to perform the amgned mitigation techniques for the chemicals/containers to whi'ch response is expected. , , • " .

3. Hasknowieclge of proper decontamlnationtechniques for personnel and equipment.

4. Keep personal protective ecjuipment ~uad hot zone entry and exit log for specialist employee mvolvement.

(d) Evaluate the progress that is madeas a remh of the actions • which have been taken by the specialist employee.

1. Ability to evalume progreu of recommended actions being implemented and to form a judgment on whether actions are or will mitigate the incident. . , • ,

6.3.3 Competencies: Analyzing the Incident

6-3.3.1 Understand the specific chemical's, physical, chemical and toxicological properties. Given a specific chemical, the responder shall be able to: ' " • '

• 6-3.3.1.1 Identify the routes of exposure from the info~matinn on the MSDS. .

6-3.3.1.2 Identify the 6ffects of exposure £.'om the MSDS. ' •

6-8.8.2 Identify container types normally used for chemical transport by the specialist employee's company, given a specific chemical, the responder slmll be able m Identify the containers Used -

• 6.8.8.2.1 Iclentify' the container used to ship the specific chemical.

6-8.4 Competendes- Plannin, g the Inddent Response

6-8.4.1 Know how to implement the speciali~ employee's company emergency response plan. The specialist employee shall understand his role in .h~ employer's emergency plan. ' "

6-8.4.1.1 Identify the specialist employee'S role wi .thln the employer's emergency plan.

6-8.4.1.2 Demonstrate implemen~tion procedur~ for the emergency plan.

6-$.4.2 Understand basic standard safe operating procedures including personnel and operational issues. Given a ~pecific chemicalthe specialist employee shall be able to tramffer the chemical or repair the container used to contain the chemical.

6-4.4.2.1 Demonstrate al~lity to transfer chemical from one container to another.

5.4.4.2.2 Demonsu'zte the. ability to repair various pans of the mntainer used for the specific container. ~

6.$.4.3 Ability to identify and use proper Personal Protective Equipment for the chemical invoNed m the specific incident. Given a specific chemical at an'incident, identify the types of personal protective equipment needed to pmtect persons in the hot zone.

6-3.4.3.1- Identify the Peraonal protective equipment n,eecled to protect persons entering the hot zone.

6-S~ competendes- Implementation of the ResPonse Plan - ~

6.S~5.1 Know how to use the personal protective equipment needed to accomplish agreed to actions. Given a specific chemical, the specialist employee shall demonstrate the me of the required personal prote , c ~ equipment. ' '

6.3~,.I.I Demonstrate the use of required personal protective equipment,

6.3.~.2 Has skills and knowledge necessary to perform the mitigation techniques for the products/containers to which response is expected. Given a Sl~Cific chemical at a specific incident, indicate the:skilLa needed to mitigate the situation. "

6.3~.2.1 D e m o n m ' ~ appropriate skills for transferring the specific chemicals.

6.~,.2,2 Demonstrate appropriate skills for repairing various pare of a container. ,

6-S.5.3 Haa knowiedge of proper decontaminationiechniques for personnel and equipment. Given a specific chemical, provide "mformati0n on how to perform decontamination techniques. ".

6-$~,.3.I Using available resources, identify the decontamination procedures for the specific chemical..

6-8.5.4 Has knowledge of procedures required to keep a permnal protective equipment and hot zone entry and exit log.

6-3.5.5 Identify the stel~ in keeping apersonal protective equipment and hot zone entry and exit log for spedalist employee involvement. , ' ' . ~ ~ ~ .

6-3.6 Competencles - Evaluadng'Progreu

6-3.6.1 Ability to evaluate progress of recommended actions being implemented and to form a judgment on Whether actions are or will mitigate the incident.

6-$.6.1.1 The specialist employee possesses certain skills from his/ her normal job functions; Successful l~efformance of these skills has been demonstrated aa part of the speoalist employee's performance review system.

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N F P A 472 ~ A92 T C D

6-4 Specialist Employee A

6-4.1 Description. This employee is specifically trained to handle ' hazardous material releases of chemi~da and/or to perform work on specific containers in use by their employer. This employee shall have the skill and ability to assist/analyze, perform functions and make appropriate decisions necessary to bring a b~,~rdous material incident to a satisfactory conclusion.

6-4.1.1 The person at this level will demonstrate all of the competencies required of the Specialist Employee B level and all the addi - tional competencies that are indicated in this section.

6-4.2 Goals. The goal of the competenciea of the Specialist Employee A level is to assure the specialist employee has the knowledge and skills to perform the following tasks safely.

(a) Analyze the incident to detehnine what hanrda are present at" the scene:

1. Help assess the incident's environmental impact for the specific chemical for which assistance is expected.

2. Select and use monitoring equipment for the chemicals to which response is expected. . or obtain expert help from within the c?mpany to me thin eqmpment.

(b) Advise the incident commander concerning actions which may be taken to bring the incident under control by completing the following tasks:

1. Apply relevant information from an MSDS to the specific incident, i.e., Personal ProtectiveEquipment. Health Hazards, and Fire/F.xplc~on/Reactivity.

2. Advise the incident commander on federal regulations impacting an emergency response.

• 3. Provides information on governmental and private sector agencies that offer assistance during a hazardous materials incident, including their roles and the type of assiJtance and resources available.

4. Select, me, test and maintain personal protective equipment needed for materials to which the employee respond&

5. Has knowledge of the need to keep an activity, personal protective equipment and hot zone entry and exit log for the mcident.

6. Identify personnel who are knowledgeable of the design, construction, and repair techniques for containers to which the specialist employee responds.

7. Identify personnel with expertise regarding ha~rdous materials transportation and disposal regulations.- -

(c) Implement actions to with the incident commander by ~mplet lng the following taslu~ , '

1. Apply additional safe operadngprocedures such as interpreting data that impact issues related to physical and menud stress, confined space, conditions that warrant approach or withdrawal and to understand when a response to an incident should be terminated.

2. Select and use the appropi'iate personal protectiv e equipment

3. Recognize and direct containment/remedlation procedures.

4. Perform advanced mitigation techniques.

5.. Identify personnel with expertise concerning decontamination procedures, the use of decontamination equipment and appropriate disposal practices.

6. Provide information for communicating with the media.

6-4.3 Competencies-Analyzing the Incident

6-4.3.1 Assessing the incident's environmental impact for the specific chemical for which assistance is expected. Given a specific .chemical at an incident, Identify the expected environmental unpact.

6-4.3.1.1. Identify the environmental concerns for the product from the MSDS.

6-4.3.1.2 As an altematlve, identify the persons to call, within the specialht employee s company, with~information on the known environmental effects of the chemical.

6-4.3.2 Identify and nee monitoring equipment for the products to which response is expected or obtain expert help from within the responder's company to use this equipment. Given a specific chemical at a ha~rdom materials incident, the responder shall Identify the proper monitoring equipment to be used.

64.$.2.1 Identify and demonstrate use of each of the pieces of monitoring equipment available for me from the specialist employee's company which are available for use by the specialist employee.

6-4.S.9.2 identify other specialized monitoring equipment that could be used in mitigating the specific incident andidentify the personnel within the specialist employee's company who can operate

equipment. " - '

6-4.$.2.$ Demonstrate the techniques'to use to get the needed resources to the scene of the incident.

6-4.5.2.4 Demonstrate field maintenance and calRrafion procedures for the monitoring equipment provided by the company forthe specialist employee to use.

6-4.4 Competencies - Planning the Incident Response

6-4.4.1 Apply relevant information from the MSDS to the chemical at a specific incident, i.e., Personal Protective Equipment, Health I-lar~i~is, and Hre/Explosion/Re~ctivity. Given a chemical at a specific incident, identify theprecautions and ~rsonal protective equipment that is needed in mitigating the inadent.

6-4.4.1.1 Identify the health bar~rds associated with the given chemical."

6-4.4.1.2 Identify personal protective equipment which must be worn to protect responders from the ha~rds of the chemicals.

6-4.4.1.3 Identify the fire and explosion potential of the chemical

6A.4.1.4 Identifyany potential reactivity of the specific chemical(s) involved~including the precautions which should be ta_hm to avoid and/or neutralize the reactivity.

6-4.4.1~5 Identify resources within the specialist employee's company where you can find help in answering the above concerns.

6-4.4.9 Advise the incident commander on federal regulations impacting an emergency response. Given a specific incident including the type of reieaee which has occurred, identify the government agencies who need to be notified of the release.

6-4.4.9.1 Identify from the MSDS the government regulations which may apply to the specific product.

6-4.4.9.2 Assist in identifying the federal regulations which apply to the specific incident.

6-4.4.2.3 As an alternative, identify where, within the specialist employee's company,, further information is available on applicable government reguianons.

6-4.4.3 Is familiar with specialist employee's employer resources that offer assistance during a hazardous materials incident, including their roles and the type of assistance or resources available. Given a specific chemical in a specific incident, identify the assistance that is available from within the specialist employee's own company.

6-4.4.$.1 Identify resources available from within the specialist employee's company including potential use of contractors.

6-4.4.$.1.I Identify how to obtain these resources. ;

6-4.4.4 Understan&s the roles of, and assistance available from CHEMTREC and CANUTEC. Identify the role of mutual aid responders at the incident.

6-4.4.4.1 Explain how CHEMTREC/CANUTEC ~m help at the scene of a chemical incident.

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NFPA 472 , /

6-4.4.4.2 F..xplain types ofasshtance that can be provided by mutual aid groups at a chemical incident..

6-4.4.5 Knows how to identify, use, test and maintain all personal protective equipment needed for materials to which the employee responds. G~en a specific incident with sp~:~c products identified:

6-4.4.5.1 Identify the personal protective eqoipment needed for the chemical.

6-4.4.5.2 Demonstrate the ability to use the i;equired personal protective equipment.

:6-4.4.5.3 Demonstrate the proper method to test thepersonal protective equipment after~xav~ing donned the eq~pment.

6-4.4.5.4 Demonstrate" the proper field maintenance which needs to be performed on the personal protective e~nipment.

6-4.4.6 Understands the requirement for esi~biishment and maintenance of activity, personal protective equipment and hot zone entry and exit logs. Given a specific chemicd incident, demonstrate the use of these log& ' "

6-4.4.6.1 Explain why these logs are imporumt and how they are to be used.

6-4.4.7 Has knowledge of, or has immediate access to, personnel who are knowledgeable regarding the design, construction, and repair techniques for containers to which employee responds. Given a specific container, give the design; const1"uction and repair techniques used on this container.. . • -

6-4.4.7.1 Identify where information is available, induding from whom at the responder's comp.any, for the design, construction, and repair techn!ques for the 8ive~ container. :

6-4.4.8 Has knowledge of,'or access to, peraonnel with expertise • concerning h2~rdons materials transportation and disposal • -. resulationa. Given a specific chemical at a ~;pecific incident, provide information concerning proper transportation and disposal of the specific product.

6-4.4.8.1 Identify, within the specialist emptoyee's company, the proper persons to contact to obtain inforn~ition on unmsporting the specific chemical. This information shall include proper shipping papers and labeling if neede(L

6-4.4.8.2 Identify, within the specialist employee's company, the proper persons to contact to obtain inforn~ati0n on the disposal options for the specific chemical.

6~4.4.8.3 Identify, within the specialist employee's company, the proper persons to provide information on ;my regu~tions which apply regatding transportation or disposal of the specific chemical.

6-4.5 Compe~ncies - Implementing the R~sponse Plan

6-4.5.1 Apply additional safe operating procedures such as interpreting data that impact issues related to physical and mental stress, confined space, conditions that approach or warrant withdrawal and to understand when a response to an incident should be terminated. Given a specific inciident and chemical, define operating parameters for th e specia~t employee.

6-4.5.1.1 Identify factors which may affect lhe sp;~cAalist employees ability to perform their assisned tasks.

(a) Hea t (b) Cold (c) Workingin confined space (d) Working in personal protective equipment (e) Working in a conl~m;nated environment (e.g. flammable or

toxic atmosphere) ' " ,

6-4.5.2 Certified in the use of the required personal protective equipment. Given a specific incident, den~Lonstrate ability to selec:t and use appropria~ personal protectiv e ec[dipment. "

6-4.5.2.1 Demonstrate the ability to wear appropriate personal protective equipment.

(a) Identify the safety procedures for pezsonne! wearing vapor protective clothing.

A92 TCD

(b) Identify the procedures for donning, working in, and dottfin 8 self contained breathing apparatus. .

(c)' Demonstrate donning, working in, and do/tfing chemical protective clothing in addition to m/y other specialized protective equipment provided to the specialist employee. • .

(d) Demonstrate the ability to use, repair and test chemical , / protective clothing in accordance with the specialist employee s " company procedures. , ~ t '

~ ' 3 ~ r m ~ l ~ e and provide advise on containment/ remedlatinn procedures. Given a specific incident, demonstrate required Containment ancVor remediation procedures,which may be, required to prevent spread of contamination. .

6-4.5.5.1 Demonstrate Containment procedures for the incident.

(a) diking, plugging,'pa~.hing

(b) 'absorbenm • r

(c) adsorbents

f~4.5.S.2 Identify remedimionprocedures which need to be taken during the emergency phase of the incident to prevent further contamination. ,

6-4.5.4 Knowledge of, and ability to, perform advanced mitigation techniques. Given a specific incident, demonstrate techniques to mitigate the incident. Of the listed competencies below, a Nx~l l i s t . employee only needs to have knowledge in the techniques which are required for the products and containers which are wi~in his/her expertise. / ,

6-4.5.4.1 Identify the parts, tools, and materials for product specific kits and ,demonstrate their use.

6-4.5.4.2 Demonsu-~tethe ability to dose open valves, tighten loose plugs, and replace missing pings.

6-4.5.4.3 Given a drum, select the appropriate material and/or equipment and demonstrate method to contain leaks in various parts of the drum. .

6-4.5.4.4 Demonstrate methods for overpackln 8 a drum into a salvage drunL

6-4.5.4.5 Identify safety cbnsiderations for product'transfer operations, including bonding, grounding, elimination of ignition sources, and shock hazards." .

6-4.5.4.6 Demonstrate knowledge of either stoppin~ the leak or transferring of the chemical from any containers .shipped by the specialist employee's company.

6-4~,.5 Has knowledge of, or'access to, personnel with expertise concerning decontamination procedures, the use 'of decontamination equipment and appropriate disposal practices for the products to which employee responds. Given a specific chemical, demon- mate proper decontamination procedui~s. ' ,

6-4.5.5.1 ' Identify procedures to be used to decontaminate equipment used at the incident.

6-4.5.5.2 Identify the persons within the specialist employee's company who can provide information on decontamination proc~uses required and appropriate disposal practice, for the specific chemicals involved in the incident. . .

6-4.5.6 Provide information to communicate with the media. Given a specific incident, demonsu'ate ability to communicatewith the media in a manner consistent with the Incident Management S y s t e m . '

6-4.5.6.1 Demonstrate ability to communicate with the media.

6-4.6 Competencies - Evaluatin 8 Progress

6-4.6.1 No additional competencies needed.

f~. On~ite Response

6-5.1 When an incident occurs within an industrial facility, specialist employees may respond and begin mitigation activities pri6r to the

N F P A 472 - - A92 T C D

implementation of the Incident Management System (IMS). The specialist employees may continue work within an IMS should the chemical inadent require the use of an'emergency response team. The specialist employee may only perform work in which they have been trained andhave demonstrated job proficiency, knowledge, and expertise.

NOTF~ "Sup~)orting materiab is available for review at NFPA Headquarlers. SUBSTANTIATION: it is eMential that private sector specialist employees be recognized and that the criteria for their training be included in this' r e ~ t ~ standard. With this change NFPA 472 will

e ~ b A c T l l i C and private sector emergency responders. ON: Accept in Principle.

Reword the proposed Chapter 6 ~s follows: Chapter 6

Competencies for Off-Site Speciafist Employees

6-1 General.

6-1.1 Introduction. Off-site s ~ 5 ~ s t employees are those who, in the course of their regular job duties, work with or are trained in the l~7~rds of specificmaterials and/or containers, in response to incidents involving chemicals, they may be called upon to provide technical advice or assistance to the incident Commander relative to their area of specialization. Off-site speciaUst employees shall receive tzainingor demonsu-ate competency in their area of spedalization annually. In addition, off-6ite specialist employees shall receive training to meet any applicable federal Department of Transporta- tion, Occupational Safety and Health Administration, Envimnmen- . tal Protection Agency, or local occupational health and safety regulatory agency requirements applicable to their area of specialization.

6-1.2 Scope. This chapter will address competencies for the following off-site specialist employee~

• ( a ) O f f ~ t e Specialist Employee C- those persons who ma,/ respond to incJdents involving chemicals and /or containers within their organization's area of specialization. The Off-site Specialist Employee C may be called upon to gather and record information, provide technical advice, and/or arrange for technical assistance consistent with their organizations's eme~enry response plan and standard operating pro~lures . The Off-rite Specialist Employee C is not expected to enter the hot/warm zone at an incident.

(b) Off-site Specialist Em#oyee B - those persons who, in the course of their regular job duties, work with or are umined in the h ~ n i s of specific chemicals or containe~ within their individual area of specialization. Because of education, training, or work experience, • the Off-site Specialist Employee B may be called upon to gather and record information, provide technical advice, and provide technical assistance (inchiding work within the hot rune) at " an incident ,involving chemicals consistent with his/her . organization s emergency response plan and standard ope~ting . procedures and the local emergency response plan. - - -

(c) Off-site Specialist Employee A - those persons who are specifically trained to handle incidents involvin~ chemicals and/or containers for chemicals used in their organizauon's area of specialization. Consistent with his/her organization's emergency response plan and standard operating p r o ~ u r e s , the Off4he Specialist Employee A shall have the ability to analyze an incident- involving chemicals within the organization's area of specialization, plan a response to that incident, fmplement the planned response ~ th in the capabilities of the resources available, and evaluate the progress of the pLanned response.

6-2 Off-aRe Specialist Employee C.

6-2.1 General.

6-2.1.1 Introduction. The Off-site Specialist Employee C shall be trained to meet the competencies at the first responder awareness level (Chapter 3) relative to his/her organization's area of spedMIr~- tion and the additional competencies in Section 6-2 o f thb C~apter: In addition, the Off-cite Specialist Employee C shall receive training to meet any applicable federal Department of Tramq)ortation, Occupational Safety and Health Administration, Environmental Protection Agency, or local occupational health and aafety regulatory.a~ency requirements applicable to the organization's area of spedalizauon.

6-2.1.2 Definition. Level C Off-site Specialist Employees are those persons who may respond to incidents involving chemicals and/or

contalners within his/herorganization's area ofspecialiration. The Off-site Specialist Employee C may be called upon to gather and record information, provide technical advice, and/or arrange for technical assistance consistent with their organizations' emergency response plan and standard operating procedures. The Off-site SpeciafistEmployee C is not expected to enter the hot/warm zone at an incident.

6-2.1.3 Goal. The goal of these competencies is to Insure that the Off-slte Specialist Employee C has the knowledge and skills to safely perform the duties and responsiblfities assigned in the organization's emergency response plan and Standard operating procedures. There~re, in addition to being trained to the first responder awareness level relative to the organization's area of specialization, the Off-site Specialist Employee C shall also be able to:

(a) Assist the Incident Command~ in analyzing the 'magnitude of an incident involving chemicals and/or containers for chemicals used in their organization's area of specialization by completing the following tasks:

1. Provide information on the h2r~ecLs and harmful effects of specific chemicals used in their organization's area of specialization.

2. Provide information on the ~ t i c s of specific containers for chemicals Used in their organization s area of specialir~tion.

'(b) Assist the Incident Commander in .planning a response to an incident involvinl| chemicals and /o r containers for chemicals used in their organlr-,t,on's area of specialization by completing the following ~.k, , ' - .

1. Provide information on the potential response options for chemicals and /or containers for chemicals ~ in their organization's area of specialization.'

6-2.2 Competencies- Analyzing the Problen~

6-2.2.1 Provide information on the h~,-~ds and harmful effects of specific chemicals. Given a specific chemical used in their organization's area of specialization and an appropriate Material Safety Data Sheet (MSDS) or other appropriate resource, the Off-site Specialist Employee C shall advise the Incident Commander of the chemical's hazards and harmful effecm.

6-2.2.1.1 Given a specific chemical within their organization's area of specialization and an appropriate Material Safety Data Sheet (MSDS), identify the foll6~fing hazard information from the MSDS:

(a) physical and chemical cha~cteristicJ " (h(h~)hysical ha~rda of the chemical (including fire and explosion

(c) health hazards of the chemical (d) signs and symptoms of exposure (e) rout~ ofentry (f) permissible exp?mre limits . (g) reacdvity hazaids (h) environmental concerns

6-2.2.1.2 Identify how to contact CHEMI'REC/CANUTEC.

6-2.2.1.$ Identify the resources available from CHEMTREC/ CANIYI~C,

6-2.2.1.4 Given their organization's emergency response plan and standard operating l~rocedures, identify additional resources of hazard i/fformation mciuding a method of contact.

6-2.2.2 Provide information on the characteristics ofspedflc containers for chemicals used in their organization's area of speci~!i,~tion. Given a specific container for a chemical used in

• their organization's area of specialization, the Off-site Specialist Employee C shall advise the Incident Commander of the characteristics of the containers. , • ' '

6-2.2.2.1 Given examples of various containers for chemicals used in their organization's area of specialization, identify each container by n a m e .

t

6-2.2.2.2' Given examples of facility and transportation containers for chemicals in their organization's area of speciali~tion, identify the markings which differentiate one container from another.

366

' ' N F P A 472 - - A92 T C D i

6-2.2.2.3 Given their organization's emergencyresponse plan and standard operating procedures, identify the resources ava]lable that can provide information about the characteJ~tics of the container.

6-2.3 Competendes - Planning the Respond. ~.

6-2.3.1 Provide information on potential rel;ponse options for a specific chemical. Given a specific chemical used in their organization's area of specialization and an appropriate Material Safety Data Sheet (MSDS) or other appropt~iate resource, the Off-~te Employee C ~b~!!'advise the Incident Comm~mder of the response information for that chemical.

6-2.3.1.1 Given a Specific chemical used in their organization's area of spedalizadon and an appropriate Mate~d Safety Data Sheet (MSDS), obtain the following response information:

(a) precautions for safe handlings, indudlng hygiene practices, protective measures, and procedures for dean-up of spilLs/leaks.

(b). applicable control measures, including personal protective equipment.

(c) emergency ahd first aid procedures.

6-2.3.1.2 Given their organization's emergency response pL3n and standard operating procedures, identify ad~fitional resources for obtainings response information for a chenticai used in their organ izafi'on's area of specialization.

6-3 Off-site Specialist Employee B.

6-3.1 General.

6-3.1.1 Introduction. The Off-site Spedalh;t Employee B shall be trained to meet, the competendes at the Off-site Specialist Employee C level and the additional co mpetendes in Section 6-$ of this Chapter. In addition, the Off-she Speciaiis~ Employee B shall receive training to meet any applicable federal Dei~trtment of Transporta- tion. Occupational Safety and Health Adrfiinistration, Environmen- tal Protection Agency, or local occupational health and safety regulatory agency requirements applicable to the individual area of specialization.

6-3.1.2 Definition. Level B Off-site Specialist Employees are those persons who, in the course of their regular job duties, work with or are trained in the h ~ i s of specific chernlicah or containers within their individual area of specialization. Becmse of their education, training,.or work experience, the Off-site Specialist Employee B may be called upon to respond to incidents in,dying chenucais. The Off-site S~ecialist Employee B may be used to gather and record informauon, provide technical advice, and provide technical assistance (including work within the hot zone) at the incident' consistent with their organization's emergency response plan and standard operating procedures and the lotal emergency response plan.

6-3.1.3 Gin1. The gnal of these competen.des is no lnmre that the ' Off-site Specialist Einpioyee B has the knc.~ledge and skills to safely perform the duties and responsibilities a~tsiigned in their organization s emergency response plan ~uld standard operating procedures. Therefore, within their individual area of spedalization, the Off-site Specialist Employee B sludl be able to: .

(a) Aasist the Incident commander in analyzing the magnitude.of an inddent involving chemicals and/or containers for chemicals within their individual area of specialization by completing the following tasks:

1. Provide and interpret information on the hazards and harmful effects of specific chemicals within their individual area of speda|i,~- tion.

2. Provide and interpret information on. the characteristics of specific containers for chemicals within their individual area of

I spedaiizadon. .

3. Provide informationon concentrations of chemicals within their individual area of specializadon from exposure - monitoring, dispersion modeling, or any other predictive method.

(b) .Msist the Incident Commander in planning a response to an incident involving chemicals and/or conudners for chemicals withi n their individual area of specialization by completing the following~ task~

I. Provide information on the potential response options and their consequences for specific chemicals and/or containers for chemicals within their individual area of specialization.

2. Provide inforthation on the personal protective .ecjuipment requirements for a specific chermcal within their individual area Of spedaliTation. ', , , "

5. Provide information on the decontamination mt, thods for a specific chemical within iheir individual area of specialization.

4. Provide information on the federallprovindai regulations that relate to the handling and /or disposal of a specific chemical within, their individual area of specialization, ~ • .

' 5. Develop a plan of action (within the capabilities'of the available resources), Including safety considerations, for handling chemicals and/or containers for chemicals within their individual area of speOallr~tion consistent with their organization's emergency response plan and sumda~l operating procedures. ~ '

(c) Implement the planned response, as developed with the lnddent Conunandcr, for chemicals and/or containers for chemicals within their individual area of spedalization, consistent with their organization's emergency response plan and standard operating prixedures and witl~m the capabilities of the available resource~ by completing th e follow!~fig tasks: , :

1'. Perform response options within their Individual area of spedalizaflon, specified m the plan of action, as agreed upon with the Incident Commander and consistent with their organization's emergency response plan and standard operating pro~-dures (within the capabilities of the ava~ble resources). '

~. Don, work in, and doffpersonal protective equiprnent needed to implement theresponse options consistent with their organization's emergenol response plan and standard operating procedures. "1 . .

(d) Assist the Inddent Commander to evaluate the remits of t~t~..ementing the planni~d response'by completing the follo~ving

1. Provide feedback on the effectiveness of the response options taken w i t ~ their individual area of specialization.

2. Provide .reporting and sfibsequent documentation of the incident involving chemicals as required in their ort~aniz~on's emergenc~ response plan and standa~l, operating p~rocedures.

6-3.2 Competencles - Analyzing the Problem.

6-3.2.1 Provide and interpret information on the b=,-~rds and harmful effects of specific chemicals. Given a specific chemical within their individual m~a of specialization and an iappropriate Material Safety Data Sheet (MSDS) or other approp~riate resource, the Off-site Specialist Employee B shall advise the Inddent Com- mander of the chemical's hazards and harmful effects and the potential consequences based on the incident.

6-3.2.1.1 Given a specific chemical within their individualarea of spedalizadon and an appropriate Material Safety Data Sheet (MSDS), identify and interpret the following hazard information:

(a) physical and chemical characteristics i. of the chemic ' (indudms and p,osion

h a z a r d s ) . , " . . .

(c) health h~s~rds of the chemical " ' ' (d) signs and symptoms ofexpmure (e) mutes of entry (f) permissible expoimre limits (g) reactivity hazaids (h) environmental concerns r

6-3.2.1.2 Given examples of specific chemicals used in their individual area of specialization and the appropriate resources (as identified in their organization's emergency response plan and standard operating procedures), predict the potential behavior of the chemicals basedon the damage found, including the consequences of that behavior. '

6-$.2.1.$ Identify the general types of h~r~l-d information available from the other resources identified in their organization's emergency response plan and standard operating procedures.

N F P A 4 7 2 - - A 9 2 T C D

6-3.2.2 Provide information on the characteristics of spe. cific container~ Given a container for specific chemicals w~thin their individual area of spedalization, the Olf-~ite Specialist Employee B shall advise the Incident Commander of the characteristics and potential behavior of that container.

6-3.2.2.1 Given examples of containers for specific chemicals used in their individual area of specialization, iclentffy the purpose and operation of the closures found on those containers.

6-3.2.2.2 List the types of damage that could occur to a'container for a chemical within their individual area of specializatiOn.

6-3.2.2.3 Given examples o f containers for specific chemicals within their individual area of specialization and the appropriate resources (as identified in their organization's emergency response plan and standard operating procedures), predict the potential behavior of the containers tnaed on the damage found, induding the consequences of that behavior.

6-5.2.2.4 Given their organization's emergency response plan and standard operating procedures, identify resources (including a method of contact) knowledgeable in the design, construction, and damage assessment of containers for chemicals within their , individual area of specialization. " . .

6-3.2.3 Provide information on concentrations of chemicals within their individual area of specialization from exposure monitoring dispersion modeling, or any other predictive method. Given a chemical used in their individual area of specialization and the applicable monitoring equipment provided by the organization for that chemical or the available predictive capabilities (e.g., dispersion modeling), the Off-site Specialist Employee B shall advise the Incident Commander of the concentrations of the released chemical and the implications of that information to the incident.

6-3.2.3.1 Identify the appropriate monitoring equipment for a chemical u s e d in their individual area of specialization.

6-3.2.3.2 Use the appropriate monitoring equipment provided by their organization to determine the actual concentrations of a specific chemical used in the individual's area of specialization.

6-3.2.3.3 Given information on the concentrations of a chemical used in their individual area of specialization, interpret the significance of that concentration information to the incident relative m the h=~rda and harmful effects of the chemical for the msponder~

6-3.2.3.4 Demonstrate field cadilration and testing procedures, as necessary, for the monitoring equipment provided by their

• organization.

6-3.2.3.5 Given their organization's emergency response plan and - standard operating procedures, identify the resources (including a method of contact) capable of providing monitoring equipment, dispersion modefing, and /o r monitoring services for chemicals within their organization's area of specialization.

6-3.3 Competencies - Planning the Response.

6-3.3.1 Provide information on the potential response options and their conseque..nces for a specific chemical within their individual area of specialization. Given specific chemicals or containers within their individual area of specialization and the appropriate resources, the Off-site Specialist Employee B shall advise the Incident Com- mander of the potential response options, and their consequences, for incidents involving claemicats and/or containers for chemicals within their individual area of specialization.

6-3.3.1.1 Given a specific chemical within their individual area of s(~SdDalization and an appropriate Material Safety Data Sheet

S), identify and interpret the following response information:

(a) precautions for safe handling, including hygiene practices,, protective measures, and procedu/~ for dean-up of spdts/leaks.

(b) applicable control measures, including personal pr0te¢five equipment.

(c) emergency and first aid procedures.

6-3.$.1.2 Given their organization's emergency response plan and standard operating procedures, identify additional resources interpreth~g response information for a chemical within their organization's area of specialization.

6-3.5.1.$ Describe the advantages and limitations of the ~ . tential response options for a specific chemical within their individual area

• of spedalization.

6-3.5.1.4 Given their organization's emergency response plan and standard operating procedures, identify resources (including a " method of contact) capable of:. "

(a) repairing containers for chemicals within their individual area of specialization. J

(b) removing the contents of containers for chemicals within their individual area of specialirJtion. .

(ci clean-up and disposal of chemicals and/or containe~ for chemicals within their individual area of specialization.

6-$.3.2 Provideinformation on the personal protective equipment requirements for various response options. Given specific chemicals and/or containers for chenucals within their individual area of

alization and the appropriate resources, the Off-site Specialist oyee B shall advise the Incident Commander of the appropri-

ate personal protective equipment necessary for various response opuons.

6 - 3 . 3 . 2 . 1 G i v e n a s p e c i f i c c h e m i c a l w i t h i n t h e i r i n d i v i d u a l a r e a o f specialization and an appropriate Material Safety Data Sheet (MSDS), identify personal protective equipment, including the materials of construction, which will be compatible with that chemical.

6-3.S.2.2 Given their organization's emergency response plan and standard operating procedures, identify other appropriate resources (including a method of contact) capable of identifying the personal protective equipment that is compatible with a specific chemical.

6-3.3.2.3 Given an incident involving a specific chemical used in their individual area of specialization and the response options for that problem, determine if the personal protective equipment provided b? their organization ~" appropriate for the options presented.

6-3.3.3 Provide information on the decontamination methods for a specific chemical. Given a specific chemical within their individual area of specialization and the available resources, the Off-site Specialist Employee B shall identify appropriate decontamination methods for various response options.

6-3.3.3.1 Given a specific chemical within their individual area of spedall~tion and a Material Safety Data Sheet (MSDS) or other resource, obtain the potential methods for removing or neutralizing that chemical.

6-3.3.3.2 Given a specific chemic~d within their individual area of specialization and a Material Safety Data Sheet (MSDS) or other r e s o u r c e , identify the circumstances when disposal of contaminated equipment would be necessary. '

6-3.3.3.3 Given their organization's emergency response plan and standard operating procedures, identify resources (including a method of contact) capable of iden "tifying potential decontamination methods for chemicals within their individual area of specialization.

6-3.3.4 Provide information on the federal/provincial regulations that relate to the handling and/or disposal of a specific chemical. Given a specific chemical within their area of specialization and the available resources, the Off-slte Specialist Employee B shall advise the Incident Commander of the federal/provincial regulations that relate to the handling, transportation, and/or disposal of that chemical.

6-3.3.4.1 Given a specific chemical within their individual area of specialization and a Material Safety Data Sheet (MSDS) or other resource, identify federal/provincial regulations that apply to the handling, wansportation, and/or di:sposal'of that chemical.

368

N F P A 4 7 2 - - A92 T C D

6-3.3.4.2 Glven'a specific chemical within their individual area of spedali~don and a Maierial Safety Data Sheet (MSDS) or other resource, identify the agendes (including a method of contact) responsible for compfiance with the federal/provincial regulations that apply to the hafidling, tnmsportaflon, ~ t d / o r dispma] ofa . specific chemical.

6-8.8.4.8 Given their organization's emergency responie plan and -standard operating procedures, identify re~)urces for information pertainln~ to feder~/provinctal ~ m ~ relative to the handling and/or disposal of a specifi c cherm/:al. '

6-5.52; Develop a plan of action (within the. capabilities of the " available resuu/ces), including safety considtera~dons, for handling chemicals and /or containers for chemicals within their individual area of specialization and consistent with their organization's emergency response plan and standard operating procedures. Given a simulated incident involving chemicals and/or containers used in their individual area of spechlizadon, the Off-eite Specialist Employee B lhall (in conjunction with the ]Incident Commander) develop a plan of action, including Safety considerations, for handling chemicals and /or contm~ners in that incident.

6-5.5-~.I Given their organlzadon's emergency response plan and standard operadng prodedures, identify the process for deveiopment of a plan of action, including safety considelrations. ' .

6-5.4 Competendes - Implementing the pl:mned Response.

6-3.4.1 Perform response options specified in the plan of action. Given an assignment by the Incident Commmander within their , individual area of specialization, the Off-die Specialist Employee B shall perform the assigned actions consbt~at with their organization's emergency response plan and standard operating procedure~

6-5.4.1.1 Perform assigned tasks consistent with their organization's emergency response plan and standard op:rating procedures and the available personnel, tools, and equipment (inducting personal protective equipment), lndudins: .

(a) confinement activities _'(b) containment activities

(c) product removal'activities

6-5.4~1.2" identify factors whicfi may affeo: the individual's ability to perform their assign~i tasks.

NOTE: List includes heat, cold, working'in confined space, working in personal protective equiplrcnt, working in a flammable or "toxic atmosphere, andpre-existing health conditions.

6-5.4.2 Don, work in, and doff personal protective equipment needed to implement the assigned respon~e options.- C~ven an assignment by the Incident Commander within their individual area of spedalizadon, the Off~te Specialist Employee B shall don, work in and doff the appropriate personal prou~:dve equipment consistent with their organization's emer~.~ncy response plan and standard operating procedure~ '

6-5.4.2.1 Don, work in, and doff the 'appropriate respiratory protection and protective clothing for the assigned tasks consistent with their Organization's emergency reSpOnse plan and standard operating procedures. ' . ,' ~

6-5.4.2.2 Identify the saLfety procedures for personnel wearing personal protective equipment, including: °

(a) buddy sy.s. tern (b) hack-up persunnel (c) ,.syrup, ms of heat and cold stress (d) limitations of personnel ~ r k i n g in personal protective

ec~e)ipment, ' , indications of material desradadon of chemical pmtecdve

clothing (f) pl /~cal and psychological stresses on the wearer ,(g) emergency procedures and hand signals.

6-5.4.2.5 Identify the procedures for cleaning, sanitizing, and inspecting personal protective equipment provided by their employer. ' ,-' .

6-5.5 Competencies - Evaluating Pmsre~,

~32;.1 Provide an enhm~on of the effectiveness of the selected response options. Given ,an incident involvin~ specific chemicals and/or contalnen for c h ~ c a t s within their individual area of specialization, the Off-site Specialist Employee B shall advise the Incident Commander of the effectiveness of the selected response options.

6-$2;.1.1 Identify the criteria for evaluating whether or not the selected response opdom are effective in accomplishing the objectives.

6.8~.1.2 Identify the circumstances 'when it would be prudent to pull back from a chemical inddent.

6.8.~.2 Provide reporting and subsequent documentation of the incident involving chemfcahas required in their organization's emergency response plan and standard operating pmcedureL Given a simulated ~cident involving chemicals and/or containers for chemicals used in their individual area of spedalization, the off- site Suecialist Employee B shall comnlete the renordna and

.'plan and standard operating

6~$~,.2.1 Identify the imporumce of documentation (including training records, exposure records, incident reports, and critique reports) for an inddent involving chemicals. '

6-5-q.2.2 Identify the steps used in keeping an activity log and exposure records as described in their organization's emergency response plan andstandardoperatin8 procedures..

6-S-~.2.3 Idendfy the re~uiremenu for compiling incident reporu from their organizafion'a emergency response p~n and standard operating procedures. . "

6-S-~.2.4 Identify the requirements for compiling hot zone entry and exit logs from their 6rganizafion's emergency response plan and standard operating procedur~

6.8.5.22; Identify the requirements for compiling personal protective equipment logs from their organization's emergency response plan and standard operating procedur~ x

6.8~;.2.6 Identify the requiremenu for'filing documents and maintaining records as prescribed in the organization's emergency response plan and sumdard operating procedures.

6.4 off~te s p ~ t Employee

6-4.1 General.

6.4.1.1 Inwoducflon. The Off-site Spedafist Emplo/ee A shall be trained to meet the competencies at the Off-rite Specialist Employee C (Section 6.2 in this O~apter), Off-rite Specialist Fan p l o y e e B (Section 6.S in this Chapter) levels, and Hazardous Matel~al Technician (Chapter 4) relative to the chemicals and obntalners

mizadon's area of J used in their orgag specialization. In addition, the Ofl~ite Specialist Employee A shall receive training to meet any aPF dicable federal Department of Transportation, Occupational Safety and Health Administration, Environmental Protection Agency, or local occupational health and safety regulatory agency

tuirements applicable t O the organization's area 9f specialization.

6-4.1.9 'Definition. Level A Off-site Specialist Employees are those permns who are specifically trained to handle incidents involving chemicals and/or containers for chemicals used in their organization's area of specialization. Consistent with their organization's emergency respo.nse plan and standard operating pr6f.edures, the Off-site Specialist Employee A shall be able to /malyze an incident involving chemicals within their organization's area of specialization, plan a response to that incident, lmplement the planned response within the capabilities of the,resources available, and e6aluate the progreu of the planned response.

6.4.1.8 Goal. The ~ ofthis level of competence is to insure that the Off, site Sp~.ia~st Employee A has the Imowiedge and skills to" safely perform the dudes and responsibilities assigned in their . organization's emergency response plan and standard operating , procedures. TheretO>re, in addidon to being competent at the Off- site Specialist Employee C and Off-eite Specialist Employee B levels, the off-slte Specialist Employee A shall be aHe to, in conjunction with the Inddent Commander.

6 9 ~ . ,


(a) Analyze an incident involving chemicals and containers for chemicals used in their organization's area of specialization to determine the magnitude of the incident by completing the following tad~

1. Survey an incident involving chemicals and containers for • chemicals used in their organization's area of speciafization to -

i identify the containers involved, identify or da~sify unknown materials, and verify the identity of the chemicals.

2. Coilect and interpret b~r~rd and response information from printed resources, technical resources, computer databases, and monitoring equipment for chemicals used in their organization's area of specialization.

5. Determine the extentofdanmge to containers of chemicals used in their organization's area of speclalization.

4. Predict the likely behavior of the chemicals and, containers for the chemicals, used in their organization's area O f spe, cialization.

5. Estimate the potential outcomes of an incident involving chemicals and containers for chemicals used in their organization's area o f specialization.

(b) Plan a response (within the capabilities of available resources) to an incident involving chemicals and containers for chemicals used in their organization's area of specialization by completing the following

1. Identify the response Objectives for an incident involving chemicals and containers for chemicals use din their organization's area of specialization.

2. Identify the potential action options for each response objective for an incident involving chemicals and containers for chemicals used in their organization's,area of specialization.

3. Select the personal protective equipment required for a given reslxmse option for an incident involving chemicals ~nd containers for chemic.~ds used in their organization~ area of spedal!7~tion.

4. Select the appropriate decontamination procedures, as necessary, for an incident involving chemicals and containers for chemicals used in their organization's area bf specialization.

5. Develop a plan of action (within the capabilities of the available resources), indudlng safety conaiderations, for handling an incident involving chemicals and containers for chemicals used in their organ.ization's. , area of specialization consistent, with their . orgamzauon s emergency response plan and standard operating procedures. , .

(c) Implement the planned response (as developed with the Incident Commander) to an incident involving chemicals and containers fol; chemicals used in their organization'sarea of specialiT~tjon consistent with their orgamzation's emergency response plan and standard operating procedures.

1. Don, work in, and doffappropriate personal protective equipment~provided by their or~..., ization for chemicals used in their organization's area of specialization, consistent with their organization's emergency response plan and standard operating procedures.

2. Perform control functions, as agreed upon with the Incident Commander, for chemicals and containers for chemicals used in their organization's area of specialization consistent with their organization's emergency r~ponse plan and standard operating procedures.

(d) Evaluate the results of implementing the planned response to an incident involving chemicais and containers for chemicals used in their organization's area of specialization.

Also add the following definitions to 1-~

Chemical. Regulated and non-regulated h ~ r ~ l o m materials (solids, liquids, and gases; natural or manmade;.indudlng petroleum products), with the potential of creating harm to people, property, and the environment when released.

Individual Area of Specialization. Refers to the qualifications or functions of a specific job(s) associated with chemicab and /o r containers uaed within an organization. • '

" Organization's Area of Spedalization. Refers to any chemicals and containers used by the ap~cialist employee's employer. COMMrI'rEE STATEMENT: The Committee agrees with the ' importance of having oampetendes established for the N~)ff-dte Specialist Employee: The Committee feels that the revised Chapter 6 as mbmitted in the Committee Section accomplishes the goal of the submitters, and keeps the Chapter consistent with the rest of NFPA 472.

(Log # 138) i

472- 474 - (B-2): Accept in Principle SUBMrlWER: Max H . McRae,,Houston Fn-e Dept., TX COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Delete B-2. SUBSTANTIATION: Specialist employees will be covered in the proposed NFPA 474 and should be removed from this document. COMMrrYEE ACTION: Accept in Principle. NFPA 474 will not be developed.

COMMITTEE STATEMENT: The Committee has decided not m develop a separate document (NFPA 474) relating to special~"areas but will include anyproposed spedalty area competendes in future revisions to NFPA 47"2.

(Log# 107) 472- 475 - (B-2-a.2(D): Reject " SUBMrI'IT.R: Kent R. Olson, American Association of Poison Control Centers COMMENT ON PROPOSAL NO.: 472-1 RECOMMENDATION: Add to (j) "regional poison control centers'. SUBSTANTIATION: See comments on 4-2.2.1 and 3-2.3.1. COMMITTEE ACTION: Reject. COMMITrEE STATEMENT: The Committee believes that the current list is adequate.

(Log # Z0S) 472- 476 - (B-2-4.1 (j)): Reject SUBMITrER: Kent R. Olson, American Association of Poison Control Centers COMMENT O N PROPOSAL NO.: 472-1 RFX~MMFJ~ATION: Add to (j) "...regional poimn control centers and other medical and toxicological hot lines ". SUBSTANTIATION: See comments on 4-2.2.1 and 3-2.3.1. COMMITTEE ACTION: Reject. COMMFI'rEE STATEMENT: See Committee Statement on Public Comment 472-475 (Log #107).

3 7 0

(ait. moj.c. grey) - nfpanfpa 472 -- a92 tcd parti part ii (log# 1) 471- 1 - (chapter 10): accept...

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