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FWS National Contingency Plan

7. SAFETY AND TRAINING

Spill response activities may require Fish and Wildlife Service personnel to operate watercraft, conduct reconnaissance in low-flying aircraft, capture oiled wildlife, and collect samples from the oiled environment. All of these activities have an element of risk associated with them and pose potential problems for the health and safety of Service personnel. Because of this, safety is a primary part of pre-spill and response activities. Training, equipment, and biomedical monitoring are key safety components of pre-spill activities. Utilization of appropriate equipment and application of safe operating techniques during a spill will help to ensure safe and effective spill response activities.

During responses to discharges of oil, response personnel are exposed to many threatening situations that impact personal safety and health. It is important to always remain aware of the work environment and surroundings. Training allows response personnel to identify the risks and evaluate the necessary precautions, enabling work to be conducted in a safe manner. In addition to adequate training to educate response personnel to the potential dangers, it is also necessary to have the proper equipment and technical information available for ensuring the safety of all participants. On spills where the ICS is implemented and a safety officer is usually part of the implementation, the FWS may have its own safety officer available for consultation and evaluation of FWS activities and required safety measures (in cooperation with the Incident Command Section Safety Officer).

Before entering a discharge site, always gather as much information as possible about the incident, including the type of oil discharged and any other chemicals that may be mixed with the oil. Evaluate the health risk from the discharged products. Never assume that the absence of emitted vapor or smoke or the absence of odor are indicative of no health risk. Going on-site is not the only area that poses risks to personnel. The handling of wildlife has its own dangers, and caution is always a necessity. Safety officers determine the training required for personnel to participate in response/removal activities and what equipment and safety protocols are needed. Even after the response activities are completed and Service personnel are participating in damage assessment activities, there is a need to be cautious, since pockets of discharged material may remain in obscure locations.

Training

The FWS Manual addresses safety training requirements for personnel involved in contaminant-related operational activities and oil and hazardous materials operations (24 AM 16.7.C and 242 FW 6). The Manual states:

Supervisors and employees involved in contaminant-related operational activities must be trained to recognize potential hazards and minimize personal exposure through the use of administrative controls, proper procedures, and personal protective equipment,.

Although Service personnel are generally prohibited from entering sites that exceed the Level D site, the contaminated sites may not be controlled, the level of hazard may not be known, or emergency conditions may warrant entry into the higher level sites, so that employees must be prepared to protect themselves under various conditions.

1. Training must include the use of respirators and other personnel protection equipment needed under foreseeable and emergency conditions. Note: User must be medically cleared and fit-tested for respirator use.
2. Training must precede actual work in hazardous environments.
3. Training will be part of a comprehensive Hazard Communication Program.

The Occupational Safety and Health Administration has established more specific safety training requirements for workers involved in emergency response activities (29 CFR 1910.120). These regulations require either an 8-, 24-, or 40-hour hazardous waste operations and emergency response (“HAZWOPER”) course depending on the potential exposure level to the personnel. The required and suggested training for FWS response personnel, including training for response, oiled wildlife capture and treatment, and use of watercraft and aircraft is detailed in Appendix T.

Safety Equipment
(see Appendix U)

Proper equipment, like proper training, is critical for safe and effective spill response actions. The equipment needs for spill response depend on a number of factors including the extent of FWS involvement (i.e., technical assistance, wildlife hazing, wildlife capture and treatment and/or relocation, and damage assessment), the size of the spill, and the type of habitats threatened by the spill.

It is current Service policy to deny Service employees entrance to sites classified as Levels A, B, or C unless entry is absolutely essential. Employees may be allowed to enter hazardous waste sites that are classified as Level D. The need and approval for entry into any hazardous waste site above Level D will be determined by the employee’s Regional Director or his/her representative. Region 9 employees must receive permission from the Assistant Director, Fisheries and Habitat Conservation.

Personal protection equipment needs for responding to oil spills will generally correspond to those required for Level D sites (minimum protection, low-level contaminants, long sleeves, overalls, gloves, etc.). Occasionally equipment for Level C sites (known contaminant type and concentrations of airborne substances, full face respirator, protective suit, disposable boots, double gloves, etc.) will be needed.

General guidance on equipment requirements for entering Level D and C sites is presented in 242 FW 6. The specific personnel protection equipment needs are discussed in Appendix U. Additional safety equipment will be required for handling wild animals, operating watercraft and flying in approved aircraft. The safety equipment needs for participation in these activities are also detailed there.

Medical Monitoring

The FWS policy on medical monitoring (24 AM 16.7.B and 242 FW 64) requires that "all employees who are or may be exposed to hazardous substances at or above established permissible exposure limits or threshold limits for 30 or more days per year be included in a medical surveillance program." The policy also encourages each Region to include personnel "who are actively or potentially involved in field activities where uncontrolled exposure to hazardous materials is possible" in a medical monitoring program. Because most spill response personnel are Environmental Contaminant Specialists, most FWS personnel responding to oil spills will already be in a medical monitoring program. However, there will be many instances where some of the responders are not part of the Environmental Contaminants Program (e.g., Refuge, Fisheries, or Law Enforcement personnel) and may not necessarily be in a medical monitoring program. In those instances, the FWS Safety Officer or Incident Command Section Safety Officer should be consulted to determine if the potential exposure of these responders warrants medical monitoring. (Note: this policy is under review as this section is being written, and a revised version may be issued within the next few months; this should be checked at the Service’s policy web site.)

Zoonoses (wildlife transmitted diseases)

This subject is discussed in the “Best Practices” Manual (Appendix D) and should be reviewed there.

Aircraft Safety

During a discharge of oil, aircraft are frequently utilized for reconnaissance and transportation of personnel, equipment, and injured or threatened wildlife. In order for FWS personnel to be able to fly in any aircraft (other than commercial), they must meet and be familiar with requirements established in the FWS Manual Chapter 331-334 FW. Several points relating to aircraft use need highlighting for those not familiar with the FWS and Departmental policy. The first point concerns contract charter or rental operations. ALL aircraft and their operators SHALL BE certified by Office of Aircraft Services (331 FW 3.1). The second point highlights the requirement that crew members shall wear protective clothing and gear (see 334 FW 2.3 and 351 DM 1.7). These two requirements should be addressed during prespill planning. If these requirements are overlooked and not adequately met during emergency response activities, aircraft and individuals that should be conducting necessary spill response reconnaissance activities for the FWS will not be permitted to fly. Also, the use of military aircraft is regulated under 351 DM 4, which does not permit personnel to "hitch" a ride for observation purposes (other than Coast Guard). Remember, that under 334 FW 1, Appendix 1, the Service will comply with all Department training requirements, specifically 352 DM 2.5. (Note: Aviation Safety policies are under review and revised versions may be issued shortly. Check the Service policy web site at http://www.fws.gov/policy/ ).

Watercraft Safety

Watercraft safety is discussed in the FWS Manual Chapter 241 FW 1. The use of watercraft during emergency spill response/removal requires specific safety precautions and training to avoid endangering FWS personnel. As with aircraft, watercraft are frequently utilized for reconnaissance and transportation of personnel, equipment, and in some instances the capture and transportation of injured or threatened wildlife. Before personnel can participate in spill response/removal activities on the water they must obtain specific training and equipment.

Incident-Specific Health and Safety Plan (HASP)

As standard protocol identified under 242 FW 6.7(C)(2), site health and safety plans shall be implemented in order to minimize exposure of personnel to hazardous substances and other risks before an activity begins. The elements of a HASP can be found in Appendix V, as well as a template and two different software programs for creating HASP’s. A copy of the NIOSH Pocket Guide to Chemical Hazards is included in Appendix V as a source of data on human toxicity, but it is highly recommended that the web site http://www.cdc.gov/niosh/npg/npg.html be checked, as these values are revised periodically.