COMDTINST 6260.31A
toxic gases generated by vessel fires; in a Weapons of Mass Destruction (WMD) incident
used and produced for the illegal drug trade; in substances and pathogens found in
unsanitary berthing and ship's galleys; and in debris and flood waters associated with a
natural disaster. Coast Guard personnel have a responsibility to protect the public and
themselves from such hazardous substances and other hazards present during emergency
response activities. Training, as a component of a comprehensive safety and health
program, provides the skills, knowledge, attitudes, and abilities that will help ensure that
Coast Guard personnel can anticipate, recognize, evaluate, control, and manage such
hazards, safeguarding both public and responder health.
b. OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER)
Standard. In 1990, the Occupational Safety and Health Administration (OSHA) began
enforcing reference (a), the Hazardous Waste Operations and Emergency Response
regulations. These regulations were promulgated to protect hazardous waste workers and
emergency responders from actual and potential releases of hazardous substances.
Included in the regulations are specific training requirements; these are based on the roles
and responsibilities of workers during operations and responses that involve hazardous
materials. The focus of the standard--as with all OSHA standards--was to ensure that
employers provide a "safe and healthful workplace" to employees, in this case at
hazardous waste sites; at hazardous waste transfer, storage, and disposal facilities
(TSDF); and for response operations involving hazardous materials. A primary
component of the standard is training of employees to meet the hazards expected during
those operations. References (b) and (c) require federal agencies to follow OSHA
regulations and standards and to incorporate them in agency guidance; exceptions exist
only for "military and military-specific operations". Reference (d) provides general Coast
Guard health and safety requirements and provides for the application of OSHA standards
in absence of specific Coast Guard guidance, regardless of whether a particular operation
may involve non-military personnel or be considered "military-specific". Reference (e) is
OSHA's guidance for training needed by typical oil spill response workers in accordance
with reference (a). This Instruction further reinforces the application of reference (a) to
Coast Guard personnel as outlined in references (b-d) and expands upon the training
guidance in reference (e) to provide specific training requirements for all types of Coast
Guard emergency response operations.
c. HAZWOPER Training Levels. The training levels as outlined in reference (a), the
HAZWOPER regulations, are divided into two major categories: emergency response
and post-emergency response.
(1) Emergency response is "a response effort...to an occurrence which results, or is likely
to result in an uncontrolled release of a hazardous substance." Uncontrolled
hazardous substance incidents are situations where the substance is moving or there
is a likelihood of movement. For example, if a vessel is aground and there is a threat
of a discharge, an uncontrolled situation exists and the incident is classified as an
emergency response. Other uncontrolled situations include: floating drug labs;
vessel or aircraft fires; weapons of mass destruction and/or opportunity incidents;
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