{"operation":"document","citation":"PHMSA Guidance, Prevention/Mitigation Guidelines","title":"Prevention/Mitigation Guidelines","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-01-19","effective_on":"2017-01-19","summary":"Prevention/Mitigation Guidelines Document 02_Prev_Mitig_Training_2016_508_Compliant.pdf (6.44 MB) Because most hazardous materials accidents are caused by human activities, communities and employers can influence the probability of incidents and the magnitude of their effects by emphasizing prevention/mitigation in hazardous materials emergency management. Hazardous materials prevention and mitigation efforts focus o","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-preventionmitigation-guidelines-6087c1b4.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-preventionmitigation-guidelines-6087c1b4.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-preventionmitigation-guidelines-6087c1b4","source_url":"https://www.phmsa.dot.gov/grants/hazmat/preventionmitigation-guidelines","body":"Prevention/Mitigation Guidelines\n\nDocument\n\n 02_Prev_Mitig_Training_2016_508_Compliant.pdf (6.44 MB)\n\n        Because most hazardous materials accidents are caused by human activities,\n\ncommunities and employers can influence the probability of incidents and the magnitude\n\nof their effects by emphasizing prevention/mitigation in hazardous materials emergency\n\nmanagement. Hazardous materials prevention and mitigation efforts focus on helping\n\ncommunities and citizens avoid becoming disaster victims in the first place, and reducing\n\nthe impact of incidents when they occur.\n\nHazardous materials prevention/mitigation includes efforts to eliminate or reduce risk\n\ndue to either accidental releases of hazardous materials or exposure to toxic\n\nsubstances. Basic hazardous materials prevention/mitigation strategies can be broadly\n\nsummarized as follows:\n\n\tImprove methods and procedures for storing, transporting, handling, and processing hazardous materials.\n\n\tPromote compliance with safety codes, regulations, and statutes.\n\n\tDevelop and enforce land-use plans that regulate the location of sites with hazardous chemicals.\n\n\tIncrease public and community awareness and support for prevention.\n\nWell-designed hazardous materials prevention/mitigation programs have been shown to\n\nreduce loss of life, property, and environmental damage from disasters. The\n\nOccupational Safety and Health Administration (OSHA) concludes that “a strong\n\ncorrelation [exists] between the application of sound management practices in the\n\noperation of safety and health programs and a low incidence of occupational injuries and\n\nillnesses. Where effective safety and health management is practiced, injury and illness\n\nrates are significantly less than rates at comparable worksites where safety and health\n\nmanagement is weak or non-existent” (Safety and Health Program Management Guidelines; Issuance of Voluntary Guidelines).\n\nFor all general hazards and risks, as well as for hazardous materials, experience has\n\nshown again and again that lives can be saved, damage to property can be reduced\n\nsignificantly, and economic recovery can be accelerated by consistently building safer\n\nand stronger buildings, strengthening existing infrastructures, ensuring safer transportation, enforcing building codes, and making the proper preparations BEFORE a disaster occurs. More important, mitigation investments by businesses and citizens will enhance and strengthen the economic structure, stability, and future of the community regardless of when a disaster may strike.\n\nIn recent years, both government and industry have made significant strides in hazardous materials prevention/mitigation. However, more must be done to encourage a change from the traditional focus on disaster preparedness and response to a new emphasis on accident prevention. This shift in perspective by business leaders and emergency management professionals will require adjustments in corporate and community attitudes about prevention/mitigation, improvements in safety management methods and technologies, better access to information and research, and a strengthened cooperation between government agencies and hazardous materials end users.\n\nOne of the most effective ways of promoting this transition is through hazardous materials prevention/mitigation training and education programs. Training helps employees understand the nature and causes of potential safety problems, apply safe work practices and procedures, and participate in the design of effective prevention programs. For this reason, federal and state agencies have consistently identified training as a critical component in all prevention activities.\n\nThis document identifies training requirements for public and private sector personnel who have a role in hazardous materials prevention/mitigation. \n\n          Issued Date: Thursday, January 19, 2017\n\n<<<PAGE 1>>>\n\nPrevention/Mitigation Curriculum\nHazardous Materials Incident\nPrevention/Mitigation\nCurriculum Guidelines\nPreface\n2016 Prevention/Mitigation Training Guidelines – Page 1\n\n<<<PAGE 2>>>\n\nPrevention/Mitigation Curriculum\nOrganization of the Curriculum\nThe ultimate goal of the Hazardous Materials/WMD Prevention/Mitigation Curriculum\nGuidelines (Prevention/Mitigation Guidelines) is to improve safety in hazardous materials\noperations, thereby reducing the probability and severity of accidents and exposures.\nThis goal is accomplished by enhancing participants’ motivation and ability to develop\nand implement effective prevention/mitigation programs and activities within their\norganizations and jurisdictions. Instruction is intended to supplement, not replace, other\njob-specific education and training that audience members receive in their primary work\nfunctions.\nThe Prevention/Mitigation Curriculum addresses the training needs of two broad audience\ngroups: persons who conduct hazardous materials operations, whether in the public or\nprivate sectors; and persons responsible for government and other oversight and\nenforcement programs to protect worker and citizen health. At this time, the general\npublic is not identified as a curriculum audience, although personnel responsible for\npublic information and education activities are included.\nThe Prevention/Mitigation Curriculum is organized into eight audience categories based on\ncommonalties in knowledge and skill requirements. These categories are briefly\ndescribed below; more detailed information on each is presented in the following\nsections.\n• Prevention/Mitigation Awareness describes the introductory training\nrequirements of all audiences in the Prevention/Mitigation Curriculum. Instruction\nis intended to give participants general knowledge about hazardous materials\nprevention/mitigation that can serve as a foundation for subsequent job-specific\ntraining. The audience includes anyone who has responsibilities in hazardous\nmaterials prevention/mitigation or could influence hazardous materials\nprevention/mitigation efforts at state and local levels. Participants are provided\nwith (1) an introduction to basic hazardous materials prevention/mitigation\nterminology and concepts, (2) an explanation of individual and organizational\nroles in hazardous materials prevention/mitigation, and (3) an overview of\ncommon hazardous materials prevention/mitigation methods and activities.\n• Prevention/Mitigation Policy Development describes the training requirements\nof persons who direct, manage, or own organizations that use hazardous\nmaterials—chief executives and senior managers from a broad spectrum of\ngovernment, private sector, and non-profit organizations. In this role, audience\nmembers oversee the development and maintenance of the hazardous materials\nprevention/mitigation program, and direct staff and others who implement the\nprogram on a day-to-day basis. They have the organizational authority to develop\nand enforce hazardous materials prevention/mitigation program policies and to\nbudget and expend related funds.\n2016 Prevention/Mitigation Training Guidelines – Page 2\n\n<<<PAGE 3>>>\n\nPrevention/Mitigation Curriculum\n• Prevention/Mitigation Program Management describes the training\nrequirements of persons who develop or manage hazardous materials\nprevention/mitigation programs and related activities for organizations that use\nhazardous materials. Individuals in this category are responsible for ensuring\nworker and public safety in hazardous materials operations, and for implementing\nthe organizational policy and direction established by senior managers. The\ntraining audience consists of supervisory-level personnel in hazardous materials\nfacilities and transport operations, both public and private. Because training\nrequirements will depend on the size and nature of the operations, the audience\nis further subdivided as follows:\n• Smaller/Less Complex Operations describes the training needs of\npersons that manage smaller and/or less complex hazardous materials\noperations, such as retail outlets, small energy distributors, trucking firms,\nand so forth.\n• Larger/More Complex Operations describes the training needs of persons\nthat manage hazardous materials prevention/mitigation programs for\nlarger producers, processors, and distributors of hazardous materials,\nincluding those subject to OSHA’s Process Safety Management (PSM)\nStandard\n• Community Prevention/Mitigation Program Management describes the\ntraining needs of persons who develop and manage state and local government\nhazardous materials prevention/mitigation programs and activities (community\nhazards analysis, hazardous materials prevention/mitigation planning, land use\nplanning, construction plans review, inspection and codes enforcement, public\neducation, etc.). The training audience includes government officials and others\nwith supervisory-level responsibilities in community hazardous materials\nprevention/mitigation, e.g., state environmental agency hazardous materials\nprevention/mitigation managers, Hazardous Materials Emergency Preparedness\n(HMEP) program managers, local response agency (fire, law enforcement,\nemergency medical services) hazardous materials prevention/mitigation\nmanagers, hazardous materials planners, zoning board members, codes\nenforcement managers, emergency management program directors, and other\ncommunity representatives.\n• Prevention/Mitigation in Operations describes the training requirements of\npersons who regulate, respond to, supervise, or operate systems or processes\nthat involve the use of hazardous materials. These employees are responsible\nfor ensuring that hazardous materials prevention/mitigation activities and safety\nrequirements defined in safety management plans and standard operating\nguidelines (SOGs) are properly implemented and enforced. The training\naudience includes employees of public, private, and non-profit facilities, including\nlarge and small operations at industrial plants, commercial establishments,\n2016 Prevention/Mitigation Training Guidelines – Page 3\n\n<<<PAGE 4>>>\n\nPrevention/Mitigation Curriculum\ntrucking and other transport companies, government agencies, health care\noperations, utilities, and many other types of organizations.\n• Design and Plans Review describes the training needs of persons who oversee\nand participate in the design, planning, approval, and construction of hazardous\nmaterials operations (plants, buildings, processing systems, equipment, etc.).\nIndividuals performing this function are responsible for incorporating the\nrequirements and recommended practices contained in prevention/mitigation\ncodes and standards into detailed plans, specifications, instructions, and other\ndocuments. The training audience includes members of the design team and\ncommunity officials who oversee the process. A secondary audience includes\npersons that implement the approved design (procurement personnel,\ncontractors, vendor representatives, production operators, etc.)\n• Facility Inspection and Enforcement describes the training needs of persons\nwho monitor, inspect, and evaluate safety in hazardous materials operations. In\nthis role, audience members (1) identify risks and prevention/mitigation\nopportunities associated with specific operations, (2) assess and enforce\ncompliance with established authorities and codes, and (3) consult with and\nmake referrals to subject matter experts for unique applications of the codes. The\naudience includes inspectors and enforcement officials from community agencies\n(fire service, police, health agency, etc.), and individuals with similar roles in\npublic, private, and non-profit organizations (safety officers, production\nmanagers, shift supervisors, insurance company representatives, consultants,\netc.).\n• Transportation Investigation and Inspection describes the training needs of\npersons who monitor, inspect, and evaluate safety in hazardous materials\ntransportation. In this role, audience members (1) identify risks and\nprevention/mitigation opportunities associated with specific transportation\nconditions, modes, and systems, and (2) assess and enforce compliance with\nestablished authorities and codes. The performance competencies displayed in\nthis section are directly based upon the competencies articulated in the\nNovember 2014 publication Hazardous Materials Transportation\nInvestigator/Inspector Uniform Training Performance Standards (HMT\nStandards), by the U.S. Department of Transportation, Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), and by the Federal Motor Carrier\nSafety Administration, the Federal Railroad Administration, and the Federal\nAviation Administration. Detailed competencies are provided for hazardous\nmaterials transportation inspectors, investigators, and supporting specialists in\nthe following six general areas;\n• Core Competencies for Hazardous Material Transportation Inspectors and\nInvestigators\n• Advanced Competencies for Hazardous Material Inspectors and\nInvestigators\n2016 Prevention/Mitigation Training Guidelines – Page 4\n\n<<<PAGE 5>>>\n\nPrevention/Mitigation Curriculum\n• Competencies for Supervisory Hazardous Material Inspectors and\nInvestigators\n• Competencies for Hazard Class Specialists\n• Competencies for Hazardous Material Packaging Specialists\n• Competencies for Modal Hazardous Material Specialists\n2016 Prevention/Mitigation Training Guidelines – Page 5\n\n<<<PAGE 6>>>\n\nPrevention/Mitigation Curriculum\nPage Intentionally Left Blank\n2016 Prevention/Mitigation Training Guidelines – Page 6\n\n<<<PAGE 7>>>\n\nPrevention/Mitigation Curriculum\nHazardous Materials Incident\nPrevention/Mitigation\nCurriculum Guidelines\nHazardous Materials\nPrevention/Mitigation\nTraining Considerations\n2016 Prevention/Mitigation Training Guidelines – Page 7\n\n<<<PAGE 8>>>\n\nPrevention/Mitigation Curriculum\nIntroduction\nBecause most hazardous materials accidents are caused by human activities,\ncommunities and employers can influence the probability of incidents and the magnitude\nof their effects by emphasizing prevention/mitigation in hazardous materials emergency\nmanagement. Hazardous materials prevention and mitigation efforts focus on helping\ncommunities and citizens avoid becoming disaster victims in the first place, and reducing\nthe impact of incidents when they occur.\nHazardous materials prevention/mitigation includes efforts to eliminate or reduce risk\ndue to either accidental releases of hazardous materials or exposure to toxic\nsubstances. Basic hazardous materials prevention/mitigation strategies can be broadly\nsummarized as follows:\n• Improve methods and procedures for storing, transporting, handling, and\nprocessing hazardous materials.\n• Promote compliance with safety codes, regulations, and statutes.\n• Develop and enforce land-use plans that regulate the location of sites with\nhazardous chemicals.\n• Increase public and community awareness and support for prevention.\nWell-designed hazardous materials prevention/mitigation programs have been shown to\nreduce loss of life, property, and environmental damage from disasters. The\nOccupational Safety and Health Administration (OSHA) concludes that “a strong\ncorrelation [exists] between the application of sound management practices in the\noperation of safety and health programs and a low incidence of occupational injuries and\nillnesses. Where effective safety and health management is practiced, injury and illness\nrates are significantly less than rates at comparable worksites where safety and health\nmanagement is weak or non-existent” (Safety and Health Program Management\nGuidelines; Issuance of Voluntary Guidelines).\nFor all general hazards and risks, as well as for hazardous materials, experience has\nshown again and again that lives can be saved, damage to property can be reduced\nsignificantly, and economic recovery can be accelerated by consistently building safer\nand stronger buildings, strengthening existing infrastructures, ensuring safer\ntransportation, enforcing building codes, and making the proper preparations BEFORE a\ndisaster occurs. More important, mitigation investments by businesses and citizens will\nenhance and strengthen the economic structure, stability, and future of the community\nregardless of when a disaster may strike.\nIn recent years, both government and industry have made significant strides in\nhazardous materials prevention/mitigation. However, more must be done to encourage a\nchange from the traditional focus on disaster preparedness and response to a new\nemphasis on accident prevention. This shift in perspective by business leaders and\nemergency management professionals will require adjustments in corporate and\ncommunity attitudes about prevention/mitigation, improvements in safety management\n2016 Prevention/Mitigation Training Guidelines – Page 8\n\n<<<PAGE 9>>>\n\nPrevention/Mitigation Curriculum\nmethods and technologies, better access to information and research, and a\nstrengthened cooperation between government agencies and hazardous materials end\nusers.\nOne of the most effective ways of promoting this transition is through hazardous\nmaterials prevention/mitigation training and education programs. Training helps\nemployees understand the nature and causes of potential safety problems, apply safe\nwork practices and procedures, and participate in the design of effective prevention\nprograms. For this reason, federal and state agencies have consistently identified\ntraining as a critical component in all prevention activities.\nThis document identifies training requirements for public and private sector personnel\nwho have a role in hazardous materials prevention/mitigation.\nThe Philosophy of Prevention\nHazardous materials prevention/mitigation is based on the concept that the majority of\naccidents don’t just happen; they are caused. While the use of chemicals may involve\nrisk, the factors that precipitate most accidents are at some point under an organization’s\nor an individual’s control. Therefore, most chemical accidents and the damage they\ncause are preventable by definition.\nHazardous materials prevention/mitigation is not new. For many years, federal and state\ngovernments have issued regulations governing workplace safety, transportation safety,\nand environmental safety. Communities have assessed local hazards, managed land\nuse, enforced safety codes, and conducted public education activities. Businesses have\nimplemented safety programs to protect worker health and minimize the potential for\naccidental releases of, and exposures to, toxic substances.\nThe benefits to communities and employers of well-designed hazardous materials\nprevention/mitigation programs have proven to be significant. These benefits include\nreductions in hazardous materials incidents and accidents; fewer deaths and injuries to\nworkers and citizens; improvements in employee skills, productivity, and morale; lower\ninsurance and operating costs; decreased damage and cleanup costs; elimination of\nregulatory penalties; and protection against litigation.\nAlthough the concepts of prevention and mitigation are well established, the practice of\nmaking safety a primary focus of production and emergency management may be new\nto some organizations. Hazardous materials prevention/mitigation requires identifying\nsafety as a basic goal and priority of hazardous materials operations. The objective is\naccomplished through formal programs that incorporate a systematic analysis of\npotential hazards, a comprehensive effort to eliminate or minimize risk, and activities that\nfoster a safety culture among workers and the public.\nA key element of this new emphasis on hazardous materials prevention/mitigation is the\nconcept of a public/private sector partnership to promote hazardous materials safety.\n2016 Prevention/Mitigation Training Guidelines – Page 9\n\n<<<PAGE 10>>>\n\nPrevention/Mitigation Curriculum\nIncreasingly, communities, businesses, and professional associations recognize the\nmutual benefits of cooperation and coordination in prevention program planning and\ndevelopment. For example, FEMA’s concept of Disaster Resistant Whole Communities\naims to bring together private industry, insurance providers, mortgage lenders, the real\nestate industry, homebuilding associations, citizens, and others to create model\ncommunities in high-risk areas. Other federal initiatives strive to promote understanding\nand cooperation between government and industry, and to simplify unnecessarily\nburdensome and confusing regulations.\nEveryone who can affect hazardous materials prevention/mitigation has a role in this\npartnership. The federal government establishes minimum safety standards, provides\nincentives and guidelines for compliance, conducts inspection and enforcement\nactivities, and supplies assistance and resources, including training. State governments\nserve as a conduit for federal programs, and provide supplementary programs,\nregulations, and assistance. Local jurisdictions identify and assess hazards, develop\nprevention strategies and plans that address community needs, and implement\nprograms to enforce safety standards and protect the public health.\nAlthough government plays a key role in hazardous materials prevention/mitigation,\norganizations that process, store, handle, and transport hazardous materials are in the\nbest position to actually eliminate or mitigate against accidents. Employers in both the\npublic and private sectors are ultimately responsible for the safety of chemical\noperations and for coordinating hazardous materials prevention/mitigation activities\nwithin the community. They accomplish these goals through programs and activities that\nare appropriate to the hazards involved and in full compliance with legal requirements.\nThe general public also has a role in hazardous materials prevention/mitigation. With\nadequate information, community groups, professional associations, and individual\ncitizens can provide valuable support and resources to government prevention programs\nand initiatives. They also contribute to hazardous materials prevention/mitigation by\npreparing individual and family preparedness plans that address household chemicals,\nand by maintaining safe homes and workplaces.\nIn addition to the concept of a public/private partnership, other aspects of this new\nphilosophy on prevention include the following:\n• A focus on safety must be evident during the complete life cycle of hazardous\nmaterials, from design and testing to production, storage, transportation, use,\ntreatment, and disposal. This approach implies methods to systematically\nevaluate entire operations, as well as comprehensive programs that address all\nphases of production and transportation operations.\n• Organizations that use hazardous materials should first attempt to eliminate the\npossibility of accidents or exposures by substituting inherently safer technologies\nor less hazardous substances in existing operations. If this approach is not\n2016 Prevention/Mitigation Training Guidelines – Page 10\n\n<<<PAGE 11>>>\n\nPrevention/Mitigation Curriculum\nfeasible, other measures should be considered to reduce the probability or\nseverity of accidents.\n• Communities and employers should recognize that costs for prevention may not\nbe extensive, and many measures will pay for themselves over time. Costs and\nbenefits should be established early in the planning process, even though it may\nbe difficult to estimate savings that accrue by avoiding accidents and exposures.\n• Safety management techniques and technologies are continually evolving. When\npossible, communities and professional associations should promote activities\nthat foster research, information sharing, technology transfer, and the\ndevelopment of a supportive regulatory and economic environment for\norganizational innovation.\nPrevention/Mitigation Legal Authorities\nHazardous materials safety efforts have continually expanded through many laws,\nregulations, and standards. These legal authorities address separate pieces of the\nhazardous materials problem, and are administered by different agencies at all levels of\ngovernment.\nOn the community level, planning for hazardous materials prevention/mitigation is often\nconsidered a natural extension of state and local governments’ responsibility for\ndeveloping emergency operations plans. In effect, planning team members “piggyback”\nand expand on the hazards analysis conducted for response planning to prepare\nprevention strategies and plans. These materials are often incorporated as an annex to\nthe community’s emergency operations plan. A number of federal laws, regulations, and\nguidelines apply to this process. (For more information, see the Hazardous Materials\nPlanning Curriculum Guidelines.)\n• Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)\n• OSHA Hazardous Waste Operations and Emergency Response (29 CFR\n1910.120)\n• Resource Conservation and Recovery Act (RCRA)\n• FEMA Emergency Operations Plan Requirements (44 CFR Part 302)\n• Guide for All-Hazard Emergency Operations Planning (FEMA SLG 101)\n• Hazardous Materials Emergency Planning Guide (NRT-1)\n• Technical Guidance for Hazards Analysis (EPA/FEMA/DOT)\n• Handbook of Chemical Hazard Analysis Procedures (FEMA/DOT/EPA)\n• National Fire Protection Association (NFPA) 400: Hazardous Materials Code\n• The Hazardous Materials Regulations (49 CFR Parts 100-185)\nPublic and private sector facilities that store, handle, or transport certain types and\nquantities of hazardous materials are also subject to federal contingency planning\nregulations. Although different requirements may apply to different facilities and\noperations, the National Response Team’s Integrated Contingency Plan (ICP) Guidance\n2016 Prevention/Mitigation Training Guidelines – Page 11\n\n<<<PAGE 12>>>\n\nPrevention/Mitigation Curriculum\nprovides a format for complying with the various planning regulations in one functional\nemergency response plan. Annex 7 of the ICP addresses prevention-based\nrequirements that are specified in the regulations or that may impact response activities.\nFederal statutes and regulations that specifically address hazardous materials\nprevention safety are listed below and described further in the appendix to these\nguidelines:\n• Hazardous Materials Transportation Act\n• Hazardous Materials Transportation Uniform Safety Act\n• Hazardous Materials Regulations (49 CFR Parts 171-180)\n• The Occupational Safety and Health Act of 1970\n• OSHA Process Safety Management of Highly Hazardous Chemicals (29 CFR\n1910.119)\n• OSHA Hazard Communication Standard (29 CFR 1910.1200/1926.59)\n• OSHA Safety and Health Program Management Guidelines (Federal Register\n54(18):3908-3916, January 26, 1989)\n• The Clean Air Act Amendments of 1990 (Public Law 101-549)\n• EPA Accidental Release Prevention Requirements: Risk Management Programs\nUnder Clean Air Act, Section 112(r)(7) (40 CFR Part 68)\n• The Hazardous Materials Regulations (49 CFR Parts 100-185)\nFinally, jurisdictions adopt and enforce standards and codes that define safe practices\nand procedures in the use of hazardous materials. These codes may govern design and\nconstruction of buildings, fire prevention, land use planning (zoning and occupancy),\nemployee safety, accident prevention, public health, environmental quality, and related\nareas. Several important national codes developed by cognizant professional\nassociations are described in Appendix A.\nHazardous Materials Prevention/Mitigation Programs\nThe key to hazardous materials prevention/mitigation programs is improving the safety of\nmethods used to store, transport, handle, and process hazardous materials. This is true whether\nthe requirement exists in business and industrial operations or in government-managed facilities\n(water treatment plants, sewer systems, utilities, etc.). Broad strategies and methods for\naccomplishing this goal include:\n• Use of less hazardous alternatives. Examples of this approach include the use of\ninherently safer technologies, substitution of non-toxic or less toxic materials,\nreassessment of plant layout to isolate hazardous substances, and reduction of chemical\nstockpiles through efficient management of inventory.\n• Engineering controls. Examples of engineering controls commonly used in hazardous\nmaterials operations include ventilation systems, containment systems, detection and\n2016 Prevention/Mitigation Training Guidelines – Page 12\n\n<<<PAGE 13>>>\n\nPrevention/Mitigation Curriculum\nmonitoring systems, robotic controls, physical barriers, isolation controls, electrical\nprotection, sprinklers, and pollution control technologies.\n• Safety information. Accurate safety information must be accessible to all end users,\nincluding secondary processors, distributors, transporters, contractors, and workers.\nTactics used to accomplish this objective include employee training, labeling and\nplacarding, and process safety information management systems. Establishing an\neffective labor-management dialogue on safety is also important.\n• Standard operating guidelines (SOGs). These guidelines distill the analysis conducted\nduring the hazard assessment, systems design, and safety planning phases into job-\nspecific procedures and worker performance standards and expectations. Development\nand enforcement of SOGs define and implement safe working practices for each\nhazardous materials application.\n• Administrative actions. Personnel management systems and procedures often have great\npotential for enhancing prevention, often at little cost. Examples include reducing\nemployee shift length, cross-training, or rotating employees to keep them alert; improving\nsecurity, access control systems, and isolation strategies; modifying maintenance and\nhousekeeping schedules and procedures; identifying safety as a factor in organizational\ngoals and objectives, worker performance reviews, and management incentives; and\nintegrating planning with the community and local health care facilities.\n• Personal protective equipment. When exposure is less controllable, adequate personal\nprotective equipment (PPE) and related training must be made available. Examples of\nPPE include chemical resistant gloves, aprons, face shields, respiratory protection, etc.\nAlthough prevention/mitigation is first and foremost a responsibility of hazardous materials users,\ngovernment oversight agencies, insurance companies, professional associations, community\ngroups, and others can do much to promote safety. Examples of activities used to motivate and\nsupport facilities and transporters in prevention include:\n• Legislation, regulations, and standards that clarify prevention requirements and\nprogrammatic guidelines\n• Community right-to-know policies and information management systems\n• Land-use planning and zoning (setback, density, relocation, land acquisition, etc.)\n• Plans review and permitting programs for building and operational systems designs\n• Inspections and enforcement of hazardous materials and other safety codes\n• Environmental and hazard monitoring systems\n• Public education and information activities\n• Disaster insurance (premium reductions, criteria for coverage, etc.)\n• Tax incentives/disincentives and financial resources\n• Methods to foster improved public/private sector coordination and cooperation\n• Research and information dissemination\n2016 Prevention/Mitigation Training Guidelines – Page 13\n\n<<<PAGE 14>>>\n\nPrevention/Mitigation Curriculum\nObviously, the concept of hazardous materials prevention/mitigation covers a broad spectrum of\nstrategies and tactics conducted by many different types of organizations. The nature of\nprevention programs is equally diverse, depending on such factors as the mission of the\norganization, the types and quantities of chemicals involved, financial and personnel resources,\nlegal requirements, etc. However, all hazardous materials prevention/mitigation programs should\nbe based on a thorough hazard assessment, and include a comprehensive and systematic\nprogram planning process appropriate to the organization’s needs.\nRationale for Hazardous Materials Prevention/Mitigation Training\nand Education\nOf all the hazardous materials prevention/mitigation strategies, training and education\nprograms may be the most effective. Well-designed training programs significantly\nreduce the number and severity of incidents arising from process operations, and assist\nin preventing small problems from leading to a catastrophic release. The Department of\nTransportation notes simply that “training is the best means of preventing hazardous\nmaterials accidents” (Training For the Safe Transportation of Hazardous Materials, DOT,\n1997).\nWhy is training so effective? It is because training directly addresses the common\nbarriers to effective hazardous materials prevention/mitigation efforts. Studies have\nidentified some of the barriers to effective hazardous materials prevention/mitigation\nprograms, as follows:\n• Inadequate information about chemical hazards and the causes of accidents,\nsafer technologies, and the costs associated with those technologies.\n• A lack of managerial awareness and expertise about preventive measures and\nregulatory requirements.\n• Organizational obstacles based on corporate attitudes.\n• Limited communications among public officials, employers, and workers.\n• Inadequate employee and citizen knowledge about safety and prevention.\nTraining and education programs targeted to the various groups that can potentially\ncontribute to prevention are an effective method for addressing these problems. Training\nprograms increase employee awareness of hazards and help workers understand the\nnature and causes of potential problems. They provide opportunities for individuals to\nlearn and practice safety systems and procedures in a risk-free environment. And they\ncontribute to the development of a safety culture within the organization that motivates\nworker participation in hazard identification, program planning, safety audits, incident\nreviews, and other prevention activities.\nTraining is also critical for public officials, executives, managers, and others not directly\ninvolved in hazardous materials operations. Promoting change within organizations is\nmost effective when the process starts at the top. Shifting the traditional focus from\nproductivity and emergency preparedness to prevention requires changing the mindset\n2016 Prevention/Mitigation Training Guidelines – Page 14\n\n<<<PAGE 15>>>\n\nPrevention/Mitigation Curriculum\nof decision-makers in government, business, and industry. The same is true for design\nprofessionals and technical experts—architects, engineers, consultants, etc.—that plan\noperational systems and contribute to policy development.\nRecognizing the importance and benefits of prevention training, OSHA, DOT, EPA, and\nother federal agencies have identified training requirements and guidelines for\nhazardous materials employers. General requirements are summarized in Appendix B;\ntraining managers may need to research more specific mandates for different industrial\nsectors and employer types.\nHazardous Materials Prevention/Mitigation Training Challenges\nAlthough hazardous materials prevention/mitigation training is mandated by law, and the\npotential benefits are well established, too few organizations place an adequate\nemphasis on this safety strategy. Several reasons exist for this state of affairs:\n• The benefits of hazardous materials prevention/mitigation are often poorly\nunderstood and difficult to quantify. As a result, some organizations place a low\npriority on prevention initiatives, including training. This is especially true in\nsmaller commercial operations, where safety information is limited and resources\nare tight.\n• Traditionally, employee training has focused on improving productivity, with\nprevention viewed as an adjunct to workers’ primary job responsibilities. Thus,\nhazardous materials prevention/mitigation training is not usually identified as a\nseparate requirement or curriculum area, with the attention and resources it\ndeserves.\n• Workplace safety is not identified as a separate competency in many\nprofessional schools of business management, architecture, engineering, public\nadministration, etc. Opportunities to deliver prevention training to these key\naudiences may be limited.\n• Hazardous materials prevention/mitigation covers a very broad range of possible\nsubject areas and audiences. The resulting scope of training program\nrequirements can be overwhelming for some communities and facilities.\n• Hazardous materials prevention/mitigation training is often highly technical and\ncomplex. Opportunities should be provided for students to practice key skills in a\nrealistic but safe environment. As a result, training delivery often benefits by the\nuse of specialized facilities and equipment that are beyond the resources of\nsome organizations.\n• Recruitment for training activities can be difficult because organizations and\naudience members may place a low priority on prevention, or view prevention as\nan ancillary duty to primary work responsibilities.\nHow individual training managers deal with these challenges will depend on the\norganizational situation they face—management priorities, training requirements, safety\n2016 Prevention/Mitigation Training Guidelines – Page 15\n\n<<<PAGE 16>>>\n\nPrevention/Mitigation Curriculum\nconcerns, resources, etc. However, three general principles can be stated: (1)\neducational activities designed to heighten the awareness of decision-makers about the\norganizational benefits of prevention should be considered early in program planning; (2)\na comprehensive hazardous materials prevention/mitigation training needs assessment\nshould be prepared to identify priorities, appropriate training methodologies, and\ntechniques for demonstrating competence; and (3) whenever possible, employee\nparticipation should be encouraged in the training development process.\n2016 Prevention/Mitigation Training Guidelines – Page 16\n\n<<<PAGE 17>>>\n\nPrevention/Mitigation Curriculum\nHazardous Materials Incident Response\nCurriculum Guidelines\nHazardous Materials\nPrevention/Mitigation\nAwareness\n2016 Prevention/Mitigation Training Guidelines – Page 17\n\n<<<PAGE 18>>>\n\nPrevention/Mitigation Curriculum\nIntroduction\nPrevention/Mitigation Awareness describes the introductory training requirements of all\naudiences in the Hazardous Materials Prevention/Mitigation Curriculum. Instruction in\nthis area is intended to give participants a general knowledge base about hazardous\nmaterials prevention/mitigation that can serve as a foundation for subsequent job-\nspecific training.\nThe goal of Prevention/Mitigation Awareness training is to enhance participants’\nunderstanding of the importance and benefits of hazardous materials\nprevention/mitigation, and to motivate them to seek additional information and\nassistance as needed. This goal is accomplished by providing students with (1) an\nintroduction to basic hazardous materials prevention/mitigation terminology and\nconcepts, (2) an explanation of individual and organizational roles in hazardous\nmaterials prevention/mitigation, and (3) an overview of common hazardous materials\nprevention/mitigation methods and activities.\n(Note: As defined here, Prevention/Mitigation Awareness is a common training requirement\nfor all audiences, not a unique audience category. This material would typically be\nincluded in training delivered to each of the audiences described in the following\nsections. It is presented as a separate category to minimize redundancy and to facilitate\nuse for mixed audiences, non-hazardous materials workers, and the general public.)\nTraining Audience\nThe training audience for Prevention/Mitigation Awareness includes everyone that has\nresponsibilities in hazardous materials prevention/mitigation or could influence\nhazardous materials prevention/mitigation efforts at the state and local levels.\nSpecifically included are employees of hazardous materials facilities, transportation\nworkers, and personnel in agencies and organizations that implement the c","truncated":true,"body_characters":228122}