Does Your Emergency Response Team Training Program Have _____ Gaps? A Compliance Perspective

Emergency response teams play a crucial role in ensuring workplace safety and preparedness. Establishing an effective emergency response team (ERT) training program is not only a best practice but is often a legal requirement. To assess the effectiveness of your ERT training program, it's essential to consider standards set by regulatory bodies such as the Occupational Safety and Health Administration (OSHA) and the National Fire Protection Association (NFPA). In this article, we delve into OSHA 1910.156(c)1 and NFPA 600 to identify potential gaps in your ERT training program.

OSHA 1910.156(c)1: Understanding the Foundation

OSHA 1910.156(c)1 outlines the minimum requirements for ERT training, emphasizing the need for regular training to ensure competency. The regulation specifies that training should include both initial and refresher training to maintain the proficiency of the emergency response team.

Commensurate Duties:

The duties of an emergency response team encompass a broad spectrum, from responding to fires (interior & exterior) and hazardous substance releases to providing medical assistance. OSHA mandates that training must cover these commensurate duties. This includes understanding the operation and limitations of emergency equipment, as well as proficiency in first aid and cardiopulmonary resuscitation (CPR).

Frequency:

The frequency of training is a critical factor in compliance. Initial training is necessary when an individual joins the ERT, ensuring they have a foundational understanding of their responsibilities. Refresher training, on the other hand, is required at least annually to keep skills sharp and knowledge up-to-date. It's important to note that the frequency may need adjustment based on changes in personnel, equipment, or procedures.

NFPA 600: Adding Depth to ERT Training

NFPA 600, Standard on Facility Fire Brigades, provides additional guidance on ERT training, focusing on the development and implementation of a comprehensive program.

Commensurate Duties:

NFPA 600 expands on commensurate duties by detailing specific competencies required for various emergency situations. This includes fire control, rescue operations, hazardous materials response, and emergency medical care. The standard emphasizes the need for tailored training programs to address the unique risks and challenges within a specific facility.

Frequency:

Similar to OSHA, NFPA 600 underscores the importance of regular training. It recommends quarterly drills for facility fire brigades to ensure that team members are well-prepared to respond to emergencies. Additionally, NFPA 600 highlights the significance of scenario-based training to simulate realistic emergency situations, allowing teams to practice their skills in a controlled environment.

Identifying Potential Gaps in Your ERT Training Program

1. Documentation and Recordkeeping: Evaluate whether your training program maintains comprehensive records of both initial and refresher training sessions. Confirm that records include details such as the topics covered, names of trainers, and dates of training.
2. Tailored Training: Assess whether your ERT training program is tailored to the specific risks and hazards present in your facility. Consider whether your team is proficient in handling the commensurate duties outlined in OSHA 1910.156(c)1 and NFPA 600.
3. Frequency of Training: Review the frequency of your ERT training sessions to ensure compliance with OSHA and NFPA standards. Verify that your program includes both regular drills and scenario-based training exercises.
4. Integration with Emergency Plans: Ensure that your ERT training program aligns with your facility's emergency response plans. Confirm that team members are familiar with the overall emergency procedures and can seamlessly integrate their roles within the broader emergency response framework.

In conclusion, maintaining a robust ERT training program requires a comprehensive understanding of OSHA 1910.156(c)1 and NFPA 600. Regular assessments of your training program against these standards will help identify and address any potential gaps, ensuring that your emergency response team is well-prepared to handle a range of emergencies within your facility.

If you are overwhelmed by the confusing complexity of OSHA and NFPA compliance standards for your ERT, you are not alone. The good news is our experienced staff at E-Med Training Services, LLC is here to answer your compliance questions free of charge regarding equipment, training, and record keeping; as well as many of the other emergency response regulations.

Simply contact us at info@emedtraining.com with your compliance questions and we will work to find answers promptly; always free of charge, and never any pressure to purchase our services.

For free assistance in finding “blind-spots” in your ERT program, click the link below to get your free PDF checklist designed to quickly find the most troublesome compliance gaps. This free checklist is Powered by BrigadeIQ, an E-Med Training Service company.

Why is it free? Because the risk of negative consequences for Emergency Response Teams are simply too great to ignore.

J. TRAVIS CARRICATO has been a member of the fire service for over 27 years. He retired as an Operations Division Chief with the Columbia (SC) Fire Department and served as a member of SC-TF1 for over nine years, rising to the position of Task Force Leader. Carricato is also the principal owner of E-Med Training Services, LLC and BrigadeIQ.com which specializes in Emergency Response training and compliance solutions for the industrial sector. An accomplished speaker and instructor, he has delivered training programs nationally as well as internationally in Russia, Saudi Arabia, China, and Kuwait.