COMMANDER /COORDINATOR
There is a funny scene in the movie Zoolander, when an overjoyed Fábio thanks the award show audience for the best Actor “Slash” Model Award and not the other way around. It reminds me of differences between an “On-Scene Commander “Slash” Emergency Coordinator”
OSHA On-scene incident commanders are required by employers to protect Hazmat teams from exposure during unintentional hazardous substance releases under 29 CFR 1910.120 Hazardous waste operations and emergency response.
Worker Protection
OSHA On-scene incident commanders protect workers and assume control of a hazardous substance release or an incident scene. They must understand and be able to implement the employer's Emergency Response Plan and their Incident Command System (ICS). They must know how to implement the Local and State Emergency Response Plans. In addition they need to understand the hazards and the risks associated with employees working in chemical protective clothing and understand the importance of decontamination procedures.
THE ENVIRONMENTAL PROTECTION AGENCY
(EPA) 40 CFR Part 262
HAZARDOUS WASTE
EMERGENCY COORDINATOR
EPA Emergency coordinators are required to protect the environment in and around Large Quantity Hazardous Waste Generator Facilities (LQG), 40 CFR 262.264 during emergencies involving their hazardous waste.
Environmental Protection
EPA’s 40 CFR 262.264 requires that Large Quantity Hazardous Waste Generators (LQG), have Emergency Coordinators on site or on call to respond in a short period of time to hazardous waste emergencies to protect the environment, by coordinating and implementing the LQG’s Contingency Plan. Emergency coordinators must be thoroughly familiar with all aspects of the generator's hazardous waste contingency plan, all hazardous waste operations and activities at the facility, the location and characteristics of all hazardous waste handled, the location of all relevant records within the facility, and the facility's layout. In addition, this person must have the authority to commit the resources needed to carry out the employer's written LQG hazardous waste contingency plan.
If these both sound similar or almost the same you’re probably starting to get it. But they aren't. OSHA will not ask about your emergency coordinators, nor will EPA ask about your on-scene commanders, unless they are the same person.
DOWNLOAD THE EPA/DOT/OSHA ONE PLAN
HERE
Many years ago I modeled for my father, as disturbing as that may sound, in the early hazardous materials seminar training programs he photographed, produced and presented. My brothers and I were used as actors “slash” models to portray the drivers and dock personnel, passing shipping papers and placards. But don't worry, I am not holding out for any peer recognition, even if there is a Zoolander III.
Get it right, now! Sign up for new Hazmat Rob’s Newsletter with the free “DOT / EPA / OSHA Regulatory Update Service” and Rob’s blog with our subscribe button to the right.
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc.