HAZWOPER training for utility crews stopping leaks

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 22, 1991

Mr. Frank E. Frye
Regulatory Compliance Specialist
Lafayette Utilities System
Water Division
[Recipient address omitted]
Dear Mr. Frye:

This is in response to your inquiry to Roslyn Ammons concerning the application of the Hazardous Waste Operations and Emergency Response standard (29 CFR 1910.120) to utility crews. Please accept my apology for the delay in this response. Your letter was inadvertently misplaced in the docket for this standard.

You cited the following two emergency incidents where there has been controversy over the classification of the level of response for the utility workers.

1. A transformer (assumed to be PCB) had a hole in the bottom of it and was leaking oil. The Electric Utilities crews climbed the pole and plugged the leak, then removed and replaced the transformer. During this procedure, other electric workers cleaned up the spill area. Meanwhile the Fire Dept. HazMat Team stood by and watched the operations.

2. An unknown source of a gas leak caused three explosions, damaging a building, a transformer and a man hole. The Civil Defense was activated. The electric utility workers (while wearing SCBA units) did all the digging and removal of conduits, in search for the gas source. The Fire Dept. stood by with water lines in case of fire or another explosion.

You mentioned that the fire department considered the utility workers skilled support personnel that need no training while the utility workers considered their activity at the technician level. Both the fire department and utility company are required to have an emergency response plan which addresses personnel roles, lines of authority, training, and communication (see 29 CFR 1910.120(q)(2)). However, the city of Lafayette could have a comprehensive plan for all city employees. The amount of training must be based on the duties and functions to be performed by each responder.

If the plan is to have personnel take an aggressive role in responding for the purposes of stopping the leak then training at least to the technician level is appropriate.

I hope this information is helpful.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

[The September 5, 1990 utility inquiry and earlier correspondence reproduced on the OSHA page are omitted here.]