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Parent Category: Safety Info Posts

Category: Emergency Response

Published: 07 May 2017

OSHA has two (2) significant LOIs, both aligning, and their HAZWOPER CPL that do a really good job of explaining how one crosses over from PSM SOP actions to actions that would fall under the definition of an “emergency response”, thus moving compliance from 1910.119 to 1910.120. I have presented both of these LOIs and the pertenant portions of the CPL below for discussion. The one point that I believe gets lost in these discussions is that someone on-site must have the training and authority to:

1. recognize the difference between an incidental release and one that calls for an “emergency response”
2. establish the release is an “emergency” and set-up an Incident Command system so that operations personnel taking defensive actions within the “Warm Zone” are accounted for and controlled in their actions.

As we can see, all three (3) documents align in where they draw the line from when a PSM Operator becomes an Emergency Responder...

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