As almost everyone has felt the financial squeeze at some point during their career and we seem to be feeling it more and more these days. As auditors that travel the world, we are still seeing the negative ripple effects of the 2009/2010 recession in the United States in 2017 and probably will continue to see them in 2018 in the EHS arena. The effect I want to talk about in this article is the change from in-house emergency response training to using off-site/open enrollment type courses to meet the facility's emergency response training needs. This is NOT about bashing these off-site training organizations, as most of them provide a world-class level of training, but there is ONE HUGE FLAW in using them to meet all of our ER training needs…

We are training using their response equipment!

I realize some schools require you to bring your own response PPE (suits, SCBA’s, etc.) and these types of schools are better at limiting this flaw’s impact; but even they have some serious limitations.

For example, during an audit earlier this year we came across a situation that had festered for a number of years and had become a significant risk for the facility and its responders.

When the great recession occurred in 2009/2010 the company laid off a portion of its workforce. One area hit especially hard was the EHS group, more specifically the emergency response manager (main Incident Commander) and three shift coordinators (shift commanders) were laid off and their duties were “contracted out”.

Side Note: it is our opinion that this type of significant change on the facility’s ability to manage the emergency response program should have gone through a MOC and maybe, just maybe, this MOC may have shed some light on how this change was going to impact the entire facility’s ability to respond to emergencies.

The normal type of contracting for items like fixed fire protection system inspections, portable fire protection system inspections, PPE monthly inspections, can be managed quite well using well trained and experienced “contractors”. But when it comes to training, we begin to see some serious issues.

After the economy got back on its feet the facility began to bring back those employees who were laid off.  For those who had moved on, the facility hired new personnel to take their place.

Another side note to keep in mind, this facility was a union facility and when a layoff occurs, it is the youngest/least senior personnel who take the brunt of layoffs. And anyone who has managed an in-house response team knows that these teams are usually made up of the younger employees for a variety of reasons. So the Emergency Response Teams (ERT) took enormous hits when it came to staffing, so much to the point that the facility had to rethink their plans for all the different types of emergencies they could face.

The four personnel: ER manager and shift ER supervisors who were let go, were not called back as their positions were “eliminated” (another flag for a MOC as this permanent change had huge impacts on the ER programs and functions within the facility; including major revisions to several ER programs/plans). And it is the elimination of these four (4) jobs/roles that lead me to write this article.

You see these four professionals had developed, implemented and managed a fully functional fire/HAZMAT/EMS/Rescue (all types) management system. They did EVERYTHING in-house, as they all believed that “if you want it done right - do it yourself”. This mindset could be seen in all the posters and banners that hung in there ER Services building. This means that all members of the ER teams received all of their training in-house, using their own response equipment (which they also inspected as part of being on the team), and trained in their respected units throughout the year. This facility was without a doubt one that I had come to admire over the years and always looked forward to spending time with these guys - they just loved emergency response!

With their departure, the EHS manager, who had zero ER experience and very limited exposure to OSHA standards, was bidding out 24-hour HAZMAT courses at some of the country's top ER training schools/universities. The facility had over 75 operators, maintenance personnel, and management that needed to receive their base-line HAZMAT training. The management team sold this new training method as a way to get a new perspective on new techniques, as if the training the teams had received over the years had grown out-dated. I can assure you, the training these men put on was world-class, using the most up-to-date techniques with the latest technology. But none the less, the tides had shifted and the facility was now deep into spending hundred’s of thousands of dollars sending their personnel all around this great nation attending different fire/HAZMAT/rescue schools.

Problem #1 (and my biggest issue)

ERT members were sent to some of the finest fire/hazmat/rescue schools in the country and while they were there they were taught how to use THE SCHOOLS RESPONSE EQUIPMENT - not the equipment the team would actually be using back at the plant! This is a HUGE MISTAKE - case in point… during an interview with an operator who had been on the team for less than a year, he was asked what’s the greatest limitation of your SCBA. He got the answer half right, as he stated “the amount of breathing air in the cylinder”; however, as he continued to answer the question he made the comment “4500 psi is not a lot of air when you really need it”. This additional comment was troubling, so we asked him how much air the SCBA’s the ERT uses has and he stated 4500 psi. Even the PSM Manager, whose was not part of the ERT, knew the facility was still using 2216 psi bottles.  But since this responder had only been trained in SCBA's usage using a 4500 psi system, he was not even aware SCBA's could have different styles and operating pressures!

I then asked the operator if he had ever donned a SCBA while working at the site, either as an operator or a responder. He stated no. So we asked him if he could demonstrate to us how to don/doff one of the ER SCBA’s. He agreed and we went to the truck bay, opened a door and the look on his face said it all…

He had trained with the latest and greatest SCOTT SCBA which has a face piece regulator with a high-pressure airline, the facility’s HAZMAT team used MSA’s which has the regulator on the belt with a low-pressure airline going to the face piece. He eventually figured it all out; but when I asked to see his training records on that style/brand of SCBA, the facility could only provide his cert from his Fire School training.

As we dug into this, we found that 100% of the personnel who had received their training at an off-site school had not received any additional training on the specific PPE they would be wearing while a responder at the facility. This is a MAJOR NO-NO; personnel MUST be trained on their specific pieces of PPE and its limitations, use, and care. We found similar concerns with air-purifying respirators, LEVEL A suits, Turn-out Gear, gloves, boots, etc. You name, it seemed that all the new responders were trained on different brands, makes, models, types of PPE than what they would be using at the facility.


Problem #2
The emergency response equipment, from the air monitors to the hand tools, they were trained to use was different. And again, the facility had not conducted any additional training for these responders on the specific response equipment the facility uses. Sadly, this matter had been brought to “managements” attention, as some of the operators had voiced concerns that they needed training on the “gas meters”; however, these operators who voiced the concerns were part of the ERT and the EHS manager “assumed” that they were receiving training on "gas meters" at their ER training schools and that this was just some type of “union ploy to avoid newly assigned duties and responsibilities”.


Problem #3
When different members train at different schools, especially when these schools do a lot of hands-on training, we loose the cohesiveness of everyone being trained under the same umbrella. Now I am all for sending my officers to different schools so they can work with different props and evaluate other schools for potential business, but the team members MUST TRAIN together to become a TEAM. Yes I know it is virtually impossible to get all fire brigade members to train together on the same prop and the same time, but damn we should at least try and make this a consideration when scheduling training.  And I am well aware that personnel change shifts and jobs over their ERT careers and that they should be capable of responding with any make-up of the ERT; I am merely suggesting that sending people from the same shift to different fire schools merely as a means of convenience should be reconsidered!


Problem #4
The Confined Space Rescue team received training in a space that in no-way reflected the specialized spaces present at the facility. During interviews, ER members stated that one particular school had a prop that “an untrained monkey could have made the rescue from the space”. In other words, the course was not challenging enough to prepare the team for what they would face. To top this off, management decided that one year they could not interrupt production so they needed the “annual mock rescue” to be done off-site. Sadly, the school that everyone complained about, stepped up and said they could do the mock rescue at their facility and signed a three (3) year contract to perform the mock rescue(s) at their off-site facility and of course using their own rescue gear, which is totally different than what the site uses and in a space that in no-way resembles the types or configurations present at the facility.  To me, this is a double whammy!!  Not only is the CS/High Angle Rescue Team receiving their baseline training, they now also receive their refreshers at the same location with the same equipment and prop!  In other words, they may never actually train with their CS rescue equipment until that dreaded moment they are forced to actually affect a rescue!

I could go on, but I don’t think it is necessary. Needless to say, there was a lengthy discussion with management about their ER management practices, changes that need a Management of Change review, and ER training. And in closing, the plant manager told us that eliminating those four (4) jobs was the worst decision the business every made. Costs continued to increase dramatically and now they see their solution (e.g. contracting it all out) was a complete failure. They, of course, wanted to throw the EHS manager under the proverbial bus, but we came to her aid and explained how it was not her fault; she was forced into the role and she told the PM and HR manager that she was in no way equipped with the skills to manage the safety and ER aspects of the job. Their response… "we’ll let you supplement with contractors in those areas you feel uncomfortable with".

I want to emphasize again, most of these schools around the country are truly world-class and can provide some of the most eye-opening live fire training seen anywhere in the world; but even they will admit their “model” has flaws, in that they can NOT train our people to a level where they could return to their facility and participate in an emergency response the very next day. All be damned, certificate in hand or not, they MUST receive training on the specific Emergency Response Plan/Procedures, specific PPE, and specific tools and equipment they will be using when responding on site. I encourage businesses with large risks/hazards that they use some of these university fire/hazmat/rescue schools so that responders can gain more and more hands-on experiences; however, with that recommendation comes the reality, that these schools just cannot meet 100% of our training REQUIREMENTS. And using these off-site schools/consultants 100% of the time (i.e. baseline and annual/quarterly refreshers) is an ABSOLUTE NO-NO.

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