I have been involved with emergency response for over 30 years. During those years, I trained thousands of municipal and private responders, specializing in traditional Hazardous Materials Responses. During all those years, when I received continuing training from the likes of Texas A&M, LSU, NFA, and SERTC, these advanced courses only validated my first HAZWOPER course at Murray State University in 1991.
Today, I got my first question, which I could not answer! So, I am turning to the ER and Safety community to see who can provide the "source" of this DECON practice...
NOTE:
The following "guide" from OSHA was NOT enough since a "guide" is non-enforceable.
The following document, Field Standard Operating Procedures Manuals: FSOP #7 Decontamination of Response Personnel, is ARCHIVED, and their legal team says it's not enforceable.
There is even a 1988 training manual from the NIH that says the same thing that I train to, but it is NOT enforceable.
The following NIH Training Manual
And I HATE it when companies play these compliance games as if OSHA/EPA/DOT standards are the best for our responders! But they have me stumped on this one.
So, where does a regulatory agency/authority require:
- The first line of DECON must be just one (1) level less than the entry team PPE
- Operations Level personnel can not DECON HAZMAT TECHS donned in LEVEL A PPE
I understand the logic of these "practices," and I have followed these practices and trained in these practices my entire career. But I was a bit caught off guard when you're doing an eight-hour refresher for a new client, AND the boss challenged the practice. This client wanted to hear it or see if it was from OSHA, EPA, DOT, etc., not from me, the person they hired to perform the training. Regardless that the students understood the reasoning behind the practice and we trained to it in our drill, when the boss arrived (and he/she did not support it), they needed an OSHA/EPA/DOT written requirement if they were to include this "practice" in their ERP.
And if anyone wants to debate these practices, I am totally open to that debate.
Ending this on a fun note - the 2024 DECON line!
