Hazardous Waste Operations and Emergency Response (HAZWOPER) 29 CFR 1910.120 Rev 1: 03/18/2013 The information in this presentation is provided voluntarily by the N.C. Department of Labor, Education Training and Technical Assistance Bureau as a public service and is made available in good faith. This presentation is designed to assist trainers conducting OSHA outreach training for workers. Since workers are the target audience, this presentation emphasizes hazard identification, avoidance, and control – not standards. No attempt has been made to treat the topic exhaustively. It is essential that trainers tailor their presentations to the needs and understanding of their audience. The information and advice provided on this Site and on Linked Sites is provided solely on the basis that users will be responsible for making their own assessment of the matters discussed herein and are advised to verify all relevant representations, statements, and information. This presentation is not a substitute for any of the provisions of the Occupational Safety and Health Act of North Carolina or for any standards issued by the N.C. Department of Labor. Mention of trade names, commercial products, or organizations does not imply endorsement by the N.C. Department of Labor.

An Outline of the Provisions of 1910.120 Scope, application, and definitions Safety and health program Site characterization and analysis Site control Training Medical surveillance Engineering controls, work practices and personal protective equipment (PPE) Monitoring Informational programs Handling drums and containers Decontamination

An Outline of the Provisions of 1910.120 Emergency response by employees Illumination Sanitation at temporary workplaces New technology programs Operations under RCRA Hazardous substance release Photo: NCDOL-OSH Division 3

Purpose 1910.120 The purpose of HAZWOPER is to improve the ability of employees and employers to respond to emergencies caused by releases of hazardous substances. Photos: NCDOL-OSH Division 4

Scope Covers the following operations: Clean-up operations required by a governmental body, whether federal, state, local or other, involving hazardous substances that are conducted at uncontrolled hazardous waste sites. Corrective actions involving clean-up operations at sites covered by Resource Conservation and Recovery Act (RCRA). Voluntary clean-up operations at sites recognized by federal, state, local or other governmental bodies as uncontrolled hazardous waste sites. 5

Scope 1910.120(a)(1) Operations involving hazardous wastes that are conducted at treatment, storage and disposal facilities licensed under the Resource Conservation and Recovery Act (RCRA). Emergency response operations for release of, or substantial threats of release of, hazardous substances. Photo: NCDOL-OSH Division 6

Scope 1910.120(a)(1) Unless The employer can demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards. Photo: MS Clipart 7

Definitions Hazardous substance Any substance to which exposure results or may result in adverse effects on the health or safety of employees. Any substance defined under section 101(14) of CERCLA Any biologic agent and other disease causing agent Listed by the U.S. DOT (49 CFR 172.101) Hazardous waste MS Clip Art 8

Definitions Hazardous Waste Hazardous waste operations EPA defines hazardous waste as by-products of society that can pose a substantial or potential hazard to human health or the environment when improperly managed. It possesses at least one of four characteristics (ignitability, reactivity, toxicity, or corrosiveness), or appears on special EPA lists. Hazardous waste operations Any operation conducted within the scope of the HAZWOPER standard. Photo: NCDOL-OSH Division 9

Definitions Hazardous materials response (HAZMAT) team An organized group of employees, designated by the employer, who are expected to perform work to handle and control actual or potential leaks or spills of hazardous substances. Photo: NCDOL-OSH Division 10

Definitions Emergency response 1910.120(a)(3) Emergency response A response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual aid groups, local fire departments, etc.) Photo from NC Emergency Management 11

Definitions Incidental release Release of a hazardous substance that does not pose a significant safety or health hazard to employees in the immediate vicinity or to the worker cleaning it up, nor does it have the potential to become an emergency. Illustration from MS Clipart 12

Definitions Post emergency response 1910.120(a)(3) Post emergency response That portion of an emergency response performed after the immediate threat of a release has been stabilized or eliminated and clean-up of the site has begun. Photo: NCDOL-OSH Division 13

Safety and Health Program 1910.120(b)(1)(i) Employers shall develop and implement a written safety and health program for their employees involved in hazardous waste operations. Illustration from MS Clipart Safety & Health Program Safety & Health Program 14

Safety and Health Program 1910.120(b)(1)(ii) Program shall incorporate: Organizational structure Comprehensive work plan Site-specific safety and health plan Safety and health training program Medical surveillance program Employer’s standard operating procedures for safety and health Any necessary interface between general program and site-specific program MS Clip Art 15

Safety and Health Program 1910.120(b)(1)(iv)-(v) Contractors and subcontractors Shall be informed of: Emergency response procedures Any potential fire, explosion, health, safety or other hazards of the operation Program availability Shall be made available to any contractor or subcontractor MS Clip Art 16

Safety and Health Program 1910.120(b)(2) Organizational structure Elements General supervisor Site safety and health supervisor Other personnel needed for HAZWOPER Lines of authority, responsibility and communication Organizational structure shall be updated as necessary. MS Clip Art 17

Safety and Health Program 1910.120(b)(3) Comprehensive workplan shall: Define anticipated clean-up activities Define work tasks and objectives Shall establish personnel requirements Shall provide for the implementation of training Provide for implementation of informational programs Implementation of medical surveillance program 18

Safety and Health Program 1910.120(b)(4) Site-specific safety and health plan Elements Hazard analysis for each site task Employee training assignments Personal protective equipment Used by employees for each site task Medical surveillance requirements Frequency and types of air monitoring Personnel Environmental sampling MS Clip Art 19

Safety and Health Program 1910.120(b)(4) Site control measures Site map Work zones Use of buddy system Site communications Safe work practices Identification of nearest medical facilities Decontamination procedures Emergency response plan Confined space entry procedures Spill containment program MS Clip Art 20

Site Characterization/Analysis Hazardous waste sites shall be evaluated to identify specific site hazards and to determine the appropriate safety and health control procedures needed to protect employees. Photo; Raleigh Fire Department 21

Site Characterization/Analysis Preliminary evaluation Performed prior to site entry Hazard identification Conditions that may pose inhalation or skin absorption hazard that are immediately dangerous to life or health (IDLH) shall be identified. MS Clip Art 22

Site Characterization/Analysis Required information Location and approximate size of the site Description of response/job to be performed. Duration of employee activity Site topography and accessibility Expected safety and health hazards Status and capabilities of emergency response teams Expected or involved hazardous substances 23

Site Characterization/Analysis Personal protective equipment Shall be provided and used during initial site entry If respiratory protection is warranted, an escape SCBA of at least five minutes shall be carried. Level B PPE shall be provided if sufficient information is not available to identify the hazards. Once hazards identified, the appropriate PPE shall be selected. MS Clip Art 24

Monitoring 1910.120(c)(6) Shall be conducted during initial site entry when the site evaluation produces information which shows the potential for ionizing radiation or IDLH conditions, or when the site information is not sufficient reasonably to eliminate these conditions

Risk Identification 1910.120(c)(7)+(c)(8) Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances shall be identified. Employees who will be working on the site shall be informed of any risks that have been identified. (Photo courtesy of Argonne National Laboratory (US Federal Government))

Training 1910.120(e)(1) Employees shall not be permitted to participate in or supervise field activities until they have been trained to a level required by their job function and responsibility. Photo: NCDOL-OSH Division 27

Training Program Elements Names of personnel and alternates responsible for site safety and health Safety, health and other hazards on site Safe use of engineering controls and equipment on site Work practices by which the employee can minimize risks from hazards Use of PPE Medical surveillance requirements Contents of site safety and health plan Photo from NCDOL-OSH Division 28

Initial Training General site workers Training Equipment operators 1910.120(e)(3)(i) General site workers Equipment operators General laborers Supervisory personnel Training Minimum 40 hours off-site Three days field experience—minimum Photo from NCDOL-OSH Division 29

Initial Training Workers on-site to complete specific limited tasks 1910.120(e)(3)(ii) Workers on-site to complete specific limited tasks Ground water monitoring Land surveying Geophysical surveying On-site workers unlikely to be exposed over permissible exposure limits (PEL) Training Receive 24 hours of instruction off-site One day actual field experience Clip Art 30

Initial Training Regular on-site workers Training 1910.120(e)(3)(iii) Regular on-site workers Exposures under PEL and respirators not required Training Receive 24 hours of instruction off-site One day actual field experience Clip Art 31

Initial Training Workers with 24 hours of training Training 1910.120(e)(3)(iv) Workers with 24 hours of training Who become general site workers or are required to wear respirators Training Receive 16 additional hours of instruction off-site Two days of actual field experience Photo Raleigh Fire Department 32

Initial Training Management and supervisors Training Supervise employees engaged in hazardous waste operations Training Receive 40 hours of instruction off-site Three days of actual field experience Photo Raleigh Fire Department 33

Initial Training Management and supervisors Training may be reduced to 24 hours and one day if only responsible for: Workers on site occasionally Workers exposures under permissible exposure limits Photo Raleigh Fire Department 34

Qualifications for Trainers Trainers shall be qualified to instruct employees about the subject matter that is being presented. Instructors shall be competent and knowledgeable in subject matter. Means possessing the skills, knowledge, experience, and judgment to perform assigned tasks or activities satisfactorily as determined by the employer 35

Qualifications for Trainers Qualifications shown by academic degrees, completed training courses and/or work experience. OSHA does not certify instructors. Illustration from MS Clip Art 36

Training Certification Employees shall be certified by an instructor as having completed the training. Those not certified are prohibited from engaging in hazardous waste operations. Written certificate Illustration: NCDOL OSH Division 37

Equivalent Training 1910.120(e)(9) Employers who can show documentation or certification that an employee has equivalent training and/or work experience. Initial training not required Employees new to a site must receive site-specific training before entry. MS Clip Art 38

Equivalent Training 1910.120(e)(9) Equivalent training includes any academic training or the training that existing employees might have already received from actual hazardous waste site experience. Photo; Raleigh Fire Department 39

Refresher Training 1910.120(e)(8) Employees, managers and supervisors shall receive eight hours of refresher training annually. Photo from NCDOL-OSH Division 40

Training FAQ Interpretation Is computer-based training acceptable for refresher training? Standard Interpretation [11/22/1994] - The use of computer-based training to satisfy OSHA training requirements. May meet some refresher training requirements Not sufficient by itself MS Clip Art 41

Training FAQ What if refresher training isn’t received in 12 months? Interpretation What if refresher training isn’t received in 12 months? Standard Interpretation [03/12/1993] - Hazardous waste operations and emergency response lapsed refresher training requirements. If the date of refresher training has lapsed Repeat of initial training must be based on the employee’s familiarity with safety and health procedures used on site. Employee should take next available refresher training course. MS Clip Art 42

Training FAQ Can refresher training be given in segments? Interpretation Can refresher training be given in segments? Standard Interpretation [07/21/1992] - Refresher training and HAZWOPER Refresher training may be given in segments so long as the required eight hours have been completed by the employee’s anniversary date. MS Clip Art 43

Training Records Recordkeeping Appendix E Recordkeeping Should be maintained for a minimum of five years after the training date HAZWOPER Illustration: Microsoft PowerPoint 44

Medical Surveillance 1910.120(f) Instituted by the employer for the following employees: Exposed to hazardous substances or health hazards at or above the PEL Employees who wear a respirator 30 days or more a year Employees who are injured, become ill or possible overexposure Members of HAZMAT teams (Photo courtesy of MS Clip Art.) 45

Medical Surveillance Medical examinations shall be made available: 1910.120(f) Medical examinations shall be made available: Prior to assignment At least once every twelve months At termination of employment As soon as possible after notification that employee has developed signs of overexposure More frequently as determined by a doctor At no cost to employee Without loss of pay Reasonable time and place MS Clip Art 46

Medical Surveillance Physician’s written opinion 1910.120(f)(7) Physician’s written opinion Employer furnish the employee with a copy of written opinion Whether employee has any medical conditions that place employee at increased risk Recommended limitations on employees assignments Results of medical examination Statement that employee has been informed of results MS Clip Art 47

Medical Surveillance Records 1910.120(f) Recordkeeping Employee exposure and medical records (1910.1020) Medical record for each employee shall be preserved and maintained for at least the duration of employment plus 30 years. Photo from MS Clipart 48

Engineering Controls and Work Practices Engineering controls and work practices are the preferred means to control employee exposure. Instituted to reduce and maintain employee exposure to or below the permissible exposure limits. Employee rotation prohibited except when there is no other way of complying with ionizing radiation dose limits. Photo: Raleigh Fire Department 49

Engineering Controls and Work Practices May include: Equipment operated remotely Removing non-essential employees from potential exposure Wetting down dusty operations Locate employees upwind of hazard Photo: OSHA.gov 50

PPE 1910.120(g)(3) The purpose of PPE is to shield or isolate individuals from the chemical, physical and biologic hazards that may be encountered. Four categories Level A Level B Level C Level D Photo from NCDOL-OSH Division 51

PPE - Level A Selected when the greatest level of skin, respiratory, and eye protection is required. Totally-encapsulating chemical protective suit Full face-piece SCBA Gloves (inner/outer) Boots, boot-covers Disposable protective suit Photo from National Institutes of Health 52

PPE—Level B Selected when the highest level of respiratory protection is necessary but a lesser level of skin protection is needed. Full face-piece SCBA Hooded chemical resistant clothing Gloves (inner/outer) Boots, boot-covers Photo from NCDOL-OSH Division (Anthony Bonapart, former NCDOL employee at OTI) 53

PPE—Level C Selected when the concentration(s) and type(s) of airborne substances is known and the criteria for using air purifying respirators are met. Full-face or half mask, air purifying respirator (NIOSH Approved) Hooded chemical resistant clothing Gloves inner/outer Boots, boot-covers Photo: U.S. Department of Veteran Affairs 54

PPE—Level D A work uniform affording minimal protection. Coveralls Gloves Glasses Boots, chemical resistant steel toe Photo: Microsoft Clip Art 55

Monitoring-Initial Entry 1910.120(h)(2) Initial entry Monitor to identify IDLH condition Photo: OSHA.gov 56

Periodic Monitoring 1910.120(h)(3) When the possibility of IDLH condition or flammable atmosphere has developed Photo: OSHA.gov 57

Monitoring of High-Risk Employees After the actual clean-up phase commences, the employer shall monitor those employees likely to have the highest exposures. Photo: OSHA.gov 58

Informational Programs Employers shall develop and implement a program, which is part of the safety and health program, to inform employees, contractors and subcontractors (or their representative) of the level and degree of exposure likely to occur. MS Clip Art 59

Drums and Containers Handling drums and containers 1910.120(j) Handling drums and containers General requirements for drum and container handling Procedures for opening drums and containers Materials handling equipment Radioactive, shock sensitive and lab waste Sampling of drums and containers Shipping and transporting Tanks and vaults Photo: Microsoft Clip Art 60

Decontamination 1910.120(k)(2) Prior to site entry, decontamination procedures must be: Implemented Developed Communicated to employees Photo: MS Clip Art 61

Decontamination 1910.120(k)(2) Site safety and health supervisor must monitor effectiveness of the decontamination procedure. Photo taken by NCEM at NCSU Mass Casualty exercise (Raleigh fire dept demonstrating decontamination) 62

Decontamination 1910.120(k)(5) + 1910.120(k)(8) Equipment and PPE must be decontaminated or disposed of in a proper manner. Regular showers and change rooms must meet the requirements of the OSHA sanitation standard—1910.141(d)(3) Illustration: Microsoft Clip Art 63

Uncontrolled Hazardous Waste Sites An uncontrolled hazardous waste site is defined as an area where an accumulation of hazardous substances creates a threat to the health and safety of individuals, the environment, or both. Emergency response by employees A written emergency response plan is required. Employers who will evacuate all personnel and not allow them to participate in response efforts are exempt from this requirement, but must prepare an emergency action plan as required by 29 CFR 1910.38. 64

Uncontrolled Hazardous Waste Sites Elements of emergency response plan Pre-emergency planning Personnel roles, lines of authority, training and communication Emergency recognition and prevention Safe distances and places of refuge Site security and control Evacuation routes and procedures MS Clip Art Emergency Response Plan 65

Uncontrolled Hazardous Waste Sites Decontamination procedures Emergency medical treatment and first aid Emergency alerting and response procedures Critique of response and follow-up PPE and emergency equipment MS Clip Art 66

Illumination Areas accessible to employees shall be lighted. Photo: Microsoft Clip Art 67

Illumination Foot Candles Area or Operations 5 General site areas 3 Excavation and waste areas, accessways, active storage areas, loading platforms, refueling, and field maintenance areas. Indoors: warehouses, corridors, hallways, and exitways. Tunnels, shafts, and general underground work areas; (Exception: minimum of 10 foot-candles is required at tunnel and shaft heading during drilling, mucking, and scaling. Mine Safety and Health Administration approved cap lights shall be acceptable for use in the tunnel heading.) 10 General shops (e.g., mechanical and electrical equipment rooms, active storerooms, barracks or living quarters, locker or dressing rooms, dining areas, and indoor toilets and workrooms.) 30 First aid stations, infirmaries, and offices. Table H-120.1 Illumination

Sanitation Sanitation at temporary workplaces Requirements Adequate supply of potable water and outlets for nonpotable water Food handling shall meet applicable laws Adequate washing facilities Showers and change rooms provided Photo: ASH 69

Minimum number of facilities Sanitation Table H-120.2 Sanitation at temporary workplaces Requirements Toilets shall be provided in accordance with Table H-120.2 Number of employees Minimum number of facilities 20 or fewer One More than 20, fewer than 200 One toilet seat and 1 urinal per 40 employees More than 200 One toilet seat and 1 urinal per 50 employees 70

New Technology 1910.120(o)(2) Employer shall develop and implement procedures for the introduction of effective new technologies and equipment. Evaluation shall be done to determine the effectiveness of the new methods, materials, or equipment. Illustration: Microsoft Clip Art Chemical detection 71

TSD Facilities Treatment, storage and disposal (TSD) facilities Under the Resource Conservation and Recovery Act of 1976 (RCRA), employers who conduct operations at TSD facilities shall implement: Safety and health program Hazard communication program Medical surveillance program Decontamination program Photo fedcenter.gov 72

TSD Facilities Training program New employees Current employees Initial training – 24 hours Annual refresher – 8 hours Current employees Previous work experience and/or training Trainers Completed training course Competent instructional skills MS Clip Art 73

TSD Facilities Emergency response program An emergency response plan developed and implemented. If employees are evacuated from the worksite when an emergency occurs and do not assist in handling the emergency are exempt if they provide an emergency action plan complying with 29 CFR 1910.38. Illustration: Microsoft Clip Art 74

Emergency Response 1910.120(a)(3) Defined as a response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. MS Clip Art 75

Emergency Response Plan 1910.120(q)(1) An emergency response plan shall be: Developed and implemented to handle anticipated emergencies. In writing and available for inspection. Employers who evacuate their employees from the worksite are exempt from the requirements of this paragraph. Plan must comply with 29 CFR 1910.38. Illustration: Microsoft Clip Art 76

Emergency Response Plan 1910.120(q)(2) Elements of an emergency response plan: Pre-emergency planning and coordination with outside parties Personnel roles, including lines of authority, training, and communication Emergency recognition and procedure Safe distances and places of refuge Site security and control Evacuation routes and procedures Decontamination Emergency medical treatment and first aid Emergency alerting and response procedures Critique of response and follow-up PPE and emergency equipment MS Clip Art 77

Handling Emergency Response 1910.120(q)(3) Procedures for handling emergency response: The senior responding emergency response official shall become the individual in charge of a site-specific ICS The ICS commander shall identify, to the fullest extent possible, all hazardous substance or conditions present The ICS commander shall implement appropriate emergency operations and assure that appropriate PPE is worn Employees engaged in emergency response and exposed to potentially hazardous substances shall wear positive pressure SCBS while engaged in emergency response The ICS commander shall limit the number of emergency response personnel at the emergency site 78

Handling Emergency Response 1910.120(q)(3) Back up personnel shall be standing by with equipment ready to provide assistance or rescue. The ICS commander shall identify a safety officer who is knowledgeable in the operation being implemented at the emergency response site When the safety officer judges activities to be IDLH and /or involve an imminent danger condition, he has the authority to terminate those activities. After emergency operations have been terminated, the ICS commander shall implement appropriate decontamination procedures. When deemed necessary, approved SCBA may be used with approved cylinders from other approved SCBA provided that such cylinders are of the same capacity and pressure rating. 79

Emergency Response Skilled support personnel 1910.120(q)(4) Skilled support personnel Skilled in the operation of certain equipment Earth moving, digging, crane and hoisting equipment Needed temporarily Shall be given initial briefing on PPE, chemical hazards and duties Photo: Microsoft Clip Art 80

Emergency Response Specialist employees 1910.120(q)(5) Specialist employees Technical advisor who is trained in the hazards of specific hazardous substances. Shall receive training or demonstrate competence in area of expertise Photo: Microsoft Clip Art 81

Emergency Response Training 1910.120(q)(6) Training Based on the duties and function to be performed by each responder of an emergency response organization. Photo: NCEM Training photo 82

Emergency Response First responder awareness level 1910.120(q)(6)(i) First responder awareness level Individuals who are likely to witness or discover a hazardous substance release. Trained to initiate an emergency response sequence by notifying the proper authorities. Shall have sufficient training or demonstrate competence in areas listed in 1910.120(q)(6). Shall take no further action than initiating an emergency response. 83

Emergency Response First responder operations level 1910.120(q)(6)(ii) First responder operations level Individuals who respond to releases or potential releases of hazardous substances as part of the initial response. Receive at least eight hours of training or have had sufficient experience to demonstrate competence in areas listed in 1910.120(q)(6)(ii). Photo source: WWW.CSB.gov 84

Emergency Response Hazardous materials technician 1910.120(q)(6)(iii) Hazardous materials technician Individuals who respond to releases or potential releases of hazardous substances for the purpose of stopping the release. Receive at least 24 hours of training equal to first responder operations level and in addition, have competency in the areas listed in 1910.120(q)(6)(iii). Photo: OSHA 85

Emergency Response Hazardous materials specialist 1910.120(q)(6)(iv) Hazardous materials specialist Individuals who respond and provide support to hazardous materials technicians. Receive at least 24 hours of training equal to technician level and in addition, have competency in the areas listed in 1910.120(q)(6)(iv). Photo: RFD

Emergency Response On scene incident commander 1910.120(q)(6)(v) On scene incident commander Individuals who assume control of the incident scene beyond the first responder awareness level. Receive at least 24 hours of training equal to the first responder operations level and in addition, have competency in the areas listed in 1910.120(q)(6)(v). Photo: RFD

Emergency Response Training Interpretation What are the HAZWOPER training requirements for hospital staff? 03/10/1999—Emergency response training necessary for hospital physicians/nurses that may treat contaminated patients If personnel are expected to provide limited decontamination services in order to attend to medical problems, they must be trained to the first responder operations level with emphasis on the use of PPE and decontamination procedures. 88

Emergency Response Training 13 NCAC 07F .0103 First responder operations plus First responders who respond to hydrocarbon fuel tank leaks where the leaking tanks contain a hydrocarbon fuel which is used to propel the vehicle on which the tank is located. Photo taken from NCDOL Hazwoper 8-hour refresher course 89

Emergency Response Training 13 NCAC 07F .0103 First responder operations plus Gasoline Diesel fuel Propane Other hydrocarbon fuels Shall receive training equal to first responder operations level Photo taken from NCDOL Hazwoper 8-hour refresher course 90

Emergency Response Training 13 NCAC 07F .0103 First responder operations plus Usage of proper specialized PPE provided to the first responder at operations plus level Understanding of basic hazardous materials terms as they pertain to hydrocarbon fuels Understanding hazard and risk assessment techniques that pertain to hydrocarbon fuels Photo: Raleigh FD 91

Emergency Response Training 13 NCAC 07F .0103 First responder operations plus Perform control, containment, or confinement operations Understand and know how to implement decontamination procedures for hydrocarbon fuels Photo: RFD 92

Post-Emergency Response 1910.120(q)(11)(ii) Response personnel and training requirements Clean-up by workplace employees Clean-up is done on plant property using plant employees shall complete training requirements of: Hand Protection (1910.138) Respiratory Protection (1910.134) HazCom (1910.1200) Photo: RFD 93

Summary Purpose Scope Definitions Safety and health program Site characterization and analysis Training Photo: RFD

Summary Medical surveillance Engineering controls, work practices Personal protective equipment (PPE) Monitoring Informational programs Handling drums and containers MS Clip Art 95

Summary Decontamination Hazardous waste sites Illumination Temporary work places New technology programs TSD facilities Response personnel and training requirements Photo: RFD 96

Final Questions?