By US Department of Highway Administration Office of Operations
National Tow Truck Driver Certification
Towing & Recovery Association of America (TRAA) represents the towing and recovery industry on a national level. This group has recognized that the tow truck driver can also be a valuable contributor to the safe, quick clearance of an incident. With proper training and certification, they can provide help with the clean-up and handling of typical vehicle fluids at an incident. Because they are often the first at the scene, this assistance serves to reduce the clean-up time and allows for lanes to be opened in a more timely fashion.
Through a grant from the DOT, TRAA established national standards for tow truck operators and developed the National Driver Certification Program. This program is based upon light, medium, and heavy duty towing and recovery, and covers the following areas:
- Customer service
- Incident management
When assisting with traffic incident clean-up involving a hazardous material, the type of requirements for tow truck drivers will depend on the type of incident, the severity of the spill, and the location of the spill relative to the damaged vehicles. More information on the levels and curriculum topics, including handling of hazardous material, is available on the TRAA Web site at http://www.towserver.net/certification.htm.19
The applicable levels for TRAA tow truck driver certification when dealing with hazardous materials are:
Level 1: For most vehicular spills (car wreck) with only minor amounts of hazardous material spilled, Level I (Light Duty) requirements should be sufficient, provided that tow truck operators are not coming in contact with the spilled material.
Level II: For vehicular spills (medium-heavy duty truck wreck) with moderate amounts of hazardous material spilled (partial saddle tank emptied), Level II (Medium Duty) requirements should be sufficient, provided that tow truck operators minimize their time near the spilled material.
Level III: For large vehicular spills (tanker spill, blood-borne pathogens, etc.), Level III (Heavy Duty) requirements will be necessary to ensure tow truck driver safety.
Response Management and Clean-up Regulations
The regulations dealing with response management, including handling, reporting, and mitigation procedures of hazardous spills, are founded in a number of federal statues rather than just one source. It is important, especially for responders in charge, to know the origin of the various requirements, including the mandated reporting procedures and ensure the proper implementation.
In the U.S., the response to an incident is regulated under many statues and many government agencies. It is important for responders to at least understand the basis of these regulations because they dictate everything, from how they manage a spill to the disposal of the spilt material. These regulations stipulate who should be notified and when it is not necessary, as well as what resources or assistance are available to local and state entities if the containment of a spill is beyond their capabilities. Therefore, some of the major federal laws that responders should have knowledge of are listed in Table 6. Responders should be aware of any local and state regulations that also apply to hazardous materials handling, reporting, and disposal in their jurisdictions. Table 6. Major Federal Hazardous Materials Incident Regulations
Sizing-up a Spill
Once a spill occurs along a roadway, it’s important for response personnel to identify the hazardous substance and prevent the spill from spreading. Initial response personnel should only attempt to determine the extent of the release by gathering and analyzing information. This is called a size-up strategy, and is a non-invasive attempt to get a general picture or impression of the nature and severity of the event
In general, responders should use a size-up strategy to obtain and evaluate the following information:
- Identity of the materials
- Amount of the release
- Hazards associated with each material(s)
- Effects and risks on the public, property, and environment
- Potential pathway of release—air, land, surface waters, or groundwater
- Most appropriate measures for controlling the release to prevent/reduce the impact
- Safety measures to protect all response personnel
A number of methods can be used to collect information for a size-up strategy. For the most part, responders should use visual observations to assist in detecting the presence or release of hazardous chemicals. Visual methods that may be utilized include the following:
- Types and numbers of containers or cargo tanks
- Placards, labels, and markings on containers or transportation vehicles
- Vapors, clouds, run-offs, or suspicious substances
- Biological indicators—dead vegetation, animals, insects, and fish
- Physical condition of containers
At other times, it may be necessary for first responders to utilize quantitative methods (monitoring, sampling, hazard characterization, etc.) to assist in detecting the presence or release of hazardous chemicals. Quantitative methods that are cost-effective and may be utilized at a traffic incident include the following:
- Colorimetric tubes
- pH paper
- Spilfyter classifiers strips
Containment and Confinement
Upon identifying an incidental hazardous substance release, first responders may perform limited cleanup activities provided that the mitigation follows a standard operating procedure and the responder has received adequate training (See previous section on training requirements). Incidental releases should not have the potential for safety or health hazards, such as fire, explosion, or chemical exposures in excess of an OSHA Permissible Exposure Limit (PEL), or exceed the immediately dangerous to life and health level.
For first responders to a small spill, limited clean-up activities may entail basic containment and confinement techniques. Spill containment involves methods used to restrict the material to its original container (e.g. plugging, patching, overpacking, etc.). Spill confinement involves methods to limit the physical size of the area of the release (e.g. mist knockdown/vapor suppression, diversion, diking,booming, absorbing, fencing, and damming). Both methods can be very effective at controlling a hazardous release, if used appropriately. However, response personnel should not utilize either method without appropriate protection and regard for safety.
For small vehicular spills that occur along a roadway, one of the easiest ways to control a spill is the use of granular absorbents, oil absorbent pads, or universal absorbent pads for non-petroleum products. These items are readily available and very effective for remediation of small spills. However, response personnel should understand the properties associated with each, standard operating procedures for utilizing them, and the correct collection and storage methods for contaminated absorbents.
Once hazardous materials are spilled, the material becomes contaminated and should be either recycled or disposed of properly. Typically, first responders to a traffic incident do not possess the appropriate licenses to perform transportation and disposal of hazardous waste. Professional licensed firms should be contracted to perform this task following the regulations established under the Resource Conservation and Recovery Act.16
First responders can improve the disposal process by mitigating the spill following a standard operating
procedure (SOP). The SOP should account for how to:
- Mitigate the spill,
- Package the waste for transport, and
- Secure the waste until a licensed transportation and disposal company can pick up it up.
More importantly, the SOP should provide first responders with guidance on how to minimize roadway congestion by conducting hazard recognition to determine the hazards presented to the general public.
There are two basic ways to control any type of spill: containment and confinement. Containment basically means restricting the material to its original container while confinement refers to limiting the physical size of the area of release. First responders should have an assortment of products for spill mitigation of a spill for both types of controls. Quick and simple actions by properly trained responders to minimize the amount of a spill as well as the area of involvement can reduce the amount of clean-up time and, thus, reduce the incident time frame requirements. For most traffic incidents involving incidental spills, Level II trained responders can effectively deal with the smaller vehicle spills if they have access to the appropriate equipment and materials. The impact of larger spills can be minimized by quick action, such as placing drain protection covers over the storm sewer inlets by DOT personnel. Properly trained responders can also reduce the incident time line in some cases involving minor vehicle crashes by having access to a spill kit containing an assortment of absorbents.
There are basically three types of spill kits. The type of spill kit that a first responder will use depends upon what liquids need to be cleaned up. The three main types are:
1. Universal or General Purpose Spill Kits. Universal or general purpose spill kits contain gray absorbents made with activated charcoal or a similar capturing agent. Universal or general purpose spill kits are used to clean-up both water-based fluids and hydrocarbons.
2. Oil-Only Spill Kits. Oil-only spill kits are used to clean-up hydrocarbons only (motor oil, jet fuel, diesel, gasoline, hydraulic oil, etc.) and contain white absorbents that repel and float on water.
3. Hazmat Spill Kits. Hazmat spill kits contain yellow absorbents to clean-up aggressive fluids, such as acids and solvents, and will absorb hydrocarbons as well as water-based fluids.
The size of the spill is an important factor in determining the mitigation technique a first responder will use. Spill kits come in various sizes. For small volume spills, first responders may use bagged or bucket spill kits. For large volume spills, a drum or wheeled cart/mobile spill kit may be better suited. In each case, both types of spill kits are easily carried on a response vehicle and can provide safe containment of the material until proper disposal can be facilitated.
If first responders do not have a spill kits readily available, there are an assortment of products that can be purchased individually and combined to produce a custom spill kit. Some of the more important items are absorbents pads, absorbent booms, drain protector covers, spill containment berm dikes, and spill classifier strips.