TABLE OF CONTENTS
| Topics | Sections |
| OVERVIEW | 2.1 What is the purpose of this chapter? 2.2 What is the scope of this chapter? 2.3 What terms do you need to know to understand this chapter? |
| ROLES AND RESPONSIBILITIES | 2.4 Who is the lead agency when there is a spill? 2.5 Who is responsible for spill response in the Service? 2.6 Which Incident Command System spill response positions may the Service fill, and what are the duties associated with each position? 2.7 How are Service personnel identified and deployed for spill response activities? |
| SAFETY AND TRAINING | 2.8 What are the safety requirements for Service spill responders? 2.9 What training must Service personnel take to participate in spill response activities? 2.10 Where and how is training and participation in a spill response documented? |
OVERVIEW
2.1 What is the purpose of this chapter? This chapter describes the U.S. Fish and Wildlife Service’s (Service) roles and responsibilities regarding response activities for oil discharges and hazardous substance releases and the safety and training requirements.
2.2 What is the scope of this chapter?
A. This chapter covers all Service employees with responsibilities for conducting spill response activities for:
(1) Oil discharges or hazardous substance releases off Service lands, and
(2) Oil discharges on Service lands.
B. This chapter does not cover responses to hazardous substance releases on Service lands (see 561 FW 10, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Site Cleanup).
2.3 What terms do you need to know to understand this chapter? See 573 FW 1, Exhibit 1 for a glossary of terms used in Part 573, Response to Discharges of Oil and Releases of Hazardous Substances and Natural Resource Damage Assessment and Restoration (NRDAR).
ROLES AND RESPONSIBILITIES
2.4 Who is the lead agency when there is a spill? Under the National Contingency Plan (NCP), the U.S. Environmental Protection Agency (EPA) and U.S. Coast Guard (USCG) are designated as primary Federal response agencies. The Service is seldom the lead Federal response agency off Service lands. Instead, we provide spill response activity support to the lead agencies. See 561 FW 10 for more information about our response to releases of hazardous substances on Service-managed lands using authority that CERCLA delegates.
2.5 Who is responsible for spill response in the Service? See Table 2-1.
Table 2-1: Responsibilities for Spill Response
| These employees... | Are responsible for... |
| A. The Director | Prioritizing Servicewide goals and objectives to ensure that adequate personnel and other resources are available for mobilization if an oil discharge or release of hazardous substance overwhelms a Region’s ability to effectively respond. |
B. The Assistant Director – Ecological Services | (1) Ensuring that Service policy for spill response is up-to-date and consistent with Department of the Interior (Department) policies; (2) Coordinating with the Director and other Directorate members regarding spill response needs and oversight, as necessary; (3) Overseeing the spill response program within the Service; and (4) Ensuring staff are available to assist Regions in addressing spill response policy questions, including issues that would set a precedent. |
C. National Spill Response Coordinator (NSRC) (in Ecological Services, Branch of Environmental Response and Restoration) | (1) Developing national policy for the Service’s spill response program; (2) Working with counterparts in other agencies and bureaus on issues related to spill response; (3) Advising Regional offices about spill response activities and documentation, including cost documentation; (4) Coordinating a response, at the request of a Region, when a Region’s capacity is exceeded or when a lead Region requests it for a spill that is cross-Regional; and (5) Updating the cost documentation tool for spill response. |
D. Regional Directors | (1) Managing Regional spill response activities in accordance with the NCP, including supporting tasks assigned within the Incident Command System (ICS); (2) Coordinating with their counterparts in other agencies and bureaus on spill response issues; (3) Providing resources in the Regional and field offices to oversee spill response activities, including coordinating with response agencies on pre-spill planning; (4) Tracking Service involvement in spill response cases and maintaining Regional records, including documenting response actions and costs; (5) Ensuring spill responders have opportunities to take pertinent training and attend relevant conferences/workshops/exercises to maintain and increase skills, as budgets and schedules allow; (6) Obtaining funding for response activities through a Pollution Removal Funding Authorization (PRFA), as appropriate; (7) Ensuring that Regional staff coordinate effectively with response agencies and NRDAR staff; (8) Ensuring that Regional staff notify the National Spill Response Coordinator about spills that may have national significance; and (9) Managing spill response in a safe and professional manner. |
| E. Regional Spill Response Coordinators (RSRC) | (1) Coordinating preparedness and planning activities with Regional emergency response staff; (2) Participating in Regional Response Team (RRT) contingency planning efforts and exercises to the extent possible, and where appropriate, coordinating the Regional planning and preparedness activities with the Security and Emergency Manager, National Spill Response Coordinator, and the Service’s Environmental Safeguards Group (ESG) representative; (3) Coordinating notification of the Regional Directorate, program offices, and affected field offices about any events affecting Regional resources; (4) Assisting Field Spill Response Coordinators (FSRC) to estimate and obtain funding for response activities through a PRFA, as appropriate; and (5) Coordinating the Regional response activities with the Security and Emergency Manager, National Spill Response Coordinator, Service ESG representative, and appropriate Regional and Headquarters staff. |
| F. Project Leaders/Field Supervisors/other Facility Managers | (1) Helping to identify personnel who have the skills and expertise needed to address spill response efforts and certify that personnel designated for deployments have the required training; and (2) Determining whether or not staff will be available for spill response activities, depending on urgency, availability, and other priorities. |
| G. Field Spill Response Coordinators (FSRC) and Field Responders (Primary and Alternates) | (1) Assisting with spill response efforts for oil discharges and hazardous substance releases, and other major disasters or emergencies, consistent with the structure structure (2) Obtaining funding for response activities through a PRFA, as appropriate; (3) Providing information about Service spill response activities to the RSRC for inclusion in PRFAs; (4) Coordinating with the Federal On-Scene Coordinator (FOSC), if one is assigned, and with officials within the unified command structure; and (5) Participating in RRT, Joint Response Team, and National Response Team (NRT) efforts consistent with procedures established in the NCP. |
2.6 Which ICS spill response positions may the Service fill, and what are the duties associated with each position? A Service employee may be asked to fill various roles within the ICS, depending on the size and scope of the response. Although not a comprehensive list, the subsections below describe the most common positions that our employees fill and organizations within which they work. See the Department’s online Incident Qualifications and Certification System (IQCS) for more information. For some small spills, a single person could fill all of the positions we describe below.
A. Agency Representative. As defined in the USCG Incident Management Handbook (IMH), an Agency Representative is an “individual assigned to an incident from an assisting or cooperating agency that has been delegated full authority to make decisions on all matters affecting their agency's participation at the incident. Agency Representatives report to the incident liaison officer.”
B. Wildlife Branch. Service personnel may serve in various positions within the Wildlife Branch, including as the Branch Director. The Wildlife Branch Director is responsible for minimizing wildlife injuries during a spill response. The Wildlife Branch Director oversees four functional groups:
(1) Wildlife Transportation Group,
(2) Wildlife Reconnaissance/Recovery Group,
(3) Wildlife Hazing Group, and
(4) Wildlife Rehabilitation Group.
C. Environmental Unit. Service personnel may serve in various positions within the Environmental Unit. Positions in this unit include technical support for Resources at Risk (RAR), Shoreline Cleanup Assessment Technique (SCAT), and Natural Resource Advisor (NRA)/Resource Advisor (READ).
(1) RAR – responsible for identifying resources at risk from exposure to the discharge/release and response activities; evaluating the relative importance of the resources, weighing the risks to each, and recommending priorities for their protection; assisting in Endangered Species Act consultation processes; and providing best management practices.
(2) SCAT – responsible for describing shoreline types and characterizing conditions, cleanup methods, and endpoint criteria for each shoreline treatment and ensuring the shoreline treatment recommendations are consistent with best management practices.
(3) NRA/READ – responsible for oversight and support for implementation of best management practices onsite. NRAs conduct activities on non-Federal lands, while READs conduct activities on Federal lands.
2.7 How are Service personnel identified and deployed for spill response activities?
A. FSRCs, RSRCs, or the NSRC (as appropriate based on the spill) must provide staffing for oil and hazardous substance responses in accordance with the Department of the Interior Incident Management and Implementation Guide. Responders must meet the minimum requirements for the position they are filling based on personal data captured in the Incident Qualifications and Certification System (IQCS), the official system of record, and will use the Resource Ordering and Status System (ROSS) software for the tracking, mobilization, and staffing of incident personnel during an all-hazards emergency.
B. Although FSRCs and RSRCs do not have to use the ROSS for small spills (i.e., 1 to 2 Service staff deployed for 2 weeks or less), the individuals they are assigning must meet the minimum requirements for the position to which they are deployed.
SAFETY AND TRAINING
2.8 What are the safety requirements for Service spill responders? Health and safety of all Service personnel is the first priority at oil discharges and releases.
A. Personnel involved in spill response activities must comply with applicable worker health and safety laws and regulations. During spill responses, Occupational Safety and Health Administration (OSHA) regulations and Service safety policies apply. Our response personnel must be in compliance with the safety requirements in 29 CFR 1910.120, the regulations for Hazardous Waste Operations and Emergency Response (HAZWOPER), and 242 FW 6, Industrial Hygiene - Hazardous Waste Operations and Emergency Response.
B. Our policy prohibits Service employees from entering sites classified as Level A.
C. For sites with Personal Protective Equipment (PPE) requirements of Level B and C, in the Regions the Regional Director or their designee has the authority to approve entry if it is absolutely essential. For Headquarters employees, the Assistant Director – Ecological Services must approve their entry.
D. Service employees may conduct spill response at sites where the PPE requirement is Level D. For more information about our PPE requirements and the levels of PPE, see 241 FW 3, PPE, and 242 FW 6.
(1) Basic Level D PPE required at spills includes minimum protection for low-level contaminants, such as long sleeves, overalls, gloves, steel-toed boots, disposable over-boots, disposable coveralls, hard hat (as required by the incident safety plan), safety goggles, chemical resistant gloves (nitrile), and, if warranted, personal flotation devices (see 241 FW 1, Exhibit 1, Watercraft Safety – Safety and Survival Equipment Requirements).
(2) Our policy requires the Project Leader/supervisor to provide, at no cost to the employee, any PPE necessary to perform assigned tasks.
2.9 What training must Service personnel take to participate in spill response activities?
A. To be considered fully trained to participate in response activities, Service personnel must complete and maintain the required training in Table 2-2 (we also identify other recommended training in the table). The Incident Commander must ensure that site-specific training is provided on any geographic physical and chemical hazards that are present prior to any field work being conducted.
Table 2-2: Training for Spill Response
| Training | Required | Recommended |
| OSHA 24-hour or OSHA 40-hour HAZWOPERa, b | ● | |
| National Incident Management System (NIMS) IS-100.a, Introduction to Incident Command System | ● | |
| NIMS IS-100.LEb, Introduction to Incident Command System for Law Enforcementc | ● | |
| NIMS IS-200.a, ICS for Single Resources and Initial Action Incidents | ● | |
| NIMS IS-293, Mission Assignment Overview | ● | |
| NIMS IS-700.a, National Incident Management System (NIMS), An Introduction | ● | |
| NIMS IS-800.b, National Response Framework, An Introduction | ● | |
| NIMS IS-809, Emergency Support Function (ESF) #9, Search and Rescue | ● | |
| NIMS IS-810 ESF #10, Oil and Hazardous Materials Response Annex | ● | |
| NIMS IS-811 ESF #11, Agriculture and Natural Resource Annex | ● | |
| Motorboat Operator’s Certification Course (MOCC)d | ● | |
| Off-Road Utility Vehicle (ORUV) Safety Traininge | ● | |
| Wildlife Hazing and Pyrotechnics | ● | |
| B3 Combination Helicopter/Airplane Safetyf | ● | |
| Water Ditch and Survivalg | ● | |
| First Aid/CPR | ● | |
| DOI All-Hazards Resource Advisor (READ)h Basic, Intermediate, and Advanced Courses | ● | |
| Departmental Inland Oil Spill Response | ● | |
| Endangered Species Act (ESA) of 1973 – Overviewi | ● | |
| Interagency Consultation for Endangered Species | ● | |
| Natural Resource Damage Assessment and Restoration | ● | |
| Field and Laboratory Techniques | ● |
a With 8-hour refresher annually
c Required for Law Enforcement personnel
d Required if operating a motorboat; refresher course required every 5 years (see 241 FW 1)
e Required if operating an ORUV; refresher course required every 5 years (see 243 FW 6)
f Required if flying is necessary; refresher course required every 3 years (see 330 FW 3 - now 330 FW 1)
g Required if flying in float planes or over water (see 330 FW 3 - now 330 FW 1)
h Advanced READ Course is currently under development
i Online prerequisite for ESA courses
B. HAZWOPER training requirements are in 242 FW 6. For oil spills or hazardous materials releases, at a minimum employees must take a 24-hour OSHA-approved HAZWOPER training course or a 40-hour OSHA training course (depending on field activities being performed). They must also take an annual 8-hour refresher course. An on-site safety briefing must be completed at each spill prior to conducting work. Following is a summary of the requirements:
(1) Employees who are engaged in the removal of oil or hazardous materials or other activities that expose them to hazardous materials and health hazards must take a 40-hour HAZWOPER course and have a minimum of 3 days field experience under direct supervision. Other activities that may require the 40-hour course include duties that have the high potential for exposure to contaminants (e.g., sampling abiotic/biotic media and capture of contaminated wildlife). Untrained and uncertified employees must not engage in on-site incident operations.
(2) Employees who are only occasionally on site or have a specific limited task (e.g., Resource Advisor (READ)) and won’t likely be exposed to materials that exceed exposure limits, must take a minimum of 24 hours of off-site instruction and have a minimum of 1 day of supervised field experience.
(3) Employees who respond to incidents to protect people, property, and natural resources, but who are not involved in direct contact with the site (e.g., assisting from an incident command post or from the duty station), must take a minimum of 24 hours of off-site instruction and have a minimum of 1 day of supervised field experience.
(4) The 24-hour HAZWOPER training is also required for those volunteers and employees of wildlife rehabilitators working with contaminated wildlife at a rehabilitation center. The state or other Federal authorities may waive this requirement on site.
C. In addition, FSRCs and RSRCs should participate in:
(1) Geographic and area contingency planning to ensure trust resource needs are addressed in these plans, and
(2) Exercises for Spills of National Significance (SONS), which provide “real world” response training in non-emergency settings.
D. We encourage supervisors to support staff requests to assist in response opportunities outside their office’s jurisdiction to maintain their on-the-ground response skills.
E. The National Conservation Training Center’s Oil Spill Response Training website has other useful training tools.
2.10 Where and how is training and participation in a spill response documented?
A. The responder should document experience from training, drills, exercises, and spill responses in a field notebook or using an ICS Form 214.
B. At least annually, the responder must update their qualifications in IQCS using the data recorded in the field notebook or ICS Form 214.
C. Supervisors should keep certificates for completed training in each employee’s personnel file, and where possible in the Department’s online Learning Management System so they are available, if requested, before the next response.