Comment Submitted by Erich J. Stafford, CPWR - The Center for Construction Research and Training

In every instance of a manmade or natural disaster, emergency response involving collapsed buildings or structures has required the skilled support of qualified and well trained responders from building and construction trades workers. Heavy equipment operators, ironworkers, electricians, plumbers, laborers and other trades people are needed to move debris quickly and safely de-energize systems to facilitate the rescue phase. At major disasters like the WTC members of local Building Trades affiliates rushed to volunteer their expertise on the site. While many of these craftsmen would eventually be deployed by their CIKR employers, during the emergency phase they were on site as volunteers. The health and safety hazards present at the WTC prompted the National Building Trades Department, through its Center for Construction Research and Training, (CPWR), to begin a program of training workers how to recognize hazards on disaster sites, to work safely, and how to integrate with the ICS on site. As an organization representing 13 international/national construction unions and over 2 million construction workers, the National Building Trades Department and CPWR has been called upon to develop a standardized program to train and certify construction workers prior to a disaster, so that a cadre of qualified skilled support personnel stand ready to assist in the event of a disaster. This training has been ongoing around the country through local Joint Labor / Management Training Committees in a variety of critical support trades. The FEMA Guideline has recommendations for credentialing volunteer/non-profit organizations. It is possible, however, that States, and local jurisdictions may not be aware of their local Building Trades Council, think of them as a “volunteer / non- profit” organization, or know that the network of Labor Management organizations has been working to prepare skilled support for emergency response. In addition, the Guideline states, “Individuals who are officially requested, invited, authorized, credentialed, and typed are more likely to reach the emergency check- in points. State, tribal, and local governments may issue conforming credentials for the employees or volunteers of these organizations.” Clearly, FEMA recognizes the importance of getting groups of qualified volunteers prepared ahead of an incident and making sure that the connection between emergency management people and key response groups is in place so that they can be mobilized and recognized at the disaster site. The National Building Trades suggests that FEMA add to the guidance document the recommendation that, where possible, State Local and Tribal entities reach out to their respective Building Trades Councils and work together to indentify, type, and credential these key responders.