Entire Health and Safety Plan Guidelines Document (very large)
Introduction to the Health and Safety Plan Guidelines
INTRODUCTION
These guidelines have been developed by a working group consisting of
both field and headquarters personnel to provide new direction to the
EM-40 program in the preparation of site-specific Health and Safety
Plans (HASPs). While based on the minimum requirements of 29 CFR
1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER),
and DOE orders, these guidelines have been developed with the express
purpose of implementing a high quality safety and health program. These
EM-40 HASP Guidelines are a "living document" to be modified and updated
as new regulations and other requirements are issued. Guiding the
development of this document has been the principle that an effective
and high-quality HASP must provide:
* A clear chain of command for safety and health activities,
* Accountability for safety and health performance,
* Well defined headquarters expectations regarding safety and health,
* Well defined task and operational hazards/risks,
* Comprehensive hazard prevention and control methods, and
* Recordkeeping requirements to track program progress.
As this document was developed the working group applied the following
assumptions:
* It is a generic document to be adapted on a site-by-site basis,
* An adequate site characterization and comprehensive workplan
exists at each field site,
* Operations analysis and risk identification methods are adequate,
* A written site safety and health program exists as required in
29 CFR 1910.120 (b),
* Written site Standard Operating Procedures exist, and
* Site specific information is available.
Each chapter of these guidelines represents an element listed in 29 CFR
1910.120(b)(4)(ii) for a HASP. The first chapter, Regulatory Framework,
provides direction on what should be included in a site-specific HASP.
29 CFR 1910.120(b)(4) has been issued as the minimum criteria, and
starting point. In several instances this guidance goes beyond this
requirement. In addition to the requirements of 29 CFR 1910.120(b)(4)
the guidance is based on good industry practice, Environmental
Protection Agency recommendations, specific DOE need (radiation
protection), and DOE orders and directives. Chapters 2 through 14
provide guidance on how to meet the requirements specified in Chapter 1.
Each chapter provides detailed information on a particular component of
a site-specific HASP. When utilizing this guidance to prepare
site-specific HASPs, the preparer of the HASP should be able to provide
appropriate documentation on how decisions were made relative to the
relevant sections of the guidance. In some cases, the requirements of
different sections overlap. The preparer of a site-specific HASP need
not repeat overlapping information but should indicate by reference
where the information is located.
Table of Contents - Health and Safety Plan Guidelines
TABLE OF CONTENTS
LIST OF FIGURES. . . . . . . . . . . . . . . . . . . . . . . . . . . viii
LIST OF TABLES . . . . . . . . . . . . . . . . . . . . . . . . . . . ix
LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . x
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.0. REGULATORY FRAMEWORK. . . . . . . . . . . . . . . . . . . . . 1-1
1.1. Background . . . . . . . . . . . . . . . . . . . . . . . 1-1
1.2. Site-Specific HASP Requirements. . . . . . . . . . . . . 1-1
1.2.1. Introduction . . . . . . . . . . . . . . . . . . 1-1
1.2.2. Key Personnel . . . . . . . . . . . . . . . . . . 1-2
1.2.3. Hazard Assessment . . . . . . . . . . . . . . . . 1-2
1.2.4. Training . . . . . . . . . . . . . . . . . . . . 1-3
1.2.5. Personal Protective Equipment . . . . . . . . . . 1-3
1.2.6. Temperature Extremes . . . . . . . . . . . . . . 1-4
1.2.7. Medical Surveillance . . . . . . . . . . . . . . 1-4
1.2.8. Exposure Monitoring and Air Sampling . . . . . . 1-5
1.2.9. Site Control . . . . . . . . . . . . . . . . . . 1-5
1.2.10. Decontamination . . . . . . . . . . . . . . . . . 1-5
1.2.11. Emergency Response/Contigency Plan . . . . . . . 1-6
1.2.12. Emergency Action Plan . . . . . . . . . . . . . . 1-7
1.2.13. Confined Space Entry. . . . . . . . . . . . . . . 1-7
1.2.14. Spill Containment . . . . . . . . . . . . . . . . 1-8
1.3. References . . . . . . . . . . . . . . . . . . . . . . . 1-8
2.0. KEY PERSONNEL . . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.1. Background . . . . . . . . . . . . . . . . . . . . . . . 2-1
2.2. Organizational Structure . . . . . . . . . . . . . . . . 2-1
2.3. Onsite Essential Personnel . . . . . . . . . . . . . . . 2-4
2.3.1. Project Manager . . . . . . . . . . . . . . . . . 2-4
2.3.2. Site Safety and Health Officer . . . . . . . . . 2-4
2.3.3. Safety and Health Personnel . . . . . . . . . . . 2-5
2.3.4. Field Team Leader . . . . . . . . . . . . . . . . 2-5
2.3.5. Command Post Supervisor . . . . . . . . . . . . . 2-6
2.3.6. Emergency Response Coordinator . . . . . . . . . 2-6
2.3.7. Decontamination Station Officer . . . . . . . . . 2-6
2.3.8. Security Officer . . . . . . . . . . . . . . . . 2-7
2.3.9. Specialty Teams . . . . . . . . . . . . . . . . . 2-7
2.4. Optional Personnel . . . . . . . . . . . . . . . . . . . 2-7
2.4.1. Industrial Hygienist . . . . . . . . . . . . . . 2-7
2.4.2. Fire Fighters . . . . . . . . . . . . . . . . . . 2-8
2.4.3. Health Physicist . . . . . . . . . . . . . . . . 2-8
2.4.4. Scientific Advisor . . . . . . . . . . . . . . . 2-8
2.4.5. Logistics Officer . . . . . . . . . . . . . . . . 2-8
2.4.6 Photographer. . . . . . . . . . . . . . . . . . . 2-9
2.4.7. Record Keeper . . . . . . . . . . . . . . . . . . 2-9
2.4.8. Public Information Officer . . . . . . . . . . . 2-9
2.4.9. Multidisciplinary Advisors . . . . . . . . . . . 2-9
2.4.10. Medical Support . . . . . . . . . . . . . . . . . 2-9
2.4.11. Bomb Squad Expert . . . . . . . . . . . . . . . . 2-10
2.5. Communications . . . . . . . . . . . . . . . . . . . . . 2-10
2.6. Other Source of Assistance . . . . . . . . . . . . . . . 2-11
2.7. References . . . . . . . . . . . . . . . . . . . . . . . 2-12
3.0. HAZARD ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . 3-1
3.1. Background . . . . . . . . . . . . . . . . . . . . . . . 3-1
3.2. Hazard Identification. . . . . . . . . . . . . . . . . . 3-2
3.2.1. Hazards List . . . . . . . . . . . . . . . . . . 3-3
3.3. Examples of Hazard Assessment Methods. . . . . . . . . . 3-4
3.4. Hazard Control . . . . . . . . . . . . . . . . . . . . . 3-4
3.4.1. Engineering Controls . . . . . . . . . . . . . . 3-5
3.4.2. Administrative Controls . . . . . . . . . . . . . 3-5
3.4.3. Personal Protective Equipment . . . . . . . . . . 3-5
3.5. Hazard Assessment Documentation Format . . . . . . . . . 3-6
3.6. References . . . . . . . . . . . . . . . . . . . . . . . 3-9
4.0. TRAINING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . 4-1
4.1. Background . . . . . . . . . . . . . . . . . . . . . . . 4-1
4.2. General. . . . . . . . . . . . . . . . . . . . . . . . . 4-1
4.3. Training Requirements for Personnel at ER Sites. . . . . 4-2
4.4. Training Requirements for Personnel at RCRA TSD Sites . 4-2
4.5. Training Requirements for Personnel in Emergency
Responses to Hazardous Substance Releases . . . . . . 4-2
4.6. References . . . . . . . . . . . . . . . . . . . . . . . 4-8
5.0. PERSONAL PROTECTIVE EQUIPMENT . . . . . . . . . . . . . . . . 5-1
5.1. Background . . . . . . . . . . . . . . . . . . . . . . . 5-1
5.2. General Provisions . . . . . . . . . . . . . . . . . . . 5-1
5.3. Selection of Personal Protective Equipment . . . . . . . 5-2
5.4. Levels of PPE. . . . . . . . . . . . . . . . . . . . . . 5-3
5.4.1. Level A PPE . . . . . . . . . . . . . . . . . . . 5-4
5.4.2. Level B PPE . . . . . . . . . . . . . . . . . . . 5-4
5.4.3. Level C PPE . . . . . . . . . . . . . . . . . . . 5-5
5.4.4. Level D PPE . . . . . . . . . . . . . . . . . . . 5-6
5.5. Use of PPE . . . . . . . . . . . . . . . . . . . . . . . 5-7
5.5.1. PPE Selection Process . . . . . . . . . . . . . . 5-7
5.6. References . . . . . . . . . . . . . . . . . . . . . . . 5-10
6.0. EXTREME TEMPERATURE DISORDERS OR CONDITIONS . . . . . . . . . 6-1
6.1. Background . . . . . . . . . . . . . . . . . . . . . . . 6-1
6.2. Heat Stress. . . . . . . . . . . . . . . . . . . . . . . 6-2
6.2.1. Monitoring . . . . . . . . . . . . . . . . . . . 6-2
6.2.2. Training . . . . . . . . . . . . . . . . . . . . 6-4
6.3. Cold Exposure. . . . . . . . . . . . . . . . . . . . . . 6-4
6.3.1. Control Measures . . . . . . . . . . . . . . . . 6-6
6.3.2. Physiological Monitoring . . . . . . . . . . . . 6-6
6.4. Prevention . . . . . . . . . . . . . . . . . . . . . . . . 6-7
6.4.1. Physiological Monitoring . . . . . . . . . . . . 6-8
6.5. Integration with Other Elements of the HASP. . . . . . . . 6-8
6.6. References . . . . . . . . . . . . . . . . . . . . . . . . 6-9
7.0. MEDICAL SURVEILLANCE. . . . . . . . . . . . . . . . . . . . . 7-1
7.1. Background . . . . . . . . . . . . . . . . . . . . . . . 7-1
7.2. Information for the Medical Program. . . . . . . . . . . 7-2
7.3. Examination Content. . . . . . . . . . . . . . . . . . . 7-3
7.4. Baseline (Initial) Examination . . . . . . . . . . . . . 7-5
7.4.1. Baseline/Periodic Medical Examination Parameters. 7-5
7.5. Periodic Medical Monitoring. . . . . . . . . . . . . . . 7-5
7.6. Examination After Illness or Injury. . . . . . . . . . . 7-8
7.7. Termination Examination. . . . . . . . . . . . . . . . . 7-8
7.8. Maintenance and Availability of Medical Records. . . . . 7-8
7.9. References . . . . . . . . . . . . . . . . . . . . . . . 7-9
8.0. EXPOSURE MONITORING/AIR SAMPLING. . . . . . . . . . . . . . . 8-1
8.1. Background . . . . . . . . . . . . . . . . . . . . . . . 8-1
8.2. General Guidance . . . . . . . . . . . . . . . . . . . . 8-1
8.2.1. Personnel Qualifications . . . . . . . . . . . . 8-2
8.3. Air Contaminants . . . . . . . . . . . . . . . . . . . . 8-3
8.4. Methods and Instrumentation. . . . . . . . . . . . . . . 8-4
8.4.1. Direct-Reading Monitoring Instruments . . . . . . 8-5
8.4.2. Time-Integrated Sampling Instruments . . . . . . 8-6
8.5. Worker Exposure Monitoring . . . . . . . . . . . . . . . 8-6
8.6. Level of Protection Monitoring . . . . . . . . . . . . . 8-7
8.7. Offsite Monitoring . . . . . . . . . . . . . . . . . . . 8-8
8.8. Perimeter Monitoring . . . . . . . . . . . . . . . . . . 8-8
8.9. Meteorological Monitoring. . . . . . . . . . . . . . . . 8-8
8.10. Quality Assurance/Quality Control. . . . . . . . . . . . 8-8
8.11. Recordkeeping. . . . . . . . . . . . . . . . . . . . . . 8-8
8.12. Time-Integrated Sampling Data . . . . . . . . . . . . . 8-9
8.13. Direct-Reading Air Monitoring Data . . . . . . . . . . . 8-9
8.14. Final Report . . . . . . . . . . . . . . . . . . . . . . 8-10
8.15. References . . . . . . . . . . . . . . . . . . . . . . . 8-10
9.0. SITE CONTROL. . . . . . . . . . . . . . . . . . . . . . . . . 9-1
9.1. Background . . . . . . . . . . . . . . . . . . . . . . . 9-1
9.2. Development of the Site Map. . . . . . . . . . . . . . . 9-2
9.3. Establishment of Work Zones. . . . . . . . . . . . . . . 9-2
9.3.1. The Exclusion Zone . . . . . . . . . . . . . . . 9-3
9.3.2. The Contamination Reduction Zone . . . . . . . . 9-4
9.3.3. The Support Zone . . . . . . . . . . . . . . . . 9-4
9.4. Using the Buddy System . . . . . . . . . . . . . . . . . 9-4
9.5. Communication Network and Procedures . . . . . . . . . . 9-5
9.6. Worker Safety Procedures . . . . . . . . . . . . . . . . 9-5
9.7. Medical Assistance . . . . . . . . . . . . . . . . . . . 9-6
9.8. References . . . . . . . . . . . . . . . . . . . . . . . 9-6
10.0. DECONTAMINATION . . . . . . . . . . . . . . . . . . . . . . . 10-1
10.1. Background . . . . . . . . . . . . . . . . . . . . . . . 10-1
10.2. General Consideration. . . . . . . . . . . . . . . . . . 10-1
10.3. Location and Layout. . . . . . . . . . . . . . . . . . . 10-2
10.4. Determining Decontamination Methods. . . . . . . . . . . 10-3
10.5. Standard Operating Procedures to Minimize Worker Contact 10-5
10.6. Collection, Storage and Disposal Procedures. . . . . . . 10-6
10.7. References . . . . . . . . . . . . . . . . . . . . . . . 10-6
11.0. EMERGENCY RESPONSE/CONTINGENCY PLAN . . . . . . . . . . . . . 11-1
11.1. Background . . . . . . . . . . . . . . . . . . . . . . . 11-1
11.2. Pre-Emergency Planning . . . . . . . . . . . . . . . . . 11-2
11.3. Personnel Roles, Lines of Authority, and
Communications . . . . . . . . . . . . . . . . . 11-2
11.3.1. Facility Emergency Coordinator . . . . . . . . . 11-3
11.3.2. Emergency Contacts . . . . . . . . . . . . . . . 11-3
11.3.3. Reporting . . . . . . . . . . . . . . . . . . . . 11-3
11.3.4. Emergency Communications . . . . . . . . . . . . 11-5
11.4. Emergency Recognition and Prevention . . . . . . . . . . 11-5
11.5. Safe Distances and Places of Refuge. . . . . . . . . . . 11-5
11.6. Site Security and Control. . . . . . . . . . . . . . . . 11-6
11.7. Evacuation Routes/Procedures . . . . . . . . . . . . . . 11-6
11.8. Decontamination Procedures . . . . . . . . . . . . . . . 11-7
11.9. Emergency Medical Treatment/First Aid. . . . . . . . . . 11-7
11.10. Emergency Alerting/Response Procedures . . . . . . . . . 11-8
11.10.1. Notification . . . . . . . . . . . . . . . . . . 11-8
11.10.2 Evaluation of the Situation . . . . . . . . . . . 11-8
11.10.3. Rescue/Response Action . . . . . . . . . . . . . 11-9
11.11. Critique of Response and Follow-up . . . . . . . . . . . 11-9
11.11.1. Critique . . . . . . . . . . . . . . . . . . . . 11-9
11.11.2. Maintaining Readiness . . . . . . . . . . . . . . 11-10
11.12. PPE and Emergency Equipment. . . . . . . . . . . . . . . 11-10
11.13. References . . . . . . . . . . . . . . . . . . . . . . . 11-11
12.0. EMERGENCY ACTION PLAN . . . . . . . . . . . . . . . . . . . . 12-1
12.1. Background . . . . . . . . . . . . . . . . . . . . . . . 12-1
12.2. Emergency Escape Route Assignment. . . . . . . . . . . . 12-1
12.3. Procedures for Critical Operations Personnel . . . . . . 12-3
12.4. Procedures to Account for All Employees. . . . . . . . . 12-3
12.5. Rescue and Medical Duties. . . . . . . . . . . . . . . . 12-3
12.6. Reporting Fires and Other Emergencies. . . . . . . . . . 12-4
12.7. EAP Contact Personnel. . . . . . . . . . . . . . . . . . 12-4
12.8. Emergency/Evacuation Alarm System . . . . . . . . . . . 12-4
12.9. EAP Training Requirements. . . . . . . . . . . . . . . . 12-4
12.10. Fire Provention Plan . . . . . . . . . . . . . . . . . . 12-5
12.10.1 Housekeeping . . . . . . . . . . . . . . . . . . 12-5
12.10.2 Training . . . . . . . . . . . . . . . . . . . . 12-5
12.10.3 Maintenance . . . . . . . . . . . . . . . . . . . 12-6
12.11 Procedures for the Review and Update of the EAP . . . . 12-6
12.12. References . . . . . . . . . . . . . . . . . . . . . . . 12-6
13.0. CONFINED SPACE ENTRY . . . . . . . . . . . . . . . . . . . . 13-1
13.1. Background . . . . . . . . . . . . . . . . . . . . . . . 13-1
13.2. Duties and Responsibilities. . . . . . . . . . . . . . . 13-1
13.2.1. Project Manager . . . . . . . . . . . . . . . . . 13-1
13.2.2 Confined Space Coordinator . . . . . . . . . . . 13-2
13.2.3. Field Team Leader . . . . . . . . . . . . . . . . 13-2
13.2.4. Entry Supervisors . . . . . . . . . . . . . . . . 13-3
13.2.5 Employees Entering Confined Space . . . . . . . . 13-3
13.2.6. Attendant . . . . . . . . . . . . . . . . . . . . 13-4
13.2.7. Rescue Team . . . . . . . . . . . . . . . . . . . 13-4
13.3. Identification and Evaluation. . . . . . . . . . . . . . 13-4
13.3.1. Hazard Re-Evaluation. . . . . . . . . . . . . . . 13-5
13.4. Hazard Assessment . . . . . . . . . . . . . . . . . . . 13-5
13.5. Hazard Controls. . . . . . . . . . . . . . . . . . . . . 13-5
13.5.1. Engineering Controls . . . . . . . . . . . . . . 13-5
13.5.2. Work Practice (Administrative) Controls . . . . . 13-6
13.5.3. Personal Protective Equipment . . . . . . . . . . 13-6
13.6. Entry Permits. . . . . . . . . . . . . . . . . . . . . . 13-6
13.6.1. Key Elements for Entry Permits . . . . . . . . . 13-7
13.7. Entry Procedures . . . . . . . . . . . . . . . . . . . . 13-8
13.8. Opening a Confined Space . . . . . . . . . . . . . . . . 13-8
13.9. Atmospheric Testing. . . . . . . . . . . . . . . . . . . 13-8
13.9.1. Evaluation Testing . . . . . . . . . . . . . . . 13-9
13.9.2. Verification Testing . . . . . . . . . . . . . . 13-9
13.9.3. Acceptable Limits . . . . . . . . . . . . . . . . 13-9
13.10. Isolation and Lockout/Tagout Safeguards. . . . . . . . . 13-10
13.11. Ingress/Egress Safeguards. . . . . . . . . . . . . . . . 13-10
13.12. Warning Signs and Symbols. . . . . . . . . . . . . . . . 13-10
13.13. Training . . . . . . . . . . . . . . . . . . . . . . . . 13-11
13.13.1. General Training . . . . . . . . . . . . . . . . 13-11
13.13.2. Specific Training . . . . . . . . . . . . . . . . 13-12
13.14. Emergency Response . . . . . . . . . . . . . . . . . . . 13-12
13.14.1. Emergency Response Plan . . . . . . . . . . . . . 13-12
13.14.2. Retrieval Systems or Methods to Facilitate
Non-entry Rescue . . . . . . . . . . . . . . . 13-13
13.15. References . . . . . . . . . . . . . . . . . . . . . . . 13-13
14.0. SPILL CONTAINMENT . . . . . . . . . . . . . . . . . . . . . . 14-1
14.1. Background . . . . . . . . . . . . . . . . . . . . . . . 14-1
14.2. Preplanning. . . . . . . . . . . . . . . . . . . . . . . 14-1
14.3. Reporting and Initial Personnel Safety . . . . . . . . . 14-2
14.4. Initial Spill Action . . . . . . . . . . . . . . . . . . 14-2
14.5. Spill Response Evaluation. . . . . . . . . . . . . . . . 14-2
14.6. Organizing a Spill Response. . . . . . . . . . . . . . . 14-3
14.7. Spill Cleanup Procedures . . . . . . . . . . . . . . . . 14-3
14.8. Post Incident Follow-up. . . . . . . . . . . . . . . . . 14-3
14.9. References . . . . . . . . . . . . . . . . . . . . . . . 14-3
APPENDIX A HASP Glossary . . . . . . . . . . . . . . . . . . . . A-1
APPENDIX B Concluding Material . . . . . . . . . . . . . . . . . B-1
APPENDIX C Training Tables . . . . . . . . . . . . . . . . . . . C-1
APPENDIX D EM-40 Hazardous Materials Training Program Memorandum D-1
APPENDIX E Other Sources of Hazard Assessment Methods. . . . . . E-1
APPENDIX F Sample Decontaimination Layouts and Procedures for
Levels of Protection A through C. . . . . . . . . . . F-1
LIST OF FIGURES
Figure 2-1 Example of a Health and Safety Plan Organizational
Structure . . . . . . . . . . . . . . . . . . . . . . 2-2
Figure 2-2 Emergency Contact Personnel Names and Phone Numbers
Example Chart . . . . . . . . . . . . . . . . . . . . 2-3
Figure 4-1 EM-40 Definitions and Graphic Depictions of
Installation, Facility, and Site. . . . . . . . . . . 4-3
Figure 7-1 Medical Surveillance Process. . . . . . . . . . . . . 7-2
Figure 10-1 Example Layout of Contamination Reduction Corridors . 10-2
Figure 10-2 Decision Aid for Evaluating Health and Safety
Aspects of Decontamination Methods. . . . . . . . . . 10-4
LIST OF TABLES
Table 2-1 Onsite Essential or Key Personnel . . . . . . . . . . 2-10
Table 2-2 Optional Personnel. . . . . . . . . . . . . . . . . . 2-11
Table 3-1 Sample Hazard Assessment: Cleaning the Inside
Surface of a Chemical/Radioactive Contaminated
Tank - Top Manhole Entry. . . . . . . . . . . . . . . 3-6
Table 4-1 Minimum Training Requirements for Personnel Engaged
at EM-40 Sites . . . . . . . . . . . . . . . . . . . 4-4
Table 4-2 Minimum Training Requirements for Personnel Engaged
at RCRA TSD Sites . . . . . . . . . . . . . . . . . . 4-6
Table 4-3 Minimum Training Requirements for Personnel Engaged
in EM-40 Emergency Responses to Hazardous Substance
Releases. . . . . . . . . . . . . . . . . . . . . . . 4-7
Table 5-1 Respiratory PPE Selection . . . . . . . . . . . . . . 5-9
Table 5-2 Clothing PPE Selection. . . . . . . . . . . . . . . . 5-9
Table 6-1 Suggested Frequency of Physiological Monitoring for
Fit and Acclimatized Workers. . . . . . . . . . . . . 6-3
Table 6-2 Windchill Index . . . . . . . . . . . . . . . . . . . 6-5
Table 6-3 Maximum Daily Time Limits for Exposure at Low
Temperatures. . . . . . . . . . . . . . . . . . . . . 6-6
Table 7-1 Example of Periodic Examination Based on Job Task . . 7-4
Table 7-2 Hazardous Substances Expected to be Encountered,
the Target Organ, Potential Health Effects, and
Recommended Medical Monitoring. . . . . . . . . . . . 7-6
Table 8-1 Framework for Presenting Staff Responsibilities . . . 8-3
Table 8-2 Air Contaminants - Summary of Properties and
Frequency of Monitoring . . . . . . . . . . . . . . . 8-4
Table 8-3 Air Contaminants - Action Levels. . . . . . . . . . . 8-4
Table 8-4 Direct-Reading Instruments for Site XX. . . . . . . . 8-6
Table 9-1 General Equivalency of Work Zones . . . . . . . . . . 9-1
Table 11-1 Emergency Contacts and Phone Numbers. . . . . . . . . 11-4
Table 11-2 Emergency Equipment and Supplies. . . . . . . . . . . 11-11
LIST OF ACRONYMS
ACGIH American Conference of Governmental Industrial Hygienists
AIHA American Industrial Hygiene Association
ALARA As Low As Reasonably Achievable
ANSI American National Standards Institute
CDC Centers for Disease Control
CERCLA Comprehensive Environmental Response, Compensation
and Liability Act (also known as Superfund)
CFR Code of Federal Regulations
CPR Cardio Pulmonary Resuscitation
CRC Contamination Reduction Corridor
CRZ Contamination Reduction Zone
DHHS Department of Health and Human Services
DOE Department of Energy
DOT Department of Transportation
EAP Emergency Action Plan
EKG Electrocardiogram
EPA Environmental Protection Agency
ER Environmental Restoration
ERP Emergency Response Plan
HASP Health and Safety Plan
HAZMAT Hazardous Material
HAZWOPER Hazardous Waste Operations and Emergency Response
HEPA High Efficiency Particulate Air
IDLH Immediately Dangerous to Life or Health
LEL/LFL Lower Explosive Limit/Lower Flammable Limit
M&O Contractor Management and Operations Contractor
MSDS Material Safety Data Sheets
MSHA Mine Safety and Health Administration
NCP National Oil and hazardous Substances Pollution
Contingency Plan
NIEHS National Institute of Environmental Health Sciences
NIOSH National Institute for Occupational Safety and Health
NRC Nuclear Regulatory Commission
OSH Occupational Safety and Health
OSHA Occupational Safety and Health Administration
OTA Office of Technology Assessment
OU Operable Unit
PC Protective Clothing
PEL Permissible Exposure Limits
PPE Personal Protection Equipment
RCRA Resource Conservation and Recovery Act
REL Recommended Exposure Limits
S&H Officer Safety and Health Officer
SARA Superfund Amendments and Reauthorization Act
SCBA Self-Contained Breathing Apparatus
SSHO Site Safety and Health Officer
SOP Standard Operating Procedure
SOSG Standard Operating Safety Guide
SSO Site Safety Office
TLV Threshold Limit Values
TLV-STEL Threshold Limit Value-Short-Term Exposure Limit
TLV-TWA Threshold Limit Value-Time-Weighted Average
TSD Treatment, Storage and Disposal
UEL/UFL Upper Explosive Limit/Upper Flammable Limit
USCG United States Coast Guard
1.1 - Background
In the 1986 amendments to the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), Congress tasked the
Administrators of the Environmental Protection Agency (EPA) and
Occupational Safety and Health Administration (OSHA), the Secretary of the
Department of Transportation (DOT), and the Director of the National
Institute for Occupational Safety and Health (NIOSH) to modify the National
Contingency Plan (NCP) (40 CFR 300) to provide for protection of health and
safety of employees involved in response actions. To satisfy this
directive, standards requiring the development of a site-specific health
and safety plan (HASP) were established by OSHA in 29 CFR 1910.120,
Hazardous Waste Operations and Emergency Response (HAZWOPER), and
incorporated into the NCP (40 CFR 300.150). Additionally, the NCP requires
compliance with standards and regulations of the Occupational Safety and
Health Act, including such standards as Construction Safety (29 CFR 1926)
and General Industry Standards (29 CFR 1910), where applicable. DOE Orders
5480.1B and 5483.1A require compliance with these standards.
This guidance document is intended to assist in the preparation of
site-specific HASPs that will meet or exceed the requirements of 29 CFR
1910.120.
This chapter summarizes the regulatory framework upon which the
site-specific HASPs for EM-40 facilities will be based. It is the intent
of this chapter to provide clear, concise direction regarding compliance
with 29 CFR 1910.120(b)(4)(ii) as applied to EM-40 facilities. Some
sections of this chapter describe techniques or modifications that are not
specifically included in the HAZWOPER standard. EM-40 has adopted these
additions, based on industry practice, perceived operational weaknesses,
other occupational safety and health standards, or other considerations.
If an existing HASP at any EM-40 site meets or exceeds the requirements of
this chapter, no modifications to that HASP are necessary. Unless
otherwise noted, the information requirements shall be included in at least
one section and references made in other sections, as necessary.
1.2 - Site-Specific HASP Requirements
1.2.1. Introduction
The site-specific HASP should include an introduction to the plan. The
main purpose of the introduction is to describe the site the HASP will
encompass and its applicability to operations. In developing this
description the preparer should include:
* A brief description,
* Background information (e.g., site history, prior site activities),
* Known site contamination,
* Synopsis of site characterization, and
* Site operations to be performed.
While all of the following sections should be included in the HASP, a site
may determine that a portion of a section does not apply (e.g., cold
temperature extremes for a tropical climate). If a portion of a section is
not applicable, it may not need to be addressed, but an explanation of
non-applicability should be provided.
1.2.2. Key Personnel
The HAZWOPER standard does not require a listing of key personnel in the
site-specific HASP. However, due to the importance of this list of
individuals to the overall safety and health effort at a hazardous waste
site, a listing of key personnel shall be included in the site-specific
HASP for EM-40 sites. The DOE Project Manager, as well as key personnel,
shall be identified at the DOE, contractor and subcontractor level.
It is an accepted practice that the number of key personnel shall be kept
to a minimum. However, the key personnel responsibilities must be assigned
and accounted for at any hazardous waste site. Both of these concerns may
be accomplished, at the discretion of the Project Manager, by assigning one
person to several positions.
At a minimum, the key personnel section to be included in the site-specific
HASP shall identify the:
* Overall Project Manager,
* Site Safety and Health Officer (SSHO),
* Additional Safety and Health Personnel,
* Field Team Leader,
* Command Post Supervisor,
* Emergency Response Coordinator,
* Decontamination Station Officer,
* Security Officer, and
* Specialty Team Personnel.
More specific information regarding Key Personnel is contained in Chapter 2.
1.2.3. Hazard Assessment
The HAZWOPER standard does not give specific guidance as to the methodology
to be used to meet the requirements of 29 CFR 1910.120(b)(4)(ii)(A). For
the purpose of the EM-40 site-specific HASP the hazard assessment approach
identified below shall be used.
Hazard assessment is a methodology used to identify inherent or potential
hazards which may be encountered in the work environment associated with
accomplishing a job. At a minimum, the hazard assessment shall include the
following steps:
* Identification of an operation or job to be assessed,
* Break down of the job or operation,
* Identification of the hazards associated with each task, and
* Determination of the necessary controls for the hazards.
Other more detailed hazard assessment procedures are also acceptable. More
specific information on the hazard assessment process is contained in
Chapter 3.
1.2.4. Training
In 29 CFR 1910.120(e) different levels of training are required, depending
on the task to be performed. Training for EM-40 employees and contractors
at EM-40 hazardous waste sites exceeds these requirements, as specified by
the EM memorandum in Appendix D. The training program (40 hour offsite and
3 day onsite supervision), at a minimum, shall address:
* Key personnel responsible for site safety and health;
* Safety, health and other hazards present on site;
* Use of Personal Protective Equipment (PPE);
* Safe work practices and site Standard Operating Procedures (SOPs);
* Safe use of onsite engineering controls and equipment;
* Medical surveillance program requirements, including
signs/symptoms of overexposure;
* Site decontamination procedures;
* Site emergency response/action plan;
* Confined space entry procedures; and
* Site spill containment program/procedures.
Management and supervisors, as identified in the Key Personnel section,
will receive an additional 8 hours of training as specified in 29 CFR
1910.120(e)(4).
Additionally, 29 CFR 1910.120 (b)(4)(iii) specifies that a pre-entry
briefing be given to each site worker, manager, supervisor and/or any other
individual associated with the site. Documentation of these briefings
shall be maintained at the site command post.
Additional information on training requirements is contained in Chapter 4
and Appendix C.
1.2.5. Personal Protective Equipment (PPE)
Careful selection and use of PPE is essential to protect the health and
safety of workers. The purpose of PPE is to shield or isolate workers from
the chemical, physical, radiological, and biological hazards that may be
encountered at the site.
The PPE program contained in the site-specific HASP shall, at a minimum,
address:
* PPE selection based on site hazards;
* PPE use and limitations;
* Work mission duration;
* Maintenance and storage;
* Decontamination and disposal;
* Training and proper fitting;
* Donning and doffing procedures;
* Inspection procedures prior to, during, and after use;
* Effectiveness evaluation procedures; and
* Limitations due to temperature extremes, and other appropriate
medical and physical concerns.
Additional information on PPE is contained in Chapter 5.
1.2.6. Temperature Extremes
Limitations due to temperature extremes often result in the necessity to
modify work schedules, work hours or otherwise reduce the time employees
shall spend in chemically protective clothing. Chapter 6 is devoted to
hazards relating to temperature extremes; it provides guidance on how to
make these determinations and evaluate the potential for temperature
related disorders or conditions. Chapter 7 provides guidance on medical
surveillance procedures. The temperature extreme program, should, at a
minimum address:
* Identification of potential hazards early in the planning phase of
the development and operation of required contingency plans.
* Proper monitoring of worker physiology.
* Implementation of preventive measures and Standard Operating
Procedures (SOPs) early in the operations so that sound worker
practices are developed and followed.
* Proper initial training of workers to recognize the symptoms of
temperature extreme related disorders or conditions in themselves
and their fellow workers.
* Implementation of a "buddy system", and
* Proper acclimatization of all workers to new or changing work
conditions.
Additional information on temperature extremes can be found in Chapter 6.
1.2.7. Medical Surveillance
Medical Surveillance of workers at hazardous waste sites is necessary to
protect the health of the worker, establish fitness for duty, and ensure
documentation of exposure to hazardous materials.
The elements of the medical surveillance program contained in the
site-specific HASP shall, at a minimum, address:
* Employees covered by the program,
* Frequency of medical exams/consultations,
* Content of medical exams/consultations,
* Information provided to the physician,
* Physician's written opinion, and
* Recordkeeping requirements.
More specific information regarding medical surveillance is contained in
Chapter 7.
1.2.8. Exposure Monitoring and Air Sampling
The monitoring component of the site-specific HASP shall be based on all
chemical, physical and radiological hazards identified in the site
characterization. At a minimum, it shall address:
* Sampling strategy and schedule for personal monitoring (breathing
zone), air monitoring (level of protection) and environmental
sampling (offsite migration),
* Instrumentation and equipment to be used,
* Calibration and maintenance of instruments and equipment, and
* QA/QC procedures and analytical methods.
More specific information on exposure monitoring and air sampling is
contained in Chapter 8.
1.2.9. Site Control
The site control program is used to control movement of people and
equipment in order to minimize worker exposure to hazardous substances.
The site control measures program contained in the site-specific HASP
shall, at a minimum, include:
* Site map,
* Site work zones,
* Definition and use of the "buddy system",
* Site communication procedures, including emergency procedures,
* Safe work practices and/or SOPs, and
* Location of nearest medical assistance.
Additional information on site control is contained in Chapter 9.
1.2.10. Decontamination
29 CFR 1910.120(k) does not contain specific procedural development
requirements in the area of decontamination. The working group has adopted
the methodology presented in the U. S. Environmental Protection Agency
(EPA) document titled "Standard Operating Safety Guide" (SOSG). The SOSG
establishes the decontamination layout and required procedures based on the
level of PPE used at the site.
The decontamination elements contained in the site-specific HASP shall, at
a minimum, include:
* Training;
* Location and layout of decontamination stations and areas;
* Decontamination methods;
* Required decontamination equipment;
* SOPs to minimize worker contact with contaminants during
decontamination;
* SOPs for decontamination line personnel; and
* Procedures for collection, storage and disposal of clothing,
equipment and any other materials that have not been completely
decontaminated.
Additional information on decontamination is contained in Chapter 10.
1.2.11. Emergency Response/Contingency Plan
The site management must develop and implement an Emergency Response Plan
(ERP) in accordance with requirements of 29 CFR 1910.120(l), if the
employees at an EM-40 site are expected to respond to emergencies at that
site.
The ERP to be included in the site-specific HASP shall, at a minimum, address:
* Pre-emergency planning;
* Personnel roles, responsibilities, and lines of communication;
* Emergency recognition, preparedness drills, and follow-up
procedures;
* Safe distances and places of refuge;
* Site security and control;
* Evacuation routes and procedures;
* Decontamination procedures that are not covered in the
site-specific HASP;
* Emergency medical treatment and first aid;
* Emergency alerting and response procedures;
* Critique of response and prevention procedures;
* PPE and emergency equipment;
* Site topography and layout;
* Incident reporting procedures;
* List of local emergency response contacts; and
* Potential worst case weather by season.
Additional information regarding the ERP is contained in Chapter 11.
1.2.12. Emergency Action Plan
If employees are expected to evacuate the site and not participate in
emergency response activities, the site must have an Emergency Action Plan
(EAP) in accordance with requirements of 29 CFR 1910.38(a).
The EAP to be included in the site-specific HASP shall, at a minimum, address:
* Emergency escape procedures and route assignments;
* Procedures to be followed by personnel who stay behind to conduct
critical operations before they evacuate;
* Procedures to account for all employees after evacuation;
* Rescue and medical duties for assigned personnel;
* Names and phone numbers of personnel and organizations to be
contacted for further information;
* Description of the alarm procedures used to alert personnel of
emergency and evacuation situations;
* EAP training requirements and methods to evaluate employee
knowledge of the plan, and
* Procedures and frequency for rehearsal, review, and update of the
plan.
Additional information regarding the Emergency Action Plan is contained in
Chapter 12.
1.2.13. Confined Space Entry
The confined space entry procedures for the EM-40 HASP Guidelines are
derived from 29 CFR 1910.146, American National Standards Institute (ANSI)
Recommendation Z117.1-1989, and applicable DOE orders.
The confined space entry program portion of the site-specific HASP shall,
at a minimum, address:
* Personnel duties and responsibilities;
* Identification, posting and evaluation of confined spaces on site;
* Hazard controls (engineering, administrative and PPE);
* Entry permit contents, requirements, and approval;
* Entry procedures;
* Lockout/tagout requirements and procedures;
* Additional safeguards and emergency procedures; and
* Training requirements.
Additional information regarding confined space entry is contained in
Chapter 13.
1.2.14. Spill Containment
The spill containment program provides procedures to contain and isolate
the entire volume of a hazardous substance spill and minimizes worker
exposure to hazardous substance spills.
The spill containment program to be included in the site-specific HASP
shall, at a minimum, address:
* Initial spill actions and response,
* Spill cleanup procedures,
* Organization of the response team, and
* Post-incident review and evaluation.
Additional information on spill containment is contained in Chapter 14.
1.3 - References
1. "U.S. EPA 1984 Standard Operating Safety Guides." Office of Emergency
and Remedial Response, Hazardous Response Support Division, Edison,
N.J. November, 1984.
2. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response"
(HAZWOPER).
3. 29 CFR 1910.146, "Permit Required Confined Spaces."
4. American National Standards Institute (ANSI) Recommendation
Z117.1-1989, "Safety Requirements of Confined Spaces."
5. 29 CFR 1910.38, "Employee Emergency Plans and Fire Prevention Plans."
6. Whitfield, P., "EM-40 Hazardous Materials Training Program," memorandum
of February 3, 1994.
7. "Occupational Safety and Health Guidance Manual for Hazardous WasteSite
Activities," NIOSH/OSHA/USCG/EPA, October 1985 (Four-Agency Document).
8. DOE Order 5480.1B, "Environment, Safety, and Health Program for
Department of Energy Operations."
9. DOE Order 5483.1A, "Occupational Safety and Health Program for DOE
Contractor Employees at Government-Owned Contractor Operated (GOCO)
Facilities."
2.1 - Background
This chapter provides guidance to assist in the preparation of the Key
Personnel portion of the site-specific HASP. In this section, the HASP
should:
* Identify an individual who has the authority to direct all
activities;
* Identify the other personnel needed for the project and assign
their general functions and responsibilities;
* Show lines of authority, responsibility, and means of contact; and
* Identify the interface with the response community.
2.2 - Organizational Structure
The HASP should specifically identify the names and organizational
relationships among the DOE, contractor, and subcontractor key personnel,
such as the Project Manager, Field Team Leader, and Site Safety and Health
Officer (SSHO). Designated alternates for the key personnel,
responsibilities, lines of authority, methods of communication, and an
organizational structure should be identified. If specific key job
responsibilities listed in this chapter are not needed, or more than one
function is to be performed by a person, those responsibilities should be
addressed in the HASP.
During the first stages of planning, an organizational structure that
supports the overall objectives of the project should be developed. An
explanation of the structure including the chain of command and overall
responsibilities of supervisors and employees in carrying out the health
and safety program should be included in the HASP. An organizational chart
should be developed depicting the structure and identifying all key
personnel and other onsite and offsite personnel (see Figure 2-1). The
chart should be placed in a central location, and included in the HASP. At
a minimum, the organizational chart should include the Project Manager, the
SSHO, the Field Team Leader, the Command Post Supervisor, the
Decontamination Station Officer(s), site security, and the specialty team.
In addition, it is recommended that a list of DOE and contractor personnel
and a list of offsite organizations (see Figure 2-2) to be contacted in the
event of an emergency be included with the organizational chart.
As the project progresses, it may be necessary to modify some
organizational aspects, such as personnel responsibilities and authorities,
so that individual tasks can be performed as efficiently and safely as
possible. Any changes to the overall organizational structure should be
recorded in the appropriate sections of the HASP that are developed for
individual phases or tasks. These specific changes should be communicated
to all parties involved.
FIGURE 2-1
Example of a Health and Safety Plan (HASP) Organizational Structure
(Figure not available in Gopher version)
FIGURE 2-2
Emergency Contact Personnel Names and Phone Numbers
Example Chart
Organization Contact Telephone
--------------------------------------------------------------------
Ambulance:
Local Police:
Fire:
State Police:
Hospital (Primary)
Hospital (Secondary)
Poison Control Center:
Regional EPA:
EPA Emergency Response 908-321-6660
Team:
State Authority:
National Response Center: 800-424-8802
Center for Disease Control: 404-488-4100
Chemtrec: 800-424-9555
Site Emergency Operations
Center:
DOE Emergency Operations 202-896-8100
Center (National Center):
2.3 - Onsite Essential Personnel
2.3.1. Project Manager
The name and position of the individual who has the authority to direct all
activities should be identified (i.e., Project Manager, Project Team
Leader, or Site Supervisor). A designated alternate for this position
should be identified by name. A general description including areas of
responsibility (i.e., assumes total control over site activities, authority
to direct response operations) should be provided for the Project Manager
who should be considered an "onsite essential" person. The specific
responsibilities of the Project Manager should be stated. These
responsibilities should include, but are not limited to:
* Management of the project;
* Preparation of the work plan, preparation of the HASP, and
designation of the field team;
* Designation of an individual within each project to act as
the confined space coordinator;
* Identification of work-site confined spaces;
* Designation of an individual to act as the medical program
administrator;
* Access permission for visitors, new hires, etc., and
coordinates activities with appropriate officials;
* Confirmation of each team member's suitability for work based
on employees training and physician's recommendation;
* Briefing field teams on their specific assignments;
* Coordination with the SSHO on safety and health requirements;
* Preparation of the final report and support files on the
response activities;
* Liaison with public officials; and
* Maintenance of a daily site log.
2.3.2. Site Safety and Health Officer
The Site Safety and Health Officer (SSHO) should be identified by name for
each DOE, contractor, and subcontractor organization. A designated
alternate for each SSHO should be identified by name. A DOE point of
contact, if appropriate, should also be identified. A general description
of duties, including lines of authority (i.e., stop work authority) should
be provided. The SSHO should be an "onsite essential" person. The
specific responsibilities of the SSHO should include, but are not limited
to:
* Managing the safety and health program for the site;
* Periodically inspecting protective clothing and equipment;
* Monitoring and evaluating HASP implementation;
* Monitoring protective clothing and equipment to ensure that
they are properly stored and maintained;
* Monitoring entry and exit to the exclusion zone;
* Verifying each team member's suitability for work based on
employee's training and physician's recommendation;
* Monitoring the work parties for signs of stress, such as
cold exposure, heat stress, and fatigue;
* Advising medical personnel of potential exposures and consequences;
* Participating in the preparation and implementation of the HASP;
* Conducting periodic inspections to verify if the HASP is
being properly implemented;
* Verifying that the "buddy" system is being implemented;
* Knowing emergency procedures, evacuation routes, and the
telephone numbers of the ambulance, local hospital, poison
control center, fire department, and police department;
* Notifying local public emergency officials when necessary; and
* Coordinating emergency medical care.
2.3.3. Safety and Health Personnel
Names and responsibilities of other personnel that have safety and health duties
should be listed.
These should include, but are not limited to:
* Construction safety experts,
* Safety specialists/technicians,
* Health physicists, and
* Industrial Hygienists.
2.3.4. Field Team Leader
The individual who is responsible for field team operations and safety
should be identified by name. In some cases, the Field Team Leader may
also be the same person as the Project Manager and may be a member of the
specialty team. A designated alternate for the should be identified by
name. A DOE point of contact, if appropriate, should also be identified.
A general description, including areas of responsibility (i.e., responsible
for field team operations and safety) should be provided for the Field Team
Leader, who should be considered an "onsite essential" person. The
specific responsibilities of the Field Team Leader should be stated. These
responsibilities include, but are not limited to:
* Managing field operations;
* Executing the work plan and schedule;
* Enforcing safety procedures;
* Coordinating with the SSHO in determining protection levels;
* Enforcing site control;
* Documenting field activities, including sample collection; and
* Serving as liaison with public officials where there is no
Public Affairs official designated.
2.3.5. Command Post Supervisor
The individual who is responsible for communications and emergency
assistance should be identified by name. In some cases, the Command Post
Supervisor may be the same person as the Field Team Leader. A designated
alternate should be identified by name. A DOE point of contact, if
appropriate, should also be identified. A general description, including
areas of responsibility (i.e., responsible for communications and emergency
assistance) should be provided for the Command Post Supervisor, who should
be considered an "onsite essential" person. The specific responsibilities
of the Command Post Supervisor should be stated. These responsibilities
should include, but are not limited to:
* Notifying emergency response personnel by telephone or radio
in the event of an emergency;
* Assisting the SSHO in rescue operations, if necessary;
* Maintaining a log of communication and site activities;
* Assisting other field team members in the clean areas, as
needed; and
* Maintaining line-of-sight and communication contact with the
work parties via walkie-talkies, signal horns, or other means.
2.3.6. Emergency Response Coordinator
The individual who has the authority to direct, control, and evaluate site
emergency response/emergency activities should be identified. A designated
alternate should be identified by name. A DOE point of contact, if
appropriate, should be identified. The Emergency Response Coordinator
should be considered an "on-site essential" person. A general description
including areas of authority and responsibilities should be provided.
These responsibilities should include, but are not limited to:
* Developing, implementing, and updating the emergency
response/emergency action plan;
* Conducting rehearsals, employee training, evaluations of
responses/actions; and
* Assuring the evacuation, emergency treatment, emergency
transport of site personnel and notifying emergency response
units and the appropriate management staff.
2.3.7. Decontamination Station Officer
The individual who is responsible for decontamination procedures,
equipment, and supplies should be identified by name. In some cases, the
Decontamination Station Officer may be the same person as the Field Team
Leader. A designated alternate should be identified by name. A DOE point
of contact, if appropriate, should also be identified. A general
description, including areas of responsibility (i.e., responsible for
decontamination procedures, equipment, and supplies) should be provided for
the Decontamination Station Officer, who should be considered an "onsite
essential" person. The specific responsibilities of the Decontamination
Station Officer should be stated. These responsibilities should include,
but are not limited to, the following:
* Setting up decontamination lines and the decontamination
solutions appropriate for the type of chemical contamination
on site;
* Controlling the decontamination of all equipment, personnel,
and samples from the contaminated areas;
* Assisting in the disposal of contaminated clothing and materials;
* Ensuring all required equipment is available and in working
order; and
* Providing for collection, storage and disposal of waste.
2.3.8. Security Officer
The individual who is responsible for managing site security should be
identified by name. A designated alternate and DOE point of contact, if
appropriate, should be identified by name. A general description,
including areas of responsibility (i.e., maintains site security) should be
provided for the Security Officer, who should be considered an "onsite
essential" person. Specific responsibilities of the Security Officer
should be stated. These responsibilities should include, but are not
limited to:
* Conducting routine area patrols,
* Controlling facility access and egress,
* Assisting with communication during an emergency,
* Securing accident/incident scenes, and
* Maintaining a log of site access and egress.
2.3.9. Specialty Teams
Specialty Teams, consisting of field team members (e.g., to include rescue
teams for retrieving personnel from dangerous situations, and sampling
teams for obtaining samples of potentially hazardous materials) who
complete the onsite tasks required to fulfill the work plan, should be
identified. A general description, including areas of responsibility and
stopwork authority (i.e., any or all of the field team may be in the
Specialty Team and should consist of at least two people) should be
provided. Specialty Team personnel should be considered "onsite essential"
personnel. Specific responsibilities of the Specialty Teams should be
stated. These responsibilities should include, but are not limited to:
* Safely completing the onsite tasks required to fulfill the
work plan,
* Complying with HASP, and
* Notifying the SSHO or supervisor of unsafe or potentially
unsafe conditions.
2.4 - Optional Personnel
2.4.1. Industrial Hygienist
The employee who is trained to anticipate, recognize, evaluate and control
environmental factors or stresses in the workplace, should be identified by
name. A qualified and designated alternate for the Industrial Hygienist
should be identified by name.
Specific responsibilities of the Industrial Hygienist should be provided.
The responsibilities should include, but are not limited to:
* Conducting health hazard assessments,
* Providing advice on adequate health protection, and
* Conducting tests to determine worker exposures to hazardous
substances.
2.4.2. Fire Fighters
The means of contacting the Fire Department should be provided in the
document, and this information should be conspicuously posted at locations
throughout the site. Responsibilities of the fire department should be
stated. These responsibilities include, but are not limited to:
* Having Emergency Medical Technicians on response teams,
* Responding to fires that occur on site, and
* Standing by for response to potential fires and performing rescues.
2.4.3. Health Physicist
The individual who is trained in radiation physics (effects, and
protection) should be identified by name. A designated alternate for the
Health Physicist should be identified by name. Specific responsibilities
of the Health Physicist, such as evaluating radiation health hazards and
recommending appropriate action, should be stated.
2.4.4. Scientific Advisor
The advisor that guides the Project Manager in technical or scientific
matters should be named. A general description should be provided for the
Scientific Advisor (i.e, reports to the Project Manager, may be located on
site or off site). The specific responsibilities of the Scientific Advisor
should be stated. These responsibilities include, but are not limited to:
* Providing advice for field monitoring,
* Sample collection, and
* Remedial plans.
2.4.5. Logistics Officer
The employee who oversees all logistics for the operation should be named.
A general description should be provided for the Logistics Officer (i.e.,
reports to the Project Manger, may be located on site or off site). The
specific responsibilities of the Logistics Officer should be stated. These
responsibilities include, but are not limited to the planning and
mobilization of the facilities, materials, and personnel required for the
response.
2.4.6. Photographer
The employee who is responsible for all site photography should be named.
A general description should be provided for the Photographer (i.e.,
reports to the Project Manager, may be located on site or off site). The
specific responsibilities of the Photographer should be stated. These
responsibilities include, but are not limited to, providing photographs of
site conditions and archiving photographs.
2.4.7. Recordkeeper
The employee who oversees all recordkeeping for the operation should be
named. A general description should be provided for the Recordkeeper (i.e,
reports to the Project Manager, may be located on site or off site.) The
specific responsibilities of the Recordkeeper should be stated. These
responsibilities include, but are not limited to, maintaining the official
records of site activities.
2.4.8. Public Information Officer
The employee who oversees the release of public information should be
named. A general description should be provided for the Public Information
Officer (i.e., reports to the Project Manager, may be located on site or
off site.) The specific responsibilities of the Public Information Officer
should be stated.
2.4.9. Multidisciplinary Advisors
The list and general description of multidisciplinary advisors should be
provided. This list includes representatives from upper level management
and onsite management, field team members, and technical experts. Specific
responsibilities should also be stated. These responsibilities include,
but are not limited to, providing advice on the design of the work plan and
the HASP.
2.4.10. Medical Support
The general description of the types of medical support personnel required
should be provided, such as consulting physicians, medical personnel at
local hospitals and clinics, and ambulance personnel. The specific
responsibilities of medical support personnel should be stated. These
include:
* Being familiar with the types of materials on site, the
potential for worker exposures and recommending the medical
program for the site;
* Providing emergency treatment and decontamination procedures
for the specific type of exposures that may occur at the site; and
* Providing emergency treatment procedures appropriate to the
onsite hazards.
2.4.11. Bomb Squad Expert
The general description of this function should be provided (i.e., reports
to the Project Manager when requested to perform site-related functions).
The specific responsibilities of the Bomb Squad Expert should be stated
(e.g., providing advice on methods of handling explosive materials and
assisting in safely detonating or disposing of explosive materials).
2.5 - Communications
The site-specific HASP should identify the location of and describe the use
of all communication equipment that could be utilized in an emergency
situation (e.g., telephones, radios, PA systems). The HASP should identify
how key personnel and optional personnel can be contacted including work
phone, home phone, radio, etc. Examples are provided in Tables 2-1 and
2-2.
TABLE 2-1
Onsite Essential or Key Personnel
Position Name & Radio Phone Alternate Radio Phone DOE Radio Phone
Organi- or Numb or Numb. Point or Numb.
zation Pager H & W Pager H & W of Pager H & W
Contact
-----------------------------------------------------------------------------
DOE Project
Manager
Contractor
Project
Manager
Safety &
Health
Officer
Field Team
Leader
Command
Post
Supervisor
Decon.
Station
Officer
Emergency
Response
Coordinator
Specialty
Team
Security
Officer
Other
(as
appropriate)
TABLE 2-2
Optional Personnel
Position Name and Phone Numb. Alternate Phone Numb.
Organization H & W H & W
-------------------------------------------------------------------
Multidisciplinary
Advisor
Medical
Support
Personnel
Bomb Squad
Expert
Emergency
Response
Center
Personnel
Regulatory
Specialist
Medical
Support
Personnel
Contractor
S&H Staff
Industrial
Hygienist
Fire Fighter
Health
Physicist
Scientific
Advisor
Logistics
Officer
Photographer
Recordkeeper
Public
Information
Officer
2.6 - Other Source of Assistance
2.6. OTHER SOURCES OF ASSISTANCE
Procedures for contacting the Emergency Response Center should be
established and identified. A general description for contacting the
communications personnel other than the Emergency Response Center, such as
Civil Defense organizations, local radio and television stations, and local
emergency service networks, should also be provided. A protocol for
contacting the organizations stated above should be established and stated.
The specific responsibilities of the Emergency Response Center include
providing communication with the public in the event of an emergency and
providing communication links for mutual aid.
Other organizations such as Chemtrec, EPA, and the NRC may provide
additional assistance and should be identified. An overview of the
services and information available from these organizations should be
provided. Services that may be available include providing advice on
properties of materials, contaminant control materials, dangers of chemical
mixtures that may result from site activities, and providing immediate
advice to those at the scene of a chemical or radiological emergency.
2.7 - References
1. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response"
(HAZWOPER).
2. Department of Health and Human Services (DHHS) (NIOSH) Publication
No. 85-115, "Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA, 1985 (Four-Agency
Document).
3. EPA 9285.8-01, "Health and Safety Plan (HASP) User's Guide," Office of
Emergency and Remedial Response, USEPA, 1992 (and ERT Health and Safety
Plan Planner, Ver. 3.0C, 1993).
4. EPA/540/G-89/010, "Health and Safety Audit Guidelines," SARA Title I,
Section 126, Office of Emergency and Remedial Response, USEPA, 1989.
5. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,
Chapter 8," Office of Emergency and Remedial Response, USEPA, 1992.
3.1 - Background
The overall objectives of the Hazard Assessment chapter are to provide
guidance on:
* The development of site-specific procedures designed to
effectively identify, assess, and control site hazards;
* The identification of all onsite operations, jobs and related
tasks that are hazardous due to their inherent characteristics;
* The development of a system for assessing the safety and health
hazards identified at the site;
* The identification and use of engineering and administrative
controls, and Personal Protective Equipment (PPE) to minimize
worker exposure to site hazards; and
* The establishment of site-specific hazard control evaluation
activities.
Hazards at EM-40 sites pose a multitude of safety and health concerns. The
hazards are a function of the nature of the site and the work being
performed. Examples of such hazards include, but are not limited to:
* Chemical exposure (irritation, organ/tissue damage, and central
nervous system depression);
* Radioactive exposure (tissue damage or cancer);
* Safety/Construction hazards (fire and explosion,
excavating/trenching, electrical hazards, and slip/trip/fall);
* Machinery (rotating, crushing, digging and drilling);
* Transportation (accidents, spills);
* Biological hazards (poisonous plants, animals, snakes,
insects, and pathogens);
* Physical hazards (noise, eyes, feet, head, oxygen deficiency,
temperature extreme stress-heat stress/cold exposure);
* Weather (ice/mud/flooding, high winds, tornados, hurricanes,
electrical storms);
* Confined spaces (oxygen deficiencies, chemical exposure hazards);
* Ergonomic/Repetitive motion (back injuries, carpal tunnel syndrome);
* Asbestos (asbestosis, mesothelioma);
* Material handling (storage, housekeeping).
Due to the nature of a hazardous waste site, these hazards may be severe,
and may occur in a large variety of forms and locations. Their recognition
and evaluation is necessary for planning and managing operations at a site.
Hazard assessment, the process of identifying and evaluating the hazards
associated with operational activities, can be divided into four broad,
interacting categories or elements:
* Selection of the operation or job to be assessed,
* Breakdown of the operation or job into constituent tasks,
* Identification of hazards associated with each task, and
* Determination of the necessary hazard controls.
To effectively manage hazardous activities and substances, and to assure
worker safety and health, site personnel should understand the processes to
be used to develop each of these elements. As new hazards in the workplace
are identified and assessed, hazard controls should be implemented, and as
improved hazard abatement methodologies and hazard controls are identified,
as appropriate, they should be implemented.
Once the hazard assessment is completed, all significant identified hazards
should be controlled as quickly as reasonably feasible.
3.2 - Hazard Identification
Management (DOE and contractor) should provide for the identification of
and have an understanding of the occupational safety and health hazards
associated with their programs. This will enable them to make effective
and efficient decisions related to facilities, processes, procedures, and
the allocation of resources to protect the safety and health of workers.
The hazard identification section should contain the process(es) to be used
to identify all actual and potential hazards which exist at the site. The
comprehensive workplan, as required by 29 CFR 1910.120(b), and site
characterization should be used as a basis for the identification.
Determining present safety and health hazards is important (critical) to
the overall evaluation of remedial action sites. Therefore, each hazard
associated with activities to be conducted at these sites should be
identified to ascertain the physical, safety, construction, chemical,
radiological, and other properties which may result in causing harm. These
inherent properties establish the anticipated problems associated with the
activity.
Evaluation and identification of hazards should take place:
* Initially, during the site characterization;
* Immediately after initial site entry. The assessment should be
a more detailed "real time" evaluation and used to further
define existing site hazards and aid in the selection of
appropriate engineering and administrative controls and PPE;
* Prior to changes in jobs, tasks, and/or processes;
* As required by changing site conditions; and
* Continually, as appropriate.
Additionally, DOE and contractors should conduct routine compliance
inspections of their worksites and subcontractor worksites to identify new
or previously overlooked OSH hazards or failures to control known hazards.
3.2.1. Hazards List
A list of hazards should be developed which describes:
* Safety hazards associated with the site's operations (e.g.,
equipment, processes);
* Hazardous substances, radiological hazards, and other health
hazards, involved or expected at the site; and
* Anticipated exposure levels for each job/task.
This list, which uses the information contained in the site
characterization and comprehensive workplan, should identify everything
that has the potential for causing injury or illness to workers.
3.2.1.1. Operations
The hazards list should contain a description of operations, including
items such as:
* Type of equipment,
* Activities conducted near hazards, and
* Type and nature of material.
The intent is not to fully describe systems operations nor to provide an
operating manual but to give an overview in relation to hazards,
operational events that may "trigger" them, and the controls that may be
needed. Adequate details necessary for later identification of hazards, as
well as the reasonableness of controls, should be presented.
Part of the description of the site's operations may involve determining
where these operations are located or performed. Site location may have a
strong bearing on the possible impacts a hazard may have, events that might
lead to the actual realization of impacts, or the nature of controls that
may be implemented.
3.2.1.2. Hazardous substances, radiological hazards, and other health hazards
All suspected hazardous substances that may cause injury/illness or that
are Immediately Dangerous to Life or Health (IDLH), or other health hazards
that may cause death or serious harm, should be identified and included in
the hazards list. To help identify hazardous materials which should be
considered, the following criteria may be used:
* Quantity of the hazardous material;
* Type, nature, and form of the hazardous materials (e.g.,
radioactive, toxicological, chemical, liquid, or solid);
* Location of the material;
* Conditions under which the material is processed, handled,
or stored (e.g. temperature, pressure, handling systems); and
* Specific hazards associated with the material.
3.2.1.3. Job/Task
Each job and related task should be analyzed to determine the hazards that
may be present. For example: Trenching (job) may require the operation of
machinery (task). In addition to the obvious hazards associated with
trenching (e.g., cave-ins), the hazards associated with operation of the
machinery should be assessed. The information obtained from the assessment
of site operations and the identification of hazardous substances should be
considered when analyzing the various tasks at the site. Jobs and their
related tasks should form the basis for documenting the information
obtained during the hazard assessment (see section 3.5).
3.3 - Examples of Hazard Assessment Methods
Many techniques are available in the literature for performing hazard
assessments. A list of several methods that can be used for the assessment
of identified hazards and subsequent assignment of risk significance are
contained in Appendix E.
3.4 - Hazard Control
The most efficient way to protect workers from workplace hazards is to
first remove obvious hazards that can be eliminated without significant
effort. Within the scope of clean-up activities, this can sometimes be
difficult, since the objective of these activities is the actual removal of
hazards.
Hazards should be controlled by the following hierarchy of methods:
* Engineering controls;
* Work practices and administrative controls, except where
prohibited by standards, orders or regulations; and
* PPE.
Often, physical hazards discovered through preliminary evaluations and
site/facility walkthroughs can be eliminated without significant effort or
cost. These hazards should be removed to the extent possible before actual
work at the site begins. Examples of ways to eliminate physical hazards
associated with the site include:
* Removing of unnecessary debris;
* Guarding exposed electrical wiring, or sharp or protruding
objects;
* Securing objects near elevated surfaces and combustible
materials; and
* Eliminating slippery surfaces, dangerous flooring, and uneven
terrain.
Hazards that cannot be readily eliminated should be properly controlled
through engineering and/or administrative means. The primary objective of
these controls is to reduce worker exposure to safe levels, thereby
avoiding the need for PPE.
3.4.1. Engineering Controls
Hazards subject to engineering controls generally include those which
present a high potential for illness or injury to workers. These hazards
present levels of concern in the following areas:
* Frequency of hazard (i.e., how often such a hazard is likely
to occur at the work site);
* Effect of hazard (i.e., whether exposure to such a hazard
would result in an injury or illness);
* Extent of injury or illness resulting from the hazard; and
* Range of effect of the hazard.
Engineering controls, such as radiation shielding, are intended to address
major hazards and are the preferred control method. These controls consist
primarily of systems which are necessary to reduce worker exposure and
prevent propagation of contaminants to "clean" areas. Other examples of
engineered controls include process enclosures maintained at negative
pressure with High Efficiency Particulate Air (HEPA)-filtered ventilation
and surface water drainage systems.
Protection of the public though engineered controls should also take into
consideration the safety and health of workers. For example, when
designing or selecting systems for mitigating dispersal of contaminants to
outside areas, attention should also be given to effects on workers within
the contaminated zone. Area enclosures can concentrate airborne
contaminants if not properly ventilated.
3.4.2. Administrative Controls
The purpose of administrative controls is to encourage safe work practices.
This is first accomplished by controlling the movement of personnel within
hazardous areas. Establishment and demarkation of exclusion areas and
physical access controls will prevent workers from unnecessarily entering
hazardous areas. These controls should also include operating procedures
and training programs which address safety precautions to be followed by
workers when working in hazardous areas. Workers should be certified for
the particular equipment they are operating. It should be noted that some
standards prohibit the use of administrative controls as a means for
controlling a hazard.
3.4.3. Personal Protective Equipment (PPE)
PPE is a common method used in hazard control. Therefore, an entire
chapter has been devoted to this topic. Please refer to Chapter 5 for
further guidance on this subject.
3.5 - Hazard Assessment Documentation Format
The information obtained during the Hazard Assessment should be documented
in a manner that readily identifies: the hazards associated with the task,
and the controls required to safely carry out the task. Table 3-1 provides
a sample format for documenting the findings of a hazard assessment. In
the sample, the job has been broken down into the various tasks (e.g., set
up equipment, install ladder in tank) required to complete the job. Each
hazard associated with a given task has been identified, and the required
control measures are specified.
TABLE 3-1
Sample Hazard Assessment: Cleaning the Inside Surface of a
Chemical/Radioactive Contaminated Tank -- Top Manhole Entry
Step Hazard Controls
----------------------------------------------------------------------
1. Select and train Operator respiratory Examination by
operators. or heart problems; industrial physician
other physical for suitability to
limitation. work.
Untrained operator; Train operators.
failure to perform Dry run. (Reference:
task. National Institute for
Occupational Safety and
Health (NIOSH) Doc.
#80-406)
2. Empty Tank Gas or liquid in Approved written
tank. operating procedures.
Improper valve Empty tank through
line-up. existing piping.
3. Assess conditions: Explosive gas. Obtain work permit signed
determine what is by safety and maintenance
in the tank, what Improper oxygen supervisors.
process is going level.
on in the tank, Test air by qualified
and what hazards Chemical exposure. person.
these pose.
Gas, dust, vapor: Ventilate to 19.5% - 23.5%
irritant oxygen and less than 10%
toxic LEL of any flammable gas.
Steaming inside of tank,
Liquid: flushing and draining, then
irritant ventilating, as previously
toxic described, may be required.
corrosive
Provide appropriate
Solid: respiratory equipment -
irritant SCBA or air line respirator.
corrosive
Provide protective clothing
Radiological for head, eyes, body and
exposure, feet.
ingestion,
contact. Provide parachute harness
and lifeline. (Reference:
OSHA standards 1910.106,
NOTE: This column 1926.100, 1926.21(b)(6);
should contain NIOSH Doc. #80-406)
specific
information about Tanks should be cleaned
the material to be from outside if possible.
encountered, i.e.,
chemical/ Provide PPE as stated in
radioactive RADCON Manual.
material name,
quantity, ALARA
anticipated length
of exposure, etc.
4. Stage equipment. Slips/trips/falls. Provide ladders, harness,
railings. (OSHA CFR 1910)
Heavy equipment Trained equipment operators.
operations.
5. Set up equipment. Electrical hazards, Arrange hoses, cords, lines
motors not locked and equipment in orderly
out and tagged. fashion, with room to
maneuver safely.
Heavy equipment
operations. Use ground-fault circuit
interrupter.
Trip or fall.
Have lockout and tag
procedures.
Install blanks in flanges
in piping to tank.
(Isolate tank.)
Follow hoisting and
rigging requirements.
Use mechanical-handling
equipment.
Provide guardrails around
work positions at tank top.
Provide lighting for tank
(Class 1, Div. 1).
6. Prepare to enter Gas or liquid in Review emergency procedures.
tank. tank.
Training.
Open tank.
Contamination control.
Perform a check of job site
by industrial hygienist
or safety professional.
Test atmosphere in tank
by qualified person
(long probe).
7. Enter tank. Gas or liquid in Provide personal protective
tank. equipment for conditions
found. (Reference: RADCON
Explosive gas. Manual, NIOSH Doc. #80-406;
OSHA CFR 1910.134)
Improper oxygen
level. Provide outside helper to
watch, instruct and guide
Chemical exposure. operator entering tank,
with capability to lift
Gas, dust, vapor: operator from tank in
irritant emergency.
toxic
Liquid:
irritant
toxic
corrosive
Solid:
irritant
corrosive
Radiological
exposure, ingestion,
contact.
Exposure to
hazardous atmosphere.
Tripping hazard.
NOTE: This column
should contain
specific information
about the material to
be encountered (e.g.,
chemical/radioactive
material name,
quantity, anticipated
length of exposure).
8. Clean tank. Chemical/ Provide protective clothing
radiological and equipment for all
exposure internal operators and helpers.
and external.
Provide exhaust ventilation
Heat Stress. (contamination control).
Failure of life Provide air supply to
support. interior of tank.
Exhaustion. Continuous monitoring of
air in tank for
Reaction of radioactivity and oxygen
chemicals/ concentration.
radioactive
material, causing Replace operator or
mist or expulsion provide rest periods.
of air contaminant.
Provide means of
communication to get help,
if needed.
Provide two-man standby
for any emergency.
9. Cleanup/ Handling of Dry run.
Decontamination. equipment, causing
injury. Follow Decon procedures in
RADCON Manual.
Spread of
Contamination. Use material-handling
equipment.
3.6 - References
1. 29 CFR 1910, "Occupational Safety and Health Standards."
2. 29 CFR 1926, "Safety and Health Regulations for Construction."
3. "ACGIH Threshold Limit Values for Chemical Substances and Physical
Agents and Biological Exposure Indices," Latest Edition.
4. DOE Order 5480.1B, "Environment, Safety, and Health Program for
Department of Energy Operations."
5. DOE Order 5480.4, "Environmental Protection, Safety, and Health
Protection Standards."
6. DOE Order 5480.9, "Construction Safety and Health Program."
7. DOE Order 5481.1, "Environmental Protection, Safety, and Health
Protection Information Reporting Requirements."
8. "NIOSH/OSHA Pocket Guide to Chemical Hazards," NIOSH Publication
#90-117, 1985.
9. "OSHA Chemical Information Manual," ACGIH Publication #0881, 1988.
10. "Occupational Safety and Health Guidance Manual for Hazardous Waste
Site Activities," NIOSH/OSHA/USCG/EPA, October 1985 (Four-Agency
Document).
11. DOE Order 5480.19, "Conduct of Operations."
4.1 - Background
The Training Requirements portion of the HASP should cover OSHA training
regulations and training requirements in applicable DOE Orders for
personnel working, auditing, touring, and visiting DOE hazardous waste
sites under the cognizance of EM-40. Activities addressed under these
requirements include:
* Environmental Restoration (ER) activities regulated under RCRA
corrective action authority and/or CERCLA;
* Treatment, Storage, and Disposal (TSD) activities regulated
under RCRA; and
* Hazardous substance release response activities under Section 303
of the "Superfund Amendments and Reauthorization Act" (SARA) of 1986
("Emergency Planning and Community Right-to-Know Act of 1986," 42
U.S.C. 11003).
Applicable DOE Orders and OSHA regulations should be consulted to ensure
full compliance with all training requirements. However, in some cases,
training beyond the requirements of OSHA is required for certain EM-40
employees and contractor employees (see Appendix D).
The Training chapter has two main objectives. One is to provide the
minimum training requirements (in compliance with 29 CFR 1910.120, DOE
Orders, and applicable federal, state, and local codes and standards) for
personnel engaged in the activities listed above. The second is to
recommend personnel not to participate in field activities until
appropriately trained.
4.2 - General
DOE Order 5480.4 Environmental Protection, Safety, and Health Protection
Standards, and 5483.1A Occupational Safety and Health Program for DOE
Contractor Employees at Government-Owned Contractor-Operated Facilities,
require both DOE employees and contractors at DOE-owned contractor-operated
facilities to comply with OSHA standards established in 29 CFR 1910.120.
The 29 CFR 1910.120 standards provide regulations to ensure the safety of
employees involved in hazardous waste operations. Subsections (e) and (p)
of 29 CFR 1910.120 specify training requirements for all employees who may
be exposed to safety or health hazards at ER sites and RCRA TSD sites
respectively. Subsection (q) specifies training requirements for employees
who participate in emergency responses to hazardous substance releases.
This chapter provides the specific training required for EM-40 employees
and contractor employees involved in these types of operations.
EM-40 has adopted, and in some cases exceeded, OSHA training standards for
its employees and contractor employees. All general employees working at
ER sites, RCRA TSD sites, and those responding to hazardous substance
releases should receive a minimum of 40 hours of initial safety and health
training and further should receive a minimum of three days (24 hours) of
appropriately-supervised field (hands-on) experience. EM-40 employees and
contractors at the Headquarters, Field Program, Project Manager, and
Supervisor levels are also required to have 40 hours of training. Site
supervisors and managers involved in or associated with site-related
activities are required to have the same training and certifications as
hazardous waste workers. In addition, site management personnel are
required to have 8 hours of supervisory training. Training requirements
for Visitors/Non-Workers who may require access to ER sites and RCRA TSD
sites are also addressed in this chapter and in Appendix C.
OSHA does not currently certify or accredit training programs. However, a
January 26, 1990, Notice of Proposed Rulemaking addresses accreditation of
29 CFR 1910.120 training programs for employees covered by 29 CFR 1910.120.
It does not address accreditation of training programs for employees
engaged in emergency response activities. Until this proposed regulation
becomes a final rule, employers should assess the adequacy of training
programs based on training criteria addressed in 29 CFR 1910.120(e)(2).
Training documentation should be maintained in accordance with DOE Order
5480.20 and DOE Order 1324.2A and applicable OSHA Standards.
4.3 - Training Requirements for Personnel at ER Sites
Training requirements for DOE employees and contractor employees are
summarized in Table 4-1. Personnel should be prohibited from participating
in field activities until appropriately trained.
The terms "installation," "facility," and "site" are defined in the
Glossary, (Appendix A), and graphically depicted in Figure 4-1. Some
facilities may contain a number of individual sites which, in turn, can be
linked through a facility-wide integrator site.
FIGURE 4-1
EM-40 Definitions and Graphic Depictions of Installation, Facility, and Site
---------------------------------------------------------------------
| |
| DOE Installation |
| |
| ---------------------------------------------------- |
| | | |
| | EM-40 Facility | |
| | | |
| | ---------- | |
| | | | | |
| | | Site | | |
| | | | | |
| | | | ---------- | |
| | ---------- | | | |
| | | Site | | |
| | | | | |
| | | | | |
| | ---------- | |
| | | |
| | | |
| ---------------------------------------------------- |
| |
---------------------------------------------------------------------
Installation: Any DOE Property (i.e., "inside the fence.")
EM-40 Facility: Any DOE installation or portion of an installation
operated, funded or otherwise controlled by EM-40.
Site: An area where physical work is being performed, including TSD
operations, where the potential of exposure to contaminants
exists, which requires the use of chemical protective clothing
and/or radiological protective clothing and/or respirators.
TABLE 4-1
Minimum Training Requirements for Personnel Engaged at EM-40 Sites
* - Training Required
Minimum Training Requirement
-----------------------------------------------------------------
|40 Hrs.|8 Hrs.|Site |8 Hrs.|Emergency|Hazard|Radio- |Lead
|Initial|Super-|Speci-|Annual|Response |Comm- |logical|and
|Safety |visor |fic |Refre-|and |unica-|Worker |Asbestos
|and | | |sher |Periodic |tion |(if |Abatement
|Health | | | |Rehersal | |appli- |(if
|and 24 | | | | | |cable) |applicable)
|hrs. | | | | | | |
|Super- | | | | | | |
|vised | | | | | | |
|Field | | | | | | |
|Exper- | | | | | | |
Operational |ience | | | | | | |
Personnel | | | | | | | |
------------------------------------------------------------------------------
EM-40 *(2) *(4) * * * * * *
Employees
EM-40 *(2) * * * * * * *
Contractor or
Subcontractor
Project
Manager (PM)
EM-40 *(2) * * * * * * *
Contractor or
Subcontractor
Field
Super-
visor (FS)
EM-40 *(2) * * * * * * *
Contractor or
Subcontractor
Site Safety
and Health
Officer (SSHO)
EM-40 *(2) *(4) * * * * * *
Contractor or
Subcontractor
Industrial
Hygienist (IH)
EM-40 *(2) *(4) * * * * * *
Contractor or
Subcontractor
Health
Physicist (HP)
EM-40 *(2) *(4) * * * * * *
Contractor or
Subcontractor
Post Super-
visor
EM-40 *(2) * * * * * * *
Contractor or
Subcontractor
Site Emergency
Responce
Coordinator
EM-40 *(2) *(4) * * * * * *
Contractor or
Subcontractor
Site Contami-
nation Station
Officer
EM-40 *(2) *(4) * * * * * *
Contractor or
Subcontractor
Site Security
Officer
EM-40 *(1,2) *(4) * * * * * *
Contractor or
Subcontractor
Optional
Personnel
Onsite/Offsite
As Needed
EM-40 *(2) *(4) * * * * * *
Contractor or
Subcontractor
General Site
Workers
EM-40 *(3) * * * * *
Visitors/Non-
Workers Who
Enter the
Site
Notes:
1. Optional personnel may include Scientific Advisor, Logistics Officer,
etc. (See section 2.4).
2. This training is required for all EM-40 employees and EM-40
contractors, regardless of length of stay on site or site exposure
levels. (See Appendix D.)
3. This training is required for all visitors/non-workers who enter an
exclusion/decontamination zone or other areas where Level A, B, or C
PPE is required. This training is not required for
visitors/non-workers who only enter areas where either Level D or no
PPE is required. (See Appendix D.)
4. The supervisor training is required for these individuals only if
they act in a supervisory capacity or are the designated alternate
for a supervisory position.
4.4 - Training Requirements for Personnel at RCRA TSD Sites
4.4. TRAINING REQUIREMENTS FOR PERSONNEL AT RCRA TSD SITES
The training requirements for personnel at RCRA TSD sites are summarized in
Table 4-2. Personnel should be prohibited from participating in RCRA TSD
sites activities until appropriate training has been received.
TABLE 4-2
Minimum Training Requirements For Personnel Engaged at RCRA TSD Sites
* - Training Required
Minimum Training Requirement
------------------------------------------------------
|40 Hrs.|8 Hrs.|Faci- |8 Hrs.|Emergency|Hazard|Radio-
|Initial|Super-|lity |Annual|Response |Comm- |logical
|Safety |visor |Speci-|Refre-|and |unica-|Worker
|and | |fic |sher |Periodic |tion |(if
|Health | | | |Rehersal | |appli-
|and 24 | | | | | |cable)
|hrs. | | | | | |
|Super- | | | | | |
|vised | | | | | |
|Field | | | | | |
|Exper- | | | | | |
Operational |ience | | | | | |
Personnel | | | | | | |
-------------------------------------------------------------------
EM-40 On-site *(1) *(3) * * * * *
Employees
EM-40 *(1) * * * * * *
Contractor or
Subcontractor
TSD Manager
EM-40 *(1) * * * * * *
Contractor or
Subcontractor
TSD Safety
and Health
Officer
EM-40 *(1) * * * * * *
Contractor or
Subcontractor
TSD
Designated
Emergency
Response
Person
EM-40 *(1) * * * * * *
Contractor or
Subcontractor
TSD Command
Post Super-
visor or TSD
Emergency
Coordinator
EM-40 *(1) *(3) * * * * *
Contractor or
Subcontractor
TSD Operators
EM-40 *(2) * * *
Visitors/
Non-workers
who enter the
TSD
Notes:
1. This training is required for all EM-40 employees and EM-40
contractors. (See Appendix D.)
2. This training is required for all visitors/non-workers who enter the
TSD site where Level A, B, or C PPE is required. This training is
not required for visitors/non-workers who only enter the TSD site
where either Level D or no PPE is required. (See Appendix D.)
3. The supervisor training is required for these individuals only if
they act in a supervisory capacity or are the designated alternate
for a supervisory position.
4.5 - Training Requirements for Personnel in Emergency Responses to Hazardous Substance Releases
Table 4-3 summarizes the minimum training requirements for personnel
conducting emergency responses to hazardous substance releases.
TABLE 4-3
Minimum Training Requirements for Personnel Engaged
in EM-40 Emergency Responses to Hazardous Substance Releases
* - Training Required
Minimum Training Requirement
---------------------------------------------
|40 Hrs.|Annual|Radio- |Emergency |24 hour
|Initial|Refre-|logical|Responder |HAZWOPER
|Safety |sher |Worker |Training |Training
|and | |(if |as required|
|Health | |appli- |by |
|and 24 | |cable) |1910.120(q)|
|hrs. | | | |
|Super- | | | |
|vised | | | |
|Field | | | |
|Exper- | | | |
Operational |ience | | | |
Personnel | | | | |
----------------------------------------------------------
EM-40 * *(2)
Contractor or
Subcontractor
First
Responder at
the Awareness
Level
EM-40 *(1) * * *
Contractor or
Subcontractor
First
Responder at
the Operation
Level
EM-40 *(1) * * *
Contractor or
Subcontractor
Hazardous
Materials
Technician
EM-40 *(1) * * *
Contractor or
Subcontractor
Hazardous
Materials
Specialist
EM-40 *(1) * * *
Contractor or
Subcontractor
On-Scene
Incident
Commander
4.6 - References
1. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response"
(HAZWOPER).
2. 29 CFR 1910.1200, "Hazard Communication."
3. 40 CFR 264.16, "Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities - Personnel Training."
4. 40 CFR 265.16, "Interim Status Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities - Personnel
Training."
5. 40 CFR 300.150, "National Oil and Hazardous Substances Pollution
Contingency Plan - Worker Health and Safety."
6. 55 FR 2776, Notice of Proposed Rulemaking, "Accreditation of Training
Programs for Hazardous Waste Operations" (29 CFR 1910.121), January 26,
1990.
7. DOE Order 3790.1B, "Federal Employees Occupational Safety and Health
Program."
8. DOE Order 5000.3B, "Occurrence Reporting and Processing of Operations
Information."
9. DOE Order 1324.2A, "Records Disposition."
10. DOE Order 5480.4, "Environmental Protection Safety, and Health
Protection Standards."
11. DOE 5480.20, "Personnel Selection, Qualifications, Training, and
Staffing Requirements at DOE Reactor and Non-Reactor Nuclear Facilities,"
February 20, 1991.
12. DOE Order 5480.11, "Radiation Protection for Occupational Workers."
13. DOE Order 5483.1A, "Occupational Safety and Health Program for DOE
Contractor Employees at Government-Owned Contractor-Operated Facilities."
14. DOE EH-0227P, "OSHA Training Requirements for Hazardous Waste
Operations," Office of Environmental, Safety and Health, USDOE, 1991.
15. DOE EH-0256T, USDOE "Radiological Control Manual", Office of
Environmental, Safety and Health, USDOE, 1992.
16. DOE Memorandum from EH-40 to Under Secretary dated January 5, 1993,
"Implementation of Section 3131 of the National Defense Authorization Act
for Fiscal Years 1992 and 1993," Public Law 102-190, (discusses the NIEHS
hazardous materials training program).
17. DOE Memorandum from EM-40 to distribution dated February 3, 1994,
"Hazardous Materials Training Program."
18. DOE Memorandum from EM-40 to EM-42, EM-43, EM-44, and EM-45 dated June
10, 1993, "Hazardous Materials Training Program."
19. DOE Memorandum from EM-40 to Distribution dated August 30, 1993,
"Hazardous Materials Training Program."
20. EPA/540/G-89/010, "Health and Safety Audit Guidelines," SARA Title I,
Section 126, Office of Emergency and Remedial Response, USEPA, 1989.
21. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,"
Office of Emergency and Remedial Response, USEPA, 1992.
22. NIEHS Memorandum addressing DOE adoption of OSHA standards for training
EM-40 employees and EM-40 contractor employees and supervisors, NIEHS,
Research Triangle Park, NC, February 12, 1993.
23. Department of Health and Human Services (DHHS) (NIOSH) Publication
No. 85-115, "Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities," NIOSH/OSHA/USCG/EPA, 1985 (Four-Agency Document).
24. OSHA 2254 (Revised), "Training Requirements in OSHA Standards and
Training Guidelines," OSHA, 1992.
25. "Superfund Amendments and Reauthorization Act of 1986 (SARA)," Section
126, (Pub.L. 99-499).
5.1 - Background
The purpose of personal protective clothing and equipment (PPE) is to
shield or isolate individuals from the chemical, physical, radiological,
and biological hazards that may be encountered at a hazardous waste site
when engineering and other controls are not feasible or cannot provide
adequate protection. Careful selection and use of adequate PPE should
protect the health of EM-40 employees.
No single combination of PPE is capable of protecting against all hazards.
Therefore, PPE should be used in conjunction with, not in place of, other
protective methods, such as engineering controls and safe work practices.
A written PPE program, as required by 29 CFR 1910.120(g)(5) should be in
place at all EM-40 hazardous waste sites. The effectiveness of the PPE
program should be evaluated regularly. The use of PPE can itself create
significant worker hazards, such as heat stress, physical and psychological
stress, impaired vision, reduced mobility, and distorted communication. In
general, the higher the level of PPE protection, the greater are the risks
associated with use of PPE. For any given situation, PPE should be
selected to provide an adequate level of protection. Over-protection as
well as under-protection can be hazardous and should be avoided.
The overall objectives of this chapter are:
* To describe the PPE program that will provide EM-40 hazardous
waste site workers with protection from chemical, physical,
biological and radiological hazards;
* To comply with applicable DOE and regulatory requirements; and
* To establish the selection, use, upgrade/downgrade, and training
requirements for the PPE program.
5.2 - General Provisions
Personal protective equipment should be utilized when:
* It is not possible and/or feasible to implement engineering
controls and work practices that will ensure the safety and
health of workers;
* It is necessary to reduce and maintain employee exposure to below
the permissible exposure limits (PELs) in 29 CFR 1910, Subparts G
and Z, and/or below the threshold limit values (TLVs) established
by the American Conference of Governmental Industrial Hygienists
(ACGIH); or in the absence of PELs or TLVs, below the recommended
exposure limits published in the National Institute for
Occupational Safety and Health (NIOSH) publication, NIOSH
Recommendations for Occupational Health Standards dated 1992;
* Handling radiological materials with removable contamination in
excess of levels established in the DOE Radiological Control
Manual, or manuals implementing these requirements, or when
working in radiologically controlled areas in which PPE
requirements have been established; or
* Existing or potential physical and/or biological hazards pose a
threat to worker safety and health.
Required PPE should be discussed with site workers prior to the start of
work. Employees should be trained and have passed a baseline medical
examination for the use of prescribed PPE. The HASP should implement a
written PPE program containing operating procedures that comply with the
applicable requirements of 29 CFR 1910.120, DOE 5480.4, and the DOE
Radiological Control Manual. If such a written PPE program consistent with
those requirements is not already in place, written procedures and
requirements for the use of PPE should be included in the HASP.
5.3 - Selection of Personal Protective Equipment
Selection of PPE, based on requirements of 29 CFR 1910 and applicable DOE
Orders, is key to protecting the safety and health of site personnel. This
should be done by qualified and knowledgeable professionals to insure that
selected PPE protects workers from site-specific hazards posed by their
task and work zone.
The use, maintenance and disposal of radiological PPE is governed by the
DOE Radiological Control Manual.
Selection of the most appropriate level of protection and combinations of
respiratory protection and protective clothing will depend on:
* Level of knowledge of onsite chemical and radiological hazards;
* Properties such as toxicity, radioactivity, route of exposure,
and matrix of the contaminants known or suspected of being
present;
* Type and measured concentrations of the contaminants that are
known or suspected of being present;
* Potential for exposure to contaminants in air, liquids, soils,
or by direct contact with hazardous materials;
* Physical hazards;
* Climatic conditions; and
* Biological hazards.
Based on the evaluation of potential hazards that will vary with individual
field activities, PPE should be selected for specific tasks and work areas
(e.g., Exclusion Zone, Contamination Reduction Zone). The specific PPE
required for each work area and/or task should be determined and listed by a
qualified (preferably certified) industrial hygienist in consultation with a
qualified (preferably certified) health physicist.
The industrial hygienist, in coordination with the health physicist, should
provide a listing of the chemicals/radioactive materials and corresponding
types and/or characteristics of protective clothing (e.g., material or brand
name). This list should be referred to when hazardous materials may be
encountered to determine appropriate chemical/radiological resistant PPE. The
industrial hygienist should specify the type of cartridges to be used and the
frequency with which the cartridges should be changed, along with information
on any limitations or restrictions for use, when air-purifying respirators are
determined to be appropriate.
Personal protective equipment is divided into two broad categories;
respiratory protective equipment and personal protective clothing. Both of
these categories are incorporated into the four levels of protection (Levels
A, B, C, and D), based on the potential severity of the hazard. The following
sections provide detail and explanation of those categories. Modifications to
these levels should be made under the direction of the Site Safety and Health
Officer (SSHO) in consultation with a qualified industrial hygienist and/or
health physicist. Such modifications are routinely employed during site work
activity to maximize efficiency and to meet site-specific needs without
compromising worker safety and health. The SSHO and Project Manager should
make the final determination on the appropriate level of PPE.
Respiratory protective gear and protective clothing should compliment one
another. Section 5.5.1. provides guidelines for determining appropriate PPE.
5.4 - Levels of PPE
The specific levels of PPE and necessary components for each level have been
divided into four categories according to the degree of protection
afforded. General guidelines for use are:
Level A: Worn when the highest level of respiratory, skin, and eye
protection is needed.
Level B: Worn when the highest level of respiratory protection is
needed, but a lesser level of skin protection is needed.
Level C: Worn when the criteria for using air-purifying respirators
are met, and a lesser level of skin protection is needed.
Level D: Refers to work conducted without respiratory protection.
This level should be used only when the atmosphere contains
no known or suspected airborne chemical or radiological
contaminants and oxygen concentrations are between 19.5%
and 23%.
The following section describes the elements of the basic levels of protective
equipment.
5.4.1. Level A PPE
5.4.1.1. Respiratory Protection
Level A respiratory protection is positive pressure, full face-piece
self-contained breathing apparatus (SCBA), or positive pressure supplied air
respirator (with escape bottle for immediately dangerous to life or health
(IDLH) or potential IDLH atmosphere).
5.4.1.2. Protective Clothing
Protective clothing provides maximum skin protection. It is used when the
potential exists for splash or immersion by chemicals and/or radiologically
contaminated liquids, or for exposure to vapors, fumes, gases, or particulates
that are harmful to skin or capable of being absorbed through the skin. This
class of protection is acceptable for radiological work activities categorized
as "High" involving pressurized or large volume liquids, or closed system
breach (see DOE Radiological Control Manual). Level A protective clothing
includes:
* Totally encapsulating non-permeable, chemical-resistant suit;
* Coveralls inner suit;
* Modest clothing under coveralls (e.g., shorts and T-shirt/long
underwear);
* Disposable gloves and boot covers (worn over fully encapsulating
suit);
* Boots, chemical-resistant, steel toe and shank (depending on suit
construction, worn over or under suit boot);
* Hard hat (under suit); and
* Hearing protection (as needed).
5.4.1.3. Other Protective Apparatus
Other protective apparatus which may be used includes:
* Cooling unit/system,
* 2-way radio communications,
* Cold weather gear/clothing, and
* Protection from biological hazards/pests.
5.4.2. Level B PPE
5.4.2.1. Respiratory Protection
Level B respiratory protection is positive pressure, full face-piece
self-contained breathing apparatus (SCBA), or a positive pressure supplied air
respirator (with escape bottle for immediately dangerous to life or health
(IDLH) or potential IDLH atmosphere).
5.4.2.2. Protective Clothing
Level B protective clothing provides a high level of skin protection. It is
used when the potential exists for contact with chemicals and/or
radiologically contaminated liquids that could saturate/penetrate cloth
coveralls (e.g., immersion or inundation of contaminants). Also, potential
vapors, fumes, gases, or dusts containing levels of chemicals harmful to skin
or capable of being absorbed through the skin are not anticipated. This class
of protection is acceptable for radiological work activities categorized as
"High" involving pressurized or large volume liquids, or closed system breach
(see DOE Radiological Control Manual). Level B protective clothing includes:
* Hooded one-piece non-permeable, chemical resistant outer suit;
* Coveralls inner suit(s);
* Modest clothing under coveralls (e.g., shorts and T-shirt/long
underwear);
* Outer chemical resistant work gloves (rated for contaminants)
taped to outer suit;
* Inner gloves of light weight PVC or latex rubber taped to inner
suit (cotton liners optional);
* Chemical resistant steel-toe boots taped to inner suit;
* Disposable outer boot covers (booties) taped to outer suit;
* Hard hat (as needed); and
* Hearing protection (as needed).
5.4.2.3. Other Protective Apparatus
Other protective apparatus which may be used includes:
* Cooling unit/system,
* Cold weather gear/clothing, and
* Protection from biological hazards/pests.
5.4.3. Level C PPE
5.4.3.1. Respiratory Protection
Level C respiratory protection includes an air-purifying respirator, full-face
or half-mask, cartridge- or canister-equipped (MSHA/NIOSH approved).
5.4.3.2. Protective Clothing
Level C protective clothing provides a moderate level of skin protection. It
is used when the potential exists for contact with chemicals and/or
radiologically contaminated materials, but when protection from liquids
(chemical and/or radioactive) is not required. It is used when potential
vapors, fumes, gases, or dusts are not suspected of containing levels of
chemicals harmful to skin or capable of being absorbed through the skin. This
class of protective clothing is appropriate for most routine radiological work
activities (see DOE Radiological Control Manual). Level C protective clothing
includes:
* Coveralls (Radiological Control Manual),
* Modest clothing under coveralls (e.g., shorts and T-shirt/long
underwear),
* Rubber/chemical resistant outer gloves rated for contaminant,
* Inner gloves of light weight PVC or latex rubber,
* Safety glasses or safety goggles (not required with full face
respirator),
* Face-shield if splash hazard exists (not required with full face
respirator),
* Steel-toe rubber boots,
* Outer disposable booties,
* Hood may be required for radiological work. (See DOE Radiological
Control Manual),
* Hard hat (as needed), and
* Hearing protection (as needed).
5.4.3.3. Other Protective Apparatus
Other Level C protective apparatus which may be used includes:
* Cooling unit/system,
* Cold weather gear/clothing, and
* Protection from biological hazards/pests.
5.4.4. Level D PPE
5.4.4.1. Respiratory Protection
There is no Level D PPE required for respiratory protection due to the nature
of the hazard.
5.4.4.2. Protective Clothing
Level D protective clothing provides a low level of skin protection. It is
used when there is no potential for contact with hazardous levels of chemicals
or radiological contamination. This level should not be worn in the Exclusion
Zone or the Contamination Reduction Zone. Oversight personnel not in zoned
areas, as well as site visitors, may be required to wear Level D modified PPE.
Level D protective clothing includes:
* Coveralls,
* Modest clothing under coveralls,
* Work gloves where appropriate,
* PVC or latex rubber surgical/light weight gloves when sampling or
handling any potentially contaminated surface or item,
* Safety glasses or safety goggles,
* Steel-toe rubber boots where wet decontamination methods are
required or steel-toe leather boots and outer boot covers, and
* Hard hat.
5.4.4.3. Other Protective Apparatus
Other Level D protective apparatus which may be used include:
* Cold weather gear/clothing,
* Protection from biological-hazards/pests, and
* Hearing protection.
5.5 - Use of PPE
Written site operating procedures for the use of PPE should include:
* Training;
* Establishing work mission duration;
* Personal use factors;
* Fit testing;
* Donning and doffing;
* In-use monitoring of personnel/equipment;
* Inspection before, during, and after use;
* Storage and maintenance;
* Upgrading/downgrading of PPE; and
* Decontamination and disposal.
These procedures should be referenced and/or included in the HASP.
No changes to the specified levels of protection should be made without the
approval of the SSHO and the Project Manager. A list of approval steps for
upgrade/downgrade of PPE should be included that specifically include the SSHO
and Project Manager as key to the approval process.
5.5.1. PPE Selection Process
Sequential steps to facilitate the selection of PPE for hazardous waste site ope
rations are:
1. Identify work area and job-specific hazard potential (e.g. chemical,
radiological, physical, mechanical),
2. Determine type of exposure for the work areas and specific work activities,
3. Determine level of respiratory protection for the work areas and specific
work activities (see Section 5.4),
3a. Select the respirator cartridge(s) for Level C,
4. Determine level of protective clothing for the work areas and specific work
activities (see Section 5.4),
4a. Evaluate the chemical resistant characteristics needed for the potential
exposures and select clothing with the appropriate protection factor,
5. Evaluate potential physical hazards associated with the work areas and
specific work activities (e.g., walking/working surfaces, electrical
installations/lines, noise exposure) and select PPE to mitigate identified
hazards,
6. Consider climatic conditions and select PPE to accommodate the conditions
(e.g., cooling units, insulated clothing/footwear),
7. Evaluate potential biological hazards (e.g., snakes, insects) and select
PPE to mitigate identified hazards, and
8. Evaluate type and level of work (e.g. heavy, moderate, light) and select
PPE for the work,
9. Evaluate PPE for both chemical and radiological hazards when mixed waste
is involved.
Table 5-1 presents the level of protection required for respiratory PPE, based
on specific hazards. Table 5-2 presents the level of PPE based on specific
hazards for selection of protective clothing.
TABLE 5-1
Respiratory PPE Selection
Hazard Level of Protection
---------------------------------------------------------------------------
Immediately Dangerous to Life or Health. A, B
Gaseous and/or Particulate. Radioactive
and/or Chemical.
Not Immediately Dangerous to Life or Health. C
Particulate. Radioactive and/or Chemical. High efficiency
respirator cartridge.
Not Immediately Dangerous to Life or Health. C
Gases or Vapors. Radioactive and/or Chemical. Respirator cartridge rated
for isotope or chemical
concentration.
Not Immediately Dangerous to Life or Health. C
Gaseous and/or particulate. Radioactive Combination chemical and
and/or Chemical. high efficiency respirator
cartridge.
TABLE 5-2
Clothing PPE Selection
Hazard Level of Protection
---------------------------------------------------------------------------
Potential for skin contact with substances A
with a high degree of hazard to the
skin. High potential for splash,
immersion, or exposure to unexpected
vapors, gases, fumes or dusts that are
harmful to, or readily absorbed by the
skin. High levels of radiological contamination.*
Potential for contact with wet, contaminated B
surfaces/material that can saturate
cloth. Vapors or gases do not contain a high
level of chemicals harmful to, or readily
absorbed by, the skin. Moderate levels
radiological contamination.*
Atmospheric contaminants, liquid splashes or C
other direct contact will not adversely
affect, or be absorbed by exposed skin. Low
levels of radiological contamination.*
No anticipated immersion, splashes, or D
potential for unexpected contact with
hazardous levels of any chemicals or
radiological contamination.
* Protective clothing for high, moderate and low radiological
contamination roughly corresponds to Levels A, B, C, and D PPE.
However, this may be modified by level of activity and isotope. The
appropriate selection should be made using the DOE Radiological Control
Manual.
5.6 - References
1. 29 CFR 1910, Subpart G, "Occupational Health and Environmental Control."
2. 29 CFR 1910, Subpart Z, "Toxic and Hazardous Substances."
3. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
4. 29 CFR 1910.132, "Eye and Face Protection."
5. 29 CFR 1910.134, "Respiratory Protection."
6. 29 CFR 1910.135, "Occupational Head Protection."
7. 29 CFR 1910.136, "Occupational Foot Protection."
8. 29 CFR 1910.137, "Electrical Protective Devices."
9. American Conference of Governmental Industrial Hygienist (ACGIH),
"Threshold Limit Values for Chemical and Physical Agents and Biological
Indices," Current edition.
10. American National Standards Institute (ANSI) Z 41.1, "Safety Toe
Footwear," Current edition.
11. ANSI Z 87.1, "Eye and Face Protection," Current edition.
12. ANSI Z 88.2, "Standard Practices for Respiratory Protection," Current
edition.
13. ANSI Z 88.6, "Physical Qualifications for Respirator Use," Current
edition.
14. ANSI Z 89.1, "Safety Requirements for Industrial Head Protection,"
Current edition.
15. National Institute for Occupational Safety and Health (NIOSH),
"Recommendations for Occupational Health Standards," 1986.
16. DOE "Radiological Control Manual."
6.1 - Background
The primary objective of this section on Temperature Extreme Disorders or
Conditions is to provide the guidance necessary for protection of
contractors/employees from the occurrence of temperature extreme related
disorders or conditions. Other objectives are to:
* Provide a description of the overall temperature extreme related
disorders or conditions program,
* Integrate the program with other elements of the HASP, and
* Provide guidance on the proper training levels necessary for
operational workers and supervisors.
The added burden of PPE required for hazardous waste operations in a
temperature extreme condition increases the potential for worker disorders
or conditions that can result in injury or illness. Disorders or
conditions associated with work conducted in temperature extreme conditions
can be controlled through proper planning and effective monitoring of
personnel. Factors that could affect a worker's ability to function in
extreme temperatures include, but are not limited to:
* Physical fitness,
* Acclimatization,
* Age,
* Obesity,
* Alcohol consumption,
* Drug use,
* Infections, and
* Disease.
An effective temperature extreme program is a requirement and should be
integrated with other elements of the HASP. Pre-existing health conditions
of workers, for example, can be identified in the medical surveillance
program (see Chapter 7). It is necessary to be aware of the potential
occurrence of heat or cold related disorders or conditions in confined
space entry or emergency response operations.
A temperature extreme disorders prevention program should be developed and
included in the site-specific HASP. The following elements should be
addressed in the program:
* Identification of potential hazards early in the planning phase
of the development and operation of required contingency plans,
* Proper monitoring of worker physiology,
* Implementation of preventive measures and Standard Operating
Procedures (SOPs) early in the operations so that sound work
practices are developed and followed,
* Proper initial training of workers to recognize the symptoms of
temperature extreme related disorders or conditions in themselves
and their fellow workers,
* Implementation of a "buddy system", and
* Proper acclimatization of all workers to new or changing work
conditions.
6.2 - Heat Stress
Increased physical demands on workers occur as a result of increased air
temperature and humidity. Wearing PPE also increases the demands on
workers, due to:
* Added weight of the equipment,
* Reduced visibility,
* Reduced mobility,
* Loss of the body's natural cooling processes,
* Increased energy consumption by the body, and
* Lack of sufficient fluid replenishment.
Other factors that influence the occurrence of heat related disorders or
conditions include environmental conditions, clothing, workload, and the
individual characteristics of workers. Workers should be pre-screened
prior to beginning operations. Once baseline values are obtained, they can
be used to effectively assess the health of workers during and immediately
after operations (e.g., pulse, blood pressure, body temperature, body
weight).
Because of the variability of these factors and the compounding effect that
each may have on an individual's health, a physiological monitoring program
should be established.
6.2.1. Monitoring
Personnel who are not required to wear PPE are not immune to the potential
hazards of heat related disorders or conditions and should be included in
the monitoring program.
The guidance for workers wearing permeable clothing is specified in the
current version of the American Conference of Governmental Industrial
Hygienists' (ACGIH) Threshold Limit Values for Heat Stress. If actual
clothing differs from the ACGIH standard ensemble in insulation value
and/or wind and vapor permeability, changes should be made to the
monitoring requirements and work rest period to account for these
differences. Table 6-1 provides the suggested frequency of physiological
monitoring for fit and acclimatized workers.
The ACGIH TLV guide contains a separate table for workers wearing
semipermeable and impermeable encapsulating clothing. In these situations,
refer to this table.
TABLE 6-1
Suggested Frequency of Physiological Monitoring
for Fit and Acclimatized Workers
Adjusted Temperature Normal Work Clothing Impermeable Clothing
Calculation
----------------------------------------------------------------------
90 F (32.2 C) or After each 45 minutes After each 15 minutes
above of work of work
87.5 - 90.0 F After each 60 minutes After each 30 minutes
(30.8 - 32.2 C) of work of work
82.5 - 87.5 F After each 90 minutes After each 60 minutes
(28.1 - 30.8 C) of work of work
77.5 - 82.5 F After each 120 minutes After each 90 minutes
(25.3 - 28.1 C) of work of work
72.5 - 77.5 F After each 150 minutes After each 120 minutes
(22.5 - 25.3 C) of work of work
The following parameters should be used when monitoring workers:
* Heart rate - Count the radial pulse as early as possible in the
rest period to ensure a more accurate reading. If the heart rate
exceeds 110 beats per minute at the beginning of the rest period,
shorten the next work cycle by one-third and keep the rest period
at the same length. If, at the end of the following work period,
the heart rate still exceeds 110 beats per minute, shorten the
work period again by one-third.
* Oral Temperature - The utilization of oral temperature applies to
the time immediately after the worker leaves the contamination
reduction zone. Using a clinical thermometer, take the
temperature for three minutes. If the oral temperature exceeds
99.6 F (37.6 C), shorten the next work cycle by one-third,
without a change to the rest period. If the oral temperature
still exceeds 99.6 F (37.6 C) at the end of the following work
period, shorten the next work cycle by one-third. Do not permit
a worker to perform duties requiring a semipermeable or
impermeable garment if the oral temperature exceeds 100.6 F (38.1
C).
* Ear Canal Readings - Ear canal readings are a valid method to
monitor the temperature of workers who remain in the
contamination reduction zone.
* Body Water Loss - Measure body weight to see if enough fluids are
being consumed to prevent dehydration.
6.2.2. Training
Worker training is an essential element of an effective temperature extreme
program. Workers who are able to identify the symptoms of early heat
stress will be able to prevent heat related disorders or conditions and
possible death to themselves and their fellow workers. Workers should be
trained to identify the following symptoms:
* Heat Rash - Caused by continuous exposure to heat or humid air.
Can be recognized by the occurrence of small red pimples on the
skin. Typically found in sensitive areas of the body where the
potential for rubbing can occur (e.g., underarm, groin area).
* Heat Cramps - Caused by heavy sweating and inadequate electrolyte
replacement. Signs to look for include muscle spasms and pain in
the extremities, such as hands and feet, and in the abdomen.
* Heat Exhaustion - Caused by increased stress on various parts of
the body, including inadequate blood circulation due to
cardiovascular insufficiency or dehydration. Signs to look for
include:
* Pale, cool, moist skin;
* Heavy sweating;
* Dizziness;
* Nausea; and
* Fainting.
* Heat Stroke - This is the most serious of all temperature related
disorders or conditions since temperature regulation fails and
the body temperature rises to critical levels. Immediate action
should be taken to cool the body before serious injury or death
occurs. Competent medical help should be obtained. Signs to
look for include:
* Red, hot, usually dry skin;
* Lack of or reduced perspiration;
* Nausea;
* Dizziness and confusion; and
* In extreme situations, coma.
6.3 - Cold Exposure
Exposure to cold temperatures increases the likelihood and potential for
worker disorders or conditions that could result in injury or illness.
Extreme low temperatures may not be the only element necessary to create
the potential for cold exposure disorders or conditions; strong wind
accompanied by cold temperatures can lead to these types of disorders or
conditions.
The windchill factor is the cooling effect of any combination of
temperature and wind velocity or air movement. The windchill index (Table
6-2) should be consulted when planning for exposure to low temperatures
and wind. The windchill index does not take into account the specific
part of the body exposed to cold, the level of activity which affects body
heat production, or the amount of clothing being worn.
TABLE 6-2
Windchill Index
ACTUAL THERMOMETER READING (F)
Wind Speed
in mph 50 40 30 20 10 0 -10 -20 -30 -40
------------------------------------------------------------------------
EQUIVALENT TEMPERATURE (F)
-------------------------------------------------------------
calm 50 40 30 20 10 0 -10 -20 | -30 -40
|------|
5 48 37 27 16 6 -5 -15 | -26 -36 -47
|------|
10 40 28 16 4 -9 -21 | -33 -46 -58 -70
|-----| |-----
15 36 22 9 -5 -18 | -36 -45 -58 -72 | -85
|-----| |------|
20 32 18 4 -10 | -25 -39 -53 -67 | -82 -96
| |------|
25 30 16 0 -15 | -29 -44 -59 | -74 -88 -104
| |
30 28 13 -2 -18 | -33 -48 -63 | -79 -94 -109
| |
35 27 11 -4 -20 | -35 -49 -67 | -82 -98 -113
| |
40 26 10 -6 -21 | -37 -53 -69 | -85 -100 -116
---------------------------------------------------------------------
Over 40 | LITTLE | INCREASING | GREAT
(little | DANGER | DANGER | DANGER
added | (for properly clothed | |
effect) | person) | (Danger from freezing of exposed flesh)
---------------------------------------------------------------------
The human body senses "cold" as a result of both the air temperature and
the wind velocity. Cooling of exposed flesh increases rapidly as the wind
velocity goes up. Frostbite can occur at relatively mild temperatures if
wind penetrates the body insulation. For example, when the actual air
temperature of the wind is 40 F (4.4 C) and the velocity is 30 mph
(48 km/h), the exposed skin would perceive this situation as an equivalent
still air temperature of 13 F (-11 C).
The generally recognized cold disorders or conditions are frostbite and hypother
mia. Contributing factors to these disorders or conditions are:
* Exposure to humidity,
* High winds,
* Contact with wetness,
* Inadequate clothing, and
* Poor worker health.
The physical conditions that effect cold exposure disorders or conditions
are the same as those associated with heat disorders or conditions, such
as physical fitness, alcohol or drug use, and disease.
6.3.1. Control Measures
The presence of dead air space between the warm body and clothing and the
outside air is essential. Many layers of relatively light clothing with
an outer shell of windproof material maintains body temperature much
better than a single heavy outer garment worn over ordinary indoor
clothing. The more air cells each clothing layer has, the more efficient
it insulates against body heat loss. Clothing also needs to allow some
venting of perspiration. In addition to adequate clothing, whenever
possible, full use should be made of windbreaks and heat tents.
Table 6-3 gives the recommended time limits for working in various low
temperature ranges.
TABLE 6-3
Maximum Daily Time Limits for Exposure at Low Temperatures
Temperature Range Maximum Daily Exposure
-------------------------------------------------------------------------
Celsius Fahrenheit
0 to -18 30 to 0 No limit, providing that the person is
properly clothed.
-18 to -34 0 to -30 Total work time: 4 hours. Alternate 1
hour in and 1 hour out of the
low-temperature area.
-34 to -57 -30 to -70 Two periods of 30 minutes each at least
4 hours apart. Total low temperature work
time allowed is 1 hour.
-57 to -73 -70 to -100 Maximum permissible work time is 5 minutes
during an 8-hour working day. At these
extreme temperatures, completely enclosed
headgear, equipped with a breathing tube
running under the clothing and down the
leg to preheat the air, is recommended.
6.3.2. Physiological Monitoring
Early recognition of the symptoms of cold exposure stress is essential in
preventing serious or permanent disorders or conditions. Workers and
managers involved in cold weather operations should be adequately trained
to recognize the following conditions and related symptoms:
* Hypothermia - The first symptoms of this condition are
uncontrollable shivering and the sensation of cold, irregular
heart beat, weakened pulse, and change in blood pressure. Severe
shaking of rigid muscles may be caused by a burst of body energy
and changes in the body's chemistry. Vague or slow, slurred
speech, memory lapses, incoherence, and drowsiness are some of
the additional symptoms. Symptoms noticed before complete
collapse are cool skin, slow and irregular breathing, low blood
pressure, apparent exhaustion, and fatigue even after rest.
As the core body temperature drops, the victim may become
listless and confused, and may make little or no attempt to keep
warm. Pain in the extremities can be the first warning of
dangerous exposure to cold. If the body core temperature drops
to about 85ø F, a significant and dangerous drop in the blood
pressure, pulse rate, and respiration can occur. In extreme
cases, death will occur.
* Frostbite - Frostbite can occur, in absence of hypothermia, when
the extremities do not receive sufficient heat from central body
stores. This can occur because of inadequate circulation and/or
insulation. Frostbite occurs when there is freezing of fluids
around the cells of the body tissues due to extremely low
temperatures. Damage may result, including loss of tissue around
the areas of the nose, cheeks, ears, fingers, and toes. This
damage can be serious enough to require amputation or result in
permanent loss of movement.
The potential for both heat and cold related disorders or conditions can
occur in many common situations. Cold early morning temperatures can give
way to warm daily temperatures, resulting in heavy perspiration within
protective clothing. As temperatures cool again in the evening, the
potential for cold related disorders or conditions can occur. Managers
should be aware of the potential for this occurrence and should monitor
workers accordingly.
6.4 - Prevention
Preventive measures are the best approach to avoiding the types of
disorders or conditions associated with temperature extreme conditions.
Many of the measures are similar for both heat and cold extremes. Proper
training and preventive measures are critical in temperature extreme
conditions to avert illness, injury and potential loss of worker
productivity.
The following steps are recommended for ensuring/protecting workers
involved in temperature extreme conditions:
* Closely monitor and modify/adjust work/rest worker schedules;
* Maintain proper worker body fluids in both cold and hot weather by:
- Maintaining drinking water temperature at 50 to 60 F (10 to
15.6 C),
- Urging workers to drink 16 ounces of fluid before beginning
work, and
- Urging workers to drink at least 4 ounces of water every 15 to
20 minutes at each monitoring break (1 to 1.6 gallons of
water a day is recommended);
* Weigh workers before and after each work session to determine if
fluid intake/replenishment is adequate;
* Encourage workers to maintain an optimal level of physical fitness;
* Encourage workers to maintain normal/constant weight (significant
weight loss can be a strong indication of physical problems);
* Advise workers that heavy alcohol intake may significantly
increase their risk of heat stroke (i.e., dehydration);
* Use cooling/heating devices that aid in natural body heat
exchange, such as:
- Heating or cooling tents,
- Showers or hoses, and
- Cooling vests, jackets, or suits.
6.4.1. Physiological Monitoring
The worker's ability to physiologically adjust to work under temperature
extreme conditions affects his/her ability to perform work. Acclimatized
workers have lower heart rates and body temperatures, sweat more profusely
than unacclimatized workers, and are, therefore, better able to function
in these specific working conditions. Managers need to be aware of the
importance of acclimatizing workers before they can be added to a regular
work schedule. Although the phenomenon of acclimatization is an important
consideration for heat stress, it has not been recognized for cold stress.
The added burden of PPE may increase the time to acclimatize workers.
Acclimatization can occur within a few days. NIOSH recommends a
progressive, 6-day acclimatization period for workers before allowing them
to perform a full work load. Under this regimen, the first day of work
should be conducted using only 50% of the anticipated workload and
exposure time. This level should be increased 10% each day for the
following 5 days.
Managers need to be aware that workers can lose their acclimatization, and
that the work regimen will need to be adjusted to accommodate these
changes. Managers may determine that other factors impact the
acclimatization period, including the use of PPE and the relative fitness
of workers.
6.5 - Integration with Other Elements of the HASP
The area of temperature extreme disorders or conditions impacts other
areas of the HASP. Temperature extreme considerations should be
integrated with other concerns, such as personnel protective equipment
(PPE) early in the planning phase of any operation, and proper contingency
planning should be undertaken. Integrated areas should include:
* Monitoring,
* Medical surveillance,
* Emergency response,
* Confined space entry,
* Buddy systems,
* Decontamination of personnel, and
* Site characterization operations.
The potential hazards associated with temperature extreme conditions can
cause problems for even the best designed work plan, and the potential for
worker injury or death is always present. Changes in ambient air
temperatures, humidity, wind, and precipitation, can change a typical
operation into an immediate health hazard to workers. It may require
logistical requirements to supplement normal operations, including
requirements such as increased water supply, on-call medical personnel,
and the ability for injured-worker retrieval teams to enter exclusionary
zones.
6.6 - References
1. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
2. DHHS (NIOSH) Publication No. 85-115, "Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA,
1985(Four-Agency Document).
3. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,
Chapter 8," Office of Emergency and Remedial Response, USEPA, 1992.
4. American Conference of Governmental Industrial Hygienist (ACGIH),
"Threshold Limit Values for Chemical and Physical Agents and Biological
Indices," Current edition.
5. Ramsey, J.D. 1976. NIOSH, "Standards Advisory Committee on Heat
Stress - Recommended Standard for Work in Hot Environments." Appendix C
in Standards for Occupational Exposure to Hot Environments, proceedings of
symposium, Cincinnati, OH.
7.1 - Background
The Medical Surveillance Program is a regulatory requirement designed to
ensure that the health of employees working on hazardous waste sites is, at
a minimum, monitored and documented before, during, and at termination of
work on the site.
The medical surveillance requirements have been derived from numerous
sources, including the Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities (also referred to as the Four-Agency
Document NIOSH/OSHA/USCG/EPA, 1985), DOE Order 5480.8A, Contractor
Occupational Medical Program, and generally accepted work practices. For
sites that contain mixed wastes, DOE orders and standards should be
consulted for radiological requirements. These requirements should be
incorporated into the medical surveillance program. The medical
surveillance program requirements include:
* Baseline or pre-assignment examination,
* Periodic monitoring,
* Examination after illness or injury,
* Termination examination, and
* Maintenance of medical records.
Medical surveillance programs are designed to:
* Establish the baseline medical condition of employees and fitness
for duty,
* Determine the ability to work while wearing protective equipment,
* Track the physiological conditions of employees on an established
schedule and at termination of the project or employment, and
* Ensure documentation of employee exposure and medical conditions is
provided and maintained as a part of the employee's medical record.
The overall objectives of the Medical Surveillance chapter are to identify:
* All personnel covered by the medical surveillance program;
* The decision-making needs of the personnel involved in the medical
surveillance program;
* Pertinent details regarding the baseline, periodic,
after-illness/injury, and termination examinations;
* Which medical records are to be maintained;
* The confidentiality of medical records.
The sequence of events associated with the medical surveillance process is
shown in Figure 7-1.
FIGURE 7-1
Medical Surveillance Process
----------------------------------
| |
| Job Identified |
| |
----------------------------------
|
|
----------------------------------
| Job Description |
| Evaluated |
| |
----------------------------------
|
|
----------------------------------
| Hazard Assessment |
-------------- | Performed | --------------
| Exam | | | | Contents |
| Period | ---------------------------------- | Based on |
| Based on | | | Hazard |
| 30-Day | | | Assessment |
| Exposure | ---------------------------------- | |
| | | Medical Examination | | |
| |----| Performed |----| |
| | | | | |
-------------- ---------------------------------- --------------
|
|
----------------------------------
| Employee and Supervisor |
| Notified of Employee |
| Fitness/Restrictions |
----------------------------------
| |
| |
-------------------- --------------------
| Employee Assigned| | Employee |
| To Job | | Reassigned |
| | | |
-------------------- --------------------
|
|
--------------------
| Periodic Medical |
| Monitoring |
| |
--------------------
|
|
--------------------
| Termination |
| Medical |
| Examination |
--------------------
7.2 - Information for the Medical Program
The Medical Program Administrator should be provided with the following
information by the SSHO for technical evaluation by a physician prior to an
employee examination:
* A tour of representative sites,
* All data related to expected or known employee exposure levels to
hazardous and radiological substances,
* A description of Personal Protective Equipment (PPE) expected to be
worn by the employee,
* A description of the duties expected to be performed by the employee,
* Available information from previous medical surveillance
examinations, and
* Updated medical and occupational history.
For hazardous waste work, the following site employees should be included
in the Medical Surveillance Program:
* All employees who are exposed to hazardous substances or health
hazards above published exposure limits (e.g., OSHA PELs, ACGIH
TLVs, NIOSH RELs) without regard to the use of respirators, for
30 days or more a year;
* All employees who wear a respirator for 30 days (or fractions of
days) or more a year or as required by 29 CFR 1910.134;
* All employees who are injured, become ill, or develop signs or
symptoms due to possible overexposure involving hazardous substances
or health hazards from an emergency response or hazardous waste
operation; and
* Members of HAZMAT teams.
Each contractor should implement DOE Quality Assurance and Records
Management requirements with respect to medical records and medical
surveillance records. In addition, the physician(s) should document that
they have a copy of the Occupational Safety and Health Administration
regulations, 29 CFR 1910.120, Hazardous Waste Operations and Emergency
Response, and 29 CFR 1910.20, Access to Employee Exposure and Medical
Records.
7.3 - Examination Content
Medical examinations should include a medical and work history with special
emphasis on symptoms related to exposure to hazardous substances or
radiological materials and their health effects, and on fitness for duty
when conducting project tasks. The content of the medical examinations
should be based on applicable laws, regulations, and known or potential
exposure to contaminants. Where possible, the content should be determined
by a licensed physician certified in Occupational Medicine by the American
Board of Preventive Medicine. However, at a minimum, the physician making
the determination should be knowledgeable and experienced in occupational
medicine screening and surveillance. If no physician is on the staff of
the employer, the content of the examination is determined by the Medical
Program Administrator in concert with a contract physician.
An example of a matrix of medical examination by job task is shown in Table
7-1.
TABLE 7-1
Example of Periodic Examination Based on Job Task
Medical Physical Pulmon- X-ray EKG Eye Audio- Urin-
and Exam. ary Exam gram alysis
Work Function
History
-------------------------------------------------------------------------
Project X X A A A A A A
Mgmt.
Data X X X A X X X X
Collect.
Oversight X X A A A A A A
Heavy X X X A X X X X
Equip.
Operator
Truck X X X A X X X X
Driver
Front-end X X X A X X X X
Loader or
Backhoe
Driver
Laborer X X X A X X X X
Other A A A A A A A A
X - Recommended
A - As Appropriate
TABLE 7-1 (cont)
Example of Periodic Examination Based on Job Task
Blood Heavy Rad. Other
Chem- Metals Bio-
istry assay
-------------------------------------------------------------------------
Project A A A A
Mgmt.
Data X X A A
Collect.
Oversight A A A A
Heavy X X A A
Equip.
Operator
Truck X X A A
Driver
Front-end X X A A
Loader or
Backhoe
Driver
Laborer X X A A
Other A A A A
X - Recommended
A - As Appropriate
7.4 - Baseline (Initial) Examination
The employee should receive a baseline or initial medical examination based
on an activity hazard assessment prior to being assigned to a hazardous or
potentially hazardous activity (e.g., exposure to toxic substances or
radiological materials, repetitive motion, heat/cold stress). The
examination should include, at a minimum, the items listed below.
7.4.1. Baseline/Periodic Medical Examination Parameters
The baseline medical examination parameters are determined by the Medical
Program Administrator or the physician, after review of the activity hazard
assessment. However, at a minimum, the following should be included:
* Complete medical and work history,
* Physical examination,
* Pulmonary function test,
* Eye examination,
* EKG,
* Audiogram,
* Urinalysis,
* Blood chemistry,
* Heavy metal screen (as appropriate),
* Radiological bioassay (as appropriate), and
* Evaluation of stresses related to repetitive motion.
It may be beneficial to develop a table of hazardous substances expected at
the work site, the target organs affected, the potential health effects,
and the medical monitoring to be performed. An example is provided in
Table 7-2. (The information in the table should be consistent with
information in the hazard assessment.)
7.5 - Periodic Medical Monitoring
Employees working on hazardous waste sites, which may include chemical,
physical and/or radiological hazards, should be provided with medical
examinations every 12 months, unless the physician believes a shorter or
longer duration is needed or required. The content of the examination is:
* Based on applicable laws and regulations,
* Determined by the physician,
* Designed to detect change from the baseline examination, and
* Designed to identify physiological changes.
Employee site-specific exposure data, parameters identified above, official
dosimetry records, and a hazard assessment should be provided to the
examining physician.
TABLE 7-2
Hazardous Substances Expected to be Encountered, the Target Organ,
Potential Health Effects, and Recommended Medical Monitoring
Hazardous Target Organ Potential Health Effects Medical Monitoring
Substance
-------------------------------------------------------------------------------
Hydrocarbons (specific hydrocarbons are identified here)
Toluene CNS, and CNS depression, History of physical exam
skin dermatitis focusing on nervous
system and changes in
skin
Trichloroethene Liver, CNS, liver disease and History for pre-existing
kidneys, kidney injury, liver disease or
respiratory, dermatitis, CNS, decreased lung
skin depression, cancer, functions, measurement
ventricular of liver enzymes and
arrhythmias liver function, urine
screen, physical exam
focusing on nervous
system, skin and
respiratory system
Heavy Metals (specific heavy metals are identified here)
Lead kidney, renal system urine screen,
blood, CNS, disfunction, measurement of kidney
GI tract general CNS function where
impairment relevant, CBC, history
and physical exam
focusing on CNS
Herbicides (specific herbicides are identified here)
2,4-D skin, PNs chloracne, peripheral history and physical
neuropathy exam focusing on skin
nervous system,
urinalysis
Radionuclides
(specific radionuclides are identified here)
Plutonium bone, lungs lung cancer history focusing on
prior exposure to
ionizing radiation,
baseline bioassay and
periodic bioassay
monitoring
7.6 - Examination After Illness or Injury
Follow-up examinations should be provided as soon as possible to the
employee due to any of the following situations:
* Notification to the supervision, management, the Medical Program
Administrator or physician that the employee has developed signs or
symptoms indicating sensitivity or overexposure,
* Potential exposure above the permissible exposure limit or published
exposure limit,
* Lost time illness of three working days or more,
* Any recordable injury to the employee, or
* Contamination incident.
In the case of injury or illness, the Site Safety and Health Officer (SSHO)
or his/her designated alternate is responsible for notifying the Medical
Program Administrator of the incident and the suspected substance involved.
If the substance is unknown, it should be identified as such.
The examination will be carried out by a licensed occupational medical
provider. The scope of the examination will be determined by the
physician. The employee will not return to work until the physician
certifies that the employee is fit to return to work, activity restrictions
are identified, and documentation of fitness for duty is provided.
7.7 - Termination Examination
The employer should provide a termination medical examination when an
employee is terminated or reassigned to an area or activity where the
employee is not exposed to hazardous substances or radiological
constituents. The termination examination content will be determined by
the physician. If termination occurs within six months of a periodic
examination, the physician may determine that an additional examination is
not necessary. Documentation of the decision not to provide a termination
examination, and its basis, should be provided in the medical file for the
employee.
7.8 - Maintenance and Availability of Medical Records
The employee should be notified of recommended limitations upon his/her
assigned work. The physician should provide a written opinion to the
records indicating that the employee has been informed of the results of
the exam and of any medical conditions which require further examination or
treatment. In addition, the following specific records should be
maintained:
* Name and Social Security number of employee;
* Physician's written opinion, recommended limitations and results of
exam;
* Employee medical complaints related to exposure to hazardous
substances;
* Information provided to the physician from the employer (not
standard or appendices); and
* Engineering controls, work practices and PPE for employee protection.
Personnel medical records and exposure monitoring records should be
maintained according to DOE orders and the requirements of 29 CFR 1910.120
(f)(8) and 29 CFR 1910.20. Access to medical records should be consistent
with the requirements of 29 CFR 1910.20. The employee medical records will
be held in confidence by the employer to the extent permitted by law.
7.9 - References
1. 29 CFR 1910.20, "Access to Employee Exposure and Medical Records."
2. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response."
3. 29 CFR 1910.134, "Respiratory Protection."
4. 29 CFR 1910.1000, Subpart Z, "Toxic and Hazardous Substances."
5. American Conference of Governmental Industrial Hygienists (ACGIH),
"Threshold Limit Values for Chemical Substances and Physical Agents and
Biological Exposure Indices," Current edition.
6. DHHS (NIOSH) Publication No. 85-115, "Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA,
1985 (Four-Agency Document).
7. DOE N 5480.6, U.S. DOE "Radiological Control Manual."
8. DOE Order 3790.1B, "Federal Employee Occupation Safety and Health Program."
9. DOE Order 5000.3A, "Occurrence Reporting and Processing of Operations
Information."
10. DOE Order 5480.4, "Environmental Protection, Safety, and Health
Protection Standards."
11. DOE Order 5480.8A, "Contractor Occupational Medical Program."
12. DOE Order 5480.10, "Contractor Industrial Hygiene Program."
13. DOE Order 5480.11, "Radiation Protection for Occupational Workers."
8.1 - Background
Hazardous waste activities generate the potential for employee exposure to,
and/or off-site migration of, hazardous concentrations of airborne
substances. This section provides the general HASP guidance for the
exposure monitoring/air sampling program and specific activities that
should take place during hazardous waste activities.
The overall objectives of the exposure monitoring/air sampling section are:
* Describe the overall exposure monitoring and air sampling program by
providing general information about the purpose of the exposure
monitoring and air sampling program, regulatory requirements, and
guidance documents; and
* Identify the different components of the exposure monitoring/air
sampling program, including personnel qualifications, air
contaminants, instrumentation, worker exposure, level of protection,
and offsite, perimeter, and meteorological monitoring, quality
assurance/quality control, and recordkeeping.
The objectives of exposure monitoring/air sampling are to accurately
determine:
* Exposure levels for site workers,
* Work areas generating the most significant airborne contaminants,
* Whether migration is occurring, and
* Whether modified levels of protection or engineering controls are
required.
This section of the HASP should be prepared in accordance with guidelines
contained in the EPA Standard Operating Safety Guides, June 1992; EPA,
Office of Emergency and Remedial Response, Air Surveillance for Hazardous
Materials; and the NIOSH Manual of Analytical Methods (latest edition).
8.2 - General Guidance
An exposure monitoring/air sampling program should be prepared and
implemented to identify and quantify airborne levels of potentially
hazardous substances. Appropriate direct-reading (i.e., real time) air
monitoring and time-integrated (e.g., 8 hour time-weighted average, 15
minute short term exposure limit) air sampling should be conducted in
accordance with applicable regulations (e.g., OSHA, EPA, State, NRC). Both
direct-reading and time-integrated sampling should be used to test for the
presence of air contaminants. Compounds which are found by time-integrated
sampling, but are not detected by direct reading air monitors, may warrant
modification of both the monitoring program and the levels of protection.
Work area air monitoring within the Exclusion Zone should be conducted to
determine if pre-established action levels are being exceeded. If the
action levels are being exceeded, additional, appropriate controls should
be implemented or workers should upgrade PPE to the appropriate level of
protection. Worker exposure monitoring with time-integrated sampling
should be conducted during the clean-up phase and where otherwise
appropriate to accurately assess worker exposure to specific chemicals.
A combination of offsite, perimeter, and work area samples should be used
to assess the release of air contaminants. While the primary objective of
work area air monitoring is to assist in protecting onsite personnel from
airborne contaminants, these data can also be used to assess the potential
for detectable offsite emissions. Upwind and downwind offsite and
perimeter monitoring should be conducted. Air contaminant levels should be
established upwind around the site perimeter in order to define the
reference point or baseline to which downwind monitoring data can be
compared. Comparisons of air monitoring data with these reference data may
indicate areas which generate air contaminant levels above established
action levels. When action levels are exceeded, appropriate actions should
be taken, such as, increasing engineering controls or making community
notifications.
As appropriate, air samples should be taken according to the requirements
of 10 CFR 20.103(a)(3), "Exposure of Individuals to Concentrations of
Radioactive Materials in Air in Restricted Areas," and DOE's "Radiological
Control Manual" (latest edition) to identify the radioactive isotopes and
corresponding radiation types (alpha, beta, gamma) in the workplace
atmosphere and at the perimeter of the site. The principles of ALARA (as
low as reasonably achievable) should be utilized to assure worker and
public protection from atmospheric emissions.
8.2.1. Personnel Qualifications
The exposure monitoring/air sampling program should be developed by an
industrial hygienist, preferably one who is certified by the American Board
of Industrial Hygiene, or otherwise board eligible, or who has a minimum of
three years experience in developing such programs for hazardous waste
sites. In addition, where exposures to radioactive materials are
anticipated, a health physicist, preferably one who is certified by the
American Board of Health Physics, or otherwise board eligible, or who has a
minimum of three years relevant experience, should assist in the
development of the exposure monitoring/air sampling program.
Staff should be experienced in implementing an air monitoring program for
the type of activities to be conducted. The staff should also be
experienced in implementing an air monitoring program designed to evaluate
worker exposure to airborne contaminants. The Site Safety and Health
Officer (SSHO) should be responsible for implementing the exposure
monitoring/air sampling program, and all activities should be conducted
under the direction of the SSHO. Other air monitoring staff may include
air monitoring specialists and field technicians. The air monitoring staff
should be provided site-specific training regarding the site-specific air
sampling, monitoring, instrumentation, sample shipping procedures, and
other duties assigned by the SSHO. The responsibilities for each staff
position and the minimum requirements for the SSHO and other air monitoring
staff should be developed and presented in tables similar to those shown in
Table 8-1.
TABLE 8-1
Framework for Presenting Staff Responsibilities
Position Number Qualifications Responsibilities
-------------------------------------------------------------------------
SSHO 2 (training, education, 1.
(including experience) 2.
alternates) 3.
Field 1.
Technicians 2.
3.
8.3 - Air Contaminants
The air contaminants to be monitored/sampled and the locations and
frequency of monitoring should be specified. The following should be
included as appropriate, depending on site-specific conditions:
* Classes of chemicals,
* Specific contaminants for individual identification and analysis,
* Oxygen content,
* Flammable atmospheres,
* Total and respirable dust,
* Specific radioisotopes and corresponding types of radiation, and
* Noise.
A table should be provided which summarizes the contaminants to be
monitored, key chemical, radiological, physical, and toxicological
properties for each contaminant, and the frequency/schedule for monitoring
each contaminant. An example is provided in Table 8-2. A table of
pre-established action levels for each contaminant, corresponding actions
to be taken when action levels are exceeded, and the basis for choosing an
action level should be developed. An example is shown in Table 8-3. In
addition, written justification and a rationale for the action level and
actions identified should be available for review.^L
TABLE 8-2
Air Contaminants - Summary of Properties and Frequency of Monitoring
-----------------------------------------------------------------
Air Contaminant:
-----------------------------------------------------------------
Physical Properties |
|
Chemical Properties |
|
Toxicological Properties |
|
Type of Sampling (e.g., |
direct-reading at |
perimeter, time-integrated |
worker exposure) |
|
Frequency |
|
Locations |
|
|
------------------------------------------------------------------
TABLE 8-3
Air Contaminants - Action Levels
----------------------------------------------------------------------
Air Contaminant:
----------------------------------------------------------------------
Action Level | Action | Basis For Action Level
----------------------------------------------------------------------
| |
| |
----------------------------------------------------------------------
| |
| |
----------------------------------------------------------------------
| |
| |
----------------------------------------------------------------------
Air Contaminant:
----------------------------------------------------------------------
Action Level | Action | Basis For Action Level
----------------------------------------------------------------------
| |
| |
----------------------------------------------------------------------
| |
| |
----------------------------------------------------------------------
| |
| |
----------------------------------------------------------------------
8.4 - Methods and Instrumentation
Air monitoring specialists should be responsible for operating air
monitoring instruments under the supervision of the SSHO. These
individuals should be required to demonstrate proficiency in the use, care,
limitations, and operating characteristics of air monitoring instruments.
These individuals should also be responsible for the maintenance and
calibration of all air monitoring equipment.
Calibrations should be in accordance with methods indicated in NIOSH's
Manual of Analytical Methods (latest edition), EPA methods, and/or methods
recommended by the equipment manufacturer. Maintenance of instruments
should be in accordance with methods recommended by the equipment
manufacturer or by the SSHO.
The EPA methods to be used for ambient air monitoring should be specified,
as well as the use of NIOSH methods for worker exposure
monitoring/sampling. The use of analytical laboratories accredited by EPA
and/or the American Industrial Hygiene Association (AIHA), should be
specified. Samples collected using NIOSH methods should be analyzed only
by laboratories currently accredited by the AIHA. When radiological
samples are to be analyzed, laboratories with appropriate accreditation
should be used.
The following sections discuss in more detail the detection principle,
limitations, and features of instruments which should be utilized during
environmental restoration projects. For selection of all instruments, a
number of factors should be considered such as:
* Accuracy,
* Mobility,
* Potential interferences on performance,
* Alarms,
* Remote sensing,
* Battery life,
* Calibration required,
* Explosion proofing, and
* Sampling range.
8.4.1. Direct-Reading Monitoring Instruments
Unlike time-integrated sampling devices, which are used to collect samples
for subsequent analysis in a laboratory, direct-reading instruments (the
term direct-reading is used synonymously for the term real-time) provide
information at the time of sampling, thus enabling rapid decision-making.
Data obtained from direct-reading monitors can often be used to assure
proper selection of personnel protection equipment, engineering controls
and work practices. The instruments can often provide the trained and
experienced user the capability to determine if site personnel are
potentially exposed to concentrations which exceed exposure limits or
action levels for specific hazardous materials.
Direct-reading monitors can be useful in identifying oxygen deficient
atmospheres, IDLH conditions, toxic levels of airborne contaminants,
flammable atmospheres, and radioactive hazards. Periodic monitoring of
airborne levels with real-time monitors is critical, especially before and
during new work activities.
Where appropriate, screening with direct-reading instruments for ionizing
radiation should be conducted prior to and during site activities. Where
appropriate, the type of radioactive isotopes present should also be
identified to assure that action levels, worker exposure and environmental
standards are not exceeded.
A summary of direct-reading instruments to be used and their specific
operating parameters should be developed. An example is provided in Table
8-4.
TABLE 8-4
Direct-Reading Instruments for Site XX
-----------------------------------------------------------
Instrument:
Number Provided at Site:
Contaminant Monitored:
Application:
Detection Method:
General Care/Maintenance:
Typical Operating Time:
8.4.2. Time-Integrated Sampling Instruments
Time-integrated sampling for chemical and radiation hazards should be
performed prior to and during site activities. The equipment and
collection media to monitor each hazard should be specified.
Time-integrated sampling may include pumps, collection media (MCE filters,
AA filters, sorbent tubes), and badge-type passive samplers.
8.5 - Worker Exposure Monitoring
The sampling strategy chosen to assess worker exposure through
time-integrated sampling and the sampling results should be documented.
Sections 8.11 through 8.14 contain additional guidance on documentation and
recordkeeping. Personal monitoring samples for both radioactive isotopes
and chemicals should be collected in the worker's breathing zone.
Representative sampling of those employees with the greatest risk of
exposure is required in accordance with 1910.120(h)(4). The sampling
strategy should be documented and changed as appropriate if the operation
or tasks change or if exposures potentially increase. Changes to the
sampling strategy should also be documented. Monitoring/sampling of
employees in all work zones (Exclusion Zone, Contamination Reduction Zone,
and Support Zone) should be included.
All employees working within a radiologically controlled area should
receive appropriate dosimetry monitoring for radiation exposure according
to the requirements of DOE's "Radiological Control Manual" or 10 CFR 20,
Subpart F, "Surveys and Monitoring." The monitoring program should include
information on the record keeping of employee's exposure to external
radiation according to the requirements of DOE's Radiological Control
Manual, Determination of Prior Occupational Dose. Each employee's
radiation exposure history should be reviewed, according to the
requirements of DOE's Radiological Control Manual, for compliance with
exposure standards prior to allowing the employee access to a
radiologically controlled area. The employee's exposure history should be
continuously documented and available for the employee's review.
8.6 - Level of Protection Monitoring
When and how often monitoring/sampling should be performed to assess the
level of protection should be specified. Frequencies and durations should
be specified for all of the following:
* Upon initial entry,
* When new operations begin,
* When work begins on a different portion of the site,
* When different contaminants are being handled,
* When working in areas with obvious liquid contamination, and
* When entering or working in confined spaces.
The use of direct-reading and time-integrated monitoring should be
considered to assure that airborne concentrations of contaminants do not
exceed the protection factors of the PPE in use.
Standard industrial hygiene practice dictates that the background levels be
taken to accurately determine the levels of exposure resulting from site
activities. The following monitoring should be conducted during:
* Initial site entry when the site evaluation shows the potential for
ionizing radiation;
* IDLH conditions; or
* When the site is not adequately characterized to eliminate these
possible conditions:
- Monitoring with direct-reading instruments for ionizing radiation;
- Monitoring with direct-reading instruments for IDLH and other
conditions (e.g., combustible, explosive, oxygen deficient, toxic
substances) that may cause death or serious injury; and/or
- Visual observations for signs of actual or potential IDLH or
other dangerous conditions.
8.7 - Offsite Monitoring
Locations of offsite monitoring stations should be determined in the field
by the SSHO. In general, at least three stations (one upwind and two
downwind) should be used at pre-established distances, in accordance with
the predominant wind directions recorded at the site. Monitoring at
downwind locations should be conducted a minimum of once each workday
following the establishment of ambient background levels. Ambient
background levels should be established at the upwind offsite monitoring
station. The mean value of three separate readings should be recorded as
the ambient background level.
8.8 - Perimeter Monitoring
Perimeter monitoring is intended to detect any migration of pollutants
outside of the Exclusion Zone. Both direct-reading and time-integrated
monitoring/sampling should be considered.
8.9 - Meteorological Monitoring
Accurate information on temperature, precipitation, wind speed, and wind
direction should be provided by existing site resources or a portable
meteorological station. Data obtained should be used to aid in determining
the daily monitoring strategy (e.g., determining sampling locations).
8.10 - Quality Assurance / Quality Control
Procedures should be developed in accordance with DOE Order 5700.6C,
Quality Assurance, and EPA requirements for quality assurance/quality
control of samples and sample results from equipment calibration through
the sample collection, sample shipment, and reporting of sample results
should be specified. The procedures should include:
* Sample packaging and shipping,
* Chain of custody,
* Record keeping,
* Quality review checks of sampling data and calculations,
* Data corrections,
* Field sample blanks, and
* Sample duplicates.
8.11 - Record Keeping
An important aspect of any data generation is accurate record keeping. The
air monitoring staff should be responsible for the completeness and storage
of all records. Forms used to record pertinent data should contain the
information specified in the following sections. When any personal samples
are taken, worker name and social security number should be added to these
forms.
8.12 - Time-Integrated Sampling Data
The following information, at a minimum, should be specified in
time-integrated sampling data forms:
* Site Location/Date,
* Work Area/Operation Name,
* NIOSH Method Used,
* Air Flow Calibration Record,
* Instrument Calibration Record,
* Temperature, Pressure, Humidity,
* Area/Sampling Location Diagram,
* Area Sample Description/Location,
* Sampling Data,
* Pump I.D.,
* Flow Rate,
* Sample Filter/Tube Number,
* Pump On/Off (Time),
* Volume Air Collected (Liters),
* Sample Submission Number,
* Laboratory Sample Number,
* Analyte Results (mg/m3, ppm, or f/cc),
* Field Notes,
* Description of Operation and Complaints/Symptoms,
* Chemicals/Materials/Equipment in Use,
* Engineering/Administrative Controls in Effect,
* Personal Protective Equipment in Use,
* Sampling Observations/Comments,
* AIHA Accredited Laboratory Name,
* Laboratory Location,
* Chemist/Industrial Hygienist Name,
* Principal Air Monitor, and
* Reviewer.
8.13 - Direct-Reading Air Monitoring Data
The following information, at a minimum, should be specified in
direct-reading air monitoring data forms:
* Site Location/Date;
* Work Process/Operation Name;
* Instrument Used - type, manufacturer, model, I.D.;
* Instrument Calibration Record;
* Sample Location - description, diagram;
* Sampling Conditions - temperature, humidity, pressure;
* Interferences;
* Direct Reading Data - time, reading (units);
* Field Notes;
* Principal Air Monitor Name; and
* Reviewer.
8.14 - Final Report
A final report document should be prepared by the SSHO and should be
submitted as part of the site records. This document should contain the
following information:
* Chain of Custody,
* Laboratory Results (raw data),
* Calculated Results (air contaminant concentrations),
* Meteorological Data,
* Daily Log,
* Air Sampling and Monitoring Forms, and
* Equipment Calibration and Maintenance Records.
8.15 - References
1. 10 CFR 20, "Standards for Protection Against Radiation."
2. 29 CFR 1910, "Occupational Safety and Health Standards."
3. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
4. 29 CFR 1910.1000, "Air Contaminants."
5. 29 CFR 1926, "Safety and Health Regulations for Construction."
6. American Conference of Governmental Industrial Hygienist (ACGIH),
"Threshold Limit Values for Chemical Substances and Physical Agents and
Biological Exposure Indices," Current edition.
7. DHHS (NIOSH) Publication No. 85-115, "Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA,
1985 (Four-Agency Document).
8. DOE EH-0256T, U.S. DOE "Radiological Control Manual," Office of
Environmental, Safety and Health, USDOE, 1992.
9. DOE Order 5480.4, "Environmental Protection Safety, and Health
Protection Standards."
10. DOE Order 5480.9, "Construction Project Safety and Health Management."
11. DOE Order 5480.10, "Contractor Industrial Hygiene Program."
12. DOE Order 5482.1B, "Environment, Safety and Health Appraisal Program."
13. DOE Order 5483.1A, "Occupational Safety and Health Program for DOE
Contractor Employees at Government-Owned Contractor-Operated Facilities."
14. DOE Order 5700.6C, "Quality Assurance."
15. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,"
Office of Emergency and Remedial Response, USEPA, 1992.
16. EPA-600-4-84-041, "Compendium of Methods for the Determination of Toxic
Organic Compounds in Ambient Air," USEPA, Most recent edition for each
method.
17. ICAO Regulations for shipment of hazardous materials on international
air cargo transport planes (supersedes DOT regulations when using air
transport).
18. NIOSH Publication No. 84-100, "NIOSH Manual of Analytical Methods"
(1984, Supplements 1985, 1987, 1988, and 1990).
9.1 - Background
The site control program at hazardous waste sites is used to control the
activities and movement of people and equipment in order to minimize the
potential for worker exposure to hazardous substances. The provisions of
29 CFR 1910.120(d) require that an appropriate site control program be
developed prior to the implementation of cleanup operations.
The site control program should be established during the planning stages
of a hazardous waste operation. It should be modified as new information
becomes available. The appropriate sequence for implementing site control
measures should be determined on a site-specific basis. It may be
necessary to implement several measures concurrently. Care should be taken
to ensure that the posting requirements of the DOE Radiological Control
Manual are properly addressed and that procedures are implemented. For the
purpose of this chapter, a Radiological Area will generally equate to an
Exclusion Zone, a Radiological Buffer Area will generally equate to a
Contamination Reduction Zone, and a Controlled Area will generally equate
to a Support Zone. This equivalency is identified in Table 9-1.
TABLE 9-1
General Equivalency of Work Zones
RAD Contamination Areas Hazardous Substance
(DOE Radiological Control Manual) Contamination Zones
-----------------------------------------------------------------
Controlled Area Support Zone
Radiological Buffer Area Contamination Reduction Zone
Radiological Area Exclusion Zone
The overall objective of the site control component of the HASP is to
specify procedures to minimize employee exposure and protect the public
from hazardous substances and to prevent unauthorized access to the site.
Procedures to meet the objectives of the site control program should
include the following:
* Coordination with site management in the establishment of site
boundaries,
* Development of a map of the hazardous sites which represents a
central source of information about the site,
* Establishment of work zones to prevent unauthorized personnel
from entering controlled zones,
* Reducing accidental spread of hazardous substances from equipment
in the contaminated area(s) by workers,
* Confining work activities to the appropriate areas,
* Facilitating the location and evacuation of personnel in case of
an emergency,
* Establishment of the "buddy system",
* Establishment of appropriate communication systems,
* Implementation of worker safety procedures, and
* Identification of the nearest medical facilities.
9.2 - Development of the Site Map
The purpose of the site map is to assist site personnel in planning and
organizing response activities. Site maps should be updated during the
course of site operations to reflect:
* New information, such as information gained after initial site entry
or from subsequent sampling and analysis activities; and
* Changes in site conditions, including changes resulting from
accidents, ongoing site operations, hazards not previously
identified, new materials introduced on site, unauthorized entry
or vandalism, and weather conditions.
The site map should be developed prior to the initial site entry using
information obtained during the preliminary evaluation. The map should
include:
* Prevailing wind direction;
* Site drainage points;
* All natural and man-made topographic features including the location
of buildings, containers, impoundments, pits, ponds, and tanks;
* Location of specific work zones including radiological and
non-radiological postings;
* Any other site features;
* Locations of all potential hazards that were identified through the
interview/records research;
* The perimeter reconnaissance;
* The initial onsite survey should be plotted on the site map;
* Observed and suspected hazards;
* Onsite and offsite air and soil sampling results; and
* Potential exposure pathways.
9.3 - Establishment of Work Zones
One of the basic elements of an effective site control program is the
delineation of work zones at the site. The purpose of establishing work
zones is to:
* Reduce the accidental spread of hazardous substances by workers or
equipment from the contaminated areas to the clean areas;
* Confine work activities to the appropriate areas, thereby minimizing
the likelihood of accidental exposures;
* Facilitate the location and evacuation of personnel in case of an
emergency; and
* Prevent unauthorized personnel from entering controlled areas.
When establishing the work zones at a site, the site map can provide a
useful format for compiling the relevant data. In the absence of sampling
results, site maps can provide essential information on potential and
suspected hazards and potential exposure pathways.
Although a site may be divided into as many zones as necessary to ensure
minimal employee exposure to hazardous substances, the three most
frequently identified zones are the Exclusion Zone (or "hot zone"), the
Contamination Reduction Zone, and the Support Zone (or "clean zone").
Movement of personnel and equipment between these zones should be minimized
and restricted to specific access control points to prevent
cross-contamination.
9.3.1. The Exclusion Zone
The Exclusion Zone is the area where contamination is either known or
expected to occur and where the greatest potential for exposure exists.
The outer boundary of the Exclusion Zone, called the Hotline, separates the
area of contamination from the Contamination Reduction Zone. The Hotline
should initially be established by visually surveying the site and
determining the extent of hazardous substances, discoloration, or any
drainage, leachate, or spilled material present. Other factors to consider
in establishing the Hotline include:
* Providing sufficient space to protect personnel outside the
Exclusion Zone from potential fire or explosion,
* Allowing an adequate area within which to conduct site operations, and
* Reducing the potential for contaminant migration.
The Hotline should be physically secured (e.g., using chains, fences, or
ropes) or clearly marked (e.g., using lines, placards, hazard tape, and/or
signs). During subsequent site operations, the boundary may be modified
and adjusted as more information becomes available. In addition, the
Exclusion Zone may also be subdivided into different areas of contamination
based on the known or expected type and degree of hazards or the
incompatibility of waste streams. If the Exclusion Zone is subdivided in
this manner, additional demarcations (e.g., "Hazards Present" or
"Protection Required") may be necessary. For sites where radiological
contamination exists, procedures for establishing and posting of
radiological zones should be developed and included in this chapter.
Procedures should be in accordance with the DOE Radiological Control
Manual.
Access to and from the Exclusion Zone should be restricted to Access
Control Points at the Hotline. Access Control Points are used to regulate
the flow of personnel and equipment into and out of the contaminated area
and to verify that site control procedures are followed. Separate
entrances and exits should be established to separate personnel and
equipment movement into and out of the Exclusion Zone.
All persons who enter the Exclusion Zone should wear the appropriate level
of Personal Protective Equipment (PPE) for the degree and types of hazards
present (see Chapter 5). If the Exclusion Zone is subdivided, different
levels of PPE may be appropriate. Each subdivision of the Exclusion Zone
should be clearly marked to identify the hazards and the required level of
PPE.
9.3.2. The Contamination Reduction Zone
The Contamination Reduction Zone is the area in which decontamination
procedures take place. It is the transition area between the Exclusion
Zone and the Support Zone. The purpose of the Contamination Reduction Zone
is to reduce the possibility that the Support Zone will become contaminated
or affected by the site hazards.
The Contamination Control Line marks the boundary between the Contamination
Reduction Zone and the Support Zone and separates the clean areas of the
site from those areas used to decontaminate workers and equipment. Access
Control Points between the Contamination Reduction Zone and the Support
Zone should be established to ensure workers entering the Contamination
Reduction Zone are wearing the proper PPE and that workers exiting the
Contamination Reduction Zone to the Support Zone remove or decontaminate
all potentially contaminated PPE.
9.3.3. The Support Zone
The Support Zone is the uncontaminated area where workers are unlikely to
be exposed to hazardous substances or dangerous conditions. Because the
Support Zone is free from contamination, personnel working within it may
wear normal work clothes. Any potentially contaminated clothing,
equipment, and samples (outer containers) should remain inside the
Contamination Reduction Zone or the Exclusion Zone.
Designation of the Support Zone should be based on all available site
characterization data and should be located upwind from the Exclusion Zone.
The Support Zone should be in an area that is known to be free of elevated
(i.e., higher than background) concentrations of hazardous substances.
9.4 - Using the Buddy System
When carrying out activities in the Exclusion Zone, workers should use the
"buddy system" to ensure that rapid assistance can be provided in the event
of an emergency. The "buddy system" is an approach used to organize
workgroups so that each worker is designated to be observed by at least one
other worker. During initial site entry, it may be appropriate to utilize
a "buddy system" in which additional workers are assigned to provide safety
backup.
The Field Team Leader, who is responsible for enforcing the "buddy system",
should implement the system at the Access Control Point for workers
entering the Exclusion Zone.
As part of the buddy system, workers should remain in close proximity and
maintain visual contact with each other to provide assistance in the event
of an emergency. Should an emergency situation arise, workers should use
prearranged communication signals agreed upon prior to entering the
contaminated area. The responsibilities of workers utilizing the buddy
system include:
* Providing his or her partner with assistance,
* Observing his or her partner for signs of chemical or heat exposure,
* Periodically checking the integrity of his or her partner's PPE, and
* Notifying the Project Manager or other site personnel if emergency
assistance is needed.
Workers should not rely entirely on the "buddy system" to ensure that help
will be provided in the event of an emergency. To augment this system,
workers in contaminated areas should remain in line-of-sight or direct
communication contact with the command post or Field Team Leader at all
times.
9.5 - Communication Network and Procedures
Communication systems should be established for both internal and external
communication. Internal communication refers to communication among
workers operating in the Exclusion Zone or Contamination Reduction Zone, or
between the Command Post and those workers. Routine checking for proper
operation should be addressed.
An internal communication system may be established using standard
communication devices such as radio, noisemakers, or visual signals.
Verbal communication can be difficult as a result of onsite background
noise and the use of PPE. Therefore, pre-arranged commands and audio or
visual cues should be developed prior to entering the Exclusion Zone. A
secondary set of non-verbal signals should be established for use when
communication devices fail or when emergency situations occur.
External communication refers to communication between onsite and offsite
personnel. An external communication system should be maintained in order
to:
* Coordinate emergency response efforts with offsite responders,
* Report progress or problems to management, and
* Maintain contact with essential offsite personnel.
The primary means of external communication are telephone and radio.
9.6 - Worker Safety Procedures
As part of the site control plan, procedures should be established to
ensure worker safety. Worker safety procedures include preparation of the
site for response activities, engineering controls and safe work practices,
and Standard Operating Procedures (SOPs). Worker safety procedures should
be prepared in advance of conducting onsite response operations and should
be available at the site command post.
Engineering controls and safe work practices should be implemented to
reduce and maintain employee exposure levels at or below the permissible
exposure limits (PELs) and published exposure limits for those hazardous
substances at the site. If engineering controls and safe work practices
are insufficient to adequately protect against exposure, PPE should be used
to protect employees against possible exposure to hazardous substances.
9.7 - Medical Assistance
As part of the site control program, the Project Manager should assure that
the identification and location of the nearest medical facilities where
response personnel can receive assistance in the event of an emergency are
posted. Information such as the names, phone numbers, addresses, and
procedures for contacting the facilities should be maintained. This
information should be posted conspicuously throughout the site, as well as
near telephones or other external communication devices.
9.8 - References
1. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
2. Department of Health and Human Services (DHHS) (NIOSH) Publication
No. 85-115, "Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA, 1985 (Four-Agency
Document).
3. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,"
Chapter 4, Office of Emergency and Remedial Response, USEPA, 1992.
4. EPA 9285.8-01, "Health and Safety Plan (HASP) User's Guide," Chapter 8,
Office of Emergency and Remedial Response, USEPA, 1992 (and ERT Health and
Safety Plan Planner, Ver. 3.0C, 1993).
10.1 - Background
Decontamination involves physically removing contaminants from personnel
and equipment and/or chemically converting them into innocuous substances.
The extent of decontamination depends on a number of factors, the most
important of which is the types of contaminants involved. The more harmful
the contaminant, the more extensive and thorough the decontamination. The
combination of decontamination, correct donning of protective clothing, and
zoning of site work areas, minimizes cross-contamination from the
protective clothing to wearer, from equipment to personnel, and from one
area to another. Only general guidance can be given on methods and
techniques for decontamination. The exact procedure is determined by
evaluating a number of factors specific to the incident and/or site. The
site should refer to the DOE Radiological Control Manual for detailed
radiological decontamination requirements.
The requirements and procedures need to be addressed and implemented for
both chemical and radiological contamination. For the purpose of this
document, a Radiological Area should generally equate to an Exclusion Zone,
a Radiological Buffer Area should generally equate to a Contamination
Reduction Zone, and a Controlled Area generally equates to a Support Zone
(see Table 9-1). Contamination of personnel, equipment and/or material can
occur from both a radiological and hazardous material. When
decontamination is required in such areas, procedures should be developed
which will accommodate both contamination types and minimize the amount of
mixed waste.
The overall objectives of the Decontamination chapter are to:
* Determine and implement the decontamination methods for personnel
and equipment that are effective for the specific
hazardous/radioactive substance(s) present,
* Ensure the decontamination procedure itself does not pose any
additional safety or health hazards,
* Provide pertinent information on the locations and layouts of
decontamination stations and equipment,
* Establish procedures for the collection, storage and disposal of
clothing and equipment that has not been completely
decontaminated, and
* Provide for the periodic evaluation of the plan against the
existing site hazards.
10.2 - General Consideration
The HASP should specify the level of decontamination necessary for
personnel and equipment at the site. The decontamination plan for
personnel and equipment is based on the assumption that all personnel and
equipment leaving the Exclusion Zone/Radiological Area (area of potential
contamination) are grossly contaminated. The plan includes a system for
washing, and rinsing, at least once, all of the mechanical and protective
equipment until they are decontaminated. If clothing or equipment is
contaminated with both radiological and hazardous material and this process
is used, mixed waste may be generated. Special precautions should be taken
to ensure this waste is properly handled, treated, stored and disposed.
10.3 - Location and Layout
An area within the Contamination Reduction Zone/Radiological Buffer Area is
normally designated the Contamination Reduction Corridor (CRC). The CRC
controls access into and out of the Exclusion Zone/Radiological Area and
confines personnel decontamination activities to a limited area. A
separate CRC should be established for equipment. Figure 10-1 provides a
graphical depiction of an example layout of CRCs in relation to work zones.
FIGURE 10-1
Example Layout of Contamination Reduction Corridors
(figure not available)
Professional judgment should be exercised in determining how the CRC should
be organized and what decontaminants should be used. Factors that should
be considered include:
* The extent and type of the expected hazard,
* Meteorological conditions (wind direction),
* Topography,
* Levels of protection selected, and
* Availability of equipment and supplies.
The size of the corridor depends on:
* The wind direction (corridor needs to remain upwind),
* Number of stations in the decontamination procedure,
* The overall dimension of work control zones (i.e., Exclusion Zone,
Contamination Reduction Zone, Support Zone), and
* The amount of space available at the site.
A corridor of 75 feet by 15 feet should be adequate for the most extensive
decontamination. Whenever possible, it should be a straight path.
The CRC boundaries should be conspicuously marked, with entry and exit
restricted. The far end is the Hotline--the boundary between the Exclusion
Zone and the Contamination Reduction Zone. Personnel and equipment exiting
the Exclusion Zone should go through the designated CRC. Anyone in the CRC
should be wearing the appropriate level of protection designated for the
decontamination crew.
Protective clothing, respirators, monitoring equipment, sampling supplies,
and other equipment should be maintained in the support area outside of the
CRC. Personnel don their protective equipment away from the CRC and enter
the Exclusion Zone through a separate access control point at the Hotline.
Appendix F recommends the decontamination layouts, procedures, and
equipment needed for PPE Levels A through C.
10.4 - Determining Decontamination Methods
The need for, and extent of decontamination depends upon the reason for an
employee leaving the Exclusion Zone/Radiological Area. A worker leaving
the Exclusion Zone/Radiological Area to pick up or drop off tools or
instruments and immediately returning may not require full decontamination.
A worker leaving to get a new air cylinder or change a respirator or
canisters, however, would require some degree of decontamination. The time
required for personnel decontamination should be ascertained and
incorporated into the scheduling of site activities. Individuals departing
the CRC to the Support Zone should be thoroughly decontaminated. Personnel
wearing a self-contained breathing apparatus should leave the work area
with sufficient air to walk to the CRC and go through decontamination.
A flow chart for evaluating safety and health aspects of a decontamination
method is depicted in Figure 10-2. Once decontamination procedures have
been established, all personnel requiring decontamination should be given
precise instructions and should practice moving through the decontamination
line.
FIGURE 10-2
Decision Aid for Evaluating Health and Safety
Aspects of Decontamination Methods
-------------------------
|Is the method effective|
--------------------|for removing |
| NO |contaminants? |
| -------------------------
| | YES
| |
| -------------------------
| |Are the decontamination|
|-------------------|materials compatible |
| NO |with the hazardous |
| |substances present? |
| -------------------------
| | YES
| |
| -------------------------
| |Are the decontamination|
|-------------------|materials compatible |
| NO |with the materials to |
| |be decomtaminated? |
| -------------------------
| | YES
| |
| -------------------------
| |Do the decontamination |
| |materials or process |-------
| |pose health or safety | NO |
| |hazards? | |
| ------------------------- |
| | YES |
| | |
-------------------------- ------------------------- |
|Take additional measures| |Can appropriate | |
|to prevent contamination|------|protective measures be | |
|or find another | NO |instituted? | |
|decontamination method. | ------------------------- |
|Consult specialists if | | YES |
|necessary. | | |
-------------------------- ----------------- |
| Method OK |------------
| to use |
-----------------
The type of decontamination equipment, materials, and supplies are
generally selected on the basis of availability, the ease of
decontamination, and disposability. Most equipment and supplies can be
easily procured. Some commonly used articles are:
* Soft-bristle scrub brushes or long-handled brushes to remove
contaminants;
* Buckets of water or garden sprayers for rinsing;
* Large galvanized wash tubs, stock tanks, or children's wading pools
for washing and rinsing solutions;
* Large plastic garbage cans or similar containers lined with plastic
bags for the storage of contaminated clothing and equipment;
* Metal or plastic cans or drums for the temporary storage of
contaminated liquids; and
* Paper or cloth towels for drying protective clothing and equipment.
Heavy equipment such as bulldozers, trucks, backhoes, and drilling
equipment are difficult to decontaminate. Decontamination Pad design and
construction should reflect consideration for overspray and pad strength
durability to accommodate heavy equipment decontamination. The methodology
generally employed involves washing the equipment on a sloped concrete or
plastic covered pad with a soapy water solution followed by a thorough
water rinse. The wash and rinse solutions are applied through the use of a
high pressure spray unit. Particular attention should be given to tires,
scoop, and other components which directly contact the contaminated areas.
Wipe tests should be employed to determine the effectiveness of the
decontamination procedure.
Protective equipment, sampling tools, and other equipment are usually
decontaminated by scrubbing with detergent water using a soft-bristle brush
followed by rinsing with a copious quantity of water. While this process
may not be fully effective in removing some contaminants (in some cases,
the contaminants may react with water), it is a relatively safe option
compared to the use of a decontaminating solution. The contaminant should
be identified before a decontamination chemical is used, as reactions of
the chemical with unidentified substances or mixtures could be hazardous or
more difficult to dispose. A decontamination solution should be selected
based on the recommendations of an experienced chemist.
10.5 - Standard Operating Procedures to Minimize Worker Contact
The minimization of worker contact with contaminants during decontamination
actually starts with Standard Operating Procedures (SOPs). Site workers
who use general safe work practices are less likely to be contaminated than
site workers who do not use these practices. Workers can take steps to
minimize their exposure during decontamination through using contact
minimization techniques such as:
* Remote handling,
* An outer layer of disposable clothing,
* Encasing tools/equipment in plastic, and.
* General safe work practices.
The HASP should incorporate all of the appropriate contact minimization
techniques addressed in the site-specific decontamination plan.
Once workers reach the decontamination line, they should strictly adhere to
proper doffing procedures. This includes minimizing contact (grabbing,
holding, touching, etc.) between contaminated site workers and
decontamination line workers.
10.6 - Collection, Storage and Disposal Procedures
All items (including clothing, equipment, liquids) used in the
decontamination procedure that cannot be completely decontaminated should
be considered radioactive, hazardous, or mixed waste, as appropriate.
Clothing and equipment should be collected, treated, stored, and disposed
of based on the type and level of contamination according to applicable
Federal, state and local regulations. Drainage and/or collection systems
for contaminated liquids should be established and approved containers
should be used. Wash water should be collected for proper disposal.
Procedures to contain contaminated water or decontamination fluids (i.e.,
collection of contaminated runoff, containment of overspray) should be
developed and included as part of the decontamination plan. Waste
minimization should be a consideration, secondary only to worker safety and
health protection requirements, when designing the decontamination
procedure.
10.7 - References
1. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
2. DHHS (NIOSH) Publication No. 85-115, "Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities," Chapter 10 and
Appendix B, Section I, NIOSH/OSHA/USCG/EPA, 1985 (Four-Agency Document).
3. DOE "Radiological Control Manual," Chapter 3, Part 7, "Construction and
Restoration Projects," June 1992.
4. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,"
Chapter 9, Office of Emergency and Remedial Response, USEPA, 1992.
5. EPA 9285.8-01, "Health and Safety Plan (HASP) User's Guide," Chapter 9,
Office of Emergency and Remedial Response, USEPA, 1992 (and ERT Health and
Safety Plan Planner, Ver. 3.0C, 1993).
6. "Resource Conservation and Recovery Act" (RCRA), 42 U.S.C. 6901.
7. "Toxic Substances Control Act (TSCA)" 15 U.S.C. 2601.
11.1 - Background
The site-specific Emergency Response/Contingency Plan, also referred to as
Emergency Response Plan (ERP), should be designed as a separate section of
the HASP and should be compatible and integrated with the disaster, fire,
and emergency response plans of local, state, and Federal agencies. Where
applicable, the plan should be coordinated with other DOE elements at the
installation. The purpose of the ERP is to protect workers in emergency
situations resulting from the release of all types of hazardous substances,
including Extremely Hazardous Substances, CERCLA hazardous substances, RCRA
hazardous wastes, and any substance listed by the U.S. Department of
Transportation as a hazardous material. The requirements for an ERP at
hazardous waste sites are codified in 29 CFR 1910.120. The ERP should be
developed and implemented prior to beginning site operations. Hazardous
waste site operations should not begin until the ERP is in place.
Sites with RCRA permitted treatment, storage, and disposal facilities for
hazardous waste, having the required contingency plan meeting the
requirements of their permit, would not need to duplicate the same planning
elements. Those items of the ERP that are properly addressed in the permit
contingency plan may be substituted into the ERP required by 29 CFR
1910.120.
The objective of this chapter is to describe the minimum required elements
of the ERP, which are as follows:
* Pre-emergency planning;
* Personnel roles, lines of authority, and communication;
* Emergency recognition and prevention;
* Safe distances and places of refuge;
* Site security and control;
* Evacuation routes and procedures;
* Decontamination procedures;
* Emergency medical treatment/first aid;
* Emergency alerting and response procedures;
* Critique of response and follow-up;
* PPE and emergency equipment; and
* Procedures for reporting incidents to local, state, and Federal
governmental agencies.
Elements identified above may require data that has already been created
and documented in other chapters of the HASP (i.e., site characterizations,
hazard assessments, maps, transportation routes, etc.). Copies of this
documentation should be incorporated into the ERP.
11.2 - Pre-Emergency Planning
The objective of pre-emergency planning is to be prepared to safely respond
to anticipated emergencies prior to commencement of hazardous waste
operations. Additionally, 29 CFR 1910.120(1)(3)(B)(iii) establishes
pre-planning to ensure that the ERP is compatible and integrated with the
disaster, fire, and/or emergency response plans of local, state, and
Federal agencies.
To ensure the complete integration of emergency response activities with
outside organizations, this section of the ERP should include the
following:
* An explanation of the relationship between site organizations and
local governmental response agencies (e.g., host, county, state);
* A list of all emergency plans affecting the site;
* A description of the relationship between this plan and other plans
affecting the site;
* A description of the ways in which all ERPs are integrated with
local response plans;
* A description of the function and responsibilities of all local
response organizations at the site (e.g., public and private
sectors, volunteer organizations, and charitable organizations); and
* A listing of all mutual agreements and other arrangements for
sharing data and response resources.
The following technical items should be considered during pre-planning and
included in this section of the ERP:
* Scenarios for potential credible accidents which may take place
during site operations or along transportation routes;
* Operations at the site that possess hazardous substances/activities
and the transportation routes along which these substances should
move;
* Other facilities/activities which may contribute to the overall
site risk;
* Site topography, layout, and prevailing weather conditions;
* Potential off-site impacts [e.g., special populations (infants,
the aged) and sensitive institutions (hospitals, schools, daycare
center)]; and
* ERP rehearsals and drills.
The ERP should be reviewed and revised on a regular basis.or as necessary,
by the Site Safety and Health Officer (SSHO). This will ensure the plan is
adequate and consistent with prevailing site conditions.
11.3 - Personnel Roles, Lines of Authority, and Communications
This section of the ERP, used in conjunction with Chapter 2, Key Personnel,
should identify and define the roles of all personnel, organizations, and
teams, both onsite and offsite, who will participate in emergency response.
Local, state, and Federal response organizations with oversight
responsibility should be identified and an explanation included for
integration and coordination into a single, workable response plan.
Depending upon the nature and scope of the emergency, the size of the site,
and the number of personnel, emergency response may require small or large
teams, or several interacting teams. In all cases, the organizational
structure should:
* Show a clear chain-of-command,
* Ensure every person knows his/her position and authority,
* Be flexible enough to handle multiple emergencies, and
* Clearly identify specific roles and responsibilities.
11.3.1. Facility Emergency Coordinator
The Facility Emergency Coordinator assumes primary responsibility for
responding to and coordinating emergency situations. This includes taking
appropriate measures to ensure the safety of site personnel and the public.
Possible actions may involve evacuation of personnel from the site area and
evacuation of adjacent residents. The Facility Emergency Coordinator is
additionally responsible for implementing corrective measures, notification
of appropriate authorities, and completion of follow-up reports. The SSHO
may be called upon to act on the behalf of the Facility Emergency
Coordinator, and direct responses to any medical emergency. Individual
contractor organizations are responsible for assisting the Facility
Emergency Coordinator and/or SSHO in his/her mission within the parameters
of their scope of work. These positions should be considered mandatory and
alternate(s) should be specified.
11.3.2. Emergency Contacts
A contact list should be developed for notification. This list should be
updated continually and made available to all emergency response personnel
and site employees (see example list in Table 11-1).
11.3.3. Reporting
Reporting requirements vary depending upon the type and severity of the
accident/incident. Procedures should be developed for reporting
accidents/incidents that occur at EM sites. These procedures are found in
the DOE 5000 Series Orders, and include notification requirements within
DOE, and to other Federal, state, and local organizations.
TABLE 11-1
Emergency Contacts and Phone Numbers
Organization Contact Telephone
--------------------------------------------------------------------
Ambulance:
Police:
Fire:
State Police:
Hospital 1:
Hospital 2:
Poison Control Center:
Regional EPA:
EPA Emergency Response 908-321-6660
Team:
State Authority:
National Response Center: 800-424-8802
Center for Disease Control: 404-488-4100
Chemtrec: 800-424-9555
Site Emergency Operations
Center:
DOE Emergency Operations 202-896-8100
Center (National Center):
11.3.4. Emergency Communications
Communications systems to be used for internal and external communications
during an emergency should be described including types and combinations of
systems, their use, and back-up systems.
An internal network of communications should be developed to alert workers
to danger, convey safety information, and maintain site control. Any
effective system or combination of systems may be employed. External
communications systems and procedures should be clear and accessible to all
workers. All personnel should be familiar with the protocol for
communication systems.
11.4 - Emergency Recognition and Prevention
A system to alert personnel to potentially hazardous situations should be
established. Site briefings should be held as necessary to brief all
employees of new developments, tasks, and hazards associated with work at
the site. These briefings should include:
* Tasks to be performed;
* Specific chemical and physical hazards that may be encountered,
including their effects, how to recognize symptoms or monitor them,
concentration limits, or other danger signals;
* Transportation routes along which hazardous substances move;
* Additional hazards as a direct result of site activities, as well
as prevention and control techniques/mechanisms; and
* Emergency procedures.
Personnel should be familiar with techniques of hazard recognition from
pre-assignment training and site-specific briefings.
Personnel should also be knowledgeable of the fire hazards associated with
the materials and processes to which they are exposed. Details on fire
prevention planning are provided in Chapter 12, of this guidance document.
11.5 - Safe Distances and Places of Refuge
The requirements for determining safe distances and places of refuge at a
specific site should be established. This section should consider the
amount and type of substance(s) at the site as well as the potential impact
on workers and the public. Safe distances should be estimated based on
emergency scenarios developed during the pre-planning phase. Actual safe
distances can only be established at the time of an emergency, based on a
combination of site-specific and incident-specific factors. Some factors
that may need to be considered are:
* The toxicological/radiological properties of the substance,
* The physical state of the substance,
* The quantity and rate of release,
* The method of release,
* The atmospheric conditions, and
* Local topography.
Onsite refuges should be identified and provided with proper equipment for
localized emergencies not requiring site evacuation. Examples of equipment
a refuge might contain are:
* Water for decontamination,
* Communications network with site emergency operations center,
* Emergency personal protection equipment,
* First-aid supplies,
* Required special monitoring devices, and
* Fire extinguisher.
11.6 - Site Security and Control
In an emergency, the Facility Emergency Coordinator should ascertain who is
on site, and control the entry of personnel into hazardous areas. In an
emergency, as in daily work activities, the site should be divided into
three areas: Exclusion Zone, Contamination Reduction Zone, and Support
Zone. Only necessary rescue and response personnel should be allowed into
the Exclusion Zone. A personal locator system should be used to locate all
personnel on site. Checkpoints (or a series of checkpoints) should be
established through which all personnel entering or exiting the emergency
site should pass. Checkpoint information should include:
* Name (affiliation),
* Time of entry/exit,
* Zones or areas to be entered,
* Tasks to be performed, and
* Protective equipment worn and air time remaining.
11.7 - Evacuation Routes / Procedures
Primary and alternate routes should be established for evacuating victims
and endangered personnel. Routes should be directed from the Exclusion
Zone, through an upwind Contamination Reduction Corridor to a Support Zone,
then to an offsite location.
The following guidelines should be used to assist in establishing safe
emergency evacuation routes and developing procedures for their use:
* Place evacuation routes predominately upwind from the Exclusion Zone;
* Run evacuation routes through the Contamination Reduction Zone;
* Consider the accessibility of potential routes;
* Develop two or more routes, separate from each other;
* Clearly mark all evacuation routes;
* Check clearances of access ports, crawlspaces, hatches, manholes,
tunnels, etc., to ensure personnel wearing PPE can get through; and
* Establish a routine for ensuring all evacuation routes are kept clear.
A map should be provided which depicts evacuation routes for the site and
immediate area. Assembly areas and safe distances in the event of a major
incident should also be included. This information should be included in
the overall training program.
11.8 - Decontamination Procedures
This section specifically addresses decontamination procedures necessary in
emergency response situations. If the general Decontamination section of
the HASP adequately addresses emergency response decontamination, that
section may be reproduced and inserted into the ERP section of the HASP.
Additional emergency decontamination procedures should be developed if
appropriate.
The following items should be considered when developing emergency
decontamination procedures:
* Decontamination of ill or injured personnel,
* Reporting of all injuries and illnesses to the Project Manager,
* Protection of emergency medical personnel,
* Decontamination and/or disposal of contaminated protection equipment
and contaminated solutions,
* Providing specific decontamination procedures to a clinic or
hospital treating ill or injured personnel, and
* Decontamination of emergency equipment.
11.9 - Emergency Medical Treatment / First Aid
In emergencies, toxic exposures and hazardous situations that cause
injuries and illnesses will vary from site to site. Medical treatment may
range from bandaging of minor cuts and abrasions to life-saving techniques.
In many cases, essential medical help may not be immediately available.
For this reason, it is vital to train onsite emergency personnel in
on-the-spot treatment techniques, to establish and maintain telephone
contact with medical experts (e.g., physicians, toxicologists), and to
establish liaisons with local hospitals and ambulance services. When
designing this program, the following should be included:
* Training of personnel in emergency treatment such as first aid and
CPR,
* Establishing liaison with local medical personnel,
* Informing and educating local medical personnel about site-specific
hazards, and
* Establishing onsite emergency first-aid stations.
11.10 - Emergency Alerting / Response Procedures
Requirements should be established for developing procedures which alert
onsite personnel to the emergency, activate the onsite emergency response
team, and establish the actions to be taken by emergency response
personnel. Procedures contained in this section should comply with
requirements for employee alarm systems as specified at 29 CFR 1910.165.
If physically impaired individuals are employed at the site, alternate
alarm methods may be necessary.
11.10.1. Notification
When notifying onsite emergency response personnel, all available
information on the incident should be provided. This may include:
* Location,
* Time of occurrence,
* Description of incident (including contaminants involved),
* Injuries or fatalities,
* Extent of damage,
* Actions taken, and
* Identified response needs.
11.10.2. Evaluation of the Situation
As quickly as possible, available information about the incident and
emergency response capabilities should be evaluated by the Facility
Emergency Coordinator and the Emergency Response Team. The following
information should be determined, to the extent possible:
What happened:
* Type of incident;
* Cause of incident;
* Extent of chemical release and transport; and
* Extent of damage to structures, equipment, and terrain.
Casualties:
* Victims (number, location, and condition);
* Treatment required; and
* Missing personnel.
What could happen?
* Types of chemicals on site;
* Potential for fire, explosion, and release of hazardous substances;
* Location of all personnel on site relative to hazardous areas; and
* Potential for danger to offsite population or environment.
What can be done?
* Equipment and personnel resources needed for victim rescue and
hazard mitigation;
* Number of uninjured personnel available for response;
* Resources available on site;
* Resources available from outside groups and agencies;
* Time for outside resources to reach the site; and
* Hazards involved in rescue and response.
11.10.3. Rescue/Response Action
Based on the available information, the type of action required should be
determined and the necessary steps implemented. Some actions may be done
concurrently. No one should attempt emergency response or rescue until
back-up personnel and evacuation routes have been identified.
Rescue/response actions include:
* Enforce the buddy system;
* At all times, retain personnel in the Exclusion Zone in
line-of-sight or communications contact with the Command Post
Supervisor or designee;
* Locate all victims and assess their condition;
* Determine resources needed for stabilization and transport;
* Assess existing and potential hazards to site personnel and to
the offsite population;
* Allocate onsite personnel and equipment to rescue and incident
response operations;
* Contact the needed offsite personnel or facilities, such as the
ambulance, fire department, and police;
* Bring the hazardous situation under complete or temporary control,
and use measures to prevent the spread of the emergency;
* Remove or assist victims from the area;
* Use established procedures to decontaminate uninjured personnel
in the Contamination Reduction Zone, or if the emergency makes
this area unsafe, establish a new decontamination area at an
appropriate distance;
* Administer any medical procedures that are necessary to stabilize
victims before moving;
* Stabilize or permanently fix the hazardous condition, and attend
to the cause of the emergency and anything damaged or endangered
by the emergency;
* Take measures to minimize contamination of the victims,
transport vehicle(s) and ambulance and hospital personnel; and
* Move site personnel to a safe distance upwind of the incident,
monitor the incident for significant changes, and take additional
actions to protect personnel, if necessary.
11.11 - Critique of Response and Follow-up
11.11.1. Critique
Review the incident and revise all aspects of the ERP according to new site
conditions and lessons learned from the emergency response. When reviewing
the information, consider typical questions such as:
* What caused the emergency?
* Was it preventable? If so, how?
* Were procedures for prevention of the emergency adequate? If not,
how can they be improved?
* Were all phases of the response adequate? How could it have been
improved?
* How did the incident affect the site profile? How were other site
cleanup activities affected?
* Was the public safety protected?
11.11.2. Maintaining Readiness
Before normal site activities are resumed, personnel should be fully
prepared and equipped to handle another emergency. Also, equipment and
supplies should be restocked, damaged equipment should be repaired or
replaced, and equipment should be cleaned and refueled for future use. A
regular schedule should be established for testing and inspecting emergency
equipment and systems.
11.12 - PPE and Emergency Equipment
An up-to-date list of all emergency equipment should be maintained.
Personal Protective Equipment (PPE) should be selected, sized, fitted,
maintained and used in accordance with the PPE section of the site-specific
HASP. Additionally, PPE training should be conducted as specified in the
HASP training section. Individuals should receive required PPE training
prior to being allowed to perform work on site. A map that shows the
location of emergency equipment should be made readily available to all
personnel.
Specific procedures for the maintenance, fueling, parking, and availability
of regular equipment, which doubles as emergency equipment, should be
developed. Adoption of the following work procedures should be considered:
* Refuel all heavy equipment once the tanks have been lowered to
one-half to one-quarter tank;
* Require equipment repairs to take place upon discovery;
* Park similar pieces of heavy equipment (e.g., bulldozers, trucks,
forklifts) in separate locations, and do not use them at the same
location at the same time;
* Inspect all emergency equipment at each shift change; and
* Ensure all equipment operators are thoroughly briefed on the
procedures and requirements for relinquishing vehicles to
emergency response personnel.
The basic emergency equipment and supplies, shown in Table 11-2, should be
made available at the site, as required.
TABLE 11-2
Emergency Equipment and Supplies
Personal Protection
---------------------------------------------------------------------
* Escape SCBA or SCBA, which can be brought to the victim to replace
or supplement his or her SCBA
* PPE and clothing specialized for known site hazards
Medical
---------------------------------------------------------------------
* Air splints
* Antiseptics
* Blankets
* Decontamination solutions appropriate for onsite chemical hazards
* Emergency eye wash
* Emergency showers or wash stations
* First aid kits
* Ice
* Reference books containing basic first-aid procedures and information
on treatment of specific chemical injuries
* Resuscitator
* Safety harness
* Stretchers
* Water, in portable containers
* Wire basket litter (stokes litter) which can be used to carry a victim
in bad weather and on difficult terrain, allows easy decontamination
of the victim, and is itself easy to decontaminate
Response Equipment
---------------------------------------------------------------------
* Fire-fighting equipment and supplies
* Spill-containment equipment, such as absorbents and oil booms
* Special hazardous-use tools such as remote pneumatic impact
wrenches, nonsparking wrenches and picks
* Containers to hold contaminated materials including overpacks
* Communication equipment such as public, site, and mobile phones,
two-way radios
* Sampling equipment including air monitors, such as Combustible Gas
Indicators, Photoionization Detectors
Special equipment should be obtained depending upon the specific types of
emergencies which may occur, and the capabilities of response personnel.
When determining the type and quantities of special equipment, the
following factors should be considered:
* The number and qualifications of response personnel;
* The worst case emergency scenario;
* Type of hazards, mitigation, containment, and protective measures;
* Capabilities and response times of offsite response personnel; and
* Number of possible victims.
11.13 - References
1. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
2. 29 CFR 1910.165, "Employee Alarm Systems."
3. 29 CFR 1910.1000, "Air Contaminants."
4. DHHS (NIOSH) Publication No. 85-115, "Occupational Safety, and Health
Guidance Manual for Hazardous Waste Site Activities," NIOSH/OSHA/USCG/EPA,
1985 (Four-Agency Document).
5. DOE 5483.XX, "Occupational Safety and Health Program for DOE Contractor
Employees (Draft)."
6. DOE Order 5000.3B, "Occurrence Reporting and Processing of Operations
Information."
7. DOE 5500.1B, "Emergency Management System."
8. DOE 5500.2B, "Emergency Categories, Classes, and Notification and
Reporting Requirements."
9. DOE 5500.3A, "Planning and Preparedness for Operational Emergencies."
10. DOE 5500, 4A, "Public Affairs Policy and Planning Requirements for
Emergencies."
11. DOE 5500.5A, "Public Affairs Policy and Planning Requirements for a
Fuel Supply Disruption Emergency."
12. DOE 5500.6B, "Shutdown of Departmental Operations Upon Failure by
Congress to Enact Appropriations."
13. DOE 5500.7B, "Emergency Operating Records Protection Program."
14. DOE 5500.8A, "Energy Emergency Planning and Management."
15. DOE 5500.9A, "Emergency Planning, Preparedness, and Response to
Continuity of Government Emergencies."
16. DOE 5500.10, "Emergency Readiness Assurance Program."
17. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,"
Office of Emergency and Remedial Response, US EPA, 1992.
18. NFPA, "Hazardous Materials Emergency Response Handbook," 1992.
12.1 - Background
Not all EM-40 sites have the organizational capability for responding to
emergencies. Most organizations at EM-40 sites should, in fact, evacuate
employees and only perform such activities as emergency shut-down or first
aid/CPR. Therefore, it is not necessary for these sites to prepare an
emergency response plan. Instead, these sites should prepare an Emergency
Action Plan (EAP) that meets the requirements of 29 CFR 1910.38(a).
The EAP should describe those actions to be taken to assure safety from
fire, hurricanes, blizzards, toxic chemical releases, floods, and other
emergencies. The Plan should be totally integrated and coordinated with
the landlord's emergency response plan, and should contain, at a minimum,
the following elements:
* Emergency escape procedures, and emergency escape route assignments;
* Procedures to ensure that all contractors on site coordinate their
EAPs to prevent conflicts and confusion;
* Procedures to be followed by personnel who stay behind to conduct
critical operations (i.e., shutdown) before they evacuate;
* Procedures to account for all employees after emergency evacuation
has been completed;
* Rescue and medical duties (first aid, CPR, etc.) for those
individuals who are to perform them;
* Methods for reporting fires and other emergencies;
* Names and phone numbers of personnel and organizations to be
contacted for further information or explanation of duties under
the Plan;
* Alarm system to be used to alert personnel to the emergency/evacuation;
* Training each employee should receive in order to effectively carry
out the requirements of the EAP, and the methods for evaluating
employee knowledge of the plan;
* Fire prevention plan; and
* Procedures for the review and update of the Plan (e.g., schedule,
rehearsal).
12.2 - Emergency Escape Route Assignment
This section of the EAP should contain the information necessary for the
safe, orderly evacuation of site employees. The contents of this section
should focus on the procedures for evacuation and the establishment of
emergency escape routes. Primary and alternate routes to be used for the
evacuation of personnel should be established. The following guidelines
should be used in establishing safe emergency evacuation routes:
* Routes should be directed from the Exclusion Zone, through an upwind
Contamination Reduction Zone to a Support Zone, and from the Support
Zone to an offsite location, should conditions require a general
site evacuation;
* Place direct evacuation routes predominately upwind from the
Exclusion Zone. In some cases, as at very large sites, some exits
may be placed in the downwind fenceline.
* Workers should be informed during training that they are not safe
until they have reached the designated safety area;
* Establish evacuation routes through the Contamination Reduction
Zone. This should allow a mechanism for accountability of all
personnel, even if there is not enough time to process evacuees
through decontamination;
* Consider the accessibility of potential routes. Obstructions such
as locked gates, trenches, pits, drums, tanks, and other barriers
should be considered, as well as the additional time and equipment
needed to maneuver around or through them;
* Develop two or more routes, separate from each other, which lead
to safe areas. Ensure that routes do not overlap or intersect;
* Mark routes as "safe" or "not safe" on a daily basis, depending
on wind direction and other conditions at the site; and
* Mark all evacuation routes. No unsafe routes should be used for
evacuation (e.g., low ground, streams, trenches).
Consider mobility limitations for personnel wearing PPE and other emergency
equipment including:
* Develop procedures to use ladders and other material to traverse
hazardous terrain (e.g., ditches, heights, trenches); and
* Check clearances of access ports, crawlspaces, hatches, manholes,
tunnels, to ensure personnel wearing protective equipment can get
through.
A routine should be established for ensuring all evacuation routes are kept
clear. In the event of an emergency which necessitates an evacuation of
the site, a procedure similar to the one below should be used.
* Make evacuation alarm notification supplemented by the use of hand
held radios. All personnel should evacuate upwind of any activities
along established "safe" evacuation routes. Proceed to the
predetermined location so that all personnel can be accounted for;
and
* Ensure that personnel proceed to the closest exit with their buddy,
and proceed to the safe distance area associated with the evacuation
route. Personnel should remain at that area until the re-entry
alarm is sounded or an authorized individual provides further
instructions.
A map should be provided which depicts evacuation routes for the site and
immediate area. In the event of a major incident, assembly areas and safe
distances should also be indicated on the map.
12.3 - Procedures for Critical Operations Personnel
Procedures should be developed which clearly identify critical operations,
critical operations personnel, and actions required of those personnel
performing critical operations during site evacuation. This section should
contain:
* A listing of all critical operations, the personnel assigned to
perform them, and the procedure for updating the listing;
* A description of any additional training requirements for
designated personnel;
* A step-by-step procedure to complete the critical tasks;
* Estimated time required for the employee to complete the assigned
critical tasks;
* Procedures for delayed evacuation (if different from normal
evacuation procedures),
* Procedures for reporting to the designated safe area; and
* Procedures for emergency communications during the conduct of
critical tasks and delayed evacuation.
12.4 - Procedures to Account for All Employees
Procedures should be developed which account for all personnel immediately
following an evacuation. These procedures should:
* Contain the requirements to account for and report the number of
personnel evacuated,
* Provide a means for notifying the SSHO and emergency personnel when
employees are missing, and
* Include procedures for accounting for personnel performing critical
operations.
12.5 - Rescue and Medical Duties
Personnel may need to perform life saving CPR or emergency first aid prior
to the arrival of the local emergency personnel (e.g., fire, medical,
rescue teams). This section of the EAP should describe the actions to be
taken by site personnel with first aid/CPR responsibilities. At a minimum,
this section should contain:
* A current listing of all personnel with first aid/CPR duties,
* Training requirements for personnel with first aid/CPR duties,
* Description of conditions under which employees perform first aid/CPR,
* Description of medical and rescue duties taken until the arrival
of the emergency response personnel,
* Procedures for notifying emergency personnel, and
* Procedures for reporting the incident to the appropriate personnel.
12.6 - Reporting Fires and Other Emergencies
All personnel at the site should be knowledgeable regarding the means by
which emergencies are reported. This section of the EAP should contain the
information needed for personnel to report fires and other emergencies at
the site. At a minimum, this section should contain:
* A description and location of communications equipment available at
the site for emergency reporting,
* Procedures for the use of site communications equipment,
* Procedures for reporting the emergency, and
* Complete listing of emergency telephone numbers, radio frequencies,
emergency signals, etc.
12.7 - EAP Contact Personnel
A list of primary and alternate key personnel should be developed which
identifies individuals and organizations with the expertise to explain and
provide technical information on the use of the EAP. These
personnel/organizations, and applicable alternates, should be listed by
name, title, and telephone number. This list should be continually updated
and made available to all employees and visitors. Additionally, the list
should include the names and addresses of site safety personnel and their
alternates (e.g., Project Manager, SSHO).
12.8 - Emergency / Evacuation Alarm System
This section should contain a complete description of all alarms and
signals (and related back-up systems) to notify personnel of an emergency.
All applicable alarms and signals (e.g., evacuation, radiation, take cover,
standard alert), as well as, the actions to be taken in the event the alarm
is sounded should be fully explained. Alarm systems and back-up systems
should be in compliance with 29 CFR 1910.165.
12.9 - EAP Training Requirements
Each employee at the site should be properly trained in all aspects of the
EAP. Additionally, critical operations personnel or those personnel with
first aid/CPR responsibilities should receive additional training necessary
to effectively carry out their duties. This training should be conducted
and documented in accordance with the training section of the site-specific
HASP.The following items in this section of the EAP should be performed and
documented:
* Designate and train a sufficient number of persons to assist in
the safe and orderly emergency evacuation of employees,
* Identify critical operations and designate and train a sufficient
number of persons to conduct those operations,
* Train all personnel working at the site in evacuation and other
required emergency procedures, as applicable,
* Provide a listing of all required training to be completed prior to
beginning work, and
* Coordinate unique training requirements with the SSHO and provide a
description of all required training not covered by the training
section of the HASP.
All personnel should receive required training prior to beginning work at
the site. The methods for evaluating personnel competency in carrying out
the requirements of the EAP should be reviewed with each individual covered
by the Plan at the following times:
* Initially, when the plan is developed,
* Upon initial assignment,
* Whenever the employee's responsibilities or designated actions under
the plan change, and
* Whenever the plan is changed.
12.10 - Fire Prevention Plan
This section should contain procedures that reduce the vulnerability of the
workplace to fire. Fire prevention plan requirements are specified by OSHA
in 29 CFR 1910.38 and include discussions of housekeeping, training and
maintenance. The plan should be updated as hazards change. In addition to
the categories listed above, the plan should include:
* A list of the major workplace fire hazards,
* Names or titles of personnel responsible for the control of
workplace hazards,
* List of types of fire protection equipment or systems and the
hazards they control, and
* Pre-fire planning in coordination with the local emergency response
services to familiarize them with workplace process hazards.
The fire prevention plan discussion satisfies part of the administrative
requirements of an overall Fire Protection Program as outlined in DOE Order
5480.7A, Fire Protection. This section of the HASP should ensure that all
requirements of DOE 5480.7A are followed or integrated into the HASP.
12.10.1. Housekeeping
Procedures should be developed to control accumulations of material and
residues so that they are not the source of a fire emergency. Fire
prevention housekeeping plans include:
* Proper handling, storage and control procedures for flammable and
combustible waste materials;
* List of potential ignition sources (e.g., welding) and their control
procedures; and
* Housekeeping procedures that maintain the means of egress free of
obstructions.
12.10.2. Training
Personnel should be informed of the fire hazards associated with the
materials and processes to which they are exposed. Personnel should be
trained on response procedures for fires. For example, in addition to
evacuation, personnel may be expected to use fire extinguishing equipment
and/or activate manual alarms.
12.10.3. Maintenance
Proper maintenance, inspection and testing of fire protection equipment and
systems are key to eliminating or controlling fire development. Equipment
should be maintained according to manufacturers' specifications. In
addition, National Fire Protection Association (NFPA) 25, Inspection,
Testing and Maintenance of Water-Based Fire Protection System and other
NFPA codes covering the particular equipment or device should be consulted.
Whether maintenance is performed in-house or contracted, the individuals
performing the work should be properly trained. Names or titles of
personnel responsible for maintenance should be kept on file. Maintenance,
inspection and testing procedures apply to:
* Equipment installed to detect fuel leaks, control heating, and
control pressurized systems (e.g., flame arresters on furnaces,
high temperature/pressure switches on dip tanks);
* Portable extinguishers, automatic sprinkler systems and fixed
extinguishing systems (e.g., sprinkler control valves, fire pumps);
* Detection systems for smoke, heat, or flame;
* Fire alarm and annunciation systems; and
* Emergency back up systems and the equipment they support.
12.11 - Procedures for the Review and Update of the EAP
This section should contain the procedures to review and update the EAP.
As a minimum, this section should describe procedures for:
* The periodic review/update of the plan;
* Training employees on the latest changes to the plan; and
* Coordinating and integrating the latest version of the EAP with the
HASP, site emergency response organizations, and the host ERP (if
applicable).
12.12 - References
1. 29 CFR 1910.38, "Employee Emergency Plans and Fire Prevention Hazards."
2. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
3. 29 CFR 1910.165, "Employee Alarm Systems."
4. DOE Order 5000.3B, "Occurrence Reporting and Processing of Operations
Information."
5. National Fire Protection Association (NFPA) 25, "Inspection, Testing
and Maintenance of Water-Based Fire Protection Systems."
13.1 - Background
A confined space is defined as any location that has limited openings for
entry and egress, is not intended for continuous employee occupancy, and is
so enclosed that natural ventilation may not reduce air contaminants to
levels below the threshold limit value (TLV). Examples of confined spaces
include: manholes, stacks, pipes, storage tanks, trailers, tank cars, pits,
sumps, hoppers, and bins. Entry into confined spaces without the proper
precautions could result in injury and/or impairment or death due to:
* An atmosphere that is flammable or explosive,
* Lack of sufficient oxygen to support life,
* Contact with or inhalation of toxic materials, or
* General safety or work area hazards such as steam or high
pressure materials.
The overall objectives of this chapter are to provide the minimum safety
requirements to be followed while entering, exiting and working in confined
spaces during environmental restoration work. This chapter provides
pertinent details on the following:
* Duties and responsibilities,
* Identification and evaluation,
* Hazard assessment,
* Hazard controls,
* Entry permits,
* Entry procedures,
* Opening a confined space,
* Atmospheric testing,
* Isolation and lockout/tagout safeguards,
* Ingress/egress safeguards,
* Warning signs and symbols,
* Training, and
* Emergency response.
13.2 - Duties and Responsibilities
13.2.1. Project Manager
The Project Manager should assign an individual within each project to act
as the project Confined Space Coordinator. This individual should be
responsible for implementing the confined space program in accordance with
this chapter.
13.2.2. Confined Space Coordinator
The Confined Space Coordinator should be responsible for implementing the
confined space program and should:
* Ensure that a list of confined spaces is maintained,
* Ensure that cancelled permits are reviewed for lessons learned,
* Ensure training of personnel is conducted,
* Ensure coordination with outside responders,
* Ensure equipment is in compliance with standards, and
* Maintain a master inventory of identified confined spaces.
13.2.3. Field Team Leader
The Field Team Leader in charge of any confined space work should:
* Ensure requirements for entry have been completed before entry
is authorized;
* Ensure confined space monitoring is performed by personnel
qualified and trained in confined space entry procedures;
* Ensure a list of monitoring equipment and personnel qualified
to operate the equipment is maintained by the Safety and
Occupational Health Office;
* Ensure that the rescue team has simulated a rescue in a confined
space within the past twelve months;
* Know the hazards that may be faced during entry, including the
mode, signs or symptoms, and consequences of exposure;
* Fill out a permit;
* Determine the entry requirements;
* Require a permit review and signature from the authorized
entry supervisor;
* Notify all involved employees of the permit requirements;
* Post the permit in a conspicuous location near the job;
* Renew the permit or have it reissued as needed (a new permit is
required every shift);
* Determine the number of attendants required to perform the work;
* Ensure the attendant knows how to communicate with the entrants
and how to obtain assistance;
* Post any required barriers and signs;
* Remain alert to changing conditions that might affect the
conditions of the permits, (i.e., require additional atmospheric
monitoring or changes in personal protective equipment);
* Change and reissue the permit, or issue a new permit as necessary;
* Ensure periodic atmospheric monitoring is done according to permit
requirements;
* Ensure that personnel doing the work and all support personnel
adhere to permit requirements;
* Ensure the permit is canceled when the work is done; and
* Ensure the confined space is safely closed and all workers are
cleared from the area.
13.2.4. Entry Supervisors
An Entry Supervisor is a qualified person authorized to approve confined
space entry permits. This person should be responsible for:
* Determining if conditions are acceptable for entry,
* Authorizing entry and overseeing entry operations,
* Terminating entry procedures as required,
* Serving as an attendant, as long as the person is trained and
equipped appropriately for that role,
* Ensuring measures are in place to keep unauthorized personnel clear
of the area,
* Checking the work at least twice a shift to verify and document
permit requirements are being observed (more frequent checks should
be made if operations or conditions are anticipated that could
affect permit requirements),
* Ensuring that necessary information on chemical hazards is kept at
the work site for the employees or rescue team,
* Ensuring a rescue team is available and instructed in their rescue
duties (e.g., an onsite team or a prearranged outside rescue
service), and
* Ensuring at least one member of the rescue team has current
certification in first aid and CPR.
13.2.5. Employees Entering Confined Space
Employees who are granted permission to enter a confined space should:
* Read and observe the entry permit requirements;
* Stay alert to the hazards that could be encountered in a confined
space;
* Use the protective equipment required by the permit;
* Immediately exit the confined space when:
- Ordered to do so by the attendant,
- Automatic alarms sound,
- They perceive they are in danger, or
- They notice physiological stresses or changes in themselves or
co-workers (e.g., dizziness, blurred vision, shortness of breath).
13.2.6. Attendant
The Attendant should be stationed outside the work space and should:
* Be knowledgeable of, and be able to recognize potential confined space ha
zards;
* Maintain a sign-in/sign-out log with a count of all persons in the
confined space and ensure all entrants sign in/sign-out;
* Monitor surrounding activities to ensure the safety of personnel;
* Maintain effective and continuous communication with personnel
during confined space entry, work and exit;
* Order personnel to evacuate the confined space if he/she:
- Observes a condition which is not allowed on the entry permit;
- Notices the entrants acting strangely, possibly as a result of
exposure to hazardous substances;
- Notices a situation outside the confined space which could
endanger personnel;
- Notices within the confined space a hazard which has not been
previously recognized or taken into consideration;
- Must leave his/her work station; or
- Must focus attention on the rescue of personnel in some other
confined space that he/she is monitoring;
* Immediately summon the Rescue Team if crew rescue becomes
necessary; and
* Keep unauthorized persons out of the confined space, order them out,
or notify authorized personnel of the unauthorized entry.
13.2.7. Rescue Team
The Rescue Team members should:
* Complete a training drill using mannequins or personnel in a
simulation of the confined space prior to the issuance of an entry
permit for any confined space and at least annually thereafter;
* Respond immediately to rescue calls from the Attendant or any other
person recognizing a need for rescue from the confined space;
* In addition to emergency response training, receive the same
training as that required of the authorized entrants; and
* Have current certification in first-aid and CPR.
13.3 - Identification and Evaluation
The Project Manager should ensure a survey is conducted of the work site to
identify confined spaces. This survey can be partially completed from
initial and continuing site characterizations, as well as other available
data (e.g. blueprints, job safety analysis). The purpose of the survey is
to develop an inventory of those locations and/or equipment that meet the
definition of a confined space. This information should be communicated to
personnel and appropriate procedures developed prior to entry. The initial
surveys should include air monitoring to determine the air quality in the
confined spaces. The following situations should be evaluated by competent
personnel:
* Flammable or explosive potential,
* Oxygen deficiency, and
* Presence of toxic and corrosive material.
13.3.1. Hazard Re-Evaluation
The Project Manager should ensure the identification and re-evaluation of
the hazards based on possible changes in activities, and/or other physical
or environmental conditions, which could adversely affect work. A master
inventory of confined spaces should be maintained. Any change in
designation of a confined space will be routed through the Site Safety and
Health Officer (SSHO) for review, prior to the change being made.
13.4 - Hazard Assessment
A hazard assessment should be completed prior to any entry into a confined
space. The hazard assessment should identify the sequence of work to be
performed in the confined space, the specific hazards known or anticipated,
and the control measures to be implemented to eliminate or reduce each of
the hazards to an acceptable level. No entry should be permitted until the
hazard assessment has been reviewed and discussed by all persons engaged in
the activity. Personnel who enter confined spaces should be informed of
known or potential hazards associated with the confined spaces to be
entered.
13.5 - Hazard Controls
Hazard controls include changes in the work processes and/or working
environment with the objective of:
* Controlling the health hazards either by eliminating the
responsible agents,
* Reducing health hazards below harmful levels, and
* Preventing the contaminants from coming into contact with the workers.
The following order of precedence should be followed in reducing confined
space risks:
* Engineering controls, such as ventilation to limit exposure to
hazards;
* Work practice controls, such as wetting of hazardous dusts, frequent
cleaning; and
* Use of PPE, such as air purifying or supplied-air respirators.
13.5.1. Engineering Controls
Engineering controls are those controls which eliminate or reduce the
hazard through implementation of sound engineering practices.
Ventilation is one of the most common engineering controls used in confined
spaces. When ventilation is used to remove atmospheric contaminants from
the confined space, the space should be ventilated until the atmosphere is
within the acceptable ranges. Ventilation should be maintained during the
occupancy if there is a potential for the atmospheric conditions to move
out of the acceptable range. When ventilation is not possible or feasible,
alternate protective measures or methods to remove air contaminants and
protect occupants should be determined by the qualified person prior to
authorizing entry. Conditions regarding continuous forced air ventilation
should be used as follows:
* Employees should not enter the space until the forced air ventilation
has eliminated any hazardous atmosphere,
* Forced air ventilation should be so directed as to ventilate the
immediate areas where an employee is or will be present within the
space,
* Continuous ventilation is maintained until all employees have left
the space, and
* Air supply for forced air ventilation should be from a clean source.
13.5.2. Work Practice (Administrative) Controls
Work practice (administrative) controls are those controls which eliminate
or reduce the hazard through changes in the work practice (e.g., rotating
workers, reducing the amount of worker exposure, housekeeping). Confined
spaces should be cleaned/decontaminated of hazardous materials to the
extent feasible before entry. Cleaning/decontamination should be the
preferred method of reducing exposure to hazardous materials. Where this
is not practicable, PPE should be worn by the entry personnel to provide
appropriate protection against the hazards which may be present.
13.5.3. Personal Protective Equipment (PPE)
If the hazard cannot be eliminated or reduced to a safe level through
engineering and/or work practice controls, PPE should be used. A qualified
person should determine PPE needed by all personnel entering the confined
space, including rescue teams. PPE which meet the specifications of
applicable standards should be selected in accordance with the requirements
of the job to be performed.
13.6 - Entry Permits
The Confined Space Entry Permit is the major tool in assuring safety during
entry in confined spaces with known hazards or with unknown or potentially
hazardous atmospheres. The entry permit process guides the supervisor and
workers through a systematic evaluation of the space to be entered. The
permit should be used to establish appropriate conditions. Before each
entry into a confined space, an entry permit will be completed by a
qualified person and the contents communicated to all employees involved in
the operation and conspicuously posted near the work location. A standard
entry permit should be used for all entries.
^L13.6.1. Key Elements for Entry Permits
A standard entry permit should contain the following items:
* Permit space to be entered;
* Purpose of the entry;
* Date of the permit and the authorized duration of the entry permit,
* Name of authorized entrants within the permit space;
* Means of identifying authorized entrants inside the permit space,
e.g., rosters or tracking systems;
* Personnel, by name, currently serving as attendants,
* Individual, by name, currently serving as entry supervisor, with a
space for the signature or initials of the entry supervisor who
originally authorized entry,
* Hazards of the permit space to be entered,
* Measures used to isolate the permit space and to eliminate or
control permit space hazards before entry, e.g., lockout or tagout
of equipment and procedures for purging, inerting, ventilating, and
flushing permit spaces;
* Acceptable entry conditions,
* Results of initial and periodic tests performed, accompanied by the
names or initials of the testers and by an indication of when the
tests were performed;
* Rescue and emergency services that can be summoned and the means,
(e.g., equipment to use, phone numbers to call) for summoning those
services,
* Communication procedures used by authorized entrants and attendants
to maintain contact during the entry,
* Equipment to be provided for compliance with this section, (e.g.,
PPE, testing, communications, alarm systems, and rescue);
* Other information whose inclusion is necessary, given the
circumstances of the particular confined space, in order to ensure
employee safety; and
* Additional permits, such as for hot work, that have been issued to
authorize work in the permit space.
Appendix D of 29 CFR 1910.146 provides an example permit containing these
items.
A permit is only valid for one shift. For a permit to be renewed, several
conditions should be met before each re-entry into the confined space.
First, atmospheric testing should be conducted and the results should be
within acceptable limits. If atmospheric test results are not within
acceptable limits, precautions to protect entrants against the hazards
should be addressed on the permit and should be in place. Second, a
qualified person should verify that all precautions and other measures
called for on the permit are still in effect. Finally only operations or
work originally approved on the permit should be conducted in the confined
space.
A new permit should be issued or the original permit reissued whenever
changing work conditions or work activities introduce new hazards into the
confined space. The employer should retain each cancelled entry permit for
at least one year to facilitate the review of the confined space entry
program. Any problems encountered during an entry operation should be
noted on the pertinent permit so that appropriate revisions to the confined
space permit program can be made.
13.7 - Entry Procedures
Whenever entry into a confined space is needed, either an Entry Supervisor
or the person in charge of the job may initiate entry procedures, including
the completion of a confined space entry permit. Entry into a confined
space should follow the standard entry procedure.
The following are requirements for standard entry:
* Training to establish personnel proficiency in the duties required,
* Atmospheric testing for entry, and
* Atmospheric monitoring during the entry.
Before an employee enters the space, the internal atmosphere should be
tested with a calibrated, direct-reading instrument. If a hazardous
atmosphere is detected during entry:
* The space should be evaluated to determine how the hazardous
atmosphere developed, and
* Measures should be implemented to protect employees before any
subsequent entry takes place.
Personnel should be prohibited from entering hazardous atmospheres without
wearing proper respiratory equipment as determined by qualified entry
supervisors. The entire confined space entry permit should be completed
for a standard entry. Entry should be allowed only when all requirements
of the permit are met and it is reviewed and signed by an Entry Supervisor.
13.8 - Opening a Confined Space
Any conditions making it unsafe to remove an entrance cover should be
eliminated before the cover is removed. When entrance covers are removed,
the opening should be promptly guarded by a railing, temporary cover, or
other temporary barrier that will prevent anyone from falling through the
opening. This barrier or cover should protect each employee working in the
space from foreign objects entering the space. If it is in a traffic area,
adequate barriers should be erected.
13.9 - Atmospheric Testing
Atmospheric test data is needed prior to entry into any confined space.
Atmospheric testing is required for two distinct purposes: evaluation of
the hazards of the permit space and verification that acceptable conditions
exist for entry into that space. If a person must go into the space to
obtain the needed data, then Standard Confined Space Entry Procedures
should be followed (i.e., rescue team, attendant, entry supervisor).
Before entry into a confined space, a qualified person should conduct
testing for hazardous atmospheres. The internal atmosphere should be
tested with a calibrated, direct-reading instrument for the following, in
the order given:
* Oxygen content,
* Flammable gases and vapors, and
* Potential toxic air contaminants.
Testing equipment used in specialty areas should be listed or approved for
use in such areas. This listing or approval should be from nationally
recognized testing laboratories such as Underwriters Laboratories or
Factory Mutual Systems.
13.9.1. Evaluation Testing
The atmosphere of a confined space should be analyzed using equipment of
sufficient sensitivity and specificity The analysis should identify and
evaluate any hazardous atmospheres that may exist or arise, so that
appropriate permit entry procedures can be developed and acceptable entry
conditions stipulated for that space. Evaluation and interpretation of
these data and development of the entry procedure should be done by, or
reviewed by, a technically qualified professional (e.g., OSHA consultation
service, certified industrial hygienist, registered safety engineer,
certified safety professional).
13.9.2. Verification Testing
A confined space which may contain a hazardous atmosphere should be tested
for residues of all identified or suspected contaminants. The evaluation
testing should permit specified equipment to determine that residual
concentrations at the time of testing and entry are within acceptable
limits. Results of testing (i.e., actual concentration) should be recorded
on the permit. The atmosphere should be periodically retested to verify
that atmospheric conditions remain within acceptable entry parameters.
Initial testing of atmospheric conditions and subsequent tests after a job
has been stopped should be done with the ventilation systems shut down. If
the confined space is vacated for any period of time, the atmosphere of the
confined space should be retested before re-entry is permitted. Further
testing should be conducted with ventilation systems turned on to ensure
the contaminants are removed and that the ventilation system is not causing
a hazardous condition.
13.9.3. Acceptable Limits
The atmosphere of the confined spaces should be considered within
acceptable limits whenever the following conditions are maintained:
* Oxygen - 19.5% to 23.5%,
* Flammability - less than 10% of the Lower Flammable Limit (LFL), and
* Toxicity - less than recognized ACGIH exposure limits or other
published exposure levels (e.g. OSHA PELs, NIOSH RELs).
Whenever testing of the atmosphere indicates levels of oxygen,
flammability, or toxicity that are not within acceptable limits, entry
should be prohibited until appropriate controls are implemented. If the
source of the contaminant cannot be determined, precautions should be
adequate to deal with the worst possible condition in the confined space.
If there is the possibility that the confined space atmosphere can become
unacceptable while the work is in progress, the atmosphere should be
constantly monitored and procedures and equipment should be provided to
allow the employees to quickly and safely exit the confined space.
13.10 - Isolation and Lockout / Tagout Safeguards
All energy sources which are potentially hazardous to confined space
entrants should be secured, relieved, disconnected and/or restrained before
personnel are permitted to enter the confined space. Equipment systems or
processes should be locked out or tagged out or both per 29 CFR 1910.147
and ANSI Z244.1-1982, Lockout/Tagout of Energy Sources prior to permitting
entry into the confined space. The current lockout/tagout program being
used at the site should be used as guidance. In confined spaces where
complete isolation is not possible, provisions should be made for as
rigorous an isolation as practical. Special precautions should be taken
when entering double walled, jacketed, or internally insulated confined
spaces that may discharge hazardous material through the vessel's internal
wall.
Where there is a need to test, position or activate equipment by
temporarily removing the lock or tag or both, a procedure should be
developed and implemented to control hazards to the occupants. Any removal
of locks, tags, or other protective measures should be done in accordance
with ANSI Z244.1-1982.
13.11 - Ingress / Egress Safeguards
Means for safe entry and exit should be provided for confined spaces. Each
entry and exit point should be evaluated to determine the most effective
methods and equipment to be utilized to enable employees to safely enter
and exit the confined space.
Appropriate retrieval equipment or methods should be used whenever a person
enters a confined space. Use of retrieval equipment may be waived by the
designated qualified persons if use of the equipment increases the overall
risks of entry or does not contribute to the rescue. A mechanical device
should be available to retrieve personnel from vertical type confined
spaces greater than five feet in depth.
13.12 - Warning Signs and Symbols
All confined spaces that could be inadvertently entered should have signs
identifying them as confined spaces. Signs should be maintained in a
legible condition. The signs should contain a warning that a permit is
required before entry. Accesses to all confined spaces should be
prominently marked.
13.13 - Training
The employer should provide training so that all employees whose work is
regulated by this section acquire the understanding, knowledge, and skills
necessary for the safe performance of their duties in confined spaces.
Training should be provided to each affected employee:
* Before the employee is first assigned duties under this section,
* Before there is a change in assigned duties,
* Whenever there is a change in permit space operations that presents
a hazard for which an employee has not been trained, and
* Whenever the employer has reason to believe either that there are
deviations from the permit space entry procedures required in this
section or that there are inadequacies in the employee's knowledge
or use of these procedures.
The training should establish employee proficiency in the duties required
by this section and should introduce new or revised procedures, as
necessary, for compliance with this section.
13.13.1. General Training
All employees who will enter confined spaces should be trained in entry
procedures. Personnel responsible for supervising, planning, entering or
participating in confined space entry and rescue should be adequately
trained in their functional duties prior to any confined space entry.
Training should include:
* Explanation of the general hazards associated with confined spaces;
* Discussion of specific confined space hazards associated with the
facility, location or operation;
* Reason for, proper use, and limitations of PPE and other safety
equipment required for entry into confined spaces;
* Explanation of permits and other procedural requirements for
conducting a confined space entry;
* A clear understanding of what conditions would prohibit entry;
* How to respond to emergencies;
* Duties and responsibilities as a member of the confined space entry
team; and
* Description of how to recognize symptoms of overexposure to probable
air contaminants in themselves and co-workers, and method(s) for
alerting attendants.
Refresher training should be conducted as needed to maintain employee
competence in entry procedures and precautions.
13.13.2. Specific Training
13.13.2.1. Training for Atmospheric Monitoring Personnel
Training should include proper use of monitoring instruments such as:
* Proper use of the equipment;
* Knowledge of calibration;
* Knowledge of sampling strategies and techniques; and
* Knowledge of PELs, TLVs, LELs, UELs, etc.
13.13.2.2. Training For Attendants
Training should include the following:
* Procedures for summoning rescue or other emergency services, and
* Proper utilization of equipment used for communicating with entry
and emergency/rescue personnel.
13.13.2.3. Training for Emergency Response Personnel
Training should include:
* Rescue plan and procedures developed for each type of confined space
that are anticipated to be encountered,
* Use of emergency rescue equipment,
* First aid and CPR techniques, and
* Work location and confined space configuration to minimize response
time.
13.13.2.4. Verification of Training
Periodic assessment of the effectiveness of employee training should be
conducted by a qualified person. Training sessions should be repeated as
often as necessary to maintain an acceptable level of personnel competence.
13.14 - Emergency Response
13.14.1. Emergency Response Plan
A plan of action should be written with provisions to conduct a timely
rescue for individuals in a confined space should an emergency arise.
13.14.2. Retrieval Systems or Methods to Facilitate Non-entry Rescue
Retrieval systems should be used whenever an authorized person enters a
permit space, unless the equipment increases the overall risk of entry or
the equipment would not contribute to the rescue of the entrant. Retrieval
systems should have a chest or full body harness and a retrieval line
attached at the center of the back near shoulder level or above the head.
If harnesses are not feasible or create a greater hazard, wristlets may be
used in lieu of the harness. The retrieval line should be firmly fastened
outside the space so that rescue can begin as soon as anyone is aware that
retrieval is necessary. A mechanical device should be available to
retrieve personnel from vertical confined spaces more than five feet deep.
13.15 - References
1. 29 CFR 1910.146, "Permit-required Confined Spaces."
2. National Safety Council Data Sheet 12304-0704, "Confined Space Entry
Control System for Research and Development Operations."
3. American National Standard Institute (ANSI) Z117.1-1989, "Safety
Requirements for Confined Spaces."
4. DHHS (NIOSH) Publication No. 87-113, "Working With Confined Spaces."
5. ANSI Z 244.1-1982, "Lockout/Tagout of Energy Sources."
6. 29 CFR 1910.147, "The Control of Hazardous Energy (Lockout/Tagout)."
14.1 - Background
The intent of this section of the HASP is to meet the requirements of 29
CFR 1910.120 (b)(4)(ii)(j). The spill containment program should address
all hazardous substance spill scenarios that are likely to occur at the
site. In addition, the spill containment program should also provide
procedures to contain and isolate the entire volume of any hazardous
substance spilled in the course of a transfer, accident, or onsite release.
The overall objectives of the Spill Containment chapter are to:
* Identify the minimum requirements of the spill containment program
that may be relevant to the site and provide methods to contain and
isolate the entire volume of any hazardous substance spilled in the
course of a transfer, major spill, or an onsite release; and
* Provide information on the initial spill action, spill response
evaluation and organization, and spill clean-up procedures.
14.2 - Preplanning
In order to develop a successful spill containment program, an assessment
should be conducted of the site conditions, current operations, and planned
activities. The assessment should carefully examine all hazardous
materials on site for where and how the materials are:
* Stored (e.g., location, type of container),
* Handled (e.g., processed, used, transferred), and
* Transported (e.g., mode, routes).
As part of the assessment, each area or activity should be analyzed for
potential accidental releases or spills. Examples of situations that have
potential for spill or release are:
* Bulging or corroded containers,
* Transfer line connections (e.g., leaking seals, misaligned connections),
* Metal fatigue of storage tanks,
* Leaking or inoperable valves, and
* Poor housekeeping (e.g., drums improperly staged).
Many potential spills can be avoided through application of proper
engineering controls to hazards identified in the assessment. In areas
where storage, handling, and transportation activities occur, preplanning
to contain the largest volume of material that could be released in the
area will minimize worker exposure. The containment measure should be
appropriate to the hazardous material(s) identified and should be installed
in the area or located nearby. The following examples are measures most
frequently used:
* Absorbent materials, (e.g., pads, booms, powders);
* Salvage containers (e.g., overpack drums);
* Bermed, lined pads;
* Concrete pad and dike;
* Inflatable containment (e.g., "kiddie" pools, bladders); and
* Associated equipment (e.g., pumps, hoses, shovels, hoists).
Procedures should be developed to properly maintained and replace, as
necessary, all spill containment equipment and fixtures.
14.3 - Reporting and Initial Personnel Safety
Upon discovery of a hazardous substance spill, personnel should be
instructed to:
* Immediately summon help by notifying the Field Team Leader, the
Site Safety and Health Officer (SSHO), and/or the Project Manager;
* Take action to ensure the safety of nearby personnel;
* Proceed to a safe location;
* If anyone is seriously injured, immediately contact emergency
medical services; and
* Keep unauthorized personnel out of the area.
14.4 - Initial Spill Action
Factors that limit the employee's response at the site of a spill are:
* Level of training,
* Personal safety,
* Available personal protective equipment (PPE), and
* Knowledge of the substance.
Employees should limit their actions to:
* Shutting off equipment or pumps,
* Closing valves,
* Blocking drains within the path of the spill, and
* Using spill kit materials to dam or impede the flow of the spill.
Unauthorized persons should be excluded from the area.
14.5 - Spill Response Evaluation
The identity and hazards of the spilled material should be determined
before decisions regarding spill containment and control are made. The
SSHO or Project Manager should evaluate the hazards associated with the
spill and decide whether project employees or external response
organizations should conduct the cleanup. If the Project Manager
determines that project response personnel cannot safely perform the spill
cleanup, the Project Manager should notify and request the assistance of,
the Emergency Response Coordinator, and the ERP should be activated.
14.6 - Organizing a Spill Response
If the Project Manager determines that cleanup can be performed safely with
project response personnel, the SSHO may act as the spill team leader and
designate required procedures. Safety practices for small spill operations
closely parallel procedures implemented during routine hazardous materials
handling operations. Before work begins, the SSHO should conduct a hazard
identification and assessment with response personnel. The following
should be discussed and established:
* Levels of PPE and safety procedures,
* Safety and work zones,
* All steps of the response activities,
* Most effective procedures or methods for cleanup,
* Means of containment,
* Leak or spill control,
* Decontamination procedures, and
* Emergency decontamination.
14.7 - Spill Cleanup Procedures
After care of injured personnel, containment of the released hazardous
material should be the next consideration to limit its effect on the safety
of personnel, the public, and the environment. The SSHO should determine
the methods of control which depend upon the nature and extent of the
spill. Actions documented in Chapter 11, Emergency Response/Contingency
Plan should also be consulted. Decontamination should be accomplished in
accordance with Chapter 10, Decontamination and disposal of contaminated
materials should meet all regulatory requirements.
14.8 - Post Incident Follow-up
The Project Manager or SSHO should implement necessary steps to ensure that
the incident is properly documented and that spill response equipment is
replenished. The Project Manager should direct the necessary corrective
actions to prevent recurrence and evaluate the response.
14.9 - References
1. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response
(HAZWOPER)."
2. EPA Publication No. 9285.1-03, "Standard Operating Safety Guides,"
Chapter 10, Office of Emergency and Remedial Response, USEPA, 1992.
3. DHHS (NIOSH) Publication No. 85-115, "Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities," Chapter 11,
NIOSH/OSHA/USCG/EPA, 1985 (Four-Agency Document).
4. UEFPC OU 3 RI Work Plan, p. 9-60, Y-12 Plant, "Environmental
Restoration Program, Health and Safety Plan," Rev. 0.
5. EPA 9285.8-01, "Health and Safety Plan (HASP) User's Guide," Chapter
12, Office of Emergency and Remedial Response, USEPA, 1992 (and ERT Health
and Safety Plan Planner, Ver. 3.0C, 1993).
Appendix A - HASP Glossary
Acceptable Entry: Those conditions that should exist in a confined space
that allow entry and ensure that employees can safely work within and exit
the space.
Access Control Point: An opening in the physical boundary between work
zones which is used to regulate movement of personnel or equipment between
the zones.
Acclimatization: A process that helps an employee adjust to work under
extreme conditions (e.g., temperature, altitude).
Action Level: A contaminant concentration at which additional measures are
implemented to protect the worker. The protective measures may include
medical surveillance, training, and modification of the level of
protection.
Activity Hazard Assessment (AHA): The process to identify and evaluate the
operational activities and their associated hazards. The process includes
implementing control measures to eliminate or reduce each hazard to an
acceptable level.
Administrative Controls: Provisions related to the organization and
management, procedures, recordkeeping, assessment, and reporting necessary
to ensure safe operation of a facility.
Assessment: The evaluation or appraisal of a process, program, or activity
to determine compliance with the relevant standard, DOE order, rule, code,
regulation, or other appropriate criteria.
Attendant: The individual stationed outside a confined space who monitors
the authorized entrants, controls access into the confined space, and is
alert to any hazards that may arise.
Authorized Entrant: An employee who is authorized by the employer to enter
a confined space.
Biological Hazards: Agents presenting hazard to the well-being of humans or
other animals, either directly through infection or indirectly through
disruption of the environment. Hazards include plant exposures (e.g.,
poison ivy and poison oak) and animal exposures (e.g., bee stings and snake
bites).
Buddy System: A system for organizing employees into work groups in such a
manner that each member of the work group is designated to be observed by
at least one other member of the group at all times. The purpose of the
buddy system is to provide rapid assistance to employees in the event of an
emergency.
Chemical Hazard: The exposure of employees to any regulated or
non-regulated hazardous materials (solids, liquids, and gases; natural and
man-made), with the potential for causing harm to people, the environment,
or property when released.
Confined Space: An enclosed area that has one or more of the following
characteristics:
* It is not intended for continuous occupancy,
* It has restricted entry and exit, and
* It may contain potential or known hazards.
Contamination Reduction Corridor: The area that controls access into and
out of the Exclusion Zone/Radiological Area and where personnel
decontamination activities take place.
Contamination Reduction Zone: The transition area between the Exclusion
Zone and Support Zone. The area where decontamination procedures take
place.
Controls: Changes in the work processes and/or working environment with the
objective of controlling the hazards either by eliminating the responsible
agents, or reducing them to levels believed not to be harmful to health, as
well as by preventing exposure to workers.
Critical Operations: Those emergency operations necessary for the safe
emergency shutdown of an operation, site, task, or piece of machinery.
Critical Operations Personnel: Those personnel identified in writing and
trained to accomplish emergency shutdown operations. These personnel may
be required to delay their own evacuation of the site during an emergency.
Emergency (Confined Space): Any occurrence (including any failure of hazard
control or monitoring equipment) or event internal or external to the
confined space that could endanger entrants.
Emergency (Site): A sudden and unexpected event, taking place on the site,
and requiring urgent action for control or remediation in order to minimize
the danger to workers, the public, the environment, or property.
Engineering Controls: Methods of controlling employee exposure to safety
and health hazards by modifying the source of exposure or reducing the
quantity of contaminants released into the work area. Examples include
piping, containment, ventilation, filtration and shielding.
Engulfment: The surrounding and effective capture of a person by a liquid
or finely divided (flowable) solid substance that can be aspirated to cause
death by filling or plugging the respiratory system, or that can exert
enough force on the body to cause death by strangulation, constriction, or
crushing.
Entry Permit (Permit): The written document that allows and controls entry
into a confined space. It is a systematic evaluation of the confined
space; it describes purpose of entry, authorized personnel, hazards, work
controls and equipment.
Entry Supervisor: The person (such as the employer, foreman, or crew chief)
who determines if acceptable entry conditions are present at a confined
space, authorizes entry, oversees entry operations, and terminates entries
as required.
Exclusion Zone: A controlled area, located on the site, where contamination
is either known or expected to occur and where the greatest potential for
exposure exists. Also known as the "Hot Zone."
Facility: Any DOE installation or portion of an installation operated,
funded, or otherwise controlled by EM-40.
Hazard: An act, condition, or phenomenon posing a source of actual or
potential physical, chemical, radiological, or biological harm to a person.
Hazard Evaluation: A process to assess the severity, and likelihood of
exposure to known, and/or potential occupational safety and health hazards,
at or in the work environment.
Hazardous Atmosphere: An atmosphere that may expose employees to the risk
of death, incapacitation, impairment of ability to self-rescue (that is,
escape unaided from a confined space), injury, or acute illness from one or
more of the following causes:
* Flammable gas, vapor, or mist in excess of 10 percent of its lower
flammable limit (LFL);
* Airborne combustible dust at a concentration that meets or exceeds
its LFL; NOTE: This concentration may be approximated as a
condition in which the dust obscures vision at a distance of 5 feet
(1.52 m) or less;
* Atmospheric oxygen concentration below 19.5 percent or above 23.5
percent;
* Atmospheric concentration of any substance for which a dose or a
permissible exposure limit is published in Subpart G, Occupational
Health and Environmental Controls, or in
* Subpart Z, Toxic and Hazardous Substances, of 29 CFR 1910, and which
could result in employee exposure in excess of its dose or
permissible exposure limit.
Hotline: The outer boundary of the Exclusion Zone. It separates the area
of highest contamination from the Contamination Reduction Zone. It
provides an adequate area in which to conduct site operations taking into
account potential contaminant migration.
Hot Work: Work that produces arcs, sparks, flames, heat, or other sources
of ignition.
Hot Work Permit: The employer's written authorization to perform operations
(for example, riveting, welding, cutting, burning, and heating) capable of
providing a source of ignition.
Immediately Dangerous to Life or Health (IDLH): Any condition or exposure
that poses an immediate or delayed threat to life or that would cause
irreversible adverse health effects.
Inerting: The displacement of the atmosphere in a confined space by a
non-combustible gas (such as nitrogen) to such an extent that the resulting
atmosphere is non-combustible. This procedure produces an IDLH
oxygen-deficient atmosphere. However, the procedure is used to isolate the
space and control hazards before entry.
Installation: Any DOE property (i.e., "inside the fence.")
Isolation: The process by which a permit space is removed from service and
is completely protected from release of energy and material into the space.
Common methods of isolation are misaligning or removing sections of lines,
pipes, or ducts; closing off or venting valves; providing lockout or tagout
of all sources of energy; and disconnecting all mechanical linkages.
Job: The detailed steps required to carry out a task.
Key Personnel: Those personnel/organizations considered to be essential to
ensure the safe operation of the facility, site, project, or task.
LEL/LFL and UEL/UFL: Lower explosive limit/lower flammable limit and upper
explosive limit/upper flammable limit describe the explosion or combustion
limits, respectively for flammable gas or vapor mixtures in air. For
example, a concentration below the lower flammable limit is not sufficient
to support combustion, and above the upper flammable limit the mixture is
too "rich" to burn.
Line Breaking: The intentional opening of a pipe, line, or duct that is or
has been carrying flammable, corrosive, or toxic material, an inert gas, or
any fluid at a volume, pressure, or temperature capable of causing injury.
Lockout/Tagout: A procedure for placing a lock/tag on the energy isolating
device to indicate that the process system or equipment should not be
operated.
Major Spill: The uncontrolled release of a hazardous substance into the
environment to such a degree that operations personnel can not control or
contain the spill, and that requires mobilization of emergency response
personnel.
Onsite Essential Personnel: Those required personnel, available on the
site, who by virtue of their position, responsibilities, and/or expertise,
are considered essential to the overall safe operation of the site.
Oxygen Deficient Atmosphere: An atmosphere containing less than 19.5%
oxygen by volume.
Oxygen Enriched Atmosphere: An atmosphere containing more than 23.5% oxygen
by volume.
Permissible Exposure Limit (PEL): The employee's permitted exposure to any
material listed in Table Z-1, Z-2, or Z-3 of OSHA Regulations found at 29
CFR 1910.1000, Air Contaminants.
Personal Protective Equipment (PPE): Clothing and equipment used to shield
or isolate individuals from the chemical, physical, and biological hazards
that may be encountered at a hazardous waste site. PPE should protect the
respiratory system, skin, eyes, face, hands, feet, head, body, and hearing.
PPE may also stand for personal protective clothing and equipment.
Physical Controls: Physical barriers put into place, which limit personnel
exposure to hazards.
Physical Hazards: Those work-related sources of actual or potential danger
(e.g., machinery, trip and fall, hoisting and rigging, shoring and
trenching) to which employees may be exposed.
Project: A unique major effort within a program which has firmly scheduled
beginning, intermediate, and ending date milestones; prescribed performance
requirements; prescribed costs; and close management, planning, and
control. A project is a basic building block within a program which is
individually planned, approved, and managed. A project is not constrained
to any specific element of the budget structure (e.g., operating expense or
plant and capital equipment).
Project Manager: The individual who has authority to direct all site
activities. The project manager has authority to direct site response and
assures overall management of projects.
Qualified Person: A person who, by reason of training, education and
experience, is knowledgeable in the operation to be performed and is
competent to judge the hazards involved.
Radiological Hazard: A source of actual or potential danger to a person(s)
which occurs or could occur because of exposure to radiation.
Recommended Exposure Limit: The NIOSH equivalent of OSHA PELs and ACGIH
TLVs to be used in the absence of PELs and TLVs.
Rescue Service: Offsite personnel designated to rescue employees from
permit spaces, or other hazardous areas when the onsite rescue team is not
available.
Site: An area where physical work is being performed and where the
potential of exposure to contaminants exists, requiring the use of chemical
protective clothing and/or radiological protective clothing and/or
respirators.
Site-Specific Training: Predefined training, unique to a particular site.
Spill: The uncontrolled release of a hazardous substance into the
environment that onsite personnel are capable of containing. Distinguished
from a major spill.
Standard Entry Procedure: A procedure for entry into confined spaces which
utilizes the complete array of entry measures. It is characterized by use
of trained personnel, atmospheric testing before and during entry, use of
proper protective equipment, and completion of the entry permit.
Storage: The temporary placement of a hazardous material in a location
which provides some protection to personnel or the environment.
Support Zone: Uncontaminated area where workers are unlikely to be exposed
to hazardous substances or dangerous conditions.
Task: A well defined unit of work having an identifiable beginning and end
with two or more elements. A task is a series of jobs performed in support
of a particular project.
Threshold Limit Value (TLV): An exposure limit established by the American
Conference of Governmental Industrial Hygienists (ACGIH) under which most
people can work consistently for 8 hours a day, day after day, with no
harmful effect.
Threshold Limit Value-Short-Term Exposure Limit (TLV-STEL): The
concentration to which workers can be exposed continuously, for a short
period of time, without suffering from irritation, chronic or irreversible
tissue damage, or narcosis, provided that the daily TLV-TWA is not
exceeded.
Threshold Limit Value-Time-Weighted Average (TLV-TWA): The time-weighted
average concentration for a normal 8-hour workday and a 40-hour workweek to
which nearly all workers may be repeatedly exposed, day after day, without
adverse effects.
Toxic Atmosphere: An atmosphere containing a concentration of a substance
above the published or otherwise known safe levels, such as the Threshold
Limit Value, Permissible Exposure Limit, Recommended Exposure Limit, or the
Immediately Dangerous to Life or Health level.
Work: The process of performing a defined task or activity; for example,
research and development, operations, maintenance and repair,
administration, software development and use, inspection, safeguards and
security, data collection, and analysis.
Work Plan: That part of a comprehensive Site Health and Safety Program
which addresses the tasks and objectives of site operations, including
logistics and resources.
Appendix C - Training Table 1
TABLE I
Minimum Training Requirements
for Personnel Engaged at EM-40 Sites
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 employees directly EM-40 adoption of OSHA 29 CFR 1910.120
involved in hazardous waste standards requires a minimum (e)(4),
operations on a daily or of 40 hours Initial Health DOE 1993b,
occasional basis, such as and Safety Training and 24 DOE 1993c,
supervising the work, hours supervised field DOE 1994 and
supervising contractor experience. NIEHS 1993
employees and evaluating
program outcome at the site.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Project standards requires a minimum (e)(4),
Manager (PM) directly of 40 hours Initial Health DOE 1993b,
responsible for and Safety Training and 24 DOE 1993c,
hazardous waste operation hours supervised field DOE 1994 and
including employees at the experience. NIEHS 1993
site and has authority to
direct response operations.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Field standards requires a minimum (e)(4),
Supervisor (FS) who has of 40 hours Initial Health DOE 1993b,
the responsibility and and Safety Training and 24 DOE 1993c,
authority to direct all hours supervised field DOE 1994 and
hazardous waste experience. NIEHS 1993
operations and
supervises employees
engaged in hazardous
waste operations at the
site. This individual
may be the same person
as the Project Manager
and may be a member of
the work party.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Site Safety standards requires a minimum (e)(4),
and Health Officer (SSHO) of 40 hours Initial Health DOE 1993b,
involved in taking total and Safety Training and 24 DOE 1993c,
control over site hours supervised field DOE 1994 and
activities. SSHO has experience. NIEHS 1993
authority to direct
response operations and
reports to upper level
management.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Industrial standards requires a minimum (e)(4),
Hygienist (IH) responsible of 40 hours Initial Health DOE 1993b,
for implementation of all and Safety Training and 24 DOE 1993c,
aspects of Health and hours supervised field DOE 1994 and
Safety Plan and experience. NIEHS 1993
verification of compliance
with applicable safety and
health requirements at the
site. Tasks include
enforcement of air
monitoring tests to
determine worker response
to hazardous substances,
advice on adequate health
protection and evaluation
of health hazard
assessments at the site.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Health standards requires a minimum (e)(4),
Physicist (HP) of 40 hours Initial Health DOE 1993b,
responsible for and Safety Training and 24 DOE 1993c,
implementation of all hours supervised field DOE 1994 and
aspects of radiation experience. NIEHS 1993
protection for workers at
the site and verifies
compliance with
applicable federal
regulations and DOE
orders. Typical task
includes evaluation of
internal and external
radiation health hazards
and recommendation of
appropriate action for
workers at the site.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Command Post standards requires a minimum (e)(4),
Supervisor. In some of 40 hours Initial Health DOE 1993b,
cases, the Command Post and Safety Training and 24 DOE 1993c,
Supervisor may be the same hours supervised field DOE 1994 and
person as the Field Team experience. NIEHS 1993
Leader. The Command Post
Supervisor is responsible
for communications and
emergency assistance and
assists the SSHO in rescue
operations, if necessary.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Site standards requires a minimum (e)(4),
Emergency Response of 40 hours Initial Health DOE 1993b,
Coordinator responsible and Safety Training and 24 DOE 1993c,
for implementing the hours supervised field DOE 1994 and
emergency plan, whenever experience. NIEHS 1993
conditions at the site
warrant such action. The
Site Emergency Response
Coordinator, who may be
the same person as the
Site Supervisor, conducts
activities such as
evacuation, emergency
treatment, emergency
transport of site
personnel, as necessary,
and notification of
emergency response units
and appropriate
management staff. The
Site Emergency Response
coordinator is certified
in first aid/CPR by the
American Red Cross or
equivalent.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Site standards requires a minimum (e)(4),
Decontamination Station of 40 hours Initial Health DOE 1993b,
Officer responsible for and Safety Training and 24 DOE 1993c,
implementing hours supervised field DOE 1994 and
decontamination experience. NIEHS 1993
procedures for large and
small equipment, supplies
and personnel involved in
clean-up activities
including visitors.
Typical tasks include set
up of decontamination
lines and decontamination
solutions appropriate for
the type of chemical
contamination on site,
and control of the
decontamination of all
equipment (small and
large), personnel, and
samples from the
contaminated areas.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor Site standards requires a minimum (e)(4),
Security Officer of 40 hours Initial Health DOE 1993b,
responsible for managing and Safety Training and 24 DOE 1993c,
site security. The hours supervised field DOE 1994 and
specific responsibilities experience. NIEHS 1993
include, but are not
limited to, the
following:
establishing routine area
patrols, monitoring
access and egress, and
assisting with
communication during an
emergency.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor optional standards requires a minimum (e)(4),
personnel on site. of 40 hours Initial Health DOE 1993b,
Typical titles include and Safety Training and 24 DOE 1993c,
Scientific Advisor hours supervised field DOE 1994 and
(guides the Project experience. NIEHS 1993
Manager in scientific
matters), Logistics
Officer (plans and
mobilizes the facilities,
materials and personnel
required for the
response), Photographer
(provides photographs of
site conditions and
archives photographs),
Public Information
Officer (releases
information to the news
media and the public
concerning site
activities) and Record
Keeper (maintains the
official records of site
activities). See Chapter
2 for a list of optional
personnel and
corresponding
responsibilities.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 As-needed offsite EM-40 adoption of OSHA 29 CFR 1910.120
personnel. EM-40 typical standards requires a minimum (e)(4),
titles include Bomb Squad of 40 hours Initial Health DOE 1993b,
Experts (advise on methods and Safety Training and 24 DOE 1993c,
of handling explosive hours supervised field DOE 1994 and
materials), Fire fighters experience. NIEHS 1993
(respond to fires that
occur on-site and perform
rescue), Hazardous
Chemical Experts (provide
immediate advice to those
at the scene of a chemical
related emergency), and
Toxicologists (advise on
toxicological properties
and health effects of
chemicals on-site).
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or EM-40 adoption of OSHA 29 CFR 1910.120
Subcontractor general standards requires a minimum (e)(4),
site workers (such as of 40 hours Initial Health DOE 1993b,
equipment operators and and Safety Training and 24 DOE 1993c,
general laborers) engaged hours supervised field DOE 1994 and
in hazardous substances experience. NIEHS 1993
removal and other
activities such as field
sampling, drilling, and
installation of
monitoring wells.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or 29 CFR 1910.120(e)(3)(ii) 29 CFR 1910.120
Subcontractor workers on requires minimum training (e)(3),
a site occasionally for a requirements of 24 hours DOE 1993b,
specific or limited task of instruction off-site and DOE 1993c,
(such as, but not limited a minimum of one day of DOE 1994, and
to, groundwater actual field experience for NIEHS 1993
monitoring, land occasional clean-up workers.
surveying, or geophysical However, EM-40 adoption of
surveying) and who are OSHA standards requires a
unlikely to be exposed minimum of 40 hours Initial
over OSHA permissible Health and Safety Training
exposure limits (PELs) and 24 hours supervised
and published exposure field experience.
limits.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or 29 CFR 1910.120(e)(3)(ii) 29 CFR 1910.120
Subcontractor workers who requires minimum training (e)(3),
work regularly on a site requirements of 24 hours DOE 1993b,
in areas which have been of instruction off-site and DOE 1993c,
monitored and fully a minimum of one day of DOE 1994, and
characterized indicating actual field experience for NIEHS 1993
that exposures are under occasional clean-up workers.
OSHA PELs and published However, EM-40 adoption of
exposure limits where OSHA standards requires a
respirators or other PPE minimum of 40 hours Initial
are not necessary, and Health and Safety Training
the characterization and 24 hours supervised
indicates that there are field experience.
no health hazards or the
possibility of an
emergency developing.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (e)(7),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Lead and Asbestos Abatement 29 CFR 1910.1001
Training, if applicable. (j)(5),
29 CFR 1926.58
(k)(3),
29 CFR 1910.1025
(l)(1) and (2),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Visitors/Non-Workers EM-40 adoption of OSHA 29 CFR 1910.120
who enter an standards requires a minimum (e)(4),
exclusion/decontamination of 40 hours Initial Health DOE 1993b,
zone or other areas where and Safety Training and 24 DOE 1993c,
Level A or Level B hours supervised field DOE 1994 and
personal protective experience. NIEHS 1993
equipment (PPE) is
required.
Visitors/Non-Workers are
on the site only
occasionally, for a
specific or limited task
such as observing work
activities. PPE should be
issued to all
Visitors/Non-Workers, and
they should be instructed
on its proper use. All
Visitors/Non-Workers
should be escorted by
trained personnel.
Non-Workers are EM-40
employees and off-site
personnel not directly
involved with site
hazardous waste
operations.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Visitor/Non-Workers OSHA requires a minimum 29 CFR 1910.120
who enter an training requirement of 24 (e)(3),
exclusion/decontamination hours of instruction DOE 1993b,
zone or other areas where off-site and a minimum of DOE 1993c,
Level C (PPE) is required. one day actual field DOE 1994 and
Visitors/Non-Workers are experience for NIEHS 1993
on the site only Visitors/Non-Workers.
occasionally, for a However, EM-40 adoption of
specific or limited task OSHA standards requires a
such as inspecting minimum of 40 hours
operations at the site. Initial Health and Safety
PPE should be issued to Training and 24 hours
all Visitors/Non-Workers, supervised field
and they should be experience.
instructed on its proper
use. All
Visitors/Non-Workers are
EM-40 employees and
Contractors not directly
involved with site
hazardous waste site
operations.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(9),
of Site-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(8),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training. 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Visitor/Non-Workers Site-Specific Training. DOE 1991,
who enter designated clean DOE 1993b,
areas of the site where DOE 1993c,
either Level D or no PPE DOE 1994, and
is required for tasks such NIEHS 1993
as observing activities in
clean portions of the
sites. PPE should be
issued, when necessary, to
all Visitors/Non-Workers,
and they should be
instructed on its proper
use. All
Visitors/Non-Workers
should be escorted by
trained personnel.
Non-Workers are EM-40
employees and Contractors
not directly involved with
site hazardous waste
operations.
Appendix C - Training Table 2
TABLE II
Minimum Training Requirements
for Personnel Engaged at EM-40 RCRA TSD Sites
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 employees directly 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120
involved in TSD facilities and (ii) require a minimum (p)(7)(i) and (ii),
operations on a daily or of 24 hours Initial Health DOE 1993b,
occasional basis, i.e., and Safety Training, or DOE 1993c,
supervising contractor equivalent instruction, for DOE 1994, and
employees and evaluating current employees. However, NIEHS 1993
program outcome. EM-40 adoption of OSHA
standards requires a minimum
of 40 hours Initial Health
and Safety Training and 24
hours supervised field
experience.
EM-40 requires a minimum DOE 1993b,
of 8 hours Supervisor DOE 1993c,
Training. DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120(p),
standards requires a minimum DOE 1991,
of Facility-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (p)(7)(i),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (p)(8)(iv),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120
Subcontractor TSD Facility and (ii) require a minimum (p)(7)(i) and (ii),
Manager (FM) responsible of 24 hours Initial Health DOE 1993b,
for operations such as and Safety Training, or DOE 1993c,
handling drums or equivalent instruction, for DOE 1994, and
containers. The TSD FM is current employees. However, NIEHS 1993
also responsible for EM-40 adoption of OSHA
supervising TSD employees standards requires a minimum
and has authority to of 40 hours Initial Health
direct response and Safety Training and 24
operations. hours supervised field
experience.
EM-40 requires a minimum DOE 1993b,
of 8 hours Supervisor DOE 1993c,
Training. DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120(p),
standards requires a minimum DOE 1991,
of Facility-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (p)(7)(i),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (p)(8)(iv),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120
Subcontractor Facility and (ii) require a minimum (p)(7)(i) and (ii),
Safety and of 24 hours Initial Health DOE 1993b,
Health Officer (FSHO) and Safety Training, or DOE 1993c,
responsible for equivalent instruction, for DOE 1994, and
implementation of all current employees. However, NIEHS 1993
aspects of Safety and EM-40 adoption of OSHA
Health Plan at the standards requires a minimum
facility. The FSHO is of 40 hours Initial Health
also responsible for and Safety Training and 24
implementing the Emergency hours supervised field
Response Plan whenever experience.
warranted at the facility.
FSHO has authority to
direct response operations
and reports to upper level
management.
EM-40 requires a minimum DOE 1993b,
of 8 hours Supervisor DOE 1993c,
Training. DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120(p),
standards requires a minimum DOE 1991,
of Facility-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (p)(7)(i),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (p)(8)(iv),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120
Subcontractor Designated and (ii) require a minimum (p)(7)(i) and (ii),
Emergency Response Person of 24 hours Initial Health DOE 1993b,
(DERP) certified in first and Safety Training, or DOE 1993c,
aid/CPR by the American equivalent instruction, for DOE 1994, and
Red Cross, or equivalent. current employees. However, NIEHS 1993
The DERP is assigned to EM-40 adoption of OSHA
the facility crew to standards requires a minimum
provide first aid and CPR of 40 hours Initial Health
services and is on the and Safety Training and 24
facility whenever hours supervised field
employees are working at experience.
the facility.
EM-40 requires a minimum DOE 1993b,
of 8 hours Supervisor DOE 1993c,
Training. DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120(p),
standards requires a minimum DOE 1991,
of Facility-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (p)(7)(i),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (p)(8)(iv),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120
Subcontractor Facility and (ii) require a minimum (p)(7)(i) and (ii),
Command Post Supervisor or of 24 hours Initial Health DOE 1993b,
Facility Emergency and Safety Training, or DOE 1993c,
Coordinator (FEC) equivalent instruction, for DOE 1994, and
responsible for current employees. However, NIEHS 1993
implementing the emergency EM-40 adoption of OSHA
plan, whenever conditions standards requires a minimum
at the facility warrant of 40 hours Initial Health
such action. The FEC who and Safety Training and 24
may be the same person as hours supervised field
the TSD Facility Manager experience.
conducts activities such
as evacuation, emergency
transport of facility
personnel, as necessary,
and notifies emergency
response units and
appropriate management
staff.
EM-40 requires a minimum DOE 1993b,
of 8 hours Supervisor DOE 1993c,
Training. DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120(p),
standards requires a minimum DOE 1991,
of Facility-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (p)(7)(i),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (p)(8)(iv),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120
Subcontractor facility and (ii) require a minimum (p)(7)(i) and (ii),
operators engaged in of 24 hours Initial Health DOE 1993b,
activities such as and Safety Training, or DOE 1993c,
handling drums or equivalent instruction, for DOE 1994, and
containers, or operation current employees. However, NIEHS 1993
of a treatment unit such EM-40 adoption of OSHA
as an incinerator or standards requires a minimum
activated carbon of 40 hours Initial Health
adsorption system. and Safety Training and 24
hours supervised field
experience.
EM-40 requires a minimum DOE 1993b,
of 8 hours Supervisor DOE 1993c,
Training. DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120(p),
standards requires a minimum DOE 1991,
of Facility-Specific DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (p)(7)(i),
of 8 hours Annual Refresher DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
Emergency Response and 29 CFR 1910.120
Periodic Rehearsal Training. (p)(8)(iv),
DOE 1993b,
DOE 1993c,
DOE 1994 and
NIEHS 1993
Hazard Communication 29 CFR 1910.120,
Training 29 CFR 1926.59
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Visitors/Non-Workers OSHA requires no minimum DOE 1993b,
who enter the facility. training for DOE 1993c,
PPE should be issued to Visitors/Non-Workers who DOE 1994, and
all Visitors/Non-Workers, enter the facility. NIEHS 1993
and they should be However, EM-40 requires a
instructed on its proper minimum of 40 hours Initial
use. All EM-40 employees Health and Safety Training
and offsite personnel not and 24 hours supervised
directly involved with TSD field experience.*
facility operations, are
Visitors/Non-Workers.
Facility-Specific Training DOE 1991,
DOE 1993b,
DOE 1993c,
DOE 1994, and
NIEHS 1993
8 hours Annual Refresher DOE 1993b,
Training.* DOE 1993c,
DOE 1994, and
NIEHS 1993
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
* This training is required for all visitors/nonworkers who enter an
exclusion/decontamination zone or other areas where Level A, B, or C
PPE is required. This training is not required for
visitors/non-workers who only enter areas where either Level D or no
PPE is required. See memo from Mr. Pat Whitfield, EM-40 to EM-40
Offices, dated February 2, 1994.
Appendix C - Training Table 3
TABLE III
Minimum Training Requirements for Personnel
Engaged at Emergency Responses to Hazardous Substances Releases
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or OSHA requires sufficient 29 CFR 1910.120
Subcontractor First training to initiate an (q)(6)(i),
Responder (FR-AW) at the emergency response sequence DOE 1994
awareness level. This by notifying the proper
individual is likely to authorities of the release
witness or discover a (or) has sufficient
hazardous substance experience to objectively
release. The FR-AW takes demonstrate competency in
no action beyond notifying the areas listed in
appropriate authorities of 1920.120(q)(6)(i).
the release.
EM-40 Contractor or OSHA requires a minimum of 29 CFR 1910.120
Subcontractor First 8-hours of training to (q)(6)(ii),
Responder (FR-OP) at the respond in a defensive DOE 1993b,
operation level. This manner without actually DOE 1993c,
individual responds to trying to stop the release; DOE 1994 and
releases or potential or sufficient experience to NIEHS 1993
releases of hazardous objectively demonstrate
substances as part of the competency in the areas
initial response at the listed in 29 CFR 1920.120
site in order to mitigate (q)(6)(i) and (ii) and
the effects of these competency certification
substances on human health by the employer are required.
and the environment. However, EM-40 requires a
minimum of 40-hours Initial
Health and Safety Training
and 24-hours supervised field
experience.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires an annual (q)(8),
refresher training, at a DOE 1993b,
minimum. DOE 1993c,
DOE 1994 and
NIEHS 1993
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1993b,
Manual (DOE/EH-0256T). DOE 1993c,
DOE 1994 and
NIEHS 1993
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or OSHA requires a minimum of 29 CFR 1910.120
Subcontractor Hazardous 24-hours of training equal (q)(8),
Materials Technician to the FR operations level DOE 1994
(HMT). This individual described in
responds to a release or 1920.120(q)(6)(ii). In
potential release for the addition, competency in
purpose of preventing or the areas listed in
stopping the release. The 1910.120(q)(6)(iii) and
HMT approaches the point competency certification
of release in order to by the employer are
plug, patch, or otherwise required. However, EM-40
stop the release of a requires a minimum of
hazardous substance. 40-hours Initial Health
and Safety Training and
24-hours supervised field
experience.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires an annual (q)(8),
refresher training DOE 1994
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1994
Manual (DOE/EH-0256T).
EM-40 Contractor or OSHA requires a minimum of 29 CFR 1910.120
Subcontractor Hazardous 24-hours of training equal (q)(6)(iv),
Materials Specialists to the HMT level. In DOE 1993b,
(HMS). This individual addition, competency in DOE 1993c,
responds to and provides the areas listed in DOE 1994, and
support for HMTs. This 1910.120(q)(6)(iv) and NIEHS 1993
position requires a competency certification
focused or specific by the employer are
knowledge of the various required. However, EM-40
substances which may be requires a minimum of
present at the site or 40-hours Initial Health
facility. and Safety Training and
24-hours supervised field
experience.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires an annual (q)(8),
refresher training DOE 1994
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1994
Manual (DOE/EH-0256T).
Operational Personnel Training Requirement Reference(s)
----------------------------------------------------------------------------
EM-40 Contractor or OSHA requires a minimum of 29 CFR 1910.120
Subcontractor On-Scene 24-hours of training equal (q)(8),
Incident Commander. This to the FR operations level DOE 1994
individual assumes described in
responsibility for control 1920.120(q)(6)(ii). In
of the incident scene addition, competency in
beyond the FR awareness the areas listed in
level. 1910.120(q)(6)(iii) and
competency certification
by the employer are
required. However, EM-40
requires a minimum of
40-hours Initial Health
and Safety Training and
24-hours supervised field
experience.
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires a minimum (e)(4),
of 8 hours Supervisor DOE 1993b,
Training. DOE 1993c,
DOE 1994 and
NIEHS 1993
EM-40 adoption of OSHA 29 CFR 1910.120
standards requires an annual (q)(8),
refresher training, at a DOE 1993b,
minimum. DOE 1993c,
DOE 1994 and
NIEHS 1993
Radiological Worker Training, DOE Notice 5480.6,
if applicable. For details, DOE 1992,
see DOE Radiological Control DOE 1994
Manual (DOE/EH-0256T).
Appendix D - EM-40 Hazardous Materials Training Program Memorandum
United States Government Department of Energy
Memorandum
Date: Feb. 03, 1994
Reply To Attn. Of: EM-43 (W. Wisenbaker, 3-8105)
Subject: Hazardous Materials Training Program
To: Distribution
The Office of Environmental Restoration (EM-40) Health and Safety Plan
(HASP) Working Group is developing HASP guidelines for EM-40. Their
discussions included interpretations of my attached memoranda, dated
June 10, 1993, and August 30, 1993, concerning the hazardous materials
training program for EM-40 employees and contractors. Based upon the
Working Group's discussions, two points of clarification may be in
order.
First, the previous memoranda did not mean to suggest that each each
EM-40 employee and EM-40 contractor employee, irrespective of his or her
job functions, must take the 40 hour Hazardous Waste Operations and
Emergency Response (HAZWOPER) Training. Instead, the memoranda meant to
include the following EM-40 employees and EM-40 contractors:
Headquarters and field program/project managers and supervisors of
hazardous waste work activities; first responders operations level;
on-site hazardous waste site clean-up responders to on-site accidents;
on-site hazardous waste site clean-up workers; persons who directly
evaluate, inspect, or review on-site hazardous waste work; and any
employee whose job functions require the 40 hour HAZWOPER by the
Department of Energy (DOE) Order 29 CFR 1910.120. The memoranda also
meant that, even though there are some workers whose job functions
normally require only 24 HAZWOPER training, they should instead receive
the 40 hour training. For example, this would include Treatment,
Storage, Disposal Facility workers or employees who only occasionally go
directly on-site for a specific limited task. To the greatest extent
possible, this 40 hour training should be taken under the auspices of
the National Institute of Environmental Health Sciences grantee program
because resources have already been allocated for this training.
Second, there are other EM-40 employees and EM-40 contractors who, by
virtue of their job functions, may still require only 24 hour HAZWOPER
training. Examples of these employees include on-site administrative
support and clerical personnel; persons who are not exposed to on-site
hazardous waste work activities; and persons who are not expected to be
directly involved in any aspects of on-site hazardous waste work as
defined in DOE Order 29 CFR 1910.120(e)(3)(iii). For these employees,
the training may be taken from any appropriate source.
Please contact Mr. William Wisenbaker at (301) 903-8105 should you have
auy questions or require additional information.
R. P. Whitfield
Reputy Assistant Secretary
for Environmental Restoration
Attachments
cc:
J. Baublitz, EM-40
R. Scott, EM-20
Appendix E - Other Sources of Hazard Assessment Methods
APPENDIX E
Other Sources of Hazard Assessment Methods
1. "Guidelines for Hazard Evaluation Procedure, Second Ed., with Worked
Examples," American Institute of Chemical Engineers, 1992.
2. "DOE Standard - Preparation Guide for U.S. Department of Energy
Non-reactor Nuclear Facility Safety Analysis Reports."
3. "DOE Standard - 1027-92," on compliance with DOE 5480.23, Nuclear
Safety Analysis Reports.
4. "Laboratory Integration and Prioritization System" (Lawrence Livermore
National Laboratory, Sandia National Laboratories, and Los Alamos National
Laboratory).
5. Office of Energy Research, ES&H Risked-Based Priority Model.
6. Draft DOE 5483.XX, "Occupational Safety and Health Program for DOE
Operations," with respect to the Risk Assessment Code Methodology, November
12, 1993.