EPA/540/G-89/010
December 1989
Health and Safety Audit Guidelines
SARA Title I Section 126
Office of Solid Waste and Emergency Response
Office of Emergency and Remedial Response
Emergency Response Division
Washington, DC 20460
-------
NOTICE
The policies and procedures set forth here are intended solely to
provide guidance to government personnel. This guidance does not constitute
rulemaking by the Agency, and may not be relied on to create a substantive or
procedural right enforceable by any party in litigation with the United
States. EPA may take action that is at variance with the policies and
procedures in these guidelines and may change them at any time without public
notice.
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
SARA TITLE I SECTION 126
HEALTH AND SAFETY AUDIT GUIDELINES
TABLE OF CONTENTS
Chapter 1 Introduction •
Chapter 2 Preliminary Evaluation
2.1 Site Location and Size
2.2 Description of Response/Job Function
2.3 Planned Duration of Employee Activity .......
2.4 Site Topography and Site Accessibility v
by Air and Roads
2.5 Safety and Health Hazards Expected-at the Site . . .
2.6 Pathways for Hazardous Substance Dispersion ....
2.7 Present Status of Emergency Response Teams for
On-Site Emergencies
2.8 Hazardous Substances and Health Hazards Involved or
Expected at the Site and Their Chemical and Physical
Properties
Chapter 3 Written Health and Safety Plan Review
3.1 Names of Key Personnel and Health and Safety
Personnel -- 29 CFR 1910.120(b)(2)
3.2 Safety and Health Risk Analysis for Each Site
Task and Operation -- 29 CFR 1910.120(b)(4) ....
3.3 Site Control -- 29 CFR 1910.120(d)
3.4 Employee Training --20 CFR 1910.120(e)
3.5 Medical Surveillance --29 CFR 1910.120(f)
3.6 Personal Protective Equipment (PPE) --
29 CFR 1910.120(g)
3.7 Frequency and Types of Air Monitoring, Personnel
Monitoring, and Environmental Sampling Techniques --
29 CFR 1910.120(h)
3.8 Confined Space Entry Procedures --
29 CFR 1910.120(j)(9)
3.9 Spill Containment Program --29 CFR 1910.120(j) . .
3.10 Decontamination -- 29 CFR 1910.120(k)
3.11 Emergency Response Plan --29 CFR 1910.120(1) . . .
Chapter 4 Health and Safety Field Review
4.1 Informational Programs -- 29 CFR 1910.120(b) and (i)
4.2 Site Control -- 29 CFR 1910.120(d)
4.3 Training -- 29 CFR 1910.120(e)
4.4 Medical Surveillance -- 29 CFR 1910.120(f)
4
5
5
6
7
8
9
11
11
12
14
15
17
18
18
20
21
22
23
26
26
27
29
33
-------
Page
4.5 Engineering Controls, Work Practices, and Personal
Protective Equipment for Employee Protection 36
4.6 Monitoring -- 29 GFR 1910.120(h) 44
4.7 Handling Drums and Containers --29 CFR 1910.120(j) . 47
4.8 Decontamination --29 CFR 1910.120(k) 51
4.9 Emergency Response --29 CFR 1910.120(1) 54
4.10 Illumination -- 29 CFR 1910.120(m) 57
4.11 Sanitation at Temporary Workplaces --
29 CFR 1910.120(n) 57
Chapter 5 Off-Site Emergency Response Review 60
5.1 Emergency Response Plan -- 29 CFR 1910.120(1) and (q). 61
5.2 Procedures for Handling Emergencies --
29 CFR 1910.120(q)(3) 64
5.3 Skilled Support Personnel -- 29 CFR 1910.120(q)(4) . . 65
5.4 Training Requirements -- 29 CFR 1910.120(q)(6) .... 66
5.5 Refresher Training --29 CFR 1910.120 (q)(8) . . . . . 73
5.6 Medical Surveillance and Consultation --
29 CFR 1910.120(f) and (q)(9) 74
5.7 Chemical Protective Clothing --
29 CFR 1910.120(g) and (q)(10) ..... 76
Appendix A Acronyms . A-l
Appendix B Other Common Applicable OSHA Standards B-l
Appendix C Incident Safety Check Off List C-l
Appendix D Levels of Personal Protection D-l
Appendix E Generic HASP E-l
Appendix F OSHA Form No. 200 F-l
Appendix G Bibliography G-l
-------
CHAPTER 1
INTRODUCTION
Section 126(a) of the Superfund
Amendments and Reauthorization Act of
1986 (SARA) requires the Secretary of
Labor to promulgate health and safety
standards pursuant to section 6 of the
Occupational Safety and Health Act of
1970 (OSH Act), for employees engaged
in hazardous waste operations. These
section 126(a) standards were
published on March 6, 1989 (54 FR
9294). Pursuant to section 126(c) of
SARA, the OSHA worker protection
regulations are effective on March 6,
1990, one year after the date of their
promulgation as a final rule. Until
that time, the existing interim final
rule, published on December 19, 1986
(51 FR 45654) , remains in effect. The
OSHA final regulations contain
standards for all private employees,
and for Federal employees through
Executive Order No. 12196. State and
local employees in States that have
OSHA-approved plans under section 18
of the OSH Act must comply with
standards at least as stringent as
the OSHA standards.
Section 126(f) of SARA requires
the Administrator of the U.S.
Environmental Protection Agency (EPA)
to promulgate standards identical to
those contained in the section 126(a)
OSHA regulations (codified at 29 CFR
1910.120). The EPA regulations
(codified at 40 CFR 311) cover State
and local government employees in
States that are without an OSHA-
approved State plan under section 18
of the OSH Act.
The EPA Audit Guidelines reflect
the requirements specified in the OSHA
final standard (29 CFR 1910.120) as
published on March 6, 1989. Because
the OSHA interim final rule is at
least as stringent as the OSHA final
rule, if an operation or activity is
in compliance with the OSHA interim
final rule of December 19, 1986, it
generally will also be in compliance
with the OSHA final standard.
The EPA Audit Guidelines provide
step-by-step guidance for assessing
preliminary evaluations, health and
safety plans (HASPs), and off-site
emergency response programs required
under the OSHA and EPA worker
protection standards. Employees
affected by the EPA standards will
primarily be those State and local
government employees engaged in
hazardous waste operations at
hazardous waste sites and State and
local off-site emergency response
personnel.
The following States currently
do not have OSHA-approved State plans
and, therefore, State and local
government employees in these States
are subject to EPA's final rule:1
Alabama
Arkansas
Colorado
Delaware
District of
Columbia
Florida
Georgia
Guam
Idaho
Illinois
Kansas
Louisiana
Maine
Massachusetts
Mississippi
Missouri
Montana
Nebraska
New Hampshire
New Jersey
North Dakota
Ohio
Oklahoma
Pennsylvania
Rhode Island
South Dakota
Texas
West Virginia
Wisconsin
1 The specific States covered by EPA's final rule may vary over time,
depending upon whether a State has in place an OSHA-approved State plan. The
States listed represent the affected States as of the date of publication of
EPA's final rule.
-------
The EPA Audit Guidelines are not
meant to be a comprehensive
compilation of all requirements in 29
CFR 1910.120. Rather, each section
and subsection in the guidelines
contains sample questions meant to
provide the auditor with a sense of
the likely level of compliance. If
compliance with the specific elements
in a subsection of these guidelines
is excellent, then it is likely that
all requirements under that subsection
have been met. If, on the other hand,
compliance is sketchy or weak, it is
advisable to pursue additional
questions and to investigate
compliance with that subsection
further. A series of questions
eliciting "YES" or "NO" answers guide
the user through the evaluation
process. A "NO" may indicate a
deficiency; the "EXPLAIN" prompt
provides an opportunity to describe
the apparent deficiency. The space
following each question can be used
to explain answers in greater detail,
and the space after the last question
in a series can be used to formulate
additional questions and/or comments
on a given subject area. The "Summary
of Responses" permits easy tabulation
of YES and NO responses after each set
of questions. The tabulation
indicates potential problems and
alerts on-site employees to areas
requiring additional work.
The EPA Audit Guidelines address
two major components of the OSHA/EPA
worker protection standards: health
and safety provisions at uncontrolled
hazardous waste sites and off-site
emergency response. The latter
provisions are addressed under Chapter
5 of these Guidelines and reflect the
requirements specified in 29 CFR
1910.120(q). The former provisions
are subdivided into three sections of
the EPA Audit Guidelines: Chapter 2:
Preliminary Evaluation, Chapter 3:
Written Health and Safety Plan Review,
and Chapter 4: Health and Safety
Field Review. The Preliminary
Evaluation section (Chapter 2)
provides background questions that may
be particularly useful if the HASP
appears weak in certain areas. A weak
HASP may be indicative of a weak
preliminary evaluation. The questions
in Chapter 2, therefore, may help the
auditor understand the reasons behind
the weakness and this in turn may lead
to the preparation of a better HASP.
For users of these Guidelines
whose purpose is to audit hazardous
waste site operations, two OSHA
publications provide useful
information on performing field
audits: Hazardous Waste Inspections
Reference Manual. 1986 and the OSHA
Field Operations Manual 2nd Edition,
1987.
The user is encouraged to refer
to the Appendices in the EPA Audit
Guidelines: Appendix A lists and
defines the acronyms used in the
Guidelines. Appendix B provides brief
explanations of other relevant OSHA
standards. Appendix C, "Incident
Safety Check Off List" is a quick
reference on the types of information
that must be obtained prior to
entering a site (i.e., preliminary
evaluation) and the types of
activities that should be conducted
following site work. Appendix D,
using information from 29 CFR 1910.120
Appendix B, provides detailed
information on EPA Levels A, B, C, and
D of personal protection, which have
been designed to take into account
respiratory and dermal routes of
exposure to hazardous chemicals.
Appendix E, "Generic HASP", refers to
a document developed by EPA to assist
field personnel in writing a HASP.
Due to the length of the document,
only the table of contents has been
provided. Copies of the document can
be obtained by contacting:
-2-
-------
U.S. Environmental Protection
Agency
Environmental Response Team
(MS-101)
Raritan Depot
Woodbridge Avenue
Edison, NJ 08837
Attention: Generic HASP
Appendix F "OSHA Form No. 200"
provides a form recommended by OSHA
for recording workplace related
injuries or illnesses. Appendix G,
"Reference List", includes a list of
reference materials that are available
to provide additional understanding
of health and safety issues and
procedures at hazardous waste sites.
Among the references are volumes on
toxicology, personal protective
equipment, and hazardous waste site
operations.
-3-
-------
CHAPTER 2
PRELIMINARY EVALUATION
29 CFR 1910.120(c)(4)
This section of the EPA Audit
Guidelines may be most useful during
the HASP review or during the health
and safety field review. Inadequacies
in these subject areas may be the
result of an insufficient PE of
available information.
The important elements in a
successful PE are listed in Appendix
C of the EPA Audit Guidelines. The
PE is an opportunity to collect
important background data regarding
the site. This information is used
to identify hazards and to select
appropriate methods of employee
protection. The PE is instrumental
in developing a HASP that tailors
protective measures to the site-
specific hazards that employees may
face. The site characterization
generally proceeds in two stages: (1)
off-site characterization, and (2)
field verification.
The following eight components
comprise essential information
required in the PE. (This information
should be compiled prior to employees
entering the site.)
2.1 Site Location and Size
The exact location and approximate size of the site should be depicted
appropriately through the use of a site location map or its equivalent.
Before going on a site, individuals should secure a site location map as well
as data on the size of the site.
2.1.1. Are the site location and approximate size of the site depicted
on a site location map or its equivalent?
[YES]
[NO, EXPLAIN]
2.1.2
2.1.3
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-4-
-------
2.2 Description of Response/Job Function
The appropriate composition of a site entry team depends on the nature of
the site, required activities of site personnel, and required level of
personal protection.
2.2.1 Prior to the initial site entry, have appropriate personnel and
responsibilities (e.g., health and safety officer, chemist)
been assigned for anticipated on-site job functions?
[YES]
[NO, EXPLAIN]
2.2.2
2.2.3
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN]
2.3 Planned Duration of Employee Activity
Estimated project duration and length of the employee workday determine
the need for special programs in the site HASP. Seasonal temperature extremes
often result in changes in recommended personal protective clothing and
equipment. Time or budget considerations may result in longer workdays for
the employees. Longer workdays may result in additional health and safety
considerations such as increased employee fatigue and additional lighting
requirements. (See Section IV.J. of these Guidelines for additional
information pertaining to appropriate lighting considerations.)
2.3.1 Does the PE estimate the appropriate length of time, (e.g.,
weeks or months, for each on-site employee activity)?
[YES]
[NO, EXPLAIN]
-5-
-------
2.3.2 Does the PE indicate the anticipated length of the on-site
employee workday?
[YES]
[NO, EXPLAIN]
2.3.3
2.3.4
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
2.4 Site Topography and Site Accessibility by Air and Roads
Topography influences movement of on-site contaminants, areas of present
contamination and potential future contamination, and logistical decisions,
such as the placement of the site command post. Before entering a site,
information should be compiled on site altitudes, site contour, presence of
bodies of water, and general terrain conditions (e.g., rocky, grassy,
mountainous, flat). Much of this information can be obtained from U.S.
Geological Survey (USGS) maps or equivalent topographical maps.
It is often possible to determine if a site is accessible by air and road
from site location maps, review of background data, and interviews. The PE
should confirm site access information. The availability of different roads
for entry and exit from a site improves the likelihood of rapid evacuation or
movement of injured personnel from the site. If roads are blocked by heavy
equipment or the results of extreme climatic conditions, alternate routes of
site entry and exit should be available. Although it is often not feasible,
air access to and from the site provides an additional alternative for rapid
evacuation of injured personnel. A significant and growing number of
hospitals provide emergency helicopter transportation for injured people.
2.4.1 Does the PE indicate that appropriate measures have been taken
to characterize the site topography?
[YES]
[NO, EXPLAIN]
-6-
-------
2.4.2 Does the PE indicate that a topographical map has been used?
[YES] [NO, EXPLAIN]
2.4.3 Does the PE identify site access by air and roads?
[YES] [NO, EXPLAIN]
2.4.4
2.4.5
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
2.5 Safety and Health Hazards Expected at the Site
During the PE it is important that safety and health hazards be
identified or anticipated prior to going on-site. By accomplishing this
during the preliminary evaluation, employees will be better able to prepare
for appropriate personal protective equipment (PPE), air monitoring
instruments, and the development of an effective work plan.
2.5.1 Does the PE identify the expected safety and health hazards for
the site?
[YES]
[NO, EXPLAIN]
2.5.2
-7-
-------
2.5.3
SUMMARY OF RESPONSES [YES]
2.6 Pathways for Hazardous Substance Dispersion
[NO, EXPLAIN].
To anticipate appropriate personal protective equipment (PPE) for the
site HASP, it is essential to understand the potential exposure pathways for
contaminants. By considering the media where contaminants are found, the
physical and chemical characteristics of the contaminants, and the anticipated
site operations, the individual(s) performing the site characterization should
be able to predict potential hazardous substance dispersion pathways.
2.6.1 Does the PE indicate the media (soil, sediment, water, and air)
where on-site chemical contamination is known to exist?
[YES]
[NO, EXPLAIN]
2.6.2
Were physical and chemical characteristics of known compounds
considered during the PE?
[YES]
[NO, EXPLAIN]
2.6.3
Does the preliminary evaluation indicate dispersion pathways,
(e.g., airborne, direct contact)?
[YES]
[NO, EXPLAIN]
2.6.4
2.6.5
SUMMARY OF RESPONSES
[YES]
[NO, EXPLAIN].
-8-
-------
2.7 Present Status of Emergency Response Teams for On-Site Emergencies
During the PE it is critical to determine the capabilities of emergency
response teams who may respond in the event of an on-site emergency.
2.7.1 Does the PE identify the present status and capabilities of the
emergency response teams that would provide assistance to on-
site employees in the event of an emergency?
[YES]
[NO, EXPLAIN]
2.7.2
2.7.3
SUMMARY OF RESPONSES
[YES]
[NO, EXPLAIN].
2.8 Hazardous Substances and Health Hazards Involved or Expected at the Site
and Their Chemical and Physical Properties
The physical and chemical properties of the hazardous substances on-site
affect PPE selection in the site HASP. For instance, for Level C personal
protection, selection of appropriate respirator canisters depends on the
physical and chemical properties of the hazardous substances (i.e., some
chemicals pass directly through certain canisters). The complexity of PPE
selection requires that the physical and chemical properties of hazardous
substances along with their health hazards be considered in the PE.
2.8.1 Are the physical and chemical properties of all known or
suspected chemical contaminants documented in the PE?
[YES]
[NO, EXPLAIN]
-9-
-------
2.8.2 Are the health hazards of all known or suspected hazardous
substances documented in the PE?
[YES]
[NO, EXPLAIN]
2.8.3
2.8.4
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-10-
-------
CHAPTER 3
WRITTEN HEALTH AND SAFETY PLAN
The HASP elements in the box to
the left do not appear in the same
order as provided in 29 CFR
1910.120(b). Instead, these elements
are arranged in the order in which
their associated relevant paragraphs
appear within 29 CFR 1910.120.
This checklist portion of the EPA
Audit Guidelines permits the user to
identify inadequacies in the HASP.
Answers to the HASP checklist
questions should be ascertainable by
reviewing the HASP.
At a ateimam tha S&SB
following
sowtate She
o£ fcey personnel responsible
i&l* SifcfS safftty; ^
Safety -and 'health jsisk analysis
each site tasK and
Sifcfr «anfcrol
£
-------
3.1.2 Are the health and safety personnel (including alternates)
identified in the HASP?
[YES]
[NO, EXPLAIN]
NOTE: During the field audit, verify key site personnel and
the presence of the site health and safety officer.
3.1.3
3.1.4
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
3.2 Safety and Health Risk Analysis for Each Site Task and Operation - 29 CFR
1910.120(b)(4)
Simple risk analyses can be conducted based on the chemical contaminants
of concern, the affected media, concentrations, and potential routes of
exposure. These elements are essential to any analysis of health risks.
OSHA-PELs and IDLH levels should be provided at a minimum for compounds, which
have the potential to become airborne. These values can be located for many
compounds in the NIOSH/OSHA Pocket Guide to Chemical Hazards. 1985, as well as
in 29 CFR 1910.1000 as published on January 19, 1989 (FR Vol. 54, No. 12).
The HASP also should incorporate some safety risk analyses to address
anticipated on-site operations. Certain field operations may be less safe
when conducted at a hazardous waste site than if conducted in a more
conventional environment. In addition, certain jobs at a hazardous waste site
differ in their potential hazards. For instance, the job of a heavy equipment
operator or materials handler would generally be a more hazardous job than the
job of a supervisor because of the increased risk of direct contact with the
concentrated waste. Methods and procedures for reducing safety hazards should
be provided in the HASP.
The EPA Superfund Public Health Evaluation Manual (1986), may be useful
to users as a tool for performing more sophisticated health risk analyses
attributable to common chemical contaminants found at hazardous waste sites.
The Guidelines enable the user to calculate hazard indices for chemicals
without carcinogenic potential, and to calculate the likely increase in cancer
incidence rates associated with exposure to carcinogens at the hazardous waste
site.
-12-
-------
3.2.1 Does the HASP address methods to deal with potential safety
problems (e.g. heavy equipment operations, presence of live
electrical sources, and slip, trip, fall hazards)?
[YES]
[NO, EXPLAIN]
3.2.2 Does the HASP contain a safety and health risk or hazards
analysis for each site task and operation found in the
workplan?
[YES]
[NO, EXPLAIN]
3.2.3
NOTE: Verification of incorporation into the HASP of health
and safety risk analysis for each site task and operation
occurring in the field should be determined during the field
audit.
Are chemical contaminants, affected media, concentrations,
potential routes of exposure, and health effects identified in
the HASP?
[YES]
[NO, EXPLAIN]
3.2.4 Does, the HASP identify the appropriate PPE level for each site
task and operation?
[YES]
[NO, EXPLAIN]
3.2.5
-13-
-------
3.2.6
[NO, EXPLAIN].
SUMMARY OF RESPONSES [YES]
3.3 Site Control - 29 CFR 1910.120(d)
A site control program is required by 29 CFR 1910.120(d). It should
include a site map, site work zones, site communications, safe work practices,
and identification of the nearest medical assistance. The "buddy system"
should be used throughout site operations.
Site control addresses the establishment of work zones to minimize the
hazard to on-site employees and to facilitate site operations.
3.3.1 Does the HASP contain a section on site control defining work
zones on-site?
[YES]
[NO, EXPLAIN]
3.3.2
Does the HASP contain information on the use of the "buddy
system" during all site operations?
[YES]
[NO, EXPLAIN]
3.3.3 Does the HASP contain a site map that includes the location of
work zones?
[YES]
[NO, EXPLAIN]
3.3.4
NOTE; Verification of the physical/visual segregation of work
zones should be conducted during the field audit.
Does the HASP contain information on site communications?
[YES1 [NO, EXPLAIN]
-14-
-------
3.3.5 Does the HASP contain information on safe work practices,
(e.g., no eating in exclusion zone)?
[YES]
[NO, EXPLAIN]
3.3.6 Does the HASP identify the nearest medical assistance?
[YES] [NO, EXPLAIN]
3.3.7
3.3.8
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
3.4 Employee Training - 29 CFR 1910.120(e)
The employee's initial health and safety training, annual health and
safety refresher training, on-the-job training, supervisory training (where
applicable), first-aid training, GPR training, and other training relevant to
the performance of hazardous waste site operations should be indicated in the
HASP for all individuals involved in on-site activities.
3.4.1 Does the HASP indicate that all on-site employees meet
appropriate health and safety training requirements?
[YES]
[NO, EXPLAIN]
If NO, please go on to questions 2-5, while if YES please go on
to question 6.
-15-
-------
3.4.2 Does the HASP indicate that all individuals expected to be on-
site have the requisite initial health and safety training?
[YES]
[NO, EXPLAIN]
3.4.3
Does the HASP indicate that individuals functioning in a
supervisory capacity have the requisite supervisory training?
[YES]
[NO, EXPLAIN]
3.4.4
Does the HASP indicate that all individuals functioning
independently of an immediate supervisor have a minimum of
three days of actual field experience under a skilled
supervisor (on-the-job training)?
[YES]
[NO, EXPLAIN]
3.4.5 Does the HASP indicate that all individuals who had their
initial health and safety training longer than one year ago
have also completed the required annual health and safety
refresher training?
[YES]
[NO, EXPLAIN]
3.4.6 Does the HASP indicate that employees have had training to
recognize the symptoms and signs of pver-exposure to chemical
hazards?
[YES]
[NO, EXPLAIN]
-16-
-------
3.4.7 If there is no medical facility in proximity to the site, do
the training records in the HASP indicate at least one
individual on-site who is adequately trained to render first
aid (see Appendix B for summary of 29 CFR 1910.151)?
[YES]
[NO, EXPLAIN]
3.4.8
3.4.9
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
3.5 Medical Surveillance - 29 CFR 1910.120(£)
29 CFR 1910.120 requires a comprehensive medical surveillance program to
monitor the health status of personnel who potentially are exposed to
hazardous substances in the field and who wear respirators 30 or more days in
a year. The program must include initial and periodic medical examinations,
examinations upon termination of employment, and medical recordkeeping.
3.5.1 Does the HASP indicate that site personnel who may be exposed
at or above the OSHA-PELs or other published exposure levels or
wear respirators 30 or more days each year are enrolled in a
comprehensive medical monitoring program before working on-
site?
[YES]
[NO, EXPLAIN]
3.5.2
3.5.3
SUMMARY OF RESPONSES [YES] [NO, EXPLAIN].
-17-
-------
3.6 Personal Protective Equipment (PPE) - 29 CFR 1910.120(g)
Engineering controls and work practices should first be explored as
methods to protect workers before personal protective equipment is used. The
standard describes PPE ensembles as Level A, B, C, and D. These levels are
described more fully in Appendix D of these Guidelines. PPE ensembles
prescribed in the HASP must specifically address the potential site-specific
hazards. PPE ensembles themselves may create additional hazards such as heat
stress under extreme conditions. Different PPE ensembles may be used for
different site operations and in different portions of the same site.
3.6.1 Does the HASP prescribe specific PPE ensembles for each site
activity as defined in the site operations/site work plan?
[YES]
[NO, EXPLAIN]
3.6.2 Does the HASP contain, or make reference to, a comprehensive,
written PPE program specific to site operations that addresses
site hazards, duration of site activity, limitations of PPE
during temperature extremes, and PPE selection, use,
maintenance and storage, decontamination procedures, training
and proper fitting, donning and doffing procedures, inspection,
and in-use monitoring?
[YES]
[NO, EXPLAIN]
3.6.3
3.6.4
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
3.7
Frequency and Types of Air Monitoring, Personnel Monitoring, and
Environmental Sampling Techniques - 29 CFR 1910.120(h)
A comprehensive, site-specific air monitoring program must evaluate the
exposure potential of all identified and suspected chemical contaminants that
could result from all site activities. Typically, such a program consists of
two types of air monitoring. First, in 29 CFR 1910.1001-1048, OSHA has
published specific personal exposure monitoring requirements for 23 chemical
-18-
-------
substances including benzene and formaldehyde. The site-specific air
monitoring program must meet any applicable requirements as described therein.
The program must characterize representative personal exposures. Personal
sampling techniques, such as passive dosimeters, diffusion tubes, and charcoal
tube sampling with pumps and subsequent laboratory analyses, are described in
the NIOSH Manual of Analytical Methods. 3rd Edition (1984).
Second, the program must describe real time air monitoring protocols
using direct reading instruments for each site activity as appropriate. These
monitoring protocols must describe the frequency and location of all real time
monitoring activity, based upon the nature of the site activity. Periodic
real time monitoring must be performed, at a minimum, whenever site work
begins, operations change, work begins on a different portion of the site, any
invasive site activity begins, contaminants other than those previously
identified are being handled, personnel begin to handle obviously contaminated
materials or personnel are handling leaking drums or containers. Monitoring
efforts should focus on personnel most likely to receive the highest exposures
and on all personnel likely to be exposed to any substance above the OSHA-
Permissible Exposure Limit (OSHA-PEL). OSHA has recently revised its list of
air contaminants and their accompanying standards. These air contaminants and
their respective OSHA-PELs are available in Air Contaminants - Permissible
Exposure Limits: OSHA 3112; 1989.
3.7.1 Does the HASP indicate that upon initial entry, representative
air monitoring shall be conducted to identify IDLH conditions,
exposure above OSHA-PELs or other published exposure levels
including exposure to radiation, flammable atmospheres, and/or
oxygen deficient atmospheres?
[YES]
[NO, EXPLAIN]
3.7.2 Does the HASP describe the components of an air monitoring
program that addresses all known and suspected site
contaminants for all site activities?
[YES]
[NO, EXPLAIN]
3.7.3 Are any chemical substances listed in 29 CFR 1910.1001-1048
known or expected to be on-site?
[YES]
[NO, EXPLAIN]
-19-
-------
If question "3" was answered [YES], does the HASP prescribe
personal monitoring programs to meet the specific personal
monitoring requirements described in that rule?
[YES]
[NO, EXPLAIN]
3.7.4 Does the HASP specify regular maintenance and calibration of
all real time air monitoring instruments?
[YES]
[NO, EXPLAIN]
3.7.5
3.7.6
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
3.8 Confined Space Entry Procedures - 29 CFR 1910.120(j)(9)
If confined space entries are anticipated during site activities, then
confined space entry procedures should be detailed in the HASP. Entry into an
abandoned building or a storage vessel may be examples of confined space
entries.
3.8.1 If confined space entry is anticipated on-site, does the HASP
contain a section on procedures for confined space entry?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
A [NOT APPLICABLE] response may indicate that confined space
entry on-site is not anticipated.
NOTE: During the field audit, verify that the confined space
entry procedures provided in the HASP are appropriate to field
conditions.
-20-
-------
3.8.2
3.8.3
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
3.9 Spill Containment Program - 29 GFR 1910.120(j)
In a spill/release of a hazardous chemical on-site, the HASP should
contain detailed information in a spill containment program. The elements
that may need to be addressed in the spill containment program include:
Drum and Container Handling
Opening of Drums and Containers
Material Handling Equipment
Radioactive Wastes
Shock Sensitive Wastes
Laboratory Waste Packs
Sampling of Drum and Container Contents
Shipping and Transport of Drums and Containers
Appropriate Procedures for Tank and Vault Entry
3.9.1 Does the HASP contain a section addressing elements of a spill
containment program that are relevant to the site?
[YES]
[NO, EXPLAIN]
3.9.2 Where there is a potential for a major spill, does the HASP
provide adequate information for the containment and isolation
of the entire volume of any hazardous substance being
transferred?
[YES]
[NO, EXPLAIN]
3.9.3
-21-
-------
3.9.4
[NO, EXPLAIN].
SUMMARY OF RESPONSES [YES]
3.10 Decontamination - 29 CFR 1910.120(k)
Decontamination involves the safe removal of chemical contaminants from
employees and equipment. Decontamination procedures should be chosen to match
the anticipated contaminants for the site.
3.10.1 Does the HASP contain a section on decontamination of employees
and equipment?
[YES]
[NO, EXPLAIN]
3.10.2 Are the decontamination procedures in the HASP appropriate for
the anticipated on-site contaminants?
[YES]
[NO, EXPLAIN]
3.10.3 Does the HASP provide for monitoring of decontamination
procedures by the site health and safety supervisor?
[YES]
[NO, EXPLAIN]
3.10.4
3.10.5
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-22-
-------
3.11 Emergency Response Plan - 29 CFR 1910.120(1)
Hazardous waste sites can present high hazard environments. Therefore, a
program addressing potential emergency situations, must be included in the
HASP. Such a contingency plan should be communicated to employees on-site
through the HASP, as well as through safety meetings and briefings. The
emergency response plan portion of the HASP should be sufficiently detailed to
insure prompt, safe evacuation of all employees from the site in the event of
an emergency. It is recommended that the auditor call the phone numbers
provided in the HASP for fire, police, ambulance, and hospital to determine
the accuracy of these phone numbers. A method for determining wind direction
that is visible to employees in the event of a site evacuation is useful in
the HASP.
3.11.1 Does the HASP contain a separate section for the emergency
response plan that is available for inspection and copying by
employees, their representatives, OSHA personnel, and other
governmental agencies with relevant responsibilities?
[YES]
[NO, EXPLAIN]
3.11.2 Does the emergency response plan in the HASP provide for on-
site emergencies by addressing the following elements?
3.11.2.1 Pre-emergency planning?
[YES]
[NO, EXPLAIN]
3.11.2.2 Personnel roles, lines of authority, and
communication?
[YES]
[NO, EXPLAIN]
3.11.2.3 Emergency recognition and prevention?
[YES] [NO, EXPLAIN]
-23-
-------
3.11.2.4 Safe distances and places of refuge in the event of
an unexpected chemical spill/release?
[YES]
[NO, EXPLAIN]
3.11.2.5 Site security and control?
[YES] [NO, EXPLAIN]
3.11.2.6 Evacuation routes and procedures?
[YES] [NO, EXPLAIN]
3.11.2.7 Decontamination procedures not covered in other parts
of the HASP?
[YES]
[NO, EXPLAIN]
3.11.2.8 Emergency medical treatment and first aid?
[YES] [NO, EXPLAIN]
3.11.2.9 Emergency alerting and response procedures?
[YES] [NO, EXPLAIN]
-24-
-------
3.11.2.10 Procedure for critique of response and follow-up?
[YES] [NO, EXPLAIN]
3.11.2.11 PPE and emergency equipment?
[YES] [NO, EXPLAIN]
3.11.2.12 Site topography, layout, and prevailing weather
conditions?
[YES]
[NO, EXPLAIN]
SUMMARY OF RESPONSES
[YES]
[NO, EXPLAIN].
-25-
-------
CHAPTER 4
HEALTH AND SAFETY FIELD REVIEW
In the field verification portion
of the EPA Audit Guidelines, the user
determines the adequacy of health and
safety measures in the field. Many
of the questions that follow can be
answered by observing field
activities, interviewing field
personnel, and reviewing the written
health and safety program. Many
questions will provide space for the
user of the EPA Audit Guidelines to
verify responses from other field
personnel. These questions are
followed by: "Field Verification
1.
2.
3.
Generally, the questions will elicit
different responses from field
personnel. These questions should be
answerable by most field personnel.
For instance, questions that provide
for additional responses will not be
those that can be answered by the EPA
Audit Guidelines user through field
observation. Certain questions do not
require verification by more than one
knowledgeable person and, as such,
would not be questions that warrant
additional field verification.
4.1. Informational Programs - 29 CFR 1910.120(b) and (i)
It is the employer's responsibility to develop and implement a written
safety and health program consistent with 29 CFR 1910.120(b) - Safety and
health program.
4.1.1 Has the employer informed workers or their representatives of
the site emergency response procedures and any potential fire,
explosion, health, safety, or other hazards of the hazardous
waste operation that have been identified?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.1.2 Is the site HASP available on-site for inspection by employees,
designated representatives of the employees, EPA, and OSHA
personnel (when applicable)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
_
-26-
-------
4.1.3 Have health and safety briefings been held prior to the start
of site activities and as necessary, to insure that employees
remain apprised of the HASP?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.1.3 Are inspections of the site being conducted by the site safety
and health supervisor or designee to verify compliance with the
plan?
(NOTE: It is the employer's responsibility to correct any
deficiencies in the site HASP.)
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.1.5
4.1.6
[NO, EXPLAIN].
SUMMARY OF RESPONSES [YES]
4.2 Site Control - 29 CFR 1910.120(d)
Site control should "minimize potential contamination of workers, protect
the public from the site's chemical and physical hazards, facilitate work
activities, and prevent vandalism."1 In accordance with 29 CFR
1910.120(d)(3), the site control plan must include a site map, site work
zones, use of a "buddy system," site communications, standard operating
procedures or safe work practices, and identification of nearest medical
assistance. Often sites are divided into exclusion zone(s), contamination
reduction zone(s), and a support zone.
1 Hazardous ¥aste Handbook for Health and Safety, p. 149.
-27-
-------
4.2.1 Is there a site map that is available to employees?
[YES] [NO, EXPLAIN]
Field Verification
1.
2.
3.
4.2.2
NOTE; It is useful if this map depicts such details as
topographic features, prevailing wind direction, location of
buildings, bodies of water, and known locations of any chemical
wastes?
Are site work zones clearly defined on-site (e.g., banner guard
or other appropriate indicators)?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.2.3 Does the site control program indicate site work zones (e.g.,
exclusion zone(s), contamination reduction zone(s), and support
zones)?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.2.4 Are on-site communication systems such as walkie talkies or
blasting horns available to alert employees in the event of a
site evacuation?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-28-
-------
4.2.5 Has the route to the nearest comprehensive medical treatment
facility been made available to on-site employees?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.2.6 Is the site perimeter indicated appropriately, (e.g., existing
fenceline, boundary markings, security patrol) and labeled with
appropriate warning signs to alert nearby residents to the
potential on-site hazards?
[YES]
[NOT AVAILABLE]
[NO, EXPLAIN]
1.
2.
3.
Field Verification
4.2.7 Are emergency phone numbers conspicuously posted at the site?
[YES] [NO, EXPLAIN]
Field Verification 1.
4.2.8
2.
3.
4.2.9
[NO, EXPLAIN].
SUMMARY OF RESPONSES [YES]
4.3 Training - 29 CFR 1910.120(e)
Training is required for all employees who engage in hazardous waste
field activities. These requirements include initial off-site health and
safety training, supervised on-the-job training, and annual health and safety
refresher training.
On-site managers or supervisors with direct responsibility for
supervision of employees engaged in hazardous waste operations require
-29-
-------
additional training. To determine field compliance with training
requirements, the users should interview employees, request documentation from
employees and/or their home office, and determine employee proficiency through
observation and requests of employees to demonstrate proficiency.
4.3.1 Do all employees working on-site have documentation available
to indicate initial health and safety training?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.3.2 Do all employees working on-site have documentation available
which meets the on-the-job training requirements for 29 CFR
1910.120(e)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.3.3 Do all employees working on-site who had their initial health
and safety training one year or more ago, have documentation
available indicating completion of an eight hour annual health
and safety refresher training course?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.3.4 Do on-site managers and supervisors who are directly
responsible for supervision of employees engaged in hazardous
waste operations have documentation of additional training
relating to site operations?
[YES]
[NO, EXPLAIN]
Field Verification 1.
-30-
-------
4.3.5 Can the employer show by documentation or certification that an
employee's work experience and/or training has resulted in
training equivalent to that required of the employee by the
standard?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.3.6 Have the employees working on-site been trained appropriately
in safety, health, and other hazards present on the site?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.3.7 Have the employees working on-site received appropriate
training in the use of PPE?
[YES]
[NO, EXPIAIN]
Field Verification 1.
2.
3.
4.3.8 Have the employees working on-site received appropriate
training in medical surveillance requirements, including
recognition of symptoms and signs that might indicate
overexposure to hazards?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-31-
-------
4.3.9
Have the employees working on-site received training in the
following elements of the site specific HASP?
4.3.9.1
[YES]
Site control measures?
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.3.9.2 Decontamination procedures ?
[YES] [NO, EXPLAIN]
Field Verification' 1.
2.
3.
4.3.9.3 Emergency response plan?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.3.9.4 Confined space entry procedures?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
4.3.10
Are individuals who may be exposed to unique or special hazards
provided with sufficient training beyond minimum training
requirements to ensure their safety when performing such
operations?
[YES]
Field Verification 1.
[NO, EXPLAIN]
2.
3.
-32-
-------
4.3.11 Do employees participating in field activities have an
appropriate level of training to perform their job function and
responsibility as indicated by an appropriate license or
certification (e.g., license indicating proficiency on the
forklift)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
4.3.12
2.
3.
4.3.13
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
4.4 Medical Surveillance - 29 CFR 1910.120(f)
A medical monitoring program is essential to assess and monitor workers'
health and fitness. In addition, OSHA recommends a medical evaluation for
employees required to wear a respirator (29 CFR Part 1910.134[b][10]), and
certain OSHA standards include specific medical requirements (e.g., 29 CFR
Part 1910.95 and 29 CFR Parts. 1910.1001 through 1910.1048). Members of
hazardous materials' teams are also required to be enrolled in a medical
monitoring program.
Medical examinations, provided without cost to the employee, must include
a medical and work history with special emphasis on symptoms related to the
handling of hazardous substances and health hazards. • Special emphasis should
also be placed on fitness for duty, including the ability to wear any required
PPE under conditions that may be expected at the work site (e.g., temperature
extremes). The employer should obtain and furnish the employee with a copy of
a written statement from the examining physician, documenting that the
employee is qualified to work at hazardous waste sites and to wear respiratory
protection equipment. All.medical records should be maintained as
confidential and made available to the employee or his designee upon written
request.
-33-
-------
4.4.1 Do the on-site employees participate in a medical monitoring
program that meets the requirements of 29 CFR 1910.120(f)?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.4.2 Do employees who wear respiratory protection at hazardous waste
sites for 30 days or more per year or may be exposed to
hazardous substances at or above OSHA-PELs or other published
exposure limits have documentation available (in their home
office or on the site) that indicates they have had baseline
physicals and receive yearly physicals consistent with 29 CFR
1910.120(f)? ,
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.4.3 Are employees provided with medical reports from the attending
physician in writing?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.4.4 Have employees received a verbal medical briefing regarding the
results of their physicals?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-34-
-------
4.4.5 Are employee medical records available upon request?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
4.4.6 Have the employees working on-site been trained in medical
surveillance requirements, including recognition of symptoms
and signs that might indicate over-exposure to physical or
chemical hazards [29 CFR 1910.120(e)]?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.4.7 Do employees who wear respiratory protection at hazardous waste
sites less than 30 days per year have documentation available
(in their home office or on the site) that certify that they
are physically able to wear a respirator (i.e., 29 CFR
1910.134)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.4.8
4.4.9
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-35-
-------
4.5 Engineering Controls, Work Practices, and Personal Protective Equipment
For Employee Protection - 29 CFR 1910.120(g)
The following references cited in Appendix G of the Guidelines would be
particularly helpful for evaluating compliance with the PPE provisions in the
HASP:
Personal Protective Equipment for Hazardous Material Incidents: A
Selection Guide. 1984;
Guidelines for the Selection of Personal Protective Equipment. 3rd
Edition, 1987;
Hazardous Waste Inspections Reference Manual. 1986; and
Performance of Protective Clothing. 1986.
To determine if an employee is adequately trained in the use of PPE, on-
site interviews should be conducted to ascertain the employee's familiarity
with the PPE. It may also be appropriate to request that an employee
demonstrate his/her knowledge of PPE by demonstrating its use in the Support
Zone. (The employee should not be requested to demonstrate PPE knowledge in
the Exclusion Zone, especially since the employee may have an inadequate
understanding of the PPE in question.)
,29 CFR 1910.120(g) requires establishment of a PPE program for hazardous
waste operations that addresses:
Site hazards;
PPE selection;
PPE use;
Work mission duration;
PPE maintenance and storage;
PPE decontamination and disposal;
PPE training and proper fitting;
PPE donning and doffing procedures;
PPE inspection procedures prior to, during, and after use;
Evaluation of the effectiveness of the PPE program; and
Limitations during temperature extremes, heat stress, and other
medical considerations.
4.5.1
Personal Protective Equipment - General
Appendix D of the EPA Audit Guidelines provides guidance on appropriate
PPE for EPA's Levels A, B, C, and D.
-36-
-------
4.5.1.1 Is a written PPE program that meets the aforementioned 11
elements including procedures, guidelines, and policy
statements regarding the use of PPE, available for
inspection?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
If the answer is [NO], ask employee(s) these questions and/or
observe for the 11 PPE program element questions below.
a. Are the employees trained regarding on-site hazards?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
b. Are the employees adequately trained in selection of PPE?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
c. Are the employees adequately trained in the use of PPE?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
-37-
-------
d. Are the employees informed regarding estimated lengths of
time for job tasks and estimated time of project duration?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
e. Do employees maintain and store PPE appropriately?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
f. Do employees know how to decontaminate and dispose of PPE
properly?
[YES]
[NO, EXPLAIN]
2.
Field Verification 1.
g. Are employees fitted properly for PPE?
3.
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
h. Do employees know how to don and doff PPE?
[YES] [NO, EXPLAIN]
Field Verification 1.
-38-
-------
i. Do employees know how to adequately inspect PPE (e.g.,
inspection of gloves, fully encapsulating suits, etc.)
prior to, during, and after use?
[YES] [NO, EXPLAIN]
Field Verification
1.
2.
3.
Is there a system in place to evaluate the effectiveness
of the PPE program?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
k. Are employees knowledgeable about limitations on PPE
related to temperature extremes, heat stress, and other
appropriate medical considerations?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.5.1.2 Are employees at this specific site adequately trained in the
use, maintenance, and storage of PPE?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
-39-
-------
4.5.1.3 Is there sufficient PPE available for the personnel involved in
the. performance of site operations?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.5.1.4 Is health and safety instrumentation (e.g., FID, PID, air
sampling pumps, radiation meters) maintained and calibrated on-
site?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.5.1.5 Is the PPE in place adequate for the chemical and physical
hazards on-site?
[YES]
[NO, EXPLAIN]
Field Verification 1.
4.5.1.6
2.
3.
4.5.1.7
4.5.2
SUMMARY OF RESPONSES
Respiratory Protection
[YES].
[NO, EXPLAIN].
The following references cited in Appendix G of the EPA Audit Guidelines
are particularly helpful for evaluating the respiratory protection provisions
in the HASP:
Air Sampling Instruments. 1983;
Guide to Industrial Respiratory Protection. 1987;
-40-
-------
Guide to Portable Instruments for Assessing Airborne Pollutants
Arising from Hazardous Wastes. 1988;
Guidelines for the Selection of Personal Protective Equipment. 3rd
Edition, 1987;
NIOSH/OSHA Pocket Guide to Chemical Hazards. 1985; and
Practical Guide to Respirator Use in Industry. 1985.
4.5.2.1 Is a written respiratory protection program that contains
written standard operating procedures for selection and use of
respirators (i.e., 29 CFR 1910.134) present and available for
inspection on-site?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.5.2.2 Have all employees who are working on-site been fit-tested
successfully for negative pressure respirators in accordance
with 29 CFR 1910.134?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.5.2.3 Do employees who wear respiratory protection at hazardous waste
sites have documentation available (at the home office or on
the site) that indicates they have had baseline physicals and
they receive yearly physicals consistent with 29 CFR
1910.120(f)?
[YES]
[NO, EXPLAIN]
Field Verification
4.5.2.4
1.
2.
-41-
-------
4.5.2.5
4.5.3
SUMMARY OF RESPONSES
PPE Physical Hazards
[YES].
[NO, EXPLAIN].
A new answer category [NOT APPLICABLE] was added to each of the questions
in this section because oftentimes specific physical hazards will be unique to
a site.
4.5.3.1 If there are overhead hazards (low hanging objects, overhead
work) on-site, do employees wear hard hats in these work areas
that meet the requirements of 29 CFR 1910.135?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.5.3.2 If 8-hour time weighted average noise measurements indicate
that ambient noise levels may be greater than or equal to 85
dBA, are ear muffs or ear plugs worn by employees on-site as
required by 29 CFR 1910.95?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
NOTE: 29 CFR 1910.95 requires.the implementation of a hearing
conservation program for employees if time weighted average
noise levels equal or exceed 85 dBA.
4.5.3.3 If heat or cold stress is a concern on-site, are engineering
and administrative controls (e.g., work/rest regimen) being
properly considered to ensure that appropriate PPE can be worn
by employees and still be protective for them?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
-42-
-------
NOTE: PPE should always be sufficient to protect employees.
Administrative controls should first be addressed as a means to
minimize exposure to temperature extremes.
Field Verification
1.
2.
3.
4.5.3.4 If radiation (i.e., ionizing or non-ionizing) is a concern on-
site, are engineering/administrative controls and/or PPE
selection appropriate for the tasks at hand (e.g., use of
radiation meters, use of UV goggles by welders)?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.5.3.5 If "hot work" such as welding or cutting is occurring on-site,
the following questions apply:
a. Is appropriate combustible gas indicator (CGI) air
monitoring being conducted?
[YES]
[NOT APPLICABLE]
• [NO, EXPLAIN]
Field Verification 1.
2.
3.
b. Is the employee wearing appropriate protective goggles and
fire retardant clothing?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-43-
-------
4.5.3.6 If there are other unique physical hazards on-site (e.g.,
explosives, deep and/or rapidly moving water), is appropriate
PPE being worn on-site to address such problems?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
Field Verification 1.
4.5.3.7
2.
3.
4.5.3.8
SUMMARY OF RESPONSES
4.6 Monitoring - 29 CFR 1910.120(h)
[YES]
[NO, EXPLAIN].
Two principal approaches are available for identifying and/or quantifying
airborne contaminants:
• On-site use of real time instruments; and
• Laboratory analysis of air samples obtained by gas sampling
bag, collection media (e.g., filter, sorbent), and/or wet-
contaminant collection methods (e.g., impinger method or wet
chemistry technique).
All instruments used on-site should be operated in accordance with
accompanying equipment manuals. Many of the detector tubes have both positive
and negative interferences that are specified in the accompanying literature
for the respective detector tube.
Air sampling methods that use charcoal tubes, TenaxR tubes, silica gel
tubes, and wet chemistry techniques (e.g., impinger methods) will often be
necessary to assist in the identification of unknown contaminants.
It is important that users realize that there are many compounds for
which there are no real time instruments capable of measuring contamination.
As a result, it often is necessary to resort to air sampling with subsequent
laboratory analyses. OSHA regulations require particular air sampling
procedures, PPE requirements, and recordkeeping for a variety of compounds.
If information from the site characterization indicates a potential for
ionizing radiation and/or IDLH conditions on-site or if insufficient
information is available to demonstrate otherwise, then air monitoring shall
include:
-44-
-------
• Monitoring with direct readout instrumentation for ionizing
radiation and/or IDLH conditions including toxic, explosive,
combustible, and oxygen deficient atmospheres; and
• Visual observation for actual or potential IDLH conditions on-site.
If after site characterization there are indications that the site is
safe for start-up operations, a regular air monitoring program must be adhered
to during site operations.
4.6.1 Is air monitoring being conducted to identify and quantify
airborne levels of hazardous substances in order to determine
the appropriate level of on-site employee protection?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.6.2 Is air monitoring being conducted to first identify Immediately
Dangerous to Life or Health (IDLH) levels and other dangerous
situations, such as the presence of flammable atmospheres,
oxygen deficient environments, toxic levels of airborne
contaminants, and radioactive materials?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.6.3 Is air monitoring being performed any time new work begins on a
different portion of the site?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-45-
-------
4.6.4 Is air monitoring being performed any time that new
contaminants are encountered that differ from those initially
encountered?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.6.5 Is air monitoring being performed every time a different
operation is initiated?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-46-
-------
4.6.6 Is air monitoring being performed whenever employees are
working in an area with obvious liquid contamination (e.g.,
spill, lagoon, leaking drums)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.6.7 Are the employees who are likely to have exposures above
established OSHA-PELs participating in a personal air sampling
program?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.6.8
NOTE: A representative sampling approach may be used as long
as it is documented and the selection of.employees and
monitored chemicals are based on the criteria stated in 29 CFR
1910.120(h).
Are there maintenance and calibration logs on-site for the air
monitoring equipment?
[YES]
[NO, EXPLAIN]
If YES, are the calibration logs on-site up to date?
[YES] [NO, EXPLAIN]
Field Verification 1.
4.6.9
2.
3.
-47-
-------
4.6.10
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
4.7 Handling Drums and Containers - 29 CFR 1910.120(j)
If drums or containers are present on-site, appropriate and specific
handling procedures must be established. Employees must be trained in the
appropriate procedures for drum handling as well as the hazards associated
with drum or container contents. During all drum or container operations
(e.g., transfer operations, sampling operations), fire extinguishing equipment
must be on hand. During clean-up procedures, drums and containers must meet
appropriate DOT, OSHA, and EPA regulations.
4.7.1 Are drums and containers being used for the clean-up on-site?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
If [YES], do the drums meet appropriate DOT, OSHA, and EPA
regulations for the wastes they contain?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.7.2 Are all drums and containers inspected for structural integrity
before moving?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-48-
-------
4.7.3 Are employees warned of the potential hazards associated with
the contents of drums or containers prior to movement?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.7.4 Is there a potential for a major spill during transfer of drums
or containers?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
If [YES], is there a spill containment program in place to
contain and isolate the entire volume of the spill?
[YES]
[NO, EXPLAIN]
4.7.5 Is a detection system being used to estimate location and depth
of drums and containers on-site prior to excavation activities?
[YES]
[NO, EXPLAIN]
2.
3.
Field Verification 1.
4.7.6 Are drums or containers being handled on-site?
[YES] [NO, EXPLAIN]
Field Verification 1.
-49-
-------
If [YES], is a fire extinguisher on-site during any drum or
container moving operation in the event of a fire?
Field Verification 1.
2.
3.
4.7.7 Does an instructional program for the employee detail
procedures for drum or container opening operations on-site?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.7.7.1 Are only required personnel present during drum or
container openings and are other personnel at a safe
distance from the operation?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
4.7.7.2 Does an instructional program for the employees
indicate either that drum openings will occur
remotely with pressure relief or that an appropriate
shield will be placed between employee and the drum
container during opening?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
-50-
-------
4.7.7.3 Are workers informed not to stand upon or work in
proximity to drums (except when the task requires
this)?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
4.7.8 Are sampling procedures for drums, tanks, containers, vaults,
etc. appropriately documented and available to employees for
review as part of a field sampling plan?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.7.9
4.7.10
[NO, EXPLAIN].
SUMMARY OF RESPONSES [YES]
4.8 Decontamination - 29 CFR 1910.120(k)
All personnel and equipment should be properly decontaminated prior to
leaving a site. The decontamination procedures shall be developed and
communicated to employees. The decontamination procedure should, at a
minimum, include the following:
• Number and location of decontamination stations;
• Required decontamination equipment;
• Appropriate decontamination methods;
• Procedures to prevent contamination of clean areas, employee
contact, and equipment contact;
• Methods and procedures to minimize worker contact with
contaminants during removal of PPE; and
-51-
-------
• Methods for disposing of clothing and equipment that are not
.completely decontaminated.
Decontamination methods could involve: (1) physically removing
contaminants; (2) neutralizing contaminants by chemical detoxification or
disinfection; or (3) removing contaminants through a combination of both
physical and chemical means. The types, locations, physical states, and
concentrations of contamination present will determine the appropriate method
of decontamination.
In general, for Level B and Level C activities, the initial
decontamination steps in the Contamination Reduction Zone (CRZ) are performed
by individuals who are one level of personal protection below those who are
exiting from the exclusion zone. All decontamination workers are in a
potentially contaminated area and must themselves be decontaminated before
entering a. clean zone.
4.8.1 Was the decontamination plan communicated to employees and
implemented prior to any employee or equipment entering areas
where potential exposure to hazardous substances exists?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.8.2 Are standard operating procedures and good work practices being
used to minimize employee contact with hazardous substances and
with equipment that has contacted hazardous substances?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.8.3 Are decontamination areas situated to minimize the potential
for contamination of uncontaminated employees or equipment
(i.e., is the CRZ located properly)?
[YES]
[NO, EXPLAIN]
Field Verification
1.
-52-
-------
4.8.4 Are all employees, clothing, and equipment decontaminated
properly prior to leaving a contaminated area?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3,
4.8.5 Are all protective clothing and equipment decontaminated,
cleaned, laundered, maintained, or replaced as needed to
maintain effectiveness?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.8.6 Do established equipment drop-off, decontamination, and
protective clothing doffing procedures minimize employee
exposures (i.e., is contaminated protective clothing being
decontaminated prior to removal by the employee)?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.8.7 Are all equipment and solvents used for decontamination
disposed of or decontaminated properly?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-53-
-------
4.8.8 Where decontamination procedures indicate a need for showers
and change rooms, are soap, hot and cold water, individual
clean towels, and separate storage facilities for street and
work clothes available as stated in 29 CFR 1910.141?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.8.9 Are unauthorized employees (e.g., administrative and support
staff) denied access to decontamination areas, decontamination
equipment, and change rooms?
[YES]
[NO, EXPLAIN]
Field Verification 1.
4.8.10
2.
3.
4.8.11
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-54-
-------
4.9 Emergency Response - 29 CFR 1910.120(1)
*
-»
i&fe a. BtiniiBuin, -fete -emergency response section, of the HftSiP B«st Atxctwde
the £. allowing:
•* fore'emergency planning;
» Jersqnnel role?, l«e» of authority and communication;:
• Emergency ±ee6gniti6tt and prevention;
» Safe aistaaoes anS places «£
Site security and
Evacuation jroute? and
BettoUfcatoinaM&it p*0E erifeique of sesponse and follow-up;
PBB and emergency eqoipmenfc?
Sit« topography, layowt, and1 prevailing weather cpndition? ; and
T?in5cedvfres for reporting incidents td local,, fitat^ and federal
In general, the emergency response section should be a discrete section
of the HASP and should be periodically reviewed in response to new or changing
site conditions or information. The aforementioned elements of the emergency
response plan should be verified by the EPA Audit Guidelines user in the
field.
4.9.1 Are personnel roles, lines of authority, and communication
among employees evident in the field (e.g., is the person who
would be in charge during an emergency incident clearly
identifiable?)
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-55-
-------
4.9.2
Are employees able to demonstrate emergency recognition and
prevention?
[YES]
[NO, EXPLAIN]
2.
3.
Field Verification 1.
4.9.3 Are site security and control measures evident in the field?
[YES] [NO, EXPLAIN]
Field Verification 1. 2. 3.
4.9.4 Are employees aware of evacuation routes and procedures?
[YES] [NO, EXPLAIN]
Field Verification 1. 2. 3. .
4.9.5 Are employees familiar with decontamination procedures?
[YES] [NO, EXPLAIN]
Field Verification -1.
2.
3.
4.9.6
Are emergency medical treatment and first aid available to
employees?
[YES]
[NO, EXPLAIN]
Field Verification 1.
-56-
-------
4.9.7 Are emergency alerting and response procedures addressed in
evidence in the field?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.9.8 Is a procedure in place to enable field personnel to critique a
response and to provide follow-up actions in the field?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.9.9 Are PPE and emergency equipment readily available to employees
in the field?
[YES]
[NO, EXPLAIN]
Field Verification !•.
2.
3.
4.9.10 Are procedures in place for reporting emergencies to local,
state, and federal governmental agencies?
[YES]
[NO, EXPLAIN]
Field Verification 1.
SUMMARY OF RESPONSES
2.
[YES].
3.
[NO, EXPLAIN].
-57-
-------
4.10.
Illumination - 29 CFR 1910.120(m)
The provisions for illumination of hazardous waste operations are
established in OSHA's industry requirements for illumination at construction
sites, 29 CFR 1926.56. For general work areas, five foot candles is the
recommended minimum illumination intensity for site work. If work may be
performed in dimly lighted areas, the HASP should provide contingency measures
for additional on-site lighting, along with a recommendation for the use of a
light meter to determine illumination intensity.
4.10.1 If site work is anticipated in dimly lighted areas, is
additional lighting provided?
[YES]
[NO, EXPLAIN]
Field Verification 1.
4.10.2
2.
3.
4.10.3
SUMMARY OF RESPONSES
4.11.
[YES].
[NO, EXPLAIN].
Sanitation at Temporary Workplaces - 29 CFR 1910.120(n)
During the field verification for good health and safety practices on-
site, the user should seek to answer the following questions pertaining to
sanitary conditions on-site.
4.11.1 Is potable water labeled as safe for drinking?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
-58-
-------
4.11.2 Are nonpotable water sources labeled as unfit for drinking,
washing, and cooking purposes?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.11.3 If there are fewer than 20 employees on-site, is there a
minimum of one toilet available?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.11.4
NOTE: Mobile work crews with transportation readily available
to equivalent toilet facilities are exempt from the
requirements of this paragraph for sanitation facilities.
If there are greater than 20 employees on-site, have additional
toilets and urinals been provided for each additional 40
employees?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
4.11.5 Is food handled in accordance with local food handling
regulations?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
-59-
-------
4.11.6 If temporary sleeping quarters are present, are they heated,
ventilated, and lighted?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
4.11.7 Are washing facilities away from hazardous substances and
adequate to permit employees to remove hazardous substances
from their bodies?
[YES]
[NO, EXPLAIN]
Field Verification 1.
4.11.8
2.
3.
4.11.9
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-60-
-------
CHAPTER 5
OFF-SITE EMERGENCY RESPONSE REVIEW
29 CFR 1910.120(q)
This section addresses the
requirements for personnel engaged in
off-site operations in response to
actual or potential releases of
hazardous chemicals. These off-site
emergency response operations may
occur anywhere. The typical
activities covered by this section are
transportation accidents and hazardous
substance releases at chemical
manufacturing facilities (such as the
release that occurred in Bhopal,
India); however, it would normally not
include established cleanup operations
(e.g., Federal EPA Superfund sites);
voluntary cleanup operations at
uncontrolled hazardous waste sites
recognized by government bodies; and
normal operations or corrective
actions involving hazardous wastes at
treatment, storage, or disposal (TSD)
facilities.
The off-site emergency response
personnel covered by the EPA standard
include both compensated and non-
compensated State and local emergency
response personnel. EPA's definition
of "employee," therefore, includes
volunteer fire fighters.
In general, the requirements for
off-site emergency response workers
are similar as those provided in
Section IV of the EPA Audit Guidelines
for hazardous waste site workers. By
referring to the subsections on site
control (pp. 27-29), personal
protective equipment (pp. 36-43), air
monitoring (pp. 43-47) , handling drums
and containers (pp. 47-50),
decontamination (pp. 50-53), and
illumination (p. 57) in Section IV,
the EPA Audit Guidelines user will
have additional questions available
that may be appropriate to the off-
site response at hand. These
questions were not restated in Section
V because many of them may not be
relevant to the particular off-site
emergency response. However, there
are four basic areas that are covered
in Section V:
• Planning. An employer's
emergency response plan must
be developed and made
available to employees, their
representatives, and OSHA/EPA
personnel.
• Training. Requirements are
based on the duties and
functions of each responder.
Skill and knowledge levels
vary from the awareness level
of first responders who
witness or discover the
release, to the hazardous
materials specialists
responsible for containment
and clean up.
• Equipment. Chemical
protective clothing and
personal protective equipment
(PPE) are required for some
personnel.
• Medical surveillance.
Baseline physicals and medical
consultation are required for
some personnel.
The principal difference in
requirements for emergency responders
and hazardous waste site workers is
the training requirements, which vary
for emergency responders according to
their level of responsibility and
terminology.
-61-
-------
5.1 Emergency Response Plan - 29 CFR 1910.120(1) and (q)
A written emergency response plan must be developed and implemented to
handle anticipated emergencies before the start of emergency response
operations.
NOTE: To avoid duplication of effort with SARA Title III plans,
emergency response organizations may use the local emergency response plan,
state emergency response plan, or both as part of their emergency response
plan.
At
a Btittifiium, the BE and ^emergency efjaipfflrotf an
-------
5.1.3 Does the emergency response plan address emergency recognition
and prevention?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
5.1.4 Does the emergency response plan address safe distances, places
of refuge, site security and control?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
5.1.5 Does the emergency response plan provide information on
decontamination of personnel and equipment?
[YES]
[NO, EXPLAIN]
Field Verification
1,
2.
3.
5.1.6 Are emergency medical treatment and first aid available to
employees?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.1.7 Are emergency alerting and response procedures addressed in the
plan and in evidence in the field?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-63-
-------
5.1.8 Does the emergency response plan provide a procedure for
critique of response and follow-up?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
5.1.9 Does the emergency response plan provide for the use of
personal protective equipment and emergency equipment, and are
they being used in the field?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.1.10 Does the emergency response plan make use of the local or state
emergency response plan?
[YES]
[NOT APPLICABLE]
[NO, EXPLAIN]
Field Verification 1.
5.1.11
2.
3.
5.1.12
SUMMARY OF RESPONSES
[YES]
[NO, EXPLAIN]
-64-
-------
5.2 Procedures for Handling Emergencies - 29 CFR 1910.120(q)(3)
5.2.1 Has an individual been identified as being in charge of the
Incident Command System (ICS)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.2.2 Has a safety official been identified by the individual in
charge of the Incident Command System (ICS)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.2.3 Are back-up personnel readily available with appropriate
equipment to provide assistance or rescue?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.2.4 When a fire is involved are employees suited in PPE in
accordance with 29 CFR 1910.156(e) (e.g., foot and leg
protection, self contained breathing apparatus)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
5.2.5
-65-
-------
5.2.6
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
5.3 Skilled Support Personnel - 29 CFR 1910.120(q)(4)
In addition to these specialist employees, it may be necessary in the
course of responding to a hazardous materials incident to call upon the
services of support personnel with special skills to perform temporary
emergency support work. These personnel are not required to meet the training
requirements for emergency responders, but must be given an initial briefing
prior to their participation and be provided with any health and safety
information provided to other employees.
5.3.1 Do skilled support personnel (e.g. crane operator) receive
initial briefings that acquaint them with PPE, chemical
hazards, and j ob duties to be performed?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.3.2 Does the employer provide the same health and safety
information to skilled support personnel as supplied to
employees?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.3.3
5.3.4
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-66-
-------
5.4 Training Requirements - 29 CFR 1910.120(q)(6)
Employees who, in the course of their regular job duties, provide
technical advice or assistance at a hazardous substance release incident, must
receive training or demonstrate competence annually according to their
specific level of responsibility.
The Varying. Skill levels fan off -site emergency ttssponddsrs are:
» First respotsder awareness level. Individuals who are likely to witness or
discover A hazardous substance fceleas An organized group of
emjiloyees, who are expected to pesfoan work to- handle and -oonfesol acttial »r
potential IfealtS or Spills o.£ haaarddUS Sllbstatldes reguiSfin$ possible Close
-approach, to the substance, the team jaembars -perSorm responses to releases
or pofcential releases o£ haaaeaous substances for: the purpose of control or
stabilisation of the incident. A B&2MM" team is not a fifce brigade ROT is
a typical brigade a 8A2M&S bsam. A- 6AZ3SJ< team, however, may be a. separate
component Of a fir* brigade; or fire
5.4.1
First Responder Awareness Level
5.4.1.1 Does the "first responder at the awareness level" have
sufficient training or sufficient experience to demonstrate
competency to initiate an emergency response sequence by
notifying the appropriate authorities of a spill/release?
[YES]
[NO, EXPLAIN]
Field Verification 1.
-67-
-------
5.4.1.2 Does the "first responder at the awareness level" have an
understanding of the employer's emergency response plan
including site security and control?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.1.3 Does the "first responder at the awareness level" have the
ability to realize the need for additional resources to address
the spill/release?
[YES]
[NO, EXPLAIN]
Field Verification 1.
5.4.1.4
2.
3.
5.4.1.5
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
5.4.2 First Responder Operations Level
5.4.2.1 Does the "first responder at the operations level" have eight
hours of training or sufficient experience to respond to
releases or potential releases of hazardous substances as part
of the initial response?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-68-
-------
5.4.2.2 Does the "first responder at the operations level" have
knowledge of basic hazard and risk assessment techniques to
help ensure protection of nearby persons, property, and the
environment?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.2.3 Does the "first responder at the operations level" know how to
perform basic control, containment and/or confinement
operations within the capabilities of the resources and PPE
available on scene?
[YES]
[NO, EXPLAIN]
Field Verification 1.
5.4.2.4
2.
3.
5.4.1.5
5.4.3
SUMMARY OF RESPONSES [YES].
Hazardous Materials Technician
[NO, EXPLAIN].
5.4.3.1 Does the "hazardous materials technician" have at least 24
hours of first responder operations level training?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-69-
-------
5.4.3.2 Does the "hazardous material technician" have sufficient
competency, as certified by the employer, to stop a
spill/release through active measures including plugging and
patching of the damaged container from which the spill/release
occurred?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.3.3 Can the "hazardous materials technician" function within an
assigned role in the Incident Command System?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.3.4 Does the "hazardous materials technician" understand and
implement decontamination procedures?
[YES]
[NO, EXPLAIN]
Field Verification 1.
5.4.3.5
2.
3.
5.4.3.6
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-70-
-------
5.4.4 Hazardous Materials Specialist
5.4.4.1 Does the "hazardous materials specialist" have at least 24
hours of training equal to the technician level?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.4.2 Does the "hazardous materials specialist" have the level of
knowledge that the hazardous materials technician has as well
as specific knowledge of the chemical substances that may need
to be contained?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.4.3 Does the "hazardous materials specialist" possess the necessary
knowledge to act as site liaison with Federal, State, and local
governments regarding site activities?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.4.4 Is the "hazardous materials specialist" able to select and use
proper specialized chemical PPE that is provided for
spill/release response?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-71-
-------
5.4.4.5 Is the "hazardous materials specialist" able to determine and
implement decontamination procedures?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.4.6 Does the "hazardous materials specialist" understand chemical,
radiological, and toxicological terminology and behavior?
[YES]
[NO, EXPLAIN]
Field Verification- 1.
5.4.4.7
2.
3.
5.4.4.8
5.4.5
SUMMARY OF RESPONSES [YES].
On Scene Incident Commander
[NO, EXPLAIN].
5.4.5.1 Does the "on scene incident commander" have at least 24 hours
of first responder operations level training?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-72-
-------
5.4.5.2 Does the "on scene incident commander" have sufficient
competency, as certified by the employer, to assume control of
the incident beyond that of the first responder?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.5.3 Does the "on scene incident commander" know how to implement
the employer's incident command system and emergency response
plan, and the local emergency response plan?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.5.4 Does the "on scene incident commander" know and understand the
hazards and risks associated with employees working in chemical
protective clothing?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.4.5.5 Does the "on scene incident commander" know and understand the
importance of decontamination procedures?
[YES]
[NO, EXPLAIN]
Field Verification 1.
5.4.5.6
-73-
-------
5.4.5.7
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
5.5 Refresher Training - 29 CFR 1910.120(q)(8)
Employees must take an annual refresher course or demonstrate competency
in their subject areas each year. The employer must provide a record of
training or demonstrated competency for the employee. If the employer
provides a record regarding demonstrated competency by an employee, the
employer shall also keep a record regarding the method by which competency was
demonstrated.
5.5.1 Do trained employees receive annual refresher training of
sufficient content and duration to maintain their competencies
on at least an annual basis?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.5.2 Does the employer have available a statement of annual
refresher training or competency demonstrated on an annual
basis for each employee?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.5.3 If the employer makes use of a statement of competency for a
specialist employee, does the employer keep a record of the
methodology used to demonstrate competency?
[NOT APPLICABLE]
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
5.5.4
-74-
-------
5.5.5
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
5.6 Medical Surveillance and Consultation - 29 CFR 1910.120(f) and (q)(9)
Hazardous Materials Specialists [29 CFR 1910.120(q)(5)(iv)] and members
of Hazardous Materials Teams (HAZMAT) must receive baseline physicals and be
part of a medical surveillance program. This program must include medical
consultation following exposure to hazardous substances, periodic physicals, a
physical upon termination of employment, and medical recordkeeping.
5.6.1
Do members of an organized and designated HAZMAT team and
Hazardous Materials Specialists receive a baseline physical?
[YES]
[NO, EXPLAIN]
Field Verification 1.
5.6.2
2.
3.
Do members of an organized and designated HAZMAT team and
Hazardous Materials Specialists receive periodic physicals (at
a frequency determined by the attending physician)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
5.6.3
3.
Do members of an organized and designated HAZMAT team and
Hazardous Materials Specialists receive a physical upon
termination of employment or reassignment to a non-HAZMAT job
if the employee has not received a physical within the last six
months?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-75-
-------
5.6.4 Do members of an organized and designated HAZMAT team and
Hazardous Materials Specialists receive medical attention
following the development of signs or symptoms that may
indicate possible overexposure to hazardous substances, or when
the employee is exposed above the OSHA Permissible Exposure
Limits or other established exposure limits in an emergency
situation?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.6.5 Does the employer furnish the employee who has received a
physical with a written physician's opinion indicating medical
results and whether the employee is capable of hazardous
materials work?
[YES]
[NO, EXPLAIN]
Field Verification 1.
3.
5.6.6 Is medical recordkeeping done in a manner consistent with 29
CFR 1910.20 (Access to Employee Exposure and Medical Records)?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.6.7
5.6.8
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN]
-76-
-------
5.7 Chemical Protective Clothing - 29 CFR 1910.120(g) and (q)(10)
A personal protective equipment (PPE) program is required by 29 CFR
1910.120(g). PPE ensembles should be carefully selected based on site
characterization and any new information (e.g., air monitoring readings)
collected on-site.
5.7.1
Is a written PPE program, including procedures, guidelines, and
policy statements regarding the use of PPE, available for
inspection?
[YES]
[NO, EXPLAIN]
Field Verification
1.
2.
3.
If the answer is [NO], ask employee(s) these questions and/or
observe for the 12 PPE program element questions below.
5.7.1.1 Are the employees trained regarding on-site hazards?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.2 Are the employees adequately trained in selection of
PPE?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.3 Are the employees adequately trained in the use of
PPE?
[YES]
[NO, EXPLAIN]
Field Verification 1.
-77-
-------
5.7.1.4 Are the employees informed regarding estimated
lengths of time for job tasks and estimated time of
project duration?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.5 Do employees maintain and store PPE appropriately?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.6 Do employees know how to decontaminate PPE?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.7 Are employees fitted properly for PPE?
[YES] [NO, EXPLAIN]
5.7.1.8 Do employees know how to don and doff PPE?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
-78-
-------
5.7.1.9 Do employees know how to adequately inspect PPE
(e.g., inspection of full-face air purifying
respirator including valves, face seal, straps,
diaphragm)?
[YES] [NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.10 Is there a system in place to indicate what PPE is
being used and what PPE is not in use?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.11 Is there a system in place to evaluate the
effectiveness of the PPE program?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.1.12 Are employees familiar with the limits of PPE during
temperature extremes?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-79-
-------
5.7.2 Is PPE chosen based on hazards and potential hazards as
identified during the site characterization that will be
sufficiently protective of hazardous materials employees?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.3 Is PPE selection based on performance characteristics relative
to potential hazards, task-specific conditions, and site
limitations?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.4 Under IDLH conditions, are positive pressure self-contained
breathing apparatus, or positive pressure air-line respirators
with escape packs used by hazardous materials employees?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.5 In cases where skin absorption of a chemical may pose an IDLH
condition, are totally-encapsulating chemical protective suits
(Level A) used by the hazardous material employees?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
-80-
-------
5.7.6 Is the level of protection for hazardous materials employees
increased in response to information that potential exposures
may be greater than OSHA-PELs for the chemicals of concern?
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
3.
5.7.7 Do the totally-encapsulating chemical protective suits worn by
hazardous materials employees, maintain positive air pressure
and prevent inward test gas leakage? (Appendix A of 29 CFR
1910.120 provides a test method for gas leakage.)
[YES]
[NO, EXPLAIN]
Field Verification 1.
2.
5.7.8
5.7.9
SUMMARY OF RESPONSES
[YES].
[NO, EXPLAIN].
-81-
-------
APPENDIX A ACRONYMS
American Conference. Of Gbvetttmental Industrial Hy$ienis.ts,'
Air Purifying Respirator,
Comprehensive Environmental Response, Compensation, and Liability Act of
1980. - *
Code of Federal Regulations,
Combustible Gas Indicator, instrument used to fcest for e5fploslves,
> ,
Contamination Reduction Zone,
U..S. Department of Transportation,
U,S. Environmental Protection Agency.
flame lonization. Detector, used to; me'asure volatile hydrocarbons,
Feasibility Study.
Health and Safety Elan.
- Hazardous. Ranking System.
Immediately Bangerpus to Life and Health. ^
Rational Institute for Occupational Safety atid Health. HIOSH is & part of
the Department of Health, and Human Services,
National Priority l,ist,
' - (? ,'s
Occupation Safety and Health Adfliittistratibn, OSHA is part of the DejwiiitmSnt
of Labor, ^ t
U^S. EPA Office Of So.lid Waste and Emergency Response,
Permissible Exposure Limit (promulgated by OSflAj same as OSHA'-EEL).
Fhotoipnization Detector, used to measure volatile "hydrocarbons.
Personal Protective Equipment..
Potentially Res:gottsibl6 Party.
Remedial Investigation/Feasibility Study.
Record of Decision: Document describing selection of a cosf-effecfcive
SUp&rfund-financed semedy.
Superfund Amendments and Reauthosiaatiion Act of 1986 Csee CERCLA).
Self Contatoed Breathing Apparatus,
Short term Exposure Limit, airborne exposure limit «sed by ACSJH,
Th£6shbld Limit Value'- Time Weighted Average., ai*b6Sne eatgosute limit
by AC0I8.
-------
APPENDIX B
OTHER COMMON APPLICABLE OSHA STANDARDS
The following items represent some common health and safety issues that
may need to be addressed prior to initiating hazardous work activities. For
sites at which any of these safety issues are applicable, the information from
the regulation should be provided in sufficient detail within the health and
safety plan (HASP) to provide adequate protection of employees working on-
site. These are OSHA regulations that are not part of 29 CFR 1910.120. OSHA
also requires a log of occupational injuries and illnesses. This information
is recorded on form OSHA No. 200 (Appendix E of the EPA Audit Guidelines).
The following are some of the OSHA standards that should be considered for
site activities.
OSHA Act, Section 5(a)(l) GENERAL DUTY CLAUSE
Under the "General Duty" clause of the Occupational Safety and Health Act
of 1970, section 5(a)(l) states that each employer "shall furnish to each of
his employees employment and a place of employment which are free from
recognized hazards that are causing or are likely to cause death or serious
physical harm to his employees."
29 CFR 1904.24 LOG AND SUMMARY OF OCCUPATIONAL INJURIES AND ILLNESSES
This regulation requires that each employer maintain a log of all
recordable occupational injuries and illnesses and that the information be -
recorded in the log within six working days of the receipt of the information.
Form OSHA No. 200 or its equivalent is to be used for this purpose.
29 CFR 1910.20 ACCESS TO EMPLOYEE EXPOSURE AND MEDICAL RECORDS
An employer must provide exposure and medical records to an employee or
designated representative within fifteen days after the request for access to
records. If the employee requests copies of this information, the employer
must make the copies available to the employee at no cost. All employee
medical records must be maintained for the duration of employment plus 30
years by the employer.
29 CFR 1910.24 FIXED INDUSTRIAL STAIRS
This section contains specifications for the safe design and construction
of fixed general industrial stairs. This classification includes interior and
exterior stairs around machinery, tanks, and other equipment, and stairs
leading to or from floors, platforms, or pits.
Requirements include stair strength, stair width, angle of stairway rise,
stairway platforms, railings and handrails, and vertical clearance. The
requirements regarding stairs are very specific. For instance, 29 CFR
1910.24(h), Railings and Handrails, references 29 CFR 1910.23. It requires
two standard rails (one set on each open side) if the stairway is more than
four feet in height from ground level.
B-l
-------
29 CFR 1910.27 FIXED LADDERS
This regulation includes information on design requirements, specific
features, appropriate clearances, special requirements (e.g., use of cage's fqr
ladder heights greater 20 feet), and appropriate pitch when using a fixed
ladder.
29 CFR 1910.28 SAFETY REQUIREMENTS FOR SCAFFOLDING
This regulation provides safety requirements for the construction,
operation, maintenance, and use of scaffolds. There are approximately 20
types of scaffolding. For each type of scaffolding, specific safety
requirements are provided.
29 CFR 1910.38 EMPLOYEE EMERGENCY PLANS AND FIRE PREVENTION PLANS
This regulation applies to all emergency action plans and fire prevention
plans required by particular OSHA standards. With the exception of employers
with 10 or fewer employees, both the emergency action plan and the fire
prevention plan are required in writing. .The required elements of each of
these plans are provided in the regulation. If the employer has 10 or fewer
employees, the elements of both types of plan must be provided orally to
employees. The employer shall also perform housekeeping and maintenance of
equipment and systems as part of the fire prevention plan.
29 CFR 1910.95 OCCUPATIONAL NOISE EXPOSURE
On many sites, different site activities (e.g., drilling operations,
heavy equipment operations) may result in appreciable noise levels. It is
important that area and personal noise surveys be conducted to categorize
noise levels appropriately. A sound level meter that has the capability to
integrate and average sound levels over the course of a work day is required.
Currently, the OSHA-Permissible Exposure Limit for an eight-hour workday,
forty-hour work week, is 90 dBA, as recorded on a sound level meter on the A
weighted scale. An employer shall implement a hearing conservation program if
8-hour time weighted average noise exposures equal or exceed 85 decibels on
the A scale. Continuous intermittent and impulsive sound levels of 80 dBA or
greater shall be integrated into the time weighted average.
29 CFR 1910.101 COMPRESSED GASES
To the extent possible, each employer should determine, through a visual
inspection, that compressed gas cylinders under his/her control are in safe
condition. Other inspections are prescribed in the DOT Hazardous Materials
Regulations. Specific safety requirements for handling compressed gases are
found in 29 CFR.252(b).
29 CFR 1910.133 EYE AND FACE PROTECTION
Eye and face protection is required when there is the potential for on-
site injury. Particular information on goggles, spectacles, and face
protection is included in this regulation. Design, construction, testing, and
use of such devices must be in accordance with ANSI Z87.1-1968 specifications.
B-2
-------
29 CFR 1910.134 RESPIRATORY PROTECTION
Prior to wearing a respirator, an employee should be certified as
medically able to wear one. Each employer should have a written respiratory
protection plan for selection and use of respirators. All employees must be
trained regarding the appropriate use of a respirator.
29 GFR 1910.135 OCCUPATIONAL HEAD PROTECTION
Qn-site situations requiring head protection include: presence of
overhead objects, on-site operation of heavy equipment, potential for flying
objects in the work area, and possible electrical shock hazard. In addition
to protecting workers from falling or flying objects, head protection affords
limited protection from electric shock and burn. Head protection must meet
ANSI Z89.1-1969 specifications.
29 CFR 1910.136 OCCUPATIONAL FOOT PROTECTION
Safety toe footwear for employees must meet ANSI Z41.1-1967 for Men's
Safety-Toe Footwear. In general, workers at hazardous waste sites must wear
leather or rubber boots with steel toes and steel shanks.
29 CFR 1910.141 SANITATION
Specifications concerning appropriate housekeeping, waste disposal,
vermin control, water supply, toilet and washing facilities, showers, change
rooms, waste disposal containers, sanitary storage, and food handling for
permanent places of employment are provided in this regulation.
29 CFR 1910.151 MEDICAL SERVICES AND FIRST AID
If a medical facility is not located in proximity to the workplace, there
shall be a person or persons on-site with adequate first-aid training. First
aid supplies approved by a consulting physician shall be available on-site.
If there is the potential for corrosive materials on-site, suitable facilities
shall be available for drenching of eyes and skin.
29 CFR 1910.165 EMPLOYEE ALARM SYSTEMS
The employee alarm system shall be recognizable to all on-site employees.
The signal from the employee alarm system shall be audible to employees in the
event of a need to warn employees of an evacuation from work areas.
29 CFR 1910.181 DERRICKS
Derricks attached to drill rigs must be periodically inspected. This
regulation defines nine different types of derricks. Specific information is
provided on inspection; frequency of inspection; load ratings; rope use and
inspection; fire extinguisher use; operation near power lines; and operating
enclosures.
B-3
-------
29 CFR 1910.252 WELDING, CUTTING, AND BRAZING
Detailed regulations exist for various types of welding, cutting, and
brazing operations. These regulations provide specific information on types
of gases, gas pressures, operation and maintenance, and safety procedures.
29 CFR 1910.307 HAZARDOUS LOCATIONS
Electrical equipment used in hazardous locations must be intrinsically
safe and suitable for use in the appropriate classified environment.
Specified definitions of classifications and further information can be found
in Section 1910.307 and 1910.399.
Subpart Z, 29 CFR 1910.1000 TOXIC AND HAZARDOUS SUBSTANCES
There are other applicable OSHA standards that refer to particular air
sampling procedures for chemical contaminants, PPE requirements, and
recordkeeping for a variety of compounds. These compounds and their
accompanying OSHA regulations are as follows:
Compound
Asbestos
Coal tar pitch volatiles
4-nitrobiphenyl
Alpha-Naphthylamine
Methyl chloromethyl ether
3,3'-dichlorobenzidine
bis-chloromethyl ether
Benzidine
4-aminodipheny1
Ethyleneimine
beta-propiolactone
2-acetylaminofluorene
4-dimethylaminoazobenzene
N-nitrosodimethylamine
Vinyl chloride
Inorganic arsenic
Lead
Benzene
Coke oven emissions
1,2-dibromo-3-chloropropane
Acrylonitrile
Ethylene oxide
Formaldehyde
29 CFR 1910.1200 HAZARD COMMUNICATION
OSHA Reference
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
1910
.10011
.1002
.1003
.1004
,1006
.1007
.1008
.1010
,1011
,1012
.1013
,1014
,1015
,1016
,1017
.1018
.1025
.1028
.1029
.1044
.1045
.1047
.1048
The employer will establish a hazard communication program to ensure that
hazards associated with chemical usage are communicated to employees. The
hazard communication program does not apply to hazardous wastes. There are
See footnote 3, page 57.
B-4
-------
training, labeling, and material safety data sheet (MSDS) requirements for
known chemicals. Employers are required to develop a written hazard
communication program that will include:
• List of known hazardous chemicals on-site;
• Method for informing employee of chemical hazards associated with
non-routine tasks; and
• Methods for informing both employees and subcontractors about
chemical hazards (e.g., chemical hazard training, distribution of
MSDSs).
29 CFR 1926.56 ILLUMINATION
General work areas shall have a minimum illumination intensity of 5 foot-
candles. Other specifications for minimum illumination intensities for
different work areas and operations are provided in this regulation.
29 CFR 1926.57 VENTILATION
Whenever dust, fumes, mists, vapors, or gases exist or are produced in
the course of construction work, their concentrations must not exceed limits
specified in 29 CFR 1926.55(a). When ventilation is used, the system must be
installed and operated according to the requirements of this section.
29 CFR 1926.151(a)(3) FIRE PREVENTION
Electrical wiring and equipment for light, heat, or power purposes must
be installed in accordance with the National Electrical Code requirements,
NFPA 70-1971; and ANSI CI-197. [29 CFR 1926.151(a)] Also, smoking is
prohibited at or in the vicinity of operations which constitute a fire hazard.
"No Smoking or Open Flame" signs must be posted. In general, smoking should
be limited to a designated area within the "support zone" at a hazardous waste
site. This will minimize the fire hazard, as well as the transfer of
contaminants to smokers' mouths. [29 CFR 1926.151(a)(3)]
29 CFR 1926.152 FLAMMABLE AND COMBUSTIBLE LIQUIDS
Information on appropriate containers and appropriate storage for
flammable and combustible liquids is contained in this reference. Note that
no more than 25 gallons of liquid may be stored indoors unless located within
an approved storage cabinet.
29 CFR 1926.200 ACCIDENT PREVENTION SIGNS AND TAGS
This regulation contains specific information on color, size, shape, and
placement of danger, caution, exit, safety instruction, directional, accident
prevention, and traffic signs.
29 CFR 1926.301 HAND TOOLS
Special attention should be paid to the use of safe hand tools. For
example, wooden tool handles must be kept free of splinters or cracks, and
B-5
-------
impact tools, such as wedges and chisels, must be kept free of mushroomed
heads. Also, wrenches must not be used when jaws are sprung to the point that
slippage occurs.
29 GFR 1926.651 SPECIFIC EXCAVATION REQUIREMENTS
Specific information on locating underground utilities; using support
systems; securing sides, slopes, and faces; using seals, benches, rock bolts,
and wire meshes; taking precautions for work adjacent to previously backfilled
areas; diverting water flows from excavated areas; using explosives
appropriately; using dust control techniques; and using ladders and ramps is
provided in this regulation.
29 GFR 1926.652 TRENCHING REQUIREMENTS
Shoring is needed when the sides of a trench are more than five feet deep
and unsuitable ground or soft material is present. Also, sides of trenches in
hard or compact soil must be shored when the trench is more than five feet
deep and eight feet long.
B-6
-------
APPENDIX C
INCIDENT SAFETY CHECK OFF LIST
-- _""" USEPA - OSWER
I. BEFORE FIELD ACTIVITY
1.
3.
4.
5.
6,
7.
8.
9,
Employee
Incident: Site_
Response Dates:_
City
State
10,
11.
Activity Description: Site Evacuation __ Containment. __
Well Drilling Facility Inspection Sampling - Air
Water -Drum Soil Residential Other
Type of Response: Spill
Other
Fire Site
Train
Site Topography: Mountains Rivers Valley Rural
Suburban Level Slopes __ Unknown
Incident Safety Flan: Region
- - - - " -ERT
Facility
^ Reviewed
Briefed
Not Developed _
Site Accessibility: Road: Good
Fair
Poor
Air: Good
Fair
Poor
Suspected chemical(s) and pathway with source(s> involved:
(A) (B) (C) (D)
Emergency Response Teams Present for First Aid, etc.
Yes TSo ~ ~ "
Protective Level(s) Selected: (A)
-- - - (c) .
(B)
CD) .
If Level "D" - Justify:
SCBA Identify Buddy System: Office/Name
Last Response: (a) Level tJsed: (A) (B)
(C) (D)
(b) Medical Attention/
Exam Performed: Yes No_
-------
• INCIDENT SAFETY CHECK OFF LIST
KISEPA - OSWER
(continued)
II
1.
2.
AFTER RESPONSE
Protective Level Used:
(C)
(B)
(D)
a. Level "C" - identify canister: _
b. Level "D" - JUSTIFY:
c. Level B or C skin protection: Tyvek _ Tyvek/Saran
Acid/Rain ........ Other __
List possible chemical exposure: Same as above: ^ _ ^
(A) _ (B) _ (C) __ _ (D)
3. Equipment Decontamination:
(a) clothing . (b) respirator (c) monitoring
Disposed: '
Cleaned; _" ; ^
No Action: ' L
4. Approximate time in exclusion area:
days
hours per day for
5. Was medical attention/exam required for this response: Yes
No > -
Part I: DATE PREPARED:
Date
Part II: DATE PREPARED:
Date
Reviewed by
•>
Reviewed by
C-2
-------
APPENDIX D
LEVELS OF PERSONAL PROTECTION**
LEVEL A - To be selected when the greatest level of skin, respiratory, and eye
protection is required.
Level A equipment; used as appropriate.
1. Pressure-demand, full face-piece self-contained breathing apparatus
(SCBA), or pressure-demand supplied air respirator with escape SCBA,
approved by the National Institute for Occupational Safety and Health
(NIOSH).
2. Totally-encapsulating chemical-protective suit.
3. Coveralls.*
4. Long underwear.*
5. Gloves, outer, chemical-resistant.
6. Gloves, inner, chemical-resistant.
7. Boots, chemical-resistant, steel toe and shank.
8. Hard hat (under suit).*
9. Disposable protective suit, gloves and boots (Depending on suit
construction, may be worn over totally-encapsulating suit).
10. Two-way radios (worn inside encapsulating suit).
*0ptional, as applicable.
LEVEL B - The highest level of respiratory protection is necessary but a
lesser level of skin protection is needed.
Level B equipment; used as appropriate.
1. Pressure-demand, full-facepiece self-contained breathing apparatus
(SCBA), or pressure-demand supplied air respirator with escape SCBA
(NIOSH approved).
2. Hooded chemical-resistant clothing (overalls and long-sleeved jacket;
coveralls; one or two-piece chemical-splash suit; disposable chemical-
resistant overalls),
3. Coveralls.*
4. Gloves, outer, chemical-resistant.
-------
5. Gloves, inner, chemical resistant.
6. Boots, outer, chemical-resistant steel toe and shank.
7. Boot-covers, outer, chemical resistant (disposable)*.
8. Hard hat.
9. Two-way radios (worn inside encapsulating suit).
10. Face shield.* '
*0ptional, as applicable.
LEVEL C - The concentrations(s) and type(s) of airborne substance(s) is known
and the criteria for using air purifying respirators are met.
Level C equipment; used as appropriate.
1. Full-face or half-mask, air purifying, canister equipped respirators
(NIOSH approved).
2. Hooded chemical-resistant clothing (overalls; two-piece chemical-splash
suit; disposable chemical-resistant overalls).
3. Coveralls.*
4. Gloves, outer, chemical-resistant.
5. Gloves, inner, chemical resistant.
6. Boots, outer, chemical-resistant steel toe and shank.*
7. Boot-covers, outer, chemical resistant (disposable).*
8. Hard hat.
9. Escape mask.*
10. Two-way radios (worn under outside protective clothing).
10. Face shield.*
*0ptional, as applicable.
LEVEL D - A work uniform affording minimal protection: used for nuisance
contamination only.
Level D equipment; used as appropriate.
1. Coveralls.
2. Gloves.*
3. Boots/shoes, chemical-resistant steel toe and shank.
4. Boots, outer, chemical-resistant (disposable).*
D-2
-------
5. Safety glasses or chemical splash goggles.*
6, Hard hat.
7. Escape mask.*
8. Face shield.*
*0ptional as applicable.
The types of hazards for which levels A, B, C, and D protection are
appropriate are described below:
Level A protection should be used when:
1. The hazardous substance has been identified and requires the highest
level of protection for skin, eyes, and the respiratory system based on
either the measured (or potential for) high concentration of atmospheric
vapors, gases, or particulates; or the site operations and work functions
involve a high potential for splash, immersion, or exposure to unexpected
vapors, gases, or particulates of materials that are harmful to skin or
capable of being absorbed through the intact skin,
2. Substances with a high degree of hazard to the skin are known or
suspected to be present, and skin contact is possible, or
3. Operations must be conducted in confined, poorly ventilated areas and the
absence of conditions requiring Level A have not yet been determined.
Level B protection should be used when:
1. The type and atmospheric concentration of substances have been identified
and require a high level of respiratory protection,. but less skin
protection.
NOTE: This involves atmospheres with IDLE concentrations of specific
substances that do not represent a severe skin hazard; or that do not
meet the criteria for use of air-purifying respirators.
2. The atmosphere contains less than 19.5 percent oxygen, or
3. The presence of incompletely identified vapors or gases is indicated by a
direct-reading organic vapor detection instrument, but vapors and gases
are not suspected of containing high levels of chemicals harmful to skin
or capable of being absorbed through the intact skin.
Level C protection should be used when:
1. The atmospheric contaminants, liquid splashes, or other direct contact
will not adversely affect or be absorbed through any exposed skin,
2. The types of air contaminants have been identified, concentrations
measured, and a canister respirator is available that can remove the
contaminants, and
3. All criteria for the use of air-purifying respirators are met.
D-3
-------
Level D protection should be used, when:
1. The atmosphere contains no hazard, and
2. Work functions preclude splashes, immersion, or the potential for
unexpected inhalation of or contact with hazardous levels of any
chemicals.
NOTE: As stated before combinations of personal protective equipment
other than those described for Levels A, B, C, and D protection may be
more appropriate and may be used to provide the proper level of
protection.
**This information is from 29 CFR 1910.120 Appendix B.
D-4
-------
APPENDIX E
GENERIC HASP
Due to the length of the generic HASP, entitled "Site Health and Safety
Plan,"* only the Table of Contents has been included.
For a complete copy of the "Site Health and Safety Plan," please contact:
U.S. Environmental Protection Agency
Environmental Response Team (MS 101)
Raritan Depot
Woodbridge Avenue
Edison, NJ 08837
Attention: Generic HASP
For any comments or questions please call:
Ms. Vickie L. Santoro (201) 906-6917
*Site Health and Safety Plan prepared by EPA/ERT, June 1989.
-------
HASP USER'S GUIDE
TABLE OF CONTENTS
J ' ^ ^'"' ' *? "J7S" * ," f
«,,.<>,,, , < ,<,„,, , ,,,,,,,
OfcEHAlIHG IHSIRDCIIOHS _, ..,...,.., "...."
i.o iHtaoDBCKQS „..../....,.
1.1 Scopa and-Applicability of tfee Bite Health and Safety Plan . .
1.2 Visitftcs < , ,, '< > {,t ."><',<> "« > < >'V
2,0 KE5f 5ERSONHEL/IDEKTIFIC&TION OP HEALTH AKD S4HOT PERSONNEL ,,,,,,,
2.1 Key Personnel . . ,. > < > , > , > < > , > ,"»<>,»', "v <" > < , < t , ,
2.2 Site Specific Health an,. , , .
3.0 TasS/OPEHATIOH SAEET3T AHD BEAI.TH Jttgl£SJtfteI,tSIS '. '.
3.1 EistWiQal Overviw «* Site * > YY < > /, < 7"I ; < k < t ,\> "'">" t >'i'>
3.2 task by Task Safety and^ Reaith Risk Analysis ." />
4.0 EEB50HBOEL TOAIBmg SEtyrreWffWffi '/ / < ^ ,- > , » < < >
4.1 ^reassignment and Annual Refsesher IrainittB , . . /
4,2 Sit* $tij>ecvlaei:s.'''TiAfning •"+<»< f <>,, i.. ,«,.,.. ( « ( ,.<>'.,
4.3 tCraining"and Briefing topics * ['.' '^ ..',.. ./,•• ...,.,
5.0 SEHSWAt EBOremsg JMWSWEOT t& 8B USED ,/.,<,<»„»,
5.1 l.evel& of fcroteofcipn: .,., k . i . i , ^ ,...,,.,.;.'. t .» ...
5.2 Level A £ttrsantleLwPrQ-$ec;b'ive Eg«ijitt«nt ."">'< .','».»,.,,,>/,,>
5.3 leVSl B jf^tftprw^l FrQtectJv^ Equipment ,..»<,<»« t' ^ , , v , t < t
5.4 level C tersonnftl frotecfcive Eetuijwenb Y .'
5.5 t«v«X P Pe*gpnnel Fito^ectlve E^piijaBbtib •-,,,"< > .',.,,, >. ..,,,.,
5.6 Reassessment oJt fr!Dta«tio» Krogratn '. :
5,7 Work Mission Dtiration '„'''•<>•••'• •. • '• • • •"" s •
5.8 Chwnioal. Re?i^tap<'><,'<>/><><' >4 t , k <
8,2 Periodic Monitoring ,'
6.3 Site Specific Medical Mtfnitoritt$ ,,.,,. ,," \ ...,,,
v <.,><,,»<><»' ^ »,» <(, t
7.0 JBEQBEHCy AND TXSES <» Atft MtSmMKtMS AND KEfiSONHEt AOR
7.1 Direot^Saading Monitoring InafcKuaienta ^,
7.2 Personal gwnpling .><.<,<,,,»<+<,,>,»,»<
7.3 Sjaacdfle ContaminantB to fee MonifeoreS. at {^IIK S^MEJ
8.0 SITE CGNXBOEi DEASBKES <<.<><»«»<,,»,»<>,>
8.1 Buddy System , , ,
8.2 Site CoHttUttJ,e*bioti5 Plan ^ ,••>•><><>.>,,<.<,<
8.3 Work 2one Dcfinitioa . . >
8.4 Saarest Medical Assistance
8.5 Sttf« Work £t«ic;Up«H5 .*<*<*<»,,<>, f t > < > ,' t
8.6 Emergency Alarm Procedures , . , '.
9,0 DECOHTAMURAirOlt HAH ><><>.*<>/.<>,',<><><
8.1 Standard Operating EEDoeduses
S,Z Levels of Deeontaminatibn. Proteetloft Beqiai±ied for Petsonnel
9.3 Equipment Decontamination >
9,4 Disposition, of Decontamination Wastes ,..
ii1
1
1
3,
3
3
4
5
S
S
6
S
&
- 9
ti
li
13
13
15,
15
18
2Q
22
22
22
22
23
29
34
34
34
as
35
35
36
41
41
41
41
41
E-2
-------
HASP USER'S GUIDE (continued)
TABLE OF CONTENTS
10,0
IB
10!
IS,
10,
1Q.
10'.
10.
10!
ajuo
XI,
11,
li.
.1
's
,4
,5
.6
9
11
BUR
?ze-Emers«ntty Planning . .
personnel Boies and lines -of Authority > < > < *
Emergency Beoognttiow and Invention
E-tf&frdatlon Souths and Fr6o6<*<><
Emergenoy Beeontamirtafcion Jrocedares , .
Emerssncy fctedicat trestraenfc
Fice or Ex^lQsion E&sponse EEOeedttres
Jersonal
Equipment ancl Emssirgency Equipment
1 B«£initi , ,
.3 trofl-edure £OE Confined Space Entry
Observe* .....
46
46
46
46
46
48
49
51
51
51
52
54
54
54
55
56
5?
E-3
-------
Bureau of Labor Statistics
Log and Summary of Occupational
Injuries and Illnesses
APPENDIX F
OSHA FORM NO. 200
NOTCt
Cteas*
Bit
»^^_L__
rNHnBar
Enttra
cmine
numbar
— A.t-1-
rfnKn
wm
f*eWt»te
com*
psrisoos
wKf>
*ifPJ»-_
frwrtttfy
ftcocUv*
(A)
Mi
J
This fwmfcrs«r*ed by Public Lsw 01486 end inust be kept RECORDABLE CASES: You are requited to record information about every occupa-
IntoasMMIshmentforSKeenr. Fafesra to maintain and post tlonal daeth; every nonfatal occupational Mlnees: and tho» nonfatal occupational m-
•"• l*"j**» *• *""""» «* etetlo""nl' ••""""" of penalties, juriaa which involve one or more of the following: loa of contciouman, reitriction
ISttfcctinfrtquinmtnaonttifothiriidioffotm.} of work or motion, tranitar to another job, or medical ueaunent (other than first aid). i
IStfdtflnltiontonthiothfrtidtofform.) ' '
DMaef
N«nrer
Onaatel
Utmai
Entsr
MoJdff.
(B)
aHfirfft
mm
EraptoyiM'aNwna
Entar f ktt name or Initial,
middl* biftial, Ian name.
(0
BM^li^ftWf|'i?A^
BgBS»yi^i^r^^^a
woo^ieuuiB
Entar regular Job title, not
acthritv amptoyae was par-
onset of Illnett- In the absence
of a formal title, entar a brief
description of the employee's
duties.
(D)
Oli&tAl*
Department
Entar department in which
the employee la regularly
wnpioyod or 9 ddcript*oft
of normal workplace to
which employee to assigned,
even though temporarily
wwfcing in another depart-
ment at the time of injury
or illness.
(E)
"«-/?, '"?^^^^" j; ' '"
i v '''s#;lsotJ"
-------
U.S. Department of Labor
APPENDIX P
(continued)
For Calendar Year 19 .
Pago.
Company Name Form A
Establishment Name
lEstatoHthment Addr«t»
•mem ef and d-teeme ef INJURY
FetamiM
INury
'Rotated
lEntar DATE
lot death.
1
1
Mo^dav/yr.
I"1
1
1
1
oifatal Injuriw
l-jriM With Loat Workdayi
nara
5HECK
Injury
nvorvas
Java away
ram
work, or
aytof
ork
setMty.
or twth.
21
inter a
CHECK If
njury In-
ralvaa dayi
iwey from
iwrfc.
3)
^A
\ * '
inter num-
Mtot
AY*«niK
iromwotk.
4)
\\
^
ntar num-
wof
AY* of
Mrttcttr-
ty.
5)
1 %
P- ' *
'. '
lurlai
Ithout Lost
orkdays
mar • CHECK
no entry wet
nada In col-
mns 1 or 2
3ut the Injury
recordable
defined
kbove.
81
^
pprovid
No. 12204029
VP*. Enant ot. and Outcome of ILLNESS
ypa of Illnase
4ECK Only One Column for Each Illntai
S*» ottifr iMt of form for nm/arOoni
Occupational skin 't
diseases or disorders ||
Oust diseases of 5
the lungs |
Respiratory conditions a
due to toxic agents *
Poisoning (systemic ef- Jl
fects of toxic materials) ^
(7)
1
b)
c)
d)
Disorders due to
physical agents
e)
^
Disorders associated
with repeated trauma
f)
V
V
All other occupa-
tional illnesses
)
V
atalltlis
nasa
mar DATE
death.
ojday/yr.
8)
^
^4^
•»-
onfttal Illnvtses
rwofrM With Lost Morkdcys
nt»ri
lllrwss
nvotvM
/s awwy
rom
work, or
•yi of
itrtcud
ork
mrvlty.
rboth.
9)
/
Cj
ntar a
-HECK It
naaa in-
roives days
rway from
mrk.
0)
c
-.V.
^
mar num-
wof
11
^
mar num-
serof
AY* of
«0flk Kttr-
2)
tthoutLott
orkdays
mar a CHECK
no entry was
made In col-
mn«8or9.
3) .
-Title _
Certification of Annual Summary Totsb "y
osHANo.aoo POST ONLY THIS PORTION OF THE LAST PAGE NO LATER THAN FEBRUARY 1.
-Due .
-------
APPENDIX G
BIBLIOGRAPHY
A Guide to the Safe Handling of Hazardous Materials Accidents: STP 825;
American Society for Testing and Materials; 1983.
Air Contaminants - Permissible Exposure Limits: OSHA 3112; 1989.
Air Sampling Instruments. 6th Edition; American Conference of Governmental
Industrial Hygienists (ACGIH); 1983.
Air Surveillance for Hazardous Materials USEPA Office of Emergency and
Remedial Response, Hazardous Response Support Division; 1985.
Casarett and Doull's Toxicology -- The Basic Science of Poisons. 3rd Edition;
Klaassen, CD, Amdur, MO, Doull, J; MacMillan; 1986.
Dangerous Properties of Industrial Materials: Sax, NI; Van Nostrand Reinhold
Co.; New York; 1984.
Detector Tube Handbook. 6th Edition; Dragerwerk AG Lubeck (National Draeger);
1985.
Fire Service Emergency Management Handbook: Federal Emergency Management
Agency; 1985.
Fire Protection Guide on Hazardous Materials. 8th Edition; National Fire
Protection Association; 1984.
Fundamentals of Industrial Hygiene. 3rd Edition; Plog, BA; National Safety
Council; 1988.
General Industry Standards and Interpretations: Volumes 1-3; OSHA 2077; US
Department of Labor, Occupational Safety and Health Administration; 1977,
Guide to Industrial Respiratory Protection: NIOSH Publication 87-116; US
Department of Health and Human Services, Public Health Service, Centers
for Disease Control, NIOSH; 1987.
Guide to Portable Instruments for Assessing Airborne Pollutants Arising from
Hazardous Wastes (draft international document); International
Organization of Legal Metrology; 1988.
Guidelines for the Selection of Personal Protective Equipment. 3rd Edition;
Schwope, AD; American Conference of Governmental Industrial Hygienists;
Cincinnati; 1987.
Handbook of Reactive Chemical Hazards. 3rd Edition; Bretherick, L;
Butterworths, London; 1985.
Hazardous Waste Inspections Reference Manual: US Department of Labor;
Occupational Safety and Health Administration; 1986.
-------
Hazardous Materials: Practical Tactical Considerations for Emergency Response
Personnel (seminar proceedings); Institute for Life Safety Technology and
Emergency Management Education, International Society of Fire Service
Instructors.
Hazardous Waste Handbook for Health and Safety:- Martin. W.F.; Lippitt, J.M. ;
Prothero, T.C.; Butterworth Publishers; 1987.
Hazardous Waste Operations and Emergency Response Regulation: 29 CFR Part
1910.120; U.S. Department of Labor, Occupational Safety and Health
Administration; 1986.
Hazardous Materials Emergencies Response and Control: Cashmon, JR; Technomic
Publishing Company; 1983.
Hazardous Materials: Isman, WE, Carlson, GP; MacMillan; 1980.
Hazardous Materials for First Responders. First Edition; International Fire
Service Training Association, Oklahoma State University; 1988.
ILO Encyclopedia of Occupational Health and Safety: Volumes 1 and 2;
International Labour Organization; 1983.
Industrial Hygiene -- A Guide to Technical Information Sources: Tucker, ME;
American Industrial Hygiene Association; 1984.
NIOSH Manual of Analytical Methods 3rd Edition; DHHS (NIOSH) Publication No.
84-100, Eller, P.M., Ph.D., CIH Editor; February 1984.
NIOSH/OSHA Pocket Guide to Chemical Hazards: US Department of Health and
Human Services, Public Health Service, Centers for Disease Control,
NIOSH; 1985.
Occupational Health Guidelines for Chemical Hazards: NIOSH/OSHA DHHS (NIOSH)
Publication No. 81-123; January 1981.
Occupational Safety and Health Guidance Manual for Hazardous Waste Site
Activities: NIOSH/OSHA/USCG/EPA; US Department of Health and Human
Services, Public Health Service, Centers for Disease Control, NIOSH;
1985.
OSHA Field Operations Manual: 2nd Edition; U.S. Department of Labor;
Occupational Safety and Health Administration; 1987.
Patty's Industrial Hygiene and Toxicology: Volumes 1 through 3B. Clayton,
F.E. et al. John Wiley and Sons, Inc.; 1978.
Performance of Protective Clothing: Barker, RL, Colletta, GC; American Society
for Testing and Materials; 1986.
G-2
-------
Personal Protective Equipment for Hazardous Materials Incidents: A Selection
Guide; NIOSH Publication 84-114; US Department of Health and Human
Services, Public Health Service, Centers for Disease Control, NIOSH;
1984.
Practical Guide to Respirator Use in Industry: Rajhans, GS, Blackwell, DSL;
Butterworth; 1985.
Protecting Personnel at Hazardous Waste Sites: Levine, SP, Martin, WF;
Butterworths.
Radiological Health Handbook: US Department of Health Education and Welfare,
Public Health Service; 1970.
Safety and Health in Building and Civil Engineering Work: International Labour
Office, Geneva; 3rd Printing, 1985.
Superfund Public Health Evaluation Manual: USEPA Office of Emergency and
Remedial Response EPA 540/1-86/060; October 1986.
The Health Physics and Radiological Health Handbook: Nucleon Lectern
Associates, Inc. Schleien, B et al editors; 1984.
The Industrial Environment -- Its Evaluation and Control: US Public Health
Service, Centers for Disease Control, NIOSH; 1973.
The Merck Index. An Encyclopedia of Chemicals and Drugs 10th Ed. Merck
Company; 1983.
Threshold Limit Values and Biological Exposure Indices for 1988-1989; American
Conference of Governmental Industrial Hygienists (ACGIH); 1988.
G-3
•ftU.S.GOVERNMENT PRINTING OFF I CEI 1 990-748-1 59/00388
------- |