EPA 540/G-90/003
                            Directive: 9285.3-05
                              September 1990
    Hazmat Team
Planning Guidance
Office of Emergency and Remedial Response
   U.S. Environmental Protection Agency
       Washington, DC 20460

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                                            NOTICE

The policies and procedures set forth in this document are intended solely to provide guidance. This guidance
does not constitute rulemaking by the U.S. Environmental Protection Agency (EPA), 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. The mention of trade names or commercial products m this manua
is for illustration purposes and does not constitute endorsement or recommendation for use by EPA. cost
estimates in this document are based on 1989 prices.  Contents of this manual do not necessarily reflect the
views and policies of EPA.
                                   ORDERING INFORMATION

 Additional copies of this document can be obtained from:

                                      ORD Publications
                                      Center for Environmental Research Information
                                      26 W. Martin Luther King Drive
                                      Cincinnati, Ohio 45268
                                      (513) 569-7562
                                      (FTS) 684-7562

 Singe copies are available without charge. Ask for publication number EPA/540/G-90/003. In addition, this
 document is archived with the National Technical Information Service (NTIS).  The document may be
 purchased by calling NTIS at (703) 487-4650.
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                                  TABLE OF CONTENTS



1.0  INTRODUCTION  ...... . ................................................. l

2.0  DO YOU NEED A HAZMAT TEAM?  ......................................... 3

       2.1     Conducting a Hazards Analysis ..................................... 3

              2.1.1  Hazards Identification ..................................... 3
              2.1.2  Vulnerability Analysis ...................................... 6
              2.1.3  Risk Analysis ............................................ 6

       2.2     Do You Need a Hazmat Team? .................................... 6

3.0 TRAINING AND EQUIPPING YOUR HAZMAT TEAM ........................... 7

       3.1     Training [[[ 7
       3.2     Medical Monitoring  ............................................. 9
       3.3     Equipment .............................................. ..... 10

              3.3.1   Monitoring Equipment ................ . ................... 10
              3.3.2   Personal Protective Equipment .............................. 11
              3.3.3   Containment Equipment  ............ ...................... 13
       3.4    Summary of Costs
 4.0 PREPARING RESPONSE PLANS
    AND STANDARD OPERATING PROCEDURES ................................ 15
        4.1    Conclusion
 APPENDIX A  Beginning the Hazards Analysis Process ............................. 17

 APPENDIX B  Medical Program .............................................. 29

 APPENDIX C  Hazardous Materials Incident: First-On-Scene Checklist ................. 53

 APPENDIX D U.S. EPA Regional Superfund Training Contacts  ...................... 55

 APPENDIX E Selected References  ............................................. 57


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                                      LIST OF TABLES



No.    Title                                                                       PagC


1      Personal Protective Equipment, Approximate Costs   	12

2      Containment Equipment and Tools, Approximate Costs  	13

B-l    Recommended Medical Program   	

B-2    Common Chemical Toxicants Found at Hazardous Waste Sites,
       Their Health Effects and Medical Monitoring  	34
                                                                                    43
B-3     Tests Frequently Performed by Occupational Physicians  	

B-4     Signs and Symptoms of Chemical Exposure and
        Heat Stress that Indicate Potential Medical Emergencies   	48


                                      LIST OF FIGURES


 No.     Title                                                                      Pa*e

 A-l    Hypothetical Dose-Response Curve of Two Chemicals, A and B 	
27

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                                    1.0  INTRODUCTION
This manual will assist local  fire departments in
identifying,  acquiring,   and  maintaining   the
hazardous  materials  response  equipment  and
trained  personnel appropriate for their  locale.
This manual offers guidance in the following areas:

•       Determining actual hazmat response
        requirements;

•       Establishing the goals  and  levels  of
        expertise   needed   to   meet  those
        requirements;

•       Estimating  the costs and  developing  a
        budget to meet your goals; and

•       Preparing response  plans and  standard
        operating procedures (SOPs) to include
        the entire local response community.
This manual will not provide specific answers to all
your questions. Each locale must plan according
to its own needs as well as its available resources.

Appendix A, Beginning  the  Hazard  Analysis
Process,  includes  an overview of the extent of
today's hazmat problem.  Appendix C contains a
Hazardous  Materials  Incident  First-On-Scene
checklist similar to one you should develop for
your response community.  Appendix E contains a
selected list of established regulations, standards,
and guidance and reference documents available to
assist you in  making informed  decisions  for your
situation. Appendix F includes  the names of some
individuals  actively involved   in  the   hazmat
response business. These people can help you plan
goals, identify sources of help,  and advise you on
pitfalls to avoid.   Keep in  mind that the most
successful response programs are  often the most
creative in meeting local needs and constraints.
                                                     Still interested?  Then let's get started!

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                        2.0  DO YOU NEED A HAZMAT TEAM?
Do you really need a Hazmat Team?  What do you
expect it to be capable of doing? How much is it
going to cost to establish and maintain a team?
These are some of the questions that we will try to
help you answer.

2.1 CONDUCTING A HAZARDS ANALYSIS

First you need to develop a realistic picture of the
potential  for a hazardous materials incident to
occur in your community by conducting a hazards
analysis. A hazards analysis will help you to:

 •      Identify  the facilities that  manufacture,
        store, and/or use hazardous substances;

 •      Determine the specific properties of the
        materials, including their health effects;

 •      Determine how  the  materials are stored
        and/or used, as well as what quantity is
        present;

 •      Determine  what  controls   and
        countermeasures exist at facilities where
        hazardous materials are  present  (e.g.,
        containment, neutralization,  facility fire
        brigades, hazmat teams, and automatic
        alarms);

  •      Identify  transportation  corridors  (e.g.,
        highways, waterways, air, and pipelines)
        through which  hazardous  materials are
        carried;

  •      Estimate the human  population, public
         buildings and systems, and environmental
         features that would be affected (and the
         extent of the effect)  in the event  of a
         release;

  •      Identify the frequency and scope of past
         incidents;

  •      Estimate the likelihood of an incident and
         the severity of any consequences to human
         beings and the environment; and
•      Understand what your organization would
       be expected to do or provide in case of an
       incident.

The U.S. Environmental Protection Agency (EPA),
the  Federal  Emergency  Management  Agency
(FEMA),   and   the   U.S.  Department   of
Transportation   (DOT)   have  published   the
Technical  Guidance for Hazards Analysis.  This
publication describes in detail how to conduct a
community-based hazards analysis, with particular
focus on lethal toxic chemicals. The same federal
agencies  have also published the Handbook of
Chemical Hazard Analysis Procedures.  It provides
an easy to  understand  overview of  chemical
hazards,  and guidance on conducting a hazards
analysis  for toxic,  flammable,  and   explosive
hazards.  You can obtain copies of these guidance
documents  and other  helpful  publications by
contacting the  agencies listed in Appendix E,
Selected References.

There are three steps in a hazards analysis:

 1.      Hazards identification;

 2.      Vulnerability analysis; and

 3.      Risk analysis.

 We will now describe each of these steps in more
 detail.

 2.1.1  Hazards Identification

 A hazards identification will provide  you with
 information on the hazardous materials in your
 area.  It provides you with information on each
 material's:

 •       Identity,

 •      Quantity,

 •      Location;

 •      Physical and chemical properties;

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•      Storage conditions;

•      Transportation routes; and

•      Potential hazards.

You can  look for this information in a variety of
places, for example:

•      SARA Title III reports;

•      Fire department records;

•      Fire inspection reports;

•      Transportation data; and

•      Government agencies and local businesses.

This  section   describes  how  each  of  these
information sources can help you.

SARA Title III Reports

Title III of the  Superfund Amendments  and
Reauthorization Act  of  1986  (SARA)  requires
facilities  to report information about hazardous
materials they have on site.  (Title III is also called
the Emergency Planning and Community Right-to-
Know Act of 1986.)

Section  302 of SARA  requires  facilities  that
produce, use, or store certain quantities of one or
more extremely hazardous substance on  EPA's
section 302 list to notify  the  State Emergency
Response Commission (SERC).  The SERC then
notifies the Local Emergency Planning Committee
(LEPC). Facilities must cooperate with LEPCs in
preparing a comprehensive emergency plan for the
district.

Section 311 of SARA requires facilities that must
prepare  or have available  Material Safety Data
Sheets (MSDSs)  under the Occupational Safety
and  Health  Administration  (OSHA)   hazards
communication regulations  to submit either copies
 of their  MSDSs, or a list of MSDS chemicals to
 the  LEPC,   the  SERC,  and the  local  fire
 department
MSDSs provide the following information:

•      The chemical name;

•      Its basic characteristics, for example:

       - toxicity, corrosivity, reactivity,
       - known health effects;
       -- basic precautions in handling, storage,
          and use;
       — basic countermeasures to take in the
          event of fire, explosion, or leak; and
       ~ basic protective equipment to
          minimize exposure to a release.

More detailed information on MSDSs and sample
information provided by MSDSs is contained in
Appendix A,  Beginning the Hazards Analysis
Process.

Section 312 of SARA requires that some facilities
submit Tier 1 and/or Tier 2 reports.  Tier 1 reports
contain aggregate information on the quantity and
general location of chemicals (listed by categories)
stored on site.  Tier 2 reports provide  substance-
specific  information  on  the  quantity  of  the
hazardous materials present on site, how they are
stored, and their location.

Title  III  requires   that  your   LEPC  make
information contained in these  various reports
available to  you, unless the information has been
protected by trade  secret provisions.

Fire Department Records

Some of the information you need may already be
in your fire department files. Review the  recent
history of your responses to hazardous materials
incidents.   Focus  on the past five years.  Go
through  your files carefully!  Unless you have
maintained very precise files, the information you
need can be buried under such classifications as
"Washdown," "Stand-by," "Odor Investigations," or
the infamous "Other." Look at the information in
these  reports for clues to the  presence of a
hazardous material. Even though you may not be
able immediately to identify the specific materials,
any  situation where something unusual occurred

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during normal fire  fighting  operations  (e.g., a
turnout coat developing holes) can indicate that a
hazardous material was present.  Try to assemble
the following information:

•      What material was present?

•      How much material was present?

•      How  much  material was  released or
       involved in the problem?

•      What injuries and/or deaths happened?

•      What environmental effects, if any, were
       there?

•      What was the  potential for additional
       injury or damage in each case?

•      What was the actual cost incurred  as a
       result of the incident (e.g., costs related to
       response,   cleanup,   and  system
       disruptions)?

•      How may incidents have occurred?

Fire Inspection Reports

Fire department pre-plans are developed around
special problems in your jurisdiction and  may
contain information about hazardous materials.

Local  fire   inspection  reports   typically   list
substances found in buildings that could present
special or  unusual  problems, concerning public
safety, as well  as provide an  assessment of the
ability of emergency responders to handle incidents
at that building.  These inspections are normally
conducted on an annual basis, with more frequent
inspections for more hazardous buildings. These
inspections focus on substances that are not on
official lists of hazardous materials or are not
present in reportable quantities, but are considered
hazardous to the responders.

Finally,  fire  inspection  reports  may help  you
develop  a  picture  of  the  rate  of  growth of
hazardous materials in your community.
Transportation Data

Police and fire department personnel may have a
good  idea  of what  hazardous  materials  pass
through a community, -the routes most frequently
used, and the frequency of transport. If you have a
truck weigh station in or around your jurisdiction,
you may be able to obtain information regarding
the number of placarded loads moving through
your area. Further information regarding the load
contents may be available through the carrier or
shipper's office.

Specific guidance on gathering information about
hazmat transportation  in  your community is
included in the Handbook of Chemical Hazard
Analysis Procedures mentioned earlier and listed in
Appendix E, Selected References.

Government Agencies and Local Businesses

Now that you have reviewed your own files, it may
be useful to contact the local health department.
Another useful contact may be the waste treatment
facility in your jurisdiction,  if you have such  a
facility. Although they may not have dealt with
large quantities of  hazardous  materials,  these
people may have investigated hazmat problems in
the past.

Try  to document  the types  and quantities  of
hazardous  materials  involved, the potential  for
harm associated with each incident, and the total
number of past incidents  in  the community.   In
addition,  try  to  contact  any  other  agency or
business in your jurisdiction that may have dealt
with these materials.

Other sources  of  historical  data  for  your
jurisdiction  include  your  state department  of
natural  resources,   your  state  emergency
management  agency, and  EPA.  These sources
frequently maintain a record  of all incidents that
occurred within the past ten years, recorded by the
counties in which they occurred.

When you complete the hazards identification step,
you  should have  a  list  of the facilities with
hazardous  materials  on  site, the location  and

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 quantity of the chemicals, the health hazards posed
 by the chemicals, and the routes used to transport
 the hazardous materials through your community.
 The  next  step  is  to  determine who might  be
 affected by an incident.

 2.1.2 Vulnerability Analysis

 The vulnerability analysis identifies the geographic
 zone of your community that may be affected by a
 spill  or release of a  hazardous  material;  the
 populations within the zone that may be subject to
 harm; specific environmental dangers; and critical
 buildings in the zone (e.g., hospitals, schools) that
 are at risk.

 You can obtain more detailed information on how
 to  conduct  a vulnerability  analysis from  the
 Technical Guidance for Hazards Analysis mentioned
 previously  and  listed  in  Appendix E,  Selected
 References.

 2.1.3  Risk Analysis

 The risk analysis  provides you with a basis to judge
 the likelihood of a release, as well as the severity
 of consequences  to  humans and the environment
 if an incident occurs. The risk analysis gives you a
 basis  for comparing sites to establish major areas
 of emphasis for emergency planning.

 You can obtain more detailed information on how
 to conduct a risk  analysis from  the Technical
 Guidance for Hazards Analysis.

2.2 DO YOU NEED A HAZMAT TEAM ?

You  should  now be  developing a reasonably
accurate picture of the hazardous materials in your
 community  and  the   potential   threat  these
 chemicals pose. Your data should be helping you
 answer two very important questions:

 •      Do you need a Hazmat Team?

 •      If so, what level of expertise do they need?

 If you determine that the hazardous materials in
 your area pose a threat to your community, there
 are a number of ways to address the problem.

 For example, you could ignore the existence of the
 hazardous  materials, you  could  rely on  the
 industrial sector to prepare for the occurrence of
 a hazardous release, or you could develop your
 public response capabilities.

 Some communities will need to start from "ground
 zero" and develop a coordinated "hazmat response
 community" that includes fire fighters, the police,
 hospitals and medical personnel, the media, public
 works  personnel,  volunteers,  contractors,  and
 others.    The  Hazardous  Materials Emergency
Planning Guide (NRT-1), published by the National
 Response Team, includes extensive guidance to
 help you set up a comprehensive local emergency
plan.   Only when your response "community" is
fully planned, trained, and  operational, will  you
develop a more accurate  picture of whether  you
need a Hazmat Team and what its role would be.

Let's presume that you  have decided that your
community needs a  Hazmat Team.   The next
chapter will provide you with some practical advice
on what you should do next.

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             3.0  TRAINING AND EQUIPPING YOUR HAZMAT TEAM
If you think that you need a Hazmat Team, you
should consider the following three areas before
announcing the formation of a team:

•       Training;
        Medical monitoring; and

        Equipment    (monitoring,
        protective, and containment).
                             personal
In  this  chapter  we  describe basic needs  and
requirements   related   to   training,   medical
monitoring, and equipment, and provide some cost
estimates for each area.  Remember: your actual
costs will depend upon your local hazmat situation.

Reference  will  be  made  to  the  following
regulations and standards:

.       29 CFR 1910.120,  OSHA  Final Rule,
        Hazardous   Waste   Operations   and
        Emergency Response; and

•       National Fire Protection  Association
        (NFPA), Standard  472,  Professional
        Competence of Responders to Hazardous
        Material Incidents.

Refer to Appendix E, Selected  References, for
information  on how to obtain  copies of these
publications. We suggest that you obtain copies of
all publications listed in Appendix E whether you
have decided to start a  Hazmat Team or not.
Even if you decide not to have a formal Hazmat
Team,  you still  have training  and operational
obligations to meet!
 3.1
TRAINING:
intelligently!
Do the  job  safely  and
 If you are going to send someone to evaluate or
 control   an  emergency  involving   hazardous
 materials, that person must receive training to do
 the job safely and intelligently.  In Standard 472,
 the  National   Fire   Protection   Association
 recommends that hazmat responders receive the
appropriate training for each of-the following four
levels:

•      First Responder Awareness Level

•      First Responder Operations Level

•      Hazardous Materials Technician

•      Hazardous Materials Specialist

A  Hazmat  Team should  be  trained  to  the
"Hazardous Materials Technician" level defined by
NFPA Standard 472.

In  addition to  the  NFPA standard,  OSHA's
Worker Protection Standards, found  in 29 CFR
1910.120,  require levels  of training,  medical
surveillance, personal protective  equipment, and
emergency response plans (including the  use of a
site-specific incident command system).

According to 29  CFR 1910.120(q)(6):   Training
shall be based on the duties and function  to  be
performed by  each responder  of an  emergency
response  organization.  The skill and knowledge
levels required for all new responders, those hired
after the effective date of this standard,  shall  be
conveyed to  them through training before  they are
permitted to take part in actual emergency operations
on  an incident.  Employees who participate, or are
expected to participate, in emergency response, shall
be given training....

EPA  has issued regulations  with the  same
requirements for hazardous materials responses in
states not covered by OSHA regulations. These
standards  are  now  required   for everyone
responding to hazardous materials incidents.

The following is a brief description of each of the
five responder  levels  in the  OSHA  Worker
Protection Standards.

First Responder Awareness Level.  This level of
training applies to individuals: (1) who are likely to
witness or discover a hazardous materials release;

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and  (2)  who have received  prior training  in
initiating  an emergency response  sequence  by
notifying the proper authorities. Individuals at this
level*can take no further action beyond notifying
the authorities of a hazardous materials release.

This  is the  first step in  hazardous materials
training.   If you  have  not yet accomplished this
goal, then this is the place to start the training for
all of your emergency  response personnel.   This
would also be a  good  level of training for local
elected officials,  industry  managers, and  any
employees involved in your budgetary development
or approval process.   This  level of training will
help  these  individuals to  develop  an accurate
picture of the hazardous materials problem and the
programs  needed to address  that problem.

First Responder Operations Level.  Individuals at
this level  function as part of the initial response
group at the  site  of an  actual  or  potential
hazardous materials release. They protect nearby
persons,  property, and/or the environment from
the effects of the release.   They are  trained to
respond in a purely defensive  manner. They are
not responsible for stopping the release.  Rather,
they contain the release, if  possible, from a safe
distance, while preventing additional exposures.

This may  be the current level of training for your
local   fire and  police departments,  emergency
medical   service  (EMS)  agency,  and  similar
organizations.  If these potential first responders
are not yet at this level,  training them should be
your primary goal.  A minimum of eight hours of
initial training is required to satisfy this level of
expertise.   You  must  accomplish this  before
proceeding with the development of your Hazmat
Team.

Hazardous Materials Technician.  Technicians are
responsible  for  stopping  hazardous  materials
releases.  A technician's goal is to plug, patch, or
in any other way, stop  the release to which he has
responded.  This is a  more aggressive role than
that of a first responder at the operations level.
The OSHA regulations require a minimum of 24
hours of training at the first responder operations
level for  hazmat technicians.   Technicians  must
also demonstrate in the field a certain competency
in these training areas.
If this response level is not compatible with your
understanding of a Hazmat Team, you may have
been envisioning the development of a well-trained
operations level  response rather than a formal
Hazmat Team.  This is just one reason why you
must determine the actual response needs of your
jurisdiction before proceeding with Hazmat Team
development.  If your goals can be met within the
definition of the  first responder operations  level,
then you probably do  not need to  incur  the
additional costs  required for technician training.
However, if you do wish to proceed, you will need
to establish a training program  that meets your
needs as well as all OSHA requirements.

Hazardous  Materials  Specialist.     Hazardous
materials specialists  respond  with  and  provide
support to hazardous materials technicians.  Their
duties parallel those of the hazardous materials
technician.  In addition, however,  their  duties
require  a more directed or specific knowledge of
the various  substances involved in the response.
Hazardous materials specialists must have training
equal to  the  technician level and demonstrate
competency in specified areas.   Among  other
things, they must be familiar with and know how
to  implement  the  relevant  local  emergency
response plan and must have knowledge of the
state emergency response plan.
                                           i
On-Scene Incident Commander.   The  On-Scene
Incident  Commander  (QIC)  assumes  overall
control  of the emergency response incident  scene
and coordinates- the activities  of the emergency
responders and the communications among  them.
The QIC must receive training equivalent to the
first  responder  operations  level  and  must
demonstrate competency in certain specified  areas.
For  example,  the QIC must  know  how  to
implement the local emergency response plan and
know of state and federal response capabilities;
know and  understand   the  hazards and  risks
associated with  employees working  in  chemical
protective clothing; and know and understand the
importance of decontamination procedures.

If you have decided  that your community  needs
responders  trained at least  to  the level  of a
hazardous materials technician, then  you  have
crossed into the  realm of a Hazmat Team.

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Cost of Training

Training costs money, whether it is conducted in
service or on an overtime basis.  Indeed, training
costs can make the biggest dent in your Hazmat
Team budget.  First, decide on the size of team
you would like to have.  Then you can  more
accurately estimate the dollars needed to train
personnel to  the response level you require.  For
example, consider the following:

•       What degree  of coverage do  you want
        (e.g., 24 hours per  day, 7 days  a week; 8
        hours per day, 5 days a week)?

•       Who will cover vacations, sick leave, or
        other absences?

•       Will  your team  always be on duty, or
        sometimes off duty subject to call?

In many communities, the total size of  a Hazmat
Team is  larger than just the number of members
on duty at a given time. Only you can accurately
estimate the personnel required. We recommend,
however, a minimum of four persons on duty per
shift.  Typical initial training costs associated with
an  "average"  four  person Hazmat Team are
approximately  $4,500,  with  additional  funds
required for supplemental financing for each year
of operations.

29 CFR  1910.120(q)(7) outlines the requirements
for "trainers" or instructors of emergency response
personnel.  Instructors within the  hazmat sector
must  be competent in the subjects  they teach.
State and federal agencies offer numerous training
programs. By taking advantage of these programs
and   programs  offered  by the  International
Hazardous Materials  Association  and  similar
organizations, you  can  minimize costs while
maximizing training opportunities.   Be sure to
establish the credibility of instructors and training
materials when investigating training  sources.
Current  information regarding available training
programs can be obtained by contacting your state
department  of  natural  resources and/or  your
regional EPA training contact Refer to  Appendix
D for a list of EPA training contacts.

At this point, you may wish  to explore alternatives
to a Hazmat Team, particularly if your department
cannot bear alone the costs of personnel, training,
and equipment

One alternative available to you is to modify the
fire department mutual aid contract. Upon written
commitment,  the   participating   mutual  aid
organizations  would  agree to  train  a certain
number  of employees  to a  specified level  of
expertise. Each organization would agree to have
at least one of these trained employees on duty at
all times.

Costs would be  shared by these organizations
according to a predetermined formula. As long as
the total response  team can be assembled at a
scene within a reasonable time (i.e., less than one
hour), this  may be an effective alternative to a
formal Hazmat Team.

If you represent a  fire  department dealing with
mostly fixed facility problems, you may want  to
approach industry representatives in your locale.
After all, these people are part of your response
community! Because industry personnel routinely
work with  the  very substances  that you are
preparing to handle, they already have a working
knowledge of the substances.  They also may have
a facility response team equipped with personal
protective equipment and  monitoring equipment.
Check to see if they will either supply equipment
for you  to  use  or replace any equipment you
expend at these sites.  Also, consider using these
industry resources in your  training program.

Also, consider calling on volunteer organizations in
your community who may have special knowledge
or talents  to support your response  capability.
Would it be possible  to recruit these people for
your  planning  operations and/or as technical
advisors  in the  event  of  a  release?    Fire
departments have volunteers and the police have
reserve  forces;  you  might  develop  a  similar
program  for your Hazmat Team.-

3.2 MEDICAL MONITORING: Keep your team
healthy!

The OSHA regulations in 29 CFR 1910.120(q)(9)
require  you to  provide a  medical  monitoring
program  for your Hazmat Team.  The medical
monitoring  program   requires   a   complete

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examination of your Hazmat Team members at the
following times:

•       Prior to assignment to the Hazmat Team;

•       At regular intervals not greater than bi-
        annually;

•       At termination of employment or upon
        reassignment to another job description;

•       After any exposure to  a  hazardous
        material; and

•       At such times as the physician  deems
        necessary.

The scope of this program will depend upon: (1)
the physician you choose to oversee your program;
and (2)  the information you  provide  to  this
physician  as a result of your  hazards  analysis
program.  You can help the  physician develop a
program  to  effectively  protect your  responders
while minimizing the costs involved.

Based upon the list of substances that your team
may be exposed to during responses, the physician
will provide, with your assistance, a written medical
monitoring procedure.   Refer  to  Appendix  B,
Medical Program, for general guidance in designing
&  medical program  for personnel  at hazardous
waste sites.   Appendix B  is  reproduced  from
chapter 5 of the Occupational Safety  and Health
Guidance  Manual for Hazardous   Waste  Site
Activities.  (See Appendix E, Selected  References,
for more  information.)

Cost of Medical Monitoring

The cost of this required  medical  monitoring
 program will range from S450 to S1000 per person
each  year.   (Keep  in mind,  this  is  only  an
 estimate.) If you  choose a team of four persons
 per shift  for three shifts, then  the costs can run
 from 55,400 to 512,000 annually.  Before you panic,
 discuss this program with a physician who can
 supply you  with  an accurate  figure  for  your
 proposed operation!     Remember  a  medical
 monitoring  program is a requirement, not  an
 option.
3.3 EQUIPMENT:  Respond Effectively!

You will need  specialized equipment for air
monitoring, personal protection, and containment.
Unless you plan to buy a new response vehicle
dedicated  solely  to  hazmat  response,   then
equipment costs will usually be less than the costs
associated with training and medical monitoring.
You probably cannot train and equip a team to
deal with every possible situation that may happen,
but you can look at your list of likely problems and
gear your program to those ends. As you identify
what  equipment  you  need,  check with  other
members  of your  response  community before
purchasing it.  If the equipment is available to you
through the response community,  then you  may
not need to purchase it.

3.3.1  Monitoring Equipment

If  you expect your  Hazmat  Team  to   enter
potentially hazardous  atmospheres of unknown
content,  your team will need the equipment to
detect dangerous airborne chemical concentrations.
The equipment listed below is the minimum any
entry team should  have when responding to an
incident:

a.  Combustible gas indicator detects the presence
of flammable gases  and indicates the approximate
concentration  of    the   gas/vapor   in   "%"
concentrations of the lowest explosive limit.

b.  Oxygen level  indicator measures the level of
available oxygen in  the atmosphere. Even though
your team is entering with positive pressure self
contained breathing apparatus (SCBA), the oxygen
meter will warn them if excessive oxygen is present
or if something is using or displacing the available
oxygen.

c.  Colorimetric tubes measure the concentration
of a specific chemical or chemical family. Through
your  hazards  analysis you have an idea of what
tubes  your team will need.   These  tubes are
calibrated to indicate "parts per million" (ppm) or
"%" concentrations.

d. pH  paper indicates  whether  a substance is
acidic or basic. This represents a small investment
 to keep the team out of corrosive situations.
                                                 10

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e.  Flame ionization and photoionization detectors
detect   the  presence  of  organic  vapors  in
concentrations as low as 0.5 ppm and are valuable
additions  to your equipment  supplies.   These
detectors may be available to you through local,
state, and federal agencies.

An investment of about $1,700 will provide your
team with this basic monitoring equipment

Before you make any decisions about monitoring
equipment, review 29  CFR 1910.120(h)  and the
Standard Operating Safety Guides, Part 5  listed in
Appendix E, Selected References, for additional
information. Both will give you a better picture of
how  monitoring  equipment may  be  used  to
characterize sites and to assure personnel safety.

3.3.2 Personal Protective Equipment

Before your team can enter areas with actual or
suspected hazardous materials concentrations, they
must be outfitted with equipment that  provides
respiratory  and dermal protection.    This  is
particularly  important   when   your  team   is
responding to a situation that has yet to be fully
 evaluated.

 You probably already own the most expensive
 piece of necessary personal protective equipment:
 the SCBA.  The cost of this  item will not be
 included here in the equipment estimates for your
 Hazmat Team because it is commonly found within
 the response community and at fixed facilities with
 potential airborne toxins.  If you do not already
 have SCBAs,  however,  then you  can count on
 spending $1,200 per unit (for  a 30-minute tank)
 and $400 per spare cylinder.

 Protection Levels

 There  are  four  levels  of protection  to  be
 considered for hazmat work.   Since  a  response
 team  usually  works  in  an  uncharacterized
 atmosphere, two levels can be eliminated from
 immediate consideration.  These are:

 Level   D:    Normal  work  uniform  with  no
 respiratory protection.
Level C:   Respiratory protection  using an air
purifying respirator (filter type mask), with some
dermal protection including a lightweight chemical
coverall, gloves, and boots.

Your goal  is  maximum  respiratory protection
when:   (1)   entering   atmospheres  containing
unknown substances; or (2) entering atmospheres
containing  known  substances   in   unknown
concentrations. This leaves two remaining levels
to discuss:

Level B: Maximum respiratory protection utilizing
SCBA and a lesser degree of dermal protection
than provided by Level A.

Level A:    Maximum  respiratory protection  by
utilizing SCBA and maximum dermal protection
from a totally encapsulating chemical suit.

Review your hazards analysis data to  determine
whether your team will be expected to work in
direct contact with concentrated chemicals. If so,
then you  should investigate attaining a  Level A
capability. Otherwise, a Level B approach may be
your best  bet. Keep in mind that even if you need
Level A capability, the majority of your responses
will require only a Level B operation.

When researching protective suits, remember that
these suits are not armor.   These suits resist
particular chemicals. They do not protect against
every chemical, nor does  one size fit all. Select
your equipment carefully, based on your team's
potential exposure, and size this equipment to your
team members on an individual basis.

Should you decide on a Level B approach for your
team, you may wish to consider a fifth protective
level:  Level B encapsulated. Level B equipment,
regardless of taping, leaves some skin, and all of
the SCBA gear, exposed.  Since several  common
chemicals are corrosive or become so upon contact
with the  moisture in the air (see  Appendix A),
ordinary Level B protection may not be adequate.
Level  B  encapsulated suits  are  slightly more
expensive, but they  afford a higher degree of
 protection, reducing the possibility  of dermal
 contact with  harmful vapors  and completely
 enclosing the wearer's air supply.
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Costs of Chemical Protection Equipment

Approximate  costs   of  chemical  protection
equipment  are contained  in Table 1. You can
estimate that the initial  cost for a  Level  B
encapsulated program with Nomexฎ coveralls (for
flash protection) would be  about $2,410 - 3,060.
The costs for your team are completely dependent
on your type of program and the number of people
involved. Don't forget that any personal protective
equipment you choose and any decontamination
procedures  you use must be consistent with the
SOPs defining their use and the provisions in 29
CFR 1910.120(q)(10).
TABLE 1
PERSONAL PROTECTIVE

EQUIPMENT


APPROXIMATE COSTS (CATALOG PRICES)
TEAM SIZE:
4

LEVEL B ENCAPSULATED CAPABILITY
OTY ITEM
6-8 "B" encapsulated Saranexฎ suits
4 Nomexฎ coveralls
8 Chemical boots
8 Latex boot covers
8 Nitrile gloves (sized over & under)
4 Vitonฎ gloves
8 Butyl gloves
8 Thermal glove liners
1 Box latex gloves
4 Hard hats
8 Hooded Saranexฎ suits
4 Acid splash protection
4 Duct tape
TOTAL
PRICE
$ 125.00 - 175.00
150.00
50.00
5.00
2.00
35.00
17.00
2.00
20.00
6.00
18.00
25.00
6.00

COST
$ 750.00 - 1,400.00
600.00
400.00
40.00
16.00
140.00
136.00
16.00
20.00
24.00
144.00
100.00
24.00
$2,410.00-3,060.00
LEVEL A CAPABILITY: SUIT OPTIONS
4 Teflonฎ encapsulated suits
4 Vitonฎ encapsulated suits
4 Butyl encapsulated suits
4 PVC encapsulated suits
5,800.00
2,800.00
1300.00
1,100.00
23,200.00
11,200.00
5,200.00
4,400.00
                                                12

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3.3.3 Containment Equipment

Once your team is suited up and ready to enter the
hot zone, they will need materials to contain the
released chemicals, tools and materials to stop the
release, as well as containers  in which to secure
volatile released products.

Table 2 below is a list of containment equipment
and non-sparking tools that should be included in
a beginning inventory of most Hazmat Teams. The
tools and equipment needed by your Hazmat Team
will  be dictated by the  hazards you might face.
Refer to your hazards analysis data  and add any
specialized equipment you  may need.
Many  of  the supplies  you  will  need can  be
purchased at local hardware  stores.  For more
information,  check the  yellow  pages  of  your
telephone book under "Fire Equipment,"  "Safety
Equipment," or other appropriate headings for the
particular equipment you may need.

If you require special equipment (such as pagers)
to summon  assistance, then you should include
these  items  in  your budget.   Do  you  have
intrinsically safe radios and lights?  If not,  then
you  will  have  to purchase them.   Using  the
information  obtained  in your  hazards  analysis
process, identify your  specific needs and include
them in your budget proposal.

QTY
2
2
1
2
2
2
12
2
2
2
2
1
100
2
6
2

TABLE 2
CONTAINMENT EQUIPMENT AND
APPROXIMATE COSTS (CATALOG
ITEM
Non-sparking bung wrench
Non-sparking drum box wrench
Non-sparking tool kit
"Safe" shovels
Rolls of banner guard
Pushbrooms
Traffic cones
85-gallon Epoxy lined drums
30-gallon Epoxy lined drums
8-gallon drums
25-gallon poly pails
Haz Mat "A" Kit
Feet of 8" oil sorbent boom
Bundles (200 each) sorbent pads
Bags of inert sorbent material
Boxes (75 each) 55-gallon PE bags
TOTAL
TOOLS
PRICES)
PRICE
$ 16.00
73.00
898.00
29.00
15.00
12.50

120.00
60.00
50.00
6.00
660.00

75.00
7.00
84.50


COST
S 32.00
146.00
898.00
58.00
30.00
25.00
150.00
240.00
120.00
100.00
12.00
660.00
425.00
150.00
42.00
169.00
S 3,257.00
                                                13

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3.4 SUMMARY OF COSTS

We have given you an overview of the exists related
to training, medical monitoring, and equipment for
a Hazmat Team. The total estimates for each area
are as follows:
Training
Medical monitoring
Monitoring equipment
Protective equipment
Containment equipment

TOTAL COST
         $4,500
   5,400 - 12,000
           1,700
   2,410-  3,060
          '3.257

S 17,267 - 24,517
Personnel costs are ongoing and will probably
increase with  time.   The cost of  equipment
maintenance and replacement will be  affected by
inflationary  increases unless alternate means of
funding and replacement can be found.

Under the Superfund program,  EPA has  issued
regulations that may permit you to recover some of
the costs your Hazmat Team incurs in the course
of its response work.  These regulations permit
reimbursement  to  local  governments  (up  to
525,000 per  incident) for "temporary emergency
measures" taken in the course of responding to a
spill or release of a CERCLA hazardous substance
or pollutant or contaminant. This reimbursement
covers immediate response measures required at
the local  level.   These measures  can include
activities such as securing the area, controlling the
release source, containing the substance released,
or similar activities your team must perform within
minutes or hours of the release to prevent or
mitigate   injury   to  human  health  or   the
environment.    This reimbursement  does   not
include expenditures associated with traditionally
local services and responsibilities, such as routine
emergency fire fighting.  For details on the six
steps that comprise the reimbursement process, see
Part 310  of Title 40 of the  Code of Federal
Regulations (40 CFR Part 310).

Some jurisdictions have  adopted an  ordinance
allowing them to bill the party responsible for a
release for equipment expended; others bill for
personnel  hours   and  equipment.     Some
organizations   have  existing   agreements  to
reimburse any assisting  group or agency for costs
resulting from an  incident at their facility.  With
these types of arrangements, the agency supplying
the assistance will not have to fully fund every item
expended.

Does this  mean maintenance costs of the hazmat
program can be reduced?  Possibly!  Remember
though, you may not be able to recover any costs
from some spillers, and reimbursement may be
delayed from  others.   You will still need to
maintain  a  budget   reserve  for  equipment
replacement in a timely manner.
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                         4.0  PREPARING RESPONSE PLANS
                   AND STANDARD  OPERATING PROCEDURES
During  an incident, your Hazmat  Team must
depend upon and work closely with other persons
or groups that have particular hazmat expertise,
including:

•       Fire personnel;

•       Police;

•       EMS personnel;

•       Public works personnel;

•       Local health department personnel;

•       Specialists in the hazardous material(s)
        with which you  are  dealing (e.g., from
        private industry, the local high school, or
        the   local   community   college   or
        university);

•       State agencies; and

•       Federal  agencies  and   the  Regional
        Response Team.

As you define  the roles needed for your response
community, start  to develop a mental picture of
the people in your area that will meet these needs,
and what training and involvement will be required
to make  them part of  your  response program.
You will need this assistance  for everything from
early recognition of the presence of hazardous
materials to the final critique of your operations.

Before  your team can respond  to  a hazardous
materials incident, however, you  need to develop
your  response plans and Standard  Operating
Procedures (SOPs)  as  required  by  29 CFR
1910.120(q).

Develop  your Hazmat Team and your  outside
resources concurrently. Listing persons and groups
as  resources  without  including them  in  the
planning and training phases of your development
process  reduces their  effectiveness  as  resources.
These people must know what is expected of them
and be  familiar  with  your response SOPs and
Incident  Command   System.    A  contractor
responding  to your request for heavy equipment
will not be of help to you if his people do not
meet OSHA training requirements.

As  you  proceed  to  develop your   response
capabilities, identify the resources available to you,
what you expect them to do, what level of training
they need, as well as what level of training they
currently have, and make sure to include them in
your planning, training, and in developing your
response SOPs.

A response will be more effective if you train and
drill your response community.  If you familiarize
the individuals  and agencies in  your  response
community   with  each   other  and  develop
compatible   procedures   through   real   scale
simulations, uniting your response community at
the scene of an emergency will be easier.

For detailed guidance  on response plans, consult
the Hazardous Materials Emergency Planning Guide
published by the  National  Response Team and
commonly referred to as NRT-1. See Appendix E,
Selected References, for directions on obtaining a
copy  of the guide.   Computer  packages  are
available (e.g., SAFERฎ, CAMEO II) to aid in the
management  of  emergency operations or  to
simulate emergency   scenarios  to  assist  with
training and preparedness.

For further information on available  computer
packages,  consult EPA's  Chemical Emergency
Preparedness and Prevention Technical Assistance
Bulletin  #5,  Computer  Systems  for  Chemical
Emergency Planning.  This bulletin will provide you
with a checklist for evaluating computer packages
and information on available systems identified as
applicable to local planning. To obtain a copy of
this  bulletin,  refer  to  Appendix  E,  Selected
References.
                                               15

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4.1 CONCLUSION                                  with  a realistic picture of the challenges  to be
                                                    overcome and the magnitude of the effort involved.
Every facility or jurisdiction will have some unique
hazard or response capability that will deserve       The  key  message we intend  to  convey in this
special consideration in the planning process. This       manual is to research your problem by conducting
manual asks a lot of questions for which you will       a hazards analysis, and then plan accordingly with
have to supply the answers. We have supplied you       your entire response community.
                                               16

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                                          APPENDIX A
                        BEGINNING THE HAZARDS ANALYSIS PROCESS
This appendix provides a summary of the sources of information about hazardous materials in a community.
Detailed information is provided about Material Safety Data Sheets (MSDSs) and their use in the hazards
analysis process.

Several recent federal studies show that there are currently between 5 and 6 million chemicals.  This number
grows at a rate of about 6,000 chemicals per month. Furthermore, a recent computer review of the complete
list of known chemicals by the Chemical Abstract Service indicates that a first responder can expect to
encounter any of 1.5 million of these chemicals in an emergency, with 33,000 to 63,000 of them considered
hazardous. To  complicate matters, these hazardous chemicals are known by 183,000 different names.

The U.S. Department of Transportation (DOT) and the U.S. Environmental Protection Agency (EPA) have
used several measures of toxicity and volume of production to develop a shortened list of chemicals that they
consider hazardous when transported in commerce. This list is comprised of about 2,700 chemicals, listed in
40 CFR 172.101. The 1987Emergency Response Guidebook also lists these chemicals. The Occupational Safety
and Health Administration (OSHA) regulates about 400 hazardous chemicals on the basis of occupational
exposures. The National Institute of Occupational Safety and Health  (NIOSH) Pocket Guide to Chemical
Hazards contains a list of these chemicals.  As required by Title III of the Superfund Amendments  and
Reauthorization Act of 1986,  EPA has  prepared  a list of extremely hazardous substances that currently
includes about 360 lethal air toxins.

Even these relatively short lists of chemicals can be intimidating to local response personnel hoping to develop
a comprehensive hazards analysis for their community.  Further complicating  their job is • the fact that,
according to a recent study by the National Academy of Sciences, National Research Council (NRC), there
is so little known about seven-eights of the 63,000 hazardous chemicals that not even a partial assessment can
be made of their health hazards.  Some conclusions drawn from the NRC study are as follows:

•    Of the  3,350 pesticides classified as important chemicals,  information sufficient to make a partial
     assessment of the associated health hazards is available on only about 1,100 to 1,200 (34%)  of them.

•    Of the  1,815 drugs or drug ingredients noted, about 36% have enough  information for a partial
     assessment.

•    For the 8,627 food additives listed, there  is partial information on 19%.

•    For the remaining 48,500 industrial chemicals, there is enough information on just 10% to develop even
     a partial assessment.

The lack  of generally accepted names  for chemicals considered hazardous and  the lack of data available to
assess risks  together create a stumbling block for emergency response personnel and community officials
responsible  for developing a viable, effective local hazardous materials management system.  Without a
contingency plan based on effective and accurate hazards analysis prior to an emergency, it would  be difficult
and time-consuming to develop the necessary information in the midst  of an emergency.
                                                17

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Hazards Analysis Data Sources

The first step of a hazards  analysis  is to gather data on the  location, quantities, and health hazards of
chemicals in a community before a release occurs. This task may seem monumental from two aspects: (1) the
sheer numbers of chemicals  out there, and (2) the lack of information in useable form available on these
chemicals.  This section suggests various methods you can use to gather useful data about chemical hazards
in your community.

1.   Consult historical records. These records contain information, on a national level, concerning the most
     frequently released chemicals.  For example, studies have shown that  the most commonly released
     hazardous chemical is commercial vehicle fuel (gasoline). In 1985, EPA commissioned a national study
     of 6,928 incidents involving chemicals other than fuel to look at hazardous chemicals and the source of
     their releases.1 The study indicated that 74.8% of the releases were fixed facility incidents and 25.2%
     were in-transit incidents.

     The fixed facility incidents were distributed as follows:

                             20.7% storage,
                             19.4% valves and pipes,
                             14.1% process,
                             17.9% unknown,  and
                             27.8% other.2

      The in-transit incidents were distributed as follows:

                             54.5% truck,
                             36.1% rail,
                              3.8% barge,
                              3.1% pipeline, and
                              2.5% other.

      Perhaps the  most useful information from this national  study is the identity of the  chemicals most
      commonly involved in these 6,928 incidents.  Approximately 48.5% of the incidents involved only the
      following 10 chemicals:

                              23.0% polychlorinated biphenyls (PCBs),
                              6.5% sulfuric acid,
                              3.7% anhydrous ammonia,
                              3.5% chlorine,
                              3.1% hydrochloric acid,
                              2.6% sodium hydroxide,
                              1.7% methanoVmethyl alcohol,
                              1.7% nitric acid,
     1 Acute Hazardous Events Data Base, Industrial Economics, Inc., Cambridge, MA, December 1985. EPA
 is in the process of updating this report.  Although the newer statistics vary slightly from those presented in
 this report, the general distribution of release incidents has not significantly changed.

     2 The types of incidents contained in this category include disposal, heating and cooling systems, and
 vehicles not in-transit.
                                                 18

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                             1.4% toluene, and
                             1.4% methyl chloride.

    Human injury or death resulted from 468 of the 6,928 incidents. Events involving injuries and deaths
    have occurred throughout all industrial sectors, with about  one-third occurring at chemical and
    petroleum refining facilities, one-third occurring at a wide variety of other industrial facilities, and one-
    third occurring in-transit.  The 10 chemicals listed above accounted for 35.8% of the death and injury
    events, as follows:

                             9.6% chlorine,"
                             6.8% anhydrous ammonia,
                             5.6% hydrochloric acid,
                             4.7% sulfuric acid,
                             2.8% PCBs,
                             2.4% toluene,
                             1.9% sodium hydroxide,
                             1.5% nitric acid,
                             0.4% methyl alcohol, and
                             0.1% methyl chloride.

     Notice that the release and injury data are different. For example, although PCBs were involved in more
     incidents, chlorine posed a greater threat to humans.  Determining this potential for causing injury to
     humans is the area of hazards analysis that takes the most effort on the  part of the local response
     community.  Gathering the information in a systematic manner cannot be done while responding to an
     incident.

2.    Consult summaries of previous  incidents available from  emergency management  and environmental
     response organizations at the local, state, regional, and federal levels.  For example, EPA Region VII
     and states in that region have comprehensive computerized records of all reported  incidents by county
     since 1977. Any jurisdiction can request these records.

3.    Local fire and police  department records may list incidents involving hazardous materials.

4.    The yellow pages of the  telephone book and the state industrial directory will list most local fixed
     facilities that manufacture, store, or use chemicals. EPA has recently prepared summaries for 14 types
     of facilities that show what types of hazardous chemicals may be encountered at the facilities.  Copies
     of the summaries may be obtained from EPA by calling the national RCRA/Superfund Industrial
     Assistance Hotline toll-free at (800) 424-9346.

Once the chemicals in a community have been identified as to name and quantity, there are several national
data bases that can evaluate the hazards and risks presented by those chemicals. You might consult any of
the following:

     A.  Poison Control Centers.  If the chemical is a consumer product, a regional Poison Control Center
         can quickly provide comprehensive hazard information.

     B.  Manufacturer's technical medical staff. If the chemical is an industrial bulk chemical, CHEMTREC
         (Chemicals in Transportation  Emergency Center) can provide quick assistance. Call (800) CMA-
         8200 for non-emergency situations, and (800) 424-9300 during emergencies.  You can also contact
         the technical medical staff of the company that manufacturers the chemical.
                                                19

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     C Agency for Toxic Substances and Disease Registry.  If the chemical is a mixture or a waste, if a
        second opinion is required, or if the chemical is unknown, a good source of information is the
        Agency for Toxic Substances and Disease Registry at the Centers for Disease Control.  It can be
        reached by dialing (404) 639-0615 day or night.

Remember that health assessment information is incomplete for many chemicals. Information from any of
the sources listed above may be qualified, and each local planning group should locate a competent medical
authority to work with them to obtain and interpret health effects data.

Material Safety Data Sheets (MSDSs)

Recent state and federal legislation regarding hazard communication, right-to-know, and mandatory local
notification for certain hazardous chemicals will assist local response groups in developing pre-emergency and
on-scene hazard assessments of chemicals in the community. This legislation makes the MSDS a primary
information source on chemical hazards.

Local response groups and planners are being provided with MSDSs by local industry as required by SARA
Title III  However MSDSs  will not be  useful  to local response groups  unless they are familiar with the
information presented on the MSDS and how that information will assist them in making a hazard assessment,
whether for pre-emergency planning or responding to an emergency.

The minimum content of an MSDS is mandated by OSHA. Each sheet must contain the following sections:

     1.  The chemical name, chemical formula, common synonyms, chemical family, and the manufacturer's
         name and  emergency telephone number;

     2.  Hazardous ingredients and regulatory exposure limits, if any;

     3.  Physical properties;

     4.  Fire and explosion  hazard data;

     5.  Health hazard data;

     6.  Reactivity data;

     7.  Spill or leak procedures;

      8. Special protection information; and

      9. Special precautions.

 Although there are several sources of generic MSDSs, including some where the information is computerized,
 response and/or planning personnel should obtain current MSDSs from  companies in their community to
 establish and maintain good working relationships with them.

 In reviewing the MSDS, note the different ways information is presented and the lack of uniform presentation.
 From the varying formats, you will gain some insights into the use of MSDSs and factors to be considered in
 interpreting them.  The depth of information furnished in  MSDSs depends on knowledge of the chemical and
 the management attitude of the company providing the information.
                                                20

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MSDS Section 1 - Materials Identification.  This section identifies the chemical by name, synonyms, and/or
family name The manufacturer's name and emergency telephone number should be used to obtain additional
data and assistance. Several preparers have chosen to emphasize the health hazards, precautionary measures,
and emergency contacts at the top of the sheets.

MSDS Section 2 • Ingredients and Hazards. This section describes all ingredients contained in the material or
chemical, and hazards associated with it. Absolute clarity in describing all ingredients  of a material and its
hazardous components is essential; however, experience indicates that clarity is not always achieved. When
discussing chlorine and its hazards, one MSDS preparer assumed  chlorine to be the pure chemical in the
gaseous form, whereas fire fighters are more likely to encounter chlorine as a solid (HTH - commonly used
in swimming pool chemical control)  or as commercial bleaches (a liquid that is fairly dilute).

If you review the ingredients and hazards of anhydrous ammonia and ammonia hydroxide, you will see that
anhydrous ammonia is a colorless gas with an extremely pungent odor and that ammonium hydroxide is a
clear, colorless  liquid.  Although their  forms are different and their ability to reach  human beings when
released is different, the hazard is the same. Ammonia is intensely corrosive to human tissue, whether it is
inhaled, contacts the skin, or is ingested. .OSHA regulates work place exposures of  ammonia at 50 ppm
(permissible exposure limit, PEL) while the American. Conference of Governmental  Industrial Hygiemsts
(ACGIH) recommends a level of 25 ppm (threshold limit value, TLV). Additionally, OSHA regulations state
that at  concentrations of 500 ppm in air, the material becomes immediately dangerous to life and health
 (IDLH).

The OSHA system is designed to provide safe working conditions for reasonably healthy adult humans for 8-
 hour exposures  for 40 hours per week for 40 years.  This approach is not directly applicable to general
 populations. Obviously, anyone with pre-existing respiratory ailments would be expected to  be more affected
 by irritants  and by those chemicals that  affect the central nervous system. The IDLH limits are likewise not
 applicable to children, especially those  in the first year of life, since their metabolism and nervous system
 responses are significantly different than those of adults or older children.
 The following information was found in MSDSs for the listed chemicals:

      Name                         Form           Exposure Limit (PEL)
      Ammonium hydroxide         Liquid
      Anhydrous ammonia          Gas
      Chlorine                     Gas
      Gasoline (unleaded)           Liquid
          petroleum distillate
          benzene
      Hydrochloric acid             Liquid
      Methyl alcohol                Liquid
      Nitric acid                   Liquid
      Polychlorinated biphenyls      Liquid
      Sodium hydroxide             Solid
      Sulfuric acid                  Liquid
      Toluene                     Liquid
 50 ppm
 50 ppm
  1 ppm (ceiling)
300 ppm (ACGIH)
500 ppm (OSHA)
 10 ppm
  5 ppm
200 ppm
  2 ppm
 0.5 mg/m3 (ACGIH)
  2 mg/m3
  1 mg/m3
200 ppm
     IDLH

  500 ppm
  500 ppm
   25 ppm
   100 ppm
25,000 ppm
   100 ppm

   200 mg/m3
    80 mg/m3
 2,000 ppm
  All of the OSHA limits are for airborne concentrations and vary widely among the substances listed.  It is
  important to note that the ratio of exposure limit to IDLH concentration also varies widely.  The greater the
  range between these two numbers, the greater the chance an exposed person will avoid permanent harm or
  death.
                                                 21

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It is important to know how these materials become airborne and the rate at which they do so.  For this
information, we will have to look elsewhere on the sheets.

MSDS Section 3 - Physical Data. When assessing hazards, the ability to evaluate the physical data combined
with the health hazard data is essential. The common physical properties provided on a typical MSDS include
boiling point, freezing point, specific gravity, vapor pressure, vapor density, solubility, and appearance. Other
parameters may be provided at the discretion of the company completing the sheets.

Let's  look briefly at characteristics of the 11 chemicals and discuss the implications of each for the first
responden

      a.  Boiling point - the temperature at which a liquid turns to a vapor.

         Chemical                                      Boiling Point

         Ammonium hydroxide                                36ฐC
         Anhydrous ammonia                                 -33ฐC
         Chlorine                                           -34ฐC
         Gasoline (unleaded)                           38ฐ - 204ฐC
         Hydrochloric acid (37%)                              53ฐC
         Hydrochloric acid (munatic) (35%)             65.6ฐ - 110ฐC
         Methyl alcohol                                    64.5ฐC
         Nitric acid (60-68%)                                 122ฐC (67%)
         Polychlorinated biphenyls                     360ฐ - 390ฐC
         Sodium hydroxide                                  1390ฐC
         Sodium hydroxide solution (50%)                    145ฐC
         Sulfuric acid                                       310ฐC
         Toluene                                     231ฐ - 232ฐC

         Since ambient temperatures range from around -20ฐC to 50ฐC (-10ฐF to 120ฐF), any chemical with
         a boiling point below the ambient temperature will  rapidly become a gas when released from its
         container.  Th. • is certainly the case for chlorine and anhydrous ammonia.  Other materials with
         boiling points  only slightly above normal ambient temperature will rapidly expand and pressurize
         containers and explode if heated only slightly.  Other materials, such as polychlorinated biphenyls
         (PCBs) and sodium hydroxide pellets, will be unaffected by the heat of normal structural fires, but
         could be affected by the application of water to that fire.  Sodium hydroxide pellets, for example, will
         dissolve in water to form a corrosive liquid.

      b.  Freezing point - temperature at which the liquid form of a chemical will turn into the solid form.

      a  Melting point - temperature at which the solid form of a chemical will  turn into the liquid form.

         The two physical parameters above may be of limited use to response personnel for most chemicals.
         There are several chemicals for which control measures such as freezing are effective and where dry
         ice, for example, may be used to mitigate a release.  Similarly, some chemicals undergo a form
         change when exposed to structural fire temperatures. This can significantly increase the hazard to
         response personnel.  Low-melting-point solids and most liquids exposed to fire temperatures may
         emit toxic materials in the smoke plume.
                                                22

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d. Specific gravity - density of a chemical compared to the density of water.  If the specific gravity is less
   than one, the chemical will float on water. If the specific gravity is greater than one, the chemical
   will sink. In either case, it is important for response personnel to consider the property of solubility
   concurrently with specific gravity.  Properties for the 11 chemicals are listed below:

   Chemical                   Exposure Limit     Specific Gravity      Solubility

   Ammonium hydroxide      50 ppm              0.9                  Infinite
   Anhydrous  ammonia       50 ppm              0.68                 Soluble
   Chlorine                   1 ppm              2.4                  0.7%
   Gasoline (unleaded)       300 ppm              0.7-0.8              Insoluble
   Hydrochloric acid           5 ppm              1.18                 Infinite
   Methyl alcohol            200 ppm              0.8                  Miscible
   Nitric acid                                     1.41                 Complete
   Polychlorinated biphenyls  0.5 mg/m3            1.5                  0.01 ppm
   Sodium hydroxide          2 mg/m3            2.13                 ill gm/100 gm
   Sulfuric acid                1 mg/m3            1.84                 Infinite
   Toluene                 200 ppm              0.86                 Q.05 gm/100 gm

   Toluene, gasoline, and methyl alcohol are all flammable or combustible liquids with similar TLV
   levels.  A glance at their solubilities shows, however, that mitigation techniques would have to be
   substantially different due to their solubility (i.e., methyl alcohol is completely miscible in water
   whereas the others  are  relatively insoluble).  Not only would fire fighting methods differ,  but
   additional attention would have to be paid  to  solubility when environmental damage is possible.
   Many chemicals  that are listed as only slightly soluble can still cause significant environmental
   toxicity  to-plants or aquatic life.  Toxicity of methyl alcohol is 250 ppm and toluene 1,180 ppm;
   therefore, each of them presents a serious environmental hazard if significant runoff is allowed to
   occur.

   Most MSDSs do not provide environmental  risk information; therefore, this data will have to be
   sought from other sources.  One excellent source for environmental risk information about many
   common chemicals is the EPA OHM-TADS (Oil & Hazardous Materials - Technical Assistance Data
   System). Access to this system can be gained by contacting any EPA Regional  Office.

e.  Vapor density - density of a gas compared to the density of air. If the vapor density is less than one,
   the material will  rise in still air and dissipate.  If the vapor density is greater than one,  the vapor will
   attempt to  sink in still air  and potentially collect in low spots and valleys.

f.  Vapor pressure -  pressure exerted by vapors against the sides of the container.  Vapor pressure is
    temperature dependent.  The lower the boiling point of the liquid, the greater the vapor pressure
    it will exert at a given temperature. In more common terms, the higher the vapor pressure, the more
    rapidly the material will change from liquid form to a vapor when released into the environment, and
    the higher the equilibrium concentration with air will be.
                                            23

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        Boiling point, vapor pressure, and vapor density as found in MSDSs for the compounds of interest
        are listed below:
        Chemical

        Ammonium hydroxide
        Anhydrous ammonia

        Chlorine
        Gasoline (unleaded)
        Hydrochloric acid (37%)
        Methyl alcohol
        Nitric acid (60-68%)
        Polychlorinated biphenyls
        Sodium hydroxide
        Sodium hydroxide
         solution (50%)
        Sulfuric acid (96%)
        Sulfuric acid (93.2%)
        Toluene
                                  Boiling Point      Vapor Pressure      Vapor Density
       36ฐC
      -33ฐC

      -34ฐC
  38 - 204ฐC
       53ฐC
     64.5ฐC
122ฐC (67%)
 360 - 390ฐC
     1390ฐC

      145ฐC
      310ฐC

 231 - 232ฐC
  15 mm Hg
     23 atm
4800 mm Hg
-SOOmmHg
        N/A
 190 mm Hg
  97mmHg
  62 mm Hg
  <1 mm Hg
   Negligible
@20ฐC
@20ฐC
@20ฐc
@20ฐC

@200C
@200C
@200C
@200C
  6.3 mm Hg @ 104ฐF
  22 mm Hg @ 145ฐC
<0.3 mm Hg @ 25ฐC
  22 mm Hg @ 20ฐC
1.2
0.6

2.49
N/A
1.27
1.1
2 to 3
N/A
               <0.3
               3.4
               3.14
        25ฐC
        The detail of the information furnished on an MSDS varies from rough estimates or general
        statements for some materials to multiple listings for others.  If you can picture the room in which
        a release occurs from its container, and then look  at the range of vapor pressures for the most
        commonly released substances, it will be apparent that both chlorine and anhydrous ammonia will
        present an almost instantaneous vapor (inhalation) hazard. Since both of these chemicals are soluble
        to some extent, a fog line may be helpful in volatilization suppression or in concentration reduction,
        even when the release is continuous.  However, when the intent is to reduce vapor production, the
        water from the hose lines should not enter pooled materials like ammonia or chlorine. For materials
        like sodium hydroxide and PCBs, a vapor hazard is not likely to exist under real-world conditions.

MSDS Section 4 - Fire and Explosion Data, Most of the MSDSs contain specific information for fire fighters
on the physical characteristics of the chemicals when involved in a fire. These characteristics, summarized
below, should be familiar to fire personnel.
         Chemical

         Ammonium hydroxide
         Anhydrous ammonia
         Chlorine
         Gasoline (unleaded)

         Hydrochloric acid
         Methyl alcohol
         Nitric acid
         PCBs
         Sodium hydroxide
         Sulfuric acid
         Toluene
                                       Flash
                                       Point
     1208ฐC
        N/A
       -45ฐF

        N/A
       52ฐF
       None
        N/A
       None
       None
       40ฐF
                   Autoignition
                   Temperature
       651ฐC
         N/A
  536 - 853ฐF

         N/A
       385ฐF
        None
         N/A
        None
        None
       480ฐF
                  Flammability   Extinguishing
                     Limits         Media
16

1.5


6-




1.3
-27%
N/A
-7.6%

N/A
36.5%
N/A
N/A
N/A
N/A
-7.1%
Shut off gas
N/A
Dry chemical
Water spray
N/A
Water spray
N/A
N/A
N/A
N/A
Dry chemical
                                               24

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In addition to these normal fire characteristics, the chemicals present other fire-related hazards, some of which
are reported in the fire and explosion section.  Examples of these are the following:

•    Chlorine and anhydrous ammonia are usually stored in pressure containers. The violent rupture of these
     containers represents a significant hazard.

•    Many of these chemicals generate toxic vapors or mists when involved in a fire.

•    Hydrochloric acid, nitric acid, sodium hydroxide, and sulfuric acid are such vigorous oxidizers or reducers
     that, although they are not flammable hazards themselves, they react  with many metals to produce
     extremely flammable hydrogen gas.

MSDS Section  5  - Health Hazard Information. This  section presents information on  routes of exposure
(inhalation, ingestion, dermal) and, in some cases, the severity of risk (low, moderate, high). This information
is essential for selecting appropriate personal protective equipment and safety procedures for response actions.
Some MSDSs highlighted the major hazards in section one, while others give a more detailed hazard listing
in this section. Some sheets list the NFPA 704 rating for the specific chemical. This should be encouraged,
as it provides emergency response  personnel  a basis for  quick judgments about the severity of personal
exposure. A brief hazard summary for each chemical is listed below:
         Chemical

         Ammonium hydroxide
         Anhydrous ammonia
         Chlorine

         Gasoline

         Hydrochloric acid
         Methyl alcohol
         Nitric acid
         PCBs •

         Sodium hydroxide
         Sulfuric acid

         Toluene
              Hazards

Corrosive -    severe eye and skin irritant
Corrosive -    severe eye and skin irritant
Corrosive -    life threatening toxic effects may occur at concentrations
              of 25 ppm on short exposures
Flammable -   irritant - CNS effects  - some evidence of carcinogenicity
              - also numerous chronic effects
Corrosive -    may be fatal if ingested
Flammable -   may be fatal if ingested
Corrosive -    strong oxidizer at higher concentrations
Very long-    lasting material - some evidence of liver damage -
              carcinogenic risk and adverse reproductive effects.
Corrosive -    may be fatal if swallowed causing severe burns
Corrosive -    causes severe burns  - may be fatal  if swallowed  -
              harmful  if inhaled
Flammable -   chronic skin irritant  - various systemic effects on  the
              central nervous system, liver, and kidneys
 These chemicals are corrosive to nearly every part of the human body.  The effects of chlorine and sulfuric
 acid are very similar. What makes chlorine a greater risk is its volatility when released. Sulfuric acid is already
 a liquid at ambient temperatures and volatilizes very slowly.

 MSDS Section 6 - Reactivity Data. Generally, four areas of information are presented in this section. All are
 potentially useful to those responding to a hazardous chemical emergency.

 a.   Stability.  Is the material stable at ambient temperatures and pressure, or at normal storage conditions?
      Most of the chemicals reviewed are stable and not liable to undergo spontaneous changes.
                                                 25

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b.   Polymerization.  Will the chemical change through polymerization at normal storage and temperature
     conditions?  For chemicals that spontaneously polymerize, this frequently leads to the heat generation
     and potential container failure.

c.   Decomposition. What new chemicals and what hazards will be created by the thermal decomposition of
     the chemical?  Important information is included in  this section for officials concerned about the
     exposures of response personnel and the general population if the chemical is exposed to fire.  For
     example, formaldehyde may be formed from fire involving methyl alcohol; oxides of nitrogen from
     anhydrous ammonia; and oxides of carbon from most of the other chemicals. This may increase the
     hazards from simple asphyxiation.

d.   Incompatible*.  What materials may cause violent reactions with the chemical?  Note especially the
     MSDS for gasoline.

Most chemicals will have a large number of potentially violent combinations. It is important to have some
idea of the likelihood of incompatibles contacting each other.  Many chemicals are potent acids or bases, and
will certainly be incompatible with chemicals of widely differing pH. For example, the sheet for sulfuric acid
lists water as being incompatible.  The mixing of sulfuric acid (96%) with water  (at pH of 7) releases enough
heat to cause a violent reaction.

MSDS Section 7 - Spill or Leak Procedures.  This section contains suggested steps for handling releases of the
chemical  in question.  The information provided is usually similar to the 1987 DOT Emergency Response
Guidebook. It is important to note the order in which the material is presented. If the material is extremely
flammable, but not particularly toxic, initial advice will usually be to control ignition sources. If the material
is extremely toxic, initial advice will generally be to evacuate or shelter in place.

MSDS Section 8 - Special Protection Information. For many MSDSs now in use, this section is not very specific.
Hopefully, improvements will be made that include specific respiratory  and  clothing information.  It is
important to know that no impervious clothing is suitable for every chemical. For example, polyethylene
protective clothing is not recommended for concentrated sulfuric acid, but is suitable for more dilute solutions.
                                                                                                 :r
Special problems may be created for first responders by  those materials that destroy normal fire fk
protective clothing.  These materials (e.g., chlorobenzene, methyl iodide),   •- which breakthrough time,  re
less than one tank of air, may not offer any useful protection to the respo  ier.  Once a hazards analy-.;s is
completed and response organizations are at the point where they are se,  !ing response equipment, / is
suggested that they obtain a copy of Guidelines for the Selection of Chemica  Protective Clothing, Cambri  j,
MA: A.D. Little Co., 1987, and check out the protective clothing recommendations for the chemicals in their
community.

MSDS Section 9 - Special Precautions.   Many MSDSs do not contain any information in this area.  For
extremely flammable materials, there is an additional warning about sparks and radiant heat.  For chlorine,
there is a warning about igniting other combustible materials on contact. For many other chemicals, standard
storage and handling procedures are repeated.

One important area that may be covered on some MSDSs is the chemical hazard to animal or aquatic life.
This information is  frequently based on controlled laboratory settings. The information from this testing is
presented in terminology different than the  regulatory TLV and PEL  information, and it  will take  an
additional effort on the responded part to eval  ate.
                                                 26

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These tests evaluate the substance's physical/chemical properties, determine routes of entry into the organisms
being tested, and document exposure variables. The tests also evaluate the biological fate of the chemicals
and develop a dose/response curve for the specific effects being evaluated. A hypothetical dose/response curve
is shown in Figure 1.  The most common expression of these test results is the dose or concentration at which
50% are affected, known as the TD50.  Toxicologists exhibit their skills by the accuracy with which they can
extrapolate animal  data to predict effects on man.  In general, TD50 data are commonly given for pesticides
and other chemicals developed for pest and weed control.   An  example of  interpreting these data for
responders is shown below:

                               RELATIVE INDEX OF TOXICOLOGY
         Toxicitv Rating

         Practically non-toxic
         Slightly toxic
         Moderately toxic
         Very toxic
         Extremely toxic
         Super toxic
     Probable Oral
        Dose

     >15g/kg
   5 - 150 g/kg
   0.5 - 5 g/kg
50 - 500 mg/kg
  5 - 50 mg/kg
     <5 mg/kg
Lethal Dose for Humans
   (Average Adult)

More than a quart
Between pint and quart
Between ounce and quart
Between teaspoonful and ounce
7 drops to teaspoonful
A taste (less than 7 drops)
Dose/response curves deal with acute exposures, but it is important to consider also the potential for repetitive
exposures at lower doses, which may accumulate in the body.  This situation is called chronic exposure and
is diagramed in Figure A-l.
                                           FIGURE A-l

                                 Hypothetical Dose-Response Curve
                                    of Two Chemicals, A and B
                               0.1         1         10

                                     Dose - Arbitrary Units
                                   100
                                               27

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                                      APPENDIX B
                                  MEDICAL PROGRAM
                                      CONTENTS


INTRODUCTION  	30

DEVELOPING A PROGRAM  	30

PRE-EMPLOYMENT SCREENING	42

 Determination of Fitness for Duty  	42
 Baseline Data for Future Exposures	 43
 Sample Pre-Employment Examination  	44

PERIODIC MEDICAL EXAMINATION	45

 Periodic Screening  	45
 Sample Periodic Medical Examination  	46

TERMINATION EXAMINATION  	46

EMERGENCY TREATMENT		47

NON-EMERGENCY TREATMENT  	49

MEDICAL RECORDS   	49

PROGRAM REVIEW 	50

REFERENCES  	51
NOTES:  For additional guidance, see U.S. EPA Environmental Response Team's Occupational Medical
Monitoring Program Guidelines for SARA Hazardous Waste Field Activity Personnel, January 1990, EPA OS WER
Directive: 9285.3-04.

This appendix is reproduced from Chapter 5 of the Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities. See Appendix E, Selected References, for information about this document.
                                          29

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INTRODUCTION

Workers handling hazardous wastes can experience high levels of stress.  Their daily tasks may expose them
to toxic chemicals, safety hazards, biologic hazards, and radiation. They may develop heat stress while wearing
orotective equipment or working under temperature extremes, or face life-threatening emergencies such as
explosions and fires. Therefore, a medical program is  essential to assess and monitor workers' health and
fitness both prior to employment or treatment; and to keep accurate records for future reference. 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 1910.1045). Information from a site medical program may also
be used to conduct future epidemiological studies; to adjudicate claims; to provide evidence in  litigation; and
to report workers' medical conditions to federal, state,  and local agencies, as required by law.

This chapter presents general guidelines for designing a medical program for personnel at hazardous waste
sites   It includes information and sample protocols for pre-employment screening  and periodic medical
examinations, guidelines for emergency and non-emergency treatment, and recommendations for program
recordkeeping and  review.   In addition, it supplies a  table of some common chemical toxicants found at
hazardous waste sites with recommended  medical monitoring procedures.

The recommendations in this chapter assume that workers will have adequate protection from exposures
through administrative and engineering controls,  and appropriate personal  protective  equipment  and
decontamination procedures, as described elsewhere in this manual. Medical surveillance should be used to
complement other controls.

DEVELOPING  A PROGRAM

A medical program should be developed for each site based on the specific needs, location, and potential
exposures of employees at the site. The program should be designed by an experienced occupational  health
physician or other qualified occupational health consultant in conjunction with the Site Safety Officer. The
director of a site medical program should be a physician who is board-certified in  occupational medicine or
 a medical doctor who has had extensive experience managing occupational health services. A director  and/or
 examining physician with such qualifications may be difficult to find, due to the shortage of doctors trained
 in occupational medicine in remote geographic areas where many hazardous waste sites are  located.  If an
 occupational health physician is not available, the site medical  program  may be managed, and relevant
 examinations performed, by a local physician with assistance from an occupational medicine consultant. These
 functions may also be performed by a qualified Registered Nurse, preferably an Occupational Health  Nurse,
 under the direction of a suitably qualified physician who has responsibility for the program.

 All medical  test analyses should be performed by a laboratory that has demonstrated satisfactory performance
 in an established interlaboratory testing program [Ij. The clinical or diagnostic laboratory to which samples
 are sent should meet either (1) minimum requirements under the Clinical Laboratories Improvement Act of
 1967 (42 CFR Part 74 Subpart M Section 263(a)), or (2) the conditions for coverage under Medicare.  These
 programs are administered by the Health Care Financing Administration (HCFA), U.S. Department of Health
 and  Human Services (DHHS).
     1  Certified, state-licensed (where required) Physician's Assistants may also perform these examinations
  if a physician is available on the premises.
                                                 30

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A site medical program should provide the following components:

•   Surveillance:
        Pre-employment screening.
        Periodic medical examinations (and follow-up examinations when appropriate).
        Termination examination.
•   Treatment:
        Emergency.
        Non-emergency (on a case-by-case basis).
•   Recordkeeping.
•   Program review.

Table B-l outlines a.recommended medical program; screening and examination protocols are described in
the following sections. These recommendations are based on known health risks for hazardous waste workers,
a review of available data on their exposures, and an assessment of several established medical programs.
Because conditions and hazards vary considerably at each site, only general guidelines are  given.

Table B-l. Recommended Medical Program
COMPONENT
     RECOMMENDED
                                                                     OPTIONAL
Pre-Employment
Screening
• Medical history.
• Occupational history.
• Physical examination.
• Determination of fitness
  to work wearing protective
  equipment.
• Baseline monitoring for
  specific exposure.
Freezing pre-employment serum specimen for
later testing (limited to specific situations, see
Baseline Data for Future Exposures in this chapter).
Periodic Medical
Examinations
   Yearly update of medical
   and occupational history;
   yearly physical examination;
   testing based on
   (1) examination results,
   (2) exposures, and (3) job
   class and task.
   More frequent testing based
   on specific exposures.
Yearly testing with routine medical tests.
 Emergency
 Treatment
   Provide emergency first aid
   on site.
   Develop liaison with local
   hospital and medical
   specialists.
   Arrange for decontamination
   of victims.
                                                31

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Table B-L  Recommended Medical Program (continued)
COMPONENT
  RECOMMENDED
                                                                    OPTIONAL
                      Arrange in advance for
                      transport of victims.
                      Transfer medical records;
                      give details  of incident and
                      medical history to next
                      care provider.
Non-Emergency
Treatment
Develop mechanism for non-
emergency health care.
Recordkeeping      •  Maintain and provide access
and Review           to medical records in
                      accordance with OSHA and
                      state regulations.
                    •  Report and record occupational
                      injuries and illnesses.
                    •  Review Site Safety Plan regularly
                      to determine if additional testing
                      is needed.
                    •  Review program periodically.  Focus
                      on current site hazards, exposures,
                      and industrial hygiene standards.
 The medical program's effectiveness depends on active worker involvement. In addition, management should
 have a firm commitment to worker health and safety, and is encouraged to express this commitment not only
 by medical surveillance and treatment, but also through management directives and informal encouragement
 of employees to maintain good health through exercise, proper diet, and avoidance of tobacco, alcohol abuse,
 and drug abuse.  In particular, management should:

 •   Urge prospective employees to provide a complete and detailed occupational and medical history.

 •   Assure employees of confidentiality.

 •   Require workers to report any suspected exposures regardless of degree.

 •   Require workers to bring any unusual physical or psychological conditions to the physician's attention.
     Employee training should emphasize that vague disturbances or apparently minor complaints (such as skin
     irritation or headache) may be important.

 When developing an individual program, site conditions must be considered and the monitoring needs of each
 worker should be determined based on the worker's medical and occupational history, as well as current and
 potential exposures on site. The routine job tasks of each worker should be considered. For instance, a heavy
                                                 32

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equipment operator exposed to significant noise levels would require a different monitoring protocol from a
field sample collector with minimal noise exposure. Likewise, an administrator may only need a pre-employment
screening for ability to wear personal protective equipment - if this is an occasional requirement - rather than
a more comprehensive program.

The potential exposures that may occur at a site must also be considered. While it is often impossible to identify
every toxic substance that exists at each hazardous waste site, certain types of hazardous substances or chemicals
are more likely to be present than others. Some of these are:

•   Aromatic hydrocarbons.

•   Asbestos (or asbestiform particles).

•   Dioxin.

•   Halogenated aliphatic hydrocarbons.

•   Heavy metals.

•   Herbicides.

•   Organochlorine insecticides.

•   Organophosphate and carbamate insecticides.

 •   Polychlorinated biphenyls (PCBs).

Table B-2 lists these groups, with representative compounds, uses, health effects, and available medical monitoring
procedures.

 In compiling a testing protocol, bear in mind that standard occupational medical tests were developed in factories
and other enclosed industrial environments, and were based on the presence of specific identifiable toxic chemicals
and the possibility of a significant degree of exposure. Some of these tests may not be totally appropriate for
 hazardous waste sites, since available data suggest that site workers have low-level exposures to many chemicals
 [2]. In addition, most testing recommendations, even those for specific toxic substances, have not been critically
 evaluated for efficacy.

 Another important factor to consider is that risk can vary,  not only with the type, amount, and duration of
 exposure, but also with individual  factors such as age, sex, weight, stress, diet, susceptibility to allergic-type
 reactions, medications taken, and off-site exposures (e.g., in hobbies such as furniture refinishing and automotive
 body work).
                                                  33

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Table B<2.
Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
Aromatic
Hydrocarbons




COMPOUNDS
Benzene
Ethyl benzene
Toluene
Xylene




USES
Commercial solvents
and intermediates for
synthesis in the
chemical and
pharmaceutical
industries.



TARGET ORGANS
Blood
Bone marrow
CNSa
Eyes
Respiratory system
Skin
Liver
Kidney

POTENTIAL
HEALTH EFFECTS
All cause:
CNSa depression:
decreased alertness,
headache, sleepiness,
loss of
consciousness.
Defatting dermatitis.

MEDICAL
MONITORING
Occupational/general
medical history
emphasizing prior
exposure to these or
other toxic agents.

Medical examination
with focus on liver,
                                                                                           Benzene suppresses
                                                                                           bone-marrow
                                                                                           function, causing
                                                                                           blood changes.
                                                                                           Chronic exposure can
                                                                                           cause leukemia.

                                                                                           Note: Because other
                                                                                           aromatic
                                                                                           hydrocarbons may be
                                                                                           contaminated with
                                                                                           benzene during
                                                                                           distillation, benzene-
                                                                                           related health effects
                                                                                           should be considered
                                                                                           when exposure to any
                                                                                           of these agents is  .
                                                                                           suspected.
                                                                                                       kidney, nervous
                                                                                                       system, and skin.

                                                                                                       Laboratory testing:

                                                                                                        CBCb
                                                                                                        Platelet count

                                                                                                       Measurement of
                                                                                                       kidney and liver
                                                                                                       function.

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Table B-2.  Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring (continued)
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP COMPOUNDS USES
POTENTIAL
TARGET ORGANS HEALTH EFFECTS
MEDICAL
MONITORING
Asbestos (or
asbestiform particles)
A variety of industrial
uses, including:

 Building
 Construction
 Cement work
 Insulation
 Fireproofmg
 Pipes and ducts for
 water, air, and
 chemicals
 Automobile brake
 pads and linings
Lungs

Gastrointestinal
system
Chronic effects:

 Lung cancer
 Mesothelioma
 Asbestosis
 Gastrointestinal
 malignancies

Asbestos exposure
coupled with cigarette
smoking has been
shown to have a
synergistic effect in
the development of
lung cancer.
History and physical
examination should
focus on the lungs
and gastrointestinal
system.

Laboratory tests
should include a stool
test for occult blood
evaluation as a check
for possible hidden
gastrointestinal
malignancy.

A high quality chest
X-ray and pulmonary
function test may
help to identify long-
term changes
associated with
asbestos diseases;
however, early
identification of low-
dose exposure is
unlikely.
 Dioxin (see
 Herbicides)

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 Table B-2.  Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring (continued)
 HAZARDOUS
 SUBSTANCE
 OR CHEMICAL
 GROUP

 Halogenated
Aliphatic
Hydrocarbons
 COMPOUNDS
"•""•"—M'^—ป•••—*•ซ•.

 Carbon tetrachloride
 Chloroform
 Ethyl bromide
 Ethyl chloride
 Ethylene dibromide
 Etnylene dichloride
 Methyl chloride
 Methyl chloroform
 Methylene chloride
Tetrachloroethane
Tetrachloroethylene
(perchloroethylene)
Trichloroethylene
Vinyl chloride
 USES
———^—^—

 Commercial solvents
 and intermediates in
 organic synthesis.
TARGET ORGANS

CNSa
Kidney
Liver
Skin
 POTENTIAL
 HEALTH EFFECTS

 All cause:

  CNSa depression;
  decreased alertness,
  headaches,
  sleepiness, loss of
  consciousness.

  Kidney changes:
  decreased urine
  flow, swelling
  (especially around
  eyes), anemia.

 Liver changes:
 fatigue, malaise,
 dark urine, liver
 enlargement,
 jaundice.

Vinyl chloride is a
known carcinogen;
several others in this
group are potential
carcinogens.
 MEDICAL
 MONITORING

 Occupational/general
 medical history
 emphasizing prior
 exposure to these or
 other toxic agents.

 Medical examination
 with focus on liver,
 kidney, nervous
 system, and skin.

 Laboratory testing for
 liver and kidney
 function;
carboxyhemoglobin
where relevant.

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Table B-2. Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring (continued)
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
Heavy Metals










w
~J





COMPOUNDS
Arsenic
Beryllium
Cadmium
Chromium
Lead
Mercury












USES TARGET ORGANS
Wide variety of Multiple organs and
industrial and systems including:
commercial uses.
Blood
Cardiopulmonary
Gastrointestinal
Kidney
Liver
Lung
CNSa
Skin







POTENTIAL
HEALTH EFFECTS
All are toxic to the
kidneys.

Each heavy metal has
its own characteristic
symptom cluster. For
example, lead causes
decreased mental
ability, weakness
(especially hands),
headache, abdominal
cramps, diarrhea, and
anemia. Lead can
also affect the blood-
forming mechanism,
kidneys, and the
peripheral nervous
system.
MEDICAL
MONITORING
History-taking and
physical exam; search
for symptom clusters
associated with
specific metal
exposure, e.g., for
lead look for
neurological deficit,
anemia, and
gastrointestinal
symptoms.

Laboratory testing:

Measurements of
metallic content in
blood, urine, and
tissues (e.g., blood
                                                                                        Long-term effects0
                                                                                        also vary. Lead
                                                                                        toxicity can cause
                                                                                        permanent kidney
                                                                                        and brain damage;
                                                                                        cadmium can cause
                                                                                        kidney or lung
                                                                                        disease.  Chromium,
                                                                                        beryllium, arsenic,
                                                                                        and cadmium have
lead level; urine
screen for arsenic,
mercury, chromium,
and cadmium).

CBCb

Measurement of
kidney function, and
liver function where
relevant.

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Table 8^2. Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring (continued)
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
  (j)
  00
COMPOUNDS
USES
TARGET ORGANS
POTENTIAL
HEALTH EFFECTS
MEDICAL
MONITORING

Herbicides Chlorophenoxy Vegetation control.
compounds:
2,4-dichloro-
phenoxyacetic acid
(2,4-D)
•
Kidney
Liver
CNSa
Skin
been implicated as
human carcinogens.
Chlorophenoxy
compounds can cause
chloracne, weakness
or numbness of the
arms and legs, and
may result in long-
term nerve damage.
Chest X-ray or
pulmonary function
testing where
relevant.
History and physical
exam should focus on
the skin and nervous
system.
Laboratory tests
include:
 2,4,5-trichloro-
 phenoxyacetic acid
 (2,4,5-T)

Dioxin (tetrachloro-
dibenzo-p-dioxin,
TCDD), which occurs
as a trace
contaminant in these
compounds, poses the
most serious health
risk.
                                                                                  Dioxin causes
                                                                                  chloracne and may
                                                                                  aggravate pre-existing
                                                                                  liver and kidney
                                                                                  diseases.
                                                              Measurement of
                                                              liver and kidney
                                                              function, where
                                                              relevant.

                                                              Urinalysis.

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Table B-2. Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring (continued)
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
Organochlorine
Insecticides









u>
VO








COMPOUNDS USES
Chlorinated ethanes: Pest control.
DDT

Cyclodienes:

Aldrin
Chlordane
Dieldrin
Endrin

Chlorocyclohexanes:
Lindane







POTENTIAL
TARGET ORGANS HEALTH EFFECTS
Kidney All cause acute
Liver symptoms of
CNSa apprehension,
irritability, dizziness,
disturbed equilibrium,
tremor, and
convulsions.

Cyclodienes may
cause convulsions
without any other
initial symptoms.
Chlorocyclohexanes
can cause anemia.
Cyclodienes and
Chlorocyclohexanes
cause liver toxicity
and can cause
permanent kidney
damage.
MEDICAL
MONITORING
History and physical
exam should focus on
the nervous system.

Laboratory tests
include:

Measurement of
kidney and liver
function.

CBCb for exposure
to
Chlorocyclohexanes.








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Table ff-2. Common

•™" •  '      I.  I,..—
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
~~"™ซ—"-^——™

Organophosphate
and Carbaraate
Insecticides
Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring (continued)
   COMPOUNDS

   Organophosphate:

   Diazinon
   Dichlorovos
   Dimethoate
   Trichlorfon
   Malathion
   Methyl parathion
   Parathion

  Carbaraate:

   Aldicarb
   Baygon
   Zectran
USES

Pest control.
                      POTENTIAL          MEDICAL
TARGET ORGANS    HEALTH EFFECTS    MONITORING
CNSa
Liver
Kidney
                                           All cause a chain of
                                           internal reactions
                                           leading to neuro-
                                           muscular blockage.
                                           Depending on the
                                           extent of poisoning,
                                           acute symptoms range
                                           from headaches,
                                           fatigue, dizziness,
                                           increased salivation
                                           and crying, profuse
                                           sweating, nausea,
                                           vomiting, cramps, and
                                           diarrhea to tightness
                                           in the chest, muscle
                                           twitching, and
                                          slowing of the
                                          heartbeat. Severe
                                          cases may result in
                                          rapid onset of
                                          unconsciousness and
                                          seizures. A delayed
                                          effect may be
                                          weakness and
                                          numbness in the feet
                                          and hands.  Long-
                                          term, permanent
                                          nerve damage is
                                          possible.
 Physical exam should
 focus on the nervous
 system.

 Laboratory tests
should include:

 RBC" cholinesterase
 levels for recent
 exposure (plasma
 cholinesterase for
 acute exposures).

 Measurement of
 delayed
 neurotoxicity and
 other effects.

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Table B-2.  Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring (continued)
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
COMPOUNDS
USES
TARGET ORGANS
POTENTIAL
HEALTH EFFECTS
MEDICAL
MONITORING
Polychlorinated
Biphenyls (PCBs)
                     Wide variety of
                     industrial uses.
                     Liver
                     CNS1 (speculative)
                     Respiratory system
                     (speculative)
                     Skin
                     Various skin
                     ailments, including
                     chloracne; may cause
                     liver toxicity;
                     carcinogenic to
                     animals.
                     Physical exam should
                     focus on the skin and
                     liver.

                     Laboratory tests
                     include:
                                                                                                          Serum PCB levels.

                                                                                                          Triglycerides and
                                                                                                          cholesterol.
                                                                                                          Measurement of
                                                                                                          liver function.
aCNS = Central nervous system.
bCBC = Complete blood count
C]
 Long-term effects generally manifest in 10 to 30 years.
dRBC = Red blood count

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PRE-EMPLOYMENT SCREENING

Pre-employment screening has two major functions: (1) determining an individual's fitness for duty, including
the ability to work while wearing protective equipment, and (2) providing baseline data to compare with medical
data.  These functions are discussed below.  In addition, a sample pre-employment examination is described.

Determination of Fitness for Duty

Workers at hazardous waste sites are often required to perform strenuous tasks (e.g., moving 55-gallon drums)
while wearing personal protective equipment, such as respirators and protective clothing, that may cause heat
stress and other problems. To ensure that prospective employees are able to meet work requirements, the pre-
employment screening should focus on the following areas:

Occupational and Medical  History

* ' Makesure theworker fills out an occupational and medical history questionnaire.  Review the questionnaire
    before seeing the worker. In the examining room, discuss the questionnaire with the worker, paying special
    attention to prior occupational exposures to chemical and physical hazards.

 .  Review past illnesses and chronic diseases, particularly atopic diseases such as  eczema and asthma, lung
    diseases, and cardiovascular disease.

 .  Review symptoms, especially shortness of breath or labored breathing on exertion, other chronic respiratory
    symptoms, chest pain,  high blood pressure, and heat intolerance.

 .  Identify individuals who are vulnerable to particular substances (e.g., someone with a history of severe
    asthmatic reaction to a specific chemical).

 •  Record relevant lifestyle habits (e.g., cigarette smoking, alcohol, and drug use) and hobbies.

 Physical Examination

  .   Conduct a comprehensive physical examination of all body organs, focusing on the pulmonary, cardiovascular,
     and musculoskeletal systems.

  .   Note conditions that could increase susceptibility to heat stroke, such as obesity and lack of physical exercise.

  •   Note conditions that could affect respirator use, such as missing or arthritic fingers, facial scars, dentures,
     poor eyesight, or perforated ear drums.

  Ability to Work While Wearing Protective Equipment [31

  .  Disqualify individuals who are clearly unable to perform based on the medical history and physical exam
      (e.g., those with severe lung disease, heart disease, or back or orthopedic problems).

  •   Note limitations concerning the worker's ability to use protective  equipment (e.g., individuals who must
     wear contact lenses cannot wear full facepiece respirators).

  •   Provide additional testing (e.g., chest X-ray, pulmonary function testing, electrocardiogram) for ability to
      wear protective equipment where necessary.
                                                   42

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•   Base the determination on the individual worker's profile (e.g., medical history and physical exams, age,
    previous exposures and testing).

•   Make a written assessment of the worker's capacity to perform while wearing a respirator, if wearing a
    respirator is a job requirement.  Note that the Occupational Safety and Health Administration (OSHA)
    respirator standard (29 CFR Part 1910.134) states that no employee should be assigned to a task that requires
    the use of a respirator unless it has been determined that the person is physically able to perform under
    such conditions.

Baseline Data for Future Exposures

Pre-employment screening can be used to establish baseline data to subsequently verify the efficacy of protective
measures and to later determine if exposures have adversely affected the worker. Baseline testing may include
both medical screening tests and biologic monitoring tests. The latter (e.g., blood lead level) may be useful
for ascertaining pre-exposure levels of specific substances to which the worker may be exposed and for which
reliable tests are available. Given the problem in predicting significant exposures for these workers, there are
not clear guidelines for prescribing specific tests. The following approach identifies the types of tests that may
be indicated:

•   A battery of tests based on the worker's past occupational and medical history and an assessment of significant
    potential exposures. Table B-3 presents examples of tests frequently performed by occupational physicians.

Table B-3. Tests Frequently Performed by Occupational Physicians
FUNCTION
   TEST
                    EXAMPLE
Liver:
 General

 Obstruction
 Cell injury
Kidney:
 General
Blood tests         Total protein, albumin, globulin, total bilirubin (direct bilirubin
                   if total is elevated).
Enzyme test        Alkaline phosphatase.
Enzyme tests       Gamma glutamyl transpeptidase (GGTP), lactic dehydrogenase
                   (LDH), serum glutamicoxaloacetic transaminase (SGOT), serum
                   glutamic-pyruvic transaminase (SGPT).
Blood tests
Blood urea nitrogen (BUN), creatinine, uric acid.
Multiple Systems
 and Organs
Urinalysis
Including  color; appearance; specific gravity;  pH; qualitative
glucose, protein, bile, and acetone; occult blood; microscopic
examination of centrifuged sediment.
Blood-Forming
 Function
Blood tests         Complete blood count (CBC) with differential  and platelet
                   evaluation, including white cell count (WBC), red blood count
                   (RBC), hemoglobin (HGB), hematocrit or packed cell volume
                   (HCT), and desired erythrocyte indices.  Reticulocyte count may
                   be appropriate if there is a likelihood of exposure to hemolytic
                   chemicals.
                                                 43

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•   Stu Jard established testing for specific toxicants in situations where workers may receive significant exposures
    to these agents. For example, long-term exposure during cleanup of a polychlorinated biphenyls (PCB)
    waste facility can be monitored with pre-employment and periodic serum PCB testing [4].   Standard
    procedures are available  for determining levels of other  substances, e.g., lead, cadmium, arsenic, and
    organophosphate pesticides.

•   Where applicable, pre-employment blood specimens and serum frozen for later testing. (PCBs and some
    pesticides are examples of agents amenable to such monitoring.)

Sample Pre-Employment Examination

Occupational and Medical History

•   Do a complete medical history emphasizing these systems: nervous, skin, lung, blood-forming, cardiovascular,
    gastrointestinal, genitourinary, reproductive, ear, nose, and throat.

Physical Examination

Include at least the following:

•   Height, weight, temperature, pulse, respiration, and blood pressure.

•   Head, nose, and throat.

•   Eyes. Include vision tests that measure refraction, depth perception, and color vision.  These tests should
    be administrated by a qualified technician or physician. Vision quality is essential to safety, the accurate
    reading of instruments and labels, the avoidance of physical hazards, and for appropriate response to color-
    coded labels and signals.

ซ   Ears. Include audiometric tests, performed at 500, 1,000, 2,000, 3.000,  4,000, and 6,000 hertz (Hz) pure
    tone in an  approved booth (see requirements listed in 29 CFR P:>"  1910.95, Appendix D).  Tests should
    be administrated by a qualified technician, and results read by a cer   ed audiologist or a physician familiar
    with audiometric evaluation. The integrity <• the eardrum should b;. ,-stablished since perforated eardrums
    can provide a route of entry for chemicals imu ihe body. The physician evaluating employees with perforated
    eardrums should consider the environmental conditions of the job and discuss possible specific safety controls
    with the Site Safety Officer, industrial hygienist, and/or other health professionals before deciding whether
    such individuals can safely work on site.

 •   Chest (heart and lungs).

 •   Peripheral vascular system.

 •  Abdomen  and rectum  (include hernia exam).

 •  Spine and other components of the muscutoskeletal system.

 •  Genitourinary system.

 *  Skin.

 •  Nervous system.
                                                 44

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Tests

•   Blood.

•   Urine.

•   A 14 x 17-inch posterior/anterior view chest X-ray with lateral or oblique views only if indicated or if
    mandated by state regulations. The X-ray should be taken by a certified radiology technician and interpreted
    by a board-certified or board-eligible radiologist.  Chest X-rays taken in the last 12-month period, as well
    as the oldest chest X-ray available, should be obtained and used for comparison.  Chest X-rays should not
    be repeated more than once a year, unless otherwise determined by the examining physician.

Ability to Perform While Wearing Protective Equipment

To determine a worker's capacity to perform while wearing protective equipment, additional tests may be necessary.
For example:

•   Pulmonary function testing. Measurement should include forced expiratory volume in 1 second (FEV),
    forced vital capacity (FVC), and FEV - to - FVC ratio, with interpretation and comparison to normal
    predicted values corrected for age, height, race, and sex. Other factors such as FEF, MEFR, MW, FRC,
    RV, and TLC2 may be included for additional information.  A permanent record of flow curves should
    be conducted by  a certified technician and the results should be interpreted by a physician.

•   Electrocardiogram (EKG). At least one standard, 12-lead resting EKG should be performed at the discretion
    of the physician.  A "stress test" (graded exercise) may be administered at the discretion of the examining
    physician, particularly where heat stress may occur.

Baseline Monitoring

If there is likelihood  of potential onsite exposure to a particular toxicant, specific baseline monitoring should
be performed to establish data relating to that toxicant.

PERIODIC MEDICAL EXAMINATIONS

Periodic Screening

Periodic medical examinations should be developed and used in conjunction with pre-employment screening
examinations. Comparing sequential medical reports with baseline data is essential to determine biologic trends
that may mark early  signs of adverse health effects, and thereby indicate appropriate protective measures.

The frequency and content of examinations will vary, depending on the nature of the work and exposures.
Generally, medical examinations have been recommended at least yearly.  More frequent examinations may
be necessary, depending on the extent of potential or actual exposure, the type of chemicals involved, the duration
of the work assignment, and the individual worker's profile. For example, workers participating in the cleanup
of a PCB-contaminated  building were initially examined monthly for serum PCB levels.
    2 FEF = forced expiratory flow, MEFR = maximal expiratory flow rate; MW = maximal voluntary
 ventilation; FRC = functional residual capacity, RV = residual volume; TLC = total lung capacity.

                                                45

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Reviewing data from the first few months revealed no appreciable evidence of PCS exposure. The frequency
of PCB testing was then reduced [4]. Periodic screening exams can include:

•   Interval medical history, focusing on changes in health status, illnesses, and possible work-related symptoms.
    The examining physician should have information about the worker's interval exposure history, including
    exposure monitoring at the job site, supplemented by worker reported exposure history and general
    information on possible exposures at other sites.

*   Physical examination.

•   Additional medical testing, depending on available exposure information, medical history, and examination
    results. Testing should be specific for the possible medical effects of the worker's exposure. Multiple testing
    for a large range of potential exposures is not always useful; it may involve invasive procedures (e.g., tissue
    biopsy), be expensive, and may produce false-positive results.

    Pulmonary function tests should be administered if the individual uses a respirator, has been or may be exposed
    to irritating or toxic substances, or if the individual has breathing difficulties, especially when wearing a
    respirator.

    Audiometric tests. Annual retests are required for personnel subject to high noise exposures (an 8-hour,
    time-weighted average of 85 dBA3 or more), those required to wear hearing protection, or as otherwise
    indicated.

    Vision tests. Annual retests are recommended to check for vision degradation.

    Blood and urine tests when indicated.

Sample Periodic Medical Examination

The basic periodic medical examination is the same as the pre-employment screening (see previous section,
Sample Pre-Employment Examination), modified according to current conditions, such as changes in the worker's
symptoms, site hazards, or exposures.

TERMINATION EXAMINATION

After finishing work at a hazardous waste site, all personnel should have a medical examination as described
in the previous sections (see Sample Pre-Employment Examination). This examination may be limited to obtaining
an interval medical history of the period since the last full examination (consisting of medical history, physical
examination, and laboratory tests) if all three following conditions are met:

 •  The last full medical examination was within the last 6 months.

 •  No exposure occurred since the last examination.

 •  No symptoms associated with exposure occurred since the last examination.

 If any of these criteria are not met, a full examination is medically necessary at the termination of employment.
     3 dBA ป decibels on A-weighted scale (29 CFR Part 1910.95).

                                                 46

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EMERGENCY TREATMENT

Provisions for emergency treatment and acute non-emergency treatment should be made at each site. Preplanning
is vital.

When developing plans, procedures, and equipment lists, the range of actual and potential hazards specific to
the site should be considered, including chemical,  physical (such as heat and/or cold stress, falls, and trips),
and biologic hazards (animal bites and plant poisoning as well as hazardous biological wastes).  Not only site
workers, but also contractors, visitors, and other personnel (particularly firefighters) may require emergency
treatment.

Emergency medical treatment should be integrated with the overall site emergency response program (see Chapter
12).  The following are recommended guidelines for establishing an emergency treatment program.

•   Train a team of site personnel in emergency first aid. This should include a Red Cross or equivalent certified
    course in cardiopulmonary resuscitation (CPR), and first-aid training that emphasizes treatment for explosion
    and burn injuries, heat stress, and acute chemical toxicity. In addition, this team should include an emergency
    medical technician (EMT) if possible. Table B-4 lists signs and symptoms of exposure and heat stress that
    indicate potential medical emergencies.

•   Train personnel in emergency decontamination procedures in coordination with the Emergency Response
    Plan.

•   Predesignate roles and responsibilities to be assumed by personnel in an emergency.

•   Establish an emergency/first-aid station on site, capable of providing (1) stabilization for patients requiring
    off-site treatment, and (2) general first aid (e.g., minor cuts, sprains, abrasions).

        Locate the station in the clean area adjacent to the decontamination area to facilitate emergency
        decontamination.

        Provide a standard first-aid kit or equivalent supplies, plus additional items such as emergency/deluge
        showers, stretchers, portable water, ice, emergency eyewash, decontamination solutions, and  fire-
        extinguishing blankets.

        Restock supplies and equipment immediately after each use and check them regularly.

•   Arrange for a physician who can be paged on a 24-hour basis.

•   Set up an on-call team of medical specialists for emergency consultations, e.g., a lexicologist, dermatologist,
    hematologist, allergist, ophthalmologist, cardiologist, and neurologist

•   Establish a protocol for monitoring heat stress.

•   Make plans in advance for emergency transportation to a nearby medical facility, develop contamination
    control procedures for that facility.

        Educate local emergency transport and hospital personnel about possible medical problems on  site;
        types of hazards and their consequences; potential for exposure; and the scope and function of site
        medical program.
                                                 47

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Table B-4.  Signs and Symptoms of Chemical Exposure and Heat Stress that  Indicate Potential Medical
Emergencies
TYPE OF HAZARD
SIGNS AND SYMPTOMS
Chemical Hazard
Behavioral changes
Breathing difficulties
Changes in complexion or skin color
Coordination difficulties
Coughing
Dizziness
Drooling
Diarrhea
Fatigue and/or weakness
Irritability
Irritation of eyes, nose, respiratory tract, skin, or throat
Headache
Light-headedness
Nausea
Sneezing
Sweating
Tearing
Tightness in the chest
 Heat Exhaustion
 Clammy skin
 Confusion
 Dizziness
 Fainting
 Fatigue
 Heat rash
 Light-headedness
 Nausea
 Profuse sweating
 Slurred speech
 Weak pulse
 Heat Stroke
 (may be fatal)
 Confusion
 Convulsions
 Hot skin, high temperature (yet may feel chilled)
 Incoherent speech
 Convulsions
 Staggering gait
 Sweating stops (yet residual sweat may be present)
 Unconsciousness
                                                48

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        Assist the hospital in developing procedures for site-related emergencies. This will help to protect
        hospital personnel and patients, and to minimize delays due to concerns about hospital safety or
        contamination.

        For specific illnesses or injuries, provide details of the incident and the worker's past medical history
        to the appropriate hospital staff. This is especially crucial when specific medical treatment is required
        (e.g., for exposure to cyanide or organophosphate pesticides).

Depending on the site's location  and potential hazards, it may be important to identify additional medical facilities
capable of sophisticated response to chemical or other exposures.

•   Post conspicuously (with duplicates near the telephones) the names, phone numbers, addresses, and .procedures
    for contacting:

        On-call physicians.

        Medical specialists.

        Ambulance services.

        Medical facility(ies).

        Emergency, fire, and police services.

        Poison control hotline.

•   Provide maps and directions.

•   Make sure at least all managers and all individuals involved in medical response know the way to the nearest
    emergency medical facility.

•   Establish a radio  communication system for emergency use.

•   Review emergency procedures daily with all site personnel at safety meetings before beginning the work
    shift.

NON-EMERGENCY  TREATMENT

Arrangements should be made for non-emergency medical  care for hazardous waste site workers who are
experiencing health effects resulting from an exposure to hazardous substances. In conjunction with the medical
surveillance program, offsite medical care should ensure that any potential job-related symptoms or illnesses
are evaluated in the context of the worker's exposure. Offsite medical personnel should also investigate and
treat non-job-related  illnesses that may put the worker at risk because of task requirements (e.g., a bad cold
or flu that might interfere with respirator use). A copy of the worker's medical records should be kept at the
site (with provisions  for security and confidentiality) and, when appropriate, at a nearby hospital.  Treating
physicians should have access to these records.

MEDICAL RECORDS

Proper recordkeeping is essential at hazardous waste sites because of the nature of the work and risks: employees
may work at a large number of geographically disparate sites during their careers, and adverse effects on long-term


                                                  49

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exposure may not become apparent for many years.  Records enable subsequent medical care providers to be
informed about workers* previous and current exposures.

OccupationalSafetyandHealthAdministration(OSHA) regulations mandate that, unless a specific occupational
safety and health standard provides a different time period, the employer must:

•   Maintain and preserve medical records on exposed workers for  30 years after they leave employment (29
    CFR Part 1910.20).

.   Make available to workers, their authorized representatives, and authorized OSHA representatives the results
    of medical testing and full medical records and analyses (29 CFR Part 1910.20).

.   Maintain records of occupational injuries  and illnesses and post  a yearly summary report (29 CFR Part
    1904).

PROGRAM REVIEW

Regular evaluation of the medical program is important to ensure its effectiveness.  Maintenance and review
of medical records and test results aid medical personnel, site officers, and the parent company and/or agency
managers in assessing the effectiveness of the health and safety program. The Site Safety Officer, medical
consultant, and/or management representative should, at least annually:

 •  Assure that each accident or illness was promptly investigated to determine the cause and make necessary
    changes in health and safety procedures.

 •  Evaluate  the efficacy of specific medical testing in the context of potential site exposures.

 .  Add or delete medical tests  as suggested by current industrial  hygiene and environmental'data.

 .  Review potential exposures and Site Safety Plans at all sites to  determine if additional testing is required

 •  Review emergency treatment procedures and update lists  of emergency contacts.
                                                  50

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REFERENCES

1.   Proficiency Testing Programs

    Division of Technology Evaluation and Assistance
    Laboratory Program Office
    Center for Disease Control
    Atlanta, GA 30333

    College of American Pathologists
    7400 N. Skokie Blvd.
    Skokie, IL 60077
    American Association for Bioanalysts
    205 W. Levee Street
    Brownsville, TX 78520

2.   Costello, R.J. 1983. U.S. Environmental Protection Agency Triangle Chemical Site, Bridge City, Texas.
    NIOSH Health Hazard Evaluations Determination Report,  HETA 83-417-1357.

3.   ANSI. 1984. American National Standard for Respiratory Protection. ANSI Z88.6-1984.  American National
    Standards Institute, 1430 Broadway, New York, NY 10018.

4.   Gleit, A; Cohen, A.G.; Chase, K.H.; and J. Toth 1985. Summary Report of the Medical Surveillance Program
    for the Binghamton State Office Building Decontamination Project. Prepared for Versar New York, Inc.
                                               51

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                                        APPENDIX C
                             HAZARDOUS MATERIALS INCIDENT
                                FTRST-ON-SCENE CHECKLIST
                                         (EXAMPLE)
1.      Report the incident as a possible hazmat accident. Give the exact location and request assistance.

2.      Stay upwind and upgrade.

3.      Isolate the area of non-essential personnel.

4.      Avoid contact with liquid or fumes.

5.      Eliminate ignition sources (lighted cigarettes, flares, and combustible engines).

6.      Rescue the injured only if prudent.

7.      Identify materials and determine conditions (spill, fire, leak, solid, liquid, vapor, single or mixed loads,
       waybills,  bills of lading, shipper, owner, manufacturer, and carrier).

                                  REPORT TO DISPATCHER

8.      Initiate evacuation, downwind first, if necessary.

                                  REPORT TO DISPATCHER

9.      Establish command post location - upwind at  a safe distance.  Report exact location and give the
        approach route to dispatcher.

                      REPORT TO  THE NATIONAL RESPONSE CENTER

                    OIL AND HAZARDOUS MATERIALS SPILLS/RELEASES

                              1-800-424-8802 (Toll  Free Day or Night)

                                      FOR ASSISTANCE:


                              EPA Regional Authority (Day or Night)

                               State Department of Natural Resources

                            State Department of Health and Environment

                             State Department of Environmental Control
                                               53

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                                        APPENDIX D
                   U.S. EPA REGIONAL SUPERFUND TRAINING CONTACTS
Sharon L, Molden
US EPA - Region I (PHD-2211)
JFK Federal Building
Boston, MA 02203
(617) 565-3390
(FTS) 835-3390

Peter Ucker
US EPA - Region II
26 Federal Plaza, Room 734
New York, NY  10278
(212) 264-6324
(FTS) 264-6324

Brenda J. Wingate
US EPA - Region III (3HW14)
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-4858
(FTS) 597-4858

Ralph D. Armstrong
US EPA - Region IV (HRMB)
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3486
(FTS) 257-3486

Steve Ostrodka
US EPA - Region V
230 S. Dearborn Street
Chicago, IL 60604
(312) 886-3011
(FTS) 886-3011
Rosemary Henderson
US EPA - Region VI
First Interstate Bank Tower - 10th Floor
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-2277
(FTS) 255-2277

William Keffer
US EPA - Region VII
25 Funston Road
Kansas City, KS  66115
(913) 236-3888
(FTS) 757-3888

Tina Artemis
US EPA - Region VIII (8HWM-ER)
Denver Place, Suite 500
999 18th Street
Denver, CO  80202-2405
(303) 294-7142
(FTS) 564-7142

Carita Hall-Reynolds
US EPA - Region IX (H-8-3)
1235 Mission Street
San Francisco, CA  94103
(415) 744-1914
(FTS) 484-1914

Loretta Hrin
US EPA - Region X (MS-533)
1200 6th Avenue
Seattle, WA  98101
(206) 442-7154
(FTS) 399-7154
                                             55

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                                         APPENDIX E
                                   SELECTED REFERENCES
This appendix lists documents that may prove helpful to anyone planning to establish a Hazmat Team.
REGULATIONS

29 CFR 1910.120, OSHA Final Rule: Hazardous
Waste Site Operations and Emergency Response,
as printed in the Federal Register, March 6, 1989,
pp. 9316 - 9330.

STANDARDS

NFPA Standard 471-1989, Recommended Practice
for Responding to Hazardous Materials Incidents.
Quincy,   MA:      National   Fire   Protection
Association, 1989.

NFPA Standard 472-1989, Standard for Professional
Competence ofResponders to Hazardous Materials
Incidents.  Quincy, MA: National Fire Protection
Association, 1989.

Copies of NFPA publications can be obtained by
calling 1-800-344-3555 or by writing to:

        National Fire Protection Association
        1  Batterymarch Park
        P.O. Box 9101
        Quincy, MA 02269

Standard 471 is available for S15.50, Standard 472
for  $13.25,  and  the Handbook (listed  under
Technical References) for $49.50.   Purchased
together, the publications cost $66.50.

GUIDANCE

Computer  Systems  for   Chemical  Emergency
Planning:  Chemical Emergency Preparedness and
Prevention  Technical Assistance Bulletin  #5.
Washington, DC: EPA, September 1989 (OSWER-
89-005).

Hazardous Materials Emergency  Planning Guide
(NRT-1).  Washington, DC:  National Response
Team, 1987.
Technical  Guidance  for  Hazardous  Analysis.
Washington, DC: EPA/FEMA/DOT, 1987.

Copies of NRT-1,  the Technical Guidance,  and
Technical Assistance Bulletin #5 may be obtained
free of charge by calling the Emergency Planning
and Community Right-To-Know Hotline at 1-800-
535-0202.

Handbook of Chemical Hazard Analysis Procedures.
Washington, DC: FEMA/DOT/ EPA.

Copies of this  handbook may  be obtained by
writing to:

       Federal Emergency Management Agency-
       Publications Office
       500 C Street, S.W.
       Washington, DC  20472

Occupational Safety and Health Guidance Manual
for Hazardous Waste  Site  Activities. Washington,
DC: NIOSH/OSHA/U.S. Coast Guard/EPA, 1985.
(DHHS/NIOSH Pub.  No.  85-115).

Standard Operating Safety  Guides. EPA, Office of
Emergency and Remedial Response, Emergency
Response  Division,  Environmental   Response
Team, 1988.
TECHNICAL REFERENCES

Hazardous Materials Response Handbook. Quincy,
MA: National Fire Protection Association, 1989.

Copies of this  Handbook may be obtained by
writing to NFPA; the address is listed above under
NFPA Standards.

Guidelines for the Selection of Chemical Protective
Clothing. Cambridge, MA: AD. Little, 1987.
                                               57

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                                         APPENDIX F
                                    INFORMED SOURCES
Chief Don Brunken
Omaha Fire Department
1516 Jackson Street
Omaha, NE 68102
(402) 444-5760

Capt. Jerry Grey
San Francisco Fire Department
Station #36
109 Oak Street
San Francisco, CA 94102
(415) 861-8000, ext. 236

Lt. Bill Hand
Houston Fire Department
1205 Dart
Houston, TX  77007
(713) 923-1334

William Keffer
U.S. EPA, Region VII
25 Funston Road
Kansas City, KS 66115
(913) 236-3888

Larry Knoche
Kansas Department of Health and Environment
Forbes Field, Building 740
Topeka, KS 66620
(913) 296-1500

Ron Kozel
Iowa Department of Natural Resources
Wallace Building
900 East Grand Avenue
Des Moines, IA 50319
(515) 281-8883

Dean Martin
Missouri Department of Natural Resources
Jefferson State Office Building
2010 Missouri Boulevard
Jefferson City, MO  65102
(314) 751-7929
 Asst. Chief Mary Beth Michos
 Emergency Medical and Technical Services
 Department of Fire and Rescue
 101 Monroe Street
 Rockville, MD  20850
 (301) 217-2099

 Bat. Chief Larry Mullekin
 Wichita Fire Department
 455 N. Main
 Wichita, KS 67202
 (316) 683-7216

 Lt. Jeff Rylee
 Salt Lake City Fire Department
 159 E. 100 Street
 Salt Lake City, UT 84111
 (801) 799-4217

 Vickie Santoro
 U.S. EPA/ERT (MS-101)
 2890 Woodbridge Avenue
 Building 18
 Edison, NJ 08837-3679
 (201) 906-6917

 Clark Smith
 Nebraska Dept. of Environmental Control
 Box 98922
 301 Centennial Mall South
 Lincoln, NE 68509
 (402) 471-2186

 Lt. Bill Stringfield
 St. Petersburg Fire Department
 1429 Arlington Avenue North
 St. Petersburg, FL 33705
 (813) 893-7650

Rod Turpin
U.S. EPA/ERT (MS-101)
2890 Woodbridge Avenue
Building 18
Edison, NJ  08837-3679
(201)  906-6917
                                             59
                                                       -&U.S. GOVERNMENT PRINTING OFFICE: IWI - 548-1117/20572

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