vvEPA
United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington. DC 20460
Publication 9285.1-03
PB92-9634U
June 1992
Superfund
Standard Operating
Safety Guides 001027155222
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Publication 9285.1-03
June 1992
STANDARD OPERATING
SAFETY GUIDES
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, DC 20460
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NOTICE
This guidance manual does not constitute a rulemaking by the Agency. The policies set forth in
this Directive are intended solely as guidance. They are not intended, nor can they be relied
upon, to create any substantive or procedural rights enforceable by any party in litigation with the
United States. EPA officials may decide to follow the guidance provided in this Directive, or may
take action that is at variance with the guidance, policies, and procedures in this Directive, on the
basis of an analysis of specific circumstances. The Agency also reserves the right to change this
Directive at any time without public notice. Mention of trade names or commercial products does
not constitute endorsement or recommendation for use.
Additional copies of this document can be obtained from:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
When ordering this document, refer to Publication 9285.1-03.
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CONTENTS
Chapter 1 Introduction 1
1.0 Introduction 3
1.1 Regulatory Background 4
1.2 Regulatory Scope 5
Chapter 2 Comprehensive and Site-Specific Health and Safety Program 7
2.0 Introduction 9
2.1 General Components of the Health and Safety Program 9
2.2 HASP Development and Site Characterization 11
2.2.1 Preliminary Evaluation 16
2.2.2 Writing the Initial Draft of the HASP 17
2.2.3 Initial Site Entry 17
2.2.4 Revising the HASP 19
2.2.5 On-Going Monitoring 20
Chapter 3 Training 23
3.0 Introduction 25
3.1 Training Requirements 25
3.1.1 General Training Requirements 25
3.1.2 Site-Specific Requirements 25
3.2 Initial Training Requirements for Field Personnel 26
3.3 Equivalent and Refresher Training 27
3.4 Trainer Qualifications and Certification 29
Chapter 4 Site Control 31
4.0 Introduction 33
4.1 Development of the Site Map 33
4.2 Establishment of Work Zones at the Site 35
4.2.1 The Exclusion Zone 35
4.2.2 The Contamination Reduction Zone (CRZ) 36
4.2.3 The Support Zone 37
4.2.4 Ensuring Integrity of the Support Zone 37
4.3 Organization of Workers Using the Buddy System 38
4.4 Establishment of a Communications Network and Procedures 39
4.5 Worker Safety Procedures 40
4.5.1 Site Preparation 40
4.5.2 Engineering Controls and Safe Work Practices 40
4.5.3 Standing Orders 41
4.6 Identification of Nearest Medical Assistance 42
in
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CONTENTS (cont'd)
Chapter 5 Personal Protective Equipment 43
5.0 Introduction 45
5.1 Selecting the Level of PPE 45
5.1.1 Level A 46
5.1.2 Level B 52
5.1.3 Level C 52
5.1.4 Level D 52
5.2 Elements of the PPE Program 53
5.2.1 Personal Use Factors and Equipment Limitations 53
5.2.2 Work Mission Duration 53
5.2.3 Storage and Maintenance 54
5.2.4 Training and Proper Fitting 55
5.2.5 Donning and Doffing Procedures 56
5.2.6 Inspection Procedures 56
5.2.7 PPE Program Evaluation 56
5.2.8 Other Considerations 56
Chapter 6 Air Monitoring 59
6.0 Introduction 61
6.1 Objectives of Air Monitoring 61
6.2 Identifying Airborne Contaminants 62
6.2.1 Direct Reading Instruments 62
6.2.2 Air Sampling 66
6.3 Air Sampling Equipment and Media 67
6.4 Sample Collection and Analysis 68
6.5 General Monitoring Practices 70
6.5.1 Perimeter Monitoring 70
6.5.2 Periodic Monitoring 70
6.5.3 Personal Monitoring 70
6.6 Meteorological Considerations 71
6.7 Long-Term Air Monitoring Programs 71
6.8 Variables in Hazardous Waste Site Air Monitoring 72
6.9 Using Vapor/Gas Concentrations to Determine
Level of Protection 72
6.9.1 Factors for Consideration 73
6.9.2 Level A Protection (500 to 1,000 ppm) 73
6.9.3 Level B Protection (5 to 500 ppm) 74
6.9.4 Level C Protection (Background to 5 ppm) 74
IV
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CONTENTS (cont'd)
Chapter 7 Medical Surveillance Program 77
7.0 Introduction 79
7.1 Employees Covered by the Monitoring Program 79
7.2 Frequency and Content of Medical Examinations 79
7.2.1 Baseline Screening 80
7.2.2 Periodic Medical Examinations 82
7.2.3 Termination Examination 82
7.3 Emergency Treatment 82
7.4 Chemical Contamination 83
7.5 Medical Records and Program Review 89
Chapter 8 Heat Stress and Cold Exposure 91
8.0 Introduction 93
8.1 Heat Stress 93
8.1.1 Heat Stress and PPE 93
8.1.2 Monitoring for Heat Stress 93
8.1.3 Preventing Heat Stress 94
8.2 Cold Exposure 95
8.2.1 PPE and Cold Exposure 95
8.2.2 Monitoring for Cold Exposure 95
8.2.3 Preventing Cold Exposure 98
8.2.4 A Control Program for Cold Stress 100
Chapter 9 Decontamination 101
9.0 Introduction 103
9.1 The Decontamination Plan 103
9.2 Developing the Plan 103
9.3 The Contamination Reduction Corridor 104
9.4 Decontamination Procedures and Equipment 105
9.4.1 Physical Removal of Contaminants 105
9.4.2 Chemical Removal of Contaminants 106
9.4.3 Decontamination Equipment 106
9.5 Protection of Decontamination Personnel 108
9.6 Health and Safety Hazards 108
Chapter 10 Drum Handling in
10.0 Introduction 113
10.1 Inspection 113
10.2 Drum Excavation and Removal Equipment 116
10.3 Drum Handling 116
10.4 Drum Opening 117
10.5 Drum Sampling 118
10.6 Characterization 118
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CONTENTS (cont'd)
Chapter 11 Other Requirements and Safety Considerations 12?
11.0 Introduction 129
11.1 Emergency Response and Prevention 129
11.1.1 Prevention 130
11.1.2 Communications 130
11.1.3 Site Mapping 131
11,2 Hazards 131
11.2.1 Explosion and Fire 131
11.2.2 Oxygen Deficiency 131
11.2.3 Ionizing Radiation 132
11.2.4 Biological Hazards 132
11.2.5 Safety Hazards 133
11.2.6 Noise Hazards 133
11.2.7 Work Hazards 134
11.3 Confined Space Entry 134
11.4 Information and New Technology Programs 137
11.5 Construction Requirements 137
Acronyms and Abbreviations 139
Appendices
APPENDIX A Sources of Information and Response Assistance 141
APPENDIX B Other Common Applicable OSHA Standards 149
APPENDIX C Incident Safety Check-Off List 155
APPENDIX D Characteristics of the Photoionization Detector (PID)
and the Flame lonization Detector (FID) 159
APPENDIX E Sample Decontamination Layouts and
Procedures for Levels of Protection A Through C 163
APPENDIX F Regional Contacts 179
VI
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ACKNOWLEDGEMENTS
This manual was developed by the Environmental Response Branch of EPA's Office of Emergency and
Remedial Response, Emergency Response Division. The project manager wishes to acknowledge and
express its appreciation for those persons who assisted in the research, development, and preparation of
the document. In addition, many thanks are offered to the technical reviewers who provided constructive
comments on the document in its final stages of development.
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CHAPTER 1 INTRODUCTION
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CHAPTER 1 INTRODUCTION
1.0 INTRODUCTION
Protecting the health and
safety of workers is a major
consideration when hazardous
substances are present at a
site. Not only must site
personnel perform a variety of
technical tasks correctly and
efficiently, but they also must work in an often
unpredictable and potentially dangerous
environment. By adequately equipping and
training personnel, and by using appropriate
standard operating procedures, the potential for
harm from exposure to hazardous substances can
be greatly reduced.
The purpose of this document is to provide
guidance for ensuring the health and safety of site
personnel who work with hazardous substances or
who work at uncontrolled hazardous waste sites.
This guidance is intended for federal, state, and
local managers and personnel at sites where
hazardous materials are present. It is meant to
supplement professional training, experience, and
knowledge, and can be used as:
• A planning and management tool for field
managers;
• An educational tool that addresses
fundamental aspects of the required health
and safety programs and plans at hazardous
waste sites;
• A reference document for site personnel
who may need to review important aspects
of on-site health and safety.
The U.S. Occupational Safety and Health
Administration (OSHA) has established
regulations governing the health and safety of
employees engaged in hazardous waste operations
and emergency response. These regulations,
codified at 29 CFR §1910.120, contain general
requirements for health and safety programs, site
characterization and analysis, site control, training,
medical surveillance, engineering controls and
work practices, personal protective equipment,
exposure monitoring, informational programs,
material handling, decontamination, and emergency
procedures. EPA has incorporated these standards
by reference into its regulations at 40 CFR Part
311. Both sets of regulations are discussed in
further detail in Section 1.1.
A number of documents have been developed
to provide guidance for protecting the health and
safety of workers exposed to hazardous substances.
The purpose of this document is to update the
U.S. EPA's July 1988 Standard Operating Safety
Guides (SOSG) to incorporate the new
requirements at 29 CFR §1910.120 and 40 CFR
Part 311. This document also includes information
presented in the Occupational Safety and Health
Guidance Manual for Hazardous Waste Site
Activities (the "Four-Agency document"), which was
written jointly by OSHA, EPA, the National
Institute for Occupational Safety and Health
(NIOSH), and the U.S. Coast Guard (USCG).
The Guide also draws from other EPA documents,
including the EPA Health and Safety Manual, the
EPA Health and Safety Audit Guidelines, and the
EPA's Standard Operating Procedures for
hazardous waste site operations. Refer to
Appendix A for a list of other useful sources of
information.
This revised SOSG is intended to provide a
comprehensive overview of the information needed
by employers to meet their responsibility to assure
the health and safety of employees engaged in
operations at hazardous waste sites. Developing
and implementing a worker protection program is
a dynamic process that requires both initial and
ongoing planning, periodic revision, and attention
to a variety of site details. This guidance
document provides a comprehensive overview of
the structure of that process as a whole, as well as
a more detailed discussion of each of the individual
components. Thus, this document is intended to
supplement the OSHA regulations at 29 CFR
§1910.120, but is not meant for use as a legal
document or as a replacement to those regulations.
This document is structured as follows:
• Chapter 1 provides an overview of the
purpose and scope of the document, and
discusses how the requirements at 29 CFR
§1910.120 and 40 CFR Part 311 fit into the
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regulatory framework of worker protection
standards.
• Chapters 2 and 3 discuss initial planning
activities that take place before work may
begin at the site. Chapter 2: Comprehensive
and Site-Specific Health and Safety Program
outlines the components of the health and
safety requirements at both the corporate
and the site-specific level, and describes the
relationship of the site characterization
process to the development of the site-
specific Health and Safety Plan (HASP).
Chapter 3: Training discusses the health and
safety training program required for workers
and managers engaged in hazardous waste
operations.
• Chapters 4 through 11 provide a discussion
of health and safety considerations for
preliminary and on-going site activities.
These include:
Chapter 4: Site Control
Chapter 5: Personal Protective Equipment
Chapter 6: Air Monitoring
Chapter 7: Medical Surveillance Program
Chapter 8: Heat Stress and Cold Exposure
Chapter 9: Decontamination
Chapter 10: Drum Handling
Chapter 11: Other Requirements and Safety
Considerations.
1.1 REGULATORY BACKGROUND
Under the authority of section
126 of the Superfund Amend-
ments and Reauthorization Act
of 1986 (SARA), EPA and
OSHA promulgated identical
health and safety standards to
protect workers engaged in
hazardous waste operations and emergency
response. The OSHA regulations, codified at 29
CFR §1910.120, became effective on March 6,1990
(54 FR 9294). (Corrections to the OSHA
regulations were published on April 13, 1990 (55
FR 14072).) The EPA regulations incorporate the
OSHA standards by reference and are codified at
40 CFR Part 311 (54 FR 26654).
The EPA and OSHA worker protection
standards for hazardous waste operations and
emergency response (HAZWOPER) apply to five
groups of workers, as shown in Exhibit 1-1. This
document addresses the standards as they apply to
the first three groups of workers, those engaged in
voluntary or mandatory cleanups at uncontrolled
hazardous waste sites, or in corrective actions at
treatment, storage, and disposal (TSD) facilities
regulated under the Resource Conservation and
Recovery Act (RCRA).
EXHIBIT 1-1
HAZWOPER standards apply to workers
engaged in:
Mandatory cleanups at uncontrolled
hazardous waste sites
Voluntary cleanups at uncontrolled
hazardous waste sites
Corrective actions at RCRA TSD facilities
Routine hazardous waste operations
at RCRA TSD facilities
Emergency response operations
without regard to location
The HAZWOPER requirements for these
workers, specified at 29 CFR §1910.120(a) through
(o), are summarized in Exhibit 1-2. In addition,
these provisions apply to any activities performed
during the preliminary planning and evaluation
stages of the remedial investigation and feasibility
study (RI/FS), such as the preliminary assessment
and site investigation (PA/SI).
HAZWOPER does not, however, apply to
employees who do not have the potential to be
exposed to hazardous substances. For example,
administrative support personnel in the Site
Command Post may not be covered by
HAZWOPER, but are, of course, protected by
other OSHA standards. They should also be made
aware of the provisions of the emergency response
plan, and must be briefed on emergency
procedures and general site operations, such as the
location of work zones.
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EXHIBIT 1-2
Hazardous Waste Operations and Emergency Response at Uncontrolled Hazardous Waste Sites
(29 CFR §1910.120(a)-(o))
(a) Scope, application, and definitions. (h)
(b) Safety and health program. (i)
(c) Site characterization and analysis. Q')
(d) Site control. (k)
(e) Training. (I)
(f) Medical surveillance.
(g) Engineering controls, work practices, and (m)
personal protective equipment for employee (n)
protection. (o
Monitoring.
Informational programs.
Handling drums and containers.
Decontamination.
Emergency response by employees at
uncontrolled hazardous waste sites.
Illumination.
Sanitation at temporary workplaces.
New technology programs.
1.2 REGULATORY SCOPE
The occupational safety and
health standards, published at
29 CFR, established minimum
requirements to ensure
protection for all private sector
employees in the U.S. The
general industry standards at
29 CFR Part 1910 were derived largely from
standards developed by industry consensus
organizations and non-OSHA Federal safety and
health standards. These requirements reflect
practices previously recognized by most industrial
sectors prior to regulation under the OSHA The
OSHA standards, however, make these practices
mandatory.
Many of the OSHA standards at 29 CFR Part
1910 establish generic specifications for using
worker tools, maintaining industrial structures,
installing equipment to make the workplace safer
(e.g., sprinkler systems), providing medical
attention, and other general health and safety
practices applicable to all types of employment.
Other sections in 29 CFR Part 1910, however, are
specific to employees engaged in a specific activity
or industry, such as hazardous waste operations.
Specifically, §1910.120 (HAZWOPER)
contains requirements to minimize the health and
safety hazards associated with conducting
hazardous waste operations at uncontrolled
hazardous waste sites and RCRA TSD facilities,
and conducting emergency response. In some
instances, the HAZWOPER standards incorporate
general worker protection provisions by reference.
For example, §1910.120(g) requires employers
engaged in hazardous waste operations and
emergency response to follow the provisions in
§1910.94 through §1910.100, which require controls
to protect employees from exposure to hazardous
substances and safety and health hazards. Those
referenced sections may apply to other industries
and activities as well, but HAZWOPER applies
only to hazardous waste operations and emergency
response during the covered activities and
locations.
In addition to the requirements set forth at
29 CFR Part 1910, OSHA codified regulations at
29 CFR 1926, Subpart C, that set forth safety and
health standards specifically applicable to the
construction industry. Both 29 CFR Part 1910 and
Part 1926 require employers to provide whatever
training and education is appropriate for
employees to safely perform a given task. Exhibit
1-3 presents a list of the OSHA standards that
might apply at uncontrolled hazardous waste sites.
Appendix B describes these standards in greater
detail. The remainder of this guide discusses the
types of activities that must be undertaken during
hazardous waste operations to ensure worker
health and safety and to comply with the
HAZWOPER requirements.
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EXHIBIT 1-3
Other Potentially Applicable
1910.20 Access to Employee Exposure
and Medical Records
1910.24 Fixed Industrial Stairs
1910.27 Fixed Ladders
1910.28 Safety Requirements for
Scaffolding
1910.38 Employee Emergency Plans and
Fire Prevention Plans
1910.94 Ventilation
1910.95 Occupational Noise Exposure
1910.101 Compressed Gases
1910.133 Eye and Face Protection
1910.134 Respiratory Protection
1910.135 Occupational Head Protection
1910.136 Occupational Foot Protection
1910.141 Sanitation
1910.151 Medical Services and First Aid
1910.157 Fire Extinguishers
1910.212 General Requirements for all
Machines
*Not intended as a complete list
OSHA Standards under 29 CFR*
1910.165 Employee Alarm Systems
1910.181 Derricks
1910.252 Welding, Cutting, and Brazing
1910.307 Hazardous Locations
1910.1000 Toxic and Hazardous Substances
1910.1200 Hazard Communication
1926.20 General Safety and Health Provisions
1926.21 Safety Training and Education
1926.56 Illumination
1926.58 Asbestos
1926.59 Hazard Communication
1926.151 Fire Prevention
1926.152 Flammable and Combustible Liquids
1926.200 Accident Prevention Signs and Tags
1926.301 Hand Tools
1926.400 Electrical General Requirements
1926.401 Grounding and Bonding
1926.651 Specific Excavation Requirements
1926.652 Trenching Requirements
FURTHER GUIDANCE: For additional information on employee health and safety at uncontrolled
hazardous waste sites, see:
1. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities
(NIOSH/OSHA/USCG/EPA, 1985, NIOSH Publication 85-115).
2. EPA Health and Safety Audit Guidelines (U.S. EPA, 1989, EPA 540/G-89/010).
3. OSWER Integrated Health and Safety Standard Operating Practice (U.S. EPA, 1992,
Publication 9285.0-01).
4. Standard Operating Procedures for Site Safety Planning (U.S. EPA, 1985, Publication 9285.2-05).
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CHAPTER 2 COMPREHENSIVE AND SITE-SPECIFIC
HEALTH AND SAFETY PROGRAM
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CHAPTER 2 COMPREHENSIVE AND SITE-SPECIFIC
HEALTH AND SAFETY PROGRAM
2.0 INTRODUCTION
The HAZWOPER regulations
at 29 CFR §1910.120(5)
require that any employer
whose workers engage in
hazardous waste operations at
an uncontrolled hazardous
waste site or who perform
corrective actions at a RCRA TSD facility must
develop and implement a written health and safety
program. This program must be designed to
identify, evaluate, and control health and safety
hazards at any site, and to provide for emergency
response during site operations. The program
must be maintained by the employer and made
available to: (1) any employee or employee
representative; (2) any contractor, subcontractor,
or other representative working for the employer
who may be potentially exposed to hazardous
substances; (3) OSHA personnel; and (4)
personnel of federal, state, and local agencies with
regulatory authority over the site. If an employer
already has developed a health and safety program
to meet the requirements of other federal, state, or
local regulations, the employer may use the
existing program to satisfy the HAZWOPER
requirements, provided that any additional
information not covered in the existing program,
but required under HAZWOPER, is incorporated
into the program.
The primary purpose of the written health
and safety program is to serve as an organization-
wide health and safety policy that applies to all
employees of the organization, regardless of the
location of the actual site where they are working.
The HAZWOPER regulations at 29 CFR
§1910.120(b) establish the components of the
general program, as shown in Exhibit 2-1.
Because the written health and safety
program is intended to be organization-wide, only
one health and safety program should be
developed by an employer, even if the employer
has workers who perform operations at several
different sites. As required by HAZWOPER, this
program should define the organizational structure,
describe the general health and safety training and
medical surveillance programs, and establish the
standard operating procedures for health and
safety. In addition, the health and safety program
must also require that both a comprehensive
workplan and a Health and Safety Plan (HASP) be
developed for each site where workers are engaged
in hazardous waste operations. Each HASP
includes plans for implementing, on a site-specific
basis, applicable requirements set forth in the
organization's health and safety program (see
Exhibit 2-1). For this reason, the health and safety
program should include procedures needed for
coordination between the comprehensive and site-
specific health and safety activities.
Section 2.1 below describes in more detail
these general components of the written health
and safety program. Because HASP development
is a complex, iterative process, Section 2.2 focuses
on the procedures for developing the HASP.
2.1 GENERAL COMPONENTS OF THE
HEALTH AND SAFETY PROGRAM
As required by 29 CFR §1910.120(b), an
organization's written health and safety program
must include certain general program components.
Each of these are described briefly below.
Organizational Structure. The organizational
structure component of the written health and
safety program identifies the specific chain of
command in the employer's organization, and
specifies the overall responsibilities of supervisors
and employees in carrying out the health and
safety program. The structure should identify the
general supervisor for all hazardous waste
operations; provide a roster of the health and
safety supervisors of all the sites; and describe the
responsibilities of other personnel engaged in
hazardous waste operations or emergency response.
The structure should also identify the lines of
authority, communication, and coordination among
personnel and managers in the organization. It is
necessary to review and update the organizational
structure periodically to reflect changes in
personnel and operations.
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EXHIBIT 2-1
Health and Safety Program:
Comprehensive and Site-Specific Components
Comprehensive Health and Safety Program
Site-Specific HASP
The HAZWOPER regulations at 29 CFR
§1910.120(b)(1) require a comprehensive
health and safety program that includes:
Organizational structure
Site-specific workplans
The HASP implements certain components
of the health and safety program on a site-
specific basis. The HASP includes:
• Site-specific health and
safety plans (HASPs)
• Health and safety training program
• Medical surveillance program
• Standard operating procedures
• Coordination procedures
• Key personnel
• Health and safety risk analysis
• Site control measures
• Training assignments
• Medical surveillance requirements
• Personal protective equipment
• Air and employee monitoring
• Spill containment program
• Confined space procedures
• Decontamination procedures
• Emergency response plan
Comprehensive Workplan. As required by
HAZWOPER, the written health and safety
program should specify that a comprehensive
workplan will be developed for each site to
evaluate the logistics and resources needed to
reach work objectives for site operations. The
workplan should identify anticipated cleanup
activities as well as normal operating procedures.
It should also establish implementation strategies
for carrying out the training, informational, and
medical surveillance programs of the general
health and safety program. The following steps
should be undertaken in developing the work plan:
• Review available information, including site
records, waste inventories, manifests,
sampling data, site photos, and other
records;
• Define work objectives;
• Determine methods for accomplishing the
objectives (e.g., sampling plan, defining
alternate technologies);
• Determine personnel requirements;
• Determine need for additional training
(refer to Chapter 3 for specific
requirements); and
• Determine equipment requirements.
Site-Specific Health and Safety Plan (HASP).
In addition to the workplan, a site-specific HASP
must be developed and implemented for each site
where workers are potentially exposed to
hazardous substances. Section 2.2 below discusses
the components of the HASP and the process for
its development.
Health and Safety Training Program. HAZ-
WOPER requires that the health and safety
program include a component to establish
organization-wide health and safety training
requirements for all site workers and supervisors.
The training program must address the hazards
present on-site, use of personal protective
equipment, work practices to minimize risks, safe
use of engineering controls and equipment, and
medical surveillance requirements. The HASP for
a particular site may implement these general
training requirements on a site-specific basis (refer
to Chapter 3 for specific requirements).
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Medical Surveillance Program. HAZ-
WOPER requires that the written health and
safety program also include a detailed program for
ensuring and monitoring the general health of
workers engaged in hazardous waste operations.
As with the training program, the HASP for a
particular site will address the medical surveillance
program requirements and any special site-specific
medical surveillance concerns. (Refer to Chapter
7 for more information.)
Standard Operating Procedures. The
HAZWOPER standards require employers to have
established standard operating procedures for safe
work practices. Such procedures should be
specified in the written health and safety program.
If the employer has already written and
implemented these procedures, it is not necessary
for new procedures to be developed.
Coordination Procedures. Because the health
and safety program includes elements that are
implemented on a site-specific basis, HAZWOPER
requires that the program include procedures
needed for coordination between the
comprehensive and site-specific health and safety
activities.
2.2 HASP DEVELOPMENT AND SITE
CHARACTERIZATION
As discussed above, the HAZWOPER
regulations at 29 CFR §1910.120(b)(4) require that
a site-specific HASP be developed for each site
where workers are engaged in hazardous waste
operations. The purpose of the site-specific HASP
is to address the health and safety hazards that
may exist at each phase of site operations and to
identify procedures for protecting employees.
A new HASP should not be developed if new
tasks or hazards are identified at a site; rather, the
original HASP should be updated. If a sub-
contractor is working at a site, the subcontractor
should carefully evaluate and identify all tasks
associated with the subcontracted activities, and
prepare a health and safety plan addressing any
identified hazards. This plan should be submitted
to the site manager, who will incorporate it into
the general site HASP after it has been reviewed
for concurrence with the site workplan.
THE RULE IS:
ONE SITE, ONE HASP
Exhibit 2-2 describes in detail the specific
components that should be included in the HASP.
Also, Exhibit 2-3 presents a sample HASP Table
of Contents. Some of the areas that must be
addressed in the HASP are discussed in further
detail in later chapters of this document.
Development of the site-specific HASP is a
process that incorporates the information collected
during the site characterization phase of hazardous
waste operations. Site characterization generally is
divided into three phases:
• Prior to site entry, the preliminary
evaluation (PE) is conducted off-site to
gather information about the site and to
conduct reconnaissance from the site
perimeter.
• During the second stage, initial site entry, a
visual survey is taken and preliminary air
monitoring is performed. During this
phase, site entry is restricted to properly
trained and protected reconnaissance
personnel.
• Once the hazards have been identified to
the greatest extent possible, other activities
may commence at the site. Monitoring
continues, however, to provide a continuous
source of information about site conditions.
It is important to recognize that site character-
ization (and, therefore, HASP development) is a
continuous process. At each phase of site
characterization, information should be obtained
and evaluated to define the hazards that the site
may pose. This assessment can then be used to
develop the HASP for the next phase of work.
The more accurate, detailed, and comprehensive
the information available about a site, the more
the HASP can be tailored to the actual hazards
that workers may encounter. In addition to the
formal information gathering that takes place
during the phases of site characterization described
here, all site personnel should be constantly alert
for new information about site conditions that may
indicate a need to update the HASP.
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EXHIBIT 2-2
Components of the HASP
Key Personnel and
Hazard Communications
Plan
(29CFR§1910.120(b)(2))
The HASP should include names of key personnel such as Project
Manager, Field Operations Leader, Site Supervisor, and Site Health and
Safety Officer, as well as their alternates. The HASP should also
identify communication procedures and provide for briefings to be held
before site activity is initiated. These meetings should be held at any
time they appear necessary to ensure that employees are adequately
apprised of the health and safety procedures being followed at the site.
Health and Safety Risk
Analyses
(29CFR§1910.120(b)(4))
Health and safety risk analyses should be established for each task and
operation identified in the site-specific workplan. Discussion of these
analyses should include identification of chemical contaminants, affected
media, concentrations, and potential routes of exposure for use in risk
analysis. Should also include safety risk analyses to address
anticipated on-site operations and safety problems.
Site Control Measures
(29CFR§1910.120(d))
The site control program in the HASP specifies the procedures that will
be used to minimize employee exposure to hazardous substances
before cleanup operations commence and during site operations. The
program must be developed during the planning stages of a hazardous
waste cleanup operation, and must be modified as any new information
becomes available. The site control program should include a site
map, designation of work zones, site communications, safety work
practices, identification of the nearest medical assistance, and
description of the 'buddy system' for site operations. Chapter 4
describes the requirements of the site control program.
Employee Training
Assignments
(29 CFR §1910.120(6))
Training assignments should address the employee's initial health and
safety training, annual health and safety refresher training, on-the-job
training, supervisory training, and first-aid and CPR training. Employees
should not be permitted to participate in or supervise field activities until
they have received training commensurate with their responsibilities.
Chapter 3 describes the applicable training requirements in greater
detail.
Medical Surveillance
(29 CFR §1910.120(f))
The medical surveillance program is required for monitoring the health
status of personnel who are potentially exposed to hazardous
substances in the field and who wear respirators 30 days or more per
year. It must include initial and periodic medical examinations,
examination upon termination of employment, and medical
recordkeeping. Chapter 7 describes the medical surveillance
requirements specified in HAZWOPER.
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EXHIBIT 2-2 (cont'd)
Component* of the HASP
Personal Protective
Equipment (PPE)
(29 CFR§ 1910.120(g))
The HASP must describe the different PPE ensembles that will be used
to address potential hazards during site activities. The HASP should
also include or refer to a comprehensive PPE program that addresses
site hazards, duration of site activities, limitations of PPE during
temperature extremes, PPE selection, maintenance, storage, and
decontamination, and training for PPE use, inspection, and monitoring.
Such PPE should be used only when engineering controls and work
practices are insufficient to adequately protect against exposure.
Chapter S discusses PPE requirements in greater detail.
Air and Personnel
Monitoring
(29CFR§1910.120(h))
The HASP must describe the employee and air monitoring equipment
and environmental sampling techniques and instrumentation that will be
used on-site for evaluating potential exposure to contaminants that
result from site activities. The monitoring program must include
procedures for initial entry monitoring, periodic monitoring, and
monitoring of high risk employees. Chapter 6 discusses monitoring
requirements and procedures.
Spill Containment
Program
(29 CFR §1910.120®)
Confined Space Entry
Procedures
(29CFR§1910.120(b)(9))
The HASP should include any elements of the spill containment program
that may be relevant to the site, and should provide procedures to
contain and isolate the entire volume of any hazardous substance
spilled in the course of a transfer, major spill, or an on-site release.
If confined space entry is anticipated on-site, the HASP should describe
procedures for entry into confined space. Such procedures ensure the
safety of site personnel who must enter areas where natural ventilation
is insufficient to reduce contaminant concentrations. Chapter 11
presents the requirements for developing confined space entry
procedures.
Decontamination
Procedures
(29CFR§1910.120(k))
The HASP should include decontamination procedures, both for
individuals and equipment on-site and in places where there is a
potential for exposure to a hazardous substance. These procedures
should explain how to minimize contact with hazardous substances and
how to conduct personal and equipment decontamination when leaving
a contaminated area. Chapter 9 presents the requirements for a
decontamination program.
Emergency Response
Plan
(29 CFR§ 1910.120(1))
The emergency response plan in the HASP must include a description
of how anticipated emergencies would be handled at the site and how
the risks associated with a response would be minimized. The
emergency response plan must be developed and implemented prior to
beginning site operations. Chapter 11 discusses the requirements for
an emergency response plan at an uncontrolled hazardous waste site.
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EXHIBIT 2-3
Sample HASP Table of Contents for Site "A"
1.0 INTRODUCTION
1.1 Scope and Applicability of the Site Health and Safety Plan
1.2 Visitors
2.0 KEY PERSONNEL/IDENTIFICATION OF HEALTH AND SAFETY PERSONNEL
2.1 Key Personnel
2.2 Site-Specific Health and Safety Personnel
2.3 Organizational Responsibility
3.0 TASK/OPERATION SAFETY AND HEALTH RISK ANALYSIS
3.1 Historical Overview of Site
3.2 Task-by-Task Risk Analysis
4.0 PERSONNEL TRAINING REQUIREMENTS
4.1 Preassignment and Annual Refresher Training
4.2 Site Supervisors Training
4.3 Training and Briefing Topics
5.0 PERSONAL PROTECTIVE EQUIPMENT TO BE USED
5.1 Levels of Protection
5.2 Level A Personal Protective Equipment
5.3 Level B Personal Protective Equipment
5.4 Level C Personal Protective Equipment
5.5 Level D Personal Protective Equipment
5.6 Reassessment of Protection Program
5.7 Work Mission Duration
5.8 Chemical Resistance and Integrity of Protective Material
5.9.5 SCBA Inspection and Checkout
5.10.1 Inspection
6.0 MEDICAL SURVEILLANCE REQUIREMENTS
6.1 Baseline or Preassignment Monitoring
6.2 Periodic Monitoring
6.3 Site-Specific Medical Monitoring
6.4 Exposure/Injury/Medical Support
6.5 Exit Physical
EPA HASP Version 3.0' This sample HASP Table of Contents reflects specific health and safety
considerations for Site "A" Other sites may address different topics in the HASP, subject to site-specific
hazards and activities
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EXHIBIT 2-3 (cont'd)
Sample HASP Table of Contents for Site "A"
7.0 FREQUENCY AND TYPES OF AIR MONITORING/SAMPLING
7.1 Direct-Reading Monitoring Instruments
7.3.1 Site Air Monitoring and Sampling Program
8.0 SITE CONTROL MEASURES
8.1 Buddy System
8.2 Site Communications Plan
8.3 Work Zone Definition
8.4 Nearest Medical Assistance
8.5 Safe Work Practices
8.6 Emergency Alarm Procedures
9.0 DECONTAMINATION PLAN
9.1 Standard Operating Procedures
9.2 Levels of Decontamination Protection Required for Personnel
9.3 Equipment Decontamination
9.4 Disposition of Decontamination Wastes
10.0 EMERGENCY RESPONSE/CONTINGENCY PLAN
10.1 Pre-Emergency Planning
10.2 Personnel Roles and Lines of Authority
10.3 Emergency Recognition/Prevention
10.4 Evacuation Routes/Procedures
10.7 Emergency Contact/Notification System
10.8 Emergency Medical Treatment Procedures
10.9 Fire or Explosion
10.10 Spill or Leaks
10.11 Emergency Equipment/Facilities
11.0 CONFINED SPACE ENTRY PROCEDURES
11.1 Definitions
11.2 General Provisions
11.3 Procedure for Confined Space Entry
11.4 Confined Space Observer (Stand-by Person)
12.0 SPILL CONTAINMENT PROGRAM
13.0 HAZARD COMMUNICATION
EPA HASP Version 3.0' This sample HASP Table of Contents reflects specific health and safety
considerations for Site "A" Other sites may address different topics in the HASP, subject to site-specific
hazards and activities.
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EXHIBIT 2-4
The Site Characterization Process
Preliminary
Evaluation
(Off-Site)
I Initial Draft of HASP
(Off-Site)
Initial Site Entry
Revision of the
HASP
On-Going
Monitoring
The sections that follow describe the phases
of site characterization and HASP development,
and provide a general guide that should be
adapted to site-specific situations. Exhibit 2-4
provides a flowchart that illustrates this process.
For additional, detailed information on HASP
development, see the Environmental Response
Team's (ERT) Health and Safety Planner (also
referred to as the generic health and safety plan),
which is a menu-driven computerized software
system designed to assist in the development,
implementation, and updating of a HASP.
2.2.1 Preliminary Evaluation
The first step in developing a HASP is to
perform a preliminary evaluation (PE) of the site's
characteristics. The PE must be accomplished off-
site, so as not to endanger the health and safety of
site workers. The purpose of the PE is to obtain
preliminary information to help identify the
specific hazards at the site and determine the
appropriate health and safety control procedures
(e.g., engineering controls, personal protective
equipment (PPE), and any additional medical
surveillance needs) that are necessary to ensure the
protection of employees who perform tasks on-site.
As set forth in 29 CFR §1910.120(c)(4), the
PE should include the following:
• Site location and size.
• Description of response activity and/or the
job to be performed.
• Duration of the planned activity.
• Site topography and accessibility.
• Site safety and health hazards expected.
• Pathways for hazardous substance
dispersion.
• Present status and capabilities of emergency
response teams that would provide
assistance for on-site emergencies.
• Hazardous substances and health hazards
expected at the site, and the chemical and
physical properties of the substances.
There are several ways in which this
information can be obtained. For example, records
of the site or interviews with persons who are
knowledgeable about the site can provide useful
information about potential hazards. Exhibit 2-5
summarizes potentially useful sources of
information. Appendix C provides a "Sample
Incident Safety Check-Off List" to serve as a quick
reference on the types of information that must be
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EXHIBIT 2-5
Sources of Site-Specific Information
Company records, receipts, worker
compensation claims, logbooks, or
ledgers.
Records and permits from federal and
state pollution control regulatory and
enforcement agencies, state Attorney
General's office, state occupational safety
and health agencies, state Fire Marshal's
office.
Interviews with personnel and their
families (all interview information should
be verified).
Generator and transporter records.
Water department and sewage records.
Interviews with nearby residents (note
possible site-related medical problems
and verify all information from interviews).
Local fire and police department records.
Court and utility company records.
Verified media reports.
Previous surveying (including soil,
ground-penetrating radar, and
magnetometer surveys), sampling, and
monitoring data.
2.2.2 Writing the Initial Draft of the
HASP
obtained prior to initial site entry, and the types of
follow-up activities that should be conducted.
In addition to interviewing knowledgeable
persons and researching the history of the site,
gathering data at the site perimeter (i.e., perimeter
reconnaissance) may help in identifying site
hazards and potential pathways for exposure and
determining the appropriate level of PPE for the
initial site entry. To identify the appropriate
monitoring techniques for perimeter reconnais-
sance, the Site Health and Safety Officer should
review the information obtained during the records
or interview research.
NOTE: Perimeter reconnaissance activities during
the PE must be conducted off-site. The site
manager must not, under any circumstances, allow
a worker to enter the site to collect information
for the PE.
Once the PE is completed and
the appropriate information
has been obtained, the
information is used to develop
the initial draft of the site-
specific HASP. The initial
draft of the HASP must
include all elements listed in Exhibit 2-2.
Specifically, it must identify each anticipated health
and safety hazard for each work operation or
activity, and describe how those hazards will be
eliminated or controlled. It must also indicate that
employees have received training and are enrolled
in a medical surveillance program. In addition, the
HASP should identify appropriate monitoring
procedures and PPE for the initial site entry. The
HASP must remain on-site at all times and only
one HASP should be developed for each site.
2.2.3 Initial Site Entry
Once the HASP has been developed and
implemented, the second stage of the site
characterization and analysis (i.e., initial site entry)
may begin. The purpose of the initial site entry is
to gather additional information and further
evaluate the site-specific risks and hazards for use
in selecting and developing appropriate
engineering controls, site controls, medical
monitoring plans, and PPE. Risks that should be
considered during the initial site entry include:
Physical hazards.
Exposure exceeding the permissible exposure
limits (PELs) and published exposure levels.
Immediately dangerous to life and health
(IDLH) concentrations.
Potential skin absorption and irritation.
Explosion sensitivity and flammability ranges.
Oxygen deficiency.
Confined spaces.
At a minimum, activities during the initial
site entry should consist of air monitoring and a
visual survey for potential hazards. Multi-media
sampling should also be performed if the site
manager has any reason to believe that soil or
water contamination may be present. Exhibit 2-6
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EXHIBIT 2-6
Initial Site Entry: Visual Inspection Checklist
Note the types of containers, impoundments,
or other storage systems:
-- Paper or wood packages.
-- Metal or plastic barrels or drums.
-- Underground tanks.
-- Aboveground tanks.
-- Compressed gas cylinders.
-- Pits, ponds, or lagoons.
Note any tags, labels, markings, or other
identifying indicators.
Note the condition of waste containers and
storage systems:
-- Sound (undamaged).
-- Visibly rusted or corroded.
-- Leaking or bulging.
-- Size and type of container.
-- Labels on containers indicating corrosive,
explosive, flammable, radioactive, or toxic
materials.
Note the physical condition of the materials:
-- Gas, liquid, or solid.
-- Color and turbidity.
-- Behavior, e.g., corroding, foaming,
vaporizing, or crystallizing.
-- Conditions conducive to splash or
contact.
Identify natural wind barriers
-- Buildings.
-- Fences.
-- Vegetation.
Determine the potential pathways of
dispersion:
-- Air.
-- Biologic routes, such as animals and food
chains.
-- Ground water.
-- Land surface.
- Surface water.
Note any indicators of potential exposure to
hazardous substances:
-- Dead fish, animals or vegetation.
-- Dust or spray in the air.
-- Fissures or cracks in solid surfaces that
expose deep waste layers.
-- Pools of liquid.
-- Gas generation or effervescence.
- Deteriorating containers.
-- Cleared land areas or possible landfilled
areas.
-- Subsiding areas indicating waste burial
locations.
Note any safety hazards. Consider:
-- Conditions of site structures.
- Obstacles to entry and exit.
-- Terrain homogeneity.
- Terrain stability.
-- Stability of stacked material.
Identify any reactive, incompatible, flammable,
or highly corrosive wastes.
Note land features.
Note the presence of any potential naturally
occurring skin irritants or dermatitis-inducing
agents, for example-
-- Poison ivy.
-- Poison oak
-- Poison sumac.
Collect samples:
-- Air (see Chapter 6, Air Monitoring).
-- Drainage ditches.
-- Soil (surface and subsurface).
-- Standing pools of liquids.
-- Storage containers
-- Streams and ponds
-- Ground water (upgradient, beneath site,
downgradient).
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provides a checklist of conditions and potential
hazards that should be noted during the initial site
entry. An accurate and comprehensive visual
survey of .the site will assist the site manager in
identifying and determining additional information
(e.g., sampling of soil or containers) that mav be
needed. For example, a visual
survey might note the
condition of waste containers
(e.g., rusted or other unusual
conditions) and identify
potential exposure pathways.
The specific monitoring requirements for
initial site entry are specified at 29 CFR
§1910.120(c)(6) and (h)(2) and are summarized in
Exhibit 2-7. Personnel entering the site should
monitor the air using direct reading instruments to
detect IDLH conditions (e.g., toxic substances) and
for ionizing radiation. Such monitoring, however,
need only be conducted if the PE produces
information that suggests: (1) the possibility of
existing IDLH conditions; or (2) the potential for
ionizing radiation. Air monitoring should also be
conducted if the information from the PE is
insufficient to reasonably conclude that neither of
these two conditions exists. When monitoring,
entry personnel should look for signs of actual or
potential IDLH hazards or other dangerous
conditions. Examples of hazards that may be
identified at a site include confined space entry,
ground subsidence, visible vapor clouds, or areas
that contain biological indicators, such as dead
vegetation. Exhibit 2-8 gives examples of
frequently used monitoring devices and exposure
limits.
The appropriate level of protection for initial
entry should be conservative, because there is often
little known information on specific hazards at that
time. Refer to Chapter 6 for additional informa-
tion on selecting appropriate levels of protection.
In addition to air monitoring, soil and water
sampling should be performed during the initial
site entry if the site manager believes
contamination may exist. Soil sampling techniques
will differ with each site; for specific sampling
strategies, refer to Volume 1 (Soil) of the Removal
Program Representative Sampling Guidance (Interim
Final). Prior to beginning site activities, it is
imperative that the purpose of the effort and the
ultimate use of the data be established. Specific
strategies should be selected based on the
EXHIBIT 2-7
Specific Monitoring Requirements for
Initial Site Entry
As specified in 29 CFR §1910.120(c)(6) and
(h)(2), the following monitoring should be
conducted at initial site entry:
• Air monitoring with direct-reading
instruments for hazardous levels of
ionizing radiation.
• Air monitoring with direct-reading test
equipment (e.g., combustible gas meters,
detector tubes) for IDLH or other
dangerous conditions.
• Visual observation for signs of actual or
potential IDLH or other dangerous
conditions.
information required. Chapter 6 provides a more
detailed discussion of monitoring techniques and
equipment.
One important goal of the initial site entry is
to identify the risks and hazards at the site so that
the work zones can be established. The three most
frequently identified zones are the Exclusion Zone.
the Contamination Reduction Zone, and the
Support Zone (also known as the clean zone).
The Support Zone should be an area of the site
that is free from contamination and that may safely
be used as a staging area for other hazardous waste
operations at the site. The Exclusion Zone is the
area with actual or potential contamination and
the highest potential for exposure to hazardous
substances. For additional information on work
zones and site control, refer to Chapter 4.
2.2.4 Revising the HASP
Once the initial site entry is completed, the
site manager is responsible for updating the HASP
to ensure that it adequately identifies any new
tasks or hazards at the site. At most sites, any
sampling performed during the initial site entry
will provide accurate information regarding the
appropriate level of PPE to be worn by site
employees and the proper designation of work
zones.
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After the initial site characterization activities
have been completed, any information concerning
the chemical, physical, and toxicological properties
of hazardous substances identified during the
initial site entry must be made available to
employees prior to the commencement of
operations at the site.
2.2.5 On-Going Monitoring
Once the HASP is revised to reflect the
information gathered during the initial site entry,
on-going monitoring may be needed to ensure that
all new hazards are identified in a timely manner
and that the appropriate controls are implemented
to protect site employees.
EXHIBIT 2-8
Atmospheric Hazard Action Guides
Monitoring Equipment
Combustible Gas
Indicator
Oxygen Level
Radiation Survey
Instrument
Colorimetric Tubes
Photoionization Detector
Flame lonization Detector
Atmospheric
Hazard3
Explosive
Gamma
Radiation
Organic &
inorganic
vapors/gases
Organic
vapors/gases
Organic
vapors/gases
Level
< 10% LELb
10-25% LEL
> 25% LEL
< 19.5%
19.5-25%
> 25%
Above
background.
< 1 mR/hr
.> 1 mR/hr
Depends on
chemical
Depends on
chemical
Depends on
chemical
Action
Continue monitoring with caution.
Continue monitoring, but with extreme caution,
especially as higher levels are encountered.
Explosion hazard! Withdraw from area
immediately.
Monitor wearing SCBA NOTE: Combustible
gas readings not valid in atmospheres with less
than 19.5% oxygen.
Continue monitoring with caution. SCBA not
needed based only on oxygen content.
Discontinue monitoring Fire potential! Consult
specialist.
Continue monitoring. Consult a health
physicist.
Withdraw. Continue monitoring only upon the
advice of a Health Physicist.
Consult reference manuals for air concentration
vs. PEL/TLV and toxicity data.
Consult reference manuals for air concentration
vs. PEL/TLV and toxicity data.
Consult reference manuals for air concentration
vs. PEL/TLV and toxicity data.
a NOTE: Hazard classes are general and not all compounds in these classes can be measured by realtime instruments.
LEL =
lower explosive limit.
NOTE: The correct interpretation of any instrument readout is difficult. If the instrument operator is uncertain of the
significance of a reading, especially if conditions could be unsafe, a technical specialist should immediately be
consulted Consideration should be given to withdrawing personnel from the area until approval by the safety officer
is given to continue operations.
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Periodic monitoring should be conducted are initiated or site conditions change. (Refer to
whenever there is any indication that exposures Exhibit 4-4 in Chapter 4 of this Guide for
have risen above the permissible exposure limits examples.) Monitoring should be conducted on
(PELs), when other dangerous conditions exist, those employees suspected of having the highest
such as the presence of flammable atmospheres or exposures to hazardous substances and health
oxygen-deficient environments, or when new tasks hazards.
FURTHER GUIDANCE: For further information on developing the written health and safety plan
and the site-specific HASP, see:
1. Characterization of Hazardous Waste Sites - A Methods Manual: Vol.II. Available Sampling
Methods, 2nd ed. (U.S. EPA, 1984, EPA 600/4-84-076).
2. EPA Health and Safety Planner: Software and User's Guide (U.S. EPA, 1990, Publication
9285.8-01).
3. EPA Health and Safety Audit Guidelines (U.S. EPA, 1989, EPA 540/G-89/010).
4. Standard Operating Guidelines for Site Entry (U.S. EPA, 1985, Publication 9285.2-01 A).
5. Standard Operating Procedures for Site Safety Planning (U.S. EPA, 1985, Publication 9285.2-05).
6. OSWER Integrated Health and Safety Standard Operating Practice (U.S. EPA, 1992,
Publication 9285.0-01).
7. Hazardous Waste Operations and Emergency Response: Uncontrolled Hazardous Waste Sites and
RCRA Corrective Action (U.S. EPA, 1991, Publication 9285.2-08FS).
8. Removal Program Representative Sampling Guidance. Volume 1 - Soil (Interim Final),
(U.S. EPA, 1991, Publication 9360.4-10).
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CHAPTER 3 TRAINING
29 CFR 1910 120(e)
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CHAPTER 3 TRAINING
3.0 INTRODUCTION
Health and safety training is an
integral part of the total health
and safety program. Site
response personnel should
receive frequent training to
maintain proficiency in using
safety equipment and know-
ledge of site safety practices. Personnel who work
at hazardous waste sites must recognize and
understand the potential hazards to health and
safety associated with the cleanup of that site.
Personnel actively engaged in cleanup activities
must be familiar with the safety programs and
procedures at the site, including the HASP and site
control measures, and must be trained to work
safely in contaminated areas. Employees may not
participate in or supervise any site activity until
they have been properly trained.
The objectives of the HAZWOPER training
program for employees engaged in hazardous waste
site activities are to:
• Educate workers about the potential health
and safety hazards they may encounter at
the site;
• Provide the knowledge and skills necessary
to minimize risk to worker health and
safety;
• Provide thorough training in the proper use
and potential limitations of safety and PPE;
and
• Ensure that workers can safely avoid or
escape from emergencies.
The HAZWOPER standards at 29 CFR
§1910.120(e) reflect a tiered approach to training.
They link the amount and type of training required
to an employee's potential for exposure to
hazardous substances and other health hazards
encountered during hazardous waste operations.
The greater the potential hazard to an employee,
the more extensive and stringent are the training
requirements. The training program should
involve both classroom instruction in a wide range
of health and safety topics, demonstrations, and
"hands-on" practice consisting of off-site drills that
simulate site activities and conditions. Any
training program for work around hazardous
substances should also incorporate on-site
experience under the direct supervision of trained,
experienced personnel. All employees are required
to complete refresher training, at least annually, to
re-emphasize the initial training and to update
workers on any new policies or procedures.
3.1 TRAINING REQUIREMENTS
3.1.1 General Training Requirements
HAZWOPER outlines a specific set of
training criteria based upon a given employee's
position, duties, and experience. The intent of the
training provisions is to provide employees with
the knowledge and skills necessary to perform
hazardous waste cleanup operations with minimal
risk to their safety and health.
The rule requires that all on-site employees
who are exposed, or potentially exposed, to
hazardous substances, health hazards, or safety
hazards receive training meeting specific
requirements before they are permitted to engage
in hazardous waste operations. This rule also
applies to site supervisors and personnel
responsible for health and safety at the site.
Employees should not be permitted to participate
in or supervise field activities until they have been
trained to a level commensurate with their job
function and responsibility.
The HAZWOPER standards specify hourly
requirements for five different categories of site
workers. These hourly training requirements, and
the requirements for each category, are discussed
in more detail in Section 3.2.
3.1.2 Site-Specific Requirements
Each employer at a site is responsible for
ensuring that their respective employees are
properly trained and equipped prior to
commencing work. HAZWOPER training must
enable site workers to identify the hazards present
on-site, the medical surveillance requirements,
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certain elements of the HASP, and operating
practices and procedures, including the use of PPE
and proper engineering controls. Exhibit 3-1
outlines the specific issues and topics that are
required to be addressed during training.
EXHIBIT 3-1
Elements to be Covered in Training
29 CFR §1910.120(e) (2) requires that health
and safety training ensure that employees are
thoroughly familiar with the following
information:
• Names of personnel and alternates
responsible for site safety and health;
• Safety, health, and other hazards
present on site;
• Use of personal protective equipment;
• Work practices by which the employee
can minimize risks from hazards;
• Safe use of engineering controls and
equipment on the site;
• Medical surveillance techniques, and
recognition of symptoms and signs that
might indicate overexposure to hazards;
• An emergency response plan meeting
the requirements for safe and effective
responses to emergencies, including all
necessary equipment;
• Confined space entry procedures;
A spill containment program; and
« Decontamination procedures.
It is also recommended that training
cover the following:
• Proper use of field equipment; and
• Employee rights and responsibilities.
First Aid.
3.2 INITIAL TRAINING REQUIREMENTS
FOR FIELD PERSONNEL
Although all employees engaged in hazardous
waste operations must receive training in health
and safety, the type of training required depends
on the employee's on-site activities and potential
for exposure to hazardous substances. Exhibit 3-2
summarizes the HAZWOPER hourly training
requirements for five categories of site workers.
Exhibit 3-3 provides a matrix of training
requirements for site personnel.
General site workers (e.g., equipment
operators, general laborers, and supervisory
personnel) engaged in hazardous substance
removal or other activities that potentially expose
workers to hazardous substances and health
hazards are required to receive at least 40 hours of
off-site instruction, as well as a minimum of 3 days
actual field experience under the direct supervision
of a trained, experienced supervisor.
Workers who are on-site only occasionally to
perform a specific limited task (e.g., ground-water
monitoring or land surveying) and who are unlikely
to be exposed to hazardous substances over their
PELs, are required to have a minimum of 24 hours
of instruction off-site and a minimum of 8 hours of
supervised field experience.
Workers regularly on-site who work in areas
where exposure levels are monitored and deter-
mined to be below PELs, and where no health or
atmospheric hazards are posed, must receive 24
hours of off-site instruction and a minimum of one
day actual field experience under the direct
supervision of a trained, experienced supervisor.
Workers with 24 hours of training who
subsequently become general site workers or whose
job requires that a respirator be worn are required
to obtain the additional 16 hours and 2 days of
training to fulfill the training requirements com-
mensurate with the new position's responsibilities.
Managers and supervisors of
the four groups of employees
described above are required
to receive the same amount of
initial training and field
experience as the employees
they supervise, plus 8
additional hours of specialized training in
managing hazardous waste operations. For
example, a supervisor that only manages employees
who work on-site occasionally must have a
minimum of 24 hours of instruction off-site and 8
hours of supervised field experience, plus an
additional 8 hours of specialized management
training. Supervisors will need to be trained in
their responsibilities under the health and safety
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EXHIBIT 3-2
Initial Training Requirements for Employees
at Uncontrolled Hazardous Waste SHes (29 CFR §1910.120(e))
Site employees
assigned site
emergency
response duties
Occasional
employees and
routine site
employees
unlikely to be
exposed above
PELs
All site workers
Trained
to a level of
competency in
addition to above
requirements
8 hours
special training
plus other
employee
requirements
40 hours
off-site
24 hours
off-site
8 hours
annual
refresher
training
8 hours
field
experience
24 hours
field
experience
program, the PPE program, the medical surveil-
lance program, and the emergency response plan.
Visitors to the site are not required to have
completed any specific training in health and
safety, although it is strongly recommended that
they be familiar with the hazards on-site as well as
PPE, decontamination procedures, and the site
emergency plan. Site visitors may not enter any
hazardous area (e.g., exclusion or decontamination
zones) without the proper training.
Although there are no specific training
requirements for on-site employees with emergency
response duties for that site, such employees must
be trained commensurate with the duties that will
be assumed.
3.3 EQUIVALENT AND REFRESHER
TRAINING
Some of the training requirements specified
above may be waived if the employee has had prior
work experience or training. For example, certain
training requirements may be waived if the
employee has had experience working at an
uncontrolled hazardous waste site or if the
employee has participated in training courses
offered by independent or federal organizations
(e.g., EPA). If the employer believes that an
employee has sufficient prior experience or
training to waive some or all of the HAZWOPER
training requirements, the employer must
document the basis for this belief, describing the
length and type of experience or training.
Equivalent training may include any relevant
academic training or the training that may have
been gained from actual hazardous waste site work
experience. Certified employees new to a site,
however, must receive appropriate site-specific
training before site entry.
All employees who perform cleanup
operations at uncontrolled hazardous waste sites,
including managers and supervisors, must receive
a minimum of 8 hours of annual refresher training.
The purpose of refresher training is to maintain
certain competencies essential for ensuring a safe
work environment. Attendance at applicable
seminars and critiques of actual responses are also
acceptable methods of satisfying the annual
refresher training requirements. Proper documen-
tation of attendance should be maintained in each
employee's personnel file to confirm that every
27
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EXHIBIT 3-3
Recommended Training by Job Category
TRAINING TOPIC
Biology, Chemistry, and
Physics of Hazardous Materials
Toxicology
Industrial Hygiene
Monitoring Equipment
Hazard Evaluation/Recognition
Site Safety Plan
Standard Opeipting Procedures
Engineering Controls
Personal Protective Clothing
and Equipment (PPE)
Medical Program
Decontamination
Legal and Regulatory Aspects
Emergencies/Accidents
Hazard Communication
General On-site Health
Site Management & & Safety
EMPHASIS OF TRAINING Worker Supervisors Staff
Chemical and physical properties; chemical reactions;
chemical compatibilities.
Dosage, exposure routes, toxicity, IDLH values, PELs,
recommended exposure limits (RELs), TLVs.
Monitoring workers' need for and selection of PPE.
Calculation of doses and exposure levels; hazard evaluation;
selection of worker health and safety protective measures.
Selection, use, capabilities, limitations, and maintenance.
Techniques of sampling and assessment.
Evaluation of field and lab results.
Chemical/Physical
Risk assessment.
Safe practices, safety briefings and meetings, Standard
Operating Procedures, site safety map.
Hands-on practice.
Development and compliance.
The use of barriers, isolation, and distance to minimize
hazards.
Assignment, sizing, fit-testing, maintenance, use, limitations,
and hands-on training.
Selection of PPE.
Medical monitoring, first aid, stress recognition.
CPR and emergencies drills.
Design and planning.
Implementation.
Hands-on training using simulated field conditions.
Design and maintenance.
Applicable safety and health regulations (OSHA, EPA)
Emergency help, self-rescue, drills, alarms, reporting.
Emergency response, investigation and documentation.
Per 29 CFR §1910.200 and §1926.59 (as applicable)
Employee Rights
/
/
O
O
/
/
O
/
/
/
O
/
/
/
J
0
J
/
s
O
/
O
/
/
/
/
/
/
/
/
/
/
O
J
/
/
/
/
/
s
s
0
/
/
J
J
/
/
/
/
s
s
s
s
s
s
s
s
s
s
s
s
/
s
s
s
s
s
s
s
s
s
s
s
s
/
/ = Recommended training O = Optional
28
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person assigned to a task has had adequate
training for that task, and that each employee has
participated in refresher training activities.
3.4 TRAINER QUALIFICATIONS AND
CERTIFICATION
Trainers must be adequately qualified to
instruct employees about the subject matter that is
being presented in training. Such trainers must
satisfactorily complete a training program for
teaching the subjects they are expected to teach, or
they must have the academic credentials and
instructional experience necessary for teaching the
subjects. Instructors are required to demonstrate
competent instructional skills and knowledge of
the applicable subject matter.
Employees and supervisors who have received
and successfully completed the required training
and field experience must be certified by their
instructor or trained supervisor as having
successfully completed the necessary training. A
written certificate must be given to each person as
proof of his or her certification (although
certification may only signify attendance, and not
competency). Any person who has not been
certified or who does not meet the requirements
may not participate in hazardous waste operations
at the site.
FURTHER GUIDANCE: For more information on employee training requirements and programs,
see:
1. Hazardous Materials Incident Response Training (HMIRT) Program: Course Schedule.
Write to: U.S. EPA/ERT, 26 West Martin Luther King, Cincinnati, OH 45268
or Call: (513) 569-7537 or FTS 684-7537
The HMIRT program is designed for emergency responders and personnel who investigate and clean
up uncontrolled hazardous waste sites. The HMIRT program has a curriculum of 12 courses that
provide specific training in worker health and safety and in various technical operations that must be
performed by site personnel engaged in hazardous materials response activities.
2. National Institute for Environmental Health Sciences (NIEHS) Worker Health and Safety Training
Programs. Write to: The National Clearinghouse on Occupational and Environmental Health,
c/o Workplace Health Fund, 815 16th Street NW, Suite 301, Washington DC, 20006
or Call: (202) 842-7833
The National Clearinghouse, established by NIEHS, provides information and support services for
occupational and environmental health education. The Clearinghouse can provide information about
training programs across the country funded by NIEHS Federal training grants.
3. National Institute for Environmental Health Sciences (NIEHS) Training Grant Program, Technical
Workshop on Training Quality Report: Minimum Criteria for Worker Health and Safety
Training for Hazardous Waste Operations and Emergency Response (1990).
4. "Accreditation of Training Programs for Ha/ardous Waste Operations," Proposed Standard,
(55 FR 2776, January 26, 1990).
29
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CHAPTER 4 SITE CONTROL
o o o
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CHAPTER 4 SITE CONTROL
4.0 INTRODUCTION
As an essential element of the HASP, the site
control program is used to control the activities
and movement of people and equipment at
hazardous waste sites in order to minimize the
potential for worker exposure to hazardous
substances. The provisions at 29 CFR
§1910.120(d) require that an appropriate site
control program be developed prior to the
implementation of response operations. Although
the degree of site control necessary for the
protection of workers depends largely on site-
specific characteristics (e.g., site size, nature of
contamination, etc.), 29 CFR §1910.120(d)(3)
identifies some essential elements of an effective
site control program. These elements are
highlighted in Exhibit 4-1.
The site control program should be
established during the planning stages of a
hazardous waste operation. It should be modified
as new information becomes available, perhaps as
a result of the initial site entry or subsequent site
assessments. The appropriate sequence for
implementing site control measures should be
determined on a site-specific basis; however, it may
be necessary to implement several measures
concurrently. The remainder of this chapter
provides more detail of each of the basic
components of a site control program.
4.1 DEVELOPMENT OF THE SITE MAP
of the site control
a map of the
As part
program
hazardous waste site should be
developed. The site map
represents a central source of
information about the site,
including the geographic layout
and the hazards present at the site. The purpose
of the site map is to assist site personnel in
planning and organizing response activities.
Exhibit 4-2 presents an example of a site map.
The site map should be developed prior to
the initial site entry using information obtained
during the preliminary evaluation. The map
should include the following information:
prevailing wind direction, site drainage points, all
natural and man-made topographic features
including the location of buildings, containers,
impoundments, pits, ponds, tanks, and any other
site features. Site maps should be updated often
during the course of site operations to reflect:
• New information, such as information
gained after initial site entry or from
subsequent sampling and analysis activities;
or
EXHIBIT 4-1
Communications
Network
The Site Control
Program
Worker Safety
Procedures
Nearby Medical
Facilities
33
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EXHIBIT 4-2
Sample Site Map
Former
Emergency Holding
Basin
o o o
/ (Partially Buried Drums)
O O O
34
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• Changes in site conditions, including changes
resulting from accidents, ongoing site
operations, hazards not previously identified,
new materials introduced on-site,
unauthorized entry or vandalism, or weather
conditions.
As new information is added to the site map, use
of overlays and other mapping techniques may
reduce the potential cluttering of information.
4.2 ESTABLISHMENT OF WORK ZONES
AT THE SITE
One of the basic elements of
an effective site control
program is the delineation of
work zones at the site. This
delineation specifies the type
of operations that will occur in
each zone, the degree of
hazard at different locations within the site, and
the areas at the site that should be avoided by
unauthorized or unprotected employees.
Specifically, the purpose of establishing work zones
is to:
• Reduce the accidental spread of hazardous
substances by workers or equipment from
the contaminated areas to the clean areas;
• Confine work activities to the appropriate
areas, thereby minimizing the likelihood of
accidental exposure; and
• Facilitate the location and evacuation of
personnel in case of an emergency.
When establishing the work zones at a site,
information from on-site and off-site data
collection efforts should be compiled in a format
that facilitates a decision concerning the placement
of work zones. The site map, as discussed above,
can provide a useful format for compiling the
relevant data. The locations of all potential
hazards that were identified through the
interview/records research, the perimeter
reconnaissance, and the initial on-site survey
should be plotted on the site map. The site map
should also indicate both observed and suspected
hazards, on- and off-site air and soil sampling
results, and potential exposure pathways. It is
important to remember that the absence of
sampling results should not be considered evidence
that an area is clean.
Although a site may be divided into as many
zones as necessary to ensure minimal employee
exposure to hazardous substances, the three most
frequently identified zones are the Exclusion Zone
(or "hot zone"), the Contamination Reduction
Zone (CRZ), and the Support Zone (or "clean
zone"). Movement of personnel and equipment
between these zones should be minimized and
restricted to specific access control points to
prevent cross-contamination from contaminated
areas to clean areas. Exhibit 4-3 illustrates the
three most commonly designated work zones. A
description of each work zone, and the factors to
be considered when establishing them, are
provided below.
4.2.1 The Exclusion Zone
The Exclusion Zone is the area where
contamination is either known or expected to
occur and the greatest potential for exposure
exists. The outer boundary of the Exclusion Zone,
called the Hotline, separates the area of
contamination from the rest of the site. The
Hotline should initially be established by visually
surveying the site and determining the areal extent
of hazardous substances, discoloration, or any
drainage, leachate, or spilled material present.
Other factors to consider in establishing the
Hotline include:
• Providing sufficient space to protect
personnel outside the zone from potential
fire or explosion;
• Allowing an adequate area in which to
conduct site operations; and
• Reducing the potential for contaminant
migration.
The Hotline should be physically secured
(e.g., using chains, fences, or ropes) or clearly
marked (e.g., using lines, placards, hazard tape,
and/or signs). During subsequent site operations,
the boundary may be modified and adjusted as
more information becomes available. In addition,
the Exclusion Zone may also be subdivided into
different areas of contamination based on the
known or expected type and degree of hazards or
the incompatibility of waste streams. If the Exclu-
35
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EXHIBIT 4-3
Illustration of Typical Work Zones
Estimated Boundary
Of Area With Highest
Contamination
Contamination
Reduction Corridor
Contamination
Reduction Zone
Command Post
i •
Contamination \ • \ • \'
Control Une | ] (. \
Prevailing wind direction
Note: Area dimensions not to scale. Distances between points may vary.
sion Zone is subdivided in this manner, additional
demarcations (e.g., "Hazards Present" or
"Protection Required") may be necessary.
Access to and from the Exclusion Zone
should be restricted to Access Control Points at
the Hotline. Access Control Points are used to
regulate the flow of personnel and equipment into
and out of the contamination area and to verify
that site control procedures are followed. Separate
entrances and exits should be established to
separate personnel and equipment movement into
and out of the Exclusion Zone. If the Exclusion
Zone is subdivided, additional Access Control
Points may be necessary to ensure minimal
employee exposure.
All persons who enter the Exclusion Zone
must wear the appropriate level of PPE for the
degree and types of hazards present at the site. If
the Exclusion Zone is subdivided, different levels
of PPE may be appropriate (see Chapter 5 for
more information on PPE). Each subarea of the
Exclusion Zone should be clearly marked to
identify the hazards and the required level of PPE.
4.2.2 The Contamination Reduction Zone
(CRZ)
As the transition area between the Exclusion
Zone ("hot zone") and the Support Zone ("clean
zone"), the CRZ is the area in which decontam-
ination procedures take place. The purpose of the
CRZ is to reduce the possibility that the Support
Zone will become contaminated or affected by the
site hazards. Because of both distance and
decontamination procedures, the degree of
contamination in the CRZ generally will decrease
as one moves from the Hotline to the Support
Zone.
Initially, the CRZ should be established
outside the areas of contamination. Contamin-
ation Reduction Corridors, which are Access
36
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Control Points between the Exclusion Zone and
the CRZ, should be established for both personnel
and heavy equipment. These corridors should
consist of an appropriate number of
decontamination stations necessary to address the
contaminants at a particular site (see Chapter 9 for
more information on decontamination procedures).
In some cases, the scale of response operations
may require more than two Contamination
Reduction Corridors.
The Contamination Control Line marks the
boundary between the CRZ and the Support Zone
and separates the clean areas of the site from those
areas used to decontaminate workers and
equipment (i.e., partially contaminated areas).
Access Control Points between the CRZ and the
Support Zone must be established to ensure that
workers entering the CRZ are wearing the proper
PPE and that workers exiting the CRZ to the
Support Zone remove all potentially contaminated
PPE.
4.2.3 The Support Zone
The Support Zone is the uncontaminated
area where workers are unlikely to be exposed to
hazardous substances or dangerous conditions.
The Support Zone is the appropriate location for
the command post, medical station, equipment and
supply center, field laboratory, and any other
administrative or support functions that are
necessary to keep site operations running
efficiently. Because the Support Zone is free from
contamination, personnel working within it may
wear normal work clothes, and access to and from
the area is not restricted to authorized site
personnel. Any potentially contaminated clothing,
equipment, and samples must remain outside of
the Support Zone until decontaminated. However,
all personnel located in the Support Zone must
receive instruction in the proper evacuation
procedures in case of a hazardous substance
emergency.
Designation of the Support Zone should be
based on all available site characterization data.
One of the most important criteria for the
selection of the Support Zone is that it must be
located in a clean area. That is, the Support Zone
should be in an area that is known to be free of
elevated (i.e., higher than background)
concentrations of hazardous substances.
Monitoring should be conducted to confirm that
the area considered for the Support Zone does not
contain concentrations of hazardous substances
that pose health risks (see Chapter 6 for details on
air monitoring procedures). When evaluating on-
site concentrations of hazardous substances, it is
important to consider the background
concentrations of these substances in the area. In
some cases, non-zero (low-level) background
concentrations of hazardous substances may be
encountered.
The size and position of the Support Zone
may be directly affected by the size of the exclusion
and contamination reduction zones. For example,
the Support Zone may be constrained by the
distances needed to prevent an explosion or fire
from affecting personnel outside the Exclusion
Zone, or the physical area required for activities
within the Exclusion Zone. In addition, the
Support Zone should be upwind and as far from
the Exclusion Zone as practicable. Whenever
possible, line-of-sight contact with all activities in
the Exclusion Zone should be maintained, and
accessibility to support services (e.g., power lines,
access roads, telephones, shelter, and water) should
be maximized. The expected duration of response
operations may also affect the placement of work
zones.
4.2.4 Ensuring Integrity of the Support
Zone
It is conceivable that the Support Zone may
inadvertently become contaminated after site
remediation begins. For example, changes in wind
speed and direction, temperature, and rainfall may
result in exposures different from those
experienced during the initial on-site survey.
Therefore, the integrity of the Support Zone
should be reconfirmed during response operations.
Several procedures can be used to ensure that
the area chosen for the Support Zone remains
clean during removal or remedial operations.
First, the strict use of site controls will minimize
the transfer of contamination to the Support Zone.
In addition, periodic monitoring of the Support
Zone will indicate whether changes in site
activities or conditions have resulted in
contamination. In the event that contamination
has occurred, the boundaries of work zones should
be reevaluated and, if appropriate, realigned.
Procedures used to maintain work zone integrity
are described below.
37
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Use of Site Controls. The CRZ is designed
to reduce the probability that the clean Support
Zone will become contaminated or affected by
other site hazards. The distance between the
Exclusion and Support Zones provided by the
CRZ, together with decontamination of workers
and equipment, limits the physical transfer of
hazardous substances into clean areas. The
Contamination Control Line, which separates the
Support Zone from areas of potential
contamination, should include two Access Control
Points, if feasible: one for personnel and one for
equipment. Persons entering the CRZ should be
required to wear PPE appropriate for the types
and degree of hazards they may encounter when
working in this area. To re-enter the Support
Zone from the CRZ, workers should remove gross
contamination, remove any protective clothing,
leave equipment in the CRZ, and exit through the
personnel Access Control Point.
Periodic Monitoring of Support Zone. A
monitoring and sampling program for the Support
Zone should be established to ensure that this area
remains free from contamination. Monitoring
should take place on a routine basis and whenever
exposure is likely to have changed. The
monitoring and sampling activities that may be
conducted periodically to ensure that the Support
Zone remains clean include:
• Air monitoring using direct-reading
instruments.
• Collecting air samples for paniculate, gas,
and vapor analysis.
• Analysis of soil samples from areas of
heavy traffic.
• Swipe tests in trailers and other areas used
by personnel.
Increased concentrations of hazardous
substances in air, soil, or other environmental
media may indicate a breakdown in site control
procedures or a change in on-site conditions. Site
personnel should be constantly alert to changes in
site conditions or the presence of any potentially
dangerous situations. Certain site activities may
increase the potential for exposure to hazardous
substances and, therefore, may indicate a need for
additional monitoring. These situations are listed
in Exhibit 4-4.
EXHIBIT 4-4
Additional Monitoring Requirements
(29 CFR §1910.120(h)(3))
As specified in 29 CFR §1910.120(h)(3),
situations where additional monitoring may be
appropriate include:
• When work begins on a different portion
of the site;
• When contaminants other than those
previously identified are being handled;
• When a different type of operation
begins (e.g., drum opening as opposed
to exploratory well drilling); and
• When employees are handling leaking
drums or containers or working in areas
with obvious liquid contamination (e.g.,
a spill or lagoon).
Additional Site Characterization Inform-
ation. Additional information concerning locations
of contaminated environmental media may become
available during monitoring or in the later stages
of site investigation and cleanup, particularly for
remedial actions. For example, more detailed soil
sampling will likely occur during the site inspection
and remedial investigation. This additional
information may indicate that areas initially
thought to be clean are, in fact, contaminated.
The location of the Support Zone should be re-
evaluated whenever new site characterization
studies are conducted.
4.3 ORGANIZATION OF WORKERS
USING THE BUDDY SYSTEM
When carrying out activities in
the Exclusion Zone, workers
should use the buddy system to
ensure that rapid assistance
can be provided in the event of
an emergency. The buddy
system is an approach used to
organize workers into workgroups so that each
worker is designated to be observed by at least one
other worker. During initial site entry, it may be
appropriate to utilize a buddy system in which two
workers are assigned to provide safety backup.
38
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The site manager, who is responsible for
enforcing the buddy system, should implement the
system at the Access Control Point for personnel
entering the Exclusion Zone. This location
represents the most logical point to enforce the
buddy system as the Site Manager is stationed in
the CRZ and all personnel who enter the
contaminated area are required to pass through the
Access Control Point.
As part of the buddy system, workers should
remain close together and maintain visual contact
with each other to provide assistance in the event
of an emergency. Should an emergency situation
arise, workers should use the communication
signals established and agreed upon prior to
entering the contaminated area (see Section 4.4
below). In general, the responsibilities of workers
utilizing the buddy system include:
• Providing his or her partner with assistance;
• Observing his or her partner for signs of
chemical or heat exposure;
• Periodically checking the integrity of his or
her partner's personal protective
equipment; and
• Notifying the site manager or other site
personnel if emergency assistance is needed.
Workers should not rely entirely on the
buddy system to ensure that help will be provided
in the event of an emergency. To augment this
system, workers in contaminated areas should
remain in line-of-sight or communication contact
with the command post or site manager at all
times.
4.4 ESTABLISHMENT OF A
COMMUNICATION NETWORK AND
PROCEDURES
Communication systems should
be established at a site for
both internal and external
communication. Internal
communication refers to
communication between
workers operating in the
Exclusion Zone or CRZ, or to communication
from the Command Post to these workers.
Internal communication is generally used to:
• Alert team members to emergency
situations;
• Convey safety information (e.g., air time
remaining in SCBA, heat stress check,
hazards detected);
• Communicate changes in the work to be
accomplished; and
• Maintain site control.
An internal communication system may be
established using standard communication devices
such as radio, noisemakers, or visual signals
(Exhibit 4-5 lists several common internal
communications devices). All communication
devices used in a potentially explosive atmosphere
must be intrinsically safe (i.e., not capable of
sparking) and should be checked daily to ensure
that they are operating properly. Because verbal
communication at a site can be difficult as a result
of on-site background noise and the use of PPE
(e.g., speech transmission through a respirator can
be poor), pre-arranged commands and audio or
visual cues should be developed prior to entering
the Exclusion Zone. A secondary set of non-verbal
signals should be established for use when
communication devices fail or when emergency
situations occur (see Chapter 11 for procedures on
communication during emergency situations).
EXHIBIT 4-5
Examples of
Internal Communication Devices
Radio, including FM and Citizens Band;
Noisemakers, including bells,
compressed air horns, megaphones,
sirens, or whistles; and
Visual Signals, including flags, flare or
smoke (only used in the Support Zone),
hand signals, lights, signal boards, and
whole body movements.
Effective internal communication also
requires the identification of individual workers so
that commands can be addressed to the right
worker. The worker's name should be marked on
39
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the suit and, for long-distance identification, color
coding, numbers, or symbols can be added. Flags
may be used to help locate personnel in areas
where visibility is poor due to obstructions such as
accumulated drums, equipment, or-waste piles.
External communication refers to
communication between on-site and off-site
personnel. An external communication system
must be maintained in order to: (1) coordinate
emergency response efforts with off-site
responders; (2) report progress or problems to
management; and (3) maintain contact with
essential off-site personnel. The primary means of
external communication are telephone and radio.
If telephone lines are not installed at a site, all
team members should know the location of the
nearest telephone to the site, and the correct
change and necessary telephone numbers should be
made readily available in the Support Zone. If a
radio is used, its location should be clearly marked.
Clear instructions for its use should be posted with
the radio at all times.
4.5 WORKER SAFETY PROCEDURES
As part of the site control
plan, procedures must be
established to ensure worker
safety. Worker safety pro-
cedures include preparation of
the site for response activities,
engineering controls and safe
work practices, and other standing orders to be
followed at all times during site operations.
Worker safety procedures should be prepared by
certified safety professionals in advance of on-site
response operations. These procedures should be
made available to workers involved in site
activities. All workers should be briefed frequently
on their use.
4.5.1 Site Preparation
Prior to undertaking response activities, time
and effort must be spent in preparing a site for
clean-up activities to ensure that response
operations go smoothly and that worker safety is
ensured. Because site preparation can be as
hazardous as site cleanup, personnel should place
high priority on safety measures at this stage of
site operations. Prior to undertaking on-site
response operations, the following site preparation
activities should be performed:
• Construct roadways to provide a sound
roadbed for heavy equipment and vehicles
and arrange traffic patterns to provide ease
of access and to ensure safe and efficient
operations;
• Eliminate physical hazards from the site to
the greatest extent possible, including:
ignition sources in flammable hazard
areas;
exposed or ungrounded wiring, and
low overhead wiring that may
entangle equipment;
sharp or protruding edges (e.g., glass,
nails, torn metal, etc.) that may
puncture protective clothing and
equipment or inflict puncture wounds;
debris, holes, loose steps or flooring,
protruding objects, slippery surfaces,
or unsecured railings, that can cause
falls, slips, or trips, or obstruct
visibility;
unsecured objects, such as bricks and
gas cylinders near the edge of elevated
surfaces such as catwalks, roof tops,
and scaffolding, that may dislodge and
fall on workers;
• Install skid-resistant strips and other anti-
skid devices on slippery surfaces;
• Construct operation pads for mobile
facilities and temporary structures, loading
docks, processing and staging areas, and
decontamination pads;
• Provide adequate illumination for work
activities. Equip temporary lights with
protective guards to prevent accidental
contact; and
• Install wiring and electrical equipment in
accordance with the National Fire Code.
4.5.2 Engineering Controls and Safe
Work Practices
Engineering controls and safe work practices
must be specified in the site control program to
protect employees from exposure to hazardous
substances and other safety and health hazards.
Engineering controls and safe work practices
40
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should be implemented to reduce and maintain
employee exposure levels at or below the
permissible exposure levels (PELs) and published
exposure levels for those hazardous substances at
the site. Examples of engineering controls that
may be used include pressurized cabins or control
booths on equipment. Safe work practices include
such activities as removing nonessential personnel
from potential exposure during drum openings,
wetting down dusty operations, and locating
employees upwind of potential hazards. If, for
whatever reason, it is not possible to maintain
employee exposure to levels at or below PELs,
technical assistance should be obtained before
proceeding with site activities (e.g., consult EPA's
Environmental Response Team (ERT) or OSHA).
Use of PPE should be a last resort to protect
employees against possible exposure to hazardous
substances. It should be used only when
engineering controls and safe work practices are
insufficient to adequately protect against exposure.
The PPE used at a site must reflect the potential
on-site hazards identified during the PE and site
characterization (see Chapter 5 for detailed
information on using PPE).
4.5.3 Standing Orders
^DANGER,
NO
SMOKING
Standing orders should be
established at a site to
maintain a strong safety
awareness and to enforce safe
work practices. These orders
typically are developed for the
Exclusion Zone. If the hazards
are sufficiently different, standing orders should be
developed for the CRZ as well. Standing orders
refer to those safety procedures that must always
be followed when operating in contaminated areas.
Examples of standing orders are provided in
Exhibit 4-6.
To ensure that all workers are informed of
the standing orders, they should be: (1) distributed
to everyone who enters the site; and (2) posted
conspicuously at the Command Post and at the
entrance Access Control Points into the CRZ
and/or the Exclusion Zone. In addition, the site
manager should review the standing orders at each
daily safety briefing and workers should be
informed immediately of any new or revised
procedures.
EXHIBIT 4-6
Examples of Standing Orders
Report any signs of
radioactivity, explosivity, or
unusual conditions to your
supervisor immediately
No Smoking, Eating,
Drinking, or Open Flame
in the Exclusion Zone or
Contamination Reduction Zone
Check in at the entrance
Access Control Point before
entering the Exclusion Zone
Always wear SCBA while
in the Exclusion Zone
J
Maintain close contact
with your buddy
in the Exclusion Zone
Check out at the exit
Access Control Point before
leaving the Exclusion Zone
1
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In addition to the procedures identified in
the standing orders, a hazardous substance
information form should be developed that lists
the names and properties of all hazardous
substances present at the site. This information
should be conspicuously posted along with the
standing orders. Finally, workers should be briefed
on the site's hazardous substances when they first
join the response team and when new substances
are identified on-site.
4.6 IDENTIFICATION OF NEAREST
MEDICAL ASSISTANCE
As part of the site control
program, the site manager
must post the identification
and location of the nearest
medical facilities where
response personnel can receive
assistance in the event of an
emergency. Medical facilities typically include area
hospitals, emergency clinics, on-call physicians,
medical specialists, or emergency, ambulance, fire,
and police services. Information to be maintained
on the medical facilities should include the names,
phone numbers, addresses, and procedures for
contacting the facilities. Maps and directions to
the medical facilities should also be provided. This
information should be posted conspicuously
throughout the site, as well as near telephones or
other external communication devices.
Furthermore, all managers and individuals likely to
become involved in medical response at the site
should know the directions to the nearest medical
facility. The staff at the designated facilities, as
well as local Emergency Response personnel,
should be aware of site activities and potential
hazards prior to any site activity.
FURTHER GUIDANCE: For more information on developing and implementing site controls, see:
1. Establishing Work Zones at Uncontrolled Hazardous Waste Sites (U.S. EPA, 1991, Publication
9285.2-06FS).
2. Standard Operating Guidelines for Establishing Work Zones (U.S. EPA, 1985, Publication
9285.2-04A).
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CHAPTER 5 PERSONAL PROTECTIVE EQUIPMENT
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CHAPTER 5 PERSONAL PROTECTIVE EQUIPMENT
5.0 INTRODUCTION
Vapors, gases, and particulates
from hazardous waste site
activities place response
personnel at risk. For this
reason, site personnel must
wear appropriate personal
protective clothing and
equipment (PPE) whenever
they are near the site. The
purpose of PPE is to shield or
isolate individuals from the
chemical, physical, and biologic
hazards that may be
encountered on-site. No single combination of
protective clothing and equipment, however, is
capable of protecting against all hazards; therefore,
PPE should be used in conjunction with (not in
place of) engineering controls and safe work
practices. The effectiveness of the PPE program
should be evaluated regularly.
The two basic objectives of any PPE program
should be to protect the wearer from safety and
health hazards, and to prevent injury to the wearer
from incorrect use and/or malfunction of the PPE.
To accomplish these goals, §1910.120(g)(5) of the
HAZWOPER standards requires a comprehensive
PPE program as part of the site-specific HASP.
Exhibit 5-1 lists the main components of a PPE
program. Exhibit 5-2 lists the other regulations
where OSHA has incorporated standards for PPE.
5.1 SELECTING THE LEVEL OF PPE
As required by HAZWOPER, PPE must
protect employees from the specific hazards they
are likely to encounter on-site. Selection of the
appropriate PPE is a complex process that should
take into consideration a variety of factors. Key
factors might include: (1) identification of the
hazards or suspected hazards; (2) potential
exposure routes (e.g., inhalation, skin absorption,
etc.); and (3) the performance of the PPE
materials and seams in providing a barrier to these
hazards.
The amount of protection offered by a
particular type of PPE is material/hazard-specific.
EXHIBIT 5-1
Elements of the PPE Program
(29 CFR §1910.120(g) (5))
PPE selection based upon site hazards.
PPE use and equipment limitations.
Work mission duration.
PPE maintenance and storage.
PPE decontamination and disposal.
PPE training and proper fitting.
PPE donning and doffing procedures.
PPE inspection procedures
Evaluation of program effectiveness.
Limitations due to external or medical
conditions.
That is, certain types of PPE will protect well
against some hazards and poorly, or not at all,
against others. Other factors in the selection
process include matching the PPE to the
employee's work requirements and task-specific
conditions. The durability of the PPE material, as
well as its performance in extreme heat or cold,
must also be considered.
Several guidelines and data bases exist that
provide information on protective clothing (e.g.,
Guidelines for the Selection of Chemical
Protective Clothing, and the Chemical Protective
Clothing Performance Index). The National Fire
Protection Association (NFPA) also issues
information and standards (e.g., NFPA 1991:
Stand on Vapor-Protection Suits for Hazardous
Chemical Emergencies). These standards and
guides provide data on chemical resistance, design
and construction application, reuse and costs. The
NFPA standards also provide information on
flammability resistance.
The more that is known about the hazards at
the site, the easier it becomes to select PPE. As
more information about the hazards and conditions
at the site becomes available, the site manager can
make decisions to upgrade or downgrade the level
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EXHIBIT 5-2
Additional Regulations
Incorporated by OSHA for
Personal Protective Equipment
29 CFR 1910.120: Hazardous Waste
Operations and Emergency Response
29 CFR 1910.132: 41 CFR 50-204.7 (General
Requirements for Personal Protective
Equipment
29 CFR 1910.133(a): ANSI* Z87.1-1968 (Eye
and Face Protection)
29 CFR 1910.134: ANSI Z88.2-1969
(Standard Practice for Respiratory Protection)
29 CFR 1910.135: ANSI Z89.1-1969
(Safety Requirements for Industrial Head
Protection)
10 CFR 1910.136: ANSI Z41.1-1967
(Men's Safety Toe Footwear)
29 CFR 1926.100:
29 CFR 1926.101:
29 CFR 1926.102:
29 CFR 1926.103:
Head Protection
Hearing Protection
Eyes and Face Protection
Respiratory Protection
American National Standards Institute
1430 Broadway, New York, NY 10018
5.1.1 Level A
Level A protection is required when the
greatest potential for exposure to hazards exists,
and when the greatest level of skin, respiratory,
and eye protection is required. The following are
examples of appropriate Level A equipment:
positive pressure, full face-piece self-contained
breathing apparatus (SCBA) or positive pressure
supplied air respirator with escape SCBA; totally-
encapsulating chemical-protective suit; inner
and/or outer chemical-resistant gloves; and
disposable protective suit, gloves, and boots.
Meeting any of the following criteria warrants
use of Level A protection:
• Hazardous substances have been identified
and require the highest level of protection
for skin, eyes, and the respiratory system;
• The atmosphere contains less than 19.5
percent oxygen;
• Site operations involve a high potential for
splash, immersion, or exposure to
unexpected materials that are harmful to
the skin;
• Operations are being conducted in
confined, poorly ventilated areas, and the
absence of hazardous substances has not yet
been determined; or
• Direct-reading instruments indicate high
levels of unidentified vapors or gases in the
air.
of PPE protection to match the tasks at hand and
the site hazards. One method of selecting the
appropriate level of PPE is to use a numerical
criterion - the total atmospheric vapor/gas
concentration. Exhibit 5-3 outlines the level of
PPE required for different ranges of vapor/gas
concentrations. (Chapter 6 provides more detailed
information on using action levels to select
appropriate levels of protection.)
The following sections present additional
guidelines for selecting the appropriate level of
PPE. Exhibit 5-4 provides examples of typical
protective clothing, and Exhibit 5-5 provides
sample protective ensembles for each of the four
levels of protection (i.e., levels A-D).
EXHIBIT 5-3
Suggested Action Levels for PPE*
Level of
Protection
A
B
C
D
Action Level
(in ppm above background)
500 to 1 ,000 ppm
5 to 500 ppm
Background to 5 ppm
N/A
Note that action levels for PPE based on vapor
concentration are only 1or situations where the identity
of the vapor or gas constituents are unknown. They
do not address IDLH environments. Refer to Section
6.9 for more information.
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EXHIBIT 5-4
Typical Protective Clothing
Body Part
Protected
Type of Clothing
Type of Protection and Precautions
FULL BODY
Fully-encapsulating suit (one-piece
garment. Boots and gloves may
be integral, attached and
replaceable, or separate).
Protects against gases, dusts, vapors,
and splashes. Does not allow body heat
to escape. May contribute to heat stress
in wearer.
Non-encapsulating suit (jacket,
hood, pants, or bib overalls, and
one-piece coverall).
Protects against splashes, dust, and
other materials but not against gases
and vapors. Does not protect parts of
head and neck. Do not use where gas-
tight or pervasive splashing protection is
required.
Aprons, leggings, and sleeve
protectors (may be integral or
separate). Often worn over non-
encapsulating suit.
Provides additional splash protection of
chest, forearms, and legs. Useful for
sampling, labeling, and analysis
operations.
Radiation-contamination protective
suit.
Protects against alpha and beta
particles. Does NOT protect against
gamma radiation. Designed to prevent
skin contamination.
Flame/fire retardant coveralls
(normally worn as an
undergarment).
Provides protection from flash fires. May
exacerbate heat stress.
HEAD
Safety helmet (hard hat, made of
hard plastic or rubber). May
include a helmet liner to insulate
against cold.
Protects the head from blows, must
meet OSHA requirements at 29 CFR
§1910.135.
Hood (commonly worn over a
helmet).
Protects against chemical splashes,
participates, and rain.
Protective hair covering.
Protects against chemical contamination
of hair, prevents hair from tangling in
equipment, and keeps hair away from
respiratory devices.
EYES & FACE
Face shield (full-face coverage,
eight-inch minimum) or splash
hood.
Protects against chemical splashes, but
does not protect adequately against
projectiles. Provides limited eye
protection.
Safety glasses.
Protects eyes against large particles and
projectiles.
Goggles.
Depending on their construction, can
protect against vaporized chemicals,
splashes, large particles, and projectiles.
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EXHIBIT 5-4
Typical Protective Clothing (cont'd)
Body Part
Protected
EARS
^ ) Qj
HANDS & ARMS
FEET
H
j ^ — ,
U, J
Type of Clothing
Ear plugs and muffs.
Headphones (radio headset with
throat
microphone).
Gloves and sleeves (may be
integral, attached, or separate from
other protective clothing).
Chemical-resistant safety boots.
Steel-shank or steel-toe safety
boots.
Non-conductive or spark-resistant
safety boots.
Disposable shoe or boot covers
(slips over regular foot covering).
Type of Protection and Precautions
Protects against physiological damage
from prolonged loud noise. Use of ear
plugs should be reviewed by a health
and safety officer because chemical
contaminants could be introduced into
the ear.
Provides some hearing protection while
allowing communication.
Protects hands and arms from chemical
contact. Wearer should tape-seal gloves
to sleeves to provide additional
protection
and to prevent liquids from entering
sleeves. Disposable
gloves should be used when possible to
reduce decontamination needs.
Protects feet from contact with
chemicals.
Protects feet from compression,
crushing, or puncture by falling, moving,
or sharp objects. Should provide good
traction.
Protects the wearer against electrical
hazards and prevents ignition of
combustible gases or vapors.
Protects safety boots from contamination
and protects feet from contact with
chemicals. Use of disposable covers
reduces decontamination needs.
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EXHIBIT 5-5
Sample Protective Ensembles1
LEVEL OF PROTECTION A
Equipment
Protection
Provided
Should Be Used When:
Limiting Criteria
RECOMMENDED:
• Pressure-demand, full-facepiece SCBA
or pressure-demand supplied-air
respirator with escape SCBA.
• Fully-encapsulating, chemical-resistant
suit.
• Inner chemical-resistant gloves.
• Chemical-resistant safety boots/shoes.
• Two-way radio communications.
OPTIONAL:
Hard hat. Coveralls. Cooling unit.
Long cotton underwear.
Disposable gloves and boot covers.
The highest 1. The chemical substance has been
available level identified and requires the highest level of
of respiratory. protection for skin, eyes, and the
skin, and eye respiratory system based on either:
protection. - measured (or potential for) high
concentration of atmospheric vapors,
gases, or particulates; or
- site operations and work functions
involving a high potential for splash,
immersion, or exposure to
unexpected vapors, gases, or
particulates of materials that are
harmful to skin or capable of being
absorbed through the intact skin.
2. Substances with a high degree of
hazard to the skin are known or
suspected to be present, and skin contact
is possible.
3. Operations must be conducted in
confined, poorly ventilated areas until the
absence of conditions requiring Level A
protection is determined.
Fully encap-
sulating suit
material must be
compatible with
the substances
involved.
LEVEL OF PROTECTION B
Equipment
Protection
Provided
Should Be Used When
Limiting Criteria
RECOMMENDED: The same level
• Pressure-demand, full-facepiece SCBA of respiratory
or pressure-demand supplied-air protection but
respirator with escape SCBA. less skin
• Chemical-resistant clothing (overalls protection than
and long-sleeved jacket; hooded, one- Level A.
or two-piece chemical splash suit;
disposable chemical-resistant one- It is the
piece suit). minimum level
• Inner and outer chemical-resistant recommended
gloves. for initial site
• Chemical-resistant safety boots/shoes. entries until the
• Hard hat. hazards have
• Two-way radio communications. been further
identified.
OPTIONAL:
Coveralls. Face shield.
Disposable boot covers.
Long cotton underwear
1. The type and atmospheric
concentration of substances have been
identified and require a high level of
respiratory protection, but less skin
protection. This involves atmospheres:
- with IDLH concentrations of specific
substances that do not represent a
skin hazard; or
- that do not meet the criteria for use of
air-purifying respirators.
2. Atmosphere contains less than 19.5
percent oxygen.
3. Presence of incompletely identified
vapors or gases is indicated by direct-
reading organic vapor detection
instrument, but vapors and gases are not
suspected of containing high levels of
chemicals harmful to skin or capable of
being absorbed through the intact skin.
Use only when the
vapor or gases
present are not
suspected of
containing high
concentrations of
chemicals that are
harmful to skin or
capable of being
absorbed through
the intact skin.
Based on EPA protective ensembles.
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EXHIBIT 5-5
Sample Protective Ensembles (cont'd)
LEVEL OF PROTECTION C
Equipment
Protection
Provided
Should Be Used When:
Limiting
Criteria
RECOMMENDED:
• Full-facepiece, air-purifying, canister-
equipped respirator
• Chemical-resistant clothing (overalls
and long-sleeved jacket; hooded, one-
or two-piece chemical splash suit;
disposable chemical-resistant one-
piece suit).
• Inner and outer chemical-resistant
gloves
• Chemical-resistant safety boots/shoes
• Hard hat.
• Two-way radio communications.
OPTIONAL:
The same level
of skin
protection as
Level B, but a
lower level of
respiratory
protection.
1. The atmospheric contaminants, liquid
splashes, or other direct contact will not
adversely affect any exposed skin.
2. The types of air contaminants have
been identified, concentrations measured,
and a canister is available that can
remove the contaminant.
3. All criteria for the use of air-purifying
respirators are met.
Atmospheric
concentration of
chemicals must
not exceed IDLH
levels.
The atmosphere
must contain at
least 19.5 percent
oxygen.
Coveralls.
Face shield.
Disposable boot covers
Long cotton underwear
Use of escape mask during initial entry is
optional only after characterization (29
CFR
LEVEL OF PROTECTION D
Equipment
Protection
Provided
Should Be Used When
Limiting Criteria
RECOMMENDED:
• Coveralls
• Safety boots/shoes.
• Safety glasses or chemical splash
goggles.
Hard hat.
OPTIONAL:
No respiratory
protection
Minimal skin
protection.
1. The atmosphere contains no known
hazard.
2 Work functions preclude splashes,
immersion, or the potential for unexpected
inhalation of or contact with hazardous
levels of any chemicals.
This level should
not be worn in the
Exclusion Zone
The atmosphere
must contain at
least 19.5 percent
oxygen
Gloves. Escape mask.
Face shield.
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EXHIBIT 5-5
Sample Protective Ensembles (cont'd)
LEVEL A Protection
Totally encapsulating vapor-
tight suit with full-facepiece
SCBA or supplied-air respirator.
LEVEL B Protection
Totally encapsulating suit
does not have to be vapor-tight.
Same level of respiratory protection
as Level A.
LEVEL C Protection
Full-face canister air
purifying respirator. Chemical
protective suit with full body
coverage.
LEVEL D Protection
Basic work uniform, i.e.,
longsleeve coveralls, gloves,
hardhat, boots, faceshield
or goggles.
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It may be necessary to base the decision to
use Level A protection on indirect evidence.
Other conditions that may indicate the need for
Level A protection include:
• Confined spaces;
• Suspected or known highly toxic substances,
especially when field equipment is not
available to test concentrations;
• Visible indicators such as leaking containers
or smoking chemical fires; and
• Potentially dangerous tasks, such as initial
site entry.
5.1.2 Level B
Level B protection is required under
circumstances requiring the highest level of
respiratory protection, with a lesser level of skin
protection. Potential Level B equipment includes:
positive pressure, full face-piece SCBA or positive
pressure supplied air respirator with escape SCBA;
inner and/or outer chemical-resistant gloves; face
shield; hooded chemical resistant clothing;
coveralls; and outer chemical-resistant boots.
Meeting any of the following criteria warrants
use of Level B protection:
• The type and atmospheric concentration of
substances have been identified and require
a high level of respiratory protection, but
less skin protection than Level A;
• The atmosphere contains less than 19.5
percent oxygen; or
• The presence of incompletely identified
vapors and gases is indicated but they are
not suspected of being harmful to the skin.
The use of Level B protection does not afford
as great a level of protection to the skin and eyes
as Level A, but it does provide a high level of
respiratory protection. At most abandoned,
outdoor hazardous waste sites, ambient
atmospheric vapor or gas levels have not
approached sufficiently high concentrations to
warrant Level A protection. Level B protection is
often adequate.
5.1.3 Level C
Level C protection is required when the
concentration and type of airborne substances is
known, and the criteria for using air purifying
respirators is met. Typical Level C equipment
includes: full-face air-purifying respirators, inner
and outer chemical-resistant gloves, hard hat,
escape mask, and disposable chemical-resistant,
outer boots.
Meeting any of the following criteria warrants
use of Level C protection:
• The atmospheric contaminants, liquid
splashes or other direct contact will not
adversely affect or be absorbed by the skin;
• The types of air contaminants have been
identified, concentrations do not exceed
IDLH levels, and an air-purifying respirator
is available that can remove the
contaminants; and
• Oxygen concentrations are not less than
19.5 percent by volume, and job functions
do not require SCBA.
Level C protection is distinguished from
Level B by the equipment used to protect the
respiratory system, assuming the same type of
chemical-resistant clothing is used. The main
selection criterion for Level C is that atmospheric
concentrations and other selection criteria permit
wearing an air-purifying respirator.
5.1.4 Level D
Level D is the minimum protection required.
Appropriate Level D protective equipment may
include: gloves, coveralls, safety glasses, face
shield, and chemical-rcsistani steel-toe boots or
shoes. Level D protection is primarily a work
uniform. This protection is sufficient under the
following conditions:
• No contaminants are present; or
• Work operations preclude splashes,
immersion, or the potential for unexpected
inhalation of or contact with hazardous
levels of any chemicals.
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While these are guidelines for typical
equipment to be used in certain circumstances,
other combinations of protective equipment may
be more appropriate, depending upon specific site
characteristics. As an aid to selecting appropriate
protective wear, it is recommended that chemical
protective suits meet the standards developed by
the National Fire Protection Association (NFPA).
5.2 ELEMENTS OF THE PPE PROGRAM
The comprehensive PPE program must
address a number of specific factors in addition to
selection of the appropriate level of protection.
These factors are discussed below. Site managers
should also refer to the Standard Operating
Procedures for Site Entry for additional technical
guidance in the use and selection of PPE.
5.2.1 Personal Use Factors and
Equipment Limitations
Certain personal features of workers may
jeopardize safety during equipment use.
Prohibitive or precautionary measures should be
taken as necessary for the following personal
features:
Facial hair and long hair that passes between
the face and the sealing surface of the respirator
should be prohibited because it interferes with
respirator fit and wearer vision, allowing excessive
contaminant penetration. Long hair must be
effectively contained within protective hair
coverings.
Eyeglasses with conventional temple pieces
will interfere with the respirator-to-face seal of a
full face-piece. A spectacle kit should be installed
in the face masks of workers requiring vision
correction, providing a gas-tight seal. Contact
lenses may trap contaminants and/or paniculate
between the lens and the eye, causing irritation.
Wearing contact lenses with a respirator in a
contaminated atmosphere is prohibited (29 CFR
Gum and tobacco chewing should be
prohibited during respirator use because they may
cause ingestion of contaminants and may
compromise the respirator fit.
It is especially important to understand all
aspects of the clothing operation and the
limitations of fully-encapsulating ensembles, as
misuse could result in suffocation. During
equipment use, workers should be encouraged to
report any perceived problems or difficulties to
their supervisor(s). These malfunctions may
include, but are not limited to:
Degradation of the protective ensemble.
Perception of odors.
Skin irritation.
Unusual residues on PPE.
Discomfort.
Resistance to breathing.
Fatigue due to respirator use.
Interference with vision or communication.
Restriction of movement.
Personal responses such as rapid pulse,
nausea, and chest pain.
If a supplied-air respirator is being used, all
hazards that might endanger the integrity of the air
line should be removed from the working area
prior to use. During use, other workers and
vehicles should be excluded from the area.
5.2.2 Work Mission Duration
In selecting PPE, it is important to consider
the anticipated duration of the work mission.
Several factors may limit the mission length,
including: air supply, equipment effectiveness,
temperature, and coolant supply.
Air Supply Consumption. The
duration of the air supply must
be considered before planning
any SCBA-assisted work
activity. The anticipated oper-
ating time of a SCBA is clearly
indicated on the breathing
apparatus. This designated operating time is based
on a moderate work rate used in the NIOSH/
MSHA certification test. In actual operation,
however, several factors can reduce the rated
operating time. The following variables should be
considered to adjust work actions and operating
time accordingly:
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• Work rate. The actual in-use duration of
SCBAs may be reduced by one-third to one-
half during strenuous work (e.g., drum
handling, major lifting, or any task requiring
repetitive speed of motion).
• Fitness. Well-conditioned individuals
generally utilize oxygen more efficiently and
can extract more oxygen from a given
volume of air than unfit individuals, thereby
slightly increasing the SCBA operating time.
• Body size. Larger individuals generally
consume air at a higher rate than smaller
individuals, thereby decreasing the SCBA
operating time.
• Breathing patterns. Quick, shallow, or
irregular breaths use air more rapidly than
deep, regularly spaced breaths. Heat-
induced anxiety and lack of acclimatization
may induce hyperventilation, resulting in
decreased SCBA operating time.
Suit/Ensemble Permeation. Degradation, and
Penetration. The possibility of chemical
permeation, degradation, or penetration of
protective ensembles during the work mission is
always a matter of concern and may limit mission
duration. Possible causes are suit valve leakage,
because of excessively hot or cold temperatures or
improper maintenance, and exhalation valve
leakage at excessively hot or cold temperatures.
Also, when considering mission duration, it
should be remembered that no single clothing
material is an effective barrier to all chemicals or
all combinations of chemicals, and no material is
an effective barrier to prolonged chemical
exposure.
O
Ambient Temperature. The
ambient temperature may have
a major influence on work
mission duration as it affects
both the worker and the
protective integrity of the
ensemble. Heat stress, which
can occur even in relatively moderate
temperatures, presents the greatest immediate
danger to an ensemble-encapsulated worker.
Protecting against heat stress is discussed later in
this chapter. Hot and cold ambient temperatures
also can affect:
• Valve operation on suits and/or respirators;
• The durability and flexibility of suit materials;
• The integrity of suit fasteners;
• The breakthrough time and permeation rates
of chemicals; and
• The concentration of airborne contaminants.
All of these factors may decrease the duration of
protection provided by a given piece of clothing or
respiratory equipment.
Coolant Supply. Under warm or strenuous
work conditions, adequate coolant (e.g., ice or
chilled air, refrigeration coils) should be provided
to keep the wearer's body at a comfortable
temperature and to reduce the potential for heat
stress. If coolant is necessary, the duration of the
coolant supply will directly affect mission duration.
5.2.3 Storage and Maintenance
Clothing and respirators must
be stored properly to prevent
damage or malfunction due to
exposure to dust, moisture,
sunlight, damaging chemicals,
extreme temperatures, and
impact. Many equipment
failures can be directly attributed to improper
storage. Procedures must be specified for both
pre-issuance warehousing and, more importantly,
post-issuance (in-use) storage.
Potentially contaminated, reusable clothing
should be stored (generally bagged) in a well-
ventilated area, with good air flow around each
item, until the extent of contamination is
documented. The garment is then either
decontaminated or disposed. Never store these
materials near street clothing.
Different types and materials of clothing and
gloves should be stored separately to prevent
issuing the wrong material by mistake. Protective
clothing should be folded or hung in accordance
with manufacturers' recommendations.
SCBAs, supplied-air respirators, and air-
purifying respirators should be dismantled, washed,
and disinfected after each use. SCBAs should be
stored in storage chests supplied by the
manufacturer. Air-purifying respirators should be
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stored individually in their original cartons or
carrying cases, or in heat-sealed or resealable
plastic bags.
The technical aspects of PPE maintenance
procedures vary by manufacturer and type of
equipment. Manufacturers frequently restrict the
sale of certain PPE parts only to individuals or
groups who are specially trained, equipped, and
"authorized" by the manufacturer to purchase
them. Explicit procedures should be adopted in
the site work plan to ensure that the appropriate
level of maintenance is performed only by
individuals trained at that level.
The following classification scheme is often
used to divide maintenance into three levels:
• Level 1: User or wearer maintenance,
requiring a few common tools or no tools at
all.
• Level 2: Shop maintenance that can be
performed by the employer's maintenance
shop.
• Level 3: Specialized maintenance that can be
performed only by the factory or an
authorized repair person.
5.2.4 Training and Proper Fitting
The PPE program must ensure that employees
arc trained in the proper use and fitting of PPE.
Training. Employees should be trained in the
proper use of protective equipment prior to using
any PPE on-site. The purpose of training is to:
(1) become familiar with the equipment in a
nonha/.ardous situation; (2) instill confidence and
awareness in the user of the limitations and
capabilities of the equipment; (3) increase the
operating and protective efficiency of PPE use; and
(4) reduce maintenance expenses.
Training must be completed prior to actual
PPE use in any hazardous environment and should
occur at least annually. At a minimum, the
training portion of ihe PPE program should
explain the user's responsibilities and should
address the following issues, utilizing both
classroom and field training when necessary:
• OSHA requirements as delineated in 29 CFR
Part 1910, Subparts 1 and Z.
• OSHA requirements for respiratory
protection at 29 CFR §1910.134.
• The proper use and maintenance of the
selected PPE, including capabilities and
limitations.
• The nature of the hazards and the
consequences of not using PPE.
• Instruction in inspection, donning, doffing,
decontaminating, checking, fitting, and using
PPE.
• Individualized respirator fit testing to ensure
proper fit.
• Use of PPE in normal air for a long
familiarity period, as well as use of PPE in a
test atmosphere to evaluate its effectiveness.
• The user's responsibility (if any) for
decontamination, cleaning, maintenance, and
repair of PPE.
• Emergency procedures and self-rescue in the
event of PPE failure.
• The elements of the HASP and the
individual's responsibilities and duties in an
emergency, including the buddy system (see
Chapter 4).
• The human factors influencing PPE
performance. The discomfort and
inconvenience of wearing PPE can create a
resistance to the conscientious use of PPE.
One essential aspect of training is to make
the user aware of the need for PPE and to
instill motivation for the proper use and
maintenance of PPE.
Respirator Fit Testing. The "fit" of the
facepiece-to-face seal of a respirator must be tested
on each potential wearer to ensure a tight seal;
every facepiece does not fit every wearer. Certain
features, such as scars, very prominent cheekbones,
deep skin creases, dentures or missing teeth, and
the chewing of gum and tobacco may interfere with
the respirator-to-face seal. Under conditions
where these features may impede a good seal, a
respirator must not be worn.
For a qualitative respirator fit testing protocol,
see Appendix D of the OSHA lead standard (29
CFR §1910.1025). For specific quantitative testing
protocols, literature supplied by manufacturers of
quantitative fit testing equipment should be
consulted.
55
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5.2.5 Donning and Doffing Procedures
The PPE program should include clearly
defined donning and doffing procedures.
Donning. A routine should be established
and practiced periodically for donning all levels of
protective clothing and equipment. As donning
and doffing the ensembles can be difficult to
perform alone and solo efforts increase the
possibility of improper use and suit damage,
assistance should be provided. The donning
routine should be modified depending on the
particular type of suit or the need for extra gloves
or boots. Once the equipment has been donned,
the fit should be evaluated. The clothing should
not be too small, increasing the likelihood of
tearing the suit material and accelerating worker
fatigue, nor should it be too large, increasing the
possibility of snagging the material and
compromising the dexterity and coordination of
the worker. In either case, better fitting clothing
should be provided.
Doffing. Exact procedures for removing PPE
must be established and followed to prevent
contaminant migration from the work area and
transfer of contaminants to the wearer's body, the
doffing assistant, and others. These procedures
should be performed only after decontamination of
the suited worker (see Chapter 9). Although they
require a suitably attired assistant, both worker and
assistant should avoid any direct contact with the
outside surface of the contaminated suit
throughout the decontamination procedures. If
the suit is to be reused, the assistant should also
avoid contact with the inside of the garment.
5.2.6 Inspection Procedures
An effective PPE inspection program should
feature four different inspections:
• Inspection and operational testing of
equipment received from the factory or
distributor;
• Inspection of equipment as it is issued;
• Inspection before and after use or training
and prior to maintenance; and
• Periodic inspection of stored equipment.
The inspection checklist in Exhibit 5-6 may be
helpful in conducting inspections of PPE prior to
and during regular use. Periodic inspection will
cover somewhat different areas in varying degrees
of depth. Detailed inspection procedures, where
appropriate, are usually available from the
manufacturer.
Individual identification numbers should be
assigned to all reusable pieces of equipment and
records must be maintained, by number, of all
inspection procedures. At a minimum, each
inspection should record the ID number, date,
inspector, and any unusual conditions or findings.
5.2.7 PPE Program Evaluation
At a minimum, the PPE
program should be reviewed
annually to evaluate the
effectiveness of the following
factors:
• The number of personnel-hours that are spent
in various PPE ensembles;
• The degree to which the site complies with
the HAZWOPER standards on PPE use,
inspection, maintenance, and recordkeeping;
• Accident, injury, and illness statistics, and
recorded levels of exposure;
• The adequacy of operating procedures to
guide the selection of PPE;
• The degree of coordination with
comprehensive and site-specific health and
safety programs; and
• Recommendations for and results of program
improvement and modification.
5.2.8 Other Considerations
There are other factors, not discussed above,
that may also affect the use and effectiveness of
PPE. Several of these factors, dealing with the
physical state of the user, are discussed below.
Heat Stress. Wearing PPE puts a hazardous
waste worker at considerable risk of developing
heat stress, which can result in adverse health
effects ranging from transient heat fatigue to
serious illness or death. Heat stress is caused by a
number of interacting factors, including
environmental conditions, clothing, workload, and
56
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EXHIBIT 5-6
Sample PPE Inspection Checklists
CLOTHING
RESPIRATORS*
Before use:
Determine that the clothing materials are correct for the
specified task at hand.
Visually inspect for:
imperfect seams
non-uniform coatings
tears
malfunctioning closures
Hold up to light and check for pinholes.
Flex product:
observe for cracks
observe for other signs of shelf deterioration
If the product has been used previously, inspect inside
and out for signs of chemical attack:
discoloration
swelling
stiffness
During the work task, periodically inspect for:
Evidence of chemical attack such as discoloration,
swelling, stiffening, and softening. Keep in mind,
however, that chemical permeation can occur without
any visible effects.
Closure failure.
Tears.
Punctures.
Seam discontinuities.
GLOVES
| Before use:
Pressurize glove to check for pinholes. Either blow into
glove, then roll gauntlet towards fingers or inflate glove
and hold under water. In either case, no air should
escape.
FULLY-ENCAPSULATING SUITS
Before use:
Check the operation of pressure relief valves.
Inspect the fitting of wrists, ankles, and neck.
Check faceshield, if so equipped, for:
cracks
fogginess
IT SCBA
Inspect SCBAs:
before and after each use
at least monthly when in storage
every time they are cleaned
Check all connections for tightness.
Check material conditions for:
signs of pliability
signs of deterioration
signs of distortion
Check for proper setting and operation of regulators and
valves (according to manufacturers' recommendations).
Check operation of alarm (s).
Check faceshields and lenses for cracks and fogginess
Y Air-Purifying Respirators
Inspect air-purifying respirators:
before each use to be sure they have been
adequately cleaned
after each use
during cleaning
monthly if in storage for emergency use
Check material conditions for:
signs of pliability
signs of deterioration
signs of distortion
Examine cartridges or canisters to ensure that:
they are the proper type for the intended use
the expiration date has not been passed
they have not been opened or use previously
Check faceshields and lenses for cracks and fogginess
Ip Supplied-Air Respirators
Inspect supplied-air respirators:
daily when in use
at least monthly when in storage
every time they are cleaned
Inspect air lines prior to each use for cracks, kinks, cuts,
frays, and weak areas.
Check for proper setting and operation of regulators and
valves (according to manufacturers' recommendations).
Check all connections for tightness.
Check material conditions for:
signs of pliability
signs of deterioration
signs of distortion
Check faceshields and lenses for cracks, fogginess
Must have NIOSH/MSHA approval
57
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the individual characteristics of the worker. Heat
stress is one of the most common and potentially
serious illnesses at hazardous waste sites and,
therefore, warrants regular monitoring and other
preventive measures. Chapter 8 provides more
detailed information on heat stress and PPE.
Other Factors. Although wearing PPE
decreases a worker's performance, the magnitude
of this effect varies considerably, depending on
both the individual and the PPE ensemble used.
One of the physiological factors that may affect
worker ability to function using PPE is physical
fitness. The more fit someone is, the more work
they can perform safely. At a given level of work,
a fit person, relative to an unfit person, will have:
less physiological strain; a lower heart rate; a lower
body temperature, indicating less retained body
heat; a more efficient sweating mechanism; slightly
lower oxygen consumption; and slightly lower
carbon dioxide production.
The degree to which a worker's body has
adjusted or acclimatized to working under hot
conditions may affect his or her ability to do work.
Acclimatized individuals generally have better
mechanisms to maintain lower skin and body
temperatures at a given level of environmental
heat and work loads. Although acclimatization can
occur quickly, a progressive 6-day acclimatization
period before allowing an employee to work a full
shift on a hot day is recommended. With fit or
trained individuals, the acclimatization period may
be shortened by 2 or 3 days. Acclimatization can
occur quickly, and work regimens should be
adjusted to account for this.
FURTHER GUIDANCE: For more information on selecting, using, and maintaining PPE, see:
1. Certified Equipment List as of December 31, 1990. (NIOSH, 1991, Publication 91-105) Cincinnati,
OH. Updated annually.
2. Standard Operating Guidelines for Site Entry (U.S. EPA, 1985, Publication 9285.2-01A).
3. Schwope, A.D.; Costas, P.P.; Jackson, J.O.; Stull, J.O.; and D.J. Weitzman, 1987, Guidelines for
the Selection of Chemical Protective Clothing, 3rd Edition. American Conference of
Governmental Industrial Hygienists, Inc. Cincinnati, OH.
4. National Fire Codes: A Compilation of NFPA Codes, Standards, Recommended Practices and
Guides, Vol.8. (1991, National Fire Protection Association, 1 Batterymarch Park, Quincy,
MA 02269-9101).
Library of Congress Catalog Card No: 38-27236
Volume 8: ISBN 0-87765-011-X
Complete Set: ISBN 0-87765- 140-X
ISSN: 0077-4545
58
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CHAPTER 6 AIR MONITORING
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CHAPTER 6 AIR MONITORING
6.0 INTRODUCTION
The presence of hazardous materials at a site,
as well as actions taken to address these materials,
can cause the release of hazardous substances into
the air. Chemical fires, transportation accidents,
open or leaking containers, wind-blown dust, and
site cleanup activities produce emissions that can
rapidly affect the health and safety of response
personnel and the public. Hazardous atmospheres
can be:
• Explosive (characterized by the presence of
ignitable or explosive vapors, gases,
aerosols, and dusts);
• Toxic (characterized by the presence of
vapors, gases, particulates, and aerosols);
• Oxygen-deficient (characterized by the
displacement of breathable air); or
• Radioactive (characterized by the presence
of radioactive materials).
The presence of one or more of these hazards is an
important factor in determining subsequent actions
that should be taken to protect people and the
environment. Their presence may dictate
operations that are necessary to mitigate the
likelihood of an incident, and safety considerations
for response personnel.
Airborne hazards can be predicted if the
substance involved, its chemical and physical
properties, and weather conditions are known.
However, air monitoring is necessary to confirm
predictions, to identify or measure contaminants,
and to detect unknown air pollutants. Therefore,
29 CFR §1910.120(h) sets forth specific
requirements for air monitoring. The remainder of
this chapter describes the air monitoring
requirements and outlines a number of practices
that can be implemented to meet these
requirements most effectively.
6.1 OBJECTIVES OF AIR MONITORING
The objectives of air monitoring during
response operations are to:
• Identify and quantify airborne contaminants
on- and off-site;
• Track changes in air contaminants that
occur over the lifetime of the incident;
• Ensure proper selection of work practices
and engineering controls;
• Determine the level of worker protection
needed;
• Assist in defining work zones; and
• Identify additional medical monitoring
needs in any given area of the site.
HAZWOPER requires air monitoring to be
performed wherever the possibility of employee
exposure to hazardous substances exists. Upon
initial entry, representative air monitoring should
be conducted to identify any IDLH conditions,
exposure over PELs, exposure over a radioactive
material's dose limits, or other dangerous
conditions, such as flammable or oxygen-deficient
environments. Air monitoring should also be
conducted to confirm that the area considered for
the Support Zone is clean (i.e., does not contain
concentrations of hazardous substances that
require worker protection). If there is any
question that contaminants may have migrated into
the area considered for the Support Zone, air
and/or surface soil samples should be collected and
compared with on-site and off-site background
samples.
To determine whether additional monitoring
is required to designate work zones, the site
manager should evaluate the results of the initial
air monitoring survey, the visual characterization
of site hazards, the properties of on-site contam-
inants, and potential pathways of contaminant
dispersion. During the site hazard evaluation, the
site manager should use information from direct-
reading instruments, visible indicators (signs,
labels, placards, etc.), and other sources (manifests,
inventories, government agency records, etc.) to
evaluate the presence or potential for the release
of contaminants into the air. Limited air sampling
may also be conducted if time is available. Based
61
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on an assessment of this preliminary information,
a more comprehensive air monitoring strategy
should be developed and implemented.
During the response operation, (e.g., when
soil or containers are moved or disturbed),
employers should monitor those employees likely
to have the highest exposures to hazardous
substances (i.e., exposures above PELs). In
accordance with 29 CFR §1910.120(h)(4), if any
employee has been exposed to elevated levels of
hazardous substances, extensive personal
monitoring must be conducted, in conjunction with
additional site control measures, to ensure
employee health and safety.
6.2 IDENTIFYING AIRBORNE
CONTAMINANTS
The two methods generally
available for identifying and/or
quantifying airborne contam-
inants are: (1) on-site use of
direct-reading instruments
(DRIs); and (2) laboratory
analysis of air samples
obtained by gas sampling bag, filter, sorbent, or
wet-contaminant collection methods.
DRIs may be used to quickly detect
flammable or explosive atmospheres, oxygen
deficiency, certain gases and vapors, and ionizing
radiation, as well as to identify changing site
conditions. Because DRIs provide information at
the time of sampling and allow for rapid decision-
making, they are the primary tools of initial site
characterization. All DRIs, however, have inherent
limitations in their ability to detect hazards. DRIs
detect and/or measure only specific classes of
chemicals and usually are not designed to detect
airborne concentrations below 1 ppm. In addition,
many of the DRIs that have been designed to
detect one particular substance also detect other
substances and, consequently, may give false
readings. DRIs must be operated, and their data
interpreted, by qualified individuals using properly
calibrated instruments. Additional monitoring
should be conducted at any location where a
positive instrument response occurs.
Because DRIs are available for only a few
specific substances and are rarely sensitive enough
to detect low concentrations of hazardous
substances that may nonetheless present health
risks, long-term or "full-shift" air samples must also
be collected and analyzed in a laboratory. Full-
shift air samples for some chemicals may be
collected with passive dosimeters, or by means of
a pump that draws air through a filter or sorbent.
Selection of the proper sampling media is
determined by the physical state of the
contaminants. Some chemicals, such as PCBs, may
occur as both vapors and particulate-bound
contaminants. In such cases, a dual-media system
is needed to measure accurately for the chemical.
6.2.1 Direct Reading Instruments
During site operations, it is essential to
monitor for the presence of, or changes in, the
level of airborne contaminants. Changes in
contaminant levels may occur when work is
initiated in a different area of the site, new
contaminants are discovered, or different types of
operations are begun in a particular area (e.g.,
drum opening, as opposed to exploratory well
drilling). DRIs can be used to provide
approximate total concentrations of many organic
chemicals and a few inorganic substances. If
specific organics (and inorganics) have been
identified, then DRIs calibrated to those materials
can be used for more accurate on-site assessment.
To obtain air monitoring data rapidly at the
site, monitoring personnel may use instruments
with flame ionization detectors (FIDs), photo-
ionization detectors (PIDs), and other similar
instruments. These may be used as survey
instruments (total concentration mode), or
operated as gas chromatographs (gas chrom-
atograph mode). As gas chromatographs, these
instruments can provide real-time, qualitative/
quantitative data when calibrated with standards of
known air contaminants. Combined with selective
laboratory analysis of samples, they provide an
excellent tool for evaluating airborne organic
hazards on a real-time basis, at a lower cost than
analyzing all samples in a laboratory. Exhibit 6-1
lists several direct-reading air monitoring
instruments, and Appendix D presents more
specific information on the characteristics of the
PID and the organic vapor analyzer (OVA).
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EXHIBIT 6-1
Summary of Direct-Reading Air Monitoring Instruments
Principle of
Detection
and Monitoring
Need
Instrument
Features
Limitations
Wheatstone
Bridge Filament
Monitoring
Need:
Combustible
Gas
Combustible
Gas Detector
Nonspecific detector for
combustible gases measures gas
concentrations as a percentage of
lower explosive limit (LEL)
Lightweight, portable, and easy to
use
Visual and audible alarms
Probe provides remote sensing
capabilities
8- to 12-hour battery operating life
for most models
Accuracy varies depending upon
the model; accuracies of ± 2 to 3
percent are attainable
Potential interferences from leaded
gasoline and silicates, which are
more strongly adsorbed on catalyst
than oxygen or gas in question.
Membranes are available to
minimize these effects.
Most models do not measure
specific gases
May not function properly in
oxygen-deficient atmospheres « 10
percent)
Chemical Cell
Monitoring
Need:
Oxygen
Deficiency
Oxygen
Meter
• Direct readout in percent oxygen
• Visual and audible alarm
• Lightweight, portable, and easy to
use
• Probe provides remote sensing
capabilities
• Accuracies of ± 1 percent are
attainable, but depend on the
particular model
• Generally 8-to 10-hour battery life
High humidity may cause
interference
Strong oxidants may cause
artificially high readout
Chemical Sensor
Wheatstone
Bridge Filament
Monitoring
Need:
Combustible
Gas/Oxygen
Deficiency
Combination
Oxygen
Meter and
Combustible
Gas Detector
• Calibrated to Pentane or Hexane
• Measure percent oxygen and gas
concentration as a percentage of
LEL
• Both visual and audible alarm
• Remote sensing capabilities
• Lightweight, portable, and easy to
use
• Accuracies of ± 2 percent are
attainable but may be as high as
±10 percent, depending on the
models
Same limitation as oxygen meters
and combustible gas detectors
In certain units, acid gases and
high CO2 concentrations shorten
the life of oxygen sensor/cells
Certain units require conversion
factor for true specific compound
response readings
In certain units, oxygen calibration
is altitude dependent
Optical, Electrical,
Piezoelectric
Monitoring
Need:
AerosolJ
Particulate
Aerosol/
Particulate
Monitor
Selectable ranges
Particle size differentiation
available
Certain units have data logging
capabilities
Factory recalibration required on
certain units
Values represent total particulates:
dust, mist, aerosols are all inclusive
with no differentiation
Cold weather may have adverse
effect on detector
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EXHIBIT 6-1
Summary of Direct-Reading Air Monitoring Instruments
Principle of
Detection
and Monitoring
Need
Instrument
Features
Limitations
Photoionization
Ultraviolet Light
Monitoring
Need:
Toxic Gas/
Vapors
Photoioni-
zation
Detector
(PID)
Nonspecific gas and vapor
detection for organics and some
inorganics
Not recommended for permanent
gases
Lightweight (4 to 9 Ibs) and
portable
Sensitive to 0.1 ppm benzene.
Sensitivity is related to ionization
potential of compound
Remote sensing capabilities
Response time of 90 percent in
less than 3 seconds
More sensitive to aromatics and
unsaturated compounds that the
flame ionization detector (FID)
8-hour battery operating life;
certain units with external
interchangeable battery packs
Audible alarm is available
Certain units have data
logging/computer interface
capabilities
Certain units available with
calibration libraries
Certain units available with
interchangeable lamps
Does not monitor for specific gases
or vapors
Cannot detect hydrogen cyanide or
methane
Cannot detect some chlorinated
organics
High humidity and precipitation
negatively affect meter response
Hydrogen Flame
Ionization
Monitoring
Need:
Toxic Gas/
Vapors
Flame
Ionization
Detector
(FID)
In the survey mode, it functions as
a nonspecific total hydrocarbon
analyzer; in the gas
chromatograph mode, it provides
tentative qualitative/quantitative
identification
Most sensitive to saturated
hydrocarbons, alkanes, and
unsaturated hydrocarbon alkanes
Lightweight (12 Ibs) and portable
Remote sensing probe is available
Response time is 90 percent in
2 seconds
8-hour battery operating life
Sounds audible alarm when
predetermined levels are
exceeded
Not suitable for inorganic gases
(e.g., CI2, HCN, NH3)
Less sensitive to aromatics and
unsaturated compounds than PID
Requires skilled technicians to
operate the equipment in the GC
mode and to analyze the results
Requires changes of columns and
gas supply when operated in the
GC mode in certain units
Because specific chemical
standards and calibration columns
are needed, the operator must have
some idea of the identification of
the gas/vapor
Substances that contain substituted
functional group (e.g.. hydroxide
(OH-) or (CI-) Chloride groups)
reduce the detector's sensitivity
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EXHIBIT 6-1
Summary of Direct-Reading Air Monitoring Instruments
Principle of
Detection
and Monitoring
Need
Instrument
Features
Limitations
Infrared Radiation
Monitoring
Need:
Toxic Gas/
Vapors
Infrared
Analyzer
Overcomes the limits of most
infrared (IR) analyzers by use of a
variable filter; can be used to scan
through a portion of the spectrum
to measure concentration of
several gases or can be set at a
particular wavelength to measure
a specific gas
Detects both organic and
inorganic gases
Portable but not as lightweight
(32 Ibs.) as the photoionization or
the flame ionization detectors
Not as sensitive as PID or the FID
Less portable than other methods
of gas/vapor detection
Requires skilled technicians to
operate and analyze results when
positive identification is needed
Interference by water vapor and
carbon dioxide
Most require AC power source
Positive identification requires
comparison of spectrum from strip
chart recorder with published
adsorption spectrum; infrared
spectrum not available for all
compounds
Chemical
Reaction
Producing a
Color Change
Monitoring
Need:
Toxic Gas/
Vapors
Indicator
Tubes
Provides qualitative, semi-
quantitative identification of
volatile organics and inorganics
Accuracy of only about ± 25
percent
Simple to use, and relatively
inexpensive
Real-time/semi-realtime results
Low accuracy
Subject to leakage during pumping
Requires previous knowledge of
gases/vapors in order to select the
appropriate detector tube
Some chemicals interfere with color
reaction to read false positive
Temperature and humidity may
affect readings
Electrochemical
Cell
Monitoring
Need:
Toxic Gas/
Vapors
Specific
Atmospheres
Toxic
Atmosphere
Monitor
Ease of operation
Small, compact, lightweight
Audible alarm upon exceeding
present action level or TLV
Certain units have digital readout
Generally compound-specific
Certain units interface with data
logger
Cross sensitivity
Slow response/recovery after
exposure to high contamination
levels
Limited number of chemicals
detected
Metal-Oxide
Semiconductor
Monitoring
Need:
Toxic Gas/
Vapors
Toxic
Atmosphere
Monitor
Ease of operation
Small, compact, lightweight
Audible alarm upon exceeding
present action level or TLV
Certain units have digital readout
Certain units interface with data
logger
Nonspecific gas and vapor
detection for some organics and
inorganics
Cross sensitivity
Slow response/recovery after
exposure to high contamination
levels
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EXHIBIT 6-1
Summary of Direct-Reading Air Monitoring Instruments
Principle of
Detection
and Monitoring
Need
Instrument
Features
Limitations
Scintillation
Detector
Monitoring
Need:
Radiation
Radiation
Meters
Measures radiation in mR/hr
(battery operated)
Probe provides remote sensing
capabilities
Accuracy and sensitivity varies
considerably with manufacturer
and type of meter
A variety of meters are available.
Some measure total ionizing
radiation; others are specific for
gamma, alpha, or a combination
of two or more types
Some meters do not determine type
of radiation
Gold Film Sensor
Monitoring
Need:
Mercury
Vapor
Mercury
Vapor
Analyzer
Compound specific; has survey
and sample modes
0.001 mg/m3 detection limit
Provides sensor saturation
readout; saturated sensor cleaning
capabilities
Can be used with dosimeters for
on-site dosimetry
Microprocessor serves reading;
automatically re-zeros
Certain units have data logging
capabilities
5-hour battery life
Requires yearly factory recalibration
Short battery life
Requires AC power for Heat
Cleaning Cycle
Sources: Mathamel, 1981; Spittler, 1980; McEnery, 1982; National Mine Service Company, 1980; Gas-Tech,
1980; Enmet Corporation, 1979; Foxboro Analytical, 1982; HNU Systems, 1982, 1991; Photovac
International, Inc., 1989; Jerome, 1990; MIE, 1990.
6.2.2 Air Sampling
For more complete information about air
contaminants, measurements obtained with DRIs
should be supplemented with air samples. To
assess air contaminants more thoroughly, air
sampling devices equipped with appropriate
collection media should be placed at various
locations throughout the area. These samples
provide air quality information, and can indicate
the presence and concentrations of contaminants
over the lifetime of site operations. As data are
obtained (from the analysis of samples, DRIs, and
site operations), adjustments should be made in
the type and number of samples, frequency of
sampling, and analysis required. In addition to air
samplers, area sampling stations may also include
DRIs equipped with recorders and operated as
continuous air monitors. Area sampling stations
should be placed in the following locations:
Upwind. Because many hazardous incidents
occur near industries or highways that generate air
pollutants, samples must be taken upwind of the
site, and wherever there are other potential sources
of contaminants, to establish background levels of
air contaminants.
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Support Zone. Samples must be taken near the
command post or other support facilities to ensure
that they are in fact located in a clean area, and
that the area remains clean throughout operations
at the site.
Contamination Reduction Zone. Air samples
should be collected along the Contamination
Control Line to ensure that personnel are properly
protected and that on-site workers are not
removing their protective gear in a contaminated
area.
Exclusion Zone. The Exclusion Zone presents
the greatest risk of exposure to chemicals and
requires the most air sampling. The location of
sampling stations should be based upon hot spots
or source areas detected by DRIs, types of
substances present, and potential for airborne
contaminants. The data from these stations, in
conjunction with intermittent walk-around surveys
with DRIs, should be used to verify the selection
of proper levels of PPE and to set Exclusion Zone
boundaries, as well as to provide a continual
record of air contaminants.
Fenceline/Downwind. Sampling stations should
be located downwind from the site to determine
whether any air contaminants are migrating from
the site. If there are indications of airborne
hazards in populated areas, additional samplers
should be placed downwind.
In many instances, only air sampling and
laboratory analysis are necessary for detection and
quantification. Although accurate, the air
sampling and laboratory analysis option has two
disadvantages: cost and time. Analyzing large
numbers of samples in laboratories is expensive,
especially when results are needed quickly. On-site
laboratories tend to reduce the turn-around time,
but their cost may be prohibitive.
6.3 AIR SAMPLING EQUIPMENT AND
MEDIA
A variety of air sampling equipment may be
used to collect samples of potentially dangerous
substances that may become airborne at hazardous
waste sites. Sampling systems typically include a
calibrated air sampling pump that draws air into
selected collection media. Some of the most
common types of sampling and collection media
are described below:
Organic Vapors. Activated carbon is an
excellent sorbent for most organic vapors.
However, other solid sorbents (such as Tenax®,
silica gel, and Florisil®) are routinely used to
sample specific organic compounds or classes of
compounds that do not adsorb or desorb well on
activated carbon. The samples should be collected
using an industrial hygiene personal sampling
pump with either one sampling port or a manifold
system capable of simultaneously collecting
samples on several sorbent tubes. Individual
pumps with varying flow rates may also be used to
collect several samples at once. The sorbent tubes
may contain:
• Activated carbon, to collect vapors of
materials with a boiling point above zero
degrees centigrade. These materials include
most solvent vapors.
• A porous polymer, such as Tenax® or
Chromosorb® to collect substances that
adsorb poorly onto activated carbon (e.g.,
high-molecular-weight hydrocarbons, organo-
phosphorus compounds, and the vapors of
certain pesticides). Some of these porous
polymers also adsorb organic materials at low
ambient temperatures more efficiently than
carbon.
• A polar sorbent, such as silica gel to collect
organic vapors that exhibit a relatively high
dipole movement (e.g., aromatic amines).
• Any other specialty adsorbent selected for the
specific site (e.g., a Florisil® tube, if PCBs are
suspected).
Inorganic Gases. The inorganic gases present
at a site would primarily be polar compounds such
as the haloacid gases and ammonia. These gases
can be adsorbed onto silica gel tubes and analyzed
by ion chromatography. Impingers filled with
selected liquid reagents can also be used.
Aerosols. Aerosols (solid or liquid particulates)
that may be encountered at an incident include
contaminated and non-contaminated soil particles,
heavy-metal particulates, pesticide dusts, and
droplets of organic or inorganic liquids. An
effective method for sampling these materials is to
collect them on a paniculate filter, such as a glass
fiber or mixed cellulose ester fiber membrane. A
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backup impinger filled with a selected absorbing
solution may also be necessary.
Colorimetric detector tubes can also be used
with a sampling pump when monitoring specific
compounds. Exhibit 6-2 lists several air collection
and analytical methods.
6.4 SAMPLE COLLECTION AND
ANALYSIS
Samples are analyzed to
determine types and quantities
of substances present at a site.
Good sources of information
on collecting and analyzing
samples for a variety of
chemical substances include:
(1) EPA's Compendium of Methods for
Determination of Toxic Organic Compounds in Air,
(2) the National Institute for Occupational Safety
and Health's (NIOSH) Manual of Analytical
Methods, (Volumes 1-3, 4th Edition); and (3)
OSHA Analytical Methods. These references may
be consulted for specific procedures. This section
provides additional guidance on sample collection
and analysis.
Aerosols. Samples for aerosols should be taken
at a relatively high flow rate (generally about 2
liters per minute) using a standard industrial
hygiene pump and filter assembly. To collect total
particulates, a membrane filter having a 0.8
micrometer pore size is common. The sample can
be weighed to determine total particulates, then
analyzed destructively or non-destructively for
metals. If a non-destructive metals analysis is
performed, or if the filter is sectioned, additional
analyses (e.g., organics, inorganics, and optical
particle sizing) can be performed.
Sorbent Samples. The sorbent material chosen,
the amount used, and sample volume will vary
according to the types and concentrations of
substances anticipated at a particular site. Polar
sorbent material such as silica gel will collect polar
substances that are not adsorbed well onto
activated carbon and some of the porous polymers.
The silica gel sample can be split and analyzed for
the haloacid gases and aromatic amines.
Activated carbon and porous polymers will
collect a wide range of compounds. Exhaustive
analysis to identify and quantify all the collected
species is prohibitively expensive at any laboratory
and technically difficult for a field laboratory.
Therefore, samples should be analyzed for
principal hazardous constituents (PHCs). The
selection of PHCs should be based on the types of
materials anticipated at a given site and on
information collected during the initial site survey.
To aid in the selection of PHCs, a sample could be
collected on activated carbon or porous polymer
during the initial site survey and exhaustively
analyzed off-site to identify the major peaks within
selected categories. This particular analysis, along
with what is already known about a particular site,
could provide enough information to select PHCs.
Standards of PHCs could then be prepared and
used to calibrate instruments used for field analysis
of samples. Subsequent, routine, off-site analysis
could be limited to scanning for only PHCs, saving
time and resources. Special adsorbents and
sampling conditions can be used for specific PHCs
if desired while continued multi-media sampling
provides a base for analysis of additional PHCs
that may be identified during the course of cleanup
operations.
Passive Dosimeters. A less traditional method
of sampling is the use of passive dosimeters. The
few passive dosimeters now available are for gases
and vapors only. Although passive dosimeters are
used primarily to monitor personal exposure, they
also can be used to monitor areas. Passive
monitors are divided into two groups:
• Diffusion samplers, in which molecules move
across a concentration gradient, usually
achieved within a stagnant layer of air,
between the contaminated atmosphere and
the indicator material.
• Permeation devices, which rely on the natural
permeation of a contaminant through a
membrane. A suitable membrane is selected
that is easily permeated by the contaminant of
interest and impermeable to all others.
Permeation dosimeters, therefore, are useful
in picking out a single contaminant from a
mixture of possible interfering contaminants.
Some passive dosimeters may be read directly,
as are DRIs and colorimetric length-of-stain
tubes. Others require laboratory analysis similar
to that conducted on solid sorbents.
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EXHIBIT 6-2
Summary of Common Air Collection/Analytical Methods
Contaminant
Alcohols
Aliphatic Amines
Aromatic Amines
Asbestos
Cyanides
Dioxin
Hydrocarbons:
BP 36-126°C
Aromatic
Halogenated
Inorganic Acids
Mercury
Metals (elements)
RGBs
Pesticides/PCBs
Polyaromatic
Hydrocarbons (PAH)
Volatile organics
Volatile organics
Collection Media
Charcoal
Silica Gel
Silica Gel
25 mm 0.8 urn MCEF filter
25 mm 0.45 ^m MCEF filter
0.8 (im MCEF filter and impinger
3" polyurethane foam plug/filter
Charcoal
Washed Silica Gel
Hopcolite/Hydrar
37 mm 0.8 jim MCEF filter
Florisil® and 13 mm glass fiber
filter
3" polyurethane foam plug
Washed XAD-2, 37 mm PTFE
filter w/support O-ring
2" x 1" Polyurethane Foam
Tenax®/carbonized molecular
sieve (CMS)
SUMMA® canister, SUMMA®
canister w/critical orifice
Collection Method
NIOSH 1400
NIOSH 1401
NIOSH 1402
NIOSH 2010
NIOSH 2002
NIOSH 7400
NIOSH 7402
NIOSH 7904
EPA TO-9
NIOSH 1500
NIOSH 1501
NIOSH 1003
NIOSH 7903
NIOSH 6009
NIOSH 7300
Lewis/McCleod
Modified
NIOSH 5503
EPA TO-4
NIOSH 5515
NIOSH 5506
EPA TO-1
EPA TO-2
EPA TO-1 4
Analytical Method
GC-FID
GC-FID
GC-FID
PCM
TEM
ISE
GC/MS
GC-FID
EPA Modified GC/MS
1C
AA
ICP-AES
GC-ECD
GC-ECD
GC-PID
HPLC-UV
GC-MS
GC-ECD, NPD or FID
GC/MS
LEGEND: AA: Atomic Absorption
GC-ECD: Gas Chromatography-Electron Capture Detector
GC-FID: Gas Chromatography-Flame lonization Detector
NPD: Nitrogen-Phosphorus Detector
GC-MS: Gas Chromatography
1C: Ion Chromatography
ICP-AES: Inductively Coupled Argon Plasma, Atomic Emission Spectroscopy
ISE: Ion Specific Electrode
PCM Phase Contrast Microscopy
TEM. Transmission Electron Microscopy
HPLC-UV- High-Pressure Liquid Chromatography with UV Detector
Note: The flow rates that appear in the NIOSH methods are often modified for outdoor ambient air sampling.
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6.5 GENERAL MONITORING PRACTICES
Air sampling should be conducted using a
variety of media to identify the major classes of
airborne contaminants and their concentrations.
The following sampling pattern can be used as a
guideline. After visually identifying the sources of
possible generation, air samples should be
collected downwind from the designated source
along the axis of the wind direction. Work should
proceed upwind to a point as close as possible to
the source. Level B protection (see Section 6.9.3)
should be worn during this initial sampling. Levels
of protection for subsequent sampling should be
based upon the results obtained and the potential
for an unexpected release of chemicals.
After reaching the source, or finding the
highest concentration, samples should be collected
along the cross-axis of the wind direction to
determine the degree of dispersion. Smoke
plumes, or plumes of instrument-detectable
airborne substances, may be released as an aid in
this assessment. To ensure that there is no
background interference and that the detected
substance(s) originate from the identified source,
air samples also should be collected upwind from
the source.
6.5.1 Perimeter Monitoring
Fixed-location monitoring at the "fenceline"
or perimeter, where PPE is no longer required,
measures contaminant migration away from the
site and enables the Site Health and Safety Officer
to evaluate the integrity of the site's clean areas.
Because the fixed-location samples may reflect
exposures either upwind or downwind from the
site, wind speed and direction data are needed to
interpret the sample results.
6.5.2 Periodic Monitoring
Site conditions and atmospheric chemical
conditions may change following the initial
characterization. Periodic monitoring should be
conducted when the possibility of a dangerous
condition has developed or when there is reason to
believe that exposures may have risen above PELs
since prior monitoring was conducted. The
possibility that exposures have risen should be
seriously considered when:
• Work begins on a different portion of the
site;
• Different contaminants are being handled;
• A markedly different type of operation is
initiated (e.g., barrel opening as opposed to
exploratory well drilling); or
• Workers are handing leaking drums or
working in areas with obvious liquid
contamination (e.g., a spill or lagoon).
6.5.3 Personal Monitoring
The selective monitoring of
high-risk workers (i.e., those
who are closest to the source
of contaminant generation) is
required by 29 CFR §1910.
120(h). This requirement is
based on the probability that
significant exposure varies directly with distance
from the source. If workers closest to the source
are not significantly exposed, then other workers,
presumably, are not significantly exposed and
should not need to be monitored.
Because occupational exposures are linked
closely with active material handling, personal air
sampling is not necessary until site operations have
begun. Thus, monitoring of those employees likely
to have the highest exposures to hazardous
substances and health hazards is not required until
the actual cleanup phase commences (e.g., when
soils, surface waters, or containers are moved or
disturbed). Personal monitoring samples should be
collected in the breathing zone and, if workers are
wearing respiratory protective equipment, outside
the facepiece. These samples represent the actual
inhalation exposure of workers who are not
wearing respiratory protection and the potential
exposure of workers who are wearing respirators.
Sampling should occur frequently enough to
characterize employee exposures. If any employee
is exposed to concentrations over PELs,
monitoring must continue to ensure the safety of
all employees likely to be exposed to concen-
trations above those limits.
Personal monitoring may require the use of
a variety of sampling media. Unfortunately, single
workers cannot carry multiple sampling media
because of the added strain and because it is not
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usually possible to draw air through different
sampling media using a single portable, battery-
operated pump. Consequently, several days may be
required to measure the exposure of a specific
individual using each of the media. Alternatively,
if workers are in teams, a different monitoring
device can be assigned to each team member.
Another method is to place multiple sampling
devices on pieces of heavy equipment. While these
are not personal samples, they can be collected
very close to the breathing zone of the heavy
equipment operator and thus would be reasonably
representative of personal exposures. These multi-
media samples can yield as much information as
several personal samples.
6.6 METEOROLOGICAL
CONSIDERATIONS
Meteorological information is
an integral part of any air
monitoring program. Data
concerning wind speed and
direction, temperature,
barometric pressure, and
humidity, singularly or in
combination, are needed for selecting air sampling
locations, calculating air dispersion, calibrating
instruments, and determining population at risk of
exposure from airborne contaminants.
Knowledge of wind speed and direction is
necessary to effectively place air samplers. In
source-oriented ambient air sampling, it is
particularly important that samplers be located at
varying distances downwind from the source.
Similarly, it is important that background air
samples be collected upwind from the source.
Samplers should be relocated or adjusted to reflect
shifts in wind direction. In addition, atmospheric
simulation models for predicting contaminant
dispersion and concentration need wind speed and
direction as inputs for predictive calculations.
Information may be needed concerning the
frequency and intensity of winds from certain
directions (windrose data). Consequently, wind
direction must be monitored continually.
Air sampling systems need to be calibrated
before use and corrections in the calibration curves
made for temperature and pressure. After
sampling, sampled air volumes should also be
corrected for temperature and pressure variations.
This requires data on air temperature and pressure
during sampling.
Data may be collected from on-site
meteorological stations or from government or
private organizations that routinely collect
meteorological data. The site manager should base
data collection decisions on the availability of
reliable data at the site, the resources needed to
obtain meteorological equipment, the level of
confidence required for the data, and the ultimate
use of the data.
6.7 LONG-TERM AIR MONITORING
PROGRAMS
A variety of long-term air monitoring
programs can be designed to detect a wide range of
airborne compounds. A number of factors should
be considered before implementing any program,
including type of equipment, costs, personnel,
accuracy of analysis, time to obtain results (turn-
around time), and availability of analytical
laboratories.
One approach to air monitoring, developed
and used by the ERT, is described here. This
program achieves a reasonable balance between
cost, accuracy, and time in obtaining data using a
combination of DRIs and air sampling systems.
The data is used to survey for airborne organic
vapors and gases, to identify and measure organic
vapors and gases, and to identify and measure
particulates and inorganic vapors and gases. The
ERT approach is based on:
• Using flame ionization detectors (FIDs)
and/or photoionization detectors (PIDs) for
initial detection of total organic gases and
vapors and for periodic site surveys (for
total organics). Equipped with strip chart
recorders, the detectors are used as area
monitors to record total organic
concentrations and changes in
concentration over a period of time.
Calibrated to specific organic contaminants,
they are used to detect and measure those
substances.
• Collecting area air samples using personal
pumps and organic gasMpor collection
tubes. Samples are analyzed using the gas
chromatograph (GC) capabilities of field
instruments. Selected samples are also
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analyzed in laboratories accredited by the
American Industrial Hygiene Association
(AIHA).
Using PIDs and/or FIDs (as a survey
instrument or GC) to provide real-time
data and to screen the number of samples
needed for laboratory analysis.
Sampling for particulates, inorganic acids,
aromatic amines, halogenated pesticides,
etc., when they are known to be present or
when there are indications that these
substances may be a problem.
6.8 VARIABLES IN HAZARDOUS WASTE
SITE AIR MONITORING
Complex environments involving numerous
substances, such as those associated with hazardous
waste sites, pose significant challenges to accurately
and safely assessing airborne contaminants.
Several independent and uncontrollable variables,
most notably temperature and weather conditions,
can affect airborne concentrations. These factors
must be considered when developing an air
monitoring program and when analyzing data.
Some of the more important variables include:
Temperature. An increase in
temperature increases the vapor
pressure of most chemicals.
Wind Speed. An increase in wind
speed can affect vapor concentrations
near a free-standing liquid surface.
Dusts and particulate-bound
Rainfall. Water from rainfall can
essentially cap or plug vapor emission
routes from open or closed containers,
saturated soil, or lagoons, thereby
Moisture. Dusts, including finely
divided hazardous solids, are highly
sensitive to moisture content. This
moisture content can vary significantly
with respect to location and time and can also
affect the accuracy of many sampling results.
Vapor Emissions. The physical
displacement of saturated vapors can
produce short-term, relatively high,
i —i vapor concentrations. Continuing
evaporation and/or diffusion may produce long-
term low vapor concentrations and may involve
large areas.
Work Activities. Work activities often
require the mechanical disturbance of
contaminated materials, which may
change the concentration and
composition of airborne contaminants.
6.9 USING VAPOR/GAS
CONCENTRATIONS TO DETERMINE
LEVEL OF PROTECTION
The objective of using total atmospheric
vapor/gas concentrations is to determine a
numerical criterion for selecting the appropriate
level of PPE (e.g., Level A, B, or C). In situations
where the presence of vapors or gases is not
known, or if present, the individual components
are unknown, personnel required to enter that
environment must be protected. Total vapor/gas
concentration can be used as a guide for selecting
PPE until more definitive criteria can be
determined (e.g., until the constituents and
atmospheric concentrations of vapor, gas, or
particulates can be determined, and until
respiratory and body protection can be chosen that
relate to the toxicological properties of these
constituents.)
Although total vapor/gas concentration
measurements are useful to a qualified professional
for the selection of protective equipment, caution
should be exercised in their interpretation. An
instrument does not respond with the same
sensitivity to several vapor/gas contaminants as it
does to a single contaminant. Also, because total
vapor/gas field instruments detect all contaminants
in relation to a specific calibration gas, the
concentration of unknown gases or vapors may be
either overestimated or underestimated.
Suspected carcinogens, particulates, highly
hazardous substances, infectious wastes, or other
substances that do not elicit an instrument
response may be known or suspected to be present.
Therefore, the protection level should not be based
solely on the total vapor/gas criterion. Rather, the
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level should be selected on a case-by-case basis,
with special emphasis on potential exposure from
the chemical and toxicological characteristics of the
known or suspected material.
6.9.1 Factors for Consideration
A number of factors should be considered
when using total atmospheric vapor/gas
concentrations as a guide for monitoring a selected
Level of Protection. First, the uses, limitations,
and operating characteristics of the monitoring
instruments must be recognized and understood.
Instruments such as the photoionization detector
(PID), flame ionization detector (FID), and others
do not respond identically to the same
concentration of a substance; nor do they respond
to all substances. Therefore, experience,
knowledge, and good judgement must be used to
complement the data obtained with instruments.
Second, other hazards may exist such as gases
not detected by the PID or FID (i.e., phosgene,
cyanides, arsenic, chlorine), explosives, flammable
materials, oxygen deficiency, liquid/solid particles,
and liquid or solid chemicals. Vapors and gases
with a very low Threshold Limit Value (TLV) or
IDLH value could also be present. Total readings
on instruments not calibrated to these substances
may not indicate unsafe conditions.
The risk to personnel entering an area must
be weighed against the need for entering.
Although this assessment is largely a value
judgment, it requires a conscientious balancing of
the known and potential risks to personnel against
the need to enter an unknown environment.
The knowledge that suspected carcinogens or
extremely toxic substances are present requires an
evaluation of a number of factors, such as the
potential for exposure, chemical characteristics of
the materials present, and the limitations of
monitoring instruments and PPE relative to the
tasks that must be done on-site.
On-site activities must be evaluated to choose
the correct level of PPE. Based upon total
atmospheric vapor concentrations, Level C
protection may be judged adequate; however, tasks
such as moving drums, opening containers, and
bulking of materials, which increase the probability
of liquid splashes or generation of vapors, gases, or
particulates, will likely require a higher level of
protection.
The following sections provide information
on levels of protection (refer to Chapter 5 for
more information on selecting PPE).
6.9.2 Level A Protection (500 to
1,000 ppm)
Level A protection provides the highest
degree of respiratory tract, skin, and eye protection
if the inherent limitations of the PPE are not
exceeded. Although Level A provides protection
against air concentrations greater than 1,000 ppm
for most substances, an operational restriction of
1,000 ppm is established as a warning flag to:
• Evaluate the need to enter environments
with unknown constituents at
concentrations greater than 1,000 ppm;
• Identify the specific chemical constituents
contributing to the total concentration and
their associated toxic properties;
• Determine more precisely the
concentrations of constituent chemicals;
• Evaluate the calibration and/or sensitivity
error associated with the instrument(s); and
• Evaluate instrument sensitivity to wind
velocity, humidity, temperature, etc.
A limit of 500 ppm total vapors/gases in air
was selected as the value at which to upgrade from
Level B to Level A. This concentration was
selected to fully protect the skin until the
constituents can be identified and measured and
substances affecting the skin are excluded. The
range of 500 to 1,000 ppm is sufficiently
conservative to provide a safe margin of protection
if readings are low due to instrument error,
calibration, and sensitivity; if higher than
anticipated concentrations occur; and if substances
highly toxic to the skin are present.
Ambient air concentrations approaching 500
ppm have not routinely been encountered on
hazardous waste sites. Such high concentrations
have been encountered only in closed buildings,
when containers were being opened, when
personnel were working in the spilled contam-
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inants, or when organic vapors/gases were released
in transportation accidents. A decision to require
Level A protection should also consider the
negative aspects: higher probability of accidents
due to cumbersome equipment, and most
importantly, the physical stress caused by heat
buildup in fully encapsulating suits.
6.9.3 Level B Protection (5 to 500 ppm)
Level B protection is the minimum level of
protection recommended for initially entering an
open site where the type, concentration, and
presence of airborne vapors are unknown. This
level of protection provides a high degree of
respiratory protection. Skin and eyes are also
protected, although a small portion of the body
(neck and sides of head) may be exposed. The use
of a separate hood or hooded, chemical-resistant
jacket would further reduce the potential for
exposure to this area of the body. Level B
impermeable protective clothing also increases the
probability of heat stress.
A limit of 500 ppm total atmospheric
vapor/gas concentration on portable field
instruments has been selected as the upper
restriction on the use of Level B. Although Level
B PPE should be adequate for most commonly
encountered substances at air concentrations
higher than 500 ppm, this limit has been selected
as a decision point for a careful evaluation of the
risks associated with higher concentrations. The
following factors should be considered when
selecting Level B protection:
• The necessity for entering environments
with unknown constituents at
concentrations higher than 500 ppm
wearing Level B protection;
• The probability that substance(s) present
pose severe skin hazards;
• The work to be done and the increased
probability of exposure;
• The need for qualitative and quantitative
identification of the specific components;
• Inherent limitations of the instruments used
for air monitoring; and
• Instrument sensitivity to winds, humidity,
temperature, arid other factors.
6.9.4 Level C Protection (Background
to 5 ppm)
Level C provides skin protection identical to
Level B, assuming the same type of chemical
protective clothing is worn, but lesser protection
against inhalation hazards. A range of background
to 5 ppm above ambient background
concentrations of vapors/gases in the atmosphere
has been established as guidance for selecting
Level C protection. Concentrations in the air of
unidentified vapors/gases approaching or exceeding
5 ppm would warrant upgrading respiratory
protection to a self-contained breathing apparatus.
A full-face, air-purifying mask equipped with
an organic vapor canister (or a combined organic
vapor/particulate canister) provides protection
against low concentrations of most common
organic vapors/gases. There are some substances
against which full-face, canister equipped masks do
not protect, for example, substances with very low
Threshold Limit Values (TLV) or IDLH concen-
trations. Many of the latter substances are gases
or liquids in their normal state. Gases would only
be found in gas cylinders, while the liquids would
not ordinarily be found in standard containers or
drums.
Every possible effort should be made to
identify the individual constituents (and the
presence of particulates) contributing to such low
total vapor readings. Respiratory protective
equipment can then be selected accordingly. It is
exceedingly difficult, however, to provide constant,
real-time identification of all components with
concentrations of less than 5 ppm in a vapor cloud
at a site where ambient concentrations are
constantly changing.
If highly toxic substances have been ruled out,
but ambient levels of less than 5 ppm persist, it is
unreasonable to assume only self-contained
breathing apparatus should be worn. The
continuous use of air-purifying masks in such low
vapor/gas concentrations gives a reasonable
assurance that the respiratory tract is protected,
provided that the absence of highly toxic
substances has been confirmed.
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Full-face, air-purifying devices are capable of Also, unanticipated transient excursions may
providing respiratory protection against most increase the concentrations in the environment
vapors at greater than 5 ppm; however, until above the limits of air-purifying devices. The
definitive qualitative information is available, a increased probability of exposure due to the work
concentration of greater than 5 ppm requires that being done may require Level B protection, even
a higher level of respiratory protection be used. though ambient levels are low.
FURTHER GUIDANCE: For more information on air monitoring equipment and procedures, see:
1. Standard Operating Guide for Air Sampling and Monitoring at Emergency Responses (U.S. EPA,
draft, Publication 9285.2-03A).
2. Standard Operating Guide for the Use of Air Monitoring Equipment for Emergency Response (U.S.
EPA, draft, expected Summer 1992).
3. Manual of Analytical Methods, (Volumes 1-3, 3rd Edition, with supplements) (NIOSH, 1989,
Publication 89-127).
4. Compendium of Methods for Determination of Toxic Organic Compounds in Air (U.S. EPA, 1987,
EPA 600/4-87/006).
5. OSHA Analytical Methods. The OSHA Technical Center maintains an updated database of
analytical testing methods. Printouts of analytical methods for individual chemicals are
available by request. Contact the OSHA Technical Center, 1781 South 300 West, Salt
Lake City, UT, 84115 (801) 524-5287.
6. Air Methods Database. Available on the Cleanup Information electronic bulletin board
(CLU-IN), formerly OSWER BBS. For further information, call (301) 589-8366.
Communications: No Parity, 8 Databits, I Stopbit, F Duplex.
7. Removal Program Representative Sampling Guidance: Air (U.S. EPA, draft, expected Summer
1992).
8. Respiratory Decision Logic (NIOSH, 1987, Publication 87-108).
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CHAPTER 7 MEDICAL SURVEILLANCE PROGRAM
E
F P
T O Z
L P E D
P E C F D
E D F C Z P
DEFPOTEC
1
2
3
4
5
6
7
8
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CHAPTER 7 MEDICAL SURVEILLANCE PROGRAM
7.0 INTRODUCTION
Workers engaged in hazardous
waste operations and
emergency response activities
perform tasks that may expose
them to a number of potential
hazards, including: toxic
chemicals; safety and biological
hazards; and physical agents, such as heat stress
and radiation. A medical program is essential for
assessing and monitoring employee health, both
prior to placement and during the course of work;
for providing emergency and other treatment, as
needed; and for keeping accurate records for future
reference. A comprehensive medical surveillance
program is required by §1910.120(f) of
HAZWOPER. The standards contain provisions
for baseline, periodic, and termination medical
examinations.
The goal of a medical surveillance program,
and of appropriate screening and monitoring in the
workplace, is the protection of employees' health.
Two factors are critical for achieving this goal:
• Detecting pre-existing disease or medical
conditions that may place an employee
performing certain tasks at an increased
risk; and
• Minimizing individual exposures at the
workplace, so that the disease process is
never initiated.
Helping to place and maintain employees in
work that is commensurate with their capabilities
and, whenever possible, attempting to avoid certain
exposure situations, will help achieve this goal of
disease prevention.
An employer should develop a comprehensive
medical program based on the specific needs,
location, and potential exposures of its employees.
The program should be designed by an experienced
occupational health physician or other qualified
occupational health consultant in conjunction with
the employer's occupational health and safety
professional. All occupational medical monitoring
examinations and procedures should be performed
by or under the direction of a physician who is
board-certified in occupational medicine or a
medical doctor who has had extensive experience
managing occupational health services.
7.1 EMPLOYEES COVERED BY THE
SURVEILLANCE PROGRAM
A medical surveillance program must include
monitoring for four groups of employees:
• Employees who are, or may be, exposed to
PELs of hazardous substances or health
hazards for 30 or more days per year;
• Employees who wear a respirator for 30 or
more days per year;
• Members of organized HAZMAT teams;
and
• Employees who are injured as a result of
overexposure during a site emergency, or
who show symptoms of illness that may
have resulted from exposure to hazardous
substances.
OSHA standards represent only the minimum
that is required by law and in no way preclude
anyone from taking additional actions to ensure
the well-being of their employees. For example,
the medical surveillance policy for EPA employees
(as outlined in the OSWER Integrated Health and
Safety Program Standard Operating Practice) is
more restrictive than the OSHA standards, and
requires monitoring for employees who are
potentially exposed to hazardous substances for 20
or more days per year.
7.2 FREQUENCY AND CONTENT OF
MEDICAL EXAMINATIONS
All employees who are required by
HAZWOPER to participate in a medical
surveillance program must undergo a baseline
medical examination prior to a field assignment.
After this initial examination, employees must have
a follow-up medical exam at least once per year,
unless an attending physician believes a longer
interval is appropriate. This longer interval,
however, cannot exceed 2 years.
79
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If the attending physician believes it is
necessary by virtue of the nature of employees'
potential exposure, more frequent medical
examinations may be required. Irrespective of
whether a baseline exam was performed, employees
must also receive a medical examination as soon as
possible if:
• The employee is injured or becomes ill
from exposure to hazardous substances on-
site; or
• The employee develops signs or symptoms
indicative of possible overexposure to
hazardous substances.
All potentially exposed employees must be trained
to recognize symptoms that might be indicative of
overexposure to chemicals or physical agents such
as heat stress. These could include dizziness,
rashes, shortness of breath, numbness, and fatigue.
In addition, employees who are reassigned or
who terminate employment must receive a final
examination. This examination is only required if
the employee has not had an examination within
the past 6 months. All required medical
examinations must be provided without cost to the
employee, without loss of pay, and at a reasonable
time and place.
The content of medical examinations should
be determined by the attending physician and the
site Health and Safety Officer, but certain key
elements must be included. The physician must
complete a medical and work history with
emphasis on the symptoms related to handling
hazardous substances. Further, the physician must
determine the employee's fitness for the types of
duties to be assigned, including whether the
employee needs to wear personal protective
equipment based on the anticipated conditions at
the work site.
To ensure that the physician understands the
OSHA and EPA medical surveillance require-
ments, the employer must provide a copy of the
standard and its appendices to the physician.
Substance-specific standards (e.g., for lead and
asbestos) should also be provided, if appropriate.
The employer is also responsible for describing to
the physician each employee's duties relative to
potential exposure levels. Additionally, the
physician must be provided with information from
the employee's previous medical exams and a
complete description of the types of PPE that the
employee will be expected to wear. This
information is required so that the physician can
adequately assess the employee's capacity to wear
PPE and other required equipment.
Once an exam has been completed, the
physician must submit a written opinion to the
employer who then has the responsibility to
provide that opinion to the employee. The
opinion must contain:
• The results of the medical examination and
tests;
• Any recommended work limitations; and
• The physician's opinion concerning the
medical condition of the employee,
including any conditions that need further
examination and treatment, or that would
place the employee at an increased risk of
injury from respirator use or work in a
hazardous substance environment.
Exhibit 7-1 outlines a recommended medical
program with screening and examination protocols.
These recommendations are based on known
health risks for hazardous waste site personnel, 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 provided here.
7.2.1 Baseline Screening
Pre-placement or baseline screening has two
major functions: (1) to determine an individual's
fitness for duty, including the ability to work while
wearing protective equipment; and (2) to provide
baseline data for comparison with future medical
data. To ensure that prospective employees are
able to meet work requirements, the pre-placement
screening should focus on the following areas:
Occupational and Medical History
• Require all personnel to fill out an
occupational and medical history
questionnaire, describing all prior
occupational exposures to chemical and
physical hazards.
80
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EXHIBIT 7-1
Minimum Examination Types and Protocols
Examination Type
History and Physical Exam
Complete Medical History
Interval History
Physical Examination by Physician
Visual Acuity
Routine Laboratory
Tests/Procedures
Pulmonary Function
Audiometry
Electrocardiogram
Chest X-ray*
Complete Blood Count
Routine Urinalysis
Blood Chemistry
Special Tests**
Cholinesterase
Methemoglobin
Heavy Metal Screen
Urine and Sputum Cytology
Polychlorinated Biphenyl (PCB)
Cardiovascular Stress Test
Baseline
X
X
X
X
X
X
X
X
X
X
X
0
X
0
0
X
Periodic
X
X
X
X
X
0
0
X
X
X
0
O
0
0
0
0
Termination
X
X
X
X
X
X
X
X
X
X
O
O
0
0
0
~
Unscheduled
X
X
O
O
O
0
O
0
0
0
O
0
0
0
0
~
X Recommended
O As indicated
* Chest X-rays not repeated more than once per year.
** Any special test which may be considered on a periodic basic should be included in the
baseline test.
Source: Occupational Medical Monitoring Program Guidelines for SARA Hazardous Waste Field Activity
Personnel (U.S. EPA, 1990, Publication 9285.3-04).
Take note of 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, heat intolerance,
or sensitivity to particular substances.
• Record relevant lifestyle habits (e.g.,
smoking, alcohol/drug use) and hobbies.
Physical Examination
• Conduct a comprehensive physical
examination focusing on the pulmonary,
cardiovascular, and musculoskeletal systems.
81
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• Note conditions that could increase
susceptibility to heat stroke or that could
affect respirator use.
Ability to Work While Wearing PPE
• Disqualify individuals who are 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 PPE.
• Provide additional testing for ability to
wear PPE where necessary.
• Complete a written assessment of worker's
capacity to perform while wear a respirator,
if wearing a respirator is a job requirement.
Note that the OSHA respirator standard
(29 CFR §1910.134) states that no
employee should be assigned to a task that
requires the use of a respirator unless that
person is physically able to perform under
such conditions.
Pre-placement screening can be used to
establish baseline data to verify the efficacy of
protective measures and to determine whether
exposures have adversely affected the worker.
Baseline testing may include both medical
screening tests and biologic monitoring tests.
Given the problem in predicting significant
exposures for these workers, there are no clear
guidelines for prescribing specific tests.
7.2.2 Periodic Medical Examinations
Periodic medical examinations should be
developed and used in conjunction with pre-
placement screening examinations. Comparison of
sequential medical reports with baseline data is
essential for determining biologic trends that may
mark early signs of adverse health effects, and
thereby facilitate appropriate protective measures.
The frequency and content of examinations
will vary, depending on the nature of the work and
exposures. It is recommended that medical exam-
inations be conducted at least annually; however,
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. Periodic screening
exams can include:
• Interval medical history, focusing on
changes in health status, illnesses, and
possible work-related symptoms;
• Physical examination; and
• Additional medical testing, depending on
available exposure information, medical
history, and examination results. Testing
specific to possible medical effects of the
worker's exposure can include pulmonary
function tests, audiometric tests, vision
tests, and blood and urine tests.
7.2.3 Termination Examination
At the end of employment as a hazardous
waste site worker, all personnel should have a
termination medical examination. A full
examination is necessary at the termination of
employment if any of the following criteria are not
met:
• The last full medical examination was
within the last 6 months;
• No exposure occurred since the last
examination; and
• No symptoms associated with exposure
occurred since the last examination.
7.3 EMERGENCY TREATMENT
Provisions for emergency
treatment and acute non-
emergency treatment should be
made at each site. When
developing plans, procedures,
and equipment lists, the range
of actual and potential hazards
specific to the site should be considered, including
chemical, physical, and biological hazards.
Contractors, visitors, and other personnel may
require emergency treatment in addition to site
workers.
82
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Emergency medical treatment should be
integrated into the overall site emergency response
program. Exhibit 7-2 lists the recommended
guidelines for establishing an emergency treatment
program. 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.
Non-emergency medical care should be
arranged for hazardous waste site personnel who
are experiencing health effects resulting from an
exposure to hazardous substances. In conjunction
with the medical surveillance program, off-site
medical care should ensure that any potential job-
related symptoms or illnesses are evaluated in the
context of the employee's exposure. Off-site
medical personnel should also investigate and treat
non-job-related illnesses that may put the
employee at risk because of task requirements.
7.4 CHEMICAL CONTAMINATION
Employees at hazardous waste
sites may be exposed to a
number of toxic chemicals with
dangerous properties. Most
sites contain a variety of
chemical substances in gaseous,
liquid, or solid forms that can
enter the unprotected body. Exhibit 7-3 lists some
common chemicals found at hazardous waste sites,
their potential health effects, and recommended
medical procedures for monitoring employee
exposure.
Preventing exposure to toxic chemicals is a
primary concern at any site. Protective clothing
and respirators help prevent the wearer from
contamination, and good work practices and
engineering controls help reduce contamination on
protective clothing, instruments, and equipment.
EXHIBIT 7-2
Recommended Guidelines for Establishing an Emergency Treatment Program
/ Train a team of site personnel in emergency
first aid, including CPR and training that
emphasizes treatment for explosion and burn
injuries, heat stress, and acute chemical
toxicity. This team should include an
emergency medical technician if possible.
/ Train personnel in emergency decontamina-
tion procedures in coordination with the
Emergency Response Plan (see Chapter 9).
/ Predesignate roles and responsibilities to be
assumed by personnel in an emergency.
/ Establish an emergency/first-aid station on-
site, capable of providing stabilization for
patients requiring off-site treatment and
general first aid.
/ 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
toxicologist, dermatologist, hematologist,
allergist, ophthalmologist, cardiologist, and
neurologist).
/ Establish a protocol for monitoring heat
stress.
/ Make plans in advance for emergency
transportation to and contamination control
procedures for treatment at a nearby
medical facility.
/ Post names, phone numbers, addresses,
and procedures for contacting on-call
physicians, medical specialists, ambulance
services, medical facilities, emergency, fire,
and police services, and poison control
hotline.
/ Provide maps and directions to medical
facilities, and confirm that all managers and
individuals involved in medical response
know the location of the nearest emergency
medical facility.
/ Establish a radio-communication system for
emergency use.
/ Review emergency procedures daily with
site personnel at safety meetings before
beginning work shifts.
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EXHIBIT 7-3
Common Chemical Toxicants Found at Hazardous Waste Sites, thefr Health Effects, and Medical Monitoring"
HAZARDOUS
SUBSTANCE OR
CHEMICAL
GROUP
Aromatic
Hydrocarbons
Asbestos (or
asbestiform
particles)
Dioxin (see
Herbicides)
COMPOUNDS
Benzene
Ethyl benzene
Toluene
Xylene
USES
Commercial solvents and
intermediates for
synthesis in the chemical
and pharmaceutical
industries.
A variety of industrial
uses, including:
Buildino
Construction
Cement work
Insulation
Fireproofing
Pipes and ducts for
water, air, and chemicals
Automobile brake pads
and linings
TARGET ORGANS
Blood
Bone marrow
CNSb
Eyes
Respiratory system
Skin
Liver
Kidney
Lungs
Gastrointestinal
system
POTENTIAL HEALTH EFFECTS
All cause:
CNSb depression: decreased alertness,
headache, sleepiness, loss of
consciousness.
Defatting dermatitis
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.
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.
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:
CBCC
Platelet count
Measurement of kidney and liver function
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.
Source Occupational Safety and Health Guidance Manual lor Hazardous Wuste Site Activities (NIOSH/OSHA/USCG/EPA, 1985)
b CNS = Central nervous system.
c CBC = Complete blood count
-------
EXHIBIT 7-3 (cont'd)
Common Chemical Toxicants Found at Hazardous Waste Sites, their Health Effects, and Medical Monitoring'
HAZARDOUS
SUBSTANCE OR
CHEMICAL
GROUP
Aromatic
Hydrocarbons
Asbestos (or
asbestlform
particles)
Dloxln (see
Herbicides)
COMPOUNDS
Benzene
Ethyl benzene
Toluene
Xylene
USES
Commercial solvents and
Intermediates for
synthesis in the chemical
and pharmaceutical
Industries.
A variety of industrial
uses, including:
Building
Construction
Cement work
Insulation
Fireproofing
Pipes and ducts for
water, air, and chemicals
Automobile brake pads
and linings
TARGET ORGANS
Blood
Bone marrow
CNSb
Eyes
Respiratory system
Skin
Liver
Kidney
Lungs
Gastrointestinal
system
POTENTIAL HEALTH EFFECTS
All cause:
CNSb depression: decreased alertness,
headache, sleepiness, loss of
consciousness.
Detailing dermatitis.
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.
Chronic effects:
Lung cancer
Mesothelloma
Asbestosis
Gastrointestinal malignancies
Asbestos exposure coupled with cigarette
smoking has been shown to have a
synerglstic effect in the development of lung
cancer.
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:
CBC0
Platelet count
Measurement of kidney and liver function.
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.
Source Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (NIOSH/OSHA/USCG/EPA, 1985).
CNS = Central nervous system.
c CBC = Complete blood count.
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EXHIBIT 7-3 (cont'd)
Common Chemical Toxicants Found at Hazardous Waste Sites, their Health Effects, and Medical Monitoring (cont'd)
HAZARDOUS
SUBSTANCE OR
CHEMICAL
GROUP
Herbicides
Organochlorlne
Insecticides
COMPOUNDS
Chlorophenoxy
compounds.
2,4-dichloro-
phenosyacetic acid
(2,4-D)
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.
Chlorinated ethanes:
DDT
Cyclodienes.
Aldrin
Chlordane
Dieldrin
Endrin
Chlorocyclohexanes:
Lindane
USES
Vegetation control
Pest control
TARGET ORGANS
Kidney
Liver
CNSa
Skin
Kidney
Livor
CNSa
POTENTIAL HEALTH EFFECTS
Chlorophenoxy compounds can cause
chloracne, weakness or numbness of the
arms and legs, and may result in long-term
nerve damage.
Dioxin causes chloracne and may
aggravate pre-existing liver and kidney
diseases.
All cause acute symptoms of 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 skin and nervous system
Laboratory tests include:
Measurement of liver and kidney
function, where relevant.
Urinalysis.
History and physical exam should focus
on the nervous system.
Laboratory tests include
Measurement of kidney and liver
function.
CBCb for exposure to
Chlorocyclohexanes.
-------
EXHIBIT 7-3 (cont'd)
Common Chemical Toxicants Found at Hazardous Waste Sites, their Health Effects, and Medical Monitoring (cont'd)
HAZARDOUS
SUBSTANCE OR
CHEMICAL
GROUP
Organophosphate
and Carbamate
Insecticides
Polychlorlnated
Blphenyls (PCBs)
COMPOUNDS
Organophosphate:
Diazinon
Dichlorovos
Dimethoate
Trichlorfon
Malathion
Methyl parathion
Parathion
Carbamate.
Aldicarb
Baygon
Zectran
USES
Pest control
Wide variety of industrial
uses
TARGET ORGANS
CNSa
Liver
Kidney
Liver
CNS" (speculative)
Respiratory system
(speculative)
Skin
POTENTIAL HEALTH EFFECTS
All cause a chain of internal reactions
leading to neuromuscular 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.
Various skin ailments, including chloracne;
may cause liver toxicity; carcinogenic to
animals.
MEDICAL MONITORING
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.
Physical exam should focus on the skin
and liver
Laboratory tests include
Serum PCB levels.
Triglycendes and cholesterol
Measurement of liver function
e RBC = Red blood count.
-------
However, contamination can occur even with these
safeguards. It is important to identify the chemical
hazards that exist at a site, and to take steps to
prevent contamination.
Chemical exposures are generally divided into
two categories: acute and chronic. Symptoms
resulting from acute exposures usually occur during
and shortly after exposure to a high concentration
of a contaminants. A chronic exposure usually
occurs at a low concentration over a long period of
time. Lethal concentrations vary with each
chemical. The symptoms of an acute exposure for
a given contaminant may be completely different
from those resulting from a chronic exposure to
the same contaminant.
For chronic and acute exposures, the toxic
effect may be temporary and reversible or
permanent (causing disability or death). Although
some chemicals cause obvious symptoms (e.g.,
burning, nausea, rashes), others may causes health
damage without any warning signs (e.g., cancer,
respiratory disease). Some toxic chemicals may be
colorless and/or odorless, may dull the sense of
smell, or may not produce immediate or obvious
physiological sensation. A worker's senses or
feelings cannot be relied upon in all cases to warn
of toxic exposures. Exhibit 7-4 lists the signs and
warning symptoms of potential chemical exposure.
The primary routes of chemical contam-
ination are as follows:
Inhalation is an exposure route of concern
because the lungs are extremely vulnerable to
chemical agents. Respiratory protection should be
used if there is any possibility that the site may
contain hazardous substances that can be inhaled.
Chemicals can also enter the respiratory tract
through punctured eardrums.
Direct contact of the skin and eyes is another
route of exposure to hazardous substances. Some
chemicals will directly injure the skin; some may
pass through the skin into the bloodstream where
they are transported to vulnerable organs. This
absorption is enhanced by abrasions, cuts, heat,
and moisture. Workers can protect against direct
contact of a hazardous chemical by wearing PPE,
refraining from use of contact lenses in contam-
inated atmospheres, keeping hands away from the
face, and minimizing contact with liquid and solid
chemicals.
Ingestion occurs when chemicals are
accidentally swallowed.
Injection can occur when chemicals are
introduced into the body through puncture
wounds, such as those caused by stepping or
tripping or falling onto contaminated sharp
objects. To protect against this type of exposure,
the site should be prepared, and workers should
wear safety shoes, avoid physical hazards, and take
common sense precautions.
EXHIBIT 7-4
Signs and Symptoms of
Chemical Contamination
Behavioral changes
Breathing difficulties
Changes in complexion or skin color
Coordination difficulties
Coughing
Dizziness
Drooling, pupillary response
Diarrhea
Fatigue and/or weakness
Irritability
Irritation of eyes, nose, respiratory tract,
skin or throat
Headache
Light-headedness
Nausea
Sneezing
Sweating
Tearing
Blurred vision
Cramps
Tightness in the chest
88
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7.5 MEDICAL RECORDS AND
PROGRAM REVIEW
Medical records for employees
must be maintained for at least
30 years after employment is
terminated. These records must
include the name and social
security number of the
employee, the physician's
written opinions including recommended
occupational limitations and results of
examinations and tests, any employee medical
complaints related to occupational hazardous
substance exposure, and a copy of the material that
the attending physician was provided before the
examination. The employer is responsible for
retaining the records if the employee or physician
leaves the area, or if the company moves, is
acquired, or goes out of business. In addition,
employers who maintain 11 or more employees
must keep injury and illness records for each
establishment. Employers are also required to
provide access to these records upon request by
the employee or designated representative.
The medical surveillance program must be
evaluated regularly to ensure its effectiveness.
Maintenance and review of medical records and
test results aid in assessing the effectiveness of the
health and safety program. At a minimum, the
Corporate Health and Safety Officer should
perform the following record keeping activities
annually:
• Ensure that each accident or illness was
promptly investigated to determine the
cause and make necessary changes in health
and safety procedures;
• Evaluate specific medical testing to
determine potential site exposures;
• Add or delete medical tests as suggested by
current industrial hygiene and
environmental data;
• Review potential exposures and the HASP
at all sites to determine whether additional
testing is required; and
• Review emergency treatment procedures
and update lists of emergency contacts.
• Assure timely access upon employee
request
FURTHER GUIDANCE: For more information on developing a medical surveillance program, see:
1. NIOSH Pocket Guide to Chemical Hazards (NIOSH, 1991, Publication 90-117).
2. Occupational Medical Monitoring Program Guidelines for SARA Hazardous Waste Field Activity
Personnel (U.S. EPA, 1990, Publication 9285.3-04).
3. Occupational Safety and Health Guidelines for Chemical Hazards/Supplement II-OHG (NIOSH,
1989, Publication 89-104).
89
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CHAPTER 8 HEAT STRESS AND COLD EXPOSURE
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CHAPTER 8 HEAT STRESS AND COLD EXPOSURE
8.0 INTRODUCTION
Temperature extremes pose a hazard of
particular concern to the health, safety, and
comfort of personnel involved in hazardous waste
site activities. Site health and safety personnel
must consider the two most common dangers, heat
stress and cold exposure, when making decisions
regarding PPE selection and work mission
duration, when establishing standard operating
procedures for site activities, and when conducting
medical monitoring.
8.1 HEAT STRESS
Heat stress is one of the most
common and potentially
serious illnesses at hazardous
waste sites and, therefore,
warrants regular monitoring
and other preventive measures.
Heat stress is caused by a
number of interacting factors, including
environmental conditions, clothing, workload, and
the individual characteristics of the worker.
Depending on the ambient conditions and the
work being performed, heat stress can occur very
rapidly - within as little as 15 minutes - and can
pose as great a danger to worker health as chem-
ical exposure. In its early stages, heat stress can
cause rashes, cramps, and drowsiness. This can
result in impaired functional ability that threatens
the safety of both the individual and co-workers.
Continued heat stress can lead to heat stroke and
death.
8.1.1 Heat Stress and PPE
Heat stress is a major health hazard for
workers wearing PPE because the same protective
materials that shield the body from chemical
exposure also limit the dissipation of body heat
and moisture. Thus, personal protective clothing
can create a hazardous condition.
Reduced work tolerance and the increased
risk of excessive heat stress is directly influenced by
the amount and type of PPE worn. The added
weight and bulk of PPE severely reduces the body's
access to normal heat exchange mechanisms and
increases energy expenditure. When selecting PPE,
therefore, each item's benefit should be carefully
evaluated in relation to its potential for increasing
the risk of heat stress. After PPE has been
selected, the safe duration of work/rest periods
should be determined based on the anticipated
work rate, the ambient temperature and other
environmental factors, the type of protective
ensemble, and the individual worker characteristics
and fitness.
8.1.2 Monitoring for Heat Stress
All workers, even those not
wearing protective equipment,
should be monitored, because
the incidence of heat stress
depends on a variety of factors
and can affect any worker.
Monitoring should be initiated
before initial entry and should be continued during
each break cycle. Some general guidelines include:
• For workers wearing permeable clothing,
monitor for signs of heat stress and follow
established work/rest schedules.
• For workers wearing semipermeable or
impermeable encapsulating ensembles,
workers should also be monitored when the
temperature in the work area is above 70°F
(21°C). Below 70°F, monitoring is
considered on a case-by-case basis.
To conduct personnel monitoring, measure
the heart rate and body temperature, as follows:
Heart Rate. Count the radial pulse during a
30-second period as early as possible in the rest
period. If the heart rate exceeds 110 beats per
minute at the beginning of the rest period, shorten
the next work cycle by one-third and keep the rest
period the same. If the heart rate still exceeds 110
beats per minute at the next rest period, shorten
the following work cycle by one-third.
Oral Temperature.
Use a clinical
thermometer (3 minutes under the tongue) or
similar device to measure the oral temperature at
the end of the work period (before drinking). If
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EXHIBIT 8-1
Suggested Frequency of Physiological Monitoring for Fit and Acclimatized Workers8
ADJUSTED TEMPERATURE13
90° F (32.2°) or above
87.5°- 90°F (30.8°- 32.2°C)
82.5°- 87.5°F (28.1°- 30.8°C)
77.5"- 82.5" F (25.3°- 28.1 °C)
72.5°-77.5°F (22.5°-25.3°C)
NORMAL WORK ENSEMBLE0
After each 45 minutes of work
After each 60 minutes of work
After each 90 minutes of work
After each 120 minutes of work
After each 150 minutes of work
IMPERMEABLE ENSEMBLE
After each 15 minutes of work
After each 30 minutes of work
After each 60 minutes of work
After each 90 minutes of work
After each 120 minutes of work
a For work levels of 250 kilocalories/hour,
b Calculate the adjusted air temperature (ta adj) by using this equation: ta adj °F = ta°F+ (13X% sunshine).
Measure air temperature (ta) with a standard mercury-in-glass thermometer, with the bulb shielded from radiant heat.
Estimate percent sunshine by judging what percent time the sun is not covered by clouds that are thick enough to
produce a shadow. (100 percent sunshine = no cloud cover and a sharp, distinct shadow; 0 percent sunshine = no
shadows.)
0 A normal work ensemble consists of cotton coveralls or other cotton clothing with long sleeves and pants.
Source: Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities
(NIOSH/OSHA/USCG/EPA, 1985).
oral temperature exceeds 99.6°F (37.6°C), shorten
the next work cycle by one-third without changing
the rest period. If oral temperature still exceeds
99.6°F (37.6°C) at the beginning of the next rest
period, shorten the following work cycle by one-
third. Do not permit a worker to wear a
semipermeable or impermeable garment when
his/her oral temperature exceeds 100.6°F (38.1°C).
Initially, the length of the work cycle should
be governed by the frequency of the required
physiological monitoring. The frequency of
physiological monitoring depends on the air
temperature adjusted for solar radiation and the
level of physical work (see Exhibit 8-1, above).
8.1.3 Preventing Heat Stress
To protect against heat stress, it is important
to choose the appropriate level of protection, to
provide careful training for workers and site
personnel, and to monitor frequently personnel
who wear protective clothing. It is also important
to ensure that work and rest periods are scheduled
regularly, and that workers frequently replace lost
fluids (it is not uncommon for workers to lose as
many as 6 to 8 quarts of water in a hot shift).
Proper training and preventive measures will
help avert serious illness and loss of work
productivity caused by heat stress. Preventing heat
stress is particularly important because one
incident of heat stress will increase the likelihood
of future incidences. The site health and safety
officer should take the following steps to prevent
heat stress:
• Adjust work and rest schedules as needed;
• Provide shelter or shaded areas to protect
personnel during rest periods;
• Maintain workers' body fluids at normal
levels to ensure that the cardiovascular
system functions adequately. Daily fluid
intake must equal the approximate amount
of water lost in sweat;
• Encourage workers to maintain an optimal
level of physical fitness. Fit individuals may
acclimatize more readily to temperatures;
• Provide cooling devices to aid natural body
heat exchange during prolonged work or
severe heat exposure. Effective devices
94
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include field showers or hose-down areas,
as well as cooling jackets, vests, or suits;
• Train workers to recognize and treat heat
stress, and to identify the signs and
symptoms of heat stress (e.g., muscle
spasms, dizziness, lack of perspiration).
Refer to Exhibit 8-2 for more detail on the
signs and symptoms of heat stress.
8.2 COLD EXPOSURE
Exposure to cold temperatures
can cause frostbite and
hypothermia as well as impair
the ability to work. Extremely
low temperatures are not
necessary to suffer cold
exposure ~ a strong wind
combined with a cold temperature can chill the
body to the point where frostbite and hypothermia
are a risk. Maintaining body temperature and
recognizing the early signs and symptoms can help
prevent illness and injury due to cold exposure.
Cold injury is generally classified as local
(e.g., frostbite or frostnip) or general (e.g.,
hypothermia). The main factors contributing to
cold injury are exposure to humidity and high
winds, contact with wetness or metal, inadequate
clothing, age, and general health. Physical
conditions that worsen the effects of cold include
allergies, vascular disease, excessive smoking and
drinking, and use of specific drugs and medicines.
8.2.1 PPE And Cold Exposure
The correct PPE depends on the specific cold
stress situation. It is important to preserve the air
space between the body and the outer layer of
clothing in order to retain body heat. The more
air pockets each layer of clothing has, the better
the insulation. However, the insulating effect is
negated if the clothing interferes with the
evaporation of sweat, or if the skin or clothing is
wet.
The most important parts of the body to
protect are the feet, hands, head, and face. Hands
and feet are the farthest from the heart, and
become cooled most easily. Keeping the head
covered is important, because as much as 40
percent of body heat can be lost when the head is
exposed.
Workers should wear several layers of
clothing instead of a single heavy outer garment.
In addition to offering better insulation, layers of
clothing can be removed as needed to keep the
worker from overheating. The outer layer should
be windproof as well as waterproof, because body
heat is lost quickly in even light winds.
8.2.2 Monitoring for Cold Exposure
Recognizing the early signs and symptoms of
cold stress can help prevent serious injury.
Described below are the most common types of
cold injury and their monitoring signals.
Hypothermia. The first symptoms of
hypothermia are uncontrollable shivering and the
sensation of cold; the heartbeat slows and
sometimes becomes irregular, the pulse weakens,
and the blood pressure changes. Severe shaking or
rigid muscles may be caused by bursts of body
energy and changes in the body's chemistry.
Uncontrollable fits of shivering, vague or slow
slurred speech, memory lapses, incoherence and
drowsiness are some of the symptoms that can
occur. Other symptoms that can be seen before
complete collapse are cool skin, slow and irregular
breathing, low blood pressure, apparent
exhaustion, and fatigue after rest.
As the core body temperature drops, the
victim may become listless, confused, and make
little or no attempt to keep warm. Pain in the
extremities can be the first warning of dangerous
exposure to cold. Severe shivering must be taken
as a sign of danger. If the body core temperature
reaches about 85°F, significant and dangerous
drops in blood pressure, pulse rate, and respiration
can occur. In some cases, the victim may die.
Frostbite. Frostbite can occur without
hypothermia when the extremities do not receive
sufficient heat from central body stores. This can
occur because of inadequate circulation and/or
insulation. Frostbite occurs when there is freezing
of the fluids around the cells of the body tissues
due to extremely low temperatures. Frostbite may
result in damage to and loss of tissue, and usually
affects the nose, cheeks, ears, fingers, and toes.
Damage from frostbite can be serious (e.g.,
scarring, tissue death resulting in amputation, and
permanent loss of movement in the affected parts).
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EXHIBIT 8-2
Classification, Medical Aspects, and Prevention of Heat Illness
Category and Clinical Features
Predisposing Factors
Underlying
Physiological
Disturbance
Treatment
Prevention
Temperature Regulation Heatstroke
Heatstroke: (1) Hot, dry skin; usually
red, mottled, or oyanotic; (2) rectal
temperature 40.5CC (104°F) and over;
(3) confusion, loss of consciousness,
convulsions, rectal temperature
continues to rise; fatal if treatment is
delayed
(1) Sustained exertion in
heat by unacclimatized
workers; (2) lack of
physical fitness and
obesity; (3) recent alcohol
intake; (4) dehydration; (5)
individual susceptibility;
and (6) chronic
cardiovascular disease
Failure of the central drive
for sweating (cause
unknown) leading to loss of
evaporative cooling and an
uncontrolled accelerating
rise in tre; there may be
partial rather than complete
failure of sweating
Immediate and rapid
cooling by immersion in
chilled water with massage
or by wrapping in wet sheet
with vigorous fanning with
cool dry air; avoid
overcooling; treat shock if
present
Medical screening of workers,
selection based on health and
physical fitness; acclimatiz-
ation for 5-7 days by graded
work and heat exposure;
monitoring workers during
sustained work in severe heat
Circulatory Hypostasls Heat Syncope
Fainting while standing erect and
immobile in heat
Lack of acclimatization
Pooling of blood in dilated
vessels of skin and lower
parts of body
Remove to cooler area; rest
in recumbent position;
recovery prompt and
complete
Acclimatization; intermittent
activity to assist venous return
to heart
Water and/or Salt Depletion
(a) Heat Exhaustion
(1) Fatigue, nausea, headache,
giddiness; (2) skin clammy and moist;
complexion pale, muddy, or hectic
flush; (3) may faint on standing with
rapid thready pulse and low blood
pressure; (4) oral temperature normal
or low, but rectal temperature usually
elevated (37.5-38.5'C or 99.5-101.3°F);
water restriction type: urine volume
small, highly concentrated; salt
restriction type: urine less
concentrated chlorides less than 3 g/L
(b) Heat Cramps
Painful spasms of muscles used during
work (arms, legs, or abdominal); onset
during or after work hours
(1) Sustained exertion in
heat; (2) lack of
acclimatization; and (3)
failure to replace water lost
in sweat
(1) Dehydration from
deficiency of water; (2)
depletion of circulating
blood volume; (3)
circulatory strain from
competing demands for
blood flow to skin and to
active muscles
Remove to cooler
environment; rest in
recumbent position;
administer fluids by mouth;
keep at rest until urine
volume indicates that water
balances have been
restored
Acclimatize workers using a
breaking-in schedule for 5-7
days; supplement dietary salt
only during acclimatization;
ample drinking water to be
available at all times and to
be taken frequently during
work day
(1) Heavy sweating during
hot work; (2) drinking
large volumes of water
without replacing salt loss
Loss of body salt in sweat,
water intake dilutes
electrolytes; water enters
muscles, causing spasm
Salted liquids by mouth, or
more prompt relief by IV
infusion
Adequate salt intake with
meals; for unacclimatized
workers, supplement salt
intake at meals.
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EXHIBIT 8-2 (continued)
Classification, Medical Aspects, and Prevention of Heat Illness
Category and Clinical Features
Predisposing Factors
Underlying
Physiological
Disturbance
Treatment
Prevention
Skin Eruptions
(a) Heat Rash
(miliaria rubra, or "prickly heat")
Profuse tiny raised red vesicles (blister-
like) on affected areas; pricking
sensations during heat exposure
(b) Anhidrotic Heat Exhaustion
(miliaria profunda)
Extensive areas of skin which do not
sweat on heat exposure, but present
gooseflesh appearance, which
subsides with cool environments;
associated with incapacitation in heat
Unrelieved exposure to
humid heat with skin
continuously wet from
unevaporated sweat
Weeks or months of
constant exposure to
climatic heat with previous
history of extensive heat
rash and sunburn
Plugging of sweat gland
ducts with sweat retention
and inflammatory reaction
Skin trauma (heat rash;
sunburn) causes sweat
retention deep in skin;
reduced evaporative
cooling causes heat
intolerance
Mild drying lotions; skin
cleanliness to prevent
infection
No effective treatment
available for anhidrotic
areas of skin; recovery of
sweating occurs gradually
on return to cooler climate
Cool sleeping quarters to
allow skin to dry between
heat exposures
Treat heat rash and avoid
further skin trauma by
sunburn; provide periodic
relief from sustained heat
Behavioral Disorders
(a) Heat Fatigue - Transient
Impaired performance of skilled
sensorimotor, mental, or vigilance
tasks, in heat
(b) Heat Fatigue - Chronic
Reduced performance capacity;
lowering of self-imposed standards of
social behavior (e.g., alcoholic over-
indulgence); inability to concentrate,
etc.
Performance decrement
greater in unacclimatized
and unskilled worker
Workers at risk come from
temperate climates for
long residence in tropical
latitudes
Discomfort and physiologic
strain
Psychosocial stresses
probably as important as
heat stress; may involve
hormonal imbalance but no
positive evidence
Not indicated unless
accompanied by other heat
illness
Medical treatment for
serious causes; speedy
relief of symptoms on
returning home
Acclimatization and training
for work in the heat
Orientation on life in hot
regions (customs, climate,
living conditions, etc.)
-------
The freezing point of the skin is about 30°F
(-1°C). As wind velocity increases, heat loss is
greater and frostbite will occur more rapidly. If
skin comes into contact with objects colder than
freezing (e.g., tools or machinery), frostbite may
develop at the point of contact, even in warmer
environments.
There are three degrees of frostbite: first
degree, which is freezing without blistering or
peeling; second degree, which is freezing with
blistering or peeling; and third degree, which is
freezing with tissue death. Exhibit 8-3 lists the
symptoms of frostbite. It is important to
remember that the victim is often unaware of the
frostbite until someone else observes the
symptoms.
EXHIBIT 8-3
Symptoms of Frostbite
The first symptom of frostbite is an
uncomfortable sensation of coldness,
followed by numbness. There may be
tingling, stinging, aching, or cramping.
The skin changes color to white or
grayish-yellow, then to reddish-violet, and
finally turns black as the tissue dies.
Pain may be felt at first, but subsides.
Blisters may appear.
The affected part is cold and numb.
When frostbite of the outer layer of skin
occurs, the skin has a waxy or whitish look
and is firm to the touch.
In cases of deep frostbite, the tissues are
cold, pale, and solid. Injury is severe.
8.2.3 Preventing Cold Exposure
In preventing cold stress, health and safety
professionals must consider factors relating both to
the individual and to the environment.
Acclimatization, water and salt replacement,
medical screening, continuing medical supervision,
proper work clothing, and training and education
will contribute to the prevention of cold stress and
injury related to working in a cold environment.
Control of the environment involves engineering
controls, work practices, work-rest schedules,
environmental monitoring, and considerations of
windchill temperature.
Acclimatization. Some degree of acclima-
tization may be achieved in cold environments.
With sufficient exposure to cold, the body
undergoes some changes that increase comfort and
reduce the risk of cold injury. However, these
physiological changes are usually minor and
require repeated uncomfortably cold exposures to
induce them. People who are physically unfit,
older, obese, taking medication, or using alcohol or
drugs may not acclimatize too readily.
Dehydration. Working in cold areas causes
significant water losses through the skin and lungs
as a result of the dryness of the air. Increased
fluid intake is essential to prevent dehydration,
which affects the flow of blood to the extremities
and increased the risk of cold injury. Warm, sweet,
caffeine-free, non-alcoholic drinks and soup should
be available at the work-site for fluid replacement
and caloric energy.
Salt. The body needs a certain amount of
salt and other electrolytes to function properly.
However, using salt tablets is not recommended.
Salt tablets cause stomach irritation, which may
include nausea and vomiting. A normal, balanced
diet should take care of salt needs. Anyone with
high blood pressure or who is on a restricted
sodium diet should consult a physician for advice
on salt intake.
Windchill. Air temperature alone is not
sufficient to judge the cold hazard of a particular
environment, because even a light wind can blow
away the thin layer of air that insulates the body
against the cold air temperature. The "windchill
factor" is the cooling effect of any combination of
temperature and air movement. The windchill
index (Exhibit 8-4) should be consulted to estimate
the equivalent temperature felt by personnel
working in cold and windy environments.
Remember, however, that the windchill index does
not take into account: (1) the body part exposed to
the cold; (2) the level of activity and the resulting
heat produced; or (3) the amount of clothing worn.
Continuous exposure of skin should not be
permitted when the windchill factor results in an
equivalent temperature of -32°C (-26°F). Workers
exposed to air temperatures of 2°C (35.6°F) or
lower who become immersed in water or whose
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EXHIBIT 8-4
Windchill Index1
Wind speed in
mph
calm
5
10
15
20
25
30
35
40
Over 40 mph
(little added effect)
ACTUAL THERMOMETER READING (F)
50 40 30 20 10
0
-10 -20
-30
-40
EQUIVALENT TEMPERATURE (F)
50 40 30 20
48 37 27 16
40 28 16 4
36 22 9 -5
32 18 4 -10
30 16 0 -15
28 13 -2 -18
27 11 -4 -20
26 10 -6 -21
Little Danger
(for properly clothed person)
10
6
-9
-18
-25
-29
-33
-35
-37
0
-5
-21
-36
-39
-44
-48
-49
-53
-10
-15
-33
-45
-53
-59
-63
-67
-69
Increasing Danger
(Danger from freez
-20
-26
-46
-58
-67
-74
-79
-82
-85
-30
-36
-58
-72
-82
-88
-94
-98
-100
-40
-47
-70
-85
-96
-104
-109
-113
-116
Great Danger
ng of exposed flesh)
'Source: Fundamentals of Industrial Hygiene, Third Edition. Plog, B.A., Benjamin, G.S., Kerwin, M.A., National Safety Council,
1988.
clothing gets wet should be given dry clothing and
be treated for hypothermia.
Special Considerations. Older workers and
workers with circulatory problems need to be extra
careful in the cold. Additional insulating clothing
and reduced exposure time should be considered
for these workers. Obese and chronically ill
people need to make a special effort to follow
preventive measures. Sufficient sleep and good
nutrition are important for maintaining a high
level of tolerance to cold. If possible, the most
stressful tasks should be performed during the
warmer parts of the day. Double shifts and
overtime should be avoided. Rest periods should
be extended to cope with increases in cold stress.
Workers should immediately go to warm
shelter if any of the following symptoms are
spotted: the onset of heavy shivering, frostnip, the
feeling of excessive fatigue, drowsiness, and/or
euphoria. The outer layer of clothing should be
removed when entering a heated shelter. If
possible, a change of dry work clothing should be
provided to prevent workers from returning to
work with wet clothing. If this is not feasible, the
remaining clothing should be loosened to permit
sweat to evaporate.
Alcohol should not be consumed while in the
warmer environment. Anyone on medication such
as blood pressure control or water pills should
consult a physician about possible side effects from
cold stress. It is strongly recommended that
workers suffering from diseases or taking
medication that interferes with normal body
temperature regulation, or that reduces tolerance
of cold, not be permitted to work in temperatures
of -1°C (30°F) or below.
To guard against cold exposure, provide
workers with appropriate clothing, have warm
shelter available at all times, carefully schedule
work and rest periods, and monitor workers'
physical conditions. Under no circumstances
should a person be given an alcoholic beverage "to
keep warm." Alcohol causes the body to release
heat more quickly and will therefore increase the
risk of cold exposure. Fruits can help warm the
body by creating increased energy and metabolism.
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8.2.4 A Control Program for Cold Stress
A control program for preventing cold stress
at hazardous waste sites should include the
following elements:
• Medical supervision of workers including
pre-placement physicals that evaluate
fitness, weight, the cardiovascular system,
and other conditions that might make
workers susceptible to cold stress. Medical
evaluation during and after cold illnesses
and a medical release for returning to work
should be required.
• Employee orientation and training on cold
stress, cold-induced illnesses and their
symptoms, water and alt replacement,
proper clothing, work practices, and
emergency first aid procedures.
Work-rest regimens, with heated rest areas
and enforced rest breaks.
Scheduled drink breaks for recommended
fluids.
Environmental monitoring, using the air
temperature and wind speed indices to
determine wind chill and adjust work/rest
schedules accordingly.
Reduction of cold stress through
engineering and administrative controls,
and the used of personal protective
equipment.
FURTHER GUIDANCE: For additional information on recognizing, preventing, and controlling
heat and cold stress, see:
1. Plog, Barbara A., Benjamin, G.S., and M.A. Kerwin. Fundamentals of Industrial Hygiene, Third
Edition. National Safety Council, 1988.
2. Pocket Guide to Cold Stress. National Safety Council, 1985.
3. Pocket Guide to Heat Stress. National Safety Council, 1985.
4. 1991-1992 Threshold Limit Values for Chemical Substances and Physical Agents and Biological
Exposure Indices. American Conference of Governmental Industrial Hygienists, 1991.
100
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CHAPTER 9 DECONTAMINATION
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CHAPTER 9
DECONTAMINATION
9.0 INTRODUCTION
Decontamination, the process
of removing or neutralizing
contaminants, is critical to
health and safety at hazardous
waste sites. Decontamination
protects workers from
hazardous substances that can
eventually permeate protective clothing, respiratory
equipment, tools, and vehicles. It protects site
personnel by minimizing the spread of hazardous
substances into clean areas on-site, prevents the
mixing of incompatible wastes, and protects the
community by preventing the migration of
contaminants from the site. Personnel engaged in
hazardous waste operations may become
contaminated in a number of ways, including:
• Contacting vapors, gases, mists, or
particulates in the air;
• Being splashed by materials while sampling
or opening containers;
• Walking through puddles of liquids or
sitting in contaminated soil; and
• Using contaminated instruments or
equipment.
Protective clothing and respirators help
prevent the wearer from becoming contaminated
or inhaling hazardous substances, and good work
practices help minimize contamination on PPE,
instruments, and equipment. But even with these
safeguards, contamination may occur. To prevent
and minimize the severity of such incidences, the
HAZWOPER regulations at 29 CFR §1910.120(k)
require the development of a decontamination plan
prior to site entry; the development of standard
operating procedures (SOPs) to minimize contam-
ination; full decontamination of employees and
equipment; and the monitoring of decontamination
procedures by the Site Health and Safety Officer.
Cross contamination from protective clothing
to the wearer, from equipment to personnel, and
from one area to another can be minimized by
combining decontamination, the correct methods
for removing contaminated PPE, and the use of
site work zones. This chapter provides an
overview of decontamination, provides general
guidelines for designing and selecting
decontamination procedures at a site, explains
equipment for decontamination procedures, and
discusses how decontamination and PPE are
related.
9.1 THE DECONTAMINATION PLAN
Any site where hazardous waste cleanup
operations occur must have a plan that outlines
decontamination procedures (29 CFR
§1910.120(k)). These procedures must be made
available to employees and must be implemented
before anyone enters areas on-site where there is
suspected contamination. The plan must ensure
that chosen decontamination methods are effective
for the specific hazardous substances present, and
that the methods themselves do not pose any
health or safety hazards. The decontamination
plan also should address:
• The number and placement of
decontamination stations;
• The necessary decontamination equipment
and methods;
• SOPs to prevent contamination of clean
areas and to minimize worker contact with
contaminants during removal of PPE; and
• Methods for disposing of clothing and
equipment that may not be completely
decontaminated.
9.2 DEVELOPING THE PLAN
The initial decontamination plan should be
based on the assumption that all personnel and
equipment leaving the Exclusion Zone ("hot zone")
will be grossly contaminated. A personnel
decontamination system should then be established
to wash and rinse (at least once) all protective
equipment used in contaminated areas. This
should be done in combination with a sequential
doffing of protective equipment, starting at the
first decontamination station with the most heavily
contaminated item and progressing to the last
decontamination station with the least
contaminated article (see Section 9.3).
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An essential part of the plan should address
SOPs for site operations, that is, methods to
prevent the contamination of people and
equipment. For example, using remote sampling
techniques, not opening containers by hand,
bagging monitoring instruments, using drum
grapplers, watering down dusty areas, and not
walking through areas of obvious contamination
would reduce the probability of becoming
contaminated and, therefore, would reduce
decontamination time.
The initial decontamination plan should be
based on a worst-case situation and should assume
no information is available about on-site
contaminants. The initial decontamination plan
can be modified later, eliminating unnecessary
stations or otherwise adapting it to site conditions,
by considering the following factors:
Type of Contaminant. The extent to which
personnel decontamination is required varies
depending on the effects the contaminants have on
the body. All contaminants do not exhibit the
same degree of toxicity (or other hazard).
Whenever it is known or suspected that personnel
can become contaminated with highly toxic or skin-
destructive substances, a full decontamination
procedure should be followed. The procedure can
be downgraded only if less hazardous materials are
present at the site.
Amount of Contamination. The amount of
contamination on protective clothing (and other
objects or equipment) usually can be determined
by visual inspection. If, after a visual inspection,
the PPE appears grossly contaminated, a thorough
decontamination is highly recommended. Gross
material remaining on the protective clothing for
any extended period of time may degrade or
permeate it. This likelihood increases with higher
air concentrations and greater amounts of liquid
contamination. Gross contamination also increases
the probability of personnel contact. Swipe tests
may help determine the type and quantity of
surface contaminants.
Type and Level of PPE. The level of
protection and specific pieces of clothing worn can
be used to determine the preliminary layout and
decontamination stations needed for the
decontamination line. Each level of protection
presents different problems in decontamination
and doffing of equipment. For example:
decontamination of SCBA harness straps and
backpack assembly often is difficult; however, a
butyl rubber apron worn over the harness may
make decontamination easier. Clothing variations
and different levels of protection may require
adding or deleting stations to the preliminary
decontamination line.
Work Function. The work each person
performs determines the potential for contact with
hazardous materials. In turn, this should dictate
the layout of the decontamination line. For
example, observers, photographers, operators of air
samplers, or others in the Exclusion Zone who are
performing tasks that will not bring them in direct
contact with contaminants may not need to have
their garments washed and rinsed. Others in the
Exclusion Zone with a potential for direct contact
with the hazardous material will require more
thorough decontamination. Different decon-
tamination lines could be set up for different job
functions, or certain stations in a line could be
omitted for personnel performing certain tasks.
Location of Contamination. Contamination
on the upper areas of protective clothing poses a
greater risk to the worker because volatile
compounds may generate a hazardous breathing
concentration both for the worker and for
decontamination personnel. There is also an
increased probability of contact with skin when
doffing the upper part of clothing.
Establishment of Procedures. Once decon-
tamination procedures have been established, all
personnel requiring decontamination must be given
precise instructions (and practice, if necessary).
Compliance must be checked frequently. The time
it takes for decontamination also must be
ascertained. Personnel wearing SCBA must leave
their work area with sufficient air to walk to the
Contamination Reduction Corridor and undergo
decontamination.
9.3 THE CONTAMINATION REDUCTION
CORRIDOR
Decontamination activities should be
confined to a designated area within the
Contamination Reduction Zone, known as the
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Contamination Reduction Corridor. The Corridor
controls access into and out of the Exclusion Zone
and confines decontamination activities to a
limited area. The size of the Corridor varies
depending on the number of stations in the
decontamination procedure, overall dimensions of
work control zones, and amount of space available
at the site. A Corridor of 75 feet by 15 feet is the
minimum area for full decontamination. Stations
should be separated physically to prevent cross
contamination and should be arranged in order of
decreasing contamination, preferably in a straight
line. For example, outer, more heavily
contaminated items (e.g., outer boots and gloves)
should be decontaminated and removed first,
followed by decontamination and removal of inner,
less contaminated items (e.g., jackets and pants).
Individual routes through the decontamination line
should be developed for workers exposed to
different contamination zones containing
incompatible wastes. Entry and exit points should
be marked clearly, and the entry and exit points
into and out of the Exclusion Zone should be
separate points. Dressing and redressing stations
for entry and exit to the CRZ should also be
separate. Personnel who wish to enter clean areas
of the decontamination facility, such as locker
rooms, should be completely decontaminated.
The decontamination Corridor boundaries
should be conspicuously marked, with entry and
exit restricted. The far end of the Corridor would
be the Hotline, the boundary between the
Exclusion Zone and the CRZ. Personnel exiting
the Exclusion Zone must go through
decontamination in the Corridor, and anyone in
the Corridor should be wearing the level of
protection designated for the decontamination
crew. Another Corridor may be required for heavy
equipment needing decontamination.
Within the Corridor, distinct areas should be
set aside for decontamination of personnel,
portable field equipment, removed clothing, etc.
These areas should be marked and access should
be restricted to personnel wearing the appropriate
level of protection. All activities within the
Corridor should be confined to decontamination.
Personnel protective clothing, respirators,
monitoring equipment, and sampling supplies
should be stored and maintenanced outside of the
Corridor. Personnel should not don their
protective equipment in the Corridor.
9.4 DECONTAMINATION PROCEDURES
AND EQUIPMENT
All personnel, clothing, equipment, and
samples leaving the contaminated area of a site
(the Exclusion Zone) must be decontaminated to
remove any harmful chemicals or infectious
organisms that may have adhered to them. Step-
by-step procedures for decontamination of
personnel wearing PPE Levels A through C are
found in Appendix E.
Three general types of decontamination
methods are commonly used: (1) physical removal
of contaminants; (2) inactivation of contaminants
by chemical detoxification or disinfection/
sterilization; or (3) a combination of both physical
and chemical means.
9.4.1 Physical Removal of Contaminants
In many cases, contaminants may be removed
by physical means; however, high pressure and/or
heat should be used only as necessary and with
caution because they can spread contamination and
cause burns. Some contaminants that can be
physically removed are described below.
Loose Contaminants. Soils or dusts that
cling to equipment and personnel or that become
lodged in PPE materials can be removed with
water or a liquid rinse. Commercially available
anti-static solutions may help to remove
electrostatically attached particles.
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Adhering Contaminants. Some contam-
inants adhere by forces other than electrostatic
attraction. Adhesive qualities vary greatly with the
specific contaminants and the temperature. For
example, contaminants such as glues, cements,
resins, and muds have great adhesive properties
and, consequently, are difficult to remove by
physical means. Adhesive contaminants can be
removed using methods such as solidification,
freezing (e.g., using dry ice or ice water),
adsorption or absorption (e.g., with powdered lime
or kitty litter), or melting.
Volatile Liquids. Volatile liquid contam-
inants can be removed from protective clothing or
equipment by evaporation (using steam jets)
followed by a water rinse. This method should be
used with caution because of the potential for
employees to inhale the vaporized hazardous
chemicals.
9.4.2 Chemical Removal of Contaminants
Physical removal of gross
contamination should be
followed by washing and
rinsing with cleaning solutions.
These solutions normally use
one or more of the following
methods:
Dissolving Contaminants. Chemical removal
of surface contaminants can be accomplished by
dissolving them in a solvent that must be
chemically compatible with the equipment being
cleaned. This is particularly important when
decontaminating personal protective clothing
constructed of organic materials that could be
damaged or dissolved by organic solvents. In
addition, any flammable or toxic organic solvents
must be used and disposed of cautiously. Organic
solvents include alcohols, ethers, ketones,
aromatics, straight-chain alkanes, and common
petroleum products.
Halogenated solvents are toxic and generally
are incompatible with most types of PPE. They
should be used only for decontamination in
extreme cases where other cleaning agents will not
remove the contaminant. Because of the potential
hazards, decontamination using chemicals should
be done only if recommended by an industrial
hygienist or other qualified health professional.
Surfactants. Surfactants supplement physical
cleaning methods by minimizing adhesion between
contaminants and the surface being cleaned and,
therefore, prevent recontamination. Among the
most common surfactants are household
detergents, some of which can be used with organic
solvents to improve the dissolving and dispersal of
contaminants into the solvent.
Solidification. Solidifying liquid or gel
contaminants can enhance their physical removal.
Contaminants may be solidified by: (1) using
absorbents such as grounded clay or powdered lime
to remove moisture; (2) chemical reactions using
polymerization catalysts and chemical reagents; and
(3) freezing with ice water.
Rinsing. Rinsing removes contaminants
through dilution, physical attraction, and
solubilization. Multiple rinses with clean solutions
remove more contaminants than a single rinse with
the same volume of solution. Continuous rinsing
with large volumes is the most effective way to
remove contaminants.
Disinfection/Sterilization. Chemical dis-
infectants are a practical means of inactivating
infectious agents. Unfortunately, standard
sterilization techniques are generally impractical
for large equipment and PPE. For this reason,
disposable PPE is recommended for use with
infectious agents.
9.4.3 Decontamination Equipment
Decontamination equipment,
materials, and supplies are
generally selected based on
availability. It is also necessary
to consider whether the
equipment itself can be
decontaminated for reuse or
can be easily disposed of. Most equipment and
supplies needed for decontamination are easily
procured (e.g., soft bristle and long handle brushes
for scrubbing; buckets or garden sprayers for
rinsing; large galvanized wash tubs or stock tanks
for solutions; and large plastic garbage cans or
other similar lined containers for storing
contaminated clothing and equipment). Other
decontamination gear includes paper or cloth
towels for drying protective clothing and
equipment. Exhibits 9-1 and 9-2 list recommended
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equipment for decontaminating personnel and
PPE, and heavy equipment and vehicles,
respectively.
EXHIBIT 9-1
Recommended Equipment for
Decontaminating Personnel and PPE
Plastic drop cloths for storing heavily
contaminated equipment and outer
protective clothing.
Drums or suitably lined trash cans for
storing disposable clothing and heavily
contaminated PPE that must be
discarded, and for storing contaminated
solutions.
Lined boxes with absorbents for rinsing
off solid or liquid contaminants.
Washing and rinsing solutions selected
to reduce contamination and the
hazards associated with contaminants.
Large galvanized tubs, stock tanks, or
children's wading pools to hold wash
and rinse solutions. These should be at
least large enough for a worker to place
a booted foot in, and should have either
no drain or be connected to a collection
tank or appropriate treatment system.
Plastic sheeting, sealed pads with
drains, or other appropriate methods for
containing and collecting contaminated
wash and rinse solutions spilled during
decontamination.
Long-handled, soft-bristled brushes to
help wash and rinse off contaminants.
Paper or cloth towels for drying
protective clothing and equipment.
Lockers and cabinets for storage of
decontaminated clothing and
equipment.
Shower facilities for full body wash or,
at a minimum, personal wash sinks
(with drains connected to a collection
tank or appropriate treatment system).
EXHIBIT 9-2
Recommended Equipment for
Decontaminating Large Equipment
and Vehicles
Tanks for temporary storage and/or
treatment of contaminated wash and
rinse solutions.
Drains or pumps for collecting
contaminated wash and rinse solutions.
Long-handled brushes, rods, and
shovels for dislodging contaminated
soil caught in tires and the undersides
of vehicles and equipment and for
general exterior cleaning.
Washing and rinsing solutions selected
to remove and reduce the hazards
associated with contamination.
Pressurized sprayers for washing and
rinsing, particularly for hard-to-reach
areas.
Curtains, or spray booths to contain
splashes from pressurized sprays.
Containers to hold contaminated soil
removed from tires and the undersides
of vehicles and equipment.
Wash and rinse buckets for use in the
decontamination of operator areas
inside vehicles and equipment
Brooms and brushes for cleaning the
insides of vehicles and equipment.
Containers for storage and disposal of
contaminated wash and rinse solutions,
damaged or heavily contaminated parts,
and equipment to be discarded.
Currently, there are no available methods for
immediately determining the effectiveness of
decontamination procedures. Discolorations,
stains, corrosive effects, and substances adhering to
objects may indicate contaminants have not been
removed. However, observable effects only
indicate surface contamination and not permeation
(absorption) into clothing, tools, or equipment.
Also, many contaminants are not easily observed.
One method for determining effectiveness of
surface decontamination is swipe testing. Cloth or
paper patches are wiped over predetermined
surfaces of the suspect object and analyzed in a
laboratory. Both the inner and outer surfaces of
protective clothing should be swipe tested.
Positive indications of both sets of swipes would
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indicate surface contamination has not been
removed and substances have penetrated or
permeated through the garment. Determining
permeation of contaminants into protective
garments requires laboratory analysis of a piece of
the material. Both swipe and permeation testing
provide after-the-fact information. Along with
visual observations, results of these tests can help
evaluate the effectiveness of decontamination.
In many cases, depending on what substances
are present at a site, chemical protective clothing
(or naturally absorbable materials) may have to be
discarded. In this case, all small equipment items
(brushes, clothing, tools) should be collected,
placed in containers, and labeled. Also, all spent
solutions and wash water should be collected and
disposed of properly. Clothing that is not
completely decontaminated should be placed in
plastic bags, pending further decontamination
and/or disposal.
9.5 PROTECTION OF
DECONTAMINATION PERSONNEL
Decontamination workers are
vital to the fulfillment of site
decontamination procedures.
It is their responsibility to
monitor and aid the decon-
tamination of personnel, PPE,
and equipment. Decontamin-
ation workers must wear the appropriate level of
protection to accomplish this task without exposing
themselves to the contamination. This level of
protection can be determined by:
• Expected or visible contamination on
workers;
• Type of contaminant and associated
respiratory and skin hazards;
• Total vapor/gas concentrations in the
contamination reduction corridor;
• Particulates and specific inorganic or
organic vapors in the Corridor; and
• Results of swipe tests.
Decontamination workers who initially come
in contact with personnel and equipment leaving
the Exclusion Zone will require more protection
from contaminants than decontamination workers
who are assigned to the last station in the
decontamination line. In some cases,
decontamination personnel should wear the same
levels of PPE as workers in the Exclusion Zone.
In other cases, decontamination personnel may be
sufficiently protected by wearing protection of one
level lower (e.g., wearing Level C protection while
decontaminating workers who are wearing Level
B). Level D is not acceptable in the CRZ for
decontamination line personnel. All decontam-
ination workers are in a contaminated area and
must themselves be decontaminated before
entering the clean Support Zone.
All decontamination personnel should be
trained in the standard operating procedures for
minimizing contact and maximizing worker
protection, and these procedures should be
enforced throughout site operations. In addition,
standard operating procedures should be
established that maximize worker protection. For
example, proper procedures for dressing prior to
entering the Exclusion Zone will minimize the
potential for contaminants to bypass the protective
clothing and escape decontamination. In general,
all fasteners should be used; gloves and boots
should be tucked under the sleeves and legs of
outer clothing; hoods (if not attached) should be
worn outside the collar; all junctures should be
taped to prevent contaminants from running inside
the gloves, boots, jackets, and suits.
9.6 HEALTH AND SAFETY HAZARDS
While decontamination is
performed to protect health
and safety, it can pose hazards
under certain circumstances.
Decontamination methods
may:
Be incompatible with the hazardous
substances being removed (i.e., a
decontamination method may react with
contaminants to produce an explosion, heat,
or toxic products).
Be incompatible with the clothing or
equipment being decontaminated (e.g.,
some organic solvents can permeate PPE).
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• Pose a direct health hazard to workers (e.g.,
vapors from chemical decontamination
solutions may be hazardous if inhaled).
The chemical and physical compatibility of
the decontamination solutions or other
decontamination materials must be determined
before they are used. Any decontamination
method that permeates, degrades, damages, or
otherwise impairs the safe functioning of the PPE
should not be used. Measures must be taken to
adequately protect all workers and equipment from
any decontamination method that does pose a
direct health hazard.
Hazardous waste facilities should also have in
place emergency decontamination procedures, in
order to prevent the loss of life or severe injury to
site personnel. In the case of threat to life,
decontamination should be delayed until the victim
is stabilized; however, decontamination should
always be performed first, when practical, if it can
be done without interfering with essential life-
saving techniques or first aid, or if a worker has
been contaminated with an extremely toxic or
corrosive material that could cause severe injury or
loss of life. During an emergency, provisions must
also be made for protecting medical personnel and
disposing of contaminated clothing and equipment.
FURTHER GUIDANCE: For more information on decontamination procedures and equipment, see:
1. Standard Operating Guidelines for Decontamination of Response Personnel (U.S. EPA, draft,
Publication 9285.2-02A).
2. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities
(NIOSH/OSHA/USCG/EPA, 1985, NIOSH Publication 85-115).
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CHAPTER 10 DRUM HANDLING
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CHAPTER 10 DRUM HANDLING
10.0 INTRODUCTION
Accidents may occur during
handling of drums and other
hazardous waste containers.
Hazards include detonations,
fires, explosions, vapor
generation, and physical injury.
The most significant ways to
improve the safety of drum handling activities at a
site are to keep the operation as remote from
workers as possible, to avoid sudden releases of
chemicals if the operation cannot be remote, and
to provide adequate safety gear and equipment to
protect the worker if spillage or contact with the
drums is unavoidable. Exhibit 10-1 outlines some
basic safety precautions in drum handling.
Regulations defining practices and procedures
for safe handling of drums and other hazardous
waste containers include:
• OSHA regulations (29 CFR Part 1910.
1200) and Part 1926) " general
requirements and standards for storing,
containing, and handling chemicals and
containers, and for maintaining equipment
used for handling materials;
• EPA regulations (40 CFR Parts 264 and
265) -- requirements for types of hazardous
waste containers, maintenance of containers
and containment structures, and design and
maintenance of storage areas; and
• DOT regulations (49 CFR Parts 171
through 178) - requirements for containers
and procedures for shipment of hazardous
wastes.
During hazardous waste operations,
containers are handled during inspection, drum
opening, sampling, and characterization. This
chapter provides guidance for safely performing
these procedures when handling drums and other
containers.
10.1
INSPECTION
Appropriate procedures for handling drums
varies depending on the drum contents. Prior to
handling, drums should be inspected visually to
identify their contents. Information that may be
helpful includes:
• Symbols, words, or other marks on the
drum indicating that its contents are
hazardous;
• Symbols, words, or other marks indicating
that the drum contains discarded laboratory
chemicals, reagents, or other potentially
dangerous materials in small-volume
individual containers;
• Signs of deterioration such as corrosion,
rust, and leaks;
• Signs that the drum is under pressure; and
• Configuration of the drumhead. For
example, if the whole lid of the drum can
be removed, then it was designed to contain
solid material; if the lid has a bung, then
the drum was intended for liquids. If the
drumhead contains a liner, the drum may
likely contain highly corrosive or otherwise
hazardous materials.
Noting the type of drum also may be useful
for identifying potential hazards. Polyethylene or
PVC-lined drums often contain strong acids or
bases. If the lining is punctured, the substance
usually quickly corrodes the steel, and may cause a
significant leak or spill. Exotic metal drums (e.g.,
aluminum, nickel, stainless steel) are very strong
and expensive, and are often used to store
extremely dangerous materials. Single-walled
drums used as a pressure vessel have fittings for
both the storage product and for an inert gas.
These drums may contain reactive, flammable, or
explosive substances.
Laboratory packs are used for disposal of
expired chemicals and process samples from
university laboratories, hospitals, and similar
institutions. Individual containers within the lab
pack often are not packed in absorbent material.
They may contain incompatible materials,
radioisotopes, or shock-sensitive, highly volatile,
highly corrosive, or highly toxic exotic chemicals.
Laboratory packs are a potential ignition source
for fires at hazardous waste sites.
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EXHIBIT 10-1
Safety Precautions for Drum Handling
ACTIVITY: LOCATING DRUMS AND CONDUCTING INVENTORY
POTENTIAL SAFETY HAZARD: Unknown location and contents of drums can lead to unsuspected
hazards
Safety
Tips
Carefully review background data pertaining to the location and types of wastes on-site.
Conduct soil and ground-water sampling only after the geophysical survey is completed
to minimize the possibility of puncturing drums.
During the random sampling of drums, which may be required for an inventory, spacing
between drums should be adequate to allow for emergency evacuation if needed.
Use remotely operated, nonsparking tools for random sampling whenever possible.
Use direct-reading air monitoring equipment to detect hot spots where contamination may
pose a risk to worker safety.
ACTIVITY: DETERMINING DRUM INTEGRITY
POTENTIAL SAFETY HAZARD: The process of visual inspections requires close contact with drums of
unknown content
Safety
Tips
Approach drums cautiously. Conduct air monitoring to indicate levels of hazards that
require withdrawal from the work area or use of additional safety equipment.
Any drum that is critically swollen should not be approached; it should be isolated using a
barricade until the pressure can be relieved remotely.
Use of the grappter or other remotely operated equipment can eliminate the need for
determining drum integrity prior to excavation, provided that rupture of the drum will not
result in fire or unacceptable environmental impact.
ACTIVITY: DRUM EXCAVATION AND HANDLING
POTENTIAL SAFETY HAZARD: Exposure to toxic/hazardous vapors; rupture of drums
Safety
Tips
Where buried drums are suspected, conduct a geophysical survey before using any
construction equipment in order to minimize the possibility of rupture.
Use a drum grappler where possible and cost-effective to minimize contact with drums. If
a grappler is not available, pump or overpack drums of poor integrity before excavation.
Ground equipment prior to transferring wastes to new drums.
Use nonsparking hand tools and nonsparking bucket teeth on excavation equipment, and
use plexiglass shields on vehicle cabs.
Where slings, yokes, or other accessories must be used, workers should back away from
the work area after attaching the accessory and before the drum is lifted.
Critically swollen drums should not be handled until pressure can be relieved.
Use bars that fit over the teeth of excavation buckets to prevent drum puncture.
Where ionizing levels of radiation are detected, the Site Health and Safety Officer should
be contacted; generally, the drum should be overpacked and isolated promptly.
Where explosive or shock-sensitive material is suspected, every effort should be made to
handle the drum remotely. Gas cylinders should not be dragged during handling.
Use direct-reading air monitoring equipment when in close proximity to drums to detect
any hot spots.
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EXHIBIT 10-1 (cont'd)
Safety Precautions for Drum Handling
ACTIVITY: DRUM STAGING AND OPENING
POTENTIAL SAFETY HAZARD: Release of toxic, hazardous vapors, rupture of drums
Safety
Tips
Stage gas cylinders in a cool, shaded area.
Stage potentially explosive or shock-sensitive wastes in a diked, fenced area.
Use remote drum opening methods where drums are unsound.
Conduct remote-operated drum opening from behind a barricade or behind a plexiglas
shield if backhoe-mounted puncture is being used.
Isolate drum opening from staging and other activities if possible to prevent a chain
reaction if an explosion or reaction does occur.
If drum opening cannot be isolated from staging, drums should be staged so as to:
(1) minimize the possibility of chain reactions in the event of a fire or explosion; and
(2) provide adequate space for emergency evacuation.
Use only nonsparking hand tools if drums are to be opened manually.
Remotely relieve the pressure of critically swollen drums before opening.
Clean up spills promptly to minimize mixing of incompatible materials.
ACTIVITY: CONSOLIDATION AND RECONTAINERIZATION
POTENTIAL SAFETY HAZARD: Mixing of incompatible wastes
Safety
Tips
Perform on-site compatibility testing on all drums.
Segregate wastes according to compatibility class following compatibility testing.
Clean up spills promptly to avoid mixing of incompatible wastes.
Intentional mixing of incompatible wastes such as acids and bases should be performed
under controlled conditions in a reaction tank where temperature and vapor release can
be monitored.
Monitor for incompatible reactions during consolidation using direct-reading air monitoring
equipment.
ACTIVITY: INTERIM STORAGE AND TRANSPORTATION
POTENTIAL SAFETY HAZARD: Mixing of incompatible wastes
Safety
Tips
Segregate incompatible wastes using dikes during interim storage.
Maintain a weekly inspection schedule.
Allow adequate aisle space between drums to allow rapid exit of workers in case of
emergency.
Keep explosives and gas cylinders in a cool, shaded, or roofed area.
Prevent contact of water reactive wastes with water.
Clean up spills or leaks promptly.
Have fire fighting equipment readily available within the storage area.
Ensure adherence to DOT regulations regarding transport of incompatible wastes and
drum integrity.
Source: Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013).
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Conditions in the immediate vicinity of the
drums may provide information about drum
contents and associated hazards. In addition, air
monitoring should be conducted around the drums.
If buried drums are suspected, ground-penetrating
systems can be used to estimate the location and
depth of the drums.
After visual inspection, drums can be classified
into preliminary hazard categories. They can be
described as radioactive, leaking or deteriorated,
bulging, and explosive or shock-sensitive. Until
their contents are characterized, unlabelled drums
should be handled in the same manner as drums
that contain hazardous materials. It is also
important to remember that drums are frequently
mislabelled - particularly drums that are reused.
Therefore, a drum's label may not accurately
describe its contents.
Results of the drum inspection can be used to
determine: (1) whether any hazards are present
and the appropriate response; and (2) which drums
need to be moved before they are opened and
sampled. A plan should be developed specifying
the extent of handling necessary and the
appropriate procedures for handling. Plans should
be revised as new information is obtained during
drum handling.
10.2 DRUM EXCAVATION AND
REMOVAL EQUIPMENT
Drum excavation and removal
equipment is used to perform
several distinct and important
functions, including:
• Excavating to the depth of
buried drums and removing
surface cover over buried drums.
• Excavating around buried drums to free them
for removal.
• Removing (lifting) drums from exposed pits and
trenches.
• Loading and transporting drums to onsite
storage areas.
• Sampling, segregating, bulking, storing, and
recontainerizing (e.g., overpacking) drums.
• Transporting offsite for appropriate storage,
treatment, or disposal.
The choice of equipment for drum handling is
based on the inherent capabilities and limitations
of the equipment, site-specific conditions that
affect equipment performance, the necessity to
protect worker safety, and costs. Generally, a
combination of equipment and accessories is
required for a particular job.
10.3 DRUM HANDLING
The purpose of drum handling is to: (1)
respond to obvious problems that might impair
worker safety; (2) unstack and orient drums for
sampling; and (3) if necessary, organize drums into
different areas on-site to facilitate characterization
and remedial action. Handling may or may not be
necessary, depending on how the drums are
positioned at a site.
To avoid accidents, drums should only be
handled when necessary. Prior to handling, all
personnel should be warned about the hazards of
handling and instructed to minimize handling as
much as possible. In all phases of handling,
personnel should be alert for new information
about potential hazards and should respond to new
hazards before continuing with routine handling
operations. Empty overpack drums (larger drums
in which smaller leaking or damaged drums are
placed for storage or shipment) and an adequate
volume of absorbent should be kept near areas
where minor spills may occur. Where major spills
may occur, a containment berm should be
constructed prior to handling. If drum contents
spill, personnel trained in spill response should
isolate and contain the spill.
The following procedures can be used to
maximize worker safety during drum handling and
movement:
• Train personnel in proper lifting and moving
techniques;
• Select vehicles with sufficient rated load
capacity to handle anticipated loads, and
ensure that vehicles can operate smoothly on
available road surfaces;
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• Air condition the cabs of vehicles to increase
operator efficiency and protect the operator
with heavy splash shields;
• Supply operators with appropriate respiratory
protective equipment when needed;
• Prepare overpacks before any attempt is made
to move drums;
• Before moving anything, determine the
appropriate sequence for moving drums and
other containers;
• Exercise extreme caution in handling drums
that are not intact and tightly sealed; and
• Ensure that operators have a clear view of the
roadway when carrying drums. Where
necessary, have ground workers available to
direct the operator's motion.
Drums containing radioactive waste should not
be handled until experts in handling radioactive
materials have been consulted. If a drum is
suspected to contain explosive or shock-sensitive
waste, specialized assistance should be sought
before handling is initiated. If handling is
necessary, extreme caution should be used and all
non-essential personnel should remain a safe
distance from the handling area. In addition,
continuous communication with the Site Health
and Safety Officer and/or the command post
should be maintained until handling operations are
complete.
Drums that may be under internal pressure can
be identified by bulging or swelling. If a
pressurized drum must be moved, whenever
possible, the drum should be handled with a
grappler unit constructed for explosive
containment. Either move Ihe bulged drum only
as far as necessary to allow seating on firm ground,
or carefully overpack the drum. Exercise extreme
caution when working with or adjacent to
potentially pressurized drums.
Laboratory packs (lab packs) should be
considered to hold explosive or shock-sensitive
wastes until otherwise characterized. Prior to
handling or transporting lab packs, all non-
essential personnel should move a safe distance
from the handling area. If handling is required,
continuous communication with the Site Health
and Safety Officer and/or the command post
should be maintained until handling operations are
complete. Once a lab pack has been opened, it
should be inspected and classified according to the
hazards of the wastes to ensure safe segregation of
the lab packs' contents.
If a drum containing a liquid cannot be moved
without rupture, its contents should be
immediately transferred to a sound drum. Leaking
drums that contain sludges or semi-solids, open
drums that contain liquid or solid waste, and
deteriorated drums that can be moved without
rupture should be placed in overpack containers.
Prior to initiating subsurface excavation,
ground-penetrating systems should be used to
confirm the location and depth of drums. Soil
should be removed with caution to minimize the
potential for drum rupture. In addition, a dry
chemical fire extinguisher should be available to
control small fires.
10.4
DRUM OPENING
Drums are usually opened and sampled in place
during site investigations. However, remedial and
emergency operations may require a separate drum
opening area. Procedures for opening drums arc
the same, regardless of where the drums arc
opened. To maximi/.c worker safety during drum
opening, the following procedures should be
instituted:
• If a supplied-air respiratory protection system
is used, place a hank of air cylinders outside
the work area and supply air to the operators
via airlines and escape SCBAs;
• Keep personnel at a safe distance from the
drums being opened; place explosion-resistant
plastic shields between personnel and the
drums for protection in case of detonation;
locate controls for drum opening equipment,
monitoring equipment, and fire suppression
equipment behind (he explosion-resistant
plastic shield;
• Conduct air monitoring during drum-opening
activities;
• Use non-sparking bronze-beryllium tools
when possible;
117
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• Use remote-controlled devices for opening
drums, when feasible;
• Hang or balance the drum opening equipment
to minimize worker exertion;
• If the drum shows signs of swelling or
bulging, perform all steps slowly and relieve
excess pressure prior to opening;
• Open exotic metal drums and polyethylene or
polyvinyl chloride-lined drums through the
bung by removal or drilling;
• Do not open or sample individual containers
within laboratory packs;
• Reseal open bungs and drill openings as soon
as possible; and
• Decontaminate equipment after each use to
avoid mixing incompatible wastes.
Exhibit 10-2 provides a summary assessment of
several drum opening techniques, Exhibit 10-3
presents a sample drum characterization sheet, and
Exhibit 10-4 illustrates two common examples of
drum opening equipment.
10.5
DRUM SAMPLING
Drum sampling can be hazardous to worker
health and safety because it can involve direct
contact with unidentified wastes. Prior to
collecting samples, a sampling plan should be
developed, including: (1) research about the waste;
(2) identification of drums to be sampled; (3)
selection of appropriate sampling device(s) and
container(s); (4) determination of the number,
volume, and locations of samples to be taken; and
(5) development of procedures for opening drums,
sampling, and sample packaging and
transportation. A trained health and safety
professional should determine the appropriate
personal protection to be used during sampling,
decontamination, and packaging of the sample.
To maximize worker safety during manual
sampling from a drum, the following techniques
should be used:
• Keep sampling personnel at a safe distance
while drums are being opened and sample
only after opening operations are complete;
• Do not lean over other drums to reach the
drum being sampled, unless absolutely
necessary;
• Cover drum tops with plastic sheeting or
other suitable uncontaminated materials;
• Never stand on drums - use mobile steps or
another platform to achieve the height
necessary to safely sample from the drums;
and
• Obtain samples with glass rods or vacuum
pumps.
10.6 CHARACTERIZATION
The goal of characterization is to obtain data
necessary to determine how to safely and efficiently
package and transport the wastes for treatment
and/or disposal. If wastes are bulked, they must be
sufficiently characterized to determine which of
them can be safely combined. Standard
compatibility tests are simple, rapid, and cost-
effective procedures used to segregate wastes into
broad categories, including water reactive,
oxidative, and radioactive. By identifying broad
waste categories, compatible waste types can be
safely bulked on-site without the risk of fore or
explosion, and disposal options can be determined
without exhaustive and costly analysis of each
drum. In some cases, however, further analysis
may be necessary to identify the waste materials
more precisely.
During the compatibility testing process, each
drum is scanned for radioactivity as it is opened.
If the scan is negative, a sample is taken to
perform the compatibility test. (Solid samples
should be taken from several different areas within
the drum.) In addition, the contents of all drums
should be described on the drum data sheet in
terms of physical slate, viscosity, and number of
phases. A sample should be taken for each phase.
Exhibit 10-5 provides a sample HAZCAT checklist
for recording screening data.
There are a number of published compatibility
testing protocols; however, procedures must be
tailored for site-specific conditions. Exhibit 10-6
presents a thorough protocol developed by the
Chemical Manufacturers' Association (CMA).
Based on the CMA protocol, wastes can be
segregated into the following broad waste
categories:
118
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EXHIBIT 10-2
Summary Assessment of Drum Opening Techniques
Recommended Drum Opening Applications (for Sample Acquisition or Recontamerization)
Technique
Bung Wrenches
(Nonsparking)
Manual Drum
Deheader
Self-Propelled Drum
Deheader (Electric or
Pneumatic)
Remotely Operated
Pneumatic Wrench
Remote Hydraulic
Plunger
• Portable
• Self-Propelled
(Electric or Pneumatic)
• Backhoe attached
• Conveyor
Backhoe Spike
(Nonsparking)
Tube and Spear device for
venting
# of Drums to be Opened
<100
X
X
X
X
X
X
X
X
100-500
X
X
X
X
>500
X
X
X
Physical Condition of
Drums
Damaged
or
Bulging
X
X
X
X
X
X
Structurally
Sound
X
X
X
X
X
X
X
X
Waste Content of Drum
Unknown
X
X
X
X
X
X
Shock
Sensitive/
Explosive
X
X1
X
X1
X1
X
X
Non-
Hazardous
X
X
X
X
X
X
X
X
Restrictions/Disadvantages
Not recommended for unknown waste
contents; full protective gear for
worker.
Only if bung is impossible to open;
used mainly for recontainerization vs.
sample acquisition; unsafe if waste
contents are unknown.
May require use of a dekinker or
readjustment of the deheader if the
chime is dented.
Requires direct contact with the drum
during attachment of the wrench.
Time-consuming setup.
Only in controlled area with spill
containment.
Most time-consuming hydraulic
plunger methods. Requires direct
contact with the drum to set up the
plunger.
Only suitable if the chime is free of
dents.
Use long boom-dipper arms (12
meters or 40 feet).
Has not been used in the field to date.
May damage drum; use long backhoe
boom (>40 feet).
Method applicable for venting of
pressure, but not for drum sampling.
1 Plunger may be of nonsparking bronze or of stainless steel, which is more durable.
Source; Drum Handling Practices at Hazardous Waste Sites (U S EPA, 1986, EPA/500/2-86/013).
-------
SITE:
Drum Size:
0 unknown
1 55 gal.
2 30 gal.
3 other
specify
Drum Opening:
0 unknown
1 ring top
2 closed top
3 open top
4 other
specify
Drum Type:
0 unknown
1 metal
2 plastic
3 fiber
4 glass
5 other
specify
Drum Color: PRI SEC
0 unknown
1 cream
2 clear
3 black
4 white
5 red
6 green
7 blue
8 brown
9 pink
10 orange
1 1 yellow
12 gray
13 purple
14 amber
15 green-blue
EXHIBIT 10-3
Sample Drum Characterization Sheet
DRUM #:
Drum Contents Color:
PRI SEC
0 unknown
1 cream
2 clear
3 black
4 white
5 red
6 green
7 blue
8 brown
9 pink
10 orange
11 yellow
12 gray
13 purple
14 amber
15 green-blue
Drum Condition:
0 unknown
1 good
2 fair
3 poor
Drum Marking Keywords:
#1
#2
#3
Drum Contents State:
PRI SEC
0 unknown
1 solid
2 liquid
3 sludge
4 gas
5 trash
6 dirt
7 gel
SAMPLE #:
Drum Content Amount:
0 unknown
1 full
2 part
3 empty
Chemical Analysis:
YES NO
radiation
ignitable
water reactive
cyanide
oxidizer
organic vapor ppm
PH
Real-time Instrument
Readings
Colorimetric tube
Radiation
PID
FID
Source: EPA Region VII
Emergency Planning and
Response Branch
120
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EXHIBIT 10-4
Examples of Drum Opening Equipment
Backhoe
arm (ref.)
Hydraulic lines
Adapter bracket
Drain to vacuum truck,
waste recovery system,
or tank
Hydraulic cyl.
with 6 in. stroke
Splash plate
Replaceable 316
stainless steel
conical plunger
(3 in. dia. x 4 in. Ig.)
Standard single
drum grabber
55 gallon drum
Spill containment
pan (portable)
75 gal capacity
Hydraulic Backhoe Drum Plunger Arrangement
55 gallon drum
Conveyor
Drain to vacuum truck,
waste recovery system,
or tank
Remote
location
Needle valve
3-Way valve
Appro* 50 ft. of hose
Air/hydraulic cylinder
Splash plate
Replaceable 316
stainless steel
conical plunger
(3 in. dia. x 4 in. Ig.)
Doors (2 sides)
containment pan &
support frame (75 gal capacity)
Belt conveyor
Fork lift slots
Conveyor Belt System for Remote Hydraulic Puncturing of
Large Number of Drums
121
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HAZCAT Checklist:
Screening Data YES
RADIOACTIVE
ACIDIC
CAUSTIC
AIR REACTIVE
WATER REACTIVE
WATER SOLUBLE
WATER BATH OVA
COMBUSTIBLE
HALIDE
INORGANIC
ORGANIC
ALCOHOL/ALDEHYDE
CYANIDE
FLAMMABLE
OXIDIZER
INERT OR OTHER
PCB SCREEN
(Chlor-N-Oil)
Source: EPA Region VII
D
D
n
D
D
D
D
D
n
n
n
n
n
n
n
n
n
n
n
n
Emergency Planning
EXHIBIT 10-5
Characterization Screening Data
NO Criteria
n
n
n
n
n
n
n
n
n
D
n
n
D
n
n
n
n
and
>1 mR over background
pH < 3
pH > 12
Reaction of > 10°F temp, change
Reaction of > 10°F temp, change
Dissolves in water
Reading = >10 ppm = Yes
Catches fire when torched in water bath
Green flame when heated with copper
WATER BATH OVA and COMBUSTIBLE = No
INORGANIC = No
WATER BATH OVA, WATER SOLUBLE, and
COMBUSTIBLE = Yes
Draeger tube over water bath > 2 ppm
Combustible = Yes, and SETA flashpoint < 140oF
Starch iodine paper shows positive reaction
Everything "No" except INORGANIC or ORGANIC
> 50 ppm
< 50 ppm
100%
Response Branch. This chart is provided only as an
example; values may need to be modified as appropriate.
Liquids: Radioactives, Peroxides and oxidizing
agents, Reducing agents, and Water-reactive
compounds.
Water Insolubles: Low halogen/low PCB,
Mixed halogen/high PCB, and High halogen/low
PCB.
Acids: Strong (pH<2), Weak (pH 2-7).
Bases: Strong (pH>12) with or without
cyanides or sulfides, and Weak (pH 7-12) with
or without cyanides or sulfides.
Solids: Radioactive and Non-radioactive.
This protocol also requires that a compatibility test
be performed by mixing small samples of wastes
that are intended to be bulked, making visual
observations for precipitation, temperature
changes, or phase separation.
When possible, materials should be
characterized using an on-site laboratory to
minimize the time before appropriate action can
be taken to handle any hazardous materials. If
samples must be analyzed off-site, samples should
be packaged on-site in accordance with DOT
regulations (49 CFR Parts 171-178) and shipped to
the laboratory for analysis.
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EXHIBIT 10-6
CMA COMPATIBILITY TESTING PROTOCOL
Test for Radioactivity
Isolate Gas Cylinders
Isolate Suspected Explosives
Liquids
Open Drum
Test for Radioactivity
Confirm Liquid
Test for Peroxides
and Oxidizers
No
Test for Water
Solubility
Yes
Test for Water
Content
See
Water Soluble
Liquids
Yes
Isolate
Determine Contents
of Containers
Isolate Oddball Drums
Isolate Lab Packs
Solids
Open Drum
Yes
Isolate
Yes
Test for Radioactivity
To Solids To Liquids
No '
Regroup
No
Confirm Solid
Yes
Test for Water
Reactivity
i
No
Isolate
Isolate
Yes
Yes
Remove Free Liquid
Test for
and
PCB
EP Toxicity
PCBs
1 '
No PCB
No
Bulk for \ / Bulk for
Disposal / I Disposal
See
Water Insoluble
Liquids
Sourest Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013).
123
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EXHIBIT 10-6 (cont'd)
CMA COMPATIBILITY TESTING PROTOCOL
Water Insoluble Liquids Testing
Test for
Organic Halogen
Test for PCB
on Composite
Test for PCB
on Composite
Retest if PCB
Retest if PCB
Low
Halogen
No PCB
Composite
Low
Halogen
No PCB
Composite
Mixed
Halogen
Middle PCB
Composite
Mixed
Halogen
High PCB
Composite
High
Halogen
Low PCB
Composite
Source: Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013).
124
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EXHIBIT 10-6 (cont'd)
CMA COMPATIBILITY TESTING PROTOCOL
Water Soluble Scan
No
Isolate
Strong
Acids
i
Weak
Acids
1
PH
<7
>7
Weak Strong
Bases Bases
pH<2
pH2-7
Isolate
Yes
pH7-12 pH>12
Cyanide, Sulfide
No
No
Isolate
Source: Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA/500/2-86/013).
125
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FURTHER GUIDANCE: For more information on drum handling, see:
1. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities.
(NIOSH/OSHA/USCG/EPA, 1985, NIOSH Publication 85-115).
2. Drum Handling Practices at Hazardous Waste Sites (U.S. EPA, 1986, EPA 500/2-86/013).
3. Guidance Document for Cleanup of Surface Tank and Drum Sites (U.S. EPA, Publication
9380.0-3).
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CHAPTER 11 OTHER REQUIREMENTS AND SAFETY
CONSIDERATIONS
DANGER
CONFINED SPACE
ENTRY BY
PERMIT ONLY
C2408S-2
-------
CHAPTER 11 OTHER REQUIREMENTS AND SAFETY
CONSIDERATIONS
11.0
INTRODUCTION
This chapter provides information on three
other important HAZWOPER requirements and
on specific hazards that employees may face in
hazardous waste operations:
• Emergency response and prevention
requirements;
• Confined space entry procedures;
• Information and new technology programs;
• Specific hazards, including chemical
contamination, explosion and fire, oxygen
deficiency, ionizing radiation, biological
hazards, and noise and safety hazards.
11.1 EMERGENCY RESPONSE AND
PREVENTION
Site emergencies are characterized by their
potential for complexity; uncontrolled toxic
chemicals may be numerous and unidentified, and
their effects may be synergistic. Rescue personnel
attempting to remove injured workers may
themselves become victims. This variability means
that advance planning, including anticipation of
different emergency scenarios and thorough
preparation for contingencies, is essential to
protect worker and community health and safety.
One of the most important components of
the HASP is the written site-specific emergency
response plan. The emergency response plan
should be designed as a separate section of the
HASP, and must be compatible and integrated
with the disaster, fire, and/or emergency response
plans of local, state, and federal agencies. The
plan must include a description of how anticipated
emergencies would be handled at the site and how
the risks associated with a response would be
minimized. The emergency response plan must be
developed and implemented prior to commencing
operations at a site.
The requirements for an emergency response
plan at an uncontrolled hazardous waste site are
listed in Exhibit 11-1 and are codified at 29 CFR
§1910.120(1)(2). Employers must develop
emergency response plans to protect workers in
emergencies resulting from the release of all kinds
of hazardous substances, including Extremely
Hazardous Substances (EHSs), CERCLA
hazardous substances, RCRA hazardous wastes,
and any substance listed by the U.S. Department of
Transportation as a hazardous material.
EXHIBIT 11-1
Required Elements of an Emergency
Response Plan at an Uncontrolled
Hazardous Waste Site
(29 CFR §1910.120(1) (2))
Pre-emergency planning.
Personnel roles, lines of authority, and
communication.
Emergency recognition and prevention.
Safe distances and places of refuge.
Site security and control.
Evacuation routes and procedures.
Decontamination procedures.
Emergency medical treatment and first
aid.
Emergency alerting and response
procedures.
Critique of response and follow-up.
PPE and emergency equipment.
Site topography, layout, and prevailing
weather conditions.
Procedures for reporting incidents to
local, state, and federal governmental
agencies.
In addition to these elements, the emergency
response plan must include information relevant
for conducting emergency operations at the site,
129
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such as information on site topography, layout, and
prevailing weather conditions, and procedures for
reporting incidents to local, state, and federal
agencies. As part of the overall training program
for site operations, the emergency response plan
also must be rehearsed regularly and reviewed
periodically to ensure that it accounts for new or
changing site conditions or new information on
potential hazards at the site. The plan must be in
writing and available for inspection and copying by
employees, their representatives, OSHA personnel,
and other government agencies with relevant
responsibilities.
An employee alarm system must be installed
at all sites in accordance with 29 CFR §1910.165
to notify employees of an emergency situation, to
stop work activities if necessary, to lower
background noise in order to speed communi-
cations, and to begin emergency procedures. Based
on the information available at the time of the
emergency, the employer should evaluate the
incident and the site response capabilities and
proceed with the appropriate steps to implement
the site emergency response plan.
In lieu of preparing an emergency response
plan, site managers may prepare an emergency
action plan in accordance with 29 CFR
§1910.38(a). This plan may only be developed in
lieu of the emergency response plan if employees
are evacuated from the site when an emergency
occurs, and are not permitted to assist in
responding to the emergency. An emergency
action plan includes an evacuation plan in which
persons responsible for an orderly exit are
identified. These designated individuals would
direct employees to leave the site and maintain a
safe distance, and would also call the appropriate
emergency response organization.
If an emergency action plan is prepared,
arrangements must be made with the local
response community (e.g., fire department or other
local response services) for them to respond to
emergencies that may occur during site operations.
The local response community must be provided
with sufficient information regarding site activities,
including the types of operations being conducted
at the site, the type and degree of contamination at
the site, the location of work zones, and any other
relevant information that may be necessary for an
appropriate response. Such information must be
provided prior to the commencement of site
operations. Regardless of whether an emergency
action plan or an emergency response plan is
prepared, local response officials should be notified
of site operations prior to the commencement of
any site activities. As an additional good operating
practice, the site manager may choose to provide
local officials with a copy of the plan to review and
concur upon.
11.1.1 Prevention
On a day-to-day basis, individual personnel
should be constantly alert for indicators of
potentially hazardous situations and for signs and
symptoms in themselves and others that warn of
hazardous conditions and exposures. Rapid
recognition of dangerous situations can avert an
emergency and prevent injuries and loss of life.
Regular health and safety meetings with employees
should address:
• Tasks to be performed;
• Time constraints (e.g., rest breaks, air tank
changes);
• Hazards that may be encountered, including
their potential effects, how to recognize
symptoms or monitor them, concentration
limits, or other danger signals; and
• Emergency procedures.
After daily work assignments, a debriefing session
should be held to review work accomplished,
problems observed, and suggestions for future
improvement.
11.1.2 Communications
In an emergency, crucial
messages must be conveyed
quickly and accurately. Site
staff must be able to communi-
cate information, such as the
location of injured personnel,
orders to evacuate the site, and
information on safe evacuation routes to
employees, even through noise and confusion.
Outside support sources must be reached and
measures for public notification must be ensured,
if necessary. To accomplish this, a separate set of
internal emergency signals should be developed
and rehearsed daily. External communication
systems and procedures should be clear and
accessible to all workers.
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11.1.3 Site Mapping
Detailed information about the
site is essential for advance
planning. For this purpose, a
site map is a valuable tool. It
serves as a graphic record of
the locations and types of
hazards, a reference source,
and a method of documentation. The map should
focus on potential areas where emergencies may
develop, and should be sure to highlight:
• Hazard areas, especially potential IDLH
conditions;
• Site terrain: topography, buildings,
barriers;
• Evacuation routes;
• Site accessibility by land, sea, and air; and
• Off-site populations or environments at
risk.
It is recommended that maps be prepared to
scale in a professional manner so that the map can
be used as a basis for planning and training, as
well as for developing potential emergency
scenarios and alternative response strategies.
When an emergency occurs, the problem areas
should be pinpointed on the map. Pertinent
information (e.g., weather and wind conditions,
temperature, and forecast) should be added. The
map can then be used to design the emergency
response plan. When using the map for such
purposes, the accuracy of the data obtained and
the potential for over- or under-estimating a
hazard should be considered. Even if the
emergency develops so fast that the map cannot be
used for on-the-spot planning, prior familiarity
with it will aid in making informed decisions.
11.2
HAZARDS
Although the medical program is essential for
assessing and monitoring employee health and
fitness before the employee begins activities and
during the course of employment, employees
should be aware of specific hazards in the
workplace.
The following sections describe the specific
hazards that site personnel face during hazardous
waste operations. It is important to remember
that no two sites are alike, and that each site may
present unique hazards to employees based on the
contaminants present, site conditions, site
geography and location, and weather.
11.2.1 Explosion and Fire
Explosions and fires at a
hazardous waste site may occur
for a variety of reasons.
Accidentally mixing incom-
patible chemicals could cause
an intense exothermic reaction.
A spark or flame could be
introduced into an oxygen enriched or flammable
atmosphere. The movement or removal of tanks
and drums could agitate shock-sensitive
compounds or could release materials stored under
high pressure.
Explosions and fires may arise spontaneously,
although they more commonly result from site
activities. In addition to the normal dangers of
intense heat, open flame, smoke inhalation, and
flying objects, an explosion or fire at a hazardous
waste site poses the additional threat of potentially
releasing hazardous substances into the
atmosphere. Such releases can threaten both
personnel on-site and members of the general
public living or working nearby. The following
precautions should be taken to protect against the
hazard: (1) have qualified personnel monitor for
explosive atmospheres and flammable vapors; (2)
keep all potential ignition sources away from an
explosive or flammable environment; (3) use
nonsparking, explosion-proof equipment; and (4)
follow safe practices when performing any task that
might result in the agitation or release of
chemicals.
11.2.2 Oxygen Deficiency
O
2
The oxygen content of normal
air at sea level is approx-
imately 21 percent. Physio-
logical effects of oxygen
deficiency are readily apparent
when the oxygen concentration
in air decreases to 16 percent.
These effects include impaired attention, judgment
and coordination, and increased breathing and
heart rate. Oxygen concentrations lower than 16
percent can result in nausea and vomiting, brain
damage, heart damage, unconsciousness, and death.
131
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For individual physiological responses and errors
in measurement, precautions should be taken when
the ambient oxygen level is 19.5 percent or lower.
Oxygen deficiency may result from the
displacement of oxygen by another gas, or the
consumption of oxygen by a chemical reaction.
Confined spaces or low-lying areas are particularly
vulnerable to oxygen deficiency and should always
be monitored prior to entry. Qualified field
personnel should always monitor oxygen levels and
should use atmosphere-supplying respiratory
equipment when oxygen concentrations drop below
19.5 percent.
11.2.3 Ionizing Radiation
Radioactive materials emit one
or more of three types of
harmful radiation: alpha, beta,
and gamma. Exhibit 11-2
presents the characteristics of
these three types of radiation.
Alpha radiation has limited
penetration ability and is usually stopped by
clothing and the outer layers of the skin. Alpha
radiation poses little threat outside the body. Beta
radiation can cause harmful "beta burns" to the
skin and damage the subsurface blood system.
Both alpha and beta radiation can be hazardous if
radioactive materials emitting alpha or beta
radiation are introduced into the body. Use of
protective clothing combined with scrupulous
personal hygiene and decontamination provides
good protection against alpha and beta radiation.
Gamma radiation passes easily through clothing
and human tissue and can also cause serious
permanent damage to the body. Chemical-
protective clothing affords no protection against
gamma radiation itself; however, use of respiratory
and other protective equipment can help keep
radioactive materials from entering the body.
If levels of radiation above natural
background levels are discovered, a health physicist
should be consulted. At levels greater than 2
millirems per hour, all site activities should cease
until the site has been assessed by health physicists.
11.2.4 Biological Hazards
Wastes from hospitals and
research facilities may contain
disease-causing organisms that
could infect site personnel.
Like chemical hazards, patho-
gens may be dispersed in the
environment via water and
wind. Other biologic hazards that may be present
include poisonous plants, insects, animals, and
EXHIBIT 11 -2
Radiation Characteristics
ALPHA
(«)
BETA
(P)
GAMMA
(y)
Form
Particle
Particle
Electro-
magnetic
Energy
Relative
Mass
4 Atomic
Mass Units
.000001
0
Velocity
1/10 C
(C = Speed
of Light)
99% C
C
Path
Length
< 1 inch
1 meter
Several
Meters to
Kilometers
Number of
lonizations/
cm in Air
Hundreds of
Thousands
Hundreds
1
Biological
Hazard
Internal
Internal/
External
External
132
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indigenous pathogens. Protective clothing and
respiratory equipment, and identification of toxic
plants, animals, and insects in the area can help
reduce the chances of exposure. Thoroughly
washing any exposed body parts and equipment
will also help protect against infection.
11.2.5 Safety Hazards
Hazardous waste sites may
contain a variety of safety
hazards, including holes,
ditches, precariously positioned
or sharp objects, slippery
surfaces, steep grades, uneven
terrain, and unstable surfaces.
In addition to those safety hazards that are a
function of the site, many safety hazards are a
function of the work itself. Heavy equipment
creates an additional hazard for workers in the
vicinity of the operating equipment. PPE can
impair workers' vision, hearing, or agility.
Removal of wastes can create physical hazards at
the site that were not present prior to the
beginning of operations.
Accidents involving physical hazards can
directly injure workers and can create additional
hazards such as increased exposure to chemicals
due to damaged protective equipment. Site
personnel should constantly be aware of potential
safety hazards, and should immediately inform a
supervisor of any new hazards so that mitigative
action can be taken.
One potential hazard that results from a
variety of sources is electrocution. Overhead
power lines, downed electrical wires, and buried
cables all pose a danger of shock or electrocution
if workers come into contact with or sever them
during site operations. Electrical equipment used
on-site may also pose a hazard to workers. Low-
voltage equipment with ground-fault interrupters
and water tight, corrosion-resistant connecting
cables should be used on-site to minimize electrical
hazards. Lightning is a hazard during outdoor
operations, particularly for workers handling metal
containers or equipment. To eliminate this hazard,
weather conditions should be monitored and work
should be suspended during electrical storms. The
OSHA standards at 29 CFR §1910.136 describe
proper clothing and equipment for protection
against electrical hazards.
11.2.6 Noise Hazards
At many sites, different
activities (e.g., drilling
operations, heavy equipment
operations) may result in
appreciable noise levels. It is
important that area and
personal noise surveys be
conducted to categorize noise levels appropriately.
A sound level meter that has the capability to
integrate and average the sound levels throughout
the work day is required to monitor employee
exposure to noise levels. Exhibit 11-3 provides
OSHA's Permissible Noise Exposures. These
values represent noise levels over which workers
may not be exposed without risking adverse
hearing effects. These values should be used as
guides and should not be regarded as fine lines
between safe and dangerous levels.
EXHIBIT 11-3
Permissible Noise Exposures
Duration per day, hours
8
6
4
3
2
Vk
1
'/2 . . .
yt or less
Sound level dBA
slow response
90
92
95
97
100
102
105
110
115
NOTE: When daily noise exposure is composed of
two or more periods of noise exposure of different
levels, their combined effect should be considered,
rather than the individual effect of each. If the sum
of the following fractions: 0,/T, + C2flz...CnfTn
exceeds unity, then, the mixed exposure should be
considered to exceed the limit value. Cn indicates
the total time of exposure at a specified noise level,
and Tn indicates the total time of exposure
permitted at that level.
Continuous and Intermittent Noise.
Currently, the OSHA-Permissible Exposure Limit
(PEL) for an 8-hour work day, 40-hour work week
is 90 decibels, as recorded on a sound level meter
on the A weighted scale (dBA). If the 8-hour time
weighted average noise exposures equal or exceed
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85 dBA, the site manager must implement a
hearing conservation program. If feasible
administrative and engineering controls do not
reduce sound levels to within acceptable limits,
employees should use appropriate PPE to reduce
personal exposure.
Impulsive or Impact Noise. Exposure to
impulsive or impact noise should not exceed the
limits given in Exhibit 11-4. No exposures in
excess of 140 dB peak sound pressure level are
permitted. Impulsive or impact noise is considered
to be a variation in noise levels that involves
maxima at intervals of greater than one per second.
Where the intervals are less than one second,
exposure should be considered continuous and
should be integrated into the time weighted
average.
EXHIBIT 11 -4
Threshold Limit Values for
Impulsive or Impact Noise
Sound Level
dB*
140
130
120
Permitted Number of
Impulses or Impacts per
Day
100
1000
10,000
Decibels peak sound pressure level
11.2.7 Work Hazards
The nature of the work done at a hazardous
waste site can contribute to the health and safety
risks at the site. Trench excavation can increase
the instability of the site and increase the risk of a
"cave in" or collapse. Moving chemical drums may
injure a worker if the drum ruptures, spilling
chemicals in higher quantity than the protective
clothing was designed to accommodate. Drums
also pose the threat of back injury or a hernia if
those workers moving them do not take proper
precautions.
Confined spaces, discussed in detail below,
often present a major health and safety hazard to
workers involved in hazardous waste site
operations. In accidents involving confined spaces,
a potential rescuer frequently becomes a victim
because he or she rushes into the space without
taking proper precautions such as a self-contained
breathing apparatus. Therefore, it is important
that rescuers recognize the atmospheric hazards of
a confined space and take proper precautions.
11.3 CONFINED SPACE ENTRY
The proposed Confined Space Standards at
29 CFR §1910.146 may provide the basis upon
which to develop a program for entry into confined
spaces that pose potential health or safety risks. A
confined space is defined as any location that, by
design, has limited openings for entry and egress,
is not intended for continuous employee
occupancy, and is so enclosed that natural
ventilation may not reduce air contaminants to
levels below the threshold limit value (TLV).
Entry into confined spaces without the proper
precautions could result in injury and/or
impairment due to:
• An atmosphere that is flammable or
explosive;
• Lack of oxygen to support life;
• Toxic materials that upon contact or
inhalation could cause injury, illness, or
death; or
• General safety hazards such as steam, high
pressure materials, or other work area
hazards that could result in injuries.
Examples of confined spaces include: manholes,
stacks, pipes, storage tanks, trailers, tank cars, pits,
sumps, hoppers, and bins. It is important to note
that even some buildings might be considered a
confined space (e.g., an abandoned chemical
laboratory with no open doors or windows).
The following elements of confined site entry
should be addressed at each site:
• Hazards information and control;
• Employee training and information;
• Prevention of unauthorized entry;
• Equipment;
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• Emergency rescue;
• Protection from external hazards;
• Training and duties of authorized entrants,
attendants, and individuals authorizing or in
charge of entry.
Before entry could be made into a confined
space, a confined space entry checklist should be
completed and signed. Exhibit 11-5 provides the
proposed Confined Space Entry Permit. To insure
that all areas of the confined space are safe for
work, the following situations should be evaluated
by competent personnel:
Flammable or Explosive Potential. Technic-
ally competent personnel trained in testing
methods using an explosive gas detector should
test the atmosphere within the confined space. If
combustible gases are present, entry should not be
allowed until the source has been isolated and the
space flushed or purged so that the test indicates
less than 5 percent of the lower explosive limit.
Oxygen Deficiency. Technically competent
personnel should use approved oxygen testing
equipment to test the atmosphere within the
confined space to determine whether the air is
respirable and contains sufficient oxygen to
support normal consciousness. If the air is found
to be oxygen deficient (less than 17 percent by
volume), positive ventilation techniques, including
fans and blowers, may be used to increase the
oxygen content. If, after further testing, the oxygen
concentration is still deficient, SCBA or another
proven air supply should be provided and used.
Toxic or Corrosive Materials. When toxic or
chemical materials that could result in injury by
contact or inhalation by persons entering the
confined space are detected or suspected, several
actions should be taken by on-site personnel.
First, any piping that conveys hazardous materials
to the confined space should be isolated. Second,
the space should be emptied of the hazardous
substance until safe limits are reached. Third,
adequate ventilation equipment, as well as all
other appropriate protective equipment for
protection of the eyes, face, and arms should be
provided if the work to be done in the confined
space includes welding, burning, or heating, which
may generate toxic fumes and gases. Finally, all
employees entering a confined space that has
contained corrosive materials should wear eye and
other appropriate protective equipment to prevent
possible contact with any remaining corrosive
material.
A hazard evaluation should be conducted
before any work in a confined space is started, to
identify existing or potential work area hazards
that have the potential to cause injuries, illness, or
property damage. Examples of work area hazard
control items include unguarded openings, high or
low temperatures, poor illumination, sharp edges,
steam, compressed gases and liquids, flammable or
combustible materials, and mechanical or electrical
exposures. When dealing with hazards that cannot
be eliminated or controlled, adequate PPE should
be used.
Prior to entry into a confined space,
consideration should be given to how life support
systems would function in the event of a power
failure. For example, in the event of electrical
failure, air supply pumps, lights, warning systems,
and other electrically powered devices would be
inoperative. Site personnel should have an
emergency plan of action that provides alternate
life support systems and a means of escape from
the confined space. The Site Health and Safety
Officer should have communicated this plan to all
employees engaged in work in confined spaces.
Each employee entering a confined space
should wear a safety belt equipped with a life-line
for evacuation purposes in case of an emergency.
If the entry is through a top opening, the safety
belt should be of the harness type that will suspend
a person in an upright position. Emergency equip-
ment such as life-lines, safety harnesses, fire
extinguishers, breathing equipment, and other
devices appropriate to the situation should be
ready and immediately available. All persons
engaged in the activity should be trained in the use
of the life support system, rescue system, and
emergency equipment. In keeping with the buddy
system, at least one person, trained in first aid and
respiration, should be immediately available
outside the confined space to provide assistance if
needed, utilizing a planned and immediately
available communications means.
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EXHIBIT 11-5
OSHA's Proposed Confined Space Entry Permit
D CONFINED SPACE ENTRY PERMIT
LOCATION and DESCRIPTION
of Confined Space
PURPOSE of Entry _
DEPARTMENT
D HAZARDOUS AREA ENTRY PERMIT
Date
Time
Expiration.
M
M
PERSON in Charge of Work .
SUPERVISOR (S) in Charge of Crews
SPECIAL REQUIREMENTS
Lock Out - De-energize
Lines Broken - Capped or Blanked
Purge - Flush and vent
Ventilation
Secure Area
Breathing Apparatus
Resuscitator - Inhalator
TEST(S) TO BE TAKEN
(Valid for one 8-hour turn entry)
% of Oxygen
% of L E.L.*
Carbon Monoxide
Aromatic Hydrocarbon
Hydrocyanic Acid
Hydrogen Sulfide
Sulfur Dioxide
Ammonia
Yes
P.E.L.*
.19 5% +21%
Any % over 10
50 ppm
10 ppm
10 ppm
10 ppm
5 ppm
25 ppm
Y
E
S
No
N
O
Type of Crew
Phone
Escape Harness
Tripod emergency escape unit
Lifelines
Fire Extinguishers
Lighting
Protective Clothing
Respirator
DATE
M
DATE
M
DATE
M
DATE
M
DATE
M
Yes
DATE
M
OKTE
M
No
DATE
M
Name
GAS TESTER
Note: Continuous/periodic tests shall be established before beginning job. Any questions pertaining to test requirements
contact certified division gas tester, Plant Gas Coordinator or the Industrial Hygienist
Ye
No
INSTRUMENTS USED Name
s D
D
Type
SAFETY STANDBY PERSON(S) Name
Ident. No.
Ck. No.
Supr authorizing all above conditions satisfied
AMBULANCE ' P.E.L Permissible Entry Level
FIRE ' L.E.L. Lower Explosion Level
Orig. to Dept.
Copy to Safety
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11.4 INFORMATION AND NEW
TECHNOLOGY PROGRAMS
Two additional programs that
must be developed, imple-
mented, and included as part
of the employer's health and
safety program are information
and new technology programs
(29 CFR §1910.120(i) and (o)).
The information program must be developed and
implemented to inform employees, contractors, and
subcontractors engaged in hazardous waste
operations of the nature, level, and degree of
exposure that may result from performing
hazardous waste operations. In developing this
informational program, the employer should
consult the Hazard Communications Standard
(HCS) (29 CFR §1910.1200 and 29 CFR
§1926.59), which may contain information that
would be useful to incorporate into the
informational program or emergency response plan
for a site. Employees, contractors, and
subcontractors working outside of the operational
part of a site are not covered by this standard.
In addition to developing an informational
program, the employer must include as part of the
health and safety program procedures for
introducing new and innovative technologies into
the work area. The purpose of the new technology
program is to ensure that new and improved
technologies and equipment are developed and
introduced to provide for the improved protection
of employees engaged in hazardous waste cleanup
operations. As part of the new technology
program, the employer must carefully evaluate new
technologies, equipment, and control measures,
such as absorbents and neutralizers, as they are
introduced and made available on the market.
This evaluation, which must be completed prior to
using the new technology on a large scale at the
site, must assess the effectiveness of the new
equipment, method, or material. Any data or
information obtained during the evaluation must
be made available to OSHA upon request.
11.5 CONSTRUCTION REQUIREMENTS
In addition to the worker protection
standards at 29 CFR §1910.120, OSHA has a
number of regulations at 29 CFR Part 1926 that
set forth safety and health standards specifically
applicable to the construction industry. These
standards establish workplace requirements for the
following, among others:
• Subpart C: General Health and Safely
Provisions;
• Subpart D: Occupational Health and
Environmental Controls, for providing
adequate illumination and ventilation;
• Subpart F: Fire Protection and Prevention,
for storing flammable and combustible
liquids;
• Subpart G: Signs, Signals, and Barricades,
for posting adequate accident prevention
signs and tags;
• Subpart I: Tools — Hand and Power; and
• Subpart P: Excavations.
Appendix B provides a detailed description of
these and other common applicable OSHA
standards.
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FURTHER GUIDANCE: For more information on emergency response and safety considerations, see:
1. HAZMAT Team Planning Guidance (U.S. EPA, 1990, EPA 540/G-90/003X
2.
3.
4.
5.
6.
NIOSH Pocket Guide to Chemical Hazards (NIOSH, 1991, Publication 90-1 17V
Occupational Safety and Health Guidelines for Chemical Hazards/Supplement II-OHG (NIOSH
, 1989,
Publication 89-104).
1991-1992 Threshold Limit Values for Chemical Substances and Physical Agents, and Biological Exposure
Indices. American Conference of Governmental Industrial Hygienists, 1991.
Criteria Document - Working in Confined Spaces (NIOSH, 1980, Publication 80-106).
NIOSH Alert: Request for Assistance in Preventing Occupational Fatalities in Confined Spaces
1986, Publication 86-110).
(NIOSH,
138
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ACRONYMS
ANSI American National Standards Institute NPRM
CFR Code of Federal Regulations OSHA
CGI Combustible Gas Indicator
CPC Chemical Protective Clothing OVA
CPR Cardiopulmonary Resuscitation PA/SI
CRZ Contamination Reduction Zone
DOT U.S. Department of Transportation PCB
DRI Direct Reading Instrument PE
EHS Extremely Hazardous Substance PEL
EPA US Environmental Protection Agency PHC
ERT US EPA Environmental Response PID
Team PPE
FID Flame lonization Detector
FR Federal Register RCRA
GC Gas Chromatography
HASP Site-Specific Health and Safety Plan REL
HAZCOM Hazard Communication Standard RI/FS
(HCS)
HAZMAT Hazardous Material SAR
HAZWOPER Hazardous Waste Operations SARA
and Emergency Response
HCS Hazard Communication Standard SCBA
(HAZCOM)
IDLH Immediately Dangerous to Life or SOP
Health SOSG
IR Infrared TLV
LEL Lower Explosive Limit TSD
NFPA National Fire Protection Association TWA
NIOSH National Institute for Occupational USCG
Safety and Health
Notice of Proposed Rulemaking
U.S. Occupational Safety and Health
Administration
Organic Vapor Analyzer
Preliminary Assessment and Site
Investigation
Polychlorinated Biphenyls
Preliminary Investigation
Permissible Exposure Limit
Principal Hazardous Constituent
Photoionization Detector
Personal Protective Clothing and
Equipment
Resource Conservation and Recovery
Act
Recommended Exposure Limit
Remedial Investigation and Feasibility
Study
Supplied-Air Respirator
Superfund Amendments and
Reauthorization Act of 1986
Self-Contained Breathing Apparatus
Standard Operating Procedure
Standard Operating Safety Guides
Threshold Limit Value
Treatment, Storage, and Disposal
Time-Weighted Average
U.S. Coast Guard
ABBREVIATIONS
cm
CO2
dBA
ft
g
hr
I
Ib
m3
cubic centimeter
carbon dioxide
decibels on A-weighted scale
foot
gram
hour
liter
pound
cubic meter
mg milligram
ml milliliter
mrem milliroentgen equivalent in man
O2 oxygen
ppb parts per billion
ppm parts per million
ta ambient air temperature
ta adj adjusted ambient air temperature
139
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APPENDIX A
SOURCES OF INFORMATION AND RESPONSE ASSISTANCE
This Appendix provides a short bibliography of technical manuals and sources of
response information. It includes basic chemical and emergency response reference
documents, toll-free hotlines and other telephone information sources, and private
organizations that offer emergency response assistance and information.
-------
SOURCES OF INFORMATION AND RESPONSE ASSISTANCE
A. INTRODUCTION
Many reference texts and organizations can provide response personnel with technical data and
physical assistance regarding both the hazards associated with an incident and methods to deal with
them. Because of the variety of activities encountered in hazardous waste field operations, it is
necessary to be aware of available resources, to determine their applicability to a project, and to
know how to use them.
The information, which may include data on sites, topography, meteorology, physical/chemical
properties of the material, applicable treatment methods, and available cleanup resources, can be
provided by various agencies, maps, reference books, and manuals. It is advisable to get data from at
least two sources and use the latest edition of any reference, especially when searching for hygienic
standards or toxicological data.
Access to on-line computer files may be possible at the site if a telephone, portable terminal, and
120-volt outlet are available. Aerial photographs can also provide useful information when properly
interpreted.
NOTE: References are not presented in any particular order.
B. BASIC REFERENCES
1. A Compendium of Superfund Field Operations Methods (U.S. EPA, 1987, EPA/540/P-87/001).
The compendium was developed by the U.S. EPA Office of Emergency and Remedial Response
primarily to assist the manager as he/she conducts site investigations and assessments. It
discusses recordkeeping, site safety, sampling, laboratories, geology, hydrology, quality assurance
and a number of other important topics. The information is presented in an easy to understand
format, but is not arranged for quick reference (an index is not included).
2. CHRIS: Chemical Hazard Response Information System developed by the U.S. Coast Guard.
Access through the National Response Center, telephone (800) 424-8802.
CHRIS consists of four manuals, a regional contingency plan, a Hazard Assessment Computer
System (HACS), and an organizational entity at Coast Guard Headquarters. Volume 1 (CG-
446-1) is designed to be used by the first responders at an incident. Volumes 2, 3, and 4 (CG-
446-2), CG-446-3, and CG-446-4, respectively) are intended for use by the On-Scene
Coordinator's (OSC) office along with Regional and National Response Center. Main Coast
Guard stations will usually have these manuals.
a. Volume 1: Condensed Guide to Chemical Hazards
Volume 1 is intended for use by the first responders on the scene of an incident. The
chemicals involved must be known, however, before the appropriate information can be
obtained from the manual. This volume also contains a list of questions needed to access
Volume 3. All information in this volume can be found in Volume 2.
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b. Volume 2: Hazardous Substance Data Manual (also available from the U.S. Government
Printing Office, Washington, DC 20402, GPO stock number 050-012-00147-2)
Volume 2 is probably the most useful in responding to spills/waste sites. It contains
information on hazardous chemicals shipped in large volume by water and is intended to
be used by port security personnel and others who may be first to arrive at the scene. The
easily understood information regarding chemical, physical, and lexicological properties
can help quickly determine the actions to be taken immediately to safeguard life, property,
and the environment.
c. Volume 3: Hazard Assessment Handbook
Volume 3 describes methods of estimating the quantity of chemicals that may be released
during an incident, their rate of dispersion, and the methods for predicting any potential
toxicity, fire, and explosive hazards.
Volumes 2 and 3 are designed to be used together. The hazard assessment code in
Volume 2 for each chemical is used in Volume 3 to select the appropriate procedures for
estimating degree of hazard.
d. Volume 4: Response Methods Handbook
Volume 4 contains information on existing methods for handling spills of hazardous
materials. The appendix lists manufacturers of equipment which may be useful. It also
describes methods of spill containment (primarily oil). This volume is intended for use by
Coast Guard OSCs with some training or experience in hazard response.
3. Condensed Chemical Dictionary, Gessner G. Hawley, Van Nostrand Reinhold Co., 135 W. 50th
Street, New York, NY 10020.
This book, a compendium of technical data and descriptive information covering many
thousands of chemicals and reactions, is designed for use in industrial situations and can be
helpful in assessing a hazardous waste site or spill. However, information pertaining to
environmental behavior of chemicals is limited and can be misleading. Three distinct types of
information are presented:
a. Technical descriptions of compounds, raw materials, and processes.
b. Expanded definitions of chemical entities, phenomena, and terminology.
c. Description or identification of a wide range of trade-name products used in the chemical
industry.
4. Dangerous Properties of Industrial Materials, edited by N. Irving Sax, Van Nostrand Reinhold,
Co., 135 W. 50th Street, New York, NY 10020.
This book provides a single source of concise information on the hazards of nearly 13,000
common industrial and laboratory materials. Descriptive information and technical data are
given in the three sections of the book. The main section "General Information" is designed to
expedite retrieval of hazard information. The three sections are:
a. "General Information" - synonyms, description, formula, physical constants.
b. "Hazard Analysis" - toxicity, fire hazard, explosive hazard.
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c. "Counter-measures" -- handling, storage, shipping, first aid, fire-fighting, personnel
protection.
This book is not intended for use on-site. It can be useful later, however, to verify hazards
associated with the emergency.
5. Documentation of the Threshold Limit Values (TLV®), ACGIH Publications Office, 6500
Glenway Avenue, Building D-5, Cincinnati, OH 45211.
This reference includes pertinent scientific information about each substance with references to
literature sources used to determine each TLV. Each documentation also describes the type of
toxic response for which the limit is used. This book should be consulted for a better
understanding of TLVs.
6. Emergency Response Guidebook: developed under the supervision of the Office of Hazardous
Materials Transportation, Research and Special Programs Administration, U.S. Department of
Transportation. The guidebook is available through UNZ&CO, 190 Baldwin Avenue, Jersey
City, NJ 07306.
The guidebook is intended to assist first responders in making informed judgments during the
initial phases of a transportation incident involving hazardous materials. It lists the UN/NA
numbers designated for hazardous materials, identifies potential hazards associated with the
materials and recommends emergency actions to be taken following a spill. It also makes
recommendations as to when areas should be evacuated or isolated in the event of a spill.
7. Handbook of Environmental Data on Organic Chemicals. Karel Verschueren, published by Van
Nostrand Reinhold Company, Inc., 115 Fifth Avenue, New York, NY 10003.
This handbook provides information to: properties of organic chemicals; air pollution factors;
water pollution factors; and biological effects. Where entries are not complete, it may be
assumed that no reliable data were provided by the references utilized. The author uses
numerous abbreviations which are explained in the first section of the book. Individuals who
are not familiar with the abbreviations will find themselves referring to the first section
frequently in order to understand listings of specific chemicals.
8. Hazardous Materials Injuries: A Handbook for Pre-Hospital Care, Bradford Communications
Corp., 7500 Greenway Center Drive, Greenbelt, MD 20770.
This reference provides information on pre-hospital care. The handbook is set-up similar to
the US DOT Guidebook.
9. The Merck Index, Merck and Company, Inc., Rahway, NJ 07065.
The Merck Index is a comprehensive, interdisciplinary encyclopedia of chemicals, drugs, and
biological substances. It describes 9,856 chemicals in a structured format. An extensive index
and cross-index make the manual easy to use. It is designed to serve a variety of purposes. For
response personnel, it provides information on physical/chemical properties of chemicals and
their toxicity.
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10. National Institute of Occupational Safety and Health/Occupational Safety and Health
Administration Resources.
a. NIOSH Pocket Guide to Chemicals Hazards, U.S. Government Printing Office, 1991,
Washington, DC 20402.
Information in this pocket guide comes from the NIOSH/OSHA Occupational Health
Guidelines. Presented in a tabular format, it is a reference for industrial hygiene and
medical surveillance practices. Included are chemical names and synonyms, permissible
exposure limits, chemical and physical properties, signs and symptoms of overexposure,
environmental and medical monitoring procedures, recommended respiratory and personal
protective equipment, and procedures for treatment.
b. NIOSH/OSHA Occupational Health Guidelines for Chemical Hazards, U.S. Government
Printing Office, Washington, DC 20402.
This three-volume document provides technical data for most of the substances listed in
the "NIOSH/OSHA Pocket Guide." The information is much more detailed and is
designed primarily for use by industrial hygienists and medical surveillance personnel. In
addition to the information found in the "Pocket Guide," "Occupational Health
Guidelines" includes recommended medical surveillance practices, air monitoring and
measurement procedures, protective equipment, and spill and disposal techniques.
11. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities: developed
by NIOSH/OSHA/USCG/EPA, U.S. Government Printing Office, 1985, Washington, DC 20402.
This manual is a guidance document for managers responsible for occupational safety and
health programs at inactive hazardous waste sites. It is intended for federal, state, and local
officials and their contractors. It may be used: as a planning tool by government or private
individuals; as a management tool by upper level or field managers; as an educational tool to
provide a comprehensive overview of all aspects of safety and health protection at hazardous
waste sites; or as a reference document for site personnel who need to review important aspects
of health and safety.
12. OHMTADS: Oil and Hazardous Materials Technical Assistance Data System, developed by the
U.S. EPA. Access through U.S. EPA Regional Offices.
OHMTADS is a computerized data retrieval system available in the form of a computer print-
out, manuals, or microfiche. For each of more than 1,000 oil and hazardous substances, there
are 126 possible information segments on, for example, toxicity and associated hazards,
personnel safety precautions, cleanup and disposal methods, materials handling, and fire
fighting. However, not all information is available for all materials.
13. Registry of Toxic Effects of Chemical Substances, U.S. Government Printing Office, Washington,
DC 20402.
This annual publication is sponsored by NIOSH and contains toxic dose data with references to
source documents and major standards and regulations for 35,000 chemicals.
14. Farm Chemicals Handbook 1991, edited by Charlotte Sine, Meister Publishing Company,
Willoughby, Ohio, 1991.
This handbook/dictionary provides information on the properties of common pesticides and
herbicides utilized in the farming industry.
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C. TOLL-FREE AND OTHER TELEPHONE INFORMATION SOURCES
1. Federal Information Sources
a. Chemical Emergency Preparedness Program (CEPP1 Information: Continental US (Toll
Free) (800) 535-0202, DC Metropolitan Area (202) 479-2449.
Contact: Chemical Emergency Preparedness Program (CEPP), Office of Solid Waste and
Emergency Response (WH-548A), U.S. Environmental Protection Agency, 401 M Street,
SW, Washington, DC 20460. EPA established the toll-free technical assistance hotline in
1985.
b. Coast Guard National Strike Force. Access through the National Response Center,
telephone (800) 424-8801.
The National Strike Force (NSF) is a part of the National Response Team established
under the authority of the Federal Water Pollution Control Act as amended in 1977.
c. Environmental Response Team (ERT). Telephone (908) 321-6740.
The National Contingency Plan directed EPA to establish the ERT to advise OSCs and
Regional Response Teams on environmental issues related to spill containment, cleanup,
and damage assessment. The team, established in October 1978, provides expertise in
biology, chemistry, and engineering for environmental emergencies, as well as special
equipment to control and clean up chemical discharges.
The ERT makes it possible for EPA to provide around-the-clock support to the Regional
Offices through personnel whose sole responsibility is to respond to environmental
emergencies. The Team is EPA's focal point for technical assistance to the Regions and
Program Offices during emergency episodes involving toxic and hazardous wastes. The
Team has two locations: Edison, NJ, and Cincinnati, OH. Usually, request for help from
the Team comes from each Region's Emergency Coordinator, once the conclusion has
been reached that technical assistance is needed. The Team consists of 23 individuals with
long experience in dealing with various types of environmental emergencies and in
responding to requests for assistance at uncontrolled hazardous waste sites.
The Team is responsible for coordinating the Response, Analytical and Engineering
Contract (REAC), a cooperative effort between the Team, the Office of Research and
Development's Oil and Hazardous Materials Spill Branch, and contractor personnel.
Services available through the Response Unit include prototype spill control equipment
such as the mobile physical/chemical treatment system, a mobile flocculation/
sedimentation system, contract laboratory analytical services, and pilot plant treatment
studies.
d. Department of Transportation (DOT) Hotline. Telephone (202) 426-2075.
This telephone service was established by the Standards Division of the Materials
Transportation Bureau, Office of Hazardous Materials Regulations, to provide
informational assistance to those interpreting DOT regulations, as defined in 49 CFR.
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e. Hazard Assessment Computer System (HACSV Telephone (800) 424-8802.
HACS, the computerized counterpart of Volume 3 of the CHRIS manuals, makes it
possible to obtain very detailed hazard evaluations through the computer at Coast Guard
Headquarters. The system is intended primarily for use by the OSC.
2. Private Information Sources
a. Bureau of Explosives. Association of American Railroads (AAR), telephone (202)
835-9500.
This 24-hour emergency number can be used for assistance for hazardous materials
incidents involving railroads. This office is often contacted through CHEMTREC.
b. Chemical Referral Center rCRC). Telephone (800) 262-8200, Monday through Friday, 8
a.m. to 9 p.m. EST.
Contact: Chemical Manufacturers Association (CMA), 2501 M Street, NW, Washington,
DC 20037. CMA makes this toll-free telephone number available for the general public
to use to gain access to non-emergency health and safety information about chemicals.
When the Center receives an inquiry about a chemical, the operator first must determine
that the call is not an emergency. Emergencies are immediately routed to CMA's
Chemical Transportation Emergency Center (CHEMTREC), which gives emergency
personnel detailed information on how to handle the incident (see below). If the inquiry
is not on emergency, the operator finds out the name of the company that manufactures
the product in question. Working from a computerized index of over 110,000 trade name
products, the operator gives the caller the address and phone number of the company
person to call. That person will provide the specific health and safety information asked
for. For more information about the CRC, contact (202) 887-1318.
c. CHEMTREC. Chemical Manufacturers Association, (800) 424-9300. Alaska, Hawaii, and
DC (202) 483-7616.
Contact: Chemical Manufacturers Association, 2501 M Street, NW, Washington, DC
20037. CMA established CHEMTREC to provide immediate assistance to those at the
scene of accident, 24 hours a day, seven days a week. CHEMTREC maintains an on-line
librarian. Other requests will be referred back to the appropriate states for handling.
When the situation requires an immediate response and the manufacturer is unable to
respond promptly, CHEMTREC can activate CHEMNET. CHEMNET is an industry-
wide mutual aid program established to provide chemical expertise at the scene of a
chemical emergency. The program currently includes more than 77 chemical producers,
their response teams, and more than 50 private contractor emergency response teams.
CHEMTREC can also provide emergency respondents with a "hard copy" of the
information which they have stored on the product during emergencies. The HIT
(Hazardous Information Transmission) program requires that response personnel be
preregistered and have access to a personal computer, a modem, and a printer. For
additional information on the HIT program, contact R. Jay Chezem at the address listed
above, or at (202) 887-1255.
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d. CHLOREP (Chlorine Emergency PlanX Access through CHEMTREC.
CHLOREP was established by the Chlorine Institute to handle chlorine emergencies in
the U.S. and Canada. The system operates through CHEMTREC. Upon receiving an
emergency call, CHEMTREC notifies the nearest manufacturer in accordance with a
mutual aid plan. This manufacturer then contacts the emergency scene to determine if a
technical team should be sent to assist. Each participating manufacturer has trained
personnel and equipment available for emergencies.
e. TEAP (Transportation Emergency Assistance Plan). Canadian Chemical Producers
Association. Access 24 hours a day through three regional control centers:
British Columbia, (604) 929-3341
Prairie Provinces, (403) 477-8339
Northern Ontario, (705) 682-2881
TEAP functions in Canada in a similar fashion to CHEMTREC in the U.S. It provides
emergency advice, gets knowledgeable personnel (usually the manufacturer) in touch with
responsible people at the scene of the emergency, and sees that on-the-scene assistance is
provided if needed. When the regional control center receives a call, the attendant
records basic information, obtains a call-back number, and perhaps gives preliminary
information from standard references if the name of the product is known. The attendant
then calls one of the center's technical advisors, who calls the scene of the accident to get
as much detail as possible and perhaps provides additional advice on coping with the
emergency. The advisor then tries to contact the producer. If the producer cannot be
reached, or if distances are great, the regional control center contacts a company familiar
with the product. The center is also prepared to send personnel and equipment to the
scene if necessary. Once contact has been established between producers and local
authorities on the scene, the technical advisor assumes a follow-up role and notifies the
Canadian Chemical Producers Association of the accident.
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APPENDIX B
OTHER COMMON APPLICABLE OSHA STANDARDS
This Appendix presents some common health and safety requirements that are
not part of 29 CFR §1910.120 that may need to be addressed prior to initiating
hazardous work activities. For sites at which any of these safety requirements are
applicable, the information from the regulation should be provided in sufficient
detail within the Health and Safety Plan (HASP) to provide adequate protection of
employees working on-site. The following are some of the more common OSHA
standards that should be considered for site activities, although the list does not
reflect all components of the OSHA General Industry (1910) or Construction (1926)
standards.
^'.^vo.j^j:
-"'• ^ •^••^^.
29 CFR 1910
29 CFR 1926
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OTHER COMMON APPLICABLE OSHA STANDARDS
OSHA Act, Section 5(a)(l): GENERAL DUTY CLAUSE
Under the "General Duty" clause of the Occupational Safety and Health Act of 1970, section 5(a)(l)
states that each employer "shall furnish to each of his employees employment and a place of employment
which are free from recognized hazards that are causing or are likely to cause death or serious physical
harm to his employees."
29 CFR §1904.2: LOG AND SUMMARY OF OCCUPATIONAL ILLNESSES AND INJURIES
This regulation requires that each employer maintain a log of all recordable occupational injuries and
illnesses and that the information be recorded in the log within 6 working days of the receipt of the
information. Form OSHA No. 200 or its equivalent is to be used for this purpose.
29 CFR §1910.20: ACCESS TO EMPLOYEE EXPOSURE AND MEDICAL RECORDS
An employer must provide exposure and medical records to an employee or designated representative
within 15 days after the request for access to records. If the employee requests copies of this information,
the employer must make the copies available to the employee at no cost. All employee medical records
must be maintained for the duration of employment plus 30 years by the employer.
29 CFR §1910.24: FIXED INDUSTRIAL STAIRS
This section contains specifications for the safe design and construction of fixed general industrial
stairs. This classification includes interior and exterior stairs around machinery, tanks, and other
equipment, and stairs leading to or from floors, platforms, or pits.
Requirements include stair strength, stair width, angle of stairway rise, stairway platforms, railings
and handrails, and vertical clearance. The requirements regarding stairs are very specific. For instance, 29
CFR §1910.24(h), Railings and Handrails, references 29 CFR §1910.23, which requires two standard rails
(one set on each open side) if the stairway is more than four feet in height from ground level.
29 CFR §1910.27: FIXED LADDERS
This regulation includes information on design requirements, specific features, appropriate
clearances, special requirements (e.g., use of cages for ladder heights greater than 20 feet), and appropriate
pitch when using a fixed ladder.
29 CFR §1910.28: SAFETY REQUIREMENTS FOR SCAFFOLDING
This regulation provides safety requirements for the construction, operation, maintenance, and use of
the approximately 20 types of scaffolding.
29 CFR §1910.38: EMPLOYEE EMERGENCY PLANS AND FIRE PREVENTION PLANS
This regulation applies to all emergency action plans and fire prevention plans required by particular
OSHA standards. With the exception of employers with 10 or fewer employees, both the emergency
action plan and the fire prevention plan are required in writing. The required elements of each of these
plans are provided in the regulation. If the employer has 10 or fewer employees, the elements of both
types of plans must be provided orally to the employees. The employer shall also perform housekeeping
and maintenance of equipment and systems as part of the fire prevention plan.
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29 CFR §1910.95: OCCUPATIONAL NOISE EXPOSURE
On many sites, different site activities (e.g., drilling operations, heavy equipment operations) may
result in appreciable noise levels. It is important that area and personal noise surveys be conducted to
categorize noise levels appropriately. A sound level meter that has the capability to integrate and average
sound levels over the course of a work day is required. Currently, the OSHA-Permissible Exposure Limit
for an 8-hour work day, 40-hour work week, is 90 decibels as recorded on a sound level meter on the A
weighted scale (dBA). An employer shall implement a hearing conservation program if 8-hour time
weighted average noise exposures equal or exceed 85 dBA. Continuous intermittent and impulsive sound
levels of 80 dBA or greater shall be integrated into the time weighted average.
29 CFR §1910.96: IONIZING RADIATION
This regulation covers employee protection measures related to the possession, use, or transfer of
ionizing radiation. The regulations set limitations on employee exposure to ionizing radiation and provide
methods for establishing precautionary procedures and personnel monitoring, including surveys of
radiation hazards, monitoring equipment, marking of radiation areas, emergency evacuation warning
signals, and personnel instruction. The regulations require notification of incidents of releases,
overexposure, or excessive levels or concentrations of radiation, and specify that employers must keep
records of employee exposure and disclose the information upon request from a former employee.
29 CFR §1910.101: COMPRESSED GASES
To the extent possible, each employer should determine, through a visual inspection, that compressed
gas cylinders under his/her control are in safe condition. Other inspections are prescribed in the DOT
Hazardous Materials Regulations. Specific safety requirements for handling compressed gases are found in
29 CFR §252(b).
29 CFR §1910.133: EYE AND FACE PROTECTION
Eye and face protection is required when there is the potential for on-site injury. Particular
information on goggles, spectacles, and face protection is included in this regulation. Design, construction,
testing, and use of such devices must be in accordance with ANSI Z87.1-1968 specifications.
29 CFR §1910.134: RESPIRATORY PROTECTION
Prior to wearing a respirator, an employee should be certified as medically able to wear one. Each
employer should have a written respiratory protection plan for selection and use of respirators. All
employees must receive training in the proper use of a respirator.
29 CFR §1910.135: OCCUPATIONAL HEAD PROTECTION
On-site situations requiring head protection include: presence of overhead objects, on-site operation
of heavy equipment, potential for flying objects in the work area, and possible electric shock hazard. In
addition to protecting workers from falling or flying objects, head protection affords limited protection
from electric shock and burn. Head protection must meet ANSI Z89.1-1969 specifications.
29 CFR §1910.136: OCCUPATIONAL FOOT PROTECTION
Safely toe footwear for employees must meet ANSI Z41.1-1967 specifications for Men's Safety Toe
Footwear. In general, workers at hazardous waste sites must wear leather or rubber boots with steel toes
and siccl shanks.
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29 CFR §1910.141: SANITATION
Specifications concerning appropriate housekeeping, waste disposal, vermin control, water supply,
toilet and washing facilities, showers, change rooms, waste disposal containers, sanitary storage, and food
handling for permanent places of employment are provided in this regulation.
29 CFR §1910.151: MEDICAL SERVICES AND FIRST AID
If a medical facility is not located in proximity to the workplace, there shall be a person or persons
on-site with adequate first-aid training. First-aid supplies approved by a consulting physician shall be
available on-site. If there is the potential for corrosive materials on-site, suitable facilities shall be
available for drenching of eyes and skin.
29 CFR §1910.165: EMPLOYEE ALARM SYSTEMS
The employee alarm system shall be recognizable to all on-site employees. The signal from the
employee alarm system shall be audible to employees in the event of a need to warn employees of an
evacuation from work areas.
29 CFR §1910.181: DERRICKS
Derricks attached to drill rigs must be periodically inspected. This regulation defines nine different
types of derricks. Specific information is provided on inspection; frequency of inspection; lead ratings;
rope use and inspection; fire extinguisher use; operation near power lines; and operating enclosures.
29 CFR §1910.252: WELDING, CUTTING, AND BRAZING
Detailed regulations exist for various types of welding, cutting, and brazing operations. There
regulations provide specific information on types of gases, gas pressures, operations and maintenance, and
safety procedures.
29 CFR §1910.307: HAZARDOUS LOCATIONS
Electrical equipment used in hazardous locations must be intrinsically safe and suitable for use in the
appropriate classified environment. Specified definitions of classifications and further information can be
found in §1910.307 and §1910.399.
Subpart Z, 29 CFR §1910.1000: TOXIC AND HAZARDOUS SUBSTANCES
There are other applicable OSHA standards that refer to particular air sampling procedures for
chemical contaminants, PPE requirements, and recordkeeping for a variety of compounds. These
compounds and their accompanying OSHA regulations are as follows:
Compound OSHA Reference
Asbestos 29 CFR §1910.1001
Coal tar pitch volatiles 29 CFR §1910.1002
4-nitrobiphenyl 29 CFR §1910.1003
Alpha-naphthylamine 29 CFR §1910.1004
Methyl chloromethyl ether 29 CFR §1910.1006
3,3'-dichlorobenzidine 29 CFR §1910.1007
bis-chloromethyl ether 29 CFR §1910.1008
beta-napthylamine 29 CFR §1910.1009
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Benzidine 29 CFR §1910.1010
4-aminodiphenyl 29 CFR §1910.1011
Ehthyleneimine 29 CFR §1910.1012
beta-propiolactone 29 CFR §1910.1013
2-acetylaminofluorene 29 CFR §1910.1014
4-dimethylaminoazobenzene 29 CFR §1910.1015
N-nitrosodimethylamine 29 CFR §1910.1016
Vinyl Chloride 29 CFR §1910.1017
Inorganic arsenic 29 CFR §1910.1018
Lead 29 CFR §1910.1025
Benzene 29 CFR §1910.1028
Coke oven emissions 29 CFR §1910.1029
l,2-dibromo-3-chloropropane 29 CFR §1910.1044
Acrylonitrile 29 CFR §1910.1045
Ethylene oxide 29 CFR §1910.1047
Formaldehyde 29 CFR §1910.1048
29 CFR §1910.1200: HAZARD COMMUNICATION
The employer will establish a hazard communication program to ensure that hazards associated with
chemical usage are communicated to employees. The hazard communication program does not apply to
hazardous wastes. There are training, labeling, and material safety data sheet (MSDS) requirements for
known chemicals. Employers are required to develop a written hazard communication program that will
include:
• List of known chemicals on-site;
• Methods for informing employees of chemical hazards associated with non-routine tasks;
• Methods for informing both employees and subcontractors about chemical hazards (e.g.,
chemical hazard training, distribution of MSDSs).
29 CFR §1926.56: ILLUMINATION
General work areas shall have a minimum illumination intensity of 5 foot-candles. Other
specifications for minimum illumination intensities for different work areas and operations are provided in
this regulation.
29 CFR §1926.57: VENTILATION
Whenever dust, fumes, mists, vapors, or gases exist or are produced in the course of construction
work, their concentrations must not exceed limits specified in 29 CFR §1926.55(a). When ventilation is
used, the system must be installed and operated according to the requirements of this section.
29 CFR §1926.59: HAZARD COMMUNICATION
29 CFR §1926.151 (a)(3): FIRE PREVENTION
Electrical equipment and wiring for light, heat, or other power purposes must be installed in
accordance with the National Electrical Code requirements, NFPA 70-1971; and ANSI CI-197. Also,
smoking is prohibited at or in the vicinity of operations which constitute a fire hazard. "No Smoking" or
"Open Flame" signs must be posted. In general, smoking should be limited to a designated area within the
"support zone" at a hazardous waste site. This will minimize the fire hazard, as well as the transfer of
contaminants to smokers' mouths.
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29 CFR §1926.152: FLAMMABLE AND COMBUSTIBLE LIQUIDS
Information on appropriate containers and appropriate storage for flammable and combustible
liquids is contained in this reference. Note that no more than 25 gallons of liquid may be stored indoors
unless located within an approved storage cabinet.
29 CFR §1926.200: ACCIDENT PREVENTION SIGNS AND TAGS
This regulation contains specific information on color, size, shape, and placement of danger, caution,
exit, safety instruction, directional, accident prevention, and traffic signs.
29 CFR §1926.301: HAND TOOLS
Special attention should be paid to the use of safe hand tools. For example, wooden tool handles
must be kept free of splinters or cracks, and impact tools, such as wedges and chisels, musl be kept free of
mushroomed heads. Also, wrenches must not be used when jaws are sprung to the point that slippage
occurs.
29 CFR §1926.651: SPECIFIC EXCAVATION REQUIREMENTS
Specific information on locating underground utilities; using support systems; securing sides, slopes,
and faces; using seals, benches, rock bolts, and wire meshes; taking precautions for work adjacent to
previously backfilled areas; diverting water flows from excavated areas; using explosives appropriately;
using dust control techniques; and using ladders and ramps is provided in this regulation.
29 CFR §1926.652: TRENCHING REQUIREMENTS
Shoring is needed when the sides of a trench are more than 5 feet deep and unsuitable ground or
soft material is present. Also, sides of trenches in hard or compact soil must be shored when the trench is
more than 5 feet deep and 8 feet long.
29 CFR Part 1926: Safety and Health Regulations for Construction
29 CFR Part 1926 is divided into twenty-four specific areas addressing safety and health standards for
the construction industry, some of which arc described in more detail above:
Subpart A General Subpart M
Subpart B General Interpretations
Subpart C General Safety and Health Suhpari N
Provisions
Subpart D Occupational Health and Subparl O
Environmental Controls
Subpart E Personal Protective and Lile Suhpart P
Saving Equipment Subparl Q
Subpart F Fire Protection and Prevention Subparl R
Subpart G Signs, Signals, and Barricades Subpart S
Subpart H Materials Handling, Storage, Use, and Suhpari T
Disposal Suhpart U
Subpart I Tools - Hand and Power Subparl V
Subpart J Welding and Cutting Subpart W
Subpart K Electrical
Subpart L Ladders and Scaffolding Subpart X
Floors and Wall Openings, and
Stairways
Cranes, Derricks, Hoists, Elevators,
and Conveyors
Molor Vehicles, Mcchani/ed
Equipment, and Marine Operations
Excavations
Concrele and Masonry Construction
Steel Erection
Underground Construction
Demolition
Blasting and Use of Explosives
Power Transmission and Distribution
Rollover Protect ve Structures;
Overhead Protection
Effective Dales
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APPENDIX C
INCIDENT SAFETY CHECK OFF LIST
The Incident Safety Check Off List, when completed correctly, fulfills the
requirements for performing Preliminary Evaluations under 29 CFR §1910.120. The
checklist is divided into two sections.
Section I, which includes the basic preliminary evaluation criteria, must be
completed prior to leaving the office for field activities. If the answers provided are
not applicable to your particular site, you may write in the appropriate information
and any necessary explanations. Section I must be reviewed and signed by a first line
supervisor or a health and safety officer before field operations may begin.
Upon returning from the response action, fill out Section II to reflect what actually
happened at the site. Section II must also be dated and reviewed by an appropriate
supervisor or officer.
Adapted from the OSWER Integrated Health and Safety Standard Operating Practice for Field Activities (U.S. EPA, January
1992. Publication 9285.3-02).
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INCIDENT SAFETY CHECK OFF LIST
I. BEFORE FIELD ACTIVITY
Employee
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Incident: Site Citv
Activity Description: Site Evaluation Containment
Samplina - Air Water Drum Soil
Type of Response: Spill Fire Site
Site Topography: Moutains Rivers
Suburban Level
Incident Safety Plan: Reaion
ERT
Facility
Site Accessibility: Road: Good
Fair
Poor
Suspected chemical(s) and pathway with source(s) involved:
(B) (C)
Emergency Response Teams Present for First Aid, etc. Yes
Protective Level(s) Selected: (A) (B)
(a) If Level "C" - 1 , Identify Canister
(b) If Level "D", JUSTIFY:
SCBA Identify Buddy System: Office/Name
Last Response: (a) Level Used: (A) (B)
(b) Medical Attention/Exam Performed: Yes
State
Well Drillina
Residential
Train
Vallev
Slopes
Reviewed
Briefed
Not Developed
Air: Good
Fair
Poor
(A)
(D)
(0
(C)
Facility Inspection
Other
Other
Rural
Unknown
No
(D)
(D)
No
II. AFTER RESPONSE
1. Protective Level Used: (A) (B) (C) (D)
(a) If Level "C", Identify Canister
(b) If Level "D", JUSTIFY:
(c) Level B or C skin protection: Tyvek Tyvek/Saran Acid/Rain Other
2. List possible chemical exposure: Same as above: (A)
(B) (C) (D)
3. Equipment Decontamination: (a) clothing (b) respirator (c) monitoring
Disposed:
Cleaned:
No Action:
4. Approximate time in exclusion area: hours per day for days
5. Was medical attention/exam required for this response: Yes No
Part I: DATE PREPARED: Reviewed by: Date:
Part II: DATE PREPARED: Reviewed by: Date:
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APPENDIX D
CHARACTERISTICS OF THE PHOTOIONIZATION DETECTOR
(PID) AND THE FLAME IONIZATION DETECTOR (FID)
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CHARACTERISTICS OF THE PHOTOIONIZATION DETECTOR
(PID) AND THE FLAME IONIZATION DETECTOR (FID)
I. INTRODUCTION
The HNU® Photoionizer* and the Foxboro® Organic Vapor Analyzer* (OVA) are two of the most widely used
hand-held real-time instruments used in the field to detect a variety of compounds in air. The two instruments differ
in their modes of operation and in the number and types of compounds they detect (Table D-l). Both instruments
can be used to detect leaks of volatile substances from drums and tanks, determine the presence of volatile compounds
in soil and water, make ambient air surveys, and collect continuous air monitoring data. If personnel arc thoroughly
trained to operate the instruments and to interpret the data, these instruments can be valuable tools for helping to
decide the levels of protection to be worn, assist in determining other safety procedures, and determine subsequent
monitoring or sampling locations.
II. ORGANIC VAPOR ANALYZER (OVA)
The OVA operates in two different modes. In the survey mode, it can determine approximate tolal
concentration of all detectable species in air. With the gas chromatograph (GC) option, individual components can
be detected and measured independently, with some detection limits as low as a few parts per million (ppm).
In the GC mode, a small sample of ambient air is injected into a chromatographic column and carried through
the column by a stream of hydrogen gas. Contaminants with different chemical structures are retained on the column
for different lengths of time (known as retention times) and hence are detected separately by the Maine ioni/aiion
detector. A strip chart recorder can be used to record the retention times, which are then compared to the retention
times of a standard with known chemical constituents. The sample can either be injected into the column from the
air sampling hose or injected directly with a gas-tight syringe.
In the survey mode, the OVA is internally calibrated to methane by the manufacturer. When the instrument
is adjusted to manufacturer's instructions it indicates the true concentration of methane in air. In response to all other
detectable compounds, however, the instrument reading may be higher or lower than the true concentration. Relative
response ratios for substances other than methane are available.
To correctly interpret the readout, it is necessary to either make calibration charts relating the instrument
readings to the true concentration or to adjust the instrument so that it reads correctly. This is done by turning the
ten-turn gas-select knob, which adjusts the response of the instrument. The knob is normally set at 3.00 when
calibrated to methane. Calibration to another gas is done by measuring a known concentration of a gas and adjusting
the gas select knob until the instrument reading equals that concentration.
The OVA has an inherent limitation in that it can detect only organic molecules. Also, it should not be used
at temperatures lower than about 40 degrees Fahrenheit because gases condense in the pump and column. It has no
column temperature control, (although temperature control kits are available) and since retention times vary with
ambient temperatures for a given column, determinations of contaminants are difficult. Despite these limitations, the
GC mode can often provide tentative information on the identity of contaminants in air without relying on costly, time-
consuming laboratory analysis.
III. HNU
The HNU portable photoionizer detects the concentration of organic gases as well as a few inorganic gases.
The basis for detection is the ionization of gaseous species. Every molecule has a characteristic ionization potential
Note: The use of any trade names does not imply their endorsement by the U.S. Environmental Protection Agency.
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TABLE D-1
COMPARISON OF THE OVA AND HNU
Action
Response
Application
Detector
Limitations
Calibration gas
Ease of operation
Detection limits
Response time
Maintenance
Useful range
Service life
OVA
Responds to many organic gases and
vapors
In survey mode, measures total
concentration of detectable gases and
vapors. In GC mode, identifies and
measures specific compounds.
Flame ionization detector (FID)
Does not respond to inorganic gases
and vapors. Kit available for
temperature control.
Methane
Requires experience to interpret
correctly, especially in GC mode.
0.1 ppm (methane)
Two - three seconds (survey mode) for
CH4
Periodically clean and inspect particle
filters, valve rings, and burner chamber.
Check calibration and pumping system
for leaks. Recharge batteries and refill
hydrogen cylinder after each use.
0-1000 ppm
Eight hours; 3 hours with strip chart
recorder.
HNU
Responds to many organics and
some inorganic gases and
vapors.
In survey mode, measures total
concentration of detectable
gases and vapors.
Photoionization detectors (PID)
Does not respond to methane.
Does not detect a compound if
probe has a lower energy than
compound's ionization potential.
Isobutylene
Fairly easy to use and interpret.
0.1 ppm (benzene)
Three seconds for 90% of total
concentration of benzene.
Clean UV lamp frequently.
Check calibration regularly.
Recharge batteries after each
use.
0-2000 ppm
Ten hours; 5 hours with strip
chart recorder.
(I.P.) which is the energy required to remove an electron from the molecule, yielding a positively charged ion and the
free electron. The incoming gas molecules are subjected to ultraviolet (UV) radiation, which is energetic enough to
ionize many gaseous compounds. Each molecule is transformed into charged ion pairs, creating a current between two
electrodes.
Three probes, each containing a different UV light source, are available for use with the HNU. Ionizing
energies of the probe are 9.5, 10.2, and 11.7 electron volts (eV). All three detect many aromatic and large molecule
hydrocarbons. The 10.2 eV and 11.7 eV probes, in addition, detect some smaller organic molecules and some
halogenated hydrocarbons. The 10.2 eV probe is the most useful for environmental response work, as the lamp's
service life is longer than the 11.7 eV probe and it detects more compounds than the 9.5 eV probe.
Note: The use of any trade names does not imply their endorsement by the U.S. Environmental Protection Agency.
161
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The HNU factory calibration gas is benzene. The span potentiometer (calibration) knob is turned to 9.8 for
benzene calibration. A knob setting of zero increases the response to benzene approximately tenfold. As with the
OVA, the instrument's response can be adjusted to give more accurate readings for specific gases and eliminate the
necessity for calibration charts.
While the primary use of the HNU is as a quantitative instrument, it can also be used to detect certain
contaminants, or at least to narrow the range of possibilities. Noting instrument response to a contaminant source
with different probes can eliminate some contaminants from consideration. For instance, a compound's ionization
potential may be such that the 9.5 eV probe produces no response, but the 10.2 eV and 11.7 eV probes do elicit a
response. The HNU does not detect methane or most inorganic compounds.
The HNU is easier to use than the OVA. Its lower detection limit is also in the low ppm range. The response
time is rapid; the meter needle reaches 90% of the indicated concentration in 3 seconds for benzene. It can be zeroed
in a contaminated atmosphere.
IV. GENERAL CONSIDERATIONS
Both of these instruments can monitor only certain vapors and gases in air. Many nonvolatile liquids, toxic
solids, particulates, and other toxic gases and vapors cannot be detected. Because the types of compounds that the
HNU and OVA can potentially detect are only a fraction of the chemicals possibly present at an incident, a zero
reading on either instrument does not necessarily signify the absence of air contaminants.
The instruments are non-specific, and their response to different compounds is relative to the calibration
setting. Instrument readings may be higher or lower than the true concentration. This can be an especially serious
problem when monitoring for total contaminant concentrations if several different compounds are being detected at
once. In addition, the response of these instruments is not linear over the entire detection range. Care must therefore
be taken when interpreting the data. All identifications should be reported as tentative until they can be confirmed
by more precise analysis. Concentrations should be reported in terms of the calibration gas and span potentiometer
or gas-select-knob setting.
Since the OVA and HNU are small, portable instruments, they cannot be expected to yield results as accurate
as laboratory instruments. They were originally designed for specific industrial applications. They are relatively easy
to use and interpret when detecting total concentrations of individually known contaminants in air, but interpretation
becomes extremely difficult when trying to quantify the components of a mixture. Neither instrument can be used as
an indicator for combustible gases or oxygen deficiency.
The OVA (Model 128) is certified by Factory Mutual to be used in Class I, Division 1, Groups A,B,C, and
D environments. As HNU now markets three models, it should be noted that the basic HNU (PI 101) is certified by
SIRA Class I, Division 2, Groups A, B, C, and D. However, a model certified for Class I, Division I, Groups A, B,
C, and D is available.
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APPENDIX E
SAMPLE DECONTAMINATION LAYOUTS AND PROCEDURES
FOR LEVELS OF PROTECTION A THROUGH C
The objective of these procedures is to minimize the risk of exposure to
hazardous substances in the field. Protective equipment must be worn by
personnel when response activities involve known or suspected hazardous
substances. The procedures for decontaminating personnel upon leaving the
contaminated area are discussed for personal protective equipment levels A
through C. The procedures given are for the maximum and minimum amount of
decontamination used for each level of protection.
The maximum decontamination procedures for all levels of protection consist of
specific activities at 19 stations. Each station emphasizes an important aspect of
decontamination. When establishing a decontamination line, each aspect should
be incorporated separately or combined with other aspects into a procedure with
fewer steps (such as the minimum decontamination procedures).
Decontamination lines are site-specific and vary depending on the types of
contamination and work activities conducted on-site. When the decontamination
line is no longer required, contamination wash and rinse solutions and
contaminated articles must be contained and disposed of as hazardous wastes in
compliance with State and Federal regulations.
-------
EQUIPMENT NEEDED TO PERFORM MAXIMUM DECONTAMINATION
MEASURES FOR LEVELS A, B, AND C
Station 1: a. Various Size Containers
b. Plastic Liners
c. Plastic Drop Cloths
Station 2: a: Containers (20-30 Gallons)
b. Decon Solution or Detergent
Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 3: a. Containers (20-30 Gallons
OR
b. Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 4: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 5: a. Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
Station 6: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 7: a. Containers (20-30 Gallons)
b. Decon Solution or Detergent
Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 8: a. Containers (20-30 Gallons)
OR
b. Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 9: a. Air Tanks or Face Masks and
Cartridge Depending on Level
b. Tape
c. Boot Covers
d. Gloves
Station 10: a: Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
d. Boot Jack
Station 11: a. Rack
b. Drop Cloths
c. Bench or Stools
Station 12: a. Table
Station 13: a. Basin or Bucket
b. Decon Solution
c. Small Table
Station 14: a. Water
b. Basin on Bucket
c. Small Table
Station 15: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 16: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 17: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 18: a. Water
b. Soap
c. Small Table
d. Basin or Bucket
e. Field Showers
f. Towels
Station 19: a. Dressing Trailer is Needed in
Inclement Weather
b. Tables
c. Chairs
d. Lockers
e. Cloths
164
-------
EQUIPMENT NEEDED TO PERFORM MINIMUM DECONTAMINATION
MEASURES FOR LEVELS A, B, AND C
Station 1: a. Various Size Containers
b. Plastic Liners
c. Plastic Drop Cloths
Station 2: a. Containers (20-30 Gallons)
b. Decon Solution
c. Rinse Water
d. 2-3 Long-Handled, Soft-
Bristled Scrub Brushes
Station 3: a. Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
Station 4: a. Air Tanks or Masks and
Cartridges Depending Upon
Level
b. Tape
c. Boot Covers
d. Gloves
Station 5: a. Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
Station 6: a. Plastic Sheets
b. Basin or Bucket
c. Soap and Towels
d. Bench or Stools
Station 7: a. Water
b. Soap
c. Tables
d. Wash Basin or Bucket
165
-------
MAXIMUM MEASURES FOR LEVEL A DECONTAMINATION
Station 1: Segregated
Equipment Drop
Station 2: Boot Cover and Glove
Wash
Station 3: Boot Cover and Glove
Rinse
Station 4: Tape Removal
Station 5: Boot Cover Removal
Station 6: Outer Glove Removal
Station 7: Suit and Boot Wash
Station 8: Suit and Boot
Station 9: Tank Change
Station 10: Safety Boot Removal
Station 11: Fully Encapsulating
Suit and Hard Hat
Removal
Station 12: SCBA Backpack
Removal
Station 13: Inner Glove Wash
Station 14: Inner Glove Rinse
Station 15: Face Piece Removal
Station 16: Inner Glove Removal
Station 17: Inner Clothing
Removal
Station 18: Field Wash
Station 19: Redress
Deposit equipment used on-site (tools, sampling devices and containers,
monitoring instruments, radios, clipboards, etc.) on plastic drop cloths or in
different containers with plastic liners. During hot weather operations, a cool-
down station may be set up within this area.
Scrub outer boot covers and gloves with decon solution or detergent/water.
Rinse off decon solution from station 2 using copious amounts of water.
Remove tape around boots and gloves and deposit in container with plastic
liner.
Remove boot covers and deposit in container with plastic liner.
Remove outer gloves and deposit in container with plastic liner.
Wash encapsulating suit and boots using scrub brush and decon solution or
detergent/water. Repeat as many times as necessary.
Rinse off decon solution using water. Repeat as many times as necessary.
If an air tank change is desired, this is the last step in the decontamination
procedure. Air tank is exchanged, new outer gloves and boot covers are
donned, and joints are taped. Worker returns to duty.
Remove safety boots and deposit in container with plastic liner.
Fully encapsulated suit is removed with assistance of a helper and is laid out
on a drop cloth or hung up. Hard hat is removed. Hot weather rest station
may be set up within this area for personnel returning to site.
While still wearing facepiece, remove backpack and place on table.
Disconnect hose from regulator valve and proceed to next station.
Wash with decon solution that will not harm the skin. Repeat as often as
necessary.
Rinse with water. Repeat as many times as necessary.
Remove face piece. Deposit in container with plastic liner. Avoid touching
face with fingers.
Remove inner gloves and deposit in container with liner.
Remove clothing and place in lined container. Do not wear inner clothing off-
site since there is a possibility that small amounts of contaminants might have
been transferred in removing the fully-encapsulating suit.
Shower if highly toxic, skin-corrosive or skin-absorbable materials are known
or suspected to be present. Wash hands and face if shower is not available
Put on clean clothes.
166
-------
MAXIMUM DECONTAMINATION LAYOUT FOR LEVEL A PROTECTION
EXCLUSION
ZONE
Tape
Outer Glove /T\< /T\* — /
Removal \ /^ \ /^ \
i
Boot Cover
Removal
r
Segregated
Removal Boot Cover & EqU'P/"ent
Glove Wash Drop
TV/TVYT^S^ rr^
/^\ /^\ /* \ /
Boot Cover &
Glove Rinse
/ 7 \ Suit/Safety
S
Tank Change 1 J
and Redress -- / Q \^ /i
Boot
Outer
Cover/ \ /"* "*t \
Gloves
/ Boot Wash
~\ Suit/Safety
__/ Boot Rinse
L
/ 10 \ Safety Boot
v_
_/ Removal
11
Fully Encapsulating Suit
and Hard Hat Removal
12 \ SCBA Backpack
Removal
CONTAMINATION
REDUCTION
ZONE
13
Inner Glove
Wash
14
Inner Glove
Rinse
15
Face Piece
Removal
16
Inner Glove
Removal
Inner Clothing
Removal
Field
Wash
18
167
Redress
CONTAMINATION
CONTROL LINE
SUPPORT ZONE
-------
MINIMUM MEASURES FOR LEVEL A DECONTAMINATION
Station 1:
Equipment Drop
Station 2:
Station 3:
Station 4:
Station 5:
Station 6:
Station 7:
Outer Garment, Boots,
and Gloves Wash and
Rinse
Outer Boot and Glove
Removal
Tank Change
Boot, Gloves, and
Outer Garment
Removal
SCBA Removal
Field Wash
Deposit equipment used on-site (tools, sampling devices and containers,
monitoring instruments, radios, clipboards, etc.) on plastic drop cloths.
Segregation at the drop reduces the probability of cross contamination.
During hot weather operations, cool-down stations may be set up within this
area.
Scrub outer boots, outer gloves and fully-encapsulating suit with decon
solution or detergent and water. Rinse off using copious amounts of water.
Remove outer boots and gloves. Deposit in container with plastic liner.
If worker leaves Exclusion Zone to change air tank, this is the last step in the
decontamination procedure. Worker's air tank is exchanged, new outer gloves
and boot covers are donned, joints are taped, and worker returns to duty.
Boots, fully-encapsulating suit, and inner gloves are removed and deposited in
separate containers lined with plastic.
SCBA backpack and facepieces are removed (avoid touching face with
fingers). SCBA is deposited on plastic sheets.
Hands and face are thoroughly washed. Shower as soon as possible.
168
-------
MINIMUM DECONTAMINATION LAYOUT FOR LEVELS A & B PROTECTION
EXCLUSION }••
ZONE
Equipment
Drop
I
Decon Outer
Garments
Remove
Boot Covers
& Outer Gloves
Tank Change-
Over Point
MT'lifWIII
Remove Boots,
Gloves and Outer
Garments (for
disposal and
off-site
decontamination)
CONTAMINATION
REDUCTION
ZONE
Remove SCBA
i:
i:
A A A A A A A AM. AAAAAAAA
AAAAAAAA V AAAAAAAAAA
A A A A A A A ^BA AAAAAAAA
A AAAAAAAB.AAAAA^ A A A A
\SUPPORT ZONE
t* * * AAAAAAAAAAAAAAAAAAAA A AA A
*.*.*. .. ,*.A. . . * . . .A. _*AAAAAAAAA,AAAAAAAAA A AA
• HOTLINE
Redress:
Boot Covers
and Outer
Gloves
2(A /20'
Wind
Direction
i
i
A A —
^ J
169
-------
MAXIMUM MEASURES FOR LEVEL B DECONTAMINATION
Station 1: Segregated
Equipment Drop
Station 2: Boot Cover and Glove
Wash
Station 3: Boot Cover and Glove
Rinse
Station 4: Tape Removal
Station 5: Boot Cover Removal
Station 6: Outer Glove Removal
Station 7: Suit and Safety Boot
Wash
Station 8: Suit, SCBA, Boot, and
Glove Rinse
Station 9: Tank Change
Station 10: Safety Boot Removal
Station 11: SCBA Backpack
Removal
Station 12: Splash Suit Removal
Station 13: Inner Glove Wash
Station 14: Inner Glove Rinse
Station 15: Face Piece Removal
Station 16: Inner Glove Removal
Station 17: Inner Clothing
Removal
Station 18: Field Wash
Station 19: Redress
Deposit equipment used on-site (tools, sampling devices and containers,
monitoring instruments, radios, clipboards, etc.) on plastic drop cloths or in
different containers with plastic liners. Segregation at the drop reduces the
probability of cross-contamination. During hot weather operations, cool-down
stations may be set up within this area.
Scrub outer boot covers and gloves with decon solution or detergent and
water.
Rinse off decon solution from Station 2 using copious amounts of water.
Remove tape around boots and gloves and deposit in container with plastic
liner.
Remove boot covers and deposit in container with plastic liner.
Remove outer gloves and deposit in container with plastic liner.
Wash chemical-resistant splash suit, SCBA, gloves, and safety boots. Scrub
with long-handle scrub brush and decon solution. Wrap SCBA regulator (if
belt mounted type) with plastic to keep out water. Wash backpack assembly
with sponges or cloths.
Rinse off decon solution using copious amounts of water
If worker leaves exclusion zone to change air tank, this is the last step in the
decontamination procedure. Worker's air tank is exchanged, new outer gloves
and boot covers are donned, joints are taped, and worker returns to duty.
Remove safety boots and deposit in container with plastic liner
While still wearing facepiece, remove backpack and place on table.
Disconnect hose from regulator valve.
With assistance of helper, remove splash suit. Deposit in container with plastic
liner.
Wash inner gloves with decon solution.
Rinse inner gloves with water.
Remove face piece. Deposit in container with plastic liner. Avoid touching
face with fingers
Remove inner gloves and deposit in container with liner.
Remove inner clothing. Place in container with liner. Do not wear inner
clothing off-site since there is a possibility that small amounts of contaminants
may have been transferred in removing the fully-encapsulating suit
Shower if highly toxic, skin-corrosive or skin-absorbable materials are known
or suspected to be present. Wash hands and face if shower is not available.
Put on clean clothes.
170
-------
MAXIMUM DECONTAMINATION LAYOUT FOR LEVEL B PROTECTION
EXCLUSION
ZONE
Tape Removal
Boot Cover &
Glove Wash
Segregated
Equipment
Drop
Outer Glove
Removal
Tank Change
and Redress -
Boot Cover/
Outer Gloves
CONTAMINATION
REDUCTION
ZONE
Boot Cover
Removal
Boot Cover &
Glove Rinse
Suit/Safety
Boot Wash
Sult/SCBA/Boot
/Glove Rinse
Safety Boot
Removal
SCBA Backpack
Removal
Splash Suit
Removal
Inner Glove
Wash
Inner Glove
Rinse
race Piece
Removal
Inner Glove
Removal
Inner Clothing
Removal
Field
Wash
Redress
CONTAMINATION
CONTROL LINE
SUPPORT ZONE
171
-------
MINIMUM MEASURES FOR LEVEL B DECONTAMINATION
Station 1:
Equipment Drop
Station 2:
Station 3:
Station 4:
Station 5:
Station 6:
Station 7:
Outer Garment, Boots,
and Gloves Wash and
Rinse
Outer Boot and Glove
Removal
Tank Change
Boot, Gloves, and
Outer Garment
Removal
SCBA Removal
Field Wash
Deposit equipment used on-site (tools, sampling devices and containers,
monitoring instruments, radios, clipboards, etc.) on plastic drop cloths.
Segregation at the drop reduces the probability of cross contamination.
During hot weather operations, cool-down station may be set up within this
area.
Scrub outer boots, outer gloves, and chemical-resistant splash suit with decon
solution or detergent water. Rinse off using copious amounts of water.
Remove outer boots and gloves. Deposit in container with plastic liner.
If worker leaves exclusion zone to change air tank, this is the last step in the
decontamination procedure. Worker's air tank is exchanged, new outer gloves
and boot covers are donned, joints are taped, and worker returns to duty.
Boots, chemical-resistant splash suit, and inner gloves are removed and
deposited in separate containers lined with plastic.
SCBA backpack and facepiece are removed. Avoid touching face with finger.
SCBA is deposited on plastic sheets.
Hands and face are thoroughly washed. Shower as soon as possible.
172
-------
MINIMUM DECONTAMINATION LAYOUT FOR LEVELS A & B PROTECTION
t EXCLUSION \^^^^^^
[^ ZONE J»»»»»J "[:-X
V>"^/.V/AVAV/.V.V.V.V.V".V.V.V.V. tquipment
://Av.v.v.v.v.v.v.v.v.-.^A*^.™i*? Drop
.v.v.v.v Plastic :.\^/////AV/AV"— |v/// .-.v.v.-.v
Sheet vjvvCvXv:-"
10
Gallon A^
Can V
^ •
^^^m^m
Decon Outer ./
Garments ^r
.S Remov
s^ Boot Cover.
s' & Outer Glove!
Tank Chanae- /*v*\
Over Point \O/
(COA
R
1\^
\:««*
\<««
\<««
L-i--i
(X
32 Gallon
Can
LAMINATION
EDUCTION
ZONE
y
"
• Remove Boots,
Gloves and Outer
Garments (for
disposal and
off-site
decontamination)
|
Remove SCBA
WmjsurPonT ZONE
BIII«1
s
J .
_ umt IMC
F" nL//L//VC
„_ Redress:
j— ,^ I . Boot {
/H\ Decon and
N^/ Solution Gic
Sv 1
^ Water
^r ^______
J-»:-»»»»»:i
Covers
Outer
ives
\t/
20°>i /20'
/\
Wind
Direction
1
1
1
173
-------
MAXIMUM MEASURES FOR LEVEL C DECONTAMINATION
Station 1:
Station 2:
Station 3:
Station 4:
Station 5:
Station 6:
Station 7:
Station 8:
Station 9:
Station 10:
Station 11:
Station 12:
Station 13:
Station 14:
Station 15:
Station 16:
Station 17:
Station 18:
Segregated
Equipment Drop
Boot Cover and Glove
Wash
Boot Cover and Glove
Rinse
Tape Removal
Boot Cover Removal
Outer Glove Removal
Suit and Boot Wash
Suit, Boot, and Glove
Rinse
Canister or Mask
Change
Safety Boot Removal
Splash Suit Removal
Inner Glove Removal
Inner Glove Wash
Face Piece Removal
Inner Glove Removal
Inner Clothing
Removal
Field Wash
Redress
Deposit equipment used on-site (tools, sampling devices and containers,
monitoring instruments, radios, clipboards, etc.) on plastic drop cloths or in
different containers with plastic liners. Segregation at the drop reduces the
probability of cross contamination. During hot weather operations, a cool-
down station may be set up within this area.
Scrub outer boot covers and gloves with decon solution or detergent and
water.
Rinse off decon solution from Station 2 using copious amounts of water.
Remove tape around boots and gloves and deposit in container with plastic
liner.
Remove boot covers and deposit in containers with plastic liner.
Remove outer gloves and deposit in container with plastic liner.
Wash splash suit, gloves, and safety boots. Scrub with long-handle scrub
brush and decon solution.
Rinse off decon solution using water. Repeat as many times as necessary.
If worker leaves exclusion zone to change canister (or mask), this is the last
step in the decontamination procedure. Worker's canister is exchanged, new
outer gloves and boot covers are donned, and joints are taped. Worker
returns to duty.
Remove safety boots and deposit in container with plastic liner.
With assistance of helper, remove splash suit. Deposit in container with plastic
liner.
Wash inner gloves with decon solution.
Rinse inner gloves with water.
Remove face piece. Deposit in container with plastic liner. Avoid touching
face with fingers.
Remove inner gloves and deposit in lined container.
Remove clothing soaked with perspiration and place in lined container. Do not
wear inner clothing off-site since there is a probability that small amounts of
contaminants might have been transferred in removing the fully-encapsulating
suit.
Shower if highly toxic, skin-corrosive, or skin-absorbable materials are known
or suspected to be present. Wash hands and face if shower is not available
Put on clean clothes.
174
-------
MAXIMUM DECONTAMINATION LAYOUT FOR LEVEL C PROTECTION
EXCLUSION
ZONE Tape
Outer Glove / & \^ / g \^ /
Removal \ A* V_/*\
\
(•)
Boot Cover
Removal
r
r~\ Suit/Safety
\ / Boot Wash
k Change 1 _ * _
Segregated
Removal Boot Cover I *uf™"'
Glove Wash orop
TS- (T^s^ r^\* r^\
_Lr\Lf^\L/* \__/
Boot Cover &
Glove Rinse
and Redress -
Boot Cover/
Outer Gloves
8 \ Sult/SCBA/Boot
/Glove Rinse
Safety Boot
Removal
11
Splash Suit
Removal
CONTAMINATION
REDUCTION
ZONE
12 \ Inner Glove
Wash
13
Inner Glove
Rinse
14
Face Place
Removal
15
Inner Glove
Removal
Inner Clothing
Removal
Field
Wash
17
-W 18 ) Redress
CONTAMINATION
' CONTROL LINE
SUPPORT ZONE
175
-------
MINIMUM MEASURES FOR LEVEL C DECONTAMINATION
Station 1:
Equipment Drop
Station 2:
Station 3:
Station 4:
Station 5:
Station 6:
Station 7:
Outer Garment, Boots,
and Gloves Wash and
Rinse
Outer Boot and Glove
Removal
Canister or Mask
Change
Boot, Gloves and
Outer Garment
Removal
Face Piece Removal
Field Wash
Deposit equipment used on-site (tools, sampling devices and containers,
monitoring instruments, radios, clipboards, etc.) on plastic drop cloths.
Segregation at the drop reduces the probability of cross contamination.
During hot weather operations, a cool-down station may be set up within this
area.
Scrub outer boots, outer gloves, and splash suit with decon solution or
detergent water. Rinse off using copious amounts of water.
Remove outer boots and gloves. Deposit in container with plastic liner.
If worker leaves exclusive zone to change canister (or mask), this is the last
step in the decontamination procedure. Worker's canister is exchanged, new
outer gloves and boot covers are donned, joints are taped, and worker returns
to duty.
Boots, chemical-resistant splash suit, and inner gloves are removed and
deposited in separate containers lined with plastic.
Facepiece is removed. Avoid touching face with fingers. Facepiece is
deposited on plastic sheet.
Hands and face are thoroughly washed. Shower as soon as possible.
176
-------
MINIMUM DECONTAMINATION LAYOUT FOR LEVEL C PROTECTION
EXCLUSION
ZONE
Equipment
Drop
Decon Outer
Garments
Remove
Boot Covers
& Outer Gloves
Cartridge or
Canister Change-
Over Point
HOTLINE
Remove Boots,
Gloves and Outer
Garments (for
disposal and
off-site
decontamination)
CONTAMINATION
REDUCTION
ZONE
I
Remove Mask
I
-1 SUPPORT ZONE I
Wind
Direction
177
-------
APPENDIX F
REGIONAL CONTACTS
This Appendix provides the addresses and telephone numbers
of Headquarters and Regional contacts at both EPA and OSHA.
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
U.S. EPA/Environmental Response Team
2890 Woodbridge Avenue
Building 18, MS 101
Edison, NJ 08837-3679
(908) 321-6740
24 Hour Hotline: (908) 321-6660
EPA REGIONAL OFFICES
EPA Region 1
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3715
EPA Region 2
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, NY 10278
(212) 264-2657
EPA Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800
EPA Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
EPA Region 5
Metcalfe Federal Building
77 W. Jackson Boulevard
Chicago, IL 60604
(312) 353-2000
EPA Region 6
1445 Ross Avenue,
9th Floor
Dallas, TX 75202
(214) 655-6444
EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66115
(913) 551-7000
EPA Region 8
999 18th Street
Suite 500
Denver, CO 80202-2405
(303) 293-1603
EPA Region 9
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305
EPA Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-1200
Note: Commercial and FTS telephone numbers are now identical with the institution of the new FTS
system.
180
-------
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
Occupational Safety and Health Administration
Department of Labor
200 Constitution Avenue NW
Room N-3647
Washington, DC 20210
(202) 523-8151
OSHA Notification Service (Complaint Hotline) for Emergency Situations
1-800-321-6742
OSHA REGIONAL OFFICES
OSHA Region 1 • OSHA Region 6
133 Portland Street, 1st Floor 525 Griffin Street, Room 602
Boston, MA 02114 Dallas, TX 75202
(617) 565-7164 (214) 767-4731
OSHA Region 2 • OSHA Region 7
201 Varick Street, Room 670 911 Walnut Street
New York, NY 10014 Kansas City, MO 64106
(212)337-2325 (816)426-5861
OSHA Region 3 • OSHA Region 8
Gateway Building, Suite 2100 1951 Stout Street
3535 Market Street Denver, CO 80204
Philadelphia, PA 19104 (303) 844-3061
(215) 596-1201
OSHA Region 9
OSHA Region 4 71 Stevenson Street
1375 Peachtree Street NE, Suite 587 Suite 415
Atlanta, GA 30367 San Francisco, CA 94105
(404)347-3573 (415)744-6670
OSHA Region 5 • OSHA Region 10
230 South Dearborn Street 1111 Third Avenue
32nd Floor, Room 3244 Suite 715
Chicago, IL 60604 Seattle, WA 98101-3212
(312) 353-2220 (206) 442-5930
Note: Commercial and FTS telephone numbers are now identical with the institution of the new FTS
system.
181
-------
U.S. EPA REGIONAL MAP
9 O
182
* U.S. G.P.O.:1992-311-893:60703
------- |