SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS
(165.8)
3 DAYS
This course is for experienced personnel responsible for developing, implementing or managing
safety programs for hazardous waste clean-up operations, treatment, storage and disposal facilities,
or responding to chemical emergencies. This advanced course compliments EPA basic safety courses
and provides a forum for information and idea exchanges among instructors and participants on
hazardous waste operations and emergency response safety topics. Greater than fifty percent of class
time involves problem solving and class discussion.
The objectives of this course are:
• To discuss the impact of 29 CFR 1910.120 and other related OSHA, EPA,
NIOSH, NFPA, and ANSI standards on personnel at hazardous waste
operations and emergency response.
• To detail the elements and development of a site-specific safety plan which
includes personnel training, medical monitoring, personal protective
equipment selection, air surveillance strategies, and emergency/contingency
planning.
Upon completion of this course, participants will be able to organize essential information into a site-
specific safety plan and better understand the decision-making associated with hazardous waste
operations and emergency response safety programs.
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Emergency and Remedial Response
Environmental Response Team
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FOREWORD
This manual is for reference use of students enrolled in scheduled
training courses of the U.S. Environmental Protection Agency. While
it will be useful to anyone who needs information on the subjects
covered, it will have it's greatest value as an adjunct to classroom
presentations involving give and take discussions among the students
and the instructional staff.
This manual has been developed with a goal of providing the best
available current information. Individual instructors may provide
additional material to cover special aspects of their presentations.
Due to the limited availability of the manual, it should not be cited in
bibliographies or other publications.
References to products and manufacturers are for illustration only:
they do not imply endorsement by the U.S. Environmental Protection
Agency.
Constructive suggestions for the improvement in the coverage, content
and format of the manual are welcome.
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SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS
TABLE OF CONTENTS
SECTION UNIT PAGE NO.
OCCUPATIONAL HEALTH AND SAFETY STANDARDS
Part 1: OSHA 29 CFR 1910.120 - Hazardous Waste Operations
and Emergency Response Standard 1
Part 2: EPA Order 1440.2 - Health and Safety Requirements for
Employees Engaged in Field Activities 37
Part 3: Other OSHA, Federal, and NFPA Regulations and
Standards Related to Hazardous Waste Operations and
Emergency Response Worker Protection 47
Part 4: NIOSH Criteria for Recommended Standard for Working
in Confined Spaces 61
Part 5: OSHA 29 CFR 1910.1200 - Hazard Communication
Standard 139
2 OCCUPATIONAL HEALTH AND SAFETY GUIDANCE DOCUMENTS
Part 1: USEPA Office of Solid Waste and Emergency Response
(OSWER) Integrated Health and Safety Policy for Field
Activities 1
Part 2: USEPA Environmental Response Team (ERT) Occupational
Medical Monitoring Program Guidelines for SARA Hazardous
Waste Field Activity Personnel 33
3 QUICK REFERENCE FACT SHEETS
Part 1: Health and Safety Roles and Responsibilities at Remedial
Sites 1
12/92
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SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS
TABLE OF CONTENTS
SECTION UNIT PAGE NO.
Part 2: Establishing Work Zones at Uncontrolled Hazardous
Waste Sites 9
Part 3: Hazardous Waste Operations and Emergency Response:
RCRA TSD and Emergency Response Without Regard to
Location 23
Part 4: Hazardous Waste Operations and Emergency Response:
Uncontrolled Hazardous Waste Sites and RCRA
Corrective Actions 37
Part 5: Hazardous Waste Operations and Emergency Response:
General Information and Comparison 55
Part 6: Hazardous Waste Operations and Emergency Response:
Available Guidance 67
4 AIR SURVEILLANCE
Part 1: Characteristics and Types of Air Surveillance Equipment 1
Part 2: Manufacturers and Suppliers of Air Monitoring and
Sampling Equipment 37
5 PERSONAL PROTECTIVE EQUIPMENT
Part 1: Introduction to Respiratory Protection 1
Appendix I: NIOSH Certified Equipment List-Example 13
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SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS
TABLE OF CONTENTS
SECTION UNIT PAGE NO.
Part 2: Air Purifying Respirators 15
Appendix I: References for Respirator Cartridges
Efficiency Studies 27
Appendix II: Respirator Fit Testing 29
Appendix III: Respirator Negative and Positive Pressure Test 33
Appendix IV: Care and Cleaning of Respirators 35
Appendix V: Warning Concentrations of Various Chemicals 39
Part 3: Self-Contained Breathing Apparatus 69
Part 4: NIOSH Respirator Decision Logic 81
Part 5: USEPA Respiratory Protection Program Guidelines -145
Part 6: Chemical Protective Clothing 201
Appendix I: Permeation References 225
Appendix II: Donning and Doffing of Fully Encapsulating
Suits (FES) and Self-Contained Breathing
Apparatus (SCBA) 227
Part 7: Personal Protective Equipment Regulations - 29 CFR
1910.132-136 233
Part 8: Manufacturers and Suppliers of Personal Protective
Equipment 241
6 REFERENCES AND GLOSSARY
Part 1: References and Resources 1
Part 2: Glossary and Acronyms 15
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SECTION 1
OCCUPATIONAL SAFETY AND HEALTH
REGULATIONS AND STANDARDS
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OCCUPATIONAL SAFETY AND HEALTH
REGULATIONS AND STANDARDS
SECTION OBJECTIVE
The objective of this section is to provide students with a copy of the following occupational health
and safety standards and guidance documents:
• U.S. Department of Labor/Occupational Safety and Health Administration Hazardous
Waste Operations and Emergency Response Worker Protection Standard 29 CFR
1910.120(1989)
• U.S. Environmental Protection Agency Health and Safety Requirements for
Employees Engaged in Field Activities Order 1440.2 (1981)
• Other OSHA, Federal, and NFPA Regulations and Standards Related to Hazardous
Waste Operations and Emergency Response Worker Protection
• NIOSH Criteria for Recommended Standard for Working in Confined Spaces (1979)
• U.S. Department of Labor/Occupational Safety and Health Administration Hazard
Communication Standard 29 CFR 1910.1200 (1985)
STUDENT PERFORMANCE OBJECTIVES
After completing this section and related lesson(s), the student will be able to:
• Discuss each paragraph and appendixes of OSHA's 29 CFR 1910.120.
• Identify other OSHA, Federal, and NFPA regulations and standards related to
occupational health and safety at hazardous waste operations and emergency response.
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SECTION 1
OCCUPATIONAL SAFETY AND HEALTH
REGULATIONS AND STANDARDS
PART 1
29 CFR 1910.120
HAZARDOUS WASTE OPERATIONS AND
EMERGENCY RESPONSE
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
1910.120-HAZARDOUS WASTE OPERATIONS
AND EMERGENCY RESPONSE
(a) Scope, application, and definitions.
(1) Scope. This section covers the following oper-
ations, unless the employer can demonstrate
that the operation does not involve employee
exposure or the reasonable possibility for
employee exposure to safety or health hazards:
(i) Clean-up operations required by a govern-
mental body, whether Federal, state, local or
other involving hazardous substances that are
conducted at uncontrolled hazardous waste
sites (including, but not limited to, the EPA's
National Priority Site List (NPL), state pri-
ority site lists, sites recommended for the
EPA NPL, and initial investigations of gov-
ernment identified sites which are conducted
before the presence or absence of hazardous
substances has been ascertained);
(ii) Corrective actions involving cleanup oper-
ations at sites covered by the Resource Con-
servation and Recovery Act of 1976 (RCRA)
as amended .(42 U.S.C. 6901 et seq.);
(iii) Voluntary clean-up operations at sites rec-
ognized by Federal, state, local or other gov-
ernmental bodies as uncontrolled hazardous
waste sites;
(iv) Operations involving hazardous wastes
that are conducted at treatment, storage, and
disposal (TSD) facilities regulated by 40 CFR
Parts 264 and 265 pursuant to RCRA; or by
agencies under agreement with U.S.E.P.A. to
implement RCRA regulations; and
(v) Emergency response operations for
releases of, or substantial threats of releases
of, hazardous substances without regard to
the location of the hazard.
(2) Application.
(i) All requirements of Part 1910 and Part
1926 of Title 29 of the Code of Federal Reg-
ulations apply pursuant to their terms to haz-
ardous waste and emergency response
operations whether covered by this section or
not. If there is a conflict or overlap, the provi-
sion more protective of employee safety and
health shall apply without regard to 29 CFR
(ii) Hazardous substance clean-up operations
within the scope of paragraphs (a)(l)(i)
through (a)(l)(iii) of this section must comply
with all paragraphs of this section except
paragraphs (p) and (q).
(iii) Operations within the scope of paragraph
(a)(l)(iv) of this section must comply only with
the requirements of paragraph (p) of this sec-
tion.
Exceptions: For large quantity generators
of hazardous waste who store those wastes
less than 90 days and for small quantity gen-
erators of hazardous wastes, who have
emergency response teams that respond to
releases of, or substantial threats of releases
of, hazardous substances, for their RCRA
workplaces only paragraph (p)(8) of this sec-
tion is applicable. Such generators of haz-
ardous wastes who do not have emergency
response teams that respond to releases of, or
substantial threats of releases of, hazardous
substances are exempt from the requirements
of this section.
(iv) Emergency response operations for
releases of, or substantial threats of releases
of, hazardous substances which are not cov-
ered by paragraphs (a)(l)(i) through (a)(l)(iv)
of this section must only comply with the
requirements of paragraph (q) of this section.
(3) Definitions."Buddy system" means a system
of organizing employees into work groups in
such a manner that each employee of the work
group is designated to be observed by at least
one other employee in the work group. The pur-
pose of the buddy system is to provide rapid
assistance to employees in the event of an
emergency.
"Clean-up operation" means an operation
where hazardous substances are removed, con-
330
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OCCUPATIONAL SAFETY AND HEALTH
1910.120(a)(3)
STANDARDS AND INTERPRETATIONS
tained, incinerated, neutralized, stabilized,
cleared-up, or in any other manner processed or
handled with the ultimate goal of making the
site safer for people or the environment.
"Decontamination" means the removal of haz-
ardous substances from employees and their
equipment to the extent necessary to preclude
the occurrence of foreseeable adverse health
affects.
"Emergency response" or "responding to
emergencies" means a response effort by
employees from outside the immediate release
area or by other designated responders (i.e.,
mutual-aid groups, local fire departments, etc.)
to an occurrence which results or is likely to
result, in an uncontrolled release of a hazardous
substance. Responses to incidental releases of
hazardous substances where the substance can
be absorbed, neutralized, or otherwise con-
trolled at the time of release by employees in
the immediate release area, or by maintenance
personnel are not considered to be emergency
responses within the scope of this standard.
Responses to releases of hazardous substances
where there is no potential safety or health haz-
ard (i.e., fire, explosion, or chemical exposure)
are not considered to be emergency responses.
"Facility" means (A) any building, structure,
installation, equipment, pipe or pipeline (includ-
ing any pipe into a sewer or publicly owned
treatment works), well, pit, pond, lagoon,
impoundment, ditch, storage container, motor
vehicle, rolling stock, or aircraft, or (B) any site
or area where a hazardous substance has been
deposited, stored, disposed of, or placed, or oth-
erwise come to be located; but does not include
any consumer product in consumer use or any
water-borne vessel.
(3) "Hazardous materials response (HAZMAT)
team" means an organized group of employees,
designated by the employer, who are expected
to perform work to handle and control actual or
potential leaks or spills of hazardous substances
requiring possible close approach to the sub-
stance. The team members perform responses to
releases or potential releases of hazardous sub-
stances for the purpose of control or stabilization
of the incident. A HAZMAT team is not a fire
brigade nor is a typical fire brigade a HAZMAT
team. A HAZMAT team, however, may be a
separate component of a fire brigade or fire
department.
"Hazardous substance" means any substance
designated or listed under paragraphs (A)
through (D) of this definition, exposure to which
results or may result in adverse affects on the
health or safety of employees:
(a) Any substance defined under section 101(14)
of CERCLA;
(b) Any biological agent and other disease-
causing agent as defined in section 101(33) of
CERCLA;
(c) Any substance listed by the U.S. Depart-
ment of Transportation as hazardous materials
under 49 CFR 172.101 and appendices; and
(d) Hazardous waste as herein defined.
"Hazardous waste" means
(a) A waste or combination of wastes as defined
in 40 CFR 261.3, or
(b) Those substances defined as hazardous
wastes in 49 CFR 171.8.
"Hazardous waste operation" means any opera-
tion conducted within the scope of this standard.
"Hazardous waste site" or "Site" means any
facility or location within the scope of this stand-
ard at which hazardous waste operations take
place.
"Health hazard" means a chemical, mixture of
chemicals or a pathogen for which there is statis-
tically significant evidence based on at least one
study conducted in accordance with established
scientific principles that acute or chronic health
effects may occur in exposed employees, the term
"health hazard" includes chemicals which are car-
cinogens, toxic or highly toxic agents, reproduc-
tive toxins, irritants, corrosives, sensitizers,
heptaotoxins, nephrotoxins, neurotoxins, agents
which act on the hematopoietic system, and agents
which damage the lungs, skin, eyes, or mucous
membranes. It also includes stress due to tem-
perature extremes. Further definition of the terms
used above can be found in Appendix A to 29 CFR
1910.1200.
"IDLH" or "Immediately dangerous to life or
health" means an atmospheric concentration of any
toxic, corrosive or asphyxiant substance that poses
an immediate threat to life or would cause irrever-
Change 51
330.1
4
1910.120(a)(3)
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1910.120(n)(3)
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
sible or delayed adverse health effects or would
interfere with an individual's ability to escape from
a dangerous atmosphere.
"Oxygen deficiency" means that concentration of
oxygen by volume below which atmosphere sup-
plying respiratory protection must be provided. It
exists in atmospheres where the percentage of
oxygen by volume is less than 19.5 percent oxy-
gen.
"Permissible exposure limit" means the
exposure, inhalation or dermal permissible
exposure limit specified in 29 CFR Part 1910, Sub-
parts G and Z.
"Published exposure level" means the exposure
limits published in "NIOSH Recommendations for
Occupational Health Standards" dated 1986 incor-
porated by reference, or if none is specified, the
exposure limits published in the standards spec-
ified by the American Conference of Governmental
Industrial Hygienists in their publication "Thresh-
old Limit Values and Biological Exposure Indices
for 1987-88" dated 1987 incorporated by reference.
"Post emergency response" means that portion
of an emergency response performed after the
immediate threat of a release has been stabilized
or eliminated and clean-up of the site has begun. If
post emergency response is performed by an
employer's own employees who were part of the
initial emergency response, it is considered to be
part of the initial response and not post emergency
response. However, if a group of an employer's
own employees, separate from the group providing
initial response, performs the clean-up operation,
then the separate group of employees would be
considered to be performing post-emergency
response and subject to paragraph (g)(ll) of this
section.
"Qualified person" means a person with specific
training, knowledge and experience in the area for
which the person has the responsibility and the
authority to control.
"Site safety and health supervisor (or official)"
means the individual located on a hazardous waste
site who is responsible to the employer and has the
authority and knowledge necessary to implement
the site safety and health plan and verify com-
pliance with applicable safety and health require-
ments.
"Small quantity generator" means a guneraLor of
hazardous wastes who in any calendar month gen-
erates no more than 1,000 kilograms (2.205
pounds) of hazardous waste in that month.
"Uncontrolled hazardous waste site" means an
area where an accumulation of hazardous waste
creates a threat to the health and safety of individ-
uals or the environment or both. Some sites are
found on public lands, such as those created by for-
mer municipal, county or state landfills where ille-
gal or poorly managed waste disposal has taken
place. Other sites are found on private property,
often belonging to generators or former genera-
tors of hazardous waste. Examples of such sites
include, but are not limited to, surface impound-
ments, landfills, dumps, and tank or drum farms.
Normal operations at TSD sites are not covered by
this definition.
(b) Safety and health program.
Note fo (b): Safety and health programs
developed and implemented to meet other Fed-
eral, state, or local regulations are considered
acceptable in meeting this requirement if they
cover or are modified to cover the topics required
in this paragraph. An additional or separate safety
and health program is not required by this para-
graph.
(1) General.
(i) Employers shall develop and implement a
written safety and health program for their
employees involved in hazardous waste opera-
tions. The program shall be designed to iden-
tify, evaluate, and control safety and health
hazards, and provide for emergency response
for hazardous waste operations.
(ii) The written safety and health program
shall incorporate the following:
(a) An organizational structure;
(b) A comprehensive workplan:
(c) A site-specific safety and health plan
which need not repeat the employer's stand-
ard operating procedures required in para-
graph (b)(l)(ii)(F) of this section:
(d) The safety and health training program:
330.2
5
Change 51
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(e) The medical surveillance program;
(f) The employer's standard operating pro-
cedures for safety and health; and
(g) Any necessary interface between gen-
eral program and site specific activities.
(iii) Site excavation. Site excavations created
during initial site preparation or during haz-
ardous waste operations shall be shored or
sloped as appropriate to prevent accidental
collapse in accordance with Subpart P of 29
CFR Part 1926.
(iv) Contractors and sub-contractors. An
employer who retains contractor or sub-
contractor services for work in hazardous
waste operations shall inform those contrac-
tors, sub-contractors, or their representatives
of the site emergency response procedures
and any potential fire, explosion, health,
safety or other hazards of the hazardous
waste operation that have been identified by
the employer, including those identified in the
employer's information program.
(v) Program availability. The written safety
and health program shall be made available to
any contractor or subcontractor or their rep-
resentative who will be involved with the haz-
ardous waste operation; to employees; to
employee designated representatives; to
OSHA personnel, and to personnel of other
Federal, state, or local agencies with regula-
tory authority over the site.
(2) Organizational structure part of the site pro-
gram.
(i) The organizational structure part of the
program shall establish the specific chain of
command and specify the overall respon-
sibilities of supervisors and employees. It
shall include, at a minimum, the following ele-
ments:
(a) A general supervisor who has the
responsibility and authority to direct all
hazardous waste operations.
(b) A site safety and health supervisor who
has the responsibility and authority to
develop and implement the site safety and
health plan and verify compliance.
(c) All other personnel needed for haz-
ardous waste site operations and emergency
response and their general functions and
responsibilities.
(d) The lines of authority, responsibility,
and communication.
(ii) The organizational structure shall be
reviewed and updated as necessary to reflect
the current status of waste site operations.
(3) Comprehensive workplan part of the site pro-
gram. The comprehensive workplan part of the
program shall address the tasks and objectives
of the site operations and the logistics and
resources required to reach those tasks and
objectives.
(i) The comprehensive workplan shall address
anticipated clean-up activities as well as nor-
mal operating procedures which need not
repeat the employer's procedures available
elsewhere.
(ii) The comprehensive workplan shall define
work tasks and objectives and identify the
methods for accomplishing those tasks and
objectives.
(iii) The comprehensive workplan shall estab-
lish personnel requirements for implementing
the plan.
(iv) The comprehensive workplan shall
provide for the implementation of the training
required in paragraph (e) of this section.
(v) The comprehensive workplan shall provide
for the implementation of the required infor-
mational programs required in paragraph (i)
of this section.
(vi) The comprehensive workplan shall
provide for the implementation of the medical
surveillance program described in paragraph
(f) of this section.
(4) Site-specific safety and health plan part of the
program.
(i) General. The site safety and health plan,
which must be kept on site, shall address the
safety and health hazards of each phase of site
operation and include the requirements and
procedures for employee protection
Change 51
330.3
6
1910.120(bM-l)(i)
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(ii) Elements. The site safety and health plan,
as a minimum, shall address the following:
(a) A safety and health risk or hazard anal-
ysis for each site task and operation found
in the workplan.
(b) Employee training assignments to
assure compliance with paragraph (e) of this
section.
(c) Personal protective equipment to be
used by employees for each of the site tasks
and operations being conducted as required
by the personal protective equipment pro-
gram in paragraph (g)(5) of this section.
(d) Medical surveillance requirements in
accordance with the program in paragraph
(f) of this section.
(e) Frequency and types of air monitoring,
personnel monitoring, and environmental
sampling techniques and instrumentation to
be used, including methods of maintenance
and calibration of monitoring and sampling
equipment to be used.
(f) Site control measures in accordance with
the site control program required in para-
graph (d) of this section.
(g) Decontamination procedures in accord-
ance with paragraph (k) of this section.
(h) An emergency response plan meeting
the requirements of paragraph (1) of this
section for safe and effective responses to
emergencies, including the necessary PPE
and other equipment.
(i) Confined space entry procedures.
(j) A spill containment program meeting the
requirements of paragraph (j) of this sec-
tion.
(iii) Pro-entry briefing. The site specific safety
and health plan shall provide for pre-entry
briefings to be held prior to initiating any site
activity, and at such other times as necessary
to ensure that employees are apprised of the
site safety and health plan and that this plan
is being followed. The information and data
obtained from site characterization and anal-
ysis work required in paragraph (c) of this
section shall be used to prepare and update
the site safety and health plan.
(iv) Effectiveness of site safety and health plan.
Inspections shall be conducted by the site
safety and health supervisor or, in the
absence of that individual, another individual
who is knowledgeable in occupational safety
and health, acting on behalf of the employer
as necessary to determine the effectiveness of
the site safety and health plan. Any deficien-
cies in the effectiveness of the site safety and
health plan shall be corrected by the
employer.
(c) Site characterization and analysis.
(1) General. Hazardous waste sites shall be eval-
uated in accordance with this paragraph to iden-
tify specific site hazards and to determine the
appropriate safety and health control procedures
needed to protect employees from the identified
hazards.
(2) Preliminary evaluation. A preliminary evalua-
tion of a site's characteristics shall be performed
prior to site entry by a qualified person in order
to aid in the selection of appropriate employee
protection methods prior to site entry. Imme-
diately after initial site entry, a more detailed
evaluation of the site's specific chai-acteristics
shall be performed by a qualified person in order
to further identify existing site hazards and to
further aid in the selection of the appropriate
engineering controls and personal protective
equipment for the tasks to be performed.
(3) Hazard identification. All suspected conditions
that may pose inhalation or skin absorption haz-
ards that are immediately dangerous to life or
health (IDLH), or other conditions that may
cause death or serious harm, shall be identified
during the preliminary survey and evaluated
during the detailed survey. Examples of such
hazards include, but are not limited to, confined
space entry, potentially explosive or flammable
situations, visible vapor clouds, or areas where
biological indicators such as dead animals or veg-
etation are located.
(4) Required information. The following informa-
tion to the extent available shall be obtained by
the employer prior to allowing employees to
enter a site:
I9l0.l20(c)(4)d)
330.4
7
(i) Location and approximate size of the site.
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OCCUPATIONAL SAFETY AND HEALTH
191tl.l20(c)(4Mii)
STANDARDS AND INTERPRETATIONS
(ii) Description of the response activity and/or
the job task to be performed.
(iii) Duration of the planned employee
activity.
(iv) Site topography and accessibility by air
and roads.
(v) Safety and health hazards expected at the
site.
(vi) Pathways for hazardous substance disper-
sion.
(vii) Present status and capabilities of
emergency response teams that would provide
assistance to hazardous waste clean-up site
employees at the time of an emergency.
(viii) Hazardous substances and health haz-
ards involved or expected at the site, and
their chemical and physical properties.
(5) Personal protective equipment. Personal pro-
tective equipment (PPE) shall be provided and
used during initial site entry in accordance with
the following requirements:
(!) Based upon the results of the preliminary
site evaluation, an ensemble of PPE shall be
selected and used during initial site entry
which will provide protection to a level of
exposure below permissible exposure limits
and published exposure levels for known or
suspected hazardous substances and health
hazards, and which will provide protection
against other known and suspected hazards
identified during the preliminary site evalua-
tion. If there is no permissible exposure limit
or published exposure level, the employer
may use other published studies and informa-
tion as a guide to appropriate personal protec-
tive equipment.
(ii) If positive-pressure self-contained
breathing apparatus is not used as part of the
entry ensemble, and if respiratory protection
is warranted by the potential hazards identi-
fied during the preliminary site evaluation, an
escape self-contained breathing apparatus of
at least five minute's duration shall be carried
by employees during initial site entry.
(iii) If the preliminary site evaluation does not
produce sufficient information to identify the
hazards or suspected hazards of the site, an
ensemble providing protection equivalent to
Level B PPE shall be provided as minimum
protection, and direct reading instruments
shall be used as appropriate for identifying
IDLH conditions. (See Appendix B for a
description of Level B hazards and the recom-
mendations for Level B protective equip-
ment.)
(iv) Once the hazards of the site have been
identified, the appropriate PPE shall be
selected and used in accordance with para-
graph (g) of this section.
(6) Monitoring. The following monitoring shall be
conducted during initial site entry when the site
evaluation produces information that shows the
potential for ionizing radiation or IDLH condi-
tions, or when the site information is not suffi-
cient reasonably to eliminate these possible
conditions:
(i) Monitoring with direct reading instruments
for hazardous levels of ionizing radiation.
(ii) Monitoring the air with appropriate direct
reading test equipment (i.e., combustible gas
meters, detector tubes) for IDLH and other
conditions that may cause death or serious
harm (combustible or explosive atmospheres.
oxygen deficiency, toxic substances).
(iii) Visually observing for signs of actual or
potential IDLH or other dangerous condi-
tions.
(iv) An ongoing air monitoring program in
accordance with paragraph (h) of this section
shall be implemented after site characteriza-
tion has determined the site is safe for the
startup of operations.
(7) Risk identification. Once the presence and
concentrations of specific hazardous substances
and health hazards have been established, the
risks associated with these substances shall be
identified. Employees who will be working on
the site shall be informed of any risks that have
been identified. In situations covered by the
Hazard Communication Standard. 29 CFR
1910.1200, training required by that standard
need not be duplicated.
Note to (c)(7).—Risks to consider include, but
are not limited to:
Change 51
330.5
8
1910 12Wc)(7>
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191IU20(c)(7)(a)
OCCUPATIONAL SAFETY AXD HEALTH
STANDARDS AND INTERPRETATIONS
(a) Exposures exceeding the permissible
exposure limits and published exposure levels.
(b) IDLH concentrations.
(c) Potential skin absorption and irritation
sources.
(d) Potential eye irritation sources.
(e) Explosion sensitivity and flammability
ranges.
(f) Oxygen deficiency.
(8) Employee notification. Any information con-
cerning the chemical, physical, and toxicologic
properties of each substance known or expected
to be present on site that is available to the
employer and relevant to the duties an employee
is expected to perform shall be made available to
the affected employees prior to the commence-
ment of their work activities. The employer may
utilize information developed for the hazard
communication standard for this purpose.
(d) Site control.
(1) General. Appropriate site control procedures
shall be implemented to control employee
exposure to hazardous substances before clean-
up work begins.
(2) Site control program. A site control program
for protecting employees which is part of the
employer's site safety and health program
required in paragraph (b) of this1 section shall be
developed during the planning stages of a haz-
ardous waste clean-up operation and modified as
necessary as new information becomes available.
(3) Elements of the site control program. The site
control program shall, as a minimum, include: A
site map; site work zones; the use of a "buddy
system"; site communications including alerting
means for emergencies; the standard operating
procedures or safe work practices; and, identi-
fication of the nearest medical assistance. Where
these requirements are covered elsewhere they
need not be repeated.
(e) Training.
(!) General.
(i) All employees working on site (such as but
I9iu.i2(«e)(3)
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OCCUPATIONAL SAFETY AND HEALTH
1910,120
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OCCUPATIONAL SAFETY AND HEALTH
ft
STANDARDS AND INTERPRETATIONS
academic training or the training that existing
employees might have already received from
actual hazardous waste site work experience.
(f) Medical surveillance.
(1) General. Employers engaged in operations
specified in paragraphs (a)(l)(i) through
(a)(l)(iv) of this section and not covered by
(a)(2)(iii) exceptions and employers of employees
specified in paragraph (g)(9) shall institute a
medical surveillance program in accordance with
this paragraph.
(2) Employees covered. The medical surveillance
program shall be instituted by the employer for
the following employees:
(i) All employees who are or may be exposed
to hazardous substances or health hazards at
or above the permissible exposure limits or, if
there is no permissible exposure limit, above
the published exposure levels for these sub-
stances, without regard to the use of respira-
tors, for 30 days or more a year;
(ii) All employees who wear a respirator for 30
days or more a year or as required by §
1910.134;
(iii) All employees who are injured due to
overexposure from an emergency incident
involving hazardous substances or health haz-
ards; or
(iv) Members of HAZMAT teams.
(3) Frequency of medical examinations and con-
sultations.
Medical examinations and consultations shall be
made available by the employer to each
employee covered under paragraph (f)(2) of this
section on the following schedules:
(i) For employees covered under paragraphs
(f)(2)(i), (f)(2)(ii), and (f)(2)(iv):
(a) Prior to assignment;
(b) At least once every twelve months for
each employee covered unless the attending
physician believes a longer interval (not
greater than biennially) is appropriate;
(c) At termination of employment or reas-
signment to an area where the employee
would not be covered if the employee has
not had an examination within the last six
months;
(d) As soon as possible upon notification by
an employee that the employee has
developed signs or symptoms indicating
possible overexposure to hazardous sub-
stances or health hazards, or that the
employee has been injured or exposed
above the permissible exposure limits or
published exposure levels in an emergency
situation;
(e) At more frequent times, if the examin-
ing physician determines that an increased
frequency of examination is medically nec-
essary.
(ii) For employees covered under paragraph
(f)(2)(iii) and for all employees including those
of employers covered by paragraph (a)(l)(v)
who may have been injured, received a health
impairment, developed signs or symptoms
which may have resulted from exposure to
hazardous substances resulting from an
emergency incident, or exposed during an
emergency incident to hazardous substances
at concentrations above the permissible
exposure limits or the published exposure lev-
els without the necessary personal protective
equipment being used:
(a) As soon as possible following the
emergency incident or development of signs
or symptoms;
(b) At additional times, if the examining
physician determines that follow-up exam-
inations or consultations are medically nec-
essary.
(4) Content of medical examinations and con-
sultations.
(i) Medical examinations required by para-
graph (0(3) of this section shall include a med-
ical and work history (or updated history if
one is in the employee's file) with special
emphasis on symptoms related to the handling
of hazardous substances and health hazards.
and to fitness for duty including the ability to
wear any required PPE under conditions (i.e.,
temperature extremes) that may be expected
at the work site.
1910.120(0(4X1)
330.8
11
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(ii) The content of medical examinations or
consultations made available to employees
pursuant to paragraph (0 shall be determined
by the attending physician. The guidelines in
the Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities
(See Appendix D, Reference #10) should be
consulted.
(5) Examination by a physician and costs. All
medical examinations and procedures shall be
performed by or under the supervision of a
licensed physician, preferably one knowledge-
able in occupational medicine, and shall be
provided without cost to the employee, without
loss of pay, and at a reasonable time and place.
(6) Information provided to the physician. The
employer shall provide one copy of this standard
and its appendices to the attending physician,
and in addition the following for each employee:
(i) A description of the employee's duties as
they relate to the employee's exposures.
(ii) The employee's exposure levels or antici-
pated exposure levels.
(iii) A description of any personal protective
equipment used or to be used.
(iv) Information from previous medical exam-
inations of the employee which is not readily
available to the examining physician.
(v) Information required by §1910.134.
(7) Physician's written opinion.
(i) The employer shall obtain and furnish the
employee with a copy of a written opinion
from the attending physician containing the
following:
(a) The physician's opinion as to whether
the employee has any detected medical con-
ditions which would place the employee at
increased risk of material impairment of the
employee's health from work in hazardous
waste operations or emergency response, or
from respirator use.
(b) The physician's recommended limita-
tions upon the employee's assigned work.
(c) The results of the medical examination
and tests if requested by the employee.
(d) A statement that the employee has been
informed by the physician of the results of
the medical examination and any medical
conditions which require further examina-
tion or treatment.
(ii) The written opinion obtained by the
employer shall not reveal specific findings or
diagnoses unrelated to occupational ex-
posures.
(8) Recordkeeping.
(i) An accurate record of the medical sur-
veillance required by paragraph (f) of this sec-
tion shall be retained. This record shall be
retained for the period specified and meet the
criteria of 29 CFR 1910.20.
(ii) The record required in paragraph (f)(8)(i)
of this section shall include at least the follow-
ing information:
(a) The name and social security number of
the employee;
(b) Physician's written opinions, recom-
mended limitations, and results of examina-
tions and tests;
(c) Any employee medical complaints
related to exposure to hazardous sub-
stances;
(d) A copy of the information provided to
the examining physician by the employer,
with the exception of the standard and its
appendices.
(g) Engineering controls, work practices, and
personal protective equipment for employee
protection.
Engineering controls, work practices, personal
protective equipment, or a combination of these
shall be implemented in accordance with this para-
graph to protect employees from exposure to haz-
ardous substances and safety and health hazards.
Change 51
330.9
12
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1910.12l
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(1) Engineering controls, work practices and PPE
for substances regulated in Subparts G and Z.
(i) Engineering controls and work practices
shall be instituted to reduce and maintain
employee exposure to or below the permissi-
ble exposure limits for substances regulated
by 29 CFR Part 1910, to the extent required
by Subpart Z, except to the extent that such
controls and practices are not feasible.
Note to (g)(1)(i): Engineering controls which
may be feasible include the use of pressurized
cabs or control booths on equipment, and/or
the use of remotely operated material hand-
ling equipment. Work practices which may be
feasible are removing all non-essential
employees from potential exposure during
opening of drums, wetting down dusty opera-
tions and locating employees upwind of possi-
ble hazards.
(ii) Whenever engineering controls and work
practices are not feasible, PPE shall be used
to reduced and maintain employee exposures
to or below the permissible exposure limits or
dose limits for substances regulated by 29
CFR Part 1910, Subpart Z.
(iii) The employer shall not implement a
schedule of employee rotation as a means of
compliance with permissible exposure limits
or dose limits except when there is no other
feasible way of complying with the airborne or
dermal dose limits for ionizing radiation.
(iv) The provisions of 29 CFR, Subpart G,
shall be followed.
(2) Engineering controls, work practices, and PPE
for substances not regulated in Subparts G and Z.
An appropriate combination of engineering con-
trols, work practices and personal protective
equipment shall be used to reduce and maintain
employee exposure to or below published
exposure levels for hazardous substances and
health hazards not regulated by 29 CFR Part
1910, Subparts G and Z. The employer may use
the published literature and MSDS as a guide in
making the employer's determination as to what
level of protection the employer believes is
appropriate for hazardous substances and health
hazards for which there is no permissible
exposure limit or published exposure limit.
(3) Personal protective equipment selection.
(i) Personal protective equipment (PPE) shall
be selected and used which will protect
employees from the hazards and potential haz-
ards they are likely to encounter as identified
during the site characterization and analysis.
(ii) Personal protective equipment selection
shall be based on an evaluation of the per-
formance characteristics of the PPE relative
to the requirements and limitations of the
site, the task-specific conditions and duration,
and the hazards and potential hazards identi-
fied at the site.
(iii) Positive pressure self-contained breathing
apparatus, or positive pressure air-line respi-
rators equipped with an escape air supply,
shall be used when chemical exposure levels
present will create a substantial possibility of
immediate death, immediate serious illness or
injury, or impair the ability to escape.
(iv) Totally-encapsulating chemical protective
suits (protection equivalent to Level A protec-
tion as recommended in Appendix B) shall be
used in conditions where skin absorption of a
hazardous substance may result in a substan-
tial possibility of immediate death, immediate
serious illness or injury, or impair the ability
to escape.
(v) The level of protection provided by PPE
selection shall be increased when additional
information on site conditions indicates that
increased protection is necessary to reduce
employee exposures below permissible
exposure limits and published exposure levels
for hazardous substances and health hazards.
(See Appendix B for guidance on selecting
PPE ensembles.)
Note to (g)(3): The level of employee protec-
tion provided may be decreased when addi-
tional information or site conditions show that
decreased protection will not result in haz-
ardous exposures to employees.
(vi) Personal protective equipment shall be
selected and used to meet the requirements of
29 CFR Part 1910, Subpart I, and additional
requirements specified in this section.
1910.12IKgK3Kvil
330.10
13
Change 51
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATION'S
(4) Totally-encapsulating chemical protective
suits.
(i) Totally-encapsulating suits shall protect
employees from the particular hazards which
are identified during site characterization and
analysis.
(ii) Totally-encapsulating suits shall be capable
of maintaining positive air pressure. (See
Appendix A for a test method which may be
used to evaluate this requirement.)
{iii) Totally-encapsulating suits shall be capa-
ble of preventing inward test gas leakage of
more than 0.5 percent. (See Appendix A for a
test method which may be used to evaluate
this requirement.)
(5) Personal protective equipment (PPE) program.
A written personal protective equipment pro-
gram, which is part of the employer's safety and
health program required in paragraph (b) of this
section or required in paragraph (p)(l) of this
section and which is also a part of the site-
specific safety and health plan shall be estab-
lished. The PPE program shall address the ele-
ments listed below. When elements, such as
donning and doffing procedures, are provided by
the manufacturer of a piece of equipment and
are attached to the plan, they need not be
rewritten into the plan as long as they ade-
quately address the procedure or element.
(i) PPE selection based upon site hazards,
(ii) PPE use and limitations of the equipment,
(iii) Work mission duration,
(iv) PPE maintenance and storage,
(v) PPE decontamination and disposal,
(vi) PPE training and proper fitting,
(vii) PPE donning and doffing procedures,
(viii) PPE inspection procedures prior to, dur-
ing, and after use,
(ix) Evaluation of the effectiveness of the PPE
program, and
(x) Limitations during temperature extremes,
heat stress, and other appropriate medical
considerations.
(h) Monitoring.
(1) General.
(i) Monitoring shall be performed in accord-
ance with this paragraph where there may be
a question of employee exposure to hazardous
concentrations of hazardous substances in
order to assure proper selection of engineer-
ing controls, work practices and personal pro-
tective equipment so that employees are not
exposed to levels which exceed permissible
exposure limits or published exposure levels
for hazardous substances.
(ii) Air monitoring shall be used to identify
and quantify airborne levels of hazardous sub-
stances and safety and health hazards in order
to determine the appropriate level of
employee protection needed on site.
(2) Initial entry. Upon initial entry, representa-
tive air monitoring shall be conducted to identify
any IDLH condition, exposure over permissible
exposure limits or published exposure levels,
exposure over a radioactive material's dose
limits or other dangerous condition such as the
presence of flammable atmospheres or oxygen-
deficient environments.
(3) Periodic monitoring. Periodic monitoring shall
be conducted when the possibility of an IDLH
condition or flammable atmosphere has
developed or when there is indication that
exposures may have risen over permissible
exposure limits or published exposure levels
since prior monitoring. Situations where it shall
be considered whether the possibility that
exposures have risen are as follows:
(i) When work begins on a different portion of
the site.
(ii) When contaminants other than those pre-
viously identified are being handled.
(iii) When a different type of operation is initi-
ated (e.g., drum opening as opposed to explor-
atory well drilling).
(iv) When employees are handling leaking
drums or containers or working in areas with
obvious liquid contamination (e.g., a spill or
lagoon).
(4) Monitoring of high-risk employees. After the
actual clean-up phase of any hazardous waste
Change 51
330.11
14
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1910.120(h)(4)
OCCUPATIONAL SAFETY AXD HEALTH
STANDARDS AND INTERPRETATIONS
operation commences; for example, when soil,
surface water or containers are moved or dis-
turbed; the employer shall monitor those
employees likely to have the highest exposure to
hazardous substances and health hazards likely
to be present above permissible exposure limits
or published exposure levels by using personal
sampling frequently enough to characterize
employee exposures. If the employees likely to
have the highest exposure are over permissible
exposure limits or published exposure limits,
then monitoring shall continue to determine all
employees likely to be above those limits. The
employer may utilize a representative sampling
approach by documenting that the employees
and chemicals chosen for monitoring are based
on the criteria stated above.
Note to (h): It is not required to monitor
employees engaged in site characterization oper-
ations covered by paragraph (c) of this section.
(i) Informational programs.
Employers shall develop and implement a pro-
gram, which is part of the employer's safety and
health program required in paragraph (b) of this
section, to inform employees, contractors, and
subcontractors (or their representative) actually
engaged in hazardous waste operations of the
nature, level and degree of exposure likely as a
result of participation in such hazardous waste
operations. Employees, contractors and sub-
contractors working outside of the operations part
of a site are not covered by this standard.
(j) Handling drums and containers.
(1) General.
(i) Hazardous substances and contaminated
soils, liquids, and other residues shall be han-
dled, transported, labeled, and disposed of in
accordance with this paragraph.
(ii) Drums and containers used during the
clean-up shall meet the appropriate DOT,
OSHA, and EPA regulations for the wastes
that they contain.
(iii) When practical, drums and containers
shall be inspected and their integrity shall be
assured prior to being moved. Drums or con-
tainers that cannot be inspected before being
moved because of storage conditions (i.e., bur-
ied beneath the earth, stacked behind other
drums, stacked several tiers high in a pile.
etc.) shall be moved to an accessible location
and inspected prior to further handling.
(iv) Unlabeled drums and containers shall be
considered to contain hazardous substances
and handled accordingly until the contents are
positively identified and labeled.
(v) Site operations shall be organized to mini-
mize the amount of drum or container move-
ment.
(vi) Prior to movement of drums or con-
tainers, all employees exposed to the transfer
operation shall be warned of the potential haz-
ards associated with the contents of the drums
or containers.
(vii) U.S. Department of Transportation spec-
ified salvage drums or containers and suitable
quantities of proper absorbent shall be kept
available and used in areas where spills, leaks,
or ruptures may occur.
(viii) Where major spills may occur, a spill
containment program, which is part of the
employer's safety and health program
required in paragraph (b) of this section, shall
be implemented to contain and isolate the
entire volume of the hazardous substance
being transferred.
(ix) Drums and containers that cannot be
moved without rupture, leakage, or spillage
shall be emptied into a sound container using
a device classified for the material being
transferred.
(x) A ground-penetrating system or other
type of detection system or device shall be
used to estimate the location and depth of bur-
ied drums or containers.
(xi) Soil or covering material shall be removed
with caution to prevent drum or container
rupture.
(xii) Fire extinguishing equipment meeting
the requirements of 29 CFR Part 1910, Sub-
part L, shall be on hand and ready for use to
control incipient fires.
(2) Opening drums and containers. The following
procedures shall be followed in areas where
drums or containers are being opened:
1910.120(j)(2)
330.12
15
Change 51
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(i) Where an airline respirator system is used.
connections to the source of air supply shall be
protected from contamination and the entire
system shall be protected from physical
damage.
(ii) Employees not actually involved in open-
ing drums or containers shall be kept a safe
distance from the drums or containers being
opened.
(iii) If employees must work near or adjacent
to drums or containers being opened, a suita-
ble shield that does not interfere with the
work operation shall be placed between the
employee and the drums or containers being
opened to protect the employee in case of acci-
dental explosion.
(iv) Controls for drum or container opening
equipment, monitoring equipment, and fire
suppression equipment shall be located behind
the explosion-resistant barrier.
(v) When there is a reasonable possibility of
flammable atmospheres being present, mate-
rial handling equipment and hand tools shall
be of the type to prevent sources of ignition.
(vi) Drums and containers shall be opened in
such a manner that excess interior pressure
will be safety relieved. If pressure can not be
relieved from a remote location, appropriate
shielding shall be placed between the
employee and the drums or containers to
reduce the risk of employee injury.
(vii) Employees shall not stand upon or work
from drums or containers.
(3) Material handling equipment. Material hand-
ling equipment used to transfer drums and con-
tainers shall be selected, positioned and
operated to minimize sources of ignition related
to the equipment from igniting vapors released
from ruptured drums or containers.
(4) Radioactive wastes. Drums and containers
containing radioactive wastes shall not be han-
dled until such time as their hazard to
employees is properly assessed.
(5) Shock sensitive wastes. As a minimum, the
following special precautions shall be taken
when drums and containers containing or sus-
pected of containing shock-sensitive wastes are
handled:
Change 51
330.13
(i) All non-essential employees shall be evacu-
ated from the area of transfer.
(ii) Material handling equipment shall be
provided with explosive containment devices
or protective shields to protect equipment
operators from exploding containers.
(iii) An employee alarm system capable of
being perceived above surrounding light and
noise conditions shall be used to signal the
commencement and completion of explosive
waste handling activities.
(iv) Continuous communications (i.e., portable
radios, hand signals, telephones, as appropri-
ate) shall be maintained between the
employee-in-charge of the immediate handling
area and both the site safety and health super-
visor and the command post until such time as
the handling operation is completed. Com-
munication equipment or methods that could
cause shock sensitive materials to explode
shall not be used.
(v) Drums and containers under pressure, as
evidenced by bulging or swelling, shall not be
moved until such time as the cause for excess
pressure is determined and appropriate con-
tainment procedures have been implemented
to protect employees from explosive relief of
the drum.
(vi) Drums and containers containing pack-
aged laboratory wastes shall be considered to
contain shock-sensitive or explosive materials
until they have been characterized.
Caution: Shipping of shock sensitive wastes
may be prohibited under U.S. Department of
Transportation regulations. Employers and
their shippers should refer to 49 CFR 173.21
and 173.50.
(6) Laboratory waste packs. In addition to the
requirements of paragraph (j)(5) of this section,
the following precautions shall be taken, as a
minimum, in handling laboratory waste packs
(lab packs):
(i) Lab packs shall be opened only when neces-
sary and then only by an individual knowl-
edgeable in the inspection, classification, and
segregation of the containers within the pack
according to the hazards of the wastes.
(ii) If crystalline material is noted on any con-
l!H0.120(j)<6Hii)
16
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OCCUPATIONAL SAPETV AND HEALTH
STANDARDS AND INTERPRETATIONS
tainer, the contents shall be handled as a
shock-sensitive waste until the contents are
identified.
(7) Sampling of drum and container contents.
Sampling of containers and drums shall be clone
in accordance with a sampling procedure which
is part of the site safety and health plan
developed for and available to employees and
others at the specific worksite.
(8) Shipping and transport.
(i) Drums and containers shall be identified
and classified prior to packaging for shipment.
(ii) Drum or container staging areas shall be
kept to the minimum number necessary to
identify and classify materials safely and pre-
pare them for transport.
{iii) Staging areas shall be provided with ade-
quate access and egress routes.
(iv) Bulking of hazardous wastes shall be per-
mitted only after a thorough characterization
of the materials has been completed.
(9) Tank and vault procedures.
(i) Tanks and vaults containing hazardous
substances shall be handled in a manner simi-
lar to that for drums and containers, taking
into consideration the size of the tank or
vault.
(ii) Appropriate tank or vault entry proce-
dures as described in the employer's safety
and health plan shall be followed whenever
employees must enter a tank or vault.
(k) Decontamination.
(1) General. Procedures for all phases of decon-
tamination shall be developed and implemented
in accordance with this paragraph.
(2) Decontamination procedures.
(i) A decontamination procedure shall be
developed, communicated to employees and
implemented before any employees or equip-
ment may enter areas on site where potential
for exposure to hazardous substances exists.
(ii) Standard operating procedures shall hi-
developed to minimize employee contact with
hazardous substances or with equipment that
has contacted hazardous substances.
(iii) All employees leaving a contaminated
area shall be appropriately decontaminated;
all contaminated clothing and equipment leav-
ing a contaminated area shall be appropriately
disposed of or decontaminated.
(iv) Decontamination procedures shall be
monitored by the site safety and health super-
visor to determine their effectiveness. When
such procedures are found to be ineffective.
appropriate steps shall be taken to correct any
deficiencies.
(3) Location. Decontamination shall be performed
in geographical areas that will minimize the
exposure of uncontaminated employees or equip-
ment to contaminated employees or equipment.
(4) Equipment and solvents. All equipment and
solvents used for decontamination shall be
decontaminated or disposed of properly.
(5) Personal protective clothing and equipment.
(i) Protective clothing and equipment shall be
decontaminated, cleaned, laundered, main-
tained or replaced as needed to maintain their
effectiveness.
(ii) Employees whose non-impermeable
clothing becomes wetted with hazardous sub-
stances shall immediately remove that
clothing and proceed to shower. The clothing
shall be disposed of or decontaminated before
it is removed from the work zone.
(6) Unauthorized employees. Unauthorized
employees shall not remove protective clothing
or equipment from change rooms.
(7) Commercial laundries or cleaning establish-
ments. Commercial laundries or cleaning estab-
lishments that decontaminate protective
clothing or equipment shall be informed of the
potentially harmful effects of exposures to haz-
ardous substances.
(8) Showers and change rooms. Where the decon-
tamination procedure indicates a need for regu-
lar showers and change rooms outside of a
lS10.I20(k)(8)
330.14
17
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OCCUPATIONAL SAFETY AND HEALTH
1910.120(k)(8)
STANDARDS AND INTERPRETATION'S
contaminated area, they shall be provided and
meet the requirements of 29 CFR 1910.141. If
temperature conditions prevent the effective use
of water, then other effective means for cleans-
ing shall be provided and used.
(I) Emergency response by employees at
uncontrolled hazardous waste sites.
(1) Emergency response plan.
(i) An emergency response plan shall be
developed and implemented by all employers
within the scope of this section to handle
anticipated emergencies prior to the com-
mencement of hazardous waste operations.
The plan shall be in writing and available for
inspection and copying by employees, their
representatives, OSHA personnel and other
governmental agencies with relevant respon-
sibilities.
(ii) Employers who will evacuate their
employees from the workplace when an
emergency occurs, and who do not permit any
of their employees to assist in handling the
emergency, are exempt from the require-
ments of this paragraph if they provide an
emergency action plan complying with section
1910.38U) of this part.
(2) Elements of an emergency response plan. The
employer shall develop an emergency response
plan for emergencies which shall address, as a
minimum the following:
(i) Pre-emergency planning.
(ii) Personnel roles, lines of authority, and
communication.
(iii) Emergency recognition and prevention.
(iv) Safe distances and places of refuge.
(v) Site security and control.
(vi) Evacuation routes and procedures.
(vii) Decontamination procedures which are
not covered by the site safety and health plan.
(viii) Emergency medical treatment and first
aid.
(ix) Emergency alerting and response proce-
dures.
(x) Critique of response and follow-up.
(xi) PPE and emergency equipment.
(3) Procedures for handling emergency incidents.
(i) In addition to the elements for the
emergency response plan required in para-
graph (1)(2) of this section, the following ele-
ments shall be included for emergency
response plans:
(a) Site topography, layout, and prevailing
weather conditions.
(b) Procedures for reporting incidents to
local, state, and federal governmental agen-
cies.
(ii) The emergency response plan shall be a
separate section of the Site Safety and Health
Plan.
(iii) The emergency response plan shall be
compatible and integrated with the disaster,
fire and/or emergency response plans of local,
state, and federal agencies.
(iv) The emergency response plan shall be
rehearsed regularly as part of the overall
training program for site operations.
(v) The site emergency response plan shall be
reviewed periodically and, as necessary, be
amended to keep it current with new or
changing site conditions or information.
(vi) An employee alarm system shall be
installed 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-
cation; and to begin emergency procedures.
(vii) Based upon the information available at
time of the emergency, the employer shall
evaluate the incident and the site response
capabilities and proceed with the appropriate
steps to implement the site emergency
response plan.
Chanjfe 51
330.15
18
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OCCUPATIONAL SAFETY AND HEALTH
i
STANDARDS AND INTERPRETATION'S
(m) Illumination.
Areas accessible to employees shall be lighted to
not less than the minimum illumination inten-
sities listed in the following Table H-120.1 while
any work is in progress:
TABLE H-120.1—MINIMUM ILLUMINATION
INTENSITIES IN FOOT-CANDLES
Foot-
candles
Area or operations
5 General site areas.
3 Excavation and waste areas, access-
ways, active storage areas, loading
platforms, refueling, and field main-
tenance areas.
5 Indoors: Warehouses, corridors, hall-
ways, and exitways.
5 Tunnels, shafts, and general under-
ground work areas. (Exception:
Minimum of 10 foot-candles is
required at tunnel and shaft heading
during drilling mucking, and scaling.
Mine Safety and Health Administra-
tion approved cap lights shall be
acceptable for use in the tunnel head-
ing).
10 General shops (e.g., mechanical and
electrical equipment rooms, active
storerooms, barracks or living quar-
ters, locker or dressing rooms,
dining areas, and indoor toilets and
workrooms.)
30 First aid stations, infirmaries, and
offices.
(n) Sanitation at temporary workplaces.
(1) Potable wafer.
(i) An adequate supply of potable water shall
be provided on the site.
(ii) Portable containers used to dispense
drinking water shall be capable of being
tightly closed, and equipped with a tap. Water
shall not be dipped from containers.
(iii) Any container used to distribute drinking
water shall be clearly marked as to the nature
of its contents and not used for any other pur-
pose.
(iv) Where single servict' cups (to be used but
once) are supplied, both a sanitary container
for the unused cups and a receptacle for dis-
posing of the used cups shall be provided.
(2) Nonpotable water.
(i) Outlets for nonpotable water, such as
water for firefighting purposes, shall be iden-
tified to indicate clearly that the water is
unsafe and is not to be used for drinking,
washing, or cooking purposes.
(ii) There shall be no cross-connection, open or
potential, between a system furnishing pota-
ble water and a system furnishing nonpotable
water.
(3) Toilet facilities.
(i) Toilets shall be provided for employees
according to the following Table H-120.2.
TABLE H-120.2—TOILET FACILITIES
Number of employees
Minimum number of
facilities
20 or fewer One.
More than 20, fewer One toilet seat and one
than 200. urinal per 40
employees.
More than 200 One toilet seat and one
urinal per 50
employees.
(ii) Under temporary field conditions, provi-
sions shall be made to assure that at least one
toilet facility is available.
(iii) Hazardous waste sites not provided with a
sanitary sewer shall be provided with the fol-
lowing toilet facilities unless prohibited by
local codes:
(a) Chemical toilets:
(b) Recirculating toilets:
(c) Combustion toilets; or
(d) Flush toilets.
(iv) The requirements of this paragraph for
sanitation facilities shall not apply to mobile
crews having transportation readily available
to nearbv toilet facilities.
1910.120(n)C!Hivl
330.16
19
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OCCUPATIONAL SAFETY AND HEALTH
1910.120(n)(3Kv)
(v) Doors entering toilet facilities shall be
provided with entrance locks controlled from
inside the facility.
(4) Food handling. All food service facilities and
operations for employees shall meet the applica-
ble laws, ordinances, and regulations of the
jurisdictions in which they are located.
(5) Temporary sleeping quarters. When tempo-
rary sleeping quarters are provided, they shall
be heated, ventilated, and lighted.
(6) Washing facilities. The employer shall
provide adequate washing facilities for
employees engaged in operations where haz-
ardous substances may be harmful to
employees. Such facilities shall be in near prox-
imity to the worksite; in areas where exposures
are below permissible exposure limits and pub-
lished exposure levels and which are under the
controls of the employer; and shall be so
equipped as to enable employees to remove haz-
ardous substances from themselves.
(7) Showers and change rooms. When hazardous
waste clean-up or removal operations commence
on a site and the duration of the work will
require six months or greater time to complete,
the employer shall provide showers and change
rooms for all employees exposed to hazardous
substances and health hazards involved in haz-
ardous waste clean-up or removal operations.
(i) Showers shall be provided and shall be
provided and shall meet the requirements of
29CFR 19l0.141(d)(3).
(ii) Change rooms shall be provided and shall
meet the requirements of 29 CFR 1910.141(e).
Change rooms shall consist of two separate
change areas separated by the shower area
required in paragraph (n)(7)(i) of this section.
One change area, with an exit leading off the
worksite, shall provide employees with a clean
area where they can remove, store, and put
on street clothing. The second area, with an
exit to the worksite, shall provide employees
with an area where they can put on, remove
and store work clothing and personal protec-
tive equipment.
(iii) Showers and change rooms shall be
located in areas where exposures are below
the permissible exposure limits and published
exposure levels. If this cannot be accom-
STAK'DARDS AND INTERPRETATIONS
plished, then a ventilation system shall be
provided that will supply air that is below the
permissible exposure limits and published
exposure levels.
(iv) Employers shall assure that employees
shower at the end of their work shift and
when leaving the hazardous waste site.
(o) New technology programs.
(1) The employer shall develop and implement
procedures for the introduction of effective new
technologies and equipment developed for the
improved protection of employees working with
hazardous waste clean-up operations, and the
same shall be implemented as part of the site
safety and health program to assure that
employee protection is being maintained.
(2) New technologies, equipment or control
measures available to the industry, such as the
use of foams, absorbents, adsorbents, neu-
tralizers, or other means to suppress the level of
air contaminants while excavating the site or for
spill control, shall be evaluated by employers or
their representatives. Such an evaluation shall
be done to determine the effectiveness of the
new methods, materials, or equipment before
implementing their use on a large scale for
enhancing employee protection. Information and
data from manufacturers or suppliers may be
used as part of the employer's evaluation effort.
Such evaluations shall be made available to
OSHA upon request.
(p) Certain Operations Conducted Under the
Resource Conservation and Recovery Act of
1976 (RCRA).
Employers conducting operations at treatment,
storage, and disposal (TSD) facilities specified in
paragraph (a)(l)(iv) of this section not exempted
by paragraph (a)(2)(iii) of this section shall
provide and implement the programs specified
in this paragraph.
(1) Safety and health program. The employer
shall develop and implement a written safety
and health program for employees involved in
hazardous waste operations that shall be avail-
able for inspection by employees, their repre-
sentatives and OSHA personnel. The program
shall be designed to identify, evaluate and con-
trol safety and health hazards in their facilities
Change 51
330.17
20
1910.120(p)(l)
-------
ISI0.120(p)(l)
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
tor the purpose of employee protection, to
provide for emergency response meeting the
requirements of paragraph (p)(8) of this section
and to address as appropriate site analysis, engi-
neering controls, maximum exposure limits, haz-
ardous waste handling procedures and uses of
new technologies.
(2) Hazard communication program. The
employer shall implement a hazard communica-
tion program meeting the requirements of 29
CFR 1910.1200 as part of the employer's safety
and program.
Note to 1910.120.—The exemption for haz-
ardous waste provided in §1910.1200 is applica-
ble to this section.
(3) Medical surveillance program. The employer
shall develop and implement a medical sur-
veillance program meeting the requirements of
paragraph (f) of this section.
(4) Decontamination program. The employer
shall develop and implement a decontamination
procedure meeting the requirements of para-
graph (k) of this section.
(5) New technology program. The employer shall
develop and implement procedures meeting the
requirements of paragraph (o) of this section for
introducing new and innovative equipment into
the workplace.
(6) Material handling program. Where employees
will be handling drums or containers, the
employer shall develop and implement proce-
dures meeting the requirements of paragraphs
(j)(l)(ii) through (viii) and (xi) of this section, as
well as (j)(3) and (j)(8) of this section prior to
starting such work.
(7) Training program.
(i) New employees. The employer shall
develop and implement a training program,
which is part of the employer's safety and
health program, for employees involved with
hazardous waste operations to enable
employees to perform their assigned duties
and functions in a safe and healthful manner
so as not to endanger themselves or other
employees. The initial training shall be for 24
hours and refresher training shall be for eight
hours annually. Employees who have received
the initial training required by this paragraph
shall be given a written certificate attesting
that they have successfully completed the nec-
essary training.
(ii) Current employees. Employers who can
show by an employee's previous work experi-
ence and/or training that the employee has
had training equivalent to the initial training
required by this paragraph, shall be consid-
ered as meeting the initial training require-
ments of this paragraph as to that employee.
Equivalent training includes the training that
existing employees might have already
received from actual site work experience.
Current employees shall receive eight hours
of refresher training annually.
(iii) Trainers. Trainers who teach initial train-
ing shall have satisfactorily completed a train-
ing course for teaching the subjects they are
expected to teach or they shall have the aca-
demic credentials and instruction experience
necessary to demonstrate a good command of
the subject matter of the courses and compe-
tent instructional skills.
(8) Emergency response program.
(i) Emergency response plan. An emergency
response plan shall be developed and imple-
mented by all employers. Such plans need not
duplicate any of the subjects fully addressed
in the employer's contingency planning
required by permits, such as those issued by
the U.S. Environmental Protection Agency,
provided that the contingency plan is made
part of the emergency response plan shall be a
written portion of the employers safety and
health program required in paragraph (p)(l) of
this section. Employers who will evacuate
their employees from the worksite location
when an emergency occurs and who do not
permit any of their employees to assist in
handling the emergency are exempt from the
requirements of paragraph (p)(8) if they
provide an emergency action plan complying
with §1910.38(a) of this part.
(ii) Elements of an emergency response plan.
The employer shall develop an emergency
response plan for emergencies which shall
address, "as a minimum, the following areas to
the extent that they are not addressed in any
specific program required in this paragraph:
330.18
21
Change 51
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(a) Pre-emergency planning and coordina-
tion with outside parties.
(b) Personnel roles, lines of authority, and
communication.
(c) Emergency recognition and prevention.
(d) Safe distances and places of refuge.
(e) Site security and control.
(f) Evacuation routes and procedures.
(g) Decontamination procedures.
(h) Emergency medical treatment and first
aid.
(i) Emergency alerting and response proce-
dures.
(j) Critique of response and follow-up.
(k) PPE and emergency equipment.
(iii) Training.
(a) Training for emergency response
employees shall be completed before they are
called upon to perform in real emergencies.
Such training shall include the elements of the
emergency response plan, standard operating
procedures the employer has established for
the job, the personal protective equipment to
be worn and procedures for handling
emergency incidents.
Exception #1: An employer need not train all
employees to the degree specified if the
employer divides the work force in a manner
such that a sufficient number of employees
who have responsibility to control emergencies
have the training specified, and all other
employees, who may first respond to an
emergency incident, have sufficient awareness
training to recognize that an emergency
response situation exists and that they are
instructed in that case to summon the fully
trained employees and not attempt control
activities for which they are not trained.
Exception #2: An employer need not train all
employees to the degree specified if arrange-
ments have been made in advance for an out-
side fully-trained emergency response team to
Change 51
330.19
respond in a reasonable period and all
employees, who may come to the incident
first, have sufficient awareness training to rec-
ognize that an emergency response situation
exists and they have been instructed to call
the designated outside fully-trained
emergency response team for assistance.
(b) Employee members of TSD facility
emergency response organizations shall be
trained to a level of competence in the recogni-
tion of health and safety hazards to protect
themselves and other employees. This would
include training in the methods used to mini-
mize the risk from safety and health hazards;
in the safe use of control equipment; in the
selection and use of appropriate personal pro-
tective equipment; in the safe operating proce-
dures to be used at the incident scene; in the
techniques of coordination with other
employees to minimize risks; in the appropri-
ate response to over exposure from health haz-
ards or injury to themselves and other
employees; and in the recognition of subse-
quent symptoms which may result from over
exposures.
(e) The employer shall certify that each cov-
ered employee has attended and successfully
completed the training required in paragraph
(p)(8)(iii) of this section, or shall certify the
employee's competency at least yearly. The
method used to demonstrate competency for
certification of training shall be recorded and
maintained by the employer.
(iv) Procedures for handling emergency inci-
dents.
(a) In addition to the elements for the
emergency response plan required in para-
graph (p)(8)(ii) of this section, the following
elements shall be included for emergency
response plans to the extent that they do
not repeat any information already con-
tained in the emergency response plan:
(1) Site topography, layout, and prevail-
ing weather conditions.
(2) Procedures for reporting incidents to
local, state, and federal governmental
agencies.
(b) The emergency response plan shall be
compatible and integrated with the disas-
1910.l20(pX8)(iv)(b)
22
-------
1910.120(p)(8)(iv)(b)
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
ter, fire and/or emergency response plans of
local, state, and federal agencies.
(c) The emergency response plan shall be
rehearsed regularly as part of the overall
training program for site operations.
(d) The site emergency response plan shall
be reviewed periodically and, as necessary,
be amended to keep it current with -new or
changing site conditions or information.
(e) An employee alarm system shall be
installed 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 communication; and to begin
emergency procedures.
(f) Based upon the information available at
time of the emergency, the employer shall
evaluate the incident and the site response
capabilities and proceed with the appropri-
ate steps to implement the site emergency
response plan.
(q) Emergency response to hazardous sub-
stance releases.
This paragraph covers employers whose
employees are engaged in emergency response no
matter where it occurs except that it does not
cover employees engaged in operations specified in
paragraphs (a)(l)(i) through (a)(l)(iv) of this sec-
tion. Those emergency response organizations who
have developed and implemented programs equiv-
alent to this paragraph for handling releases of
hazardous substances pursuant to section 303 of
the Superfund Amendments and Reauthorization
Act of 1986 (Emergency Planning and Community
Right-to-Know Act of 1986, 42 U.S.C. 11003) shall
be deemed to have met the requirements of this
paragraph.
(1) Emergency response plan. An emergency
response plan shall be developed and imple-
mented to handle anticipated emergencies prior
to the commencement of emergency response
operations. The plan shall be in writing and
available for inspection and copying by
employees, their representatives and OSHA
personnel. Employers who will evacuate their
employees from the workplace when an
emergency occurs, and who do not permit any of
their employees to assist in handling the
emergency, are exempt from the requirements
of this paragraph if they provide an emergency
action plan in accordance with §1910.38(a) of this
part.
(2) Elements of an emergency response plan. The
employer shall develop an emergency response
plan for emergencies which shall address, as a
minimum, the following to the extent that they
are not addressed elsewhere:
(i) Pre-emergency planning and coordination
with outside parties.
(ii) Personnel roles, lines of authority, train-
ing, and communication.
(Hi) Emergency recognition and prevention.
(iv) Safe distances and places of refuse.
(v) Site security and control.
(vi) Evacuation routes and procedures.
(vii) Decontamination.
(viii) Emergency medical treatment and first
aid.
(ix) Emergency alerting and response proce-
dures.
(x) Critique of response and follow-up.
(xi) PPE and Emergency equipment.
(xii) Emergency response organizations may
use the local emergency response plan or the
state emergency response plan or both, as
part of their emergency response plan to
avoid duplication. Those items of the
emergency response plan that are being prop-
erly addressed by the SARA Title III plans
may be substituted into their emergency plan
or otherwise kept together for the employer
and employee's use.
(3) Procedures for handling emergency response.
(i) The senior emergency response official
responding to an emergency shall become the
individual in charge of a site-specific Incident
Command System (ICS). All emergency
responders and their communications shall be
coordinated and controlled through the indi-
vidual in charge of the ICS assisted by the
senior official present for each employer.
1910.120(q)(3)(i)
330.20
23
Change 51
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OCCUPATIONAL SAFETY AND HEALTH
1910.120(q)(3)(i)
STANDARDS AND INTERPRETATIONS
Note to (q)(3)(i).—The "senior official" at an
emergency response is the most senior official
on the site who has the responsibility for con-
trolling the operations at the site. Initially it
is the senior officer on the first-clue piece of
responding emergency apparatus to arrived
on the incident scene. As more senior officers
arrive (i.e., battalion chief, fire chief, state
law enforcement official, site coordinator,
etc.) the position is passed up the line of
authority which has been previously estab-
lished.
(ii) The individual in charge of the ICS shall
identify, to the extent possible, all hazardous
substances or conditions present and shall
address as appropriate site analysis, use of
engineering controls, maximum exposure
limits, hazardous substance handling proce-
dures, and use of any new technologies.
(iii) Based on the hazardous substances and/or
conditions present, the individual in charge of
the ICS shall implement appropriate
emergency operations, and assure that the
personal protective equipment worn is appro-
priate for the hazards to be encountered.
However, personal protective equipment shall
meet, at a minimum, the criteria contained in
29 CFR 1910.156(e) when worn while per-
forming fire fighting operations beyond the
incipient stage for any incident or site.
(iv) Employees engaged in emergency
response and exposed to hazardous substances
presenting an inhalation hazard or potential
inhalation hazard shall wear positive pressure
self-contained breathing apparatus while
engaged in emergency response, until such
time that the individual in charge of the ICS
determines through the use of air monitoring
that a decreased level of respiratory protec-
tion will not result in hazardous exposures to
employees.
(v) The individual in charge of the ICS shall
limit the number of emergency response per-
sonnel at the emergency site, in those areas of
potential or actual exposure to incident or site
hazards, to those who are actively performing
emergency operations. However, operations
in hazardous areas shall be performed using
the buddy system in groups of two or more.
(vi) Back-up personnel shall stand by with
equipment ready to provide assistance or res-
cue. Advance first aid support personnel, as a
minimum, shall also stand by with medical
equipment and transportation capability.
(vii) The individual in charge of the ICS shall
designate a safety official, who is knowledge-
able in the operations being implemented at
the emergency response site, with specific
responsibility to identify and evaluate hazards
and to provide direction with respect to the
safety of operations for the emergency at
hand.
(viii) When activities are judged by the safety
official to be an IDLH condition and/or to
involve an imminent danger condition, the
safety official shall have the authority to alter,
suspend, or terminate those activities. The
safety official shall immediately inform the
individual in charge of the ICS of any actions
needed to be taken to correct these hazards at
an emergency scene.
(ix) After emergency operations have termi-
nated, the individual in charge of the ICS
shall implement appropriate decontamination
procedures.
(x) When deemed necessary for meeting the
tasks at hand, approved self-contained com-
pressed air breathing apparatus may be used
with approved cylinders from other approved
self-contained compressed air breathing appa-
ratus provided that such cylinders are of the
same capacity and pressure rating. All com-
pressed air cylinders used with self-contained
breathing apparatus shall meet U.S. Depart-
ment of Transportation and National Institute
for Occupational Safety and Health criteria.
(4) Skilled support personnel. Personnel, not nec-
essarily an employer's own employees, who are
skilled in the operation of certain equipment,
such as mechanized earth moving or digging
equipment or crane and hoisting equipment, and
who are needed temporarily to perform immedi-
ate emergency support work that cannot reason-
ably be performed in a timely fashion by an
employer's own employees, and who will be or
may be exposed to the hazards at an emergency
response scene, are not required to meet the
training required in this paragraph for the
employer's regular employees. However, these
personnel shall be given an initial briefing at the
site prior to their participation in any
emergency response. The initial briefing shall
Change 51
330.21
24
1910.120(q)U)
-------
I910.120(q)(-IC
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
include instruction in the wearing of appropriate
personal protective equipment, what chemical
hazards are involved, and what duties are to be
performed. All other appropriate safety and
health precautions provided to the employer's
own employees shall be used to assure the
safety and health of these personnel.
(5) Specialist employees. Employees who, in the
course of their regular job duties, work with and
are trained in the hazards of specific hazardous
substances, and who will be called upon to
provide technical advice or assistance at a haz-
ardous substance release incident to the individ-
ual in charge, shall receive training or
demonstrate competency in the area of their
specialization annually.
(6) Training. Training shall be based on the
duties and function to be performed by each
responder of an emergency response organiza-
tion. The skill and knowledge levels required for
all new responders, those hired after the effec-
tive date of this standard, shall be conveyed to
them through training before they are permitted
to take part in actual emergency operations on
an incident. Employees who participate, or are
expected to participate, in emergency response,
shall be given training in accordance with the
following paragraphs:
(i) First responder awareness level. First
responders at the awareness level are individ-
uals who are likely to witness or discover a
hazardous substance release and who have
been trained to initiate an e.mergency
response sequence by notifying the proper
authorities of the release. They would take no
further action beyond notifying the authorities
of the release. First responders at the aware-
ness level shall have sufficient training to
have had sufficient experience to objectively
demonstrate competency in the following
areas.
(o) An understanding of what hazardous
materials are, and the risks associated with
them in an incident.
(b) An understanding of the potential out-
comes associated with an emergency cre-
ated when hazardous materials are present.
(c) The ability to recognize the presence of
hazardous materials in an emergency.
l910.I2()(q)(bMi)(n
330.22
25
(d) The ability to identify the hazardous
materials, if possible.
(e) An understanding of the role of the first
responder awareness individual in the
employer's emergency response plan includ-
ing the site security and control and the
U.S. Department of Transportation's
Emergency Response Guidebook.
(f) The ability to realize the need for addi-
tional resources, and to make appropriate
notifications to the communication center.
(ii) First responder operations level. First
responders at the operations level are individ-
uals who respond to releases or potential
releases of hazardous substances as part of
the initial response to the site for the purpose
of protecting nearby persons, property, or the
environment from the effects of the release.
They are trained to respond in a defensive
fashion without actually trying to stop the
release. Their function is to contain the
release from a safe distance, keep it from
spreading, and prevent exposures. First
responders at the operational level shall have
received at least eight hours of training or
have had sufficient experience to objectively
demonstrate competency in the following
areas in addition to those listed for the aware-
ness level and the employer shall so certify:
(a) Knowledge of the basic hazard and risk
assessment techniques.
(b) Know how to select and use proper per-
sonal protective equipment provided to the
first responder operational level.
(c) An understanding of basic hazardous
materials terms.
(d) Know how to perform basic control, con-
tainment and/or confinement operations
within the capabilities of the resources and
personal protective equipment available
with their unit.
(e) Know how to implement basic decon-
tamination procedures.
(f) An understanding of the relevant stand-
ard operating procedures and termination
procedures.
Change 51
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OCCUPATIONAL SAFETY AND HEALTH
1910.120(q)(6Kiii)
STANDARDS AND INTERPRETATIONS
(ill) Hazardous materials technician. Hazardous
materials technicians are individuals who
respond to releases or potential releases for
the purpose of stopping the release. They
assume a more aggressive role than a first
responder at the operations level in that they
will approach the point of release in order to
plug, patch or otherwise stop the release of a
hazardous substance. Hazardous materials
technicians shall have received at-least 24
hours of training equal to the first responder
operations level and in addition have compe-
tency in the following areas and the employer
shall so certify:
(a) Know how to implement the employer's
emergency response plan.
(b) Know the classification, identification
and verification of known and unknown
materials by using field survey instruments
and equipment.
(c) Be able to function within an assigned
role in the Incident Command System.
(d) Know how to select and use proper spe-
cialized chemical personal protective equip-
ment provided to the hazardous materials
technician.
(e) Understand hazard and risk assessment
techniques.
(f) Be able to perform advance control, con-
tainment, and/or confinement operations
within the capabilities of the resources and
personal protective equipment available
with the unit.
(g) Understand and implement decon-
tamination procedures.
(h) Understand termination procedures.
(i) Understand basic chemical and tox-
icological terminology and behavior.
(iv) Hazardous materials specialist. Hazardous
materials specialists are individuals who
respond with and provide support to haz-
ardous materials technicians. Their duties
parallel those of the hazardous materials tech-
nician, however, those duties require a more
directed or specific knowledge of the various
substances they may be called upon to con-
tain. The hazardous materials specialist would
also act as the site liaison with Federal, state,
local and other government authorities in
regards to site activities. Hazardous materials
specialists shall have received at least 24
hours of training equal to the technician level
and in addition have competency in the follow-
ing areas and the employer shall so certify:
(a) Know how to implement the local
emergency response plan.
(b) Understand classification, identification
and verification of known and unknown
materials by using advanced survey instru-
ments and equipment.
(c) Know of the state emergency response
plan.
(d) Be able to select and use roper spe-
cialized chemical personal protective equip-
ment provided to the hazardous materials
specialist.
(e) Understand in-depth hazard and risk
techniques.
(f) Be able to perform specialized control,
containment, and/or confinement operations
within the capabilities of the resources and
personal protective equipment available.
(g) Be able to determine and implement
decontamination procedures.
(h) Have the ability to develop a site safety
and control plan.
(i) Understand chemical, radiological and
toxicological terminology and behavior.
(v) On scene incident commander. Incident
commanders, who will assume control of the
incident scene beyond the first responder
awareness level, shall receive at least 24
hours of training equal to the first responder
operations level and in addition have compe-
tency in the following areas and the employer
shall so certify:
(a) Know and be able to implement the
employer's incident command system.
(b) Know how to implement the employer's
emergency response plan.
Change 51
330.23
26
1910.120(q)(6)(v)(b)
-------
1910.120(q)(6)(v)(c)
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(c) Know and understand the hazards and
risks associated with employees working in
chemical protective clothing.
(d) Know how to implement the local
emergency response plan.
(e) Know of the state emergency response
plan and of the Federal Regional Response
Team.
(f) Know and understand the importance of
decontamination procedures.
(7) Trainers. Trainers who teach any of the above
training subjects shall have satisfactorily com-
pleted a training course for teaching the sub-
jects they are expected to teach, such as the
courses offered by the U.S. Fire Academy, or
they shall have the training and/or academic cre-
dentials and instructional experience necessary
to demonstrate competent instructional skills
and a good command of the subject matter of the
courses they are to teach.
(8) Refresher training.
(i) Those employees who are trained in accord-
ance with paragraph (q)(6) of this section shall
receive annual refresher training of sufficient
content and duration to maintain their compe-
tencies, or shall demonstrate competency in
those areas at least yearly.
(ii) A statement shall be made of the training
or competency, and if a statement of compe-
tency is made, the employer shall keep a rec-
ord of the methodology used to demonstrate
competency.
(9) Medical surveillance and consultation.
(i) Members of an organized and designated
HAZMAT team and hazardous materials spe-
cialists shall receive a baseline physical exam-
ination and be provided with medical
surveillance as required in paragraph (f) of
this section.
(ii) Any emergency response employees who
exhibits signs or symptoms which may have
resulted from exposure to hazardous sub-
stances during the course of an emergency
incident, either immediately or subsequently,
shall be provided with medical consultation as
required in paragraph (f)(3)(ii) of this section.
(10) Chemical protective clothing. Chemical pro-
tective clothing and equipment to be used by
organized and designated HAZMAT team mem-
bers, or to be used by hazardous materials spe-
cialists, shall meet the requirements of
paragraphs (g)(3) through (5) of this section.
(11) Post-emergency response operations. Upon
completion of the emergency response, if it is
determined that it is necessary to remove haz-
ardous substances, health hazards, and mate-
rials contaminated with them (such as
contaminated soil or other elements of the natu-
ral environment) from the site of the incident,
the employer conducting the clean-up shall com-
ply with one of the following:
(i) Meet all of the requirements of paragraphs
(b) through (o) of this section; or
(ii) Where the clean-up is done on plant prop-
erty using plant or workplace employees, such
employees shall have completed the training
requirements of the following: 29 CFR
1910.38(a); 1910.134; 1910.1200, and other
appropriate safety and health training made
necessary by the tasks that they are expected
to be performed such as personal protective
equipment and decontamination procedures.
All equipment to be used in the performance
of the clean-up work shall be in serviceable
condition and shall have been inspected prior
to use.
APPENDICES TO 1910.120—HAZARDOUS WASTE OPER-
ATIONS AND EMERGENCY RESPONSE
Note: The following appendices serve as non-mandatory
guidelines to assist employees and employers in complying with
the appropriate requirements of this section. However para-
graph 1910.120(g) makes mandatory in certain circumstances
the use of Level A and Level B PPE protection.
Appendix A—Personal Protective Equipment Test Methods
This appendix sets forth the nonmandatory examples of tests
which may be used to evaluate compliance with S 1910.120
(g)(4)(ii) and (iii). Other tests and other challenge agents may
be used to evaluate compliance.
A. Totally-encapsulating chemical protective suit pressure
test.
1.0—Scope
1.1 This practice measures the ability of a gas tight totally-
1910.120 Appendix A
330.24
27
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OCCUPATIONAL SAFETY AND HEALTH
1910.120 Appendix A
STANDARDS AND INTERPRETATIONS
encapsulating chemical protective suit material, seams, and clo-
sures to maintain a fixed positive pressure. The results of this
practice allow the gas tight integrity of a totally-encapsulating
chemical protective suit to be evaluated.
1.2 Resistance of the suit materials to permeation, penetra-
tion, and degradation by specific hazardous substances is not
determined by this test method.
2.0—Definition of terms
2.1 "Totally-encapsulated chemical protective suit (TECP
suit)" means a full body garment which is constructed of protec-
tive clothing materials; covers the wearer's torso, head, arms,
legs and respirator; may cover the wearer's hands and feet with
tightly attached gloves and boots; completely encloses the
wearer and respirator by itself or in combination with the
wearer's gloves and boots.
2.2 "Protective clothing material" means any material or
combination of materials used in an item of clothing for the pur-
pose of isolating parts of the body from direct contact with a
potentially hazardous liquid or gaseous chemicals.
2.3 "Gas tight" means, for the purpose of this test method,
the limited flow of a gas under pressure from the inside of a
TECP suit to atmosphere at a prescribed pressure and time
interval.
3.0—Summary of test method
3.1 The TECP suit is visually inspected and modified for the
test. The test apparatus is attached to the suit to permit infla-
tion to the pre-test suit expansion pressure for removal of suit
wrinkles and creases. The pressure is lowered to the test pres-
sure and monitored for three minutes. If the pressure drop is
excessive, the TECP suit fails the test and is removed from
service. The test is repeated after leak location and repair.
4.0—Required Supplies
4.1 Source of compressed air.
4.2 Test apparatus for suit testing, including a pressure
measurement device with a sensitivity of at least 'A inch water
gauge.
4.3 Vent valve closure plugs or sealing tape.
4.4 Soapy water solution and soft brush.
4.5 Stop watch or appropriate timing device.
5.0—Safety Precautions
5.1 Care shall be taken to provide the correct pressure safety
devices required for the source of compressed air used.
6.0—Test Procedure
6.1 Prior to each test, the tester shall perform a visual
inspection of the suit. Check the suit for seam integrity by vis-
ually examining the seams and gently pulling on the seams.
Ensure that all air supply lines, fittings, visor, zippers, anil
valves are secure and show no signs of deterioration.
6.1.1 Seal off the vent valves along with any other normal
inlet or exhaust points (such as umbilical air line fittings or face
piece opening) with tape or other appropriate means (caps,
plugs, fixture, etc.). Care should be exercised in the sealing
process not to damage any of the suit components.
6.1.2 Close all closure assemblies.
6.1.3 Prepare the suit for inflation by providing an
improvised connection point on the suit for connecting an air-
line. Attach the pressure test apparatus to the suit to permit
suit inflation from a compressed air source equipped with a
pressure indicating regulator. The leak tightness of the pres-
sure test apparatus should be tested before and after each test
by closing off the end of the tubing attached to the suit and
assuring a pressure of three inches water gauge for three min-
utes can be maintained. If a component is removed for the test,
that component shall be replaced and a second test conducted
with another component removed to permit a complete test of
the ensemble.
6.1.4 The pre-test expansion pressure (A) and the suit test
pressure (B) shall be supplied by the suit manufacturer, but in
no case shall they be less than: (A)=three inches water gauge;
and (B) = two inches water gauge. The ending suit pressure (C)
shall be no less than 80 percent of the test pressure (B); i.e.,
the pressure drop shall not exceed 20 percent of the test pres-
sure (B).
6.1.5 Inflate the suit until the pressure inside is equal to
pressure (A), the pre-test expansion suit pressure. Allow at
least one minute to fill out the wrinkles in the suit. Release suf-
ficient air to reduce the suit pressure to pressure (B), the suit
test pressure. Begin timing. At the end of three minutes, rec-
ord the suit pressure as pressure (C), the ending suit pressure.
The difference between the suit test pressure and the ending
suit test pressure (B-C) shall be defined as the suit pressure
drop.
6.1.6 If the suit pressure drop is more than 20 percent of the
suit test pressure (B) during the three-minute test period, the
suit fails the test and shall be removed from service.
7.0—Retest Procedure
7.1 If the suit fails the test check for leaks by inflating the
suit to pressure (A) and brushing or wiping the entire suit
(including seams, closures, lens gaskets, glove-to-sleeve joints,
etc.) with a mild soap and water solution. Observe the suit for
the formation of soap bubbles, which is an indication of a leak.
Repair all identified leaks.
7.2 Retest the TECP suit as outlined in Test procedure 6.0.
8.0—Report
8.1 Each TECP suit tested by this practice shall have the fol-
lowing information recorded:
8.1.1 Unique identification number, identifying brand name,
date of purchase, material of construction, and unique fit fea-
tures, e.g., special breathing apparatus.
8.1.2 The actual values for test pressures (A), (B), and (C)
shall be recorded along with the specific observation times. If
the ending pressure (C) is less than 80 percent of the test pres-
Change 51
330.25
28
1910.120 Appendix A
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1910.120 Appendix A
OCCUPATIONAL SAFETY AND HEALTH
ft
STANDARDS AND INTERPRETATION'S
sure (B), the suit shall be identified as failing the test. When
possible, the specific leak location shall be identified in the test
records. Retest pressure data shall be recorded as an additional
test.
8,1.3 The source of the test apparatus used shall be identified
and the sensitivity of the pressure gauge shall be recorded.
8.1.4 Records shall be kept for each pressure test even if
repairs are being made at the test location.
Caution
Visually inspect all parts of the suit to be sure they are posi-
tioned correctly and secured tightly before putting the suit
back into service. Special care should be taken to examine each
exhaust valve to make sure it is not blocked.
Care should also be exercised to assure that the inside and
outside of the suit is completely dry before it is put into stor-
age.
B. Totally-encapsulating chemical protective suit qualitative
leak test.
1.0—Scope
I.I This practice semi-qualitatively tests gas tight totally-
encapsulating chemical protective suit integrity by detecting
inward leakage of ammonia vapor. Since no modifications are
made to the suit to carry out this test, the results from this
practice provide a realistic test for the integrity of the entire
suit.
1.2 Resistance of the suit materials to permeation, penetra-
tion, and degradation is not determined by this test method.
ASTM test methods are available to test suit materials for
these characteristics and the tests are usually conducted by the
manufacturers of the suits.
2.0—Definition of terms
2.1 "Totally-encapsulated chemical protective suit (TECP
suit) means a full body garment which is constructed of protec-
tive clothing materials; covers the wearer's torso, head, arms,
legs and respirator; may cover the wearer's hands and feet with
tightly attached gloves and boots; completely encloses the
wearer and respirator by itself or in combination with the
wearer's gloves, and boots.
2.2 "Protective clothing material" means any material or
combination of materials used in an item of clothing for the pur-
pose of isolating parts of the body from direct contact with a
potentially hazardous liquid or gaseous chemicals.
2.3 "Gas tight" means, for the purpose of this test method,
the limited flow of a gas under pressure from the inside of a
TECP suit to atmosphere at a prescribed pressure and time
interval.
2.4 "Intrusion Coefficient" means a number expressing the
level of protection provided by a gas tight totally-encapsulating
chemical protective suit. The intrusion coefficient is calculated
by dividing the test room challenge agent concentration by the
concentration of challenge agent found inside the suit. The
accuracy of the intrusion coefficient is dependent on the chal-
lenge agent monitoring methods. The larger the intrusion
coefficient the greater the protection provided by the TECP
suit.
3.0—Summary of recommended practice
3.1 The volume of concentrated aqueous ammonia solution
(ammonia hydroxide NH4OH) required to generate the test
atmosphere is determined using the directions outlined in 6.1.
The suit is donned by a person wearing the appropriate respira-
tory equipment (either a positive pressure self-contained
breathing apparatus or a positive pressure supplied air respira-
tor) and worn inside the enclosed test room. The concentrated
aqueous ammonia solution is taken by the suited individual into
the test room and poured into an open plastic pan. A two-
minute evaporation period is observed before the test room
concentration is measured, using a high range ammonia length
of stain detector tube. When the ammonia vapor reaches a con-
centration of between 1000 and 1200 ppm, the suited individual
starts a standardized exercise protocol to stress and flex the
suit. After this protocol is completed, the test room concentra-
tion is measured again. The suited individual exits the test
room and his stand-by person measures the ammonia con-
centration inside the suit using a low range ammonia length of
stain detector tube or other more sensitive ammonia detector.
A stand-by person is required to observe the test individual
during the test procedure; aid the person in donning and doff-
ing the TECP suit; and monitor the suit interior. The intrusion
coefficient of the suit can be calculated by dividing the average
test area concentration by the interior suit concentration. A
colorimetric ammonia indicator strip of bromophenol blue or
equivalent is placed on the inside of the suit face piece lens so
that the suited individual is able to detect a color change and
know if the suit has a significant leak. If a color change is
observed the individual shall leave the test room immediately.
4.0—Required supplies
4.1 A supply of concentrated aqueous (58 percent ammonium
hydroxide by weight).
4.2 A supply of bromophenol/blue indicating paper or equiv-
alent, sensitive to 5-10 ppm ammonia or greater over a two-
minute period of exposure. [pH 3.0 (yellow) to pH 4.6 (blue))
4.3 A supply of high range (0.5-10 volume percent) and low
range (5-700 ppm) detector tubes for ammonia and the corre-
sponding sampling pump. More sensitive ammonia detectors
can be substituted for the low range detector tubes to improve
the sensitivity of this practice.
4.4 A shallow plastic pan (PVC) at least 12":14":1" and a half
pint plastic container (PVC) with tightly closing lid.
4,5 A graduated cylinder or other volumetric measuring
device of at least 50 milliliters in volume with an accuracy of at
least ± 1 milliliters.
5.0—Safety precautions
5.1 Concentrated aqueous ammonium hydroxide. NH,OH. is
a corrosive volatile liquid requiring eye, skin, and respiratory
protection. The person conducting the test shall review the
MSDS for aqueous ammonia.
1910.120 Appendix A
330.26
29
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1910.120 Appendix A
STANDARDS AND INTERPRETATIONS
5.2 Since the established permissible exposure limit for
ammonia is 50 ppm, only persons wearing a positive pressure
self-contained breathing apparatus or a positive pressure sup-
plied air respirator shall be in the chamber. Normally only the
person wearing the totally-encapsulating suit will be inside the
chamber. A stand-by person shall have a positive pressure self-
contained breathing apparatus, or a positive pressure supplied
air respirator available to enter the test area should the suited
individual need assistance.
5.3 A method to monitor the suited individual must be used
during this test. Visual contact is the simplest but other
methods using communication devices are acceptable.
5.4 The test room shall be large enough to allow the exercise
protocol to be carried out and then to be ventilated to allow for
easy exhaust of the ammonia test atmosphere after the test(s)
are completed.
5.5 Individuals shall be medically screened for the use of res-
piratory protection and checked for allergies to ammonia before
participating in this test procedure.
6.0—Test procedure
8.1.1 Measure the test area to the nearest foot and calculate
its volume in cubic feet. Multiply the test area volume by 0.2
milliliters of concentrated aqueous ammonia solution per cubic
foot of test area volume to determine the approximate volume
of concentrated aqueous ammonia required to generate 1000
ppm in the test area.
S.1.2 Measure this volume from the supply of concentrated
aqueous ammonia and place it into a closed plastic container.
6.1.3 Place the container, several high range ammonia detec-
tor tubes, and the pump in the clean test pan and locate it near
the test area entry door so that the suited individual has easy
access to these supplies.
K.2.1 In a non-contaminated atmosphere, open a pre-sealed
ammonia indicator strip and fasten one end of the strip to the
inside of the suit face shield lens where it can be seen by the
wearer. Moisten the indicator strip with distilled water. Care
shall be taken not to contaminate the detector part of the
indicator paper by touching it. A small piece of masking tape or
equivalent should be used to attach the indicator strip to the
interior of the suit face shield.
K.2.2 If problems are encountered with this method of attach-
ment, the indicator strip can be attached to the outside of the
respirator face piece lens being used di'ring the test.
8.3 Don the respiratory protective device normally used with
the suit, and then don the TECP suit to be tested. Check to be
sure all openings which are intended to be sealed (zippers.
gloves, etc.) are completely sealed. DO NOT, however, plug off
any venting valves.
ti.4 Step into the enclosed test room such as a closet, bath-
loorn, or test booth, equipped with an exhaust fan. No air
should be exhausted from the chamber during the test because
this will dilute the ammonia challenge concentrations.
ii.5 Open the container with the premeasured volume of con-
centrated aqueous ammonia within the enclosed test room, and
pour the liquid into the empty plastic test pan. Wait two min-
utes to allow for adequate volatilization of the concentrated
aqueous ammonia. A small mixing fan can be used near the
evaporation pan to increase the evaporation rate of the
ammonia solution.
6.6 After two minutes a determination of the ammonia con-
centration within the chamber should be made using the high
range colorimetric detector tube. A concentration of 1000 ppm
ammonia or greater shall be generated before the exercises are
started.
6.7 To test the integrity of the suit the following four minute
exercise protocol should be followed:
6.7.1 Raising the arms above the head with at least 15 raising
motions completed in one minute.
6.7.2 Walking in place for one minute with at least 15 raising
motions of each leg in a one-minute period.
6.7.3 Touching the toes with at least 10 complete motions of
the arms from above the head to touching of the toes in a one-
minute period.
6.7.4 Knee bends with at least 10 complete standing and
squatting motions in a one-minute period.
6.8 If at any time during the test the colorimetric indicating
paper should change colors, the test should be stopped and sec-
tion 6.10 and 6.12 initiated (See
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1910.120 Appendix A
OCCUPATIONAL SAFETY AND HEALTH
i
STANDARDS AND INTERPRETATIONS
7.0—Retest procedures
7.1 If the suit fails this test, check for leaks by following the
pressure test in test A above.
7.2 Retest the TECP suit as outlined in the test procedure
6.0.
8.0—Report
8.1 Each gas tight totally-encapsulating chemical -protective
suit tested by this practice shall have the following information
recorded.
8.1.1 Unique identification number, identifying brand name,
date of purchase, material of construction, and unique suit fea-
tures; e.g., special breathing apparatus.
8.1.2 General description of test room used for test.
8.1.3 Brand name and purchase date of ammonia detector
strips and color change data.
8.1.4 Brand name, sampling range, and expiration date of the
length of stain ammonia detector tubes. The brand name and
model of the sampling pump should also be recorded. If another
type of ammonia detector is used, it should be identified along
with its minimum detection limit for ammonia.
8.1.5 Actual test results shall list the two test area con-
centrations, their average, the interior suit concentration, and
the calculated intrusion coefficient. Retest data shall be
recorded as an additional test.
8.2 The evaluation of the data shall be specified as "suit
passed" or "suit failed," and the date of the test. Any detect-
able ammonia (five ppm or greater for the length of stain detec-
tor tube) in the suit interior indicates the suit has failed this
test. When other ammonia detectors are used, a lower level of
detection is possible and it should be specified as the pass fail
criteria.
Caution
Visually inspect all parts of the suit to be sure they are posi-
tioned correctly and secured tightly before putting the suit
back into service. Special care should be taken to examine each
exhaust valve to make sure it is not blocked.
Care should also be exercised to assure that the inside and
outside of the suit is completely dry before it is put into stor-
age.
Appendix B—General Description and Discussion of the
Levels of Protection and Protective Gear
This appendix sets forth information about personal protec-
tive equipment (PPE) protection levels which may be used to
assist employers in complying with the PPE requirements of
this section.
As required by the standard, PPE must be selected which
will protect employees from the specific hazards which they are
likely to encounter during their work on-site.
Selection of the appropriate PPE is a complex process which
should take into consideration a variety of factors. Key factors
involved in this process are identification of the hazards, or sus-
pected hazards; their routes of potential hazard to employees
(inhalation, skin absorption, ingestion, and eye or skin contact);
and the performance of the PPE materials (and seams) in
providing a barrier to these hazards. The amount of protection
provided by PPE is material-hazard specific. That is, protective
equipment materials will protect well against some hazardous
substances and poorly, or not at all, against others. In many
instances, protective equipment materials cannot be found
which will provide continuous protection from the particular
hazardous substance. In these cases the breakthrough time of
the protective material should exceed the work durations, or
the exposure after breakthrough may not pose a hazardous
level.
Other factors in this selection process to be considered are
matching the PPE to the employee's work requirements and
task-specific conditions. The durability of PPE materials, such
as tear strength and seam strength, should be considered in
relation to the employee's tasks. The effects of PPE in relation
to heat stress and task duration are a factor in selecting and
using PPE. In some cases layers of PPE may be necessary to
provide sufficient protection, or to protect expensive PPE
inner garments, suits or equipment.
The more that is known about the hazards at the site, the
easier the job of PPE selection becomes. As more information
about the hazards and conditions at the site becomes available,
the site supervisor can make decisions to up-grade or down-
grade the level of PPE protection to match the tasks at hand.
The following are guidelines which an employer can use to
begin the selection of the appropriate PPE. As noted above,
the site information may suggest the use of combinations of
PPE selected from the different protection levels (i.e., A, B, C,
or D) as being more suitable to the hazards of the work. It
should be cautioned that the listing below does not fully
address the performance of the specific PPE material in rela-
tion to the specific hazards at the job site, and that PPE selec-
tion, evaluation and re-selection is an ongoing process until
sufficient information about the hazards and PPE performance
is obtained.
Part A. Personal protective equipment is divided into four
categories based on the degree of protection afforded. (See
Part B of this appendix for further explanation of Levels A, B,
C, and D hazards.)
I. Level A—To be selected when the greatest level of skin,
respiratory, and eye protection is required.
The following constitute Level A equipment; it may be used
as appropriate:
1. Positive pressure, full face-piece self-contained breathing
apparatus (SCBA), or positive pressure supplied air respirator
with escape SCBA, approved by the National Institute for
Occupational Safety and Health (NIOSH).
2. Totally-encapsulating chemical-protective suit.
1910.120 Appendix B
330.28
31
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OCCUPATIONAL SAFETY AND HEALTH
1910.120 Appendix B
STANDARDS AND INTERPRETATION'S
3. Coveralls.1
4. Long underwear.'
5. Gloves, outer, chemical-resistant.
fi. Gloves, inner, chemical-resistant.
7. Boots, chemical-resistant, steel toe and shank.
8. Hard hat (under suit)."
9. Disposable protective suit, gloves and boots (depending on
suit construction, may be worn over totally-encapsulating suit).
II. Level B—The highest level of respiratory protection is
necessary but a lesser level of skin protection is needed.
The following constitute Level B equipment; it may be used
as appropriate.
1. Positive pressure, full-facepiece self-contained breathing
apparatus (SCBA), or positive pressure supplied air respirator
with escape SCBA (NIOSH approved).
2. Hooded chemical-resistant clothing (overalls and long-
sleeved jacket; coveralls; one or two-piece chemical-splash suit;
disposable chemical-resistant overalls).
3. Coveralls.1
4. Gloves, outer, chemical-resistant.
5. Gloves, inner, chemical-resistant.
6. Boots, outer, chemical-resistant steel toe and shank.
7. Boot-covers, outer, chemical-resistant (disposable).1
8. Hard hat.1
9. [Reserved)
10. Face shield.1
III. Level C—The concentration(s) and type(s) of airborne
substance(s) is known and the criteria for using air purifying
respirators are met.
The following constitute Level C equipment; it may be used
as appropriate.
1. Full-face or half-mask, air purifying respirators (NIOSH
approved).
2. Hooded chemical-resistant clothing (overalls; two-piece
chemical-splash suit; disposable chemical-resistant overalls).
3. Coveralls.1
4. Gloves, outer, chemical-resistant.
'Optional, as applicable.
Change 51
5. Gloves, inner, chemical-resistant.
6. Boots (outer), chemical-resistant steel toe and shank.1
7. Boot-covers, outer, chemical-resistant (disposable).'
8. Hard hat.1
9. Escape mask.1
10. Face shield.1
IV. Level D—A work uniform affording minimal protection.
used for nuisance contamination only.
The following constitute Level D equipment; it may be used
as appropriate:
1. Coveralls.
2. Gloves.1
3. Boots/shoes, chemical-resistant steel toe and shank.
4. Boots, outer, chemical-resistant (disposable).'
5. Safety glasses or chemical splash goggles*.
6. Hard hat.'
7. Escape mask.1
8. Face shield.1
Part B. The types of hazards for which levels A, B, C, and D
protection are appropriate are described below:
I. Level A—Level A protection should be used when:
1. The hazardous substance has been identified and requires
the highest level of protection for skin, eyes, and the respira-
tory system based on either the measured (or potential for)
high concentration of atmospheric vapors, gases, or particu-
lates; or the site operations and work functions involve a high
potential for splash, immersion, or exposure to unexpected
vapors, gases, or particulates of materials that are harmful to
skin or capable of being absorbed through the 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 are being conducted in confined, poorly venti-
lated areas, and the absence of conditions requiring Level A
have not yet been determined.
II. Level B—Level B protection should be used when:
1. The type and atmospheric concentration of substances
have been identified and require a high level of respiratory pro-
tection, but less skin protection;
2. The atmosphere contains less than 19.5 percent oxygen: or
3. The presence of incompletely identified vapors or gases is
indicated by a direct-reading organic vapor detection instru-
ment, but vapors and gases are not suspected of containing
high levels of chemicals harmful to skin or capable of being
absorbed through the skin.
330.
32
29
1910.120 Appendix B
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1910.120 Appendix B
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
Note: This involves atmospheres with IDLH concentrations
of specific substances that present severe inhalation hazards
iind that do not represent a severe skin hazard; or that do not
meet the criteria for use of air-purifying respirators.
III. Level C—Level C protection should be used when:
I. The atmospheric contaminants, liquid splashes, or other
direct contact will not adversely affect or be absorbed through
any exposed skin:
2. The types of air contaminants have been identified, con-
centrations measured, and an air-purifying respirator is avail-
able that can remove the contaminants; and
3. All criteria for the use of air-purifying respirators are met.
IV. Level D—Level D protection should be used when:
1. The atmosphere contains no known hazard; and
2. Work functions preclude splashes, immersion, or the
potential for unexpected inhalation of or contact with hazardous
levels of any chemicals.
Note: As stated before, combinations of personal protective
equipment other than those described for Levels A. B, C. and
D protection may be more appropriate and may be used to
provide the proper level of protection.
As an aid in selecting suitable chemical protective clothing, it
should be noted that the National Fire Protection Association is
developing standards on chemical protective clothing. These
standards are currently undergoing public review prior to
adoption, including:
NFPA 1991—Standard on Vapor-Protective Suits for Haz-
ardous Chemical Emergencies (EPA Level A Protective
Clothing)
NFPA 1991—Standard on Liquid Splash-Protective Suits for
Hazardous Chemical Emergencies (EPA Level B Protective
Clothing.)
NFPA 1993—Standard on Liquid Splash-Prptective Suits for
Non-emergency, Non-flammable Hazardous Chemical Situa-
tions (EPA Level B Protective Clothing)
These standards would apply documentation and perform-
ance requirements to the manufacture of chemical protective
suits. Chemical protective suits meeting these requirements
would be labelled as compliant with the appropriate standard.
When these standards are adopted by the National Fire Protec-
tion Association, it is recommended that chemical protective
suits which meet these standards be used.
Appendix C — Compliance Guidelines
1. Occupational Safety and Health Program. Each haz-
ardous waste site clean-up effort will require an occupational
safety and health program headed by the site coordinator or
the employer's representative. The purpose of the program will
be the protection of employees at the site and will be an exten-
sion of the employer's overall safety and health program. The
program will need to be developed before work begins on the
site and implemented as work proceeds as stated in paragraph
(b). The program is to facilitate coordination and communica-
tion of safety and health issues among personnel responsible for
the various activities which will take place at the site. It will
provide the overall means for planning and implementing the
needed safety and health training and job orientation ot
employees who will be working at the site. The program will
provide the means for identifying and controlling worksite haz-
ards and the means for monitoring program effectiveness. The
program will need to cover the responsibilities and authority of
the site coordinator or the employer's manager on the site for
the safety and health of employees at the site, and the relation-
ships with contractors or support services as to what each
employer's safety and health responsibilities are for their
employees on the site. Each contractor on the site needs to
have its own safety and health program so structured that it
will smoothly interface with the program of the site coordinator
or principal contractor.
Also those employers involved with treating, storing or dis-
posal of hazardous waste as covered in paragraph (p) must have
implemented a safety and health program for their employees.
This program is to include the hazard communication program
required in paragraph (p)(l) and the training required in para-
graphs (p)(7) and (p)(8) as parts of the employers comprehen-
sive overall safety and health program. This program is to be in
writing.
Each site or workplace safety and health program will need
to include the following: (1) Policy statements of the line of
authority and accountability for implementing the program, the
objectives of the program and the role of the site safety and
health supervisor or manager and staff; (2) means or methods
for the development of procedures for identifying and controll-
ing workplace hazards at the site; (3) means or methods for the
development and communication to employees of the various
plans, work rules, standard operating procedures and practices
that pertain to individual employees and supervisors; (4) means
for the training of supervisors and employees to develop the
needed skills and knowledge to perform their work in a safe
and healthful manner; (5) means to anticipate and prepare for
emergency situations; and (6) means for obtaining information
feedback to aid in evaluating the program and for improving
the effectiveness of the program. The management and
employees should be trying continually to improve the effec-
tiveness of the program thereby enhancing the protection being
afforded those working on the site.
Accidents on the site or workplace should be investigated to
provide information on how such occurrences can be avoided in
the future. When injuries or illnesses occur on the site or work-
place, they will need to be investigated to determine what
needs to be done to prevent this incident from occurring again.
Such information will need to be used as feedback on the effec-
tiveness of the program and the information turned into posi-
tive steps to prevent any reoccurrence. Receipt of employee
suggestions or complaints relating to safety and health issues
involved with site or workplace activities is also a feedback
mechanism that can be used effectively to improve the program
and may serve in part as an evaluative tool(s).
For the development and implementation of the program to
be the most effective, professional safety and health personnel
should be used. Certified Safety Professionals, Board Certified
Industrial Hygienists or Registered Professional Safety Engi-
neers are good examples of professional stature for safety and
health managers who will administer the employer's program.
2. Training. The training programs for employees subject to
the requirements of paragraph (e) of this standard should
address: the safety and health hazards employees should expect
1910.120 Appendix C
330.30
33
Change 3!
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OCCUPATIONAL SAFETY AND HEALTH
1910.120 Appendix C
STANDARDS AND INTERPRETATIONS
to find on hazardous waste clean-up sites; what control meas-
ures or techniques are effective for those hazards; what
monitoring procedures are effective in characterizing exposure
levels; what makes an effective employer's safety and health
program; what a site safety and health plan should include;
hands on training with personal protective equipment and
clothing they may be expected to use; the contents of the
OSHA standard relevant to the employee's duties and function;
and, employee's responsibilities under OSHA and other regula-
tions. Supervisors will need training in their responsibilities
under the safety and health program and its subject areas such
as the spill containment program, the personal protective
equipment program, the medical surveillance program, the
en.ergency response plan and other areas.
The training programs for employees subject to the require-
ments of paragraph (p) of this standard should address: the
employers safety and health program elements impacting
employees; the hazard communication program; the medical
surveillance program; the hazards and the controls for such
hazards that employees need to know for their job duties and
functions. All require annual refresher training.
The training programs for employees covered by the require-
ments of paragraph (q) of this standard should address those
competencies required for the various levels of response such
as: the hazards associated with hazardous substances; hazard
identification and awareness; notification of appropriate per-
sons; the need for and use of personal protective equipment
including respirators; the decontamination procedures to be
used; preplanning activities for hazardous substance incidents
including the emergency response plan; company standard
operating procedures for hazardous substance emergency
responses; the use of the incident command system and other
subjects. Hands-on training should be stressed whenever possi-
ble. Critiques done after an incident which include an evalua-
tion of what worked and what did not and how could the
incident be better handled the next time may be counted as
training time.
For hazardous materials specialists (usually members of haz-
ardous materials teams), the training should address the care,
use and/or testing of chemical protective clothing including
totally encapsulating suits, the medical surveillance program.
the standard operating procedures for the hazardous materials
team including the use of plugging and patching equipment and
other subject areas.
Officers and leaders who may be expected to be in charge at
an incident should be fully knowledgeable of their company's
incident command system. They should know where and how to
obtain additional assistance and be familiar with the local dis-
trict's emergency response plan and the state emergency
response plan.
Specialist employees such as technical experts, medical
experts or environmental experts that work with hazardous
materials in their regular jobs, who may be sent to the incident
scene by the shipper, manufacturer or governmental agency to
udvise and assist the person in charge of the incident should
have training on an annual basis. Their training should include
the care and use of personal protective equipment including
respirators; knowledge of the incident command system and
how they are to relate to it; and those areas needed to keep
them current in their respective field as it relates to safety and
health involving specific hazardous substances.
Those skilled support personnel, such as employees who
work for public works departments or equipment operators
who operate bulldozers, sand trucks, backhoes. etc., who may
be called to the incident scene to provide emergency support
assistance, should have at least a safety and health briefing
before entering the area of potential or actual exposure. These
skilled support personnel, who have not been a part of the
emergency response plan and do not meet the training require-
ments, should be made aware of the hazards they face and
should be provided all necessary protective clothing and equip-
ment required for their tasks.
3. Decontamination. Decontamination procedures should be
tailored to the specific hazards of the site, and may vary in
complexity and number of steps, depending on the level of haz-
ard and the employee's exposure to the hazard. Decontamina-
tion procedures and PPE decontamination methods will vary
depending upon the specific substance, since one procedure or
method may not work for all substances. Evaluation of decon-
tamination methods and procedures should be performed, as
necessary, to assure that employees are not exposed to hazards
by re-using PPE. References in Appendix F may be used for
guidance in establishing an effective decontamination program.
In addition, the U.S. Coast Guard's Manual, "Policy Guidance
for Response to Hazardous Chemical Releases." U.S. Depart-
ment of Transportation, Washington, DC (COMDTINST
M16465.30) is a good reference for establishing an effective
decontamination program.
4. Emergency response plans. States, along with designated
districts within the states, will be developing or have developed
local emergency response plans. These state and district plans
should be utilized in the emergency response plans called for in
the standard. Each employer should assure that its emergency
response plan is compatible with the local plan. The major ref-
erence being used to aid in developing the state and local dis-
trict plans is the Hazardous Materials Emergency Planning
Guide, NRT—1. The current Emergency Response Guidebook
from the U.S. Department of Transportation, CMA's CHEM-
TREC and the Fire Service Emergency Management Hand-
book may also be used as resources.
Employers involved with treatment, storage, and disposal
facilities for hazardous waste, which have the required con-
tingency plan called for by their permit, would not need to
duplicate the same planning elements. Those items of the
emergency response plan that are properly addressed in the
contingency plan may be substituted into the emergency
response plan required in 1910.120 or otherwise kept together
for employer and employee use.
5. Personal protective equipment programs. The purpose of
personal protective clothing and equipment (PPE) is to shield
or isolate individuals from the chemical, physical, and biologic
hazards that may be encountered at a hazardous substance site.
As discussed in Appendix B, no single combination of protec-
tive equipment and clothing is capable of protecting against all
hazards. Thus PPE should be used in conjunction with other
protective methods and its effectiveness evaluated periodically.
The use of PPE can itself create significant worker hazards,
such as heat stress, physical and psychological stress, and
impaired vision, mobility, and communication. For any given
situation, equipment and clothing should be selected that
provide an adequate level of protection. However, over-
protection, as well as under-protection, can be hazardous and
should be avoided uhere possible.
Two basic objectives of any PPE program should be to pro-
tect the wearer from safety and health hazards, and to prevent
Change 51
330.31
1910.120 Appendix C
34
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1910.120 Appendix C
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
injury to the wearer from incorrect use and/or malfunction of
the PPE. To accomplish these goals, a comprehensive PPE pro-
gram should include hazard identification, medical monitoring,
environmental surveillance, selection, use, maintenance, and
decontamination of PPE and its associated training.
The written PPE program should include policy statements,
procedures, and guidelines. Copies should be made available to
all employees, and a reference copy should be made available at
the worksite. Technical data on equipment, maintenance man-
uals, relevant regulations, and other essential information
should alsoie collected and maintained.
6. Incident command system (ICS). Paragraph
1910.120(q)(3)(ii) requires the implementation of an ICS. The
ICS is an organized approach to effectively control and manage
operations at an emergency incident. The individual in charge
of the ICS is the senior official responding to the incident. The
ICS is not much different than the "command post" approach
used for many years by the fire service. During large complex
fires involving several companies and many pieces of appa-
ratus, a command post would be established. This enabled one
individual to be in charge of managing the incident, rather than
having several officers from different companies making sepa-
rate, and sometimes conflicting, decisions. The individual in
charge of the command post would delegate responsibility for
performing various tasks to subordinate officers. Additionally,
all communications were routed through the command post to
reduce the number of radio transmissions and eliminate confu-
sion. However, strategy, tactics, and all decisions were made
by one individual.
The ICS is a very similar system, except it is implemented
for emergency response to all incidents, both large and small,
that involve hazardous substances.
For a small incident, the individual in charge of the ICS may
perform many tasks of the ICS. There may not be any, or little,
delegation of tasks to subordinates. For example, in response
to a small incident, the individual in charge of the ICS, in addi-
tion to normal command activities, may become the safety
officer and may designate only one employee (with proper
equipment) as a backup to provide assistance if needed. OSHA
does recommend, however, that at least two employees be des-
ignated as back-up personnel since the assistance needed may
include rescue.
To illustrate the operation of the ICS, the following scenario
might develop during a small incident, such as an overturned
tank truck with a small leak of flammable liquid.
The first responding senior officer would implement and take
command of the ICS. That person would size-up the incident
and determine if additional personnel and apparatus were nec-
essary; would determine what actions to take to control the
leak; and, determine the proper level of personal protective
equipment. If additional assistance is not needed, the individual
in charge of the ICS would implement actions to stop and con-
trol the leak using the fewest number of personnel that can
effectively accomplish the tasks. The individual in charge of the
ICS then would designate himself as the safety officer and two
other employees as a back-up in case rescue may become neces-
sary. In this scenario, decontamination procedures would not
be necessary.
A large complex incident may require many employees and
difficult, time-consuming efforts to control. In these situations,
the individual in charge of the ICS will want to delegate dif-
ferent tasks to subordinates in order to maintain a span of con-
trol that will keep the number of subordinates, that are
reporting, to a manageable level
Delegation of task at large incidents may be by location.
where the incident scene is divided into sectois. and subordi-
nate officers coordinate activities within the sector that they
have been assigned.
Delegation of tasks can also be by function. Some of the func-
tions that the individual in charge of the ICS may want to dele-
gate at a large incident are: medical services; evacuation; water
supply; resources (equipment, apparatus); media relations;
safety; and, site control (integrate activities with police for
crowd and traffic control). Also for a large incident, the individ-
ual in charge of the ICS will designate several employees as
back-up personnel; and a number of safety officers to monitor
conditions and recommend safety precautions.
Therefore, no matter what size or complexity an incident
may be, by implementing an ICS there will be one individual
in charge who makes the decisions and gives directions; and, all
actions, and communications are coordinated through one cen-
tral point of command. Such a system should reduce confusion,
improve safety, organize and coordinate actions, and should
facilitate effective management of the incident.
7. Site Safety and Control Plan?. The safety and security of
response personnel and others in the area of an emergency
response incident site should be of primary concern to the inci-
dent commander. The use of a site safety and control plan could
greatly assist those in charge of assuring the safety and health
of employees on the site.
A comprehensive site safety and control plan should include
the following: summary analysis of hazards on the site and a
risk analysis of those hazards; site map or sketch; site work
zones (clean zone, transition or decontamination zone, work or
hot zone); use of the buddy system; site communications; com-
mand post or command center; standard operating procedures
and safe work practices; medical assistance and triage area;
hazard monitoring plan (air contaminate monitoring, etc.);
decontamination procedures and area; and other relevant areas.
This plan should be a part of the employer's emergency
response plan or an extension of it to the specific site.
8. Medical surveillance programs. Workers handling haz-
ardous substances may be exposed to toxic chemicals, safety
hazards, biologic hazards, and radiation. Therefore, a medical
surveillance program is essential to assess and monitor
workers' health and fitness for employment in hazardous waste
operations and during the course of work; to provide
emergency and other treatment as needed: and to keep accu-
rate records for future reference.
The Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities developed by the National
Institute for Occupational Safety and Health"(NIOSH), the
Occupational Safety and Health Administration (OSHA), the
U.S. Coast Guard (USCG). and the Environmental Protection
Agency (EPA), October 1985 provides an excellent example of
the types of medical testing that should be done as part of a
medical surveillance program.
Appendix D—References
The following references may be consulted for further infor-
mation on the subject of this standard:
1. OSHA Instruction DFO CPL 2.70-^January 29. 1986. Spe-
cial Emphasis Program: Hazardous Waste Si/en.
1910.120 Appendix U
330.32
Change 51
35
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OCCUPATIONAL SAFETY AND HEALTH
1910.120 Appendix D
STANDARDS AND INTERPRETATIONS
2. OSHA Instruction DFO CPL 2-2.37A-January 29, 1986,
Technical Assistance and Guidelines for Superfund and Other
Hazardous Waste Site Activities
3. OSHA Instruction DTS CPL 2.74Wanuary 29, 1986, Haz-
ardous Waste Activity form, OSHA 175.
4. Hazardous Waste Inspections Reference Manual, U.S.
Department of Labor, Occupational Safety and Health Admin-
istration, 1986.
5. Memorandum of Understanding Among the National
Institute for Occupational Safety and Health, the Occupational
Safety and Health Administration, the United States Coast
Guard, and the United States Environmental Protection
Agency, Guidance for Worker Protection During Hazardous
Waste Site Investigations and Clean-up and Hazardous Sub-
stance Emergencies. December 18, 1980.
6. National Priorities List, 1st Edition, October 1984; U.S.
Environmental Protection Agency, Revised periodically.
7. The Decontamination of Response Personnel, Field
Standard Operating Procedures (F.S.O.P.) 7; U.S. Environ-
mental Protection Agency, Office of Emergency and Remedial
Response, Hazardous Response Support Division, December
1984.
8. Preparation of a Site Safety Plan, Field Standard Oper-
ating Procedures (F.S.O.P.) 9; U.S. Environmental Protection
Agency, Office of Emergency and Remedial Response, Haz-
ardous Response Support Division, April 1985.
9. Standard Operating Safety Guidelines; U.S. Environ-
mental Protection Agency, Office of Emergency and Remedial
Response, Hazardous Response Support Division, Environ-
mental Response Team; November 1984.
10. Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities, National Institute for
Occupational Safety and Health (NIOSH), Occupational Safety
and Health Administration (OSHA), U.S. Coast Guard
(USCG), and Environmental Protection Agency (EPA); Octo-
ber 1985.
11. Protecting Health and Safety at Hazardous Waste
Sites; An Overview, U.S. Environmental Protection Agency,
EPA/625/9—55/005; September 1985.
12. Hazardous Waste Sites and Hazardous Substance
Emergencies, NIOSH Worker Bulletin, U.S. Department of
Health and Human Services, Public Health Service, Centers
for Disease Control, National Institute for Occupational Safety
and Health; December 1982.
13. Personal Protective Equipment for Hazardous Mate-
rials Incidents: A Selection Guide; U.S. Department of
Health and Human Services, Public Health Service, Centers
for Disease Control, National Institute for Occupational Safety
and Health; October 1984.
14. Fire Service Emergency Management Handbook,
International Association of Fire Chiefs Foundation, 101 East
Holly Avenue, Unit 10B, Sterling, VA 22170, January 1985.
15. Emergency Response Guidebook, U.S. Department of
Transportation, Washington, DC, 1987.
16. Report to the Congress on Hazardous Materials Train-
ing, Planning and Preparedness, Federal Emergency Man-
agement Agency, Washington, DC, July 1986.
17. Workbook for Fire Command, Alan V. Brunacini and J.
David Beageron, National Fire Protection Association, Bat-
terymarch Park, Quincy, MA 02269, 1985.
18. Fire Command, Alan V. Brunacini, National Fire Pro-
tection, Batterymarch Park, Quincy, MA 02269, 1985.
19. Incident Command System, Fire Protection Publica-
tions, Oklahoma State University, Stillwater, OK 74078, 1983.
20. Site Emergency Response Planning, Chemical Manufac-
turers Association, Washington, DC 20037, 1986.
21. Hazardous Materials Emergency Planning Guide,
NRT-1, Environmental Protection Agency, Washington, DC,
March 1987.
22. Community Teamwork: Working Together to Promote
Hazardous Materials Transportation Safety. U.S. Depart-
ment of Transportation, Washington, DC, May 1983.
23. Disaster Planning Guide for Business and Industry,
Federal Emergency Management Agency, Publication No.
FEMA 141, August 1987.
(The Office of Management and Budget has approved the infor-
mation collection requirements in this section under control
number 1218-0139)
Change 51
330.33
36
1910.120 Appendix D
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SECTION 1
OCCUPATIONAL SAFETY AND HEALTH
REGULATIONS AND STANDARDS
PART 2
EPA ORDER 1440,2 - HEALTH AND SAFETY REQUIREMENTS
FOR EMPLOYEES ENGAGED IN FIELD ACTIVITIES
37
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ENVIRONMENTAL
PROTECTION ORDER 1440.2
W AGENCY juiy 12, 1981
PROTECTIVE SERVICES - SAFETY
HEALTH AND SAFETY REQUIREMENTS FOR EMPLOYEES ENGAGED
IN FIELD ACTIVITIES
1. PURPOSE. This order establishes policy, responsibilities,
and mandatory requirements for occupational health and safety
training and certification, and occupational medical monitoring
of Agency employees engaged in field activities.
2. DEFINITIONS.
a. The term "field activities" as used in this Order means
EPA program activities that are conducted by EPA employees
outside of EPA administered facilities. These activities include
environmental and pesticides sampling, inspection of water and
wastewater treatment plants, and hazardous material spills and
waste site investigations, inspections, and sampling.
b. The term "health and safety training" means scheduled,
formal or informal training courses, approved and sponsored by
EPA and conducted by EPA o-r its contracted agents which is
designed to develop, improve and upgrade the health and safety
knowledge of EPA employees involved in field activities.
c. The term "occupational medical monitoring" means
surveillance over the health status of employees by means of
periodic medical examinations or screening in accordance with the
Agency's Occupational Medical Monitoring guidelines.
d. The term "certification" as used in this Order means
that the employee has successfully completed the minimum
classroom and field training requirements for the specified level
of training and the Agency has issued a certificate attesting
that the employee met those requirements.
Dist: Directives Distribution Initiated by: PM-273
39
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ORDER _ 144°'2
July 12, 1981
3. REFERENCES.
a. 29 CFR 1910, Parts 16, 94, 96, 106, 109, 111, 134, 151,
1000, Occupational Health and Safety Standards
b. Executive Order 12196, Section 1-201, Sec. (k),
Occupational Health and Safety Programs for Federal Employees.
c. 29 CFR 1960.59(a), Occupational Safety and Health for
the Federal Employee.
d. EPA Occupational Health and Safety Manual, Chapter 7(1).
e. EPA Training and Development Manual, Chapter 3, Par
7(b).
f. Occupational Health and Safety Act of 1971, P.L. 91-596,
Sec. 6.
g. EPA Order on Respiratory Protection (Proposed).
h. 49 CFR, Parts 100-177, Transportation of Hazardous
Materials.
i. EPA Order 1000.18, Transportation of Hazardous
Materials.
j. EPA Order 3100.1, Change 1, Uniforms, Protective
Clothing, and Protective Equipment.
4. BACKGROUND. Field activities are a critical part of most
EPA programs. These activities range from routine environmental
reconnaisance sampling, inspections, and monitoring, to entering
and working in environments with known and unknown hazards.
Since protection cannot be engineered into the field working
situation, the protection of personnel engaged in field
activities involves training employees in safe operational
procedures and the proper use of appropriate personal protective
clothing and equipment.
5. APPLICABILITY. This Order applies to all E"BA organizational
units which have employees engaged in field activities.
6. POLICY. It is the policy of the Environmental Protection
Agency to carry out its field activities in a manner that assures
the protection of its employees.
40
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ORDER 144°'2
July 12, 1981
7. RESPONSIBILITIES.
a. Assistant Administrators, Regional Administrators,
Deputy Assistant Administrators, Laboratory Directors, and
Division Directors. These officials are responsible within their
jurisdictions for implementing the provisions of this Order and
for budgeting the necessary funds for employee training and
certification, personal protective clothing and equipment, and
occupational medical monitoring programs.
b. Supervisors. Supervisors are responsible for complying
with the requirements of this Order for employee training and
certification, and occupational medical monitoring programs.
They will identify those employees who require training and
certification, and occupational medical monitoring, and assure
they receive it to comply with the provisions of this Order and
will insure these requirements are properly contained in position
descriptions and job postings.
"C. Employees. Employees are responsible for making known
upon request from their supervisors the extent of their
individual occupational health and safety training and the
history of their occupational medical monitoring participation.
Employees should notify their supervisor of any hazardous work
situation and make suggestions for corrective measures.
Employees are responsible for applying the knowledge, skills, and
techniques acquired through training in a manner that will help
assure their health and safety and that of fellow workers.
d. Occupational Health and Safety Designees. The
Occupational Health and Safety Designees are responsible for
identifying program areas that require training and
certification, and occupational medical monitoring; recommending
or providing training and certification resources to meet the
requirements of this Order; and maintaining records of persons
receiving training and certification.
e. Office of Occupational Health and Safety. The Director,
Office of Occupational Health and Safety is responsible for
establishing policy and requirements for adequate training and
certification programs for field activities, developing and
maintaining an occupational medical monitoring program, approving
health and safety training and certification programs for
employees involved in field activities, and for evaluating the
results of these training and certification programs.
41
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ORDER 144°'2
July 12, 1981
8. OBJECTIVES.
a, Training and Certification. The objectives of the
health and safety training and certification programs for
employees involved in field activities are:
(1) To assure that EPA employees are aware of the
potential hazards they amy encounter during the performance of
field activities;
(2) To provide the knowledge and skills necessary to
perform the work with the least possible risk to personal health
and safety;
(3) To assure that Agency program goals are
accomplished in as safe and healthful manner as feasible; and
(4) To assure that EPA employees can safely disengage
themselves from an actual hazardous situation which may occur
during a field activity.
b- Occupational Medical Monitoring. The objectives of the
occupational Medical Monitoring program are:
(1) To detect any adverse effects of occupational
exposure on the employees health and to initiate prompt
corrective actions when indicated; and
(2) To assure that employees assigned arduous or
physically taxing jobs or jobs requiring unique skills are able
to perform those jobs without impairing their health and safety
or the health and safety of others.
9. TRAINING AND CERTIFICATION REQUIREMENTS. Employees shall
not be permitted to engage in routine field activities until
they have been trained and certified to a level commensurate with
the degree of anticipated hazards.
a. Basic Level. All employee shall be provided a minimum
of 24 hours of health and safety training prior to their becoming
involved in normal, routine field activities. The training shall
include but not be limited to classroom instruction in all the
following subject areas:
42
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ORDER 1440'2
July 12, 1981
(1) Employee Rights and Responsibilities;
(2) Nature of Anticipated Hazards;
(3) Emergency Help and Self-Rescue;
(4) Vehicles - Mandatory Rules and Regulations;
(5) Safe Use of Field Equipment;
(6) Use, Handling, Storage, and Transportation of
Hazardous Materials;
(7) Personal Protective Equipment and Clothing, Use
and Care;
(8) Safe Sampling Techniques.
In addition to classroom instruction, the employee shall
accompany an employee experienced in field activities and perform
actual field tasks for a minimum of three days within a period of
three months after classroom instruction. Employees
satisfactorily completing these requirements will receive
certification at the Basic Level of training from the
Occupational Health and Safety Designee at the Reporting Unit.
b. Intermediate Level. All inexperienced employees who are
to work with experienced employees in uncontrolled hazardous
waste and hazardous spill sites investigations or employees
engaged in other activities which at a later date are determined
by the Director, Office of Occupational Health and Safety, to
present unique hazards requiring additional training, shall be
provided a minimum of 8 hours of additional health and safety
training. This training shall include (in addition to the Basic
Level requirements) but not be limited to the following subject
manner:
(1) Site surveillance, observation, and safety plan
development;
(2) Use and decontamination of totally enclosed
protective clothing and equipment;
(3) Use of field test equipment for radioactivity,
explosivity, and other measurements; and
(4) Topics specific to other identified activities.
In addition to classroom instruction, the employee shall
accompany another employee experienced in hazardous waste and
spill site investigations and/or cleanup operations and perform
actual field tasks for a minimum of three days within a period of
three months after classroom instruction. The employee should
also be able to provide on-the-job training and instructions to
inexperienced employees during normal, routine field activities
(as required above). Employees satisfactorily completing these
requirements will be certified at the Intermediate Level by the
Occupational Health and Safety Designee and the Reporting Unit.
43
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ORDER
1440.2
July 12, 1981
c. Advanced Level. All employees who manage uncontrolled
hazardous waste site and spill site monitoring, sampling,
investigations, and cleanup operations shall be provided a
minimum of 8 hours additional health and safety training. The
classroom training shall include but not be limited to (in
addition to the Basic and Intermediate Level requirements),
instruction in the following subject areas:
(1) Management of restricted and safe zones;
(2) Rules of Handling the Press and VIP's; and
(3) Safe Use of Specialized Sampling Equipment.
In addition to classroom instruction, the employee shall
accompany another employee with experience in managing hazardous
waste and spill site investigations or cleanup operations and
perform actual field tasks for a minimum of three days within a
three month period after receiving classroom instruction. After
satisfactorily completing these requirements, employees will
receive Advanced Level certification from the Occupational Health
and Safety Designee at the Reporting Unit.
d. General.
(1) An employee may receive certification at the next
higher level by completing only the additional training
requirements if certified at the next lower level within the
previous one-year period.
(2) The Director, Office of Occupational Health and
Safety, may certify employees based on an evaluation of previous
training, education, and experience. Recommendations for this
type certification should be made to the Director by the
Occupational Health and Safety Designee at the Reporting Unit.
10. FREQUENCY OF TRAINING. Employees at the Basic, Intermediate
and Advanced Levels shall complete a minimum of 8 hours of
refresher classroom instruction annually consisting of a review
of all subject areas to maintain their certification. In
addition to the classroom instruction, employees shall have
demonstrated by having performed actual field tasks that they
have sufficient practical experience to perform their assigned
duties in a sage and healthful manner.
11. RECORD OF TRAINING
a. A record of the level of training and certification
shall be maintained in the employee's official personnel file.
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1440 . 2
ORDER
July 12, 1981
b. The Occupational Health and Safety Designee shall
maintain a roster of employee training and certification so that
a schedule of annual training can be established.
c. The Occupational Health and Safety Designee shall issue
a certificate to the employee showing the level of training and
certification.
12. OCCUPATIONAL MEDICAL MONITORING REQUIREMENTS. All employees
routinely engaged in field activities which present the
probability of exposure to hazardous or toxic substances, which
are arduous or physically taxing, or which require the use of
respiratory protective equipment shall be included in the
Agency's Occupational Medical Monitoring Program. Employees
should not be permitted to engage in field activities unless they
have undergone a baseline medical examination (as defined in the
Agency's Occupational Medical Monitoring Guidelines), which will
show physical fitness and provide a base to measure any adverse
effects their activities may have on these individuals.
13. SAVINGS PROVISION. Changes in the Act, Executive Order, or
EPA and OSHA standards and guidelines which occur after the
effective date of this Order will automatically come under the
purview of this Order on the effective date of the change.
Full implementation of this Order shall be within one year of its
effective date.
Edward J. Hanley
Director, Office of Management
Information and Support Services
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SECTION 1
OCCUPATIONAL SAFETY AND HEALTH
REGULATIONS AND STANDARDS
PART 3
OTHER OSHA, FEDERAL, AND NFPA REGULATIONS AND
STANDARDS RELATED TO HAZARDOUS WASTE OPERATIONS AND
EMERGENCY RESPONSE WORKER PROTECTION
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RELATED OSHA REGULATIONS
GENERAL DUTY CLAUSE OF THE
OCCUPATIONAL SAFETY AND HEALTH
ACT (OSH Act) OF 1970
The OSH Act, Section 5(a)(l) states that each
employer "shall furnish to each of his employees
employment and a place of employment which
causing or are likely to cause death or serious
physical harm to his employees".
LOG AND SUMMARY
OCCUPATIONAL
ILLNESSES
INJURIES
O F
AND
29 CFR 1904.24 requires that each employer
maintain a log of all recordable occupational
injuries and illnesses and that the information be
recorded in the log within six working days of
the receipt of the information. Form OSHA No.
200 or its equivalent is to be used for this
purpose.
ACCESS TO EMPLOYEE EXPOSURE AND
MEDICAL RECORDS
29 CFR 1910.20 requires that an employer
provide exposure and medical records to an
employee or designated representative within
fifteen days after the request for access to
records. If the employee requests copies of this
information, the employer must make the copies
available to the employee at no cost. All
employee medical records must be maintained
by the employer for the duration of employment
plus 30 years.
EMPLOYEE EMERGENCY PLANS AND
FIRE PREVENTION PLANS
29 CFR 1910.38 applies to all emergency
action plans and fire prevention plans required
by particular OSHA standards. With the ex-
ception of employers with 10 or fewer em-
ployees, 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
employees. The employer shall also perform
housekeeping and maintenance of equipment and
systems as part of the fire prevention plan.
OCCUPATIONAL NOISE AND EXPOSURE
29 CFR 1910.95 states that 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. The OSHA-
Permissible Exposure Limit for an eight-hour
recorded on a sound level meter on the A
weighted scale. An employer shall implement a
hearing conservation program if 8-hour time
weighted average noise exposures equal or
exceed 85 decibels on the A scale. Continuous
intermittent and impulsive sound levels of 80
dBA or greater shall be integrated into the time
weighted average.
IONIZING RADIATION
29 CFR 1910.96 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
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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
employer must keep records of employee
exposure and disclose the information upon
request from a former employee.
CHEMICAL PROCESS SAFETY
29 CFR 1910.119 establishes procedures for
process safety management that will protect
employees by preventing or minimizing the
consequences of chemical accidents involving
highly hazardous chemicals.
PERSONAL PROTECTIVE EQUIPMENT
29 CFR 1910.132-1910.136 requires the
provision of personal protective equipment for
eye, face, head, and extremities in hazardous
environments. This protective equipment must
be provided, used, and maintained in sanitary
and reliable condition. Specific requirements are
described as follows:
Section 133 - Eye and Face Protection
29 CFR 1910.133 requires provision of
protective eye and face equipment when there is
the potential for on-site injury. Particular
information on goggles, spectacles, and face
protection is included. Design, construction,
testing, and use of such devices must be in
accordance with ANSI Z87.1-1968
specifications. The regulation also addresses the
proper use, maintenance, and repair of the
equipment.
Section 134 - Respiratory Protection
29 CFR 1910.134 presents guidance for
respiratory protective equipment. It requires the
provision and use of appropriate respirators
when engineering controls are not feasible to
control atmospheric contamination. Employers
must develop atmospheric protection for
workers, provide and maintain respiratory
equipment, establish operating procedures and
employee training for respirator use, and adhere
to air quality requirements. Employers must
also set up a program of regular inspection of
respirators for defects and repair needs. Gas
mask canisters must be appropriately identified
through use of a color code.
Section 135 - Occupational Head Protection
29 CFR 1910.135 requires head protection for
on-site workers in the following situations:
presence of overhead objects,f operation of
heavy equipment, potential for flying objects in
the work area, and possible electrical shock
hazard. In addition to protecting workers from
falling or flying objects, head protection affords
limited protection from electric shock and burn.
Head protection must meet ANSI Z89.1 -1969
specifications.
Section 136 - Occupational Foot Protection
29 CFR 1910.136 requires that safety toe
footwear for employees meet ANSI Z41.1-1967
standards. In general, workers at hazardous
waste sites must wear leather or rubber boots
with steel toes and steel shanks.
SANITATION
29 CFR 1910.141 contains specifications
conccerning 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.
MEDICAL SERVICES AND FIRST AID
29 CFR 1910.151 states that 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
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approved by a consulting physician shall be
available on-site. If there is a potential for
corrosive materials on-site, suitable facilities
shall be available for drenching of eyes and skin.
FIRE BRIGADES
29 CFR 1910.156 applies to fire brigades,
industrial fire departments, and contractual-type
fire departments. The requirements cover
organization, training, and personal protective
equipment (PPE) for fire brigades whenever they
are established by the employer.
EMPLOYEE ALARM SYSTEMS
29 CFR 1910.165 states that 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.
TOXIC AND HAZARDOUS SUBSTANCES
In Subpart Z, 29 CFR 1910.1000, there are
other applicable OSHA standards that refer to
particular air sampling procedures for chemical
contaminants, PPE requirements, and record
keeping for a variety of compounds.
29 CFR 1910.1016
29 CFR 1910.1001
29 CFR 1910.1002
29 CFR 1910.1003
29 CFR 1910.1004
29 CFR 1910.1006
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
1910.1007
1910.1008
1910.1010
1910.1011
1910.1012
1910.1013
1910.1014
1910.1015
Asbestos
Coal tar pitch volatiles
4-nitrobiphenyl
Alpha-Naphthylamine
Methyl chloromethyl-
ether
3,3'-dichlorobenzidine
bis-chloromethyl ether
Benzidine
4-aminodiphenyl
Ethyleneimine
bata-propiolactone
2-acetylaminofluorene
4-dimethylaminoazo-
benzene
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
1910.1017
1910.1018
1910.1025
1910.1028
1910.1029
1910.1044
29 CFR 1910.1045
29 CFR 1910.1047
29 CFR 1910.1048
N-nitrosodi-
methylamine
Vinyl chloride
Inorganic arsenic
Lead
Benzene
Coke oven emissions
1,2-dibromo-3-chloro-
propane
Acrylonitrile
Ethylene oxide
Formaldehyde
BLOODBORNE PATHOGENS
29 CFR 1910.1030 requires occupational
exposure to blood or other potentially infectious
materials be minimized or eliminated using a
combination of engineering and work practice
controls, personal protective clothing and
equipment, training, medical surveillance,
Hepatitis B vaccination, signs and labels, and
other provisions.
HAZARD COMMUNICATION
STANDARD
29 CFR 1910.1200 ensures that produced or
imported chemical hazards are evaluated and
information concerning these hazards
is communicated to affected employers and
employees. This is accomplished through
hazard communication programs which include
container labels and warnings, material safety
data sheets, and employee information training.
These requirements apply to any chemical which
is known to be present in the workplace to
which employees may be exposed. Any
chemical produced in or imported to the
workplace must be evaluated to determine if it is
hazardous. If a chemical is identified as
hazardous, the employer must develop and
implement certain standards (i.e., warnings,
labels, data sheets, employee information, and
training) to ensure employee safety and
protection. Section 1200 also defines health
hazards related to chemicals, explains mandatory
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hazard determination, lists information sources
for hazard determination, and discusses the issue
of trade secrets in the context of chemical
hazards.
HAZARDOUS
LABORATORIES
CHEMICALS IN
29 CFR 1910.1450 requires the forrmationand
implementation of a Chemical Hygiene Plan
(CHP) to maintain employee exposures at or
below permissible exposure levels (PELs) in
laboratories. The CHP must include necessary
work practices, procedures, and policies to
ensure that employees are protected from all
potentially hazardous chemicals in use in their
work area.
SAFETY AND HEALTH REGULATIONS
FOR CONSTRUCTION
29 CFR 1926 sets forth safety and health
standards under Section 107 of the Contract
Work Hours and Safety Standards Act. The
regulations state that no contractor or
subcontractor can require laborers or mechanics
to work under conditions that are unsanitary,
hazardous, or dangerous to health and safety.
Safety training and education programs
concerning recognition and prevention of unsafe
conditions will be established by OSHA and
used by employers to control or eliminate
hazards. Employers must practice proper fire
prevention, housekeeping, and sanitation. Part
1926 is divided into twenty-four specific areas
including:
Subpart A
Subpart B
Subpart C
Subpart D
Subpart E
Subpart F
General
General Interpretations
General Safety and
Health Provisions
Occupational Health and
Environmental Controls
Personal Protective and
Life Saving Equipment
Fire Protection and
Prevention
Subpart G Signs, Signals, and
Barricades
Subpart H Materials Handling,
Storage, Use, and
Disposal
Subpart I Tools - Hand and Power
Subpart J Welding and Cutting
Subpart K Electrical
Subpart L Ladders and Scaffolding
Subpart M Floors and Wall
Openings, and
Stairways
Subpart N Cranes, Derricks,
Hoists, Elevators, and
Conveyors
Subpart O Motor Vehicles,
Mechanized Equipment
and Marine Operations
Subpart P Excavations, Trenching,
and Shoring
Subpart Q Concrete, Concrete
Forms, and Shoring
Subpart R Steel Erection
Subpart S Tunnels and Shafts,
Caissons, Cofferdams,
and Compressed Air
Subpart T Demolition
Subpart U Blasting and Use of
Explosives
Subpart V Power Transmission and
Distribution
Subpart W Rollover Protective
Structures; Overhead
Protection
Subpart X Effective Dates
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FEDERAL REGULATIONS RELATED TO WORKER
PROTECTION
RESPIRATORY PROTECTIVE DEVICES
30 CFR Part 11 is the Mine Safety and Health
Administration (MSHA) program to certify
respiratory protective devices. It requires that
NIOSH (National Institute for Occupational
Safety and Health) and/or MSHA certify any
respiratory protective device before it can be
used. Respirators for use in hazardous
atmospheres must be approved, used, and
maintained in accordance with the provisions of
American National Standard Practices for
Respiratory Protection. Thirteen subparts
outline procedures for the approval process for
respirators as well as inspection, examination,
and testing requirements:
Subpart A General Provisions
Subpart B Application for Approval
Subpart C Fees
Subpart D Approval and Disapproval
- Subpart E Quality Control
Subpart F Classification of Approved
Respirators; Scope of Approval;
Atmospheric Hazards; Service
Time
Subpart G General Construction and
Performance Requirements
Subpart H Self-Contained Breathing
Apparatus
Subpart I Gas Masks
Subpart J Supplied-Air Respirators
Subpart K Dust, Fume, and Mist
Respirators
Subpart L Chemical Cartridge Respirators
Subpart M Pesticide Respirators
Subpart N Special Use Respirators
NATIONAL CONTINGENCY PLAN
The National Contingency Plan is required by
the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA), as amended by Superfund
Amendments and Reauthorization Act of 1986
(SARA). The revised National Oil and
Hazardous Substances Pollution Contingency
Plan (National Contingency Plan or NCP) was
signed by the EPA Administrator on February 2,
1990. The NCP covers discharges of oil into
navigable waters and releases of hazardous
substances into the environment. It provides for
efficient, coordinated, and effective response to
discharges of such substances. The NCP
consists of the following Subparts:
Subpart A Introduction
Subpart B Responsibility and Organization
for Response
Subpart C Planning and Preparedness
Subpart D Operational Response Phases for
Oil Removal
Subpart E Hazardous Substance Response
Subpart F State Involvement in Hazardous
Substance Response
Subpart G Trustees for Natural Resources
Subpart H Participation by Other Persons
Subpart I Administrative Record for
Selection of Response Action
Subpart J Use of Dispersants and Other
Chemicals
Subpart K Federal Facilities (Reserved)
The NCP requires planning and coordination for
response to oil and hazardous substance releases
and it requires that the National Response Center
(NRC) be notified of a release. The National
Response Team (NRT) is responsible for
national planning and coordination of response
actions and the Regional Response Team (RRT)
is responsible for regional planning and
preparedness activities. The RRT also provides
assistance and advice to the On-Scene
Coordinator (OSC) who directs the response to
the release.
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HAZARDOUS MATERIALS
TRANSPORTATION REGULATIONS
49 CFR specifies shipping regulations for a
variety of different materials. All parties
involved with the shipment of hazardous
materials must be cognizant of the restrictions
that apply to these materials. These restrictions
regulate hazardous materials transport for
aircraft, motor carriers, rail carriage, and vessel
carriage. 49 CFR provides a hazardous
materials table referencing appropriate packaging
and labeling requirements. The regulations
require notification to Federal authorities in the
event of a release of a hazardous material.
The RQ program is a integral part of Superfund.
To control acute threats, Federal, State, and
local emergency responnseauthorities need to
know about them. The release reporting
requirements of Superfund are quite broad.
Although several reporting exemptions are
provided, thousands of reports are still required
each year to the National Response Center, State
emergency response commissions, and local
emergency planning committees. Because the
potential liability for failure to notify is great,
and the effort required to comply generally is
quite small, it is of interest to all organizations
that handle hazardous substances to learn and
understand their reporting obligations.
THE REPORTABLE QUANTITIES
PROGRAM
The purpose of the "reportable quantities" (RQ)
program is to alert Federal, State, and local
response authorities of releases of hazardous
substances that may potentially pose a threat to
public health, welfare, or the environment.
These government authorities are notified when
a certain threshold, or RQ, of the hazardous
substance is released into the environment.
Specifically, CERCLA section 103 requires the
release of a CERCLA hazardous substance in an
RQ or more to be reported immediately to the
National Response Center (NRC). If the release
is less than an RQ, no report is necessary. RQs
serve as a trigger for informing response
authorities of a hazardous substance release so
that they can evaluate the need for a response
action, and undertake any necessary action in a
timely fashion. RQs do not reflect a
determination that a release of a substance will
be hazardous at the RQ level and not hazardous
below that level. A Federal On-Scene
Coordinator makes the risk determination based
on the unique circumstances of the release.
Title III of SARA supplements this NRC
reporting with additional emergency notification
requirements to State and local response
officials.
REIMBURSEMENT TO LOCAL
GOVERNMENT FOR EMERGENCY
RESPONSE TO HAZARDOUS SUBSTANCE
RELEASES
40 CFR Part 310 contains regulations, developed
under section 123 of CERCLA, concerning
procedures for reimbursing local governments
for expenses incurred in carrying out temporary
emergency measures in response to hazardous
substance threats. These measures must be
necessary to prevent or mitigate injury to human
health and the environment from a release of a
hazardous substance or a pollutant or
contaminant. Temporary emergency measures
may include such activities as erecting security
fencing to limit access, responding to fires and
explosions and other measures that require
immediate response at a local level. The intent
of the reimbursement program is to alleviate
significant financial burden on a local
government resulting from such responses.
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Office of Solid Waste and Emergency Response December 1989
Office of Emergency and Remedial Response
Emergency Response Division — MS-101
SARA TITLE I/TITLE III EMERGENCY RESPONSE PLANNING REQUIREMENTS
TITLE I EMERGENCY RESPONSE TITLE III PLANNING
PLANNING REQUIREMENTS REQUIREMENTS FOR
29 CFR 1910.120 (q)(2) LEPCs
(i) Pre-emergency planning and coord- • Identify facilities and transportation
ination with outside parties routes of extremely hazardous
substances (EHSs)
The LEPC plan must only cover EHSs; the Title I plan will need to include more hazardous
chemicals (e.g., CERCLA hazardous substances, RCRA hazardous wastes).
(ii) Personnel roles, lines of authority, • Designate a community coordinator and
training, and communications facility coordinator(s) to implement the
LEPC plan
Title III simply requires the identification of community and facility emergency coordinators.
Although some explanation of the individuals' responsibilities should be included in the LEPC
plan, the plan will not cover the specifics of an Incident Command System (ICS) or the lines of
authority below the coordinators that the Title I plan requires. The site security and control
requirements under Title I refers to procedures that limit personnel on site to those who are
actively performing emergency operations. The LEPC plan would probably not include detailed
emergency response information of this type.
(iii) Emergency recognition and prevention • Describe methods for determining the
occurrence of a release and the probable
affected area and population
The LEPC plan should contain specific guidelines for approach, recognition, and evaluation of
releases. This may include generic types of hazards and guidance. The Title I requirements must
include the same type of information. The LEPC requirement includes specifics on determining
the probable affected area because the LEPC plan is community oriented. The Title I plan should
contain more specifics geared towards the actual responders.
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SARA TITLE I/TITLE III EMERGENCY RESPONSE PLANNING REQUIREMENTS
TITLE I EMERGENCY RESPONSE TITLE III PLANNING
PLANNING REQUIREMENTS REQUIREMENTS FOR
29 CFR 1910.120 (q)(2) LEPCs
(iv) Safe distances and places of refuge • Outline evacuation plans
These planning elements overlap. The plans must identify potential conditions requiring
evacuation, an indication of how evacuation distances are determined, the designated authority
for ordering evacuations, shelter facilities, means for locating "sensitive populations" (e.g.,
elderly, handicapped), evacuation routes and procedures, and designated authority to make re-
entry decisions.
(v) Site security and control
See paragraph (ii)
(vi) Evacuation routes and procedures
See paragraph (iv)
(vii) Decontamination • Describe emergency response
procedures, on-site and off-site
Overlap may exist to some extent. Both plans must address alternate means of communication
and public altering procedures, and should designate a person to be in charge of public
information during an incident. The Title I decontamination requirement is a specific emergency
response procedure. The LEPC plan requirements are intended to include standard emergency
response procedures; LEPC plans may not be sufficiently specific to satisfy the requirements
under Title I.
(viii) Emergency medical treatment and first • Describe community and industry emer-
aid gency equipment and facilities, and the
identity of persons responsible for them
Both rules require equipment to be identified for various levels and types of emergencies.
References to neighboring jurisdictions' equipment and facility resources should be included and
arrangements, either formal or informal, should be made for their use during an emergency.
Maintenance schedules may also be included in both plans. PPE is a specific type of equipment
that must be addressed in the Title I plan. Emergency medical treatment and first aid must be
addressed explicitly in the Title I plan.
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SARA TITLE I/TITLE III EMERGENCY RESPONSE PLANNING REQUIREMENTS
ft
TITLE I EMERGENCY RESPONSE
PLANNING REQUIREMENTS
29 CFR 1910.120 (q)(2)
TITLE III PLANNING
REQUIREMENTS FOR
LEPCs
(ix) Emergency alerting and response
See paragraph (vii)
(x) Critique of response and follow-up
Outline emergenc
procedures procedures
notification
Present methods and schedules for
exercising emergency response plans
These two criteria are different and complementary. The LEPC requirement refers to table-top
exercises or simulated accidents to test a variety of local response systems. The Title I
requirement specifies that following an actual event, participants critique the response in order
to improve capabilities for the next accident. The two requirements together provide an
opportunity to test the plan and learn from the results of a response.
(xi) PPE and emergency requirements
See paragraph (viii)
(xii) Emergency response organizations may
use the local emergency response plan
or the State emergency response plan or
both, as part of their emergency
response plan to avoid duplication.
Those items of the emergency response
plan that are being properly addressed
by the SARA Title III plans may be
substituted into their emergency plan or
otherwise kept together for the employer
and employee's use.
The LEPC may develop their plan based
on the guidance provided by the
National Response Team (Hazardous
Materials Emergency Planning Guide,
NRT-1). This document provides
additional information on the nine
general planning requirements and
reinforces the importance of the
planning process for the community.
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SARA TITLE I/TITLE III EMERGENCY RESPONSE TRAINING REQUIREMENTS
TITLE I EMERGENCY RESPONSE TITLE III TRAINING
TRAINING REQUIREMENTS REQUIREMENTS FOR
29 CFR 1910.120 (q)(6) LEPCs
Training shall be based on duties and • Describe a training program for
functions to be performed by each emergency response personnel (including
responder of an emergency response schedules)
organization
Title I requires specific training for employees engaged in emergency response, based on 5
categories of responders: first responder awareness level, first responder operations level,
hazardous materials technician, hazardous materials specialist, and on-scene incident commander.
The Title III planning requirements were developed prior to the OSHA regulations and thus may
not specifically address the training programs and schedules necessary to fulfill the OSHA
requirements.
SUMMARY OF COMPARISON The primary difference between the Title I and the Title III
requirements is the intended audience. Title III has nine very general planning elements that allow a
community to develop emergency plans based on their perceived needs. Title I contains the federally-
determined, specific criteria for employer plans to protect emergency responders. A good LEPC plan
may significantly overlap with the Title I plan; however a good LEPC plan may also be too general for
Title I purposes.
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RELATED NATIONAL FIRE PROTECTION ASSOCIATION
STANDARDS
RESPONDING TO HAZARDOUS
MATERIALS INCIDENTS
NFPA 471 recommends procedures and
practices for mitigating hazardous materials
incidents. Topics include decontamination,
methods of mitigation, chemical protective
clothing, and safety.
PROFESSIONAL COMPETENCE OF
RESPONDERS TO HAZARDOUS
MATERIALS INCIDENTS
NFPA 472 deals with training and capabilities
that are required at various levels of response to
hazardous materials incidents, including First
Responder Awareness and Operational levels;
the Technician level; and the Specialist level.
An appendix deals with management of an
incident.
PROFESSIONAL COMPETENCE OF
EMERGENCY MEDICAL SERVICES
RESPONDERS TO HAZARDOUS
MATERIALS INCIDENTS
NFPA 473 identifies the level of competence
required of emergency medical services
personnel who respond to hazardous materials
incidents. The competencies outlined have been
prepared to reduce the numbers of accidents,
exposure, and injuries resulting from HAZMAT
incidents.
IDENTIFICATION OF THE
HAZARDS OF MATERIALS
FIRE
NFPA 704 presents a system of recognizable
markings ("Hazard Diamond") that indicate the
relative reactivity, flammability, and health
hazards of materials in storage. Includes
expanded definitions for the Health and
Reactivity Hazard Ratings.
FIRE DEPARTMENT OCCUPATIONAL
SAFETY AND HEALTH PROGRAM
NFPA 1500 provides minimum standard
requirements for a fire service related
occupational safety and health program for all
career and volunteer departments. Covers
organization, training and education, vehicles
and equipment, protective clothing, protective
equipment, facilities, safety, medical and
member assistance programs.
FIRE DEPARTMENT SAFETY OFFICER
NFPA 1501 outlines the duties of a Fire
Department Safety Officer, and requires every
department to have a safety officer.
FIRE DEPARTMENT
MANAGEMENT SYSTEM
INCIDENT
NFPA 1561 provides minimum criteria for
emergency incident management. Such incident
management systems are intended to provide
structure, coordination, and effectiveness of all
emergency incidents to enhance safety and health
of fire department members and other persons
involved.
FIRE DEPARTMENT
CONTROL PROGRAM
INFECTION
NFPA 1581 specifies minimum requirements
for infection control practices for public safety
and emergency response personnel providing
EMS care and in contact with potentially
infectious persons and materials in emergency
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settings, and for universal precautions for
infection control in routine or non-emergency
settings.
PROTECTIVE CLOTHING AND
EQUIPMENT FOR STRUCTURAL
FIREFIGHTING AND STATION / WORK
UNIFORMS
NFPA 1971-Protective Clothing
NFPA 1971 specifies minimum performance,
design, and testing requirements for protective
coats, trousers and hoods.
NFPA 1972-Helmets
NFPA 1971 specifies performance criteria and
test methods for helmets.
NFPA 1973-Gloves
NFPA 1972 specifies minimum performance
criteria and test methods for the materials and
construction of gloves.
NFPA 1974-Footwear
NFPA 1974 specifies minimum standard
design, performance, and testing requirements
for protective footwear.
NFPA 1975-Station/Work Uniforms
NFPA 1975 specifies performance criteria and
test methods for uniforms worn under
protective clothing.
OPEN-CIRCUIT SELF-CONTAINED
BREATHING APPARATUS
NFPA 1981 specifies performance criteria and
testing methods for open-circuit self-contained
breathing apparatus (SCBA) in addition to
NIOSH/OSHA certification.
VAPOR-PROTECTIVE SUITS
HAZARDOUS CHEMICALS
EMERGENCIES
FOR
NFPA 1991 specifies minimum design,
performance, testing, and documentation
requirements for vapor-protective suits for
protection from exposure to specified chemicals
in vapor and splash environments. Covers
technical documentation, chemical permeation
resistance, suit pressurization, water permeation,
penetration resistance of closures, exhaust valve
leaking and cracking pressure; and materials for
testing for burst, tear, abrasion, flammability,
cold performance and flexural fatigue.
LIQUID SPLASH-PROTECTIVE SUITS
FOR HAZARDOUS CHEMICALS
EMERGENCIES
NFPA 1992 specifies minimum design,
performance, testing, and documentation
requirements for liquid splash-protective suits
for protection from exposure to specified
chemicals in liquid splash environments. Covers
technical documentation, chemical permeation
resistance, and water permeation; and materials
for testing for burst, tear, abrasion,
flammability, cold performance and flexural
fatigue.
SUPPORT FUNCTION GARMENTS FOR
HAZARDOUS CHEMICALS OPERATIONS
NFPA 1993 specifies minimum design,
performance, testing, and documentation
requirements garments worn by personnel
performing support functions in known,
controlled atmospheres outside the "hot zone" at
a hazardous material incident.
NFPA STANDARDS ARE AVAILABLE FROM:
National Fire Protection Association
1 Batterymarch Park
P.O. Box 9101
Qunicy, MA 02269-9101
(617) 770-3000
60
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SECTION 1
OCCUPATIONAL SAFETY AND HEALTH
REGULATIONS AND STANDARDS
PART 4
NIOSH CRITERIA FOR A RECOMMENDED STANDARD FOR
WORKING IN CONFINED SPACES
61
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criteria for a recommended standard.
WORKING in CONFINED SPACES
U. S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
Public Health Service
Center for Disease Control
National Institute for Occupational Safety and Health
December 1979
For ••!<• by the Superintendent of Document* U.S. Co
Priming Office, Washington, D.C. 20*02
63
-------
DHEW (NIOSH) Publication No. 80-106
64
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PREFACE
The Occupational Safety and Health Act of 1970 emphasizes the need for
standards to protect the health and safety of workers exposed to an ever-
increasing number of potential hazards in their workplace.
The National Institute for Occupational Safety and Health (N10SH)
evaluates all available research data and criteria and recommends standards
for safe work practices and occupational exposure to toxic substances. The
Secretary of Labor will weigh these recommendations along with other
considerations, such as feasibility and means of implementation, in
promulgating regulatory standards.
N10SH will periodically review the recommended standards to ensure
continuing protection of workers and will make successive reports as new
research and epidemiologic studies are completed and as engineering controls
for the workers safety are developed.
The contributions to this document on working in confined spaces by
members of the NIOSH staff, other Federal agencies or departments, the review
consultants, and Robert B. O'Connor, M.D., NIOSH consultant in occupational
medicine, are gratefully acknowledged.
The views and conclusions expressed in this document, together with the
recommendations for a standard, are those of NIOSH. They are not necessarily
those of the consultants, the reviewers selected by professional and trade
associations, or other Federal agencies. However, all comments, whether or
not incorporated, were considered carefully and were sent with the criteria
document to the Occupational Safety and Health Administration for
consideration in setting the standard. The review consultants and the Federal
agencies which received the document for review appear on pages v and vi
respectively.
- )
Anthony Robbins, M.D.
Director, National Institute for
Occupational Safety and Health
iii
65
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The Division of Safety Research, National Institute for Occupational
Safety and Health, had primary responsibility for the development of the
criteria and recommended standard for confined spaces. This document on
entering, working in, and exiting from confined spaces was prepared by:
Ted A. Pettit
Criteria Manager
Division of Safety Research
Patricia M. Gussey
Chemist
Division of Safety Research
Rebecca S. Simons
Occupational Health Nurse
Division of Safety Research
The Division of Safety Research review for this document was provided by
Earle P. Shoub and James A. Oppold, Ph.D.
NIOSH review of this document was provided by Edward J. Baler (Office of
the Director), Vernon E. Rose, Ph.D., Irwin P. Baurael, Ph.D., Frank L.
Mitchell, D.O., Jerry L. Chandler, Ph.D., Jack McCracken, Ph.D., David West
(Division of Criteria Documentation and Standards Development), and Robert
O'Conner, M.D., (NIOSH Consultant).
iv
66
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REVIEW CONSULTANTS
O.C. Amrhyn, P.E., C.S.P.
Assistant Manager, Outside Plant
American Telephone and Telegraph
295 North Maple Avenue
Basking Ridge, New Jersey 07920
Colin G. Drury, Ph.D.
Associate Professor
State University of New York at Buffalo
Department Industrial Engineering
Amherst, New York 14260
Richard L. Miller, Ph.D.
Research Chemical Engineer
USAF School of Aerospace Medicine (VNL)
Brooks Air Force Base, Texas 78235
John B. Moran
Director, Industrial Hygiene &
Professional Services
American Optical Corporation
14 Mechanic Street
Southbridge, Massachusetts 01550
Rafael Moure
Industrial Hygienist
Oil, Chemical, and Atomic Workers
International Union
1626 Champa Avenue
Denver, Colorado 80201
Gerald R. Williams, M.D., J.D.
Medical Director Watson Refinery
Atlantic-Richfield Company
1801 E. Sepulvada
Carson, California 90747
Philip Zullo
Industrial Hygienist
227 Indian Creek Drive
Mechanicsburg, Pennsylvania 17055
67
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FEDERAL AGENCIES
Department of Defense
Department of the Army
Environmental Hygiene Agency
Department of the Navy
Naval Regional Medical Center
Department of Commerce
Maritime Administration
Department of Health, Education, and Welfare
National Institute of Health
Department of Interior
Bureau of Mines
Department of Labor
Mine Safety and Health Administration
Occupational Safety and Health Administration
National Aeronautics and Space Administration
vi
68
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CONTENTS
Page
PREFACE iii
REVIEW CONSULTANTS v
FEDERAL AGENCIES vi
I. RECOMMENDATIONS FOR A STANDARD FOR
WORKING IN CONFINED SPACES 1
Section 1 - Definitions 1
Section 2 - Entry and Rescue 3
Section 3 - Permit System 6
Section 4 - Medical 8
Section 5 - Training 8
Section 6 - Testing and Monitoring 9
Section 7 - Labeling and Posting 10
Section 8 - Safety Equipment and Clothing 11
Section 9 - Work Practices 13
II. INTRODUCTION 18
III. CONFINED SPACE HAZARDS 19
Overview and Magnitude of the Problem 19
Hazardous Atmospheres 21
General Safety Hazards 28
Statistical Data 31
IV. DEVELOPMENT OF THE STANDARD 37
Previous Standards 37
Basis for Recommended Standard 38
V. TRAINING GUIDELINES 43
VI. RESEARCH NEEDS 46
VII. REFERENCES 47
VIII. APPENDIX I - Cross Reference - NIOSH Recommended
Standard for Working In Confined Spaces to
the OSHA Standard 54
IX. APPENDIX II - Recommended Respiratory Selection Guide 58
X. APPENDIX III - Sample Permit - Confined Space Entry 61
XI. APPENDIX IV - Characteristics of Cases Included as Confined
Space Related 63
Vll
69
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I. RECOMMENDATIONS FOR A STANDARD FOR
WORKING IN CONFINED SPACES
NIOSH recommends the procedures set forth in the following sections as a
means of protecting the health, and significantly reducing accidental injury
and death associated with entering, working in, and exiting from confined
spaces. The standard is designed not only to make the confined space safe for
the worker, but also to make the worker cognizant of the hazards associated
with this work area and the safe work practices necessary to deal with these
hazards. The criteria and standard will be reviewed and revised as necessary.
Section 1 - Definitions - For Purposes of this Document
Atmosphere
Ceiling Level
Combustible Dust
Confined Space
Confined Space, Class "A1
Confined Space, Class "B"
Confined Space, Class "C"
Refers to the gases, vapors, mists, fumes,
and dusts within a confined space.
The maximum airborne concentration of a
toxic agent to which an employee may be
exposed for a specified period of time.
A dust capable of undergoing combustion or
of burning when subjected to a source of
ignition.
Refers to a space which by design has
limited openings for entry and exit;
unfavorable natural ventilation which could
contain or produce dangerous air
contaminants, and which is not intended for
continuous employee occupancy. Confined
spaces include but are not limited to
storage tanks, compartments of ships,
process vessels, pits, silos, vats,
degreasers, reaction vessels, boilers,
ventilation and exhaust ducts, sewers,
tunnels, underground utility vaults, and
pipelines.
A confined space that presents a situation
that is immediately dangerous to life or
health (IDLH). These include but are not
limited to oxygen deficiency, explosive or
flammable atmospheres, and/or concentrations
of toxic substances.
A confined space that has the potential for
causing injury and illness, if preventive
measures are not used, but not immediately
dangerous to life and health.
A confined space in which the potential
hazard would not require any special
modification of the work procedure.
1
70
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Hot Work
Inerting
Any work involving burning, welding,
riveting, or similar fire producing
operations, as well as work which produces a
source of ignition, such as drilling,
abrasive blasting, and space heating.
Displacement of the atmosphere by a non-
reactive gas (such as nitrogen) to such an
extent that the resulting atmosphere is
noncombustible.
Isolation
Lower Flammable Limit (LFL)
Oxygen Deficiency
Oxygen Enriched Atmosphere
A process whereby the confined space is
removed from service and completely
protected against the inadvertent release of
material by the following: blanking off
(skillet type metal blank between flanges),
misaligning sections of all lines and pipes,
a double block and bleed system, electrical
lockout of all sources of power, and
blocking or disconnecting all mechanical
linkages.
The minimum concentration of a combustible
gas or vapor in air (usually expressed in
percent by volume at sea level), which will
ignite if an ignition source (sufficient
ignition energy) is present.
Refers to an atmosphere with a partial
pressure of oxygen (P02) less than 132 mm
Hg. Normal air at sea level contains
approximately 21% oxygen at a PO2 of 160 mm
Hg. At an altitude of 5,280 feet normal air
contains approximately 21% 02 at a P02 of
132 mm Hg.
Any oxygen concentration greater than 25%
(P02 - 190 mm Hg) at normal atmospheric
pressure.
Permissible Exposure Limit (PEL) The maximum 8-hour time weighted average of
any airborne contaminant to which an
employee may be exposed. At no time shall
the exposure level exceed the ceiling
concentration for that contaminant as listed
in 29 CFR Part 1910 Sub Part Z.
Purging
Qualified Person
The method by which gases, vapors, or other
airborne impurities are displaced from a
confined space.
A person designated by the employer, in
writing, as capable (by education and/or
specialized training) of anticipating,
recognizing, and evaluating employee
71
-------
Respirator (Approved)
Standby Person
exposure to hazardous substances or other
unsafe conditions in a confined space. This
person shall be capable of specifying
necessary control and/or protective action
to insure worker safety.
A device which has met the requirements of
30 CFR Part 11 and is designed to protect
the wearer from inhalation of harmful
atmospheres and has been approved by the
Bureau of Mines and the National Institute
for Occupational Safety and Health, and Mine
Safety and Health Administration (formerly,
Mining Enforcement and Safety
Administration) .
A person trained in emergency rescue
procedures and assigned to remain on the
outside of the confined space and to be in
communication with those working inside.
Section 2 - Entry and Rescue
The Confined Space Classification Table on page A is based on existing or
potential hazards relative to the confined space. The classification is based
upon the characteristics of the confined space, oxygen level, flammability and
toxicity. If any of the hazards present a situation which is immediately
dangerous to life or health (IDLH) , the confined space shall be designated
Class A. The classification shall be determined by the most hazardous
condition of entering, working in, and exiting a confined space. Class B
confined space has the potential for causing injury and illness but is not
immediately dangerous to life and health. A Class C entry would be one in
which the hazard potential would not require any special modification of the
work procedure.
The Check List of Consideration on page 5 delineates the minimum
preparation required for each class of confined space entry. In the
recommended standard where specific procedures, activities or requirements are
correlated with a classification: the procedure, activity or requirement is
mandatory. As an example, Section 3 - Permit System (Class A, B and C) means
that a permit is mandatory for Class A, B, and C confined space entry.
3
72
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CHECK LIST OF CONSIDERATIONS FOR ENTRY,
WORKING IN AND EXITING CONFINED SPACES
ITEM
CLASS A
CLASS B
CLASS C
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
X -
0 -
Permit
Atmospheric Testing
Monitoring
Medical Surveillance
Training of Personnel
Labeling and Posting
Preparation
Isolate/lockout/tag
Purge and ventilate
Cleaning Processes
Requirements for special
equipment/ tools
Procedures
Initial plan
Standby
Communications/observation
Rescue
Work
Safety Equipment
and Clothing
Head protection
Hearing protection
Hand protection
Foot protection
Body protection
Respiratory protection
Safety belts
Life lines, harness
Rescue Equipment
Recordkeeping/Exposure
indicates requirement
indicates determination by the
X
X
X
X
X
X
X
X
0
X
X
X
X
X
X
0
0
0
0
0
0
X
X
X
X
qualified person
X
X
0
X
X
X
X
X
0
X
X
X
X
X
X
0
0
0
0
0
0
X
0
X
X
X
X
0
0
X
X
0
0
0
0
X
0
X
X
X
0
0
0
0
0
X
X
74
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If the work practice involved in the confined space has the potential to
increase existing hazards' or generate additional ones, it shall be necessary
to frequently evaluate the space to determine if a classification change is
warranted.
Rescue procedures shall be specifically designed for each entry. If a
confined space has an A or B Classification, there shall be a trained standby
person assigned to that confined space with a fully charged, positive
pressure, self-contained breathing apparatus (SCBA) at hand. Additional
duties of the standby person are to maintain unobstructed life lines and
communications to all workers within the confined space, and to summon rescue
personnel if necessary. Under no circumstances will the standby person enter
the confined space until he is relieved and is assured that adequate
assistance is present. However, while awaiting rescue personnel the standby
person will make rescue attempts utilizing the life lines from outside the
confined space. Rescue teams entering a Class A or B confined space shall be
equipped with all the aforementioned safety equipment of the standby person
and required life lines.
In the event of a Class C confined space rescue, a supplied-air respirator
or a self-contained breathing apparatus shall be used. A person summoned or
one who recognizes the need for rescue shall summon assistance and await their
arrival outside the confined space. Respirators and life lines shall be
donned by rescue personnel with necessary equipment for removal of the
victim(s).
Section 3 - Permit System (Class A, B, and C)
Entry into a confined space shall be by permit only. The permit is an
authorization and approval in writing that specifies the location and type of
work to be done, and certifies that all existing hazards have been evaluated
by the qualified person, and necessary protective measures have been taken to
insure the safety of each worker.
The supervisor or a qualified person shall be responsible for securing the
permit and both shall sign off when the following areas and actions have been
reviewed and confirmed:
(a) Location and description of the work to be done.
(Class A, B, and C)
(b) Hazards that may be encountered.
(Class A, B, and C)
(c) Complete isolation checklist.
(Class A, B, and C)
(1) Blanking and/or disconnecting.
(2) Electrical lockout.
(3) Mechanical lockout.
75
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(d) Special clothing and equipment.
(Class A and B)
(1) Personal protective equipment and clothing
(2) Safety harness and/or lines.
(3) Tools approved for use in accordance with the
Hazardous Location Classification (NEC-1978).
(4) Approved electrical equipment.
(e) Atmospheric test readings.
(Class A, B, and C)
(1) Oxygen level.
(2) Flammability and/or explosive levels.
(3) Toxic substance levels.
(f) Atmospheric monitoring while work is being performed.
(Class A on a continuous basis and Class B as determined
by the Qualified Person)
(g) Personnel training and complete understanding of the hazards.
(Class A, B, and C)
(h) Standby person(s) as named on the permit.
(Class A and B)
(i) Emergency procedures and location of first aid equipment.
(Class A, B and C)
(j) Confined space classification A, B, and C.
This permit shall be dated and carry an expiration time that will be valid
for one shift only. The permit shall be updated- for each shift with the same
requirements.
The permit for a Class A or B confined space shall be posted in a
conspicuous place, close to the entrance, with a copy on file with the
employer.
The sample permit in Appendix III should serve as a guide and not be
limited to the areas mentioned. The training requirements of personnel
entering and/or working in confined spaces shall be suitable for the nature of
the hazard and the work to be performed and will therefore vary with the
confined space classification. The permit will vary among different
industrial activities. However, it should serve the same purpose for all
industries, to insure the safety of the worker.
7
76
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Section 4 - Medical (Class A, B)
(a) Workers who enter a Class A or B confined space shall have a pre-
placement physical examination made available to them. The employer shall
provide to the physician performing or responsible for the medical
surveillance program information such as the type of confined space the
employee may be required to enter, the type of substances the employee may
encounter, and a description of any protective devices or equipment the
employee may be required to use. The physical examination shall include:
(1) A demonstration of the worker's ability to use negative and
positive pressure respirators as cited in 29 CFR 1910.134.
(2) A demonstration of the workers ability to see and hear warnings,
such as flashing lights, buzzers or sirens.
(3) The examination should place emphasis on general evaluations of
the employee's ability to carry out his assigned duties and the detection of
any diseases or abnormalities which may make it difficult to work within
confined spaces.
(b) Following completion of the examinations, the physician shall give to
the employer a written statement specifying any condition or abnormality found
which would increase risk to the employee's health by working in confined
spaces.
(c) Periodic medical examinations shall be made available to employees
required to work in Class A or B confined spaces.
(d) First Aid Provisions
(1) For Class A and B entry there shall always be someone readily
available in the area of the confined space who is currently trained in
cardio-pulmonary resuscitation (CPR) and basic first-aid procedures.
(2) Fjnployees shall be aware of the location of the nearest first-
aid equipment, and how to obtain emergency assistance and medical attention.
An adequate supply of first-aid equipment shall be within easy access of the
confined space.
(e) Records of exposure to known health hazards shall be included in that
employee's medical record. These records shall be made available to the
designated medical representatives of the Secretary of Health, Education and
Welfare, of the Secretary of Labor, of the employer and of the employee or
former employee.
Section 5 - Training (Class A, B, and C)
The employer shall be responsible for training personnel and for the
safety of the entire operation. Personnel who work in the vicinity of
confined spaces shall be made aware of the hazards associated with confined
spaces during orientation. Personnel who are required to work in a confined
space, or in support of those working in a confined space shall have
additional training in the following areas:
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(a) Emergency entry and exit procedures (Class A, B, and C) ;
(b) Use of applicable respirators (Class A, B, and C) ;
(c) First aid (Class A, B);
(d) Lockout procedures (Class A, B, and C);
(e) Safety equipment use (Class A, B, and C) ;
(f) Rescue and training drills designed to maintain proficiency shall be
given initially to new employees, and thereafter, at least annually, or at
lesser intervals as determined necessary by the judgment of the employer
(Class A, B, and C);
(g) Permit system (Class A, B and C) ; and
(h) Work practices as recommended in Section 9 of this proposed standard.
(Class A, B and C)
Training shall not be considered as complete until the supervisor or other
employer-designated official, safety or training officer, judges that the
employee has attained an acceptable degree of proficiency for entering and
working in confined spaces. The trainee's judgment of the adequacy of his
training should be properly considered.
Section 6 - Testing and Monitoring (Class A, B, and C)
Entry into a confined space is prohibited until initial testing of the
atmosphere has been done from the outside . Appropriate tests shall be made
to insure that the atmosphere is safe. The tests performed shall include
those for oxygen content, flammability, and toxic materials. Any necessary
additional tests will be selected and performed to the satisfaction of the
qualified person. Monitoring of a Class A confined space shall be done on a
continuous basis. Class B and C shall be monitored as determined by the
qualified person.
Entry into a confined space for any type of hot work shall be prohibited
when tests indicate the concentration of flammable gases in the atmosphere is
greater than 10% of the lower flammability limit (LFL). It is necessary to
determine the oxygen level (by appropriate testing) prior to measuring the
range of flammability to make necessary corrections in the flammability
measurement. Monitoring of the atmosphere shall be performed in accordance
with the permit. Equipment for continuous monitoring of gases and vapors
shall be explosion proof and equipped with an audible alarm or danger
signaling device that will alert employees when a hazardous condition
develops. Instruments used for testing the atmosphere in a confined space
shall be selected for their functional ability to measure hazardous
concentrations. Instruments shall be calibrated in accordance with the
manufacturer's guidelines or manuals. Each calibration shall be recorded,
filed by the employer, and available for inspection for 1 year after the last
calibration date.
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In any confined space classified as a Class II or Class III hazardous
location according to the 1978 National Electrical Code, Article 500 Sections
5 and 6, a fire watch shall be established as part of the entry procedure. In
such areas surface dust and fibers shall be removed and no hot work shall be
initiated until the airborne particulate level is below 10% of the LFL for the
material. When combustible dusts or ignitable fibers/flyings are present, all
equipment and ventilation systems used in the confined space shall comply with
Articles 502 and 503 of the National Electrical Code.
The percentage of oxygen for entry into a confined space shall be no less
than 19.5% nor greater than 25% at 760 mm Hg. At sea level the normal
atmospheric pressure for air (20.9% 02 + 78.1% N2 + 1% Ar + trace amounts of
various inert gases) is 14.7 psi or 760 mm Hg absolute. The partial pressure
of oxygen (PO 2) at sea level will be approximately 160 mm Hg. P02 can be
reduced by reducing the 02 level in air at a given elevation or through
increasing altitude. If tests indicate the oxygen level to be greater than
25% hot work is prohibited until ventilating techniques have reduced the
oxygen level to approximately 21%. If the percentage of oxygen falls below
19.5% approved respiratory equipment shall be used in accordance with Section
8 and Appendix II.
When the contaminants in 'the atmosphere cannot be kept within permissible
exposure levels as set down in 29 CFR Part 1910 Sub Part Z, then the employee
shall wear an approved respirator.
Section 7 - Labeling and Posting (Class A, B, and C)
(a) All warning signs shall be printed both in English and in the
predominant language of non-English reading workers. Where established
symbols exist, they shall also be used. Workers unable to read labels and
posted signs shall receive information regarding hazardous areas and shall be
informed of the instructions printed on the signs.
(b) All entrances to any confined space shall be posted. Signs shall
include but not necessarily be limited to the following information:
DANGER
CONFINED SPACE
ENTRY BY PERMIT
ONLY
(c) When a specific work practice is performed or specific safety
equipment is necessary, the following statement shall be added, in large
letters, to the warning sign:
RESPIRATOR REQUIRED
FOR ENTRY
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LIFELINE REQUIRED
FOR ENTRY
HOT WORK PERMITTED
OR
NO HOT WORK
(d) Emergency procedures, including phone numbers of fire departments and
emergency medical services shall be posted conspicuously within the immediate
area of the confined space, or at the telephone from which help would be
summoned.
Section 8 - Safety Equipment and Clothing (Class A, B, and C)
The entry permit shall include a list of necessary protective equipment to
be used in the confined space as determined by the qualified person. The
employer shall be responsible for the proper use of the safety equipment, and
the inspection and maintenance procedures performed on the safety equipment.
The type of protective equipment required, will be determined by the qualified
person.
Those items normally used to protect against traumatic injury include:
safety glasses, hardhats, footwear and protective clothing.
(a) Eye and Face Protection - For persons who wear corrective spectacles,
either prescription ground safety glasses or piano-goggles shall be provided.
Additionally if eye-irritating chemicals, vapors, or dusts are present, safety
goggles shall be required, and if both the face and eyes are exposed to a
hazard, as during scrapping scale or cutting rivets, a full coverage face
shield with goggles shall be used. During welding operations the special
goggles or shields required shall be in accordance with 29 CFR 1910.252.
(b) Head Protection - Hard hats shall meet the requirements cited in 29
CFR 1910.135.
(c) Foot Protection - All foot protection shall meet or exceed the
requirements cited in 29 CFR 1910.136 and shall provide, in addition to
protection from falling objects, protection from any other hazard identified
by the qualified person.
(d) Body Protection - All personnel entering a confined space shall wear
full coverage work clothing as specified by the qualified person. Gloves and
clothing made of impervious rubber or similar material are to be worn to
protect against toxic or irritating materials. If the hazards of heat or cold
stress exist in the confined space, clothing which has been tested to provide
protection from over-exposure to these hazards shall be worn. Other body
protection required in specific operations such as welding (flame proofed),
riveting (heat resistant) and abrasive blasting (abrasion resistant) shall be
provided to insure worker safety.
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(e) Hearing Protection - Shall be required when engineering technology is
insufficient to control the noise level, and the ambient exposure limit
exceeds those allowed in Table G-16 of 29 CFR 1910.95. Emergency alarms shall
be distinguishable when hearing protection is worn. The sound level meters
used to measure noise levels shall be certified by NIOSH in accordance with 24
CFR 82. Where the potential for explosion exists, the sound level meters
shall be of an explosion proof design.
(f) Respiratory Protection - Shall be determined by the qualified person
based upon conditions and test results of the confined space, and the work
activity to be performed. Halfmask respirators are not recommended for use in
any atmosphere greater than 10 x PEL because of the probability of accidently
breaking the facepiece to face seal due to the work condition in a confined
space. Also, gas masks designed for the same respiratory protection may be
substituted for chemical cartridge respirators in the table (see Appendix II) ,
but they are more cumbersome and restrictive to movement. The minimum service
time of self-contained breathing apparatus shall be calculated on the entry
time, plus the maximum work period, plus twice the estimated escape time for
safety margin.
The respirators used shall be NIOSH and MSHA approved devices and shall be
fitted and maintained in accordance with 29 CFR 1910.134. However, supplied-
air respirators purchased before 1975 and bearing Bureau of Mines approval may
be used until March 31, 1980. Self-contained breathing apparatus, with
audible alarms and all gas masks, approved by the Bureau of Mines may be used
until further notice.
(g) Hand Protection - If hands are exposed to rough surfaces or sharp
edges, the degree of protection can range from canvas to metal mesh gloves,
depending on the material handled. Gloves made of impervious rubber or
similar material are to be worn to protect against toxic or irritating
materials. Heat protective gloves are required when employees handle objects
with temperatures greater than 60 C (140 F). Where a current flow through the
body of more than 5 milliamperes may result from contact with energized
electrical equipment, employees shall wear insulating gloves that have been
visually inspected before each use. Above 5,000 volts, rubber gloves in
accordance with 29 CFR 1910.137 shall be worn.
Additional safety equipment that is necessary to protect the worker in the
environment of a confined space: a safety belt with "D" rings for attaching a
life line shall be worn at all times; the combination of a body harness and/or
safety belt with life line shall be used when an employee is required to enter
to complete the gas analysis; when an employee is working in an area where
entry for purposes of rescue would be contraindicatec (special limitations or
fire hazard); when any failure of ventilation would allow the build-up of
toxic or explosive gases within the time necessary to evacuate the area, or
when the atmosphere is immediately dangerous to life and health. Safety belts
may be used as the primary means of suspension for the life line only when
rescue may be made by keeping the disabled body in a position that will
maintain easy passage through exit openings. If the exit opening is less than
18 inches (45 cm) in diameter, then a wrist type harness shall be used. When
it is determined by the qualified person that none of the special hazards
associated with confined spaces pose an immediate threat to life, as in a
Class C entry, then life lines shall be readily available but not used during
entry and work procedures.
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Other protective measures shall include: safety nets used to protect
employees working 10 feet (3 m) above ground or grade level when other
protective devices are impractical; life jackets worn if the workers are
exposed to falls into liquid over 4 feet (1.2 m) in depth; and insulated floor
mats when hot work requires use of electrical energy.
When employees enter a confined space, a barricade shall be erected if
inadvertent entry poses a problem. The barricade shall have a mechanism to
prevent closure of the escapeway, signs warning of the danger present, a
physical barrier (fence) to keep the area clear, and an adequate platform (3
feet x 3 feet as a minimum) for entry or exit. Such added features as a
tripod with block and tackle for safety lines and communication equipment
should be considered when the entry plan is formulated. The employer shall be
responsible for maintenance of the barricade system.
Section 9 - Work Practices (Class A, B, and C)
Before entering a confined space, employees shall review the specific
guidelines appropriate for safe entry and emergency exit. These guidelines or
standards shall be compiled by the qualified person and be definitive on all
the possible hazards. Areas covered by such guidelines shall follow this
recommended standard.
(a) Purging and Ventilating (Class A, B)
Environmental control within a confined space is accomplished by purging
and ventilating. The method used will be determined by the potential hazards
that arise due to the product stored or produced, suspected contaminants, the
work to be performed, and the design of the confined space. When ventilating
and/or purging operations are to be performed, the blower controls shall be at
a safe distance from the confined space. In a Class A entry, an audible
warning device shall be installed in all equipment to signal when there is a
ventilation failure. When a ventilation system is operational, air flow
measurements shall be made before each workshift to ensure that a saf«=.
environmental level is maintained. Initial testing of the atmosphere shall be
performed from outside the confined space before ventilation begins to
determine what precautions are necessary in purging and ventilating. Testing
of more remote regions within the confined space may be performed once the
immediate area within the confined space has been made safe. Exhaust systems
shall be designed to protect workers in the surrounding area from contaminated
air. If flammable concentrations are present all electrical equipment shall
comply with the requirements of NEC (NFPA no. 70) hazardous locations, and the
bonding requirements of Article 250 of NEC, 1978. Where continuous
ventilation is not a part of the operating procedure, the atmosphere shall be
tested until continuous acceptable levels of oxygen and contaminants are
maintained for three tests at 5-minute intervals. Care shall be taken to
prevent recirculation of contaminated air and interaction of airborne
contaminants.
Continuous general ventilation shall be maintained where toxic atmospheres
are produced as part of a work procedure, such as welding or painting, or
where a toxic atmosphere may develop due to the nature of the confined space,
as in the case of desorption from walls, or evaporation of residual chemicals.
General ventilation is an effective procedure for distributing contaminants
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from a local generation point throughout the work space to obtain maximum
dilution. However, special precautions shall be taken if the ventilating
system partially blocks the exit opening. These precautions include a method
for providing respirable air to each worker for the time necessary for exit,
and a method of maintaining communications.
Local exhaust ventilation shall be provided when general ventilation is
not effective due to restrictions in the confined space or when high
concentrations of contaminants occur in the breathing zone of the worker.
Local high concentrations of contaminants may occur during work activities
such as welding, painting, and chemical cleaning. The worker shall not be
exposed to concen rations of contaminants in excess of those specified in 29
CFR Part 1910 Sub Part Z. Therefore, respiratory protection, as recommended
in Section 8, may be needed in addition to engineering controls. The use of
respiratory protection will be determined by the qualified person. However,
when fumes may be generated that contain highly toxic or other airborne metal
contaminants, the provisions of 29 CFR 1910.252 shall be observed. When
freely moving exhaust hoods are used to provide control of fumes generated
during welding, such hoods shall maintain a velocity of 100 feet per/minute in
the zone of the welding. The effective force of freely moving exhaust hoods
is decreased by approximately 90% at a distance of one duct diameter from the
plane of the exhaust opening. Therefore, to obtain maximum effectiveness the
welder shall re-position the exhaust hood as he changes welding locations to
keep the hood in close proximity to the fume source.
Special precautions shall be taken when outgassing or vaporization of
toxic and/or flammable substances are likely. If the vapor-generating rate
can be determined, the exhaust rate required can be calculated to dilute the
atmosphere below the PEL and/or 10% of the LFL, whichever is the lower. This
shall be the lowest acceptable ventilation rate. If the area of concern is
relatively small, diffusion of the contaminants may be controlled by enclosure
with a relatively low volume exhaust for control, or by exhaust hoods located
as close as possible to the area of vaporization or outgassing. If the area
to be ventilated is too extensive to be controlled by local exhaust, then
general ventilation procedures shall be used to control the contaminant level.
When the problem of outgassing is due to the application of protective
coatings or paint, ventilation shall be continued until the build-up of a
flammable and/or toxic atmosphere is no longer possible.
There are three components necessary for combustion: fuel, oxygen, and a
source of ignition. If work with fire becomes necessary in a confined space
and the source of fuel cannot be controlled, then the atmosphere shall be
inerted. This is a highly hazardous work situation, and continuous monitoring
of the inert make-up ventilation is mandatory. Monitoring shall include flow
measurement as well as gas analysis. The inerting operation shall be
continuously monitored and supervised by the qualified person. Since every
confined space will have its own infiltration rate, inerting shall continue
for the entire duration of the work at a rate that will prevent air from
entering the confined space.
(b) Isolation/Lockout/Tagging (Class A, B)
The isolation procedures shall be specific for each type of confined
space. Safety equipment required during this procedure shall be designated by
the qualified person and be dependent upon the potential hazards involved. A
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Class A or B confined space shall be completely isolated from all other
systems by physical disconnection, double block and bleed, or blanking off all
lines. In continuous systems, where complete isolation is not possible, such
as sewers or utility tunnels, specific written safety procedures that are
approved and enforced by the employer shall be used. Blanks used to seal off
lines shall be capable of withstanding the maximum working pressure or load of
the line (with a minimum safety factor of 4), be provided with a gasket on the
pressure side to insure a leakproof seal, and be made of chemically non-
reactive material. Shutoff valves serving the confined space, shall be locked
in the closed position and tagged for identification. In addition to
blanking, pumps and compressors serving these lines entering the confined
space shall be locked out to prevent accidental activation.
All blanks for that specific confined space shall be recorded on the entry
permit and recorded in the employer's file, which shall be available for
inspection.
If a drain line is located within the confined space, provision shall be
made when necessary to tag it and leave it open. This shall also be recorded
on the entry permit.
Additional procedures, which are necessary when the confined space is of a
double wall type construction, eg, water jacketed or similar type, shall be
determined by the qualified person and noted on the entry permit.
Electrical isolation of the confined space to prevent accidental
activation of moving parts that would be hazardous to the worker is achieved
by locking circuit breakers and/or disconnects in the open (off) position with
a key-type padlock. The only key is to remain with the person working inside
the confined space. If more than one person is inside the confined space,
each person shall place his own lock on the circuit breaker. In addition to
the lockout system, there must be an accompanying tag that identifies the
operation and prohibits use.
Mechanical isolation of moving parts can be achieved by disconnecting
linkages, or removing drive belts or chains. Equipment with moving mechanical
parts shall also be blocked in such a manner that there can be no accidental
rotation.
(c) Cleaning (Class A, B, and C)
Procedures and processes used to clean the inside of a confined space
shall be reviewed and authorized by the qualified person. The method to be
prescribed shall be dependent upon the product in the space. If the confined
space contains a flammable atmosphere above the upper flammable limit, it
shall be purged with an inert gas to remove the flammable substance before
ventilating with air. Initial cleaning shall be done from outside the tank if
at all possible.
Special procedures should be adopted to handle the hazards created by the
cleaning process itself. For example: if the tank is steamed, (1) it shall
be allowed to cool prior to entry; (2) ventilation shall be maintained during
neutralization procedures to prevent build-up of toxic materials; (3) steaming
shall not be used as a cleaning method when the product stored was a liquid
with an autoignition temperature 120% or less of the steam temperature, and
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(4) the pipe or nozzle of the steam hose shall be bonded to the tank to
decrease the generation of static electricity that could accumulate in tanks
during steaming procedures. These and other hazards and controls shall be
evaluated by the qualified person.
(d) Equipment and Tools (Class A, B, and C)
Equipment and tools to be used in a confined space shall be carefully
inspected and shall meet the following requirements:
(1) Hand tools shall be kept clean and in good repair.
(2) Portable electric tools, equipment, and lighting shall be
approved in accordance with 29 CFR Part 1910 Sub Part S and be equipped with a
ground fault circuit interrupter that meets the requirements of 29 CFR
1910.309. All grounds shall be checked before electrical equipment is used in
a confined space.
(3) All electrical cords, tools, and equipment shall be of heavy
duty type with heavy duty insulation and inspected for visually detectable
defects before use in a confined space.
(4) Air driven power tools shall be used when flammable liquids are
present. The use of air driven power tools will reduce the risk of explosion,
not eliminate it. Explosions can arise by tools overheating (drilling),
sparks produced by striking (percussion), grinding or discharge of accumulated
electrostatic charges developed from the flow of compressed air.
(5) Lighting used in Class A and B confined spaces shall be of
explosion proof design and where necessary, equipped with guards. Only
equipment listed by the Underwriters Laboratories for use in Division 1,
atmospheres of the appropriate class and group, or approved by U.S. Bureau of
Mines or Mining Enforcement and Safety Administration or Mine Safety and
Health Administration, or the US Coast Guard shall be used. Lighting shall
not be hung by electric cords, unless specifically designed for that purpose.
The illumination of the work area shall be sufficient to provide for safe work
conditions as referenced in the ANSI standard All-1-1965, or the revision,
1970. Under no circumstances will matches or open flames be used in a
confined space for illumination.
(6) Cylinders of compressed gases shall never be taken into a
confined space, and shall be turned off at the cylinder valve when not in use.
Exempt fron this rule are cylinders that are part of self-contained breathing
apparatus or resuscitation equipment.
(7) Ladders shall be adequately secured, or of a permanent type
which provides the same degree of safety as cited in 29 CFR Part 1910 Sub Part
D.
(8) Scaffolding and staging shall be properly designed to carry
maximum expected load (safety factor of 4), be equipped with traction type
planking, and meet the requirements of 29 CFR 1910.28.
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(9) Electrical lines, junctions and appurtenances will be in
accordance with National Electrical Code (NEC) and National Fire code (NFC) as
cited in 29 CFR 1910.309.
(10) Only hose lines and components designed specially for the
compressed gas and working pressure shall be used, and such systems shall have
a pressure relief valve outside the confined space.
(11) All equipment that may be used in a flammable atmosphere shall
be approved as explosion proof or intrinsically safe for the atmosphere
involved by a recognized testing laboratory such as the US Bureau of Mines,
MESA, or MSHA for methane and by the Underwriters Laboratories or by Factory
Mutual for all cases.
(e) Recordkeeping (Class A, B)
The employer shall maintain a written record of training including safety
drills, inspections, tests, and maintenance. The records shall be retained 1
year after the last date of training, inspection, test, or maintenance. In
the event of separation of the employee, disposal of equipment or appliance,
records may be disposed of after 1 year.
Where atmospheric testing indicates the presence of a toxic substance,
records shall be maintained in accordance with the existing Federal
regulation(s). These records shall include the dates and times of
measurements, duties and location of the employees within the confined space,
sampling and analytical methods used, number, duration, and results of the
samples taken, PEL concentrations estimated from these samples, type of
personal protective equipment used, if any, and employees' names. These
records shall be made available to the designated representatives of the
Secretary of Labor, of the Secretary of Health, Education, and Welfare, of the
employer, and of the employee or former employee.
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II. INTRODUCTION
This document presents the criteria and the recommended standard based
thereon that were prepared to meet the need for preventing occupational
injuries and deaths associated with persons entering, working in, and exiting
confined spaces. This document does not address the specialized areas of
radiation, inert atmospheres or hyperbaric atmospheres; except to recognize
they do exist and represent a potential hazard. The criteria document
fulfills the responsibility of the Secretary of Health, Education, and
Welfare, under Section 20(a)(2) of the Occupational Safety and Health Act of
1970 to "...develop and establish recommended occupational safety and health
standards."
After reviewing data and consulting with others, NIOSH developed criteria
upon which standards can be established to protect the health and to provide
for the safety of workers exposed to occupational hazards. It should be noted
that criteria for a recommended standard should enable management and labor to
develop better work practices and more appropriate training programs that will
result in safer work environments. Simply complying with the recommended
standard should not be the final goal.
The worker who enters a confined space may be, or often is exposed to
multiple hazards due primarily either to ignorance of the potential hazards or
negligence in the enforcement of safety regulations. Ignorance and negligence
have led to deaths by asphyxiation, by fire and explosion, and by fatal
exposure to toxic materials. NIOSH is aware that a number of deaths occur
each year when workers must enter and work in a confined space, and it
recognizes that due to current data collection methods, an estimate of the
injuries and deaths which do occur will be inaccurate. Also, since there is
no specific Standard Industrial Classification where these injuries and deaths
are recorded for confined spaces, they are recorded in several different
categories, thereby giving the appearance of a limited exposure to the hazard.
These criteria for a standard are a part of a continuing series of
documents published by NIOSH. The proposed standard applies only to entering
into, working in, and exiting from confined spaces as applicable under the
Occupational Safety and Health Act of 1970.
The method used in this study consisted of developing, evaluating, and
recording information from extensive literature searches, site visits to
various industries, and consultation with reviewers knowledgeable on the
subject of confined spaces.
Standards covering issues of occupational safety and health that are of
general application without regard to any specific industry are intended to be
applicable to this recommended standard even though no specific reference is
made to them. Examples of these general areas are: exposure to toxic
chemicals, noise, temperature extremes, and general duty requirements.
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III. CONFINED SPACE HAZARDS
Overview and Magnitude of the Problem
(a) Overview
The hazards encountered and associated with entering and working in
confined spaces are capable of causing bodily injury, illness, and death to
the worker. Accidents occur among workers because of failure to recognize
that a confined space is a potential hazard. It should therefore be
considered that the most unfavorable situation exists in every case and that
the danger of explosion, poisoning, and asphyxiation will be present at the
onset of entry.
Before forced ventilation is initiated, information such as restricted
areas within the confined space, voids, the nature of the contaminants
present, the size of the space, the type of work to be performed, and the
number of people involved should be considered. The ventilation air should
not create an additional hazard due to recirculation of contaminants, improper
arrangement of the inlet duct, or by the substitution of anything other than
fresh (normal) air (approximately 20.9% oxygen, 79.1% nitrogen by volume).
The terms air and oxygen are sometimes considered synonymous. However, this
is a dangerous assumption, since the use of oxygen in place of fresh (normal)
air for ventilation will expand the limits of flammability and increase the
hazards of fire and explosion.
Hazardous conditions to be discussed in this Chapter include: Hazardous
Atmospheres (flammable, toxic, irritant, and asphyxiating), and General Safety
Hazards (mechanical, communications, entry and exit, and physical).
An estimation of the number of workers potentially exposed to confined
spaces would be difficult to produce. A report prepared under contract for
NIOSH [1] shows that the rate of confined space related injuries in the
shipbuilding and repair industry is 4.8%. Projected on a national level,
2,448 accidents per year may be attributed to the hazards of working in
confined spaces in this single industry. The Bureau of Labor Statistics shows
that the Standard Industrial Classification (SIC) 373, Shipbuilding and Repair
Industry, has a 23.9% injury rate. Based on this injury rate 57. of all
accidents in the Shipbuilding and Repair Industry occur while working in and
around confined spaces. Because of the lack of data it is not possible at
this time to project this proportion of confined space related injuries to
other industries [2]. Based on the total working population of selected
specific SIC codes, and a rough estimate of the percentage of each category
who may work in confined spaces at some time, NIOSH estimates that millions of
workers may be exposed to hazards in confined spaces each year.
(b) Types of Confined Spaces
Confined spaces can be categorized generally as those with open tops and
with a depth that will restrict the natural movement of air, and enclosed
spaces with very limited openings for entry [3]. In either of these cases the
space may contain mechanical equipment with moving parts. Any combination of
these parameters will change the nature of the hazards encountered.
Degreasers, pits, and certain types of storage tanks may be classified as open
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topped confined spaces that usually contain no moving parts. However, gases
that are heavier than air (butane, propane, and other hydrocarbons) remain in
depressions and will flow to low points where they are difficult to remove
[4]. Open topped water tanks that appear harmless may develop toxic
atmospheres such as hydrogen sulfide from the vaporization of contaminated
water [5]. Therefore, these gases (heavier than air) are a primary concern
when entry into such a confined space is being planned. Other hazards may
develop due to the work performed in the confined space or because of
corrosive residues that accelerate the decomposition of scaffolding supports
and electrical components.
Confined spaces such as sewers, casings, tanks, silos, vaults, and
compartments of ships usually have limited access. The problems arising in
these areas are similar to those that occur in open topped confined spaces.
However, the limited access increases the risk of injury. Gases which are
heavier than air such as carbon dioxide and propane, may lie in a tank or
vault for hours or even days after the containers have been opened [6] .
Because some gases are odorless, the hazard may be overlooked with fatal
results. Gases that are lighter than air may also be trapped within an
enclosed type confined space, especially those with access from the bottom or
side.
Hazards specific to a confined space are dictated by: (1) the material
stored or used in the confined space; as an example, damp activated carbon in
a filtration tank will absorb oxygen thus creating an oxygen deficient
atmosphere [7]; (2) the activity carried out, such as the fermentation of
molasses that creates ethyl alcohol vapors and decreases the oxygen content of
the atmosphere [8]; or (3) the external environment, as in the case of sewer
systems that may be affected by high tides, heavier than air gases, or flash
floods [9].
The most hazardous kind of confined space is the type that combines
limited access and mechanical devices. All the hazards of open top and
limited access confined spaces may be present together with the additional
hazard of moving parts. Digesters and boilers usually contain power-driven
equipment which, unless properly isolated, may be inadvertently activated
after entry. Such equipment may also contain physical hazards that further
complicate the work environment and the entry and exit process.
(c) Reasons for Entering Confined Spaces
Entering a confined space as part of the industrial activity may be done
for various reasons. It is done usually to perform a necessary function, such
as inspection, repair, maintenance (cleaning or painting), or similar
operations which would be an infrequent or irregular function of the total
industrial activity [10].
Entry may also be made during new construction. Potential hazards should
be easier to recognize during construction since the confined space has not
been used. The types of hazards involved will be limited by the specific work
practices. Uhen the area meets the criteria for a confined space, all
ventilation and other requirements should be enforced.
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One of the most difficult entries to control is that of unauthorized
entry, especially when there are large numbers of workers and trades involved,
such as welders, painters, electricians, and safety monitors.
A final and most important reason for entry would be emergency rescue.
This, and all other reasons for entry, must be well planned before initial
entry is made and the hazards must be thoroughly reviewed. The standby person
and all rescue personnel should be aware of the structural design of the
space, emergency exit procedures, and life support systems required.
Hazardous Atmospheres
Hazardous atmospheres encountered in confined spaces can be divided into
four distinct categories: (a) Flammable, (b) Toxic, (c) Irritant and/or
Corrosive, and (d) Asphyxiating.
(a) Flammable Atmosphere
A flammable atmosphere generally arises from enriched oxygen atmospheres,
vaporization of flammable liquids, byproducts of work, chemical reactions,
concentrations of combustible dusts, and desorption of chemicals from inner
surfaces of the confined space.
Alther [H] reported on a case involving workers in an enriched oxygen
atmosphere. Two men entered a newly constructed tank to repair a bulge which
had formed after the flange of the manhole was welded to the tank. The
planned repair procedure was to have two men enter the tank with a jack to
force the flange of the manhole into place while a third worker heated the
bulge from the outside. To accomplish this procedure the men had to close the
manhole. To improve the air within the tank, oxygen used for welding was
blown in through an opening. A worker on the outside noticed through the
opening that the hair of one of the workmen inside was on fire. The cover was
immediately removed and one of the workers managed to escape, his clothing was
burning rapidly, the second worker had collapsed and remained unconscious
inside. It became necessary to invert the tank to remove the unconscious
workman. Both workmen who were doing the work inside suffered serious burns.
One died a short time later; the second was hospitalized for several months.
A rescuer in the operation was burned on the hands.
Investigation of the accident revealed the use of oxygen in place of
normal air increased the flammability range of combustibles. Enrichment of
the atmosphere with only a few percent of oxygen above 21% will cause an
increase in the range of flammability, hair as well as clothing will absorb
the oxygen and burn violently. Enriched oxygen atmospheres which expand the
region of flammability could be the result of improper blanking off of oxygen
lines, chemical reactions which liberate oxygen, or inadvertently purging the
space with oxygen in place of air [11].
An atmosphere becomes flammable when the ratio of oxygen to combustible
material in the air is neither too rich nor too lean for combustion to occur.
Combustible gases or vapors will accumulate when there is inadequate
ventilation in areas such as a confined spa,ce. Flammable gases such as
acetylene, butane, propane, hydrogen, methane, natural or manufactured gases
or vapors from liquid hydrocarbons can be trapped in confined spaces, and
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since many gases are heavier than air, they will seek lower levels as in pits,
sewers, and various types of storage tanks and vessels [12,13]. In a closed
top tank, it should also be noted that lighter than air gases may rise and
develop a flammable concentration if trapped above the opening.
The byproducts of work procedures can generate flammable or explosive
conditions within a confined space. Specific kinds of work such as spray
painting can result in the release of explosive gases or vapors [14]. Table
III-3 shows that approximately one-third of the events identified as
"atmospheric condition" were the result of the victims performing activities
that generated fumes or depleted the oxygen supply. The most common of these
activities was welding in a confined space. Welding in a confined space was a
major cause for explosions in areas that contained combustible gas [1].
Chemical reactions forming flammable atmospheres occur when surfaces are
initially exposed to the atmosphere, or when chemicals combine to form
flammable gases. This condition arises when dilute sulfuric acid reacts with
iron to form hydrogen or when calcium carbide makes contact with water to form
acetylene. Other examples of spontaneous chemical reactions that may produce
explosions from small amounts of unstable compounds are acetylene-metal
compounds, peroxides, and nitrates. ,In a dry state these compounds have the
potential to explode upon percussion or exposure to increased temperature.
Another class of chemical reactions that form flammable atmospheres arise from
deposits of pyrophoric substances (carbon, ferrous oxide, ferrous sulfate,
iron, etc) that can be found in tanks used by the chemical and petroleum
industry. These tanks containing flammable deposits, will spontaneously
ignite upon exposure to air [15].
Combustible dust concentrations are usually found during the process of
loading, unloading, and conveying grain products, nitrated fertilizers, finely
ground chemical products, and any other combustible material. It has been
reported that high charges of static electricity, which rapidly accumulate
during periods of relatively low humidity (below 50%) , can cause certain
substances to accumulate electrostatic charges of sufficient energy to produce
sparks and ignite a flammable atmosphere [14]. These sparks may also cause
explosions when the right air or oxygen to dust or gas mixture is present.
Desorption of chemicals from the inner surfaces of a confined space is
another process that may produce a flammable atmosphere. This is often a
natural phenomenon in which the partial pressure at the interface between the
surfaces and the stored chemical is radically reduced. For example, after
liquid propane is removed from a storage tank the walls of the vessel may
desorb the remaining gas from the porous surface of the confined space.
Dorias [16] reported on an explosive gas-air mixture in a horizontal
cylindrical container (1000 m3) , which had contained liquid propane. The
cylinder was emptied to check for stress cracking. The space was to be filled
with water to expell the gas, and drained so it could automatically fill with
normal air. The container was presumably filled full of water arid drained.
The gas analysis of the resulting space showed an explosive gas-air mixture.
The procedure of filling with water and draining was repeated and the test
results were the same, an explosive gas-air mixture. To speed up the process,
a man climbed into the cylinder and sprayed the interior with water for 3
hours, and allowed the interior to air dry. On the 4th day, a mechanic
entered the tank and prepared the areas to be inspected for stress. Following
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this, a man entered the tank with a test device and a Katel lamp (220 volts
not of an explosion-proof design) . There was a sudden explosion and flame
streamed out of the entry manhole. The man who was testing the atmosphere
suffered severe injuries from which he died 6 days later. Investigation of
the events revealed that the tanks were filled only 50% full the first time
and only 80-90% full the second time. Therefore, it was concluded the space
was never thoroughly emptied of all gas. Reconstruction of the operation
showed that the spraying operation did not remove all the propane, and left a
gas-air mixture of approximately 57, propane by volume, an extremely explosive
condition [16] .
(b) Toxic Atmospheres
The substances to be regarded as toxic in a confined space can cover the
entire spectrum of gases, vapors, and finely-divided airborne dust in industry
[17]. The sources of toxic atmospheres encountered may arise from the
following:
(1) The manufacturing process (for example, in producing polyvinyl
chloride, hydrogen chloride is used as well as vinyl chloride monomer which is
carcinogenic) .
(2) The product stored (removing decomposed organic material from a
tank can liberate toxic substances such as
(3) The operation performed in the confined space (for example,
welding or brazing with metals capable of producing toxic fumes) .
Zavon [18] reported, in 1970, that four employees of a local utility were
repairing a water meter in an underground vault 18 feet x 6 feet x 5 feet with
an opening 24 inches in diameter. To make the repairs, it was necessary to
cut 26 cadmium plated bolts with an oxygen propane torch. Two men worked in
the vault with one man cutting and the other standing beside him. Neither man
wore a respirator and no ventilation was provided. Two other men remained on
the surface. During the cutting of the bolts with the oxygen propane torch, a
"heavy blue smoke" filled the vault. This smoke was exhausted after the
cutting was completed.
The 56-year-old man who had cut the bolts died 17 days after exposure. He
became nauseated shortly after the job and was seen by his family physician
the next day for fever (102-103 F) , chest pain, cough, and sore throat. On
the 4th day following the incident he was in greater distress and was
hospitalized. Death occurred in 2 weeks and was attributed to massive
coronary infarction and corpulmonale . The 29-year-old assistant complained of
chills, nausea, cough and difficulty in breathing. He was treated for
pneumonia and made a slow recovery. A reenactment of the work demonstrated
that the exposure to cadmium was well above the threshold limit value of "0.1
mg/m3" [18]. Symptoms attributed to cadmium poisoning include: severe labored
breathing and wheezing, chest pain, persistent cough, weakness and malaise,
and loss of appetite. The clinical course is similar in most cases. The
injured frequently are well enough to work the day after exposure, but their
conditions deteriorate until approximately the 5th day. At this point, the
exposed worker will either get much worse or begin to improve [19].
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Toxic gases may be evolved when acids are used for cleaning. Hydrochloric
acid can react chemically with iron sulfide to produce hydrogen sulfide [20].
Iron sulfide is formed on the walls of cooling jackets when only several parts
per million sulfide are in the water used in the cooling process. As an
example, 5 men were overcome while cleaning a heat exchanger using a
hydrochloric acid solution [20].
Another area where the hydrogen sulfide hazard exists is in the tanning
industry. Lime pits used in the process of removing hair from the hides
contain in addition to lime, a 1% solution of sodium sulfate (NajSOi,). Acid
dichromate solution is also used in the tanning process. If these two
solutions (sodium sulfate and acid dichromate) are combined accidentally,
hydrogen sulfide (H2S) will be produced. One such incident occurred when
several unused pits at a tannery were being cleaned. Sludge had formed on the
bottom of the pit due to drainage from the hides when they had been treated
with lime and acid dichromate. When men entered the pit to clear the drain
line, they were overcome. Because of the high specific gravity of hydrogen
sulfide, the gas formed by the sodium sulfide-dichrornate reaction had settled
in the pit, and when the sludge was stirred the released gas overcame the
workers. In this instance, 5 men became unconscious and two died [21]. The
particular hazard associated with hydrogen sulfide at higher concentrations is
due to its physiological effect of anesthetizing the olfactory nerves and can
also cause a loss of reasoning, paralysis of the respiratory system,
unconsciousness, and death [22,23].
During loading, unloading, formulation, and production, mechanical and/or
human error may also produce toxic gases which are not part of the planned
operation.
Toxic solvents, which present problems [24], such as trichloroethylene,
methyl chloroform, and dichloromethane, are used in industry for cleaning and
degreasing. Acrylonitrile, infrequently used, has been encountered as an
ingredient in a protective coating applied to tank interiors [17].
Trichloroethane and dichloroethane are widely used in industry as cleaning
solvents because they are among the least toxic of the chlorinated aliphatic
hydrocarbons. These solvents have been used as a replacement for carbon
tetrachloride and trichloroechylene [25-27] .
In a case report by Hatfield and Maykoski [28] trichloroethane, also known
as methyl chloroform was substituted for trichloroethylene because of the high
toxicity of the latter. A radiator and metal tank repairman was involved in
an aircraft tip tank cleaning and assembly operation. The technique of
cleaning the interior of the tanks varied among workers. Some workmen would
moisten a pad with solvent and would hand wipe the metal surfaces by reaching
through an opening on the end of the tank; some would use pads on the end of a
shaft, while others would climb inside and clean. One particular worker would
saturate a pad with solvent and lower himself head first into the down-tilted
tip of the tank and clean as fast as possible. This worker was found with his
legs protruding from the upper end of the 450 gallon tank and was
unresponsive. He was removed immediately and was given artificial respiration
until a physician arrived and pronounced him dead.
Reconstruction of the fatal accident revealed the concentration of methyl
chloroform in the tank had reached 62,000 ppm. The workers assumed that since
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the new cleaning solvent was less toxic than the one previously used, there
was less danger. However, the new cleaning solvent, methyl chloroform, is a
potent anesthetic at 30,000 ppm, which was less than half the concentration
level in the worker's breathing zone.
The compatibility of materials must be considered when structural members
and equipment are introduced in confined spaces. The previous history of the
confined space must be carefully evaluated to avoid reactions with residual
chemicals, wall scale, and sludge which can be highly reactive. One such case
was reported in May of 1968, when an aluminum ladder was used for entry into a
chemical evaporating tank which had contained aqueous sodium arsenite (Na As02
H20) and sodium hydroxide (NaOH) . The aluminum reacted with the NaAs02 And
the NaOH to liberate hydrogen, which in turn reacted with the arsenic to form
arsine [29]. Other cases of incompatability arise from the use of chemical
cleaning agents. The initial step in chemical cleaning usually is the
conversion of the scale or sludge into a liquid state which may cause
poisonous gases to be liberated. In 1974, several employees who were cleaning
a boiler tank prior to repairing a leak used a cleaning fluid, Vestan 675.
The cleaning action caused the release of ammonia fumes that were not properly
exhausted. The men were hospitalized with severe chest pains, but recovered
[29].
Another hazardous gas that may build up in a confined space is carbon
monoxide (CO). This odorless colorless gas that has approximately the same
density of air is formed from Incomplete combustion of organic materials such
as wood, coal, gas, oil, and gasoline [30]; it can be formed from raicrobial
decomposition of organic matter in sewers, silos, and fermentation tanks.
Carbon monoxide is an insidious toxic gas because of its poor warning
properties. Early stages of carbon monoxide intoxication are nausea and
headache. Carbon monoxide may be fatal at 1000 ppm in air, and is considered
dangerous at 200 ppm, because it forms carboxyhemoglobin in the blood which
prevents the distribution of oxygen in the body.
Carbon monoxide (CO) is a relatively abundant colorless, odorless gas,
therefore, any untested atmosphere must be suspect. It must also be noted
that a safe reading on a combustible gas indicator does not ensure that CO is
not present [14]. Carbon monoxide must be tested for specifically. The
formation of CO may result from chemical reactions or work activities,
therefore, fatalities due to CO poisoning are not confined to any particular
industry. There have been fatal accidents in sewage treatment plants [8] due
to decomposition products and lack of ventilation in confined spaces. Another
area where CO results as a product of decomposition is in the formation of
silo gas in grain storage elevators [8] . In another area, the paint industry,
varnish is manufactured by introducing the various ingredients into a kettle,
and heating them in an inert atmosphere, usually town gas, which is a mixture
of carbon dioxide and nitrogen. In one accident report, a maintenance
engineer entered a kettle that had been vented for 12-24 hours to check a
blocked sampling tube. He was found dead some time later. Death was due to
carbon monoxide poisoning. Investigation into the inert gas supply system
revealed that the CO content of the town gas was over 1% (10,000 ppm), and
that there were minor faults in the protective valves into the kettle so that
a small leak was occurring. The employee had entered an atmosphere of reduced
oxygen partial pressure containing CO and had succumbed before he could save
himself [21]. In many cases CO poisoning occurs because of poor work
practices.
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In welding operations, oxides of nitrogen and ozone are gases of major
toxicologic importance, and incomplete oxidation may occur and carbon monoxide
can form as a byproduct [31] . One such case, documented in the Pennsylvania
Occupational Injury Files of 1975, involved an employee who was overcome by
carbon monoxide while welding inside a copper heat-treating oven with the door
partially closed.
Another poor work practice, which has led to fatalities, is the
recirculation of diesel exhaust emissions [32]. Tests have shown that
although the initial hazard due to exhaust toxicants may be from increased C02
levels (or depleted 02), the most immediate hazard to life processes is CO
[33]. Increased CO levels can only be prevented by strict control of the
ventilation or the use of catalytic converters.
(c) Irritant (Corrosive) Atmosphere
Irritant or corrosive atmospheres can be divided into primary and
secondary groups. The primary irritants exert no systemic toxic effects
because the products formed by them on tissues of the respiratory tract are
non-irritant, and other irritant effects are so violent as to obscure any
systemic toxic action. Examples of primary irritants are chlorine (Cla),
ozone (03), hydrochloric acid (HC1), hydrofluoric acid (HF), sulfuric acid
(H2SOH), nitrogen dioxide (N02), ammonia (NH3), and sulfur dioxide (S02). A
secondary irritant is one that may produce systemic toxic effects in addition
to surface irritation. Examples of secondary irritants include benzene
(C6H6), carbon tetrachloride (CC1, ), ethyl chloride (CH3CH2C1),
trichloroethane (CH^CCLa), trichloroethylene (CHC1CC12), and chloropropene
(allyl chloride-CH2CHCH2Cl) [34].
Irritant gases vary widely among all areas of industrial activity. They
can be found in plastics plants, chemical plants, the petroleum industry,
tanneries, refrigeration industries, paint manufacturing, and mining
operations [17].
Prolonged exposure at irritant or corrosive concentrations in a confined
space may produce little or no evidence of irritation. This has been
interpreted to mean that the worker has become adapted to the harmful agent
.involved. In reality, it means there has been a general weakening of the
defense reflexes from changes in sensitivity, due to damage of the nerve
endings in the mucous membranes of the conjunctivae and upper respiratory
tract. The danger in this situation is that the worker is usually not aware
of any increase in his exposure to toxic substances [17],
(d) Asphyxiating Atmosphere
The normal atmosphere is composed approximately of 20.9% oxygen and 78.1%
nitrogen, and 1% argon with small amounts of various other gases. Reduction
of oxygen (02) in a confined space may be the result of either consumption or
displacement [35].
The consumption of oxygen takes place during combustion of flammable
substances, as in welding, heating, cutting, and brazing. A more subtle
consumption of oxygen occurs during bacterial action, as in the fermentation
process. Oxygen may also be consumed during chemical reactions as in the
formation of rust on the exposed surface of the confined space (iron oxide).
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The number of people working in a confined space and the amount of their
physical activity will also influence the oxygen consumption rate.
A second factor in oxygen deficiency is displacement by another gas.
Examples of gases that are used to displace air, and therefore reduce the
oxygen level are helium, argon, and nitrogen. Carbon dioxide may also be used
to displace air and can occur naturally in sewers, storage bins, wells,
tunnels, wine vats, and grain elevators. Aside from the natural development
of these gases, or their use in the chemical process, certain gases are also
used as inerting agents to displace flammable substances and retard pyrophoric
reactions. Gases such as nitrogen, argon, helium, and carbon dioxide, are
frequently referred to as non-toxic inert gases but have claimed many lives
[36]. The use of nitrogen to inert a confined space has claimed more lives
than carbon dioxide. The total displacement of oxygen by nitrogen will cause
immediate collapse and death. Carbon dioxide and argon, with specific
gravities of 1.53 and 1.38, respectively, (air = 1) may lie in a tank or
manhole for hours or days after opening [36]. Since these gases are colorless
and odorless, they pose an immediate hazard to health unless appropriate
oxygen measurements and ventilation are adequately carried out.
In a report by the Ontario (Canada) Health Department, an underground oil
storage tank which required cleaning, had been blanketed with nitrogen to
prevent oxidation of the oil. The man assigned to clean the tank dropped an
air hose into the tank before entering. As he reached the bottom of the
ladder, he passed out. His helper outside the tank went in to help and
feeling faint, left without getting the man out. He went to get assistance
from a nearby maintenance shop. Three men came to the tank and climbed down
and all were overcome. Finally, after about 20 minutes, all four men were
recovered with the help of the fire department. The only reason that there
were no fatalities was that an airline in the tank was blowing air into the
vicinity of the fallen workers [37].
Oxygen deprivation is one form of asphyxiation. While it is desirable to
maintain the atmospheric oxygen level at 21% by volume, the body can tolerate
deviation from this ideal. When the oxygen level falls to 17%, the first si3n
of hypoxia is a deterioration to night vision which is not noticeable until a
normal oxygen concentration is restored. Physiologic effects are increased
breathing volume and accelerated heartbeat. Between 14-16% physiologic
effects are increased breathing volume, accelerated heartbeat, very poor
muscular coordination, rapid fatigue, and intermittent respiration. Between
6-10% the effects are nausea, vomiting, inability to perform, and
unconsciousness. Less than 6%, spasmatic breathing, convulsive movements, and
death in minutes [12,38].
In discussing oxygen and what constitutes an oxygen deficient atmosphere
from a physiologic view, one must address the concept of partial pressures.
At sea level the normal atmospheric pressure for air (20.9% 02 + 78.1% N2 + 1%
Ar + trace amounts of various inert gases) is 14.7 psi or 760 mm Hg absolute.
The partial pressure of 02 (POj) at sea level will be approximately 160 mm Hg.
The concept of partial pressures is that in any mixture of gases, the total
gas pressure is the sum of the partial pressures of all the gases [39].
The P02 in ambient air can be decreased by a reduction in the 02 level at
constant pressure or by maintaining the percentage of 02 constant and
decreasing the total atmospheric pressure as in the case at high altitudes.
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It is important not only to know the 02 percent by volume, but to understand
the relationship of 02 to altitude and the concept of partial pressure. For
example, 20.9% QZ in air at sea level constitutes a greater P02 than 20.9% Qz
at 5,000 feet because the total atmospheric pressure at 5,000 feet is less.
As the POa in the atmosphere drops, the volume of air required to maintain a
POa of 60 mm Hg in the alveolar space of the lungs increases. A POz below 60
mm Hg in the alveolar space is considered oxygen deficient [39].
Absorption of oxygen by the vessel or the product stored therein is
another mechanism by which the fO2 may be reduced and result in an oxygen
deficient atmosphere. For example, activated carbon, usually considered as an
innocuous material free of occupational hazard and toxicity, was responsible
for two fatalities in a carbon filtration tank. Damp activated carbon absorbs
oxygen and has been known to decrease the oxygen level from 21% to 4% in a
closed vessel [7].
Montgomery et al [7] reported on two fatalities caused by the use of
activated carbon in a water filtration vessel, (12.5 feet in diameter and 17
feet high). The space was newly constructed, filled halfway with granular
carbon in a slurry form (water medium), the water was drained off through a
bottom drain, and the tank was closed off to protect it from the weather. The
next morning two workers entered the filtration vessel to perform necessary
adjustments to the carbon bed and the interior sprinkler mechanism. When the
workmen failed to appear at lunch time, they were found dead on the carbon
bed. However, a rescuer entered the tank without any type of respiratory
protection and with no ill affects. Tests of the atmosphere revealed no cause
of death, the oxygen level was 21%, hydrocarbon and hydrogen sulfide tests
were negative.
The investigation of the fatalities revealed the following: the tank was
re-closed and re-opened the following day. No toxic gases were found;
however, the oxygen level had dropped from 21% to 12% by volume. Other
vessels checked at this location which had been closed for several weeks
revealed the oxygen level was down to 2%.
In summary, it was discovered that dry carbon would not reduce the oxygen
level significantly. Damp activated carbon, however, supposedly an innocuous
material and free from toxicity, contributed to the death of two workers as a
result of selective absorption of oxygen in a confined space with no
ventilation.
General Safety Hazards
(a) Mechanical
If activation of electrical or mechanical equipment would cause injury,
each piece of equipment should be manually isolated to prevent inadvertent
activation before workers enter or while they work in a confined space.
[12,40]. The interplay of hazards associated with a confined space, such as
the potential of flammable vapors or gases being present, and the build-up of
static charge due to mechanical cleaning, such as abrasive blasting, all
influence the precautions which must be taken.
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To prevent vapor leaks, flashbacks, and other hazards, workers should
completely isolate the space [41]. To completely isolate a confined space the
closing of valves is not sufficient. All pipes must be physically
disconnected or isolation blanks bolted in place [5]. Other special
precautions must be taken in cases where flammable liquids or vapors may re-
contaminate the confined space. The pipes blanked or disconnected should be
inspected and tested for leakage to check the effectiveness of the procedure.
Other areas of concern are steam valves, pressure lines, and chemical transfer
pipes. A less apparent hazard is the space referred to as a void, such as
double walled vessels, which must be given special consideration in blanking
off and inerting.
(b) Communication Problems
Communication between the worker inside and the standby person outside is
of utmost importance. If the worker should suddenly feel distressed and not
be able to sumnon help, an injury could become a fatality. Frequently, the
body positions that are assumed in a confined space make it difficult for the
standby person to detect an unconscious worker [10]. When visual monitoring
of the worker is not possible because of the design of the confined space or
location of the entry hatch, a voice or alarm-activated explosion proof type
of communication system will be necessary [15].
Suitable illumination of an approved type is required to provide
sufficient visibility for work in accordance with the recommendations made in
the Illuminating Engineering Society Lighting Handbook.
(c) Entry and Exit
Entry and exit time is of major significance as a physical limitation and
is directly related to the potential hazard of the confined space. The extent
of precautions taken and the standby equipment needed to maintain a safe work
area will be determined by the means of access and rescue. The following
should be considered: type of confined space to be entered, access to the
entrance, number and size of openings, barriers within the space, the
occupancy load, and the time requirement for exiting in event of fire, or
vapor incursion, and the time required to rescue injured workers [41].
(d) Physical
The hazards described in this section include non-chemical, physiologic
stressors. These include thermal effects (heat and cold), noise, vibration,
radiation, and fatigue while working in a confined space.
(1) Thermal Effects
Four factors influence the interchange of heat between man and his
environment. They are: (1) air temperature, (2) air velocity, (3)
moisture contained in the air, and (4) radiant heat [42,43]. Because of the
nature and design of most confined spaces, moisture content and radiant heat
are difficult to control. As the body temperature rises progressively,
workers will continue to function until the body temperature reaches 38.3 -
39.4 C. when this body temperature is exceeded, the workers are less
efficient, and are prone to heat exhaustion, heat cramps, or heat stroke [44].
In a cold environment certain physiologic mechanisms come into play, which
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tend to limit heat loss and increase heat production. The most severe strain
in cold conditions is chilling of the extremities so that activity is
restricted [42]. Special precautions must be taken in cold environments to
prevent frostbite, trench foot, and general hypothermia.
Protective insulated clothing for both hot and cold environments will add
additional bulk to the worker and must be considered in allowing for movement
in the confined space and exit time. Therefore, air temperature of the
environment becomes an important consideration when evaluating working
conditions in confined spaces.
(2) Noise
Noise problems are usually intensified in confined spaces because the
interior tends to cause sound to reverberate and thus expose the worker to
higher sound levels than those found in an open environment. This intensified
noise increases the risk of hearing damage to workers which could result in
temporary or permanent loss of hearing. Noise in a confined space which may
not be intense enough to cause hearing damage may still disrupt verbal
communication with the emergency standby person on the exterior of the
confined space. If the workers inside are not able to hear commands or danger
signals due to excessive noise, the probability of severe accidents can
increase [42].
(3) Vibration
Wholebody vibration may be regarded as a "generalized stressor" and
may affect multiple body parts and organs depending upon the vibration
characteristics. Segmental vibration, unlike wholebody vibration, appears to
be more localized in creating injury to the fingers and hands of workers using
tools, such as pneumatic hammers, rotary grinders or other hand tools which
cause vibration [42],
(4) General/Physical
Some physical hazards cannot be eliminated because of the nature of the
confined space or the work to be performed. These hazards include such items
as scaffolding, surface residues, and structural hazards. The use of
scaffolding in confined spaces has contributed to many accidents caused by
workers or materials falling, improper use of guard rails, and lack of
maintenance to insure worker safety. The choice of material used for
scaffolding depends upon the type of work to be performed, the calculated
weight to be supported, the surface on which the scaffolding is placed, and
the substance previously stored in the confined space.
Surface residues in confined spaces can increase the already hazardous
conditions of electrical shock, reaction of incompatible materials, liberation
of toxic substances, and bodily injury due to slips and falls. Without
protective clothing, additional hazards to health may arise due to surface
residues.
Structural hazards within a confined space such as baffles in horizontal
tanks, trays in vertical towers, bends in tunnels, overhead structural
members, or scaffolding installed for maintenance constitute physical hazards,
which are exacerbated by the physical surroundings. In dealing with
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structural hazards, workers must review and enforce safety precautions to
assure safety.
Rescue procedures may require withdrawal of an injured or unconscious
person. Careful planning must be given to the relationship between the
internal structure, the exit opening, and the worker. If the worker is above
the opening, the system must include a rescue arrangement operated from
outside the confined space, if possible, by which the employee can be lowered
and removed without injury
Statistical Data
Accidents in confined spaces, like all others, are required by Federal
regulations to be reported only if medical attention or loss of time from
work, or death is involved. Some states and workers' compensation carriers
have slightly more stringent requirements, but none require the reporting of
incidents which can be considered near misses. The report by Safety Sciences
prepared under contract for NIOSH [1] tended to show that fatalities occurred
more frequently in confined spaces. For example, death by asphyxiation would
be reported; however, if an employee experienced shortness of breath or
dizziness, but managed to escape the confined space, and was not treated by a
physican, this would probably not be a reported case.
The criteria used in selecting cases was based on the definition published
in the Federal Register 42:213, November 4, 1977 and specific circumstances
likely to be found on injury and fatality records.
Table I1I-1 shows the number of "events", injuries, and fatalities from
each data source. "Events" refers to the number of separate occasions in
which one or more confined space-related injuries or illnesses occurred [1].
Table III-2 shows the number of events, injuries and fatalities obtained
for each of the 15 basic accident and illness types which are described in
Appendix 4 of this document. A total of 276 confined space related events
were identified, which resulted in a total of 234 injuries and 193 fatalities.
The table shows that the most hazardous conditions in a confined space are a
result of atmospheric related events [1].
Table I1I-3 shows the number of events by SIC code for each of the 15
confined space-related accident and illness types [1].
31
100
-------
TABLE III-l
NUMBER OF CONFINED SPACE-RELATED CASES OBTAINED BY DATA SOURCE
1.
2.
3.
4.
Data Source
First Reports
from Previous
NIOSH Study 1974-75
OSHA 36's 1976-77
Equifax, Inc.
"Occupational
Death Reports"
8/76-12/76
Shipbuilding and
Repair Cases 1976-77
Totals
Approx. No. of
Cases Reviewed
20,000
6,000
1,700
750
28,450
No. of
Events
67
132
41
36
276
No. of
Injuries
66
130
2
36
234
No. of
Fatalities
1
143
49
0
193
Safety Sciences, San Diego, California - 1977 [1]
32
101
-------
TABLE III-2
ACCIDENT AND ILLNESS TYPE
CONFINED SPACE (CS)
Ref .
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Totals
Safety
Accident and Illness Type
Atmospheric Condition in CS
Explosion or Fire in CS
Explosion or Fire at Point-of-Entry
to CS
Electrocution or Electrical Shock
Caught In/ Crushing of CS
Trapped in Unstable Materials in CS
Struck by Falling Objects in CS
Falls (while in CS; not into CS)
Ingress/Egress of CS
Insufficient Maneuverability in CS
Eye Injury in CS
Contact with Temperature Extreme
in CS
Noise in CS
Vibration in CS
Stress from Excess Exertion in CS
Sciences, San Diego, California - 1977
33
102
Events
80
15
23
11
10
16
15
27
33
15
10
7
1
1
12
276
[1]
Injuries
72
49
20
2
3
0
1
26
30
15
10
4
1
1
0
234
Fatalities
78
15
32
9
10
16
14
1
3
0
0
3
0
0
12
193
-------
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105
-------
IV. DEVELOPMENT OF THE STANDARD
Previous Standards
The basis for most of the previous standards were safety codes designed
for specific industrial activities, and dealt with areas such as open surface
tanks, welding and cutting, and the pulp and paper, and shipping industries.
The most recent standard published on confined spaces is the 12-year
effort compiled by the American National Standards Institute, Zl17.1-1977.
Despite the effort, the ANSI standard does not address the vitally important
areas of training of personnel and specific recommendations for the safety
equipment required in a confined space. All personal protective equipment is
referenced to different ANSI Standards, which are broad based and do not
address the specific problems of confined spaces.
The- ANSI Standard also accepts the use of tagging as a reliable method of
locking out a potentially hazardous situation. The tagging system as a
substitute for locking out all lines or pipes, or de-energizing systems of a
confined space does not provide sufficient protection to the worker against
accidental activation.
The ANSI Standard does mention the use of life lines; however, the only
recommendation is for their use in an oxygen deficient atmosphere.
The General Industry Safety and Health Standards of the Occupational
Safety and Health Administration (OSHA) address safety in confined spaces in
over 50 different sections of 29 CFR 1910. The defining parameters of a
confined space as given in the OSHA regulations are: (1) limited means of
exit, (2) a space subject to accumulation of toxic or flammable contaminants
or, (3) one where an oxygen deficient atmosphere may develop. It includes but
is not limited to such spaces as storage tanks, process vessels, bins, boilers
and open top spaces more than 4 feet in depth. This is essentially the same
definition used to establish the scope of this recommended criteria. However
the "Classification of open-surface tank operation" (1910.94 (d) (2) (i-ii))
differs from the classification system proposed in this document. This
proposed classification system is intended to apply to all confined spaces and
is based upon the evaluation of several additional parameters. Such a
classification will allow the application of a wider range of safety measures
and ease the enforcement of the OSHA regulation. The confined space
classification system was designed to create a focal point by drawing together
over 140 references in the OSHA standards. For example, the use of life lines
in all confined spaces, has been addressed in this document and a solution to
their excessive use has been proposed. The two documents agree on many areas
of good work practices, such as the use of standby personnel, blanked-off
lines, and main shutoff valves. Another area of agreement is the acceptance
of 19.5% as the minimal oxygen level for safe work practice. There are some
areas of the OSHA regulations that appear to accept tagging as a sufficient
measure to ensure against opening of valves or energizing equipment during
entry or while working in confined spaces. The proposed standard is more
stringent in that only locking-out, blanking-off or disconnection are
acceptable.
1306
-------
Canadian [45] and Australian [46,47] regulations and standards on confined
space entry were reviewed. The Canadian Standard uses a hazard evaluation
report, which appears to be a condensed form of the recommended permit system.
The Canadian Standard also relies on the qualified person to make decisions
for entry and necessary precautions for working in and for making emergency
escape. A minimum safe level of oxygen for entry is not stated, only what is
considered an oxygen deficient atmosphere (less than 17% by volume). The
Australian Standard, which comes under the Factories' Regulations, states the
confined space shall be emptied and flushed of hazardous substances and be
ventilated with fresh air before entry. The Australian Standard is concerned
primarily with entry and exit, not with isolation or safe oxygen level. The
Australian Standard does; however, refer to a competent person similar to the
qualified person for testing the atmosphere for flammable level. Other
countries [14,48-50] published guidelines or standards for entering and
working in confined spaces. Many of those reviewed follow recommendations
similar to the Australian and Candadian standards. Therefore, it would be
redundant to make a lengthy comparative list of standards. The state
standards reviewed [8,12,51-54] and those from industry [40,55-68] were also
closely evaluated. The number of references involved prohibits the citing of
each one, although valuable concepts were obtained.
Basis for the Recommended Standard
Workers who enter and work in confined spaces are confronted with many
potentially hazardous conditions. The hazards can range from an oxygen
deficient atmosphere or liberation of a toxic agent, to mechanical equipment
accidentally energized. The hazardous atmospheres that can be encountered in
a confined space are; flammable, toxic, irritant and/or corrosive, and
asphyxiation. These atmospheric conditions are discussed in Chapter III,
along with cited accident cases to emphasize the hazards involved with
confined space entry.
The limited statistical data available on accidents and injuries directly
related to confined spaces indicate a very high mortality level. This
disproportionately high mortality level for the number of reported accidents
and injuries could be the result of inadequate reporting methods, as not
reporting a near miss with death, or data collection systems failing to list a
confined space as a causative or other factor in traumatic accidents. In the
accident and injury cases tabulated for this document, atmospheric conditions
in confined spaces were responsible for the most frequent accident type in
terms of events and number of persons killed or injured [1] .
The work practices section in Chapter I of the recommended standard was
developed after extensive review of published literature, [2,11,15-
17,31,33,36,55-92] the current Federal, State, and local applicable codes,
[8,12,51-54,93-101], international codes or recommendations [3,45-50,102], and
site visits to facilities where working in confined spaces is part of the
industrial activity.
(a) Testing and Monitoring
Prior to entry into a confined space, workers should know the space's
potential hazards. Deaths have occurred because a presumably safe space was
not tested prior to initial entry [7,13]. The various tests to be performed
38
107
-------
prior'to entry shall include tests for flammability, toxic agents, oxygen
deficiency, and harmful physical agents. Specific instruments are required
for testing the atmosphere for flammability, oxygen deficiency, carbon
monoxide, and physical agents. For example, combustible gas indicators are
designed for the purpose of measuring the concentration of flammable gases ,
and will not measure or indicate the presence of carbon monoxide at toxic
levels, conversely a carbon monoxide detector is designed for the measurement
of carbon monoxide only. It should be noted that combustible gas indicators
respond differently to different flammable hydrocarbons and should be
calibrated for the specific contaminant if known. The flammability
measurement may be erroneous if the oxygen level is less or greater than
normal atmospheric concentrations. Therefore, it is recommended that the
oxygen level be determined prior to flammability testing to make any necessary
corrections in the flammability measurement.
When the materials may form a combustible dust mixture, special
precautions must be taken to prevent an explosive atmosphere from developing.
There are numerous instruments available for measuring airborne dust
concentrations; however, none appear to have automatic alarm systems and would
require constant personal monitoring. The only practical approach to the
control of combustible dusts is to eliminate the hazard by preventive
measures, such as, (1) engineering controls, (2) good housekeeping, (3)
elimination of ignition sources, (4) isolation of dust producing operations
and, (5) training and education of the employees.
The oxygen deficiency measuring instrument is designed to measure the
volume of oxygen present, usually scaled with a range of 0.0-25%. If the
percentage of oxygen in a confined space atmosphere is less than 19.5% or
greater than 25%, special precautions, as determined by the qualified person,
shall be taken. In accordance with OSHA Safety and Health Standard 29 CFR
Part 1910 and other references [12,33,51,76,87], a minimum oxygen level of
19.5% has been adopted for worker safety. The upper oxygen limit has been set
at 25% because an increase above this level will greatly increase the rate of
combustion of flammable materials [11].
Continuous and/or frequent monitoring becomes necessary in cases where the
work being performed within the confined space has the potential of generating
toxic agents [4,5,14,54,58,64,74,81,83,84,86,87]. Data collected for NIOSH by
Safety Sciences [1] shows that in 28 out of 80 accident events, the toxic gas
or oxygen deficiency was not in the confined space at the time of entry, but
was either generated by the work occurring in the space, or by gas being
unexpectedly admitted into the confined space after the worker had entered.
In these cases, only continuous and/or frequent monitoring would be a possible
countermeasure.
(b) Medical
Medical requirements for workers who might enter a confined space should
take into consideration the increased hazard potential of confined spaces. In
this setting, the workers must rely more heavily upon their physical, mental,
and sensory attributes, especially under emergency conditions. Workers should
be evaluated by competent medical personnel to insure that they are physically
and mentally able to wear respirators under simulated and actual working
conditions. Because of the additional stress placed on the cardiopulmonary
system, some pathologic conditions, such as cardiovascular diseases or those
39
108
-------
assodiated with hypoxemia, should preclude the use of respiratory protective
devices [101).
In areas where the hazard potential is high, a person certified in CPR and
first aid should be in attendance. Since irreversible brain damage can occur
in approximately 4 minutes in an oxygen deficient atmosphere, it is essential
that resuscitation attempts occur within that time [102].
(c) Safety Equipment and Clothing
Many cases of accidental dermal exposure, respiratory distress, and
traumatic injury due to falling objects have occurred in confined spaces;
therefore, a general safety standard should address the problem of whole body
protection [3] . Another area of concern is the use of life lines in all
confined spaces. Part of the recommended standard should be an evaluation of
the confined space to define when life lines shall be used and when a safety
belt with D rings for attaching life lines would be sufficient
[12,14,17,53,58,61,73,93,97,103,104].
(d) Training
Training of employees for entering and working in confined spaces is
essential because of the potential hazards and the use of life saving
equipment. To insure worker safety, the training program should be especially
designed for the type of confined space involved and the problems associated
with entry and exit. If different types of confined spaces are involved, this
will require additional training. Areas that should be covered in an
effective training program are:
1. Emergency entry and exit procedures
2. Use of applicable respiratory equipment
3. First Aid and Cardio-Pulmonary Resuscitation (CPR)
4. Lockout procedures
5. Safety equipment use
6. Rescue drills
7. Fire protection
8. Communications
Training of employees should be done by the qualified person or someone
knowledgeable in all relevant aspects of confined space entry, hazard
recognition, use of safety equipment, and rescue [3,33,53,58,63,68,84,90,97].
For training to be effective, classroom sessions, on-the-job training, or
simulated conditions, appear to be the most satisfactory methods. Classroom
sessions should include all applicable Federal, state, and local regulations
that govern the specific industrial activity in which the employee will be
working, as well as the hazards of a confined space (physical and chemical).
The training guidelines in Chapter V can be used as a format for additional
classroom activity. On-the-job training should be closely supervised until
the employee has a complete understanding of all potential hazards. Testing
of the employee should take place to evaluate the person's competency and
determine if retraining is necessary.
40
109
-------
(e) Work Practices
(1) Purging and ventilation - poor natural ventilation is one of the
defining parameters of a confined space, therefore purging and mechanical
ventilation must be closely evaluated when safe work practices are developed
for entering and working in confined spaces. Purging is the initial step in
adjusting the atmosphere in a confined space to acceptable standards (PEL's,
LEL's, and LFL's). This is accomplished either by displacing the atmosphere
in the confined space with fluid or vapor (inert gas, water, steam and/or
cleaning solution), or by forced air ventilation. According to the literature
[11] 20 air changes should bring the atmosphere in the confined space into
equilibrium with the external environment.
After purging, one establishes general and/or local exhaust ventilation to
maintain a safe uncontaminated level. Guidelines for establishing ventilation
rates are referenced in the ANSI Standard Z9.2-1972 [105] and NIOSH
Recommended Industrial Ventilation Guidelines [106]. In addition, other
information applicable to the special problems of confined spaces must be
considered such as the Occupational Safety and Health Standard 29 CFR
L915.31(b) [31,45,69,107-109]. Entering into an inert atmosphere is one of
the most hazardous activities associated with working in a confined space.
Work in an inert atmosphere is usually performed by employees of companies who
specialize in this because of the high degree of training and expertise needed
to perform inert entry operations safely. The scope of this document deals
with the necessary precautions but does not cover the specialized training for
entry into a confined space containing an inert atmosphere [11,106].
(2) Isolation/Lockout/Tagging - a review of the statistical data
provided to NIOSH [1] demonstrated an obvious need for lockout procedures.
The use of tags, while valuable for identification and/or information
purposes, appears to have been inadequate in preventing accidents. A review
of the literature has shown that proper isolation and lockout procedures are
more effective than tagging [5,6,12,45,55,57,61,64,88,103].
(3) Cleaning - decontaminating a space by cleaning is necessary to
provide for worker safety. However, it must be recognized that the cleaning
process itself can generate additional hazards. Continuous and/or frequent
monitoring is required during this process to determine that flammable
mixtures and hazardous concentrations of contaminants are adequately diluted
before safe entry can be made [3,5,15,20,48,49,59,61,79,80,91].
(4) Equipment and tools - the literature reviewed [15,58,63,64,109],
has shown the potential for explosion is greatly increased when explosion
proof equipped tools and equipment are not used or improperly maintained.
Also the potential for electrocution is increased when low voltage or ground
fault circuit interrupters are not used.
(5) Permit System - the inherent dangers associated with a confined
space clearly indicate the need for strict control measures of employees and
equipment. The literature has shown [50,52,55,56,63,69,77,86,88,90] that the
use of a permit system is a very effective method of attaining control. The
permit provides written authorization for entering and working in confined
spaces, clearly states all known or potential hazards, and identifies the
safety equipment required to insure the safety of the worker.
41
110
-------
(6) Entry and Rescue - the potential hazards associated with a
confined space must be evaluated prior to entry. These hazards would include
the following: oxygen level, flammability characteristics, toxic agents, and
physical hazards ie, limited openings and communications. To simplify entry
and rescue it would appear logical to set up a classification table for easy
reference. The literature reviewed [5,12,51,63,69,76] has provided necessary
information to set up an entry classification table and allow for flexibility
in the selection of personal protective equipment.
It is essential that well planned rescue procedures and the proper use of
personal protective equipment be followed. The literature and data reviewed
have shown a very poor record in successful rescue efforts. Spontaneous
reaction instead of well planned and executed rescue procedures has led to
multiple fatalities in confined spaces. In 19 of the 25 cases in which rescue
was attempted, the rescuers were injured or killed. These cases resulted in
13 deaths and 30 injuries to rescuers, even though only 5 victims were
successfully saved. One particular case resulted in injury to 15 rescuers;
however, they were successful in saving 3 lives [1]• Therefore, the standby
and/or rescue team shall be properly equipped and trained in all aspects of
rescue.
(7) Recordkeeping - from a review of the limited data available (no
SIC code for confined spaces) and the information collected from the plant
site visits on accidents in confined spaces, it is apparent that recordkeeping
systems must be changed to identify areas where accidents occur, so that
underlying causes can be determined. The records to be kept by the employer
should contain such information as employee name, age, training, job
description, number of years on the job, accident location and severity,
underlying causes, and action taken to insure future worker safety.
42
111
-------
V. TRAINING GUIDELINES
The very nature of the hazards encountered in a confined space is of
paramount importance in structuring an effective training program which will
provide for safe work practices and techniques. The training program should
be based on the specific hazards to be encountered, approved by a trained
safety person and given to all individuals who will perform the work or may be
assigned as standby or rescue persons.
(a) Qualifications of Training Personnel
It is essential that the person in charge of training know the relevant
aspects of safety as they relate to confined spaces. The instructor(s) must
have a thorough working knowledge of the following:
(1) Type(s) of confined spaces associated with the industrial
activity.
(2) Hazards involved
(A) Chemical
(B) Physical
(3) Work practices and techniques
(4) Testing requirements, PEL's, etc.
(5) Safety equipment
(A) Respirators
(B) Clothing
(C) Other protection (shields, helmets, etc)
(6) Rescue procedures
(7) Knowledge of applicable Federal, state, and local regulations
(8) Evaluation and test methods
(b) Training methods
The method and approach of training will be determined by the previous
experience and skills of the employee, with the exception of a newly hired
person who should receive a complete and thorough safety orientation. Basic
types of training prescribed are:
(1) Orientation of all new employees. This type of training would
consist of classroom sessions along with a walk-through of the physical plant
layout to give the trainee a basic understanding of the industrial activity.
43
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(2) On-the-job training. This would be a second phase of training.
After classroom sessions and after the trainee has gained a basic
understanding of the operation and hazards involved, on-the-job instruction
should include observation and closely supervised participation in actual work
practices or simulated conditions.
(3) Retraining. This should be performed periodically and as
frequently as needed. Many industrial activities are quite complex and
operations are frequently updated to keep up with modern innovations. It is
necessary, therefore, for a formal retraining program to be planned so that
all personnel concerned may be kept abreast of changes. Retraining should
also be considered necessary if a supervisor notices a weakness in employee
performance.
(c) Training Evaluation
The effectiveness of the training program can be determined by observation
of the employee by the qualified person to see if safe work practices are
being followed, testing the employee for knowledge of the operations and
hazards, and a reduction in the accident rate due to safe work practices and
techniques which have been learned and are being practiced.
(d) Training Program
The work practices section presented in Chapter I was designed to set a
formalized standard that could, when complied with, eliminate or minimize
accidents and injuries occurring in confined spaces. The standard would not
be sufficient without a formal written training program and job planning to
convey safe work practices and their relationship to the entire operation.
The employer is responsible for ensuring that each employee is adequately
trained and given refresher courses in assigned duties, and that the employee
understands and applies safe work practices. The following are recommended
areas that should be covered thoroughly in training:
<1) The types of confined spaces that are found in the industrial
complex. This should cover physical location, size, and any pertinent
information that would inform the worker of its function.
(2) Physical and chemical hazards involved. The physical hazards
would include structural members within a confined space, equipment that will
be used, eg, scaffolding or ladders, size of openings, flooring, and other.
Chemical hazards discussed will cover the product which has been stored,
chemical cleaners used, and air contaminants which can be liberated due to the
work practices.
(3) Atmospheric testing of the confined space. This phase of the
instruction should emphasize the contaminants which should be tested for and
the safe levels for entry.
(A) Cleaning and purging. Cleaning methods to be discussed should
include steaming, water rinses, chemical cleaners, or other specific processes
used .
44
113
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(5) Ventilation of the space by mechanical methods to reduce or
eliminate toxic airborne contaminants. This category should be covered
sufficiently to alert the employee of potential hazards, and the need for
warning devices to signal when there is a ventilation failure.
(6) Isolation and lockout of the confined space. The worker should
be able to recognize a hazard by visual observation of the connecting lines to
a confined space. The lockout of electrical circuits and mechanical
disconnects to complete confined space isolation should be explained as should
the employees' responsibilities in this area.
(7) Safety equipment and clothing. The worker should be aware of
the proper use and care required for his personal protective equipment. This
should include the type of protective shoes, gloves, face protection,
protective clothing, head protection, and safety belts and harnesses that are
to be worn as well as the rationale for their use. A major area in this
section will be the use of respirators: the types required, their use,
quantitative fit (test), respirator cleaning procedures, and proper storage.
It should be emphasized that different type respirators are required for
different atmospheres and the dangers involved when the wrong type is used
[39]. The mandatory wearing of safety belts should be stressed. The use of
safety belts and harnesses should be demonstrated so that each individual
understands the importance of having the rescue system available, and
operative, and is constantly aware of the necessity of keeping life lines
clear to the point of exit.
(8) Buddy system and use of a standby person.
(9) Communication systems and emergency signals.
(10) Rescue procedures. All employees working in or around a
confined space should be fully trained in emergency entry and exit procedures
and be trained in first aid and CPR. This should include on-site entry and
rescue drills.
(11) Permit system used by the employer. Information covered on the
permit should include: purpose of the permit; location where permit will be
posted; responsible persons; emergency information, and hazards to be
encountered.
(12) Documentation of Training. Satisfactory completion of this
safety training, and refresher courses, should be entered into the employee's
permanent record.
45
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VI. RESEARCH NEEDS
The primary research need in the area of confined spaces is the
development of a data system that would have the capability of recording
injury and mortality information specific to the causative factor eg, confined
space and be readily accessible. It is now impossible to retrieve data
directly related to confined space injuries and mortality, since data are.
currently collected b> general classifications, such as SIC codes.
Feasibility studies are being done by NIOSH on a system that could correct
this weakness in data recording'and retrieval and provide a more accurate
picture in areas such as confined space hazards. These data are essential to
the proper evaluation of the .causes of injuries and deaths. Specific data
will provide a base for establishing training programs and standards aimed
toward the more hazardous areas and permit the evaluation of current
standards. These data would also provide a background for analyzing unusual
accidents to establish causal factors and prevent recurrence.
A final step that would be accomplished by an approved data base on
confined spaces would be to standardize the degree of hazards throughout
industry and provide justification for a uniform standard. This uniform
standard would serve as the basis for a training program, which could be
tailored to meet the needs of large as well as small industries.
The second area of research needed is development of more adequate methods
for preventing and detecting gas leaks into confined spaces. Many accidents
have occurred because the atmosphere in a confined space, which was presumed
to be safe by the nature of the contents or obvious safe history of the
confined space, had suddenly become lethal. Historical cases reported have
shown that faulty seals in storage or processing vessels may allow seepage
from an external source, which could be naturally lethal or could form a
lethal substance when combined with residual material in the tank.
A third area for research is the analytical devices used in confined
spaces, such as intrinsically safe continuous monitors for gases as well as
explosive dusts, personal dosimeters, and test meters designed to withstand
rugged field use and maintain their integrity. It becomes difficult to
calibrate a gas detection meter after continued field use and to be sure of
its accuracy. The instrument, for field use, should be of the internal
calibration type that will allow for more accurate testing.
A fourth area of research is the need to define and evaluate the stresses
on employees who are required to work in confined spaces. This evaluation
should include physical stressors (eg heat stress, cold stress) and sensory
deprivation with respect to the work practice and length of work period.
46
115
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VII. REFERENCES
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Sciences. February 1978
2. Chartbook on Occupational Injuries and Illnesses in 1976, Report 535.
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4. Atmospheres in Sub-Surface Structures and Sewers. Data sheet 550.
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5. Wareing TH: Entry into Confined Spaces, in Handley W: Industrial
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95
6. Fox JR: Permit to Work Systems Governing the Entry into Tanks and
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8. Chapter 201, Places of Employment. Title 25 Rules and Regulations.
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9. Creber FL: Safety for Industry - A Manual for Training and Practice.
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10. Kleinfeld M, Felner B: Health Hazards Associated with Work in Confined
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Occupational Safety and Health Administration Regulations G.S. 95-126,
95-155. Raleigh, North Carolina. North Carolina Department of Labor.
1977
13. Confined Spaces. National Safety News. Chicago, National Safety
Council. October 1967, pp 40-43
14. Safe Work in Confined Spaces. Pub. No. 69. Netherlands General
Directorate of Labor. 1973
15. Safety Measures for Work in Tanks. ENPI Technical Committee for the
Chemical Industry. Securitas: 2-3:281-357. 1973
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16.' Dorias H: Explosive Gas-Air Mixtures. Die Berufsgenossenschaft. No.
7: 279-81, (Ger) 1974
17. Encyclopaedia of Occupational Health and Safety. 1: 330-31, 441, 519-
20, 604, 606. Geneva. International Labor Office
18. Zavon MR, Meadows DC: Vascular Sequalae to Cadmium Fume Exposure. Am
Ind Hyg Assoc: 180-82. 1970
19. Beton DC, Andrews CS, Davies HJ, Howells L, and Smith GF: Acute Cadmium
Fume Poisoning. Br J of Ind Med 23: 292-301. 1966
20. Halley PD: Tank Cleaning Hazards and how to Control Them. Safety
Maintenance. 237(2); 45-48. 1969
21. St Hill CA: Occupation as a Cause of Sudden Death. Trans Soc Occup
Med. 16: 6-9. 1966
22. Yant WP: Hydrogen Sulphide in Industry-Occurrence, Effects, and
Treatment. Am J Public Health: 598-608, 1930
23. Three Die in Mill Accident. The Paperworker 4(6): 1,2. United Paper
International Union. February 1976
24. Longley EO, Jones R: Acute Trichloroethylene Narcosis. Arch Environ
Health 7: 133-36. 1963
25. Saunders RA: A New Harard in Closed Environmental Atmospheres. Arch
Environ Health 14: 380-84. March 1967
26. Stahl CJ, Abdullah V, Fatteh MB, Dominguez AM: Trichloroethane
Poisoning: Observations on the Pathology and Toxicology in Six Fatal
Cases. Forensic 11(3) : 393-97. 1969
27. Hadengue A: A Case of Fatal Poisoning by Dichlorethane. Ann Med Log
23: 247-49. France. 1953
28. Hatfield TR, Maykoski RT: A Fatal Methyl Chloroform (Trichloroethane)
Poisoning. Arch Environ Health, Vol. 20. February 1970
29. Levinsky WJ, Smalley RV, Hillyer PN, Shindler RL: Arsine Hemolysis.
Arch Environ Health 20: 436-40. 1970
30. The Effects of Carbon Monoxide. Fire Journal. July 1967, pp 46-47
31. Brief RS, Raymond LW, Meyer WH, Yoder JD: Better Ventilation for Close-
Quarter Work Spaces. Air Conditioning, Heating, and Ventilation, 1961,
pp 74-88
32. Marshall WF, Hum RW: Hazard from Engines Rebreathing Exhaust in
Confined Space. U.S. Bureau of Mines Report of Investigation 7757.
U.S. Department of Interior. 1973
33. Preventing Confined Space Accidents. MOH, 22(2): 1-8. Lansing,
Michigan. Michigan Department of Public Health, 1977
48
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34 . Henderson Y, Haggard H: Noxious Gases and the Principles of Respiration
Influencing their Action. Chapters 8 and 9. New York, Reinhold Pub.
Corp. 1943
35. Working Safely in Confined Spaces. Safety Newsletter. Pulp, Paper and
Related Products Section. Chicago, National Safety Council. August
1975
36. Allison WW: Work in Confined Areas. National Safety News. Chicago,
National Safety Council. February 1976, pp 45-50; April 1976, pp 61-67
37. Entry Into Confined Spaces. Occupational Health in Ontario. 22: 13-16.
Toronto, Ontario Department of Health. September 1970
38. Walters JD: Physiological and Hygiene Problems Involved in the Study of
Enclosed and Sealed Environments. Ann Occup Hyg 11: 309-320. 1968.
39. Pritchard JA: A Guide to Industrial Respiratory Protection. DHEW
(NIOSH) Publication No. 76-189. Cincinnati, U.S. Department of Health,
Education and Welfare, Public Health Service, Center for Disease
Control, National Institute for Occupational Safety and Health, Division
of Physical Sciences and Engineering, 1976
40. Confined Space Entering Safety and Health Procedure. Bulletin No. 124.
Dearborn, Michigan. Ford Motor Company. 1975
41. Clarke JP: Fertilizer Sessions, Confined Space Hazards. Transactions
5: 39-43. Chicago, National Safety Congress. 1975
42. Occupational Diseases, A Guide to Their Recognition. DHEW (NIOSH)
Publication No. 77-181. Rockville, Maryland. U.S. Department of
Health, Education and Welfare, Public Health Service Center for Disease
Control, National Institute for Occupational Safety and Health. 1977
43. Criteria for a Recommended Standard ... Occupational Exposure to Hot
Environments, DHEW (NIOSH) Publication No. HSM 72-10169. Cincinnati,
U.S. Department of Health, Education, and Welfare, Public Health
Service, Center for Disease Control, National Institute for Occupational
Safety and Health. 1972
44. Standards for Occupational Exposure to Hot Environments, Proceedings of
Symposium February 27-28, 1973 Pittsburgh, Pennsylvania. DHEW (NIOSH)
Publication No. 76-100. Cincinnati, U.S. Department of Health,
Education and Welfare, Public Health Service, National Institute for
Occupational Safety and Health, Division of Biomedical Science. 1976
45. Safety Standard, Hazardous Confined Spaces. Occupational Health and
Safety, Section 2, 121. Canada. Public Service of Canada. 1974
46. Factories (Health and Safety) Regulations. Part IV, Confined Spaces, in
Government Gazette No. 85. West Perth, Australia. Department of
Labour. October 1967
47. South Australia-Regulations Under the Industrial Code. Part III General
Provisions, No. 19, Confined Spaces. Adelaide, 1967
49
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48.' Annual Report on Health and Safety Industry and Services, Confined Space
Entry. London, Her Majesty's Factory Inspectorate. 1975
49. Norway State Labor Inspection Directorate. Safety Rules No. 34, Work in
Tanks. State Labor Inspection Directorate. 1976
50. Safe Work in Confined Spaces, p 69, 2nd ed. Voorburg, Netherlands,
Directorate of Labor, Labor Inspectorate. 1972
51. Hot, Flammable, Poisonous, Corrosive and Irritant Substances. Title 8,
Article 109 of General Industry Orders. Sacramento, California.
California Division of Industrial Safety. 1972
52. Entry to Confined Spaces. Hygienic Information Guide No. 86.
Harrisburg, Pennsylvania. Pennsylvania Department of Environmental
Resources. 1974
53. Work in Confined Spaces, New Jersey Administrative Code 12:170.
Trenton, Department of Labor and Industry, Bureau of Engineering and
Safety. 1967
54. Kentucky Occupational Safety and Health General Industry Standards, 803
KAR 2:020 Section 2, (3) and Construction Standards 803 KAR 2:030,
Section 2, (1). Frankfort.
55. General Instructions: GC-11. Safety Permit Administration, CE-3,
Blinding Control Procedure; GC-30, Respiratory Protection; GC-29,
Radiation Areas; GE-1, Lock-Out and Tagging Procedures; GE-2 Summary of
Electrical Equipment Lock-Out and Tagging; Standing Instruction DDA-3,
Safety Requirements for Personnel Tank Roof Access. Houston, Texas.
Shell Oil Company. October 1977
56. Hazardous Condition Permit System. Spl pl-9. Los Angeles. Atlantic
Richfield Co. 1974
57. Entering Vessels and Other Enclosed Spaces. S-28: 1-3. Houston, Shell
Chemical Co. 1972
58. Fire Protection and Safety Standard No. 8.03. Rochester, New York.
Eastman Kodak Company. 1975
59. Entering and Working in Tanks, Tank Cars, Kettles or Other Confined
Spaces. Article 21. Philadelphia, Rohm and Haas Co. 1974, pp 1-7
60. Work in Confined Spaces. Corporate Policy Guideline. Neenah,
Wisconsin, Kimerly-Clark Corporation. 1977
61. Confined Space Entry Procedure. Emmaus, Pennsylvania. Buckeye Pipe
Line Company. 1976
62. Lockout/Tagout Procedure. Hamilton Standard Safety Regulation No. 19.
Hartford, Connecticut. United Technologies Corporation. 1976
63. Pits, Tanks and Confined Spaces. Hamilton Standard Safety Regulation
No. 16. Hartford, Connecticut. United Technologies Corporation. 1976
50
119
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64. Vessel and Confined Space Entry Procedure. Wilmington, Delaware. E. I.
Dupont De Nemours and Company
65. Confined Space Entry Procedure. Midland, Michigan. Dow Chemical Co.
66. Confined Space Entry Procedure. South Charleston, West Virginia. Union
Carbide Corp.
67. Confined Space Entry, Safety Standard No. K-SS-8.2. Oak Ridge Gaseous
Diffusion Plant. Oak Ridge, Tennessee. Union Carbide Corporation.
1974
68. NASSCO Repair Dept. Safety Manual. San Diego, California. National
Steel and Shipbuilding. 1977, pp 3-36
69. Vessel Entry in the Rubber Industry. Data Sheet 458. Chicago, National
Safety Council. 1969, 7 pp
70: Raines J: Welding in Confined Spaces. Metal Construction, p 493-94.
November 1976
71. Cleaning or Safeguarding Small Tanks and Containers. NFPA Standard No.
327: 1-12. Boston, National Fire Protection Association. 1970
72. Pulp Mill Digesters. Data sheet 340. Chicago, National Safety Council.
1973, 8 pp
73. How to Build a Breathing Protection Program. Occup. Hazards, p 46-47.
August 1972
74. Brief RS, Confer RG: Combustible Gas Indicator Response in Low Oxygen
Atmosphere. Am Ind Hyg Assoc J, p 576-581. 1969
75. DeVanna L, Doulames G: Planning is the Key to LNG Tank Purging, Entry,
and Inspection. Oil and Gas J. 1975
76. Safety Requirements for Working in Tanks and Other Confined Spaces.
American National Standard Z-117.1, New York, ANSI. 1977
77. Stephens HM: Safer Tank Entry. Paper presented at the National Safety
Congress. Chicago. October 1977, 17 pp
78. Venting Atmospheric and Low-Pressure Storage Tanks. API Standard 2000,
2nd ed. Washington, American Petroleum Institute. December 1973, 8 pp
79. Cleaning Petroleum Storage Tanks. API Pub. 2015, 2nd ed. Washington,
American Petroleum Institute. November 1976, 15 pp
80. A Guide for Controlling the Lead Hazard Associated with Tank Entry and
Cleaning. API supplement to RP 2015. Washington, American Petroleum
Institute. May 1975, 5 pp
81. Preparation of Equipment for Safe Entry and Work. Chap 5 in Guide for
Inspection of Refinery Equipment, 2nd ed. Washington, American
Petroleum Institute. 1972
51
120
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82.' Inspection, Rating, Repair of Pressure Vessels in Petroleum Refinery
Service. API RP 510, 3rd ed. Washington, American Petroleum Institute.
July 1975, 14 pp
83. Procedure for Entering/Working in Vaults and Manholes. Phoenix,
Arizona. Salt River Project. June 1977
8A. Standard for the Control of Gas Hazards on Vessels to be Repaired.
National Fire Codes. 10:306-1-1, 306-3-4.2. Boston, National Fire
Protection Association. 1978
85. Control of Flammable and Combustible Liquids and Gases in Manholes,
Sewers, and Similar Underground Structures. Boston, National Fire
Codes. 13;328-3, 328-18. National Fire Protection Association. 1971
86. Work in Confined Spaces. Procedure Number 0727-006: 1-7. Cummins
Engine Co., Inc. November 1977
87. A Primer on Confined Area Entry. Malvern, Pennsylvania. Bio Marine
Industries, Inc., 17 pp
88. Neoprene Latex Tank Entry Procedures. Louisville, Kentucky. E.I.
Dupont De Nemours and Company. July 1975, pp 1-3
89. Safety Procedure for Entry and Work Inside 12' Bubble Vessel. Appendix
6. Argonne, Illinois. Argonne National Laboratory. 1977
90. Working in Confined Areas. Research and Development Section Fact Sheet.
Chicago, National Safety Council
91. Entering Tanks and Other Enclosed Spaces. MCA Safety Guide SG-10.
Washington, Manufacturing Chemists Association. 1961
92. Meyer. (Safe Portable Electric Tools.) Eisen and Stahl. 5:184-205.
Germany. 1974
93. Criteria for a Recommended Standard...Emergency Egress from Elevated
Workstations. DHEW (NIOSH) Publication No. 76-128. Rockville,
Maryland. U.S. Department of Health, Education and Welfare, Public
Health Service, Center for Disease Control, National Institute for
Occupational Safety and Health. 1975
94. Recommended Occupational Health Standard... Occupational Exposure to
Vinyl Chloride. DHEW (NIOSH), Rockville, Maryland. U.S. Department of
Health, Education and Welfare, Public Health Service, Center for Disease
Control, National Institute for Occupational Safety and Health. 1974
95. Naval Engineering Manual. Chap 9920, NSTM. Washington, U.S. Coast
Guard
96. Maintenance of Permanently Installed Storage and Dispensing Systems for
Petroleum and Unconventional Fuels. Air Force Manual 85-16. U.S.
Department of the Air Force. May 1965
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97. Safety Procedures and Equipment for Confined Space Entry (Including
Missile Propellant Tanks). Technical Manual T.O. 00-25-235. U.S.
Department of the Air Force. January 1974
98. Fire Marshall and Gas Free Engines Manual. Washington, D.C. Bureau of
Naval Personnel. 1971, 80 pp
99. Tank and Confined Space Entry. Procedures Number BCO-O-PEM-097.
National Aeronautics and Space Administration. 1976
100. Confined Space Entry Procedure. Los Angeles, Los Angeles County
Sanitation District. 1977
101. Manual of Respiratory Protection Against Airborne Radioactive Materials.
NUREG-0041. U.S. Nuclear Regulatory Commission. 1976
102. Safe Practices in Confined Work Areas. Toronto, Industrial Accident
Prevention Assn. 1972
103. Birkhahn W: Entering Confined Spaces. Sicherheitsingenieur, 4(5):
230-241. Heidelberg, Germany. May 1973
104. Olishifski JB: Respiratory Hazards. National Safety News. Chicago,
National Safety Council. July 1971, pp 91-95
105. American National Standard. Z9.2-1971, Fundamentals Governing the
Design and Operation of Local Exhaust Systems. New York, ANSI, 1971
106. Hagopian JH, Bastress EK: Recommended Industrial Ventilation
Guidelines, DHEW (NIOSH) Publication No. 76-162. Cincinnati, U.S.
Department of Health, Education and Welfare, Public Health Service,
Center for Disease Control, National Institute for Occupational Safety
and Health, Division of Physical Sciences and Engineering. 1976
107. Accident Prevention Manual for Industrial Operations. 6th ed: 896-916.
Chicago, National Safety Council. 1969
108. TLVs-Threshold Limit Values for Chemical Substances and Physical Agents
in the Workroom Environment with Intended Changes for 1977. Cincinnati,
American Conference of Government Industrial Hygienizts. 1977
109. National Electric Code, NFPA No. 70-1978, Articles 500 and 555. Boston,
National Fire Protection Association. 1978
llU. Safety Engineering Tables, in Accident Prevention Manual for Industrial
Operations. 7th ed. Chap. 46, 1447-1449. Chicago, National Safety
Council. 1974
53
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VIII. APPENDIX I
CROSS REFERENCE - NIOSH RECOMMENDED STANDARD FOR WORKING IN
CONFINED SPACES TO THE OSHA STANDARD
NIOSH Recommended Standard OSHA Standard
Confined Space Definition 1926 .21(b) (6) (ii)
1915. 2(n)
1916. 2(n)
1917. 2(n)
Standards Notice 20
Training of Personnel 1926. 21 (b) (6) (i)
Isolation, Lockout, and Tagging 1910.252(d) (3) (i)
1910.261(b)(5)
1910.261(f)(6)(i)
1910. 261 (g)(4)(ii)
1910. 261 (g)(15)
1910. 261 (j)(6)(i)
1910.262(p) and (g)
1910.263(d)(6)(ii)
1910. 263(1) (3) (iii)
Cleaning 1910.252(d) (2) (vi) (c)
1910.261(g)(4)(i)
Testing 1910. 94(d)(ll) (iii)
1915.11
1917.11
1915. 33(c)
1916. 33(c)
1917. 33(c)
1915. 33(d)
1916. 33(d)
1915. 33(e)
1916. 33(e)
1926.651(v)
1926.850(e)
1926.956(a)(3)(i)
1926.956(a)(3)(ii)
1926.956(b)(3)
54
123
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APPENDIX I (CONTINUED)
CROSS REFERENCE - NIOSH RECOMMENDED STANDARD FOR WORKING IN
CONFINED SPACES TO THE OSHA STANDARD
NIOSH Recommended Standard OSHA Standard
Ventilation and Purging 1910. 94(d) (11) (iv)
1910.252(e)(4)(ii)
1910.252(f)(2)(i)
1910.252(f)(2)(ii)
1910.252(f)(3)(i)
1910.252(f)(3)(ii)
1910.252(f)(4)(i)
1910.252(f)(4)(ii)
1910.252(f)(5)(ii)
1910.261(g)(4)(i)
1910.261(g)(6)
1910.261(g)(15)
1910.261(g)(22)
1910.265(f)(4)
1915. 31(b)
1916. 31(b)
1917. 31(b)
1918.93
1926.154(a)(2)
1926.353(b)(l)
1926.353(b)(2)
1926.353(c)(l)
1926.353(c)(2)
1926.651 (v)
1926.850 (e)
1926.956(a)(3)(i)
1926.956(a)(3)(ii)
1926.956(a)(3)(iii)
1926.956(b)(2)
Equipment and Tools 1910. 252 (a) (1) (ii)
1910.252(e)(4)(iii)
1910.261(g)(15)
1910.263(d)(6)(iii)
1910.265(f)(4)
1915.35(b)(4)
1916.35(b)(4)
1917.35(b)(4)
1915. 32(g)
1916. 32(g)
1917. 32(a)
1926.350(b)(4)
1926.352(g)
55
124
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APPENDIX 1 (CONTINUED)
CROSS REFERENCE - NIOSH RECOMMENDED STANDARD FOR WORKING IN
CONFINED SPACES TO THE OSHA STANDARD
NIOSH Recommended Standard
OSHA Standard
Personal Protective Equipment
Standby Person and Rescue
1910.94(a)(5)
1910.94(d)(9)(vi)
1910.94(d)(H)(v)
1910.134(e)(3)
1910.252(e)(4)(iv)
1910.252(f)(4)(ii)
1910.252(f)(4)(iii)
1910.252(f)(4)(iv)
1910. 261 (b) (5)
1910.261(g)(4)(i)
1910. 261 (g) (6)
1910. 261 (g) (8)
1910. 261 (g) (15)
1915.23(a)(4)
1916.23(a)(4)
1915. 23 (b)
1916. 23(b)
1917. 23 (b)
1915. 24(a)
1916. 24(a)
1916.82
1917.82
1918.82
1926. 21(b) (6) (i)
1926.103(b)(3)
1926.104(a)
1926. 104 (b)
1926.104(d)
1926.104(f)
1926.250(b)(2)
1926. 353 (b) (2)
1926.353(c)(2)
1926.354(c)
1926.651(v)
1926.957(h)(2)
1910
1910
1910
1910
1910
1910
1910
1910
56
•134(e)(3)
,134(e)
,134(e)
,134(e)
.252(e)
,252(f)
•261(b)(5)
261(f)(6)
125
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APPENDIX I (CONTINUED)
CROSS REFERENCE - NIOSH RECOMMENDED STANDARD FOR WORKING IN
CONFINED SPACES TO THE OSHA STANDARD
NIOSH Recommended Standard OSHA Standard
Standby Person and Rescue 1910. 261 (g) (4) (ii)
1910. 261 (g)(8)
1910.268(0)(1)(±)
1910. 268(0) (l)(ii)
1910.268(0)(2)(±)
1910. 268(0) (2)(ii)
1910. 268(0) (2) (ill)
1910.268(0)(3)
1910. 268(0) (A)
1910. 268(0) (5) (i)
1910. 268(0) (5)(ii)
1915. 46(b)
1916. 46(b)
1917. 46(b)
1915.54
1916.54
1917.54
1926.353(b)(2)
1926.956(b)(l)
57
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X. APPENDIX III
SAMPLE PERMIT
CONFINED SPACE ENTRY
CLASS
Location of Work:
Description of Work (Trades) :
Employees Assigned:
Entry Date: , Entry Time:
Outside Contractors:
Isolation Checklist:
Blanking and/or Disconnecting
Electrical
Mechanical
Other
Hazardous Work:
Burning
Welding
Brazing
Open Flame
Other
Hazards Expected:
Corrosive Materials
Hot Equipment
Flammable Materials
Toxic Materials
Drains Open
Cleaning (Ex: chemical or water lance)
Spark Producing Operations
Spilled Liquids
Pressure Systems
Other
Vessel Cleaned:
Deposits
Method
Inspection
Neutralized with
Fire Safety Precautions:
61
130
-------
Personal Safety:
Ventilation Requirements
Respirators
Clothing
Head, Hand, and Foot Protection
Shields
Life Lines and Harness
Lighting
Communications
Employee Qualified
Buddy System
Standby Person
Emergency Egress Procedures
Training Sign Off (Supervisor or Qualified Person)_
Remarks:
Atmospheric Gas Tests
Tests Performed - Location - Reading
Example: (Oxygen) (19.5%)
Example: (Flammability) (Less than 10% LFL)
Remarks:
Test Performed By:
Signature
Time:
Authorizations:
Supervisor:
Prod Supervisor:
Line Supervisor:
Safety Supervisor:
Etc.:
Entry and Emergency Procedures Understood:
Standby Person
Rescue
Telephone
Permit Expires:
Classification:
62
131
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-------
SECTION 1
OCCUPATIONAL SAFETY AND HEALTH
REGULATIONS AND STANDARDS
PARTS
OSHA 29 CFR 1910.1200
HAZARD COMMUNICATION STANDARD
139
-------
»i VU'ATIONAt. .-AKETY AND HEALTH
.-TAXDAKDS AND J.VTEKPKETATIuXS
1910.120O—HAZARD COMMUNICATION
Note: The Office nf Management and Budget has disap-
proved, under (he Paperwork Reduction Act. three applica-
tions of the Hazard Communication Standard:
(l)The requirement that material safety data
sheets be provided on multi-employer worksites:
(2) Coverage of any consumer product excluded
from the definition of "hazardous chemical"
under section 311(e)(3) of the Superfund Amend-
ments and Reauthorization Act of 1986: and
(3) Coverage of any drugs regulated by the L'.S.
Food and Dme Administration in the non-man-
ufacturing sector.
(a) Purpose.
(1) The purpose of this section is to ensure that
the hazards of all chemicals produced or
imported are evaluated, and that information
concerning their hazards is transmitted to
employers and employees. This transmittal of
information is to be accomplished by means of
comprehensive hazard communication pro-
grams, which are to include container labeling
and other forms of warning, material safety
data sheets and employee training.
(2) This occupational safety and health stand-
ard is intended to address comprehensively the
issue of evaluating the potential hazards of
chemicals, and communicating information con-
cerning hazards and appropriate protective
measures to employees, and to preempt any
legal requirements of a state, or political sub-
division of a state, pertaining to the subject.
Evaluating the potential hazards of chemicals,
and communicating information concerning haz-
ards and appropriate protective measures to
employees, may include, for example, but is not
limited to, provisions for: developing and main-
taining a written hazard communication pro-
gram for the workplace, including lists of
hazardous chemicals present: labeling of con-
tainers of chemicals in the workplace, as well as
of containers of chemicals being shipped to
other workplaces: preparation and distribution
of material safety data sheets to employees and
downstream employers: and development and
implementation of employee training programs
regarding hazards of chemicals and protective
measures. Under section 18 of the Act. no state
or political subdivision of a state may adopt or
enforce, through any court or agency, any
requirement relating to the issue addressed by
this Federal standard, except pursuant to a
Federally-approved state plan.
(b) Scope and application.
(1) This section requires chemical manufac-
turers or importers to assess the hazards of
chemicals which they produce or import, and all
employers to provide information to their
employees about the hazardous chemicals to
which they are exposed, by means of a hazard
communication program, labels and other forms
of warning, material safety data sheets, and
information and training. In addition, this sec-
tion requires distributors to transmit the
required information to employers.
(2) This section applies to any chemical which is
known to be present in the workplace in such a
manner that employees may be exposed under
normal conditions of use or in a foreseeable
emergency.
(3) This section applies to laboratories only as
follows:
(i) Employers shall ensure that labels on
incoming containers of hazardous chemicals
are not removed or defaced:
(ii) Employers shall maintain any material
safety data sheets that are received with
incoming shipments of hazardous chemicals.
and ensure that they are readily accessible to
laboratory employees: and.
(iii) Employers shall ensure that laboratory
employees are apprised of the hazards of the
chemicals in their workplaces in accordance
with paragraph (h) of this section.
(4) In work operations where employees only
handle chemicals in sealed containers which are
not opened under normal conditions of use (such
as are found in marine cargo handling, ware-
806.15
141
ISIO.r'OfHbH-l)
-------
OCCUPATIONAL SAFETY AS!) HEALTH
ANDARDS AND INTERPRETATIONS
housing, or retail sales), this section applies to material safety data sheets that are received
these operations only as follows: ^'ith incoming shipments of the sealed con-
tainers of hazardous chemicals, shall obtain a
material safety data sheet for sealed con-
(i) Employers shall ensure that labels on tainers of hazardous chemicals received with-
incoming containers of hazardous chemicals out a material safety data sheet if an
are not removed or defaced; employee requests the material safety data
sheet, and shall ensure that the material
(ii) Employers shall maintain copies of any safety data sheets are readily accessible dur-
4
)SlU.12W)(b)(4)(ii) Jfigfc.16 Change -19
-------
orUTATIOXAL SAFETI .AND HKA1.TH
806.16.2
143
-------
1'iin. ijiioihm ii iii
OCCUPATIONAL SAFETY AND HEALTH
-------
OCCUPATIONAL SAFETY AND HEALTH
IHKI.r.MMHri
retary of Labor for Occupational Safety and
Health, U.S. Department of Labor, or designee.
"Chemical" means any element, chemical com-
pound or mixture of elements and/or compounds.
"Chemical manufacturer" means an employer
with a workplace where chemical(s) are produced
for use or distribution.
"Chemical name" means the scientific designa-
tion of a chemical in accordance with the nomencla-
ture system developed by the International Union
of Pure and Applied Chemistry (IUPAC) or the
Chemical Abstracts Service (CAS) rules of nomen-
clature, or a name which will clearly identify the
chemical for the purpose of conducting a hazard
evaluation.
"Combustible liquid" means any liquid having a
flashpoint at or above 100 °F (37.8 °C). but below
200 °F (93.3 °C), except any mixture having com-
ponents with flashpoints of 200 °F (93.3 °C), or
higher, the total volume of which make up 99 per-
cent or more of the total volume of the mixture.
"Common name" means any designation or iden-
tification such as code name, code number, trade
name, brand name or generic name used to iden-
tify a chemical other than by its chemical name.
"Compressed gas" means:
(i) A gas or mixture of gases having, in a
container, an absolute pressure exceeding 40
psi at 70 °F (21.1 °C); or
(ii) a gas or mixture of gases having, in a con-
tainer, an absolute pressure exceeding 104 psi
at 130 °F (54.4 °C) regardless of the pressure
of 70 °F (21.1 °C);or
(iii) A liquid having a vapor pressure exceed-
ing 40 psi at 100 °F (37.8 °C) as determined
by ASTM D-323-72.
"Container" means any bag, barrel, bottle, box,
can, cylinder, drum, reaction vessel, storage tank,
or the like that contains a hazardous chemical. For
purposes of this section, pipes or piping systems,
and engines, fuel tanks, or other operating sys-
tems in a vehicle, are not considered to be
containers.
"Designated representative" means any individ-
ual or organization to whom an employee gives
STANDARDS AND INTERPRETATIONS
written authorization to exercise such employee'.-
rights under this section. A recognized or certified
collective bargaining agent shall be treated auto-
matically as a designated representative without
regard to written employee authorization.
"Director" means the Director, National
Institute for Occupational Safety and Health. U.S.
Department of Health and Human Services, or
designee.
"Distributor" means a business, other than a
chemical manufacturer or importer, which supplies
hazardous chemicals to other distributors or to
employers.
"Employee" means a worker who may be
exposed to hazardous chemicals under normal
operating conditions or in foreseeable emergen-
cies. Workers such as office workers or bank
tellers who encounter hazardous chemicals only in
non-routine, isolated instances are not covered.
"Employer" means a person engaged in a busi-
ness where chemicals are either used, distributed,
or are produced for use or distribution, including a
contractor or subcontractor.
"Explosive" means a chemical that causes a sud-
den, almost instantaneous release of pressure, gas,
and heat when subjected to sudden shock, pres-
sure, or high temperature.
"Exposure" or "exposed" means that an em-
ployee is subjected to a hazardous chemical in the
course of employment through any route of entry
(inhalation, ingestion, skin contact or absorption,
etc.), and includes potential (e.g. accidental or pos-
sible) exposure.
"Flammable" means a chemical that falls into
one of the following categories:
(i) "Aerosol, flammable" means an aerosol
that, when tested by the method described in
16 CFR 1500.45, yields a flame projection
exceeding 18 inches at full valve opening, or
a flashback (a flame extending back to the
valve) at any degree of valve opening;
(ii) "Gas, flammable" means:
(a) A gas that, at ambient temperature
and pressure, forms a flammable mixture
with air at a concentration of thirteen (13)
percent by volume or less: or
Change 48
806.17
i9io.noo(c>
145
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IS 10.12(101 c I,
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(b) A gas that, at ambient temperature
and pressure, forms a range of flammable
mixtures with air wider than twelve (12)
percent by volume, regardless of the lower
limit;
(iii) "Liquid, flammable" means any liquid
having a flashpoint below 100 °F (37.8 °C),
except any mixture having components with
flashpoints of 100 °F (37.8 °C) or higher, the
total of which make up 99 percent or more of
the total volume of the mixture;
(iv) "Solid, flammable" means a solid, other
than a blasting agent or explosive as defined
in § 190.l09(a), that is liable to cause fire
through friction, absorption of moisture,
spontaneous chemical change, or retained
heat from manufacturing.or processing, or
which can be ignited readily and when ig-
nited burns so vigorously and persistently as
to create a serious hazard. A chemical shall
be considered to be a flammable solid if,
when tested by the method described in 16
CFR 1500.44, it ignites and burns with a self-
sustained flame at a rate greater than one-
tenth of an inch per second along its major
axis.
"Flashpoint" means the minimum temperature
at which a liquid gives off a vapor in sufficient con-
centration to ignite when tested as follows:
(i) Tagliabue Closed Tester (See American
National Standard Method of Test for Flash
Point by Tag Closed Tested, Zll.24-1979
(ASTM D 56-79)) for liquids with a viscosity
of less than 45 Saybolt University Seconds
(SUS) at 100 °F (37~.8 °C), that do not contain
suspended solids and do not have a tendency
to form a surface film under test; or
(ii) Pensky-Martens Closed Tester (See
American National Standard Method of Test
for Flash Point by Pensky-Martens Closed
Tester, Zll.7-1979 (ASTM D 93-79)) for liq-
uids with a viscosity equal to or greater than
45 SUS at 100 T (37.8 °C), or that contain
suspended solids, or that have a tendency to
form a surface film under test; or
(iii) Setaflash Closed Tester (see American
National Standard Method of Test for Flash
Point by Setaflash Closed Tester (ASTMD
3278-78))
Orpanic peroxides, which undergo autoaccelerat-
ing thermal decomposition, are excluded from any
of the flashpoint determination methods specified
above.
"Foreseeable emergency" means any potential
occurrence such as, but not limited to, equipment
failure, rupture of containers, or failure of control
equipment which could result in an uncontrolled
release of a hazardous chemical into the workplace.
"Hazardous chemical" means any chemical which
is a physical hazard or a health hazard.
"Hazard warning" means any words, pictures,
symbols, or combination thereof appearing on a
label or other appropriate form of warning which
convey the hazard(s) of the chemical(s) in the con-
tainer(s).
"Health hazard" means a chemical for which
there is statistically significant evidence based on
at least one study conducted in accordance with
established scientific principles that acute or
chronic health effects may occur in exposed
employees. The term "health hazard" includes
chemicals which are carcinogens, toxic or highly
toxic agents, reproductive toxins, irritants, corro-
sives, sensitizers, hepatotoxins, nephrotoxins,
neurotoxins, agents which act on the hematopoie-
tic system, and agents which damage the lungs.
skin, eyes, or mucous membranes. Appendix A
provides further definitions and explanations of
the scope of health hazards covered by this sec-
tion, and Appendix B describes the criteria to be
used to determine whether or not a chemical is to
be considered hazardous for purposes of this
standard.
"Identity" means any chemical or common name
which is indicated on the material safety data
sheet (MSDS) for the chemical. The identity used
shall permit cross-references to be made among
the required list of hazardous chemicals, the label
and the MSDS.
"Immediate use" means that the hazardous
chemical will be under the control of and used only
by the person who transfers it from a labeled con-
tainer and only within the work shift in which it is
transferred.
"Importer" means the first business with
employees within the Customs Territory of the
United States which receives hazardous chemicals
produced in other countries for the purpose of sup-
1910.1200(c)
806.18
146
Change -
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OCCUPATIONAL SAFETY AND HEALTH
1910.12UOlct
plying them to distributors or employers within
[he United States.
"Label" means any written, printed, or graphic
material, displayed on or affixed to containers of
hazardous chemicals.
"Material safety data sheet (MSDS)" means
written or printed material concerning a hazardous
chemical which is prepared in accordance with
paragraph (g) of this section.
"Mixture" means any combination of two or
more chemicals if the combination is not, in whole
or in part, the result of a chemical reaction.
"Organic peroxide" means an organic compound
that contains the bivalent -0- 0-structure and
which may be considered to be a structural deriva-
tive of hydrogen peroxide where one or both of the
hydrogen atoms has been replaced by an organic
radical.
"Oxidizer" means a chemical other than a blast-
ing agent or explosive as defined in § 1910.109(a),
that initiates or promotes combustion in other
materials, thereby causing fire either of itself or
through the release of oxygen or other gases.
"Physical hazard" means a chemical for which
there is scientifically valid evidence that it is a
combustible liquid, a compressed gas, explosive,
flammable, an organic peroxide, an oxidizer,
pyrophoric, unstable (reactive) or water-reactive.
"Produce" means to manufacture, process, for-
mulate, or repackage.
"Pyrophoric" means a chemical that will ignite
spontaneously in air at a temperature of 130 °F
(54.4 °C) or below.
"Responsible party" means someone who can
provide additional information on the hazardous
chemical and appropriate emergency procedures,
if necessary.
"Specific chemical identity" means the chemical
name, Chemical Abstracts Service (CAS) Registry
Number, or any other information that reveals the
precise chemical designation of the substance.
"Trade secret" means any confidential formula,
pattern, process, device, information or compila-
tion of information that is used in an employer's
Change 48
STANDARDS AND INTERPRETATIONS
business, and that gives the employer an oppor-
tunity to obtain an advantage over competitors
who do not know or use it. Appendix D sets out
the criteria to be used in evaluating trade secrets.
"Unstable (reactive)" means a chemical which in
the pure state, or as produced or transported, will
vigorously polymerize, decompose, condense, or
will become self-reactive under conditions of
shocks, pressure or temperature.
"Use" means to package, handle, react, or
transfer.
"Water-reactive" means a chemical that reacts
with water to release a gas that is either flam-
mable or presents a health hazard.
"Work area" means a room or defined space in a
workplace where hazardous chemicals are pro-
duced or used, and where employees are present.
"Workplace" means an establishment, job site,
or project, at one geographical location containing
one or more work areas.
(d) Hazard determination.
(1) Chemical manufacturers and importers shall
evaluate chemicals produced in their workplaces
or imported by them to determine if they are
hazardous. Employers are not required to eval-
uate chemicals unless they choose not to rely on
the evaluation performed by the chemical man-
ufacturer or importer for the chemical to satisfy
this requirement.
(2) Chemical manufacturers, importers or
employers evaluating chemicals shall identify
and consider the available scientific evidence
concerning such hazards. For health hazards,
evidence which is statistically significant and
which is based on at least one positive study
conducted in accordance with established scien-
tific principles is considered to be sufficient to
establish a hazardous effect if the results of the
study meet the definitions of health hazards in
this section. Appendix A shall be consulted for
the scope of health hazards covered, and
Appendix B shall be consulted for the criteria to
be followed with respect to the completeness of
the evaluation, and the data to be reported.
(3) The chemical manufacturer, importer or
employer evaluating chemicals shall treat the
806.19 1910.1200(d)(3)
147
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
following sources as establishing that the chemi-
cals listed in them are hazardous:
(i) 29 CFR Part 1910. Subpart Z. Toxic and
Hazardous Substances, Occupational Safety
and Health Administration (OSHA); or,
(ii) Threshold Limit Values for Chemical
Substances and Physical Agents in Ike Work
Environment, American Conference of Gov-
ernment Industrial Hygienists (ACGIH)
(latest edition).
The chemical manufacturer, importer, or em-
ployer is still responsible for evaluating the haz-
ards associated with the chemicals in these source
lists in accordance with the requirements of this
standard.
(4) Chemical manufacturers, importers and
employers evaluating chemicals shall treat the
following sources as establishing that a chemical
is a carcinogen or potential carcinogen for haz-
ard communication purposes:
(i) National Toxicology Program (NTP), An-
nual Report on Carcinogens (latest edition);
(ii) International Agency for Research on Can-
cer (IARC) Monographs (latest editions); or
(iii) 29 CFR Part 1910, Subpart Z, Toxic and
Hazardous Substances, Occupational Safety
and Health Administration.
Note—The Registry of Toxic Effects of
Chemical Substances published by the
National Institute for Occupational Safety
and Health indicates whether a chemical has
been found by NTP or IARC to be a poten-
tial carcinogen.
(5) The chemical manufacturer, importer or
employer shall determine the hazards of mix-
tures of chemicals as follows:
(i) If a mixture has been tested as a whole to
determine its hazards, the results of such
testing shall be used to determine whether
the mixture is hazardous;
(ii) If a mixture has not been tested as a
whole to determine whether the mixture is a
health hazard, the mixture shall be assumed
to present the same health hazards as do the
components which comprise one percent (by
weight or volume) or greater of the mixture,
except that the mixture shall be assumed to
present a carcinogenic hazard if ii contains a
component in concentrations of 0.1 percent or
greater which is considered to be a carcinogen
under paragraph (d)(4) of this section:
(iii) If a mixture has not been tested as a
whole to determine whether the mixture is a
physical hazard, the chemical manufacturer,
importer, or employer may use whatever sci-
entifically valid data is available to evaluate
the physical hazard potential of the mixture:
and,
(iv) If the chemical manufacturer, importer,
or employer has evidence to indicate that a
component present in the mixture in con-
centrations of less than one percent (or in the
case of carcinogens, less than 0.1 percent)
could be released in concentration.? which
would exceed an established OSHA permissi-
ble exposure limit or ACGIH Threshold
Limit Value, or could present a health hazard
to employees in those concentrations, the
mixture shall be assumed to present the
same hazard.
(6) Chemical manufacturers, importers, or
employers evaluating chemicals shall describe in
writing the procedures they use to determine
the hazards of the chemical they evaluate. The
written procedures are to be made available,
upon request, to employees, their designated
representatives, the Assistant Secretary and
the Director. The written description may be
incorporated inio the written hazard communi-
cation program required under paragraph (e) of
this section.
(e) Written hazard communication pro-
gram.
(1) Employers shall develop, implement, and
maintain at the workplace, a written hazard
communication program for their workplaces
which at least describes how the criteria spec-
ified in paragraphs (f). (g). and (h) of this sec-
tion for labels and other forms of warning,
material safety data sheets, and employee infor-
mation and training will be met. and which also
includes the following.
(i) A list of the hazardous chemicals known
to be present using an identity that is refer-
1910.1200(e)(lKi)
I4g)6.20
Change -48
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UCCl'PATIO.VAL SAFETV AND HEALTH
19]O.J200lf>U>(i)
encecl on the appropriate material safety data
sheet (the list may be compiled for the work-
place as a whole or for individual work
area?): and,
(ii) The methods the employer will use to
inform employees of the hazards of non-rou-
tine tasks (for example, the cleaning of reac-
tor vessels), and the hazards associated with
chemicals contained in unlabeled pipes in
their work areas.
(2) Multi-employer workplaces. Employers who
produce, use, or store hazardous chemicals at a
workplace in such a way that the employees of
other employer(s) may be exposed (for example,
employees of a construction contractor working
on-site) shall additionally ensure that the hazard
communication programs developed and imple-
mented under this paragraph (e) include the fol-
lowing:
(i).The methods the employer will use to
provide the other employer(s) with a copy of
the material safety data sheet, or to make it
available at a central location in the work-
place, for each hazardous chemical the other
employer(s)' employees may be exposed to
while working;
(ii) The methods the employer will use to
inform the other employer(s) of any precau-
tionary measures that need to be taken to
protect employees during the workplace's
normal operating conditions and in foresee-
able emergencies; and,
(iii) The methods the employer will use to
inform the other employer(s) of the labeling
system used in the workplace.
(3) The employer may rely on an existing haz-
ard communication program to comply with
these requirements, provided that it meets the
criteria established in this paragraph (e).
(4) The employer shall make the written hazard
communication program available, upon
request, to employees, their designated repre-
sentatives, the Assistant Secretary and the
Director, in accordance with the requirements
of 29 CFR 19l0.20(e).
(f) Labels and other forms of warning.
(1) The chemical manufacturer, importer, or
Change 48 806.21
STANDARDS AND INTERPRETATIONS
distributor shall ensure that each container of
hazardous chemicals leaving the workplace is
labeled, tagged or marked with the following
information;
(i) Identity of the hazardous chemical(s);
(ii) Appropriate hazard warnings; and
(iii) Name and address of the chemical manu-
facturer, importer, or other responsible party.
(2) For solid metal (such as a steel beam or a
metal casting) that is not exempted as an article
due to its downstream use, the required label
may be transmitted to the customer at the time
of the initial shipment, and need not be included
with subsequent shipments to the same employ-
er unless the information on the label changes.
The label may be transmitted with the initial
shipment itself, or with the material safety data
sheet that is to be provided prior to or at the
time of the first shipment. This exception to
requiring labels on every container of hazardous
chemicals is only for the solid metal itself and
does not apply to hazardous chemicals used in
conjunction with, or known to be present with,
the metal and to which employees handling the
metal may be exposed (for example, cutting flu-
ids or lubricants).
(3) Chemical manufacturers, importers, or dis-
tributors shall ensure that each container of
hazardous chemicals leaving the workplace is
labeled, tagged, or marked in accordance with
this section in a manner which does not conflict
with the requirements of the Hazardous Mate-
rials Transportation Act (49 U.S.C. 1801 et seq.)
and regulations issued under that Act by the
Department of Transportation.
(4) If the hazardous chemical is regulated by
OSHA in a substance-specific health standard,
the chemical manufacturer, importer, distribu-
tor or employer shall ensure that the labels or
other forms of warning used are in accordance
with the requirements of that standard.
(5) Except as provided in paragraphs (0(6) and
(0(7) the employer shall ensure that each con-
tainer of hazardous chemicals in the workplace
is labeled, tagged or marked with the following
information:
(i) Identity of the hazardous chemical(s) con-
tained therein; and
1910.1200(f)(5)(i)
149
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UUTI'ATru.VAL SAFETY ANL> HEALTH
STAN DAP. US AND INTER PR ETATIOXS
(ii) Appropriate hazard warnings.
(6) The employer may use signs, placards.
process sheets, batch tickets, operating proce-
dures, ur other such written materials in lieu of
ni'fixing labels to individual stationary process
containers, as lung as the alternative method
identifies the containers to which it is applicable
and conveys the information required by para-
graph (f)(5) of this section to be on a label. The
written materials shall be readily accessible to
the employees in their work area throughout
each work shift.
(7) The employe)- is not required to label port-
able containers into which hazardous chemicals
are transferred from labeled containers, and
which are intended only for the immediate use
of the employee who performs the transfer.
(8) The employer shall not remove or deface
existing labels or incoming containers of haz-
ardous chemicals unless the container is imme-
diately marked with the required information.
(9) The employer shall ensure that labels or
other forms of warning are legible, in English,
and prominently displayed on the container, or
readily available in the work area throughout
each work shift. Employers having employees
who speak other languages may add the infor-
mation in their language to the material pre-
sented, as long as the information is presented
in English as well.
(10) The chemical manufacturer, importer, dis-
tributor or employer need not affix new labels
to comply with this section if existing labels
already convey the required information.
(g) Material safety data sheets.
(1) Chemical manufacturers and importers shall
obtain or develop a material safety data sheet
for each hazardous chemical they produce or
import. Employers shall have a material safety
data sheet for each hazardous chemical which
they use.
(2) Each material safety data sheet shall be in
English and shall contain at least the following
information:
(i) The identity used on the label, and.
except as provided for in paragraph (i) of this
section on trade secrets:
(a) If the hazardous chemical is a single
substance, its chemical and common
namelsj;
(b) If the hazardous chemical is a mixture
which has been tested as a whole to deter-
mine its hazards, the chemical and com-
mon nameis) of the ingredients which
contribute to these known hazards, and
the common nameis) of the mixture itself:
or.
(c) If the hazardous chemical is a mixture
which has not been tested as a whole:
(1) The chemical and common name(s)
of all ingredients which have been
determined to be health hazards, and
which comprise I7c or greater of the
composition, except that chemicals iden-
tified as carcinogens under paragraph
(d)(4) of this section shall be listed if the
concentrations are 0.1% or greater; and.
(2) The chemical and common name(s)
of all ingredients which have been
determined to be health hazards, and
which comprise less than 1% (0.19c for
carcinogens) of the mixture, if there is
evidence that the ingredient(s) could be
released from the mixture in concentra-
tions which would exceed an established
OSHA permissible exposure limit or
ACGIH Threshold Limit Value, or
could present a health hazard to
employees: and.
(3) The chemical and common nameis)
of all ingredients which have been
determined to present a physical hazard
when present in the mixture:
(ii) Physical and chemical characteristics of
the hazardous chemical (such as vapor pres-
sure, flash point).
(iii) The physical hazards of the hazardous
chemical, including the potential for fire.
explosion, and reactivity:
(iv) The health hazards of the hazardous
chemical, including signs and symptoms of
exposure, and am medical conditions which
are generally recognized as being aggravated
by exposure to the chemical.
06.22
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'KXTPATIONAL SAFETY AND HEALTH
(y) The primary route(s) of entry:
(vi) The OSHA permissible exposure limit.
ACGIH Threshold Limit Value, and any
other exposure limit used or recommended
by the chemical manufacturer, importer, or
employer preparing the material safety data
sheet, where available:
(vii) Whether the hazardous chemical is
listed in the National Toxicology Program
(K'TP) Annual Report o>t Carcinogens (latest
edition) or has been found to be a potential
carcinogen in the International Agency for
Research on Cancer (IARC) Monographs
(latest editions), or by OSHA;
(viii) Any generally applicable precautions
for safe handling and use which are known to
the chemical manufacturer, importer or
employer preparing the material safety data
sheet, including appropriate hygienic prac-
tices, protective measures during repair and
maintenance of contaminated equipment, and
procedures for clean-up of spills and leaks;
(ix) Any generally applicable control meas-
ures which are known to the chemical man-
ufacturer, importer or employer preparing
the material safety data sheet, such as appro-
priate engineering controls, work practices,
or personal protective equipment;
(x) Emergency and first aid procedures;
(xi) The date of preparation of the material
safety data sheet or the last change to it; and,
(xii) The name, address and telephone num-
ber of the chemical manufacturer, importer,
employer or other responsible party prepar-
ing or distributing the material safety data
sheet, who can provide additional information
on the hazardous chemical and appropriate
emergency procedures, if necessary.
(3) If not relevant information is found for any
given category on the material safety data
sheet, the chemical manufacturer, importer or
employer preparing the material safety data
sheet shall mark it to indicate that no applicable
information was found.
(4) Where complex mixtures have similar haz-
ards and contents (i.e. the chemical ingredients
STANDARDS AND INTERPRETATIONS
are essentially the same, but the specific com-
position varies from mixture to mixture), the
chemical manufacturer, importer or employer
may prepare one material safety data sheet to
apply to all of these similar mixtures.
(5) The chemical manufacturer, importer or
employer preparing the material safety data
sheet shall ensure that the information recorded
accurately reflects the scientific evidence used
in making the hazard determination. If the
chemical manufacturer, importer or employer
preparing the material safety data sheet
becomes newly aware of any significant infor-
mation regarding the hazards of a chemical, or
ways to protect against the hazards, this new
information shall be added to the material
safety data sheet within three months. If the
chemical is not currently being produced or
imported the chemical manufacturer or import-
er shall add the information to the material
safety data sheet before the chemical is intro-
duced into the workplace again.
(6) Chemical manufacturers or importers shall
ensure that distributors and employers are
provided an appropriate material safety data
sheet with their initial shipment, and with the
first shipment after a material safety data sheet
is updated. The chemical manufacturer or im-
porter shall either provide material safety data
sheets with the shipped containers or send them
to the employer prior to or at the time of the
shipment. If the material safety data sheet is
not provided with a shipment that has been
labeled as a hazardous chemical, the employer
shall obtain one from the chemical manufacturer,
importer, or distributor as soon as possible.
(7) Distributors shall ensure that material
safety data sheets, and updated information,
are provided to other distributors and employ-
ers. Retail distributors which sell hazardous
chemical to commercial customers shall provide
a material safety data sheet to such employers
upon request, and shall post a sign or otherwise
inform them that a material safety data sheet is
available. Chemical manufacturers, importers.
and distributors need not provide material
safety data sheets to retail distributors which
have informed them that the retail distributor
does not sell the product to commercial
customers or open the sealed container to use it
in their own workplaces.
(8) The employer shall maintain copies of the
Chance -18
806.23
1910.1200(K)(8)
151
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATION'S
required material safety data sheets for each
hazardous chemical in the workplace, and shall
ensure that they are readily accessible during
each work shift to employees when they are in
their work area(s).
(9) Where employees must travel between
workplaces during a workshift. i.e.. their work
is carried out at more than one geographical
location, the material safety data sheets may be
kept at a central location at the primary work-
place facility. In this situation, the employer
shall ensure that employees can immediately
obtain the required information in an emer-
gency.
(10) Material safety data sheets may be kept in
any form, including operating procedures, and
may be designed to cover groups of hazardous
chemicals in a work area where it may be more
appropriate to address the hazards of a process
rather than individual hazardous chemicals.
However, the employer shall ensure that in all
cases the required information is provided for
each hazardous chemical, and is readily accessi-
ble during each work shift to employees when
they are in their work area(s).
(11) Material safety data sheets shall also be
made readily available, upon request, to desig-
nated representatives and to the Assistant Sec-
retary, in accordance with the requirements of
29 CFR 1910.20(e). The Director shall also be
given access to material safety data sheets in
the same manner.
(h) Employee information and training.
Employers shall provide employees with infor-
mation and training on hazardous chemicals in
their work area at the time of their initial assign-
ment, and whenever a new hazard is introduced
into their work area.
(1) Information. Employees shall be informed
of:
(i) The requirements of this section:
(ii) Any operations in their work area where
hazardous chemicals are present; and,
(iii) The location and availability of the writ-
ten hazard communication program, includ-
ing the required list(s) of hazardous
chemicals, and material safety data sheets
required by this section.
(2) Training. Employee training shall include at
least:
(i) Methods and observations that may be
used to detect the presence or release of a
hazardous chemical in the work area (such as
monitoring conducted by the employer, con-
tinuous monitoring devices, visual appear-
ance or odor of hazardous chemicals when
being released, etc.):
(ii) The physical and health hazards of the
chemicals in the work area:
(iii) The measures employees can take to
protect themselves from these hazards.
including specific procedures the employer
has implemented to protect employees from
exposure to hazardous chemicals, such as
appropriate work practices, emergency pro-
cedures, and personal protective equipment
to be used; and,
(iv) The details of the hazard communication
program developed by the employer, includ-
ing an explanation of the labeling system and
the material safety data sheet, and how
employees can obtain and use the appropriate
hazard information.
(i) Trade secrets.
(1) The chemical manufacturer, importer, or
employer may withhold the specific chemical
identity, including the chemical name and other
specific identification of a hazardous chemical.
from the material safety data sheet, provided
that:
(i) The claim that the information withheld is
a trade secret can be supported;
(ii) Information contained in the material
safety data sheet concerning the properties
and effects of the hazardous chemical is
disclosed;
(iii) The material safety data sheet indicates
that the specific chemical identity is being
withheld as a trade secret; and.
(iv) The specific chemical identity is made
1910.l200U)(l)(iv)
806.24
152
Change J8
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OCCUPATIONAL SAFETY AND HEALTH
available to health professionals, employees.
and designated representatives in accordance
\vith the applicable provisions of this
paragraph.
(2) Where a treating physician or nurse deter-
mines that a medical emergency exists and the
specific chemical identity of a hazardous chemi-
cal is necessary for emergency or first-aid treat-
ment, the chemical manufacturer, importer, or
employer shall immediately disclose the specific
chemical identity of a trade secret chemical to
that treating physician or nurse, regardless of
the existence of a \vritten statement of need of a
confidentiality agreement. The chemical man-
ufacturer, importer, or employer may require a
written statement of need and confidentiality
agreement, in accordance with the provisions of
paragraphs (i;(3) and (4) of this section, as soon
as circumstances permit.
(3) In non-emergency situations, a chemical
manufacturer, importer, or employer shall,
upon request, disclose a specific chemical iden-
tity, otherwise permitted to be withheld under
paragraph (i)(l) of this section, to a health pro-
fessional (i.e. physician, industrial hygienist,
toxicologist, epidemiologist, or occupational
health nurse) providing medical, or other
occupational health services to exposed em-
ployee(s), and to employees or designated rep-
resentatives, if:
(i) The request is in writing;
(ii) The request describes with reasonable
detail one or more of the following occupa-
tional health needs for the information:
(a) To assess the hazards of the chemicals
to which employees will be exposed;
(b) To conduct or assess sampling of the
workplace atmosphere to determine em-
ployee exposure levels;
(c) To conduct pre-assignment or periodic
medical surveillance of exposed em-
ployees:
(d) To provide medical treatment to ex-
posed employees;
(e) To select or assess appropriate per-
sonal protective equipment for exposed
employees:
Change 48
806.25
STANDARDS AND INTERPRETATIONS
(f) To design or assess engineering con-
trols or other protective measures for
exposed employees; and,
(g) To conduct studies to determine the
health effects of exposure.
(iii) The request explains in detail why the
disclosure of the specific chemical identity is
essential and that, in lieu thereof, the dis-
closure of the following information to the
health professional, employee, or designated
representative, would not satisfy the pur-
poses described in paragraph (i)(3)(ii) of this
section:
(a) The properties and effects of the
chemical;
(b) Measures for controlling workers' ex-
posure to the chemical;
(c) Methods of monitoring and analyzing
worker exposure to the chemical; and,
(d) Methods of diagnosing and treating
harmful exposures to the chemical;
(iv) The request includes a description of the
procedures to be used to maintain the con-
fidentiality of the disclosed information; and,
(v) The health professional, and the
employer or contractor of the services of the
health professional (i.e. downstream
employer, labor organization, or individual
employee), employee, or designated repre-
sentative, agree in a written confidentiality
agreement that the health professional,
employee, or designated representative, will
not use the trade secret information for any
purpose other than the health need(s)
asserted and agree not to release the infor-
mation under any circumstances other than
to OSHA, as provided in paragraph (i)(6) of
this section, except as authorized by the
terms of the agreement or by the chemical
manufacturer, importer, or employer.
(4) The confidentiality agreement authorized by
paragraph (i)(3)(iv) of this section;
(i) May restrict the use of the information to
the health purposes indicated in the written
statement of need;
1910.1200(1X4)0)
153
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l910.120Wi>UMil
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATION'S
(ii) May provide for appropriate legal reme-
dies in the event of a breach of the agree-
ment, including stipulation of a reasonable
pre-estimate of likely damages: and.
(iii) May not include requirements for the
posting of a penalty bond.
(5) Nothing in this standard is meant to pre-
clude the parties from pursuing non-contractual
remedies to the extent permitted by law.
(6) If the health professional, employee, or des-
ignated representative receiving the trade
secret information decides that there is a need
to disclose it to OSHA, the chemical manufac-
turer, importer, or employer who provided the
information shall be informed by the health pro-
fessional, employee, or designated representa-
tive prior to, or at the same time as, such
disclosure.
(7) If the chemical manufacturer, importer, or
employer denies a written request for dis-
closure of a specific chemical identity, the denial
must:
(i) Be provided to the health professional,
employee, or designated representative,
within thirty days of the request;
(ii) Be in writing;
(iii) Include evidence to support the claim
that the specific chemical identity is a trade
secret;
(iv) State the specific reasons why the
request is being denied; and,
(v) Explain in detail how alternative informa-
tion may satisfy the specific medical or
occupational health need without revealing
the specific chemical identity.
(8) The health professional, employee, or desig-
nated representative whose request for infor-
mation is denied under paragraph (i)(3) of this
section may refer the request and the written
denial of the request to OSHA for considera-
tion.
(9) When a health professional, employee, or
designated representative refers the denial to
OSHA under paragraph (i)(8) of this section,
OSHA shall consider the evidence to determine
if:
(i) The chemical manufacturer, importer, or
employer has supported the claim thai the
specific chemical identity is a trade secret:
(ii) The health professional, employee, or
designated representative has supported the
claim that there is a medical or occupational
health need for the information; and,
(iii) The health professional, employee, or
designated representative has demonstrated
adequate means to protect the confi-
dentiality.
(10)
(i) If OSHA determines that the specific
chemical identity requested under paragraph
(i)(3) of this section is not a bona fide trade
secret, or that it is a trade secret, but the
requesting health professional, employee, or
designated representative has a legitimate
medical or occupational health need for the
information, has executed a written con-
fidentiality agreement, and has shown ade-
quate means to protect the confidentiality of
the information, the chemical manufacturer.
importer, or employer will be subject to cita-
tion by OSHA.
(ii) If a chemical manufacturer, importer, or
employer demonstrates to OSHA that the
execution of a confidentiality agreement
would not provide sufficient protection
against the potential harm from the
unauthorized disclosure of a trade secret spe-
cific chemical identity, the Assistant Secre-
tary may issue such orders or impose such
additional limitations or conditions upon the
disclosure of the requested chemical informa-
tion as may be appropriate to assure that the
occupational health services are provided
without an undue risk of harm to the chemi-
cal manufacturer, importer, or employer.
(11) If a citation for a failure to release specific
chemical identity information is contested by
the chemical manufacturer, importer, or
employer, the matter will be adjudicated before
the Occupational Safety and Health Review
Commission in accordance with the Act's
enforcement scheme and the applicable Com-
mission rules of procedure. In accordance with
806.26
154
Change -IS
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OCCUPATIONAL SAFETY AND HEALTH
the Commission rules, when a chemical man-
ufacturer, importer, or employer continues to
withhold the information during the contest, the
Administrative Law Judge may review the cita-
tion and supporting documentation in camera
or issue appropriate orders to protect the con-
fidentiality of such matters.
(12) Notwithstanding the existence of a trade
secret claim, a chemical manufacturer," import-
er, or employer shall, upon request, disclose to
the Assistant Secretary any information which
this section requires the chemical manufacturer,
importer, or employer to make available.
Where there is a trade secret claim, such claim
shall be made no later than at the time the
information is provided to the Assistant Secre-
tary so that suitable determinations of trade
secret status can be made and the necessary
protections can be implemented.
(13) Nothing in this paragraph shall be con-
strued as requiring the disclosure under any cir-
cumstances of process or percentage of mixture
information which is a trade secret.
(j) Effective dates.
(1) Chemical manufacturers, importers, and
distributors shall ensure that material safety
data sheets are provided with the next ship-
ment of hazardous chemicals to employers after
September 23. 1987.
(2) Employers in the nonmanufacturing sector
shall be in compliance with all provisions of this
section by May 23, 1988. (Note: Employers in
the manufacturing sector (SIS Codes 2 thru 39)
are already required to be in compliance with
this section.)
APPENDIX A TO 19)0.1200
HEALTH HAZARD DEFINITIONS (MANDATORY)
Although safety hazards related to the physical characteris-
tics of a chemical can be objectively defined in terms of testing
requirements (e.g. flammability). health hazard definitions are
less precise and more subjective. Health hazards may cause
measurable changes in the body—-such as decreased pulmonary
function. These changes are generally indicated by the occur-
rence of signs and symptoms in the exposed employees—such
as shortness of breath, a non-measurable, subjective feeling
Employees exposed to such hazards must be apprised of both
the change in body function and the signs and symptoms thai
nay occur to signal thai change.
The determination of occupational health hazards is compli-
cated by the faci thai many of the effects or signs and symp-
STAN'DARDS AND INTERPRETATIONS
lomf occur commonly in non-orrupalionally exposed popula-
tions, so thai effects of exposure art- difficult in separate from
normally occurring illnesses. Occasionally, a substance cau.-e<
an effect that i> rarely seen in the population at large, such ».-
anposarcomas caused by vinyl chloride exposure, thus making
u easier to ascertain that the occupational exposure was the
primary causative factor. More often, however, the effects are
common, such as lung cancer. The situation is further compli-
cated by the fact that most chemicals have not been adequately
tested to determine (heir health hazard potential, and riau do
not exist to substantiate these effects.
There hare been many attempts to categorize effects and to
define them in various ways. Generally, the terms "acute" and
"chronic" are used to delineate between effects on the basis of
severity or duration. "Acme".effects usually occur rapidly as a
result of short-term exposures, and are of short duration.
"Chronic" effects generally occur as a result of long-term
exposure, and are of long duration.
The acute effects referred to most frequently are those
defined by the American National Standards Institute (ANSI)
standard for Precautionary Labeling of Hazardous Industrial
Chemicals (2129.1-1982)—irritation, corrosivity. sensitization
and lethal dose. Although these are important health effects.
they do not adequately cover the considerable range of acute
effects which may occur as a result of occupational exposure.
such as. for example, narcosis.
Similarly, the term chronic effect is often used to cover only
carcinogenicity, leratogenicity. and muugenicity. These effects
are obviously a concern in the workplace, but again, do not ade-
quately cover the area of chronic effects, excluding, for exam-
ple, blood dyscrasias (such as enemia), chronic bronchitis and
liver atrophy.
The poa! of defining precisely, in measurable terms, every
possible health effect that may occur in the workplace as a
result of chemical exposures cannot realistically be accom-
plished. This does not negate the need for employees to be
informed of such effects and protected from them. Appendix B.
which is also mandatory, outlines the principles and procedures
of hazardous assessment.
For purposes of this section, any chemicals which meet any
of the following definitions, as determined by the criteria sei
forth in Appendix B are health hazards:
1. Carcinogen: A chemical is considered to be a carcinogen if:
(a) It has been evaluated by the International Agency for
Research on Cancer (1ARC). and found to be a carcinogen or
potential carcinogen: or
(b) It is listed as a carcinogen or potential carcinogen in the
Annual Report on Carcinogens published by the National Tox-
icology- Program (NTP) (latest edition): or.
(c) It is regulated by OSHA as a carcinogen.
2. Corrosive: A chemical that causes visible destruction of. or
irreversible alterations in. living tissue by chemical action at
ihe site of contact. For example, a chemical is considered to be
corrosive if. when tested on the intact skin of albino rabbits by
ihe method described by the U.S. Departmenl of Transporva-
uon in Appendix A to -19 CFR Part 173. i; destroys or changes
irreversibly the structure of the tissue at the site of contact fol-
lowmp an exposure period of four hours. This term shall noi
refer to action or inanimate surfaces.
Chanjre 48
806.27
1910.1200 Appendix A
155
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1 SI0.12(111 Appendix A
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
3. Highl) loxic: A chemical falling wuhm any of the following
categories:
(aI A chemical thai has a median lethal dose (LD.v.) of 50 milli-
grams or lesf per kilogram of body weight when administered
orally to albino rats weighing between 200 and 300 grams each
(h) A chemical that has a median lethal dose (LD»,i of 200 milli-
grams or less per kilogram of body weight when administered
by continuous contact for 24 hours (or less if death occurs
within 2-1 hours) with the bare skjn of albino rabbits weighing
between two and three kilograms each
(c) A chemical that has a median lethal concentration (LCy.) in
air of 200 parts per million by volume or less of gas or vapor, or
2 milligrams per liter or less of misi. fume, or dust, when
administered by continuous inhalation for one hour tor less if
death occurs within one hour) to albino rats weighing between
200 and 300 prams each
•I. Irritant: A chemical, which is not corrosive, but which
causes a reversible inflammatory effect on living tissue by
chemical action at the site of contact. A chemical is a skin irri-
tant if. when tested on the intact skin of albino rabbits by the
methods of 16 CFR 1500.41 for four hours exposure or by other
appropriate techniques, it results in an empirical score of five
or more. A chemical is an eye irritant if so determined under
the procedure listed in 16 CFR 1500.42 or other appropriate
techniques.
5. Sensitizer: A chemical that causes a substantial proportion
of exposed people or animals to develop an allergic reaction in
normal tissue after repeated exposure to the chemical
6. Toxic. A chemical falling within any of the following
categories:
(a) A chemical that has a median lethal dose (LDM) of more
than 50 milligrams per kilogram but not more than 500 milli-
grams per kilogram of body weight when administered orally to
albino rats weighing between 200 and 300 grams each
(b) A chemical that has a median lethal dose (LDW) of more
than 200 milligrams per kilogram but not more than 1.000 milli-
grams per kilogram of body weight when administered by con-
tinuous contact for 2-1 hours (or less if death occurs within 24
hours) with the bare skin of albino rabbits weighing between
two and three kilograms each.
Ic) A chemical that has a median lethal concentration (LCy>) in
air of more than 200 pans per million but not more than 2.000
parts per million by volume of pas or vapor, or more than two
milligrams per liter but not more than 20 milligrams per liter of
mist. fume, or dust, when administered by continuous inhala-
tion for one hour (or less if death occurs within one hour) to
albino rats weighing between 200 and 300 grams each.
7. Target organ effects. The following is a target organ cate-
gorization of effects- wnicn may occur, including examples of
signs and symptoms and chemicals which have been found to
cause such effects. These examples are presented to illustrate
the range and diversity of effects and hazards found in the
workplace, and the broad scope employers must consider in this
area, but are not intended to be aJI-mclusive
a Hepatoioxins: Chemicals which produce bver damage
Signs & Symptoms: Jaundice: liver enlargement
Chemicals: Carbon letrachlonde; nurosamines
b. N'ephrotoxins. Chemicals which produce kidney damage
Signs & Symptoms: Edema: proteinuna
Chemicals. Halogenated hydrocarbons: uranium
c. Neurotoxms. Chemicals which produce their primary toxic
effects on the nervous system
Signs & Symptoms: Narcosis: behavioral changes, decrease
in motor functions
Chemicals: Mercury; carbon riisulfirte
d. Agents which act on the blood or hematopoietic system:
Decrease hemoglobin function; deprive the body tissue of
oxygen
Signs i Symptoms: Cyanosis: loss of consciousness
Chemicals: Carbon monoxide; cyanides
c. Agents which damage the lung: Chemicals which irritate or
damage the pulmonary tissue
Signs & Symptoms: Cough; tightness in chest; shortness of
breath '
Chemicals: Silica; asbestos
f. Reproductive toxins: Chemicals which affect the reproduc-
tive capabilities including chromosomal damage imuta-
tions) and effects on fetuses (teratogenesis)
Signs & Symptoms: Birth defects; sterility
Chemicals: Lead; DBCP
g. Cutaneous hazards: Chemicals which affect the dermal layer
of the boy
Signs & Symptoms: Defattinp of the skin; rashes: irritation
Chemicals: Ketones; chlorinated compounds
h. Eye hazards: Chemicals which affect the eye or visual
capacity
Signs & Symptoms: Conjunctivitis: corneal damage
Chemicals: Organic solvents; acids
APPENDIX B TO § 1910.1200
HAZARD DETERMINATION (MANDATORY)
The quality of a hazard communication program is largely
dependent upon the adequacy and accuracy of the hazard deter-
mination. The hazard determination requirement of this stand-
ard is performance-oriented. Chemical manufacturers.
importers, and employers evaluating chemicals are not re-
quired to follow any specific methods for determining hazards.
but they must be able to demonstrate that they have ade-
quately ascertained the hazards of the chemicals produced or
imported in accordance with the criteria set forth in this
Appendix.
Hazard evaluation is a process which relies heavily on the
professional judgment of the evaluator. particularly in the area
of chronic hazards. The performance-orientation of the hazard
determination does not diminish the duty of the chemical man-
ufacturer, importer or employer to conduct a thorough evalua-
tion, examining all relevant data and producing a scientifically
defensible evaluation. For purposes of this standard, the fol-
lowing criteria shall be used in making hazard determinations
mat meet the requirements of this standard.
1. Carcinogenicity: As described in paragraph (d)(4) and
Appendix A of this section, a determination by the National
Toxicology Program, the International Agency for Research on
Cancer, or OSHA thai a chemical is a carcinogen or potential
carcinogen will be considered conclusive evidence for purposes
o( this section.
19)0.1200 Appendix B
156
806.28
Change -IS
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OCCUPATIONAL SAFETY AND HEALTH
1910.1200 Appendix B
'1. Human data: Where available, epidemiological studies and
case reports of adverse health effects shall be considered in the
evaluation.
3. Animal data: Human evidence of health effects in exposed
Imputations is generally not available for the majority of chem-
icals produced or used in the workplace. Therefore, the avail-
able results of lexicological testing in animal populations shall
be used to predict the health effects that may be experienced
by exposed workers. In particular, the definitions of certain
acute hazards refer to specific animal testing results (see
Appendix Al.
•1. Adequacy and reporting of data. The results of any studies
which are designed and conducted according to established sci-
entific principles, and which report statistically significant con-
clusions regarding the health effects of a chemical, shall be a
sufficient basis for a hazard determination and reported on any
material safety data sheet. The chemical manufacturer, import-
er, or employer may also report the results of other scien-
tifically valid studies which tend to refute the findings of
hazard.
STANDARDS AND INTERPRETATIONS
Toxicology of the Eye. by Vf. .Morion Grant
Charles C. Thomas. 301-327 East Lawrence Avenue. Spring-
field. 1L.
Recognition of Health Hatard$ in Industry
William A. Burgess. John Wiley and Sons. 605 Third Avenue.
New York. NY 10158.
Chemical Hazards of Ike Workplace
Nick H. Proctor and James P. Hughes. J.P. Lipincott Com-
pany, 6 Winchester Terrace, New York, NY 10022.
Handbook of Chemistry and Physics
Chemical Rubber Company, 18901 Cranwood Parkway.
Cleveland. OH 44128.
Threshold Limil Values for Chemical Substances and Physical
Agents in the Work Environment and Biological Exposure
Indices with Intended Changes .
American Conference of Governmental Industrial Hygienists
(ACG1H). 6500 Glen-way Avenue. Bldg. D-5. Cincinnati,
OH 45211.
Information on the physical hazards of chemicals may be found
in publications of the National Fire Protection Association.
Boston, MA.
APPENDIX C TO 1910.1200
INFORMATION SOURCES (ADVISORY)
The following is a list of available data sources which the
chemical manufacturer, importer, distributor, or employer may
wish to consult to evaluate the hazards of chemicals they pro-
duce or import:
—Any information in their own company files, such as tox-
icity testing results or illness experience of company
employees.
—Any information obtained from the supplier of the chemi-
cal, such as material safety data sheets or product safety
bulletins.
—Any pertinent information obtained from the following
source list (latest editions should be used):
Condensed Chemical Dictionary
Van Nostrand Reinhold Co., 135 West 50th Street. New
York, NY 10020.
The Merck Index: An Encyclopedia of Chemicals and Drugs
Merck and Company, Inc., 126 E. Lincoln Ave., Rahway, NJ
07065.
I ARC Monographs on the Evaluation of the Carcinogenic Risk
of Chemicals la Man
Geneva: World Health Organization, International Agency for
Research on Cancer, 1972-Present. (Multivolume work).
Summaries are available in supplement volumes. 49 Sheridan
Street, Albany, NY 12210.
Industrial Hygiene and Toxicology, by P.A. Patty
John Wiley & Sons, Inc., New York, NY (Multivolume work).
Clinical Toxicology of Commercial Products
Gleason, Gosselin, and Hodge
Casarelt and Doull's Toxicology; The Basic Science of Poisons
Doull. Klaassen. and Amdur, Macmillan Publishing Co., Inc..
New York, NY.
Industrial Toxicology, by Alice Hamilton and Harriet L. Hardy
Publishing Sciences Group, Inc., Acton. MA.
Note.—The following documents may be purchased from the
Superintendent of Documents, U.S. Government Printing
Office, Washington, DC 20402.
Occupational Health Guidelines
NIOSH/OSHA (N10SH Pub. No. 81-123)
NIOSH Pockel Guide to Chemical Hazards
N10SH Pub. No. 85-114
Registry of Toxic Effects of Chemical Substances
N10SH Pub. No. 80-102
Miscellaneous Documents published by the National Institute
for Occupational Safety and Health:
Criteria documents.
Special Hazard Reviews.
Occupational Hazard Assessments.
Current Intelligence Bulletins.
OSHA's General Industry Standards (S9 CFR Part J9JOJ
NTP Annual Report on Carcinogens and Summary of the
Annual Report on Carcinogens.
National Technical Information Service (NT1S). 5285 Port
Royal Road, Springfield. VA 22161: (703) 487-4650.
BIBLIOGRAPHIC DATA BASES
Service Provider
File nome
Bibliographic Relrievol Service!
(BRS). 1200 Roule 7. toihom.
NY 12110.
Change 48
806.29
Biosii Previews
CA Seorch
Medlorj
NTIS
Hozordline
Amencon Chemical Society
Journal
Excerpio Medico
IRCS Medical Science Journo'
Pre-Med
1910.1200 Appendix C
157
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1910.1200 Appendix D
OCCITAT10NAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
Lockheed—DIALOG Informo-
lion Service Inc . 3460 Hill-
vtew Avenue Polo Aho. CA
94304
SDC—Obit. SOC Informolion
Service, 2500 Colorodo Ave-
nue. Sonio Monico, CA
90406
Nolionol Librory o( Medicine.
Deportment of Heolih ond
Homon Services. Public
Heolth Service. Nolionol
Instnuie of Heolih, Bethesdo.
MD 20209.
Pergomon Iniernohono! Infor-
motion Corp., 1340 Old
Chom Bridge Rd.. Mcleon,
VA 22101.
Quesiel. Inc.. 1625 Eye Slreel,
NW. Suite 818, Washington,
DC 20006
Chemical Information System
ICI (ICIS), Bureau of National
Affairs. I 133 15lh Street.
NW, Suite 300. Washington.
DC 20005.
Occupational Heolih Services.
400 Plaza Drive. Secoucus.
NJ 07094
Intl. Pharmaceutical Abstracts
Paper Chem
BIOSIS Prev. Files
CA Search files
CAB ADSUOCIS
Chemical Exposure
Chemnome
Chemsis Files
Chemzero
Embose Files
Environmental Bibliographies
Envirolme
Federal Research in-Progress
IRL Life Science Collection
NTIS
Occupational Safety ond
Health (NIOSH)
Paper Chem
CAS Files
Chemdex, 2, 3
NTIS
Hazardous Substances Data
Bonk (NSDB)
Medline files
Toxline Files
Concerlit
RTECS
Chemline
Laboratory Hazard Bulletin
CIS/HO
Concernel
Structure ond Nomenclature
Search System (SANSS)
Acute Toxicily (RTECS)
Clinical Toxicology of Commer-
cial Products
Oil ond Hazardous Materials
Technical Assistance Doto
System
CCRIS
CESARS
MSDS
Hozordlme
APPENDIX D TO 1910.1200
DEFINITION OF "TRADE SECRET" (MANDATORY)
The following is a reprini of the Restatement of Torts section
757, comment b (1939):
b. Definition of trade secret. A trade secret may consist of
any formula, pattern, device or compilation of information
which is used in one's business, and which gives him an oppor-
tunity to obtain an advantage over competitor? who do not
know or use it. It may be a formula for a chemical compound.
process of manufacturing, treating or preserving materials, a
pattern for a machine or other device, or a list of customers. It
differs from other secret information in a business (see * 759 of
the Restatement of Torts which is not included in this Appendix
in that it is not simply information as to single or ephemera)
events in the conduct of the business, as. for example, the
amount or other terms oi'a secret bid for a contract or tht t-al-
ary uf certain employees, or the security investment.- made or
contemplated, or the date fixed for the announcement of a new
policy or for bringing out a new model or the like A trade
secret is a process or device for continuous use in the opera-
tion.- of the business. Generally it relates to the production of
goods, as. for example, a machine or formula for the production
of an article. It may. however, relate to the sale of goods or to
other operations in the business, such as a code for determining
discounts, rebates or other concessions in a price list or cata-
logue, or a list of specialized customers, or a method of book-
keeping or other office management.
Scrrffi/. The subject matter of a trade secret must be secret.
Matters of public knowledge or of general knowledge in an
industry cannot be appropriated by one as his secret. Matters
which are completely disclosed by the goods which one markets
cannot be his secret. Substantially, a trade secret is known only
in the particular business in which it is used. It if not requisite
that only the proprietor of the business know it. He may. with-
out losing his protection, communicate it to employees involved
in its use. He may likewise communicate it to others pledged to
stcrecy. Others may also know of it independently, us. for
example, when they have discovered the process or formula by
independent invention and are keeping it secret. Nevertheless.
a substantial element of secrecy must exist, so that, except by
the use of improper means, there would be difficulty in acquir-
ing the information. An exact definition of a trade secret is not
possible. Some factors to be considered in determining whether
given information is one's trade secret are: (1) The extent to
which the information is known outside of his business: (2) the
extent to which it is known by employees and others involved
in his business: (3) the extent of measures taken by him to
guard the secrecy of the information; (4) the value of the infor-
mation to him and his competitors: (5) the amount of effort or
money expended by him in developing the information; (6) the
ease or difficulty with which the information could be properly
acquired or duplicated by others.
Xorelty and prior art. A trade secret may be a device or
process which is patentable: but it need not. be that. H may be a
device or process which is clearly anticipated in the prior an or
one which is merely a mechanical improvement that a good
mechanic can make. Novelty and invention are not requisite for
a trade secret as they are for patentability. These requirements
are essential to patentability because a patent protects against
unlicensed use of the patented device or process even by one
who discovers it properly through independent research.
The patent monopoly is a reward to the inventor. But such is
not the case with a trade secret. Us protection is not based on a
policy of rewarding or otherwise encouraging the development
of secret processes or devices. The protection is merely against
breach of faith and reprehensible means of learning another's
secret. For this limited protection it is not appropriate to
require also the kind of novelty and invention which is a requi-
site of patentability. The nature of the secret is. however, an
important factor in determining the kind of relief that is appro-
priate against one who is subject to liability under the rule
stated in this section. Thus, if the secret consists of a device or
process which is a novel invention, one who acquires the secret
wrongfully is ordinarily enjoined from further use of it and is
required to account for the profits derived from his past use. If.
on the other hand, the secret consists of mechanical improve-
ment? that a good mechanic can make without resort to the
secret the wrongdoer's liability may be limned 10 damage.-.
and an injunction against future use of the improvements made
with ihe aid of the secret may be inappropriate
1910.1200 Appendix D
806.30
Change -IS
158
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IK'l U'ATIONAL SAFETY AND HKALTH
STA\UAi:i>S ASH INTKKI'UKTATION-
i Approved bv the Office ol 'Management ;ini| Itudv'el uiidt-i
O'litml X. t-i coverall' ol'un\ I'on.-umer produci excluded from
l he definition ol "hazardou> cnemicid" under Secunn :il HvK.ii ul
ihe Suiierl'und Amemlmenis and Keauthomaumi Act »l" liiMi.
and lUi coverajre ol any r> ri'j;ulaled by itie Kood and l)ru.u
Administraiiun in ihe noii-rnanul'acturint: sector i
153 K.K. 15035. April 27.
806.31
159
- -IH
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SECTION 2
OCCUPATIONAL HEALTH
AND
SAFETY GUIDANCE DOCUMENTS
-------
OCCUPATIONAL HEALTH
AND
SAFETY GUIDANCE DOCUMENTS
SECTION OBJECTIVE
The objective of this section is to provide students with a copy of the following US EPA health and
safety guidance documents:
• US EPA Office of Solid Waste and Emergency Response (OSWER) Integrated Health
and Safety Policy for Field Activities (1988)
• US EPA Environmental Response Team's (ERT) Occupational Medical Monitoring
Program Guidelines for SARA Hazardous Waste Field Activity Personnel
(Publication 9285.3-04-1990)
STUDENT PERFORMANCE OBJECTIVES
After completing this section and related lesson(s), the student will be able to:
• Discuss elements of an employer's overall safety and health program.
• Discuss recommended guidelines for implementation of a medical surveillance
program, including purpose, frequency, and recommended test protocol for medical
examinations.
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SECTION 2
OCCUPATIONAL SAFETY
AND
HEALTH GUIDANCE DOCUMENTS
PART 1
US EPA OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
(OSWER)
INTEGRATED HEALTH AND SAFETY POLICY
FOR FIELD ACTIVITIES
-------
OFFftE OF SOLID WASTE AND EMERGENCY RESPONSE
INTEGRATED HEALTH AND SAFETY POLICY
FOR
FIELD ACTIVITIES
ASSISTANT ADMINISTRATOR
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
401 M Street, NW
Washington OC 20460
May 15, 1988
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ABSTRACT
PURPOSE: The purpose of this document is to establish an Integrated Health
and Safety Policy for all Office of Solid Haste and Emergency Response
(OSWER) Superfund Amendment Reauthorization Act field activity employees who
are engaged in hazardous substances or related activities.
BACKGROUND: The Environmental Protection Agency (EPA) is mandated by a
number of laws and regulations to safeguard the health and safety of its
employees. While the Occupational Health and Safety Staff (OHSS), within
the Office of Administration and Resources Management's (OARM) Office of
Administration (OA), has overall responsibility for the development,
organization, and administration of EPA's Health and Safety Programs, the
responsibilities for establishing, implementing, and enforcing an
Occupational Health and Safety Program have been delegated to Assistant
Administrators (AA) and Regional Administrators (RA) by the EPA Occupational
Health and Safety Manual (EPA Order 1440). Since OSWER has the
responsibility for developing and implementing specific health, safety, and
training programs for its employees, this document is intended to inform the
field activity employee of his/her duties and responsibilities in regard to
specific health and safety policies, and to demonstrate OSWER's overall
commitment to the protection of its employees.
APPLICABILITY: This policy is effective for all OSWER field activity
employees who are either actively or potentially involved in various
hazardous substances field activities (i.e., RCRA major corrective actions
and RCRA storage, treatment, and disposal facilities regulated under 40 CFR
parts 264 and 265; Hazardous Waste & Emergency Response; Chemical
Preparedness; Underground Storage Tanks; Solid Wastes; etc., and other field
activities involving hazardous or potentially hazardous substances ).
Applicability of this policy also extends to persons who are not employed by
OSWER, but are either under a specific contract or otherwise under the
jurisdiction of OSWER.
May 15, 1988
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CONTENTS
1.0 PURPOSE 1
2.0 OSWER POLICY 1
3.0 AUTHORITY 2
4.0 RESPONSIBILITY 2
4.1 ADMINISTRATIVE 2
4.2 TRAINING 3
4.3 MEDICAL SERVICES 3
4.4 OSWER INTEGRATED HEALTH
AND SAFETY PROGRAM 4
5.0 FIELD ACTIVITY CATEGORIES
AND PROCEDURES 4
5.1 DEFINITION OF CATEGORIES 4
5.2 CATEGORY REQUIREMENTS 6
5.3 STANDARD OPERATING GUIDELINES 7
6.0 MEDICAL BASELINE AND MONITORING PROGRAMS 9
7.0 TRAINING REQUIREMENTS 9
8.0 HAZARD COMMUNICATION/RIGHT-TO-KNOW 10
APPENDIX A OSWER INCIDENT SAFETY CHECK-OFF SHEET 12
APPENDIX B OSWER MEDICAL MONITORING REQUIREMENT 13
APPENDIX C SUMMARY OF THE OSWER HEALTH AND
SAFETY TRAINING REQUIREMENTS 14
APPENDIX D OSWER RESPIRATORY PROTECTION PROGRAM 15
APPENDIX E OSWER INTEGRATED HEALTH & SAFETY
WORK GROUP ORGANIZATIONAL CHART 22
APPENDIX F EPA HEALTH AND SAFETY REQUIREMENTS
AND GUIDELINES 23
APPENDIX G GENERAL DESCRIPTION OF THE OERR LEVELS
OF PROTECTION AND PROTECTIVE GEAR 24
May 15, 1988
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1.0 PURPOSE
The purpose of this document is to establish an Integrated Health and
Safety Policy for all OSWER employees who are presently, or who may
be engaged 1n the future field activities (e.g. hazardous substance
field activities and related activities involving hazardous
chemicals/ substances).
1.1 Each OSWER employee involved in field activities shall receive
appropriate training, equipment, and medical monitoring in
accordance with the U.S. EPA Occupational Health and Safety
Manual (Order 1440), U.S. EPA Orders 1440.2 and 1440.3, the
Office of Emergency and Remedial Response (OERR), Hazardous
Response Support Division Standard Operating Safety Guides, as
well as other appropriate Federal/State requirements and
guidelines such as 29 CFR 1910/1926.
1.2 Any extension of duty associated with hazardous substances or
other similar OSWER field activities beyond the specific field
category to which a particular employee is assigned or for which
he/she is specifically qualified by training and practical
experience is prohibited. No supervisor is authorized to order,
direct, or otherwise instruct an employee to enter a situation
that is more hazardous than that employee's field training
certification (e.g., Occupational Health and Safety Manual
[Chapter 7], EPA Order 1440.2 and 29 CFR 1910.120). Such an
assumption of duty by an employee involves the concomitant
assumption of all risks on the part of that individual should
the employee be specifically Informed.that the assumption or
duty is beyond the scope of his/her training.
2.0 OSWER POLICY
2.1 All employees who participate in field activities must be
classified into field activity categories.
2.2 An employee must receive the required training and health
monitoring prior to performing field activities.
2.3 All organizations that have their own health and safety
programs, including private contractors and other Federal, state
and local agencies, shall utilize and be responsible for the
administration of their individual programs as long as these
programs are at least as stringent as the OSWER requirements and
OSHA standards.
2.4 EPA has delegated to the AA, OSWER, the Health and Safety
responsibility for OSWER employees. It is OSWER policy that
contractors shall be responsible for implementing the Office of
Emergency and Remedial Response (OERR) Standard Operating Safety
Guides (SOSG) for its employees and operations, including
employee rights to know. In this regard, EPA at a minimum
May 15, 1988
-------
requires that each contractor know and adhere to HRSD'S SOSG, 29
CFR 1910.120, and 29 CFR 1910/1926. EPA has chosen to Implement
this policy by allowing the contractor to design an Internal
health and safety program and to certify to EPA that the
company's program complies with the SOSG and 29 CFR 1910/1926.
Where a contractor's health and safety program differs from the
SOSG, the contractor must certify to EPA that his program is at
least as stringent as EPA requirements.
3.0 AUTHORITY
The authority for this program is derived from: U.S. EPA, OHSS,
Occupational Health and Safety Manual, U.S. EPA Order 1440, 1440.2,
and 1440.3, and all applicable Federal requirements.
4.0 RESPONSIBILITY
4.1 ADMINISTRATIVE
4.1.1 CATEGORIZATION - This order identifies four distinct
field activity categories into which employees are
assigned based upon their field training certification
classification (EPA Order 1440.2 and 29 CFR 1910.120)
and exposure potential. The categories are defined and
outlined in Section 5.0. (Procedures and Duty
Categories) of this document.
4.1.2 Office Directors are delegated the authority and
responsibility to implement and enforce this policy. To
ensure a truly integrated/coordinated program, each
Office Director is required to assign at least one
occupational and safety health person to serve as
liaison on the OSWER Integrated Health and Safety
Workgroup chaired by the Environmental Response Team
(ERT), Edison, N.J.
4,1.3 Division Directors are delegated the authority to
identify each field activity position in their
Divisions.
Budgeting of funds for safety training and for the
purchase, maintenance and storage of employee safety
equipment is the responsibility of the Division
Director.
4.1.4 Branch Chiefs are responsible for assigning field
activity categories to Section Chiefs/first line
supervisors.
The Branch Chiefs are also responsible for maintaining
Employee Safety and Training Records, which contain all
safety-related matters.
May 15, 1988
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4.1.5 Section Chiefs/first line supervisors are responsible
for assigning field activity categories to an individual
employee. Each employee shall be provided with a
complete description of the field activity categories.
The Section Chief or deslgnee is responsible for
purchasing, Issuing, and training his/her personnel
concerning any phase of respiratory protection.
4.1.6 Employee must read and fully understand the OSWER policy
and sign a statement attesting to that fact.
4.1.7 OSWER Integrated Health and Safety Workgroup will
coordinate the implementation and maintenance of this
policy. The Workgroup representative is the focal point
for coordinating the office's activities with regard to
OSWER employee occupational health and safety
activities.
4.2 TRAINING
4.2.1 The development, implementation, and maintenance of
safety training programs shall be the highest OSWER
training priority. The AA, OSWER, or designee, is
ultimately responsible for ensuring that all OSWER
employees and contractors receive the appropriate safety
equipment and training or equivalent in accordance with
U.S. EPA Orders (e.g., 1440, 1440.2, 1440.3) and 29 CFR
1910/1926.
4.2.2 The responsibility for ensuring that all employees
receive the appropriate mandatory safety training is
shared jointly by the OSWER Office Directors, Division
Directors, Branch Chiefs, Section Chiefs/first line
supervisors, and employee.
4.2.3 All supervisors equivalent to or lower than Section
Chiefs in charge of field activity employees should
receive commensurate safety training in all applicable
field safety categories.
4.3 MEDICAL SERVICES
4.3.1 The AA, OSWER, (or designee) is ultimately responsible
for ensuring that all field activity employees actively
participate in a Medical Monitoring Program (See
Appendix B).
4.3.2 It is the employee's responsibility to seek medical
assistance and advise his/her supervisor in the event of
exposure or potential exposure to a contaminant. In
addition, the employee must report all accidents/
May 15, 1988
-------
exposure to his supervisor so the required workers'
compensation form can be carried to the medical
provider.
4.3.3 If an emergency exists, the employee must contact the
supervisor and complete the necessary forms as soon as
possible (see EPA Occupational Health and Safety Manual,
Order 1440, Chapter 3).
4.4 OSWER INTEGRATED HEALTH AND SAFETY PROGRAM
The Agency's Occupational Health and Safety Manual (EPA ORDER
1440), particularly Chapter 9, establishes occupational health
and safety policy and requirements, and assigns responsibilities
for EPA employees engaged in hazardous substance field
activities. In order to meet these requirements, the
Environmental Response Team (ERT), Edison, NJ has been delegated
the responsibility to manage the OSWER Integrated Health and
Safety Program. The primary objective of the program is to
ensure that all aspects of the safety and occupational health
requirements are met in a timely fashion to afford each employee
proper protection.
5.0 FIELD ACTIVITY CATEGORIES AND PROCEDURES
5.1 DEFINITION OF CATEGORIES
In order to meet the specific needs of the individual OSWER
employees, this policy requires additional administrative
controls over those of EPA Orders 1440.2 and 1440.3. The
administrative control is a further restriction to EPA Order
1440.2 "Basic, Intermediate and Advanced" training
certification, and is accomplished by assigning Categories No.
1-4 to the appropriate field activity personnel. Because of
these additional administrative controls, Categories 2 and 3
employees are exempt from the EPA Order 1440.2 requirement of
three days of on-the-job training within three months of
classroom training unless requested by the employee. However,
when applicable, they are still required to meet the three days
of on-the-job training.
The employee's category assignment may be changed by the first
line supervisor via written notification to the Manager, OSWER
Integrated Health and Safety Program, U.S. EPA-ERT, (Mail Code
MS101) Raritan Depot, Bldg. 10, Woodbridge Ave., Edison, NJ
08837 (FTS 340-6740). This notification consists of identifying
the employee's necessary change(s) and verifying that the
appropriate training, equipment, and medical examination have
been provided to the employee for the reclassification.
May 15, 1988
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5.1.1 Category 1 is established as the OSWER highest risk
category. This category Includes all employees whose
job description/critical job elements require handling
of, or potential exposure to, Identified or unidentified
hazardous chemicals. For example, employees responding
to spill emergencies, uncontrolled hazardous waste
sites, etc. (i.e., ERT personnel) are in this category.
These employees are authorized to wear OERR Levels of
Personnel Protective Equipment A, B, C, and D. Medical
examinations are given every six months. See Appendix G
for details.
5.1.2 Category 2 includes those OSWER personnel who are
required to enter the "Exclusion Zone" or a facility's
"Treatment/Storage Activity Area" where there is the
potential of exposure to identified or unidentified
hazardous chemicals, for more than approximately 20
days per calendar year1. Sampling and corrective
action activities are some examples of the job
function. These employees are authorized to wear OERR
Levels of Personnel Protective Equipment C and D, and
receive Medical Examinations annually. (Those employees
that will only engage in RCRA activities will receive a
Category 2A Listing.) See Appendix G for details.
5.1.3 Category 3 includes those OSWER personnel who are
required to enter the "Exclusion Zone" or a facility's
"Treatment/Storage Activity Area" where there is the
potential of exposure to identified or unidentified
hazardous chemicals situations, etc., for less than
approximately 20 days per calendar year1. Sampling
and corrective action activities are some examples of
the job function. (Those employees that will only
engage in RCRA activities will receive a Category 3A
Listing.) See Appendix G for details.
Medical examinations are scheduled based on the
employee's number/frequency of hours of potential
exposure. This period may range from 1-4 years. These
employees are authorized to wear OERR Levels of
Personnel Protective Equipment C and D. See Appendix G
for details.
5.1.4 Category 4 includes all other OSWER field activity
personnel not specifically addressed in Categories 1-3,
but who are required to perform his/her job function 1n
a "Secure/Clean Area" of those activities Identified in
Categories 1 through 3. These employees are not
authorized to wear OERR Levels of Personnel Protective
Equipment.
* The period of potential exposure of greater than or less than 20 days
is derived from the 30-day standard in 29 CFR 1910.120 and may be modified
as appropriate per supervisor and employee agreement.
May 15, 1988
10
-------
Examples of this type of employee are: Certain
operations conducted under RCRA as described In 29 CFR
1910.120(0); employees and supervisors who perform
activities in the "Support Zone" at hazardous waste site
emergency spills.
5.2 CATEGORY REQUIREMENTS
This section of the OSWER policy provides a basic framework for
the safe conduct of Category 1-4 personnel while being directly
or indirectly Involved 1n a hazardous substance activity.
5.2.1 OSWER field activity personnel must be aware, 1n
advance, of the objectives of each site visit and must
be prepared to employ safe operations to avoid potential
hazards. Each employee 1s required to enforce and
comply with this policy and exercise good personal
judgement and technical expertise on a case-by-case
basis.
5.2.2 Whenever applicable, OSWER field activity personnel are
required to implement the OERR, HRSD, Standard Operating
Safety Guides for guidance and selection criteria.
OSWER personnel must exercise extreme caution to prevent
loss of life, injury, or health hazards to themselves
and to the general public. OSWER field activity
personnel are required to adhere to this policy whether
or not the Regional requirements are as specific as this
policy.
5.2.3 In the event of conflicting safety regulations, the
employee must implement those sa/ety practices affording
the highest level of protection 'for everyone involved.
5.2.3.1 Qualifications
To be eligible to perform Category 1-3 duties,
the employee must:
a) be assigned to the on-site work by his/her
supervisor;
b) complete a Baseline Medical Examination and
participate in a medical monitoring
program;
c) complete the appropriate health and safety
training program as per U.S. EPA Order
1440.2, 1440.3, and 29 CFR 1910.120 prior
to involvement in field activities, and/or
other types of similar field activities;
d) be assigned the appropriate Field Activity
Category.
May 15, 1988
11
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5.3 STANDARD OPERATING GUIDELINES
5.3.1 Pre-arrival Planning
In planning a field activity, it is the employee's
responsibility to be aware of the purpose of the field
activity and comply with the OSWER Integrated Health and
Safety Policy, OHSS Occupational Health & Safety Orders,
29 CFR 1910.120, and all applicable requirements.
5.3.1.1 PRIOR to arrival at a field activity location,
the employee shall complete Part One of the
OSWER Incident Safety Check Sheet (refer to
Appendix A) and furnish it to the first line
supervisor or designee for review. It is
recognized that lead time and availability of
information are usually limited; however, the
employee must attempt to complete this form
(preferably prior to office departure). If any
emergency arises, it is recommended that, the
employee and his/her supervisor contact the
Environmental Response Branch's Edison, NJ
Hotline (201-321-6660) for technical
assistance.
5.3.1.2 When Applicable, Site Safety Plans shall be
completed and submitted in accordance with 29
CFR 1910.120, OHSS, Occupational Health and
Safety Manual, and OERR, HRSD, Standard
Operating Safety Guides.
5.3.2 Safety Onsite (When Applicable)
OSWER personnel shall implement on-site evaluation and
inspection in accordance with the OERR, HRSD, Standard
Operating Safety Guides.
5.3.2.1 The buddy system shall be utilized in the
field; OSWER field personnel shall not enter an
"Exclusion Area" or a RCRA hazardous waste TSD,
etc., alone. Employees shall make use of their
practical experience and technical expertise to
keep alert to potentially dangerous
situations. Guidance for these types of
precautionary measures and procedures is
provided in the OERR, HRSD, Standard Operating
Safety Guides and other state-of-the-art
technology documents.
May 15, 1988
12
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5.3.2.2 If any condition suggestive of a situation more
hazardous than anticipated 1s discovered, all
field activity shall temporarily stop for a
revaluation of the hazard and the level of
protection required.
5.3.2.3 In the event that an OSWER field activity
employee experiences any adverse effects or
symptoms of exposure while engaged 1n field
activities, he/she must immediately leave the
site/area, and contact the site/facility
supervisor (OSC, etc.), and seek appropriate
medical attention. Such incidents must be
reported in accordance with Chapter 3 of the
EPA Occupational Health and Safety Manual (EPA
Order 1440).
5.4 Personnel Protection
If OSWER personnel are required to enter any area 1n which there
is a risk of potential exposure or in which respiratory
protection is needed, e.g., a hazardous site/spill exclusion
zone, RCRA storage facility, manufacturers production area,
etc., they are required to adhere to this Integrated Health and
Safety Policy whether or not the Regions have a policy or a
specific site safety plan. Employees are required to refer to
the OERR, HRSD, Standard Operating Safety Guides for a detailed
description of the levels of protection and selection criteria.
5.5 Site Departure and Decontamination Procedures
Disposable safety clothing and sampling equipment shall be
properly disposed. If appropriate disposal facilities are not
available, safety clothing, and sampling equipment shall be
placed in a suitable container pending proper disposal.
Nondisposable safety clothing and sampling equipment shall be
decontaminated (preferably on-site) 1n accordance with the OERR,
HRSD, Standard Operating Safety Guides. In the event that the
adequacy of these procedures is questionable, nondisposable
equipment shall be placed in appropriate containers until the
exact nature of the sampled material 1s known. Suitable
decontamination procedures shall then be employed to clean the
equipment, or the equipment shall be properly disposed of at an
approved RCRA hazardous waste facility that meets the
requirements of the EPA offsite policy (OSWER Directive 9834.11)
and EPA Land Disposal Restrictions (RCRA sections 268.30 and
268.32).
Hay 15, 1988
13
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6.0 MEDICAL BASELINE AND MONITORING PROGRAMS
Based on their field exposure classification, OSWER field activity
employees shall undergo routinely scheduled examinations to determine
the possible health effects of such activity. A medical baseline
health profile shall be established for this purpose. As a minimum,
the OSWER medical monitoring program shall consist of OHSS guidelines
and requirements. In general, the medical monitoring program shall
be apportioned into three classes on the basis of employee field
activities and potential exposure. In addition, OSWER field activity
personnel shall immediately receive post-exposure medical/treatment
examinations upon notifying their Section Chief(s) of an exposure. A
tabular summary of the OSWER Medical Monitoring Requirements
according to Field Activity Category is included in Appendix B of
this document.
7.0 TRAINING
An adequate training program is essential for proper implementation
of this Integrated Health and Safety Policy. The complexities of the
topics of interest, the variety of courses offered, and the need for
specific training within each category necessitates formulation of
certain ground rules.
7.1 Each OSWER field activity employee shall receive safety training
commensurate with the job requirements and field exposure
classification. First line supervisors shall recommend
additional safety training courses for an employee's future
needs.
7.2 A series of core topics are designated for each category as
tabulated in the Summary of the OSWER Health and Safety Training
Requirements (Appendix C). These core topics are mandatory of
all OSWER Field Activities Category Employees. The other topics
identified as "desirable" should be taken by employees based
upon the recommendations of their supervisors. The level of
training provided shall be consistent with the employee's job
function and responsibilities. Supervisors are responsible for
insuring that their employees are properly trained.
7.3 The training plans and programs must remain flexible enough to
include/delete any additional/obsolete topics as the need arises
or new ideas are introduced. As per EPA Order 1440.2 and 29 CFR
1910.120, 8 hours of refresher training are required annually of
most OSWER field activity personnel.
7.4 Training hour requirements vary on the specific field activity.
The following summarizes the 29 CFR 1910.120 training
requirements as it relates to the OSWER Field Activity
Categories:
May 15, 1988
14
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Category 1: Forty hours of training, plus 3 days of actual
field experience under the direct supervision of a trained,
experienced supervisor. (Field supervisor in this category will
be required to have an additional 8 hours of "Supervisor
Training.") All employees shall receive 8 hours of refresher
training annually.
Category 2: Hazardous waste site and corrective action site
workers are required to have the same as Category 1 (above).
All other Category 2 personnel that do not enter an Exclusion
Zone or equivalent area, may qualify for 29 CFR 1910.120(0)
training requirements of 24 hours initial training and 8 hours
refresher training annually.
Category 3: Hazardous waste site and corrective action site
workers are required to have the same as Category 1 (above).
All other Category 3 personnel that do not enter an Exclusion
Zone or equivalent area, may qualify for 29 CFR 1910.120(0)
training requirements of 24 hours initial training and 8 hours
refresher training annually.
Category 4: Although not required by 29 CFR 1910.120, all
Category 4 employees are required to have a minimum of 4 hours
of training in those areas identified in Appendix C.
8.0 HAZARD COMMUNICATION/RIGHT-TO-KNOW
8.1 The EPA is required to communicate the hazards associated with
the workplace to all EPA employees. EPA Order 1440.7, Hazard
Communication, requires that employees be given information and
training on hazardous substances in their work areas.
8.2 It is EPA policy that it will extend the hazardous
communication/right-to-know requirement to its contractors or
contractor representatives. At a minimum, OSVIER employees and
contractors and their representatives must be informed of the
physical and health hazards of known substances in the work
area, methods to detect hazardous substances, and measures
employees can take to protect themselves from the hazards. In
the case of OSWER employees, the hazardous substances are often
unknown.
8.3 All parties working together at hazardous waste sites or spill
emergencies/accidents must share all available information on
the possible hazards involved.
8.4 As part of the hazard communication, employees are to be
informed of the threat to human reproduction by chemicals in the
workplace. OSWER employees (both male and female) who are
potentially exposed to chemicals that affect reproduction, such
as teratogens, mutagens, and chemicals that alter fertility,
May 15, 1988
15
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have the right to request a temporary change in job assignment
as needed to allow conception or to protect an unborn child.
Each request will be handled on an individual basis. For each
request the supervisor has the responsibility to assess the
reproductive hazards associated with the job and to make
reasonable accommodations of equal professional status.
May 15, 1988
16
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Appendix A
OSWER INCIDENT SAFETY CHECK-OFF LIST
I. BEFORE FIELD ACTIVITY Employee
1. Incident: Site City State.
a. Response Dates,
Activity Description: Environmental Sampling Product Sampling,
Residential Site Evaluation Containment Hell Drilling_
Facility Inspection,
3. Type of Response: Spill Site Facility Other
4. Site Topography: Mountains Rivers Valley Rural.
Suburban Urban Level Slopes
Facility
5. Incident Safety Plan: Not Developed Reviewed
(when applicable) Region Briefed
ERT
6. Site Accessibility: Road: Good Air: Good
(when applicable) Fair Fair
Poor Poor
7. Suspected chemical(s) and pathway with source(s) involved: (A)
(B) (C) (D).
8. Emergency Response Teams present for First Aid, etc. Yes No
9. Protective Level(s) Selected: (A) (B) (C) (D) ~
(a) If Level "C," Identify Canister.
If Level "D," JUSTIFY: write in comments section at bottom of page
10. If SCBA, Identify Buddy System: Office/Name.
11. Last Response: (a) Level Used: (A) (B) (C) (D)
(b) Medical Attention/Exam Performed: Yes No_
II. AFTER RESPONSE
1. Protective Level Used: (A) (B) (C) (D)
a. Level "C," identify canister: b. Level "D" (comment below)
c. Level B/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: hr/day for days
PART I: Date Prepared Reviewed by Date
PART II: Date Prepared Reviewed by Date
May 15, 1988
17
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APPENDIX B
SUMMARY OF OSWER MEDICAL MONITORING REQUIREMENTS
PER EMPLOYEE CATEGORY
EMPLOYEE
CATEGORY 1
2
3 4
Examination
Class*
N/A
Base line
Medical
Monitoring
Exam every
6 months
plus
Base line plus
Annual
Medical
Monitoring
Exam
Base line plus
periodic medi-
cal monitoring
exam based on
potential exp-
osure freq.
(avg 1-4 yr)
* Examination rate may increase with increasing incidence of exposure.
NOTE: A "calendar year" is a somewhat arbitrary term when discussing a
measurement of exposure. For example, 8 one-day visits to a site
where the exposure is great or the toxicity is high may be more
critical to the health of the individual than 19 visits at another
site. Therefore, all factors must be considered when selecting the
Medical Monitoring Exam schedule.
May 15, 1988
18
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APPENDIX C
SUMUKT Of THE OSUER HEALTH AND SAFETY TRAINING COURSE REQUIREMENTS
OERR
Levels
Cate- of Pro- EPA Order OSVCR Policy OCRR Standard Operating Properties of
gory tection 1U0.2 Classification Oocunent Safety Guides Hazardous Mtls. Toxicology
1
2
3
i>
A.B.C
C
C
NONE
Advance
Intermediate/Basic
Intermediate/Basic
N/A
X
X
X
X
X
X
X
X
X
X
X
H/A
X
X
X
N/A
Employe*
Rights and
Cate- Basic Office Basic Field Protective Respiratory Decontamination Entry Responsi- Defensive
gory First Aid First Aid CPU Clothing Protection Procedures Procedures bitities Driving
1
2
3
4
0
0
0
0
X
X
X
0
0
0
0
0
X
X
X
N/A
X
X
X
N/A
X
X
X
N/A
X
X
X
N/A
X
X
X
X
X
X
X
X
Key: X - Mandatory, Core Topics
0 > Desirable, But Hot Mandatory
N/A • Not Applicable
• * CardiopulBonary Resuscitation
May 15, 1988
19
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APPENDIX D
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised March 1988)
I. Purpose
The Office of Solid Waste and Emergency Response (OSWER) respiratory
protection program is intended to control exposures to those agents
that may cause occupational diseases when air is contaminated with
harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors.
II. Objective
Respiratory protection may be properly worn when effective
engineering control methods are not feasible, while they are being
implemented, or in emergencies. Generally, most corrective actions
do not lend themselves to effective engineering controls.
Therefore, respiratory protection is judged to be the best approach
to ensure employee health protection. It is important to note,
however, that effective work practices can minimize reliance on such
devices. The primary objective of this program is to protect the
employee against "potential" exposure as well as measured exposure.
III. Scope
This respiratory protection program is intended to address all OSWER
field activity employees.
IV. Responsibility
It is the responsibility of Section Chiefs/first line supervisors to
administer this program in close liaison with medical monitoring
personnel. Supervisors are required to provide both the appropriate
training and respiratory protection employees need, at no cost to
the employee.
Employees shall use the respiratory protection provided in
accordance with instructions and training received. Each employee
shall guard against damage to the respirator, and report any
respirator malfunctions to the supervisor.
V. Program Elements
A. The OSWER respiratory protection program meets all provisions of
29 CFR 1910.134 and 29 CFR 1910.120. In addition, it meets all
EPA, OHSS's Occupational Health and Safety requirements and the
OERR's, HRSD Standard Operating Safety Guides.
May 15, 1988
20
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B. Program Elements
1. Standard Operating Procedures. This respiratory protection
program shall function as the written standard operating
procedures governing the selection and use of respiratory
protection for OSWER personnel.
2. Respirator Fitting and Selection
a. The selection of the proper type of respiratory
protection shall be based primarily on, but not limited
to the:
1) Nature of the field activity;
2) Type of respiratory hazard;
3) Location of the hazardous area;
4) Period of time for which respiratory protection must
be provided;
5} Employee's potential exposure;
6) Employee's activities;
7) Employee's physical characteristics and functional
activities;
8) Limitations of the various types of respirators; and
9) Respirator protection factors/respirator fit.
b. Factors concerning both the potential and the measured
hazard shall be considered when requiring the use of
respiratory protection. These factors shall include,
but not be 1imited to:
1) Types of hazard;
2) Physical and chemical properties;
3) Physiological effects on the^body;
4) Expected concentration/level;
5) Established ACGIH TLV's, OSHA PEL'S, AIHA WEEL's.
6) IDLH considerations; and
7) Agent warning properties.
c. U.S. EPA Environmental Response Team's (ERT) Air
Monitoring Guidelines (FSOP #8) shall be followed, when
applicable, to identify the type of respiratory hazards,
define their nature and potential (i.e., vapor,
particulate, etc.), and determine the concentration in
the work area.
d. Factors concerning potential and actual site activities
shall be taken into account in selecting proper
respiratory protection. These factors include a
description of work activities; description of the
potential hazards; agents of health concern, employee
exposure potential and work activities. The selected
respirator protection must be continuously evaluated to
reflect changes in conditions or factors.
May 15, 1988
21
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e. The work activity location, with respect to a safe/clean
area, shall be considered in selecting respirator
protection. Not only does this permit for a well
identified contamination reduction zone, but also
requires the presence of emergency access and exit
areas.
f. The period of time a respirator is to be worn shall be
considered when selecting respiratory protection.
g. Worker activities and locations during site activities
shall be considered when selecting proper respiratory
protection.
h. The physical characteristics, functional capabilities,
and performance limitations of various types of
respiratory protection shall be considered when
selecting a respirator.
i. The hazards for which a particular respirator is
designed shall be considered when selecting a
respirator.
j. A qualitative respirator fit test shall be performed on
each user to determine a satisfactory fit with negative
pressure respirators. Test results shall be used to
select specific types, makes, and models for individual
workers. All OSWER Category 1 and 2 employees will be
fit tested at least annually. Category 3 personnel will
be fit tested before each respirator use after the
initial testing. Fit testing is not required for
positive pressure respirators (e.g., SCBA units).
Individual workers shall be trained to qualitatively
check respirator fit via the positive-negative pressure
method each time a unit is donned. Whenever possible, a
quantitative fit test shall be incorporated.
k. Respirators shall not be worn when conditions prevent a
good seal. Employees shall not wear respirator temple
bars, straps, head coverings, etc. between the sealing
surface of the respirator. Neither shall respirators be
worn If facial hair, features, etc., prevent a good fit.
1. Respirator fit testing records shall be kept. Records
shall include type of fit-test method used, specific
make and model of respirator tested, name of worker
tested, name of test operator, date of test, and results
of fit testing.
m. A variety of sizes of respirator facepieces shall be
available to OSWER personnel to accommodate the wide
range of facial shapes and dimensions among personnel.
-17-
May 15, 1988
22
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n. Employee preference for a particular respirator model
shall be considered when selecting suitable respiratory
protection. This includes such factors such as comfort,
breathing resistance, weight, field of vision, etc.
However, the preferred model must have a satisfactory
fit test.
o. Where feasible, respirators shall be individually
assigned to workers for their exclusive use. If a
respirator is marked for identification purposes, the
marking shall not affect the respirator performance.
3. Training and Education
a. Each respirator wearer shall be given training that
shall include explanations and discussions of
respiratory hazards and misuse; the need for respiratory
protection; the reason for selecting a particular
respirator; the function, capabilities, and limitations
of the selected respirator; the method for donning the
respirator and checking its fit and operation; proper
wearing instructions; respirator maintenance;
recognizing and handling emergencies; special
instructions as required; regulations concerning
respirator use; and identification of respirator
cartridges and canisters by color code.
b. The training shall include a hands-on portion that
covers donning, wearing, and removing the respirator;
adjusting the respirator for proper fit; wearing the
respirator in a safe atmosphere and in a test
atmosphere.
c. The Section Chief or designee is responsible for
purchasing, issuing, and training his/her personnel
concerning any phase of respiratory protection.
d. Trainers, employees, and others associated with the
respiratory protection program shall be trained to
ensure the proper use of respirators. Training shall
include basic respiratory protection practices, the
nature and extent of expected respiratory hazard
exposure, principles and criteria for selecting
respirators, using respirators and monitoring their use,
maintenance and storage, and regulations governing
respirator use.
e. Each respirator wearer shall be retrained and fit tested
at least annually or as appropriate (e.g.,after large
changes in body weight, dental surgery, etc.) when
facial size or shape significantly changes (see
Paragraph V.B.2.J).
Hay 15, 1988
23
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4. Cleaning and Disinfecting
a. Respirators shall be regularly cleaned and disinfected.
Those issued for the exclusive use of one worker should
be cleaned after each day's use, or more often if
necessary. Those used by more than one worker shall be
thoroughly cleaned and disinfected after each use (e.g.,
routine, non-routine, emergency, or rescue units).
5. Equipment Storage
a. Respirators shall be stored in a convenient, clean, and
sanitary location so that they are protected against
dust, sunlight, extreme temperature, excessive moisture,
or damaging chemicals.
b. Respirators shall be stored to prevent distortion of
rubber or other elastomeric parts. Respirators shall
not be stored in such places as lockers and tool boxes
unless they are adequately protected from contamination,
distortion, and damage. Consult the "use and care"
instructions, usually mounted inside the carrying case
lid, for proper storage of emergency respirators.
6. Inspection and Repair
a. Each respirator shall be inspected routinely before and
after each use. A respirator shall be inspected by the
user immediately before each use to ensure that it is in
proper working condition.
b. After cleaning and sanitizing, each respirator shall be
inspected to determine if it is in proper working
condition, if it needs replacement parts or repairs, or
if it should be discarded. Each respirator stored for
emergency or rescue use shall be inspected at least
monthly and after each use by an experienced person.
Respirator inspection shall include a check for
tightness of connections; for the conditions of the
respiratory inlet covering, head harness, valves,
connecting tubes, harness assembly, filter(s),
cartridges, canister, end-of-service-life indicator, and
shelf life date(s); and for the proper function of
regulators, alarms, and other warning systems.
c. Each rubber or elastomeric part shall be inspected for
pliability and signs of deterioration. Each air and
oxygen cylinder shall be inspected to ensure that it is
fully charged according to the manufacturer's
instructions.
May 15, 1988
24
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d. Only parts designed for a specific respirator shall be
used in its repair. Do not replace components or make
adjustments or repairs beyond the manufacturer's
recommendations. Reducing and admission valves or
regulators shall be returned to the manufacturer or to a
trained technician for adjustment or repair.
e. A record of inspection dates, findings, and remedial
actions shall be kept for each SCBA respirator
maintained for emergency or rescue use.
7. Surveillance
Appropriate surveillance or work area conditions and degree
of employee exposure or stress shall be maintained.
8. Evaluation of Respiratory Protection Program
a. There shall be periodic (at least annual) inspection and
evaluation to determine the continued effectiveness of
the respiratory protection program. It is essential to
ensure that all employees are provided with adequate
protection. The program should be improved and
deficiencies should be eliminated based on evaluation
results.
b. Respirator wearers shall be consulted periodically about
their acceptance of respirators. Frequent inspection of
the program shall be conducted to ensure that proper
types of respirators are selected, that users are
properly trained, that appropriate equipment is issued
and used, that respirators are worn properly, that
respirators are in good operating condition, that
respirators are inspected and maintained properly, that
respiratory storage is acceptable, that respiratory
hazards are monitored, and medical examinations are
given as necessary, to evaluate user health.
c. The results of the inspection and evaluation shall be
utilized to improve or maintain elements of the program
as appropriate. Follow up investigations shall be
conducted to ensure that sources of concerns are
identified and corrected. Evaluation findings shall be
documented. Plans to correct program concerns shall be
documented (i.e., problem, target dates, responsibility,
etc.).
9. Medical Approval
a. Each employee shall have a medical evaluation to
determine fitness to wear respiratory protection and
potential exposure. Adequate medical data shall be
provided as part of the preplacement examination and all
Hay 15, 1988
25
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subsequent examinations to allow a physician to make a
judgement on each worker's fitness (Refer to Appendix B
of the Integrated Health and Safety Policy for Field
Activities for examination schedule).
b. Employees shall show the examining physician their
exposure records (e.g., Incident Safety Check-off Sheet
[See Appendix A of the Integrated Health and Safety
Policy for Field Activities]) since the last
examination.
10. Approved Respiratory Protection
Only approved respiratory protection shall be selected when
available. Any modification of an approved respirator that
is not authorized by the approval agencies (e.g., MSHA and
NIOSH) voids the respirator approval.
VI. Air Quality
A. Compressed air, compressed oxygen, liquid air, and liquid oxygen
used for respiratory protection shall be of high purity.
Compressed air should be the principle source of breathing air.
Compressed gaseous air shall meet at least the requirements for
Type 1 - Grade D breathing air of Compress Gas Association
Commodity Specification G-7.1-1966.
B. Breathing air should be supplied to respirators from cylinders.
11 cylinders shall be tested for quality and maintained in
accordance with applicable DOT specifications for shipping
containers (Title 4-9, Code of Federal Regulations, Parts 173
and 178).
C. Breathing air containers shall be marked in accordance with ANSI
Z48.1-1954 (R1971) or Interim Federal Specification GG-B-675b,
September 23, 1976.
Hay 15, 1988
26
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Appendix E
OSWER INTEGRATED HEALTH AND SAFETY WORKGROUP
Rodney D. Turpin
Occupational Health and Safety Manager
Environmental Response Team
Edison, NO 08837
FTS: 340-6741 - COMM: 201 321-6741
OCCUPATIONAL HEALTH AND SAFETY STAFF
Sheldon Rabinovitz
FTS: 382-3649 - MAIL CODE: PM 273F
David Weitzman (Alt.)
FTS: 382-3640 - HAIL CODE: PH 273F
OFFICE OF WASTE PROGRAMS ENFORCEMENT
Charlotte White
FTS: 382-4846 - MAIL CODE: WH 527
Rolf Hill (Alt.)
FTS: 475-7037 - MAIL CODE: WH 527
Steve Henne (Alt.)
FTS: 475-7030 - MAIL CODE: WH 527 J
OSWER - ANALYSIS 4 EVALUATION STAFF
Kate Connors
FTS: 382-6647 - MAIL CODE: WH 562A
Jim Cruickshank
FTS: 475-4515 - MAIL CODE: WH 562A
OSWER - PREPAREDNESS STAFF
Elaine Davies
FTS: 475-8600 - MAIL CODE: WH 562A
OFFICE OF UNDERGROUND STORAGE TANKS
John Heffel finger
FTS: 382-7950 - MAIL CODE: WH 565A
fOFFICE OF EMERGENCY
ANP RFHFOT/M RFSPQNSF
OFFICE OF SOLID WASTE
Jim O'Leary
FTS: 382-4649 - MAIL CODE: WH562
Cynthia Folkerts
FTS: 382-7917 - MAIL CODE: WH 565A
HAZARDOUS SITE CONTROL]
DIVISION
John J. Smith
FTS: 382-7996
MAIL CODE: WH 548E
Nancy Willis (Alt.)
FTS: 382-2347
HAIL CODE: WH 548E
EMERGENCY RESPONSE
DIVISION
Victoria van Roden
FTS: 382-2188
MAIL CODE: WH 548B
J_
HAZARDOUS SITE EVALUATION
DIVISION
Robert Heffernan
FTS: 475-9748 - MAIL CODE: WH548A
Scott Fredericks (Alt.)
FTS: 382-2467 - MAIL CODE: WH548A
ENVIRONMENTAL RESPONSE
TEAM
Vickie L. Santoro
FTS: 340-6917
MAIL CODE: MS101
27
May 15, 1988
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APPENDIX F
EPA HEALTH AND SAFETY REQUIREMENTS AND GUIDELINE
1. EPA Occupational Health and Safety Manual (1440)
Chapter 1. Policy and Responsibilities
Chapter 2. Occupational Health and Safety Program
Administration
Chapter 3. Accident and Illness Investigation, Reporting,
and Recordkeeping Requirements
Chapter 4. Inspections and Correction of Unhealthful or
Unsafe Working Conditions
Chapter 5. Occupational Health and Safety Committees
Chapter 6. Occupational Health and Safety Standards
Chapter 7. Occupational Health and Safety Training
Chapter 8. Laboratory Use of Toxic Substances
Chapter 9. Hazardous Substances Responses
Chapter 10. EPA Diving Safety Policy
2. EPA Health and Safety Orders
1440.2 - Field Activities
1440.3 - Respiratory Protection
1440.4 - Health and Safety Training Requirements for Mine
Safety
1440.5 - Qualifications and Training Requirements for
Occupational Health and Safety Program Personnel
1440.6 - Motor Vehicle Occupant Restraining Systems
1440.7 - Hazard Communication
3. Health and Safety Guidelines
Respiratory Protection Program Guideline
Eye Protection Program Guidelines
Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities
Medical Monitoring Program Guidelines
Health and Safety Guidelines for EPA Asbestos Inspections
Guidelines for the Selection of Chemical Protective
Clothing, Second Edition
May 15, 1988
28
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APPENDIX G
GENERAL DESCRIPTION OF THE OERR LEVELS OF PROTECTION AND PROTECTIVE GEAR
Personal protective equipment has been divided into four categories based
on the degree of protection afforded and are as follows:
Level A - To be selected when the greatest level of skin, respiratory, and
eye protection is required.
Level A equipment; used as appropriate:
1. Pressure-demand, self-contained breathing apparatus, approved by the
Mine Safety and Health Administration (MSHA) and National Institute
of Occupational Safety and Health (NIOSH).
2. Fully encapsulating chemical-resistant suit.
3. Coveralls*
4. Long Underwear*
5. Gloves (outer) chemical-resistant
6. Gloves (inner) chemical-resistant
7. Boots, chemical-resistant, steel toe and shank. (Depending on suit
construction, worn over/or under suit boot.)
8. Hard hat (under suit)*
9. Disposable protective suit, gloves, and boots (Depending on suit
construction, may be worn over fully encapsulating suit boot.)
10. Two-way radios (worn inside encapsulating suit).
* Optional, as appropriate
May 15, 1988
29
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Level B - The highest level of respiratory protection is necessary but a
lesser level of skin protection is needed.
Level B equipment; used as appropriate:
1. Pressure-demand, self-contained breathing apparatus (MSHA/NIOSH
approved), or airline respirator.
2. Hooded chemical-resistant clothing (overalls and long-sleeved jacket;
coveralls; one or two-piece chemical-splash suit; disposable
chemical-resistant overalls).
3. Coveralls*
4. Gloves (outer) chemical-resistant
5. Gloves (inner) chemical-resistant
6. Boots (outer), chemical-resistant, steel toe and shank.
7. Boot covers (outer), chemical-resistant (disposable)*.
8. Hard hat (face shield)*
9. Two-way radios (worn inside encapsulating suit).
* Optional, as appropriate
Hay 15, 1988
30
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Level C - The concentration(s) and type(s) of airborne substance(s) is
known and the criteria for using air purifying respirators are met.
Level C equipment; used as appropriate:
1. Full-face, air purifying, canister-equipped respirators (MSHA/NIOSH
approved).
2. Hooded chemical-resistant clothing (overalls; two-piece
chemical-splash suit; disposable chemical-resistant overalls).
3. Coveralls*
4. Gloves (outer) chemical-resistant
5. Gloves (inner) chemical-resistant*
6. Boots (outer), chemical-resistant, steel toe and shank*.
7. Boot covers (outer), chemical-resistant (disposable)*.
8. Hard hat (face shield)*
9. Escape Mask *
10. Two-way radios (worn under outside protective clothing).
* Optional, as appropriate
May 15, 1988
31
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Level D - A work uniform.
Level D equipment; used as appropriate:
1. Coveralls
2. Gloves*
3. Boots/shoes, leather or chemical-resistant, steel toe and shank.
4. Boots (outer), chemical-resistant (disposable)*.
5. Safety glasses or chemical splash goggles*
6. Hard hat (face shield)*
7. Escape Mask*
* Optional, as appropriate
May 15, 1988
32
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SECTION 2
OCCUPATIONAL SAFETY
AND
HEALTH GUIDANCE DOCUMENTS
PART 2
US EPA ENVIRONMENTAL RESPONSE TEAM'S
OCCUPATIONAL MEDICAL MONITORING PROGRAM GUIDELINES
FOR SARA HAZARDOUS WASTE FIELD ACTIVITY PERSONNEL
33
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Publication 92853-04
U.S. EPA
ENVIRONMENTAL RESPONSE TEAM'S
OCCUPATIONAL MEDICAL MONITORING PROGRAM
GUIDELINES
FOR SARA HAZARDOUS WASTE FIELD ACTIVITY PERSONNEL
January 1590
Office of Solid Waste and Emergency Response
Office of Emergency and Remedial Response
Emergency Response Division
35
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ABSTRACT
PURPOSE: The purpose of this document is to suggest guidelines covering
the requirements for a comprehensive occupational medical monitoring
program for those personnel involved in SARA hazardous waste field
activity.
BACKGROUND: Occupational medical monitoring is the surveillance of the
health status of selected employees by means of periodic examinations.
Occupational medical monitoring assists in the early detection and
prevention of adverse effects from occupational exposure to hazardous
agents and physical stress. Specifically, such a program would provide:
o Early recognition of effects from unsuspected hazards;
o Evaluation of health status with respect to work assignments;
o Indication of effectiveness of protective measures taken for known
hazards;
o Data for studies of the longterm subtle effects of occupational
exposures;
o Assurance from a physician that employees are physically able to work
under unique physical stresses, such as wearing respirators.
APPLICABILITY: It is EPA's pal.icy that a program of medical surveillance
must be instituted for each employee exposed to potentially hazardous
working conditions (i.e., SARA hazardous waste field activity).
Furthermore, the Agency's Occupational Medical Monitoring Program must
accommodate changes associated with variation in working conditions,
advances in the practice of occupational medicine, current health and
safety standards and regulations, and changes indicated by findings from
medical examinations.
January 10, 1990
36
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CONTENTS
1.0 PURPOSE 1
2.0 GENERAL REQUIREMENTS 1
2.1 PHYSICIAN REQUIREMENTS 1
2.2 PRIVACY ACT 1
2.3 MEDICAL HISTORY 1
2.4 NATURE OF EXAMINATION
2.5 MINIMUM EXAMINATION TYPES AND CONTENTS 1
3.0 BASELINE 1
4.0 PERIODIC EXAMINATION 2
5.0 UNSCHEDULED EXAMINATION 2
5.1 TIMING OF EPISODIC EXAMINATION 2
6.0 TERMINATION EXAMINATION 2
7.0 REPORTING REQUIREMENTS 2
7.1 EMPLOYEE COPY 2
7.2 NON-OCCUPATIONALLY-RELATED SYMPTOM REPORTING
(TO EMPLOYEE) 2
7.3 OCCUPATIONALLY-RELATED SYMPTOM REPORTING
(OCCUPATIONAL MEDICAL MONITORING COORDINATOR) 2
7.4 WRITTEN CLEARANCE FOR JOB CONDITIONS 3
8.0 SPECIAL REQUIREMENTS 3
8.1 IMMUNIZATIONS 3
8.2 RESEARCH TESTS 3
8.3 REPRODUCTIVE HAZARDS 3
9.0 RELATIONSHIP BETWEEN OCCUPATIONAL MEDICAL MONITORING
AND WORKERS' COMPENSATION 3
APPENDIX A TABLE OF MINIMUM EXAMINATION TYPES AND CONTENTS A-l
APPENDIX B GUIDELINES FOR IMMUNIZATION REQUIREMENTS B-l
REFERENCES iv
January 10, 1990
37
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REFERENCES
1. Title 5, United States Code, Sections 7901 and 7902.
2. Executive Order 12196, Occupational Safety and Health Programs for
Federal Employees.
3. 29 CFR 1960, Basic Program Elements for Federal Employee Occupational
Safety and Health, Occupational Safety and Health Administration
(OSHA), Department of Labor.
4. 0PM, Federal Personnel Manual, Chapter 339, Medical Examinations for
Appointment.
5. 0PM, Federal Personnel Manual, letter 293-20.
6. EPA, Occupational Health and Safety Manual, Chapter 8, Laboratory Use
of Toxic Substances.
7. EPA, Order 1440.2, Health and Safety Requirements for Employees
Engaged in Field Activities.
8. EPA, Order 1440.3, Respiratory Protection.
9. EPA, Occupational Medical Monitoring Guidelines.
10. 29 CFR 1910.20, General Industry Standards, OSHA, Department of Labor.
11. 29 CFR 1910.20, General Industry Standards, OSHA, Department of Labor.
January 10, 1990
38
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1.0 PURPOSE
The purpose of this document is to suggest guidelines covering the
requirements for an occupational medical monitoring program for those
personnel involved in SARA hazardous waste field activity.
2.0 GENERAL REQUIREMENTS
2.1 All occupational medical monitoring examinations and procedures
must be performed by or under the supervision of a licensed
physician. The physician chosen should be experienced and/or
board certified in occupational medicine. If a specialist in
occupational medicine is not available, a local physician should
be chosen who is equipped to conduct thorough physical
examinations and who is familiar with, or is willing to become
familiar with the Agency's programs and the hazards to which its
employees could potentially be exposed. All examinations must
be handled through the medical provider, and employees may not
substitute an examination by his/her personal physician.
2.2 All federal employees participating in the occupational medical
monitoring program must read and sign a copy of the Privacy Act
Statement. The original form must be filed with the employee's
official occupational medical monitoring records, and a copy
should be provided to the employee.
2.3 Each employee who is required to have an examination or medical
certificate before assignment, should complete a medical history
form and give the form to the physician at the time of the
examination.
2.3 The nature and extent of the medical examinations must be based
on the individual's potential for exposure.
2.4 Each employee is required to have baseline, periodic,
termination, and unscheduled examinations. Each of these
examinations is briefly described below. Complete descriptions
of each type of examination are identified in Appendix A.
3.0 BASELINE
The baseline or preemployment/preplacement medical examination is
given to" ensure that employees are physically able to perform the
duties of their intended positions without danger to themselves
and/or others. This examination is a comprehensive medical
evaluation intended to provide reference information for the
evaluation of subsequent examination findings. These examinations
are a condition of employment for otherwise acceptable applicants for
positions that require such an examination, or which require a
medical certificate before assignment.
January 10, 1990
39
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4.0 PERIODIC EXAMINATION
Periodic examinations are regularly scheduled examinations to
identify physical changes or illnesses thereby ensuring that prompt
treatment and remedial actions can be taken. The interval or
frequency of these examinations must be based on recommendations made
by the Employer's Occupational Medical Monitoring Coordinator.
5.0 UNSCHEDULED EXAMINATION
Unscheduled examinations are conducted to determine adverse health
effects of exposure to specific significant hazards or stresses, or
where results of a periodic, baseline or exit examination have
indicated an actual or potential health problem.
5.1 An episodic examination should be given whenever there is a
direct question about an employee's continued capacity to meet
the physical or medical requirements of the position (i.e.,
employee's direct exposure to hazardous materials).
6.0 TERMINATION EXAMINATION
A termination examination can be the same comprehensive examination
as the baseline or preemployment/preplacement examination. This
examination documents the health status of the employee at the end of
employment and provides information on any changes that have occurred
during the employment period.
7.0 REPORTING REQUIREMENTS
Any physician or medical facility that conducts a medical examination
should be required to meet the following criteria:
7.1 After each examination, furnish the employee with a written,
nontechnical evaluation report of examination findings, and a
statement of the employee's fitness for the position. The
employee should be provided with the opportunity to discuss the
results with the examining physician.
7.2 Advise the employee of abnormal test results that are felt to be
the results of non-occupationally-related causes so that the
employee may contact his/her private physician for follow-up.
7.3 Notify the employee first, and second, notify the Occupational
Medical Monitoring Coordinator, of abnormal occupational-
related findings so that any follow-up examinations or treatment
can be scheduled, or so that remedial actions can be taken in
the employee's workplace.
January 10, 1990
40
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(The Medical Monitoring Coordinator should notify the employee's
supervisor and/or the Director, Occupational Health and Safety
Staff, of abnormal test results within 48 hours of receipt of a
report of occupational-related positive findings. This notice
should be general in nature to protect the employee's
Confidentiality Rights.)
7.4 Furnish the employee with a written statement that his/her
health and physical condition are satisfactory to wear
respiratory protective devices.
8.0 SPECIAL REQUIREMENTS
8.1 Immunizations. The special situations where immunizations are
recommended are outlined in the U.S. EPA Occupational Medical
Monitoring Guidelines, Washington D.C. See Appendix B for
general information regarding immunizations.
8.2 Research Tests. Research tests for the purpose of investigation
or experimentation aimed at the discovery and interpretation of
medical facts, revision of accepted theories in the light of new
facts, or practical application of such new or revised theories
are not recommended as a part of the occupational medical
monitoring program because of their limited clinical value.
8.3 Reproductive Hazards. Extreme caution must be exercised to
ensure that employees are not exposed to harmful quantities of
classified or unclassified substances that are known or
suspected of affecting reproduction in both males and females.
As part of a hazardous substances communication, employees are
to be informed of the threat to human reproduction by chemicals
in the workplace. Employees (both male and female) who can
potentially be exposed to chemicals that effect reproduction,
such as teratogens, mutagens, and chemicals that alter
fertility, have the right to request a temporary change in job
assignment as needed to allow conception or to protect an unborn
child. Each request should be handled on an individual basis
and each supervisor should have the responsibility to assess the
reproductive hazards associated with the job and to make
reasonable accommodations of equal professional status.
8.0 RELATIONSHIP BETWEEN OCCUPATIONAL MEDICAL MONITORING AND WORKERS'
COMPENSATION
The intent of the Occupational Medical Monitoring Program is to
detect the deleterious consequences of occupational exposure to
hazardous substances or conditions, or harmful physical agents. Once
such a possibility is detected, the employee may file a claim for
worker's compensation. The federal employee's medical expenses from
that point are covered by the Office of Worker's Compensation (OWCP),
U.S. Department of Labor. If the claim is disallowed by OWCP, the
employee may use his/her medical coverage to pay the costs.
January 10, 1990
41
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APPENDIX A - MINIMUM EXAMINATION TYPES AND CONTENT
BASELINE PERIODIC TERMINATION UNSCHEDULED
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*
Choiinesterase
Methemoglobin
Heavy Metal Screen
Urine and Sputum Cytology
Polychlorinated Biphenyl (PCB)
Cardiovascular Stress Test
X - Recommended
0 - As indicated
X
X
X
X
X
X
X
X
0
X
0
0
X
X
X
0
0
X
X
X
0
0
0
0
0
0
X
X
X
X
X
X
X
0
0
0
0
0
X
0
0
0
0
0
0
0
0
0
0
0
0
0
* Any special test which may be considered on a periodic basis should be included
in the baseline test.
January 10, 1990
42
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What are the basic laboratory tests to be included for each participant
for the baseline, periodic, and termination examinations?
A. Blood Tests
Each individual should receive a basic panel of blood counts and
chemistries to evaluate blood-forming organs, kidney, liver, and
endocrine/metabolic function. The following blood tests are
considered to be the minimum desirable:
o White blood cell
count and
differential cell
count
o Hemoglobin and/or
hematocrit
o Albumin, globulin,
and total protein
o Serum glutamic
oxalacetic
transaminase (SGOT)
o Lactic
dehydrogenase (LDH)
o Alkaline
phosphatase
B. Urinalysis
o
o
o
o
o
o
o
Calcium
Phosphorus
Uric acid
Creatinine
Urea nitrogen
Cholesterol
Glucose
Each employee should have a routine urinalysis that consists of the
following:
o
o
Specific gravity
pH
January 10, 1990
43
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o Microscopic
examination
o Protein
o Acetone
o Glucose
For further information in determining the content of medical examination
with regard to specific hazardous materials, refer to Chapter Five of the
NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance.
January 10, 1990
44
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APPENDIX B - GUIDELINES FOR IMMUNIZATION REQUIREMENTS
Immunization of adult employees is rarely required after the 18th birthday.
Hepatitis Vaccine - Pre-exposure prophylaxis (Hepatitis A - ISG) for personnel in
close contact with newly imported primates is recommended every four months.
Emphasis should be also be placed on other measures such as scrupulous hygiene
practices, use of protective clothing and the limiting of human contact with
animals.
Tetanus prophylaxis - Should be the responsibility of the examining physician
when an employee is wounded. Managing of the wounded employee should be based in
the history of previous tetanus vaccinations and the condition of the wound.
Poliomyelitis vaccine - Routine primary polio vaccination of adults (those past
the 18th birthday) residing in the United States is not necessary. Most adults
are already immune and have a very small risk of exposure to poliomyelitis.
Those at increased risks such as laboratory workers handling specimens which may
contain the polioviruses should receive the vaccine as adults. Unvaccinated
adults and incompletely immunized adults (at increased risks) should be given a
full course.
Rabies prophylaxis - Local and state public health officials should be consulted
if questions arise about the need for prophylaxis.
Plague vaccine - (Infection of humans resulting from exposure to wild
rodents/their fleas occurring mostly in the western part of the United States.)
Routine bacteriologic precautions are sufficient to prevent accidental infection
with plague.
Guidelines for Female Field Investigators
Female employees of child-bearing age should not be exposed to large quantities
of unclassified chemicals. Since the teratogenic effect of some chemical
exposures on the unborn fetus is not known, extreme caution should be exercised
in said situation. Reassignment of the female should be made to nonhazardous
duties as soon as pregnancy is diagnosed.
* CDC Monograph, September, 1980.
December 6, 1988
45
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SECTION 3
QUICK REFERENCE FACT SHEETS
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QUICK REFERENCE FACT SHEETS
SECTION OBJECTIVE
The objective of this section is to provide students with a copy of the following U.S. Environmental
Protection Agency Environmental Response Team (USEPA-ERT) Health and Safety Quick Reference
Fact Sheets:
• Publication 9285. 1-02: Health and Safety Roles and Responsibilities at
Remedial Sites
• Publication 9285.2-06FS: Establishing Work Zones at Uncontrolled
Hazardous Waste Sites
• Publication 9285.2-07FS: Hazardous Waste Operations and Emergency
Response: RCRA TSD and Emergency
Response Without Regard to Location
• Publication 9285.2-08FS: Hazardous Waste Operations and Emergency
Response: Uncontrolled Hazardous Waste
Sites and RCRA Corrective Actions
• Publication 9285.2-09FS: Hazardous Waste Operations and Emergency
Response: General Information and
Comparison
• Publication 9285.2-10FS: Hazardous Waste Operations and Emergency
Response: Available Guidance
STUDENT PERFORMANCE OBJECTIVES
After completing this section and related lesson(s), the student will be able to:
• Understand the historical development of hazardous waste and emergency response
worker protection standards.
• Identify key occupational health and safety standards and guidance documents.
• Identify to whom and to what operations OSHA 29 CFR 1910.120 applies, and the
major legal requirements under paragraphs (a) through (q) in 1910.120.
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SECTION 3
QUICK REFERENCE FACT SHEETS
PARTI
HEALTH AND SAFETY ROLES AND RESPONSIBILITIES
AT REMEDIAL SITES
-------
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication
9285.1-02
July 1991
EPA HEALTH AND SAFETY ROLES
AND RESPONSIBILITIES AT
REMEDIAL SITES
Office of Emergency and Remedial Response
Hazardous SHe Control Division OS - 220W
Quick Reference Fact Sheet
Additional tact sheets which address health and safety at Superfund sites have been compiled by the
Environmental Response Team (ERT). The ERT Fact Sheets are listed in the Bibliography on page 6.
INTRODUCTION
The complex inter-relationships between the many
parties involved in remedial activities make it difficult to
administer the health and safety program. To implement an
effective, well coordinated program all participants must be
made aware of the health and safety roles and
responsibilities of ail parties involved in site remediation.
The purpose of this fact sheet is to define the major
components of the health and safety program and to
delineate the health and safety roles and responsibilities for
Remedial Project Managers (RPM), lead parties/agencies,
and contractors during the remedial action phase of Super-
fund clean-ups. It addresses the various roles of all parties
in the overall health and safety program for a site, with
emphasis on Occupational Safety and Health Act/Agency
(OSHA) compliance. More detailed health and safety
guidance documents are available through the Environ-
mental Protection Agency's (EPA's) Environmental
Response Team (ERT), Edison, NJ, (908) 321-6740 and
OSHA.
OCCUPATIONAL HEALTH &
SAFETY OVERVIEW
All governmental agencies and private employers are
directly responsible for the health and safety of their
employees. This general rule applies to the many parties
involved in the hazardous waste clean-up at Superfund sites
e. OSHA citations to abate unsafe or unheaJthful working
conditions would be written to the party whose employees
are at risk).
OSHA requires that a written (site-specific) occupa-
tional safety and health program, that includes a safety and
health plan, be in place for remedial activities at all Super-
fund sites. EPA, OSHA, and the U.S. Army Corps of
Engineers (USAGE) often use different terminology to
describe written safety and health programs and plans. EPA
uses the term Health and Safety Plan (HASP), OSHA uses
Safety and Health Program and/or Plan, while USAGE uses
the term Site Safety and HeaJth Plan (SSHP). In this
document the term HASP is used. The objective of the
HASP is to protect workers through the identification,
evaluation, and control of health and safety hazards and to
provide for emergency response contingency planning.
The party responsible for the HASP should be
identified in the work plan. It is usually developed and
implemented by the prime contractor's site coordinator, and
reviewed and accepted by the construction manager for
Fund-Lead projects and by the RPM and oversight official
for enforcement lead projects. The construction manager is
usually USAGE, the U. S. Bureau of Reclamation (USER),
or an Alternative Remedial Contracting Strategy (ARCS)
contractor. Accepted means the HASP has been reviewed
by the construction manager/oversight official and any
deficiencies have been identified and corrected prior to the
start of work. OSHA requires the HASP to be developed
and implemented before work begins at the site.
The HASP shall include a written statement delineat-
ing the responsibilities, authority, and accountability of the
various parties involved in the remedial action. A goal of
the HASP is to facilitate coordination and communication of
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health and safety issues among personnel responsible for
the various activities. The HASP is mandated by OSHA
and/or the construction contract as the legally enforceable
plan for the job site. The prime contractor is usually re-
sponsible for review and approval (after acceptance by the
RPM and construction manager) of subcontractor health
and safety programs. The HASP will be incorporated into
each subcontractor health and safety program.
The EPA must be provided an original and a copy of
all changes to the HASP prior to implementation, as they
may affect public health, the environment, overall cost,
scheduling, or technical quality of a project. It is an RPM's
responsibility to insure that all Federal safety and health re-
quirements are met at a site, however the construction
manager, not the RPM, accepts and enforces changes to the
HASP.
Specific topics/statements in the HASP include:
Training
The HASP shall specify that a training plan comply-
ing with OSHA training requirements outlined in 29 CFR
1910.120 (e) and the Hazard Communication Standard, 29
CFR 1926.59 for construction, will be implemented (it is
usually the prime contractor's responsibility). OSHA
requires both on-site and off-site training for workers at RA
sites. Increased OSHA enforcement of the training require-
ments of these standards is likely at RA sites as exemplified
by recent OSHA enforcement actions. For specific require-
ments, consult the sources of information listed at the end
of this fact sheet.
The requirements for off-site training are a function
of both the potential for exposure and management respon-
sibility. Information pertaining to off-site (initial) training
is available through a number of sources including courses
offered by ERT, USAGE (Huntsville Division) and
through the National Clearinghouse on Occupational and
Environmental Health (funded by a National Institute of
Environmental Health Sciences Grant). Additional sources
of information are listed at the end of this fact sheet.
EPA employees who have not had the 40-hours
training are not permitted to enter areas where occupational
exposures above established limits are likely. The use of
respirators implies that exposures are likely. Exceptions
are strongly discouraged, but can be made on a case-by-
case basis with the approval of the site safety and health
officer if respirators are NOT required, time on site is
limited, and visitors are given a pre-entry site briefing and
accompanied by trained personnel at all times.
On-site construction managers normally are required
to have completed a 40 hour off-site course. For those con-
struction managers who have on-site supervisory responsi-
bilities, an additional 8-hour supervisory training is
required. An 8-hour annual refresher training is required
for all site workers. Training requirements for entry to sites
where occupational exposures above established limits are
likely, or where respirators or other personal protective
equipment are required are described in the ERT Fact
Sheets listed at the end of this publication.
On-site training must be tailored to the conditions of
individual sites. At RA sites, construction managers,
RPMs, and authorized visitors must receive on-site training
prior to entering restricted areas.
Logistics and Resources
The HASP should specify that the party responsible
for health and safety plan implementation (i.e.the prime
contractor) will provide for logistics and resources, such as
qualified health and safety managers to meet plan tasks and
objectives.
The Site-Specific HASP
OSHA, 29 CFR 1910.120 (b), requires that a site
HASP be developed and reviewed by qualified personnel
for each remedial action. Subcontractors can modify the
plan to account for their own work. However, their plan or
modifications shall be formally incorporated into the
general site plan. Only one HASP is applicable to a
particular site. It must be kept on site and shall be made
available for review by employees, emergency response
personnel, or, if applicable, employee representatives.
The plan should not be generic, but should be
based on specific site characterizations, anticipated hazards
and expected work conditions at the site. OSHA requires
the plan address the following elements:
(1) A safety and health risk or hazard analysis for each
site task and operation found in the workplan.
(2) Employee training.
(3) Personal protective equipment for each task or
operation.
(4) Medical surveillance.
(5) Frequency and types of air monitoring, personal
monitoring, environmental sampling techniques,
instrumentation, and methods to be used.
(6) Site control measures.
(7) Decontamination procedures.
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(8) An Emergency Response Plan.
(9) Confined Space entry procedures
(10) A spill containment program.
Emergency Response
Most sites are too small to warrant fully staffed on-
site medical and fire fighting facilities. Where services can
be provided by surrounding communities, EPA may
provide limited training and support to compensate for
OSHA requirements specific to hazardous waste response
training and support on a case-by-case basis. The amount
of training and support that local fire fighting and emer-
gency response personnel will require for OSHA compli-
ance (Paragraph (q) of the Worker Protection Standard if
off-site responders) depends on site-specific conditions and
on Response Tasks (i.e. off-site training duration can vary
between 24 and 40 hours). Examples of the types of
suppon that may be provided by EPA to local responders
on a case-by-case basis include off and on-site training, no-
cost personal protective equipment and specialized haz-mat
equipment loans, medical surveillance, and reimbursement
of response funds.
As a minimum, the emergency response plan should
be a separate section of the site HASP. The designer (for
design operations involving site entry) and the party
responsible for the remedial action health and safety plan
(usually the prime contractor) have the responsibility to
arrange for emergency response support and written
agreements prior to commencement of operations involving
site entry. This will entail an evaluation of the capabilities
of local fire departments, hospitals, police departments, etc.
to provide coordinated and integrated services to the RD
and RA. Selection of the provider should be based on an
evaluation of current capabilities, required support levels,
response time, jurisdicuonal authority, and cost to the
Government. This information is often available from
information obtained during pre-design activities. Because
failure to secure agreements can result in remedial project
delays or work stoppage, it is important for the RPM to
address emergency response in pre-design work plans, etc.
and solicit early involvement with community relations
staff in the process.
The site safety officer (or equivalent position) should
make a copy of the HASP (to include the emergency
response plan) available, and provide on-site training for
local fire fighting and emergency response personnel
subject to respond to calls at Superfund RA sites.
Health and Safety Plan Improvements
Feedback or communications from safety meetings,
training and inspections should be openly encouraged so
that the HASP can be adjusted and improved. EPA strongly
endorses an open communication policy in which all health
and safety inquiries receive a prompt, professional re-
sponse. The HASP should outline procedures for response
to health and safety inquiries and for modifications. Con-
sistent with the OSHA worker protection standard, on-
going inspections and/or monitoring will, at times, require
changes to the HASP. Modifications should be drafted by
professional staff (i.e. the prime contractor's industrial
hygienist) and approved by the construction manager.
INSPECTIONS
Health and safety program oversight is an RPM
responsibility, however, the RPM is not required to conduct
health and safety inspections. Inspections for enforcement
purposes are the responsibility of OSHA. If inspections
uncover conditions that may adversely affect public (or
worker) health and/or the environment, the overall cost,
scheduling, or technical quality of the project, then prompt
lead party and RPM notification is necessary. For RA
projects the construction manager or oversight official is re-
sponsible for enforcing the terms of the contract or settle-
ment agreement to include the issuance of stop work orders
in situations where the health and safety provisions of the
contract are violated.
Employee Representatives
A worker representative (if applicable, the Union
health and safety representative) should be given the oppor-
tunity to accompany the inspector during non-OSHA health
and safety inspections or evaluations. For OSHA inspec-
tions, the worker representative has the right to accompany
the inspector. In situations where more than one union
represents workers at the site being inspected, the inspect-
ing official should select a health and safety representative
for each area being inspected. The selection and participa-
tion of the employee health and safety representative during
inspections and evaluations should be addressed in the
HASP.
Imminent Danger
Whenever, and as soon as the RPM (or any other
party) is made aware of a danger which could reasonably be
expected to cause death or serious physical harm, that
person has the responsibility to IMMEDIATELY notify the
affected employees, and parties with the responsibility and
authority to remove the danger. In situations where an
imminent danger exists, both the prime contractor's site
coordinator and the construction manager's on-site repre-
sentative (or equivalent) have the responsibility and
-------
authority to stop all activities or withdraw employees. The
RPM does NOT shut down or remove personnel from
unsafe operations, but recommends action for decisions by
lead agency officials. If steps are not taken to remove the
danger, OSHA shaJl be consulted.
Other Unsafe or Unhealthful Working
Conditions
For Federal-lead RA projects, health and safety
inquiries should be channeled through the construction
manager, who has the responsibility to notify the site
coordinator verbally and in writing of the unsafe or
unheaJthful condition. For other than Federal-lead
projects, the RPM should notify the site coordinator (or
responsible party) verbally and in writing of unsafe or un-
healthful working conditions. IF NOT SATISFIED
WITH THE CORRECTIVE ACTION TAKEN, THE
RPM SHOULD CONSULT WITH THE REGIONAL
SAFETY AND HEALTH OFFICER, THE ENVIRON-
MENTAL RESPONSE TEAM (ERT) ((908) 321-6740)
OR THE HEADQUARTERS HAZARDOUS SITE
CONTROL DIVISION (HSCD) ((703) 308-8393) PRIOR
TO SEEKING INTERVENTION FROM OSHA.
OSHA STANDARDS
OSHA Standards are found in Title 29 of the Code
of Federal regulations (29 CFR). Two parts must be
followed during remediation activities: Pan 1910,
General Industry Standards and Part 1926, Construction
Standards. The interpretation as to which parts of Title 29
apply to a particular activity is often complex. EPA Stan-
dard Operating Safely Guides (and US ACE regulations for
USAGE managed projects) supplement OSHA regulations.
If a conflict arises, the more protective standard should be
applied to a particular operation.
Worker Protection
OSHA's Worker Protection Standard for Hazardous
Waste Operations and Emergency Response, 29 CFR
1910.120, will have the most applicability to remediation
activities. Guidance on interpretation of the Standard can
be found in ERT Fact Sheets. Compliance with the
standard should be addressed in the preliminary assess-
ment/site inspection stage, during the remedial investiga-
tion/feasibility study stage, and through the remedial
design and remedial action. The delineation of a site into
work zones where the worker protection standard applies
should be addressed in the remedial design site HASP. In
situations where competent health and safety professionals
lack sufficient information to conclude that occupational
exposure will be well within limits considered acceptable,
a protective interpretation of the standard is recommended
(However, overprotection, as well as underprotection can
be hazardous and should be avoided wherever possible).
6
Hazard Communication
The OSHA hazard communication standard(s), 29
CFR 1926.59 for construction and 1910.1200 for general
industry, require that all hazardous chemicals on a site be
identified. Every potentially exposed worker must be
given hazard communication training at the time of initial
work assignment and each time a new hazard is intro-
duced into a work area. Material Safety Data Sheets
(MSDS) must be available for all hazardous materials
brought onto the site except hazardous wastes, as defined
by the Resource Conservation and Recovery Act (RCRA),
which are exempt. Training centers around information
contained in the MSDS. Similar requirements are con-
tained in the worker protection standard, 29 CFR
1910.120, which requires a worker risk assessment for
hazardous materials found on-sile. Problem areas com-
monly encountered include the lack of access to and the
quality of information in Material Safety Data Sheets
(MSDS).
ROLES AND RESPONSIBILITIES
The basic health and safety responsibilities of the
various parties involved in the RD and RA phases of work
at Superfund sites follow:
Remedial Design
The remedial design contractor is responsible for the
development and implementation of a HASP for all on-
site RD activities; for the development of specifications
for the remedial action site health and safety plan; and for
the description of minimum requirements for health,
safety, and emergency response. The following should be
specified in the final design:
1. An estimate of increased hazards (over back-
ground).
2. The degree of existing hazard based on contami-
nation identified in the site characterization
report, on the Agency for Toxic Substances and
Disease Registry (ATSDR) Health Assessment,
and on the short term effects component of the
feasibility study.
3. Minimal acceptable standards for
-Worker protection
-The general public
-Monitoring, reporting and interpretation (what
constitutes acceptable concentration)
-Emergency response and evacuation
-Site control; decontamination of personnel and
equipment; clean-up procedures
During the design phase, it is the responsibility of
the designer to establish site boundaries where 29 CFR
-------
1910. 120 applies and to describe criteria utilized in such
determinations. These boundaries should be reviewed and
approved by a qualified health and safety professional
such as a certified industrial hygienist, certified health
physicist, etc.
Remedial Action
OSHA, or its State counterpart, has Occupational
Safety and Health Act enforcement authority at RA sites.
In addition to complying with Federal standards, the prime
contractor must also comply with contractual health and
safety policies and guidelines from EPA. For Alternative
Remedial Contract Strategy (ARCS), the U.S. Army Corps
of Engineers (USAGE), and the U.S. Bureau of Reclama-
tion (BUREC) managed projects, health and safety
enforcement responsibilities under the contract are dele-
gated to the construction manager's resident inspector (or
equivalent position). For State lead projects these respon-
sibilities are delegated to the State's on-site official; and
for Potentially Responsible Party (PRP) projects, health
and safety enforcement is the responsibility of EPA 's
oversight official. The resident inspector must be
certified to be on site (i.e. have a medical examination,
training, experience, etc.), conduct health and safety
inspections and evaluations of contractor compliance with
the health and safety contract provisions, and possess a
complete understanding of the contract
Implementation of the health and safety program is
the responsibility of the prime contractor. The State's on-
site official or the PRP oversight official is responsible for
health and safety during the implementation of the operation
and maintenance phase.
HEALTH & SAFETY PROGRAM
OVERSIGHT
RPM Responsibilities
As the EPA's prime contact or representative for a
site, it is important for the RPM to be a strong health and
safety advocate. The RPM has the responsibility to coordi-
nate, direct, and review the work of EPA contractors
responsible parties and other agencies to assure compliance
with the National Contingency Plan. As such the RPM
oversees compliance with occupational health and safety
programs. The RPM normally does not have direct line
authority over the RA prime contractor but recommends
action through the lead agency or PRPs. The RPM will be
informed of situations where health and safety issues impact
overall project cost, scheduling, technical quality or public
health/environmental protection. However, the RPM's
primary responsibility is oversight, not action. Items
requiring action should be referred to the appropriate indi-
viduals or agencies (Prime contractor, USAGE, BUREC,
ARCS, Responsible Party, the State, or OSHA).
SOURCES OF INFORMATION
For questions about OSHA regulations or EPA/
OSHA relationships, how to contact Regional or Federal
OSHA representatives, and/or HASP computer software
package, contact:
Rod Turpin
USEPA Environmental Response Team
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or FTS 340-6740
For OSHA publications contact:
U.S. Department of Labor - OSHA
Publications Office, Room N3101
200 Constitution Avenue N.W.
Washington, D.C. 202 10
(202) 523-9667
For questions pertaining to health and safety during
remedial design/remedial action, contact:
Joe Cocalis
USEPA Hazardous Site Control Division
Design and Construction Management Branch
Mailstop OS-220W
40 1 M. Street SW
Washington, D.C. 20460
(703) 308-8356 or FTS 398-8356
7
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SOURCES OF INFORMATION
(continued)
For information pertaining to health and safety training contact ERT or the National Institute for Environmental
Health Sciences Training Grant Clearinghouse:
USEPA ERT
26 West Martin Luther King
Cincinnati, OH 45268
(513)569-7537
or
National Clearinghouse on Occupational & Environmental Health
c/o Workplace Health Fund
815 16th Street, N.W. Suite 301
Washington, D.C. 20006
(202) 842-7833
BIBLIOGRAPHY
29 CFR 1910, OSHA General Industry Standards
(1) 1910.120 Hazardous Waste Operations and Emergency Response
(2) 1910.134 Respiratory Protection
(3) 1910.1200 Hazard Communication
29 CFR 1926, OSHA Construction Industry Standards
OSWER Directive 9285-01, Health and Safely Plan (HASP), June 1989.
ERT Fact Sheets
A. Hazardous Waste Operations and Emergency Response: General Information and Compari-
son (#9285.2 - 09fs)
B. Establishing Work Zones at Uncontrolled Hazardous Waste Sites (#9285.2 - 06fs)
C. Hazardous Waste Operations and Emergency Response: Uncontrolled Hazardous Waste Sites
and RCRA Corrective Action (#9285.2 - 08fs)
D. Hazardous Waste Operations and Emergency Response: RCRA TSD and Emergency
Response Without Regard to Location (#9285.2 - 07fs)
E. Hazardous Waste Operations and Emergency Response: Available Guidance (#9285.2-10fs)
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SECTION 3
QUICK REFERENCE FACT SHEETS
PART 2
ESTABLISHING WORK ZONES
AT UNCONTROLLED HAZARDOUS WASTE SITES
-------
o-EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9285.2-06FS
April 1991
Establishing Work Zones at
Uncontrolled Hazardous
Waste Sites
Office of Emergency and Remedial Response
Emergency Response Division MS-101
Quick Reference Fact Sheet
Under the authority of section 126 of the
Superfund Amendments and Reauthonzation Act
of 1986 (SARA), the U.S. Environmental
Protection Agency (EPA) and the U.S.
Occupational Safety and Health Administration
(OSHA) promulgated identical health and safety
standards to protect workers engaged in hazardous
waste operations and emergency response. The
OSHA regulations became effective on
March 6, 1990 and are codified at 29 CFR
1910.120 (54 FR 9294, March 6, 1989); the EPA
regulations also became fully effective on March 6,
1990 and are codified at 40 CFR 311 (54 FR
26654, June 23, 1989). The EPA regulations
incorporate the OSHA standards by reference.
Although the two sets of standards contain
identical substantive provisions, EPA and OSHA
address different audiences. In states without an
OSHA-approved program, federal OSHA
standards protect all private and federal employees
engaged in hazardous waste operations and
emergency response; the EPA worker protection
standards protect all state and local government
employees. In states with an OSHA-approved
program, the state program covers all private,
state, and local government employees; OSHA
covers federal employees in those states. Another
Fact Sheet, Hazardous Waste Operations and
Emergency Response: Uncontrolled Hazardous
Waste Sites and RCRA Corrective Action (OSWER
Publication No. 9285.2-08FS), provides a general
overview of the worker protection standards as
they apply to operations conducted at uncontrolled
hazardous waste sites.
The purpose of this Fact Sheet is to
summarize the procedures and requirements for
establishing and maintaining work zones, including
Support Zones, at hazardous waste sites. This
Fact Sheet is divided into five parts. The first
provides definitions for the work zones that are
commonly designated at hazardous waste sites.
The second describes the data collection
requirements for the initial site characterization.
Part 3 discusses evaluation of site data and other
considerations in work zone selection. Part 4
describes methods for ensuring the integrity of
Support Zones during remedial or removal actions.
The final part of this Fact Sheet provides
additional references and contacts for further
information.
PART 1: INTRODUCTION TO WORK ZONES
The worker protection standards at 29 CFR
I910.120(b) require that employers with employees
engaged in hazardous waste operations at
uncontrolled hazardous-waste sites develop and
implement a written health and safety program for
their employees. The purpose of this program is
to identify, evaluate, and control safety and health
hazards, and provide for emergency response
during hazardous waste operations. As part of the
overall health and safety program, 29 CFR
I910.120(d) specifies that appropriate site control
procedures must be implemented before clean-up
work begins, to minimize employee exposure to
hazardous substances. One of the basic elements
of a site control program is the delineation of
work zones. 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.
11
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EXHIBIT 1
Illustration of Typical Work Zones
Exclusion
Zone
Estimated Boundary
Of Area With Highest
Contamination
Access
Control Points
Contamination
Reduction Corridor
Contamination
Reduction Zone
Command Post
Contamination
Control Line
Prevailing wind direction
I Support Zone I
Note: Area dimensions not to scale. Distances between points may vary.
EPA's Standard Operating Safety Guides
describes the process for establishing and
maintaining work zones. 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, the Contamination
Reduction Zone (CRZ), and the Support Zone.
The purpose of establishing the zones is to (1)
reduce the accidental spread of hazardous
substances by workers or equipment from the
contaminated areas to the clean areas; (2) confine
work activities to the appropriate areas, thereby
minimizing the likelihood of accidental exposure;
and (3) facilitate the location and evacuation of
personnel in case of an emergency. Movement of
personnel and equipment among these zones is
minimized and restricted to specific access control
points to prevent cross-contamination from
contaminated areas to clean areas. A
representation of the three most commonly
designated work zones is found in Exhibit I. A
description of each zone is provided below.
Exclusion Zone
The Exclusion Zone is the area where
contamination does or could occur and the greatest
potential for exposure exists. In order to separate
the Exclusion Zone from the rest of the site, the
outer boundary of the Exclusion Zone, known as
the Hotline, should be clearly marked. Access of
personnel and equipment to and from the
Exclusion Zone should be restricted by access
control points on the zone's periphery. All persons
who enter the Exclusion Zone should wear the
appropriate level of personal protective equipment
(PPE) for the degree and types of hazards at the site.
12
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The Exclusion Zone also may be subdivided
into different areas of contamination, based on the
known or expected type and degree of hazard or
the incompatibility of waste streams. If the
Exclusion Zone is subdivided in this manner,
additional demarcations and access control points
may be necessary.
Contamination Reduction Zone
As the transition area between the
contaminated area and the clean area, the CRZ is
the area in which decontamination procedures take
place. This zone is designed to reduce the
probability that the Support Zone will become
contaminated or affected by other site hazards.
Due to 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.
Support Zone
The Support Zone is defined as the
uncontaminated area where workers should not be
exposed to hazardous conditions. Any potentially
contaminated clothing, equipment, and samples
must remain outside of the Support Zone until
decontaminated. 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 for authorized
site personnel. Such personnel, however, should
receive instruction in the proper evacuation
procedures in case of a hazardous substance
emergency.
PART 2: SITE CHARACTERIZATION -- DATA
COLLECTION
To establish a Support Zone, the specific
hazards and the degree of potential employee
exposure at the site must be considered. The site
characterization, as specified in 29 CFR
1910.120(c), is the basis for developing the site
health and safety plan (HASP), and provides
information needed to identify site hazards, select
proper PPE, and implement safe work practices.
Site characterization generally proceeds in three phases:
• Prior to site entry, an off-site
characterization, including data gathering
and perimeter reconnaissance.
• An on-site survey.
• Ongoing monitoring to provide a
continuous source of information about
site conditions.
Off-site characterization and the on-site survey
are discussed below. Ongoing monitoring is
discussed in Part 4 of this Fact Sheet, Ensuring
Integrity of Work Zones.
Data-Gathering Prior to Initial Site Entry
The initial stages of site characterization must
be accomplished off-site, so as not to endanger the
health and safety of workers. For example, at new
uncontrolled hazardous sites, or at those sites with
areas that have not been evaluated, the range of
potential hazards and exposure risks is unknown.
As much information as possible should be
obtained during off-site characterization to
evaluate the hazards and institute preliminary
controls for protecting initial entry personnel.
Once the off-site characterization is completed and
the appropriate information is obtained, the
information is used to develop an initial draft of
the site-specific HASP. (For more information on
developing a HASP, refer to the fact sheet
Hazardous Waste Operations and Emergency
Response: Uncontrolled Hazardous Waste Sites and
RCRA Corrective Action, OSWER Publication No.
92S5.2-08FS, 1991.)
29 CFR I910.120(c)(i) through (c)(viii)
identifies the generic information that must be
considered and evaluated before designated
personnel enter a site. These requirements are
listed in Exhibit 2, along with resources that can
be useful for obtaining the required information.
These information sources include general
background documents (e.g., area maps), site
records, interviews with persons who have
knowledge about the site, and perimeter
reconnaissance.
Interview/Records Research. Records of the
site or interviews with persons who have
knowledge of the site can provide useful
information about the potential hazards at a site.
13
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EXHIBIT 2
Information Required Prior to Site Entry
29 CFR 1910.120(c)(4)
Regulatory Requirements:
Location, Size of Site (c)(4)(i)
Description of Job or Activity
to be Performed (c)(4)(ii)
Activity Duration (c)(4)(in)
Site Topography and
Accessibility (c)(4)(iv)
Safety and Health Hazards at
Site (c)(4)(v)
Pathways for Hazardous
Substance Dispersion
(c)(4)(vi)
Status of Response Teams
(c)(4)(vii)
Hazardous Substances and
Health Hazards (c)(4)(vin)
Sources of Information
General
Background
References
/
/
S
/
Records/Interviews
Site-Specific
/
/
/
/
/
Interviews
/
/
Perimeter Reconnaissance
Visual
/
/
/
/
S
Sampling
/
/
/
/
/
Site
Manager
Assessment
S
s
/
Examples of records that may be useful are found
in Exhibit 3.
Perimeter Reconnaissance. In addition to the
interview/records research, data-gathering at the
site perimeter may help in identifying site hazards
and determining the appropriate level of PPE for
the initial site entry. Many of the activities that
occur during perimeter reconnaissance, including
making visual observations, monitoring
atmospheric concentrations of airborne pollutants,
and collecting soil samples, are similar to the
activities that occur during the initial site entry.
Perimeter reconnaissance activities, however, are
generally not as extensive or specific as the
activities undertaken during the on-site survey. To
determine the scope and level of effort for the
perimeter reconnaissance, the information from
the interview/records research should be evaluated.
Historical data on chemicals stored at the site, for
example, may help to identify the appropriate air
monitoring techniques for the perimeter
reconnaissance.
Initial Site Entry and Data Collection
The goal of the on-site survey is to gather the
additional information needed to identify the risks
and hazards presented by the site, so that the work
zones can be established and the appropriate
controls, PPE, and medical monitoring program
can be selected for the tasks that will be performed
at the site. Risks that should be considered are
specified in 29 CFR Part 1910.120 (c)(7) and are
listed in Exhibit 4.
Immediately upon entering the site, entry
personnel should monitor the air for immediately
dangerous to life and health (IDLH) and other
conditions that may cause death or serious harm
(e.g., combustible or explosive atmospheres, oxygen
deficiency, toxic substances) and monitor for
ionizing radiation. In addition, entry personnel
should visually observe for signs of actual or
potential IDLH hazards or other dangerous
conditions. Exhibit 5 provides examples of visible
indicators of potential IDLH hazards and other
dangerous conditions.
14
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EXHIBIT 3
Sources of Site-Specific Information
Company records, receipts, logbooks, or
ledgers that describe the activity (hat
occurred at the site.
Waste storage inventories and manifests
or shipment papers
Records from state and federal pollution
control regulatory and enforcement
agencies, state Attorney General's Office,
state occupational safety and health
agencies, state Fire Marshal's office.
Water and sewage district records.
Previous survey, sampling, and monitoring
results.
Local fire and police department records.
Site and aerial photos.
Media reports (all information from the
media should be verified).
Interviews with personnel (all interview
information should be verified).
Interviews with nearby residents (note
possible site-related medical problems and
verify all information from interviews).
Maps (e.g, USGS, land use, etc.).
Meteorological data (e.g., wind direction,
temperature profiles).
If IDLH hazards or other dangerous conditions
are not present, or if proper precautions can be
taken, the survey can continue. At a minimum, the
initial on-site survey should consist of a visual survey
for potential hazards and air monitoring.
Visual Survey. An accurate and
comprehensive visual survey of the site will assist
in identifying potential hazards and determining
where additional information (e.g., air monitoring,
sampling of soil or containers) may be needed.
EXHIBIT 4
Risks to Consider
29 CFR 1910.120 (c)(7)
Risks to consider include, but are not limited
to:
Exposure exceeding the permissible
exposure limits (PELs) and published
exposure levels.
IDLH concentrations
• Potential skin absorption and irritation.
• Potential eye irritation.
• Explosion sensitivity and flammabiliry
ranges.
• Oxygen deficiency
EXHIBIT 5
Visible Indicators of
Potential IDLH and Other
Dangerous Conditions
Large containers or tanks that must be
entered.
Enclosed spaces such as buildings or
trenches that must be entered
Potentially explosive or flammable
situations (indicated by bulging drums,
effervescence, gas generation, or
instrument readings)
Extremely hazardous materials (such as
cyanide, phosgene, or radiation sources).
Visible vapor clouds.
Areas where biological indicators (such as
dead animals or vegetation) are located.
15
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This visual survey should include the following
activities:
• Noting the types of containers,
impoundments, or other storage systems
(e.g., paper or wood packages, barrels or
drums, tanks, lagoons).
• Noting the condition of waste containers
and storage systems (e.g., undamaged,
rusted or corroded, leaking).
• Noting the types and quantities of
material in containers (e.g., full or empty;
labels indicating corrosive, explosive,
flammable, radioactive, or toxic materials).
• Noting the physical condition of the
materials (e.g., solid, liquid, or gas;
conditions conducive to contact).
• Noting any unusual conditions (e.g.,
clouds, discolored liquids, oil slicks,
discolored soil, free-standing liquid,
stressed vegetation).
• Determining the potential pathways of
exposure and dispersion (e.g., air, soil,
surface water, ground water).
• Noting any indicators of potential
exposure to hazardous substances (e.g.,
dead fish, animals, or vegetation; pools of
liquids; foams or oils on liquid surfaces;
deteriorating containers; discolored soils).
• Identifying natural wind barriers (e.g.,
buildings, hills, tanks).
The results of the visual survey may help to
identify a potential location for the Support Zone,
which can be confirmed through air monitoring
and soil sampling.
Air Monitoring. The purpose of air
monitoring is to identify and quantify airborne
contaminants in order to determine the level of
worker protection and identify additional medical
monitoring needs in any given area of the site. Air
monitoring should be used to confirm that the
areas considered for the Support Zone do not
contain concentrations of hazardous substances
that require worker protection. The two methods
that generally are available for identifying and/or
quantifying airborne contaminants are (1) on-site
use of direct-reading instruments and
(2) laboratory analysis of air samples obtained by
gas sampling bag, filter, sorbent, or wet-
contaminant collection methods.
Direct-reading instruments may be used to
rapidly detect flammable or explosive atmospheres,
oxygen deficiency, certain gases and vapors, and
ionizing radiation, as well as to identify changing
site conditions. Because direct-reading instruments
provide information at the time of sampling and
allow for rapid decision-making, they are the
primary tools of initial site characterization. All
direct-reading instruments, however, have inherent
constraints in their ability to detect hazards.
Direct-reading instruments detect and/or measure
only specific classes of chemicals and are usually
not designed to detect airborne concentrations
below 1 ppm. In addition, many of the direct-
reading instruments that have been designed to
detect one particular substance also detect other
substances and, consequently, may give false
readings. Direct-reading instruments must be
operated, and their data interpreted, by qualified
individuals using properly calibrated instruments and
refying on chemical response curves. Additional
monitoring should be conducted at any location
where a positive instrument response occurs.
Exhibit 6 lists several direct-reading
instruments and the conditions and/or substances
they measure. Additional information concerning
direct-reading instruments is available in the
references.
Because direct-reading instruments 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, air samples must
also be collected and analyzed in a laboratory.
Exhibit 7 lists some sample collection and
analytical methods that are appropriate for certain
types of substances that are likely to be
encountered at hazardous waste sites. Additional
information concerning air sampling and
monitoring is available in the references listed in
Part 5 of this Fact Sheet.
Other Information. At some sites, air
monitoring, the visual survey, and consideration of
activities that will be occurring at the site will be
16
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EXHIBIT 6
Some Direct-reading
Air Monitoring Instruments
Instrument
Hazard Monitored
Combustible Gas
Indicator (CGI)
Flame lonization
Detector (FID)
with Gas Chromo-
tography Option
Gamma Radiation
Survey Instrument
Portable Infrared
(IR) Spectro-
photomeier
Ultraviolet (UV)
Photoionization
Detector (PID)
Direct-reading
Colorimetnc
Indicator Tube
Oxygen Meter
Combustible gases
and vapors
Many organic gases
and vapors
Gamma radiation
Many gases and
vapors
Many organic and
some inorganic
gases and vapors
Specific gases and
vapors
Oxygen (O2)
adequate to determine the appropriate level of
PPE, to establish additional medical monitoring
needs, and-to define work zones. For many sites,
however, consideration of planned site activities
may reveal the need for more extensive
environmental sampling. Analysis of surface soil
and soil borings may be required if site workers are
expected to be exposed to surface and subsurface
soil that may be contaminated. Ground water or
surface water sampling may be necessary if site
workers are likely to be exposed via these media.
To determine whether additional monitoring is
required to designate work zones, the results of the
air monitoring survey and visual characterization of
site hazards and contaminants should be reviewed
and potential pathways of contaminant dispersion
should be evaluated. If there is any question that
contaminants may have migrated into the area
EXHIBIT 7
Some Air Sampling
Collection Methods
Substance
Collection Device
Anions:
Bromide
Chloride
Fluoride
Nitrate
Phosphate
Sulfate
Aliphatic or
aromatic amines
Asbestos
Metals
Particulates
High MW
hydrocarbons
Organophosphorus
compounds
Selected pesticides
Organics
PCBs
Pesticides
Frew-ashed silica
gel tube
Silica gel
Mixed cellulose
ester filter
(MCEF)
Tenax/Chromosorb
Charcoal tube
Glass fiber filter
and flonsil tube
13mm glass fiber
filter/chromosorb
102 tube
PUF/filter
considered for the Support Zone, both air and
surface soil samples should be collected and
compared with on-site and off-site background
samples.
Soil sampling can be simple or complex,
depending on site conditions. Sampling plan
designs routinely fall into the following categories:
judgmental random, stratified random, systematic,
and search. Prior to beginning any sampling
activities, it is imperative that the purpose of the
effort and ultimate use of the acquired data be
established. Strategies should be selected based on
the information required. Certain target
17
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contaminants may warrant special considerations.
For example, when sampling for the extent of
contamination of a dioxin site, tiered sampling and
designed grid-laying approaches should be
considered to achieve the 95 percent confidence
level. Additional information concerning soil
sampling is available in the references listed in
Part 5 of this Fact Sheet.
PART 3: SITE CHARACTERIZATION --
SELECTION OF WORK ZONES
After the off-site and on-site data collection
are complete, the collected information is used to
establish work zones. In addition, the HASP is
revised to address the specific on-siie hazards.
Data Compilation
All of the information should be compiled in
a format that facilitates a decision concerning the
placement of work zones. A site map can provide
a useful format for compiling the collected data.
The locations of all the potential hazards that were
identified through the interview/records research,
the perimeter reconnaissance, and the initial on-
site survey should be plotted on the map. The
map should indicate both the hazards that were
observed and any areas that interviews or records
suggest may be contaminated with hazardous
wastes. In addition, all sampling results from the
on-site and off-site surveys should be plotted on
the map. It is important to record locations where
hazardous substances were detected and locations
where hazardous substances were not detected.
The absence of sampling results should not be
considered evidence that an area is clean.
Information concerning exposure pathways,
particularly the predominant wind direction, also
should be included on the map.
Data Evaluation
After all available site characterization data
have been compiled, the data are used to select a
location for the Support Zone. One of the most
important criteria for selection of an area for the
Support Zone is that it must be located in a clean
area. 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. When evaluating on-site
concentrations of hazardous substances, it is
important to consider the background
concentrations of these substances in the area.
Non-zero background concentrations of hazardous
substances may be present at some sites.
SUPPORT
ZONE
MUST
BE
CLEAN 1
Other Considerations
The size and position of the Support Zone
also 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 in
the Exclusion Zone. In addition, the Support
Zone should, whenever possible, be upwind from
the Exclusion Zone. The Support Zone should be
located as far from the Exclusion Zone as
practicable. Whenever possible, line-of-sight
contact with all activities in the Exclusion Zone
should be maintained. Accessibility to support
services (e.g., power lines, access roads, telephones,
shelter, and water) also must be considered in
selecting a Support Zone. The expected duration
of the removal action also will affect the placement
of work zones.
It is also conceivable that the Support Zone
may inadvertently become contaminated after site
remediation begins, despite everyone's best efforts.
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. The integrity of the Support Zone
should be reconfirmed during remedial activities.
PART 4:
ZONES
ENSURING INTEGRITY OF WORK
Several procedures can be used to ensure that
the area chosen for the Support Zone remains
clean during removal or remedial operations. 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.
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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 boundary between the Support
Zone and the CRZ, called the contamination
control line, separates the Support Zone from an
area of possible low contamination. Access to the
CRZ from the Support Zone should be through
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 degree and types of hazards
they may encounter when working in this area. To
reenter the Support Zone from the CRZ, workers
should remove gross contamination, doff 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 change.
Situations where additional monitoring may be
appropriate are specified in 29 CFR 1910.120
(h)(3) and are listed in Exhibit 8. 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. In addition, site personnel
should be constantly alert to changes in site
conditions or the presence of any potentially
dangerous situations. Exhibit 9 lists the
monitoring and sampling activities that may be
conducted to ensure that the Support Zone
remains clean.
Considering Additional Site Characterization
Information
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
EXHIBIT 8
Conducting Additional Monitoring
29 CFR 1910.120 (h)(3)
Situations that require consideration of the
possibility that exposures have risen are:
• 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 is
initiated (e.g., drum opening as opposed to
exploratory well drilling).
• When employees are handling leaking
drums or containers or working in areas
with obvious liquid contamination (e.g., a
spill or lagoon).
sampling will occur during the site inspection (SI)
and remedial investigation (RI). This additional
information may indicate that areas initially
considered clean are, in fact, contaminated. The
location of the Support Zone should be
reevaluated whenever new site characterization
studies are conducted.
EXHIBIT 9
Periodic Support Zone
Monitoring Activities
Air monitoring using direct-reading
instruments.
Collecting air samples for paniculate, gas,
or vapor analysis.
Analysis of soil samples from heavily
trafficked areas.
Occasional swipe tests in trailers and other
areas used by personnel.
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PART 5: CONSULTATION AND REFERENCES
For more information regarding work zones,
the following references may be consulted.
Federal Regulations
• OSHA Regulations (particularly 29 CFR
1910 and 1926)
• EPA Regulation 40 CFR 311
Guidance Documents
The following publications explain site
operating procedures and guidelines, including
safety procedures for decontamination,
considerations for establishing work zones, and
sampling and monitoring programs:
• EPA Standard Operating Safety Guides',
U.S. Environmental Protection Agency,
Office of Emergency and Remedial
Response, Environmental Response Team,
OSWER Directive 9285.1-01C, 1988.
• Field Standard Operating Procedures for
Establishing Work Zones F.S.O.P. 6; U.S.
Environmental Protection Agency, Office
of Emergency and Remedial Response,
OSWER Directive 9285.2-04, 1985.
• Field Standard Operating Procedures for Air
Surveillance F.S.O.P- 8; U.S.
Environmental Protection Agency, Office
of Emergency and Remedial Response,
OSWER Directive 9285.2-03, 1985.
• Environmental Response Team (ERT)
Standard Operating Procedures, Soil
Sampling SOP # 2012, U.S.
Environmental Protection Agency,
Environmental Response Team, 1988.
• Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities',
NIOSH/OSHA/USCG/EPA, DHH'S
(NIOSH) Publication Number 85-115,
GPO No. 017-033-00419-6, 1985.
The following publication provides step-by-step
guidance for assessing preliminary evaluations,
health and safety plans, and off-site emergency
response plans:
• EPA Health and Safety Audit Guidelines;
U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency
Response, Emergency Response Division,
EPA-540/G-89/010, OSWER Directive
9285.8-02, 1989.
The following publications provide general
information concerning the development of a
specific health and safety program for workers at
hazardous waste sites:
• EPA Standard Operating Safety Guides;
U.S. Environmental Protection Agency,
Office of Emergency and Remedial
Response, Environmental ResponseTeam,
OSWER Directive 9285.1-01C, 1988.
• Field Standard Operating Procedures for
Site Safety' Plan F.S.O.P. 9, U.S.
Environmental Protection Agency, Office
of Emergency and Remedial Response,
OSWER Directive 9285.2-05, 1985.
• Generic Site Safety Plan; U.S.
Environmental Protection Agency,
OSWER Directive 9285.8-01.
• Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities;
NIOSH/OSHA/USCG/EPA, DHHS
(NIOSH) Publication Number 85-115,
GPO No. 017-033-00419-6, 1985.
The following two volumes entitled
Characterization of Hazardous Waste Sites - A
Methods Manual address issues related to
characterization of hazardous waste sites, from
preliminary data gathering to sampling and
analysis:
• Volume I - Site Investigations; U.S.
Environmental Protection Agency, Office
of Research and Development,
Environmental Monitoring Systems
Laboratory, Las Vegas, NV, EPA-
600/4-84/075, 1985.
• Volume II - Available Sampling Methods,
Second Edition; U.S. Environmental
Protection Agency, Office of Research and
Development, Environmental Monitoring
Systems Laboratory, Las Vegas, NV, EPA-
600/4-84/076, 1984.
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The following publication provides information
on sampling design and associated statistical
methods for determining contaminant
concentrations:
• Methods for Evaluating the Attainment of
Cleanup Standards, Volume I: Soil and
Solid Media; U.S. Environmental
Protection Agency, Office of Policy,
Planning, and Evaluation, EPA-
230/02-89-042, 1989.
The following publication provides guidance
for using portable instruments for assessing
airborne pollutants arising from hazardous waste:
• Draft International Document on Guide to
Portable Instruments for Assessing Airborne
Pollutants Arising from Hazardous Wastes;
U.S. National Working Group (NWG-4
OIML) Pilot Secretariat PS-17:
"Measurement of Pollution" Reporting
Secretariat RS-5- "Measurement of
Hazardous Waste Pollution." ISBN: 0-
936712-75-9.
The following four volumes collectively
entitled Procedures for Conducting Air Pathway
Analyses for Superfund Applications address a
variety of issues relevant to the air impacts at
Superfund sites:
• Volume I: Application of Air Pathway
Analyses for Superfund Applications; U:S.
Environmental Protection Agency, EPA-
450/1-89-001, 1989. NTIS PB90
113374/AS.
• Volume II: Estimation of Baseline Air
Emissions at Superfund Sites; U.S.
Environmental Protection Agency, EPA-
450/1-89-002, 1989. NTIS PB89
180053/AS.
• Volume III: Estimation of Air Emissions
from Clean-up Activities at Superfund Sites;
U.S. Environmental Protection Agency,
EPA-450/1-89-003, 1989. NTIS PB89
18006 I/AS.
• Volume IV: Procedures for Dispersion
Modelling and Air Monitoring for Superfund
Air Pathway Analysis; U.S. Environmental
Protection Agency, EPA-450/1-89-004, 1989. NTIS
PB90 113382/AS.
Fact Sheets
The following fact sheet provides a summary of
the federal regulations at 29 CFR 1910.120 and 40
CFR 311, as they pertain to worker protection at
uncontrolled hazardous waste sites:
• Hazardous Waste Operations and
Emergency Response: Uncontrolled
Hazardous Waste Sites and RCRA
Corrective Action; U.S. Environmental
Protection Agency, Environmental
Response Team, OSWER Publication No.
9285.2-08FS, 1991.
The following fact sheet provides a list and
description of computer software, fact sheets,
guidance documents and ERT training programs
that pertain to the worker protection standards:
• Hazardous Waste Operations and
Emergency Response: Available Guidance;
U.S. Environmental Protection Agency,
Environmental Response Team, OSWER
Publication No. 9285.2-10FS, 1991.
Contact Persons or Groups
Several contact persons or groups can provide
additional information on the establishment of
work zones at uncontrolled hazardous waste sites.
These contacts include:
• U.S. EPA's Environmental Response Team
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or (FTS) 340-6740
• U.S. Department of Labor, OSHA
Office of Health Compliance Assistance
200 Constitution Avenue, NW
Washington, D.C. 20210
(202) 523-8036 or (FTS) 523-8036
In addition, addresses and telephone numbers
for EPA and OSHA regional offices are listed in
Exhibit 10.
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EXHIBIT 10
Regional Addresses and Telephone Numbers
EPA Regional Offices
• EPA Region 1
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3715 or (FTS) 835-3715
• EPA Region 2
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, NT 10278
(212) 264-2657 or (FTS) 264-2657
• EPA Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800 or (FTS) 597-9800
• EPA Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727 or (FTS) 257-4727
• EPA Region 5
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000 or (FTS) 353-2000
• EPA Region 6
1445 Ross Avenue, 9th Floor
Dallas, TX 75202
(214) 655-6444 or (FTS) 255-6444
• EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66115
(913) 551-7000 or (FTS) 276-7000
EPA Region 8
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1603 or (FTS) 293-1603
EPA Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322
• EPA Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-1200 or (FTS) 399-1200
OSHA Regional Offices
OSHA Region 1
133 Portland Street, 1st Floor
Boston, MA 02114
(617) 565-7164 or (FTS) 835-7164
OSHA Region 2
201 Varick Street, Room 670
New York, NY 10014
(212) 337-2325 or (FTS) 660-2378
• OSHA Region 3
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
(215) 596-1201 or (FTS) 596-1201
• OSHA Region 4
•1375 Peachtree Street, NE, Suite 587
Atlanta, GA 30367
(404) 347-3573 or (FTS) 257-3573
• OSHA Region 5
230 South Dearborn Street
32nd Floor, Room 3244
Chicago, IL 60604
(312) 353-2220 or (FTS) 353-2220
• OSHA Region 6
525 Griffin Street, Room 602
Dallas, TX 75202
(214) 767-4731 or (FTS) 729-4731
• OSHA Region 7
911 Walnut Street
Kansas City, MO 64106
(816) 426-5861 or (FTS) 867-5861
OSHA Region 8
1951 Stout Street
Denver, CO 80204
(303) 844-3061 or (FTS) 564-3061
• OSHA Region 9
71 Stevenson Street, Suite 415
San Francisco, CA 94105
(415) 744-6670 or (FTS) 484-6670
• OSHA Region 10
1111 Third Avenue, Suite 715
Seattle, WA 98101-3212
(206) 442-5930 or (FTS) 399-5930
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SECTION 3
QUICK REFERENCE FACT SHEETS
PART 3
HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
RCRA TSD AND EMERGENCY RESPONSE WITHOUT
REGARD TO LOCATION
23
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&EPA
United Slates
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9285 2-07FS
April 1991
Hazardous Waste Operations
and Emergency Response:
RCRA TSD and Emergency Response
Without Regard to Location
Office of Emergency and Remedial Response
Emergency Response Division MS-101
Quick Reference Fact Sheet
INTRODUCTION
Under the authority of section
126 of the Superfund Amend-
ments and Reauthorization Act
of 1986 (SARA), the U.S.
Environmental Protection
Agency (EPA) and the U.S.
Occupational Safety and
Health Administration (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,
published originally on June 23, 1989 at 54 FR
26654, incorporate the OSHA standards by
reference and are codified at 40 CFR 311.
Although the EPA and OSHA worker
protection standards for hazardous waste
operations and emergency response
(HAZWOPER) contain identical substantive
provisions, the regulations differ with respect to
the scope of coverage. The OSHA standards apply
directly to private employees and 10 federal
employees through Executive Order 12196. OSHA
has no authority to enforce regulations protecting
state and local government employees. However,
under section 18(b) of the OSH Act, a state may
elect to develop and implement its • own
occupational safety and health program. This
program must be at least as effective as the federal
OSHA standards and must be reviewed and
approved by OSHA prior to implementation of the
plan. Through its review and approval authority,
OSHA requires states to extend occupational
safety and health protection to all state and local
government employees, as well as to private
employees, within the state's jurisdiction.
EPA's authority extends to state and local
government employees conducting hazardous waste
operations and emergency response in states that
do not have in effect a delegated OSHA program.
The EPA regulations also cover both compensated
and uncompensated workers. Therefore, the EPA
standards protect volunteers, such as fire fighters.
Although federal OSHA recommends that states
with delegated programs define "employee" to
include both compensated and uncompensated
workers, not all states have followed this
recommendation.
Despite the fact that the EPA and OSHA
regulations differ in their scope of coverage, both
regulations apply to three primary groups of
workers: (1) employees engaged in emergency
response without regard to location; (2) employees
engaged in routine hazardous waste operations at
treatment, storage, and disposal (TSD) facilities
regulated under the'Resource Conservation and
Recovery Act (RCRA); and (3) employees engaged
in mandatory or voluntary clean-ups at
uncontrolled hazardous waste sites, including
corrective actions at RCRA TSD facilities. The
standards, however, do not cover those employees
who will not be exposed to, or who do not have
the potential to be exposed to, hazardous
substances.
The purpose of this Fact Sheet is to explain
the principle requirements of the EPA and OSHA
worker protection standards as they apply to
employees who perform emergency response
operations irrespective of location and employees
who perform hazardous waste operations at RCRA
TSD facilities. Requirements that apply at
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uncontrolled hazardous waste sites are addressed in
a Fact Sheet entitled "Hazardous Waste
Operations and Emergency Response:
Uncontrolled Hazardous Waste Sites and RCRA
Corrective Action" Publication No. 9285.2-08FS.
This Fact Sheet is divided into three parts.
The first two parts describe the planning, training,
and medical surveillance requirements as they
apply to emergency response activities without
regard to location and hazardous waste operations
at RCRA TSD facilities. The final part of this
Fact Sheet provides important addresses and
telephone numbers.
PART 1: Requirements
for Planning, Training,
and Medical Surveillance
for Emergency Response
Without Regard to
Location (29 CFR
1910.120(q))
This part of the Fact Sheet addresses the
requirements in 29 CFR 19l0.120(q) that apply to
emergency responders who respond to hazardous
waste emergencies wherever they may occur (i.e.,
without regard to location). Although there are
eleven required elements specified at 29 CFR
1910.120(q) for protecting workers who perform
emergency response operations without regard to
location, this Fact Sheet addresses only the
planning, training, and medical surveillance
requirements. For a complete list of the
requirements at 29 CFR 1910.120(q), refer to
Exhibit 1.
Overview of Emergency
Response
An "emergency response" is
defined at 29 CFR
1910.120(a)(3) as a response
effort by employees from
outside the immediate release area or by other
responders, such as local fire fighters, to a,n
incident that results, or is likely to result, in an
uncontrolled release of a hazardous substance. A
response to an incidental release of a hazardous
substance that can be absorbed, neutralized, or
otherwise controlled by employees in the
immediate area or by maintenance personnel is not
considered an emergency response within the scope
of the standard.
EXHIBIT 1
Emergency Response Operations
Conducted without Regard to Location
(29 CFR 1910.120(q))
Emergency response plan
Elements of an emergency response
plan
Procedures for handling emergency
response
Skilled support personnel
Specialist employees
Material handling program
Training based on the duties and
functions performed by each level of
responder
Refresher training program
Medical surveillance and
consultation
Chemical protective equipment
clothing
Post-emergency response operations
The worker protection standards contain
several requirements that apply to workers engaged
in "emergency response." These requirements are
specified at 29 CFR 1910.120(1) for emergency
responders at uncontrolled hazardous waste sites;
29 CFR 1910.120(p)(8) for emergency responders
at RCRA TSD facilities; and 29 CFR 1910.120(q)
for employees who perform emergency response
operations irrespective of location.
The emergency response requirements at
(p) and (1) apply to site workers who will respond
to emergencies only at their specific work site; the
emergency response requirements at 29 CFR
1910.120(q) are specifically designed to protect
employees who respond to a variety of emergencies
at different locations with various extenuating
circumstances. This part of the Fact Sheet only
addresses the requirements specified at (q). These
requirements cover a variety of emergency
response workers, including public and private
HAZMAT teams, fire fighters, and police officers.
Examples of emergency response operations that
occur irrespective of location could include a fire
at a gas station; a transportation accident, such as
an overturned tractor trailer or a train derailment;
or a chemical spill at a fixed facility, such as a
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manufacturing plant or a pharmacy, where outside
assistance is needed to cleanup the spill.
Planning Requirements
Under 29 CFR 1910.120(q)(l),
employers must develop and
implement an emergency
response plan to handle
anticipated emergencies prior
to the commencement of emergency response
operations. In developing this plan, the employer
must take into account the variety of possible
emergencies that could occur within the employer's
jurisdiction. Exhibit 2 provides a comprehensive
list of the elements that must be addressed in the
emergency response plan. In addition to these
elements, the emergency response plan must
include the procedures for setting up an Incident
Command System (ICS) and identify the chain of
command that will be operative during an
emergency. For example:
• The senior response official responding to
an emergency will become the individual in
charge of a site-specific ICS. All emergency
responders and their communications must
be coordinated and controlled through the
individual in charge of the ICS. The
emergency response plan should address the
responsibilities of the individual in charge;
these responsibilities are specified at 29
CFR 1910.120(q)(3).
• The Safety Official, designated by and
accountable to the individual in charge of
the ICS, must be knowledgeable in the
operations being implemented at the
incident site and be able to identify and
evaluate hazards. The Safety Official also
has authority to alter, suspend, or terminate
activities at a site if it is determined that an
immediately dangerous to life or health
(IDLH) condition or imminent danger
condition exists.
In addition to the planning requirements
specified at 29 CFR 1910.120(q), there' are a
multitude of planning requirements specified under
SARA Title III that address emergency response
planning for a community. The goal of the Title
III planning requirements is to protect the public
in the event of an emergency involving an
extremely hazardous substance. Emergency
response organizations should incorporate the
EXHIBIT 2
Required Elements of an
Emergency Response Plan
(29 CFR I910.120(q)(2)
and (p)(8)(ii))
Pre-emergency planning and
coordination with outside parties.
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.
Personal protective equipment
(PPE) and emergency equipment.
local emergency response plan or the state
emergency response plan or both as part of their
emergency response plan to avoid any unnecessary
duplication of information. For additional
information on the SARA Title III planing
requirements, please contact the Title III Hotline
at (800) 535-7672, or (202) 475-9652 in the
Washington, D.C. metropolitan area.
Training Requirements
The purpose of the training
requirements for emergency
response personnel is to give
employees the knowledge and
skill to perform an emergency
response with minimal risk to their own health and
safety and the health and safety of others.
Employees who respond to emergencies may
become exposed to a hazardous substance. The
risks of exposure, however, will vary with each
response. As such, the amount and type of
training required under the worker protection
standards for employees who perform emergency
response operations is linked directly to an
employee's potential for exposure to hazardous
substances and to other health hazards during an
27
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emergency response. No employee may participate
in an emergency response activity unless they have
been adequately trained.
The specific training requirements for
employees who perform emergency response
operations without regard to location are specified
at 29 CFR 1910.120(q)(6). These training
requirements are based on "Levels" that are
generally recognized in the hazardous materials
response industry. There are five Levels of
emergency response personnel; each Level specifies
unique training requirements. The following is an
overview of the responsibilities of each Level of
responder and a brief summary of the training
requirements for that Level.
Level 1 Responders
(Awareness Level)
Must Have Sufficient Training
or Proven Experience
in Specific Competencies
Level 1. Level 1 Responders are most likely to
witness or discover a hazardous substance release
and to initiate an emergency response sequence by
notifying the proper authorities. Police officers
who do not actually respond to a release are good
examples of a Level 1 Responder, For example, a
Slate Trooper who responds to an overturned
truck carrying hazardous materials on a highway,
contacts the police dispatcher to report the
location and the type of accident, and uses his
patrol car to block lines of traffic, would be a
Level 1 Responder, so long as he does not try to
contain the release. The number of training hours
that a Level 1 Responder must receive is not
specified in the regulation. Level 1 Responders,
however, must have sufficient training or
experience to demonstrate competency in the
following areas:
• Understanding hazardous substances and
their risks;
• Understanding the implications of
hazardous substance emergencies;
• Recognizing the presence of hazardous
substances;
• Identifying hazardous substances;
• Understanding the first responder role; and
• Recognizing the need for additional
resources.
Level 2 Responders
(Operations Level)
Must Have Level I Competency,
plus a Minimum of 8 Hours of Training
to Demonstrate Specific Competencies
Level 2. Level 2 Responders are part of the initial
response to a release or potential release of
hazardous substances. Local police officers, fire
fighters, and rescue personnel, who try to contain
the effects of a release without necessarily stopping
it, are typical Level 2 Responders. Specifically, a
Level 2 Responder may assist with evacuation
proceedings, contain the release from a safe
distance, and prevent further exposures. Level 2
Responders must have Level 1 competency and a
minimum of 8 hours training or sufficient
experience to demonstrate competency in the
following areas:
• Understanding basic hazard and risk
assessment techniques;
• Selecting and using PPE;
• Understanding basic hazardous materials
terms;
• Performing basic control, containment,
and/or confinement operations;
• Implementing basic decontamination
procedures; and
• Understanding the relevant standard
operating procedures and termination
procedures.
Level 3 Responders
(HAZMAT Technicians)
Must Have a Minimum of 24 Hours
of Training at Leve! 2, plus
Sufficient Experience to Demonstrate
Specific Competencies
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Level 3. Level 3 Responders are Hazmat
Technicians responsible for attempting to stop the
release, as compared to a Level 2 responder who
attempts only to contain the release and contact
the appropriate authorities. Level 3 Responders
must have a minimum of 24 hours of training at
Level 2, and sufficient experience to demonstrate
competency in the following areas:
• Implementing the employer's emergency
response plan;
• Classifying, identifying, and verifying known
and unknown materials by using field survey
instruments and equipment;
• Functioning within an assigned role in the
Incident Command System;
• Selecting and using specialized chemical
PPE;
• Understanding hazard and risk assessment
techniques;
• Implementing advance control, con-
tainment, and/or confinement operations;
• Implementing decontamination procedures;
• Understanding termination procedures; and
• Understanding basic chemical and
lexicological terminology and behavior.
Level 4 Responders
(HAZMAT Specialists)
Must Have a Minimum of 24 Hours
of Training at Level 3, plus
Sufficient Experience to Demonstrate
Specific Competencies
Level 4. Level 4 Responders are Hazmat
Specialists. They respond with and provide
support to the Hazardous Materials Technipians
(Level 3). Level 4 Responders are expected to be
more knowledgeable about hazardous substances
than are Level 3 Responders. Hazmat Specialists
will sometimes act as liaisons with government
authorities, explaining site activities and associated
risks. Level 4 Responders must have a minimum
of 24 hours of training at Level 3, and sufficient
experience to demonstrate competency in the
following areas:
• Implementing the local emergency response
plan;
• Classifying, identifying, and verifying known
and unknown materials;
• Having knowledge of the state emergency
response plan;
• Selecting and using specialized chemical
PPE;
• Understanding in-depth hazard and risk
techniques;
• Performing specialized control, con-
tainment, and/or confinement operations;
• Determining and implementing
decontamination procedures;
• Developing a site safety and control plan;
and
• Understanding chemical, radiological, and
lexicological terminology and behavior.
Level 5 Responders
(On-Scene Incident Commanders)
Must Have a Minimum of 24 Hours
of Training at Level 2, plus
Sufficient Experience to Demonstrate
Specific Competencies
Level 5. The Level 5 Responder is the On-Scene
Incident Commander or Senior OIC. The Senior
OIC assumes control of the emergency response
incident scene. Senior OICs coordinate the
activities of all emergency responders and ensure
that open lines of communications exist between
them. The OIC is usually a generalist with broad
knowledge in managing emergency incidents.
Level 5 Responders must have a minimum of 24
hours of training at Level 2, and additional
corroetency in the following areas:
• Implementing the Incident Command
System;
29
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• Implementing the employer's emergency
response plan;
• Implementing the local emergency response
plan;
• Having knowledge of the state emergency
response plan and the Federal Regional
Response Team;
• Understanding the hazards and risks
associated with chemical protective
clothing; and
• Understanding the importance of
decontamination procedures.
In addition to the aforementioned training
requirements, each emergency responder must
receive either annual refresher training, or must
demonstrate sufficient competency in the relevant
areas on a yearly basis. With respect to refresher
training, there are no specific hourly requirements,
however, it should be of sufficient content and
duration to enable responders to maintain their
competencies. If an employee does not submit to
refresher training but is able to demonstrate
competency to the employer in the relevant areas,
the employer must document on a yearly basis the
statement of competency and maintain a record of
the method used to determine competency.
There are two types of workers who may be
needed during an emergency response, but are not
covered by the training requirements in 29 CFR
1910.120(q)(6). These employees include skilled
support personnel and specialist employees.
Skilled support personnel are trained in the
operation of specialized mechanical equipment
such as crane and hoisting equipment or a
backhoe, and generally are not employed by the
same organization as the other emergency response
personnel at the incident scene. Such skilled
personnel would be used in special situations to
assist with an emergency. Although they may be
exposed to hazards during an emergency response,
they are only at the scene temporarily to perform
immediate emergency support work that cannot
reasonably be performed by fully trained hazardous
response personnel.
The only training required for such skilled
personnel is that they receive an initial briefing of
the site, which must include instruction on the
proper use of PPE, a review of the potential
hazards at the site, an overview of the duties to be
performed, and an overview of other safety and
health precautions. Such personnel must be
briefed at the site prior to their participation in
any emergency response operations.
In addition to skilled support personnel, an
employer may call upon specialist employees to
assist in an emergency response effort. Specialist
employees have specialized knowledge about some
aspect of emergency response or hazardous
substances. These individuals are called upon on
an as needed basis to provide technical advice or
assistance to the individual in charge at an incident
where there has been a release of a hazardous
substance. For example, if an emergency release
involves two or more hazardous substances, a
chemist may be called in to predict the potential
reactivity of the agents involved at the scene.
Although there is no statutory limitation on
a specialist employee's functions, they must receive
proper training prior to performing any operations.
Specifically, specialist employees must receive
training commensurate with their area of
specialization on an annual basis. There are,
however, no hourly training requirements specified
under the worker protection standards for
specialist employees.
4-V-H
Medical Surveillance
Requirements
Employers whose employees
engage in emergency response
operations without regard to
location must develop and
implement a medical surveillance program that
includes provisions for baseline, periodic, and
termination medical examinations.
As specified in 29 CFR 1910.120(q)(9), a
medical surveillance program must be provided for
the following three groups of employees:
• Hazardous Materials Specialists;
• Members of an organized and designated
HAZMAT Team; and
• Employees who exhibit signs or symptoms
that may have resulted from exposure to
hazardous substances during the course of
an emergency incident, either immediately
or subsequently.
30
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Employers are not required to provide a
formal medical monitoring program for first
responders at the awareness and operations levels
(i.e., Levels 1 and 2) and Level 3 Responders who
are not members of designated HAZMAT teams.
These employees, however, must be provided with
medical examinations if they are injured due to
overexposure during an emergency incident.
Furthermore, because coverage under 29 CFR
I910.120(f)(2) does not apply to emergency
responders without regard to location, fire fighters
who wear respirators for 30 days or more per year
are only required to undergo medical surveillance
if they are members of designated HAZMAT
Teams or are injured due to overexposure to
hazardous substances during an emergency
incident.
If employees fall within the first two groups
listed above, they must undergo a baseline medical
examination prior to an assignment. After this
initial examination, employees must have a follow-
up medical examination once a year; an attending
physician may suggest a shorter or longer interval,
but this period may not exceed two years. The
content of these examinations is to be determined
by the attending physician, but certain key
elements must be included. For example, the
physician must complete a medical and work
history and determine the employee's fitness for
the type of duties to be assigned, including the
ability of the employee to wear PPE.
In addition to these requirements, an
employee must receive a medical examination as
soon as possible if the employee is injured or
becomes ill from exposure to hazardous substances
during an emergency, or the'employee develops
signs or symptoms that indicate a possible
overexposure to hazardous substances. In addition,
employees must receive a final examination when
they are reassigned or terminate employment and
thus no longer are exposed to hazardous
substances. This examination is only required if
the employee has not had an examination within
the past six months. All required medical
examinations must be provided without cost to the
employee, without loss of pay, and at a reasonable
time and place.
Medical records for employees must be
maintained for a period of thirty years following
termination of employment. 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 exposure
to hazardous substances; and a copy of the
information provided to the examining physician by
the employer. The employer is responsible for
retaining the records if the employee or physician
leaves the area. For additional information on
medical recordkeeping requirements, refer to 29
CFR 1910.20.
PART 2: Requirements
for Planning, Training,
and Medical Surveillance
at RCRA TSD Facilities
(29 CFR 1910.120(p))
This part of the Fact Sheet explains the
applicability of 29 CFR 1910.120(p) and describes
several of the requirements specified in the OSHA
standards for personnel involved in hazardous
waste operations and emergency response activities
at RCRA TSD facilities. Although there are eight
required elements specified at 29 CFR 1910.120(p)
for protecting workers who perform hazardous
waste operations and emergency response at
RCRA TSD facilities, this Fact Sheet addresses
only the planning, training, and medical
surveillance requirements. For a complete list of
the requirements at 29 CFR 1910.l20(p), refer to
Exhibit 3.
EXHIBIT 3
Operations Conducted Under the
RCRA Act of 1976
(29 CFR 1910.120(p))
Safety and health program
Hazard communication program
Medical surveillance program
Decontamination program
New technology program
Material handling program
Training program
Emergency response program
31
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Applicability of 29 CFR
19l0.120(p)
The requirements under the
worker protection standards
for personnel engaged in
hazardous waste operations
and emergency response at a RCRA TSD facility
are specified at 29 CFR 1910.120(p). These
requirements apply to any TSD facility regulated
under 40 CFR 264 and 265, or by a state program
authorized under RCRA; the requirements apply
to both permitted and interim status facilities.
Facilities that have been granted exemptions from
the RCRA TSD requirements (as detailed at 40
CFR 264 and 265), however, are exempt from the
worker protection requirements, except those at 29
CFR 1910.120(p)(8) which detail the requirements
for an emergency response plan, emergency
response training, and other procedures for
handling emergencies.
Planning Requirements
Employers at RCRA TSD
facilities must develop and
implement a written safety and
health program for their
employees engaged in
hazardous waste operations. The program must be
designed to identify, evaluate, and control safety
and health hazards at the facility, and provide for
emergency response during hazardous waste
operations at the TSD facility. In addition, the
program must address appropriate site analysis,
engineering controls, maximum exposure limits,
hazardous waste handling procedures, and uses of
new technologies. One important component of
the safety and health program is the emergency
response plan. This plan must be developed and
implemented as a separate part of the safety and
health program.
The emergency response plan must be
developed prior to the commencement of
operations at the facility. This plan must include
a description of how an emergency would be
handled at the facility and how the risks associated
with a response would be minimized. The
elements required in an emergency response plan
for a RCRA TSD facility are identical to the
requirements shown in Exhibit 2; the RCRA
requirements are codified at 29 CFR
In addition to the requirements outlined in
Exhibit 2, the emergency response plan must
include information on site topography, layout, and
prevailing weather conditions, and procedures for
reporting incidents to local, state, and federal
agencies. The emergency response plan should
also 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.
When preparing an emergency response
plan, employer's need not duplicate any of the
subjects that are addressed fully in the contingency
plan required under RCRA regulations, provided
that the contingency plan is incorporated into the
emergency response plan. Employer's may also
incorporate local emergency response plans or
state emergency response plans, or both, into the
emergency response plan, if appropriate.
In lieu of preparing an emergency response
plan under 29 CFR 1910.120(p)(8), employers 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 employers plan to evacuate their employees from
the facility when an emergency occurs, and not
permit employees to assist in responding to the
emergency.
In addition to developing an emergency
response plan, employers must also address the
following items in their safety and health plan, as
appropriate: the selection of engineering controls,
hazardous waste handling procedures, and uses of
new technologies.
Training Requirements
An employer must develop and
implement a training program
as part of the safety and health
program, for employees
engaged in hazardous waste
operations at RCRA TSD facilities. The worker
protection standards reflect a tiered approach to
training; the amount and type of training is linked
directly to an employee's potential for exposure to
hazardous substances and to other hazards during
a hazardous waste operation. The standards require
that only those employees that have been
appropriately trained may perform hazardous waste
operations or emergency response at a facility. A
summary of the training requirements for workers
32
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engaged in hazardous waste operations at RCRA
TSD facilities is provided below. An overview of
the basic hourly training requirements is also
provided in Exhibit 4.
THE RULE IS:
IF YOU ARE NOT TRAINED,
YOU CANNOT PARTICIPATE
EXHIBIT 4
Training Requirements for Employees at
RCRA TSD Facilities
(29 CFR 1910.120(p)(7) and p(8)(iii))
General Site Employees
Emergency Response
Personnel
24 Hours or
Equivalent and 8
hours of annual
refresher training
Trained to a Level
of Competency --
no specific hourly
requirements
The training requirements specified at 29
CFR 1910.120(p)(7)(i) for all new employees
engaged in hazardous waste operations at RCRA
TSD facilities include a minimum of 24 hours of
initial training. The purpose of this training is to
prepare employees to "perform their duties and
functions in a safe and healthful manner so as not
to endanger other employees." The regulation
does not specify what topics and issues should be
covered during training.
The initial training requirements can be
waived for current employees, if it is determined
that their prior work experience or training is
equivalent to the initial training requirements in
the standard. Equivalent training includes the
training an employee may have already received
from actual site work experience.
In addition to the initial training
requirements, all new and current employees
subject to the worker protection standards,
including managers and supervisors, must receive
a minimum of eight hours of refresher training
annually. The purpose of refresher training is to
ensure that employees maintain certain
competencies. There are several ways to satisfy the
annual refresher training requirement, such as
attending applicable seminars or participating in a
critique of an actual response.
The training requirements for employees
who engage in emergency response operations at a
RCRA TSD facility differ from the initial training
requirements specified above; there are no
specified hourly requirements for either training or
refresher training for emergency responders at
RCRA TSD facilities. The training requirements
for emergency personnel are specified at 29 CFR
1910.120(p)(8)(iii) and require employees who
participate in emergency response activities to be
familiar with the elements of the emergency
response plan, standard operating procedures
established for the response, and appropriate PPE.
Employees must also be trained to a level of
competence in the recognition of various health
and safety hazards at the facility. Specifically,
training should include information on the safe use
of control equipment and the proper techniques of
coordination among parties involved in the
incident.
•H-Vt
Medical Surveillance
Requirements
Employers at RCRA TSD
facilities must provide a
medical monitoring program
for the following four groups
of employees:
• Employees who wear a respirator for more
than 30 days a year;
• Hazardous Materials Specialists;
• Members of an organized and designated
HAZMAT Team; and
• Employees who exhibit signs or symptoms
that may have resulted from exposure to
hazardous substances during the course of
an emergency incident, either immediately
or subsequently.
The medical surveillance requirements for these
four groups of employees are identical to those
requirements outlined earlier in this Fact Sheet for
emergency responders without regard to location
33
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(pages 6 and 7). The requirements for medical
examinations and recordkeeping for employees at
RCRA TSD facilities are specified at 29 CFR
1910.120(p)(3).
PART 3: Sources of
Additional Information
The following is a brief
summary of where to obtain
additional information on the
EPA and OSHA worker
protection standards on hazardous waste
operations and emergency response. Please refer
to Exhibit 5 for the appropriate addresses and
telephone numbers of the contacts referenced
below.
• If you have questions regarding the existing
relationship between EPA and OSHA with
respect to the implementation of the
standards, contact the Environmental
Response Team (ERT) in Edison, NJ.
• For information about EPA's training
courses, contact ERTs Operations Section
in Cincinnati, OH.
• For information on guidance on the
substance of 29 CFR 1910.120, contact the
appropriate OSHA Regional Office. If
additional information is needed, contact
OSHA's Office of Health Compliance
Assistance in Washington, D.C.
• For information on how to establish a
Hazmat Team, refer to the Hazmat Team
Planning Guidance Document (U.S. EPA,
1990, Pub. No. EPA/540/G-90/003). This
Document identifies equipment that may be
necessary for an emergency response and
suggests ways to acquire and maintain such
equipment. In addition, the Document
offers guidance in determining actual
HAZMAT response requirements.
To obtain a copy of the Hazmat Team
Planning Guidance Document, please call
the National Technical Information Service
at (703) 487-4600. When requesting the
Document, be certain to specify the
publication number.
• There are four other Fact Sheets that are
available on the worker protection
standards for hazardous waste operations
and emergency response:
Hazardous Waste Operations and
Emergency Response: General
Information and Comparison (Pub.
No. 9285.2-09FS) explains the scope
of the worker protection standards
and distinguishes these standards
from regulations and consensus
standards covering the same or
similar subject matter.
Hazardous Waste Operations and
Emergency Response: Uncontrolled
Hazardous Waste Sites and RCRA
Corrective Action (Pub. No. 9285.2-
08FS) explains the specific
requirements for operations
conducted at uncontrolled hazardous
waste sites, including corrective
actions at RCRA TSD facilities.
Establishing Work. Zones at
Uncontrolled Hazardous Waste Sites
(Pub. No. 9285.2-06FS) describes the
requirements and procedures for
establishing support zones at
uncontrolled hazardous waste sites.
Hazardous Waste Operations and
Emergency Response: Available
Guidance (Pub. No. 9285.2-10FS)
describes guidance materials
developed by the Environmental
Response Team to help workers
engaged in hazardous waste
operations and emergency response
understand the HAZWOPER
requirements.
Copies of these Fact Sheets may be
obtained by calling or writing ERT in Edison, NJ.
(Refer to Exhibit 5 for the appropriate address and
telephone number.) Please specify the title and
publication number of the Fact Sheet(s).
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EXHIBIT 5
Important Telephone Numbers and Addresses
. U.S. EPA/ERT
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or (FTS) 340-6740
U.S. EPA/ERT
Operations Section
26 West Martin Luther King
Cincinnati, OH 45268
(513) 569-7537 or (FTS) 684-7537
• U.S. Department of Labor, OSHA
Office of Health Compliance Assistance
200 Constitution Avenue, NW
Washington, D.C. 20210
(202) 523-8036 or (FTS) 523-8036
OSHA Regional Offices
• U.S. Department of Labor, OSHA
Region 1
133 Portland Street, 1st Floor
Boston, MA 02114
(617) 565-7164 or (FTS) 835-7164
• U.S. Department of Labor, OSHA
Region 2
201 Varick Street, Room 670
New York, NY 10014
(212) 337-2325 or (FTS) 660-2378
• U.S. Department of Labor, OSHA
Region 3
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
(215) 596-1201 or (FTS) 596-1201
• U.S. Department of Labor, OSHA
Region 4
1375 Peachtree Street, NE, Suite 587
Atlanta, GA 30367
(404) 347-3573 or (FTS) 257-3573
• U.S. Department of Labor, OSHA
Region 5
230 South Dearborn Street
32nd Floor, Room 3244
Chicago, IL 60604
(312) 353-2220 or (FTS) 353-2220
• U.S. Department of Labor, OSHA
Region 6
525 Griffin Street, Room 602
Dallas, TX 75202
(214) 767-4731 or (FTS) 729-4731
• U.S. Department of Labor, OSHA
Region 7
911 Walnut Street
Kansas City, MO 64106
(816) 426-5861 or (FTS) 867-5861
• U.S. Department of Labor, OSHA
Region 8
1951 Stout Street
Denver, CO 80204
(303) 844-3061 or (FTS) 564-3061
• U.S. Department of Labor, OSHA
Region 9
71 Stevenson Street, Suite 415
San Francisco, CA 94105
(415) 744-6670 or (FTS) 484-6670
• U.S. Department of Labor, OSHA
Region 10
1111 Third Avenue, Suite 715
Seattle, WA 98101-3212
(206) 442-5930 or (FTS) 399-5930
EPA Regional Offices
• U.S. Environmental Protection Agency
Region 1
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3715 or (FTS) 835-3715
35
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EXHIBIT 5 (continued)
Important Telephone Numbers and Addresses
EPA Regional Offices (continued)
U.S. Environmental Protection Agency
Region 2
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, NY 10278
(212) 264-2657 or (FTS) 264-2657
U.S. Environmental Protection Agency
Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800 or (FTS) 597-9800
U.S. Environmental Protection Agency
Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727 or (FTS) 257-4727
U.S. Environmental Protection Agency
Region 5
230 South Dearborn Street
Chicago, 1L 60604
(312) 353-2000 or (FTS) 353-2000
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue, 9th Floor
Dallas, TX 75202
(214) 655-6444 or (FTS) 255-6444
U.S. Environmental Protection Agency
Region 7
726 Minnesota Avenue
Kansas City, KS 66115
(913) 551-7000 or (FTS) 276-7000
U.S. Environmental Protection Agency
Region 8
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1603 or (FTS) 293-1603
U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322
U.S. Environmental Protection Agency
Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-1200 or (FTS) 399-1200
Call the Emergency Planning and
Community Right-to-Know Information
Hotline for the addresses and telephone
numbers of state emergency response
commissions and local emergency planning
committees in your area. The telephone
numbers for the Hotline are: toll-free
800-535-7672, or 202-475-9652 in the
Washington, D.C. area.
36
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SECTION 3
QUICK REFERENCE FACT SHEETS
PART 4
HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
UNCONTROLLED HAZARDOUS WASTE SITES
AND RCRA CORRECTIVE ACTIONS
37
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EPA
United Stales
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9285 2-08FS
April 1991
Hazardous Waste Operations
and Emergency Response:
Uncontrolled Hazardous Waste Sites
and RCRA Corrective Actions
Office of Emergency and Remedial Response
Emergency Response Division MS-101
Quick Reference Fact Sheet
INTRODUCTION
Under the authority of section
126 of the Superfund Amend-
ments and Reauthorization Act
of 1986 (SARA), the U.S.
Environmental Protection
Agency (EPA) and the U.S.
Occupational Safety and
Health Administration (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,
published on June 23, 1989 at 54 FR 26654,
incorporate the OSHA standards by reference and
are codified at 40 CFR 311.
The EPA and OSHA worker protection
standards for hazardous waste operations and
emergency response (HAZWOPER) apply to three
primary groups of workers: (1) employees engaged
in voluntary and mandatory clean-ups at
uncontrolled hazardous waste sites, including
corrective actions at treatment, storage, and
disposal (TSD) facilities regulated under the
Resource Conservation and Recovery Act
(RCRA); (2) employees engaged in routine
hazardous waste operations at RCRA TSD
facilities; and (3) employees engaged in emergency
response operations without regard to location.
The purpose of this Fact Sheet is to explain
the principle requirements of the EPA and OSHA
worker protection standards as they apply to
employees engaged in hazardous waste operations
at uncontrolled hazardous waste sites, including
employees who perform corrective actions at
RCRA TSD facilities. The other two groups of
employees affected by the regulations are
addressed in a separate Fact Sheet entitled
Hazardous Waste Operations and Emergency
Response: RCRA TSD and Emergency Response
Without Regard to Location (Publication
No. 9285.2-07FS). The requirements that apply to
individuals engaged in hazardous waste operations
at RCRA TSD facilities and emergency responders
who respond to emergencies without regard to
location are specified at 29 CFR I9l0.120(p) and
(q), respectively.
The HAZWOPER requirements for
workers who engage in hazardous waste operations
and emergency response at uncontrolled hazardous
waste sites are specified at 29 CFR 1910.120(a)
through (o), and are summarized in Exhibit 1,
these requirements also apply to those workers
who perform corrective actions at RCRA TSD
facilities. These requirements apply to any
employee working at an uncontrolled hazardous
waste site who has the potential to be exposed to
hazardous substances. As such, the On-Scene
Coordinator (OSC) and me Remedial Project
Manager (RPM) are both covered by the standards
and must fully implement the standards for other
employees engaged in hazardous waste sue clean
ups. These provisions also 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)
In sum, all stages of a removal and remedial
operation performed at a site in which there is a
potential for exposure to hazardous substances
must be conducted in accordance with the worker
protection standards specified at 29 CFR
39
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EXHIBIT I
Hazardous Waste Operations and
Emergency Response at Uncontrolled
Hazardous Waste Sites
(29 CFR 1910.120(a)-(o))
(a) Scope, application, and definitions.
(b) Safety and health program
(c) Sue characterization and analysis
(d) Sue control.
(e) Training.
(f) Medical surveillance
(g) Engineering controls, work practices, and
personal protective equipment for employee
protection
(h) Monitoring
(i) Informational programs
(j) Handling drums and containers.
(k) Decontamination
(1) Emergency response by employees at
uncontrolled hazardous waste sites
(m) Illumination.
(n) Sanitation at temporary workplaces
(o) New technology programs
19l0.120(a) through (o). The standards, however,
do not apply to employees who do not have the
potential to be exposed to hazardous substances.
For example, administrative support personnel in
the Incident Command Post may not be covered by
HAZWOPER. These employees, however, must
be made aware of the provisions of the emergency
response plan. Specifically, they must be briefed
on the procedures to take during an emergency at
the site, and they must be familiar with general site
operations, such as the location of work zones.
Employees not covered by HAZWOPER are, of
course, protected by other OSHA standards
including the Hazard Communication Standard
(HAZCOM).
In addition to the requirements specified at
29 CFR 1910.120(a) through (o), other worker
protection requirements may also apply at
uncontrolled hazardous waste sites For example,
29 CFR 1910.120(q) applies to workers, such as
local HAZMAT team members, who come on-sitc
specifically to perform emergency response
operations. The requirements specified at (q),
however, do not apply to regular site employees
who perform routine clean-up operations at the
site and who may also perform emergency response
operations; these individuals are covered by the
requirements in 29 CFR 1910.120(e)
This Fact Sheet is divided into six parts
The first three parts describe the planning,
training, and medical surveillance requirements for
workers engaged in hazardous waste operations
and emergency response at uncontrolled hazardous
waste sites. The fourth part of this Fact Sheet
discusses other requirements of HAZWOPER thai
must be implemented at uncontrolled hazardous
waste sites. The fifth part of this Fact Sheet
discusses employee rights under section 8 of the
Occupational Safety and Health Act of 1970, as
amended (OSH Act) The final part of this Fact
Sheet provides important addresses and telephone
numbers.
PART 1: PLANNING
REQUIREMENTS
Part 1 of this Fact Sheet
explains the purpose of the
comprehensive safety and
health program and the site-
specific health and safety plan (HASP); describes
the specific steps that must be taken to develop a
HASP; explains the type of information that must
be included in the HASP; and summarizes the
responsibilities of the OSC, RPM, and the
Environmental Response Team (ERT) in
developing a HASP at an EPA-lead sue.
There are many different types of entities,
including state agencies, private corporations, and
the federal government, that may have lead
responsibility in cleaning up an uncontrolled
hazardous waste site or a contaminated RCRA
TSD facility. Each of these entities uses different
titles to identify the person who has overall
responsibility for site activities. For purposes of
this Fact Sheet, this responsible person is referred
to as the OSC/RPM, as it is at EPA-lead sites.
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Safety and Health Program
Any employer whose workers engage in
hazardous waste operations and emergency
response at an uncontrolled hazardous waste site
or who perform corrective actions at a RCRA TSD
facility must develop and implement a written
safety and health program. This program must be
designed to identify, evaluate, and control safety
and health hazards at any site, and to provide for
emergency response during site operations The
written safety and health program must include an
organizational structure; a site-specific health and
safety plan (HASP); a comprehensive workplan; a
medical surveillance program; and a description of
the employer's standard operating procedures. For
a complete list of the elements required in the
written safety and health program, refer to 29 CFR
The primary purpose of the safety and
health program is to serve as the organization's
comprehensive health and safety policy that applies
to all employees of the company, irrespective of
the location of the actual site where they are
working. This program must be maintained by the
employer and made available to any employee or
employee representative; contractor, subcon tractor,
or other representative working for the employer
who will be potentially exposed to hazardous
substances; OSHA personnel; and personnel of
federal, state, and local agencies with regulatory
authority over the site. It is important to note that
only one safety and health program should be
developed by an employer, even if the employer
has workers that perform operations at several
different sites.
If an employer has already developed a
safety and health program to meet the
requirements of other federal, state, and -local
regulations, the employer may use the existing
program to satisfy the HAZWOPER requirements,
so long as any additional information not covered
in the existing program but required under
HAZWOPER is incorporated into the program.
Site-Specific HASP
Although the standards require employers
to develop and implement only one safety and
health program, a site-specific HASP must be
developed and implemented for each site where
workers are potentially exposed to hazardous
substances.
The purpose of the site-specific HASP is to
address the safety and health hazards that may
exist at each phase of site operations and to
identify procedures for protecting employees.
Exhibit 2 presents a comprehensive list of the
elements that must be included in the HASP.
Information gained during the site
characterization, as specified ai 29 CFR
1910.120(c), must be considered in developing the
HASP. The site characterization may be divided
into three stages: preliminary evaluation (PE),
initial site entry, and ongoing monitoring. Under
the requirements of 29 CFR I9l0.120(b)(4), the
HASP must be developed after the PE has been
performed and before any site entry. The
following is a brief discussion of the specific steps
that must be taken to develop, implement, and
maintain a HASP.
Step 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 no! to endanger ihe health and safety oj
site workers. The purpose of the PE is to obtain
preliminary information 10 help identify the
specific hazards at the sue and determine the
approptiate safety and health 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.
The specific information that must be obtained
during the PE is summarized below and outlined
in Exhibit 3. The information obtained during the
PE should be used to develop the HASP.
There are several ways in which the
information specified in Exhibit 3 can be obtained
For example, records of the sue or interviews with
persons who are knowledgeable aboui the sue can
provide useful information about the potential
hazards at a site. Potentially useful sources of
information include: company records, receipts,
logbooks, or ledgers that describe sue activities,
records from state and federal pollution control
regulatory and enforcement agencies and stale
occupational and health offices; local fire and
police department records, site photos, and media
reports.
In addition to interviewing knowledgeable
persons and researching the history of the site,
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EXHIBIT 2
The Specific Components
of a HASP
Key personnel.
Safety and health risk or hazards analysis
for each sue task and operation found in
the workplan.
Employee training assignments to assure
that each employee receives the training
required before they engage in any
operation that could potentially lead 10
exposure to a hazardous substance or to
safety or health hazards
personal protective equipment appropriate
for each site task or operation conducted
Medical surveillance requirements
Employee and air monitoring equipment
and environmental sampling techniques and
instrumentation to be used
Sue control measures that include at a
minimum - a site map, a buddy system, site
communications system (including
emergency alerting), standard operating
procedures or safe work practices, and
identification of the nearest medical
assistance.
Decontamination procedures both for
individuals and equipment on sue and in
places where there is a potential for
exposure to a hazardous substance.
An emergency response plan for safe and
effective responses to emergencies.
Confined space entry procedures.
A spill containment program to contain and
isolate the entire volume of any hazardous
substance spilled in the course of a transfer.
Hazard communications plan (29 CFR
1910.1200 and 29 CFR 1926.59).
data-gathering 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. Perimeter reconnaissance activities
during the PE must be conducted off-site. To
identify the appropriate sampling techniques for
perimeter reconnaissance, the safety and health
officer should review the information obtained
during the records/interview research. The most
important thing to remember is that the
OSC/RPM must not, under any circumstances,
allow a worker to enter the site to collect
information for the PE.
THE PE MUST BE COMPLETED
PRIOR TO
ANYONE ENTERING THE SITE
Step 2. Developing the HASP
Once the PE is completed and the
appropriate information is obtained, the
OSC/RPM at the site must use the information
gathered during the PE to develop the initial draft
of the site-specific HASP. The initial draft of the
HASP must include all elements listed in Exhibit
2. Specifically, it must identify each anticipated
safety and health hazard for each work operation
or activity, and describe how those hazards will be
eliminated or controlled. 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.
NO ONE MAY ENTER THE
SITE UNTIL THE HASP HAS BEEN
DEVELOPED, APPROVED, AND
IMPLEMENTED
Step 3: Initial Site Entry
Once the HASP is developed and
implemented, the second stage of the site
characterization and analysis (i.e., the initial site
entry) may begin. The purpose of the initial site
entry is to gather additional information and
further evaluate the site's specific characteristics to
identify and confirm existing site hazards and to
aid in the selection of appropriate engineering
controls and PPE.
At a minimum, activities during the initial
site entry should consist of a visual survey for
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EXHIBIT 3
Specific Components of the
Preliminary Evaluation
(29 CFR I910.l20(c)(4))
Site location and size
Description of response activity and/or
the job to be performed
Duration of the planned activity.
Site topography and accessibility by air
and roads.
Safety and health hazards expected at
the site-
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 involved or expected at the
site, and the chemical and physical
properties of these substances
potential hazards and, when there is potential for
exposure, air monitoring. Multi-media sampling
should also be performed if ihe OSC/RPM has
reason to believe that contamination may have
occurred.
An accurate and comprehensive visual
survey of the site will assist the OSC/RPM in
identifying and determining what additional
information (e.g., sampling of soil or containers)
may be needed. This visual survey could include
noting the condition of waste containers (e.g.,
undamaged or rusted); noting any unusual
conditions; and determining potential pathways for
exposure.
When entering the site, entry personnel
should monitor the air using direct reading
instruments for immediately dangerous to life and
health (IDLH) conditions (e.g., combustable or
explosive atmospheres, oxygen deficiency^ toxic
substances) and for ionizing radiation. Such
monitoring, however, need only be conducted if the
PE produces information that indicates (1) existing
IDLH conditions, or (2) the potential for ionizing
radiation, or 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,
visible vapor clouds, or areas thai contain
biological indicators such as dead vegetation. The
specific monitoring requirements for initial site
entry are specified at 29 CFR 1910.120(c)(6) and
In addition to air monitoring, multi-media
sampling should be performed dunng ihe initial
site entry, if the OSC/RPM believes contammaiion
may exist. The soil sampling techniques employed
will differ with each site. 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 information required
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. For additional information
and guidance on how to designate work zones,
consult the Fact Sheet entitled Establishing Work
Zones at Uncontrolled Hazardous Waste Sites
(Publication No. 9285.2-06FS).
Any information concerning the chemical,
physical, and lexicological 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.
INITIAL SITE ENTRY ACTIVITIES
MUST, AT A MINIMUM, INCLUDE A
VISUAL SURVEY AND, WHEN THERE
IS POTENTIAL FOR EXPOSURE,
AIR MONITORING
Step 4: Update the HASP
Once the initial site entry is completed, the
OSC/RPM is responsible for updating the HASP
to ensure that it adequately identifies any new
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tasks or hazards at the site. At most sites, any air
and multi-media sampling performed during the
initial site entry will provide the OSC/RPM with
more accurate information regarding the
appropriate level of PPE to be worn by site
employees and the proper designation of work
zones.
UPDATE THE HASP AFTER
THE INITIAL SITE ENTRY
Step 5: On-Going Site Activities
Once the HASP is revised to reflect the
information gathered during the initial site entry,
on-going monitoring must occur ai the sue to
ensure that all new hazards are identified in a
timely manner and that the appropriate controls
are implemented to protect site employees.
If new tasks or hazards are identified at a
site, do not develop a new HASP; instead, update
the original HASP. If a subcontractor 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 OSC/RPM 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
When developing a HASP, be careful to
ensure that all required information as specified at
29 CFR 1910.120(b)(4)(ii) is addressed in the
HASP. The remainder of this part of the Fact
Sheet will explain the specific elements that must
be included in the HASP.
Elements of the HASP
The information that must be included in
the HASP is specified at 29 CFR
1910.120(b)(4)(ii) and summarized in Exhibit 2.
Some of the areas that must be addressed in the
HASP, such as the employer's monitoring and
decontamination programs, are discussed in further
detail below. In addition to the elements specified
at 29 CFR 1910.120(b)(4)(ii), the HASP must
identify key personnel and HAZCOM
requirements and provide for pre-entry 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 safety and health procedures being
followed at the site.
Monitoring program (29 CFR 1910.120(h)). The
OSC/RPM's proposed monitoring program must
be included in the HASP The monitoring
program must include procedures for initial entry
monitoring, periodic monitoring, and monitoring
of high risk employees. The monitoring
requirements for initial site entry are specified at
29 CFR I9l0.120(c)(6) and (h)(2) and are
discussed in detail on p. 5.
In general, monitoring must be performed
whenever there is any possibility that employees
may be exposed to hazardous substances. The
purpose of monitoring is to ensure that the proper
engineering controls, work practices, and PPE are
used to protect employees at the site.
Periodic monitoring should be conducted
whenever there is any indication that exposures
have risen above the permissible exposure limits
(PELs), or other dangerous conditions exist such
as the presence of flammable atmospheres or
environments that are oxygen-deficient.
Monitoring of high risk employees should be
conducted on those employees suspected of having
the highest exposures to hazardous substances and
health hazards.
In addition to the monitoring requirements
specified in 29 CFR 1910.120, there are other
applicable OSHA standards, specifically Subpart Z,
29 CFR 1910.1000, that refer to particular air
sampling and monitoring procedures for chemical
contaminants. These standards also specify certain
PPE and recordkeeping requirements for a variety
of compounds. The compounds and their
accompanying regulations are listed in Exhibit 4.
Site control program (29 CFR I910.120(d)). The
site control program in the HASP specifies the
procedures that will be used to minimize employee
exposure to hazardous substances before clean-up
operations commence and during site operations.
The site control program must be developed
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EXHIBIT 4
Toxic and Hazardous Substances
Subpart Z, 29 CFR 1910.1000
Compound
Asbestos
Coal tar pitch volatiles
4-nitrobiphenyl
Aipha-Naphlhylamme
Methyl chloromethyl ether
3,3'-dichlorobenzidine
bis-chloromethyl ether
Benzidme
4-ammodiphenyl
Ethyleneimine
beta -propiolactone
2-acetylammofluorene
4-dimethylaminoazo-
benzene
N-nitrosodimethy!atnine
Vinyl chloride
Inorganic arsenic
Lead
Benzene
Coke oven emissions
l,2-dibromo-3-chloro
propane
Acrylonitrile
Ethylene oxide
Formaldehyde
OSHA Reference
29 CFR 1910.1001
29 CFR 1910.1002
29 CFR 1910.1003
29 CFR 1910.1004
29 CFR 1910.1006
29 CFR 1910.1007
29 CFR 1910.1008
29 CFR 1910.1010
29 CFR 1910 1011
29 CFR 1910.1012
29 CFR 1910.1013
29 CFR 19101014
29 CFR 1910 1015
29 CFR 1910.1016
29 CFR 1910.1017
29 CFR 1910.1018
29 CFR 1910 1025
29 CFR 1910 1028
29 CFR 1910 1029
29 CFR 1910 1044
29 CFR 1910.1045
29 CFR 1910.1047
29 CFR 1910.1048
during the planning stages of a hazardous waste
clean-up operation, and must be modified as any
new information becomes available. The site
control program must, at a minimum, include a
site map, work zones, communications,
identification of the nearest medical assistance, 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 work practices
should be implemented to reduce and maintain
employee exposure to levels at or below the PELs
for those hazardous substances at the site.
Examples of engineering controls that may be used
include pressurized cabins and control booths on
equipment. If, for whatever reason, it is not possible
to maintain employee exposure to levels at or below
PELs, technical assistance should be obtained from
other sources before proceeding with site activities
(e.g., EKT or OS1-IA).
PPE should be used as a last rcson to
protect employees against possible exposure to
hazardous substances. It should only be used when
engineering controls and work practices arc
insufficient to adequately protect against exposure.
The PPE used at the site must be reflective of the
potential site hazards identified during the PE and
initial site characterization
Decontamination program (29 CFR 1910.120(k)).
The decontamination procedures should be
developed and appropriately communicated to all
employees before they enter a site where potential
for exposure to hazardous substances exists The
OSC/RPM must develop and include
decontamination procedures in the HASP that
identify standard operating procedures at the sue,
such procedures should provide employees with
information on how to minimize their contact with
hazardous substances. In addition, the
decontamination program must include procedures
for employees who leave a contaminated area on
the site. Such employees must be decontaminated
and their equipment must be disposed of or
decontaminated. The requirements for a
decontamination program are codified at 29 CFR
1910.120(k).
Emergency response plan (29 CFR 1910.120(1)). One
of the most important components of the HASP is
the written site-specific emergency response plan.
This 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 summarized in Exhibit 5 and are codified
at 29 CFR 1910.120(1)(2)
In addition to these elements, the
emergency response plan must include information
relevant for conducting emergency operations at
the site, such as information on site topography,
layout, and prevailing weather conditions, and
procedures for reporting incidents to local, state,
and federal agencies. The emergency response
plan must also be rehearsed regularly and reviewed
periodically to ensure that it accounts for new or
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EXHIBIT 5
Required Elements of an
Emergency Response Plan at an
Uncontrolled Hazardous Waste Site
(29 CFR 1910.L20(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.
changing site conditions or new information on
potential hazards at the site.
In lieu of preparing an emergency response
plan, OSC/RPMs 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 will direct employees
to leave the site, maintain a safe distance, and 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 on 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 must be notified of
site operations prior to the commencement of any
site activities
Spill containment program (29 CFR
1910.120(j)(l)(viii)). In the event of a major spill
or a release on-sitc, the spill containment program
must be implemented to contain and isolate the
hazardous substance release.
Responsibilities of the OSC/RPM
The OSC/RPM is responsible for reviewing
the HASP for consistency with the workplan and
accepting the HASP for the site. The HASP must
accurately reflect the work being performed at the
site, and must be reviewed and approved again
when any additions or revisions are made to the
HASP throughout the course, of work at the site.
The OSC/RPM is also responsible for
ensuring that employees are adequately informed
of the procedures to report a health and safety
violation, as well as the procedures for filing a
workman's compensation report. Specifically,
employees should be told that a health and safety
complaint may be made either in writing or
verbally, and that such complaints should be
addressed to the OSC/RPM, the contractor's health
and safety officer, and the EPA contract officer.
The OSC/RPM should also ensure that workman
compensation forms are available on-site. For
additional information on employee rights, refer to
Part 5 of this Fact Sheet
Role of the Environmental Response Team
(ERT)
If additional guidance is needed or desired,
the OSC/RPM may submit the HASP to ERT for
review or may request a site audit. It is important
to note that ERT does not approve HASPs; ERT
will only review them and provide
recommendations. As soon as the HASP has been
accepted by the OSC/RPM, covered operations at
the site may commence; a plan may be
implemented without ERT concurrence.
In general, it is the Agency's policy to
encourage the development of an effective HASP
and to assist the Regions -with the task of
reviewing and processing HASPs. As such, ERT
will provide consultation and assistance if such
assistance is requested. For further information on
ERT assistance, contact the OSWER Health and
Safety Manager in ERT in Edison, New Jersey, at
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(FTS) 340-6740 or (908) 321-6740. Regional
Health and Safety Officers may also be available
for plan review and consultation. Refer to your
Regional directory for the relevant addresses and
telephone numbers.
A
PART 2: TRAINING
REQUIREMENTS
This par! of the Fact Sheet
addresses the HAZWOPER
training requirements that
apply to employees engaged in
hazardous waste operations and emergency
response at uncontrolled hazardous waste sites and
employees who perform corrective actions at
RCRA TSD facilities.
General Training Requirements
Each employer at a site is responsible for
ensuring that their respective employees are
properly trained and equipped prior to
commencing work at a site. The HAZWOPER
training required for site workers must identify the
hazards present on-site, the medical surveillance
requirements, certain elements of the HASP, and
operating practices and procedures, including the
use of PPE and proper engineering controls. The
specific issues and topics that are required to be
addressed during training are specified at 29 CFR
1910.120(e)(2). The amount of training required
for site workers is linked directly to an employee's
potential for exposure to hazardous subsiances and
to other health hazards at the site, and is specified
at 29 CFR 1910.120(e)(3) and (4). Employees may
not participate in or supervise any.site activity until
they have been adequately trained.
The HAZWOPER standards specify hourly
requirements for four different categories of sile
workers. The amount of training a worker must
receive is commensurate with the employee's
potential for exposure; the hourly training
requirements are described briefly below and
summarized in Exhibit 6.
General site workers at an uncontrolled
hazardous waste site include equipment operators
and general laborers engaged in routine hazardous
waste removal. These routine site workers must
have a minimum of 40 hours of instruction off-site
and 24 hours of field experience under the
supervision of a trained and experienced
supervisor.
EXHIBIT 6
Initial Training Requirements for
Employees at Uncontrolled
Hazardous Waste Sites
(29 CFR 19IO.l20(e))
Routine Site
Employees
40 Hours Off-Sue
24 Hours Field Fjcpenence
Occasional
Employees and
Routine Site
Employees Unlikely
to be Exposed
Above PELs
24 Hours Off-Site
8 Hours Field Experience
Supervisors
Site Employees
Assigned Site
Emergency
Response
Duties
8 Hours of Specialized
Training, in addition to
(he Requirements for
the Employees they
Supervise
Trained to a Ixvel
of Competency in
Addition to above
Requirements
All Sue
Workers
Hours Annual
Refresher Training
Workers who are on-site only occasionally
to perform a specific job, such as groundwater
monitoring, and who are unlikely to be exposed
over PELs, are required to have a minimum of 24
hours of instruction off-site and a minimum of
eight hours of supervised field experience.
Routine site workers who work only in
areas where the exposure levels are monitored and
determined to be below PELs are also required to
receive 24 hours of instruction off-site and 8 hours
of supervised field experience.
Supervisors of the three 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, if a supervisor only manages employees
who work on site occasionally, the supervisor must
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have a minimum of 24 hours of instruction off-site
and 8 hours of supervised field experience, plus an
additional eight hours of specialized management
training.
In addition to the requirements listed above,
any worker who receives 24 hours of training and
who then becomes a general site worker or whose
job function requires that a respirator be worn,
must have an additional 16 hours of instruction
off-site and 16 hours of supervised field experience
before commencing the new duties at the site.
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 and 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 his belief, denoting length
and type of experience or training.
Although there are no specific additional
training requirements for employees with
emergency response duties at a site, such
employees must be trained commensurate with the
duties that will be assumed.
Refresher Training
All employees who perform clean-up
operations at uncontrolled hazardous waste sites,
including managers and supervisors, must receive
a minimum of eight hours of annual refresher
training. The purpose of refresher training is to
maintain certain competencies. There are several
ways to satisfy the annual refresher training
requirement. For example, as explained on p. 7 of
this Fact Sheet, the emergency response plan of
the HASP must be rehearsed regularly. These
rehearsals can be used to meet some of the annual
refresher training requirements. Attendance at
applicable seminars and critiques of actual
responses are also acceptable methods of satisfying
the annual refresher training requirements. Proper
documentation of attendance, however, should be
maintained.
Training Accreditation
On January 26, 1990, OSHA published a
Notice of Proposed Rulcmaking (NPRM) (55 FR
2776) that proposed accreditation procedures for
programs to train employees engaged in clean-up
operations at uncontrolled hazardous waste sites,
and for employees engaged in certain hazardous
waste operations at RCRA TSD facilities. The
NPRM also proposed amendments to 29 CFR
1910.120 to include appropriate references to the
provisions set forth in the proposed rule. If this
regulation is promulgated as it was proposed, all
employees subject to 29 CFR 1910.120 at
uncontrolled hazardous waste sites will be required
to attend an accredited training program or to
document equivalent training and experience.
PART 3: MEDICAL
SURVEILLANCE
REQUIREMENTS
Part 3 of this Fact Sheet
discusses the medical
surveillance requirements in
HAZWOPER that apply to employees engaged in
hazardous waste operations and emergency
response at uncontrolled hazardous waste sites,
including employees who perform corrective
actions at RCRA TSD facilities.
General Medical Surveillance Requirements
The HAZWOPER medical surveillance
requirements (29 CFR 1910 120(f)) provide the
framework for a medical monitoring program for
workers at uncontrolled hazardous waste sites.
The standards contain provisions for baseline,
periodic, and termination medical examinations.
A medical surveillance program must
include monitoring for the following four groups of
employees:
• Employees who are, or may be, exposed to
PELs or health hazards for 30 or more days
a year;
• Employees who wear a respirator for 30 or
more days a year;
• Members of organized HAZMAT Teams;
and
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• Employees who are injured due to
overexposure during an emergency incident,
or who show symptoms of illness that may
have resulted from exposure to hazardous
substances.
If employees fall within the first three
groups specified above, they must undergo a
baseline medical examination prior to a site
assignment. After this initial examination,
employees must have a follow-up medical
examination once a year; an attending physician
may suggest a shorter or longer interval, but this
period may not exceed two years. The content of
these examinations should be determined by the
attending physician, but certain key elements must
be included. For example, the physician must
complete a medical and work history and
determine the employee's fitness for the type of
duties to be assigned, including the employee's
ability to wear PPE. Once the medical
examination has been completed, the employer
must obtain and furnish the employee with a copy
of the physician's written opinion. The physician's
written opinion must include the results of the
medical examination and tests, any recommended
work limitations, and the physician's opinion
concerning the medical condition of the employee.
In addition to the initial and follow-up
examinations, employees must receive a medical
examination as soon as possible if they are injured
or become ill from exposure to hazardous
substances on-site or during an emergency, or they
develop signs or symptoms that indicate a possible
overexposure to hazardous substances. In addition,
employees who are reassigned or terminate
employment and, therefore, will no longer be
exposed to hazardous substances must receive a
final examination. This examination is only
required if the employee has not had an
examination within the past six months. All
required medical examinations must be provided
without cost to the employee, without loss of pay,
and at a reasonable time and place.
Additional guidance on these medical
surveillance requirements can be found in:
U.S. EPA OERR Medical Monitoring
Program Guidelines, OSWER Directive
9285.3-04. To obtain a copy of these
guidelines, contact the Environmental
Response Team (ERT) of EPA in Edison,
New Jersey. (Refer to Exhibit 8 for the
appropriate address and telephone number.)
• Standard Operating Safety Guides, OSWER
Directive 9285.1-O1C. To obtain a copy of
this document, contact ERT in Edison, New
Jersey.
• Hazmat Team Planning Guidance,
Publication Number EPA/540/G-90/003. To
obtain a copy of this document, contact the
National Technical Information Service at
(703) 487-4600.
• Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities
(Chapter 5 - Medical Monitoring),
Publication Number 017-033-00419-6. To
obtain a copy of this document, contact the
Superintendent of Documents at the U.S.
Government Priniing Office in Washington,
D.C. 20402 ((202) 783-3238)
Medical Records
Medical records for employees must be
maintained for a period of thirty years following
termination of employment. 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 exposure
to hazardous substances; and a copy of the
information provided to the examining physician by
the employer. The employer is responsible for
retaining the records if the employee or physician
leaves the area, or the company goes out of
business. For additional information on medical
recordkeeping equirements, refer to 29 CFR
1910.20.
PART 4: OTHER
REQUIREMENTS
This part of the Fact Sheet
discusses other requirements in
HAZWOPER that apply to
employees engaged in
hazardous waste operations and emergency
response at uncontrolled hazardous waste sites.
Specifically, this part outlines the requirements for:
(1) handling drums and containers, (2)
illumination and sanitation requirements, and (3)
informational and new technology programs.
49
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Requirements for Handling Drums and
Containers (29 CFR 1910.1200))
When performing site operations,
HAZWOPER specifies some basic requirements
for handling drums and containers on-site. In
general, sue operations should be organized to
minimize the amount of drum and container
movement. However, if drums or containers must
be moved, the following are a few of the
requirements that must be met
• Drums and containers must be inspected
prior to being moved. If this is not possible
because the drums are buried beneath the
earth or stacked several tiers high, the
drums or containers should be moved to an
accessible location and then inspected prior
to further handling.
• Prior to the movement of drums, all
employees who have a potential to be
exposed to hazardous substances as a result
of the transfer operation must be notified
of the potential hazards associated with the
contents of the drums or containers
In addition to the above requirements,
HAZWOPER provides specific procedures for
(1) opening drums and containers; (2) selecting
and operating material handling equipment, (3)
handling radioactive and shock-sensitive wastes and
laboratory waste packs; (4) sampling the contents
of drums or containers; (5) shipping and
transporting drums or containers; and (6) handling
tanks and vaults containing hazardous substances.
Illumination and Sanitation Requirements
(29 CFR 1910.120(m) and (n))
The employer is responsible for ensuring
that appropriate procedures exist at the site to
maintain certain minimum illumination intensities
and an adequate supply of water. There must be
two separate systems for furnishing water: a
potable and a nonpotable system. The potable
system should provide drinking water only; the
nonpotable system should provide water for fire
fighting purposes. There are also requirements for
toilet facilities, food handling, sleeping quarters,
washing facilities, and shower/change rooms.
Informational and New Technology
Programs (29 CFR 1910.120(i) and (o))
Two additional programs that must be
developed, implemented, and included as part of
the employer's safety and health program are the
information and new technology programs. A
program must be developed and implemented to
inform employees of the nature, level, and degree
of exposure that may occur as a result of
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). The HCS may
contain information that would be useful to
incorporate into the informational program or
emergency response plan for a site.
In addition to. developing an informational
program, the employer must include as part of the
safety and health 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 clean-up
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. The
evaluation, which must be completed prior to using
the new technology at the site, must identify 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.
PARTS: EMPLOYEE
RIGHTS UNDER
SECTION 8 OF THE OSH
ACT
Section 8 of the OSH Act,
Inspections, Investigations, and
Recordkeeping, gives employees certain rights to
inspect documents, and request and participate in
inspections. Exhibit 7 provides a summary of the
principle provisions of section 8 of the OSH Act.
OSHA has authority to inspect a site on
their own initiative at any reasonable time. Under
paragraph (f)(l) of section 8, however, an
50
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EXHIBIT 7
Principal Provisions of
Section 8 of the OSH Act
Paragraph 8(c)(l):
• Employers are required to inform
employees of their rights under the
OSH Act
Paragraph 8(c)(3):
• Employees are entitled access to any
required records that indicate the
person's exposure to toxic materials
Paragraph 8(e):
• An employee and employer
representative must be given the
opportunity to accompany OSHA
during any workplace inspection
Paragraph 8(0:
• An employee 01 employee
representative may request an OSHA
inspection if the person believes that
there is a violation of a safety or
health standard that threatens physical
harm, or that causes an imminent
danger
employee or employee representative also can
request an OSHA inspection if the person making
the request believes either that there is a violation
of a safety or health standard that threatens
physical harm, or that an imminent danger exists.
The request must be written and signed, and must
include a reasonable statement of the violation or
danger. An employer is entitled to get a copy of
the request, but the employee can ask OSHA not
to disclose his name. When an employee makes a
request under this provision, OSHAmi«r conduct
an inspection if they determine that there are
reasonable grounds to believe a violation or danger
exists. If OSHA makes a contrary determination,
the person who made the request must be notified.
Under paragraph (f)(2), before or during an
inspection, an employee or employee
representative has the right to notify OSHA in
writing of any violation of the OSH Act that the
person has reason to believe exists in the
workplace. If the person making the request asks,
OSHA must explain any determination not to
sanction the employer.
If there is an OSHA inspection, under
section 8(e), an authorized employee
representative must be given the chance to
accompany OSHA during any inspection If there
is no authorized employee representative, the
OSHA inspector has a further duty to consult with
a reasonable number of employees on matters of
health and safety. Under section 8(e), employers
are also provided, with the opportunity to designate
a representative to accompany OSHA on the
inspection. An important point to remember,
however, is that under no circumstances may the
employer designate the employee representative
Section 8 sets out three other important
employee rights. Paragraph (c)(l) requires
employers to post a notice or use some other
appropriate means to inform employees of how the
OSH Act protects them, as well as what employee
obligations are. Further, where the OSH Act
requires measuring or monitoring potentially toxic
materials or harmful physical agents (e.g., Subpait
Z, 29 CFR 1910.1000), paragraph (c)(3) gives an
employee or an authorized employee
representative the right to observe any such
activity, and to have access to the records. This
same paragraph states that an employee or former
employee is entitled to have access to any required
records that indicate the person's exposure to toxic
materials or harmful physical agents. When an
employee is so exposed, the employer must notify
him of an exposure above levels prescribed by an
applicable OSHA standard, and inform the
employee of actions taken to correct the conditions
that led to the impermissible exposure.
There are other provisions of the OSH Act
that set forth employee rights. For additional
information, consult the OSH Act. Another useful
source to consult on this subject is the OSHA
publication entitled Employee Workplace Rights
(OSHA Publication No. 3021). To obtain a copy
of this document, contact OSHA's Publications
Office. (Refer to Exhibit 8 for the appropriate
address and telephone number.) When ordering
the document, be certain to specify the publication
number.
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PART 6: SOURCES OF
ADDITIONAL
INFORMATION AND
REFERENCE
MATERIALS
Part 6 of this Fact Sheet provides
information on where you can obtain a copy of a
generic HASP; describes a set of Guidelines that
can help an OSC/RPM assess the efficacy of a
HASP; and provides important addresses and
telephone numbers for additional information on
HAZWOPER requirements
Generic HASPs
ERT has developed a computer software
package to assist field personnel in preparing a
site-specific health and safety plan, complete with
all the elements required by HAZWOPER You
can obtain a copy of the generic HASP by
contacting:
ERC - Health and Safety
U.S. EPA/ERT
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
Attention: Generic HASP
Single copies are available without charge.
Requestors must specify their desired disk size
(i.e., either 3 1/2 or 5 1/4 inch disk) and whether a
high density or double density disk is preferred.
Health and Safety Audit Guidelines
ERT has developed step-by-step guidance
for evaluating the comprehensiveness and efficacy
of the preliminary evaluation and the HASP for
activities at uncontrolled hazardous wastes sites.
These "Health and Safety Audit Guidelines" may
be used in conducting a health and safety site
audit, or simply to assist OSC/RPMs in
determining whether a HASP is likely to comply
with the HAZWOPER requirements.
A copy of the "Health and Safety Audit
Guidelines" (Publication Number EPA/540/G-
89/010) may be obtained by calling the National
Technical Information Service at (703) 487-4600.
Additional Sources of Information
The following is a brief summary of where
to obtain additional information on the
HAZWOPER standards. Please refer to Exhibit 8
for the appropriate addresses and telephone
numbers of the contacts referenced below.
• If you have questions regarding the existing
relationship between EPA and OSHA with
respect to the implementation of the
standards, contact the ERT in Edison, NJ.
• For information about EPA's training
courses, contact ERTs Operations Section
in Cincinnati, OH.
• For information and guidance on the
substance of 29 CFR 1910.120, contact the
appropriate OSHA Regional office. If
additional information is needed, contact
the OSHA Office of Health Compliance
Assistance in Washington, D.C.
• For information on how to obtain technical
assistance from OSHA, contact the
appropriate OSHA Regional office. (Refer
to Exhibit 8 for appropriate addresses and
telephone numbers.)
• There are four other HAZWOPER Fact
Sheets that are available:
Hazardous Waste Operations and
Emergency Response: General
Information and Comparison (Pub.
No. 9285.2-09FS) explains the scope
of the HAZWOPER standards, and
distinguishes them from regulations
and consensus standards covering the
same or similar subject matter;
Hazardous Waste Operations and
Emergency Response: RCRA TSD
and Emergency Response Without
Regard to Location (Pub. No. 9285.2-
07FS) explains the principal
HAZWOPER requirements for
emergency response without regard
to location and routine hazardous
waste operations at RCRA TSD
facilities.
52
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Ho/A Zo/n'i af
Uncontrolled Hazardous Waste Sites
(Pub. No. 9235.2-06FS) describes the
requirements and procedures for
establishing support zones at
uncontrolled hazardous waste sites.
Hazardous Waste Operations and
Emergency Response: Available
Guidance (Pub. No. 9285.2-lOFS)
describes guidance materials
developed b\ the Environmental
Response Team of EPA to help
workers engaged in hazardous waste
operations and emergency response
understand the HAZWOPER
requirements.
Copies of these Fact Sheets may be
obtained by calling or writing ERT in Edison, NJ.
Please specify the title and directive number of the
Fact Sheet(s). (Refer to Exhibit 8 for the
appropriate address and telephone number.)
EXHIBIT 8
Important Telephone Numbers and Addresses
U.S. EPA/ERT
2590 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or (FTS) 340-6740
U.S. EPA/ERT
Operations Section
26 West Martin Luther King
Cincinnati, OH 45268
(513) 569-7537 or (FTS) 684-7537
• U.S. Department of Labor, OSHA
Office of Health Compliance Assistance
200 Constitution Avenue, NW
Washington, D.C 20210
(202) 523-8036 or (FTS) 523-8036
• U.S. Department of Labor, OSHA
Publications Office
Room N 3101
200 Constitution Avenue, NW
Washington, D.C. 20210
(202) 523-9667
OSHA Regional Offices
• U.S. Department of Labor, OSHA
Region 1
133 Portland Street, 1st Floor
Boston, MA 02114
(617) 565-7164 or (FTS) 835-7164
U.S Department of Labor, OSHA
Region 2
201 Vanck Street, Room 670
New York, NY 10014
(212) 337-2325 or (FTS) 660-2378
U.S. Department of Labor, OSHA
Region 3
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
(215) 596-1201 or (FTS) 596-1201
U S Department of Labor, OSHA
Region 4
1375 Peachtree Street, NE, Suite 587
Atlanta, GA 30367
(404) 347-3573 or (FTS) 257-3573
U.S. Department of Labor, OSHA
Region 5
230 South Dearborn Street
32nd Floor, Room 3244
Chicago, IL 60604
(312) "353-2220 or (FTS) 353-2220
U.S. Department of Labor, OSHA
Region 6
525 Griffin Street, Room 602
Dallas, TX 75202
(214) 767-4731 or (FTS) 729-4731
U.S. Department of Labor, OSHA
Region 7
911 Walnut Street
Kansas City, MO 64106
(816) 426-5861 or (FTS) 867-5861
53
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EXHIBIT 8 (continued)
Important Telephone Numbers and Addresses
QSHA Regional Offices (continued)
• U.S. Department of Labor, OSHA
Region $
1951 Stout Street
Denver, CO 80204
(303) 844-3061 or (FTS) 564-3061
• U.S. Department of Labor, OSHA
Region 9
71 Stevenson Street, Suite 415
San Francisco, CA 94105
(415) 744-6670 or (FTS) 454-6670
• U.S. Department of Labor, OSHA
Region 10
1111 Thud Avenue, Suite 715
Seattle, WA 98101-3212
(206) 442-5930 or (FTS) 399-5930
EPA Regional Offices
• U.S Environmental Protection Agency
Region 1
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3715 or (FTS) 835-3715
• U.S. Environmental Protection Agency
Region 2
Jacob K- Javitz Federal Building
26 Federal Plaza
New York, NY 10278
(212) 264-2657 or (FTS) 264-2657
U.S. Environmental Protection Agency
Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800 or (FTS) 597-9800
• U.S. Environmental Protection Agency
Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727 or (FTS) 257-4727
U.S. Environmental Protection Agency
Region 5
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000 or (FTS) 353-2000
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue, 9th Floor
Dallas, TX 75202
(214) 655-6444 or (FTS) 255-6444
U.S. Environmental Protection Agency
Region 7
726 Minnesota Avenue
Kansas City, KS 66115
(913) 551-7000 or (FTS) 276-7000
U.S Environmental Protection Agency
Region 8
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1603 or (FTS) 293-1603
U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322
U.S. Environmental Protection Agency
Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-1200 or (FTS) 399-1200
Call the Emergency Planning and
Community Right-to-Know Information
Hotline for the addresses and telephone
numbers of state emergency response
commissions and local emergency planning
committees in your area. The telephone
numbers for the Hotline are: toll-free
800-535-7672, or 202-475-9652 in the
Washington, D.C. area.
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SECTION 3
QUICK REFERENCE FACT SHEETS
PARTS
HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
GENERAL INFORMATION AND COMPARISON
55
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-a EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9285.2-09FS
April 1991
Hazardous Waste Operations
and Emergency Response:
General Information and Comparison
Office of Emergency and Remedial Response
Emergency Response Division MS>-101
Quick Reference Fact Sheet
INTRODUCTION
Under the authority of section
126 of the Superfund Amend-
ments and Reauthorization Act
of 1986 (SARA Title I), the
U.S. Environmental Protection
Agency (EPA) and the U.S.
Occupational Safety and
Health Administration (OSHA) issued identical
health and safety standards to protect workers
engaged in hazardous waste operations and
emergency response. The OSHA regulations,
codified al 29 CFR 1910.120, became effective on
March 6, 1990 (54 FR 9294). Corrections to these
regulations were published on April 13, 1990 (55
FR 14072) to clarify certain medical surveillance
requirements and to identify which employers must
comply with 29 CFR 19l0.120(p). The EPA
regulations, published on June 23, 1989 at 54 FR
26654, incorporate the OSHA standards by
reference and are codified at 40 CFR Part 311.
The EPA and OSHA worker protection
standards for hazardous waste operations and
emergency response (HAZWOPER) affect
employers whose employees are engaged in the
following activities:
• Clean-up operations at uncontrolled
hazardous waste sites when a government
authority requires the cleanup (29 CFR
Corrective actions at treatment, storage,
and disposal (TSD) facilities regulated
under the Resource Conservation and
Recovery Act (RCRA) (29 CFR
57
Voluntary clean-up operations at
uncontrolled hazardous waste sites (29 CFR
• Hazardous waste operations conducted at
RCRA TSD facilities (29 CFR
1910.120(a)(iv)); and
• Emergency response operations without
regard to location, where there is the
release or a substantial threat of release of
a hazardous substance (29 CFR
1910.120(a)(v)).
The purpose of this Fact Sheet is to explain
the scope and purpose of the worker protection
standards issued under SARA Title I, and to
distinguish these standards from other regulations
and consensus standards covering the same or
similar subject matter. This Fact Sheet is also
designed to facilitate compliance with the
HAZWOPER requirements by helping employers
and other interested readers to understand their
special responsibilities under these worker
protection standards. For a summary of the
HAZWOPER requirements, refer to Exhibit 1.
This Fact Sheet is divided into five sections.
Section one gives a brief legislative history of the
EPA and OSHA worker protection standards for
hazardous waste operations and emergency
response, and explains the responsibilities of these
two agencies in implementing the standards.
Sections two, three, and four compare the 1910.120
standards with other programs governing the same
kinds of activities. Finally, section five explains
how to obtain the publications discussed in this
Fact Sheet.
Printed on Recycled Paper
-------
EXHIBIT 1
The Worker Protection Standards
for Hazardous Waste Operations and
Emergency Response
(29 CFR 1910.120)
(a) Scope, application, and definitions
(b) Safety and heahh program
(c) Site characterization and analysis
(d) Sue control
(e) Training
(f) Medical surveillance
(g) Engineering controls, work practices, and
personal protective equipment for employee
protection
(h) Monitoring
(i) Informational programs
(j) Handling drums and containers
(k) Decontamination
(1) Emergency response by employees at
uncontrolled hazardous waste sues.
(m) Illumination
(n) Sanitation at temporary workplaces
(o) New technology programs.
(p) Certain operations conducted under the
Resource Conservation and Recovery Act of
1976.
(q) Emergency response to hazardous substance
releases by employees not previously covered.
Overview of EPA and
OSHA Worker
Protection Authority
The Occupational Safety and
Health Act of 1970, as
amended, (OSH Act) established health and safety
standards for the American workplace. Section 6
of the OSH Act established Federal authority to
issue general health and safety standards for
private industry; section 19 addresses standards for
Federal government employees. Under the
authority of section 6 of the OSH Act, OSHA
promulgated general industry standards and
standards that apply specifically to the construction
industry; these standards are codified at 29 CFR
1910 and 1926, respectively. These standards set
forth the minimum health and safety requirements
necessary to ensure protection for M private sector
employees in the United States. The scope of the
coverage of the standards set forth in 29 CFR 1910
and 1926 changed dramatically on February 26,
1980, when President Jimmy Carter signed
Executive Order 12196, requiring the Federal
government to comply with the more stringent
general industry standards issued under section 6
of the OSH Act.
SARA section 126(a) requires the Secretary
of Labor to issue health and safety standards under
section 6 of the OSH Act for the benefit of private
sector employees - and through the Executive
Order, Federal employees — engaged in hazardous
waste operations and emergency response. Federal
OSHA has no authority to enforce regulations
protecting state and local government employees.
Under section 18 of the OSH Act, a state
may elect to develop and implement its own
occupational safety and health program if: (1) the
state is willing to document its program in a state
plan, and (2) the state's requirements are at least
as stringent as the Federal regulations. Before a
state program can become effective, however,
OSHA must review and approve the state plan.
Through its review and approval authority, OSHA
requires states to extend occupational safety and
health protection to state and local government
employees, as well as to private sector employees,
within the state's jurisdiction. Currently, there are
23 states and two territories with delegated OSHA
programs. These state plans must be amended to
incorporate the newly promulgated standards in 29
CFR 1910.120, to address the safety and health of
employees engaged in hazardous waste operations
and emergency response.
SARA section 126(f) requires the EPA
Administrator to issue standards for hazardous
waste operations and emergency response that are
identical to OSHA's standards. Although the two
sets of standards contain identical substantive
provisions, EPA and OSHA address different
audiences. EPA's authority extends to state and
local government employers conducting hazardous
waste operations and emergency response in states
58
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that do not have in effect a delegated OSHA
program. Currently, 27 states, one territory, and
the District of Columbia fall under EPA's
authority. The EPA regulations cover both
compensated and uncompensated state and local
government employees engaged in the covered
activities. Therefore, the EPA standards protect
volunteers, such as volunteer fire fighters who are
responding to hazardous substance emergencies.
AJ though Federal OSHA recommends that
delegated state programs also cover
uncompensated employees, not all states have
followed this recommendation.
In summary, in states without an OSHA-
approved plan, Federal OSHA standards protect
all private sector and Federal employees engaged
in hazardous waste operations and emergency
response; the EPA worker protection standards
protect all state and local government employees,
including volunteer workers. In states with an
OSHA-approved plan, the state program covers all
private sector employees, as well as state and local
government employees; Federal OSHA covers
Federal employees in those states. The shaded
area in Exhibit 2 shows jurisdictions wilhout an
OSHA-delegated program.
Inter-Agency Agreement
EPA and OSHA have an agreement to
share responsibility for implementing the Title I
worker protection standards. Under the terms of
this agreement, OSHA performs the following
activities:
• Support of the National Response Team and
Regional Response Teams.
• Technical Assistance. OSHA advises EPA
on the types of actions EPA should take at
uncontrolled hazardous waste sites to
ensure full compliance with the
HAZWOPER requirements. As an advisor,
OSHA will identify problems that EPA may
face and suggest appropriate solutions.
• Compliance Activities. OSHA conducts
inspections and takes enforcement actions
to ensure compliance with the worker
protection standards at Superfund sites.
• Implementation Activities. OSHA supports
EPA in conducting workshops to explain
the requirements of the standards, and
provides official interpretations of the
health and safety requirements.
EXHIBIT 2
Shaded States Do Not Have Delegated OSHA Programs
59
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If you have questions on the substance of
the worker protection standards for
hazardous waste operations and emergency
response, contact an OSHA Regional Office
or OSHA's Office of Health Compliance
Assistance in Washington, D.C. Refer to
Exhibit 4 for relevant addresses and
telephone numbers.
The next three sections of this Fact Sheet
compare OSHA's health and safety standards for
hazardous waste operations and emergency
response with several related regulations,
standards, and guidelines developed by OSHA,
EPA, and the National Fire Protection Association
(NFPA). Be aware that in the context of this
discussion, we will talk about "hazardous
substances," "extremely hazardous substances"
(EHSs), "hazardous materials," "hazardous wastes,"
and "highly hazardous chemicals." Each of these
terms means something different, and the
regulatory programs that employ them are
intended to prevent or mitigate the effects from
exposure to a distinct set of hazardous chemicals.
Comparing Regulatory
Requirements Under
SARA Title I, SARA
Title III, and OSHA's
Proposed Rule on Highly
Hazardous Chemicals
SARA Title I
Under the authority of Title I, section 126
of SARA, EPA published worker protection
standards for hazardous waste operations and
emergency response (HAZWOPER).
HAZWOPER specifies certain health and safety
requirements to ensure the protection of
employees engaged in hazardous waste operations
and emergency response during five specified.
activities (see page 1 of this Fact Sheet).
HAZWOPER does not address emergency
responders who engage only in handling traditional
fire and medical emergencies; other OSHA
programs protect these employees. HAZWOPER,
however, requires that an employer provide, among
other things, proper emergency response planning,
training, and medical surveillance. Affected
workers must be protected during the entire
remedial process, from the preliminary evaluation
and initial site entry to final closure of the site.
Emergency Response Planning. An employer
must develop an emergency response plan to
protect workers in an emergency resulting from the
release of all kinds of hazardous substances,
including EHSs, CERCLA hazardous substances,
RCRA hazardous wastes, and any substance listed
by the U.S. Department of Transportation as a
hazardous material.
Training. An employer also must ensure
that workers receive the kind of training specified
in the regulation. The standard reflects a tiered
approach to training, linking the amount and type
of training to an employee's potential for exposure
to hazardous substances and to other health
hazards during a hazardous waste operation or an
emergency response. The greater the potential
hazard, the more extensive and stringent are the
training requirements.
Medical Surveillance.
HAZWOPER
establishes a framework for a medical monitoring
program for certain workers engaged in hazardous
waste operations and emergency response. The
medical surveillance requirements include
provisions for a baseline, periodic, and termination
medical examination for specific groups of
employees. HAZWOPER also requires that
employees receive a medical examination as soon
as possible if they are injured or become ill from
exposure to hazardous substances on-site or during
an emergency, or develop signs or symptoms that
indicate a possible overexposure to hazardous
substances. Although an attending physician may
determine the content of medical examinations
required under the standard, the examination must
address key elements related to handling hazardous
substances.
SARA Title HI
SARA Title III, or the Emergency Planning
and Community Right-to-Know Act, is a law
enacted to improve state and local government
capacity to respond to an emergency caused by an
accidental release of an EHS; and to disseminate
information to the public on dangerous chemicals
made, used, or stored in their community.
Think of this law as having four main parts.
The first part, sections 302 and 303, requires each
state to create a State Emergency Response
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Commission (SERC). In turn, these SERCs must
create Local Emergency Planning Committees
(LEPCs) that correspond to local emergency
planning districts. LEPCs develop and update
emergency response plans for accidents involving
EHSs; and receive, manage, and provide public
access to information about toxic and other
hazardous substances in the district. SERCs
review emergency response plans, and generally
supervise and coordinate LEPC activities.
The second part of SARA Title III (section
304) sets out emergency release reporting
requirements. Under this part of the law, the
owner or operator of a facility from which an EHS
or CERCLA hazardous substance is released at or
above a reportable quantity (RQ) must notify
SERCs and LEPCs in the affected area by
telephone. There must be a written follow-up
report to this immediate notification. Both the
initial and follow-up reports must give details on
known or anticipated health risks and advice
regarding medical attention.
The third part of SARA Title III (sections
311 and 312) gives people the right to know what
substances are being made, used, or stored in their
communities. The OSHA Hazard Communication
Standard (HCS) requires owners and operators to
keep "material safety data sheets" (or MSDSs) with
information about the health hazards of chemicals
at the facility, and to make these MSDSs available
to their employees. SARA Title III piggy-backs on
the MSDS requirements in the HCS. Under
SARA Title III, the owner or operator also must
send copies of MSDSs, or lists of chemicals with
MSDSs, to SERCs, LEPCs, and fire departments.
LEPCs, in turn, make this information available to
the public during normal business hours.
The final part of SARA Title III (section
313) requires certain owners and operators to
report toxic substances released from theii facility
-- whether the release is routine or accidental; and
to report toxic substances they transport to
another site as waste.
Of these four pans, the one that most
closely parallels the SARA Title I worker
protection standards is the part dealing with
emergency response planning (section 303). There
are nine emergency response planning elements in
section 303 of SARA Title III. Although these
planning elements do not correspond point-for-
point with the emergency response planning
elements in the worker protection standards issued
under SARA Title I, each program covers similar
subjects. Title I (HAZWOPER) and Title III
emergency response planning elements both:
• Highlight the need for planning before there
is an emergency;
• Require planners to identify emergency
response decision-makers and other
personnel;
• Require planners to develop guidelines for
recognizing and evaluating releases;
• Require evacuation planning;
• Require that the emergency response plan
set out an orderly sequence of steps to
follow in an emergency;
• Direct planners to specify equipment that
may be needed for various levels and types
of emergencies; and
• Require testing the plan and providing
appropriate training for emergency
responders.
On the other hand, there are some
important differences in emergency response
planning requirements under Title I and Title III.
For example, a Title I plan must address a number
of chemical hazards, while a Title III plan must
cover only those emergencies arising from the
release of an EHS. Further, a plan to protect
employees under Title I may require far more
specificity than a Title III plan. Although a Title
III plan may be too general for use as an
employer's Title I plan, the Title I plan may
reference the Title III plan to avoid any
unnecessary duplication of information. If a Title
III plan is referenced, a copy of the referenced
document must be kept with the Title I plan.
The most important thing to remember in
distinguishing Title I and Title III emergency
response planning is that Title I plans focus on
worker safety; Title III plans focus on community
safety. The similarities and differences between
the Title I and Title III emergency response
planning requirements are addressed in greater
detail in a paper entitled "SARA Title I/Title III
Emergency Response Planning Requirements." To
obtain a copy of this document, contact the
Environmental Response Team (ERT) of EPA in
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Edison, New Jersey. (Refer to Exhibit 4 for the
appropriate address and telephone number.)
OSHA's Highly Hazardous Chemicals NPRM
On July 17,1990, OSHA published a Notice
of Proposed Rulemaking (NPRM), proposing a
new regulation entitled "Process Safety
Management of Highly Hazardous Chemicals" (55
FR 29150). The NPRM proposes requirements
that will eliminate or mitigate the harm to
employees as a consequence of chemical releases
during the manufacturing or processing of highly
hazardous chemicals. OSHA's proposed rule
emphasizes management of hazards associated with
highly hazardous chemicals, and defines a "highly
hazardous chemical" as:
A substance possessing toxic, flammable,
reactive, or explosive properties.
The NPRM identifies 140 highly hazardous
chemicals and proposes threshold quantities for
each of the listed chemicals. The proposed
requirements are similar to the worker protection
standards issued under SARA Title I and the self-
implementing provisions of SARA Title III in that
each of these programs contains requirements for
emergency response planning and employee
training.
The NPRM requires an employer to
establish and implement an emergency action plan
under 29 CFR 19l0.38(a). An emergency action
plan must include an evacuation plan through
which an employer identifies persons responsible
for an orderly exit and work area check in the
event of an emergency, and directs employees to
leave an emergency incident site, maintain a safe
distance, and call an appropriate emergency
response organization. However, if an employer's
highly hazardous chemical operation falls within
one of the activities covered by HAZWOPER, the
emergency response planning elements of 1910.120
apply. (Under HAZWOPER, an employer also
may prepare a 1910.38(a) plan if the employer
does not allow employees to respond to an
emergency. If employees are allowed to respond,
however, a more detailed emergency response plan
is required.) Title I, Title III, and the Highly
Hazardous Chemicals NPRM also require training
for workers commensurate with their assigned
duties.
Comparing General
Requirements Under 29
CFR Parts 1910 and
1926 with the Particular
Requirements of 29 CFR
1910.120
The occupational safety and health
standards published in 29 CFR set out minimum
requirements to ensure protection for all private
sector employees in the United States. The
general industry standards contained in Part 1910
of Title 29 were derived largely from standards
developed by industry consensus organizations and
non-OSHA Federal safety and health standards.
The 1910 requirements reflect practices already
recognized in most industrial sectors before there
was an Occupational Safety and Health
Administration. Part 1910, however, makes those
practices mandatory.
Many of the Part 1910 standards set out
generic specifications for worker tools, tolerances
and specifications for industrial structures,
requirements for installing equipment that make
the workplace safer (e.g., sprinkler systems), rules
for providing medical attention, and other general
health and safety practices applicable to all types
of employment. Other sections in Part 1910,
however, are specific to an identified activity or
industry; HAZWOPER is an example of the latter
type of standard.
Section 1910.120 (HAZWOPER) contains
specific requirements to minimize the health and
safety hazards associated with conducting
hazardous waste operations and emergency
response at uncontrolled hazardous waste sites and
RCRA TSD facilities, and performing emergency
response operations without regard for location.
In some instances, 1910.120 incorporates general
worker protection provisions by reference. For
example, 19l0.120(g), Engineering controls, work
practices, and personal protective equipment for
employee protection, requires employers engaged in
hazardous waste operations and emergency
response to follow the provisions in 1910.94
through 1910.100 in setting up 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
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response during the covered activities and
locations.
ft
If ever there appears to be a conflict
between the general industry standards in
1910 or 1926 and HAZWOPER, the
HAZWOPER requirements take precedent
during the covered activities.
In addition to the requirements set forth
under Part 1910, OSHA codified regulations in 29
CFR 1926 Subpart C that set forth safety and
health standards specifically applicable to the
construction industry. Pan 1926 Subpart C
includes safety standards for worker tools, and
other standards relevant to health and safety in the
construction environment (e.g., 29 CFR 1926.21
addresses programs for the education and training
of employees and employers).
Parts 1910 and 1926 both require employers
to provide whatever training and education is
appropriate for employees to perform a given task
safely. Appendix B in EPA's Health and Safety
Audit Guidelines briefly summarizes the OSHA
standards in 1910 and 1926 that may be most
applicable to hazardous waste site activities;
Exhibit 3 presents a list of these OSHA standards.
For additional information on the standards listed
in Exhibit 3 or on other OSHA standards, contact
your local OSHA Regional Office. (Refer to
Exhibit 4 for relevant addresses and telephone
numbers.)
Comparing the Section
1910.120 Standards and
the NFPA's Hazardous
Materials Incidents
Publications
Private organizations sometimes publish
consensus documents addressing subject matter
covered in Federal regulations. The National Fire
Protection Association (NFPA) has published two
highly relevant documents: Recommended Practice
for Responding to Hazardous Materials Incidents
(NFPA 471), and Standard for Professional
Competence of Responders to Hazardous Materials
Incidents (NFPA 472). The NFPA standards are
not Federal regulations.
EXHIBIT 3
Other Potentially Applicable
OSHA Standards
(by section in 29 CFR)
1910.20 Access lo Employee Exposure and
Medical Records
1910.24 Fixed Industrial Stairs
1910.27 Fixed Ladder,
1910.28 Safety Requirements for Scaffolding
1910.38 Employee Emergency Plans and
Fire Prevention Plans
1910.57 Ventilation
1910.95 Occupational Noise Exposure
1910.101 Compressed Cases
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 Ser\'ices and First Aid
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
192659 Hazard Communication
1926.151 Fire Prevention
1926.152 Flammable and Combusnb/e
Liquids
1926.200 Accident Prevention Signs and Tags
1926.301 Hand Tools
1926.651 Specific Excavation Requirements
1926.652 Trenching Requirements
NFPA 471 offers guidance in identifying the
minimum competencies a responsible authority
should attain before responding to a hazardous
materials incident, and specifies operating
guidelines for a response. Like HAZWOPER,
NFPA 471 covers, among other things, planning
for an emergency response, ensuring that
responders have the proper equipment at their
disposal, and conducting an emergency response.
NFPA 472 is a competency standard for
workers who respond to hazardous materials
incidents. NFPA 472 training criteria differ from
the 1910.120 standards in that the former do not
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establish specific hourly training requirements for
emergency response personnel. There is no
Incident Commander category in NFPA 472, but
an Appendix to the standard does identify the role
of an Incident Commander.
Indeed, the NFPA publications on
hazardous materials incident response are similar
in approach and breadth of coverage to
HAZWOPER. In many instances, NFPA
references the Federal standards. You must
remember, however, that although the NFPA
documents provide useful guidance to emergency
response planners and responders, only the EPA
and OSHA standards are mandatory Federal
standards. If your organization falls within the
scope of 29 CFR 1910.120, you must comply.
Therefore, in any conflict between the NFPA
Standard/Practice and the Title I worker protection
standards, the Federal standards govern.
Where to Get
Information and
Publications
You can get any volume of the
CFR by contacting the U.S.
Government Printing Office (GPO) or any Federal
Depository Library in your state. To contact GPO,
call or write:
Superintendent of Documents
Government Printing Office (GPO)
Washington, D.C. 20402
(202) 783-3238
Many state college and university libraries
are also Federal Depository Libraries. For a
complete list of these libraries, ask GPO for A
Directory of U.S. Government Libraries.
OSHA offers a catalogue listing Agency-
issued publications and audiovisual aids that help
employers and other interested persons to
understand both the scope of OSHA regulations,
and specific substantive provisions in health and
safety standards. You can obtain a free copy -of
the catalogue, OSHA Publications and Audiovisual
Programs, by sending your request with a self-
addressed mailing label to:
U.S. Department of Labor, OSHA
Publications Office, Room N3101
200 Constitution Avenue, NW
Washington, D.C. 20210
To get a copy of the NFPA publications
discussed in this Fact Sheet, or to obtain additional
information on the substance of the publications,
write:
National Fire Protection Association (NFPA)
1 Batterymarch Park
P.O. Box 9101
Quincy, MA 02269-9904
For additional information on the SARA
Title III requirements, contact the Emergency
Planning and Community-Right-to-Know Hotline.
The telephone numbers for the Hotline are: toll-
free 800-535-7672, or 202-475-9652 in the
Washington, D.C. area.
Currently, there are four other Fact Sheets
that are available on the worker protection
standards for hazardous waste operations and
emergency response:
Hazardous Waste Operations and
Emergency Response: Uncontrolled
Hazardous Waste Sites and RCRA
Corrective Action (Pub. No. 9285.2-
08FS) explains the specific
requirements for hazardous waste
operations conducted at uncontrolled
hazardous waste sites, including
corrective actions at RCRA TSD
facilities.
Establishing Work Zones at
Uncontrolled Hazardous Waste Sites
(Pub. No. 9285.2-06FS) describes the
requirements and procedures for
establishing support zones at
uncontrolled hazardous waste sites.
Hazardous Waste Operations and
Emergency Response: RCRA TSD
and Emergency Response Without
Regard to Location (Pub. No. 9285.2-
07FS) describes the principal
requirements of the standards for
hazardous waste operations at RCRA
TSD facilities and emergency
response operations without regard
to location.
Hazardous Waste Operations and
Emergency Response: Available
Guidance (Pub. No. 9285.2-10FS)
describes guidance materials
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developed by the Environmental
Response Team to help workers
engaged in hazardous waste
operations and emergency response
understand the HAZWOPER
requirements.
Copies of these Fact Sheets may be
obtained by calling or writing the Environmental
Response Team of EPA in Edison, New Jersey.
(Refer to Exhibit 4 for the appropriate address and
telephone numbers.) Please specify the title and
publication number of the Fact Sheet(s).
EXHIBIT 4
Important Telephone Numbers and Addresses
• U.S. EPA/ERT
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or (FTS) 340-6740
• U.S. Department of Labor, OSHA
Office of Health Compliance Assistance
200 Constitution Avenue, NW
Washington, D.C 20210
(202) 523-8036 or (FTS) 523-8036
OSHA Regional Offices
• U.S. Department of Labor, OSHA
Region 1
133 Portland Street, 1st Floor
Boston, MA 02114
(617) 565-7164 or (FTS) 835-7164
• U.S. Department of Labor, OSHA
Region 2
201 Varick Street, Room 670
New York, NY 10014
(212) 337-2325 or (FTS) 660-2378
• U.S. Department of Labor, OSHA
Region 3
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
(215) 596-1201 or (FTS) 596-1201
• U.S. Department of Labor, OSHA
Region 4
1375 Peachtree Street, NE, Suite 587
Atlanta, GA 30367
(404) 347-3573 or (FTS) 257-3573
U.S. Department of Labor, OSHA
Region 5
230 South Dearborn Street
32nd Floor, Room 3244
Chicago, IL 60604
(312) 353-2220 or (FTS) 353-2220
U.S. Department of Labor, OSHA
Region 6
525 Griffin Street, Room 602
Dallas, TX 75202
(214) 767-4731 or (FTS) 729-4731
U.S. Department of Labor, OSHA
Region 7
911 Walnut Street
Kansas City, MO 64106
(816) 426-5861 or (FTS) 867-5861
U.S. Department of Labor, OSHA
Region 8
1951 Stout Street
Denver, CO 80204
(303) 844-3061 or (FTS) 564-3061
U.S. Department of Labor, OSHA
Region 9
71 Stevenson Street, Suite 415
San Francisco, CA 94105
(415) 744-6670 or (FTS) 484-6670
U.S. Department of Labor, OSHA
Region 10
1111 Third Avenue, Suite 715
Seattle, WA 98101-3212
(206) 442-5930 or (FTS) 399-5930
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EXHIBIT 4 (continued)
Important Telephone Numbers and Addresses
EPA Regional Offices
U.S. Environmental Protection Agency
Region 1
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3715 or (FTS) 835-3715
U.S. Environmental Protection Agency
Region 2
Jacob K Javitz Federal Building
26 Federal Plaza
New York, NY 10278
(212) 264-2657 or (FTS) 264-2657
U.S. Environmental Protection Agency
Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800 or (FTS) 597-9800
U.S. Environmental Protection Agency
Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727 or (FTS) 257-4727
U.S. Environmental Protection Agency
Region 5
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000 or (FTS) 353-2000
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue, 9th Floor
Dallas, TX 75202
(214) 655-6444 or (FTS) 255-6444
U.S. Environmental Protection Agency
Region 7
726 Minnesota Avenue
Kansas City, KS 66115
(913) 551-7000 or (FTS) 276-7000
U.S. Environmental Protection Agency
Region 8
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1603 or (FTS) 293-1603
U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322
U.S. Environmental Protection Agency
Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-1200 or (FTS) 399-1200
Call the Emergency Planning and
Community Right-to-Know Information
Hotline for the addresses and telephone
numbers of state emergency response
commissions and local emergency planning
committees in your area. The telephone
numbers for the Hotline are: toll-free
800-535-7672, or 202-475-9652 in the
Washington, D.C. area.
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SECTION 3
QUICK REFERENCE FACT SHEETS
PART 6
HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
AVAILABLE GUIDANCE
67
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EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9285 2-10FS
April 1991
Hazardous Waste Operations
and Emergency Response:
Available Guidance
Office of Emergency and Remedial Response
Emergency Response Division MS-101
Quick Reference Fact Sheet
INTRODUCTION
The U.S. Environmental Protection
Agency (EPA) and ihe U.S.
Occupational Safety and Health
Administration (OSHA) have issued
identical health and safety standards
to protect workers engaged in hazardous waste operations
and emergency response (HAZWOPER) The EPA
regulations are codified at 40 CFR Part 311 (54 FR
6654). The OSHA regulations are codified at 29 CFR
1910.120 (54 FR 9294 and 55 FR 14072).
The Environmental Response Team (ERT) at
EPA developed this Fact Sheet to alert interested parties
to the availability of guidance materials that will help
employers, employees, On-Scene Coordinators (OSCs),
and Remedial Project Managers (RPMs) to better
understand and comply with the new HAZWOPER
standards. This Fact Sheet is organized into four
sections, representing the four distinct formats used to
present information about the new requirements: (1)
Software; (2) HAZWOPER Fact Sheets; (3) Guidance
Documents; and (4) Training. Exhibit 1 presents at a
glance the various guidance that is described m this Fact
Sheet.
COMPUTER SOFTWARE
Two major ERT software systems are
currently available for HAZWOPER.
The topics addressed by these systems
are discussed below and are listed in
Exhibit 2.
Health and Safety Planner (U.S. EPA, 1990)
The Health and Safety Planner (HASP) — often
called the generic health and safety plan — is a menu-
driven computerized software system designed to assist
health and safety officers in designing, implementing, and
updating a site health and safety plan. HASP contains
several valuable data bases that include information on
chemical hazards associated with many of the chemicals
typically found at an uncontrolled hazardous waste site.
HASP allows the user to retrieve data on chemical
hazards, suggests appropriate monitoring devices,
identifies likely routes of exposure, and recommends
levels of personal protective equipment based on those
hazards and the tasks that will be performed at the sue
HASP also includes standard protocols for typical
assessment and remediation activities. Finally, HASP
uses standard text components to actually produce a site-
specific health and safety plan, addressing the potential
hazards identified for the site. The health and safety plan
format generated by HASP is consistent with OSHA's 29
CFR 1910.120 requirements. HASP is available on either
3'A" or SVi" diskettes, for either double density or high
density disk drives; it runs on most IBM-compatible
personal computers, and it comes with a User's Guide
(OSWER Directive 9285.8-01).
Field Certification Tracking System (U.S. EPA, 1989)
The Field Certification Tracking System (FCTS)
is a computerized software system that simplifies the
recordkeepmg associated with the health and • safety
requirements under HAZWOPER. The system creates
personnel files, updates the personnel files, and produces
personnel reports. FCTS is essentially a tracking system,
it cannot be used to identify training and medical
monitoring requirements, but rather allows the user to
specify the requirements and to track the employee's
fulfillment of those requirements. Employees working at
a location, for example, may be grouped into categories,
such as HAZMAT Team Member, routine site worker, or
first responder, and then training and medical monitoring
requirements for each worker or each category of workers
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EXHIBIT 1
Available Guidance
Computer Software
Health and Safety Planner (HASP)
Field Certification Tracking System (FCTS)
HAZWOPER Fact Sheets
Hazardous Waste Operations and Emergency Response
General Information and Comparison
Hazardous Waste Operations and Emergency Response
Uncontrolled Hazardous Waste Sues and RCRA
Corrective Action
Hazardous Waste Operations and Emergency Response
RCRA TSD and Emergency Response Without Regard to
Location
Establishing Work Zones at Uncontrolled Hazardous
Waste Sites
Guidance Documents
Hazmat Team Planning Guidance
Occupational Medical Monitoring Program Guidelines for
SARA Hazardous Waste Field Activity Personnel
Health and Safely Audit Guidelines
Standard Operating Safety Guides
Field Standard Operating Procedures
Training
Hazardous Materials Incident Response Training Program
Course Schedule
EXHIBIT 2
Computer Software
Health and Safety Planner
Identification of chemical hazards
Selection of monitoring devices
Identification of likely routes of exposure
Selection of personal protective equipment
Field Certification Tracking System
Simplification of recordkeeping for field personnel
Creation of personnel files for health and safety
requirements
Updating of personnel files
must be input into the FCTS system. The training and
medical monitoring requirements entered for each
employee may be more or less stringent than those
specified in 29 CFR 1910.120. Thus, although all affected
employees must comply with the training and medical
monitoring requirements in 29 CFR 1910.120, FCTS
provides the user with flexibility regarding the elements
that will be tracked. Once a personnel file is created, the
system can be used to list the required training for an
employee's category, update an employee's file to reflect
newly acquired training, and target personnel files to
identify employees who are overdue for a particular type
of training. FCTS is available on either 3!/i" or 5VV
diskettes, for either double density or high density disk
drives, it runs on most IBM-compatible personal
computers, and it comes with a User's Guide (OSWER
Directive 92853-03).
HAZWOPER FACT SHEETS
Currently, there are four available
ERT Fact Sheets (in addition to this
one) that provide guidance on the
HAZWOPER requirements. The
topics addressed by these Fact Sheets
are discussed below and are presented in Exhibit 3.
Hazardous Waste Operations and Emergency Response:
General Information and Comparison (U.S. EPA, 1991,
Pub. No. 9285.2-09FS)
This Fact Sheet explains the scope and purpose
of the HAZWOPER standards, and distinguishes the
Title 1 standards from regulations and consensus
standards covering the same or similar subject matter.
Specifically, this Fact Sheet provides a brief legislative
history of HAZWOPER, and compares it with other
programs governing the same kinds of activities, such as
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EXHIBIT 3
IIAZWOPER Fact Sheets
General Information and
Comparison
Overview of EPA and OSHA Authority
Comparing Regulatory Requirements
Comparing General Requirements
NFPA's Hazardous Materials Incidents Publications
Sources of Additional Information
Uncontrolled Hazardous Waste Sites
and RCRA Corrective Aclion
Planning Requirements
Training Requirements
Medical Surveillance Requirements
Other Requirements
Employee Rights
Sources of Additional Information
RCRA TSD and Emergency
Response Without Regard to location
Requirements for Planning, Training, and Medic.il
Surveillance for Emergency Response Without
Regard to Location
Requirements for Planning, Training, and Medical
Surveillance at RCRA I'SD Facilmes
Sources of Additional Information
Establishing Work Zones at Uncontrolled
Hazardous Waste Sites
Definitions of Work Zones
Data Collection Requirements
Selection of Work Zones
Ensuring Integrity of Work Zones
Consultation and References
SARA Title III and OSHA's proposed rule on highly
hazardous substances. This Fact Sheei also discusses how
the HAZWOPER requirements relate to the industry-
specific standards at 29 CFR 1910 and the standards
applicable to the construction industry at 29 CFR 1926.
Finally, this Fact Sheet describes relevant National Fire
Protection Association (NFPA) publications and their
relationship to HAZWOPER.
Hazardous Waste Operations and Emergency Response:
Uncontrolled Hazardous Waste Sites and RCRA Corrective
Action (U.S. EPA, 1991, Pub. No. 9285.2-08FS)
This Fact Sheet explains the principle
HAZWOPER requirements as they apply to employees
engaged in hazardous waste operations and emergency
response at uncontrolled hazardous waste sites, including
employees who perform corrective actions at RCRA TSD
facilities. Specifically, this Fact Sheet describes the
relevant planning, training, and medical surveillance
requirements in HAZWOPER, including the site control
and decontamination programs, the emergency response
plan, the spill containment program, and the specific
responsibilities of the OSC/RPM and ERT. Other
requirements, such as the procedures for handling drums
and containers, illumination and sanitation requirements,
and the informational and new technology programs also
are addressed. Finally, this Fact Sheet discusses
employee rights under section 8 of the Occupational
Safety and Health Act of 1970, as amended (OSH Act).
Hazardous Waste Operations and Emergency Response:
RCRA TSD and Emergency Response Without Regard to
location (U.S. EPA, 1991, Pub. No. 9285.2-07FS)
This Fact Sheet describes the planning, training,
and medical surveillance requirements in HAZWOPER
as they apply to emergency responders regardless of
location, and employees who perform routine hazardous
waste operations at RCRA TSD facilities. The Faci
Sheet explains the applicable HAZWOPER planning and
medical monitoring requirements, as well as the five
specific levels of training required for responders to
emergencies that could occur at any location
Establishing Work Zones at Uncontrolled Hazardous Waste
Sites (U.S. EPA, 1991, Pub. No. 9285.2-06FS)
This Fact Sheet summarizes the requirements
and procedures for establishing and maintaining Support
Zones (i.e., Clean Zones) at hazardous waste sues The
Fact Sheet defines the different work zones usually found
at a hazardous waste site (i.e., Exclusion, Contamination
Reduction, and Support), describes data collection and
site characterization requirements for establishing a
Support Zone (both prior to and during initial site
entry), provides information on selecting and maintaining
work zones (i.e., data compilation and evaluation), and
provides information on maintaining the work zones (i.e.,
use of site controls, periodic monitoring of the support
zone, and other considerations). This Fact Sheet also
references a number of technical guidance documents
71
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that address some of the activities that are conducted in
establishing work zones (e.g., air monitoring).
GUIDANCE DOCUMENTS
Five major ERT guidance documents
are currently available for
HAZWOPER. The topics addressed
by these documents are discussed
briefly below and are presented in
Exhibit 4.
Hazmat Team Planning Guidance (U.S. EPA, 1990, Pub.
No. EPA/540/G-90/003)
The Hazmai Team Planning Guidance document
assists local fire departments and other response
organizations in establishing a HAZMAT Team. The
document identifies necessary equipment and suggests
ways to acquire and maintain the equipment and to train
personnel for the HAZMAT Team. The document offers
guidance in determining actual HAZMAT response
requirements, establishing the goals and levels of
expertise needed to meet those requirements, and
estimating the costs of meeting those goals. The
document also provides assistance in preparing response
plans and standard operating procedures (SOPs) The
Appendices to the document provide a summary of how
to begin the hazards analysis process and how to design
a medical program. The Appendices also contain a list
of EPA Regional Superfund training contacts and
selected guidance and reference documents.
Occupational Medical Monitoring Program Guidelines for
SAjRA Hazardous Waste Field Activity Personnel (U.S. EPA,
1990, Pub. No. OSWER Directive 9285.3-04)
This summary document provides guidelines
covering the requirements for a comprehensive
occupational medical monitoring program for personnel
involved in hazardous waste field activities. This
document outlines general medical monitoring
requirements such as the type of physician who must
perform or supervise examinations, and the procedures
required of the personnel who must undergo the
monitoring. The four types of examinations — baseline,
periodic, unscheduled, and termination — are described,
as well as reporting requirements, special requirements
(i.e., immunizations, research tests, and reproductive
hazards), and the relationship between occupational
medical monitoring and workers' compensation. The
Appendices to the document address the minimum
examination types and content, and provide guidelines for
immunization requirements. References arealso provided.
EPA Health and Safety Audit Guidelines (U.S. EPA, 1989,
Pub. No. EPA/540/G-89/010)
These Guidelines provide a representative sample
of the HAZWOPER requirements at different stages of
cleanup at an uncontrolled hazardous waste site, as well
as during emergency response operations that occur
without regard to location. Ii is in a workbook format
that provides the user with space for notes regarding the
comprehensiveness and efficacy of the written site-specific
health and safety plan, as well as the health and safety
measures being implemented in the field and during off-
site emergency response operations. The Guidelines may
be used to assist an auditor or site supervisor in
obtaining a sense of the likely level of compliance with
the HAZWOPER requirements; they, however, are not
meant to be a comprehensive compilation of all
requirements. If compliance with the specific elements in
a subsection of these guidelines is excellent, then it is
likely that all requirements under that subsection have
been met. If, on the other hand, compliance is sketchy or
weak, it is advisable to pursue additional questions and to
further investigate compliance with that subsection. The
EPA Audit Guidelines are in a simple, easy to follow,
question and answer format. The Appendices to the
document provide an incident safety check-off list, a
description of levels of personnel protection, and a log
and summary form for occupational injuries and illnesses.
Standard Operating Safety Guides (U.S. EPA, 1988,
OSWER Directive 9285.1-OIC)
The Standard Operating Safety Guides (SOSG)
provide guidelines for use by any organization in
developing its own specific operation safety procedures.
These Guides should be adapted to address the safety
criteria required for protection of response personnel
from the hazards created by a specific operation or
incident. This document is not meant to be a
comprehensive safety manual, but rather it provides
technical information that should be considered in
developing instructions on how to accomplish specific
hazardous waste operations in a safe manner.
Field Standard Operating Procedures (FSOPs)
EPA has published a series of FSOPs that
provides procedures to minimize the risk of exposure to
hazardous substances. These procedures were derived
from early drafts of EPA's Standard Operating Safety
Guides and are presented in a format that is more
appropriate for use in the field. Five of the most
relevant FSOPs are described below. i
72
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ft
EXHIBIT 4
Guidance Documents
Hazmat Team Planning Guidance
• Do you need a hazraal learn?
• Training and equipping your hazmat team
• Preparing response plans and standard operating
procedures
Occupational Medical Monitoring Program
Guidelines for SARA Hazardous Waste
Field Activity Personnel
Genera] requirements
Baseline examination
• Penodic examination
Unscheduled examination
• Termination examination
Reporting requirements
Special requirements
• Relationship between occupational medical monitoring
and workers' compensation
Minimum examination types and requirements
• Guidelines (or immunization requirements
Health and Safely Audit Guidelines
• Preliminary evaluation
• Written health and safety plan review
• Health and safety field review
• Off-site emergency response review
Standard Operating Safety Guides
• Environmental incidents
• Standard operating procedures
• Health and safety requirements
• Sue safety plan
• Initial site survey and reconnaissance
• Levels of personal protective equipmem
• Effects of stress
• Work zones
• Decontamination
• Air surveillance
Field Standard Operating Procedures
• Site entry
• Work zones
• Decontamination of response personnel
• Air surveillance
• Site safety plan
FSOP #4: Site Enlry (U.S. EPA, 1985, OSWER
Directive 9285.2-01). This document discusses site entry
procedures, including proper selection, use, and
decontamination of personal protective equipment; use of
field equipment; activities conducted during initial site
entry; and check-out procedures for a self-contained
breathing apparatus.
FSOP #6: Work Zones (U.S. EPA, 1985, OSWER
Directive 9285.2-04). This document discusses a number
of topics related to work zones, including definitions of
work zones, methodology for selecting work zone
locations, personal protective levels, and air monitoring.
FSOP #7: Decontamination of Response Personnel
(U.S. EPA, 1985, OSWER Directive 9285.2-02). This
document provides flow charts for decontamination
layouts, descriptions of personal protective equipment,
procedures for- decontamination, and lists of
decontamination equipment.
FSOP #8: Air Surveillance (U.S. EPA, 1985,
OSWER Directive 9285.2-03). This document describes
the types and methods of air surveillance, procedures and
equipment for air monitoring, and a method for analyzing
organic solvents by gas chromaiography
FSOP #9: Site Safety Plan (U.S. EPA, 1985,
OSWER Directive 9285.2-05) This document describes
the general requirements for a site safety plan, discusses
development and implementation of a site safety plan,
and provides sample plans and a checklist.
73
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TRAINING
As part of EPA's comprehensive
program for protecting the public and
the enviionmeni from releases of
hazardous materials, ERT developed
the Hazardous Materials Incident
Response Training (HMIRT) Program A list of the
HMIRT courses is provided in Exhibit 5 A schedule of
these courses is available from ERT in Cincinnati, Ohio.
EXHIBIT 5
Training
Hazardous Materials Incident Response
Training Program Schedule of Courses
Personal Protection anc Safety
Hazardous Materials Treatment Technologies
Ajr Surveillance for Hazardous Materials
Hazardous Matenals Incident Response Operations
Risk Assessment Guidance for Superfund
Introduction to Groundxvater Investigations
Safety and Health Compliance for Managers
Sampling for Hazardous Matenals
Radiation Safely ai Superfund Sites
Emergency Response to Hazardous Matenals
Incidents
Advanced Air Sampling for Ha/ardous Matenals
Removal Cosi Management System
Hazardous Materials Incident Response Training
Program Course Schedule
The HMIRT program is designed for emergency
responders and for personnel who investigate and clean
up uncontrolled hazardous waste sites. The HMIRT
program currently has a curriculum of 12 courses. (See
Exhibit 5.) The curriculum covers emergency operations,
as well as the scientific and technical aspects of response
to hazardous materials incidents. The courses provide
specific training in worker health and safety and in
various technical operations that must be performed by
site personnel and emergency responders to identify,
evaluate, and control releases of hazardous substances.
All HMIRT courses, which generally last from
three to five days, emphasize the practical application of
lecture material through problem solving, case studies,
and demonstrations, along with actual exercises using
response equipment and instruments. Many of the
HMIRT courses are accredited by the American Council
on Education. The program also offers continuing
education units and American Board of Industrial
Hygiene (ABIH) certificate maintenance credits for
course participants. Tuition for HMIRT courses is free
to any government worker, including federal, state, and
local personnel, as well as to volunteer fire companies,
however, there is a nominal tuition fee for members of
industry.
WHERE TO OBTAIN
GUIDANCE
The guidance described in this Fact
Sheet can be obtained from the
sources shown in Exhibit 6. When
calling or writing, please be certain to
specify the title and identification number (if available)
of the guidance.
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EXHIBIT 6
Where to Obtain Guidance
To Obtain:
• Computer Software
- HASP (and User's Guide, 9285.8-01)
- FCTS (and User's Guide, 92853-03)
. HAZWOPER Fact Sheets
-- General Information and Comparison (9285 2-09FS)
-- Uncontrolled Hazardous Waste Sites and RCRA
Corrective Acnon (9285 2-08FS)
-- RCRA TSD and Emergency Response Without Regard
to Location (9285 2-07FS)
-- Establishing Work Zones at Uncontrolled Hazardous
Waste Sites (9285 2-06FS)
• Occupational Medical Monitoring Program Guidelines for
SARA Hazardous Waste Field Activity Personnel
(9285 3-04)
• Standard Operating Safely Guides (9285 1-OIC)
• Field Standard Operating Procedures
- FSOP #4 Site Entry (92852-01)
- FSOP #6 Work Zones (9285 2-04)
-- FSOP #1 Decontamination of Response Personnel
(9285 2-02)
- FSOP #8 Ajr Surveillance (9285 2-03)
-- FSOP #9 Sue Safety Plan (9285 2 05)
Call or Write
. U S EPA/ERT ERG H&S
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or (FTS) 340-67-10
To Obtain:
. Hazmat Team Planning Guidance (EP.-V540/G 90/003)
. Heallh and Safely Audit Guidelines (EPA/540/G 89/010)
Cull or Write:
• National Technical Information Service (NT1S)
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4600
To obtain:
- HMIRT Course Schedule
Call or Write:
. US EPA/ERT
26 West Martin Luther Kjng
Cincinnati, OH 45268
(513) 569-7537 or (FTS) 684 7537
To Obtain:
• Other information on worker protection standards
Call or Write:
• Emergency Planning and Community Right-lo-Kjiow
Information
U S. EPA (OS-120)
401 M Street, SW
Washington, D.C. 20460
(800) 535-0202 or (202) 479-2449
• Superfund Docket/U S EPA
401 M Street, SW
Room 2427 SD1C
Washington, D.C. 20460
(202) 382-3046
• U.S. Department of Labor
Occupational Safety and Health Administration (OSHA)
OSHA Publications Office, Room N3101
200 Constitution Avenue, NW
Washington, DC 20210
(202) 523-9667
• National Institute of Occupational Safety and Health
N1OSH Publications
4676 Columbia Parkway
Cincinnati, OH 45226
• Federal Emergency Management Agency (FEMA)
P O Box 70274
Washington, D C 20024
(or contact FEMA Regional Office directly)
• Emergency Management Institute (EMI)/
National Fire Protection Academy (NFA)
Federal Emergency Management Agency
16825 South Seton Avenue
Emmitsburg, MD 21727
(301) 447-1122
• National Fire Protection Association (NFPA)
1 Banerymarch Park
P O Box 9101 _,
Qmncy, MA 02269-9101
(617) 770-3000
• Fire Protection Publications
Oklahoma State University
Stillwater, OK 74078-0118
(405) 744-7576
• Supenntendent of Documents
U S Government Printing Office
Washington, D.C 20402
(202) 783-3238
• National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4600
75
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SECTION 4
AIR SURVEILLANCE
-------
AIR SURVEILLANCE
SECTION OBJECTIVE
The objectives of this section are to:
• Discuss charactersics and types of air monitoring and sampling equipment.
• Provide students with a list of manufacturers and suppliers of air monitoring and
sampling equipment.
STUDENT PERFORMANCE OBJECTIVES
After completing this section and related lesson(s), the student will be able to:
• Identify various types of air surveillance equipment.
• Discuss the basics of initial site survey and long term monitoring, and identify factors
affecting an air surveillance plan.
• Compare and contrast available air surveillance techniques.
• Identify manufacturers and suppliers of air monitoring and sampling equipment.
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SECTION 4
ft
AIR SURVEILLANCE
PART 1
CHARACTERISTICS AND TYPES OF AIR SURVEILLANCE EQUIPMENT
ft
I. INTRODUCTION
Airborne contaminants can present a significant threat to human health. Identifying and
quantifying these contaminants by air monitoring is an essential component of a health and
safety program at a hazardous waste site. Air monitoring data is useful for:
Assessing the health risks to the public and response workers.
Selecting personal protective equipment.
Delineating areas where protection is needed.
Determining actual or potential effects on the environment.
Selecting actions to mitigate the hazards safely and effectively.
Direct-reading instruments were developed as early warning devices for use in industrial
settings, where leaks or an accident could release a high concentration of a known chemical.
Today, some direct reading instruments can detect low concentrations of contaminants as
little as one part contaminant per million parts of air (ppm). Direct-reading instruments
provide information at the time of sampling and do not require sending samples to a
laboratory for subsequent analysis. This characteristic of direct-reading instruments enables
rapid decision-making.
Many of the common types of monitoring equipment discussed in this part are listed in
tabular form in APPENDIX I.
II. CHARACTERISTICS OF AIR MONITORING INSTRUMENTS
To be useful air monitoring instruments must be:
• Portable and rugged.
• Easy to operate.
• Inherently safe.
• Able to generate reliable and useful results.
A. Portability
A prime consideration for field instruments is portability. Transportation shock
resulting from the movement from one place to another, together with unintentional
abuse, shortens the usable life of an instrument. To reduce the effects of this
trauma, instruments should be selected that have reinforced shells or frames, shock-
mounted electronic packages, or padded containers for shipment.
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Exposure to the elements and to the test atmosphere itself is of concern for those
instruments repeatedly used in adverse conditions or as long-term monitors.
Anodized or coated finishes, weather resistant packaging and remote sensors are
effective in reducing downtime and increasing portability.
An internal power supply is important for portability. Some instruments use
replaceable or rechargeable batteries and some do not require a power supply.
An instrument should not be so heavy or bulky that it is difficult for a response
worker to carry.
B. Ease Of Operation
Because many of these instruments were designed for industrial use, allowances may
not have been made for using the instrument while wearing protective equipment.
One must consider how easy it is to use the instrument while wearing gloves or how
difficult it is to read the meter while wearing a respirator. Also, how quickly a
worker can learn to operate the instrument correctly should be considered.
Preparation time for use of the instrument should be short. Rapid warm-up, easy
attachment of accessories, and quick instrument checks shorten preparation time.
C. Inherent Safety
The portable instrumentation used to characterize hazardous material spills or waste
sites must be safe to use. Electrical devices, including instruments, must be
constructed in such a fashion as to prevent the ignition of a combustible atmosphere.
The sources of this ignition could be: an arc generated by the power source itself
or the associated electronics, or a flame or heat source necessary for function of the
instrument. Several engineering, insurance, and safety organizations have
standardized test methods, established inclusive definitions, and developed codes
for testing electrical devices used in hazardous locations. The National Fire
Protection Association (NFPA) has created minimum standards in its National
Electrical Code (NEC) published every 3 years. This code spells out types of areas
in which hazardous atmospheres can be generated and the types of materials that
generate these atmospheres, and design safeguards acceptable for use in hazardous
atmospheres.
1. Hazardous Atmospheres
Depending upon the response worker's background, the term "hazardous
atmosphere" conjures up situations ranging from toxic air contaminants to
flammable atmospheres. For NEC purposes, an atmosphere is hazardous if
it meets the following criteria:
• It is a mixture of any flammable material in air whose concentration
is within the material's flammable range (i.e. between the material's
lower flammable limit and its upper flammable limit).
• There is the potential for an ignition source to be present.
• The resulting exothermic reaction could propagate beyond where it
started.
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To adequately describe hazardous atmospheres, the NEC categories them
according to their Class, Group, and Division.
a. Class and Group
Class is a category describing the type of flammable material that
produces the hazardous atmosphere:
• Class I is flammable vapors and gases, such as gasoline and
hydrogen. Class I is further divided into groups A, B, C,
and D on the basis of similar flammability characteristics
(TABLE 1).
• Class II consists of combustible dusts like coal or grain and
is divided into groups E, F, and G (TABLE 2).
• Class III is ignitable fibers such as produced by cotton
milling.
b. Division
Division is the term describing the "location" of generation and
release of the flammable material.
• Division 1 is a location where the generation and release are
continuous, intermittent, or periodic into an open, unconfmed
area under normal conditions.
• Division 2 is a location where the generation and release are
only from ruptures, leaks or other failures from closed
systems or containers.
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TABLE 1
SELECTED CLASS I CHEMICALS BY GROUPS
Group A Atmospheres acetylene
Group B Atmospheres (not sealed in conduit 1/2 inch of larger)
1,3-butadiene
ethylene oxide
formaldehyde (gas)
hydrogen
manufactured gas (containing greater than 30% H2 by volume)
propylene oxide
propyl nitrate
allyl glycidyl ether
n-butyi glycidyl ether
Group C Atmospheres (selected chemicals)
acetaldehyde epichlorohydrin tetrahydrofuran
carbon monoxide ethylene triethylamine
crotonaldehyde ethyl mercaptan ethylene glycol
dicyclopentadiene hydrogen cyanide monoethyl ether
diethyl ether hydrogen selenide hydrazine
di-isobutyl amine hydrogen sulfide chloroaldehyde
methylacetylene morpholine tetraethyl lead
ethylene glycol monoethyl (39 others)
ether acetate nitropropane
Group D Atmospheres (selected chemicals)
acetone methane acetonitrile
methanol acrylonitrile methyl ethyl ketone
ammonia naphtha benzene
propane butane styrene
chlorobenzene vinyl chloride
Source: Classification of Gases. Vapors and Dusts for Electrical Equipment in
Hazardous (classified) Locations. 1986 National Fire Protection Association
ANSI/NFPA 497M.
6/91
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TABLE 2
SELECTED CLASS II CHEMICALS BY GROUPS
Group E Conductive Dusts
Atmospheres containing metal dusts, including aluminum, magnesium, and their
commercial alloys, and other metals of similarly hazardous characteristics.
Group F Semi-Volatile Dusts
Atmospheres containing carbon black, coal or coke dust with more than 8% volatile
material.
Group G Non-Conductive Dusts
Atmospheres containing flour, starch, grain, carbonaceous, chemical thermoplastic,
thermosetting and molding compounds.
Source: Classification of Gases. Vapors and Dusts for Electrical Equipment in
Hazardous (classified) Locations. 1986 National Fire Protection Association
ANSI/NFPA 497M.
2. Using this system
A hazardous atmosphere can be routinely and adequately defined. As an
example, an abandoned waste site containing intact closed drums of methyl
ethyl ketone, toluene and xylene would be considered a Class I, Division 2,
Group D environment. However, when transferring of the flammable liquids
takes place at the site, or if releases of flammable gases/vapors is considered
normal, the areas would be considered Class I, Division 1.
3. Controls
The following three methods of construction exist to prevent a potential
source from igniting a flammable atmosphere:
• Explosion-proof: Explosion-proof instruments allow the flammable
atmosphere to enter. If an arc is generated, the ensuing explosion is
contained within the specially built enclosure. Within it, any flames
or hot gases are cooled prior to exiting into the ambient flammable
atmosphere so that the explosion does not spread into the
environment.
• Intrinsically Safe: The potential for arcing among components is
reduced by encasing them in a solid insulating material. Also,
reducing the instrument's operational current and voltage below the
energy level necessary for ignition of the flammable atmosphere
provides protection. An "intrinsically safe" device, as defined by the
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National Electrical Code, is incapable "of releasing sufficient
electrical or thermal energy under normal or abnormal conditions to
cause ignition of a specific hazardous atmospheric mixture in its most
easily ignited concentration. Abnormal conditions shall include
accidental damage to any wiring, failure of electrical components,
application of over-voltage, adjustment and maintenance operations
and other similar conditions".
Purged: The arcing or flame-producing device is buffered from the
flammable atmosphere with an inert gas. In a pressurized or
"purged" system, a steady stream of, nitrogen or helium is passed by
the potential arcing device, keeping the flammable atmosphere from
the ignition source. This type of control, however, does not
satisfactorily control analytical devices that use flame or heat for
analysis, such as a combustible gas indicator (CGI). It also requires
a source of gas which would reduce instrument portability.
4. Certification
If a device is certified as explosion-proof,intrinsically safe, or purged for a
given Class, Division, and Group, and is used, maintained, and serviced
according to the manufacturer's instructions, it will not contribute to ignition.
The device is not, however, certified for use in atmospheres other than those
indicated. All certified devices must be marked to show Class, Division, and
Group, (see FIGURE 1) Any manufacturer wishing to have an electrical
device certified must submit a prototype to a laboratory for testing. If the
unit passes, it is certified as submitted. However, the manufacturer agrees
to allow the testing laboratory to randomly check the manufacturing plant at
any time, as well as any marketed units. Furthermore, any change in the
unit requires the manufacturer to notify the test laboratory, which can
continue the certification or withdraw it until the modified unit can be
retested. NFPA does not do certification testing. Testing is done by such
organizations as Underwriters' Laboratory Inc. (UL) or Factory Mutual
Research Corp. (FM). Currently, these are the only two testing labs
recognized by OSHA.
6/91
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Combustible Gas and 02 Alarm
m0[jE| 260 part no. 449900
calibntid (or
Pen Lane
InlMniicjItr S«lf to' ut< In harirdoui !DCil'On\ Cl*ji 1. Q«»iiion \t
C'OUDi C *nO D «nd Non-«/tCfrtdivf lo^ u»< in ClJlt 1. 0«vaion 2. G'^up^ *•
5. C, *nd D »-h«« uifO «i1h WSA 3-nfry. P.n NO. <5/239.
MUST BE OPERATED IN ACCORDANCE WITH INSTRUCTIONS
WJII nfV 1
BY
MINE SAFETY APPLIANCES COMPANY
PlTTSBl/OGK. PENNSYLVANIA. U S. A. 15208
UJ fAl »B l.tD.lll f»I(«IIO in CAHAO* 1111
»S3t!
FIGURE 1
CERTIFICATION LABEL FROM MSA MODEL 260
COMBUSTIBLE GAS AND O2 INDICATOR
To ensure personnel safety, it is recommended that only approved instruments be
used on-site and only in atmospheres for which they have been certified. When
investigating incidents involving unknown hazards, the monitoring instruments should
be rated for use in the most hazardous locations. The following points will assist in
selection of equipment that will not contribute to ignition of a hazardous atmosphere:
• The mention of a certifying group in the manufacturer's equipment literature
does not guarantee certification.
• Some organizations test and certify instruments for locations different from
the NEC classification. The Mine Safety and Health Administration (MSHA)
tests instruments only for use in methane-air atmospheres and in atmospheres
containing coal dust.
• In an area designated Division 1, there is a greater probability of generating
a hazardous atmosphere than in Division 2. Therefore, the test protocols for
Division 1 certification are more stringent than those for Division 2. Thus
a device approved for Division 1 is also permitted for use in Division 2, but
not vice versa. For most response work this means that devices approved for
Class I (vapors, gases), Division 1 (areas of ignitable concentrations), Groups
A, B, C, D should be chosen whenever possible. At a minimum, an
instrument should be approved for use in Division 2 locations.
• There are so many Groups, Classes, and Divisions that it is impossible to
certify an all-inclusive instrument. Therefore, select a certified device based
on the chemicals and conditions most likely to be encountered. For example,
a device certified for a Class II, Division 1, Group E (combustible metal
dust) would offer little protection around a flammable vapor or gas.
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D. Reliable and Useful Results
The response time, sensitivity, selectivity, accuracy and precision of an instrument
are important in evaluating the reliability and usefulness of the data the instrument
generates.
Response time, the interval between an instrument "sensing" a contaminant and
generating data, is important to producing reliable and useful results in the field.
Response time depends on: test(s) to be performed, dead time between sample
periods (the time for analysis, data generation, and data display), and the sensitivity
of the instrument. Response times for direct-reading instruments may range from
a few seconds to several minutes.
Sensitivity is important when slight concentration changes can be dangerous.
Sensitivity is defined as the ability of an instrument to accurately measure changes
in concentration. Sensitive instruments can detect small changes in concentration.
The lower detection limit is the lowest concentration to which instrument will
respond to. The operating range is the lower and upper use limits of the instrument.
It is defined by the lower detection limit at one end and the saturation concentration
at the other end. It is important to use an instrument with an operating range that
will accurately measure the concentration in the range of concern.
Amplification, a term often used synonymously (and incorrectly) with sensitivity, is
the instrument's ability to increase very small electronic signals emanating from the
detector to the readout. Changing the amplification of the detector does not change
its sensitivity. However, it may be useful in calibration. Instruments with amplifier
circuits can be effected by radio frequency from pulsed DC or AC power lines,
transformers, generators, and radio wave transmitters.
Accuracy is defined as the relationship between a true value and the instrument
reading. Precision is the indication of the reproducibility. These factors can be
indicated by the error factor. For example, some detector tubes may have an error
factor of ±.35% of the true value; meaning the actual concentration of the chemical
being measured is within a range of 35% higher and lower than the tube reading.
Selectivity is the ability of an instrument to detect and measure a specific chemical
or group of similar chemicals. Additionally, selectivity is dependent upon interfering
compounds which may produce a similar response. Selectivity and sensitivity must
be reviewed and interpreted together. Interferences can effect the accuracy of the
instrument reading.
Another consideration is that the instrument must give results that are immediately
useful. Instruments should be direct reading, with little or no need to interpolate,
integrate, or compile large amounts of data.
When selecting an instrument, compare the desired sensitivity, range, accuracy,
selectivity, and ability to vary amplification of detector signals with the available
instrument characteristics.
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III. CALIBRATION AND RELATIVE RESPONSE
For an instrument to function properly in the field, it should be calibrated prior to use.
Calibration is the process of adjusting the instrument readout so that it corresponds to the
actual concentration. Calibration involves checking the instrument results with a known
concentration of a gas or vapor to see that the instrument
gives the proper response. For example, if a combustible gas meter is calibrated with a gas
that is 20% of the lower explosive limit (LEL), then tha instrument should read 20% of the
LEL. If it does not read accurately, it is out of calibration and should be adjusted until
accurate readings are obtained. Although an instrument is calibrated to give a one-to-one
response for a specific chemical (the calibration gas), its response to other chemicals may
be different. This variability is called relative response. A combustible gas indicator
calibrated to pentane will give a higher instrument reading for methane than the actual
concentration (see TABLE 3). The relative response of an instrument to different chemicals
can be calculated by dividing the instrument reading by the actual concentration and is
expressed as a ratio or a percent. Note that for the calibration standard the relative response
should be 1.00 or 100%.
If the instrument is being used for a chemical that is not the calibration standard, then it may
be possible to look at the manufacturer's information to get the relative response of that
instrument for the chemical. Then the actual concentration can be calculated. For example,
if the instrument's relative response for xylene is .27 (27%) and the reading is 100 ppm
(parts per million), then the actual concentration is 370 ppm (.27 x actual concentration =
100 ppm, then actual concentration = 100/.27 = 370 ppm). If there is no relative response
data for the chemical in question, it may be possible to recalibrate the instrument. If the
instrument has adjustable settings and a known concentration is available, the instrument may
be adjusted to read directly for the chemical. As recalibration takes time, this is usually
done only if the instrument is going to be used for many measurements of the special
chemical.
TABLE 3
RELATIVE RESPONSE FOR A COMBUSTIBLE GAS
INDICATOR CALIBRATED TO PENTANE
Chemical
Methane
Acetylene
Pentane
1,4-Dioxane
Xylene
Concentration
(% LEL)
50
50
50
50
50
Meter Response
(% LEL)
85
60
53
37
27
Relative
Response
170%
120%
106%
74%
54%
Source: Portable Gas Indicator. Model 250 & 260. Response Curves. Mine Safety
Appliances Company, Pittsburgh, PA.
6/91
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IV. TYPES OF DIRECT-READING INSTRUMENTS
A. Introduction
Many hazards may be present when responding to hazardous materials spills or
uncontrolled waste sites. There are several types of instrumentation for detecting
hazardous atmospheres. This section will discuss oxygen indicators, combustible gas
indicators, and toxic atmosphere monitors.
B. Oxygen Indicators
Oxygen indicators are used to evaluate an atmosphere for the following:
• Oxygen content for respiratory purposes. Normal air is 20.9% oxygen.
Generally, if the oxygen content decreases below 19.5% it is considered
oxygen deficient and special respiratory protection is needed.
• Increased risk of combustion. Generally, concentrations above 25% are
considered oxygen-enriched and increase the risk of combustion.
• Use of other instruments. Some instruments require sufficient oxygen for
operation. For example, some combustible gas indicators do not give
reliable results at oxygen concentrations below 10%. Also, the inherent
safety approvals for instruments are for normal atmospheres and not for
oxygen enriched ones.
• Presence of contaminants. A decrease in oxygen content can be due to the
consumption (by combustion or a reaction such as rusting) of oxygen or the
displacement of air by a chemical. If it is due to consumption then the
concern is the lack of oxygen. If it is due to displacement then there is
something present that could be flammable or toxic.
Oxygen deficient atmospheres may occur in unventilated areas or may by due to
terrain variations in cases where heavier than air vapors may collect. Most
indicators have meters which display the oxygen concentration from 0-25%. There
are also oxygen indicators available which measure concentrations from 0-5% and
0-100%. The most useful range for response is the 0-25% oxygen content readout
since decisions involving air-supplying respirators and the use of combustible gas
indicators fall into this range.
Many instrument manufacturers make oxygen meters. They can be small hand-held
units with or without pumps to draw the sample across the detector cell. Some
pumps are single aspirating (hand-squeeze) bulbs, others are battery powered
diaphragm pumps. Units that combine 0^ meters and combustible gas indicators into
one instrument are available from a number of manufacturers. Also, flashing and
audible alarms can be found on many instruments. These alarms go off at a pre-set
oxygen concentration to alert the users even if they are not watching the meter.
Manufacturers of oxygen indicators are found at the end of this manual section.
1. Principle of Operation
Oxygen indicators have two principle components for operation. These are
the oxygen sensor and the meter readout. In some units air is drawn into the
oxygen detector with an aspirator bulb or pump; in other units, the ambient
6/91 10
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air is allowed to diffuse to the sensor. The oxygen detector uses an
electrochemical sensor to determine the oxygen concentration in air. A
typical sensor consists of: two electrodes; a housing containing a basic
electrolytic solution; and a semipermeable Teflon membrane (FIGURE 2).
Oxygen molecules (O2) diffuse through the membrane into the solution.
Reactions between the oxygen, the solution and the electrodes produce a
minute electric current proportional to the oxygen content. The current
passes through the electronic circuit. The resulting signal is shown as a
needle deflection on a meter or digital reading.
2. Limitations and Considerations
The operation of oxygen meters depends on the absolute atmospheric
pressure. The concentration of natural oxygen (to differentiate it from
manufactured or generated oxygen) is a function of the atmospheric pressure
at a given altitude. While the actual percentage of oxygen does not change
with altitude, at sea level the weight of the atmosphere above is greater, and
more O2 molecules (and the other components of air) are compressed into a
given volume than at higher elevations. As elevation increases, this
compression decreases, resulting in fewer air molecules being "squeezed"
into a given volume. Consequently, an Oj indicator calibrated at sea level
and operated at an altitude of several thousand feet will falsely indicate an
oxygen deficient atmosphere because less oxygen is being "pushed" into the
sensor. Therefore, it is necessary to calibrate at the altitude the instrument
is used.
o.
MEMBRANE/COVER
ELECTRODE
ELECTRODE
ELECTROLYTE
FIGURE 2
SCHEMATIC OF OXYGEN SENSOR
Selection from Product Literature. Rexnard Electronic Products Division. Biomarine
Oxygen Sensor, by Rexnard, Inc., reprinted with permission of publisher.
6/91
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High concentrations of carbon dioxide (CC^) shorten the useful life of the
oxygen sensor. As a general rule, the unit can be used in atmospheres
greater than 0.5% CO2 only with frequent replacing or rejuvenating of the
sensor. Lifetime in a normal atmosphere (0.04% COj) can be from one
week to one year depending on the manufacturer's design.
Temperature can affect the response of oxygen indicators. The normal
operating range for them is between 32°F and 120°F. Between 0°F and 32°F
the response of the unit is slower. Below 0°F the sensor may be damaged
by the solution freezing. The instrument should be calibrated at the tem-
perature at which it will be used.
Strong oxidizing chemicals, like ozone and chlorine, can cause increased
readings and indicate high or normal Oj content when the actual content is
normal or even low.
C. Combustible Atmosphere Indicators
Combustible gas indicators (CGIs) measure the concentration of a flammable vapor
or gas in air, indicating the results as a percentage of the lower explosive limit
(LEL) of the calibration gas.
The LEL (or LFL - lower flammable limit) of a combustible gas or vapor is the
minimum concentration of the material in air which will propagate flame on contact
with an ignition source. The upper explosive limit (UEL) is the maximum
concentration. Above the UEL, the mixture is too "rich" to support combustion so
ignition is not possible. Below the LEL there is insufficient fuel to support
combustion.
CGI's are available in many styles and configurations. All units have some type of
pump to draw the air sample into the detector. The pumps are either hand operated
square bulbs or automatic (battery-powered) diaphragm types. Many units are
"combination meters". This means they have an 0^ meter and CGI (and sometimes
one or two specific gas indicators) combined in the same instrument. Flashing and
audible alarms are options on many units. The alarms go off at a pre-set
concentration to warn the instrument operator of potentially hazardous
concentrations. Other options such as larger sampling lines, moisture taps, all dust
filters are also available. Manufacturers of CGIs are listed at the end of this manual
section.
Concentrations between the LEL and the UEL are considered flammable.
1. Principle of Operation
Combustible gas indicators use a combustion chamber containing a filament
that combusts the flammable gas. To facilitate combustion the filament is
heated or is coated with a catalyst (like platinum or palladium), or both. The
filament is part of a balanced resistor circuit called a Wheatstone Bridge.
The hot filament combusts the gas on the immediate surface of the element,
thus raising the temperature of the filament. As the temperature of the
filament increases so does its resistance. This change in resistance causes an
6/91 12
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imbalance in the Wheatstone Bridge. This is measured as the ratio of
combustible vapor present compared to the total required to reach the LEL.
For example, if the meter reads 0.5 (or 50%, depending upon the readout),
this means that 50% of the concentration of combustible gas needed to reach
a flammable or combustible situation is present. If the LEL for the gas is
5% then the meter indicates that a 2.5% concentration is present. Thus, the
typical meter readout indicates concentration up to the LEL of the gas. See
FIGURE 3a.
If a concentration greater than LEL and lower than the UEL is present, then
the meter needle will stay beyond the 1.0 (100%) level on the meter. See
FIGURE 3b. This indicates that the ambient atmosphere is readily
combustible. When the atmosphere has a gas concentration above the UEL
the meter needle will usually rise above the 1.0 (100%) mark and then return
to zero. See FIGURE 3c. This occurs because the gas mixture in the
combustion cell is too rich to burn. This permits the filament to conduct a
current just as if the atmosphere contained no combustibles at all. Some
instruments have a lock mechanism that prevents the needle from returning
to zero when it has reached 100% and must be reset in an atmosphere below
the LEL.
100
%LEL
100
%LEL
IOO
% LEL
a
Lower than the
LEL
Between the LEL
and the UEL
Above the UEL
FIGURE 3
COMPARISON OF METER READINGS TO
COMBUSTIBLE GAS CONCENTRATIONS
6/91
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2. Limitations and Considerations
The response of the instrument is temperature dependent. If the temperature
at which the instrument is zeroed differs from the sample temperature, the
accuracy of the reading is affected. Hotter temperatures raise the
temperature of the filament and produce a higher than actual reading. Cooler
temperatures will reduce the reading. It works best to calibrate and zero the
instrument at the sample temperature.
The instruments are intended for use only in normal oxygen atmospheres.
Oxygen-deficient atmospheres will produce lowered readings. Also the
safety guards that prevent the combustion source from igniting a flammable
atmosphere are not designed to operate in an oxygen-enriched atmosphere.
Organic lead vapors (e.g. gasoline vapors), sulfur compounds, and silicone
compounds will foul the filament. Acid gases (e.g. hydrogen chloride and
hydrogen fluoride) can corrode the filament. Most units have an optional
filter that protects the sensor from leaded vapors.
There is no differentiation between petroleum vapors and combustible gases.
If the flammability of the combined vapors and gases in an atmosphere is the
concern this is not a problem. However, if the instrument is being used to
detect the presence of a released flammable liquid - like gasoline - in a sewer
system where methane may be present, the operator can't tell if the reading
is the contaminant or the methane. A pre-filter can be used to remove the
vapors but will not remove the methane. Thus, if readings are made with
and without the filter, the user can compare the readings and can conclude
that differences in the values indicate that a petroleum vapor (i.e. the
contaminant) is present.
D. Toxic Atmosphere Monitors
Along with oxygen concentration and flammable gases or vapors, there is a concern
about chemicals present at toxic concentrations.
This usually involves measurements at concentrations lower than would be indicated
by oxygen indicators or combustible gas indicators. There is a need to determine if
toxic chemicals are present and identify them so the environmental concentration can
be compared to exposure guidelines. Toxic atmosphere monitoring is done to:
• identify airborne concentrations that could pose a toxic risk to response
workers and the public.
• evaluate the need for and type of personal protective equipment.
• set up work zones or areas where contaminants are or are not present.
There are several different groups of instruments that can be used for these
functions.
6/91 14
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1. Colorimetric Indicator Tubes (Detector Tubes)
a. Principle of Operation
Colorimetric indicator tubes consist of a glass tube impregnated with
an indicating chemical (FIGURE 4). The tube is connected to a
piston- or bellows- type pump. A known volume of contaminated air
is pulled at a predetermined rate through the tube by the pump. The
contaminant reacts with the indicator chemical in the tube, producing
a change in color whose length is proportional to the contaminant
concentration.
COTTON PLUG
GLASS VIAL
TT
L
PHE FILTER INDICATING CHEMICAL
ON SILICA GEL
COTTON PLUG
FIGURE 4
DIRECT-READING COLORIMETRIC
INDICATOR TUBE
Detector tubes are normally chemical specific. There are different
tubes for different gases; for example, chlorine detector tube for
chlorine gas, acrylonitrile tube for acrylonitrile gas, etc. Some
manufacturers do produce tubes for groups of gases, e.g. aromatic
hydrocarbons, alcohols. Concentration ranges on the tubes may be
in the ppm or percent range. A preconditioning filter may precede
the indicating chemical to:
• remove contaminants (other than the one in question) that
may interfere with the measurement. Many have a prefilter
for removing humidity.
• react with a contaminant to change it into a compound that
reacts with the indicating chemical.
6/91
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"Haz-mat kits are available from at least two manufacturers. These
kits identify or classify the contaminants as a member of a chemical
group such as acid gas, halogenated hydrocarbon, etc. This is done
by sampling with certain combinations of tubes at the same time by
using a special multiple tube holder or by using tubes in a specific
sampling sequence. Detector tube manufacturers are listed at the end
of this manual section.
b. Limitations and Considerations
Detector tubes have the disadvantage of poor accuracy and precision.
In the past, the National Institute for Occupational Safety and Health
(NIOSH) tested and certified detector tubes that were submitted to
them. For the tubes they tested they certified the accuracy to be
±35% at concentrations at 1/2 the OSHA Permissible Exposure Limit
(PEL) and ±25% at 1 to 5 times the PEL. NIOSH has discontinued
testing and certification. Special studies have reported error factors
of 50% and higher for some tubes.
The chemical reactions involved in the use of the tubes are affected
by temperature. Cold weather slows the reactions and thus the
response time. To reduce this problem it is recommended that the
tubes be kept warm (for example, inside a coat pocket) until they are
used if the measurement is done in cold weather. Hot temperatures
increase the reaction and can cause a problem by discoloring the
indicator when a contaminant is not present. This can happen even
in unopened tubes. Therefore, the tubes should be stored at a
moderate temperature or even refrigerated during storage.
Some tubes do not have a prefilter to remove humidity and may be
affected by high humidity. The manufacturer's instructions usually
indicate if humidity is a problem and list any correction factors to use
if the tube is affected by humidity.
The chemical used in the tubes deteriorates over time. Thus the
tubes are assigned a shelf life. This varies from 1 to 3 years. Shelf
life can be extended by refrigeration but the tube should equilibrate
to ambient temperature before use.
An advantage that detector tubes have over some other instruments
is that it is possible to select a tube that is specific to a chemical.
However, some tubes will respond to interfering compounds.
Fortunately, the manufacturers provide information with the tubes on
interfering gases and vapors.
Interpretation of results can be a problem. Since the tube's length of
color change indicates the contaminant concentration, the user must
be able to see the end of the stain. Some stains are diffused and are
not clear cut; others may have an uneven endpoint. When in doubt
use the highest value that would be obtained from reading the
different aspects of the tube.
6/91 16
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The total volume to be drawn through the tube varies with the tubes.
The volume needed is given as the number of pump strokes needed,
i.e. the number of times the piston or bellows is manipulated. Also,
the air does not instantaneously go through the tube. It may take 1
to 2 minutes for each volume (stroke) to be completely drawn.
Therefore, sampling times can vary from 1 to 30 minutes per tube.
This can make the use of detector tubes time consuming.
Due to these many considerations, it is very important to read the
instructions that are provided with and are specific to a set of tubes.
The information includes the number of pump strokes needed, time
for each pump stroke, interfering gases and vapors, effects of
humidity and temperature, shelf life, proper color change and
whether the tube is reusable.
While there are many limitations and considerations for using
detector tubes, detector tubes allow the versatility of being able to
measure a wide range of chemicals with a single pump. Also, there
are some chemicals for which detector tubes are the only direct-
reading indicators.
2. Specific Chemical Monitors
There are several gas monitors which utilize electrochemical cells or metal
oxide semi-conductors (MOS) for detecting specific chemicals. MOS
detectors change conductivity when exposed to certain gases or vapors. They
can be designed to respond to a large group of chemicals or to a specific
chemical. The most common monitors are used to detect carbon monoxide
or hydrogen sulfide but there are also monitors available for hydrogen
cyanide, ammonia and chlorine. They are more accurate than detector tubes
but there are only about a dozen different chemicals they can monitor.
3. Photoionization Detector (PID)
These instruments detect concentrations of gases and vapors in air by
utilizing an ultraviolet light source to ionize the airborne contaminant. Once
the gas or vapor is ionized in the instrument, it can be detected and
measured.
a. Principle of Operation
All atoms and molecules are composed of particles: electrons,
protons, and neutrons. Electrons, negatively charged particles,
rotate in orbit around the nucleus, the dense inner core. The nucleus
consists of an equal number of protons (positively charged particles)
as electrons found in the orbital cloud. The interaction of the
oppositely charged particles and the laws of quantum mechanics keep
the electrons in orbits outside the nucleus.
6/91 17
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The energy required to remove the outermost electron from the
molecule is called the ionization potential (IP) and is specific for any
compound or atomic species (see TABLE 4). Ionization potentials
are measured in electron volts (eV). High frequency radiation
(ultraviolet and above) is capable of causing ionization and is hence
called ionizing radiation.
When a photon of ultraviolet radiation strikes a chemical compound,
it ionizes the molecule if the energy of the radiation is equal to or
greater than the IP of the compound. Since ions are charged
particles, they may be collected on a charged plate and produce a
current. The measured current will be directly proportional to the
number of ionized molecules (see FIGURE 5).
The photo ionization process can be illustrated as:
R + h - R+ + e
where R is an organic or inorganic molecule and h represents a
photon of UV light with energy equal to or greater than the ionization
potential of that particular chemical species.
molecule.
R is the ionized
TABLE 4
IONIZATION POTENTIALS OF SELECTED CHEMICALS
Chemical
Hydrogen cyanide
Carbon dioxide
Methane
Hydrogen chloride
Water
Oxygen
Chlorine
Propane
Hydrogen sulfide
Hexane
Ammonia
Vinyl chloride
Acetone
Benzene
Phenol
Ethyl amine
Ionization Potential (eV)
13.9
13.8
13.0
12.5
12.6
12.1
11.5
11.1
10.5
10.2
10.1
10.0
9.7
9.2
8.5
8.0
6/91
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PIDs use a fan or a pump to raw air into the detector of the
instrument where the contaminants are exposed to UV light and the
resulting negatively charged particles (ions) are collected and
measured.
AMPLIFIER
/
METER
/
SAMPLE OUT
ELECTRODE
t
UV
LAMP
ELECTRODE
SAMPLE IN
FIGURE 5
DIAGRAM OF PHOTOIONIZATION DETECTOR
LAMP AND COLLECTING ELECTRODES
b. Photoionization Considerations and Limitations
Since the ability to detect a chemical depends on the ability to ionize
it, the IP of a chemical to be detected must be compared to the
energy generated by the UV lamp of the instrument. As can be seen
from TABLE 4 there is a limit imposed by the components of air.
That is to say, the lamp cannot be too energetic or oxygen and
nitrogen will ionize and interfere with the readings for contaminants.
The energy of lamps available are 8.3, 8.4, 9.5, 10.2, 10.6, 10.9,
11.4, 11.7 and 11.8 eV. Not all lamps are available from a single
manufacturer.
6/91
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One use of the different lamps is for selective determination of
chemicals. For example, if a spill of propane and vinyl chloride
were to be monitored with a PID the first check would be to see if
they could be detected. The IP of propane is 11.1 eV and the IP of
vinyl chloride is 10.0 eV. To detect both, a lamp with an energy
greater than 11.1 eV is needed (like a 11.7 or 11.8). If vinyl
chloride was the chemical of concern, then a lamp with an energy
greater than 10.0 but less than 11.1 (such as 10.2 of 10.6) could be
used. The propane would neither be ionized nor detected. Thus,
propane would not interfere with the vinyl chloride readings. The
sample drawn into the instrument passes over the lamp to be ionized.
Dust in the atmosphere can collect on the lamp and block the
transmission of UV light. This will cause a reduction in instrument
reading. This problem will be detected during calibration and the
lamp should be cleaned on a regular basis.
Humidity can cause two problems. When a cold instrument is taken
into a warm moist atmosphere, the moisture can condense on the
lamp. Like dust this will reduce the available light. Moisture in the
air also reduces the ionization of chemicals and cause a reduction in
readings.
Since an electric field is generated in the sample chamber of the
instrument, radio-frequency interference from pulsed DC or AC
power lines, transformers, generators, and radio wave transmission
may produce an error in response.
As the lamp ages the intensity of the light decreases. It will still
have the same ionization energy, but the response will decline. This
will be detected during calibration and adjustments can be made.
However, the lamp will eventually burn out.
Photoionization detectors are calibrated to a single chemical. The
instrument's response to chemicals other than the calibration
gas/vapor can vary. TABLE 5 shows the relative responses of
several chemicals for a specific PID.
In some cases, at high concentrations the instrument response can
decrease. While the response may be linear (i.e. 1 to 1 response)
from 1 to 600 ppm for an instrument, a concentration of 900 ppm
may only give a meter response of 700.
Units which utilize photoionization include the Thermo
Environmental Instruments Model 580A, the Photovac TIP and the
HNUPI 101.
6/91 20
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TABLE 5
RELATIVE RESPONSES FOR SELECTED CHEMICALS USING
THE HNU MODEL PI 101 WITH 10.2 eV PROBE CALIBRATED TO BENZENE
Chemical
m-Xylene
Benzene
Phenol
Vinyl chloride
Acetone
Hexane
Phosphine
Ammonia
Relative Response
1.12
1.00
0.78
0.63
0.50
0.22
0.20
0.03
Source: Instruction Manual for Model PI 101. Portable Photoionization Analyzer. HNU
Systems, Inc., Newton, MA, 1986.
c. HNU PI 101 Photoionization Detector
The HNU PI 101 consists of two modules connected via a single
power cord (FIGURE 6):
• A read-out unit consisting of a 4.5 inch analog meter, a
rechargeable battery, and power supplies for operation of the
amplifier and the UV lamp.
• A sensor unit consisting of the UV light source, pump,
ionization chamber, and a preamplifier.
The unit has a separate sensor unit because the lamps available - 8.3,
9.5, 10.2 (standard) and 11.7 eV - require separate electronic
circuits. To change the energy of ionization the whole sensor or
probe has to be switched and not just the lamp. Lamps are
replaceable.
d. Photovac TIP (Total lonizables Present)
The TIP has components similar to those the HNU has, but they are
all contained in an 18 inch long and 2.5 inch diameter unit. The
standard lamp is 10.6 eV, but it can easily be replaced with a 8.4,
9.5, 10.2, or 11.7 eV lamp. A separate sensor is not used. The
readout is digital with a range of 0 to 2000. The instrument also has
a replaceable dust filter to eliminate collection on the lamp.
6/91
21
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REATOLT UK:T
IOX CKS>SER
• SSMPLE
FIGURE 6
PORTABLE PHOTOIONIZATION DETECTOR
Selection from Instruction Manual for Model PI 101 Photoionization
Detector, by HNU Systems, Inc., copyrighted 1975, by HNU
Systems, Inc., reprinted with permission of Publisher.
e. (Organic Vapor Meter Model 580A) (Thermo Environmental
Instrument)
The Organic Vapor Meter (OVM) is 5" by 5" by 10" with a handle
on top and in the center. It can use any of four different lamps -
9.5, 10.0, 10.6 (standard), 11.8 eV. The instrument has a digital
readout with a range of 0 to 2000. It has a maximum hold feature so
that you can get two readings - the current concentration or the
maximum concentration during the survey. The meter has a lock-out
if the readout exceeds 2000 so that high concentrations are not
missed. It must be reset in an area of low concentrations. The
instrument has a microprocessor for assistance in calibration and
lamp changing.
The unit also has connections and software for interfacing the unit
with a personal computer and a data logger for recording readings at
6/91
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coded locations so that the readings can be looked at later or
unloaded into a computer.
Photoionization detectors are also used in gas chromatographs made
by Photovac, HNU and Thermo Environmental Instruments. Gas
chromatography will be discussed later in this part.
4. Flame lonization Detector (FID)
These units utilize combustion as the means to ionize airborne contaminants.
Once they are ionized, they can be detected and measured.
a. Principle of Operation
Flame ionization detectors use a hydrogen flame as the means to
ionize organic (toxic) vapors. FID responds to virtually all organic
compounds, that is, compounds that contain carbon-hydrogen or
carbon-carbon bonds. The flame detector analyzes by the mechanism
of breaking bonds as the following reaction indicates:
RH + 0 -* RHO+ + e- - CO2 + H2O
Inside the detector chamber, the sample is exposed to a hydrogen
flame which ionizes the organic vapors. When most organic vapors
burn, positively charged carbon-containing ions are produced which
are collected by a negatively charged collecting electrode in the
chamber. An electric field exists between the conductors surrounding
the flame and a collecting electrode. As the positive ions are
collected, a current proportional to the hydrocarbon concentration is
generated on the input electrode. This current is measured with a
preamplifier which has an output signal proportional to the ionization
current. A signal conducting amplifier is used to amplify the signal
from the preamp and to condition it for subsequent meter or external
recorder display.
Flame ionization detectors have a more generalized response in
detecting organic vapors. This generalized sensitivity is due to the
breaking of chemical bonds which require a set amount of energy and
is a known reproducible event. When this is compared to
Photoionization (PID), a major difference should be noted between
the detectors. PID detection is dependent upon the ionization
potential (eV) and the ease in which an electron can be ionized
(displaced) from a molecule. This mechanism is variable, highly
dependent on the individual characteristics of a particular substance.
This results in a more variable response factor for the vast majority
of organics that are ionizable. Therefore, in general, one does not
see large sensitivity shifts between different substances when using
6/91 23
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an FID as compared to a PID. Flame ionization detectors are the
most sensitive for saturated hydrocarbons, alkanes and unsaturated
hydrocarbons alkenes. Substances that contain substituted functional
groups such as hydroxide (OH"), and chloride (Cl~), tend to reduce
the detector's sensitivity; however, overall, the detectabilities remain
good.
Companies that manufacture FIDs include Beckman Industrial, The
Foxboro Company and Thermo Environmental Instruments. The
Foxboro Century Organic Vapor Analyzer (OVA) will be discussed
as an example later.
b. Flame Ionization Detector Considerations
Flame ionization detectors respond only to organic compounds.
Thus, they do not detect inorganic compounds like chlorine,
hydrogen cyanide, or ammonia.
As with all instruments, flame ionization detectors respond differently
to different compounds. TABLE 6 is a list of the relative responses
of the Foxboro CENTURY OVA to some common organic
compounds. Since that instrument is factory calibrated to methane,
all responses are relative to methane and are given by percentage,
with methane at 100%.
Thus with all survey-type instruments, the identity of the chemical of
interest must be ascertained before its concentration can be
determined. However, the CENTURY OVA can be purchased as a
dual mode survey-gas chromatograph and can separate and define the
components present in a gas mixture. As with all instruments,
individuals should be trained for best operation and performance.
Experience in gas chromatography is an important aspect to
successful operation of the chromatographic option.
6/91 24
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TABLE 6
RELATIVE RESPONSES FOR SELECTED CHEMICALS
USING THE OVA CALIBRATED TO METHANE
Compound
Methane
Ethane
Propane
n-Butane
n-Pentane
Ethyl ene
Acetylene
Benzene
Toluene
Acetone
Methyl ethyl ketone
Methyl isobutyl ketone
Methanol
Ethanol
Isopropyl alcohol
Carbon tetrachloride
Chloroform
Trichlorethylene
Vinyl chloride
Relative Response
100
90
64
61
100
85
200
150
120
100
80
100
15
25
65
10
70
72
35
Selection from Product Literature. The Foxboro Company, with permission of the Foxboro
Company.
c. Foxboro CENTURY Organic Vapor Analyzer (OVA)
(The Foxboro CENTURY OVA consists of two major parts
(FIGURE 7)
• A 12-pound package containing the sampling pump, battery
pack, support electronics, flame ionization detector, hydrogen
gas cylinder, and an optional gas chromatography (GC)
column.
• A hand-held meter/sampling probe assembly.
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Signal Processor Chan Recorder
Compressed Gas
Sample
Sample Pump
FIGURE 7
ORGANIC VAPOR ANALYZER SCHEMATIC
Selection from Product Literature. The Foxboro Company, with
permission of the Foxboro Company.
The OVA is generally calibrated to methane, but can be calibrated
to the species of interest.
The OVA can operate in two modes:
Survey mode: During normal survey mode operation, a sample is
drawn into the probe and transmitted to the detector chamber by an
internal pumping system. When the sample reaches the FID it is
ionized as described before and the resulting signal is translated on
the meter for direct-reading concentration as total organic vapors or
recorded as a peak on a chart. The meter display is an integral part
of the probe/readout assembly and has a scale from 0 to 10 which can
be set to read 0-10, 0-100, or 0-1000 ppm.
Gas chromatography mode: Gas chromatography (GC) is a technique
for separating components of a sample and qualitatively and
quantitatively identifying them. The sample to be separated is
injected into a column packed with an inert solid. As the carrier gas
(for the OVA it is hydrogen) forces the sample through the column,
the separate components of the sample are retained on the column for
different periods of time. The amount of time a substance remains
on the column, which is called its retention time, is a function of its
6/91
26
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affinity for the column material, column length, column temperature,
and flow rate of the carrier gas. Under preset instrumental
conditions each component elutes from the column at a different but
reproducible length of time. As the components elute from the
column, they flow into the detector. Since the output of the detector
can be connected to a strip chart recorder, separate peaks are
recorded for each component. This readout is called a gas
chromatogram (see Qualitative identification is made by measuring
retention time. Retention time is defined as the period of time that
elapses between the injection of the compound into the column and
the elution of that compound as represented by a peak. Retention can
be expressed as a function of either time or the measured distance
between the injection point and the peak on the strip chart recorder.
If the retention time of an unknown chemical agrees with the
retention time of a known chemical recorded under the same set of
analytical conditions, the unknown is tentatively identified. In
addition, the area under the peak is proportional to the concentration
of the corresponding sample component. If these areas are compared
to the areas of standards, recorded under identical analytical
conditions, the concentration of the sample components can be
calculated. (See FIGURE 8)
5. Catalytic Combustion Detectors
There are toxic monitors which use the same detection system as CGIs but
are more sensitive. In a sense they are super sensitive CGIs with readouts
in ppm instead of %LEL. Since the detection method is similar, they have
the same limitations and considerations as CGIs.
Some of these instruments, e.g. the Bacharach TLV Sniffer, give only
readings in parts per million (ppm). There are combination units, e.g.
Gastec Models 1238 and 1314, which give ppm readings along with %LEL
and oxygen readings.
6. Infrared Spectrophotometer
a. Principle of Operation
The infrared spectrophotometer is a compound- specific instrument.
Each compound being analyzed will absorb radiation at a discrete
infrared wavelength. The unit measures how much of the infrared
energy (IR) is absorbed and gives readings of percent IR absorbed or
ppm of chemical.
6/91
27
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Peak Height
Injection
Time (seconds)
Peak Area
FIGURE 8
EXAMPLE OF A GAS CHROMATOGRAM
Selection from Product Literature. The Foxboro Company, reprinted
with permission of The Foxboro Company.
Molecules are composed of atoms which are held together by bonds
of various types and lengths. These arrangements, as in the ball and
spring configurations presented in introductory chemistry, establish
finite locations and discrete movements for each atom (ball) and bond
(spring). These movements can be either vibrational, rotational,
stretching, or bending of the chemical bonds. The frequencies of
these movements are on the order of infrared radiation. A given
bond movement can be initiated by stimulating the molecule with IR
of varying frequency. As the bond moves, it absorbs the
characteristic energy associated with that movement. The frequencies
and intensity of IR absorbed are specific for a compound and its
concentration, providing a "fingerprint" which can be used as an
analytical tool.
Foxboro, Perkin-Elmer, and Beckman are producers of portable
infrared spectrophotometers. The MIRAN is manufactured by
Foxboro and is discussed below (FIGURE 9).
6/91
28
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ft
FILTER WHEEL
DETECTOH I CHOPPER
i r*—-r
PREAMP '
PATHLENGTH ADJUSTMENT
ELECTRONIC
BOARD
VARIABLE PATH GAS SAMPLE CELL
SOURCE
FIGURE 9
OPTICAL SCHEMATIC OF MIRAN ANALYZER
ft
The MIRAN (miniature infrared analyzer) is a field IR
spectrophotometer which uses a variable length gas cell to measure
concentrations of vapors in ambient air. The air sample is drawn
into a chamber for exposure to IR. Several movable mirrors permit
repeated passes, producing paths from several centimeters to several
meters. The longer the path length the better the detector response.
Field analysis presents problems not normally encountered with
spectrophotometry in the laboratory. With lab instruments, the
analyst can control the concentration of material entering the sample
cell. Liquid or solid samples are preferable to gas samples because
they possess more molecules than a gas of the same volume.
Additionally, the spectra of analyses of the same chemical in the
liquid phase and gaseous phase are markedly different. To analyze
gas samples the IR beam in the MIRAN must make repeated passes
to achieve reliable results. In the gaseous state, the molecules are
free to rotate, and inter-molecular actions are at a minimum. The
liquid state "locks" the molecules in a given structure.
Limitations and Considerations
The MIRAN is designed for industrial hygiene work in occupational
settings where known types of materials are generated. Thus it is
easy to select the IR frequency that is specific for the chemical in
question.
If the contents of the atmosphere are not known, a full scan of the IR
spectrum could be done to pick up any peaks. However, if many
chemicals were present it would be difficult to identify a specific
6/91
29
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chemical because of the many absorption peaks. If the instrument is
just looking at a "fingerprint" peak, there is the possibility that a
chemical could absorb at a peak that is not its "fingerprint" and cause
a false indication.
The instrument needs a flat or level surface free from vibration so
that the internal mirrors do not move and effect the light path.
7. Aerosol Monitors
Not all toxic materials dispersed in air are in the form of a gas or vapor.
Solids and liquids can become suspended in air by combustion, splashing
liquids or by disturbing soil.
There are direct-reading instruments that measure aerosols, i.e. dust, mist,
fume, smoke, fog, spray. Most of them use a light source and a light sensor
that measures the amount of light scattered by the aerosol. Readouts are in
milligrams per cubic meter (mg/m3). Some examples are MIE Incorporated
RAM-1 and MINIRAM and TSI Incorporated's Model 5150.
Other methods of detection are the piezoelectric crystal mass monitor and
beta attenuation. The piezoelectric crystal mass monitor uses a crystal that
resonates at a certain frequency as electric current is applied to it. As
particles collect on the crystal its resonant frequency changes and the change
is measured. An instrument using this detector is TSI Incorporated's Model
3500.
Beta attenuation measures the attenuation of beta radiation by particles
collected on a surface between the beta source and a beta detector. GCA
Corporation's Model RDM-101 is an instrument using this type of detector.
Accessories for these types of instruments include; an attachment that only
allows collection of "respirable" particles (i.e., ones that collect in the lungs)
instead of the total particles in air; and integrators for giving average
concentrations.
It is important to remember that these instruments give the total amount of
particulate and not the type of paniculate. Individual content, e.g., lead or
arsenic, must be analyzed separately. However, if the content of the sample
is known, then the direct-reading instrument could be used if content of the
dust is assumed to remain constant. For example, if the dust being detected
is 5% lead and 1% arsenic and the concentration of dust is 2 mg/m3 then the
concentration of lead and arsenic are 0.1 mg/m3 and 0.02 mg/m3
respectively (0.05 x 2 mg/m3 = 0.1 mg/m3 and 0.01 x 2 mg/m3 = 0.02
mg/m3).
8. Accessories/Options
As mentioned earlier, instruments combining more than one detector can be
found. For examples, "trimeters" and "quadmeters" combine an oxygen
indicator, a combustible gas indicator and one or two toxic monitors. Also
there are units with alarms that indicate readings that are above or below a
concentration of concern, strip chart (printed) outputs, and electronic outputs
for data storage.
6/91 30
-------
Some instruments have an integrator that averages concentrations while the
instrument is operating or over a specified time, e.g. 15 minutes. This
permits use of the instrument as a long term monitor as well as a direct-
^^ reading instrument.
One of the more recent additions is the microprocessor. This can be used
with a gas chromatograph so the microprocessor "reads" the output and
compares it to calibration information in its memory. That way the
instrument instead of the operator qualifies and quantifies the chemicals. In
some cases the operator asks the microprocessor to check for a chemical and
the unit uses its memory to match retention time and peak height.
Microsensor's Micromonitor, the Photovac 10S50, and the Sentex Scentor
use this capability. The MIRAN IB uses the microprocessor to select the
fingerprint frequency for the chemical requested. The main limitation with
the microprocessors are the number of chemicals in their memory or
"library". What the microprocessor doesn't recognize it can't identify. Most
portable units have libraries for up to 100 chemicals. Also the detection
method (PID, FID, etc.) used must be considered as that limits the number
of chemicals that can be identified.
9. Programmed Thermal Desorber (PTD)
The Programmed Thermal Desorber (Foxboro PTD-132A) is not a detection
system but does aid in on-site evaluation of air samples. It utilizes the
principle of thermal desorption to extract contaminants from carbon or other
sorbent tubes. The instrument performs this function automatically and has
the ability to store the desorbed sample in a 300 ml chamber and to make
replicate sample injections into a gas chromatograph or other analytical
instrument. It allows rapid on-site analysis of collected air samples. Within
the instrument is a small oven which is used to heat the sorbent tube to
temperatures ranging from 100°-350°C depending upon the application. This
heating has the effect of separating the sample from the sorbent, thus freeing
it to be carried by a flow of clean carrier gas to the storage chamber. From
there, the sample is released in carefully controlled amounts into the
analytical instrument of choice. If the instrument is a gas chromatograph,
the chromatogram is recorded in the normal fashion and the peaks are
qualitatively and quantitatively determined. The calculations necessary to
find the concentration of contaminant in the original air sample are simple
volumetric ratios. While the PTD was designed to be used with the Foxboro
CENTURY Organic Vapor Analyzer with a gas chromatograph accessory, it
can be used with other instruments.
6/91
31
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V. REFERENCES
1. American Conference of Governmental Industrial Hygienists: Air Sampling
Instruments for Evaluation of Atmospheric Contaminants. 6th Edition. 6500
Glenway Avenue, Building D-7, Cincinnati, OH.
2. Cee, R.J., J.C. Septon, J.C. Ku and T. Wilczek: " An Evaluation of Commercial
Detector Tube Systems." Paper presented at American Industrial Hygiene
Conference, Montreal, Canada, June 1987.
3. Clayton, George D. (ed.): The Industrial Environment - Its Evaluation and Control.
3rd ed., Public Health Services Publication, 1973.
4. Clayton, G.D., and F.E. Clayton (ed.): Patty's Industrial Hygiene and Toxicology,
3rd review ed., Vol. I: General Principles, John Wiley and Sons, New York, NY,
1978.
5. Conley, Robert: Infrared Spectroscopy. 2nd ed., Allyn and Bacon, Inc., Boston,
MA, 1972.
6. Klinsky, Joseph (ed,): Manual of Recommended Practice for Combustible Gas
Indicators and Portable Direct-Reading Hydrocarbon Detectors. 1st ed., American
Industrial Hygiene Association, Akron, OH, 1980.
7. National Fire Prevention Association: National Electrical Code. Vol. 70. 470
Atlantic Ave., Boston, MA 02210, 1986.
6/91 32
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SECTION 4
AIR SURVEILLANCE
PART TWO
MANUFACTURERS AND SUPPLIERS OF
AIR MONITORING AND SAMPLING EQUIPMENT
I. AIR MONITORING/SAMPLING EQUIPMENT
A. Aerosol/Particulate Monitors:
Andersen Samplers Incorporated
Air Techniques Incorporated
California Measurements, Inc.
General Metal Works Inc.
HUND Corporation
MDA Scientific, Inc.
Met One Inc.
MIE, Inc.
Pacific Scientific (HIAC/ROYCO Instrument Division)
Particle Measuring Systems Inc.
Products Production Marketing, Inc.
TSI Incorporated
Wedding & Associates, Inc.
B. Calibration Gases: (many manufacturers of instruments provide calibration gases for
use with their instruments)
— Airco Industrial Gases
- Alphagaz
Digicolor
Environics Inc.
GC Industries
Liquid Air Corporation
National Specialty Gases
Scott Specialty Gases
VICI Metronics
C. Canister Samplers:
Andersen Samplers Incorporated
Nutech Corporation
Scientific Instrumentation Specialists (SIS)
Wedding & Associates, Inc.
6/90 37
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D. Collection Media:
Ace Glass Incorporated
BGI Incorporated
DACO Products
Gelman Sciences
Gilian Instrument Corp.
Hi-Q Environmental Products Company
LaMotte Chemical Products Company
Micro Filtration Systems.
Millipore Corporation
Mine Safety Appliances Co.
Nuclepore Corporation
Schleicher & Schuell
Sipin, Anatole J., Co., Inc.
SKC Inc.
E. Combustible Gas Meters:
Bacharach Instruments
Biosystems Inc.
Dynamation Incorporated
Enmet Corporation
GasTech Inc.
GfG America Gas Detection Ltd.
Grace Industries, Inc.
Heath Consultants Incorporated
Industrial Scientific Corporation
J and N Enterprises, Inc.
Lumidor Safety Products e.s.p. inc.
Mine Safety Appliances Co.
National Draeger, Inc.
Neotronics N.A., Inc.
Rexnord Safety Products
Scott Aviation
Sierra Monitor Corporation
Texas Analytical Controls, Inc.
F. Detector/Colormetric Tubes:
— Enmet Corporation
- Matheson Safety Products
Mine Safety Appliances Co.
— National Draeger, Inc.
Sensidyne
G. Gas Bags:
AeroVironment Inc.
The Anspec Company, Inc.
6/90
38
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BGI Incorporated
Calibrated Instruments, Inc.
Digicolor
Nutech Corporation
Plastic Film Enterprises
Pollution Measurement Corporation
SKC Inc.
H. Gas Chromatographs:
Bruker Instruments
CMS Research Corporation
The Foxboro Company
HNU Systems, Inc.
Microsensor Technology, Inc.
Photovac Incorporated
S-Cubed
Sentex Sensing Technology, Inc.
Summit Interests
Thermo Environmental Instruments Inc.
Varian
XonTech, Inc.
I. Oxygen Meters:
Bacharach Inc.
Biosystems Inc.
Dynamation Incorporated
Enmet Corporation
GC Industries
GfG America Gas Detection Ltd.
GasTech Inc.
Industrial Scientific Corporation
Lumidor Safety Products e.s.p., Inc.
MDA Scientific, Inc.
Metrosonics, Inc.
Mine Safety Appliances Co.
National Draeger, Inc.
Neotronics N.A., Inc.
Rexnord Safety Products
Scott Aviation
— Sensidyne
Sierra Monitor Corporation
Teledyne Analytical Instruments
J. Passive Dosimeters:
Advanced Chemical Sensors
- Air Quality Research, Inc.
6/90 39
-------
MDA Scientific, Inc.
Midwest Environics, Inc.
Mine Safety Appliances Co.
Nutech Corporation
Sensidyne
Sipin, Anatole J., Co., Inc.
SKC Inc.
Spectrex Corporation
Staplex Air Sampler Division
Wedding & Associates
M. Toxic Monitors: (direct-reading instruments for low concentrations of contaminants)
Analect Instruments
Arizona Instrument, Jerome Division
Bacharach Inc.
Biosystems Inc.
- CEA Instruments, Inc.
CMS Research Corporation
- Dynamation Incorporated
- The Foxboro Company
GasTech Inc.
GfG America Gas Detection Ltd.
GMD Systems, Inc.
Grace Industries, Inc.
Heath Consultants Incorporated
HNU Systems, Inc.
Industrial Scientific Corporation
InterScan Corporation
J and N Enterprises, Inc.
Macurco, Inc.
Matheson Safety Products
Metrosonics Inc.
Mine Safety Appliances Co.
Neotronics N.A., Inc.
Photovac Incorporated
— Rexnord Safety Products
Scott Aviation
— Sensidyne
— Sierra Monitor Corporation
Summit Interests
Sybron Corporation
Tekmar Company
Texas Analytical Controls, Inc.
TIP Instruments, Inc.
- Transducer Research, Inc.
VICI Metronics
6/90 40
-------
ft
Berthold Analytical Instruments, Inc.
28 Charron Avenue
Nashua, NH 03063
603/889-3309
800/343-6345
Biosystems, Inc.
P.O. Box D
Pistol Shop Road
Rockfall, CT 06481
203/344-1079
Bruker Instruments, Inc.
Manning Park
Billerica, MA 01821
617/667-9580
CEA Instruments, Inc.
P.O. Box 303
16 Chestnut Street
Emerson, NJ 07630
201/967-5660
Calibrated Instruments, Inc.
731 Saw Milt River Road
Ardsley, NY 10502
914/693-9232
Crystal Diagnostics, Inc.
600 West Cummings Park
Woburn, MA 01801
617/933-4114
DACO Products, Inc.
12 S. Mountain Avenue
Montclair, NJ 07042
201/744-2453
Delta Power Corporation
Box 1197
Mashpee, MA 02649
617/477-0404
Digicolor
2770 East Main Street
P.O. Box 09763
Columbus, OH 43209
614/236-1213
Dosimeter Corporation of America
11286 Grooms Road
Cincinnati, OH 45242
513/489-8100
DuPont Company Instrument Systems
P.O. Box 10, N. Walnut Road
Kennett Square, PA 19378
215/444^035
800/344-4900
Dynamation Incorporated
3784 Plaza Drive
Ann Arbor, MI 48104
313/769-0573
Eberline Instrument Corporation
Division of Thermo Electron Corp.
P.O. Box 2108
Santa Fe, NM 87504-2108
505/471-3232
Energetics Science
Six Skyline Drive
Hawthorne, NY 10532
914/592-3010
Emnet Corporation
P.O. Box 979
2308 S. Industrial Highway
Ann Arbor, MI 48106-0979
313/761-1270
FMT Equipment
P.O. Box 6198
Hemden, CT 06517
203/865-2864
The Foxboro Company
Foxboro, MA 02035
617/543-8750
G C Industries
20361 Prairie St., Unit 4
Chatsworth, CA 91311
213/701-7072
GFG America Gas Detection Ltd.
8269 Brentwood Industrial Court
St. Louis, MO 63144
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R.S. Landauer, Jr. & Co.
Glenwood Science Park
Glenwood, IL 60425-1586
312/755-7000
Ludlum, Inc.
P.O. Box 248
Sweetwater, TX 79556
915/235-5494
Lumidor Safety Products e.s.p., Inc.
5364 NW 167th Street
Miami, FL 33014
305/625-6511
MDA Scientific, Inc.
405 Barclay Blvd.
Lincolnshire, IL 60069
312/634-2800
800/323-2000
MG Industries
175 Meister Avenue
North Branch, NJ 08876
201/231-9595
MIE, Inc.
213 Burlington Road
Bedford, MA 01730
617/275-5444
Macurco, Inc.
3946 S. Mariposa Street
Englewood, CO 80110
303/781-t062
Mast Development Company
Air Monitoring Division
2212 East 12th Street
Davenport, IA 52803
319/326-0141
Mateson Chemical Corporation
1025 E. Montgomery Avenue
Philadelphia, PA 19125
215/423-3200
Matheson Safety Products
P.O. Box 85
East Rutherford, NJ 07073
201/933-2400
Met One, Inc.
481 California Avenue
Grants Pass, OR 97526
503/479-1248
Metrosonics, Inc.
P.O. Box 23075
Rochester, NY 14692-3075
800/654-7778
Micro Filtration Systems
6800 Sierra Court
Dublin, CA 94568
415/828-6010
Microsensor Technology, Inc.
47747 Warm Springs Blvd.
Fremont, CA 94539
415/490-0900
Millipore Corporation -
Lab Products Division
80 Ashby Road
Bedford, MA 01730
800/225-1380
Mine Safety Appliances
P.O. Box 426
Pittsburgh, PA 15230
412/967-3000
National Draeger, Inc.
101 Technology Drive
Pittsburgh, PA 15230
412/787-8383
National Specialty Gases
630 United Drive
Durham, NC 27713-9985
Neotronics N.A., Inc.
P.O. Box 370
411 North Bradford Street
Gainesville, GA 30503
404/535-0600
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Spectrex Corporation
3594 Haven Avenue
Redwood City, CA 94063
415/365-6567
Staplex Company
Air Sampler Division
777 Fifth Avenue
Brooklyn, NY 11232-1695
212/768-3333
800/221-0822
Summit Interests
P.O. Box 1128
Lyons, CO 80540
303/823-5303
Sybron Corporation
Analytical Products Division
221 Rivermoor Street
Boston, MA 02132
617/469-3300
3M/Occupation Health & Safety
Products Division 3M Center
Building 220-3E
StPaul, MN 55144
800/328-1667
TIP Instruments Inc.
9101 NW 7th Avenue
Miami, FL 33150
305/757-8811
TSI Incorporated
500 Cardigan Road
P.O. Box 43394
St Paul, MN 55164
612/483-0900
Tekmar Company
P.O. Box 371856
Cincinnati, OH 45222
800/543-4461
Teledyne Analytical Instruments
16830 Chestnut Street
City of Industry, CA 91749
213/283-7181
Terradex Corporation
460 N. Wiget Lane
Walnut Creek, CA 94598
415/938-2545
Texas Analytical Controls, Inc.
P.O. Box 42520
Houston, TX 77242
713/240-4160
Thermo Environmental Instruments
108 South Street
Hopkinton, MA 01748
617/435-5321
Thompson & Nielsen Electronics Ltd.
303-4019 Carling Avenue
Kanata, Ontario, Canada
613/592-3019
VICI Metronics
2991 Corvin Drive
Santa Clara, CA 95051
408/737-0550
Victoreen Instrument Inc.
10101 Woodland Avenue
Cleveland, OH 44104
216/795-8200
Warrington Laboratories, Inc.
P.O. Box 15147
7801 N. Lamar, D-lll
Austin, TX 78752
512/452-2590
Wedding & Associates, Inc.
P.O. Box 1756
Fort Collins, CO 80522
303/221-0678
Whatman Paper Division
9 Bridewell Place
Clifton, NJ 07014
201/773-5800
Wheaton Scientific
1000 North 10th Street
Millville, NJ 08332
609/825-1400
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SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
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PERSONAL PROTECTIVE EQUIPMENT
SECTION OBJECTIVE
The objectives of this section are to:
Discuss characteristics and types of respiratory protection and chemical protective
clothing equipment.
Provide students with a copy and/or summary of the following personal protective
equipment standards and guidance documents:
OSHA Regulations for Personal Protective Equipment
(29CFR 1910.132- 136).
USEPA Occupational Health and Safety Respiratory Protection Guidelines
(1983).
NIOSH Respiratory Decision Logic (1987).
Provide students with a list of manufactures and suppliers of personal protective
equipment.
STUDENT PERFORMANCE OBJECTIVES
After completing this section and related lesson(s), the student will be able to:
• Identify various types of respiratory protection and chemical protective clothing.
• Discuss the decision-making process in selecting respiratory protection and chemical
protective clothing.
• Identify manufactures and suppliers of personal protective equipment.
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SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
PART 1
INTRODUCTION TO RESPIRATORY PROTECTION
I. INTRODUCTION
The respiratory system is able to tolerate exposures to toxic gases, vapors and particulates,
but only to a limited degree. Some chemicals can impair or destroy portions of the
respiratory tract, or they may be absorbed directly into the bloodstream from the lungs.
Chemicals that enter the blood may eventually affect the function of other organs and tissues.
The respiratory system can be protected by avoiding or minimizing exposure to harmful
substances. Engineering controls such as ventilation help decrease exposure. When these
methods are not feasible respirators may provide protection. Certain respirators can filter
gases, vapors, and particulates in the ambient atmosphere, other respirators are available
which can supply clean breathing air to the wearer.
The use of respirators is regulated by the Occupational Safety and Health Administration
(OSHA). Regulations stipulate the use of approved respirators, proper selection, and
individual fitting of respirator users. This unit discusses the topics necessary to ensure
quality respiratory protection.
II. THE RESPIRATORY SYSTEM - STRUCTURE AND FUNCTION
A. Inhalation
When air is inhaled, the chest muscles and diaphragm contract, lifting the rib cage
and dropping the diaphragm. These actions enlarge the chest cavity. As a result,
the lungs expand and fill with air (FIGURE 1).
Normally, air is pulled through the nose, but it also can be inhaled through the
mouth. The nasal passages are very narrow and divided which forces the air to
travel a turbulent path. Particulate matter is impacted, and soluble particulates, and
gases are absorbed on the walls of the passages. Still, some contaminants escape this
initial deposition and penetrate further into the respiratory system.
The inhaled air passes through the pharynx and enters the trachea at the larynx. The
pharynx is the common port for the passage of air and food. The trachea, commonly
called the windpipe, divides into two bronchi, one leading to each lung. Further
divisions of the bronchus are named bronchioles. Collectively the passages are
called conducting tubes because they carry air to the sites where oxygen and carbon
dioxide are exchanged. Lining the conducting tubes are mucous and cilia.
Contaminants are caught in the mucous, swept up to the esophagus by the cilia, and
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swallowed. In this way, the respiratory system rids itself of some contaminants in
inhaled air.
At the end of the bronchioles are alveoli, sacs with very thin walls, filled with
bundles of capillaries (minute blood vessels that connect arteries and veins). Here
oxygen in the inhaled air is diffused into the bloodstream and carbon dioxide is
diffused out to be exhaled.
Masai
Passages
Pharynx
Bronchiole
Terminal
Bronchiole
Diaphragm
Alveoli
FIGURE 1
STRUCTURE OF RESPIRATORY SYSTEM
B. Exhalation
When air is exhaled, the chest muscles and diaphragm are expanded, decreasing the
size of the chest cavity. This forces air out of the lungs back along the same route.
A relaxed person breathes about 10 liters of air per minute. During brisk activity,
the volume can increase to over 75 liters per minute. In such a situation, the
respiratory system must handle a very large volume of air.
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III. RESPIRATORY HAZARDS
The normal atmosphere consists of 78% nitrogen, 21% oxygen, 0.9% inert gases and 0.04%
carbon dioxide. An atmosphere containing toxic contaminants, even at very low
concentrations, could be a hazard to the lungs and body. A concentration large enough to
decrease the percentage of oxygen in the air can lead to asphyxiation, even if the con-
taminant is an inert gas.
A. Oxygen Deficiency
The body requires oxygen to live. If the oxygen concentration decreases, the body
reacts in various ways (TABLE 1). Death occurs rapidly when the concentration
decreases to 6%.
TABLE 1
PHYSIOLOGICAL EFFECT OF OXYGEN DEFICIENCY
% OXYGEN (by volume) AT SEA
LEVEL
21 - 16
16 -21
12 - 10
10 -6
< 6
EFFECTS
Nothing abnormal
Loss of peripheral vision, increased
breathing
volume, accelerated heartbeat, impaired
attention and thinking, impaired
coordination
Very faulty judgement, very poor
muscular coordination, muscular exertion
causes fatigue that may cause permanent
heart damage, intermittent respiration
Nausea, vomitting, inability to perform
vigorous movement, or loss of all
movement, unconsciousness, followed by
death
Spasmatic breathing, convulsive
movement, death in minutes
Physiological effects of oxygen deficiency are not apparent until the concentration
decreases to 16%. The various regulations and standards dealing with respirator use
recommend that concentrations ranging from 16-19.5% be considered indicative of
an oxygen deficiency. Such numbers take into account individual physiological
responses, errors in measurement, and other safety considerations. In hazardous
materials response operations 19.5% oxygen in air is considered the lowest "safe"
working concentration. Below 19.5% available oxygen, a supplied air respirator
must be used.
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B. Aerosols
Aerosol is a term used to describe fine particulates (solid or liquid) suspended in air.
Particulates ranging in diameter from 5 to 30 microns are deposited in the nasal and
pharyngeal passages. The trachea and smaller conducting tubes collect particulates
1-5 microns in diameter. For particulates to diffuse from the bronchioles into alveoli
they must be less than 0.5 microns in diameter. Larger particles do reach the alveoli
due to gravity. The smallest particulates may never be deposited in the alveoli and
so may diffuse back into the conducting tubes to be exhaled.
Aerosols can be classified in two ways: by their physical form and origin and by the
physiological effect on the body.
1. Physical Classification Examples:
Mechanical dispersoid: liquid or solid particle
mechanically produced.
Condensation dispersoid: liquid or solid
particle often produced by combustion.
Spray: visible liquid mechanical dispersoid.
Fume: extremely small solid condensation
dispersoid.
Mist: liquid condensation dispersoid.
Fog: mist dense enough to obscure vision.
Smoke: liquid or solid organic particles
resulting from incomplete combustion.
Smog: mixture of smoke and fog.
2. Physiological Classification Examples:
Nuisance: no lung injury but proper lung functioning
inhibited.
Inert pulmonary reaction causing: non-specific reaction.
Pulmonary fibrosis1 causing: effects ranging from nodule
production in lungs to serious diseases such as asbestosis.
Chemical irritation: irritation, inflammation, or
ulceration of lung tissue.
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Systemic poison: diseases in other parts of the body.
Allergy-producing: causes allergic hyper sensitivity
reactions such as itching or sneezing.
C. Gaseous Contaminants
Gases and vapors are filtered to some degree on their trip through the respiratory
tract. Soluble gases and vapors are absorbed by the conducting tubes in route to the
alveoli. Not all will be absorbed so that along with insoluble gases, they finally
diffuse into the alveoli where they can be directly absorbed into the bloodstream.
Gaseous contaminants can be classified as chemical and physiological hazards.
1. Chemical
Acidic: acids or react with water to form
acids.
Alkaline: bases or react with water to
form bases.
Organic: compounds which contain carbon;
may range from methane to chlorinated organic solvents.
Organometallic: organic compounds containing
metals.
Hydrides: compound in which hydrogen is
bonded to another metal.
Inert: no chemical reactivity.
2. Physiological
Irritants: corrosive substances which injure
and inflame tissue.
Asphyxiants: substances which displace oxygen
or prevent the use of oxygen in the body.
Anesthetics: substances which depress the
central nervous system, causing a loss of
sensation or intoxication.
Systemic poisons: substances which can cause
disease in various organ systems.
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IV. RESPIRATORY PROTECTION DEVICES
The basic function of a respirator is to reduce the risk of respiratory injury due to breathing
airborne contaminants. A respirator provides protection by removing the contaminants from
ambient air or by supplying the wearer with an alternate source of clean breathing air.
All respiratory apparatus are composed of two main parts: (1) the device which supplies or
purifies air, and (2) the facepiece which covers the nose and mouth and seals out the
contaminants. The first component defines what class of respirator the device is; the second
determines the relative measure of protection afforded by that respirator.
A. Classes of Respirators
Respirators are divided into two major classifications according to their mode of
operation:
1. Air Purifying Respirators (APR's) remove contaminants by passing the
breathing air through a purifying element. There are a wide variety of
APR's available to protect against specific contaminants, but they all fall into
two subclasses: (1) paniculate APR's which employ a mechanical filter
element, and (2) gas and vapor APR's that utilize chemical sorbents
contained in a cartridge or canister.
It is important to realize that there are limitations on the applications of
APR's. These devices are specific for certain types of contaminants, so the
identity of the hazardous agent must be known. There are maximum
concentration limits; this requires a knowledge of the ambient concentration
of the contaminant, as well as the Maximum Use Limit (MUL) of the
respirator. Since APR's only clean the air, the ambient concentration of
oxygen must be sufficient (> 19.5%) for the user.
2. Atmosphere - Supplying Respirators (ASR's) provide a substitute source of
clean breathing air. The respirable air is supplied to the worker from either
a stationary source through a long hose, or from a portable container. The
first type are called supplied-air respirators and the latter are known as self-
contained breathing apparatus (SCBA).
These devices can be used regardless of the type of airborne
contaminant or oxygen concentration. However, the contaminant
concentration limits vary for the different types of ASR's and the wearer
must be aware of the limitations of his/her respirator.
B. Respiratory Protection
The protection provided the respirator wearer is a function of how well the facepiece
(mask) fits. No matter how efficient the purifying element or how clean the supplied
air, there is little protection afforded if the respirator mask does not provide a leak-
free facepiece-to-face seal. Facepieces are available in three basic configurations
(see FIGURE 2) which relate to their protective capacity.
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Quarter-Mask (Type B Half-Mask) fits over the bridge of the nose, along the
cheek, and across the top of the chin. The headbands which hold the
respirator in place are attached at two or four places of the mask (i.e. two-
or four-point suspension). Limited protection is expected because the respir-
ator can be easily dislodged, creating a breach in the seal.
Half-Mask (Type A Half-Mask) fits over the bridge of the nose, along the
cheek, and under the chin. Headbands have a fourpoint suspension. Because
they maintain a better seal and are less likely to be dislodged, half-masks
give greater protection than quarter-masks.
Full-Facepiece fits across the forehead, down over the temples and cheeks,
and under the chin. They typically have a head harness with a five or six-
point suspension. These masks give the greatest protection because they are
held in place more securely and because it is easier to maintain a good seal
along the forehead than it is across the top of the nose. An added benefit is
the eye protection from the clear lens in the full-facepiece.
FACETIECE
INHALATION VALVE
AIR PURIFYING
ELEMENT
EXHALATION VALVE
OUABTER-MASK RESPIRATOR
HEADBANDS
HALF-MASK RESPIRATOR
INHALATION VALVE
AIM rURIFTINQ
ELEMENT
FACEMECC
AIR DIRECTING
INLET
EXHALATION VALVE
FULL FACEPIECE RESPIRATOR
FIGURE 2
TYPES OF RESPIRATOR FACEPIECES
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Not all respirators fit everyone, so each individual must find out which
manufacturer's masks he/she can properly wear. At best, any given respirator will
fit 60% of the working population. But with the large number of respirators
available, at least one type should be found to fit an individual.
The use of respirators is prohibited when conditions prevent a good facepiece-to-face
seal. Some examples of these conditions are facial hair, skullcaps, long hair, make-
up, temple pieces on eyeglasses. Because maintaining a leak-free seal is so
important, personnel required to wear respirators must successfully pass a fit-test
designed to check the integrity of the seal.There are two types of fit-tests:
quantitative and qualitative. The quantitative test is an analytical determination of
the concentration of a test agent inside the facepiece compared to that outside the
mask. This concentration ratio is called the Assigned Protection Factor (APF) and
is a measure of the relative protection offered by a respirator. For example, if the
ambient concentration of the test agent is 1000 and the concentration inside the mask
is 10 ppm, the respirator gives the tested individual an APF of 100. So:
Concentration outside mask
"~ ~ Concentration inside mask
Because quantitative tests are expensive and tedious, qualitative tests are most
often performed to check respirator fit. A qualitative fit-test is not an analytical
measurement. It is a subjective test where an irritant or aroma is used to determine
if there is a good facepiece-to-face seal. If the test subject does not respond (by
smelling, tasting, coughing, etc.) to the test agent, he/she can wear the tested
respirator with the APF for that type of mask. Table 2 lists several types of
respirators and their APFs.
A Protection Factor is used to determine the Maximum Use Limit (MUL) of a
successfully fit-tested respirator. The MUL is the highest concentration, not
exceeding IDLH concentration, of a specific contaminant in which a respirator can
be worn:
MUL = APF x TLV
For example, if a contaminant has a TLV-TWA of 10 ppm, then the MUL for any
half-mask respirator is 100 ppm; the MUL for a full-facepiece APR or demand
SCBA is 1000 ppm. If the ambient concentration is greater than 1000 ppm, then a
pressure demand SCBA is required.
Fit testing and Assigned Protection Factors are only two of the several considerations
for selecting the proper respirator. Much more detailed information on the types and
applications of APR's and ASR's is covered in the other Parts of this Section.
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TABLE 2
RESPIRATOR ASSIGNED PROTECTION FACTORS*
Type of Respirator
Air-purifying
quarter-mask
half-mask
Air-line
quarter-mask
half-mask
Hose mask
full facepiece
SCBA, demand
quarter-mask
half-mask
Air-purifying
full facepiece
Air-line, demand
full facepiece
SCBA, demand
full facepiece
Airline, pressure-demand,
with escape provision
full facepiece (no test required)
SCBA, pressure-demand or
positive pressure
full facepiece (no test required)
NIOSH
APF (Qualitative Test)
5
10
10
10
10
10
10
50
50
50
10,000
10,000
* For more detailed information consult Table 5. "Respirator Protection Factors" in ANSI Z88.2-
1980.
V. RESPIRATOR USE AND SELECTION
A. User Requirements
The health of a respirator wearer is based on how the respirator is used. The
American National Standards Institute (ANSI) has prepared the "American National
Standard Practices for Respiratory Protection", and updates it periodically. The
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latest, version Z88.2-1980, was issued in 1980 as a voluntary standard. It addresses
all phases of respirator use and is highly recommended as a guide to respiratory
protection.
The Occupational Safety and Health Administration (OSHA), in 19 CFR Part
1910.120, refers to 19 CFR Part 1910.134 as the source of respiratory protection
regulations issued in 1975 (see Part 7). In 19 CFR Part 1910.134, OSHA cites
ANSI Z88.2-1969 as the reference for these enforceable regulations.
Section b of 29 CFR 1910.134, as well as Z88.2-1980, requires a "minimal
acceptable program" to ensure sound respiratory protection practices. The balance
of the regulations discusses specific requirements for respiratory use. The
requirements for a minimal acceptable program are quoted from 29 CFR 1910.134
as follows:
1. Written standard operating procedures governing the selection and use of
respirators shall be established.
2. Respirators shall be selected on the basis of the hazards to which the worker
is exposed.
3. The user shall be instructed and trained in the proper use of respirators and
their limitations.
4. Respirators shall be regularly cleaned and disinfected. Those used by more
than one worker shall be thoroughly cleaned and disinfected after each use.
5. Respirators shall be stored in a convenient, clean, and sanitary location.
6. Respirators used routinely shall be inspected during cleaning. Worn or
deteriorated parts shall be replaced. Respirators for emergency use such as
self-contained devices shall be thoroughly inspected at least once a month and
after each use.
7. Appropriate surveillance of work area conditions and degree of employee
exposure or stress shall be maintained.
8. There shall be regular inspection and evaluation to determine the continued
effectiveness of the program.
9. Persons should not be assigned to tasks requiring use of respirators unless it
has been determined that they are physically able to perform the work and
use the equipment. The local physician shall determine what health and
physical conditions are pertinent. The respirator user's medical status should
be reviewed periodically (for instance annually).
10. Approved respirators shall be used. The respirator furnished shall provide
adequate respiratory protection against the particular hazard for which it is
designed in accordance with approvals established by the National Institute
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for Occupational Safety and Health (NIOSH). The complete text of 29 CFR
1910.134 can be found in Part 7 of this section.
B. Selection
In general ANSI Z88.2-1980 states that the selection of the proper approved
respirator depends upon:
The nature of the hazard.
The characteristics of the hazardous operation or
process.
The location of the hazardous area with respect
to a safe area having respirable air.
The period of time for which respiratory protection may be
needed.
The activity of workers in the hazardous area.
The physical characteristics, functional capabilities, and
limitations of respirators of various types.
The respirator/protection factors and respirator
fit.
All these criteria must be considered in the selection of a respirator. The Joint
NIOSH/OSHA Standards Completion Respirator Committee devised a "Respirator
Decision Logic" based on the above criteria.
ANSI Z88.2-1980 also describes the suitability of a particular respiratory protective
device for oxygen deficient or Immediately Dangerous to Life or Health (IDLH)
atmosphere. This information supplies only a portion of the information required to
select the appropriate respirator.
VI. RESPIRATOR APPROVAL
As stated above, OSHA regulations require the use of approved respirators. Respirators are
tested at the NIOSH Testing Laboratory in Morgantown, West Virginia in accordance with
the requirements of 30 CFR Part 11 and are jointly approved by the Mine Safety and Health
Administration (MSHA).
An MSHA/NIOSH approval indicates that the respirator in use is identical to the one
submitted for the original approval. If a manufacturer changes any part of the respirator
without resubmitting it to the NIOSH Testing Lab, the approval is invalid and will be
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rescinded. This is intended to protect the respirator user. Also, any unauthorized changes
or hybridization of a respirator by the user invalidates the respirator approval and all the
guarantees understood with the approval.
Appendix I presents the approval schedules for specific types of respirators. The schedule
number came from the original Bureau of Mines respirator approval requirements. The
Bureau of Mines preceded the Mining Enforcement and Safety Administration (NESA),
which eventually became MSHA.
Many agencies were responsible for respirator certification at one time or another. Thus
respirators in use today may bear approval numbers issued to the manufacturers by the
Bureau of Mines, MESA, and MSHA. The approval number must be displayed on the
respirator or its container. It consists of the prefix TC (Testing and Certification), the
schedule number, followed by the approval number. For example in TC-13F-69, "13" is
the schedule for self-contained breathing apparatus, "F" indicates the number of revisions
to the schedule, and 69 is the consecutive approval number. Also, the approval label
includes the certifying agencies.
Periodically, NIOSH publishes a list of all approved respirators and respirator components.
The current edition, issued in 1988, is entitled the NIOSH Certified Equipment List as of
September. (DHHS [NIOSH] Publication No. 87-102). This document is used to answer two
basic questions about respiratory protection:
Is this respirator appropriate (approved) for the
existing work conditions?
Is this respirator (mask and purifying-elements)
an approved assembly?
If the answer to either of these questions is "no", then the worker is prohibited from using
that respirator (or type of respirator). Table 3 in Appendix I presents an example of the
"NIOSH Certified Equipment List".
VII. RESPIRATOR CARE AND CLEANING
Once a respirator has been used it must be cleaned. All detachable parts such as straps,
valves, and gaskets are removed. Cartridges cannot be cleaned. They can be used again
if their service life has not been exhausted and they are stored properly. The facepiece and
other parts can be washed separately in sanitizer solution. The parts should go through two
water rinses and be left to air dry. When dry, the parts are reassembled and the respirator
is put in a clean plastic bag and stored where it will be protected from high temperatures,
very dusty environments or conditions that could alter the shape of the mask. Additional
details are provided in Part 2, Appendix IV.
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APPENDIX I
NIOSH CERTIFIED EQUIPMENT LIST
I. RESPIRATOR SELECTION
The selection of an appropriate respirator for use in a given situation can only be made by
carefully considering a number of interrelated environmental, equipment, work situation, and
human factors.
Once a type of respirator is selected, then the user can refer to appropriate table for a list
of all approved devices of that type:
RESPIRATOR TYPE
Self-Contained Breathing Apparatus
Gas Masks
Supplied-Air Respirators
Dust, Fume, and Mist Respirators
Chemical Cartridge Respirators
Vinyl Chloride Respirators
APPROVED SCHEDULE
TC-13F-
TC-14G-
TC-19C-
TC-21C-
TC-23C-
TC-11-
Also, if the user chooses a specific respirator, he/she can look up the approval number for
that device and determine the type of respirator protection it provides. For example, if you
were to choose an MSA half-mask respirator with organic vapor cartridges, you would first
find the approval number on the cartridge label. Next you look under the schedule for
chemical cartridge respirators organic vapor until you find the correct listing, in this case
TC-23C-201. From TABLE 3 (next page), it can be seen that this respirator can be used
for organic vapors, paints-lacquers-enamels, and dusts or mists under specified conditions.
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*
CO
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SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
PART 2
AIR-PURIFYING RESPIRATORS
I. INTRODUCTION
Respiratory protection must be used when the concentration of a substance in the ambient
atmosphere exceeds a personal exposure limit. Several exposure limits used to determine
the need for respiratory protection. In order of precedence,these are the OSHA Permissible
Exposure Limits (PELs), NIOSH Recommended Exposure Limits (RELs), and the ACGIH
Threshold Limit Values (TLVs). If none of these are available, other published data may
be used.
Air-purifying respirators may be used only if all of the following requirements are met:
The identity and concentration of the contaminant are known.
The ambient concentration of a contaminant is below the Immediately Dangerous to
Life and Health (IDLH) concentration.
The oxygen content in the atmosphere is greater than 19.5%.
The respirator assembly is approved for protection against the specific concentration
of a contaminant.
There is periodic monitoring of the work area.
The respirator assembly has been successfully fit tested on the user.
II. RESPIRATOR CONSTRUCTION
An air-purifying respirator (APR) consists of a facepiece and a purifying element. In some
APR designs there are combined in a single unit, more often they are separate components.
There are several basic designs of air-purifying respirators.
Disposable Dust Respirators
These are generally constructed using cloth or paper as the filter element. A
satisfactory face to respirator seal is difficult to achieve with this type of respirator.
Most respirators of this design are not approved. Those which are approved are
used for protection against dusts and mists. Some may be approved for asbestos use.
6/91 15
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Emergency Escape Mouthbit Respirators
Mouthbit respirators are approved for escape use only. The mouthpiece containing
the cartridge element is held in place by the teeth and a clamp is used to seal the
nostrils.
Quarter-Mask Respirators (Type B Half-Mask)
The quailer-mask respirator is used for dusts (airborne exposure limits not less than
0.05 mg/m3). The facepiece fits from the top of the nose to the top of the chin.
Half-Mask Respirators (Type A Half-Mask)
The half-mask respirator has approved cartridges for pesticides, organic vapors,
dusts, mists, fumes, and several other combinations. A half-mask respirator fits
from above the nose to under the chin.
Full-Face Respirators
A full-face respirator provides full face protection, including the eyes. It has a much
higher Assigned Protection Factor than either a quarter- of half-mask respirator. The
full-face mask may be used with a wide variety of filtration media. This type of
respirator may be used with cheek-mounted cartridges, chin-mounted cartridges,
chin-mounted canisters, or chest/back-mounted canisters.
Powered Air-Purifying Respirators
Powered air-purifying respirators utilize pumps or fans to force air through the
purifying elements. This eliminates breathing resistance and may help to maintain
positive pressure in the facepiece. Powered air-purifying respirators are available
in quarter, half, and full face designs as well as with specialized helmet assemblies.
III. FACEPIECE
The facepiece is the means of sealing the respirator assembly to the user's face. The
facepiece consists of the lens (full face only), mask suspension, and a means of attaching
the filtration elements. Inhalation check valves are used to prevent moist exhaled air from
being passed through the filter element. Exhalation check valves are used to allow
exhalation through the diaphragm. Each respirator manufacturer utilized different means for
attaching components to the facepiece. This prevents mixing parts from different
manufacturers (hybridization) which would void a respirator's approval.
Although many configurations exist, only four types of facepiece-element assemblies are
permissible for use with hazardous materials:
H?.lf-mask with twin cartridges or filters
Full-face mask with twin cartridges or filters
6/91 16
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Full-face mask with chin-mounted canister
Full-face mask with harness-mounted canister (gas mask)
The full-facepiece is the recommended facepiece for use. It provides eye protection, is
easier to fit, and has an Assigned Protection Factor greater than the half-mask.
IV. AIR-PURIFYING ELEMENTS
Respiratory hazards can be broken down into two classes: particulates and vapors/gases.
Particulates are filtered by mechanical means, while vapors and gases are removed by
sorbents that react chemically with them. Respirators using a combination of mechanical
filter and chemical sorbent will effectively remove both hazards.
A. Particulate-Removing Filters
Particulates can occur as dusts, fumes, or mists. The particle size can range from
macroscopic to microscopic, and their toxicological effects can be severe or
innocuous. The hazard posed by a particulate can be determined by its exposure
limit (EL). A nuisance particulate will have an EL of 10 mg/m3, while a toxic
particulate may have an EL well below 0.05 mg/m3.
Mechanical filters are classified according to the protection for which they are
approved under schedule 21C of 30 CFR Part 11. Most particulate filters are
approved only for dusts and/ or mists with ELs equal to or greater than 0.05 mg/m3.
These dusts are usually considered to produce pneumoconiosis and fibrosis. Such
filters have an efficiency of 80-90% for 0.6 micrometer particles.
Respirators approved for fumes are more efficient, removing 90
99% for 0.6 micrometer particles. This type of respirator is approved for dusts,
fumes and mists with ELs equal to or greater than 0.05 mg/m3.
Finally there is a high efficiency filter, which is 99.97% effective against particles
0.3 microns in diameter. It is approved for dusts, mists, and fumes with an EL less
than 0.05 mg/m3.
Mechanical filters load with particulates as they are used. As they do, they become
more efficient, but also become more difficult to breathe through. When a
mechanical filter becomes difficult to breathe through it should be replaced.
B. Gas and Vapor-Removing Cartridges and Canisters
When selecting a gas- or vapor-removing element, it must be chosen for protection
against a specific type of contaminant. Some of the commonly employed types of
chemical cartridges and canisters and their OSHA-required color coding are listed
in Table 4. This table has been excerpted from the OSHA respirator regulations for
general industry (29 CFR 1910.134) - the entire text of these regulations can be
found in Part 7 of this manual section.
6/91 17
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1. Style and Size
Gas- and vapor-elements are available in different styles. The physical
differences are: (1) size and (2) means of attachment to the facepiece. The
smallest elements are cartridges which contain 50-200 cm3 of sorbent and
attach directly to the facepiece, usually in pairs. Chin canisters have a
volume of 250-500 cm3 and are attached to a full-facepiece. Gas mask, or
industrial-size canisters contain 1000-2000 cm3 and are attached by a harness
to the wearer's front or back and connected to the full-facepiece by a
breathing hose. Figure 3 illustrates several styles of APR's.
1910.135
29 CFR Ch. XVII (7-1-86 Edition)
TABLE 4
CHEMCIAL CARTRIDGE TYPES AND COLOR CODING
ATMOSPHERIC CONTAMINANTS
TO BE PROTECTED AGAINST
Acid Gases
Hydrocyanic acid gas
Chlorine gas
Organic vapors
Ammonia gas
Acid gases and ammonia gas
Carbon monoxide
Acid gases and organic vapors
Hydrocyanic acid gas and chloropicrin vapor
Acid gases, organic vapors, and ammonia gases
Radioactive manterials, excepting tritium and noble gases
Particulates (dusts, fumes, mists, fogs, or smokes) in
combination with any of the above gases or vapors
All of the above atmospheric contaminants
COLORS ASSIGNED1
White
White with 1/2 inch green stripe completely around the
canister near the bottom
White with 1/2 inch yellow stripe completely around
the canister near the bottom
Black
Green
Green with 1/2 inch white stripe completely around the
canister near the bottom
Blue
Yellow
Yellow with 1/2 inch blue stripe completely around the
canister near the bottom
Brown
Purple (Magenta)
Canister color for contaminants, as designated above,
with 1/2 inch gray stripe completely around the canister
near the top.
Red with 1/2 inch gray stripe completely around the
canister near to top.
'Gray shall not be assigned as the main color for a canister designed to remove acids or vapors.
NOTE: Orange shall be used as a complete body, or stripe color to represent gases not included in this table. The user will
need to refer to the canister label to determine the degree of protection the canister will afford.
6/91
18
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HEADBANDS
<- 1/2 MASK AND CARTRIDGES
EXHALATION
VALVt
FACEFIECE
EYEPIECE
AIR DIRECTING INLET
INHALATION VALVE
AIR PURIFTIHG
ELEUEKT
<- FULL-FACEPIECE AND CHIN CANISTER
EXHALATION VALVE
EYEPIECC
DIRECTING AIR INLET 1
INHALATION VALVE
EXHALATION VALVE
HEAD HAHHCII
FUU-FACERECE AND INDUSTRIAL CANISTER ->
AIR r
ELEMENT (CANISTER)
FIGURE 3
TYPICAL STYLES OF APR'S
6/91
19
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The difference in applications is the Maximum Use Concentration (MUC) for which the
cartridge or canister can be used in accordance with its NIOSH/MSHA approval. For
example, organic vapors can be removed by the appropriate cartridges, chin canister, or
gas-mask canister. Cartridges are approved for use in atmospheres up to 1,000 ppm
(0.1%) organic vapors, chin style canisters up to 5000 ppm (0.5%), and gas mask
canisters up to 20,000 ppm (2.0%). However, no air-purifying respirator is permitted
in an IDLH atmosphere.
2. Service Life
Each sorbent has a finite capacity for removing contaminants and when this limit is
reached the cartridge or canister is said to be saturated. At this point the element will
allow the contaminant to pass through and enter the facepiece. The length of time a
cartridge or canister will effectively sorb the contaminant is known as the service life of
the element. Service life of a type of cartridge or canister is dependent on several
factors: the breathing rate of the wearer; contaminant concentration; and sorption
efficiency.
a. Breathing Rate
If the breathing rate of the user is rapid, the flow rate of the contaminated air drawn
through the cartridge is greater than it is at a moderate or slow respiration rate. A
higher flow rate brings a larger amount of contaminant in contact with the sorbent
in a given period of time which, in turn, increases the rate of sorbent saturation and
shortens service life.
b. Contaminant Concentration
The expected service life of an organic vapor cartridge decreases as ambient
contaminant concentration increases. As concentration goes up, the mass flow rate
increases, bringing more contaminant in contact with the sorbent in a given period
of time. For example, at any constant breathing rate, ten times as much contaminant
contacts the element when the concentration is 500 ppm compared to 50 ppm.
c. Cartridge Efficiency
Chemical sorbents vary in their ability to remove contaminants from air. Table 5
compares the efficiency of organic vapor cartridges for a number of solvents by
recording the amount of time until a 1% breathrough concentration was measured in
the cartridge-filtered air. The initial test concentration is 1000 ppm of solvent vapor;
the breathrough concentration is 10 ppm. From the table it can be seen that it takes
107 minutes for chlorobenzene to reach a 1% breakthrough, while it only takes 3.8
minutes for vinyl chloride. The sorbent (activated carbon) in the organic vapor
cartridge is much better for removing chlorobenzene than vinyl chloride under the
test conditions. Cartridge efficiencies need to be considered when selecting and
using APR's. References for cartridge efficiency studies can be found in Appendix
I.
6/91 20
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TABLE 5
EFFECT OF SOLVENT VAPOR ON
RESPIRATOR CARTRIDGE EFFICIENCY1
SOLVENT
Aromatics3
Benzene
Toluene
Ethyl benzene
m-Xylene
Cumene
Mestiylene
Alcohols3
Methanol
Ethanol
Isopropanol
Allyl alcohol
n-Propanol
sec-Butanol
Butanol
2-Methoxyethanol
Isoamyl alcohol
4-Methyl-2~pentanol
2-Ethoxyethanol
Amyl alcohol
2-Ethyl-l-butanol
Monochlorides3
Methyl chloride
Vinyl chloride
Ethyl chloride
Allyl chloride
1-Chloropropane
l-Chlorobutane
Chlorocyclopentane
TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
MINUTES (2)
73
94
84
99
81
86
0.2
28
54
66
70
96
115
116
97
75
77
102
76.5
0.05
3.8
5.6
31
25
72
78
6/91
21
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TABLE 5 CONT'D
EFFECT OF SOLVENT VAPOR ON
RESPIRATOR CARTRIDGE EFFICIENCY1
SOLVENT
TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
MINUTES (2)
Monochlorides3
Chlorobenzene
1-Chlorohexane
o-Chlorotoluene
1-Chloroheptane
3-(Choromethyl heptane)
107
77
102
82
63
Bichlorides3
Dichloromethane
trans-l,2-Dichloroethylene
1,1-Dichloroethane
cis-1,2-Dichloroethylene
1,2-Dichloroethane
1,2-Dichloropropane
1,4-Dichlorobutane
o-Dichlorobenzene
10
33
23
30
54
65
108
109
Trichlorides3
Chloroform
Methyl chloroform
Trichloroethylene
1,1,2-Trichlorethane
1,2,3-Trichloropropane
33
40
55
72
111
Tetra- anmd Pentachlorides3
Carbon tetrachloride
Perchloroethylene
1,1,2,2-Tetrachloroethane
Pentachloroethane
77
107
104
93
Acetates3
Methyl acetate
Vinyl acetate
Ethyl acetate
Isopropyl acetate
33
55
67
6/91
22
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TABLE 5 CONT'D
EFFECT OF SOLVENT VAPOR ON
RESPIRATOR CARTRIDGE EFFICIENCY1
SOLVENT
Acetates3 Cont'd
Isopropenyl acetate
Propyl acetate
Allyl acetate
sec-Butyl acetate
Butyl acetate
Isopentyl acetate
2-Methoxyethyl acetate
1,3-Dimethylbutyl acetate
Amyl acetate
2-Ethoxyethyl acetate
Hexyl acetate
Ketones4
Acetone
2-Butanone
2-Pentanone
4~Methyl-2-pentanone
Mesityl oxide
Cyclopentanone
3-Hepanone
2-Heptanone
Cyclohexanone
5-Methyl-3-heptanone
3-Methylcyclohexanone
Diisobutyl ketone
4-Methylcyclohexanone
Alkanes4
Pentane
Hexane
Methylcyclopentane
Cyclohexane
2,2,4-Trimethylpentane
Heptane
Methylcyclohexane
5-Ethylidene-2-norbornene
Nonane
Decane
TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
MINUTES (2)
83
79
76
83
77
71
93
61
73
80
67
37
82
104
94
96
122
141
91
101
126
86
101
71
111
61
52
62
69
68
78
69
87
76
71
6/91
23
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TABLE 5 CONT'D
EFFECT OF SOLVENT VAPOR ON
RESPIRATOR CARTRIDGE EFFICIENCY1
SOLVENT
Amines4
Methyl amine
Ethyl amine
Isopropyl amine
Propyl amine
Diethyl amine
Butyl amine
Triethyl amine
Dipropyl amine
Diisopropyl amine
Cyclohexyl amine
Ditbutyl amine
TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
MINUTES (2)
12
40
66
90
88
110
81
93
77
112
76
Miscellaneous materials4
Acrylonitrile
Pyridine
1-Nitropropane
Methyl iodide
Dibromomethane
1,2-Dibromoethane
Acetic anhydride
Bromobenzene
49
119
143
12
82
141
124
142
1 Nelson, G. 0., and C. A. Harder. Respirator Cartridge Efficiency Studikes,
University of California, Livermor. 1976.
2 Cartridge pairs tested at 1000 ppm, 50% relative humidity, 22C, and 53.3
liters/minute (equivalent to a moderately heavey work rate). Pair cartridges
preconditioned at room temperature and 50% relative humidity for at least 24
hours prior to testing.
3 Mine Safety Appliances Cartridges.
4 American Optical Cartridges.
6/91
24
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Warning Properties
A warning property is used as a sign that a cartridge or canister in use is beginning to lose its
effectiveness. A warning property can be detected as an odor, taste, or irritation. At the first
such signal, the old cartridge or canister must be exchanged for a fresh one. Without a warning
property, respirator efficiency may drop without the knowledge of the wearer, ultimately causing
a health hazard.
Most substances have warning properties at some concentration. A warning property detected
only at dangerous levels -- that is, greater than EL--is not considered adequate. An odor,
taste, or irritation detected at extremely low concentrations is also not adequate because the
warning is being given all the time or long before the filter begins to lose its effectiveness. In
this case, the wearer would never realize when the filter actually becomes ineffective.
The best concentration for a warning property to be first detected is around the EL. For
example, toluene has an odor threshold of 40 ppm and an EL of 100 ppm. This is usually
considered an adequate warning property. Conversely, dimethylformamide has an EL of 10 ppm
and an odor threshold of 100 ppm. An odor threshold ten times the EL is not an adequate
warning property. Adequate warning properties are discussed in more detail in the
NIOSH/OSHA Respirator Decision Logic (Section 5, Part 4, I of this manual). A list of
warning properties is found in Section 5, Part 2, Appendix V.
If a substance causes rapid olfactory fatigue (that is, the sense of smell is no longer effective),
its odor is not an adequate warning property. For example, upon entering an atmosphere
containing hydrogen sulfide, the odor is quite noticeable, After a short period of time, it is no
longer detectable.
V. REQUIREMENTS FOR RESPIRATOR USE
The use of an air-purifying respirator is contingent upon a number of criteria. If the conditions
spelled-out in this section of the text cannot be met, then use of an APR is prohibited. Figure
2-2 illustrates the selection criteria in a flow diagram.
A. Oxygen Content
The normal atmosphere contains approximately 21% oxygen. The physiological effects of
reduced oxygen begin to be evident at 16%. Without regard to contaminants, the
atmosphere must contain a minimum of 19.5% oxygen to permit use of an air-purifying res-
pirator. This is a legal requirement of 30 CFR Part 11 and a recommendation of ANSI
Z88.2 - 1980. Below 19.5% oxygen, atmosphere-supplying respirators must be used
instead.
B. Identification of Contaminants
It is absolutely imperative that the contaminant(s) be known so that:
the toxic effects of inhaling the contaminant can be determined;
appropriate particulate filters or cartridges/canisters can be chosen;
6/91 25
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it can be determined that adequate warning properties exist for the contaminant;
the appropriate facepiece be selected (full-face mask is necessary if the agent causes eye
irritation).
C. Known Contaminant Concentration
The maximum concentration depends on the contaminant and the respirator.
concentration must not exceed IDLH;
the Maximum Use Limit of the respirator cannot be exceeded (MUL = APF * EL);
the Maximum Use Concentration of a particular type and size cartridge or canister must
not be surpassed;
expected service life (cartridge/canister efficiency) should be detertnined, if possible..
D. Periodic Monitoring of Hazards
Because of the importance of knowing the identity and concentration of the contaminant(s),
monitoring of the work area with appropriate equipment must occur at least periodically
during the work day. This is done to ensure that no significant changes have occurred and
the respirators being used are adequate for the work conditions.
E. Approval of Respirators
The respirator assembly (facepiece and air-purifying elements) is approved for protection
against the contaminant at the concentration which is present in the work area. The
concentration must not exceed the NIOSH/MSHA designated MUC for that type and size
cartridge or canister.
F. Fit-test
The wearer must pass a qualitative fit-test for the make, model, and size of air-purifying
device used (Appendices II and III) provide instructions for the qualitative tests. The OSHA
regulations, in 29 CFR 1910.1345 (e) (5) (i), state: "Every respirator wearer shall receive
fitting instructions including demonstrations and practice in how the respirator is worn, how
to adjust it, and how to determine if it fits properly. Respirators shall not be worn when
conditions prevent a good face seal. Such conditions may be growth of beard, sideburns,
a skull cap that projects under the facepiece, or temple pieces on glasses. Also, the absence
of one or both dentures can seriously affect the fit of a facepiece. The worker's diligence
in observing these factors shall be evaluated by periodic check. To assure proper protection,
the facepiece fit shall be checked by the wearer each time he puts on the respirator. This
may be done by giving filing instructions".
6/91 26
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APPENDIX I
REFERENCE FOR RESPIRATOR CARTRIDGE EFFICIENCIES STUDIES
Ruch, W.E., G.O. Nelson, C.L. Lindeken, R.E. Johjnsen, and D.J. Hodgkins. "Respirator
Cartridge Efficiency Studies: 1. Experimental Design." American Industrial Hygiene
Association i.33. 105 (1972)
Nelson, G.O., and D.H. Hodgkins. "Respirator Cartridge Efficiency Studies:
II. Preparation of Test Atmospheres." American Industrial Hygiene Association J. 33. 110
(1972).
Nelson, G.O., R.E. Johnsen, C.L. Lindeken, and R.D. Taylor. "Respirator
Cartridge Efficiency Studies: III. A Mechanical Breathing Machine to Simulate Human
Respiration." American Industrial Hygiene Association J. 33, 745 (1972).
Nelson, G.O., C.A. Harder. "Respirator Cartridge Efficienty Studies: IV.
Effects of Steady-State and Pulsating Flow." American Industrial Hygiene Association J. 33,
797 (1972).
Nelson, G.O., C.A. Harder, and B.E. Bigler. "Respirator Cartridge Efficiency
Studies: VI. Effect of Concentration". Lawrence Livermore Laboratory, Rept. UCRL-76184
(November, 1974).
Nelson, G.O., and C.A. Harder. "Respirator Cartridge Efficiency Studies: V.
Effect of Solvent Vapor." American Industrial Hygiene Association J. 35, 391 (1974).
Nelson, G.O., C.A. Harder, and B.E. Bigler. "Respirator Cartridge Efficiency
Studies: VII. Effect of Relative Humidity and Temperature." Lawrence Livermore Laboratory,
Rept. UCRL-77390 (August, 1975).
Nelson, G.O., and A.N. Correia. "Respirator Cartridge Efficiency Studies:
VIII. Summary and Conclusions." American Industrial Hygiene Association J. 37,9 (1976).
6/91 27
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APPENDIX II
RESPIRATOR FIT-TESTING
I. INTRODUCTION
All users of potential users of demand-type respiratory protection devices should be fit tested
to ensure a proper facepiece-to-face seal. Either isoamyl acetate or irritant smoke should be
used with one of the four methods described below. A selection of respirators should be tested,
with users allowed to choose the most comfortable from those that fit satisfactorily.
II. METHODS
A. Method No 1 - Swab or Brush (Organic Vapors)
Use only facepieces equipped with organic vapor cartridges.
Perform the test in area with no noticeable air movement.
- Saturate a tissue, cloth, or brush with isoamyl acetate.
Prior to testing, expose subject to a very low concentration of isoamyl acetate to assure
that he/she can detect the odor.
After subject dons the respirator, tester visually inspects facepiece-to-face seal. If seal
obviously leaks, test ends and mask is recorded as unsatisfactory. If subject is
uncomfortable, test ends.
Move saturated material slowly around entire sealing surface of the respirator at a
distance of 3 to 6 inches. Perform first with test subject sedentary, then with subject
moving head and face (i.e., talking, moving head side to side and up and down). End
test if any leakage occurs.
If the subject detects the odor during fitting, record that respirator as unsatisfactory,
remove it from the subject, and visually inspect the facepiece-to-face seal. If any doubt
exists about the respirator or cartridges, test a duplicate to assure that the leakage was
due to facepiece-to-face seal.
B. Method No. 2 - Around Seal (Particulates)
- Use respirators equipped with high-efficiency filters (HEPA)
Perform test in area with no noticeable air movement.
6/91 29
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Break both ends of a ventilation smoke tube. Insert one
end into the tube connected to the positive-pressure end of a two-way aspirator bulb and
cover the other end with 1- to 2 inch length of Tygon, surgical, or rubber tubing.
Squeeze the aspirator bulb to generate the test aerosol.
After subject dons the respirator, tester visually inspects facepiece-to-face seal. If seal
obviously leaks, test ends and mask is recorded as unsatisfactory. If subject is
uncomfortable, test ends.
Direct the smoke around entire sealing surface of the respirator at a distance of 3 to 6
inches. Instruct subject to breathe shallowly during initial test around surface and
normally thereafter if no leakage is detected. If a half-mask is being tested, instruct
subject to close his/her eyes for the duration of the test. Perform the test first with
subject sedentary, then with subject moving head and face (i.e., talking, moving head
side to side and up and down). End test if any leakage occurs.
- If the subject detects the odor during fitting, record that respirator as unsatisfactory,
remove it from the subject, and visually inspect the sealing surface. If any doubt exists
about the respirator or cartridges, test a duplicate to assure that the leakage was due to
the facepiece-to-face seal.
C. Method No. 3 - Enclosure in Plastic Bag (Organic Vapors)
Use facepieces equipped with organic vapor cartridges.
Saturate a tissue or cloth with isoamyl acetate and suspend it inside the top of a plastic
garbage bag or harvard hood.
Prior to testing, expose subject to a very low concentration of the isoamyl acetate to
assure that he/she can detect the odor.
After subject dons the respirator, tester visually inspects facepiece-to-face seal. If seal
obviously leaks, test ends and mask is recorded as unsatisfactory. If subject is
uncomfortable, test ends.
Instruct subject to put his/her head into the bag or hood and breathe normally during a
short (30-60 seconds) sedentary period. If no leakage is detected, instruct the subject
to perform various exercises simulating, as nearly as possible, work conditions (i.e.,
talking, running in place, head movements, bending over). End test if any leakage
occurs.
If the subject detects the odor during fitting, record that respirator as unsatisfactory,
remove it from the subject, and visually inspect the sealing surface. If any doubt exists
about the respirator or cartridges, test a duplicate to assure that leakage was due to the
facepiece-to-face seal.
D. Method No. 4 - Enclosure in Plastic Bag (Particulates)
Use respirators equipped with high-efficiency filters (HEPA).
6/91 30
-------
Break both ends of a ventilation smoke tube. Insert one end into the tube connected to
the positive-pressure end of a two-way aspirator bulb and cover the end with 1- to 2-inch
length of Tygon, surgical, or rubber tubing. Squeeze the aspirator bulb to generate the
^^ test aerosol.
After subject dons the respirator, tester visually inspects facepiece-to-face seal. If seal
obviously leaks, test ends and mask is recorded as unsatisfactory. If subject is
uncomfortable, test ends.
Generate smoke into a hole punched in the top of the closed plastic bag until smoke can
be visually detected throughout the bag or hood.
- Instruct subject to put his/her head into the bag or hood and breath shallowly during a
short (30-60 seconds) sedentary period. If a half-mask is being tested, instruct subject
to close his/her eyes before entering and keep them closed until exiting. If no leakage
is detected during sedentary period, instruct subject to perform various exercises
simulating, as nearly as possible, work conditions (i.e., talking, running in place, head
movements, bending over) while breathing normally. End test if any leakage occurs.
If the subject detects the odor during fitting, record that respirator as unsatisfactory,
remove it from the subject, and visually inspect the sealing surface. If any doubt exists
about the respirator or cartridges, test a duplicate to assure that leakage was due to the
facepiece-to-face seal.
6/91 31
-------
APPENDIX III
RESPIRATOR NEGATIVE AND POSITIVE PRESSURE TEST
I. FITTING
Place the respirator over the face and draw the straps evenly and securely. The mask should
not be so tight as to cause discomfort or a headache. Secure bottom straps first, progressing to
the top straps.
II. NEGATIVE PRESSURE TEST
This test (and the positive pressure test) should be used only as a very gross determination of
fit. The wearer should use this test just before entering the hazardous atmosphere. In this test,
the user closes off the inlet of the canister, cartridge(s), or filter(s) by covering with the palm(s),
inhales gently so that the facepiece collapses slightly; and holds breath for about 10 seconds. If
the facepiece remains slightly collapsed and no inward leakage is detected, the respirator is
probably tight enough.
Although this test is simple, it has drawbacks; primarily that the wearer must handle the
respirator after it has been positioned on his face. This handling can modify the facepiece seal.
III. POSITIVE PRESSURE TEST
This test, similar to the negative pressure test, is conducted by closing off the exhalation valve
and exhaling gently into the facepiece. The fit is considered satisfactory if slight positive
pressure can be built up inside the facepiece without any evidence of outward leakage. For
some respirators, this method requires that the wearer remove the exhalation valve cover; this
often disturbs the respirator fit even more than does the negative pressure test. Therefore, this
test should be used sparingly if it requires removing and replacing a valve cover. The test is
easy for respirators whose valve cover has a single small port that can be closed by the palm
or a finger.
6/91 33
-------
APPENDIX IV
CARE AND CLEANING OF RESPIRATORS
I. GENERAL REQUIREMENTS
Any organization using respirators on a routine basis should have a program for their care and
cleaning. The purpose of a program is to assure that all respirators are maintained at their
original effectiveness. If they are modified in any way, their Protection Factors may be voided.
Usually one person in an organization is trained to inspect, clean, repair, and store respirators.
The program should be based on the number and types of respirators, working conditions, and
hazards involved. In general, the program should include:
Inspection (including a leak check)
Cleaning and disinfection
Repair
Storage
II. INSPECTION
Inspect respirators after each use. Inspect monthly a respirator that is kept ready for emergency
use to assure it will perform satisfactorily.
On air-purifying respirators, thoroughly check all connections for gaskets and "O" rings and for
proper tightness. Check the condition of the facepiece and all its parts, connecting air tube, and
headbands. Inspect rubber or elastomer parts for pliability and signs of deterioration.
Maintain a record for each respirator inspection, including date, inspector, and any unusual
conditions or findings.
III. CLEANING AND DISINFECTION
Collect respirators at a central location. Brief employees required to wear respirators on the
respirator program and assure them that they will always receive a clean and sanitized respirator.
Clean and disinfect respirators as follows:
Remove all cartridges, canisters, and filters, plus gaskets or seals not affixed to their seats.
Remove elastic headbands.
Remove exhalation cover.
6/91 35
-------
Remove speaking diaphragm or speaking diaphragm-exhalation valve assembly.
Remove inhalation valves.
Wash facepiece and breathing tube in cleaner/sanitizer powder mixed with warm water,
preferably at 120° to 140° F. Wash components separately from the facemask, as necessary.
Remove heavy soil from surfaces with a hand brush.
Remove all parts from the wash water and rinse twice in clean warm water.
Air dry parts in a designated clean area.
- Wipe facepieces, valves, and seats with a damp lint-free cloth to remove any remaining soap
or other foreign materials.
NOTE: Most respirator manufacturers market their own cleaners/sanitizers as dry mixtures
of a bactericidal agent and a mild detergent. One-ounce packets for quantity use are
usually available.
IV. REPAIRS
Only a trained person with proper tools and replacement parts should work on respirators. No
one should ever attempt to replace components or to make adjustments or repairs beyond the
manufacturer's recommendations.
Make repairs as follows:
Replace all faulty or questionable parts or assemblies. Use parts only specifically designed
for the particular respirator.
Reassemble the entire respirator and visually inspect the completed assembly.
Insert new filters, cartridges, or canisters, as required. Make sure that gaskets or seals are
in place and tightly sealed.
V. STORAGE
Follow manufacturers' storage instructions, which are always furnished with new respirators or
affixed to the lid of the carrying case. In addition, these general instructions may be helpful:
After respirators have been inspected, cleaned, and repaired, store them so as to protect
against dust, excessive moisture, damaging chemicals, extreme temperatures and direct
sunlight.
6/91 36
-------
Do not store respirators in clothes lockers, bench drawers, or tool boxes. Place them in
wall compartments at work stations or in a work area designated for emergency equipment.
Store them in the original carton or carrying case.
Draw clean respirators from storage for each use. Each unit can be sealed in a plastic bag,
placed in a separate box, and tagged for immediate use.
6/91 37
-------
i
APPENDIX V
WARNING CONCENTRATIONS OF VARIOUS CHEMICALS
The following table is a compilation of warning concentrations of various chemicals taken from
several sources. A warning concentration is that concentration in air at which a person can detect
the material either by its odor, by its taste, or by it causing irritation. Exposure limits, where they
exist, are included so that a comparison can be made to determine if a chemical has adequate
warning properties. A material has adequate warning properties if the effects (odor, taste, irritation)
are detectable and persistent at concentrations "at" or "below" the exposure limit. Please note that
some sources give a statement like "adequate" or "inadequate" for the warning properties. Since
the statement may be used in conjunction with a different exposure limit than is used in this table,
it should be used with caution. Some of the chemicals have a range of concentrations because the
different sources have different values. This can be due to the variability of human perceptions or
different test methods. The sources may have used different end points for their testing. This value
could be when the first person detected the odor, when everyone could smell it, or when 50% of
the test subjects could detect it. Because of these variations the full range of warning
concentrations is given so that the user can decide on which value to use.
The warning concentrations given are generally odor thresholds with irritation thresholds given in
parentheses. Taste thresholds are noted as special cases. The concentration units used in the table
are parts per million unless otherwise noted.
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1 The exposure limits are 8 hour Time Weighted Averages (TWA) unless otherwise noted.
2 Fatigue = Indicates that the chemical can cause olfactory fatigue.
'(a) = Simple asphyxiant. Check oxygen concentration.
A1 = Confirmed Human Carinogen (ACGIH)
A2 = Suspected Human Carcinogen (ACGIH) animal = irritation concentration based on animal studies
C = Ceiling Limit. Ceiling limits for REL may be limited to 10 minutes, 15 minutes or not to be exceeded for
any time. Check individual value.
Ca = NIOSH has recommended that the substance be treated as a potential human carcinogen; IDLH's are not
listed for those substances.
HWC = "To be handled in the workplace with caution" (NIOSH)
IDLH = Immediately Dangerous to Life or Health, NIOSH Pocket Guide to Chemical Hazards. Sept. 1985.
LD = "Reduce exposure to lowest reliably detectable level" (NIOSH)
LL = "Reduce exposure to lowest feasible level" (NIOSH)
ME = "Minimize occupational exposure" (NIOSH)
N.A. = NIOSH has not assigned an IDLH
NN = Not applicable because of NIOSH REL
NE = "No exposure limit recommended due to absence of a reliable monitoring method" (NIOSH)
P = "Acceptable maximum peak above the acceptable ceiling concentration for an 8-hour shift." Each has a
specific time limit.
PEL = Permissible Exposure Limits, "29 CFR 1910 Subpart Z," Occupational Safety and Health Administration
(OSHA)
REL = Recommended Exposure Limits, NIOSH Recommendations for Occupational Safety and Health Standards.
1988, National Institute for Occupational Safety and Health (NIOSH)
TLV = Threshold Limit Value. Threshold Limit Values and Biological Exposure Indices for for 1988-1989, American
Conference of Governmental Industrial Hygienists (ACGIH)
STEL = Short Term Exposure Limit
WEEL = American Industrial Hygiene Association Workplace Environmental Exposure Level Guides (1988). This
is not a PEL but is placed in that column due to space limitations. The first number is an 8 hour TWA. The
second number is a short term TWA. The time varies from 1-15 minutes. Check individual values.
67
-------
ft
SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
PART 3
SELF-CONTAINED BREATHING APPARATUS
I. INTRODUCTION
Respiratory apparatus must frequently be used during response to hazardous materials
incidents. If the contaminant is unknown or the requirements for using air-purifying
respirators cannot be met, then an atmosphere supplying respirator is required. Several
types of atmosphere supplying devices are available:
Oxygen-generating
One of the oldest respirators is the oxygen-generating respirator, which utilizes a
canister of potassium superoxide. The chemical reacts with water vapor to produce
oxygen which replenishes the wearer's exhaled breath. Exhaled CO^ is removed by
a scrubber device containing LiOH. This reoxygenated air is then returned to the
wearer. Oxygen-generating respirators have been used by the military and for escape
purposes in mines. It generally is not used for hazardous material applications
because of the chemical reaction taking place within the respirator itself.
Hose mask
This type of respirator consists of a facepiece attached to a large diameter hose
which transports clean air from a remote area. In units where the wearer breathes
the air in, the hose lines can go up to 75 feet. With powered units the hose length
can vary from 50 to 250 feet.
Airline respirator
The airline respirator is similar to the hose mask, except that breathing grade air is
delivered to the wearer under pressure; either from a compressor or a bank of
compressed air cylinders. The air may flow continuously, or it may be the wearer
breathes (demands it). The air source must not be depletable, and no more than 300
feet of airline is allowed. An escape device is required for entry into an IDLH
atmosphere.
Self-contained breathing apparatus
The self-contained breathing apparatus (SCBA) consists of a facepiece and regulator
mechanism connected to a cylinder of compressed air or oxygen carried by the
wearer.
6/91 69
-------
The self-contained breathing apparatus (SCBA) is generally used because it allows the wearer
to work without being confined by a hose or airline. The wearer of the SCBA depends on
it to supply clean breathing air.
If the wearer is not properly trained to wear the SCBA or it is not properly cared for,
then it may fail to provide the protection expected.
The user should be completely familiar with the SCBA being worn. Checkout procedures
have been developed for inspecting an SCBA prior to use, allowing the user to recognize
potential problems. An individual who checks out the unit is more comfortable and
confident wearing it.
There are two types of apparatus: closed-circuit, which use compressed oxygen, and open-
circuit, which use compressed air. SCBA's may operate in one of two modes, demand or
pressure-demand (positive-pressure). The length of time an SCBA operates is based on the
air supply. The units available operate from 5 minutes to over 4 hours.
Pressure Demand (positive pressure) is the only approved type of open circuit SCBA for use
in Hazardous Environments by the US EPA and NFPA.
Both open- and closed-circuit SCBA's will be discussed and the modes of operation
explained. The bulk of the discussion deals with open circuit pressure-demand SCBA's
which are most widely used because they offer more protection.
II. MODES OF OPERATION
A. Demand
In the demand mode, a negative pressure is created inside the facepiece and
breathing tubes when the wearer inhales (TABLE 6). This negative pressure draws
down a diaphragm in the regulator in an SCBA. The diaphragm depresses and opens
the admission valve, allowing air to be inhaled. As long as the negative pressure
remains, air flows to the facepiece.
The problem with demand operation is that the wearer can inhale contaminated air
through any gaps in the facepiece-to-face sealing surface. Hence, a demand
apparatus with a full facepiece is assigned a Protection Factor of only 100, the same
as for a full face air-purifying respirator.
B. Pressure-Demand
An SCBA operating in the pressure-demand mode maintains a positive pressure
inside the facepiece at all times. The system is designed so that the admission valve
remains open until enough pressure is built up to close it. The pressure builds up
because air is prevented from leaving the system until the wearer exhales. Less
pressure is required to close the admission valve than is required to open the spring-
loaded exhalation valve.
6/91 70
-------
At all times, the pressure in the facepiece is greater than the ambient pressure
outside the facepiece (TABLE 6). If any leakage occurs, it is outward from the
facepiece. Because of this, the pressure-demand (positive pressure) SCBA has been
assigned a Protection Factor of 10,000.
TABLE 6
PRESSURE INSIDE FACEPIECE OF SCBA RELATIVE TO
AMBIENT PRESSURE OUTSIDE
Inhalation
Exhalation
Static (between breaths)
Demand
-
+
same
Pressure Demand
(positive pressure)
+
+
+
III. TYPES OF APPARATUS
A. Closed-Circuit
The closed-circuit SCBA (FIGURE 4), commonly called the rebreather, was
developed especially for oxygen-deficient situations. Because it recycles exhaled
breath and carries only a small oxygen supply, the service time can be considerably
greater than an open-circuit device, which must carry all of the user's breathing air.
The air for breathing is mixed in a flexible breathing bag. This air is inhaled,
deflating the breathing bag. The deflation depresses the admission valve, allowing
the oxygen to enter the bag. There it mixes with exhaled breath, from which carbon
dioxide has just been removed by passage through a CC^ scrubber.
Most rebreathers operate in the demand mode. Several rebreathers are designed to
provide a positive pressure in the facepiece. The approval schedule 13F under 30
CFR Part II for closed-circuit SCBA makes no provisions for testing "demand" or
"pressure-demand" rebreathers. The approval schedule was set up to certify only
rebreathers that happen to operate in the demand mode. Thus, rebreathers designed
to operate in the positive pressure mode can be approved strictly as closed-circuit
apparatus. Since regulations make no distinction, and selection is based on approval
criteria, rebreathers designed to maintain a positive pressure can only be considered
as a demand-type apparatus. Rebreathers use either compressed oxygen or liquid
oxygen. To assure the quality of the air to be breathed, the oxygen must be at least
medical grade breathing oxygen which meets the requirements set by the "U.S.
Pharmacopeia".
6/91
71
-------
B.
Open-Circuit
The open-circuit SCBA requires a supply of compressed breathing air. The user
simply inhales and exhales. The exhaled air is exhausted from the system. Because
the air is not recycled, the wearer must carry the full air supply, which limits a unit
to the amount of air that the wearer can easily carry. Available SCBA's can last
from 5 to 60 minutes. Units which have 5-to-15 minute air supplies are only
applicable to escape situations.
The air used in open-circuit apparatus must meet the requirements in the Compressed
Gas Association's Pamphlet G-7.1, which calls for at least "Grade D". Grade D air
must contain 19.5 to 23.5% oxygen with the balance being predominantly nitrogen.
Condensed hydrocarbons are limited to 5 mg/m3, carbon monoxide to 20 parts per
million (ppm) and carbon dioxide to 1,000 ppm. An undesirable odor is also
prohibited. Air quality can be checked using an oxygen meter, carbon monoxide
meter and detector tubes.
Head Harness
f
Faceplece
Exhalation
Salrva Trap
and Pressure
Relief Valve
Check Valve
£^^\ Inhalation Tube
Breathing Bag
Main Valve
Granular Solid Adsorbent lor Carbon Dioxide
Compressed-
Oxygen Tank
Admission Valve
— U A .Pressure Plate
Bypass Valve
Bypass Lint
FIGURE 4
CLOSED-CIRCUIT SCBA
6/91
72
-------
IV. COMPONENTS OF A TYPICAL OPEN-CIRCUIT PRESSURE DEMAND SCBA
A. Cylinder
Compressed air is considered a hazardous material. For this reason, any
cylinder used with a SCBA must meet the Department of Transportation's (DOT)
"General Requirements for Shipments and Packaging" (49 CFR Part 173) and
"Shipping Container Specifications" (49 CFR Part 178).
A hydrostatic test must be performed on a cylinder at regular intervals: for steel &
aluminum cylinders, every 5 years; for composite cylinders (glass fiber/aluminum),
every 3 years. Composite cylinders are relatively new, designed with fiberglass.
Composite cylinders have a DOT exemption because there are no set construction
requirements at this time. Overall difference is in weight. The construction
technology reduces the weight of the cylinder and thereby the overall weight of the
SCBA.
Air volume of 45 cubic feet of Grade D air at a pressure of 2,216 pounds per square
inch (psi) is needed for a 30-minute supply. Cylinders are filled using a compressor
or a cascade system of several large cylinders of breathing air. If the cylinder is
overfilled, a rupture disc releases the pressure. The rupture disc is located at the
cylinder valve, along with a cylinder pressure gauge to be accurate within _+ 5%.
Because the gauge is exposed and subject to abuse, it should be used only for
judging if the cylinder is full, and not for monitoring air supply to the wearer.
B. High-Pressure Hose
The high-pressure hose connects the cylinder and the regulator. The hose should be
connected to the cylinder only by hand, never with a wrench. An O-ring inside the
connector assures a good seal.
C. Alarm
A low-pressure warning alarm is located near the connection to the cylinder. This
alarm sounds to alert the wearer that only 20-25% of the full cylinder air supply is
available for retreat, usually 5 to 8 minutes.
D. Regulator Assembly
Air travels from the cylinder through the high-pressure hose to the regulator
(FIGURE 5). There it can travel one of two paths. If the by-pass valve is opened,
air travels directly through the breathing hose into the facepiece. If the mainline
valve is opened, air passes through the regulator and is controlled by that
mechanism. Also at the regulator (before air enters one of the valves) is another
pressure gauge which also must be accurate to jf 5%. Because it is visible and well
protected, this gauge should be used to monitor the air supply.
6/91 73
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Under normal conditions, the bypass valve is closed and the mainline valve opened
so air can center the regular. Once in the regulator, the air pressure is reduced from
the actual cylinder pressure to approximately 50-100 psi by reducing mechanism.
A pressure relief valve is located after the pressure reducer for safety should the
pressure reducer malfunction. The airflow rate to meet NIOSH standards must meet
or exceed 40 liters/minute. NFPA 1981 states the airflow rate must meet or exceed
100 liters/minute.
6/91 74
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E. Breathing Hose and Facepiece
The breathing hose connects the regulator to the facepiece. Rubber gaskets at both
ends provide tight seals. The hose is usually constructed of neoprene and is
corrugated to allow stretching.
Above the point in the mask where the hose is connected, is a one way check valve.
This valve allows air to be drawn from the hose when the wearer inhales but
prevents exhaled air from entering the breathing hose. If the checK valve is not in
place, the exhaled air may not be completely exhausted from the iacepieces.
The facepiece is normally constructed of neoprene, but sometimes of silicone rubber.
Five- or six-point suspension is used to hold the mask to the face. The visor lens
is made of polycarbonate or other clear, shatter proof, and chemically resistant
material. At the bottom of the facepiece is an exhalation value.
Some masks include an air-tight speaking diaphragm, which facilitates
communications while preventing contaminated air from entering.
F. Back Pack and Harness
A back pack and harness support the cylinder and regulator, allowing the user to
move freely. Weight should be supported on the hips not the shoulders.
V. INSPECTION AND CHECKOUT
The SCBA must be inspected according to manufacturers as well as 29 CFR
recommendations. In addition, the SCBA should be checked out immediately prior to use.
Checkout and inspection procedures should be followed closely to assure safe operation of
the unit.
VI. IMPORTANT INFORMATION ON CYLINDER
A cylinder on a SCBA typically carries the following information (FIGURE 6).
1. DOT exemption for composite cylinder
2. DOT rated pressure and air volume
3. Cylinder number
4. Manufacturer's name, symbol and part number
5. Original hydrostatic test date, month/year
6/91 76
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^-~-^- V^^'-^.'ivACr^"' **
^£^^^0; '''
&~ ~m-- _ _ i^r"."^ . r'*"*""
•»* --:?'-
S^ AIR; 45jSCF_ ATr22J ff PSl
FIGURE 6
INFORMATION ON TYPICAL SCBA CYLINDER
VII. NFPA 1981 "OPEN CIRCUIT SELF-CONTAINED BREATHING APPARATUS FOR
FIRE FIGHTERS" 1987 Edition
The National Fire Protection (NFPA) has developed a standard for performance requirements
and appropriate testing procedures designed to simulate various environmental conditions that
fire fighter's SCBA can be exposed to during use and storage. These requirements are in
addition to the basic NIOSH/MSHA certification requirements. This Standard, NFPA 1981,
now applies only to open circuit SCBA.
A. Basic Design Requirements
The basic design requirements for SCBA units under 1981 are:
1. That the units be NIOSH/MSMA certified positive-pressure.
2. The maximum weight shall not exceed 35 pounds, in accordance with
NIOSH/MSMA certification.
3. The rated service time shall be 30 minutes or more.
4. No positive-pressure unit that can be switched to demand mode.
5. The unit shall not be approved under the Bureau of Mines Schedule
6. The manufacturer shall provide with each SCBA instructions on maintenance,
storage, disinfecting, inspection, use, operations, limitations and training
materials.
6/91
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B. General Requirements
Additionally, SCBA units must meet certain general requirements which include:
1. Labeling showing that the unit meets the requirements.
2. Initial, annual and fifth year testing of the SCBA.
3. Retesting of unit after any modifications.
4. Test series to include three categories, with on SCBA used per category.
C. Performance Tests
1. Airflow
This test increases the current NIOSH breathing machine requirements of 40
liters per minute to 100 liters per minute. The 100 liters per minute volume
was derived from a review of several studies indicating that a ventilation rate
of 100 standard liters per minute encompasses the 98th percentile of all fire
fighters studies.
NOTE: An airflow test is then performed after each of the following tests,
with the exception of the fabric component test, to ensure breathing apparatus
performance.
2. Thermal Resistance Test
This series of test expose the breathing apparatus to various temperature
extremes and temperature cycles that breathing apparatus might be exposed
to during actual firefighting operations.
3. Vibration and Shock
This test is designed to provide a reasonable level of assurance that when the
breathing apparatus is exposed to vibration, such as being carried on a rig
that often travels over rough road surfaces, the apparatus will perform and
function properly.
4. Fabric Components Test
Flame, heat and thread tests are added to provide a reasonable level of
assurance that the fabric components of a harness assembly used to hold the
backplate to the wearer's body will remain intact during firefighting
operations.
5. Accelerated Corrosion Resistance Test
This test is to provide a reasonable level of assurance that the breathing
apparatus is designed to resist corrosion that may form and interfere with the
apparatus performance and function.
6/91 78
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6. Particulate Resistance Test
This test exposes the breathing apparatus to a specified concentration of
» participates to provide a reasonable level of assurance that the apparatus is
designed to properly function when exposed to dust conditions commonly
present during firefighting operations.
7. Facepiece Lens Abrasion Resistance Test
This test is designed to provide a reasonable level of assurance that the
facepiece lens of the breathing apparatus is not easily scratched during
firefighting operations that could result in reduced visibility for the fire
fighter.
8. Communications Test
This test is designed to assure that the facepiece of the breathing apparatus
does not significantly reduce a fire fighter's normal voice communications.
6/91 79
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ft
SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
PART 4
NIOSH RESPIRATOR DECISION LOGIC
81
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3n
Respirator Decision
LOOK
83
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Public Health Service
Centers for Disease Control
National Institute (or Occupational Safety and Health
-------
NIOSH RESPIRATOR DECISION LOGIC
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Pub Iic HeaIth Serv fee
Centers for Disease Control
National Institute for Occupational Safety and Health
Division of Standards Development and Technology Transfer
May 1987
84
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DISCLAIMER
Mention of the name of any company or product
does not constitute endorsement by the National
Institute for Occupational Safety and Health.
DHHS (NIOSH) Publication No. 87-108
85
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FOREWORD
The initial Respirator Decision Logic was developed in 1975 as part of the
National Institute for Occupational Safety and Health/Occupational Safety
and Health Administration (NIOSH/OSHA) Standards Completion Program and was
updated in 1978. Due to technical advances in respirator design and
research, NIOSH has again revised the Respirator Decision Logic.
This revision retains many aspects of the original Respirator Decision
Logic, but it differs in five areas: odor warning properties with respect
to air-purifying cartridge/canister respirators, recognition of the
problems in assigning protection factors, changes in protection factors for
certain respirator classes, respirator recommendations for carcinogens ^nA
medical recommendations.
and
The recognition of wide variation among workers in their sensitivities for
detection of odors has led to the recommendation that employers not rely
solely on currently published data on odor thresholds to ensure that
workers who wear air-purifying cartridge or canister respirators are
capable of smelling the contaminant at the applicable exposure limit.
Recent research on in-plant respirator testing suggests that some
previously assigned protection factors based on data from laboratory fit
testing may not be valid. This revised Respirator Decision Logic has
incorporated assigned protection factors based on data from recent in-plant
research for some powered air-purifying respirators (PAPR) and some similar
respirators, such as loose-fitting and tight-fitting continuous flow
air-line respirators. Since NIOSH maintains that there is no safe exposure
to carcinogens, only the most protective respirators should be used to
protect workers from exposure to carcinogens in the workplace. Finally,
specific medical recommendations are included to assist physicians in
determining an individual's fitness to wear a respirator.
Donald Mi Ilar, M.D., D.T.P.H. (Lond.)N
ant Surgeon General
Director, National Institute for
Occupational Safety and Health
Centers for Disease Control
86
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ft
ACKNOWLEDGMENTS
This Respirator Decision Logic was prepared by a subcommittee of the NIOSH
Respiratory Protection Committee, Sheldon H. Rabinovitz, Ph.D., Chairman.
The Committee consists of members of each Division of NIOSH. The
subcommittee consisted of the following individuals:
Warren R. Myers, Ph.D., Chairman, DSR
Nancy J. Bo 11inger, DSR
Thomas K. Hodous, M.D., DRDS
Nelson A. Lei del, Sc.D., OD
Sheldon H. Rabinovitz, Ph.D., DSDTT
Laurence D. Reed, DSR
The document was reviewed by the following experts in respiratory protection:
Earle Shoub, Consultant
Robert A. daRoza, Chairman, ANSI Z88 Committee
Mark Nicas, California Division of Occupational Safety and Health
Christopher C. O'Leary, Chairman, American Industrial Hygiene
Association, Respiratory Protection Committee
Robert C. Spear, Ph.D., Professor and Director, Northern California
Occupational Health Center, University of California, Berkeley
In addition, appreciation is extended to the following persons for their
assistance in preparing this document:
R. Schutz for technical review; C. Browning, R. Grubbs, E. Kuempel,
and H. Linn for editorial review; and J. Curless, L. DeVor, B. Ellis!
J. Hamons, D. Hill, C. Klinker, N. Morgan, and A. Ritchey for typing.
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CONTENTS
FOREWORD j i i
ACKNOWLEDGMENTS i v
TABLES AND FIGURE vi
I. INTRODUCTI ON 1
A. Background and Scope 1
B. Cautionary Statements 2
II. RESPIRATOR DECISION LOGIC 5
A. Criteria for Selecting Respirators 6
B. Restrictions and Requirements
for All Respirator Usage 7
C. Respirator Decision Logic Sequence 8
D. Subparagraphs 21
1. Oxygen-Deficient Atmosphere 21
2. Exposure Limi ts 21
3. Immediately Dangerous to Life or Health (IDLH) 22
4. Eye Irritation 23
5. Escape Apparatus 24
6. Potential Warning Properties for Use with
Cartridge/Canister Air-Purifying Respirators 26
7. Limitations of Respirators for Gases and Vapors 27
8. Assigned Protection Factors 27
9. Particulate Filter Respirators 29
10. Suggested Medical Evaluation and Criteria for Respirator Use 30
III. REFERENCES 35
IV. GLOSSARY 40
V. APPENDICES 43
A. NIOSH Policy Statement on Approval of Air-Purifying
Respirators with End-of-Service-Life Indicators 43
B. NIOSH Policy Statement on Use of Single-Use and Dust
and Mist Respirators for Protection Against Asbestos 47
C. Odor Warning: Background Information 48
D. Protection Factor: Background Information 50
E. Medical Aspects of Wearing Respirators: Background
Information 52
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TABLES
Numbe r Page
1. Assigned protection factor classifications of respirators
for protection against particulate exposures 13
2. Assigned protection factor classifications of respirators
for protection against gas/vapor exposures 15
3. Assigned protection factor classifications of respirators
for protection against combination gas/vapor and particulate
exposures 17
4. Selection options for escape respirators 25
5. NIOSH recommended maximum use concentrations for gas
and vapor air-purifying elements 28
6. Suggested frequency of medical fitness determinations 32
FIGURE
Numbe r Page
1. Flow Chart of Respirator Decision Logic Sequence 19
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I. INTRODUCTION
A. Background and Scope
The National Institute for Occupational Safety and Health (NIOSH) routinely
makes recommendations regarding the use of respirators for workers exposed
to workplace environments that contain hazardous concentrations of airborne
contaminants and/or oxygen-deficient atmospheres. Such recommendations are
made only when engineering controls are not technically feasible, while
controls are being installed or repaired, or when emergency and other
temporary situations arise. Respirators are the least preferred method of
worker protection from respiratory hazards because they can be unreliable if
an adequate respiratory protection program is not established by the
employer and because they require worker cooperation. The intent of this
decision logic is to provide industrial hygienists and other professionals
knowledgeable in respirator selection with a procedure for selecting
suitable classes of respirators for particular concentrations of specific
contaminants. In this decision logic, concerns are raised about limitations
of the data used to set protection factors for several classes of
respi rators.
To ensure uniformity and adherence to proper respirator usage, NIOSH
recommendations have been based on the Respirator Decision Logic developed
jointly in 1975 by NIOSH and the Occupational Safety and Health
Administration (OSHA) as part of the Standards Completion Program and
updated in June 1978. That decision logic incorporated requirements
contained in 30 CFR 11 and fit factor data developed by the Los Alamos
National Laboratory (LANL). NIOSH has now modified that decision logic to
reflect new developments that include increased use of respirators to
control exposure to carcinogens in the workplace, introduction of new
respiratory equipment, and reporting of field research data on workplace
protection factors (WPF's).
This modified decision logic identifies the criteria necessary to determine
the classes of respirators that will provide a known degree of respiratory
protection for a given work environment, assuming that the respirators are
used correctly. The degree of protection is related in part to protection
factors. Many of the assigned protection factors (APF's) that appear in
this decision logic are based on laboratory studies and should be regarded
as approximate.
The selection of a specific respirator must be made by individuals
knowledgeable about the limitations associated with each class of
respirators and familiar with the actual workplace environment, including
the job task(s) to be performed. The correct use of a respirator is just as
important as the selection process if adequate worker protection is to be
achieved. Without a complete respiratory protection program, workers will
not receive the degree of protection anticipated from a respirator, even if
it is a correct choice for the situation. Training, motivation, medical
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evaluation, fit testing, and a respirator maintenance program are critical
elements for the successful use of a respirator. As a minimum, compliance
with 29 CFR 1910.134 is mandatory whenever respirators are used by workers,
whether on a required or voluntary basis.
B. Cautionary Statements
NIOSH concerns about the use of respirators are discussed further in various
parts of the document and are summarized in the following six cautionary
statements:
• Assigned Protection Factors
In general, the assigned protection factors (APF's) that appear in this
decision logic are not based on measurements of actual field (workplace)
performance. As noted in the footnotes accompanying Tables 1, 2, and 3,
in only a few instances are the APF's based on any workplace performance
testing; the majority of the APF's have no workplace performance basis at
all. APF's based solely on laboratory fit testing should be viewed and
applied with particular caution, even when the laboratory testing
involves a simulated work regimen. To date, no relation has been
demonstrated between laboratory fit factors and measured workplace
performance. As more performance testing of respirators is undertaken in
the workplace by NIOSH and others, NIOSH may find it necessary to revise
the APF's upward or downward. For the present, APF's should not be
considered reliable predictors of performance levels that will be
achieved during actual use, since APF's are not based on a sufficient
amount of workplace testing.
• Fit Testing
No qualitative or quantitative fit tests have been demonstrated to be
capable of effectively identifying inadequately fitting respirators
(i.e., respirator-wearer combinations that provide less protection than
the APF). The presently used fit tests (e.g., ANSI-recommended,
OSHA-approved) may fail to identify individual wearers with inadequate
respiratory protection. Thus fit tests should be used with caution and
with recognition of their possible deficiencies. As appropriate,
periodic evaluations of the effectiveness of each respirator during use
in the workplace should be conducted to ensure that each wearer is being
provided with adequate respiratory protection.
• QNFT Fit Factor Screening Levels
Regarding quantitative fit testing (QNFT), no studies are available to
indicate what fit factor value (i.e., screening level) will ensure a high
probability of identifying inadequately fitting respirators. That is,
there are no studies demonstrating what fit factor values are adequate
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accept/reject criteria for QNFT fit screening. When QNFT is used for fit
screening, the fit factor screening level should be chosen with caution
and with recognition of the uncertainty of its effectiveness. As
appropriate, periodic evaluation of the effectiveness of each respirator
during use in the workplace should be conducted to ensure that each
wearer is being provided with adequate respiratory protection.
• Adequate Warning Properties
No physiological effects in humans (e.g., odor, taste, eye irritation,
respiratory irritation) have been demonstrated as being capable of
consistently providing respirator wearers with timely, consistent,
persistent, and reliable warning of hazardous airborne concentrations
inside a respirator. Individual wearers' may be unable to detect the
warning effect when necessary and may fail to take action necessary to
protect themselves (e.g., leaving the area where respirators are
necessary or changing the sorbent cartridge or canister). When warning
properties must be relied on as part of a respiratory protection program,
the employer should accurately, vaiidly, and reliably screen each
prospective wearer for the ability to detect the warning properties of
the hazardous substance(s) at exposure levels that are less than the
exposure limits for the substance(s). Warning properties should be
regarded with caution and with recognition of their unreliability.
• Service Life Information
For essentially all gases and vapors, no adequate service life
information is available to respirator wearers or to those responsible
for respiratory protection programs. When this information is not
available, respirators with air-purifying sorbent elements should be used
with caution and with recognition of the wide variability of service
lives under differing use conditions. Employers should possess valid and
reliable estimates of service lives for all sorbent elements used in the
respiratory protection program. Service life test data should be
representative of all conditions of intended use that can be reasonably
anticipated. Factors known to affect the service lives of sorbent
elements include, but are not limited to, the make and model of sorbent
element, airborne concentrations of contaminant(s), and relative humidity
through each sorbent element. When appropriate service fife data is
available, any reliance on the data should be undertaken with caution and
with recognition of the limitations and uncertainties of the information.
• Determination of Protection Factor Levels Required for Adequate Protection
Workers are never exposed to a single unvarying concentration of a
contaminant. In a given work area, individual exposures may vary widely
between workers, during a workshift, and between days. The range of
potential exposures should be appropriately determined for all workers
and for all circumstances that can be reasonably anticipated. The
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highest anticipated exposure for each respirator wearer should be used to
compute the protection factor required for each wearer. Required
protection factors should be used with caution and with recognition of
their uncertainties.
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II. RESPIRATOR DECISION LOGIC
This decision logic contains a series of questions regarding situations which
may require the use of respirators. (See Respirator Decision Logic Sequence,
page 8.) In answering these questions, the user of this decision logic is
assisted in identifying specific classes of respirators, applicable
restrictions, and the appropriate respirator selection table to use. When
using one of the tables to identify a suitable class of respirators, the user
must keep in mind the restrictions identified in the question section of this
decision logic.
This decision logic identifies the criteria necessary to determine the classes
of respirators that will provide the minimum acceptable degree of protection
for a chemical at a given concentration. Classes of respirators offering
greater protection can usually be used in place of the minimum acceptable
class of respirators. Respirator classes are consistent with respirator
certification groupings as specified in 30 CFR 11.
The recommendations in this decision logic are based primarily on the
physical, chemical, and toxicologic properties of the contaminant and on the
limitations of each class of respirators, including filtration efficiency, air
supply capability, and face seal characteristics and leakage. Thus this
decision logic is limited to identifying classes of acceptable respirators,
rather than individual respirators.
After various classes of respirators are identified as being suitable for a
given situation, an evaluation is made of other factors of the particular work
environment so that the best respirator within the recommended classes can be
chosen. In some situations, the selection of a respirator classified as
providing a higher level of protection may be advisable.
To assist the user, this decision logic contains ten subparagraphs following
the Respirator Decision Logic Sequence that describe respirator limitations,
use of applicable exposure limits, warning properties, protection factors,
oxygen limitations, and medical evaluation of suitability to wear
respirators. Additional supporting information is contained in Appendices A
through E. To properly use this decision logic, the user should carefully
read the subparagraphs.
The assigned protection factors (APF's) used in this decision logic were based
on quantitative fit factor data developed by Los Alamos National Laboratories
(LAND under contract to NIOSH and on field evaluation data gathered by NIOSH
and others. Specific references and summaries of the data used to generate
certain protection factors can be found in Subparagraph 8, page 28. Fit
factors determined for the individual wearer of a respirator by quantitative
fit testing or by any other method used to determine fit should not be
substituted for the APF given for each class of respirators. However, the fit
factor determined through quantitative fit testing must be greater than the
APF; otherwise, the respirator cannot be used by the worker.
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A. Crjjeria for Selecting Respirators
To use this decision logic, the user must first assemble the necessary
toxicologic, safety, and other relevant information for each contaminant,
including the following:
• General use conditions, including determination of contaminant(s);
• physical, chemical, and toxicologic properties of the contaminant(s);
• Odor threshold data;
• NIOSH recommended exposure limit (RED or when no REL exists, OSHA
permissible exposure limit (PEL) or other applicable exposure limit;
• Immediately dangerous to life or health (IDLH) concentration; -
• Eye irritation potential; and
• Any service life information available (for cartridges and canisters).
Obtaining complete information on all criteria needed to use this decision
logic may be difficult. When conflicting or inadequate data are found,
experts should be consulted before decisions are made that could affect the
proper use of this decision logic. In addition, the adequacy of the
respirator selected is dependent on the validity of the exposure limit
used. While the decision logic can be used with any exposure limit, NIOSH
recommends that an REL be used when one exists for a given contaminant. For
a more detailed discussion on the use of exposure limits, especially when
selecting respirators for protection against carcinogens, see Subparagraph 2,
page 21.
The information obtained on general use conditions for respirators should
include a description of the actual job task, including the duration and
frequency, location, physical demands, and industrial processes, as well as
the comfort of the respirators. Some general use conditions may preclude the
use of specific types of respirators in certain circumstances because the
individual must be medically and psychologically suitable to wear a given
respirator for a given task, particularly if the respirator is a
self-contained breathing apparatus (SCBA).
Information obtained on the service life of the cartridge/canister under
conditions of intended use should be evaluated regardless of the odor warning
properties of the chemicals. These evaluations should be based on all
gas(es) and vapor(s) present at the temperature and relative humidity
extremes (high and low) in the workplace. NIOSH recommends that when the
employer or a representative of the employer conducts the tests, the
challenge concentrations of the gases and vapors should be at least 10 times
the maximum use concentration of the respirator. The service life value
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obtained from these tests should be used to determine how long a
cartridge/canister could provide protection under actual use conditions.
This information can be used to set up cartridge replacement schedules and
should be used in conjunction with sensory warning properties. Workers
should be trained to exit the contaminated area whenever they detect the
odor of the contaminant. (See Subparagraph 6, page 26, for a discussion on
service life testing for chemicals with poor warning properties.)
B. Restrictions and Requirements for All Respirator Usage
The following requirements and restrictions must be considered to ensure
that the respirator selected will provide adequate protection under the
conditions of intended use:
1. A complete respiratory protection program should be instituted which
includes regular worker training; maintenance, inspection, cleaning, and
evaluation of the respirator; use of the respirator in accordance with the
manufacturer's instructions; fit testing; and environmental monitoring.
Whenever possible, quantitative evaluation of the protection factor in the
workplace should be performed to confirm the actual degree of protection
provided by the respirator to each worker. Minimum respiratory protection
requirements for all contaminants can be found in the OSHA Safety and
Health Standards, 29 CFR 1910.134, and in separate sections for specific
contaminants (e.g., 1910.1001 for asbestos, 1910.1025 for lead, etc.).
2. Qualitative or quantitative fit tests should be provided as appropriate
to ensure that the respirator fits the individual. Periodic evaluation of
the effectiveness of each respirator during use in the workplace should be
conducted to ensure that each wearer is being provided with adequate
respiratory protection. When quantitative fit testing (QNFT) is used, the
fit factor screening level should be chosen with caution and with the
recognition of the uncertainty of its effectiveness since no studies have
demonstrated what fit factor values provide adequate accept/reject
criteria for quantitative fit screening.
3. Negative pressure respirators should not be used when facial scars or
deformities interfere with the face seal.
4. No respirator (including positive pressure respirators) should be used
when facial hair interferes with the face seal.
5. The respirators should be properly maintained, correctly used, and
conscientiously worn.
6. The usage limitations of air-purifying elements, particularly gas and
vapor cartridges, should not be exceeded.
7. The respirators must be approved by the Mine Safety and Health
Administration and the National Institute for Occupational Safety and
Health (MSHA/NIOSH).
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8. Workers should be instructed to leave the contaminated area immediately
upon suspicion of respirator failure and then to determine the problem.
9. Workers are not exposed to a single unvarying concentration of a
hazardous substance, rather individual exposures may vary throughout a
workshift and between days. The highest anticipated concentration should
therefore be used to compute the required protection factor for each
respi rator wearer.
10. Respirator wearers should be aware of the variability in human
responses to the warning properties of hazardous substances. When warning
properties must be relied on as part of a respiratory protection program,
the employer should screen each prospective wearer for the ability to
detect the warning properties of the hazardous substance(s) at exposure
concentrations that are less than the REL for each given substance. (See
Subparagraph 6, page 26, and Appendix C, page 48, for additional
informal ion.)
11. The assigned protection factors (APF's) that appear in this decision
logic are .based for the most part on laboratory studies. However, a few
APF's have been validated and revised as necessary after consideration of
data obtained from studies of workplace protection factors (WPF's). As
more WPF testing of respirators is undertaken by NIOSH and others, the APF
values may be further revised. For the present, the APF's should be
regarded as approximate if they are not based on WPF's.
C. Respirator Decision Logic Sequence
After all criteria have been identified and evaluated and after the
requirements, and restrictions of the respiratory protection program have
been met, the following sequence of questions can be used to identify the
class of respirators that should provide adequate respiratory protection:
1. Is the respirator intended for use during fire fighting?
a. If yes, only a self-contained breathing apparatus (SCBA) with a full
facepiece operated in pressure demand or other positive pressure mode
is recommended.
b. If no, proceed to Step 2.
2. Is the respirator intended for use in an oxygen-deficient atmosphere,
i.e., less than 19.5% oxygen at sea level? (Refer to Subparagraph 1,
page 21, for a discussion of oxygen deficiency.)
a. If yes, any type of SCBA or supplied-air respirator (SAR) with an
auxiliary SCBA is recommended. Auxiliary SCBA must be of sufficient
duration to permit escape to safety if the air supply is interrupted.
If additional contaminants are present, proceed to Step 3.
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b. If no, proceed to otep 3.
3. Is the respirator intended for use during emergency situations?
a. If yes, two types of respirators are recommended: a SCBA with a
full facepiece operated in pressure demand or other positive pressure
mode or an SAR with a full facepiece operated in pressure demand or
other positive pressure mode in combination with an auxiliary SCBA
operated in pressure demand or other positive pressure mode. Auxiliary
SCBA must be of sufficient duration to permit escape to safety if the
ai r supply is interrupted.
b. If no, proceed to Step 4.
4. !s the contaminant regulated by the Department of Labor as a potential
occupational carcinogen or identified by NIOSH as a potential human
carcinogen in the workplace, and is the contaminant detectable in the
atmosphere?
a. If yes, two types of respirators are recommended: a SCBA with a
full facepiece operated in pressure demand or other positive pressure
mode or an SAR with a full facepiece operated in pressure demand or
other positive pressure mode in combination with an auxiliary SCBA
operated in pressure demand or other positive pressure mode. Auxiliary
SCBA must be of sufficient duration to permit escape to safety if the
air supply is interrupted.
b. If no, proceed to Step 5.
5. Is the exposure concentration of the contaminant, as determined by
acceptable industrial hygiene methods, less than the NIOSH REL or other
applicable exposure limit? (Whenever a worker is given a respirator to
use on a voluntary basis when ambient levels are below applicable limits,
OSHA requires the implementation of a complete respiratory protection
program, which includes medical evaluation, training, fit testing,
periodic environmental monitoring, and all other requirements in
29 CFR 1910.134.)
a. If yes, a respirator would not be required except for an escape
situation. Proceed to Step 7.
b. If no, proceed to Step 6.
6. Are conditions such that a worker who is required to wear a respirator
can escape from the work area and not suffer loss of life or immediate or
delayed irreversible health effects if the respirator fails, i.e., are the
conditions not immediately dangerous to life or health (IDLH)? (Refer to
Subparagraph 3, page 22, for additional information on IDLH's.)
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a. If yes, conditions are not considered to be IDLH. Proceed to Step 7.
b. If no, conditions are considered to be IDLH. Two types of
respirators are recommended: a SCBA with a full facepiece operated in
pressure demand or other positive pressure mode or an SAR with a full
facepiece operated in pressure demand or other positive pressure mode
in combination with an auxiliary SCBA operated in pressure demand or
other positive pressure mode. The auxiliary SCBA must be of sufficient
duration to permit escape to safety if the air supply is interrupted.
7. Is the contaminant an eye irritant, or can the contaminant cause eye
damage at the exposure concentration? (Refer to Subparagraph 4, page 23,
for a discussion of eye irritation and damage.)
a. If yes, a respirator equipped with a full facepiece, helmet, or hood
is recommended. Proceed to Step 8;
b. If no, an orinasal respirator may still be an option, depending on
the exposure concentration. Proceed to Step 8.
8. Divide the 8-hour time-weighted average (TWA) exposure concentration
for the contaminant (or maximum exposure concentration for a contaminant
with a ceiling limit) determined in Step 5 by the NIOSH REL or other
applicable exposure limit to. determine the minimum protection factor
required. For escape respirators, determine the potential for generation
of a hazardous condition caused by an accident or equipment failure. If a
potentially hazardous condition could occur or a minimum protection factor
has been calculated, proceed to Step 9.
9. If the physical state of the contaminant is a particulate (solid or
liquid) during periods of respirator use, proceed to Step 10; if it is a
gas or vapor, proceed to Step 11; if it is a combination of gas or vapor
and particulate, proceed to Step 12.
10. Particulate Respirators
10.1. Is the particulate respirator intended only for escape purposes?
a. If yes, refer to Subparagraph 5, page 24, for a discussion and
selection of "escape only" respirators.
b. If no, the particulate respirator is intended for use during normal
work activities. Proceed to Step 10.2.
10.2. A filter medium that will provide protection against exposure to the
particulate in question is recommended. (Refer to Subparagraph 9,
page 29, for a discussion on limitations of approvals for filter media.)
Proceed to Step 10.3.
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10.3. Respirators that have not been previously eliminated from Table 1
and that have APF's equal to or greater than the minimum protection factor
determined in Step 8 are recommended. (Refer to Subparagraph 8, page 28,
and Appendix D, page 50, for a discussion of protection factors, and to
Subparagraph 9, page 29, for a discussion on limitations of filter
approvals.) Maximum airborne concentrations for each level of respiratory
protection can be calculated by multiplying the NIOSH REL or other
applicable exposure limit by the APF for that class of respirators.
Workers wearing respirators should meet the medical guidelines discussed
in Subparagraph 10, page 30.
11. Gas/Vapor Respirators
11.1. Is the gas/vapor respirator intended for "escape only" purposes?
a. If yes, refer to Subparagraph 5, page 24, for a discussion on
selection of "escape only" respirators.
b. If no, the gas/vapor respirator is intended for use during normal
work activities. Proceed to Step 11.2.
11.2. Are the warning properties for the gas/vapor contaminant adequate at
or below the NIOSH REL or other applicable exposure limit? (Refer to
Subparagraph 6, page 26, and Appendix C, page 48, for additional
information on requirements for adequate warning properties.)
a. If yes, proceed to Step 11.3.
b. If no, an air-purifying respirator equipped with an effective
end-of-service-life indicator (ESLI), a supplied-air respirator, or a
self-contained breathing apparatus is recommended. (Refer to
Appendix A, page 43, for additional information on approval of
air-purifying respirators with ESLI's.) Proceed to Step 11.4.
11.3. An air-purifying chemical cartridge/canister respirator is
recommended that has a sorbent suitable for the chemical properties of the
anticipated gas/vapor contaminant(s) and for the anticipated exposure
levels. (Refer to Subparagraph 7, page 27, for the recommended maximum
use concentrations of air-purifying chemical cartridge/canister
respirators.) Proceed to Step 11.4.
11.4. Respirators that have not been previously eliminated from Table 2
and that have APF's equal to or greater than the minimum protection factor
determined in Step 8 are recommended. (Refer to Subparagraph 8, page 28,
and Appendix D, page 50, for a discussion of protection factors.) Maximum
airborne concentrations for each class of respiratory protection can be
calculated by multiplying the NIOSH REL or other applicable exposure limit
by the APF for that class of respirators. The calculated maximum use
concentration limits should not exceed the limitations noted in
Subparagraph 7, page 27. Workers wearing respirators should meet the
medical guidelines discussed in Subparagraph 10, page 30.
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12. Combination Particulate and Gas/Vapor Respirators
12.1. Is the combination respirator intended for "escape only" purposes?
a. If yes, refer to Subparagraph 5, page 24, for a discussion and
selection of "escape only" respirators.
b. If no, the combination respirator is intended for use during normal
work activities. Proceed to Step 12.2.
12.2. Does the gas/vapor contaminant have adequate warning properties at
or below the NIOSH REL or other applicable exposure limit? (Refer to
Subparagraph 6, page 26, and Appendix C, page 48, for additional
information on requirements for adequate warning properties.)
a. If yes, proceed to Step 12.3.
b. If no, either an air-purifying respirator equipped with
ESLI (Appendix A, page 43), a supp Ned-air respir;
self-contained respirator is recommended. Proceed to Step
an effective
respirator, or a
12.4.
12.3. An air-purifying chemical cartridge/canister is recommended that has
a particulate prefilter suitable for the specific type(s) of gas/vapor and
participate contaminant(s) and for the exposure concentrations. (Refer to
Subparagraphs 7, page 27, and Subparagraph 9, page 29, for recommended
maximum use concentrations and filter limitations.) Proceed to Step 12.4.
12.4. Respirators that have not been previously eliminated from Table 3
and that have APF's equal to or greater than the minimum protection factor
determined in Step 8 are recommended. (Refer to Subparagraph 8, page 28,
and Appendix D, page 50, for a discussion of protection factors and
Subparagraph 9, page 29, for a discussion on limitations of filter
approvals.) Maximum airborne concent rat ions for each level of respiratory
protection can be calculated by multiplying the NIOSH REL or other
applicable exposure limit by the APF for that class of respirators. The
calculated maximum use concentration limits should not exceed the
Limitations noted in Subparagraph 7, page 27. Workers wearing respirators
should meet the medical guidelines discussed in Subparagraph 10, page 30.
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Table 1. — Assigned protection factor classifications of respirators
for protection against participate exposures1
Assigned protection
factor Type of respirator
5 Single-use (see definition in Glossary) or quarter
^ respi rator
10 Any air-purifying half-mask respirator including
disposable^ (see definition in Glossary) equipped with
any type of particulate filter except single
Any air-purifying full facepiece respirator equipped
with any type of particulate filter^
Any supplied-air respirator equipped with a half-mask
and operated in a demand (negative pressure) mode^
25 Any powered air-purifying respirator equipped with a
hood or helmet and any type of particu'ate filter^
Any supplied-air respirator equipped with a hood or
helmet and operated in a continuous flow mode^
50 Any air-purifying full facepiece respirator equipped
with a high efficiency filter^
Any powered air-purifying respirator equipped with a
tight-fitting facepiece and a high efficiency filter^
Any supplied-air respirator equipped with a full
facepiece and operated in a demand (negative pressure)
mode^
Any supplied-air respirator equipped with a
tight-fitting facepiece and operated in a continuous
f low mode^
Only high efficiency filters are permitted for protection against
particulates having exposure limits less than 0.05 mg/rn^.
The assigned protection factors (APF's) were determined by Los Alamos
National Laboratories (LANL) by conducting quantitative fit testing on a
panel of human volunteers [6].
An APF factor of 10 can be assigned to disposable particulate respirators
if they have been properly fitted using a quantitative fit test.
APF's were based on workplace protection factor (WPF) data or laboratory
data more recently reported than the LANL data [7-11, 14-17].
The APF was based on consideration of efficiency of dust, fume, and/or
mist filters.
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Table 1.—Assigned protection factor classifications of respirators
for protection against particulate exposures'*—Continued
Assigned protection
factor Type of respirator
50 cont. Any self-contained respirator equipped with a full
facepiece and operated in a demand (negative pressure)
mode^
1,000 Any supplied-air respirator equipped with a half-mask
and operated in a pressure demand or other positive
pressure mode^
2,000 Any supplied-air respirator equipped with a full
facepiece and operated in a pressure demand or other
positive pressure mode^
10,000 Any self-contained respirator equipped with a full
facepiece and operated in a pressure demand or other
positive pressure mode^
Any supplied-air respirator equipped with a full
facepiece operated in a pressure demand or other
positive pressure mode in combination with an auxiliary
self-contained breathing apparatus operated in a
pressure demand or other positive pressure mode^
1 Only high efficiency filters are permitted for protection against
particulates having exposure limits less than 0.05 mg/m^.
2 The assigned protection factors (APF's) were determined by Los Alamos
National Laboratories (LANL) by conducting quantitative fit testing on a
panel of human volunteers [6].
3 An APF of 10 can be assigned to disposable particulate respirators if
they have been properly fitted using a quantitative fit test.
4 The APF's were based on workplace protection factor (WPF) data or
laboratory data more recently reported than the LANL data [7-11, 14-17].
5 The APF was based on consideration of efficiency of dust, fume, and/or
mist fi I ters.
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Table 2.—Assigned protection factor classifications of respirators for
protection against gas/vapor exposures
Assigned protection
factor1 Type of respirator
10 Any air-purifying half mask respirator (including
disposable) equipped with appropriate gas/vapor
car t r idges^
Any supplied-air respirator equipped with a half mask
and operated in a demand (negative pressure) mode^
25 Any powered air-purifying respirator with a
loose-fitting hood or helmet^
Any supplied-air respirator equipped with a hood or
helmet and operated in a continuous flow mode^
50 Any air-purifying full facepiece respirator equipped
with appropriate gas/vapor cartridges or gas mask
(canister respirator)^
Any powered air-purifying respirator equipped with a
tight-fitting facepiece and appropriate gas/vapor
cartridges or canisters^
Any supplied-air respirator equipped with a full
facepiece and operated in a demand (negative pressure)
Any supplied-air respirator equipped with a tight-
fitting facepiece operated in a continuous flow mode^
Any self-contained respirator equipped with a full
facepiece and operated in a demand (negative pressure)
1,000 Any supplied-air respirator equipped with a half-mask
and operated in a pressure demand or other positive
pressure mode^
^ The assigned protection factor (APF) for a given class of air-purifying
respirators may be further reduced by considering the maximum use
concentrations for each type of gas and vapor air-purifying element.
2 The APF ' s were determined by Los Alamos National Laboratories (LAND by
conducting quantitative fit testing on a panel of human volunteers [6].
3 The APF's were based on workplace protection factor (WPF) data or
laboratory data more recently reported than the LANL data [7-11, 14-17].
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Table 2.—Assigned protection factor classifications of respirators for
protection against gas/vapor exposures—Continued
Assigned protection
factor'' TXPe of respirator
2,000 Any supplied-air respirator equipped with a full
facepiece and operated in a pressure demand or other
positive pressure mode^
10,000 Any self-contained respirator equipped with a full
facepiece and operated in a pressure demand or other
positive pressure mode^
Any supplied-air respirator equipped with a full
facepiece operated in a pressure demand or other
positive pressure mode in combination with an auxiliary
self-contained breathing apparatus operated in a
pressure demand or other positive pressure mode^
1 The assigned protection factor (APF) for a given class of air-purifying
respirators may be further reduced by considering the maximum use
concentrations for each type of gas and vapor air-purifying element.
2 The APF's were determined by Los Alamos National Laboratories (LANL) by
conducting quantitative fit testing on a panel of human volunteers [6].
3 The APF's were based on workplace protection factor (WPF) data or
laboratory data more recently reported than the LANL data [7-11, 14-17].
ft
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Table 3.—Assigned protection factor classifications of respirators for
protection against combination gas/vapor and participate exposures"'
Assigned protection
factor2 Type of respirator
10 Any air-purifying half-mask respirator equipped with
appropriate gas/vapor cartridges in combination with any
type of particulate filter^
Any full facepiece respirator with appropriate gas/vapor
cartridges in combination with a dust or mist or fume;
dust and mist; or dust, mist, and fume filter^
Any supplied-air respirator equipped with a half-mask
and operated in a demand (negative pressure) mode**
25 Any powered air-purifying respirator equipped with a
loose-fitting hood or helmet^
Any supplied-air respirator equipped with a hood or
helmet and operated in a continuous flow
50 Any air-purifying full facepiece respirator equipped
with appropriate gas/vapor cartridges in combination
with a high efficiency filter or an appropriate canister
incorporating a high efficiency filter^
Any powered air-purifying respirator with a
tight-fitting facepiece equipped with appropriate
gas/vapor cartridges in combination with a high
efficiency filter or an appropriate canister
incorporating a high efficiency filter^
Any supplied-air respirator equipped with a full
facepiece and operated in a demand (negative pressure)
mode^
Only high efficiency filters are permitted for protection against
particulates having exposure limits less than 0.05 mg/m^.
The assigned protection factor (APF) for a given class of air-purifying
respirators may be further reduced by considering the maximum use
concentrations for each type of gas and vapor air-purifying element.
The APF's were determined by Los Alamos National Laboratories (LAND by
conducting quantitative fit testing on a panel of human volunteers [6].
The APF was based on consideration of efficiency of dust, fume, and/or
mist filters.
The APF's were based on workplace protection factor (WPF) data or
laboratory data more recently reported than the LANL data [7-11, 14-17].
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Table 3.—Assigned protection factor classifications of respirators for
protection against combination gas/vapor and participate exposures^—
Continued
Assigned protection
factor^ Type of respirator
50 cont. Any suppl ied-ai r respirator equipped with a
tight-fitting facepiece and operated in a continuous
f low mode^
Any self-contained respirator equipped with a full
facepiece and operated in a demand (negative pressure)
1,000 Any suppl ied-ai r respirator equipped with a half-mask
and operated in a pressure demand or other positive
pressure mode^
2,000 Any suppl ied-ai r respirator equipped with a full
facepiece and operated in a pressure demand or other
positive pressure mode^
10,000 Any self-contained respirator equipped with a full
facepiece and operated in a pressure demand or other
positive pressure mode^
Any suppl ied-ai r respirator equipped with a full
facepiece operated in a pressure demand or other
positive pressure mode in combination with an auxiliary
self-contained breathing apparatus operated in a
pressure demand or other positive pressure mode^
Only high efficiency filters are permitted for protection against
particulates having exposure limits less than 0.05 mg/m^.
The assigned protection factor (APF) for a given class of air-purifying
respirators may be further reduced by considering the maximum use
concentrations for each type of gas and vapor air-purifying element.
The APF's were determined by Los Alamos National Laboratories (LANL) by
conducting quantitative fit testing on a panel of human volunteers [6].
The APF was based on consideration of efficiency of dust, fume, and/or
mist f i Iters.
The APF's were based on workplace protection factor (WPF) data or
laboratory data more recently reported than the LANL data [7-11, 14-17].
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The Respirator Decision Logic Sequence is presented in Figure
of a flow chart. This flow chart can be used to identify sui
of respirators for adequate protection against specific
1 in the form
fy suitable classes
respirators for adequate protection against specific environmental
conditions. Refer to the corresponding narrative section for additional
information pertaining to a specific part of the flow chart.
It other contaminants
- , are present
KEY: CC—Contaminant Concentration
EL—Exposure Limit
ESLI —End of Service Life Indicator
FF—Full Facepiece
IDLH — Immediately Dangerous
to Life or Health
PD—Pressure Demand
PF—Protection Factor
PFa—Assigned PF
PFmin—Minimum PF
PP—Positive Pressure
SCBA—Self-Contained
Breathing Apparatus
SAR—Supplied-Air Respirator
A' - SCBA with FF operated in PO or PP mode.
B" • Type C supplied-air respirator (airline)
operated in PD or PP mode with auxiliary SCBA.
C' • Escape respirator or gas mask with appropriate
filter/sorbent (Subparagraph 5); if 0, deficient,
then SCBA.
Figure 1. — Flow Chart of Respirator Decision Logic Sequence
108
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Air-Purt tying
Chemical
CarlridgefCanlster
(Subparagraph 7)
Samas is
10.3
Air-Purifying Respirator
with ESLI (Appendix A)
or any SAR, SCBA
Orinasal Style
Respirator May
Be Optional
FF.
Helmet, or Hood
Only Option
Select Respirator Type
Based on PFs>PFmin
(Subparagraphs 8, 9, 10.
and Appendix D)
0
PFmln - CC/EL
Adequate
Warning
Properties?
(Subpar. 6 &
App. C)
Select
Paniculate
Type Filter
(Subparagraph 9)
Gas/Vapor,/ ^ \Partlculate
Contamlnmant
State
Combination y Partlculate-Gas/Vapor
M2.
Sam
10
;
4)
i as
3
Air-Purifying
Respirator with
ESLI (Appendix A)
or any
SAR, SCBA
No / Adequate \^ Yes
i^ f Warning N ^
N. Properties? /
\ (Subpar. 6 1 /
X APP. ci \S
_^-
Chemical
Cartridge/
Canister with
Paniculate Prelllter
(Subparagraph 7)
\
Figure 1. — Flow Chart of Respirator Decision Logic Sequence — Continued
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D, Subparagraphs
The following subparagraphs provide additional information to assist the
reader in using the Respirator Decision Logic Sequence:
Subparagraph 1: Oxygen-Deficient Atmosphere
The National Institute for Occupational Safety and Health (NIOSH) defines an
oxygen-deficient atmosphere as any atmosphere containing oxygen at a
concentration below 19.5% at sea level [1]. NIOSH certification of air-line
or air-purifying respirators is limited to those respirators used in
atmospheres containing at least 19.5% oxygen, except for those air-line
respirators equipped with auxiliary self-contained breathing apparatus
(SCBA).
The minimum requirement of 19.5% oxygen at sea level provides an adequate
amount of oxygen for most work assignments and includes a safety factor.
The safety factor is needed because oxygen-deficient atmospheres offer
little warning of the danger, and the continuous measurement of an
oxygen-deficient atmosphere is difficult.
At oxygen concentrations below 16% at sea level, decreased mental
effectiveness, visual acuity, and muscular coordination occur. At oxygen
concentrations below 10%, loss of consciousness may occur, and below 6%
oxygen, death will result. Often only mild subjective changes are noted by
individuals exposed to low concentrations of oxygen, and collapse can occur
without warning [2,3,4].
Since oxygen-deficient atmospheres are life-threatening, only the most
reliable respirators are recommended; the most reliable respirators are the
self-contained breathing apparatus or the supplied-air respirators with
auxiliary self-contained units. Because a high protection factor is not
necessary to ensure an adequate supply of oxygen even in an atmosphere
containing no oxygen, any certified self-contained unit is adequate. All
aspects of a respiratory protection program must be instituted for these
recommendations to be valid.
Subparagraph 2: Exposure Limits
The majority of the OSHA PEL's were adopted from the American Conference of
Governmental Industrial Hygienists (ACGIH) TLVs® published in 1968. The
difficulty in changing PEL's through promulgation of standards when new
toxicologic information is identified has caused many standards to become
outdated. The effectiveness of this decision logic is limited to the
adequacy of the selected exposure limits in protecting the health of
workers. Exposure limits based on a thorough evaluation of more recent or
extensive data should be given priority.
For all chemicals that cause irritation or systemic effects but do not cause
carcinogenic effects, it is currently believed that a threshold exposure
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concentration exists such that virtually all persons in the working
population (with the possible exception of hypersensitive individuals) would
experience no adverse health effects.
For many carcinogenic substances, most available data provide no evidence
for the existence of a threshold exposure concentration below which the
substance would be safe. As with noncarcinogenic substances, there appears
to be a dose-response relationship for carcinogenic substances. If no
threshold exists for a carcinogen, then there is no safe exposure
concentration; however, lower exposures would be associated with lower risks.
For some carcinogens, NIOSH attempts to identify the lowest REL on the basis
of the quantitative detection Limit for the method used to monitor
exposures. For other carcinogens, NIOSH does not identify a precise
exposure limit but recommends instead that the employer control worker
exposures to the lowest feasible limit.
Regardless of the selected exposure limit for a carcinogen, the best
engineering controls and work practices should be instituted. Respirators
should not be used as a substitute for proper control measures. When
respiratory protection is required to achieve the lowest exposure
concentration, then only the most effective respirators should be used. Two
types of respirators are recommended: a full facepiece SCBA operated in a
pressure-demand or other positive pressure mode or a full facepiece
supplied-air respirator (SAR) operated in a pressure-demand or other
positive pressure mode in combination with a SCBA operated in a pressure
demand or other positive pressure mode. The practicality of each situation
must be assessed to determine the most technically feasible protection for
the worker.
Other variables such as the specific situation, worker, or job may influence
the selection of the appropriate exposure limit for a given contaminant.
For example, the effects of some hazardous substances may be increased due
to exposure to other contaminants present in the workplace or the general
environment or to medications or personal habits of the worker. Such
factors, which would affect the toxicity of a contaminant, would not have
been considered in the determination of the specific exposure limit. Also,
some substances are absorbed by direct contact with the skin and mucous
membranes, thus potentially increasing the total exposure.
Subparagraph 3: Immediately Dangerous to Life or Health (IDLH)
An IDLH exposure condition is defined in this decision logic as one that
poses a threat of exposure to airborne contaminants when that exposure is
likely to cause death or immediate or delayed permanent adverse health
effects or prevent escape from such an environment. The purpose of
establishing an IDLH exposure level is to ensure that the worker can escape
from a given contaminated environment in the event of failure of the
respiratory protection equipment. The IDLH is considered a maximum level
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above which only a highly reliable breathing apparatus providing maximum
worker protection is permitted. Any appropriate approved respirator may be
used to its maximum use concentration up to the IDLH concentration.
In establishing
assured:
the IDLH concentration, the following conditions must be
a. The ability to escape without loss of life or immediate or delayed
irreversible health effects. (Thirty minutes is considered the maximum
time for escape so as to provide some margin of safety in calculating the
IDLH.)
b. The prevention of severe eye or
reactions that would hinder escape.
respiratory irritation or other
Sources of information for determining whether the exposure
contaminant represents an IDLH condition are as follows:
limit for
a. Specific IDLH guidelines provided in the literature such as the
American Industrial Hygiene Association (A I HA) Hygienic Guides and the
NIOSH Pocket Guide for Hazardous Chemical Substances (previous editions
were published jointly by NIOSH and OSHA), and/or
b. Human exposure and effects data, and/or
c. Animal exposure and effects data, and/or
contaminant are lacking, toxicologic
chronic animal exposure data may be
d. Where such data specific to the
data from analogous substances and
cons idered.
Subparagraph 4: Eye Irritation
Eye protection in the form of respirators with full facepieces, helmets, or
hoods is required for routine exposures to airborne contaminants that cause
any irritation to the mucous membranes of the conjunctivae or the cornea or
cause any reflex tearing. Eye protection is required for contaminants that
cause minor subjective effects as well as for those that cause any damage,
including disintegration and sloughing of conjunctiva! or corneal
epithelium, edema, or ulceration. NIOSH is not aware of any standards for
gas-tight goggles that would permit NIOSH to recommend such goggles as
providing adequate eye protection.
For escape, some eye irritation is permissible if the severity of irritation
does not inhibit the escape and if no irreversible scarring or ulceration of
the eyes or conjunctivae is likely.
When data on
or half-mask
threshold levels for eye
respirators can be used,
i rr i tat ion are
provided that
insufficient, quarter-
the worker experiences
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no eye discomfort and no pathologic eye effects develop. Workers should be
told that if any eye discomfort is experienced, they will be provided with
respirators that have full facepieces, helmets, or hoods and that provide
protection equivalent to the quarter- or half-mas.k respirators.
Subparagraph 5: Escape Apparatus
Escape devices have a single function: to allow a person working in a
normally safe environment sufficient time to escape from suddenly occurring
respiratory hazards.
Escape devices can be separated into two categories: air-purifying
respirators- and self-contained breathing apparatus. Air-purifying
respirators remove contaminants from the air by sorbent and/or filter media,
but because they do not provide air, these respirators cannot be used in an
oxygen-deficient atmosphere. Air-purifying escape respirators include the
escape gas mask (canister) respirator, the gas mask (canister) respirator,
and the filter self-rescuer. The escape gas mask consists of a half-mask or
a mouthpiece respirator. The mouthpiece respirator can be used for short
periods of time to escape from low concentrations of organic vapor or acid
gas. The escape gas mask, which utilizes a half-mask, filters contaminants
from the air. These respirators may also be used to escape from low
concentrations of organic vapor or acid gas. Escape gas mask respirators
equipped with full facepieces can also be used for escape from IDLH
conditions but not from oxygen-deficient atmospheres. No air-purifying
device is suitable for escape from a potentially oxygen-deficient
atmosphere. The filter self-rescue unit is the mouthpiece device, which is
designed to protect specifically against less than 1% carbon monoxide.
A self-contained breathing apparatus (SCBA) provides air to the user for
escape from oxygen-deficient environments. Escape SCBA devices are commonly
used with full facepieces or hoods and, depending on the supply of air, are
usually rated as 3- to 60-minute units. Self-contained self-rescuer (SCSR)
devices have been approved by MSHA/NIOSH for escape from mines, but these
devices may also have application in other similar environments. SCSR's are
mouthpiece respirators that provide a source of oxygen-enriched air for up
to 60 minutes. All SCBA devices can be used in oxygen-deficient atmospheres.
When selecting escape apparatus, careful consideration must be given to
potential eye irritation. This consideration is important for determining
whether a gas mask or SCBA equipped with a full face.piece should be selected
rather than a device equipped with a half-mask or mouthpiece.
The majority of gas masks or escape gas masks can be used in situations
involving gas(es), vapor(s), or particulates. For escape from
particulate-contaminated environments, an air-purifying element must be
selected that will provide protection against the given type of
particulate. The information in Table 4 should be used to select the
appropriate escape apparatus.
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Table 4.—Selection options for escape respirators
Escape conditions
Type of respirator
Short distance to exit, no
obstacles (no oxygen deficiency)
Long distance to exit
or obstacles along the way
(no oxygen deficiency)
Potential oxygen deficiency
Any escape gas mask^ (canister
respirator) or gas
(canister respi rator)
Any escape self-contained
breathing apparatus having a
sui tab I e servi ce I i f e^
Any acceptable device for entry
into emergency situations
Any gas
Any escape self-contained
breathing apparatus having a
sui table service I i
Any self-contained self-rescuer
having a suitable service life
Any escape self-contained
breathing apparatus having a
sui table service I i
Any self-contained self-rescuer
having a suitable service life
An escape gas mask is a respirator designed for use during escape only
from immediately dangerous to life or health (IDLH) or non-IDLH
atmospheres. It may consist of a half mask facepiece or mouthpiece,
appropriate air-purifying element for the contaminant, and associated
connections. Maximum use concentrations for these types of respirators
are designated by the manufacturer.
A gas mask consists of a full facepiece and either chin-style or front-
or back-mounted canisters with associated connections. Maximum use
concentrations for canister air-purifying elements are listed in Table 5.
Escape self-contained breathing apparatus can have rated service lives
of 3 to 60 minutes. All acceptable devices for entry into emergency
situations can also be used.
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Subparagraph 6: Potential Warning Properties for Use With
Cartridge/Canister Air-Purifying Respirators
For the purpose of this decision logic, warning properties are defined
according to odor, taste, eye irritation, or respiratory irritation.
Adequate warning properties imply that the gas or vapor of interest has a
persistent odor or irritant effect at concentrations at or below the OSHA
PEL or NIOSH REL. Recognition of an odor depends on a person's sensory
ability to detect it. Since the range of odor recognition thresholds within
a population is very large, odor recognition should not be relied on as the
only means for determining that a cartridge or canister is no longer
effectively removing a contaminant from the air. A more detailed discussion
of variability of odor detection within a population is provided in
Appendix C.
NIOSH recommends that the employer ensure that each worker who is required
to wear an air-purifying cartridge or canister respirator is capable of
recognizing the odor of the substance of concern at a concentration at or
below the applicable exposure limit. Such a determination will necessitate
that an odor screening test be conducted on each individual for each
substance of concern in the particular workplace.
It is recognized that existing screening tests are subjective in nature and
not sufficiently sensitive and that conducting screening tests for a group
of workers exposed to several substances may be impractical. Therefore,
NIOSH knows of no compelling reason not to develop quantitative service life
test data to supplement or replace odor screening test results if it can be
demonstrated that such a procedure will afford the wearer a level of
protection at least equivalent to that indicated by odor screening. Even
when service life test data are used, the employer and the respirator wearer
should not ignore the usefulness of sensory detection properties (for those
who can detect the contaminant's presence) to serve as a warning that the
cartridge/canister has failed or that the integrity of the respirator face
seal has been compromised.
It is important to realize that 30 CFR 11 [specifically, 30 CFR 11.90(b)
(note 4) for gas masks (canister respirators) and 30 CFR 11.150 (note 7) for
chemical cartridge respirators], which provides for approval of
air-purifying (organic vapor) devices, prohibits their approval for use
against organic vapors with poor warning properties unless there is an OSHA
standard which permits their use. A more detailed discussion appears in
Appendix C.
A recent policy decision by NIOSH allows the use of respirators with
effective end-of-service-life indicators for protection against contaminants
with poor warning properties, provided that certain conditions are met.
These conditions are described in that policy statement, which is reproduced
in Appendix A.
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Subparagraph 7: Limitations of Respirators for Gases and Vapors
Air-purifying respirators cannot be used in IDLH atmospheres or in
atmospheres containing less then 19.5% oxygen by volume. Gas masks
(canister respirators) may be used for escape if the atmosphere is not
oxygen-def ici ent.
If, after the APF is multiplied by the REL or other applicable exposure
limit (APF X REL), the product exceeds the IDLH value, then the IDLH value
shall be the maximum use concentration. (See Tables 1, 2, and 3.) In
addition, there are maximum use concentrations associated with all gas and
vapor air-purifying elements. (See Table 5.)
Air-purifying devices should not be allowed for either entry into or escape
from hazardous environments when supporting evidence exists to demonstrate
that unreasonably short service life would occur at the maximum use
concent rat ion.
Where there is reason to suspect that a sorbent has a high heat of reaction
with a substance, use of that sorbent is not recommended. For such a
substance, only non-oxidizabIe sorbents should be allowed.
Air-purifying respirators cannot be used for protection against gases and
vapors with poor warning properties unless the respirator is approved with
an effective ESLI. (See Appendix A.)
Although limited in number, there are specific air-purifying respirators
that are approved by MSHA/NIOSH for protection against gases and vapors when
respirators approved for a given class of contaminants (e.g., organic
vapors) cannot be used due to sorbent deficiencies.
Subparagraph 8: Assigned Protection Factors (APF's)
APF's (sometimes referred to in the literature as respirator protection
factors), which appear in the 1975 and 1978 versions of the OSHA/NIOSH
•Respirator Decision Logic, in the 1980 American National Standards Institute
(ANSI) standards for respiratory protection, and in all OSHA health
standards, are based on quantitative fit testing (QNFT) of respirators [6].
(See definition of fit factors in Appendix D.) No data have been reported
in the literature to demonstrate that the results of QNFT are sufficiently
indicative of the protection that a given respirator provides in the
workplace. Recent studies by NIOSH [7-9] and others [10-12] have suggested
that fit factors do not correlate with the workplace protection factors
provided by powered air-purifying respirators (PAPR's) and negative pressure
half-mask respirators. (See definition of workplace protection factors in
Appendix D.)
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Table 5.—NIOSH recommended maximum use concentrations (expressed in ppm)
for gas and vapor air-purifying elements
Class
Type of gas or vapor
Organic vapors
Acid gases
Sulfur dioxide (S02)
Chlorine (Cl2)
Hydrochloric (HCI)
Ammonia (NK^)
Methyl amine (CH3NH2)
Carbon monoxide (CO)
ification of gas
Cartridge(s)
1,000*
50
10
50
300
100
NA
and vapor air-puri
Chin-style
canister
s.ooot
100
25
100
500
—
NA
fying elements
Front- or
back-mounted
canister
20,000t
100
25
100
500
—
1,500
* Maximum use concentration will be 1,000 ppm or the immediately dangerous
to life or health (IDLH) value for the specific organic vapor, whichever
i s Iowe r.
t Maximum use concentration for "entry into" will be limited to the value
listed or to the IDLH value for the specific organic vapor, whichever is
I owe r.
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APF's that are still based on the fit factors determined by Los Alamos
National Laboratories (LANL) can be used for those classes of respirators
for which no WPF data or simulated workplace protection factor (SWPF) data
are available. However, as WPF data are developed, these APF's will be
revised, as have the current APF's for powered air-purifying respirators
(PAPR's) [7-9,11,14-16]. It should be noted that a number of studies
[17-20] on the workplace performance of respirators have appeared in the
literature. However, the results of these studies are of little value for
establishing APF's because their protocols did not require proper fit or
correct use and conscientious wearing of the respirator while in-facepiece
sampling was done. A notable exception is the study by Revoir (1974) [21].
When WPF data existed, NIOSH utilized the point estimate equation proposed
by Myers et al. [13] to help establish the APF's recommended in this
decision logic. The point estimate equation is as follows:
protection factor (PF) =/ag/SgzP
where /Ig = the geometric mean of the measured WPF
Sg = the geometric standard deviation of the measured WPF
Zp = the value corresponding to the selected proportion
(p) on the log-normal probability distribution
When WPF data existed, NIOSH selected a confidence limit of p=0.95. Thus
for a given set of data and given class of respirators, NIOSH would expect
that 95% of the WPF's would exceed the calculated point estimate value.
Despite the fact that some of the PF's have a statistical basis, they are
still only estimates of an approximate level of protection. It must not be
assumed that the numerical values of the APF's presented in this decision
logic represent the absolute minimum level of protection that would be
achieved for all workers in all jobs against all respiratory hazards. The
industrial hygienist or other professional responsible for providing
respiratory protection or evaluating respiratory protection programs is
therefore encouraged to .evaluate as accurately as possible the actual
protection being provided by the respirator.
Subparagraph 9: Particulate Filter Respirators
MSHA/NIOSH particulate respirators are certified according to seven basic
categories. These categories consist of the following types of exposures:
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• Dusts: Airborne exposure limit not less than 0.05 mg/m^ or 2 mppcf
(see Appendix B);
• Fumes: Airborne exposure limit not less than 0.05 mg/m^ or 2 mppcf;
• Mists: Airborne exposure limit not less than 0.05 mg/m^ or 2 mppcf
(see Appendix B);
• Dusts, Fumes, and Mists: Airborne exposure limit less than
0.05 mg/m^ or 2 mppcf and radionuclides;
• Radon Daughters;
• Asbestos-Containing Dusts and Mists (see Appendix B); and
• Single-Use Dust and Mist Respirators (see Appendix B).
Subparagraph 10: Suggested Medical Evaluation and Criteria for Respirator
Use
The following NIOSH recommendations allow latitude for the physician in
determining a medical evaluation for a specific situation. More specific
guidelines may become available as knowledge increases regarding human
stresses from the complex interactions of worker health status, respirator
usage, and job tasks. While some of the following recommendations should be
part of any medical evaluation of workers who wear respirators, others are
identified as being applicable for specific situations.
a. A Physician Should Make the Determination of Fitness to Wear a
Respirator by Considering the Worker's Health, the Type of Respirator,
and the Conditions of Respirator Use.
The recommendation above satisfies OSHA regulations and leaves the final
decision of an individual's fitness to wear a respirator to the person
who is best qualified to evaluate the multiple clinical and other
variables. Much of the clinical and other data could be gathered by
other personnel. It should be emphasized that the clinical examination
alone is only one part of the fitness determination and that
collaboration with foremen, industrial hygienists, and others may often
be needed to better assess the work conditions and other factors that
affect an individual's fitness to wear a respirator.
b. A Medical History and At Least a Limited Physical Examination are
Recommended.
The medical history and physical examination should emphasize the
evaluation of the cardiopulmonary system and should elicit any history of
respirator use. The history is an important tool in medical diagnosis
and can be used to detect most problems that might require further
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evaluation. Objectives of the physical examination should be to confirm
the clinical impression based on the history and to detect important
medical conditions (such as hypertension) that may be essentially
asymptomatic.
c. While Chest X-Ray and/or Spirometry May Be Medically Indicated in
Some Fitness Determinations, These Should Not Be Routinely Performed.
In most cases, the hazardous situations requiring the wearing of
respirators will also mandate periodic chest X-ray and/or spirometry for
exposed workers. When such information is available, it should be used
in the determination of fitness to wear respirators. (See Recommendation
h, page 33.)
Routine chest X-rays and spirometry are not recommended solely as data
for determining if a respirator should be worn. In most cases, with an
essentially normal clinical examination (history and physical) these data
are unlikely to influence the respirator fitness determination;
additionally, the X-ray would be an unnecessary source of radiation
exposure to the worker. Chest X-rays in general do not accurately
reflect a person's cardiopulmonary physiologic status, and limited
studies suggest that mild to moderate impairment detected by spirometry
would not preclude the wearing of respirators in most cases. Thus it is
recommended that chest X-ray and/or spirometry be done only when
clinically indicated. (See Appendix E, page 52, for further discussion
on the pulmonary effects of wearing respirators.)
d. The Recommended Periodicity of Medical Fitness Determinations Varies
According to Several Factors but Could Be as Infrequent as Every 5 Years.
Federal or other applicable regulations shall be followed regarding the
frequency of respirator fitness determinations. The guidelines for most
work conditions for which respirators are required are shown in Table 6.
These guidelines are similar to those recommended by ANSI, which
recommends annual determinations after age 45 [22]. The more frequent
examinations with advancing age relate to the increased prevalence of
most diseases in older people. More frequent examinations are
recommended for individuals performing strenuous work involving the use
of SCBA. These guidelines are based on clinical judgment and, like the
other recommendations in this section, should be adjusted as clinically
indicated.
e. The Respirator Wearer Should Be Observed During a Trial Period to
Evaluate Potential Physiological Problems
In addition to considering the physical effects of wearing respirators,
the physician should determine if wearing a given respirator would cause
extreme anxiety or claustrophobic reaction in the individual. This could
be done during training, while the worker is wearing the respirator and
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is engaged in some exercise that approximates the actual work situation.
Present regulations state that a worker should be provided the
opportunity to wear the respirator "in normal air for a long familiarity
period..." [23]. This trial period should also be used to evaluate the
ability and tolerance of the worker to wear the respirator [24]. This
trial period need not be associated with respirator fit testing and
should not compromise the effectiveness of the vital fit testing
procedure.
Table 6.—Suggested frequency of medical fitness determinations*
Worker age (years)
<35 35 - 45 >45
Most work condi- Every 5 yrs Every 2 yrs 1-2 yrs
tions requiring
respi rators
Strenuous work Every 3 yrs Every 18 mos Annually
conditions wi th
SCBAt
* Interim testing would be needed if changes in health status occur.
t SCBA = self-contained breathing apparatus
f. Examining Physicians Should Realize that the Main Stress of Heavy
Exercise While Using a Respirator Is Usually on the Cardiovascular System
and that Heavy Respirators (e.g., Self-Contained Atmosphere Supplying)
Can Substantially Increase this Stress. Accordingly, Physicians May Want
To Consider Exercise Stress Tests with Electrocardiographic Monitoring
When Heavy Respirators Are Used, When Cardiovascular Risk Factors Are
Present, or When Extremely Stressful Conditions Are Expected.
Some respirators may weigh up to 35 pounds and may increase workloads by
20 percent. Although a lower activity level could compensate for this
added stress [25], a lower activity level might not always be possible.
Physicians should also be aware of other added stresses, such as heavy
protective clothing and intense ambient heat, which would .increase the
worker's cardiac demand. As an extreme example, firefighters who use
SCBA inside burning buildings may work at maximal exercise levels under
life-threatening conditions. In such cases, the detection of occult
cardiac disease, which might manifest itself during heavy stress, may be
important. Some authors have either recommended stress testing [26] or
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at least its consideration in the fitness determination [22].
Kilbom [26] has recommended stress testing at 5-year intervals for
firefighters below age 40 who use SCBA and at 2-year intervals for those
aged 40-50. He further suggested that firemen over age 50 not be allowed
to wear SCBA.
Exercise stress testing has not been recommended for medical screening
for coronary artery disease in the general population [27,28]. It has an
estimated sensitivity and specificity of 78% and 69%, respectively, when
the disease is defined by coronary angiography [27,29]. In a recent
6-year prospective study, stress testing to determine the potential for
heart attack indicated a positive predictive value of 27% when the
prevalence of disease was 3 1/2% [30,31]. While stress testing has
limited effectiveness in medical screening, it could serve to detect
those individuals who may not be able to complete the heavy exercise
required in some jobs.
A definitive recommendation regarding exercise stress testing cannot be
made at this time. Further research may determine whether this is a
useful tool in selected circumstances.
g. An Important Concept Is that "General Work Limitations and
Restrictions Identified for Other Work Activities Also Shall Apply for
Respirator Use" [22].
In many cases, if a worker is able to do an assigned job without an
increased risk to health while not wearing a respirator, the worker will
in most situations not be at increased risk when performing the same job
white wearing a respirator.
h. Because of the Variability in the Types of Respirators, Work
Conditions, and Workers' Health Status, Many Employers May Wish to
Designate Categories of Fitness To Wear Respirators, Thereby Excluding
Some Workers from Strenuous Work Situations Involving the Wearing of
Respirators.
Depending on the various circumstances, there could be several
permissible categories of respirator usage. One possible scheme would
consist of three overall categories: full respirator use, no respirator
use, and limited respirator use including "escape only" respirators. The
latter category excludes heavy respirators and strenuous work
conditions. Before identifying the conditions that would be used to
classify workers into various categories, it is critical that the
physician be aware that these conditions have not been validated and are
presented only for consideration. The physician should modify the use of
these conditions based on actual experience, further research, and
individual worker sensitivities. The physician may wish to consider the
following conditions in selecting or permitting the use of respirators:
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• History of spontaneous pneumothorax;
• Claustrophobia/anxiety reaction;
• Use of contact lens (for some respirators);
• Moderate or severe pulmonary disease;
• Angina pectoris, significant arrhythmias, recent myocardial
infarct ion;
• Symptomatic or uncontrolled hypertension; and
• Age.
It seems unlikely that wearing a respirator would play any significant
role in causing lung damage such as pneumothorax. However, without good
evidence that wearing a respirator would not cause such lung damage, it
may be prudent to prohibit the individual with a history of spontaneous
pneumothorax from wearing a respirator.
Moderate lung disease is defined by the Intermountain Thoracic Society
[32] as being a forced expiratory volume in one second (FEV-|) divided
by the forced vital capacity (FVC) (i.e., FEV^FVC) of 0.45 to 0.60 or
an FVC of 51 to 65% of the predicted FVC value. Similar arbitrary limits
could be set for age and hypertension. It would seem more reasonable,
however, to combine several risk factors into an overall estimate of
fitness to wear respirators under certain conditions. Here the judgment
and clinical experience of the physician are needed. Even many impaired
workers would be able to work safely while wearing respirators if they
could control their own work pace, including having sufficient time to
rest.
Conclusion
Individual judgment is needed in determining the factors affecting an
individual's fitness to wear a respirator. While many of the preceding
guidelines are based on limited evidence, they should provide a useful
starting point for a respirator fitness screening program. Further research
is needed to validate these recommendations and others currently in use. Of
particular interest would be laboratory studies involving physiologically
impaired individuals and field studies conducted under actual day-to-day
work condi tions.
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59. Harber P, Tamimie RJ, Bhattacharya A, Barber M. Physiologic effects of
respirator dead space and resistance loading. J Occup Med
1982,-24(9):681-84.
60. Petsonk EL, Hancock J, Boyles C. Physiologic effects of a
self-contained self-rescuer. Am Ind Hyg Assoc J 1983;44(5):368-73.
61. Morgan WP. Psychological problems associated with the wearing of
industrial respirators: a review. Am Ind Hyg Assoc J 1983;44(9):671-76.
62. Morgan WP. Psychological problems associated with the wear of
industrial respirators. J Int Soc Respir Prot 1983;1:67-108.
63. Ronk R, White MK. Hydrogen sulfide and the probabilities of
"inhalation" through a tympanic membrane defect. J Occup Med
1985;27(5):337-40.
64. Cantekin El, Bluestone CD, Saez CA, Bern SA. Airflow through the
eustachian tube. Ann Otol 1979;88.'603-612.
65. daRoza RA, Weaver C. Is it safe to wear contact lenses with a
full-facepiece respirator? Lawrence Livermore National Laboratory
manuscript UCRL-53653, 1985, pp. 1-3.
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IV. GLOSSARY
The following definitions of terms are provided to assist in the
understanding and application of this decision logic.
ASSIGNED PROTECTION FACTOR (APF): See PROTECTION FACTOR.
BREAKTHROUGH: The penetration of challenge material(s) through a gas or a
vapor air-purifying element. The quantity or extent of breakthrough during
service life testing is often referred to as the percentage of the input
concent rat ion.
DISPOSABLE RESPIRATORS: A respirator that is discarded after the end of
its recommended period of use, after excessive resistance or physical
damage, or when odor breakthrough or other warning indicators render the
respirator unsuitable for further use.
DUST: A solid, mechanically produced particle with a size ranging from
submicroscopic to macroscopic.
EMERGENCY RESPIRATOR USE SITUATION: A situation that requires the use of
respirators due to the unplanned generation of a hazardous atmosphere (often
of unknown composition) caused by an accident, mechanical failure, or other
means and that requires evacuation of personnel or immediate entry for
rescue or corrective action.
ESCAPE GAS MASK: A gas mask that consists of a half-mask facepiece or
mouthpiece, a canister, and associated connections and that is designed for
use during escape only from hazardjus atmospheres (see Subparagraph 5).
ESCAPE ONLY RESPIRATOR: Respiratory devices that are designed for use
only during escape from hazardous atmospheres.
FILTERING FACEPIECE: A particulate respirator with a filter as an
integral part of the facepiece or with the entire facepiece composed of the
filtering medium. (See SINGLE-USE DUST or DUST and MIST RESPIRATORS and
DISPOSABLE RESPIRATORS.)
FIT FACTOR: A quantitative measure of the fit of a specific respirator
facepiece to a particular individual. (For further discussion of fit
factors, refer to Appendix D.)
FUME: A solid condensation particulate, usually of a vaporized metal.
GAS: An aeriform fluid that is in a gaseous state at standard temperature
and pressure.
IMMEDIATELY DANGEROUS TO LIFE OR HEALTH (IDLH): Acute respiratory
exposure that poses an immediate threat of loss of life, immediate or
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delayed irreversible adverse effects on health, or acute eye exposure that
would prevent escape from a hazardous atmosphere.
MIST: A liquid condensation particle.
ORINASAL RESPIRATOR: A respirator that covers the nose and mouth and that
generally consists of a quarter- or half-facepiece.
PUNNED or UNPLANNED ENTRY into an IDLH ENVIRONMENT, AN ENVIRONMENT OF
UNKNOWN CONCENTRATION of HAZARDOUS CONTAMINANT, or an ENVIRONMENT of UNKNOWN
COMPOSITION: A situation in which respiratory devices are recommended to
provide adequate protection to workers entering an area where the
contaminant concentration is above the IDLH or is unknown.
POTENTIAL OCCUPATIONAL CARCINOGEN: Any substance, or combination or
mixture of substances, which causes an increased incidence of benign and/or
malignant neoplasms, or a substantial decrease in the latency period between
exposure and onset of neoplasms in humans or in one or more experimental
mammalian species as the result of any oral, respiratory, or dermal
exposure, or any other exposure which results in the induction of tumors at
a site other than the site of administration. This definition also includes
any substance that is metabolized into one or more potential occupational
carcinogens by mammals (29 CFR 1990.103, OSHA Cancer Policy).
PROTECTION FACTORS (See Appendix D):
ASSIGNED PROTECTION FACTOR (APF): The minimum anticipated protection
provided by a properly functioning respirator or class of respirators to
a given percentage of properly fitted and trained users.
SIMULATED WORKPLACE PROTECTION FACTOR (SWPF): A surrogate measure of
the workplace protection provided by a respirator.
WORKPLACE PROTECTION FACTOR (WPF): A measure of the protection
provided in the workplace by a properly functioning respirator when
correctly worn and used.
RECOMMENDED EXPOSURE LIMIT (REL): An 8- or 10-hour time-weighted average
(TWA) or ceiling (C) exposure concentration recommended by NIOSH that is
based on an evaluation of the health effects data.
SERVICE LIFE: The length of time required for an air-purifying element to
reach a specific effluent concentration. Service life is determined by the
type of substance being removed, the concentration of the substance, the
ambient temperature, the specific element being tested (cartridge or
canister), the flow rate resistance, and the selected breakthrough value.
The service life for a self-contained breathing apparatus (SCBA) is the
period of time, as determined by the NIOSH certification tests, in which
adequate breathing gas is supplied.
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SINGLE-USE DUST or DUST AND MIST RESPIRATORS: Respirators approved for
use against dusts or mists that may cause pneumoconiosis and fibrosis.
VAPOR: The gaseous state of a substance that is solid or liquid at
temperatures and pressures normally encountered.
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V. APPENDICES
APPENDIX A. NIOSH POLICY STATEMENT ON APPROVAL OF
AIR-PURIFYING RESPIRATORS WITH END-OF-SERVICE-LIFE INDICATORS
Department of Health and Human Services
Public Health Service
Centers for Disease Control
National Institute for Occupational Safety and Health
NIOSH/MSHA TESTING AND CERTIFICATION OF AIR-PURIFYING RESPIRATORS WITH
END-OF-SERVICE-LIFE INDICATORS
Agency: National Institute for Occupational Safety and Health (NIOSH)
Action: Notice of Acceptance of Applications for Approval of Air-Purifying
Respirators with End-of-Service-life Indicators
Summary: 30 CFR 11; Sec. 11.150 states that NIOSH and MSHA may, after a
review of the effects on wearers' health and safety, approve respirators for
gases and vapors not specifically listed in that section. The current
regulations also permit the use of "window indicators" for gas masks to warn
the wearer when the canister will no longer remove a contaminant
[11,102-5(c)(2)]. Although indicators are not mentioned in Subpart L,
Chemical Cartridge Respirators, there is nothing in the regulations which
explicitly prohibits their use. A NIOSH policy to allow end-of-service-life
indicators (ESLI's) on air-purifying respirators for gases and vapors with
adequate warning properties has already been established (Letter to All
Respirator Manufacturers from Dr. Elliott Harris, June 18, 1975).
Use of ESLI's on chemical cartridge respirators for use against gases and
vapors with poor warning properties could also be approved, because
30 CFR 11; Sec. 11.150; footnote 7 states:
"Not for use against gases or vapors with poor warning properties (except
where MSHA or Occupational 'Safety and Health Administration standards may
permit such use for a specific gas or vapor)...." Thus, air-purifying
respirators with ESLI's could be approved for substances such as
aerylonitri le, because the OSHA aerylonitri le standard permits the use of
chemical cartridge respirators.
Under the present regulations, NIOSH can also require "any additional
requirements deemed necessary to establish the quality, effectiveness, and
safety of any respirator used as protection against hazardous atmospheres"
[30 CFR 11; Sec. 11.63 (c)]. NIOSH must notify the applicants in writing of
these additional requirements [30 CFR 11; Sec. 11.63 (d)].
The purpose of this notification is to inform respirator manufacturers and
users of the NIOSH requirements for approving air-purifying respirators with
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either effective passive or active ESLI's for use against gases and vapors
with adequate warning properties or for use against gases and vapors with
inadequate warning properties whenever there is a regulatory standard
already permitting the use of air-purifying respirators.
For additional information, contact: Chief, Certification Branch,
944 Chestnut Ridge Road, Morgantown, WV 26505, (304) 291-4331.
Supplemental Information
Because human senses are not foolproof in detecting gases and vapors and
because many gases and vapors found in the workplace do not have adequate
warning properties, NIOSH has been investigating alternate means of
detection for respirator wearers. In 1976, NIOSH adopted its current policy
which allows acceptance of applications for certification of air-purifying
respirators, provided that the respirators are equipped with active ESLI's
for use against gases and vapors with poor warning properties and are not
specifically listed in 30 CFR 11.
An active ESLI is defined as an indicator that invokes an automatic and
spontaneous warning signal (e.g., flashing lights, ringing bells, etc.). An
active indicator does not require monitoring by the wearer although a
passive indicator (normally color change indicator) does.
During the past several years, NIOSH has received notices of concern from
respirator manufacturers, regulatory agencies, and general industry
regarding the Institute's policy of accepting only active ESLI's for
certification. At the October 1983 Mine Health Research Advisory Council
(MHRAC) meeting, NIOSH presented a document briefing on "Consideration of
Use of End-of-Service-Life Indicators in Respiratory Protective Devices,"
and requested that MHRAC provide recommendations to the Institute with
regard to the appropriateness of the use of both active and passive ESLI's.
MHRAC asked their Respirator Subcommittee to review the issue.
The Respirator Subcommittee held a public meeting in Washington, D.C., on
December 19, 1983, to solicit comments from interested parties. The
Subcommittee reviewed the comments and then reported back to the full
committee at the February 2, 1984, MHRAC meeting. Based on the public
comments, the Subcommittee also suggested a few additions or modifications
be made to the NIOSH proposed evaluation criteria. NIOSH incorporated the
recommendations. MHRAC also recommended that active and passive ESLI's are
appropriate for use with respiratory protective devices provided that
criteria are established for their certification and use to ensure that the
user is not exposed to increased risk as a consequence of relying upon such
ESLI's.
In order for NIOSH to determine the potential effects of ESLI's on user
safety and health, NIOSH recommends that all applications for approval of
gas and vapor respirators with ESLI's contain the following information:
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CRITERIA FOR CERTIFICATION OF END-OF-SERVICE-LIFE INDICATORS A
An applicant for certification of an ESLI for use against substances with
poor warning properties must provide NIOSH with the following information:
1. Data demonstrating that the ESLI is a reliable indicator of sorbent
depletion (_< 90% of service life). These shall include a
flow-temperature study at low and high temperatures, humidities, and
contaminant concentrations which are representative of actual workplace
conditions where a given respirator will be used. A minimum of two
contaminant levels must be utilized: the exposure limit (PEL, REL, TLV®,
etc.) and the exposure limit multiplied by the assigned protection factor
for the respirator type.
2. Data on desorption of any impregnating agents used in the indicator,
including a flow-temperature study at low and high temperatures and
humidities which are representative of actual workplace conditions where
a given respirator will be used. Data shall be sufficient to demonstrate
safe levels of desorbed agents.
3. Data on the effects of industrial interferences which are commonly
found in workplaces where a given respirator will be used. Data should
be sufficient to show which interferences could impair the effectiveness
of the indicator and the degree of impairment, and which substances will
not affect the indicator.
4. Data on any reaction products produced in the reaction between the |
sorbent and the contaminant gases and vapors, including the
concentrations and toxicities of such products.
5. Data which predict the storage life of the indicator. (Simulated
aging tests will be acceptable).
In addition to the foregoing, all passive ESLI's shall meet the following)
criteria:
1. A passive ESLI shall be placed on the respirator so that the ESLI i;s
visible to the wearer.
2. If the passive indicator utilizes color change, the change shall be
such that it is detectable to people with physical impairments such as
color blindness.
3. If the passive indicator utilizes color change, reference colors for
the initial color of the indicator and the final (end point) color of the
indicator shall be placed adjacent to the indicator.
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All ESLIrs shall meet the following criteria:
1. The ESLI shall not interfere with the effectiveness of the face seal.
2. The ESLI shall not change the weight distribution of the respirator to
the detriment of the facepiece fit.
3. The ESLI shall not interfere with required lines of sight.
4. Any ESLI that is permanently installed in the respirator facepiece
shall be capable of withstanding cleaning and a drop from a height of
6 feet. Replaceable ESLI must be capable of being easily removed and
shall also be capable of withstanding a drop from a height of 6 feet.
5. A respirator with an ESLI shall still meet all other applicable
requirements set forth in 30 CFR 11.
6. If the ESLI uses any electrical components, they shall conform to the
provisions of the National Electrical Code and be "intrinsically safe."
Where permissibility is required, the respirator shall meet the
requirements for permissibility and intrinsic safety set forth in 30
CFR 18, Subpart D. Also, the electrical system shall include an
automatic warning mechanism that indicates a loss of power.
7. Effects of industrial substances interferences which are commonly
found where a given respirator will be used and which hinder ESLI
performance, shall be identified. Substances which are commonly found
where the respirator is to be used must be investigated. Data sufficient
to indicate whether the performance of the respirator would be affected
must be submitted to NIOSH. The user shall be made aware of use
conditions that could cause false positive and negative ESLI responses.
8. The ESLI shall not create any hazard to the wearer's health or safety.
9. Consideration shall be given to the potential impact of common human
physical impairments on the effectiveness of the ESLI.
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APPENDIX B. NIOSH POLICY STATEMENT ON USE OF SINGLE-USE AND DUST
AND MIST RESPIRATORS FOR PROTECTION AGAINST ASBESTOS
June 21, 1984, OSHA Public Hearings
Under Title 30, Code of Federal Regulations, Part 11 (30 CFR 11), NIOSH is
required to test and certify respirators within the categories specified
therein when such devices are submitted to NIOSH by applicants. Currently,
30 CFR' 11, Subpart K defines a number of dust, fume, and mist respirators
which may be used for protection against certain hazardous particulate
atmospheres. Among the respirators defined in Subpart K are single-use dust
respirators designed as respiratory protection against pneumoconiosis-
producing and fibrosis-producing dusts, or dusts and mists. Subpart K lists
asbestos as one of the dusts against which the single-use dust respirator is
designed to protect [Subpart K, Sec. 11.130(H)]. Although at the time of
the promulgation of Subpart K, it may have been assumed appropriate to list
asbestos as a fibrosis-producing particulate against which the single-use
disposable respirator could be reasonably expected to provide adequate
protection, NIOSH is no longer confident that such an assumption is
reasonable because asbestos is also a potent carcinogen.
The current requirements as (specified in 30 CFR 11) for approval of a
single-use dust respirator or dust and mist respirator do not include any
tests with fibrous challenge aerosol. NIOSH is currently in the process of
doing a comprehensive revision of 30 CFR 11 and intends to address the issue
of appropriate respiratory protection for use against asbestos, and to
require that any respirator for which such approval is sought be proven to
provide effective protection against asbestos. NIOSH may change the
regulations included in 30 CFR 11 only in accordance with procedures set
forth in the Administrative Procedures Act. In the interim, NIOSH will
continue to consider applications for approval of single-use and replaceable
dust/mist respirators for use against asbestos only because of the legal
requirement in the current approval regulations. However, NIOSH does not
recommend the use of such respirators where exposures to asbestos may occur
because such a recommendation would not be prudent based on the occupational
health risk.
This policy position is contained in "The Statement of the National
Institute for Occupational Safety and Health—The Public Hearings on
Occupational Exposure to Asbestos."
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APPENDIX C. ODOR WARNING: BACKGROUND INFORMATION
It is important to realize that 30 CFR 11 prohibits the use of MSHA/NIOSH
approved air-purifying (organic vapor) respirators for protection against
organic vapors with poor warning properties unless there is an OSHA standard
that permits such use. Specifically, 30 CFR 11, Section 11.90(b), footnote
4 gives the standards for gas masks (canister devices), while 30 CFR 11,
Section 11.150, footnote 7 gives the standards for chemical cartridge
respirators. Thus the "organic vapor respirator" shall be approved only for
organic vapors with adequate warning properties. In addition, the
requirement for adequate warning properties also applies to all
MSHA/NIOSH-approved air-purifying respirators for protection against organic
gases and vapors.
A recent policy decision by NIOSH allows the use of respirators for
protection against contaminants with poor warning properties, provided that
certain conditions are met. These conditions are outlined in the policy
statement in Appendix A. MSHA/NIOSH approval may be granted for a
respirator designed for use against gases and vapors with poor warning
properties if the respirator incorporates an effective end-of-service-life
indicator (ESLI).
However, unless the respirator incorporates an ESLI, wearers of
air-purifying chemical cartridge/canister respirators must rely on adequate
warning properties to alert them to the breakthrough of the sorbent in the
cartridge or canister. Amoore and Hautala [33] have noted:
The ability of members of the population to detect a given odor is
strongly influenced by the innate variability of different
persons' olfactory powers, their prior experience with that odor,
and by the degree of attention they accord to the matter.
Amoore and Hautala [33] found that on the average, 95% of a population will
have a personal odor threshold that lies within the range from about
one-sixteenth to sixteen times the reported mean "odor threshold" for a
substance. That is, about 2.5% of a population will be able to detect a
substance's odor at concentrations less than one-sixteenth of the "odor
threshold" for a substance. Correspondingly, about 2.5% of the individuals
will need to be exposed to concentrations exceeding by a factor of 16 the
"odor threshold" in order to perceive the odor. Thus for many substances
the width of distribution of personal odor threshold is over two orders of
magnitude of concentration. The "odor thresholds" reported in the
literature generally are the median values for wide population
distributions. Also, 50% of prospective respirator wearers can detect a
substance's odor only at levels that must exceed the reported "odor
threshold," and about 15% cannot detect the odor at levels that exceed the
"odor threshold" by fourfold [33].
OSHA incorporated into the lead standard a new isoamyl acetate qualitative
fit test protocol, developed by Du Pont, which requires odor threshold
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screening [29 CFR 1910.1025, Appendix D (I)(A)]. Du Pont realized that a
qualitative fit test depending on odor recognition would be ineffective if m
every individual were not first screened for the ability to detect the odor ™
of isoamyl acetate at some minimum concentration. This is also true for
detection of the odor of the gas or vapor used to alert the wearer of
sorbent element (cartridge or canister) breakthrough. Thus NIOSH recommends
screening tests for workers who wear air-purifying gas or vapor respirators
to determine their ability to detect the odor below the exposure limit for
that gas or vapor.
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APPENDIX D. PROTECTION FACTOR: BACKGROUND INFORMATION
The U.S. Bureau of Mines referred to the term "Decontamination Factor" in
their Approval Schedule 21B, first issued in 1965, and defined it to be "the
ratio of the concentration of dust, fume, or mist present in the ambient
atmosphere to the concentration of dust, fume, or mist within the facepiece
while the respirator is being worn." The decontamination factor is now
referred to as the respirator protection factor. The original definition
and application given in schedule 21B has been somewhat generalized over the
years.
The protection factor of a respirator is an expression of performance based
on the ratio of two measured variables, C| and CQ- The variable C| is
defined only as the measured concentration of a contaminant inside the
respirator facepiece cavity, and CQ is defined only as the measured
contaminant concentration outside the respirator facepiece. The
relationship between these two variables can be expressed not only as the
protection factor (CQ/C|) but also as the penetration (C|/C0) or
efficiency [(Crj-C| )/Crj] .
The protection factor can be related to the penetration (p) and efficiency
(E) as fol lows:
PF = CQ/CI = 1/p = 1/(1-E)
A further implicit condition on the PF function is that Cj < CQ;
therefore, the PF will always be greater than unity.
Protection factor assessments are made almost exclusively on man/respirator
systems, while penetration and efficiency assessments are made only on
component parts of the respirator system. It is important to recognize that
on a man/respirator system, the measured variable C| becomes a complicated
function of many individual sources of penetration (e.g., air-purifying
element penetration, exhalation valve penetration, face seal penetration,
and other inboard penetration) and those environmental conditions that would
effect penetration. To deal with the multiple methods for determining and
applying protection factors, a number of definitions have been proposed
[13]. These definitions, described below in greater detail than in the
Glossary, are as follows:
ASSIGNED PROTECTION FACTOR (APF): A special application of the general
protection factor concept, APF is defined as a measure of the minimum
anticipated workplace level of respiratory protection that would be provided
by a properly functioning respirator or class of respirators to a percentage
of properly fitted and trained users. The maximum specified use
concentration for a respirator is generally determined by multiplying the
exposure limit for the contaminant by the protection factor assigned to a
specific class of respirators [13].
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SIMULATED WORKPLACE PROTECTION FACTOR (SWPF): A surrogate measure of the
workplace protection factor (WPF) of a respirator, SWPF differs from the WPF
only in that it is measured in a laboratory simulation of a workplace
setting rather than in the actual workplace. The definitions and
restrictions of CQ and C| are as described for the WPF. For laboratory
protection factor testing to reliably estimate WPF's, a relationship must be
demonstrated between the two tests. No such relationship has been
identified in the literature. Until such a relationship can be shown to
exist, the laboratory protection factor is of questionable use in
determining or predicting the WPF [13].
WORKPLACE PROTECTION FACTOR (WPF): A measure of the actual protection
provided in the workplace under the conditions of that workplace by a
properly functioning respirator when correctly worn and used, WPF is defined
as the ratio of the estimated contaminant concentration outside the
respirator facepiece (C^) to the contaminant concentration inside the
respirator facepiece (C|). The sampling restrictions placed on CQ and
C| are that both CQ and C-j should be TWA samples taken simultaneously
while the respirator is being properly worn and used during normal work
activities. In practice, the WPF would be determined by measuring the
concentration inside and outside the facepiece during the activities of a
normal workday [13].
FIT FACTOR: A special application of the protection factor ratio that
represents a quantitative measure of the fit of a particular respirator
facepiece to a particular individual, the fit factor is defined under the
conditions of quantitative fit testing as the aerosol concentration in the
test chamber (CQ) divided by the penetration that occurs through the
respirator face seal interface (Cj) [34]. For C| to reflect only face
seal leakage, high efficiency filters [greater than 99.97% efficient against
0.3 /jm aerodynamic mass median diameter (AMMD) dioctyIphthalate aerosol] are
installed on the respirator. It is assumed that either no leakage or only a
negligible amount of leakage into the facepiece occurs through the
exhalation valve or any source other than the face seal. The fit factor is
measured on a complete respirator worn by a test subject who follows a
regimen of slow head movements, deep breathing, and talking; a polydispersed
oil mist or sodium chloride aerosol is used that has an AMMD of
approximately 0.6 ± 0.1 /^m (with a geometric standard deviation of
approximately 2 to 2.4).
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APPENDIX E. MEDICAL ASPECTS OF WEARING RESPIRATORS: BACKGROUND INFORMATION
In recommending medical evaluation criteria for respirator use, one should
apply rigorous decision-making principles [35], using knowledge of screening
test sensitivity, predictive value, etc. Unfortunately, many gaps in
knowledge in this area exist. The problem is complicated by the large
variety of respirators, their conditions of use, and individual differences
in the physiologic and psychologic responses to them. For these reasons,
the preceding guidelines (see Subparagraph 10) are to be considered as
informed suggestions rather than established NIOSH policy recommendations.
The following information is intended primarily to assist the physician in
developing medical evaluation criteria for respirator use.
Health Effects of Wearing Respirators
Brief descriptions of the health effects associated with wearing respirators
are summarized below. Interested readers are referred to recent reviews for
more detailed analyses of the data [36,37].
Pulmonary: In general, the added inspiratory and expiratory resistances
and dead space of most respirators cause an increased tidal volume and
decreased respiratory rate and ventilation (including a small decrease in
alveolar ventilation). These respirator effects have usually been small
both among healthy individuals and, in limited studies, among individuals
with impaired lung function [38-42]. This generalization is applicable to
most respirators meeting Federal regulations when resistances
(particularly expiratory resistance) are low [1,43,44]. While most
studies report minimal physiologic effects during submaximal exercise, the
resistances commonly lead to reduced endurance and reduced maximal
exercise performance [45-49]. The dead space of a respirator (reflecting
the amount of expired air that must be rebreathed before fresh air is
obtained) tends to cause increased ventilation. At least one study has
shown substantially increased ventilation with a full-face respirator, a
type which can have a large effective dead space [50]. However, the net
effect of a respirator's added resistances and dead space is usually a
small decrease in ventilation [39,45,46-48,51].
The potential for adverse effects, particularly decreased cardiac output,
from the positive pressure feature of some respirators has been reported
[52]. However, several recent studies suggest that this is not a
practical concern, at least not in healthy individuals [53-55].
Theoretically, the increased fluctuations in thoracic pressure while
breathing with a respirator might constitute an increased risk to subjects
with a history of spontaneous pneumothorax. Few data are available in
this area. While an individual is using a negative pressure respirator
with relatively high resistance during very heavy exercise, the usual
maximal peak negative oral pressure during inhalation is about 15-17 cm of
water [53]. Similarly, the usual maximal peak positive oral pressure
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during exhalation is about 15-17 cm of water, which might occur with a
respirator in a positive pressure mode, again during very heavy exercise
[53]. By comparison, maximal positive pressures, such as those during a
vigorous cough, can generate 200 cm of water pressure [56]. The normal
maximal negative pleural pressure at full inspiration is -40 cm of water
[57], and normal subjects can generate -80 to -160 cm of negative water
pressure [56]. Thus while vigorous exercise with a respirator does alter
pleural pressures, the risk of barotrauma would seem to be substantially
less than that of the cough maneuver.
In some asthmatics, an asthmatic attack may be exacerbated or induced by a
variety of factors including exercise, cold air, and stress, all of which
may be associated with wearing a respirator. While most asthmatics who
are able to control their condition should not have problems with
respirators, a physician's judgment and a field trial may be needed in
selected cases.
Cardiac: The added work of breathing from respirators is small and
could not be detected in several studies [38,39]. A typical respirator
might double the work of breathing from 3 to 6% of the oxygen consumption,
but this is probably not of clinical significance [38]. In concordance
with this view is the finding of several studies that at the same
workloads heart rate does not change with the wearing of a respirator
[39,54,58-60].
In contrast, the added cardiac stress due to the weight of a heavy
respirator may be considerable. A self-contained breathing apparatus
(SCBA), particularly one that uses compressed air cylinders, may weigh up
to 35 pounds. Heavier respirators have been shown to reduce maximum
external workloads by 20% and similarly increase heart rate at a given
submaximal workload [46]. In addition, it should be appreciated that many
uses of SCBA (e.g., for firefighting and hazardous waste site work) also
necessitate the wearing of 10-25 pounds of protective clothing.
Raven et al. [40,58] found significantly higher systolic and/or diastolic
blood pressures during exercise for persons wearing respirators (although
increases were minimal, i.e., OO mmHg systolic, 0-2 mmHg diastolic).
Arborelius et al. [54] did not find significant differences for persons
wearing respirators during exercise.
Body Temperature: Proper regulation of body temperature is primarily of
concern with the closed circuit, self-contained breathing apparatus that
produces oxygen via an exothermic chemical reaction. Inspired air within
these respirators may reach 120°F (49°C), thus depriving the wearer of a
minor cooling mechanism and causing discomfort. Obviously this can be
more of a problem with heavy exercise and when ambient conditions and/or
protective clothing further reduce the body's ability to lose heat. The
increase in heart rate due to increasing temperature represents an
additional cardiac stress.
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Closed-circuit breathing units of any type have the potential for heat
stress since warm expired gases (after exothermic carbon dioxide removal
with or without oxygen addition) are rebreathed. Respirators with large
dead space also have this potential problem, again because of partial
rebreathing of warmed expired air [50].
Diminished Senses: Respirators may reduce visual fields, decrease
voice clarity and loudness, and decrease hearing. Besides the potential
for reduced productivity, these effects may result in reduced industrial
safety. These factors may also contribute to a general feeling of stress
[61].
Psychologic: This important topic is discussed in recent reviews by
Morgan [61,62]. There is little doubt that virtually everyone suffers
some discomfort when wearing a respirator. The large variability and the
subjective nature of the psycho-physiologic aspects of wearing a
respirator, however, make studies and specific recommendations
difficult. Fit testing obviously serves an important additional function
in providing a trial to determine if the wearer can psychologically
tolerate the respirator. General experience indicates that the great
majority of workers can tolerate respirators and that experience aids in
this tolerance [62]. However, some individuals are likely to remain
psychologically unfit for wearing respirators.
Local Irritation: Allergic skin reactions may occur occasionally from
wearing a respirator, and skin occlusion may cause irritation or
exacerbation of preexisting conditions such as pseudofol I iculitis
barbae. Facial discomfort from the pressure of the mask may occur,
particularly when the fit is unsatisfactory.
In addition to the health effects associated with wearing respirators
(described above) specific groups of respirator wearers may be affected
by the following factors:
Perforated Tympanic Membrane: While inhalation of toxic materials
through a perforated tympanic membrane (ear drum) is possible, recent
evidence indicates that the airflow would be minimal and rarely if
ever of clinical importance [63,64]. In highly toxic or unknown
atmospheres, use of positive pressure respirators should ensure
adequate protection [63].
Contact Lens: Contact lenses are generally not recommended for use
with respirators, although little documented evidence exists to
support this viewpoint [65]. Several possible reasons for this
recommendation are noted below:
a. Corneal irritation or abrasion might occur with the exposure.
This would, of course, be a problem primarily with quarter- and
half-face masks, especially with particulate exposures. However,
exposures could occur with full-face respirators due to leaks or
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inadvisable removal of the respirator for any reason. While A
corneal irritation or abrasion might also occur without contact m
lenses, their presence is known to substantially increase this risk. ^
b. The loss or misplacement of a contact lens by an individual
wearing a respirator might prompt the wearer to remove the
respirator, thereby resulting in exposure to the hazard as well as
to the potential problems noted in "a." above.
c. The constant airflow of some respirators, such as powered
air-purifying respirators (PAPR) or continuous flow air-line
respirators, might irritate a contact lens wearer.
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SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
PARTS
RESPIRATORY PROTECTION PROGRAM GUIDELINES
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TABLE OP CONTENTS
Pa
1. PURPOSE AND OBJECTIVE 1
2. BACKGROUND I
3. DEFINITIONS 1
4. THE RESPIRATORY PROTECTION PROGRAM 3
5. ESTABLISHMENT OF THE RESPIRATORY PROTECTION PROGRAM 3
6. SELECTION OF RESPIRATORY PROTECTIVE DEVICES 4
Identification of the Hazard 4
Evaluation of the Hazard 7
Approved Respiratory Protective Devices 8
7. RESPIRATOR USE 14
Employee Responsibilities 14
Supervision of Respirator Use 15
Respirator Use Under Special Conditions 15
Special Problems In Respirator Use 17
8. TRAINING AND FITTING 18
Training 18
Fitting 20
9. RESPIRATORY PROTECTIVE DEVICE INSPECTION, CLEANING,
"MAINTENANCE AND STORAGE 24
Inspection of Respiratory Protective Devices 24
Cleaning and disinfecting 27
Maintenance 28
Storage 28
10. MEDICAL ASPECTS OF RESPIRATORY EQUIPMENT USAGE 29
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TABLE OF CONTENTS (Continued)
Page
11. EVALUATION OF THE RESPIRATORY PROTECTION PROGRAM 30
Surveillance of the Work Area 30
Program Evaluation 30
REFERENCES 33
APPENDIX
A. Respiratory Protection Device Recommendation Form 34
B. Model Standard Operating Procedure, Respirator Use,
High Hazard Areas 36
C. Employee Training Program 38
D. Respirator Protection Factors 4.3
E. Checklist for Inspection of Pressure Demand SCBA ........ 46
F. Duty Status Report 51
THIS DOCUMENT HAS NOT BEEN PEER AND ADMINISTRATIVELY REVIEWED WITHIN EPA
AND IS FOR INTERNAL AGENCY USE/DISTRIBUTION ONLY.
ii
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RESPIRATORY PROTECTION PROGRAM GUIDELINE
1. PURPOSE AND OBJECTIVE. The purpose and objective of this guideline are
to provide management personnel with sufficient information to establish and
operate a respiratory protection program to adequately protect its employees
as required by EPA Order 1440.3, Respiratory Protection, and by the Occupa-
tional Safety and Health Administration (OSHA) Regulations 29 CFR 1910.134.
2. BACKGROUND. OSHA has set maximum exposure standards for many airborne
toxic materials. If employee exposure to these substances exceeds the
standards, the regulations requires that feasible engineering controls and/
or administrative controls be installed or instituted to reduce employee
exposure to acceptable levels. If these controls do not prove feasible,
or while they are being installed/instituted, the Agency is required to
provide appropriate, approved respiratory protection for its employees.
Respirators are the least acceptable means for reducing personnel exposures;
they only provide good protection If properly selected and fitted, worn by
employees when needed, and replaced when their service life is over. Addi-
tionally, some employees may not be able to wear a respiratory protective
device. Despite these difficulties, respiratory protective devices are the
only means of protection available to employees when engineering and work
practice controls are not feasible or inadequate, i.e., during field
operations.
3. DEFINITIONS.
a. Approved. Approved means that a respiratory protective device
has been tested and listed as satisfactory by the Bureau of
Mines (BOM) of the U.S. Department.of Interior, or jointly by the
Mine Safety and Health Administration (MSHA) of the U.S. Depart-
ment of Labor and the National Institute for Occupational Safety
and Health (N-IOSH) of the U.S. Department of Health and Human
Services.
b. Canister (air-purifying) . An air-purifying canister is a container
with a filter, and/or sorbent, and/or catalyst which removes specific
contaminants from the air drawn through it.
c.' Canister (oxygen-generating). An oxygen-generating canister is a
container filled with a chemical which generates oxygen by chemical
reaction.
d. Ceiling concentration. The ceiling concentration means the concen-
tration of an airborne substance that shall not be exceeded.
e. Confined spac_e. A confined space is a space defined by the con-
current existence of the following conditions:
Existing ventilation is insufficient to remove dangerous air
contamination and/or oxygen deficiency which may exist or develop.
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2.
Ready access or egress for the removal of a suddenly disabled
employee Is difficult due to the location and/or size of the
opening(s).
f. Contaminant. A contaminant is a harmful, irritating, or nuisance ™
material that is foreign to the normal atmosphere.
g. Corrective lens. A corrective lens is a lens ground to the wearer's
individual corrective prescription to permit normal visual acuity.
h. Emergency respirator use. Emergency respirator use means wearing a
respirator when a hazardous atmosphere suddenly occurs which requires
immediate use of a respirator either for escape only from the hazard-
ous atmosphere or for entry into the hazardous atmosphere to
carry out maintenance or some other task or for rescue purposes.
i. Hazardous atmosphere. A hazardous atmosphere is any atmosphere,
either immediately or not immediately dangerous to life or health,
which is either oxygen deficient or which contains a toxic or disease-
producing contaminant exceeding the legally established permissible
exposure limit (PEL), or where applicable, the Threshold Limit
Value (TLV) established by the American Conference of Governmental
Industrial Hygienists (ACGIH).
j. Immediately dangerous to life or health. Immediately dangerous
to life or health refers to any atmosphere that poses an immediate
hazard to life or produces immediate irreversible effects on health
that will be debilitating.
k. Not immediately dangerous to life or health. Not immediately dan-
gerous to life or health refers to any hazardous atmosphere which
may produce physical discomfort immediately, chronic poisoning
after repeated exposure, or acute adverse physiological symptoms
after prolonged exposure.
1. Odor threshold limit. The lowest concentration of a contaminant in
air that can be detected by the olfactory sense.
m. Permissible exposure limit (PEL). Permissible exposure limit is the
legally established time-weighted average (TWA) concentration or
ceiling concentration of a contaminant that shall not be exceeded.
n. protection factor. Protection factor is the ratio of the ambient
concentration of an airborne substance to the concentration of the
substance inside the respirator at the breathing zone of the wearer.
The protection factor is a measure of the degree of protection
provided to the wearer.
o. Time-weigh ted average (TWA)_. Time-weighted average is the average
concentration of a contaminant in air during a specific time period.
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3.
4. THE RESPIRATORY PROTECTION PROGRAM. EPA Order 1440.3, Respiratory
Protection, sets out the Agency policy, responsibilities, and basic require-
ments for a respiratory protection program to protect its employees whose
Jobs require the use of respiratory protective devices. EPA management is
required to establish and implement a respiratory protection program at
each Agency location where the activities of employees may cause them to
encounter atmospheres that contain or are suspected of containing unhealthy
quantities of airborne contaminants or atmospheres with insufficient oxygen
content, or where there is the threat of an imminent release of toxic
agents. Respiratory protection may also be necessary for routine but in-
frequent operations and for non-routine operations in which the employee
is exposed briefly to high concentrations of a hazardous substance, i.e.,
during maintenance or repair activities, or during emergency conditions.
As a minimum, a respiratory protection program must contain all the elements
outlined in EPA Order 1440.3. These requirements are:
a. Approved respiratory protective devices must be properly selected.
b. There must be a determination of the need for respiratory protective
devices.
c. An employee training program must be established in which the
employee becomes familiar with the respiratory protective devices
and is trained in the proper selection and use of respirators and
their limitations.
d. There must be provisions for:
Proper inspection, maintenance, storage and repair of respiratory
protective devices.
Assigning respiratory protective equipment to employees for
their exclusive use, where practical.
Testing for the proper fit of the respiratory protective
equipment.
Surveillance of the work area and for employee exposure and stress.
Medical screening of each employee assigned to wear respiratory
protective devices to determine if he/she is physically and•
psychologically able to wear a respirator.
e. Written standard operating procedures must exist for the selection
and use of respiratory protective devices.
5. ESTABLISHMENT OF THE RESPIRATORY PROTECTION PROGRAM. Management at each
EPA location where it has been determined a Respiratory Protection Program is
required should designate one person responsible for administering the pro-
gram at that location. This person should have the responsibility for the
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4.
entire respirator program and develop the standard operating procedures.
To administer effectively the respiratory protection program, the designated
person must have: A
a. Sufficient training in all aspects of respiratory protection to
adequately manage the program.
b. The ability to make sound Judgments based on hazard evaluation and
an understanding of the workplace hazards.
c. The knowledge and authority to coordinate equipment purchasing,
maintenance, cleaning and repair.
d. The knowledge and authority to assure that written operating
procedures are prepared for specific operations and that these
procedures are being followed.
e. The knowledge and authority to assure compliance with OSHA
and Agency respiratory protection requirements.
f. The resources to maintain all records associated with the program,
i.e., monitoring, medical surveillance and job assignment data,
respirator care and maintenance records, emergency equipment
inspection/maintenance tags, training records, etc.
The individual assigned the respiratory program responsibility may be a
safety specialist/manager, safety engineer, industrial hygienist, or super-
visory person. This individual must have the full support of management |
at the workplace regardless of who assumes the program responsibility.
6. SELECTION OF RESPIRATORY PROTECTIVE DEVICES. The proper selection of
respiratory protective devices basically involves three steps:
a. Identification of the hazard.
b. Evaluation of the hazard.
c. The selection of the appropriate approved respiratory protective
device based on the first two considerations. (See Appendix A,
Respiratory Protective Device Recommendation.)
Respiratory protective devices that will provide greater protection than
required may be selected, but the device selected must always be approved.
a. Identification of the Hazard. It is important to know something
about the different kinds of hazardous atmospheres which may require the
use of respirators.
o Contaminated Atmospheres
Gaseous Contaminants - These contaminants are of two types.
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5.
Gases are aeriform fluids which are in the gaseous state at
ordinary temperature and pressure., e.g., carbon dioxide. Such substances
are solids or liquids only at much lower temperatures or much higher pressures
than are commonly found in the work environment. Carbon dioxide, is a gas at
rooon temperature, but it occurs as solid "dry ice" at low temperature, or
as a liquid in pressurized tanks.
Vapors are the gaseous state of a substance that is solid or
liquid at ordinary temperature and pressure. Vapors are formed by the
evaporation of substances, i.e., acetone or trichloroethylene, which
ordinarily occur as liquid.
Participate Contaminants - Particulate contaminants are suspended
particles or droplets of a substance. Many of these particles can remain
suspended in air indefinitely and are easily inhaled. There are three types
of particulates:
Dusts are solid particles produced by such processes as grinding,
crushing, and mixing of powder compounds.
Mists are tiny liquid droplets dispersed whenever a liquid is
sprayed, vigorously mixed, or otherwise agitated.
Fumes are solid condensation particles of extremely small
particle size.
. Combination Contaminants - The two basic forms of contaminated
atmospheres - gaseous and particulate - frequently occur together.
o Oxygen Deficient Atmospheres - In an oxygen deficient atmosphere,
the problem 'is not the presence of something harmful, but the absence of
something essential. These atmospheres are most coomonly found in confined
and usually poorly ventilated spaces. Oxygen deficient atmospheres are
classified as either immediately dangerous to life or health or not immediately
dangerous to life or health depending on the oxygen concentration in the
atmosphere. (An oxygen deficient atmosphere immediately dangerous to life and
health is an atmosphere that contains less than L6 volume percent of oxygen
in the atmosphere at sea level. An oxygen deficient atmosphere not immediately
dangerous to life and health is an atmosphere having an oxygen concentration
between 16 and 19.5 volume percent of oxygen in the atmosphere at sea level.)
Oxygen deficient atmospheres occur in two different ways: (1) Oxygen may
be "used up" by a chemical reaction, and (2) Oxygen is displaced by another gas.
There is no definition of oxygen deficient atmosphere that has been universally
accepted. OSHA has adopted and EPA accepts an oxygen deficient atmosphere as
one that contains less than 19.5 volume percent of oxygen in the atmosphere at
sea level. The following table is a partial listing of definitions of oxygen
deficient atmospheres, their source and conditions of determination.
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6.
Definitions of Oxygen Deficient Atmospheres
Source
ACGIH Threshold Limit Values
for 1973
Federal Regulations
29 CFR Part 1915.SI
(Maritime Standards)
29 CFR Part 1910.94
(Ventilation Standards)
(Respirator Approval Tests)
ANSI Standards Z88.2-1969
(Respirator Practices)
ANSI Standards Z88.2-1980
(Practices for Respiratory
Protection)
Z88.5-1973
(Firefighting)
K13.1-1973
(Marketing of air-purifying
canisters and cartridges)
Oxygen
Content
(Vol.7.)
18.0
16.5
19.5
19.5
16.0
19.8
19.5
19.5
Conditions for Determination
". . . under normal atmosphere
pressure. . . ."
(not specified)
(not specified)
". . . by volume at sea level.
". . . normal air. ..."
". . . normal air. . . ."
". . .at sea level. . . ."
". . .at sea level. . . ."
It is difficult to visualize the effect of oxygen deficient atmospheres on
the individual. He/she is not aware of the nature of their situation.
Gradual depression of the central nervous system affects powers of discrimi-
nation, logic, and auditory acuity, with muscular weakness and lack of
coordination. Since no distressful sensations are produced, the entire
experience is comfortable and even pleasant. In reality, however, breathing
in an oxygen deficient atmosphere is like breathing under water. The
symptoms of oxygen deficiency also depend on the oxygen concentration pre-
sent. The following table presents the physiological effects of atmospheres
at and below 16 volume percent of the oxygen at sea level.
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7.
Effects of Oxygen Deficiency
02 VoL %
at Sea Level Physiological Effect
16-12 Increased breathing volume.
Accelerated heartbeat.
Impaired attention and thinking.
Impaired coordination.
14-10 Very faulty judgment.
Very poor muscular coordination.
Muscular exertion causes rapid fatigue that may
cause permanent heart damage.
Intermittent respiration.
10-6 Nausea.
Vomiting.
Inability to perform vigorous movement, or loss
of all movement.
Unconsciousness, followed by death.
Less than 6 Spasmatic breathing.
Convulsive movements.
Death in minutes.
b. Evaluation of the Hazard. The person who evaluates respiratory
hazards must have the cooperation of others in obtaining information on the
work area, work activities and materials to properly evaluate and determine
the appropriate respiratory protective device that will provide the best
protection for the employee. Consideration of these questions will help in
the selection of the correct equipment.
1) Does the atmosphere oxygen level meet standards? Is the atmos-
phere oxygen level expected to remain constant or decrease?
2) What is the contaminant? la it a gas, vapor, mist, dust, or fume?
. i) What is the estimated concentration of the contaminant? Have
measurements been taken?
4) Could the contaminant be considered immediately dangerous to
life or health?
5) Is the contaminant flammable? Does the concentration approach
the lower explosive limit? Do dust concentrations create a potential
explosion problem?
6) Does the contaminant have adequate warning properties, e.g.,
smell, irritation?
7) Will the contaminant irritate the eyes at the estimated concen-
tration? Is eye protection also needed?
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8.
8) What type(s) of respirators will provide the required degree
of employee protection?
9) Is the recognized contaminant the only contaminant present?
10) If the contaminant is a gas or vapor, is there an effective
sorbent for the respirator cannister?
11) Can the contaminant be absorbed through the skin? If it can, will
it result in a serious injury?
c. Selection of Approved Respiratory Protective Devices. The person
designated as the respiratory protection program manager should have an
approval authority for the purchase of respiratory protective devices. Any
respiratory protective devices purchased should be approved for the parti-
cular contaminants for which they will be used. If only one brand of
respirator is approved for a particular hazard, then that brand is considered
to be "available" and must be used. The NIOSH approval on a respirator has
the following information:
o An assigned identification number placed on each unit.
o A label identifying the type of hazard for which the respirator is
approved.
o Additional information on the label which gives limitations and
identifies the component parts approved for use with the basic unit.
In the past, the BOM approved respirators. The BOM no longer grants
approval; however, some older respirators which were BOM-approved may
still be used.
o BCM-approved self-contained breathing apparatus (SCBA) may be used
until further notice.
o BOM-approved gas masks may be used until further notice.
d. Categories of Respiratory Protective Devices. Respiratory protective
devices fall into two broad categories - air purifying and atmosphere
supplying.
1) Air-purifying respirators - These devices remove the contaminant
from the breathing air before it is inhaled. For each model of air-purifying
respirator, there are usually many air-purifying cartridges available for
protection against specific contaminants. Combination cartridges for pro-
tection against both particulates and organic vapors are also available.
o Particulate removing filter respirators - These are generally
called "dust," "mist," or "fume" respirators and by a filtering action remove
particulates before they can be inhaled.
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9.
. Single use, dust - The single-use respirator is a respirator
which is completely disposed of after use. They are for individual use
and should be discarded when resistance becomes excessive or the respirator
is damaged. Generally these respirators are approved only for pneumoconiosis
or fibrosis producing dust such aa coal dust, silica dust, and asbestos.
Quarter-mask, dust and mist; half-mask, dust and mist - The
quarter-mask covers the mouth and nose; the half-mask fits over the nose
and under the chin. The half-mask usually produces a better facepiece to
face seal than does the quarter-mask and is therefore preferred for use
against more toxic materials. Dust and mist respirators are approved for
protection against dusts and mists whose TLV is^greater than 0.05 milligram
particulate matter per cubic meter of air (mg/MJ).
Quarter-mask, fume; half-mask, fume - These masks, similar
to the quarter-mask dust and mist; half-mask dust and mist, utilize a filter
element which can remove metal fumes in addition to dusts and mists from
the inhaled air. The filters are approved for metal fumes having a TLV
above 0.05 mg/M3.
Half-mask, high efficiency - These masks are the same as the
units mentioned in the two previous paragraphs above, but use a high efficiency
filter. Because of this high efficiency filter, they can be used against dusts,
mists, fumes, and combinations of those whose TLV is less than 0.05 mg/M .
Full facepiece - Full facepiece respirators cover the face
frcra the hairline to below the chin. In addition to providing more pro-
tection to the face and also a measure of eye protection, the full-face-
piece gives a better seal than the half- or quarter-masks. The protection
these respirators provide against dusts, mists, fumes, or any combination
of these contaminants depends upon the type of filter used.
Powered air-purifying respirators - These respirators use
a blower that passes the contaminated air through the cartridge or canister
where the contaminant is removed and passes the purified air into the face-
piece. The air purifying element can be a filter to remove particulates,
a cartridge or canister to remove gases or vapors, or a combination to
remove both. The face covering can be a half-mask, full-face mask, or
hood or helnet. The advantage to using a powered air-purifying respirator
is that it supplies air at a positive pressure within the facepiece, hood
or helmet, so that any leakage is outward.
The protection provided depends on the air-purifying element and the type
and concentration of the contaminants. Powered air-purifying respirators
must deliver at least 4 cubic feet per minute (CFM) to a tight fitting
facepiece such as a mask and at least 7 cfm to a loose fitting helmet or
hood. If the powered air-purifying respirator is battery operated, it
should provide the airflows mentioned for at least 4 hours without having
to recharge the battery.
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10.
o Limitations - air purifying respirators for participates -
. Air-purifying respirators do not provide oxygen, so they
must never be worn in oxygen deficient atmospheres.
Air-purifying respirators for particulates offer no protection
against atmospheres containing contaminant gases or vapors.
.. These respirators are not NIOSH approved for abrasive blasting
operations and should not be used.
o Problems - air purifying respirators for particulates -
The air flow resistance of a particulate-removing respirator
filter element increases as the quantity of particles it retains increases,
thus increasing the breathing resistance. As a rule of thumb, when comfortable
breathing is impaired because of dust build-up, the filter should be replaced.
The performance of some filter materials is affected by open
storage in very humid atmospheres. Care should be taken in storing filter
elements.
o Chemical Cartridge and Canister Respirators, Gas and Vapors -
Vapor and gas-removing respirators use cartridges or canisters containing
chemicals to trap or react with specific vapors and gases and remove them
from the air breathed. The basic difference between a cartridge and a
canister is the volume of the sorbent. Generally, a "cartridge" refers to a
chemical adsorbing element which attaches directly to the facepiece, whereas
a "canister" refers to the chemical adsorbing_element held in a harness and
which is connected to the facepiece via a corrugated breathing tube. Some
of the typical chemical cartridge or canister respirators are:
Half-mask and quarter-mask respirators - These are available
for protection against single chemicals such as ammonia or against entire
classes such as organic vapors. Be sure to read the label on the cartridge
or canister since it tells what the cartridge or canister protects against,
what the maximum concentration is for which the element can be used, and
in some instances, the service life or expiration date of the element.
. Full facepiece - The full facepiece respirator may use a canister
or cartridge(s) as the protective element. The front, back, and chin-mounted
full-facepiece canister respirators are also referred to as "gas masks."
o Limitations - chemical cartridge or canister, gas and vapor -
These respirators do not supply oxygen, so they must never be
worn in oxygen deficient atmospheres.
They must not be used if the hazardous chemical lacks adequate
warning properties - odor, taste, or irritation, unless their use is permitted
by applicable OSHA or MSHA standards. These warning properties are necessary
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11.
to alert the user that the aorbent is saturated and that the contaminant
is passing through the cartridge or canister into the respiratory tract.
They must not be used in atmospheres immediately dangerous
to life or health, except for escape.
They are intended for use only for the specific gases or vapors
for which they were tested and approved. (They may be worthless for other
gases or vapors.)
2) Atmosphere Supplying Respirators - Atmosphere supplying respirators,
rather than removing the hazardous material from the air, exclude the workplace
air altogether and provide clean air from an independent source. There are
two kinds of atmosphere supplying respirators: (1) A supplied-air respirator
in which the user is supplied with respirable air through a hose and (2) A
self-contained respirator in which the user carries a supply of respirable
air.
o Supplied-air respirator - Supplied-air respirators use a central
source of breathing air that is delivered to the wearer through an air supply
line or hose.
. Airline respirator devices - Airline respirator devices use
a stationary source of compressed air delivered through a high-pressure hose.
Airline respirator devices can be equipped with a half- or full-facepiece
masks, helmets, or hoods, or the device can come as a complete suit. Air-
line respirators can be used for protection against either particulates,
gases, or vapors. They provide a high degree of protection against these
contaminants but they cannot be used in atmospheres immediately dangerous to
life or health because the user is completely dependent on the integrity of
the air supply hose and the air source. If something were to happen to
either the hose or air supply, the user could not escape from the contaminated
area without endangering his/her life, since the user is not guaranteed a.
supply of breathing air for escape. A great advantage of the airline respirator
is that it can be used for long continuous periods. There are three types of
airline respirators.
Demand Airline Respirator Devices - In a demand device,
the air enters the facepiece only on demand of the user, i.e., when the user
inhales. This is due to the nature of the valve and pressure regulator.
During inhalation there is a negative pressure in the mask, so if there is
leakage, contaminated air may enter the mask and be breathed by the user.
The leakage problem is a major drawback of the demand device. Full face
masks provide a better seal than the half-mask against leakage.
Pressure Demand Airline Devices - The pressure demand
device has a regulator and valve design such that there is a continuous
flow of air into the facepiece at all times. The air flow into the mask
creates a positive pressure in the mask, therefore, there is no problem of
contaminant leakage into the facepiece. This is the significant advantage
of this type of device.
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12.
Continuous-flow Airline Devices - The continuous-flow
airline respirator maintains a constant airflow at all times and does
not use a regulator. Instead an airflow control valve or orifice regulates
the flow of air. The continuous-flow device creates a positive pressure
in the facepiece. There is no problem of inward leakage of contaminant.
o Air Supply System - Supply air sources (compressor or tanks)
for the supplied-air respirators must meet the following requirements.
The air compressor must be located where contaminated air
cannot enter the system.
The air receiver must be of sufficient capacity to enable
the wearer to escape in the event of compressor failure.
The system must have alarms to indicate compressor failure
or overheating.
If the compressor is oil-lubricated it must have a high
temperature and/or carbon monoxide (CO) alarm. If there is no CO alarm,
frequent carbon monoxide tests of the air must be made to insure that the
CO level does not exceed 20 parts per million.
All airline couplings must be incompatible with outlets for
other gas systems.
Breathing air quality must meet the requirements of Grade D
breathing air as described by the Compressed Gas Association. Grade D
requirements are:
The oxygen content of the compressed air should be between
19.5 - 23.5 percent oxygen and the remainder mainly nitrogen;
Hydrocarbon concentrations must not exceed 5 parts per
million;
Carbon monoxide concentration must not exceed 20 parts
per million;
Carbon dioxide concentrations must not exceed 1000 parts
per million; and
There must not be any pronounced odor.
.o Limitations - Supplied-air respirators -
These devices must not be used in atmospheres immediately
dangerous to life or health since the user is dependent upon an air hose
which, if cut, crushed, or damaged, leaves him/her with little or no pro-
tection.
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13.
The trailing air supply hose of the airline respirator
severely restricts the wearer's mobility. This makes the airline respirator
unsuitable for the user who must move frequently between work stations that
are separated or cover a large area, i.e., during field work.
o Self-Contained Breathing Apparatus (SCBA). The self-contained
breathing apparatus (SCBA) allows the user to carry a respirable breathing
supply with him/her, and does not,need a stationary air source such as a
compressor to provide breathable air. The air supply may last from 3 minutes
to 4 hours depending on the device.
. Closed Circuit SCSA - In a closed circuit SCBA the air is
rebreached after the exhaled carbon dioxide has been removed and the oxygen
content restored by a compressed oxygen source or an oxygen-generating solid.
These devices are designed primarily for 1-4 hour use in toxic atmospheres.
Because negative pressure is created in the facepiece during inhalation,
there is increased leakage potential. Therefore, the devices should be
used in atmospheres immediately hazardous to life and health only when long-
duration use of an SCBA is indicated, i.e., in mine rescue. Two types of
closed circuit SCBA are available.
Compressed Oxygen Cylinder Type - In this device, breath-
able air is supplied from an inflatable bag. Exhaled air from the user
goes through an adsorber to remove carbon dioxide, and the oxygen consumed is
replenished from an oxygen cylinder.
Oxygen-generating Type - This type of SCBA uses an oxygen-
generating solid which reacts with water vapor and carbon dioxide from the
exhaled breath, to release oxygen. The oxygen then passes to the inflatable
bag. This device is lighter, simpler, and less expensive than the cylinder
type. However, it is useful for only about 1 hour and, once initiated,
cannot be turned off.
Open Circuit SCBA - An open circuit SCBA. exhausts the exhaled
air to the atmosphere instead of recirculating it. A tank of compressed
air carried on the user supplies air via a regulator to the facepiece.
Because there is no recirculation of air, the service life of the open
circuit SCBA is shorter than a closed circuit device. Two types of open
circuit SCBA's are available.
Demand SCBA - In a demand SCBA, air flows into the face-
piece only on the demand of the user, i.e., when the user inhales. This is
due to the nature of the valves and pressure regulator. During inhalation
there is a negative pressure in the mask, so if there is leakage, contaminated
air can enter the mask and be breathed by the user. The leakage problem is a
major drawback of the demand device. Because of this problem, a demand type
open circuit SCBA should not be used in atmospheres immediately dangerous to
life or health.
Pressure Demand SCBA - The pressure demand open circuit
SCBA has a regulator and valve design which maintains a positive pressure
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in the facepi.ece at all times regardless of the demand of the user. Because
of this, there is no problem of contaminant leakage into the facepiece.
This is a significant advantage of the pressure demand device. The use
time of this device, though, may be reduced considerably by air leakage
outvard from the facepiece.
o Combination Atmosphere Supplying Respirator - Supplied Air and
SCBA - Designed primarily as a long duration device, this respirator combines
an airline respirator with an auxiliary air supply (usually compressed air)
to protect against the possible failure of the primary air supply (the air-
line) . The additional supply can be approved for 15 minutes or even longer.
The choice depends upon how long it would take to escape from the toxic
atccsphere if the primary air supply failed. This modification, therefore,
allows these devices to be used in atmospheres immediately dangerous to life
and health.
o Limitations of atmosphere supplying respirators -
The air supply is limited to the amount in the cylinder (SCBA's
using a compressed air tank) and therefore the respirator cannot be used for
extended periods without recharging or replacing the cylinders.
Because these respirators are bulky and heavy, they are often
unsuitable for strenuous work or use in confined spaces.
Because of the short service time of the auxiliary air supply,
the escape portion of the combination unit can be used only for escape from
atmospheres immediately hazardous to life or health unless the escape portion
has a minimum of 15 minutes service life. Such devices can then be used
for entry into immediately dangerous to life or health atmospheres provided
not more than 20 percent of the available breathing supply is used. These
devices may always be used for entry into immediately dangerous to life or
health atmospheres when utilized with the external air supply.
Because the outward air leakage from the facepiece of the
pressure demand device can cause loss of air the use time may be shortened
7. RESPIRATOR USE. All employees required to wear respiratory protective
devices should, if practical, be assigned their protective equipment for
their exclusive use. A system should be established to facilitate the account
ing of users and of the equipment. When a respirator is assigned to a user
it should be permanently marked to indicate to whom it is assigned. The
marking must be done in such a way that it does not hurt the respirator per-
formance. Records should indicate the date of initial issue, the dates of
reissue, and a listing of repairs.
a. Employee Responsibilities. As a respiratory protective device user,
employees have these responsibilities:
1) Use respiratory protective equipment as instructed.
2) Guard against damaging the respirator.
3) Go immediately to an area of "clean" air if the respirator
malfunctions.
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4) Report any malfunctioning of respiratory protective devices
to their supervisor. These malfunctions would include but not be limited
to:
Discomfort;
Resistance to breathing;
Fatigue due to respirator usage;
Interference with vision or communication;
Restriction of movement.
b. Supervision of Respirator Use. Respirators in use must be randomly
inspected at frequent intervals to ensure that those selected for the job
are being used and that they are in good condition. This periodic monitoring
should include:
1) A determination that the proper respirators are being used.
2) Determination that respirators are being worn properly.
3) Consultation with users about:
Discomfort
Resistance to breathing
. Fatigue
Interference with vision
Interference with communications
Restriction of movement
Interference with job performance
Confidence in the respirator
If problems are discovered during the randooi inspection, they should be
rectified.
c. Respirator Use Under Special Conditions. There are several conditions
where the use of respiratory protective devices require special preparations.
1) Dangerous Atmospheres - If respiratory protective devices are to
be used in atmospheres immediately dangerous to life or health, a standard
operating procedure for work in high hazard areas must be written. (See
Appendix B, Model Standard Operating Procedure, Respirator Use, High Hazard
Areas.) The standard operating procedure must as a minimum cover the following
points.
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Individuals designated to enter Into dangerous atmospheres
must have training with the proper equipment. These individuals must be
equipped with safety harnesses and safety lines so that they can be removed
from the atmosphere if necessary. ^
Designation and provision of a standby individual, equipped ^
with proper rescue equipment, who must be present in a nearby safe area
for possible emergency rescue.
Provision for communication between persons in the dangerous
atmosphere and the standby person must be made. Communication may be visual
or by voice, signal line, telephone, radio, or other suitable means.
Other important data such as toxicological information and emergency phone
numbers should be included.
2) Confined Spaces - Confined spaces are defined as enclosures
where the existing ventilation is insufficient to remove dangerous air
contamination and/or oxygen deficiency which may exist or develop and ready
access or egress for the removal of a suddenly disabled employee Is difficult
due to the location and/or size of the opening(s). These special precautions
must be taken:
Before entering a confined space, tests should be made to
determine the presence and concentration of any flammable gas, toxic air-
borne particulate, vapor, gas, and oxygen concentration.
If the concentration of a flammable substance exceeds 25 per-
cent of the lower explosive limit, the confined space must be force ventilated j
to keep the concentration well below the lower explosive limit. The concen- "
tration of contaminant or oxygen percent should be continuously monitored
while individuals are working in the confined space.
Only Individuals specially trained should be allowed to enter
confined spaces and the proper respiratory protective devices must be worn.
.. Air-purifying respirators and airline type supplled-air
respirators may be worn in a confined space only if the tests show that the
atmosphere contains adequate oxygen and that air contaminants are well below
levels immediately dangerous to life or health. While employees wearing
these types of respirators are in a confined space, the atmosphere must be
monitored continuously.
If the atmosphere in a confined space is immediately
dangerous to life or health due to a high concentration of air contaminant or
oxygen deficiency, employees entering the space must wear a positive pressure
SCBA or a combination airline and a positive pressure SCBA..
A standby individual with proper rescue equipment, including
an SCBA, must be present outside the confined space for possible emergency
rescue. Communication must be maintained via voice, signal line, telephone,
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etc., between employees in the confined space and the standby person. The
employee inside the confined space must be equipped with safety harnesses and
safety lines to allow removal in case of an emergency.
3) Low and High Temperatures - The use of respiratory protective
devices in low temperatures can create several problems. The lenses of the
full facepiece equipment may fog due to condensation of the water vapor in
the exhaled breath. (Coating the inner surface of the lens with an anti-
fogging compound will reduce fogging. Nose cups that direct the warm, moist
exhaled air through the exhalation valve without touching the lens are
available from manufacturers for insertion into the full facepiece.) The
exhalation valve can freeze onto the valve seat due to the moisture in the
exhaled air. The user will be aware when this situation occurs by the
increased pressure in the facepiece. (When unsticking the valve, care
should be taken so as not to tear the rubber diaphragm.)
Respirator usage in hot environments can put additional stress on the user.
The stress can be minimized by using a light-weight respirator with low
breathing resistance. An airline type atmosphere-supplying respirator
equipped with a vortex tube can be used. The vortex tube may either cool
or warm the supplied air (depending on the connection and setting). This
protection scheme can be used in both hot and cold environments.
d. Special Problems in Respirator Use
1) Facial Hair - Facial hair lying between the sealing surface of
a respirator facepiece and the wearer's skin will prevent a good seal. If
the respirator permits negative air pressure inside the facepiece during
inhalation, there will be excessive penetration by an air contaminant. Even
a few days growth of stubble will permit excessive contaminant penetration.
Any employee who has stubble, a moustache, sideburns, or a beard that
passes between his face and the sealing surface must not wear a respirator
that allows negative pressure inside the facepiece during inhalation.
2) Corrective Lenses - Spectacle temple bars or straps that pass
between the sealing surface of a full facepiece and the wearer's face
prevent a good seal. Therefore, spectacles that have temple bars or straps
must not be used when a full-facepiece respirator must be worn. Spectacles
with short temple bars that do not protrude between the sealing surface and
the user's face, or spectacles without temple bars which-are taped to the
wearer's face may be used temporarily. Special corrective lenses that can
be mounted inside the full facepiece are available and should be used by
employees who need them. The special corrective lenses must be mounted
in the full facepiece by a qualified person to ensure good vision, comfort,
and proper sealing of the facepiece. Spectacles or goggles may also
interfere with quarter- or half-masks. They must be worn so as not to
interfere with the seal of the facepiece. If there is interference, a full
facepiece respirator should be worn to avoid sealing problems.
Contact lenses must not be worn while wearing a respirator in a contaminated
atmosphere. A properly fitted respirator may stretch the skin around the
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eyes, creating the possibility that the contact lens will fall out. Also,
contaminants that do penetrate the respirator could get underneath the
contact lens and cause severe discomfort. The user's first reaction would
be to remove the facepiece to remedy the situation - which could be fatal
in a lethal environment.
3) Other Sealing Problems - Scars, hollow temples, very prominent
cheekbones, deep skin creases, and lack of teeth or dentures may cause
respiratory facepiece sealing problems. Full dentures should be retained
when wearing a respirator, but partial dentures may or may not have to be
removed, depending upon the possibility of swallowing them. With full
lower dentures, problems in fitting quarter-masks can be expected, as the
lower part of the mask tends to unseat the denture. Persons with punctured
ear drums also should not wear respirators.
8. TRAINING AND FITTING
a- Training. Selecting the respirator appropriate for a given hazard
is important, but equally important is using the selected device properly.
Proper use can be ensured by carefully training both supervisors and users
in selection, use, and maintenance of respiratory protective devices. The
content of a training program can vary widely, depending on the needs,
however, OSHA requires that the training of both users and supervisors
include the following, no matter what the circumstances:
1) An opportunity to handle the respirator,
2) Propar fitting,
3) Test of facepiece to face seal,
4) A long familiarizing period of wear in normal air.
The training of users and supervisors for specific use situations should
also include:
1) A discussion of the engineering and administrative controls in
use and why respirators are needed.
2) Explanation of the nature of the respiratory hazard and what
would happen if the respirator is not used properly,
3) Explanation of why a particular type of respirator has been
selected,
4) A discussion of how to recognize and handle emergencies.
The training requirements apply to both large and small groups or units of
employees required to wear respiratory protective devices, with no differen-
tiation to meet individual needs.
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1) Supervisor - Supervisors who oversee the daily activities of
one or more employees who wear respirators frequently should have a know-
ledge of respirators and respiratory protec'tion practices. Supervisory
training should include, but not be limited to, the following areas.
Basic respiratory protection practices,
Selection and use of respirators to protect each employee
against every respiratory hazard to which he/she may be exposed,
. The nature axid extent of the respiratory hazards to which
the employees may be exposed,
The structure and operation of the entire respirator pro-
gram. The supervisor should understand his/her responsibility to facilitate
the implementation of the program, including maintenance that the employee
may be expected to do, issuance of respirators, control of their use, and
evaluation of the program's effectiveness.
The legal requirements pertinent to use of respirators in
his/her area of Jurisdiction.
These supervisory training requirements apply to the large groups or field
units with employees required to use respiratory protective devices. A
smaller group or field unit may have to combine the supervisor training
with that of the employee. This will benefit the employees because they
will receive more comprehensive training.
2) Employee Instruction and Training - EPA Order 1440.3 requires
that employees receive a minimum of six hours of initial training, and two
to four hours annually thereafter. This is a minimum requirement. The
extent and frequency of the employee's training will depend on the nature
and extent of the hazard. If the hazard is a nuisance particulate, for
example, the danger froai misuse of the respirator is not likely to be serious.
However, against highly toxic particulates, a single misuse may have serious
consequences. The same is true for gases and vapors. If the respirator
is to be used in an emergency, training in its use should be very thorough
and complete. In any case, the employee must be given some instruction
and training in respiratory protection practices. Because proper respirator
use depends upon the employee's motivation, it is important that the need
for respiratory protection be explained fully. The following points should
be included in a minimum acceptable respiratory protection training program.
Instruction in the nature of the hazard, whether acute, chronic,
or both, and an honest appraisal of what may happen if the respirator is
not used.
Explanation of why more positive control is not immediately
feasible. This should include recognition that every reasonable effort is
being made to reduce or eliminate the need for respirators.
Discussion of why the proper type of respirator must be
used for each particular hazard.
Discussion of respirator capabilities and limitations.
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Instruction and training in actual use of th« respirator.
Classroom and field training in recognizing and coping with
emergencies.
Proper fitting.
Other special training as needed.
The major thrust of the training is toward explaining as much as possible
the reasons for wearing a respirator. This is to motivate the user to
accept the fact that protection is necessary, and to instill in him/her
the desire to wear and maintain his/her respirator properly. Just giving
a respirator to an e^plovee vith orders that it must be worn because OSHA
says so is one of the easiest ways to ensure its misuse. It is also a
cop-out by management. (See Appendix C, Employee Training Program.)
At best, a respirator may cause discomfort and inconvenience, so there is
a natural resistance toward wearing it conscientiously. Most of an employee's
natural resistance can be overcome by taking the time and effort to inform
the user why he/she needs the respirator. This effort will create easier
acceptance of respirators and contribute to correct use.
b. Fitting. The proper fitting of respiratory protective devices
requires the use of some type of fit test. The fit test is needed to deter-
mine a proper match between the facepiece of the respirator and the face of
the user.
1) Test Atmospheres - It is required that the user be allowed to
test the facepiece to face seal of the respirator and wear it in a test
atmosphere. The test atmosphere amounts to an enclosure in which the user
can enter with the equipment on, and a "test" atmosphere (of low toxicity)
can be generated.
Elaborate enclosures are available commercially, but a "do it yourself"
qualitative fit test enclosure can be put together by the use of a plastic
bag, several hangers, and some cotton. This enclosure is illustrated on
the following page.
2) Test Methods - There are two types of tests: Qualitative tests
and quantitative tests. The selection of one or both types of tests depends
on the severity and extent of the respiratory hazard and the size of the
unit or number of employees involved in wearing respiratory protective
devices. During any fitting test, the respirator headstraps must be as
comfortable as possible. Tightening the straps will sometimes reduce
facepiece leakage, but the user may be unable to tolerate the respirator
for any length of time.
Qualitative Tests - Qualitative tests are fast, require no
complicated expensive equipment, and are easily performed. However, these
tests rely on the user's subjective response, and so are not entirely
reliable. There are two major qualitative tests:
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Hangers
Cotton Wad
Hol«
Plastic Bag
Isoamyl Acetate - Isoamyl acetate, a Low toxicity sub-
stance with a banana oil like odor, is."used widely in testing the facepiece fit
of organic vapor cartridge/canister respirators. The substance is applied
to the cotton wad inside the enclosure. The user should put on the respira-
tory protective device in an area away from the test enclosure so that there
is no prior contamination of the cartridge or "pre-exposure" to the isoamyl
acetate. The user should perform the following.
... Normal breathing.
... Deep breathing, as during heavy exertion.
should noc be done long enough to cause hyperventilation.
This
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... Side-to-side and up-and-down head movements. These
movements should be exaggerated, but should approximate those that take
place on the job.
Talking. This is most easily accomplished by reading
a prepared text loudly enough to be understood by someone standing nearby.
... Other exercises may be added depending upon the need.
The major drawback of the iosanryl acetate test is that the odor threshold
varies widely among individuals. Also, the sense of snail is easily dulled
and nay deteriorate during the test so that the user can detect only high
vapor concentrations. Another disadvantage is that isoamyl acetate smells
pleasant, even in high concentrations. Therefore, a user may say that the
respirator fits although it has a leak. A user may say that a respirator
fits because he/she likes the fit of the particular respirator or is
following the respirator selection of another employee. Conversely, a
user may claim that a particular respirator leaks if it is uncomfortable,
etc. Therefore, unless the employee is highly motivated toward wearing
respirators, the results of this test must sometimes be suspect.
Irritant Smoke Test - The irritant smoke teat, similar to
the isoamyl acetate test in concept, is used widely in testing the facepiece
fit of particulate filter respirators. This test can be used for both air-
purifying and atmosphere-supplying respirators, but an air-purifying
respirator must have a high-efficiency filter. The test substance is an
irritant (stannic chloride or titanium tetrachloride) which is available
commercially in sealed glass tubes. When the tube ends are broken and air
passed through them, a dense irritating smoke is emitted. In this test,
the user steps into the test enclosure and the irritant smoke is sprayed
into the test hole. If the user detects any of the irritant smoke, it
means a defective fit, and adjustment or replacement of the respirator
is required. The irritant smoke test must be performed with caution
because the aerosol is highly irritating to the eyes, skin, and mucous
membrane. As a qualitative means of determining respirator fit, this
test has a distinct advantage in that the wearer usually reacts involuntarily
to leakage by coughing or sneezing. The likelihood of giving a false
indication of proper fit is reduced.
Negative Pressure Test - This test (and the positive pressure
test) should be used only as a very gross determination of fit. The wearer
should use this test just before entering the hazardous atmosphere. In this
test, the user closes off the inlet of the canister, cartridge(s) or filter(s)
by covering with the palm(s) or squeezing the breathing tube so that it
does not pass air; inhales gently so that the facepiece collapses slightly;
and holds his/her breath for about 10 seconds.
If the Eacepiece remains slightly collapsed and no inward leakage is
detected, the respirator is probably tight enough. This test, of course,
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can only be used on reapirators with tight-fitting facepieces. Although
this test is simple, it has severe drawbacks; primarily that the wearer
must handle the respirator after it has supposedly been positioned on hia
face. This handling can modify the facepiece seal. A second drawback is
that, with a negative pressure in the facepiece, a leaking facepiece may
be drawn tightly to the face to form a good seal, giving a false reading
of a good seal.
Positive Pressure Test - This test, similar to the negative
pressure test, is conducted by closing off the exhalation valve and exhaling
gently into the facepiece. The fit is considered satisfactory if slight
positive pressure can be built up inside the facepiece without any evidence
of outward leakage. For some respirators, this nethod requires that the
wearer remove the exhalation valve cover; this often disturbs the respirator
fit even more than does the negative pressure test. Therefore, this test
should be used sparingly if it requires removing and replacing a valve
cover. The test is easy for respirators whose valve cover has a single
small port that can be closed by the palm or a finger.
2) Quantitative Tests - Quantitative respirator performance tests
involve placing the user wearing the device in an atmosphere containing an
easily detectable, relatively nontoxic gas, vapor, or aerosol. The atmos-
phere inside the respirator is sampled continuously through a probe in the
respiratory-inlet covering. The leakage is expressed as a percentage of
the test atmosphere outside the respirator, called "percent of penetration,"
01 simply "penetration." The greatest advantage of a quantitative test
is that it indicates respirator fit numerically, and does not rely on a
subjective response. The quantitative fit test is highly recomended
when facepiece leakage must be minimized for work in highly toxic atmos-
pheres or those immediately dangerous to life or health. (See Appendix D,
Respirator Protection Factors.)
The quantitative tests require expensive (up to $10,000) equipment that
can be operated only by highly trained personnel. Also, it is difficult
to use because of its complexity and bulk. Each test respirator must be
equipped with a sampling probe to allow continual removal of an air sample
from the facepiece so the same facepiece cannot be worn in actual service,
since the test orifice negates the approval of the respirator.
.. Sodium Chloride (NaCl) Test - In this test, a liquid aerosol
is generated continuously from a salt water solution, dried to produce dis-
crete submicron salt particles, and dispersed into a test chamber or hood.
A means is provided for sampling the atmosphere in the chamber or hood
and inside the respirator. These samples are fed to the analyzing section
where the aerosol's penetration inside the respirator is determined. The
amount of penetration is displayed on a meter or recorder.
.. Dioctyl Phthalate (DOP) Test - The dioctyl phthalate (DOP)
quantitative fitting teat, which uses an air-generated DOP serosol, differs
from the NaCl test only in that the aerosol particle is liquid. The aerosol
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is generated using a nozzle-type atomizer, but being an oil, DOP does not
dry into solid particles when injected into a diluting air stream.
9. RESPIRATORY PROTECTIVE DEVICE INSPECTION, CLEANING, MAINTENANCE, AND
STORAGE. Scrupulous respirator maintenance must be made an integral part
of the overall respirator program. Wearing poorly maintained or malfunc-
tioning respirators is, in one sense, more dangerous than not wearing a
respirator at all. The employee wearing a defective device thinks he/she
is protected when, in reality, he/she is not. Emergency escape and rescue
devices are particularly vulnerable to poor maintenance as they generally
are used infrequently, and then in the most hazardous and demanding cir-
cumstances. The possible consequences of a user wearing a defective
eTiergencv escape and rescue device are lethal.
A proper maintenance program ensures that the user's respirator remains
as effective as when it was new. All programs are required to include as a
minimum:
a. Inspection for defects (including a leak check),
b. Cleaning and disinfecting,
c. Repair,
d. Storage.
a. Inspection of Respiratory Protective Devices. An important part
of a respirator maintenance program is the inspection of the devices. If
performed carefully, inspections will identify damaged or malfunctioning
respirators.
1) Inspection Schedules - All respiratory protective devices must
be inspected:
o Before and after each use; and
o During cleaning.
Equipment designated for emergency use must be inspected:
o After each use;
o During cleaning; and
o At least monthly.
Self-contained breathing apparatus must be inspected:
o At least monthly.
2) Recordxeeping - A record must be kept of inspection dates and
findings for respirators maintained for emergency use.
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3) Inspection Considerations - The primary defects to look for in
the inspection of the components of the respirator are itemized below.
Information within the parentheses are suggested actions to be taken.
o Disposable respirator
Holes in the filter (obtain new disposable respirator);
Straps for elasticity and deterioration (replace straps -
contact manufacturer); and
Metal nose clip for deterioration, if applicable (obtain
new disposable respirator).
o Air-purifying respirators (quarter-mask, half-mask, full
facepiece and gas mask)
Rubber facepiece - check for:
Excessive dirt (clean all dirt from facepiece);
Cracks, tears, or holes (obtain new facepiece);
Distortion (allow facepiece to "sit" free from any
constraints and see if distortion disappears; if not, obtain new facepiece);
and
Cracked, scratched, or loose fitting lenses (contact
respirator manufacturer to see if replacement is possible; otherwise obtain
new facepiece).
Headstraps - check for
Breaks or tears (replace heads traps);
Loss of elasticity (replace headstraps);
Broken or malfunctioning buckles or attachments
(obtain new buckles); and
Excessively worn serrations on the head harness which
might allow the facepiece to slip (replace headstrap).
Inhalation valve, exhalation valve - check for:
Detergent residue, dust particles, or dirt on valve
or valve seat (clean residue with soap and water);
Cracks, tears, or distortion in the valve material
or valve seat (contact manufacturer for instructions); and
Missing or defective valve cover (obtain valve cover
from manufacturer).
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replacement);
26.
Filter element(s) - check for:
Proper filter for the hazard;
Approval designation;
Missing or worn gaskets (contact manufacturer for
Worn threads - both filter threads and facepiece
threads (replace filter or facepiece, whichever is applicable);
harness); and
Cracks or dents in filter housing (replace filter);
Deterioration of gas mask cannister harness (replace
Service life indicator, or end of service date - for
expiration, gas mask (contact manufacturer to find out if filter element
has one; if not ask what will indicate the "end of service").
Corrugated beathing tube (gas mask) - check for:
Cracks or holes (replace tube);
Missing or loose hose clamps (obtain new clamps); and
Broken or missing end connectors (obtain new connectors), t
o Atmosphere Supplying Respirators
Facepiece, headstraps, valves, and breathing tube - These
items should be checked as for the air-purifying respirators.
Hood, helmet, blouse, or full suit, if applicable -
check for:
Rips and torn seams (if unable to repair the tear
adequately, replace);
Headgear suspension (adjust properly for you);
Cracks or breaks in faceshield (replace faceshield); and
Protective screen to see that it is intact and fits
correctly over the faceshield, abrasive blasting hoods, and blouses (obtain
new screen).
Air supply system - check for:
Breathing air quality;
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Breaks or kinks in air supply hosea and end fitting
attachments (replace hose and/or fitting);
Tightness of connections;
Proper setting of regulators and valves (consult
manufacturer's recommendations); and
Correct operation of air-purifying elements and carbon
monoxide or high temperature alarms.
o Self-contained breathing apparatus (SCBA.) - (See Appendix E.)
b. Cleaning and Disinfecting. When respiratory protective devices
are used routinely, the respirators should be cleaned and disinfected daily.
If respirators are used only occasionally, periodic cleaning and disinfecting
is appropriate.
1) Methods - The actual cleaning may be done in a variety of ways.
o The respiratory protective device should be washed with
detergent in warm water using a brush, thoroughly rinsed in clean water, and
then air dried in a clean place. Care should be taken to prevent damage
from rough handling. This method is an accepted procedure for a small group
or unit of employees where each employee cleans his/her own respirator.
o A standard domes tic-type dish or clothes washer may be used
if a rack is installed to hold the facepieces in a fixed position. (If
the facepieces are placed loose in the washer they may be damaged.) This
method is especially useful in a large unit or group and where respirator
usage is extensive.
2) Detergents and disinfectants - If possible, detergents containing
a bactericide should be used. Organic solvents should not be used, as they
can deteriorate the rubber facepiece. If the above combination is not avail-
able, a detergent may be used, followed by a disinfecting rinse. Reliable
disinfectants may be made from some available household solutions.
o Hypochlorite solution (50 parts per million (ppca) of chlorine)
made by adding approximately two tablespoons of chlorine bleach per gallon
of water. A two-minute immersion disinfects the respirators.
o Aqueous solution of iodine (50 ppm made by adding approxi-
mately one teaspoon of tincture of iodine per gallon of water). Again, a
tvo-minute immersion la sufficient and will not damage the rubber and
plastic in the respirator facepieces. Check with the manufacturer to
find out the proper temperature for the solutions.
3) If the respirators are washed by hand, a separate disinfecting
rinse -nay be provided. If a dish or clothes washing machine is used the
disinfectant must be added to the rinse cycle, and the amount of water in the
machine at that time will have to be measured to determine the correct
amount of disinfectant to be added.
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28.
4) Rinsing - The cleaned and disinfected respirators should be
rinsed thoroughly in clean water (120 F maximum) to remove all traces of
detergent, cleaner and sanitizer, and disinfectant. Thi 3 is very imp or t an t
to prevent dermatitis.
5) Drying - The respirators may be allowed to dry by themselves
on a clean surface. They also may be hung from a horizontal wire, like
drying clothes, but care must be taken not to damage the facepieces.
c. Maintenance. Continued usage of respiratory protective devices
may require periodic repair or replacement of component parts of the
equipment. Such repairs and parts replacement must be done by a qualified
individual(s).
Replacement of parts and repair of air-purifying respirators, in most cases,
present little problem. Most equipment manufacturers supply literature which
details the component parts of their respirator and include servicing infor-
mation. The manufacturer will also provide replacements parts. Replacement
parts for respiratory protective devices must be those of the manufacturer
of the equipment. Substitution of parts from a different brand or type of
respirator will invalidate the approval of the respirator.
Defective air-supplying respiratory protective equipment, with the exception
of the SCBA, can be repaired and worn if broken parts are replaced by a
qualified Individual - again with the aid of the manufacturer's literature
and parts. Maintenance of SCBA. equipment Is more difficult, primarily
because of the valve and regulator assembly. Because of this, regulations
require that SCBA. equipment be returned to the manufacturer for adjustment
or repair.
d. Storage. All the care that has gone into cleaning and maintenance
of a respirator can be negated by improper storage. Respiratory protective
equipment must be stored to protect it from dust, sunlight, heat, extreme
cold, excessive moisture, and damaging chemicals. Leaving a respirator
unprotected can lead to damage of the working parts or permanent distortion
of the facepiece, thus making it ineffective.
After cleaning and disinfecting the respirators, they should be placed
individually in heat-sealed or resealable plastic bags until reissue. They
should be stored in a single layer with the facepiece and exhalation valve
in a more or less normal position to prevent the rubber or plastic from
taking a permanent distorted "set".
1) Air-purifying respirators - Air purifying respirators kept
ready for nonroutine or emergency use should be stored in a cabinet In
individual compartments.
2) Air-supplying respiratory protective equipment - A storage chest
for self-conrained breathing apparatus may be purchased from the manufacturer.
All storage cabinets should be located in noncontaminated, but readily
accessible, areas.
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29.
10. MEDICAL ASPECTS OF RESPIRATORY EQUIPMENT USAGE. EPA Order 1440.3,
Respiratory Protection, requires that employees assigned to tasks requiring
the use of respiratory protective devices must have a medical evaluation,
defined by the Agency's Occupational Medical Monitoring Guidelines. There
must be a determination that employees are physically capable of performing
the work while wearing the devices. These requirements are necessary because
the use of any type of respirator may impose some physiological stress on
the user. Air-purifying respirators, for example, make breathing more
difficult because" the filter or cartridge impedes the flow of air. The
special exhalation valve on an open circuit pressure demand respirator
requires the user to exhale against significant resistance. The bulk and
weight of an SCBA can be a burden. If the employee is using an airline
respirator, he/she might have to drag up to 300 feet of hose around. All
of these factors can significantly Increase the employee's workload.
So that the examining physician can give a qualified opinion regarding
whether an employee can use a respirator, the Agency should provide the
following information. (See Appendix F, Duty Status Report.)
a. Type of respiratory protection equipment to be used, and its modes
of operation;
b. The tasks that the employee will perform while wearing the respirator;
c. Visual and audio requirements associated with the task;
d. Length of time that the employee will wear the respiratory
protective equipment; and
e. The substance(s) to which the employee will be exposed, and the
related toxicity data.
The following checklist will give the Respiratory Protection Program Manager
a good indication of the employee's ability to wear a respirator.
a. Lung
History of asthma or emphysema.
Difficulty in breathing.
Previously documented lung problems.
b. Heart
High blood pressure.
Artery diseases.
Documented heart problems.
c. Other
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30.
-Missing or arthritic fingers.
Facial scars.
Claustrophobia.
Poor eyesight.
Perforated ear drum(s).
A "yes" answer to any of these questions would constitute a warning sign
regarding the use of respirators by an employee. A medical opinion to
confirm any of these situations should then be obtained.
11. EVALUATION OF THE RESPIRATORY PROTECTION PROGRAM. Two important aspects
of the respirator program are the periodic surveillance of the work areas
which require use of respirators, and an evaluation of the program for effect
iveness.
a. Surveillance of the Work Area. Many things can affect the need to
use respirators. To determine the continued necessity of respiratory
protection or need for additional protection, there should be appropriate
surveillance of the work area conditions and the degree of employee exposure
or stress to allow for program changes as needed.
b. Program Evaluation. The respirator program at each Agency unit
should be evaluated at least annually, with program adjustments, as appro-
priate, made to reflect the evaluation results. The following are areas
of the Respiratory Protection Program that should be evaluated.
1) Program Administration
o Program responsibility is vested in one individual who is
knowledgeable and who can coordinate all aspects of the program.
o The implementation of engineering controls, if feasible,
to alleviate the need for respirators is in progress.
o There are written procedures/statements covering these aspects
of the respirator program.
A Program Manager has been designated.
Procedures for respirator selection are developed.
The purchase of approved equipment is assured.
The procedures for issuing respiratory equipment are in
place.
The medical aspects of respirator usage are defined and a
program is in place.
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31.
Employees are properly fitted for respiratory protective
devices.
Provisions for the maintenance, storage, and repair
of respiratory protective equipment are being followed.
There la a program for regular inspection of respiratory
protective equipment, and
The provisions for use of respiratory protective equipment
under special conditions are defined.
2) Program Operation
o The selection of respiratory protective equipment consider
these factors:
The work area conditions and employee exposures.
Respirators are selected on the basis of hazards to
which the employee Is exposed.
The selection of respirators Is made by knowledgeable '
Individuals.
o Only approved respirators are purchased and used to provide
adequate protection for specific hazards and concentrations of contaminants.
o Respirators are issued to users for their exclusive use,
where practical, and records are maintained covering the issuance.
o The fitting of respiratory protective equipment taken into
consideration these factors:
Users are given the opportunity to try on several different
brands of respirators to assure that the make of respirator they will be
wearing is the best fitting one.
Respiratory protective equipment is fit tested at appropriate
intervals.
Respiratory protective equipment users who require corrective
lenses are properly fitted.
Respiratory protective equipment users are prohibited froai
wearing contact lenses when using the respirator.
Facepiece to face seal Is tested in a test atmosphere.
o The maintenance of respiratory protective equipment covers
these factors.
Cleaning and Disinfecting -
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32.
Respirators are cleaned and disinfected after each
use when different employees use the same device or as frequently as
necessary for devices issued to individual users.
Proper methods of cleaning and disinfecting are
utilized.
Storage
Respirators are stored in a manner so as to protect
them from dust, sunlight, heat, excessive cold or moisture, and damaging
chemicals.
Respirators are stored properly to prevent them from
deforming.
Inspection
Respirators are inspected before and after each use
and during cleaning.
Employees/users are instructed in inspection
techniques.
Respiratory protective equipment designated for
emergency use is inspected at least monthly (in addition to after each use).
Records are kept of the Inspection of emergency use
respiratory protective equipment.
. Repair
The replacement parts used for repairing respirators
are those of the manufacturer of the respirator.
Repairs are made by knowledgeable individuals.
Repairs of SCBA.'s are made by certified personnel
or by a manufacturer's representative.
Special Use Conditions
Procedures are developed for the use of respiratory
protective equipment in atmospheres Immediately dangerous to life or health.
Procedures are developed for equipment usage for
entry into confined spaces.
. Training
Employees are trained in proper usage of respiratory
protective equipment.
Employees are trained in the basis for respirator
selection.
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33.
REFERENCES
1. EPA Order 1440.3, Respiratory Protection. July 24, 1981.
2. Department of Labor, OSHA, Occupational Health and Safety Standards.
29 CFR Part 1910.134, General Respirator Requirements, Federal Register,
Volume 37, Number 202, October 18, 1972.
3. Department of Labor, OSHA, Occupational Health and Safety Standards.
29 CFR 1910.94, 111, 252, 261, 262, 265, 266, 1001-1029, Specific Respirator
Requirements, Federal Register, Volume 37, Number 202, October 18, 1972.
4. Department of the Interior, Bureau of Mines, Respiratory Protective Devices;
Tests for Permissibility; Fees, 30 CFR Part 11, Federal Register, Volume
37, Number 59, March 25, 1972.
5. American National Standards Institute, Standard Z88.2-1969, Respirator
Practices, ANSI, 1430 Broadway, New York, N. Y. 10018.
6. American National Standards Institute, Standard Z88.2-1980, Practices for
Respiratory Protection. ANSI, 1430 Broadway, New York, N. Y. 10018.
7. American Conference of Governmental Industrial Hygienists, Threshold Limit
Values for 1973 (and current year), ACGIH, 1014 Broadway, Cincinnati,
Ohio 45202.
NOTE: Information from these references is either used or referred to in this
guideline. A copy of the complete text of the references is valuable in setting
up and managing a respiratory protection program. It is recommended that copies
of these references be obtained and filed with this guideline.
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APPENDIX A
34.
Respiratory Protective Device Recommendation
Kaine of Employee/User
Program Office Telephone Number
Anticipated Hazards
1. Materials
a. Chemical Name _
b. Trade Name .
c. Formula
d. TLV or TWA. OSHA. 1910.1000 Other
2. Form of Materials
a. Liquid? b. Solid? c. Gaseous?
d. If gaseous, is it an organic vapor? _ or acid gas?
other? _
3. Maximum expected concentration
a. _ parts per million, or
b. _ milligrams per cubic meter
4. Will material b« heated? _ If so, to what temperature?
5. What is the odor threshold of the material?
6. At what concentration Is the material considered to t>e Immediately
dangerous to life or health?
7. Can the substance be absorbed through the skin?
8. Irritant to eyes? respiratory tract? skin?
9. At what concentration is it an irritant?
10, If the substance is known to be flammable, what are the lower and
upper flammable limits, in per cent by volume?
11. What is the vapor pressure of the material?
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35.
12. Will the material b« mixed with oth«r chemicals? If so, give
details
13. Any possibility of oxygen deficiency?
14. Can good ventilation of the area be maintained?
15. Will exposure be continuous? or intermittent?
16. Will the respiratory device be used for routine exposures, or will
it b« uaed as an escape device? _.. . .
Respiratory Protective Devtce(s) Recommended:
Other Personal Protective Clothing or Equipment Recommended:
Date Respiratory Protection Program Manager
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APPENDIX B
36.
MODEL
STANDARD OPERATING PROCEDURE
RESPIRATOR USE
HIGH HAZARD AREAS
1. Location:
2. Date of Preparation
3. Prepared by
4. Operation or Procedures where respirators are required
5. Type(s) of respirator to be used
6. Other Protective clothing and equipment required:
Harness Skin
Safety Linea Head
Eye Protection Other
Body (full) (partial)
7. Training required: .
8. Provisions for Standby person:
9. Provisions for communication
10. Conditions under which respirator is to be used
Oxygen deficient?
Type(s) of contaminants ?
Expected Concentrations?
Peak Concentrations?
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37
11. Type and Frequency of Monitoring:
12. Emergency Procedures (include type of respirator, protective clothing,
cleanup procedures, etc.,
Comments
185
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APPENDIX C
38.
TO
NOTES
INSTRUCTOR
EMPLOYEE TRAINING PROGRAM
A. Why t» rwpirmtory protective equipment required?
Name work area
List substances
Describe activities
Describe chemicaJ exposure
Describe areas
Name storage areas
Describe emergency situation
which could exist in your plant
Suggested phraseology
Plan to have ...
Describe what controls are to
be/being implemented
Discuss administrative controls
(rotating work schedules,
spreading work over two shifts,
etc.)
1. The Occupational Safety and Health Administration
OSHA has »et maximum exposure standard* for many air-
borne toxk materials and hsj set standards governing specific
working environments to protect your health. A recent evalua-
tion of your working environment revealed that:
a. In work areas (****), atmo«pheric concentrations of
•ubalances (****) were found to be above acceptable limits.
6. Maintenance activities (****) during which you are ex-
posed to (****) a high concentration for a ihort period of
jtime, lead to excessive exposure.
a Several areas (****) were found to be "oxygen deficient,"
"tfeee Appendix II)
d Hazardous »ubetanc«s are stored at (****) and if these
•ubstance* spill, etc., an emergency condition will exist, or
<****).
2. Static of Engineering Controls
(****) Since the company recognizes that respiratory protec-
tion is not the accepted method for control of airborne
hazards, we are taking steps to implement engineering control
solutions.
a We (***•) installed the following engineering controls
(***,*)
6. And the following administrative controls (****).
However, while the above steps are being implemented,
respiratory protection will be required.
B. Respirator Selection and Procedure
Selection procedure of the proper equipment normally involves
three steps: the identification of the hazard; the evaluation of the
hazard; and finally the selection of the appropriate respiratory
equipment based on the first two steps.
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39.
NOTES
TO INSTRUCTOR
Discuss only those contaminant
atmospheres representing
problems in your facility. S«e
following discussion.
A further discussion of ODA's
can be found in Appendix IL
EMPLOYEE TRAINING PROGRAM
7. Identification of the Hazard
Before we get into the "specifics" about the respiratory protec-
tive equipment you will be wearing, a few ttatement* about
hazard identification.
There are aeveral kinds of hazardous atmospheres which may
require the ua« of respirators, (****)
a. Gaseous Contaminant*
Gates are the normal form of rabatances like carbon di-
oxide or hydrogen sulfide. Theae substance* are solids or li-
quids only at very low temperatures or extremely high pres-
rare*. Carbon dioxide, for instance, is a gas at room tem-
perature. But it also occurs as solid "dry ice" formed at low
temperature*.
Vapor* are exactly like gases except that they are formed by
the evaporation of substances, such aa acetone or
trichlorethylene, which ordinarily occur a» liquids.
6. Particulate Contaminant*
Particulates are tiny particles, solid or liquid, generated by
ruch processes as grinding, crushing, and mixing of a com-
pound, either a solid or a liquid. There are three types of
particulates,
DutU are solid particles produced by such processes aa
grinding, crushing, and mixing of powder compounds. Ex-
amples are sand and plaster dust. By comparison to the
following two types of particulates, dust particles are
usually large.
Mists are tiny liquid dropleta, usually formed whenever a
liquid is sprayed, vigorously mixed, or otherwise agitated.
Acid mists around diptanks used for metal cleaning, and oil
mists near newspaper printing presses, are two examples.
Fumes are solid condensation particles of extremely small
particle sire. Fumes are found in the air near soldering,
welding, and brazing operations, as well as near molten
metal processes such as casting and galvanizing.
Two basic forms — gaseous and particulate — frequently
occur together. Paint spraying operations, for example, pro-
duce both paint mist (particulate) and solvent vapors
(gases).
a. Oxygen Deficient Atmospheres (****). Oxygen deficient
atmoepheres (ODA) are most commonly found in confined
spaces which have poor ventilation. Examples are silos,
petrochemical tanks, degreasers, and the holds of ships.
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40.
NOTES
TO INSTRUCTOR
After explaining to th* employe*
the f.xp< of hazardous
*tmo4pher* (a ind/or b and/or
c) requiring respiratory
protection, you »hould then
discuss the haiard specifics.
Check vendor literature,
toxicologic references, or
Material Sa/ety Data Sheet (or
contact OSHA or NIOSH
regional offices).
See Figure I.
Refer to Appendix I to describe
the type instrument used
(optional).
See Appendix V.
EMPLOYEE TRAINING PROGRAM
2. Hazard Specific* (**••)
a. Hazard Name
• Organic vtpor (name)
• Particulat* (name)
• Gai (name)
b. ToxicityData (****)
• Effects
See Appendix IV.
3. Evaluation of the Hazard (****)
a. To determine the concentration of the hazard, as iden-
tified above, measurements were made. (****) The con-
centration and/or work environment examined were com-
pared with the published Federal Standard* (****).
4. Selection of the Respirator
a. After it was determined that respirators were required,
the Standards Completion Program (SCP) was consulted
to find out the required respiratory protection equipment
(•••*).
C. U»« and Proper Fitting of Respiratory Protective Equip-
ment
Using Appendix VII and
information supplied by the
manufacturer, show the
employee how to put on the
•elected respirator. Show the
various components of the
respirator, and how the
respirator functions to remove
the contaminants.
At this time, you should have
available at least two different
types (different manufacturers)
of selected respiratory
equipment — for the employee
to try on.
/. Use of Respiratory Protective Equipment
2. Proper\Fitting
So that respiratory protective devices, which use tight fitting
facepiecea, give maximum protection, there must be a proper
"match" between the facepiece and your face. A poor face seal
can cause contaminants to be inhaled through the respirator
•ealing surfaces, instead of through the canister, filter, or air
•upply system. (****)
a. In most cases, there are several different brands of the
same type of respiratory protection equipment approved for
use against a specific hazard or work environment- (****)
188
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41.
NOTES
TO INSTRUCTOR
Refer to Appendix VIII for
discussion of fitting test*. The
qualitative fit tests can be used
as a quick test to ascertain the
proper fit. However, if respirator
u*« will be in an extremely
hazardous atmosphere, or for
emergencies, the quantitative fit
test ihould be used.
Demonstrate how the
qualitative fit test works. Show
illustration of a quantitative
test set-up (if there is not an
actual set-up on the premises).
EMPLOYEE TRAINING PROGRAM
b. However, just because a respirator "feel* comfortable" it
does not mean that it is protecting you to the fullest extent
from the hazard. The key word is proper fit. To determine if
the fit » proper, »everal te*t* can b« used. (****)
Consult Appendix VII and the
specific respiratory protective
equipment — under
Limitations.
D. Limitations of Respiratory Equipment (
However, the respiratory protective equipment that you will use
does have some limitations on its usage.
Refer to Section VII(A) for
detafla concerning cleaning of
equipment Several suggested
cleaning methods are given.
Discuia provisions.
Refer to Section VII(B) and
discuss storage provisions by
company.
Refer to Section VIII for
discussion on inspection for
defects.
E. Maintenance and Storage of Respiratory Equipment
To maintain the proper functioning of respirators requires that
they be regularly cleaned and disinfected, and stored in a conve-
nient and clear location.
7. Cleaning (•••*)
Your respiratory protective equipment should be cleaned
daily after use. The company has made provisions for doing
this, (****)
2. Storage (****)
Equipment must be stored properly at the conclusion of the
work shift.
3. Inspection for Defect* (****)
This is one of the most important functions associated with
respirator usage. These inspections can identify damage to
malfunctioning respiratory protective equipment.
189
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42.
NOTES EMPLOYEE TRAINING PROGRAM f
TO INSTRUCTOR
Before you discuss this section F. 8umm«y<****)
with the user, you should fint
prepare the summary — ai it
applies to your usage. A summary of thcwe aspect* of the proper uw» of respiratory pro-
tective equipment. Reasons for Respiratory Protective Equip-
ment.
/. Respirator Selection Procedure
a. Identification of hazard.
b. Hazard specifics.
c. Evaluation of the hazard.
d. Selection of the respirator.
1 j
2. 'proper Fitting and Utage
6. Fitting.
3. Limttationt
4. Maintenance and Storage
190
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APPENDIX D
43.
RESflRATOR fROTICTlON FACTORS1
Faccpieic*1 Protection
Type Rcytrator rVc«m»f« Factor
L Air-Purifying
l A. Parricutite1 removing
Sintfc-uK* dust5 - 5
Qurrtcr-maik. dutt* - - 5
Half-mask, dim* - 10
HxJf- or Quirtcr-mtsk, fume — 10
Half-or Quancr-miik, High-Efficiency* - 10
Full Faccpiecc, High-Efficiency - 50
Powered, High-Efficiency, all e»do«ures + 1000
Powered, dutt or fume, all endcwurrs + X*
B. G*i and V»po«^Rcmovinf"
HaJf-M**k - 10
Full Ficepicce - 50
II. Acmojphcrc-Supplyinf
A. Supplied-Air
Demand, HaJf-mtik - 10
Demand.'Full Ficcpiece - 50
Hose M*jk Without Blower. Full Ftcepiece - 50
PTCJSUre-Demand, Half-Mask" + 1000
Presjurc-Demind, FuQ Faccpiece" ' * 2000
Ho*e Huk With Blower. Full Facepiece - 50
Continuous Flow, Half-Mask" + 1000
Continuouj Flow, Full Facepiece13 * 2000
Continuous Flow, Hood, Hdmct. or Suit" + 2000
B. Self-Contained Bretthinf Apparatus (SCBA)
Opcn-Qrcuh. Demand, Full Prwxpicce - 50
Open-Circuit, Pressure-demand Pufl Facepiece * 10.00014
aojed-Circuit, Oxyjen Tank-type, Full Facepiece — 50
II|. ComblnatioD Respirator
A. Any combinadon of air-purifying and Utc minimum protection
annoffhcrc-jupplying respirator. factor liitEd above for
B. Any combination of supplkd-air type of mode of operation,
respirator and an SCBA
Exception: Corobination suppb'ed-air respirators. La preature-demand or other positive
prcuure mode, with an auxiliary »df-contained air supply, and • full facepiece, should
u»e the PP for prexwre-demand SCBA,
NOTE: Reference "A Guide to Induatrial Respiratory Protection", NIOSH
June 1976 '
101
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44.
1 TV OTrraU proeecric«> afforded by a fr»ea respirator design (and mode of operation) miy be
defined in terms of ra protection factor (FT). UK PF • a soeaswre of the defrce of protection
afforded by a respirator, defined aa the ratio of die concentration of contaminant in the
ambient atmoapoere to dxat inside tie eadoaure (*suaity Inside the facepiece) under coadi-
tioa* of n*e. Respirators aoouJd be selected to diat tie eoooentrarion inhaled by the wearer
win not exceed the appropriate limit. The recommended respirator PFs are ackcnoo and use
fnides, an-d should ocJy be wed whea the ortpkiyeT Ka< otablitfaed a nioiznaJ acceptable
raptraior program M defined in Section 3 of tbe ANSI ZMJ-1969 Standard.
Jln uididcm to fxccpv^ca, thin bdutioi tny tyjx of endosurc ex' covering of the wetrcr'j
breorlun| IODC, loch a wppl>ed when published test data indicate the
cartridge or canister has ad«raatc aorbent efficiency and »enrice life for a specific pis or vapor.
In addition, the PF ahouid not be applied in {as or rapor concentrations that are: 1)
immediately dangerous to Hfe, 2) above the tower cxptoeve Emit, and 3) cauje eye irritation
when usinj a half-mask.
nA positive pressure svipplied-air respirator ttjoipped with a half-tnask facepiece may not be
M stable on the face as a full faccpiece. Therefore, the PF recommended is half that for a
ismiar derice e cmph_iiirc mat it
ii not for emergency use, the PF is limited to 2,000.
192
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45.
"The da'tfa of the supplied-tJr hood, suit, or helmet (with a minimum of 6 dm of air) may
determine its overall efficiency and protection. For example, when working with the arras
over the had, some hoodi draw the contaminant into the hood breathinf zone. This may be
overcome by wearing a short hood under a cott or overalls- Other limitations specified by the
approval agency must be considered before using in certain types of atmospheres.
MThc SCBA opcnicd in the pos'rivc prctrjre mode h«j been tested on x selected 31-mxn
pand and the facepiccc leakage recorded as less than 0.01% penetration. Therefore, a PF of
10.0OCH a recommended. At this time, the lower limit of detection 0.01% does not warrant
luring a higher number. A positive procure SCBA for an unknown concentration a recom-
mended. This is consistent with the 10»OOO+ that is listed. It is essential to have an emergency
device for use in unknown concentrations. A combination jupplicd-air respirator in pressure-
demand or other positive presture mode, with auxiliary self-contained air supply is also
recommended for use in unknown concentrations of contaminants immediately dangerous to
life. Other limitations, such as skin absorption of HCN or tritium, must be considered.
193
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APPENDIX K
(46.
CHECKLIST FOR INSPECTION Of PRESSURE DEHAND SSLf-COffTAINSD BREXTBING
APPARATUS HIT BOUT HODS SELSCT LEVER t
PRIOR TO BZGIXNING INSPECTION:
1. Chock to assura that high pressure hose connector is tight on
cylinder fitting
2. Bypass valve
3. HainliD* valve closed
4. tfo cover or obstruction on regulator outlet
J. 3AQC PACK C HARWS55 AS5EK3LT
A. 5trapa
2. Visually Inspttct for complete set
2. Visually inspect for frayed or damaged straps that may
break during
B. Buckles
1. Visually inspect for eating ends
2. ChecJc locJting fonction
C. SacJcplate £ Cylinder LocJc
1. VisuaJly inspect JbacAplate for cracJcs Jtnd for missing
rivets or screws.
2. Visually inspect cylinder ?>old -down strap and pnysically
checJc strap tightener and locJc to assura that it is fully
engaged
U. CYLINDER £ CTLINDER VALVE ASSOtflUT
A. Cylinder'
1. Physically chec-fc cylinder to assure that it is tightly fastened
to 2>ac* plate
(H) 2. Checfc Hydrostatic Test Date to assure it is current
(H) 3. Visually inspect cylinder for large dents or gouges inactal
B. Bead £ Valve Assembly
(H) 1, Visually inspect cylinder valve JocJc for presence
(M) 2. Visually inspect cylinder gauge for condition of face, needle,
and lens
J. Open cylinder valve and listen or feel for leakage axoung
packing. (If leakage is noted, do not use until repaired. )
Note function of valve lock
194
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JJJ. PECULATOR £ BIGS PRESSURE BOSK
A. High Pressure Hose f Connector
1. Listen or feel for leakage in bos* or at bos* to cylinder
connector. (Bubble in outer hose covering nay be caused
by seepage of air through bose when stored under pressure.
TbJLs dots not necessarily nean a faulty bose.
B. Regulator C Lou Pressure Alam
1. Cover outlet of regulator with pa2a of band. Open main-
line valve and read regulator gauge {must read at least
1800 PSI and not oore tban rated cylinder pressure)
2. Close cylinder valve and slowly move band from regulator
outlet to allow slew flow of air. Gauge should begin to
shew immediate loss of pressure as air flews. Lou pressure
alarm sbould sound between 650 and 55O PSI. Remove band
completely from' outlet and close mainline valve.
3. Place mouth onto or over regulator outlet and blow. A
positive pressure sbould be created and maintained for
5-20 seconds without any loss of air. Next sucJc a slight
negative on regulator and bold for 5-10 seconds. Vacuum
sbould remain constant. Tbls tests the integrity of the
diaphragn. Any loss of pressure or vacuum during this
test indicates a leak in tbe apparatus.
4. Open cylinder valve.
5. Place band over regulator outlet and open mainline valve.
Remove hand from outlet And replace in rapid aovcment.
Repeat twice. Air sbould escape when band is removed
each time, indicating a positive pressure in chamber.
Cloee mainline valve and remove hand from outlet.
6. Ascertain that no obstruction is in or over the
regulator outlet. Open and close bypass valve
momentarily to assure flow of air through buoass
system. y*
IV. FACEPIECZ £ CORRUGATED BREXTB^HG TUBS
A. Face piece
1. Visually inspect head harness for damaged serrations and
deteriorated rubber. Visually inspect rubber faceplece
body for signs of deterioration or extreme distortion.
2. Visually inspect lens for proper seal in rubber face piece,
retaining clamp properly in place, and cracks or large
scratches.
3. Visually inspect exhalation valve for visible deterioration
or foreign materials build-up.
195
-------
48.
B. anything lube t Connector
1. Stretch breathing tube and visually inspect for
deterioration and hole5.
2. Visually inspect connector to assure good condition of
threads and for presence and proper condition of "0*
ring or rubber gasAet seal.
NOTE: Final test of facepiece vould involve * negative
pressure test for overall scad and cbec.fc or"
exhalation valve. If eonthly inspection, nasJc
a*y no* be placed against face and following tests
performed. If preparing for use, don backpack,
don face piece and use following procedure.
C. negative Pressure Test on Paccpiece
1. With facepiece held tightly to face or facepiece properly
donnedt stretch hreathing tuhe to open corrugations and
place tto^»h or hand over end of connector. Inhale.
Negative pressure should he created inside masJcf causing
it to pull tightly to r"a
-------
INSPECTION AND MAINTENANCE CHECK LISTS
Self-Contained Breathing Apparatus Serial Number
Issued To Date of Issue
Location
WEEKLY INSPECTION
DATE
INSPECTED
CYLINDER OK
CYLINDER
CHANGED
DATE
INSPECTED
CYLINDER OK
CYLINDER
CHANGED
DATE
INSPECTED
CYLINDER OK
CYLINDER
CHANGED
MONTHLY INSPECTION
DATE
INSPECTED
CYLINDER OK
CYLINDER
CHANGED
REGULATOR
OK
FACEPIECE&
BREATHING
TUBE OK
CLEANED AND
SANITIZED
ENTIRE
APPARATUS
OK
REMARKS
INSPECTED
BY
197
-------
INSPECTION AFTER EACH USE
DATE
USED
CYLINDER
OK
CYLINDER
CHANGED
FACEPffiCE
AND
BREATHING
TUBE OK
ENTIRE
APPARATUS
OK
CLEANED
AND
SANITIZED
CONNECTORS
OK
REMARKS
INSPECTED
BY
DATE
INSPECTED
198
-------
APPENDIX F
51.
MODEL
DUTY STATUS REPORT
1. Employee's Name
2. Work Location
3. Occupation
4. Date
5. Use of Respiratory Protective Devicea
a. Type of Respirator
b. Mode of Operation
c. Tasks Employee will perform
d. Visual requirements
e. Audio requirements
f. How long employee is expected to wear the device
g. What 8ubstance(s) will employee be exposed to (include toxicity
data
Signature of Supervisor
Medical Surveillance
At this examination on no contraindications to the
use of the equipment described above have been identified.
Physician's Signature
199
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SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
PART 6
CHEMICAL PROTECTIVE CLOTHING
I. INTRODUCTION
Chemical protective clothing (CPC) is worn to prevent harmful chemicals from coming in
contact with the skin (or eyes). It provides a barrier between the body and chemicals which
have a detrimental effect on the skin or which can be absorbed through the skin affecting
other organs. Used with respiratory protection, properly selected chemical protective
clothing can protect personnel who must work in a hostile chemical environment from
injury.
Protecting workers against skin exposure requires using the most effective chemical
protective clothing. Of primary importance is selecting clothing made from a material which
is most resistance to the attack chemical. The style of clothing is also important and
depends on whether the attack substance is in the air or skin exposure will be from splash
or direct contact with solids or semi-solids. Other selection criteria which should be
considered include the probability of being exposed, ease of decontamination, mobility while
wearing clothing, durability of clothing, and to a lesser degree, cost.
A variety of manufactured material? exists^ which are used to make the fabric for chemical
protective clothing. Each of these materials provides a degree of skin protection against a
range of chemicals. But no one material affords maximum protection against all chemicals.
The chemical protective clothing selected must be made from a material which affords the
greatest deterrent against the chemicals known or expected to be encountered.
Properly selected chemical protective clothing can minimize risk of exposure to chemical
substances, but may not protect against physical hazards, i.e. fire, radiation, electrical. The
use of other personal protective equipment must also be determined for a complete ensemble.
Head protection is provided by hard hats; eye and face protection by goggles or impact
resistant lenses in spectacles; hearing protection by earmuffs or earplugs; and foot protection
by impact resistant and chemically-resistant boots.
II. CLASSIFICATION OF CHEMICAL PROTECTIVE CLOTHING
Chemical protective clothing is classified by style, protective material from which the fabric
is made, and whether the clothing is single use (disposable).
A. Style
Fully Encapsulating Suit (TES): Fully encapsulating, chemical protective
clothing is a one piece garment that completely encloses the wearer. Boots,
6/91 201
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gloves and facepiece are an integral part of the suit, but may be removed.
If removable they are connected to the suit by devices that provide a vapor
or gas proof seal.These are gas tight suits and must be periodically pressure
tested to insure integrity.
Respiratory protection and breathing air is provided to the wearer by a
positive-pressure, self-contained breathing apparatus worn under the suit, or
by an air-line respirator which maintains a positive-pressure inside the suit.
Fully encapsulating suits are primarily for protecting the wearer against toxic
vapors, gases, mists, or particulates in air. Concomitantly, they protect
against splashes of liquids. The protection they provide against a specific
chemical depends upon the material from which they are constructed.
Non-Encapsulating Suit: Non-encapsulating chemical protective clothing
(frequently called splash suits) does not have a facepiece as an integral part
of the suit. A positive pressure self-contained breathing apparatus or air-line
respirator is worn outside the suit, or an air-purifying respirator is used.
Splash suits are of two types: a one-piece, "coverall" or a two piece, "pants
and coat". Either type may include a hood and other accessories.
Non-encapsulating suits are not designed to provide maximum protection
against vapors, gases, or other airborne substances but against splashes.
In effect, splash suits can be made (by taping wrist, ankle and neck joints)
to totally enclose the wearer such that no part of the body is exposed but
they still are not considered to be gas tight. They may be an acceptable
substitute for a fully encapsulating suit if the concentration of airborne
contamination is low and the material is not extremely toxic to the skin.
B. Protective Material
Chemical protective clothing also is classified based on the material from which it
is made. All materials fall into two general categories, elastomers and non-
elastomers.
Elastomers: polymeric (plastic-like) materials, that after being stretched,
return to about their original shape. Most protective materials are
elastomers. These include: polyvinyl chloride, neoprene, polyethylene,
nitrile, polyvinyl alcohol, viton, teflon, butyl rubber and others. Elastomers
may be supported (layered on to cloth-like material) or unsupported.
Non-elastomers: materials that do not have the quality of stretchability.
Non-elastomers include tyvek, tyvek coated garments and other materials.
C. Single-Use
A third classification is single use or disposable garment. This classification is
relative and based on cost, ease of decontamination and quality of construction.
Disposable chemical protective clothing is commonly considered to be less than
$25.00 per garment. In situations where decontamination is a problem, more
expensive clothing may be considered disposable.
6/91 202
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Ill. PERFORMANCE REQUIREMENTS FOR CHEMICAL PROTECTIVE CLOTHING
There are a number of performance requirements that must be considered in selecting the
appropriate protective material. Their relative importance is determined by the particular
work activity and site specific conditions.
Chemical Resistance: The ability of a material to withstand chemical and physical
change. A material's chemical resistance is the most important performance
requirement. The material must maintain its structural integrity and protective
qualities upon contact with a hazardous substance. This requirement is discussed in
detail in Section IV.
Durability: The ability to withstand wear. The ability to resist punctures, abrasions,
and tears. The materials' inherent strength.
Flexibility: The ability to bend or flex; pliable. It is extremely important both for
glove and full-body suit materials, for it directly impacts the worker's mobility,
agility, and range of motion.
Temperature Resistance: The ability of a material to maintain its chemical
resistance during temperature extremes (especially heat), and to remain flexible in
cold weather. A general tendency for most materials is that higher temperatures
reduce their chemical resistance; lower temperatures reduce flexibility.
Service Life: The ability of a material to resist aging and deterioration. Factors
such as chemicals, extreme temperatures, moisture, ultraviolet light, oxidizing
agents, and others decrease a material's service life. Storage away from and proper
care against these conditions can help prevent aging. Manufacturers should be
consulted regarding any recommendations on a suit's shelf-life.
Cleanability: The ability to effectively decontaminate protective materials.
Cleanability is a relative measure of the ability of a material to release the contact
substance. Some materials are nearly impossible to decontaminate, so it may be
important to cover those materials with disposable garments to prevent gross
contamination.
Design: The way a suit is constructed which includes the general type and specific
features it has. A variety of suit styles and features are manufactured including:
Fully encapsulating or non-encapsulating
One, two, or three piece suits
Hoods, facepieces, gloves, and boots (attached or unattached)
Location of zipper, buttons, storm flaps, and seams
(front, side and back)
Pockets, cloth collars, and velcro straps
Exhalation valves or ventilation ports
Ease of compatibility with wearing respiratory
protection
6/91 203
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Size: The physical dimensions or proportions of clothing. Size is directly related
to comfort and influences the number of unnecessary physical accidents. Ill-fitting
clothing limits a worker's mobility, dexterity and concentration. Manufacturers offer
standard sizes in boots and gloves for both men and women, however standard suit
sizes for women are not available.
Color: Brightly colored suit material make it easier to maintain visual contact
between personnel. Suits of darker colors (black, green) absorb radiant heat from
external sources and transfer it to the worker increasing heat related problems.
Cost: The cost of chemical protective clothing varies considerably. Cost will often
play a role in the selection and frequency of use of CPC. In many situations, less
expensive, single use garments are more appropriate and as safe as more costly
clothing. Other situations require high quality, costly clothing which may have to
be discarded after limited use.
IV. CHEMICAL RESISTANCE
The effectiveness of materials to protect against chemicals is based on their resistance to
penetration, degradation, and permeation. Each of these properties must be evaluated when
selecting the style of chemical protective clothing and the material from which it is made.
In choosing protective materials:
There is no protective material that is impermeable.
There is no one material that affords protection against all
chemicals, and
For certain contaminants and chemical mixtures there are no materials
available that will protect for more than an hour after initial contact.
Penetration is the transport of chemicals through openings in a garment. A chemical may
penetrate due to design or garment imperfections. Stitched seams, button holes, pinholes,
zippers, and woven fabrics can provide an avenue for the chemical to penetrate the garment.
A well designed and constructed garment prevents this by using selfsealing zippers, seams
overlayed with tape, flap closures, and nonwoven fabrics. Rips, tears, punctures, or
abrasions to the garment also allow penetration.
Degradation is a chemical action involving the molecular breakdown of the material due to
chemical contact. Degradation is evidenced by physical changes to the material. The action
may cause the material to shrink or swell, become brittle or soft, or completely change its
chemical properties. Other changes may be a slight discoloration, rough or gummy surface,
or cracks in the material. Such changes may enhance permeation or allow penetration by
the contaminant.
Degradation test data for specific chemical or generic classes of chemical (TABLE 7) is
available from product manufacturers, suppliers, or other sources. The published data
provides the user with a general degradation resistance rating. The rating is subjectively
expressed as excellent, good, fair, or poor. Degradation data can help in assessing the
6/91 204
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protective capability of a material but should not replace permeation test data. The reason
for this is that a material with excellent degradation resistance can have poor permeation
properties. Degradation and permeation are not directly related and cannot be used
interchangeably. The manufacturer should be consulted by the user to determine on which
degradation changes the rating is based.
Permeation is a chemical action involving the movement of chemicals, on a molecular level,
through intact material. Permeation is a process which involves the sorption of the chemical
on the outside surface, diffusion through, and desorption of the chemical from the inside
surface of the protective material. A concentration gradient (high on the outside: low on the
inside) is established. Because the tendency is to achieve concentration equilibrium,
molecular forces "drive" the chemical into the material toward the area of no or lower
concentration. Eventually the highest flow of permeating chemical exists and is referred to
as the steady flow state.
Permeation is measured as a rate. Permeation rate is the quantity of chemical that will move
through an area of protective material in a given time. It is usually expressed in micrograms
of chemical permeated per square centimeter per minute of exposure (ug/cnrVmin). Several
factors influence the rate of permeation including the type of material and thickness. A
general rule of thumb is that the permeation rate is inversely proportional to the thickness
(2 x thickness = 1/2 x permeation rate). Other important factors are chemical
concentration, contact time, temperature, material grade, humidity, and solubility of the
material in the chemical.
6/91 205
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TABLE 7
EFFECTIVENESS OF PROTECTIVE MATERIALS AGAINST
CHEMICAL DEGRADATION (BY GENERIC CLASS)1
Generic Class
Alcohols
Aldehydes
Amines
Esters
Esters
Halogenated
hydrocarbons
Hyrocarbons
Inorganic acids
Inorganic bases
and salts
Ketones
Natural fats
and oil
Organic acids
Butyl Rubber
E
E-G
E-F
G-F
G-F
G-P
F-P
G-F
E
E
G-F
E
Polyvinyl
Chloride
E
G-F
G-F
P
G
G-P
F
E
E
P
G
E
Neoprene
E
E-G
E-G
G
E-G
G-F
G-F
E-G
E
G-F
E-G
E
Natural
Rubber
E
E-F
G-F
F-P
G-F
F-P
F-P
F-P
E
E-F
G-F
E
1 E - Excellent F - Fair
G - Good P - Poor
Source: Survey of Personal Protective Clothing and Respiratory Apparatus. DOT. USCG, Office
of Research and Development (September, 1974).of material and thickness. A general rule of thumb
is that the permeation rate is inversely proportional to the thickness (2 x thickness = 1/2 x
permeation rate). Other important factors are chemical concentration, contact time, temperature,
material grade, humidity, and solubility of the material in the chemical.
Another measure of permeation is breakthrough time, expressed in minutes. Breakthrough
is the elapsed time between initial contact of a chemical with the outside surface and
detection at the inside surface of the material. Like permeation rate, breakthrough time is
chemical specific for a particular material and is influenced by the same factors. A rule of
thumb concerning breakthrough time is that it is directly proportional to the square of the
thickness (2 x thickness = 4 x break-through time).
Permeation and breakthrough test data is available from manufacturers which gives specific
rates and times (TABLE 8). A given manufacturer's recommendations serve as a relative
guideline to properly selecting their products. This data is obtained using the American
6/91
206
-------
Society for Testing and Materials (ASTM) standard test method F739-81. Although ASTM
has a standard method for permeation testing, considerable variation exists between
manufacturer's test data. The differences are due to material thickness and grade,
manufacturing processes, temperature, chemical concentrations, and analytical detection
method. Therefore, caution should be used when comparing different manufacturers results.
The results for the same material/chemical combination will differ considerably between
manufacturers. ASTM also has test methods for penetration and degradation resistance.
The best protective material against a specific chemical is one that has a low permeation rate
(if any) and a long breakthrough time. However, these properties do not always correlate.
Compare propyl acetate (TABLE 8) and 1,1,1-trichloromethane against nitrile NBR or
dimethyl sulfoxide and methyl alcohol against neoprene. As indicated, a long breakthrough
time does not always correlate with a low permeation rate or vice versa. A long
breakthrough time is usually desired.
The literature on material testing also notes that permeation rates and breakthrough times are
not tested for those materials which receive a poor degradation rating; only breakthrough
time is measured for those chemicals (especially corrosives) which are known to be direct
skin hazards. The data also reflects the testing of pure substances and not mixtures.
In addition to the manufacturer's chemical resistance data, the best general reference for
selection of CPC is Guidelines For The Selection Of Chemical Protective Clothing. ACGIH
(1985). This reference compiles degradation and permeation test data from manufacturers,
vendors, and independent laboratories with recommendations for over 300 chemicals.
Specific chemicals are rated against a variety of protective materials. The ratings (RR, rr,
NN, nn) are based on two criteria; breakthrough times and vendor chemical resistance data.
Each rating represents a combination of performance, number of sources confirming that
performance, and consistency of the data. The number and size of the letters indicate this.
The available test data and recommendations for all chemical protective clothing is extremely
limited in scope and use. The user must consider these restrictions when selecting CPC and
use the guidelines in the way they were intended to be used.
6/91 207
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KEY TO PERMEATION RATE: Simply Stated
Drops Per Hour
Through a Glove
(Eyedropper size drop)
ND - None detected during a six hour test None
E - Excellent; permeation rate of less 0 to 1/2 drop
than .09 ug/cm2/min.
VG - Very Good; permeation rate of less 1 to 5 drops
than 90 ug/cm2/min.
G - Good; permeation rate of less than 6 to 50 drops
90 ug/cm2/min.
F - Fair; permeation rate of less than 51 to 500 drops
900 ug/cm2/min.
P - Poor; permeation rate of less than 501 to 5000 drops
9000 ug/cm2/min.
NR - Not Recommended; permeation rate 5001 drops up
greater than 9000 ug/cm2/min.
Note: The current revision to the ASTM standard permeation test calls for permeation to
be reported in micrograms of chemical permeated per square centimeter of garnet
exposed per minute of exposure, *ug/cm2/min.*.
V. PROTECTIVE MATERIALS
There is a wide variety of protective materials. The following is a list cf the more common
materials used in CPC segregated as elastomers or non-elastomers. The elastomers are not
listed in any particular priority. The classes of chemicals rated as "good for" or "poor for"
represent test data for both permeation breakthrough and permeation rate. They are general
recommendations; there are many exceptions within each chemical class. Sources consulted
for this information included Guidelines for the Selection of Chemical Protective Clothing
(ACGIH, Vol. 1, 1985) and manufacturer's literature. The costs are recent estimates and
are subject to change.
A. Elastomers
Butyl Rubber: (Isobutylene/Isoprene Copolymer)
Good for: bases and many organics
heat and ozone resistance decontamination
6/91 209
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Poor for: aliphatic and aromatic hydrocarbons
gasoline
halogenated hydrocarbons abrasion resistance
Cost: Gloves - $10/pr.
Boots - $25/pr.
FES - $900 - $1,350
Chlorinated Polyethylene: (Cloropel, CPE)
Good for: aliphatic hydrocarbons
acids and bases
alcohols, phenols
abrasion and ozone
Poor for: amines, esters, ketones
halogenated hydrocarbons
cold temperature (becomes rigid)
Cost: splash suit - $60
FES - $600
Natural Rubber: (Polyisoprene)
Good for: alcohols
dilute acids and bases flexibility
Poor for: organic chemicals
aging (affected by ozone)
Cost: Gloves - $10-$15/doz.
Boot Covers - $5/pr.
Neoprene: (Chloroprene)
Good for: bases and dilute acids
peroxides
fuels and oils
aliphatic hydrocarbons
alcohols
glycols
phenols
abrasion and cut resistance
Poor for: halogenated hydrocarbons
aromatic hydrocarbons
ketones
concentrated acids
6/91 210
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Cost: Gloves - $70/doz. (supported)
- $13/doz. (unsupported)
Boots - $35/pr.
Splash Suit - $40-$60
Nitrile Rubber:(Acrylonitrile rubber, Buna-N, NBR,
hycar, paracril, krynac)
Good for: phenols
PCBs
oils and fuels
alcohols
amines
bases
peroxides
abrasion and cut resistance flexibility
Poor for: aromatic & halogenated hydrocarbons
amides
ketones
esters
cold temperature
Cost: Gloves - $2/pr.
Boots -$18/pr.
Note: The higher the acrylonitrile concentration, the better the chemical re-
sistance; but also increases stiffness.
Polyurethane:
Good for: bases
aliphatic hydrocarbons
alcohols
abrasion resistance
flexibility - especially at cold
temperatures
Poor for: halogenated hydrocarbons
Cost: Boots - $25/pr.
Splash Suit - $60
Polyvinyl Alcohol: (PVA)
Good for: almost all organics
ozone resistance
6/91 211
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Poor for: esters
ethers
acids and bases A
water and water solutions flexibility m
Cost: Gloves - $13/pr.
Polyvinyl Chloride: (PVQ
Good for: acids and bases
some organics
amines, peroxides
Poor for: most organic compounds
cut and heat resistance decontamination
Cost: Gloves - $17-$25/doz. (outer)
- $6/doz. (inner)
Boots - $15/pr.
Splash Suit - $10-$30
One-pc. Suit - $55
FES - $300-$900
Viton:
Good for: aliphatic and aromatic hydrocarbons |
halogenated hydrocarbons
acids
decontamination
physical properties
Poor for: aldehydes
ketones
esters (oxygenated solvents) amines
Cost: Gloves - $27/pr.
FES - $1,600-$3,300
Teflon: Teflon has become available for chemical protective suits. Limited
permeation test data is published on teflon. Teflon, similar to viton,
is thought to afford excellent chemical resistance against most
chemicals. Teflon suits are relatively expensive ($2,000-$3,000).
Blends/Layers
CPC Manufacturers have developed a technique of layering materials to improve chemical
resistance. Essentially one suit is designed with multiple layers. Some examples of layered
fully encapsulating suits are viton/ butyl (Trelleborg), viton/neoprene (MSA Vautex and
Draeger), and butyl/ neoprene (MSA Betex).
6/91 212
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B. Non-Elastomers
Tyvek: (non-woven polyethylene fibers)
Good for: dry paniculate and dust protection
decontamination (disposable) lightweight
Poor for: chemical resistance (penetration/
degradation) durability
Cost: Standard suit - $3-$5
Recommendations: Used against toxic particulates but provides no chemical
protection; worn over other CPC to prevent gross
contamination of non-disposable items and under suits to
replace cotton.
Polyethylene: (coated tyvek)
Good for: acids and bases
alcohols
phenols
aldehydes
decontamination (disposable)
lightweight
Poor for: halogenated hydrocarbons
aliphatic and aromatic hydrocarbons physical properties
(durability) penetration (stitched seams)
Cost: Suit - $8-$ 10
Gloves - $1.50/box of 100 (disposable)
Booties - $13/box of 50 (disposable)
Recommendation: Provides limited chemical protection against concentrated
liquids and vapors. Useful against low concentrations and
those activities which do not create a high risk of splash; also
worn over CPC to prevent gross contamination of non-
disposables. The disposable poly considered "inner liners"
and assist decontamination procedures.
Saranex: (laminated tyvek)
Good for: acids and bases
amines
some organics
PCBs
decontamination (disposable)
lightweight
durability
6/91 213
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Poor for: halogenated hydrocarbons
aromatic hydrocarbons
stitched seams (penetration may occur)
Cost: Suit - $15
"OSHA" suit - $26
Recommendation: Provides greater chemical resistance and overall protection
compared to polyethylene coated tyvek; used to prevent
contamination of non-disposable clothing.
VI. SELECTING CHEMICAL PROTECTIVE CLOTHING
Selecting the most effective chemical protective clothing is easier when the chemical for
which protection is necessary is known. Selection becomes more difficult when the presence
of chemicals is unknown, multiple chemicals (known or unknown) are involved, or an
unidentifiable substance is present. As uncertainties about the substances involved increases,
selecting the proper clothing becomes more difficult.
Another major difficulty in selection is that there is not enough available information
concerning the protective qualities of commonly used protective materials against the wide
range of chemicals that could be encountered.
The selection process consists of:
Deciding that workers must be in an environment where they could be exposed.
Identifying the chemical involved and determining its physical, chemical, and
toxicological properties.
Deciding whether, at the concentrations known or expected, the substance is a skin
hazard.
Selecting protective material which provides the least permeation and degradation for
the longest period of time.
Determining whether a fully encapsulating suit or a non-encapsulating is required.
In those incidents where the presence of hazardous substances is not known or they can not
be readily identified there are usually clues which can assist in choosing the style of
clothing. Observations which could indicate wearing fully encapsulating suits are:
visible emissions of gases, vapors, dust or smoke.
indications of airborne hazards on direct-reading
instruments.
6/91 214
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configurations of containers or vehicles which indicate
they contain gases or pressurized liquids.
signs, labels, placards, or bills of lading indicating substances that could become
airborne and are toxic
to the skin.
enclosed, poorly ventilated areas where toxic vapors,
gases and other airborne substances could accumulate.
work functions required might expose workers to high concentrations of skin toxics.
Unknown situations require considerable judgement as to whether maximum protection to
the skin (fully encapsulating clothing) is necessary, or whether splash suits are appropriate.
After determining the type of protective garment to be worn, the next step is to select the
protective material. Vendors or manufacturers of materials used to make chemical protective
materials can sometimes (but not always) supply information concerning their product's
chemical resistance and make recommendations about what chemicals it is good for. The
number of chemicals their product is tested against may be limited, for they can not test
against the 1000's of chemicals that exist.
Permeation is the primary selection criteria. The best protective material against a specific
chemical would be one that has a very low permeation rate (if any), and a long breakthrough
time, and has been constructed free of design imperfections.
Less useful information is degradation. This is usually a qualitative determination of a
materials ability to standup under the attack of a chemical, usually expressed in subjective
units of excellent, good, poor, or similar terms. Degradation data can help in assessing the
protective capability of a materials, if no other data is available.
However, a fabric with good degradation resistance may be very permeable to the same
chemical. Permeation and degradation are not directly related and cannot be used
interchangeably. In those situations where a protective material can not be chosen because
of uncertainty of the attack substance, there are some reasonable options.
Select a protective material which protects against the greatest range of chemicals.
These are generally garments made from butyl rubber, viton, or teflon. Chemicals
against which these materials (or other materials) do not provide protection could
possibly be eliminated as not being present.
Clothing made of multiple protective material could be used. Garments consisting
of butyl-viton, neoprene-viton, and neoprene-butyl are manufactured. If not
commercially available, two garments made of different material could be worn with
a disposal type garment on the outside.
Whether fully encapsulating or non-encapsulating clothing should be worn may not
be self-evident. If based on an assessment of the situation it is determined that either
style would provide effective protection other factors to consider would be:
6/91 215
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Ease in wearing: Non-encapsulating suits are easier to wear. Wearers are less prone
to accidents for they have better visibility and the clothing is less cumbersome.
Communications: It is more difficult to communicate in fully encapsulating
suits.
Decontamination: Fully encapsulating suits protect self-contained breathing
apparatus, which are difficult to decontaminate, from being contaminated.
Heat stress: Non-encapsulating clothing generally causes less heat stress. However
as less area of the body is exposed by wearing gloves and hoods and taping hoods
to respirator masks, there is little difference in the heat build-up of either style.
Cost: Non-encapsulating garments are less expensive.
VII. PHYSICAL STRESS
Wearing chemical protective clothing can cause problems. These involve heat stress,
accident proneness, and fatigue. The major problem is heat stress caused by protective
clothing interfering with the body's ability to cool itself. Clothing that provides a barrier
against chemicals contacting the skin, prevents the efficient dissipation of body heat.
Evaporation, the body's primary cooling mechanism is reduced, since ambient air is not in
contact with the skin's surface. Other heat exchange mechanisms (convection and radiation)
are also impeded. Additional strain is put on the body as it attempts to maintain it's heat
balance. This added stress can result in health effects ranging from transient heat fatigue
to serious illness or death.
The smaller the area of the body exposed to the air, the greater the probability for heat
stress. Fully encapsulating suits allow no ambient air to contact the skin's surfaces to aid
in the evaporation of moisture. Heat in these suits builds up quickly. Splash suits may
allow more body surface (head, neck, and hands) to be cooled by the air, but if those areas
are covered by hoods, gloves and respirators and the joints taped, the same conditions will
exist as if wearing a fully encapsulating suit. Heat-related problems become more common
as the ambient temperature rises above 70'F., but can occur at much lower temperatures.
Although wearing protective clothing establishes conditions that are conducive to heat-related
illness, individuals vary in their susceptibility to heat stress and their ability to withstand
high temperatures.
Accident proneness also increases when wearing chemical protective clothing. Suits are
heavy, cumbersome, decrease mobility and dexterity, lessen visual and audio acuity, and
increase physical exertion. The severity of the problems depend on the style of clothing
worn. These negative qualities increase the risk of common accidental injury, for example
slips, falls, or being struck.
Increased physical exertion caused by working in protective clothing can in itself cause
problems. Worker performance may decrease due to increased fatigue levels. Other more
serious illnesses such as stroke or heart attack could occur.
6/91 216
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To minimize the adverse effects of physical stress, workers wearing protective clothing must
change their normal work regimen. A medical surveillance program, including baseline
physicals and routine medical monitoring, should be instituted. Personnel must be allowed
to acclimatize to stressful environmental factors by varying work and rest periods as needed.
Projects should be scheduled for cooler periods of the day when possible. The intake of
fluids must be maintained at levels to prevent dehydration, and body electrolytes replaced
through added salting at mealtimes. Compensatory efforts such as these must be established
as part of Standard Operating Safety Procedures on a site-specific basis to reduce the risks
associated with wearing protective clothing.
VIII. INSPECTION OF PROTECTIVE CLOTHING
Before wearing chemical protective clothing it must be properly inspected. The following
is a checklist for visually inspecting all types of chemical protective suits. Chemical suits
should be inspected immediately before use and monthly when not in use.
A. Inspection Procedures:
Spread suit out on a flat surface.
Examine the outside for the following:
fabric for abrasions, cuts, holes, or tears
fabric has retained the original flexibility and durability
seams for separations, or holes
zippers, buttons, storm flaps, and other connecting devices for proper sealing
and operation
signs of previous chemical attack or incomplete decontamination
(unusual discoloration, rough surface, gummy feeling, cracks)
elastic around wrists and ankles and the draw strings on hoods are
in good condition (if applicable)
Fully encapsulating suits require additional
inspection which include (if applicable):
Exhalation valves (positive pressure) for debris
and proper functioning.
Suit facepiece for poor visibility (cuts, scratches, dirt) and an
adequate facepiece to suit seal.
Presence and condition of waist belts, velcro adjustments (head and hips),
and ankle straps.
Condition of integral gloves, boots, and leg
gaiters.
Presence of hard hat or ratchet head suspension.
Presence and condition of airline attachment
and hoses for cooling system.
Leak detection and pinholes.
6/91 217
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1. If an air source is available, secure the suit and inflate it, then using a mild soap
solution observe for bubbles on the surface or around seams, or
2. Inside a dark room, run a flashlight inside the suit and look for pinpoints of light
from outside the suit.
3. OSHA 1910.120 Standard has an Appendix A attachment which outlines two test
methods for evaluating the integrity of totally encapsulating chemical suits. One is
an Air Pressure test and the other is an Ammonia Leak Test. These tests are non-
mandatory under the standard.
Records should be maintained on each suit's inspection, use conditions, and repair
status. These records are especially important for fully encapsulating suits (FES)
which are usually not individually assigned but shared. Suggestions for maintaining
records include:
1. Inspection - who, when,and any problems.
2. Use conditions - where, activity, and chemicals if known.
3. Repair status - what is the problem, who repaired it (in-house or
manufacturer), date of repair, and tag the suit "out of service" if not
repaired.
**Always refer to manufacturer recommendations for routine or any special inspection
procedures. {
IX. PERSONAL COOLING DEVICES
A. INTRODUCTION
Wearing chemical resistant clothing and respirators increases the risk for heat stress.
They cause additional strain on the body by adding weight, increasing breathing
resistance and restricting movement. They can also reduce the body's natural
cooling mechanism. The body releases heat by convecting heat to cooler air,
radiating heat to cooler surfaces in the surroundings, and evaporating moisture from
the skin. Chemical resistant clothing interferes with these processes. This can lead
to heat illness, heat fatigue, heat rash, heat cramps, heat syncope (fainting), heat
exhaustion or even heat stroke. Methods used to prevent heat illness include
frequent rest breaks, reduced work loads, increased consumption of fluids,
acclimatization, and working during the cooler times of the day. Another method
that is available is the use of personal cooling devices to remove heat from the user's
body. These devices are divided into two types: those that use a coolant source
external to the wearer (an umbilical system) or self-contained systems that are not
connected to'an outside source.
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B. EXTERNAL COOLANT SYSTEMS
Devices using an external cooling source need a connection between the wearer and
the coolant source. The coolant can be compressed air or a liquid.
1. Compressed air systems
Compressed air systems use cool, dry air to aid in cooling the body.
Generally the air is distributed to the ankles, wrists, and head by an
arrangement of air tubes worn on the body or attached to the protective
clothing (FIGURE 7). Some systems can be found in the form of a hood or
vest. Many manufacturers of fully encapsulating suits have air distribution
systems built into their suits.
The air is delivered to the units comes from a compressor or a large
compressed air container (like a cascade system). The air acts as an insulator
from external heat and increases evaporation of sweat because of the constant
flow of dry air. If additional cooling is needed, a vortex cooler to chill the
air can be connected into the airline at the user's end. The vortex cooler
(FIGURE 8) takes compressed air, increases its velocity, directs it into an
outer "hot" tube, and forms a vortex. The air spirals down the tube and a
fraction escapes through a valve in the end. The remaining air forms a
second vortex which passes through the center of the outer vortex -flowing
in the opposite direction - and exits from the "cold" tube. The outer vortex
takes heat from the inner vortex. How much heat is transferred is
determined by how much air the valve releases; more hot air out, more cold
air to user. The vortex cooler is attached to a belt or other support. It must
be worn on the outside of any protective clothing so that the heat can be
vented.
It is important to remember that NIOSH does not have a specific testing and
certification schedule for supplied air suits. Thus, the suits should not be
used for respiratory protection. Some suits and hoods have a NIOSH/MSHA
respiratory approval under the SCBA or airline testing schedules. If a vortex
tube is used with a unit for respirator protection, then the respirator must be
tested and approved with the vortex tube.
Compressed air systems have two advantages. They are able to cool the
whole body and they allow the wearer to work as long as desired. However,
they have several disadvantages. They restrict mobility because of the airline
umbilical. Since the system is continuous flow, they use a lot of air -
especially if using a vortex cooler. One unit with a vortex cooler uses 25
cubic feet of air per minute to deliver 15 cubic feet of useable air to the
wearer. A normal airline respirator uses 6-8 cubic feet per minute. Also,
the hot air from the vortex tube - as hot as 162 F - can add heat to the
environment or to the outside surface of the protective clothing.
6/91 219
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FIGURE 7
FULLY ENCAPSULATING SUIT WITH AIR DISTRIBUTION SYSTEM
Used with permission of Mine Safety Appliances, Pittsburgh, PA.
H ODD OB M t I U C T
VORTCX TUBE -*-
FIGURE 8
VORTEX TUBE; SCHEMATIC OF VORTEX TUBE; VORTEX
TUBE CONNECT TO AIR-SUPPLIED HOOD
Used with permission of Fyrepel Products, Inc., Newark, OH.
6/91
220
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2. LIQUID-COOLED DEVICES
There is only one device in this category. Water is circulated through tubing
in a garment resembling long Johns. It can use an external water supply -
which can be chilled - or a portable chilling unit for recirculated water.
This unit has the same advantages and disadvantages of the air-supplied
systems. It has additional disadvantages. There is additional weight due to
the water in the system. At the present, fully encapsulating suits do not have
liquid line connections. One advantage is that the cooling system can be
located away from the user and thus not add heat to the user's immediate
area.
C. SELF-CONTAINED SYSTEMS
Self-contained systems have all of the heat exchanging elements as part of the
wearer's ensemble. Thus, they are not hooked to an outside coolant source. These
systems are usually of two types - those that use ice to cool the wearer and those that
circulated a liquid cooled by a heat exchange system.
1. Ice Vests/Jackets
These systems use ice in a vest/jacket or in removable packets. The size and
number of packets vary form manufacturer to manufacturer. Some systems
come with a inner vest to prevent direct contact with the skin. Some have
an outer vest to reduce external heat effects on the ice. (See FIGURE 9)
These systems have several advantages. They are simple to use, have no
moving parts, and do not restrict mobility. They can be worn under
protective clothing or an SCBA. They also have disadvantages. They are
usually limited to a maximum of 1 hour of cooling. If more time is needed,
extra packets are needed. If the unit has no removable packets, the whole
vest has to be refrozen. After the ice melts, the wearer is carrying extra
weight with no cooling benefit. They weigh from 12 to 15 pounds. If there
is no inner insulation, they may be too cold.
2. Circulating Systems
Circulating systems use a water or a water/alcohol mixture circulated through
the vest to cool the wearer. The liquid is cooled by ice or other frozen
liquid contained in a pouch or container carried by the wearer (see FIGURE
10). In some cases, the melting ice becomes part of the circulating system.
There are a couple of experimental models that use dry ice to cool the
circulating liquid.
The circulating systems have some of the same advantages and disadvantages
as the ice vests. They have the additional disadvantage of using an electric
circulator. This requires battery pack to power the circulator. Thus, more
weight is added. Also, while the units have waterproof and sparkproof
connections, none have received an inherent safety rating. Their main
6/91 221
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advantage is that the cooling rate can be controlled by controlling the flow
of the liquid through the vest. They can be worn under protective clothing
and a SCBA. There is one model that is incorporated into a fully
encapsulating suit. The ice can be replenished without removing the suit.
D. CONCLUSION
There are many different types of personal cooling devices. At the end of this
section is a list of manufacturers and the types they make. When selecting a unit,
one main consideration is whether it is compatible with the other protective
equipment worn. Mobility, weight and duration of use must also be considered.
Worker acceptance is also an important consideration. Whatever device is used, it
must be remembered that the device reduces but doesn't eliminate the heat stress.
f-iim? connection
faoov t)»r.
F»w»mnf bcmon - top
imuuim; v«:
^UMnno cunon - txjoom
7 CAfl" v«H
£ F*4TkJ tCCASKK)'
•J,
~m^r*
J==^g^g ,
FIGURE 9
WATER FILLED ICE VEST
(Whole jacket is frozen prior to use) Used with
permission of National Draeger, Pittsburgh, PA.
6/91
222
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FIGURE 10
COOL VEST* Model 19.
(The back of unit has battery operated pump and pouch containing ice
and circulating water) Used with permission of ILC Dover,
Frederica, DE.
6/91
223
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X.
MANUFACTURERS AND SUPPLIERS OF PERSONAL COOLING DEVICES*
KEY:
A = airline cooling system
C = self contained circulating vest
W = water line cooling system
Encon Manufacturing Co.
13333 Northwest Freeway
Houston, TX 77040
713/462-4723
(A)
Fyrepel Products Inc.
P.O. Box 518
Newark, OH 43055
614/344-0391
(V, I)
ILC Dover
P.O. Box 26
Frederica, DE 19946
302/335-3911
(A, C, V, W)
Life Support Systems Inc.
1400 Stierlin Road
Mountain View, CA 94043
415/962-9800
(C)
Mine Safety Appliances
600 Penn Center Boulevard
Pittsburgh, PA 15235
412/273-5000
1-800-MSA-2222
(A, I)
National Draeger, Inc.
401 Parkway View Drive
Pittsburgh, PA 15205
412/787-8383
(I)
I = ice vest
V = vortex cooler
Racal Health & Safety, Inc.
Racal Airstream Division
7309 Grove Road, Frederick, MD 21701
301/695-8200
800/682-9500
(V)
Standard Safety Equipment (StaSafe)
431 North Quentin Road
Palatine, IL 60067
312/359-1400
(A)
Steele Incorporated
First and Washington
P.O. Box 7304
Kingston, WA 98346
206/297-4555
(I)
3M
220-7W
St. Paul, MN 55144
612/733-6234
(V)
Trusafe
9369 8th Avenue South
Seattle, WA 98108
206/762-7407
(I)
Wheeler Protective Apparel, Inc.
4330 W. Belmont
Chicago,IL 60641
312/685-5551
(A)
*Mention of a particular manufacturer or product does not imply endorsement by the U.S.
Environmental Protection Agency. Omission of a manufacturer or product is not
intentional.
6/91
224
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APPENDIX I
PERMEATION REFERENCES
1. Development of Performance Criteria for Protective Clothing Used Against Carcinogenic
Liquids. NIOSH, Technical Report No. 79-106. NTIS.
2. "A Discussion: Resistance of Butyl Rubber Gloves to the Penetration of
Aromatic Nitro and Amino Compounds". Amer. Ind. Hyg. Assoc. J. 39:314316 (1978).
3. Henry, N. W. Ill and C. N. Schlatter. "The Development of a Standard
Method for Evaluating Chemical Protective Clothing by Hazardous Liquids" (1981).
4. Lynch, A. L. "Protective Clothing", Handbook of Laboratory Safety. 2nd ed. (1971).
5. Middleton, H.W. Glove Corrosive Liquid Immersion and Permeability Study. No. GEPP-
322, General Electric Co., Neutron Devices Dept., P. O. Box 11508, St. Petersburg, FL
33733.
6. Nelson, G. O. and C. M. Wong. "Glove Permeation by Organic Solvents".
Amer. Ind. Hyg. Assoc. J., 42:217-225 (1981).
7. Permeation of Protective Garment Material by Liquid Halogenated Ethanes and a
Polychlorinated Biphenyl. NIOSH Publication 81-110 (1981).
8. Sansome, E. B. and U. B. Tewari. "The Permeability of Laboratory Gloves to Selected
Solvents". Amer. Ind. Hyg. Assoc. J. 39:164-174 (1978).
9. Weeks, R. W. Jr., and B. J. Dean. "Permeation of Methanolic Aromatic
Amine Solutions through Commercially Available Glove Materials". Amer.
Ind. Hyg. Assoc. J., 38:721-725 (1977).
10. Weeks, R. W. Jr., and M. J. McLeod. "Permeation of Protective Garment
Material by Liquid Benzene and by Tritiated Water". Amer. Ind. Hyg.
Assoc. J., 43:201-211 (1982).
11. Williams, J. R. "Permeation of Glove Materials by Physiologically Harmful Chemicals".
Amer. Ind. Hyg. Assoc. J., 40:877-882 (1979).
6/91 225
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APPENDIX II
DONNING AND DOFFING OF THE FULLY ENCAPSULATING SUIT
I. INTRODUCTION
In responding to episodes involving hazardous substances, it may be necessary for response
personnel to wear self-contained breathing apparatus (SCBA) and fully encapsulating suits
to protect against toxic environments. Donning/Doffing of both is a relatively simple task,
but a routine must be established and practiced frequently. Not only do correct procedures
help instill confidence in the wearer, they reduce the risk of exposure and the possiblity of
damage to the suit. It is especially important to remove the equipment systematically so as
to prevent or minimize the transfer of contaminants from suit to wearer.
The following procedures for donning/doffing apply to certain types of suits. They should
be modified if a different suit or extra boots and gloves are worn. These procedures also
assume that:
The wearer has been trained in the SCBA.
SCBA has been checked out.
Appropriate decontamination steps have been taken prior to removal of the suit or
other components.
Sufficient air is available for routine decontamination and doffing of suit.
Donning/doffing an encapsulating suit is more difficult if the user has to do it alone because
of the physical effort required. Also the possibility of wearer exposure to contaminants or
damaging the suit greatly increases. Therefore, assistance is needed in donning/doffing the
equipment.
II. DONNING
A. Before donning suit, thoroughly inspect for deficiencies that will decrease its
effectiveness as the primary barrier for protecting the body. Do not use any suit
with holes, rips, malfunctioning closures, cracked masks, etc. If suit contains a
hoodpiece, or a hard hat is worn, adjust it to fit user's head. If suit has a back
enclosure for changing air bottles, open it.
B. Use a moderate amount of talcum powder or cornstarch to prevent chafing and
increase comfort. Both also reduce rubber binding.
C. Use antifog on suit and mask facepieces.
6/91 227
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D. While sitting (preferably), step into legs, place feet nroperly, and gather suit around
waist.
E. While sitting (preferably), put on chemical-resistant, steel toe and shank boots over
feet of suit. Properly attach and affix suit leg over top of boot.
1. For one-piece suits with heavy-soled protective feetv wear leather or short
rubber safety boots inside suit.
2. Wear an additional pair of disposable boot protectors if necessary.
F. Put on SCBA airtank and harness assembly. Don facepiece and adjust it securely yet
comfortably. Do not connect breathing hose. Open valve to air tank. (The air tank
and harness assembly could also be put on before stepping into legs of suit).
G. Depending on type of suit:
1. Put on inner gloves.
2. For suits with detachable gloves, secure gloves to sleeves, if this has not
been done prior to entering the suit. (In some cases, extra gloves are worn
over suit gloves).
H. While standing, put arms into sleeves, and then head into hood of suit. The helper
pulls suit up and over SCBA, resting hood on top of SCBA, adjusting suit around
SCBA backpack and user's shoulders to assure unrestricted motion. To facilitate
entry into the suit, bend at the knees as hood is placed over wearer's head. Avoid
bending at the waist, as this motion tends to use up room in the suit rather that
provide slack. For a tall or stout person, it is easier to put on the hood of the suit
before getting into the sleeves.
I. Begin to secure suit by closing all fasteners until there is only room to connect the
breathing hose. Also, secure all belts and/or adjustable leg, head, and waist bands.
Connect breathing hose while opening main valve.
J. When breathing properly in SCBA, complete closing suit.
K. Helper should observe for a time to assure that wearer is comfortable and equipment
is functioning properly.
III. DOFFING
Exact procedures must be established and followed to remove the fully encapsulating suit and
SCBA. Adherence to these procedures is necessary to minimize or prevent contamination
(or possible contamination) of the wearer through contacting the outside surface of the suit.
The follo'wing procedures assume that before the suit is removed, it has been properly
decontaminated, considering the type and extent of contamination, and that a suitably attired
helper is available.
6/91 228
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A. Remove any extraneous or disposable clothing, boot covers, or gloves.
B. If possible, wearer kicks off chemical-resistant boots unassisted. To achieve this,
oversized boots are often selected. Otherwise, helper loosens and removes chemical-
resistant boots.
C. Helper opens front of suit to allow access to SCBA regulator. As long as there is
sufficient air pressure, hose is not disconnected.
D. Helper lifts hood of the suit over wearer's head and rests hood on top of SCBA air
tank. For a tall or stout person it is easier to remove the arms from the sleeves of
the suit prior to removing the hood.
E. Remove external gloves.
F. To minimize contact with contaminated clothing, helper touches only the outside of
the suit, and the wearer touches only the inside. Remove arms, one at a time, from
suit. Helper lifts suit up and away from SCBA back pack, avoiding any contact
between outside surface of suit and wearer's body. Helper lays suit out flat behind
wearer.
G. While sitting (preferably), remove both legs from suit.
H. After suit is completely removed, roll internal gloves off hands, inside out.
I. Walk to clean area and follow procedure for doffing SCBA.
J. Remove inner clothing, clean body thoroughly.
IV. ADDITIONAL CONSIDERATIONS
A. If work is at a very dirty site or the potential for contamination is extremely high,
wear disposable Tyvek or PVC coveralls over fully encapsulating suit. Make a slit
in back to fit around bulge of the SCBA back pack.
B. Wear clothing inside the suit appropriate to outside temperatures. Even in hot
weather, wear long cotton underwear, which absorbs perspiration and acts as a wick
for evaporation, thus aiding body cooling. Long underwear also protects skin from
contact with hot surface of suit, reducing the possibility of burns in hot weather.
C. Monitor wearer for heat stress.
D. If a cooling device is used, modify donning/doffing procedure.
E. If low-pressure warning alarm sounds signifying approximately 5 minutes of air
remaining, follow these procedures:
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1. Quickly hose off suit and scrub especially around entrance/exit zipper.
(Remove any disposable clothing.)
2. Open zipper sufficiently to allow access to regulator and breathing hose. A
3. Disconnect breathing hose from regulator as main valve is closed.
4. Immediately attach canister for vapor, acid gas, dust, mist, or fume to
breathing hose. This provides protection against contaminants still present.
5. Continue doffing suit as in steps A through J of previous section. Take extra
care to avoid contaminating helper and wearer.
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SECTION 5
PERSONNEL PROTECTION EQUIPMENT
PART 7
OSHA Regulations for Personal Protective Equipment
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
ANSI - American National Standards Institute
1430 Broadway
New York, NY 10018
6/91 231
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OCCUPATIONAL SAFETY AND HEALTH l»10-Subpart I
STANDARDS AND INTERPRETATIONS
PART 1910
OCCUPATIONAL SAFETY AND HEALTH STANDARDS
SUBPART I—PERSONAL PROTECTIVE EQUIPMENT
1910.132 General requirements.
1910.133 Eye and face protection.
1910.134 Respiratory protection.
1910.135 Occupational head protection.
1910.136 Occupational foot protection.
1910.137 Electrical protective devices.
1910.138 Additional delay in effective date.
1910.139 Sources of standards.
1910.140 Standards organizations.
1910-Subpart I
233
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1910.182
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
SUBPART I—PERSONAL PROTECTIVE EQUIPMENT
1910.132—GENERAL REQUIREMENTS
(a) Application.
Protective equipment, including- personal
protective equipment for eyes, face, head, and
extremities, protective clothing, respiratory
devices, and protective shields and barriers,
shall be provided, used, and maintained in a
sanitary and reliable condition wherever it is
necessary by reason of hazards of processes
or environment, chemical hazards, radiologi-
cal hazards, or mechanical irritants encoun-
tered in a manner capable of causing injury
or impairment in the function of any part of
the body through absorption, inhalation or
physical contact.
(b) Employee-owned equipment.
Where employees provide their own protec-
tive equipment, the employer shall be respon-
sible to assure its adequacy, including proper
maintenance, and sanitation of such equip-
ment.
(c) Design.
All personal protective equipment shall be
of safe design and construction for the work
to be performed.
1910.133—EYE AND FACE PROTECTION
(a) General.
(1) Protective eye and face equipment shall
"be required where there is a reasonable
probability of injury that can be prevented
by such equipment. In such cases,
employers shall make conveniently avail-
able a type of protector suitable for the work
to be performed, and employees shall use
such protectors. No unprotected person
shall knowingly be subjected to a hazardous
environmental condition. Suitable eye pro-
tectors shall be provided where machines
or operations present the hazard of flying
objects, glare, liquids, injurious radiation,
or a combination of these hazards.
(2) Protectors shall meet the following
minimum requirements:
(i) They shall provide adequate protection
against the particular hazards for which
they are designed.
(ii) They shall be reasonably confortable
mo.i33U)(3)(i)
when worn under the designated condi-
tions.
(iii) They shall fit snugly and shall not
unduly interfere with the movements of
the wearer.
(iv) They shall be durable.
(v) They shall be capable of being disin-
fected.
(vi) They shall be easily cleanable.
(vii) Protectors should be kept clean and
in good.repair.
(3) Persons whose vision requires the use
of corrective lenses in spectacles, and who
are required by this standard to wear eye
protection, shall wear goggles or spectacles
of one of the following types:
(i) Spectacles whose protective lenses pro-
vide optical correction.
234
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OCCUPATIONAL SATrTY AND HEALTH
m0.133t»X3Ktl)
STANDARDS AND INTERPRETATIONS
(ii) Goggles that can be worn over correc-
tive spectacles without disturbing the
adjustment of the spectacles.
(iii) Goggles that incorporate corrective
lenses mounted behind the protective
lenses.
(4) Every protector shall be distinctly
marked to facilitate identification only of
the manufacturer.
(5) When limitations or precautions are
indicated by the manufacturer, they shall
be transmitted to the user and care taken
to see that such limitations and precautions
are strictly observed.
(6) Design, construction, testing, and use of
devices for eye and face protection shall be
in accordance with American National
Standard for Occupational and Educational
Eye and Face Protection. Z87.1-1968.
1910.134—RESPIRATORY PROTECTION
(a) Permissible practice.
(1) In the control of those occupational dis-
eases caused by breathing air contaminated
with harmful dusts, fogs, fumes, mists,
pases, smokes, sprays, or vapors, the pri-
mary objective shall be to prevent at-
mospheric contamination. This shall be
accomplished as far as feasible by accepted
engineering control measures (for example,
enclosure or confinement of the operation,
general and local ventilation, and substitu-
tion of less toxic- materials). When effective
engineering: controls are not feasible, or
while they are being instituted, appropriate
respirators shall be used pursuant to the
following requirements.
(2) Respirators shall be provided by the
employer when such equipment is neces-
sary to protect the health of the employee.
The employer shall provide the respirators
which are applicable and suitable for the
purpose intended. The employer shall be
responsible for the establishment and
maintenance of a respiratory protective
program which shall include the require-
ments outlined in paragraph (b) of this sec-
tion.
(3) The employee shall use the provided
respiratory protection in accordance with
instructions and training received.
(b) Requirements for a minimal acceptable
program.
(7) Written standard operating procedures
38
governing the selection and use of
respirators shall be established.
(2) Respirators shall be selected on the basis
of hazards to which the worker is exposed.
(3) The user shall be instructed and trained
in the proper use of respirators and their
limitations.
(4) Removed
(5) Respirators shall be regularly cleaned and
disinfected. Those used by more than one
worker shall be thoroughly cleaned- and disi-
nfected after each use.
(6) Respirators shall be stored in a conven-
ient, clean, and sanitary location.
(7) Respirators used routinely shall be
inspected during cleaning. Worn or
deteriorated parts shall be replaced. Res-
pirators for emergency use such as self-
contained devices shall be thoroughly
inspected at least once a month and after
each use.
(8) Appropriate surveillance of work area
conditions and degree of employee exposure
or stress shall be maintained.
1910.154(bX8)
235
-------
mo.is«bx»)
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(9) There shall be regular inspection and
evaluation to determine the. continued
effectiveness of the program.
(10) Persons should not be assigned to tasks
requiring use of respirators unless it has
been determined that they are physically
able to perform the work and use the equip-
ment. The local physician shall determine
what health and physical conditions are
pertinent. The respirator user's medical
status should be reviewed periodically (for
instance, annually).
(11) Approved or accepted respirators shall
be used when they are available. The
respirator furnished shall provide adequate
respiratory protection against the par-
ticular hazard for which it is designed in
accordance with standards established by
competent authorities. The U.S. Depart-
ment of Interior, Bureau of Mines, and the
U.S. Department of Agriculture are recog-
nized as such authorities. Although
respirators listed by the U.S. Department
of Agriculture continue to be acceptable for
protection against specified pesticides, the
U.S. Department of the Interior, Bureau of
Mines, is the agency now responsible for
testing and approving pesticide respirators.
(c) Selection of respirators.
Proper selection of respirators shall be
made according to the guidance of American
National Standard Practices for Respiratory
Protection Z88.2-1969.
(d) Air quality.
(1) Compressed air, compressed oxygen,
liquid air, and liquid oxygen used for respi-
ration shall be of high purity. Oxygen shall
meet the requirements of the United States
Pharmacopoeia for medical or breathing
oxygen. Breathing air shall meet at least
the requirements of the specification for
Grade D breathing air as described in Com-
pressed Gas Association Commodity Specifi-
cation G-7.1-1966. Compressed oxygen shall
not be used in supplied-air respirators or
in open circuit self-contained breathing
apparatus that have previously used com-
pressed air. Oxygen must never be used
with air line respirators.
(2) Breathing air may be supplied to
respirators from cylinders or air compres-
sors.
(i) Cylinders shall be tested and main-
tained as prescribed in the Shipping Con-
tainer Specification Regulations of the
Department of Transportation (49 CFR
Part 178).
(ii) The compressor for supplying air shall
be equipped with necessary safety am!
standby devices. A breathing air-type
compressor shall be used. Compressors
shall be constructed and situated so as
to avoid entry of contaminated air into
the system and suitable in-line air purify-
ing sorbent beds and filters installed to
further assure breathing air quality. A
receiver of sufficient capacity to enable
the respirator wearer to escape from a
contaminated atmosphere in event of
compressor failure, and alarms to
indicate compressor failure and overheat-
ing shall be installed in the system. If an
oil-lubricated compressor is used, it shall
have a high-temperature or carbon
monoxide alarm, or both. If only a high-
temperature alarm is used, the air from
the compressor shall be frequently tested
for carbon monoxide to insure that it
meets the specifications in subparagraph
(1) of this paragraph.
(3) Air line couplings shall be incompatible
with outlets for other gas systems to pre-
vent inadvertent servicing of air line
respirators with nonrespirable gases or
oxygen.
(4) Breathing gas containers shall be
marked in accordance with American
National Standard Method of Marking Port-
able Compressed Gas Containers to Identify
the Material Contained, Z48.1-1954;
Federal Specification BB-A-1034a, June 21.
1968, Air, Compressed for Breathing Pur-
poses; or Interim Federal Specification
GG-B-00675b, April 27, 1965, Breathing
Apparatus, Self-Contained.
(e) Use of respirators.
(1) Standard procedures shall be developed
for respirator use. These should include all
1910.1J4(eKl)
236
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OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
information and guidance necessary for
their proper selection, use, and care. Possi-
ble emergency and routine uses of
respirators should be anticipated and
planned for.
(2) The correct respirator shall be specified
for each job. The respirator type is usually
specified in the work procedures by a qual-
ified individual supervising the respiratory
protective program. The individual issuing
them shall be adequately instructed to
insure that the correct respirator is issued.
(3) Written procedures shall be prepared
covering safe use of respirators in danger-
ous atmospheres that might be encountered
in normal operations or in emergencies. Per-
sonnel shall be familiar with these proce-
dures and the available respirators.
(!) In areas where the wearer, with failure
of the respirator, could be overcome by
a toxic or oxygen-deficient atmosphere,
at least one additional man shall be pres-
ent. Communications (visual, voice, or
signal line) shall be maintained between
both or all individuals present. Planning
shall be such that one individual will be
unaffected by any likely incident and
hnve the proper rescue equipment to be
able to assist the o£her(s) in case of emer-
gency.
(ii) When self-contained breathing
apparatus or hose masks with blowers are
used in atmospheres immediately dan-
gerous to life or health, standby men must
be present with suitable rescue equip-
ment.
(iii) Persons using air line respirators in
atmospheres immediately hazardous to
life or health shall be equipped with
safety harnesses and safety lines for lift-
ing or removing persons from hazardous
atmospheres or other and equivalent pro-
visions for the rescue of persons from
hazardous atmospheres shall be used. A
standby man or men with suitable self-
36
contained breathing apparatus shall be
at the nearest fresh air base for emer-
gency rescue.
(4) Respiratory protection is no better than
the respirator in use, even though it is worn
conscientiously. Frequent random inspec-
tions shall be conducted by a qualified
individual to assure that respirators are
properly selected, used, cleaned, and main-
tained.
(5) For safe use of any respirator, it is essen-
tial that the user be properly instructed in
its selection, use, and maintenance. Both
supervisors and workers shall be so
instructed by competent persons. Training
shall provide the men an opportunity to
handle the respirator, have it fitted prop-
erly, test its face-piece-to-face seal, wear it
in normal air for a long familiarity period,
and, finally, to wear it in a test atmosphere.
(i) Every respirator wearer shall receive
fitting instructions including demonstra-
tions and practice in how the respirator
should be worn, how to adjust it, and how
to determine if it fits properly. Res-
pirators shall not be worn when condi-
tions prevent a good face seal. Such condi-
tions maybe a growth of beard, sideburns,
a skull cap that projects under the
facepiece, or temple pieces on glasses.
Also, the absence of one or both dentures
can seriously affect the fit of a facepiece.
The worker's diligence in observing these
factors shall be evaluated by periodic
check. To assure proper protection, the
facepiece fit shall be checked by the
wearer each time he puts on the
respirator. This may be done by following
the manufacturer's facepiece fitting
instructions.
(ii) Providing respiratory protection for
individuals wearing corrective glasses is
a serious problem. A proper seal cannot
be established if the temple bars of eye
glasses extend through the sealing edge
of the full facepiece. As a temporary
measure, glasses with short temple bars
or without temple bars may be taped to
the wearer's head. Wearing of contact
lenses in contaminated atmospheres with
a respirator shall not be allowed. Systems
have been developed for mounting correc-
mc.l34UX5XU)
237
-------
1910.1J4UK5XU)
OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
live lenses inside full facepieces. When a
workman must wear corrective lenses as
part of the facepiece, the facepiece and
lenses shall he fitted by qualified in-
dividuals to provide pood vision, comfort.
and a gas-tight seal.
(iii) If corrective spectacles or goggles are
required, they shall be worn so as not to
affect the fit of the facepiece. Proper
selection of equipment will minimize or
avoid this problem.
(f) Maintenance and care of respirators.
(1) A program for maintenance and care of
respirators shall be adjusted to the type of
plant, working conditions, and hazards
involved, and shall include the following
ba.sic services:
(i) Inspection for defects (including a leak
check),
(ii) Cleaning and disinfecting,
(iii) Repair,
(iv) Storage
Equipment shall be properly maintained to
retain its original effectiveness.
(2)
(!) All respirators shall be inspected
routinely before and after each use. A
respirator that is not routinely used but
•s kept ready for emergency use shall be
spected after each use and at least
donthly to assure that it is in satisfactory
working condition.
Self-contained breathing apparatus
be inspected monthly. Air and
oxygen cylinders shall be fully charged
according to the manufacturer's instruc-
tions. It shall be determined that the reg-
ulator ar>'' warning devices function prop-
erly.
(iii) Respirator inspection shall include a
check of the tightness of connections and
the condition of the facepiece, heacl-
bands, valve;-, connecting tube, and canis-
ters. Rubber or elastomer parts shall he
inspected for pliability and signs of
deterioration. Stretching and manipulat-
ing rubber or elastomer parts with a mas-
saging action will keep them pliable and
flexible and prevent them from taking a
set during storage.
(iv) A record shall be kept of inspection
dates and findings for respirators main-
tained for emergency use.
(3) Routinely used respirators shall be col-
lected, cleaned, and disinfected as fre-
quently as necessary to insure that proper
protection is provided for the wearer. Respira-
tors maintained for emergency use shall be
cleaned and disinfected after each use.
(4) Replacement or repairs shall be done
only by experienced persons with parts
designed for the respirator. No attempt
shall be made to replace components or to
make adjustment or repairs beyond the
manufacturer's recommendations. Reduc-
ing or admission valves or regulators shall
be returned to the manufacturer or to a
trained technician for adjustment or repair.
(5)
(i) After inspection, cleaning, and neces-
sary repair, respirators shall be stored to
protect against dust, sunlight, heat,
extreme cold, excessive moisture, or
damaging chemicals. Respirators placed
at stations and work areas for emergency
use should be quickly accessible at all
times and should be stored in compart-
ments built for the purpose. The compart-
ments should be clearly marked.
Routinely used respirators, such as dust
respirators, may be placed in plastic bags.
Respirators should not be stored in such
places as lockers or tool boxes unless they
are in carrying cases or cartons.
36
238
-------
OCCUPATIONAL SAFETY AND HEALTH
(ii) Respirators should be packed or stored
so that the facepiece and exhalation valve
will rest in a normal position and function
will not be impaired by the elastomer set-
ting in an abnormal position.
(iii) Instructions for proper storage of
emergency respirators, such as gas masks
and self-contained breathing apparatus.
are found in "use and care" instructions
usually mounted inside the carrying case
lid.
(g) Identification of gat mask canisters.
(I) The primary means of identifying a gas
mask canister shall be by means of properly
worded labels. The secondary means of iden-
tifying a gas mask canister shall be by a
color code.
(2) All who issue or use gas masks falling
within the scope of this section shall see that
all gas mask canisters purchased or used
by them are properly labeled and colored
in accordance with these requirements
before they are placed in service and that
the labels and colors are properly main-
tained at all times thereafter until the
canisters have completely served their pur-
pose.
(3) On each canister shall appear in bold let-
ters the following:
(0
Canister for
(Name for atmospheric contaminant)
or
Type N Gas Mask Caniiter
(ii) In addition, essentially the following:
wording shall appear beneath the appro-
priate phase on the canister label: "For
STANDARDS AND INTERPRETATIONS
respiratory protection in atmospheres
containing not more tnan per-
cent bv volume of
(4) Canisters having a special high-effi-
ciency filter for protection against
radionuclides and other highly toxic par-
ticulates shall be labeled with & statement
of the type and degree of protection afforded
by the filter. The label shall be affixed to
the neck end of. or to the gray stripe which
is around and near the top of, the canister.
The degree of protection shall be marked
as the percent of penetration of the canister
by a 0.3-micron-diameter dioctyl phthalate
(DOP) smoke at a flow rate of 85 liters per
minute.
(5) Each canister shall have a label warning
that gas masks should be used only in
atmospheres containing sufficient oxygen
to support life (at least 16 percent by
volume), since gas mask canisters are only
designed to neutralize or remove contami-
nants from the air.
(6) Each gas mask canister shall be painted
a distinctive color or combination of colors
indicated in Table 1-1. All colors used shall
be such that they are clearly identifiable
by the user and clearly distinguishable from
one another. The color coating used shall
offer a high degree of resistance to chipping,
scaling, peeling, blistering, fading, and the
effects of the ordinary atmospheres to
which they may be exposed under normal
conditions of storage and use. Appro-
priately colored pressure sensitive tape
may be used for the stripes.
Chaact7
239
-------
U10.1J4 OCCUPATIONAL SAJTTY AND HEALTH
STANDARDS AND INTERPRETATIONS
TABLT I-l
Atmoipticric contaminants to be protected
against Colors assigned*
Acid gases White.
Hydrocyanic acid gas Whit* with ^-inch green stripe completely
around the canister ne&r the bottom.
Chlorine gas White with y^-lnch yellow stripe completely
around the canister near the bottom.
Organic vapors Black.
Ammonia gas Green.
Acid gases and ammonia gas Green with %-lnch white stripe completely
around the canister near the bottom.
Carbon monoxide Blue.
Acid gases and organic vapors Yellow.
Hydrocyanic acid gas and chloroplcrtn vapor. Yellow with »^-lnch blue stripe completely
around the canister near the bottom.
Acid gases, organic vapors, and ammonia Brown.
gases.
Radioactive materials, excepting tritium and Purple (Magenta).
noble gases.
Particulates (dusts, fumes, mists, fogs, or Canister color Tor contaminant, as designated
smokes) in combination with any of the above, with ^-Inch gray stripe completely
above gases or vapors. around the canister near the top.
All of the above atmospheric contaminants Red with %-lnch gray stripe completely
around the canister near the top.
•Gray shall not be assigned as the main color for a canister designed to remove acids or
vapors.
NOTE: Orange shall be used as a complete body, or stripe color to represent gases not
included in this table. The user will need to refer to the canister label to determine the
degree of protection the canister will afford.
1910.135—OCCUPATIONAL HEAD PROTECTION
Pii.ii7.ets for the protection of heads of occu- requirements and specifications established
pational workers from impact and penetration in American National Standard Safety
from falling and flying- objects and from Requirements for Industrial Head Protection,
limited electric shock and burn shall meet the Z89.1-1969.
1910.136— OCCUPATIONAL FOOT PROTECTION
Safety-toe footwear for employees shall American National Standard for Men's
meet the requirements and specifications in Safety-Toe Footwear, Z41. 1-1967.
1910-13«
22
240
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SECTION 5
PERSONAL PROTECTIVE EQUIPMENT
PART 8
MANUFACTURERS AND SUPPLIERS OF PERSONNEL PROTECTIVE GEAR
I.
RESPIRATOR AND PROTECTIVE CLOTHING MANUFACTURER ADDRESSES
A-Best Products
3865 W. 150th Street
Cleveland, OH 44111
216/941-9400
American Optical Corp.
Safety Products Division
14 Mechanic Street
Southbridge, MA 01550
617/765-9711
Andover Industries, Inc.
10 Railroad Street
Andover, MA 01810
617/475-1302
Barry Manufacturing Co., Inc.
920 Lakeshore Road East
Mississauga, Ontario, Canada
416/274-3691
Cesco Safety Products
100 E. 16th Street
P.O. Box 1237
Kansas City, MO 64141
816/842-8500
Charkate Glove and Specialty Co.
130 W. 10th Street
Huntington Station, NY 11746
516/427-1802
800/221-0224
Colonial Glove and Garmet
54 Penataquit Avenue
Bay Shore, NY 11706
516/968-8888
Cosmasec
Drawer 10
Niblic Road
Enfield, CT 06082
203/741-2207
Bata Shoe Company, Inc.
Industrial Products Division
Belcamp, MD 21017
301/272-2000
Bendix Corp.
12345 Starkey Road
Largo, FL 33543
813/536-6523
Best Manufacturing Co.
Edison Street
Menlo, GA 30713
404/862-2302
Dayton Flexible Products
2210 Arbor Blvd.
Dayton, OH 45439
513/298-7511
Defense Apparel
286 Murphy Road
Hartford, CT 06114
800/243-3847
The DeVilbis Company
300 Phillips Avenue
P.O. Box 913
Toledo, OH 43692
419/470-2169
6/91
241
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Boss Manufacturing Co.
221 West First Street
Kewanee, IL 61443
309/852-2131
E. D. Bullard Company
2680 Bridgeway
Sausalito, CA 94965
415/332-0410
Edmont Division of Becton,
Dickinson, and Company
1300 Walnut Street
Coshocton, OH 43812
614/622-4311
Encon Manufacturing Co.
4919 Dickson Street
Houston, TX 77007
713/462-4723
Expendables, Inc.
2945 Congressman Lane
Dallas, TX 75220
214/350-6783
Frommelt Industries, Inc.
Safety Products Division
P.O. Box 658
2455 Kerper Boulevard
Dubuque, IA 52001
319/589-2736
Fyrepel Products, Inc.
P.O. Box 518
Newark, OH 43055
614/344-0391
Glendale Optical Co., Inc.
130 Crossway Park Drive
Woodbury, NY 11797
516/921-5800
Globe Safety Products, Inc.
125 Sunrise Place
Dayton, OH 45407
513/2247468
Disposables, Inc.
14 Locust Street
Manhasset, NY 11030
516/627-4554
Durafab, Inc.
P.O. Box 658
Cleurne, TX 76031
817/645-8851
W. L. Gore & Assoc.
Box 1130
Elkton, MD 21921
301/392-3700
Granet Div., ESB, Inc.
25 Loring Drive
P.O. Box 588
Framingham, MA 01701
617/875-3521
H.S. Cover Company
107 E. Alexander Street
Buchanan, MI 49107
616/695-9663
Hodgeman
207 E. Wolf Street
Yorkville, IL 60560
312/553-0100
International Latex, Inc.
213 Hanna Building
Cleveland, OH 44115
216/523-1000
International Safety Instruments, Inc.
16717 Smoketree Street
Hesperia, CA 92345
619/244-9404
ILC Dover
P.O., Box 266
Frederica, DE 19946
302/335-3911
6/91
242
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Glover Latex, Inc.
514 South Rose Street
Anaheim, CA 02805
714/535-8920
Jomac Products, Inc.
863 Easton Road
Warrington, PA 18976
215/343-0800
Kappler Disposables, Inc.
Post Office Drawer 218
Guntersville, AL 35976
205/582-2195
Keller Glove Mfg. Co.
Route 611
Plumsteadville, PA 18949
215/343-1135
LRC Safety Products (Surety Rubber)
Rt. 46 West
Little Falls, NJ 07424
201/256-5500 Ext.227
LaCrosse Rubber Mills Co.
Indian Hill
LaCrosse, WI 54601
608/782-3020
Lehigh Safety Shoe Co.
1100 E. Main Street
Endicott, NY 13760
607/754-7980
Life Support System, Inc.
1400 Stierlin Road
Mountain View, CA 94043
415/962-9800
Lion Uniform, Inc.
Industrial Safety Division
P.O. Box 14165
Northridge Branch
Dayton, OH 45414
513/278-6531
800/543-9698
Iron Age Shoe Company
2408 Woodmere Drive
Pittsburgh, PA 15205
412/922/7000
Jordan David Safety Products
P.O. Box 400
Warrington, PA 18976
215/343-6470
Mar-Mac Mfg. Co.,Inc.
Box 278
McBee, SC 29101
803/335-8211
Melco, Inc.
6603 Printz Blvd.
Wilmington, DE 19809
800/441-9749
Mine Safety Appliances
600Penn Center Blvd.
Pittsburgh, PA 15235
412/273-5000
Monte Glove Company
Monte Lane
Maben, MI 38750
601/263-5353
National Draeger, Inc.
401 Parkway View Drive
Pittsburgh, PA 15205
412/787-8383
National Safety Wear, Inc.
18 East Main Street
Malone, NY 12953
518/483-7246
Neese Industries, Inc.
P.O. Box 628
Gonzales, LA 70737
504/644-6553
6/91
243
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Magid Glove Mfg. Co.
2060 N. Kolmar Avenue
Chicago, IL 60639
312/384-2070
800/621-8010
Oak Medical Supply Company
The Oak Rubber Company
219 S. Sycamore Street
Ravenna, OH
216/296-3416
Plastex Protective Products, Inc.
9-T Grand Street
Garfield, NJ 02706
201/779-4946
Plastimayd Corporation
2216 S. E. Seventh Avenue
Portland, OR 97214
503/232-5101
Playtex Industrial Gloves
700 Fairfield Avenue
Stamford, CT 06902
203/356-8000
Protexall Company
Box 307
Green Lake, WI 54941
414/294-6511
Pulmosan Safety Equipment Corp.
30-48 Linden Place
Flushing, NY 111354
212/939-3200
Racal Airstream, Inc.
7309-A Grove Road
Frederick, MD 21701
301/695-8200
Rainfair,Inc.
P.O. Box 1647
Racine, WI 53401
800/558-5990
North Safety Equipment
(formerly Norton)
Division of Siebe North
2000 Plainfield Pike
Cranston, RI 02920
401/943-4400
Pioneer Industrial Products
1831 Olive Street
St. Louis, MO 63103
314/621-7788
Record Industrial Company
P.O. Box 407
King of Prussia, PA 19406
215/337-2500
Red Kap Industries
749 Massman Drive
Nashville, TN 37210
615/889-6800
800/251-1068
Renco Corporation
2060 Fairfax Avenue
Cherry Hill, NJ 08003
609/424-5755
Rexnord Safety Products, Inc.
(Biomarine)
45 Great Valley Corporation Center
Malvern, PA 19355
215/647-7200
Safety Clothing & Equipment Co.
4900 Campbell Road
Willoughby, OH 44094
216/946-1880
Scott Aviation
225 Erie Street
Lancaster, NY 14086
716/683-5100
Sijal, Inc.
P.O. Box 205
205 Roesch Avenue
Oreland, PA 19075
215/572-0216
6/91
244
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Ranger Rubber Company
Division of Endicott Johnson
1100 East Main Street
Endicott, NY 13760
607/757-4260
Standard Safety Equipment
(StaSafe)
Box 188
431 N. QuentinRoad
Palatine, IL 60067
312/359-1400
Steel Grip Safety
Apparel Co., Inc.
700 Garfield Street
Box 833
Danville, IL 61832
217/442-6240
3M/Occupational Health & Safety
Products Division
220-7W 3M Center
St. Paul, MN 55144
612/733-6234
Tingley Rubber Company
P.O. Box 100
South Plainfleld, NJ 07080
201/757-7474
Trades Company
100 Cabot Street
Holyoke, MA 01040
413/533-7141
United States Safety Service Co.
1535 Walnut Street
P.O. Box 1237
Kansas City, MO 64108
816/842-8500
Vidaro Corporation
333 Martinel Drive
P.O. Box 535
Kent, OH 44240
216/673-7413
Wheeler Protective Apparel,Inc.
224 W. Huron Street
Chicago, IL 60610
312/787-1156
Willson Safety Products
P.O. Box 622
Reading, PA 19603
Survivair Division
U.S. Divers Corporation
3323 W. Warner Avenue
Santa Ana, CA 92702
714/540-8010
6/91
245
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SECTION 6
REFERENCES AND GLOSSARY
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SECTION 6
REFERENCES AND GLOSSARY
PARTI
REFERENCES AND RESOURCES
I. INTRODUCTION
This list provides the titles of references and organizations which may be of value to those
responding to hazardous material incidents. Other resources are available which are not names
here. This list can be expanded based on personal preferences and requirements.
The references are categorized by subject. The title, author, publisher, and place of publication
are given for each. The year of publication is not always given because many are revised
annually. The user should attempt to obtain the most recent edition.
The last section lists sources of these references as well as other information that might be useful.
Usually, these agencies or associations will provide a catalogue on request. Where available,
phone number are listed.
Items identified with an asterisk (*) may be particularly useful in "first response" situations.
II. REFERENCES
A. Industrial Hygiene (Air Sampling and Monitoring, Respiratory Protection, Toxicology).
1. Air Sampling Instruments for Evaluation of Atmospheric Contamin- ants,
American Conference of Governmental Industrial Hygienists, Cincinnati, OH.
2. Basic Industrial Hygiene. Richard Brief, American Industrial Hygiene
Association, Akron, OH.
3. Direct Reading Calorimetric Indicator Tubes Manual. American Industrial
Hygiene Association, Akron, OH.
4. Documentation of the Threshold Limit Values (TLV). American Conference of
. Governmental Industrial Hygienists, Cincinnati, OH.
5. Fundamentals of Industrial Hygiene. National Safety Council, Chicago, IL.
6. Health Aspects of the Disposal of Waste Chemicals. Grisham, J.W.,
Pergamon Press.
7. The Industrial Environment-Its Evaluation and Control, National Institute for
Occupational Safety and Health, Rockville, MD.
1
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8. Industrial Hygiene and Toxicology. Frank A. Patty, John Wiley and Sons,
Inc., New York, NY.
9. Industrial Toxicology - Safety and Health in the Workplace. Williams and
Burson, ACGIH.
10. Manual of Recommended Practice for Combustible Gas Indicators and
Portable. Direct Reading Hydrocarbon Detectors. American Industrial
Hygiene Association, Akron, OH.
11. NIOSH Manual of Analytical Methods. Volumes 1-7. NIOSH, Department of
Health and Human Services, Cincinnati, OH.
12. NIOSH/OSHA Pocket Guide to Chemical Hazards. DHHS No. 85-114,
NIOSH, Department of Health and Human Services, Cincinnati, OH.
13. Occupational Health Guidelines for Chemical Hazards. DHHS No. 81-123,
NIOSH, Department of Health and Human Services, Cincinnati, OH.
14. Registry of Toxic Effects of Chemical Substances. DHHS No. 83107, National
Institute for Occupational Safety and Health, Rockville, MD.
15. Respiratory Protective Devices Manual. American Industrial Hygiene
Association, Akron, OH.
16. TLVs Threshold Limit Values and Biological Exposure Indices (Threshold
Limit Values for Chemical Substances and Physical Agents in the Workroom
Environment). American Conference of Governmental Industrial Hygienists,
Cincinnati, OH.
17. Toxicology - The Basic Science of Poisons. John Doull, Curtis D. Klaasen and
Mary O. Amdur, Macmillan Publishing Co., New York, NY (1980).
B. Chemical Data
1. Chemical Hazard Response Information System (CHRIS). U.S. Coast Guard,
Washington, DC. Commandant Instruction M. 16565.12A.
2. CHRIS - A Condensed Guide Chemical Hazards. U.S. Coast Guard,
Commandant Instruction M16565.11a.
3. Chemical Hazards of the Workplace. Proctor and Hughes, J. B. Lippincott
Company.
4. Chemistry of Hazardous Materials. Eugene Meyer, Prentice-Hall, Englewood
Cliffs, NJ.
5. Clinical Toxicology of Commercial Products. Gosselin, R. E., William and
Wilkins.
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* 6. The Condensed Chemical Dictionary. G. Hawley, Van Nostrand
Reinhold Co., New York, NY.
7. CRC Handbook of Chemistry and Physics. CRC Press-Boca Raton, FL.
* 8. Dangerous Properties of Industrial Materials. N. Irving Sax, Van Nostrand
Reinhold Co., New York, NY.
* 9. Effects of Exposure to Toxic Gases. Matheson.
* 10. Emergency Handling of Hazardous Materials in Surface Transpor- ation.
Student, P.J., Bureau of Explosives, Association of American Railroads.
11. Farm Chemicals Handbook. Farm Chemicals Magazine, Willoughby, OH
* 12. Firefighter's Handbook of Hazardous Materials. Baker, Charles J., Maltese
Enterprises, Indianapolis, IN.
* 13. Fire Protection Guide to Hazardous Materials. National Fire Protection
Association, Boston, MA.
14. Handbook of Chemical Property Estimation Methods. Lyman, W.J., Reehl, W.
F., and Rosenblatt, D.H.; McGraw Hill Book Company.
15. Handbook of Environmental Data on Organic Chemicals.Verschueren. K., Van
Nostrand Reinhold Co.
16. Handbook of Reactive Chemical Hazards. Bretherick, L., Butter worths, Boston,
MA.
17. Handbook of Toxic and Hazardous Chemicals. Sittig, Marshal, Noyes
Publications.
18. Hazardous Materials Handbook. Meidl, J.H., Glencoe Press.
19. Hygienic Guides. American Industrial Hygiene Association, Akron, OH.
20. The Merck Index. Merck and Co., Inc., Rahway, NJ.
21. Toxic and Hazardous Industrial Chemicals Safety Manual. The International
Technical Information Institute, Tokyo, Japan.
C. EPA Methods Manuals for Sampling and Analysis
1. Biological Field and Laboratory Methods for Measuring the Quality of
Surface Water and Effluents. EPA-670/4-73-001.
2. Emergency Drum Handling at Abandoned Dump SitesJ EPA Contract No. 68-
03-3113.
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3. EPA Solid Waste Manual. Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods. SW-846 (May 1980).
4. Handbook for Analytical Quality Control in Water and Waste-water Laboratories.
EPA-600/4-79-019 (March 1979).
5. Methods of Chemical Analysis of Water and Wastes. EPA-600/479020
(March 1979).
6. Microbiological Methods for Monitoring the Environment, Water and Wastes.
EPA-600/8-78-017 (December 1978).
7. Procedures Manual for Ground water Monitoring at Solid Wastes Disposal
Facilities. EPA-530/SW-611 (August 1977).
D. Safety and Personnel Protection
1. Best's Safety Directory. A.M. Best Co., Oldwick, NJ.
2. CRC Handbook of Laboratory Safety. Norman V. Steere, CRC Press, Boca
Raton, FL.
3. Fire Protection Handbook. National Fire Protection Association, Quincy, MA.
4. Flammable Hazardous Substances Emergency Response Handbook: Control
and Safety Procedures. EPA Contract No. 68-03-3014.
5. FM Approval List, Factory Mutual, Norwood, MA.
* 6. Guidelines for the Selection of Chemical Protective Clothing. Vol. 1: Field
Guide. A.D. Schwope, P.P. Costas, J.O. Jackson, D. J. Weitzman, Arthur D.
Little, Inc., Cambridge, MA (March 1983).
7. 1 Guidelines for the Selection of Chemical Protective Clothing. Volume 2:
Technical and Reference Manual. A.D. Schwope, P.P. Costas, J.O. Jackson,
D.J. Weitzman, Arthur D. Little, Inc., Cambridge, MA (March 1983).
8. Handling Radiation Emergencies. Purington and Patterson, NFPA.
9. Hazardous Materials Injuries. A Handbook for Pre-Hospital Care. Douglas R.
Stutz, Robert C. Ricks, Michael F. Olsen, Bradford Communications Corp.,
Greenbelt, MD.
10. National Safety Council Safety Sheets. National Safety Council, Chicago, IL.
11. NIOSH Certified Equipment List. U.S. Dept. of Health and Human Services.
12. Personal Protective Equipment for Hazardous Materials Incidents: A Selection
Guide. NIOSH, U. S. Department of Health and Human Services.
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13. Protecting Health and Safety at Hazardous Waste Sites: An Overview. U.S.
Environmental Protection Agency.
14. Radiation Protection - A Guide for Scientists and Physicians. Shapiro, Jacob,
Harvard University Press, Cambridge, MA.
15. Radiological Health Handbook. U.S. Dept. of Health, Education and Welfare.
* 16. Radiological Health - Preparedness and Response in Radiation Accidents.
U.S. Dept. of Health and Human Services.
17. A Review of the Department of Transportation Regulations for Transportation
of Radioactive Materials. U. S. Department of Transportation.
* 18. SCBA-A Fire Service Guide to the Selection. Use. Care, and Main- tenance of
Self-Contained Breathing Apparatus. NFPA, Batterymarch Park, Quincy, MA.
* 19 . Standard First Aid and Personal Safety. American Red Cross.
20. Underwriters Laboratories Testing for Public Safety. Annual Directory.
Underwriters Laboratories, Inc., Northbrook, IL.
E. Planning Guides
1. Chemical Emergency Planning Program. U.S. EPA.
2. Detoxification of Hazardous Wastes. Exner, Jurgen H., Ann Arbor Science.
* 3. Federal Motor Carrier Safety Regulations Pocketbook. (U. S. Dept. of
Transportation) J.J. Keller and Associates, Inc.
4. Handbook for Remedial Action at Waste Disposal Sites. EPA 625/682-006 (June
1982).
5. Hazardous and Toxic Materials: Safe Handling and Disposal. Fawcett,
H.H., John Wiley and Sons.
6. Hazardous Chemical Spill Cleanup. Noyes Datat Corporation, Ridge Park, New
Jersey.
7. Hazardous Materials Emergency Planning Guide. National Response Team. U.S.
Environmental Protection Agency, 401 M. Street S.W., Washington, DC 20460
(1987).
8. Hazardous Materials Spills Handbook. Gary F. Bennett, Frank S. Feates, Ira
Wilder, McGraw-Hill Book Co., New York, NY.
9. Hazardous Waste Regulation-An Interpretive Guide. Mallow, Alex, Van
Nostrand Reinhold Company.
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10. Occupational Safety and Health Guidance Manual for Hazardous Waste Site
Activities. NIOSH/OSHA/USCG/EPA, U.S. Dept. of Health and Human
Services, NIOSH.
11. Standard Operating Safety Guides. Environmental Response Branch, Office of "
Emergency and Remedial Response, U.S. Environmental Protection Agency.
12. State Decision-Makers Guide for Hazardous Waste Management. SW 612. U.S.
EPA (1977).
13. 1984 Emergency Response Guidebook - Guidebook for Hazardous Mat-erials
Incidents. DOT P 5800.3 USDOT, Materials Transportation tation Bureau,
Attn: DMT-11, Washington, DC 20590.
III. TECHNICAL INFORMATION AND POTENTIAL RESPONSE/INFORMATION
SOURCES
1. AFX Rail Car Mfgr.
314/724-7850
2. Agency for Toxic Substances Disease Registry
Centers for Disease Control
Shamlee 28 S., Room 9
Atlanta, GA 30333
404/452-4100
3. American Conference of Governmental Industrial Hygienists
6500 Glenway Avenue, Building D-5
Cincinnati, OH 45211
513/661-7881
4. American Industrial Hygiene Association
475 Wolf Ledges Parkway
Akron, OH 44311-1087
216/762-7294
5. American Insurance Association (AIA)
(National Board of Fire Underwriters)
Engineering and Safety Service
85 John St.
New York, NY 10038
212/533-4400
6. American National Standards Institute, Inc.
1430 Broadway
New York, NY 10018
212/354-3300
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7. American Petroleum Institute (API)
1220 L Street N.W., 9th Floor
Washington, DC 20005
202/682-8000
8. American Society of Mechanical Engineering (AS ME)
United Engineering Center
345 East 47th Street
New York, NY 10017
212/644-7722
9. ARMY ORDINANCE UNIT
10. Ashland Chemical Company
3849 Risher Road
Columbus, OH 43228
614/276-6143
11. Association of American Railroads (AAR)
50 F Street N.W.
Washington, DC 20001
202/639-2100
12. Association of American Railroads (AAR)
59 East Van Buren Street
Chicago, IL 60650
312/939-0770
13. BOMB HANDLERS
14. Bureau of Explosives
American Association of Railroads
1920 L Street, N.W.
Washington, DC 20036
202/293-4048
15. Center for Disease Control
Atlanta, GA
404/633-5313
16. CHEMICAL INFORMATION
17. CHEMICAL RESPONSE INFORMATION
18. Chemical Manufacturer's Association
2501 M St. N.W.
Washington, DC 20037
202/877-1100
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19. CHEMISTS
20. Chemtrec
Washington, DC A
800/424-9300 \
21. CIVIL DEFENSE CLEANUP CONTRACTORS
22. The Clorine Institute
342 Madison Avenue
New York, NY 10017
212/682-4324
23. The Compressed Gas Association, Inc. (CGA)
500 Fifth Avenue
New York, NY 10036
212/354-1130
24. CONSTRUCTION COMPANIES (HEAVY EQUIPMENT)
25. CRC Press, Inc.
2000 Corporate Blvd., N.W.
Boca Raton, FL 33431
305/994-0555, Ext. 330
26. DEPARTMENTS OF ENVIRONMENTAL QUALITY (STATE, LOCAL)
27. DEPARTMENT OF TRANSPORTATION (STATE)
28. Dow Chemical Company
Midland, MI 48640
517/636-4400
29. DuPont Company
1007 Market Street
Wilmington, DE 19898
302/774-7500
30. Energy Research Development Admin.
Albuquerque Office
Albuquerque, NM 87101
505/264-4667(8)
31. ENVIRONMENTAL PROTECTION AGENCY
32. EPIDEMIOLOGISTS
33. Factory Mutual Engineering Corp. Lab
1150 Boston-Providence Turnpike
Norwood, MA 02062
617/762-4300
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34. The Fertilizer Institute (TFI)
1015 18th St., N.W.
Washington, DC 20036
202/861-4900
35. FIRE DEPARTMENTS
36. GAS COMPANIES
37. GATX RAIL CAR MFGR.
312/621-6200
38. HAZARDOUS MATERIALS EXPERTS
39. HAZARDOUS MATERIALS TEAMS
40. HEALTH DEPARTMENT
41. HIGHWAY DEPARTMENT
42. HOSPITALS
43. Institute of Makers of Explosives (IME)
420 Lexington Avenue
New York, NY 10017
212/986-6920
44. J. T. Baker Chemical Company
Phillipsburgh, NY 08856
201/859-2151
45. Kerr-McGee Chemical Corp.
Kerr-McGee Center
Oklahoma City, OK 73125
405/270-1313
46. LAW ENFORCEMENT AGENCIES
47. Mallinckrodf, Inc.
P.O. Box 5439
St. Louis, MO 63147
314/895-0123
48. Manufacturing Chemists Association, Inc.
1825 Connecticut Avenue N.W.
Washington, DC 20009
202/483-6126
49. MANUFACTURERS REPRESENTATIVES
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50. MOTOR CARRIER SAFETY
51. National Bureau of Standards
U.S. Department of Commerce
Washington, DC 20234
301/921-1000
52. National Fire Protection Association
Batterymarch Park
Quincy, MA 02269
617/328-9290
53. National Institute for Occupational Safety and Health
Division of Technical Services
46765 Columbia Parkway
Cincinnati, OH 45226
513/684-8302
54. National Response Center (USCG and EPA)
800/424-8802
55. National Safety Council
444 North Michigan St.
Chicago, IL 60611
312/527-4800
56. National Tank Truck Carriers, Inc.
1616 P St.
Washington, DC 20036
202/797-5426
57. National Transportation Safety Board
800 Independence Avenue
Washington, DC 20594
202/655-4000
58. NATX Rail Car Mfgr.
312/648-4000
59. Occupational Safety and Health Administration
U.S. Department of Labor
Washington, DC
202/523-9700
60. Oil and Hazardous Material Technical Assistance Data System
202/245-3045
61. Poison Control Center
Charleston, SC
502/432-9516
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62. PORT AUTHORITIES
63. PUBLIC INFORMATION MEDIA
64. PUBLIC WORKS
65. RADIOACTIVE MATERIAL HAULERS
66. Radiological Assistance Zone 3
Savannah River Operations Office
Aiken, SC 29801
803/725-6211, x3333
67. RADIO STATIONS
68. RAILROAD DIVISION SUPERINTENDENT
69. RAILROAD MATERIAL HANDLERS
70. RAILROADS
71. REGIONAL RESPONSE TEAMS
72. SANITATION AGENCIES
73. SHERIFF'S OFFICE
74. SHIPPER REPRESENTATIVES
75. STATE FIRE MARSHAL
76. STATE POLICE
77. STEVEDORING COMPANIES
78. STREET DEPARTMENT
79. STRUCTURAL ENGINEERS
80. Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
202/783-3238
81. TELEVISION STATIONS
82. TOXICOLOGISTS
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83. Underwriters' Laboratories
207 East Ohio St.
Chicago, IL 60611
312/642-6969 A
84. Union Carbide Corp.
Linde Div.
51 Cragwood Road
S. Plainfield, NJ 07080
201/753-5800
85. U.S. Army Explosive and Ordnance Disposal
301/677-5182
86. U.S. COAST GUARD
87. U.S. DEPARTMENT OF AGRICULTURE
88. U.S. Department of Defense
Nuclear Accident Center
505/264-4667
89. U.S. Department of Energy
Washington, DC 20545
202/252-5000
90. U.S. Department of Transportation
Materials Transportation Bureau I
Office of Hazardous Materials Operations
400 7th St. S.W.
Washington, DC 20590
202/366-4555
91. U.S. EPA
Office of Research and Development
Publications - CERI
Cincinnati, OH 45268
513/684-7562
92. U.S. EPA
Office of Solid Waste
(WH-562)
Superfund Hotline
401 M. St. SW
Washington, DC 20460
800/424-9346
12
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93. U.S. Mine Safety and Health Administration
Department of Labor
4015 Wilson Blvd. Room 600
Arlington, VA 22203
703/235-1452
94. U.S. National Oceanic and Atmospheric Administration
Hazardous Materials Response Branch
N/OMS 34
7600 Sand Point Way, N.E.
Seattle, WA 98115
206/527-6317
95. U.S. Nuclear Regulatory Commission
Washington, DC 20555
301/492-7000
96. UTLX Rail Car Mfgr.
312/431-3111
97. UTILITIES
98. WASTE DISPOSAL COMPANIES
99. WATER COMPANIES
100. WRECKING COMPANIES
13
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SECTION 6
REFERENCES AND GLOSSARY
PART 2
GLOSSARY AND ACRONYMS
I. GLOSSARY
Accident - An unexpected event generally resulting in injury, loss of property, or disruption of
service.
Action Level - A quantitative limit of a chemical, biological, or radiological agent at which
actions are taken to prevent or reduce exposure or contact.
Acute Exposure - A dose that is delivered to a receptor in a single event or in a short period of
time.
Air Surveillance - Use of air monitoring and air sampling during a response to identify
and quantify airborne contaiminants on and off-site, and monitor changes in air contaminants that
occur over the lifetime of the incidents
Aquifer - A water bearing formation of permeable rock, sand, or gravel capable of yielding water
to a well or spring.
Chronic Exposure - Low doses repeatedly delivered to a receptor over a long period of time.
Confinement - Control methods used to limit the physical area or size of a released
material. Examples: dams, dikes, and absorption processes.
Containment - Control methods used keep the material in its container. Examples: plugging and
patching.
Contaminant/Contamination - An unwanted and non-beneficial substance.
Control - Chemical or physical methods used to prevent or reduce the hazards associated with
a material. Example: Neutralizing an acid spill.
Decontamination - The process of physically removing contaminants from individuals and
equipment or changing their chemical nature to innocuous substances
Degree of Hazard - A relative measure of how much harm a substance can do.
Direct-Reading Instruments - A portable device that rapidly measures and displays the
concentration of a contaminant in the environment.
Emergency - A sudden and unexpected event calling for immediate action.
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Emergency Removal - Action or actions undertaken, in a time-critical situation, to prevent,
minimize, or mitigate a release that poses an immediate and/or significant threat(s) to human
health or welfare or to the enivronment. (See also Removal Action)
Environmental Assessment - The measurement or prediction of the concentration, transport,
dispersion, and final fate of a released hazardous substance in the environment.
Environmental Emergencies - Incidents involving the release (or potential release) of hazardous
materials into the environment which require immediate action.
Environmental Hazard - A condition capable of posing an unreasonable risk to air, water, or soil
quality, and to plants or wildlife.
Environmental Sample - Samples that are considered to contain no contaminants or low
concentrations of contaminants as compared to hazardous samples.
Episode - Incident.
First Responder - The first personnel to arrive on the scene of a hazardous materials
incident. Usually officials from local emergency services, firefighters, and police.
Groundwater - Water found in the saturated portions of geologic formations beneath the surface
of land or water.
Hazard - A circumstance or condition that can do harm. Hazards are categorized into four
groups: biological, chemical, radiation, and physical.
Hazard Evaluation - The impact or risk the hazardous substance poses to public health and the
environment.
Hazard Classes - A series of nine descriptive terms that have been established by the UN
Committee of Experts to categorize the hazardous nature of chemical, physical, and biological
materials. These categories are:
1. Explosives,
2. Non-flammable and flammable gases,
3. Flammable liquids,
4. Flammable solids,
5. Oxidizing materials,
6. Poisons, irritants, and disease causing materials,
7. Radioactive materials,
8. Corrosive materials, and
9. Dangerous materials.
Hazardous - Capable of posing an unreasonable risk to health and safety (Department of
Transportation). Capable of doing harm.
Hazardous Material - A substance or material which has been determined by the Secretary of
Transportation to be capable of posing an unreasonable risk to health, safety, and property when
transported in commerce, and which has been so designated. (Department of Transportation)
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Hazardous Sample - Samples that are considered to contain high concentrations of contaminants.
Hazardous Substance - 1) A material and its mixtures or solutions that is identified by the letter
"E" in Column (1) of the Hazardous Materials Table, 49 CFR 172.101, when offered for
transportation in one package, or in one transport vehicle if not packaged, and when the quantity
of the material therein equals or exceeds the reportable quantity. 2) Any substance designated
pursuant to Section 311(b)(2) (A) of the Federal Water Pollution Control Act, (B) any element,
compound, mixture, solution, or substance designated pursuant to Section 102 of this Act, (C)
any hazardous waste having the characteristics identified under or listed pursuant to Section 3001
of the Solid Waste Disposal Act (but not including any waste the regulation of which under the
Solid Waste Disposal Act has been suspended by Act of Congress), (D) any toxic pollutant listed
under Section 307(a) of the Federal Water Pollution Control Act, (E) any hazardous air pollutant
listed under Section 112 of the Clean Air Act, and (F) any imminently hazardous chemical
substance or mixture with respect to which the Administrator has taken action pursuant to Section
7 of the Toxic Substances Control Act. The term does not include petroleum, including crude
oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous
substance under subparagraphs (A) through (F) of this paragraph, and the term does not include
natural gas, natural gas liquids, liquified natural gas, or synthetic gas usable for fuel (of mixtures
of natural gas and such synthetic gas).
Hazardous Waste - Any material that is subject to the hazardous waste manifest requirements of
the Environmental Protection Agency specified in 40 CFR, Part 262 or would be subject to these
requirements in the absence of an interim authorization to a State under 40 CFR Part 123,
Subpart F.
Incident - The release or potential release of a hazardous substance or material into the
environment.
Incident Characterization - The process of identifying the substance(s) involved in an incident,
determining exposure pathways and projecting the effect it will have on people, property, wildlife
and plants, and the disruption of services.
Incident Evaluation - The process of assessing the impact released or potentially released
substances pose to public health and the environment.
Information - Knowledge acquired concerning the conditions or circumstances particular to an
incident.
Inspection - Same as investigation.
Intelligence - Information obtained from existing records or documentation, placards, labels,
signs, special configuration of containers, visual observations, technical records, eye witnesses,
and others.
Investigation - On-site and off-site survey(s) conducted to provide a qualitative and quantitative
assessment of hazards associated with a site.
Limited Quantity - With the exception of Poison B materials, the maximum amount of a
hazardous material for which there is a specific labeling and packaging exception.
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Mitigation - Actions taken to prevent or reduce the severity of threats to human health and the
environment.
Monitoring - The process of sampling and measuring certain environmental parameters on a real-
time basis for spatial and time variations. For example, air monitoring may be conducted with
direct-reading instruments to indicate relative changes in air contaminant concentrations at various
times.
National Contingency Plan - Policies and procedures that the Federal Government follows in
implementing responses to hazardous substances.
Qn-Site - Presence within the boundaries of the worksite.
Off-Site - Presence outside of the worksite.
Pathways of Dispersion - The environmental medium (water, groundwater, soil, and air) through
which a chemical is transported.
Persistent Chemicals - A substance which resists biodegradation and/or chemical transformation
when released into the environment and tends to accumulate on land, in air, in water, or in
organic matter.
Planned Removal (Non-Time-Critical Removal) - The removal of released hazardous substances
that pose a threat or potential threat to human health or welfare or to the environment from a site
within a non-immediate time period. Under CERCLA: Actions intended to minimize increases
in exposure such that time and cost commitments are limited to 12 months and/or two million
dollars. (See also Emergency Removal)
Pollutant - A substance or mixture which after release into the environment and upon exposure
to any organism will or may reasonably be anticipated to cause adverse effects in such organisms
or their offspring.
Pollutant Transport - An array of mechanisms by which a substance may migrate outside the
immediate location of the release or discharge of the substance. For example, pollution of
groundwater by hazardous waste leachate migrating from a landfill.
Qualified Individual - A person who through education, experience, or professional accreditation
is competent to make judgements concerning a particular subject matter. A Certified Industrial
Hygienist may be a qualified individual for preparing a site safety plan.
Regulated Material - A substance or material that is subject to regulations set forth by the
Environmental Protection Agency, the Department of Transportation, or any other federal
agency.
Release - Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing of hazardous substances into the environment.
Remedial Actions - As in the National Contingency Plan, responses to releases on a National
Priority List that are consistent with treatment-oriented remedy that is protective of human health
and the environment and that permanently and significantly reduces toxicity, mobility, or volume
of hazardous substances.
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Removal Actions - Any appropriate actions(s) taken to abate, minimize, stablize, mitigate, or
eliminate the release or threat of release that poses a threat to human health or welfare or to the
environment. As set forth in the National Contingency Plan, these actions shall be terminated
after $2 million has been obligated or 12 months have elapsed from the date of initial response.
Reportable Quantity - As set forth in the Clean Water Act, the minimum amount (pounds or
kilograms) of a hazardous substance that may be discharged in a 24 hour period that requires
notification of the appropriate government agency.
Response Actions - Actions taken to recognize, evaluate, and control an incident.
Response Operations - Same as Response Actions.
Risk - The probability that harm will occur.
Risk Assessment - The use of factual base to define the health effects of exposure of individuals
or populations to hazardous materials and situations.
Risk Management - The process of weighing policy alternatives and selecting the most
appropriate regulatory action integrating the results of risk assessment with engineering data and
with social and economic concerns to reach a decision.
Routes of Exposure - The manner in which a contaminant enters the body through inhalation,
ingestion, skin absorption, and injection.
Safety - Freedom from man, equipment, material, and environmental interactions that result in
injury or illness.
Sampling - The collection of representative portion of the universe. Example: the collection of
a water sample from a contaminated stream.
Severe - A relative term used to describe the degree to which hazardous material releases can
cause adverse effects to human health and the environment.
Site - Location.
Site Safety Plan - Written, site-specific safety criteria that establishes requirements for protecting
the health and safety of responders during all activities conducted at an incident.
Toxicity - The ability of a substance to produce injury once it reaches a susceptible site in or on
the body.
Work Plan - Written directives that specifically describe all work activities that are to take place
at a work site.
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II. ACRONYMS
ACGIH - American Conference of Governmental Industrial Hygienists M
AIHA - American Industrial Hygiene Association
ANSI - American National Standards Institute
ASTM - American Society of Testing and Materials
APR - Air-Purifying respirator
B of M - Bureau of Mines
BOP - Biological oxygen demand
CAG - Carcinogen Assessment Group
CDC - Center for Disease Control
CERCLA - Comprehensive Environmental Response Compensation and
Liability Act (1980)
CFR - Code of Federal Regulations
CGI - Combustible Gas Indicator
CHEMTREC - Chemical Transportation Emergency Center
CHRIS - Chemical Hazard Response Information System
CMA - Chemical Manufacturers' Association
CPM - Counts per minute
CRC - CRC Press. A publisher of scientific reference books
CRP - Community Relations Plan
DDT - Dichlorodiphenyltrichloroethane
DECON - Decontamination
DFM - Diesel fuel marine
DHHS - Department of Health and Human Services
POD - Department of Defense
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DPI - Department of the Interior
POL - Department of Labor
DOT - Department of Transportation
DRI - Direct-reading Instruments
EERU - Environmental Emergency Response Unit
EPA - Environmental Protection Agency
ERCS - Emergency Response Cleanup Services, under EPA contract
ERT - Environmental Response Team
eV - Electron volt
FEMA - Federal Emergency Management Agency
FID - Flame ionization detector
FIT - Field Investigation Team under contract to EPA
FM - Factory Mutual
GC - Gas chromatograph or gas chromatography
HEPA - Common use: "HEPA Filter" High efficiency particulate air
filter.
IDLH - Immediately dangerous to life or health
IP - Ionization potential
IR - Infrared radiation
IUPAC - International Union of Pure and Applied Chemists
LQ5Q - Lethal concentration, 50%
LDjQ - Lethal Dose, 50%
LEL - Lower explosive limit
mg/L - Milligrams per litre
mg/m3 - Milligrams per cubic meter
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MIRAN - Trade name for series of Foxboro miniature infrared analyzers
mR/hr - Milliroentgens per hour
MSDS - Materials Safety Data Sheets *
MSHA - Mine Safety and Health Administration
MUC - Maximum use concentration
MUL - Maximum use limits
NBR - Nitrile-Butadiene Rubber (syn. Buna-N)
NCP - National Contingency Plan
NEC - National Electric Code
NFPA - National Fire Protection Association
NIOSH - National Institute for Occupational Safety and Health
NOAA - National Oceanic and Atmospheric Administration
NOS or n.o.s. - Not otherwise specified
NPL - National Priorities List
NRC - Nuclear Regulatory Commission
NRT - National Response Team
OHMTADS - Oil and Hazardous Materials Technical Assistance Data System
ORM - Other regulated material. Various specific classes such as ORM-A, ORM-E, etc.
QSC - On-Scene coordinator
QSHA - Occupational Safety and Health Administration
OVA - Organic Vapor Analyzer
PCB - Polychlorinated Biphenyl
PEL - Permissible exposure limit
PF - Protection factor
PIP - Photo ionization detector
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ppb - Parts per billion
ppm - Parts per million
ppt - Parts per trillion
PVA - Poly Vinyl Alcohol
PVC - Poly Vinyl Chloride
OA/QC - Quality assurance/Quality control
RCRA - Resource Conservation and Recovery Act
REL - Recommended Exposure Limits
REMFIT - Field Investigation Team for remedial actions under contract
to EPA
RI/FS - Remedial Investigation/Feasibility Study
RRP - Regional Response Plan
RRT - Regional Response Team
SBR - Styrene-Butadiene rubber
SCBA - Self contained breathing apparatus
SOPs - Standard operating procedures
SOSGs - Standard operating safety guides
STEL - Short term exposure limit
TAT - Technical Assistance Team under contract to EPA
TCDD - Tetrachlorodibenzo - p - dioxin
TCE - Trichloroethylene
TLVs - Threshold limit values
TWA - Time weighted average
2. 4. 5-T - 2, 4, 5-Trichlorophenoxyacetic acid
UEL - Upper explosive limit
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UL - Underwriters Laboratories
UN - United Nations
USCG - United States Coast Guard
USGS - United States Geological Survey
WEEL - Workplace Environmental Exposure Levels
74 * U S. GOVERNMENT PRINTING OFFICE 1993-3 1+1-835' 83011
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