905R91102
HEALTH AND
SAFETY MANUAL
REGION 5
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY
REGION 5
1991 EDITION
R51440
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
TABLE OF CONTENTS
Page
t- Number
1. POLICY AND RESPONSIBILITY 1-1
1.1 Policy 1-1
1.2 Purpose 1-1
1.3 Program Policy Goal 1-2
1.4 Responsibilities 1-2
2. PROGRAM ADMINISTRATION 2-1
2.1 Regional Program Goals 2-1
2.2 Program Budget and Resources 2-1
2.3 Dissemination of Occupational Health 2-2
and Safety Program Information
2.4 Contracts and Contractor Responsibility 2-2
for Safety
3. ACCIDENT AND COMPLAINT PROCEDURES 3-1
3.1 Workers Complaints 3-1
3.2 Injury and Illness 3-1
4. ANNUAL INSPECTIONS AND SURVEYS 4-1
4.1 Standards 4-1
4.2 Annual Safety Inspections 4-1
4.3 Annual Industrial Hygiene Surveys 4-2
4.4 Annual Environmental Compliance Audits 4-2
4.5 Special Studies 4-2
4.6 Deficiency Abatement Procedures 4-3
And Tracking
5. TRAINING AND CERTIFICATION 5-1
5.1 Required Training Policy 5-1
5.2 40-Hour Field Safety Course 5-1
(Superfund)
5.3 24-Hour Field Safety Course 5-3
(RCRA And Field Inspection)
5.4 8-Hour Refresher Course For All 5-3
Field Personnel
5.5 Safety Training For Laboratory Employees 5-4
5.6 Field Certification Procedures 5-6
5.7 Documentation 5-7
5.8 Other Health And Safety courses 5-8
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Region 5 Health and Safety Manual
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
TABLE OF CONTENTS
Page
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6. SAFETY COMMITTEE AND ORGANIZATION 6-1
6.1 Safety Committee Policy 6-1
6.2 Safety Committee Organization 6-1
6.3 Committee Operations 6-2
6.4 Regional Safety Organization 6-2
7. COMPLIANCE REVIEW 7-1
7.1 Overall Policy 7-1
7.2 Safety And Health Review Of New 7-1
Construction/Repairs And Alterations
7.3 Safety And Health Reviews Of Marine 7-1
Construction/Repairs And Alterations
7.4 Review Of PPE Procurement 7-2
7.5 Review of Hazardous Materials And 7-2
Hazardous Waste Disposal Procurement
7.6 Health And Safety Review Of Contracts 7-2
7.7 Review Of Miscellaneous Procurement 7-2
Impacting Safety, Health or Environmental
Compliance
8. ANNUAL SAFETY AWARD 8-1
8.1 Policy 8-1
8.2 Selection Procedures 8-1
8.3 Other Awards 8-1
9. STANDARD OPERATING PROCEDURES 9-1
9.1 Policy 9-1
9.2 Field SOPs 9-1
9.3 Laboratory SOPs 9-2
9.4 Marine SOPs 9-2
10. MEDICAL MONITORING PROGRAMS 10-1
10.1 Medical Monitoring Selection Policy 10-1
10.2 Medical Monitoring Program Procedures 10-2
10.3 Employee Health Maintenance Exams (EHMEs) 10-5
10.4 Other Health Services Provided To EPA 10-5
Employees
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Region 5 Health and Safety Manual
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
TABLE OF CONTENTS
Page
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11. FIELD SITE SAFETY PROGRAM 11-1
11.1 Guidance and Procedures For 11-1
Site Activities And Investigations
11.2 Program Requirements 11-6
11.3 Work Practice Requirements 11-10
12. PERSONAL PROTECTIVE EQUIPMENT 12-1
12.1 Policy and Responsibility 12-1
12.2 Protective Clothing and 12-4
Equipment Requirements
12.3 Issuance and Training In The Use Of 12-10
Protective Clothing And Safety Equipment
13. RESPIRATORS 13-1
13.1 Purpose 13-1
13.2 Background 13-1
13.3 Selection Of Respiratory Protective Devices 13-2
13.4 Use Of Respiratory Protective Devices 13-7
13.5 Inspection, Maintenance, Repair, And 13-12
Storage Of Respiratory Protective Devices
Attachments 13-15
14. CONFINED SPACES 14-1
14.1 Purposes 14-1
14.2 Confined Space Defined 14-1
14.3 References 14-4
Attachments 14-5
15. HAZARDOUS WASTE SITES 15-1
15.1 Requirements 15-1
15.2 Safety Plans 15-2
16. LAB SAFETY 16-1
16.1 General Lab Safety Rules 16-1
16.2 Hazard Communication And Identification 16-2
16.3 Contingency Plans 16-3
16.4 Ventilation Requirements 16-3
16.5 Storage Requirements 16-4
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
TABLE OF CONTENTS
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17. ENVIRONMENTAL COMPLIANCE 17-1
17.1 Responsibilities 17-1
17.2 Air 17-1
17.3 Drinking Water 17-2
17.4 Water Pollution 17-2
17.5 Nonhazardous Solid Waste 17-2
17.6 Hazardous Waste 17-3
17.7 Asbestos 17-4
17.8 Polychlorinated Biphenyls (PCBs) 17-4
18. MARINE SURVEY SAFETY 18-1
18.1 Research Vessel 18-1
18.2 Small Boats 18-2
18.3 Diving Operations 18-2
18.4 Helicopter Operations 18-3
19. RADIATION SAFETY 19-1
19.1 Department of Energy Plants 19-1
19.2 Laboratories 19-3
19.3 Waste Sites 19-4
20. OFFICE AND TRAFFIC SAFETY 20-1
20.1 Office Safety 20-1
20.2 Fire Evacuation Plans 20-1
20.3 Defensive Driving 20-2
APPENDIX A - ACRONYMS A-l
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Chapter 1 - POLICY AND RESPONSIBILITIES
1.1 POLICY
U.S. EPA REGION 5 - HEALTH AND SAFETY POLICY STATEMENT
It is the policy of EPA, Region 5, that all EPA employees
working in offices, laboratories, field activities, and
special programs are entitled to a comprehensive health and
safety program. The goals of the program are to ensure that
each employee work in an environment free of recognized
hazards and to eliminate and/or mitigate occupational
accidents as much as possible. These goals shall be
accomplished through:
1. Training employees in the proper techniques for
field investigations, proper use of and access to safety
equipment, and proper protocol for inspections;
2. Development of standard operating procedures for
routine and non-routine work environments;
3. Enabling employees to identify those work situations
where they believe a hazard exists without any adverse action
taken against the employee;
4. Medical monitoring of employees in risk situations.
Through the above steps, it is hoped that all EPA employees
(management and staff) can mutually share the responsibility
to reduce work place hazards and that the Agency can provide
the environment for that to occur.
This policy shall be coordinated by the Regional Safety
Manager. In addition to the above stated steps, this policy
shall meet the applicable requirements of the Occupational
Safety and Health Administration, the provisions of Executive
Order 12196 and other relevant statutes, laws, policies and
guidance of the Federal Government regarding occupational
health and safety.
1.2 PURPOSE
This manual establishes policies, responsibilities,
procedures, rules, and guidelines for all Regional
Occupational Safety & Health and Environmental Compliance
Programs.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
1.3 PROGRAM POLICY GOAL
It is the goal of Region 5 to administer its programs in
a manner that will assure that its employees are free from
recognized hazards.
1.4 RESPONSIBILITIES
The responsibilities of relevant EPA personnel are
detailed in the following paragraphs, separated by title.
1.4.1 Assistant Regional Administrator
The Assistant Regional Administrator (ARA) for Planning
and Management is the Designated Regional Occupational Safety
and Health Official. This ARA is responsible for establishing
Regional Health and Safety and Environmental Compliance
policies, programs, standards, goals, objectives, and
priorities. The ARA is also responsible for establishing an
organization including the designation of a Regional Health
and Safety Manager with an adequate budget and staff to
implement occupational health and safety and environmental
compliance programs at all levels throughout Region 5.
1.4.2 Occupational Health and Safety Manager
The Occupational Health and Safety Manager, under the
direction of the ARA for Planning and Management, is
responsible for developing Regional occupational health and
safety and environmental compliance policies, programs,
standards, goals, and objectives for evaluating the
effectiveness of the Region's occupational health and safety
and environmental compliance programs at all levels. He/she
must also provide technical and management support, direction,
and services to all Regional occupational health and safety
and environmental compliance programs.
1.4.3 Division. Office, and Laboratory Directors
Division, Office, and Laboratory Directors are
responsible for implementing the Region's Occupational Health
and Safety and Environmental Compliance Programs in their
reporting unit and work places within their area of
jurisdiction.
1.4.4. Occupational Health and Safety Representatives
Occupational Health and Safety Representatives are to be
appointed by each Division and Office Director for each
Division and Office in the Region. The number of Safety
Representatives to be appointed will be determined by each
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Division and Office Director based on need. Occupational
Health and Safety Representatives are responsible for
assisting the management of their Division or Office in
directing health and safety activities within their Division
or Office and for coordinating such activities with the
Regional Safety Manager. Divisional or Office Safety
Representatives will also serve on the Regional Health and
Safety Committee. (Safety Representatives may also be
appointed at the Branch, Section, and/or Unit level.)
1.4.5 Supervisors and Managers
Supervisors and managers are responsible, to the extent
of their authority, for the health and safety of their
employees. Supervisors and managers are also responsible for
providing employees with working conditions free from
recognized hazards that are likely to cause death or serious
harm (i.e., equipment, place of employment, etc.).
Supervisors and managers shall comply with the Region's
Occupational Health and Safety and Environmental Compliance
Standards, along with all safety rules, regulations, and
orders issued by the Region. Furthermore, they are
responsible for enforcing these correct work practices.
1.4.6 Employee Rights and Duties
EPA employees are expected to follow all health and
safety rules and to perform duties in order to protect their
own well being and that of their fellow employees.
1.4.6.1 Employee Compliance
Employees are obliged to follow the Region's Occupational
Health and Safety and Environmental Compliance Standards,
rules, regulations, and orders which are applicable to their
own job duties, actions, and conduct. Employees are also
required to use safety equipment, personal protective
equipment (PPE), and other safety devices and, moreover, to
follow safety procedures as provided and directed, that the
Region deems necessary for their protection.
1.4.6.2 Employee Rights and Responsibilities
The rights and responsibilities of EPA personnel with
regard to occupational health and safety are detailed in the
"Occupational Health and Safety for Environmental Protection
Agency Employees" poster. (Attachment 1.1)
1-3
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Region 5 Health and Safety Manual
Attachment 1.1
R5 1440 (9/29/91)
Occupational
Health and Safety
for Environmental
Protection Agency
Employees
Occupational Health and Safety Policy
The Environmental Protection Agency shall
administer its programs in a manner that
will assure its employees places and
conditions of employment free from
recognized hazards which are likely to
cause death or serious harm.
Agency
Responsibilities
Designate an Occupational Health and
Safety Official to administer EPA's health
and safety programs. This Official is
Harm
fiSe
• Furnish employment and a place of
employment free from recognized
hazards.
• Comply with OSHA standards or
develop more stringent alternate
standards.
• Ensure that the performance
evaluation of all managers and
supervisors measures his her
performance in meeting requirements of
EPA's Occupational Health and Safety
Programs.
• Acquire, maintain, and require the use
of approved personal protective
equipment and approved safety
equipment.
• Authorize Agency health and safety
personnel to utilize expertise from other
agencies, professional groups.
consultants, universities, labor
organizations, health and safety
committees, and other appropriate
sources.
• Ensure appropriate resources to
effectively implement and administer the
Agency's Occupational Health and
Safety Programs
Occupational
Health and Safety
Responsibilities
• Develop an Agency Occupational
Health and Safely Program thai includes
policies, programs standards, goals and
objectives
• Ev.ihi.ne 'hf 5'**i\-t'\fnoas of the
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• ProvuK' ti
Supervisor
Responsibilities
To the extent of their authority.
Supervisors shall:
• Provide his/her employees with
employment and places of employment
free from recognized hazards.
• Comply with all health and safety
standards and with all rules, regulations
and orders issued by the Agency.
• Enforce safe work practices.
Employee
Responsibilities
• Comply with the Agency's
Occupational Health and Safety
standards, rules, regulations, and orders
applicable to their own actions and
conduct.
• Use the safety equipment personal
protective equipment and other health
and safety devices provided by the
Agency.
• Follow the procedures, provided or as
directed, that the Agency deems
necessary for their protection.
• Report all work-related property and
personal accidents, and illnesses to their
supervisor.
Employee and
Employee Representative
Rights
• Access to copies of the Agency's
standards, injury and illness statistics.
and procedures.
• Comment on standards proposed by
the Agency.
• Participate or assist in inspections and
tell inspectors about unsafe or
unhealthful working conditions.
• Authorized official time to participate
in the Agency's Occupational Health and
Safety Program activities
• May derlinc to perform assigned
usks bc'CeiiiiC' of a reasonable belief that
under the circumstances the task poses
jr, imminent risk of death or serious
bodily harm and that there is not time to
go through established reporting and
abatement procedures.
• Report unsafe or unhealthful working
conditions to appropriate officials. (See
Chapter 4 of the Agency's Occupational
Health and Safety Manual for detailed
procedures.)
• Appeal if you disagree with the
Agency's disposition of an unsafe or
unhealthful working condition. Write
appeal to:
OHIO* c* F*d«tf AMDCV Stfaty and Health
US.D*
IS. DOMHIIHIU o> Ubof
0X120210
Discrimination
If you exercise your rights under the
Agency's Occupational Health and
Safety Programs, you are protected from
any discrimination, restraint
interference, coercion or reprisal.
Occupational Health
and Safety Committee
EPA requires that an Occupational
Health and Safety Committee be
established at each Agency Reporting
Unit and Establishment. Membership of
these committees must be determined
to provide for effective representation of
all employees. Your Occupational Health
and Safety Committee Chairperson is:
Name and Title
Location and Telephone Number
Further
Information
Further information regarding EPA's
Occupational Health and Safety
Programs, its standards and procedures.
the Federal law. or any other
information on health and safety is on
file and can be reviewed in the Office of
tne Occupational Health and Safety
Designe"
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SEPA
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Chapter 2 - PROGRAM ADMINISTRATION
2.1 REGIONAL PROGRAM GOALS
The Safety Manager is responsible for preparing an annual
workplan for submittal to the Assistant Regional Administrator
(ARA). The workplan should outline Regional Safety, Health,
and Environmental Compliance Program goals for the coming
fiscal year and their proposed method of implementation. Time
frames for implementations should also be included.
The goals and their implementation should be proactive in
nature and designed to build and improve the Regions already
highly proactive Safety, Health, and Environmental Compliance
Programs.
2.2 PROGRAM BUDGET AND RESOURCES
The Regional Safety Manager shall ensure that all Safety,
Health, and Environmental Compliance submissions include
proposed funding and resources for implementation. He/she
will administer effectively the Regional Occupational Safety,
Health, and Environmental Compliance Programs for all Offices
and Divisions in the Region and all other Agency organizations
serviced by the Regional Safety, Health & Environmental
Compliance personnel.
Appropriate funds and other resources for administering
the programs shall provide for, but not be limited to:
1. Sufficient personnel resources (including contract
resources) to implement and administer the overall program at
all levels;
2. Necessary administrative costs for such services as
training, personal protective equipment, etc.;
3. Contracts and lAGs for medical monitoring, complete
hygiene, and environmental compliance services including
laboratory analysis and hazardous waste disposal services;
4. Safety and health sampling, testing, and diagnostic
and analytical supplies and equipment;
5. Program training and promotion materials such as
posters, slides, films, and video tapes, and;
6. Technical information, documents, books, standards,
codes, and publications.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
2.3 DISSEMINATION OF OCCUPATIONAL HEALTH AND SAFETY
PROGRAM INFORMATION
The Regional Safety Manager shall promote employee
awareness of Regional Occupational Safety, Health, and
Environmental Compliance Programs through:
».
1. Upon request, providing copies of Executive Order
12196, 29 CFR 1910, and the Region's Occupational Health and
Safety Program to all employees. Also, copies of Agency and
Regional standards and other applicable occupational health
and safety standards shall be available to all employees for
review upon request.
2. Posting a copy of the Agency's Policy poster in an
observable place in each Agency facility.
3. Bringing Occupational Health and Safety issues to
the attention of employees through in-house publications,
forums, and promotional materials.
2.4 CONTRACTS AND CONTRACTOR RESPONSIBILITY FOR SAFETY
All contracts for contractors performing work for Region
5 or for any EPA activity or organization serviced by Regional
Safety personnel shall contain provisions in writing which
require contractors and contract personnel to follow the same
rules and requirements as U.S. EPA personnel performing
similar work. Wherever possible, contractual provisions
should require that all safety equipment and services (e.g.
personal protective equipment, medical monitoring, training,
etc.) shall be equivalent to that provided for EPA personnel
in the Region.
Enforcement of the above provisions shall be made through
the appropriate Project and Contracting Officers. Unresolved
conflicts should be reported to the Regional Safety Manager
for resolution.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Chapter 3 - ACCIDENT & COMPLAINT PROCEDURES
3.1 WORKER'S COMPLAINTS
f.
If an employee considers a situation or a work condition
to be a safety hazard, it is his/her responsibility to report
it directly to the Safety Manager or his/her Divisional Safety
Designee. It is an employee's responsibi1ity to report
potential safety hazards. (No one can take action against an
individual who reports a safety problem.)
3.1.1 Reporting
Potential safety hazards should be reported in writing to
the Regional Health and Safety Office as soon as they are
recognized. The Health and Safety Manager or his/her staff
will investigate the situation and recommend corrective
actions, if deemed necessary. The Health and Safety Office
will either make these corrections or pass the recommendations
to a more appropriate party, i.e. the General Services
Administration, building management, etc.
3.1.2 Recordkeepinq
Copies of all employee complaints, as well as
documentation of corrective actions, are kept on file in the
Regional Health and Safety Office.
3.2 INJURY & ILLNESS
When an EPA employee suffers an injury, whether traumatic
or nontraumatic, or is stricken ill while on the job, there
are necessary procedures to be followed in order to protect
the employee's interests and well being. These procedures are
set forth below.
3.2.1 Injury and Illness Defined
Injuries are considered either "traumatic" or
"nontraumatic." (a) A "traumatic injury" is defined as a
wound or other condition of the body caused by an external
force, including stress or strain. (b) A "nontraumatic
injury," also referred to as an "occupational disease or
illness," is a condition caused or aggravated by working in
a job environment over an extended period. This includes
injuries and illnesses caused by repeated stress or strain,
systemic infection, and those caused by continuous or repeated
exposure to toxins, poisons, fumes, etc.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
3.2.1.1 Reporting Procedures
Employees must report all accident or incidents, which
may result in an injury, to their immediate supervisor and may
do so without fear of reprisals. Moreover, it is in the
employee's best interest to report all injuries sustained on
the job, regardless of how minor they may appear, because a
slight injury could develop into something more serious.
Specific forms are used for reporting an injury. When
reporting a traumatic injury, complete Form CA-1, "Federal
Employee's Notice of Traumatic Injury and Claim for
Continuation of Pay/Compensation." When reporting a
nontraumatic injury, complete Form CA-2, "Federal Employee's
Notice of Occupational Disease and Claim for Compensation."
(These forms are available through the Human Resources
Department.) If an employee is incapacitated and is unable to
complete these forms, another person (coworker, supervisor,
etc.) may complete them. All forms should be signed by this
other person and forwarded to the employee's supervisor.
Five steps should be followed by the employee in the in
the event of a traumatic injury, in the order given:
1. Report the injury or incident to your supervisor as
soon as possible.
2. Obtain medical attention. Emergency treatment does
not require prior authorization. In case of non-emergency
treatment, your supervisor must first complete a CA-16 form
(within four hours of an employee's request) in order to
authorize medical treatment. (This form is valid for 60 days
from date of issue unless canceled by the OWCP.) Choose a
local Federal medical officer/hospital, if available, or a
local private physician/ hospital, and schedule a
consultation. Bring the CA-16 form and form HCFA 1500
(standard billing form) with you to your appointment.
3. File an official written notice of a traumatic injury
within two working days, using form CA-1. (Continuation of
Pay cannot be authorized if this form is filed more than 30
days of the injury. Compensation may be paid if form is filed
within 3 years of the injury.) Form CA-2 is filed instead
of form CA-1 if disability results from an occupational
disease or illness.
4. Retain a "receipt" of Notice of Injury from your
supervisor for your own personal records. It is attached
to Forms CA-1 and CA-2.
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5. If disabled as a result of the traumatic injury,
the employee may choose to take leave or request Continuation
of Pay (maximum of 45 calendar days.) If disability is a
result of an occupational disease, an employee may use leave
or request compensation using Form CA-7.
To reiterate, six claim forms must be completed in order
to document your injury/incident and initiate a worker's
compensation claim with the Department of Labor. These forms
are to be completed in the following order by the
corresponding party:
Employee:
CA-1 (front)
CA-2 (front)
complete your portion and
forward to your
supervisor, or
complete your portion and
forward to your
supervisor
Supervisor:
CA-1 (back)
CA-2 (back)
CA-16 (front)
CA-17 (front)
EPA-1440-9,
or
and
complete section before
employee goes to doctor,
return to employee; or a
complete section before
employee goes to doctor,
return to employee; and
an
distribute copies as
follows: original to
EPA, Occupational Health
and Safety Staff (PM-
273), Washington, D.C.
20460; goldenrod copy to
employee; pink copy for
supervisor's files; and
green copy (along with
original CA-l or CA-2) to
Personnel Office or
Employee Compensation
Coordinator; and a
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Supervisor: CA-3 complete when employee
(continued) returns to work if
they have lost time from
work
Physician: <•. CA-16 (back) or a
CA-17 (back) and an
HCFA 1500 (standard billing form)
NOTE; For the employee's own protection, copies of all
forms and documents should be made for his/her personal files.
3.2.1.2 Investigation
Investigation of an accident or illness is necessary to
prevent similar occurrences and does not attempt to prove
guilt or innocence, but, attempting to identify and abate
hazards. Investigations should be conducted promptly by both
the employee's supervisor and the Occupational Health and
Safety Designee. Both parties should gather and document all
facts and statements surrounding an incident, make
recommendations for resolution, and provide copies of findings
to each other, as well as to the employee involved. Further
details of investigative procedures are available in the
Occupational Health and Safety Manual.
3.2.1.3 Recordkeeping
Under OSHA regulations, it is the responsibility of the
Safety Office to maintain and keep current two OSHA Forms.
"The Log of Federal Occupational Injuries and Illnesses" is
used for compiling data and statistics on injuries and
illnesses. "The Annual Summary of Federal Occupational
Injuries and Illnesses" is a questionnaire completed by each
Region for Headquarters in order to help them prepare the
annual health and safety summary of the Agency for submission
to the Department of Labor.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Chapter 4 - ANNUAL INSPECTIONS AND SURVEYS
4.1 STANDARDS
Standards or regulations to be used for all types of
inspections or surveys conducted in Region 5 will be applied
as follows in descending order: EPA regulations either in CFR
form or as EPA Orders or as other EPA regulations; OSHA
regulations contained in various CFR regulations (e.g. 29 CFR
1910, 29 CFR 1926); other laws and regulations as applicable
(e.g. DOT, Coast Guard Regulations, State and local
environmental laws and regulations) ; consensus standards such
as NFPA (National Fire Protection Association) and ANSI
(American National Standards Institute.) All these standards
and regulations are used as appropriate to assess and evaluate
hazardous conditions during the inspection. If there is a
conflict in the application of various standards and
regulations, the Regional Health and Safety Manager will
decide which standard or regulation applies, using
professional judgement and risk assessment techniques.
4.2 ANNUAL SAFETY INSPECTIONS
Safety inspections or evaluations are conducted annually
by the Regional Health and Safety Manager of all Region 5
occupied facilities, space, vehicles, vessels, and other
equipment. The only exceptions are Regional laboratories
which are required by EPA Order 1440 to be inspected semi-
annually. The purpose of these inspections is to assess and
reduce hazards and evaluate the Safety Program throughout the
Region.
4.2.1 Safety Inspection Deficiency Notice and Report
All inspections will be followed by a written Safety
Inspection Deficiency Notice and Report, stating hazards
observed, the regulation or standard which applies, the risk
assessment of the hazard (serious, non-serious, etc.,) the
required abatement measure, the location, division, branch,
type of occupancy, and so on. See Exhibit 4.1 - Safety
Inspection Deficiency Notice and Report.
4.2.2 Required Abatement Request and Reports
A cover letter to the Division or Office Director of the
area inspected will accompany the report and will require a
first abatement report in 45 days and subsequent reports every
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
coordinate such abatement with the division or office
concerned.
4.6 DEFICIENCY ABATEMENT PROCEDURES AND TRACKING
Deficiency or hazard abatement was previously discussed
under Annual Safety Inspections. All deficiencies or hazards
contained in an Annual Inspection Report must be reported on
every 45 days from receipt of the report until all
deficiencies are corrected or abated. Each abatement report
from the Division or Office Director need only refer to those
deficiencies or hazards which were uncovered in the previous
abatement report.
Once deficiencies are reported to the Regional Health and
Safety Manager in an abatement report from a division or
office, each individual deficiency or hazard, its cost,
expected time of abatement and other related factors are
tracked via an automated Deficiency or Hazard Abatement
System. This tracking system will cause a letter to be sent
to the appropriate division or office every 45 days if
Abatement Reports are not received. Also, this system will
enable the Regional Health and Safety Manager to inform senior
management of abatement status and percentage of hazards
abated and other related factors relative to a given division
or office or the Region overall.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Chapter 5 - TRAINING AND CERTIFICATION
5.1 REQUIRED* TRAINING POLICY
All required courses will be provided by the EPA Safety
Manager, with the exception of Superfund training. (Superfund
training will be provided by the Office of Superfund.)
Training will be offered on at least a yearly basis and in a
quantity sufficient to train all individuals required to take
an individual course.
5.1.1 Training for Field and Lab Personnel
Health and Safety training is required for EPA Field and
Lab personnel. This training consists of the following:
initially, a 40-Hour Superfund Hazardous Waste Site Training
course for all OSCs, RPMs, and related personnel, and a
similar 8-Hour Refresher Course yearly. All other field
personnel, including inspectors, are required to take the EPA
24-Hour Field Safety Training course initially and the 8-Hour
Refresher Field Safety Training course yearly thereafter, per
EPA Order 1440.2. Also, a 24-Hour Lab Safety Course must be
taken initially by all lab personnel and a 4-Hour Lab Safety
Refresher course thereafter. Further, supervisors must
receive Safety Management Training yearly. (The requirements
for Lab Safety and Supervisor Training can be found in EPA
Order 1440.2.)
5.1.2 Training for Waste Site Workers
All waste site workers are required by 29 CFR 1910.120 to
receive initial 24- or 40- Hour Safety Training and 8-Hour
Refresher Training yearly.
5.2 40 HOUR FIELD SAFETY COURSE (SUPERFUND)
EPA Order 1440.2 and OSHA 29 CFR 1910.120, Hazardous
Waste Operations and Emergency Response require that employees
working on sites exposed to hazardous substances, health
hazards or safety hazards, and their supervisors and
management responsible for the site, must receive a minimum of
40 hours instruction off the site. Employees shall not be
permitted to participate in or supervise field activities
until they have been trained to a level required by their job
function and responsibility.
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5.2.1 Initial Training Requirements
Prior to engaging in any work at hazardous waste sites
where a possible exposure to hazardous substances, health
hazards, or safety hazards exist, employees must receive a
minimum of 40 hours of off-site instruction. Elements to be
covered must include:
1. Response organization;
2. Safety, health, and other hazards likely to be
associated with work;
3. Use of personal protective equipment;
4. Work practices by which the employees can minimize
risks from hazards;
5. Safe use of engineering controls and equipment on
the site;
6. Medical surveillance requirements including symptoms
and signs which might indicate overexposure to hazards;
7. All required elements of a site safety and health
plan ;
8. Site control;
9. Safe use of specialized sampling equipment;
10. Respiratory protection;
11. Field monitoring instruments;
12. Hazard analysis;
13. Toxicology; and
14. Standard operating safety guidelines.
5.2.2 Additional Initial Training Requirements
In addition to classroom instruction, the employee shall
receive a minimum of three days actual field experience under
the direct supervision of a trained, experienced supervisor.
Field experience should be provided within three months after
receiving classroom instruction.
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5.2.3 Management and Supervisor Training
OSHA requires that all on-site management and supervisors
directly responsible for, or who supervise employees engaged
in hazardous waste operations shall receive 40 hours initial
training, and three days of supervised field experience, and
at least eight additional hours of specialized training on
such topics as, the employer's safety and health program and
the associated employee training program, personal protective
equipment program, spill containment program, and health
hazard monitoring procedure and techniques.
5.2.4 Recordkeepinq and Certification
Employees and supervisors that have received and
successfully completed the training and field experience
requirements shall be certified by their instructor and
trained supervisor as having successfully completed the
necessary training. A written certificate shall be given to
each person so certified. A record of the training and the
certification shall be maintained in the employee's personnel
file. Employees engaging in field activities shall carry
proof of certification with them.
5.3 24 HOUR FIELD SAFETY COURSE fRCRA AND FIELD INSPECTIONS
The employee must have successfully completed the minimum
classroom and field training required for the specified level
of training and must hold certification issued by the Agency
attesting that the employee met these requirements.
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 personal
protection clothing and equipment.
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.
Supervisors and employees are responsible for complying
with the requirements for employee training and certification.
5.4 8-HOUR REFRESHER COURSE FOR ALL FIELD PERSONNEL
Employees at the basic, intermediate, and advanced levels
shall complete a minimum of 8 hours of refresher classroom
instructions annually consisting of a review of all subject
areas to maintain their certification. In addition to the
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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
safe and healthful manner.
For further details on this subject, refer to EPA Order
1440.2 Transmittal- July 12, 1981.
5.5 SAFETY TRAINING FOR LABORATORY EMPLOYEES
All EPA and Contractor personnel who work in EPA owned
or leased laboratory space (this includes laboratories on
research vessels, and all field locations) must meet the
safety training requirements specified in EPA Order 1440 and
Regional Safety Manuals. Chapter eight of EPA Order 1440
specifically addresses working with toxic substances in
Laboratories. Regional and laboratory safety regulations are
designed to comply with the OSHA regulations 29 CFR Part 1910
"Occupational Exposures to Hazardous Chemicals in
Laboratories". Each laboratory may have site-specific safety
manuals and rules including fire escape plans, emergency
plans, and environmental compliance rules.
5.5.1 24 Hour Lab Safety Course
The 24-Hour Lab Safety Course must be completed by all
EPA and contractor personnel who work in any EPA laboratory
part-time or full time. The course is completed once during
the working career of the employee. New employees must take
the course as soon as possible after being hired. Usually the
course will be offered once per year.
New employees must receive training before working in the
laboratory. This training should include the fire escape plan
and any site-specific safety rules. The supervisor is
responsible for providing this safety orientation or arranging
for another qualified person to do so.
The 24-hour lab safety course is designed to cover all
aspects of laboratory safety. Topics include: possible
sources of exposure; adverse health effects; work practice and
engineering controls; environmental and medical monitoring
procedures; personal protective equipment; and storage of
incompatible materials. For further information, refer to EPA
Headquarters Order 3500.1 titled "Training and Development for
Compliance Inspectors/Field Investigators."
5.5.2 4-Hour Lab Safety Refresher Course
The 4-Hour Lab Safety Refresher Course is mandatory
training for all EPA and contractor personnel who work in the
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laboratory. The refresher course must be completed each year.
This course is designed to cover safety topics with personnel
who already have a basic understanding of safety rules.
Recent advances in safety and safety regulations should be
included along with a basic refresher.
5.5.3 Laboratory Safety Orientation
New employees in a laboratory setting require an
immediate safety orientation. The specific safety rules of
the laboratory such as: fire plans, waste disposal
procedures, protective equipment, location of eyewashes, fire
alarms, spill control stations, etc., must be reviewed.
A formal short course is sometimes appropriate and recommended
until the formal 2 4-hour course can be provided. The
orientation can be provided by their supervisor, a safety
designee or other qualified person.
New employees must receive on-the-job training as
specified in Order 1440, chapter eight. The supervisor or
other qualified person must instruct new employees in basic
safety regulations and any specific hazards involved in the
analysis procedures.
5.5.4 Emergency Response Team Training
In some laboratories, it is necessary or desirable to
have a designated emergency response team. The team shall be
trained in spill response and respiratory protection
(including SCBA). The team members should be trained in CPR
and first aid. Practice drills are required on an annual
basis.
5.5.5 Radiation Safety Training
In some laboratories, radiation sources are used in
equipment such as Gas Chromatographs/Mass Spectrometers (GCMS)
or may be used in the actual analysis process. Personnel who
work with radiation must receive training on radiation safety.
Safety Procedures are contained in the Central Regional
Laboratory Radiation Safety Manual.
5.5.6 Environmental Compliance Training
All laboratories generate waste and some wastes are
hazardous under the RCRA regulations. All laboratory
personnel must receive training on the basics of environmental
compliance so they can understand their role in assuring
compliance with the RCRA regulations. This training can be
included in the 24-hour training and/or 4-hour training
courses.
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5.6 FIELD CERTIFICATION PROCEDURES
5.6.1 Certification For Hazardous Waste Site Workers
All EPA employees who work at or inspect hazardous waste
sites (Superfvmd or RCRA remedial action sites) must meet the
requirements of <29 CFR Part 1910.120 "Hazardous Waste
Operations and Emergency Response." Fulfillment of these
requirements will entitle an employee to be field certified to
enter and work at a Hazardous Waste site. A certification
card issued by an authorized EPA representative shall
demonstrate that the employee has fulfilled these requirements
for the applicable year. The certification requirements are
summarized below:
1. Attend 40 hours of approved hazardous waste site
field safety training;
2. Completion of a baseline physical and certification
of fitness by the examining physician;
3. Satisfactory completion of a respirator quantitative
fit test and issuance of a proper size and fit respirator;
4. Completion of three days of field experience at a
hazardous waste site with an experienced, certified senior
inspector.
When these requirements have been met the employee will be
issued a wallet sized card certifying that these requirements
have been completed.
The certification must be updated on an annual basis. To
maintain field certification an employee must complete the
following requirements:
1. Completion of an annual medical monitoring physical
and certification of fitness by the examining physician;
2. Completion of an approved eight hour field safety
refresher course;
3. Satisfactory completion of a respirator quantitative
fit test.
The certification card will be reissued on an annual basis.
5.6.2 Field Certification For Other Field Inspectors
Any employee who conducts audits or inspections at field
locations must meet requirements in EPA Order 1440.2. As
previously described, a certification card issued by an
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authorized EPA representative shall demonstrate that the
employee has fulfilled these requirements for the applicable
year. The basic certification requirements are listed below:
1. Completion of 24 hours of approved field safety
training;
r,
2. Completion of a baseline physical and certification
of fitness by the examining physician;
3. Completion of three days of field experience with an
experienced, certified senior inspector.
When these requirements have been met the employee will be
issued a wallet sized card certifying that the employee has
completed the basic requirements.
The certification must be updated on an annual basis. To
maintain basic field certification an employee must complete
the following requirements:
1. Completion of an annual medical monitoring physical
and certification of fitness by the examining physician;
2. Completion of an approved eight hour field safety
refresher course.
The certification card will be reissued on an annual basis.
Any employee who must be certified to wear a respirator
must also complete an annual quantitative fit test.
5.7 DOCUMENTATION
Documentation for all EPA required training courses and
field certification must be maintained by the employee's
immediate supervisor, the Branch or Division Safety
Representative, the EPA Safety Manager, and the EPA Training
Officer. In all cases, each attender of an EPA required
safety course is to fill out a Standard Form 182 prior to
training and send it to the Regional Training Officer in order
that a permanent record can be maintained in the Human
Resources Branch Training Data Management System.
Required training courses and field certification will be
further recorded and certified by the Safety Manager yearly,
along with certification of yearly medical monitoring and
respirator fit testing, if required. A card will then be
issued to each field inspector or other field personnel
certifying the above information.
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5.8 OTHER HEALTH AND SAFETY COURSES
In addition to courses that are required for field and
lab personnel, other courses will be offered that are intended
for all employees, including office workers who do not
routinely work in unsafe situations. In addition to courses
for non-field/lab^ personnel, courses will be offered that
address potentially serious health risks. Some courses will
be offered consistently throughout the year while others will
be offered occasionally.
5.8.1 Defensive Driving
Courses in defensive driving will be taught. The course
will be taught every year by qualified instructors, such as
members of the National Safety Council. Given the number of
fatalities in the United States resulting from automobile
accidents, a course taken in defensive driving can be a wise
investment.
5.8.2
Courses in Cardio Pulmonary Resuscitation (CPR) will be
taught throughout the year. Instructors may be fellow
employees who have had proper training, or instructors from an
outside agency. Presuming that "someone else" will know CPR
is a dangerous assumption.
5.8.3 First Aid
First Aid, like CPR, will be taught throughout the year.
This course is valuable to all, but especially important to
personnel who are engaged in potentially hazardous activities.
Like CPR, knowledge of First Aid is something that can be
valuable outside of the work place.
5.8.4 Safety Management for Supervisors and Managers
A course designed to teach supervisors and managers how
to play an active role in the safety of their employees will
be taught on a yearly basis. Unlike the other courses in this
section, this course is mandatory for supervisors and
managers.
5.8.5 Office Safety
Courses offered in office safety will be offered on a
yearly basis. These courses are valuable considering the
number of injuries that occur in "safe" office environments.
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Chapter 6 - SAFETY COMMITTEE AND ORGANIZATION
6.1 SAFETY COMMITTEE POLICY
The Occupational Health and Safety Committee is the
medium for achieving the participation of employees in the
Region's Occupational Health and Safety Programs. A well
organized, balanced health and safety committee will have the
diversified knowledge of all job operations and activities in
the Region. The committee is an advisory, not policy making
group. Committee members ascertain facts and render
recommendations so management can make intelligent policy
decisions in the area of health and safety matters affecting
employees. The Regional Occupational Health and Safety
Committees shall:
1. Be effectively supported by management.
2. Be given specific tasks to accomplish, not general
topics of consideration.
3. Include personnel from the program areas which
committee decisions will effect.
4. Provide effective representation of all Regional
employees.
5. Include a cross-section of experts who have an
intimate knowledge of pertinent work conditions and practices.
6.2 SAFETY COMMITTEE ORGANIZATION
Per the Safety Committee Bylaws and as set forth in EPA
Order 1440, the Regional Occupational Health and Safety
Committee is operational in nature and consists of personnel
from Divisions or Offices which the committee's
recommendations will effect.
The committee currently consists of the committee elected
chairperson and members of each Division and Office, appointed
by their Division or Office Director. The number of members
is not strictly set, nor is the term for which each member
serves on the committee.
The Regional Safety Member provides organizational and
technical guidelines for the committee including providing an
agenda for each meeting and, recording and distributing the
meeting's minutes.
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6.3 COMMITTEE OPERATIONS
The Regional Occupational Health and Safety Committee
meets every two months, normally on the second Wednesday of
that month. Issues and subjects covered at committee meetings
include: Annual Safety Inspection and Industrial Hygiene
Survey results, the Medical Monitoring Program, the Annual
Safety Budget, the Radiation Protection Program, the Lab
Safety Program, Personal Protective Equipment (PPE)
Subcommittee, the Safety Training Subcommittee and Program,
and other organizational and technical issues effecting EPA
personnel.
Additionally, three subcommittees, each led by a
chairperson, study issues raised in committee meetings in
greater detail. Subcommittees then make recommendations to
the Regional Occupational Health and Safety Committee for
consideration and possible action. At present, three
subcommittees exist: the Personal Protective Equipment (PPE)
Subcommittee, the Safety Training Subcommittee, and the
Regionwide Safety Issues Subcommittee.
Safety Committee Bylaws, adopted in June 1988, are
currently in effect and govern all activities of the
committee.
6.4 REGIONAL SAFETY ORGANIZATION
The Regional Safety Organization consists of Regional
Occupational Health and Safety Committee members and others
designated as Safety Representatives by their Division
Directors. These Safety Representatives make up the overall
operational Regional Safety Organization as compared to the
Advisory Regional Safety Committee.
The Regional Safety Organization, which is operational in
nature, is managed by the Regional Safety Manager. Safety
Representatives may serve at the Regional, Branch or section
level and assist the Safety Manager in the overall management
of the Health and Safety Program.
Specific duties of Safety Representatives include
coordinating safety inspections and surveys, and scheduling
required training, respirator fit testing, medical monitoring
exams, and related matters for personnel in their
organization.
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All Safety Representatives are required to report medical
monitoring, required training, field certification, respirator
fit testing, medical monitoring exams, and related matters to
the Office of Health and Safety for entry into the Region's
Automated Tracking System. These reports should be prepared
using the designated forms and are to be reported to the
Regional Safety Manager on the first day of each quarter.
In addition, Safety Representatives are expected to
assist their Division Management in reporting abatement status
of health and safety hazards or deficiencies found and cited
during Annual and Semi-Annual Occupational Health and Safety
and Environmental Compliance Surveys and Inspections. These
reports are to be delivered to the Safety Manager every 30
days until all citations are abated.
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Chapter 7 - COMPLIANCE REVIEW
7.1 OVERALL POLICY
All construction, safety related procurements, and safety
related contract activity must be reviewed initially, and
while in process if appropriate, by the Regional Safety
Manager or other professionals working under the direction of
the Regional Safety Manager. This should include any of the
above activities which in any significant manner impact on the
Safety, Occupational Health or Environmental Compliance
(Hazardous Waste handling, transportation or disposal)
relative to Region 5 employees, contractors or the public.
Supervisors, managers, property control personnel, and
procurement personnel all have a responsibility to assist the
Regional Safety Manager in the maintenance or enforcement of
Health and Safety Office policies.
7.2 SAFETY & HEALTH REVIEW OF NEW CONSTRUCTION/REPAIRS
AND ALTERATIONS
All new facility construction activity and significant
repairs and alterations must be reviewed by the Regional
Safety Manager or other professionals working under his/her
direction. The review shall be initiated at the planning and
design phases and continue throughout construction. The
Safety Manager will recommend design changes or design
applications relative to safety, occupational health, fire
prevention & protection, hazardous waste handling & disposal,
and related program areas. As necessary, the Safety Manager
may enlist and coordinate the services of specialized experts
in such fields as fire protection engineering, ventilation,
hazardous waste, and other related fields. All facility
activity impacting life safety must have the approval of the
Regional Safety Manager before it can be undertaken.
7.3 SAFETY & HEALTH REVIEWS OF MARINE REPAIRS AND ALTERATIONS
All construction, repairs or alterations to Region 5 or
GLNPO vessels, labs or other marine equipment in any way
impacting safety, sanitation, occupational health, fire
prevention and protection, environmental compliance or related
issues must have the approval of the Regional Safety Manager
before such activity can be initiated.
All design and planning activity relative to major
shipbuilding or alteration activity must include adequate
input from the Regional Safety Manager.
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The Safety Manager will coordinate, assist or oversee the
activity of specialized experts such as fire protection and
ventilation engineers and others as needed.
7.4 REVIEW OF PPE PROCUREMENT
i'.
All PPE purchases must be reviewed and approved by the
Safety Manager. The signature of the Safety Manager is
mandatory on all purchase requests before final processing for
procurement. Additional information relative to PPE
procurement is contained in Chapter 12 (PPE.)
7.5 REVIEW OF HAZARDOUS MATERIALS AND HAZARDOUS WASTE
DISPOSAL PROCUREMENT
Procurement requests for hazardous materials and
hazardous waste disposal at Region 5 and GLNPO facilities must
be signed off by the Safety Manager or someone designated by
the Safety Manager. This procedure is necessary due to the
complexity of regulations dealing with both hazardous
materials and hazardous waste and the subsequent potential
agency liability.
7.6 HEALTH AND SAFETY REVIEW OF CONTRACTS
Any contracts which involve field or lab work or
otherwise appear to impact health and safety must be received
by the Regional Safety Manager while in the initial planning
stage. All EPA contracts in Region 5 must contain provisions
which require that the contract employee follow all regional
and other safety, health, and environmental compliance rules
and regulations. Final determinations on which rules apply
will be made by the Regional Health and Safety Manager.
7.7 REVIEW OF MISCELLANEOUS PROCUREMENT. IMPACTING SAFETY.
HEALTH OR ENVIRONMENTAL COMPLIANCE
Any procurement issue which has not been addressed in
this chapter but appears to impact safety, health or hazardous
material or waste handling or disposal, should be brought to
the attention of the Regional Safety Manager. The Regional
Safety Manager will then determine what action if any needs to
be taken.
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chapter 8 - ANNUAL SAFETY AWARD
8.1 POLICY
This awajrd is to be granted to an individual or group of
the U.S. EPA Region 5 employees who have demonstrated
noteworthy contributions relative to the Regional Occupational
Safety and Health or Environmental Compliance programs that
year. This award is to be given to an individual or group of
employees for significant achievements which affect the
overall success of the Regional Occupational Safety and Health
or Environmental Compliance Program.
This award is a non-monetary honor award to be granted
once yearly by the Regional Administrator. All award
procedures will be in accordance with EPA #3130 - Awards
Manual - 1983 Edition.
8.2 SELECTION PROCEDURES
The Regional Safety Committee will nominate one or more
candidates or groups meeting specific criteria for this award
and forward the name or names to senior management for final
selection. Specific criteria and the process for selection of
candidates will be developed and distributed by the Regional
Safety Committee.
8.3 OTHER AWARDS
The Annual Safety Award is not intended to exclude the
use of monetary or other non-monetary awards to honor
individuals or groups for significant contributions to Health
& Safety . (In fact, supervisors and managers are encouraged
to do so.)
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Chapter 9 - STANDARD OPERATING PROCEDURES
9.1 POLICY
Written«Health & Safety Standard Operating Procedures
(SOP) must be developed for each distinct activity (eg.
pesticide inspections, PCB inspections, RCRA permit
inspections, RCRA enforcement of TSDs, etc.) related to field
or lab activity. All safety, occupational health and
environmental compliance (hazardous waste transport and
disposal) issues should be addressed in these SOPs. Further
when new SOPs are written, they should only address these
Safety and Health issues and not unrelated operational issues.
Division or Office management has the final responsibility for
the development of safety SOPs and each newly developed SOP
should be reviewed by the appropriate Division or Office
Safety Representative. All SOPs should be readily available
for examination by the Regional Safety Manager during the
Annual Safety Inspection or Survey. All issues of non-
compliance with the policies contained in this chapter will be
addressed in the Safety Manager's Annual Safety Inspection.
No specific format is required for SOPs. However, each
safety SOP should address issues such as Safety Procedures to
be followed, personal protective equipment needed, all
training requirements (formal and on the job), medical
monitoring and respirator fit testing requirements, and
special requirements, such as type of respirator required,
confined space entry requirements, etc. Division or office
management will need to determine the amount of detail in each
SOP (eg. confined space entry issues relative to the specific
hazards encountered may be included, but then the Regional
Confined Space Entry Policy referenced for further
information.) If questions arise as to what should be written
or any other questions relative to a specific SOP, contact the
Regional Safety Manager.
9.2 FIELD SOPs
A safety SOP is required for each type of field activity,
not each task (eg. only one SOP is needed for all pesticide
inspection activity and not a separate SOP for each type of
different sampling technique or method. Field activities are
defined to include all Superfund and RCRA hazardous waste site
activities, all air, waste, and other inspection and sampling
activities by Regional personnel.
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Special emphasis when writing a field safety SOP needs to
be placed on such issues as PPE (personal protective
equipment), required types of respirators to be used and under
what circumstances, and specific safety procedures to be
followed relative to work being performed, etc.
Division and office management has the responsibility to
see that once SOPs are developed, they are followed by
employees and supervisors alike. Employee and supervisor
compliance with a division or office's safety SOPs will be
monitored by the Regional Safety Manager via the Annual Safety
Survey or Inspection process.
9.3 LABORATORY SOPs
SOPs for laboratory operations are required. Two types
of laboratory SOPs are generally recommended: the first
should be a more general SOP addressing issues related to a
specific lab (such as metals labs.) Examples of issues which
should be addressed are general requirements of PPE use in the
area, safety procedures to be followed specific to that lab,
etc. The second type of SOP would, unlike other SOPs
mentioned in this chapter, be included in the specific written
sampling method or technique. That is the specific safety
procedures or Safety SOP is normally included as a part of the
total written sampling method or technique.
Compliance with laboratory safety SOPS by all laboratory
personnel is the responsibility of laboratory and Division or
Office management. Monitoring of SOP compliance will be
performed as part of the required Semi-Annual Regional Safety
Inspections of all laboratories. These SOPs must be
incorporated into an overall Chemical Hygiene Plan for each
laboratory, as required by the most current OSHA regulations.
9.4 MARINE SOPs
All marine sampling, recovery, and operational activities
are required to have SOPs or the equivalent for each specific
activity which impacts safety, health or environmental
compliance. Specific examples of SOPs relative to marine
activity could include lock out - tag out procedures on
research vessels, chain, sling, and rope inspection
procedures, small boat operation procedures, etc. Any
questions relative to the need for specific SOPs for a given
activity should be addressed to the Safety Manager; Division
or Office management has the final responsibility to determine
whether specific SOPs are needed and to obtain compliance with
all SOPs by all personnel involved. Compliance will be
monitored by the Safety Manager during the Annual or Semi-
Annual Safety Inspection Surveys.
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Chapter 10 - MEDICAL MONITORING PROGRAMS
10.1 MEDICAL MONITORING SELECTION POLICY
I*
The Regional Medical Monitoring Selection Policy is
detailed in Regional Order 3130 and is to be followed by all
EPA Region 5 employees to which it applies.
10.1.1 Purpose
The purpose of the Regional policy is to insure
consistency in our approach to mandatory participation in
Medical Monitoring and to ensure that we provide the most
comprehensive health protection possible for our employees.
Baseline and subsequent yearly periodic medical monitoring
exams are required for three categories of Regional employees.
10.1.2 Policy
The three categories for which Medical Monitoring is
mandatory are Hazardous Waste Site Workers, Laboratory
Personnel, and Other Field Personnel or Inspectors who are
exposed to toxic materials. These categories are detailed
within the Procedure section below.
10.1.3 Procedure
The first category of employees, Hazardous Waste Site
Workers, are those who are engaged or involved in clean-up
operations, investigations, inspections, corrective actions or
similar activities at hazardous waste sites, (TSDs) treatment,
storage, and disposal facilities or emergency response
operations involving hazardous substances. Regulations
relative to Medical Monitoring requirements which apply to
Hazardous Waste Site Workers can be found in both 29 CFR
1910.120, Hazardous Waste Operations and Emergency Response,
Final Rule, dated March 6, 1989, and EPA Order 1440.2.
The second category of employees required to participate
in the Regional Medical Monitoring Program is Laboratory
Personnel who regularly work with toxic substances or in the
area of toxic substances which have a risk of impairing the
health of the employee. The regulations covering Medical
Monitoring for Laboratory Personnel are set out in the EPA
Order 1440, Chapter 8.
The third group of employees covered by mandatory Medical
Monitoring consists of Field Personnel who are routinely
engaged in field activities (other than Hazardous Waste Site
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activities) that might expose them to toxic substances or
involve significant physical exertion. These employees are
field inspectors and other personnel who work with toxic
substances, or in the area of toxic substances to the degree
that there is a risk of health impairment, or who frequently
engage in arduous or physically taxing activity, or who use
respiratory protective equipment.
All other personnel who may be exposed to some or all of
the hazards and conditions described in this Order, but to a
lesser degree than the three categories of employees described
herein, are encouraged to enroll in the Regional Medical
Monitoring Program. Final determination, if a question arises
relative to individual participation or application of other
related requirements relative to Medical Monitoring, will be
made by the Regional Safety Manager who will consult with U.S.
PHS Personnel, as appropriate. The determinations made in
this regard are important. A determination that an employee
is in the mandatory category of Medical Monitoring is also a
determination that Medical Monitoring is a condition of
employment in that position. Refusal to comply with this
requirement could represent grounds for disciplinary action up
to removal.
10.1.4 Further References
The regulations relative to Medical Monitoring for the
personnel mentioned in this Order are to be found in EPA Order
1440.2.
10.2 MEDICAL MONITORING PROGRAM PROCEDURES
U.S. EPA, Region 5, has established an agency-wide
medical surveillance program to reduce insofar as possible the
health risks of its employees who may be exposed to toxic
substances or similar hazardous materials. This program is
designed to monitor the health of employees whose work
regularly or periodically poses the possibility of exposure to
hazardous materials. Representative job categories that have
health monitoring made available to them include laboratory
workers. Generally, administrative, fiscal, secretarial, and
other support personnel who have only indirect, infrequent, or
inconsequential incidental exposures are not included.
All personnel who work (regularly or periodically) at
Super fund or RCRA waste sites are required, by law, to
participate in the medical surveillance program as a condition
of employment. (29 CFR 1910.120) Other employees whose jobs
justify inclusion in the program are free to participate or
not as they choose, although EPA recommends participation by
all employees who are referred for an examination.
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Health monitoring is an employer responsibility and EPA
bears the entire cost. When a preexisting or non-job related
condition is detected in the course of a health monitoring
examination, the employee is referred to his/her private
physician for further evaluation, treatment, and follow-up.
The employee must bear these costs. If the condition is later
determined t» have resulted from employment, the employee may
seek compensation and recovery of medical expenses from the
Department of Labor, Office of Workers' Compensation Programs.
The health provider source for EPA employees is the U.S.
Public Health Service (PHS), Division of Federal Employee
Occupational Health (DFEOH) by contractual arrangements. The
PHS/DFEOH health units are located in the Dirksen Federal
Building at 219 S. Dearborn Street and the Federal Office
Building at 536 S. Clark Street (Chicago); in the McNamara
Building (Detroit); and the Federal Office Building (Akron).
Consultation is available with the Regional Occupational
Medicine Officer when a job-related illness is detected or
suspected.
10.2.1 Content of Medical Surveillance Examinations
Medical surveillance consists of a series of blood
chemistry tests, urine tests, and electrocardiogram, pulmonary
function testing, vision tests, hearing testing when there has
been or might be exposure to noise, cervical cytology (Pap
smear test) and pelvic examination (females) , medical and work
history, and a complete hands-on examination by a physician.
Chest x-rays and other special tests may also be included as
necessary. The physician is responsible for explaining the
significance of all findings - no employee should leave the
health unit with unanswered questions or concerns.
10.2.2 Frequency of Medical Surveillance Examinations
- Baseline or preplacement examinations are conducted
prior to a job assignment where exposure to toxic
substances or similar hazardous materials may be
possible.
- Annual examinations are conducted for all persons in
the job categories previously described.
- Termination examinations are conducted at the
termination of employment or before reassignment to an
area where medical examinations are not required, if an
employee has not had an examination within the last six
months.
- Crisis monitoring will be provided to EPA employees who
have experienced acute exposures or other work related
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health hazards, or who report aggravated pre-existing
medical conditions as a result of adverse work
activities, on an emergency basis. Under these
conditions, the employee may report directly to the PHS
health unit for special tests as necessary. For life
threatening emergencies and for non emergencies
occurring outside of normal working hours, the nearest
hospital-based emergency center is the most appropriate
provider of the required services. Prior EPA approval
for medical testing is not required under emergency
circumstances; however, an application for EPA
approval must be submitted promptly to the EPA.
10.2.3 Access to Medical Surveillance Examinations
The EPA Regional Health and Safety Officer develops a
list of employees who are to be examined and provides these
names to the PHS health units. The decision as to whom is
recommended for the program often rests with the Branch Chief
or supervisor most familiar with the possible hazards involved
for employees under their supervision. If you have not been
included in the medical surveillance program and believe you
may be exposed to toxic substances or hazardous materials,
please contact your supervisor.
Upon enrollment in the medical surveillance program, you
will be contacted by the PHS health unit nurse to schedule
your appointment. You will also need to pick up various forms
from the Health and Safety Office to be completed before your
exam - a medical and work history (Baseline or Interim),
Privacy Act Statement, Authorization for Disclosure of
Information (to EPA Regional Health and Safety Officer for
occupationally related findings only), and a medical
questionnaire for respirator users. It is requested that your
supervisor complete two forms - a "Request for Medical
Clearance for Respirator Use" (top portion) and a "Report of
Employee Exposure to Hazardous Substance or Conditions". All
forms will be provided to you by an EPA liaison person or the
PHS health unit nurse.
The medical surveillance examination is normally
accomplished in two visits to the health unit. On your first
visit, basic tests are administered and samples of blood and
urine are submitted to the laboratory. (NOTE: NO DRUG
TESTING OR A.I.D.S. TESTING IS DONE.) A return visit is
scheduled with the physician when all test results have been
received.
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10.3 EMPLOYEE HEALTH MAINTENANCE EXAMINATION PROGRAM fEHMEs1
EPA's policies on employee health maintenance are
described in a Regional Order titled "Employees Health
Maintenance Policy and Procedures." The order describes the
available services under the Employee Health Maintenance
Program. The program provides periodic examinations to
evaluate the health of employees who are not clinically ill.
It is designed to discover previously undiagnosed diseases and
to assist employees and organizations in maintaining optimum
on-the-job health for their employees. EPA, Region 5
participates in this program through the Department of Health
and Human Services, Division of Federal Employee Occupational
Health. The order also describes the process for selecting
candidates for inclusion in the program and the criteria used
in determining eligibility. The examination consists of blood
tests, hearing tests, vision screening and glaucoma tests,
spirometry (a test for evaluating the condition of the lungs) ,
an EKG (a test to evaluate the condition of the heart), a pap
smear (for women), a proctoscopy of the colon (optional), and
a full body physical examination. An employee may not receive
an EHME exam more often than ever two years.
10.4 OTHER HEALTH SERVICES PROVIDED TO EPA EMPLOYEES
Occasionally, there is confusion between the medical
surveillance examination and the EHME-Employee Health
Maintenance Examination. EHMEs are routine general medical
exams, not related specific work exposures. As a
participating agency in the PHS/DFEOH program, EPA is allotted
a certain number of EHMEs per year. EPA, in turn, provides
names of employees who are to receive EHMEs to PHS based on a
set of criteria developed by EPA. The EHME and the medical
surveillance examinations are performed for different reasons
and should be viewed as two separate programs.
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Chapter 11 - FIELD SITE SAFETY PROGRAM
11.1 GUIDANCE AND PROCEDURES FOR SITE ACTIVITIES
AND INVESTIGATIONS
This document establishes policy and requirements, and
assigns responsibility for the Region 5 Occupational Health
and Safety Program for EPA employees engaged in hazardous
substance responses and other work at uncontrolled waste sites
and where applicable to other field activities. (If a
question of applicability arises, contact the Regional Health
and Safety Manager for clarification.)
Personnel performing field work must deal with the risks
associated with such activities. Field personnel cannot
anticipate every hazard, so precautions must be taken to
prevent illness or injury to themselves, other workers, and to
the public.
Since personnel performing field work cannot eliminate
risk, they must reduce it to the lowest feasible level; no
set of rules can be uniformly applied to every situation. All
field personnel must conscientiously apply the requirements of
this chapter at each hazardous substance response or other
uncontrolled waste sites and where applicable to other field
activities.
11.1.1 Responsibilities
11.1.1.1 Assistant Regional Administrator for Planning and
Management (ARA) and Division Directors (DD)
1. Implementing the requirements of this document for
field work performed by Region 5 employees;
2. As appropriate, budgeting the necessary funds for
employee training and certification, personal
protective clothing and equipment, and
occupational medical monitoring programs; and
3. Assuring completion of annual program evaluations.
11.1.1.2 Regional Health and Safety Manager (HSM)
1. Developing, organizing, directing, and evaluating
the Regional Occupational Health & Safety Program;
2. Identifying program areas that require training
and certification, and occupational medical
monitoring;
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3. Recommending or providing training and
certification resources to meet the requirements
specified in Section 11.2.5 of the chapter;
4. Coordinating the investigation of all incidents
involving injury or exposure to hazardous
material*, the resultant accident reporting and
recordkeeping, and the medical monitoring program;
5. Coordinating reports of potential Occupational
Safety and Health Administration (OSHA) violations
for referral to the Regional OSHA office;
6. Coordinating approval of site-specific safety plans;
and
7. Performing an annual evaluation of the Region 5
Field Health and Safety Program by Division.
11.1.1.3 Supervisors
1. Assuring that all field staff and other involved
programs and support staff who are involved in
field work, or conduct a response or
investigation, are qualified by training or
experience and are certified at the appropriate
level as specified in Section 11.2.5, and have the
necessary equipment to conduct the work safely;
2. Assuring that EPA employees are included in the
EPA Occupational Medical Monitoring Program and
have undergone a baseline medical examination
before they are allowed to work on-site (in
compliance with EPA Order 1440.2.);
3. Assuring that a site-specific Site Safety Plan is
prepared and approved prior to the start of on-
site activities for all uncontrolled waste sites.
4. Oversight of review of site-specific site safety
plans prior to submittal to Health and Safety
Personnel for approval;
5. For non-uncontrolled waste site inspections,
assuring that adequate SOPs are in place and that
preinspection planning has occurred prior to an
inspection (see Chapter 9 discussing SOPs).
6. Assuring that requirements for training,
certification, and medical monitoring are properly
contained in position descriptions and vacancy
announcements.
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11.1.1.4 Project Team Leader (PTL)
One member of the field response team assigned as the
lead member on a project team to whom other EPA personnel
would refer for site information or guidance. Examples may
include On-Scene Coordinator (OSC), Remedial Project Manager
(RPM), or Supervisor. The PTL is responsible for:
1. Selecting the level of personnel protection needed
for use at a site and assuring that the necessary
personal protective equipment is available before
EPA employees are allowed to work on-site;
2. Selecting safe work practices and other controls
at sites;
3. Preparing the site-specific safety plan and any
needed detailed procedures for uncontrolled waste
sites when required;
4. Submitting the site-specific Site Safety Plan to the
Supervisor, the Safety Specialist, or the Health
and Safety Manager for review and approval well in
advance of field work dates. Site specific safety
plans are only required for uncontrolled RCRA and
Superfund waste sites.
5. Submitting the site-specific Post-Visit Summary
and Documentation for Hazardous Duty Pay (when
applicable) to the Health and Safety Program
Personnel promptly after site work is completed;
6. Ensuring copies of the approved safety plan or SOPs
are available to all affected program and
supporting EPA personnel, and providing copies to
those employees participating in specific responses
or site related activities;
7. Assuring that EPA employees are trained and
certified in the work practices required to ensure
safety, and are informed of the hazards associated
with site activities before they are allowed to
work on-site (in compliance with EPA Order 1440.2,
Paragraph 9);
8. Designating, if support is needed, one member of the
field response team as the site Safety Officer,
and assuring that the designated person fulfills all
responsibilities necessary for safe operations on-
site;
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9. Supervising the safety performance of the staff to
ensure that the required work practices are used;
10. Arranging for immediate medical attention for any
incident that results in injury or over exposure
of personnel to hazardous substances; and
reporting the incident to the Regional Health and
Safety Manager;
11. Report all accidents and incidents of over exposure
to hazardous materials, and assisting in
investigating accidents;
12. Investigating and reporting in writing any problem
pertaining to operation and implementation of safe
work practices;
13. Correcting work errors and conditions that may
result in injury or exposure to hazardous
substances;
14. Assuring safe and healthful working conditions for
all EPA employees at the site; and
15. Informing non-EPA employees of the hazards and
appropriate measures to assure safe and healthful
working conditions for these individuals.
11.1.1.5 Site Safety Officer
This category is only necessary if one is designated by
the PTL, is responsible for implementing the Safety Plan at
the site. The Site Safety Officer advises the PTL on all
aspects of health and safety on site, and may recommend
stopping work or activities on site, if any operation
threatens employee or public health and safety.
Responsibilities include, but are not limited to, the
following:
1. Participating in the preparation and
implementation of the Site Safety Plan;
2. Selection of appropriate protective clothing and
equipment;
3. Ensuring periodic inspection of protective
clothing and equipment for integrity and proper
maintenance;
4. Ensuring that protective clothing and equipment
are properly stored, maintained, decontaminated,
and/or disposed;
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5. Controlling entry and exit at the Access Control
Points;
6. Coordinating safety and health program activities
with technical, scientific, and support personnel;
7. Confirming each team member's suitability for work
based on a physician's recommendation, and
ensuring each team member has had the appropriate
training;
8. Monitoring the work parties for signs of stress,
such as cold exposure, heat stress, and fatigue;
9. Monitoring on-site hazards and conditions;
10. Conducting periodic inspections to determine if
the Site Safety Plan is being followed;
11. Enforcing the "buddy" system;
12. Knowing emergency procedures, evacuation routes,
and the telephone numbers of the ambulance, local
hospital poison control center, fire department,
and police department;
13. Notifying, when necessary, local emergency
officials;
14. Coordinating emergency medical care; and
15. Ensuring that a safety meeting is conducted with
all employees prior to the initiation of site
activity, and before each work day begins.
11.1.1.6 Employees
1. Complying with the occupational health and safety
program established by this chapter and this Health
and Safety Manual;
2. Reporting to the Site Safety Officer and their
supervisor any unsafe conditions and all facts
pertaining to incidents which resulted in employee
injury or exposure to hazardous substances;
3. Reading, understanding, and complying with the
site-specific safety plan;
4. Carrying out responses in accordance with site-
specific safety plan; and
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5. Participating in the safety training and
occupational medical monitoring programs as
prescribed in EPA Orders 1440.2 and 1440.3.
11.2 PROGRAM REQUIREMENTS
f»
Safety Plans, Standard Operating Procedures (SOPs),
safety inspections, training, certification, and medical
monitoring are all considered requirements of a Regional
Health and Safety Program.
11.2.1 Site Safety Plan
Adequate planning is the first and the most critical
element of performing potentially hazardous field activities.
By anticipating and taking precautionary measures to prevent
potential hazards to health and safety, field activities can
proceed with a minimum of risk to employees and to the public.
There are three necessary aspects of planning: (l)
developing an overall structure for site operations; (2)
establishing comprehensive Work and Sampling Plans (including
information for proper shipping and handling of all hazardous
materials and hazardous wastes generated) ; and (3) developing
and implementing a Site Safety Plan.
The Site Safety Plan (SSP) establishes policies and
procedures to protect on-site employees and the public from
the potential hazards associated with uncontrolled waste site
activities. To be effective, the SSP must be developed and
implemented before site activities begin. The SSP must
provide measures to minimize accidents and injuries that may
occur during normal activities, during adverse conditions, and
during site emergencies.
Development of a written SSP will help to ensure that all
safety aspects of site operations are thoroughly examined
prior to commencing field work. However, the SSP should be
amended whenever necessary to reflect changed site conditions
and/or new information.
Only one Site Safety Plan is required for each site, even
if there will be several visits to the site over a period of
time. Each time an employee visits the site, the SSP should
be reviewed to ensure that there are no changes. If there are
none, the signature page should be submitted to the supervisor
as a record that the employee will be visiting the site and
the SSP has been reviewed. Upon returning from each visit to
the site, a Post-Visit Summary must be completed and
submitted.
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Any time changes are made to the plan, it must be
reviewed by the supervisor and approved. When it is necessary
to make changes to the SSP in the field, or develop a SSP
while in the field, the PTL must contact the HSM for approval.
Detailed Guidance for development of a SSP can be found
in NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities. October 1985; and
EPA-OERR/ERT Standard Operating Safety Guides. July 1988. At
a minimum, the plan should:
A. Name key personnel and alternates responsible for site
safety and response operations;
B. Describe the risks associated with the field work and
with each operation conducted;
C. Specify the training required for personnel to perform
their job responsibilities and to handle the specific
hazardous situations they may encounter;
D. Describe the protective clothing and equipment to be worn
by personnel during various site operations and for each work
zone of the site;
E. Describe site-specific medical surveillance requirements;
F. Describe the program for periodic air monitoring,
personnel monitoring, and environmental sampling, if needed;
G. Describe the actions to be taken to mitigate existing
hazards (e.g., containment of contaminated materials) to make
the work environment less hazardous;
H. Define site control measures and include a site map;
I. Establish decontamination procedures for personnel and
equipment;
J. Describe proper disposal of hazardous materials and
hazardous wastes generated on-site;
K. Set forth a Contingency Plan for safe and effective
response to emergencies; and
L. Set forth the site's Operating Procedures. Operating
Procedures should be developed for those activities that can
be standardized (e.g., decontamination procedures, respirator
cleaning/sanitizing procedures, and emergency procedures).
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These procedures must be prepared in advance and may include
checklists. These procedures must be:
1. Based on the best available information,
operational principles, and technical guidance;
2. Field-tested or reviewed by qualified health and
safety professional, and revised as appropriate;
3. Appropriate to the types of risk at that site;
4. Formulated to be easily understood and practiced;
5. Provided in writing to all site personnel, who
must be briefed on their use; and
6. Included in training programs for site personnel.
11.2.2 Site Specific Safety Plan
A. Appendix A contains an example of a Site-Specific Safety
Plan that can be adapted for field activities. The Site
Specific SSP is intended primarily for low-to-moderate hazard
situations and is suitable for most Level B/C/D inspection and
sampling activities. Level A activities require additional
documentation to support the added requirements.
Appendix B contains an example of a Post-Visit Summary
which must be forwarded to the Superfund Safety Specialist or
HSM as soon as possible after returning to the Regional
Office. The Post-Visit Summary provides feedback and serves
as documentation of hazards actually present on the site and
the procedures used to mitigate the hazards.
B. Site Specific Safety Plans are generally required for any
uncontrolled hazardous waste site including emergency response
situations involving hazardous materials or waste. Field SOPs
can be used for all other field activities.
11.2.3 Safety Meetings
To ensure that the site Safety Plan is being followed, a
safety meeting will be conducted prior to initiating any site
activity and before each work day. The purpose of these
safety meetings is to:
A. Describe the assigned tasks and their potential hazards;
B. Coordinate activities;
C. Identify methods and precautions to prevent injuries;
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D. Describe any changes in the Site Safety Plan;
E. Obtain employee feedback on how well the Site Safety Plan
is working; and
F. Discuss actions to be taken during emergency situations.
f»
11.2.4 Safety Inspections
The Site Safety Officer should conduct frequent
inspections of site conditions, facilities, equipment, and
activities to determine whether the Site Safety Plan is
adequate and being followed.
At hazardous sites, risks to workers can change quickly
and dramatically when there are changes in:
A. Work and other site activities;
B. State of degradation of containers and containment
structures;
C. State of equipment maintenance; and
D. Weather conditions.
The minimum frequency at which to make inspections varies
with the characteristics of the site and the equipment used on
the site.
11.2.5 Training and Certification
Before participating in any non-administrative field
activity, all EPA employees must have received training
commensurate with the degree of anticipated hazard; as
appropriate, hold valid Certification at the Basic Level; and
have completed a minimum of three days of field training with
experienced field personnel. (40 hours field training is
required for uncontrolled waste sites.)
In addition, in order to remain current in certification,
employees are required to attend recertification training (8
hours minimum/year) on an annual basis, provided by Region 5
11.2.6 Medical Monitoring
All EPA 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 must
be included in the EPA Occupational Medical Monitoring
Program.
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11.3 WORK PRACTICES REQUIREMENTS
The work practices specified in this section must be used
by all personnel at all responses.
11.3.1 Personnel Practices
&
11.3.1.1 Protective Clothing
Appropriate protective clothing must be worn by all
personnel while on-site unless sufficient information has been
acquired to enable the PTL to make an informed judgement that
protective clothing is not needed.
11.3.1.2 Emergency Procedures
After obvious skin contact with a hazardous substance,
all personnel must initially flush the affected area with a
copious amount of water. Seek medical attention if necessary.
Record a Post-Visit Summary.
If a hazardous substance should contact the eye,
immediate action is necessary. Both eyes should be held open
and flushed with a copious amount of water. Seek medical
attention if necessary.
If water is not available for these procedures, alternate
procedures must be explained in the SSP. Emergency eye-washes
must be available within 100 feet of the hazard, or within a
10-second access time.
11.3.1.3 Personal Hygiene
Whenever possible, all personnel, except for observers
must shower before entering clean areas after having been in
contaminated areas. If it is not feasible to have shower
facilities available at the site, personnel must shower at
their first opportunity.
Prior to rest breaks, eating, drinking, smoking, applying
cosmetics, or departing from the site, all personnel must wash
their hands and face.
11.3.2 Additional Operational Practices
11.3.2.1 Sampling Procedures
Sampling procedures must minimize the risk of personal
exposure to hazardous materials during sampling, packaging,
shipping, unpacking, and analysis and the exposure of others
to spilled or residual waste materials. Specific procedures
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can be found in the Sample Plan, including shipping and
handling requirements.
11.3.2.2 Sampling Equipment
Sampling equipment used on a response should be
disposable ifr possible. Sampling instruments and other non-
disposal equipment should be kept clean with disposable
protective covers. Scoops, sampling tubes, and similar
devices should be placed in plastic bags for disposal or later
decontamination.
11.3.2.3 Decontamination of Personnel and Equipment
Decontamination protects employees from hazardous
substances to which they have been exposed while working on
the job, and prevents the spread of contamination to clean
areas. Personnel decontamination will usually occur in a
contamination reduction area and may consist of
decontaminating protective clothing and/or proper removal of
contaminated clothing for disposal.
Equipment should be decontaminated prior to leaving the
site whenever possible. Equipment which cannot be
decontaminated at the site must be double bagged and
transported to another area for eventual decontamination.
When possible, verify completeness of decontamination (e.g.,
with sniffers, wipe tests or other appropriate methods.)
11.3.2.4 Packaging and Shipping
Hazardous substances must be packaged to withstand
shocks, pressure changes, and any other conditions which might
cause the leakage of contents incident to ordinary handling
during transportation. Shipments of hazardous substance must
be in accordance with DOT regulations, and 49 CFR.
11.3.2.5 Leaving the Site
Procedures for leaving the suspect contaminated area must
be planned before entry. Provision must be made for:
decontamination and safe packing of protective samples and
preparation of samples for shipment; transfer of equipment,
gear, and samples for shipment; transfer of equipment, gear,
and samples from the "contaminated" area to the "clean" area;
etc. Sequences will depend on several variables and must be
worked out in advance.
11.3.2.6 Site Monitoring Equipment
Use direct reading instruments (e.g., portable
combustible gas and oxygen meter, photo-ionization meter, gas
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chromatograph, infrared spectrometer, radiation survey meter,
and colorimetric detector tubes) for immediate evaluation of
potential hazards. The limitation of these instruments for
characterizing the hazardous substances at the sites must be
remembered.
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LIST OF REFERENCES
United States Environmental Protection Agency Occupational
Health and Safety Manual (3/18/86)
NIOSH/OSHA/USCG/EPA, Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities. October 1985.
EPA-OERR/ERT, Standard Operating Safety Guides. July 1988.
Title 29, Code of Federal Regulations, Part 1910.120 (29 CFR
1910.120).
Title 49, Code of Federal Regulations (49 CFR).
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APPENDIX A
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Region 5 Health and Safety Manual
APPENDIX A
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 9
OFFICE OF POLICY AND MANAGEMENT
HEALTH AND SAFETY OFFICE
SITE SAFETY PLAN
FOR
HAZARDOUS SUBSTANCES RESPONSE AND FIELD INVESTIGATIONS
I. DESCRIPTION OF FIELD ACTIVITY:
Site: • ___ Site Phone: ( )_
Location: ; Superfund : Yes No
SSP Prepared By: Mail Code ( ) Phone -_
Proposed Date of Response/Investigation:
Purpose/Ob j ective:
Background Review: Complete Preliminary
Background Material Attached: Yes No
Indicate which of the following information source(s) were consulted:
State and/or Local Agency, State and/or Federal OSHA, NIOSH, EPA
files, Site Operator and Local Fire Department.
Overall Hazard Summary: Low High
Medium Unknown
Route of Exposure: Inhalation Skin Contact Ingestion
Map or Sketch Attached: Yes No
EPA-9 FORM HS0003 !/89
BLG.007
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Region 5 Health and Safety Manual
II. SITE CHARACTERISTICS;
A. Facility Description:
B. Hazardous Substance(s) Description:
C. Disposal/Storage Methods:
D. Status: Active Inactive Unknown
E. History: (Include accidents or injuries on-site, complaints from
public, previous releases and agency reports):
F. Is personal protective equipment required by Facility/Site Manage-
ment? List equipment and specific areas where required:
G. Are employees working at the facility/site monitored for exposure
to airborne contaminants? If so, describe situation:
H. Do employees working at the facility/site participate in an oc-
cupational medical monitoring program? If so, are special biological
tests performed or Biologic Limit Values (BLVs) used?
I. Describe medical monitoring procedures for evidence of personnel
exposure:
J. Is there an on-site emergency alarm system? If so, describe alarm:
K. Is there an eyewash/safety shower available on site? If not, ex-
plain alternate procedures (where applicable):
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III. HEALTH AND SAFETY CONSIDERATIONS:
Hazard Assessment1 (Toxic effects, TLV, odor threshold, reactivity,
stability, flamnability, and operational hazards with sampling, decon-
tamination, etc.): __ .
Areas of Concern2' Hazard Potential^ Precautions
Explosion:
Oxygen Deficiency:
(e.g. Confined Spaces) ;
Radiation:
Toxic Gases:
a. General (HNU meter)
b. Specific: (e.g.,
Sorbent or Detector Tube)
Skin/Eye Contact:.
Heat Stress:
Falling Objects:
(e.g. stacked barrels, '
etc.)
Falls:
(e.g. pits, ponds, ele-
vated work places, etc.)
Confined Spaces:
(e.g. manholes, vaults, ~~~ ~
closed rooms, trenches,
etc.)
_i: Attach copy of Hazardous Substance Information Form
(Appendix C) , Material Safety Data Sheet (MSDS), OHMTADS,
Hazardline printouts, etc..
Not:e 2: See Chapter 2, FHSM, "Atmospheric Hazard Action Guides"
Kote 3: Subjective evaluation (e.g., low, moderate, high, unknown
or not applicable.
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IV. WORK PLAN INSTRUCTIOHS:
hazardous Substance Sampling and Field Investigations
A. Level of Protection: A B C D
Modifications:
Surveillance Equipment and Materials:
B. Entry Procedures:
C. Field Investigation and Decontamination Procedures:
Perimeter Establishment: Zones of Contamination Identified?
Public Perimeter Identified? Map/Sfcetch Attached?
Notes: ________________
Team MaXe-Op: EPA FIT TAT CG STATE OTHER
Station Designation (Name/responsibility) :
1. 4.
2. 5.
3. 6.
Work Schedule/Limitations:
Hot Line Location (initial) :
Command Post - Location (initial):
- Radio Call Sign:
- Frequency/Channel:
Equipment and Materials/Special Facilities:
Decontamination Procedures (contaminated protective clothing, in-
struments, equipment, etc.): _
Disposal Procedures (contaminated equipment, supplies, disposal
items, wash water, etc.):
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V. EMERGENCY PRECAUTIONS:
Acute Exposure Symptoms
Agent Symptom
First Aid
A. Nearest Hospital Emergency ROOD. Note: for remote loca-
tions, give directions to hospital and attach nap.
Name:
Address: _
Telephone:
B. Emergency Services (Telephone Numbers)
1. Fire:
2. Police:
3. Ambulance
C. Poison Control Center of San Francisco
Toxic and Hazardous Chemicals: 415-476-6600 (24-Hr.)
D. Regional Health and Safety Office: 415-974-7422 or -8377
E. Regional Radiation Representative: 415-974-8378
F. Office of Radiation Programs, Las Vegas Facility (ORP-LVF):
702-798-2476 FTS 545-2476
APPROVALS:
Project Team Leader:
Supervisor:
Date:
Health and Safety Office:
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Appendix B
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APPENDIX B
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 9
OFFICE OF POLICY AND MANAGEMENT
HEALTH AND SAFETY OFFICE
POST-VISIT SUMMARY
r Field
Employee (s): ___________ Activity Datc(s)
Site: _ City/State:
If Superfund, list Site Number:
1. Protection Level Used: A 8_
a. Level B/C - SJcin protection: Tyvek Tyvek/Saranex
Acid/Rain- Other
b. Level C - Identify Cartridge/Canister.
c. Level D - Provide Justification for Hazard Pay Differential.
2. Monitoring Instruments Used: On-Site Levels
a. Combustible gas indicator * LEL
b. Oxygen concentration meter * Oxygen
c- Radiation survey meter (Type: ) mR/hr
d. Organic vapor survey meter (Type:
e. Colorimetric tubes (Type: ) ppm
f. Other ( )
Did any of the above—mentioned employees experience respirator
cartridge breakthrough? If yes, explain. Yes No
4. Equipment Decontamination: a. Clothing b. Respirator c. Monitoring
Disposed:
Cleaned:
No Action:
5. Approximate time in hot zone/exclusion area:
6. Was Medical attention/exam required for this response: Yes No
If Yes, explain:
7~IDate Supervisor's
Prepared: Signature: Date:
For additional comments use reverse, or additional pages.
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Chapter 12 - PERSONAL PROTECTIVE CLOTHING & EQUIPMENT
12.1 POLICY AND RESPONSIBILITY
This section establishes policy, responsibilities, and
practices for the procurement, issue, control, and use of
protective clothing and equipment by Region 5 employees
engaged in laboratory and field activities.
12.1.1 Policy
It is the policy of the Environmental Protection Agency:
1. To administer its programs in a manner that will
assure the protection of the health and safety of all
personnel in routine field and laboratory work.
2. To assure personnel engaged in field or laboratory
work of a hazardous or toxic nature additional levels of
protection by providing and requiring the use of specified
protective clothing and equipment.
12.1.2 References
1. Occupational Safety and Health Act, P.L. 91-596.
2. 29 CFR 1910, Subpart I. Sections 132, 133, 134, 135,
136, 137, and 139.
3. EPA Order 1440.2 Health and Safety Requirements for
Employees engaged in Field Activities, EPA Order 1440.3
Respiratory Protection.
12.1.3 Definitions
The applicable terms used in this chapter are defined in
the following paragraphs.
12.1.3.1 Field Activities
The term field activities as used in this chapter means
EPA program activities that are conducted by EPA employees
outside of EPA administered facilities. These activities
include, but are not limited to, environmental and pesticides
sampling, field analysis, inspection of water and wastewater
treatment plants, hazardous material spills and waste site
investigations, inspections, and sampling.
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12.1.3.2 Routine Laboratory Activities
The term routine laboratory activities means EPA program
activities that are conducted by EPA employees in an EPA
administered laboratory facility.
12.1.4 Applicability
The provisions of this chapter are applicable to all
Region 5 EPA employees at all operational levels. They are
also applicable to employees of EPA contractors and are to be
specified by contract established to perform the work.
12.1.5 Background
Field and laboratory activities are a critical part of
EPA Region 5 program operations. Therefore, it is the
responsibility of the Agency to establish safety rules,
practices, and procedures for the use of personal protective
clothing and equipment.
12.1.6 Responsibilities
The duties assigned Regional personnel with regard to
Personal Protective Equipment (PPE), are detailed in the
following paragraphs, broken down by individual title.
12.1.6.1 Regional Administrator
The Regional Administrator is responsible for
implementing the regional safety program of which the
requirements of this chapter are a part. It is the
responsibility of the Regional Administrator to require
Division and Office Directors to budget the funds necessary to
procure personal protective clothing and equipment.
12.1.6.2 Division and Office Directors
The Division and Office Directors are responsible for
assigning staff to field and laboratory work which may require
the use of personal protective clothing and safety equipment.
12.1.6.3 Supervisors
In accordance with the procedures of this manual, the
supervisor is responsible for determining the level of
protection required (in consultation with the Health and
Safety Officer). He/she is responsible for controlling,
issuing, and inspecting the protective clothing/equipment in
their section. He/she is responsible for identifying
employees who require protective prescription lenses and for
having these employees provide current prescription. He/she
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is responsible for keeping an accurate inventory and for
maintaining the protective clothing/equipment in a functional
condition. He/she is responsible for identifying employees
who require training and certification; for assuring those
employees receive training and certification in compliance
with the provisions of EPA Orders 1440.2, 1440.3, and OSHA 29
CFR 1910.120<; and for ensuring these requirements are
contained in their position description. He/she is
responsible for recommending appropriate correction and/or
disciplinary action of employees who violate or neglect safety
requirements.
12.1.6.4 Regional Health and Safety Manager
The Regional Health and Safety Manager (RHSM) is
responsible for assisting supervisors select, procure, issue,
and maintain protective clothing and equipment. He/she
reviews every procurement request related to safety, health or
personal security, to assure that the request is justified and
the requested item is appropriate. He/she will determine if
the item, or an acceptable alternative, is available in the
Region, based on the Regional inventory of all protective
clothing/equipment that he/she maintains. He/she will
annually perform a review and audit of the condition
inventory, and use of protective clothing/equipment for each
Division and Office. A report of this annual review/audit
will be distributed to all Division/Office Directors. He/she
is responsible for identifying program areas that require
training and certification. As a member of the Region 5
training committee, he/she advises the Office of Personnel on
the Health and Safety training requirements of EPA 1440.2,
1440.3, and OSHA 29 CFR 1910.120 and recommends the funding
needed to accomplish task. The Regional Health and Safety
manager shall be responsible for administering the Respiratory
Protection Program in Region 5. He/she is responsible for
negotiating and determining the Regions requirement and for
preparing the consolidated Procurement Requests (and
individual PR's) for Regional protective clothing/equipment.
12.1.6.5 Employee
Employees are responsible for the protective clothing
and/or equipment issued to them and are required to wear and
use the clothing and equipment as prescribed in this chapter.
Employees are responsible for reporting any damage and/or
malfunction of the clothing/equipment issued to them.
Employees are responsible for providing a current prescription
at their own expense if the supervisor has determined that the
government will provide protective prescription eyewear.
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Employees assigned protective clothing and/or equipment are
required to sign a receipt for such items to include the
following statement:
1. They have received proper training in the use and
maintenance of these items;
«»
2. They have read the safety procedures and agree to
accept the responsibilities provided therein.
3. Each person is responsible for the maintenance and
use of the protective clothing and equipment assigned to him
or her. Cleaning, sanitizing and maintaining the respirators
is included in his responsibility. Any damage, excessive
wear, or malfunction of the equipment must be reported
immediately to the individual's supervisor. Individuals are
also responsible for the cost of replacing items of protective
clothing or equipment lost, damaged, or stolen through their
own negligence.
4. Items provided from a general supply will be
maintained by the organizational unit responsible for its
supply and issuance.
12.1.6.6 Organizational Units Engaged in Hazardous Field Work
Each organizational unit regularly engaged in hazardous
or potentially hazardous field work will be responsible for
maintaining an adequate supply of disposable coveralls and
gloves, and replacement filter cartridges for respiratory
protective devices. In addition, lockable cabinets will be
provided for storage of these items.
For organizational units that are engaged in frequent
hazardous or potentially hazardous field work, a general
supply of respirators, pull-on rubber boots and disposable
coveralls and gloves will be made available.
12.2 PROTECTIVE CLOTHING AND EQUIPMENT REQUIREMENTS
It is a policy of the Agency to determine the level of
protection required for employees assigned specific duties, to
provide the protective clothing/equipment and to enforce its
correct use. Specific information on the appropriate material
for protection against a particular chemical exposure is
available by consulting the Regional Health and Safety
Manager.
The Agency requires the use of protective clothing and/or
safety equipment when there is a probability of injury that
can be prevented by the use of such equipment. No unprotected
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person shall knowingly be subjected to hazardous environmental
conditions. All laboratory and field operations should be
employed to ensure that adequate protective clothing/equipment
is required and used.
12.2.1 Eye and Face Protection
*»
Descriptions of the protective equipment available
specifically for the eyes and face are included in the
following paragraphs.
12.2.1.1 Protective Eye Wear
Protective eye wear, including plain and prescription
lenses, shall be provided to all field and laboratory
employees. They must be worn when the danger of eye injury
exists. No one may enter a controlled location where eye
protection is mandatory without such equipment. Areas in a
laboratory, or on-site locations may be designated as
controlled areas by the person in charge. It is his
responsibility to determine the level of protection required
and to enforce its use.
12.2.1.2 Safety Glasses
Safety glasses that comply with the standard for
Occupational and Educational Eye and Face Protection (OSHA
Regulation) shall be the minimum eye protection required for
regular use in EPA Region 5. This standard requires that the
glasses pass a flammability test, consist of lens retaining
frames, contain a minimum lens thickness of 3mm and are impact
resistant. Safety glasses meeting this standard will be
suitably marked with the manufacturer's identification.
12.2.1.3 Face Shields
Safety glasses or goggles offer little protection to the
face and neck. Full face shields that protect the face and
neck shall be worn when the maximum protection from flying
particles and splashes from harmful liquids is needed. Face
shields are not a primary eye protection device and are
designed for use over the protective eyewear identified for
the operation.
12.2.1.4 Contact Lenses
Contact lenses are not protective eyewear. In situations
where protective eyewear is required, the person in charge
will determine if contact lenses may be worn, and if so, they
must be worn with appropriate eye protection as determined by
29 CFR 1910.134. Contact lenses may not be worn where there
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is a risk of exposure to: intense heat; molten metals; high
particulate containing atmospheres; chemical fumes, vapors or
splashes; or while wearing a respirator.
12.2.2 Head Protection
All head protection must meet the requirements of current
OSHA requirements. Head protection will be worn by all Region
5 employees where there is danger of injury from limited
electric shock or from falling or flying objects. Head
protection is required at waste-clean up sites where injury
may result from operating equipment. Employees are required
to wear head protection during all inspections of industrial
and chemical plants, waste disposal operations, and sites
where any of the above hazards exist.
12.2.3 Protective Apparel
Protective apparel is required for most field and
laboratory work performed in the Region. It should resist
physical hazards while allowing the wearer to easily perform
manual tasks. It should be strong, resistant to chemical and
thermal penetration, flexible, and easy to clean. The
performance requirements are to be determined by the
substances being handled. It is the responsibility of the
supervisor to determine the choice of garment to be worn
(laboratory coat, coveralls, rubber or plastic aprons, splash
suits, fully encapsulating disposable coveralls, etc.)
12.2.3.1 Aprons, Coveralls, Splash Suits
Plastic or rubber aprons, coveralls or splash suits
provide protection from corrosive or irritating liquids;
however, they can accumulate a charge of static electricity
and in the case of fire can complicate injuries. Therefore,
they should not be worn in areas where flammable solvents or
other materials could be ignited by a static charge.
12.2.3.2 Flame Resistant Garments
Pants, jackets and hardhat liners with appropriate
chemical treatment and of proper design provide protection
from fire hazards such as unexpected furnace flames and from
the potential hazard of splashing molten metal. Jackets with
pockets only on the inside help to prevent injury in the
presence of high temperature airborne particles. Similarly,
properly fitted jackets and pants, which are not rolled up,
can also prevent injury. Employees are required to wear
chemically treated jackets and pants during all coke oven
battery and blast furnace casthouse inspections. Employees
are required to wear chemically treated jackets, at a minimum,
during inspections at basic oxygen furnace shops, electric arc
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furnace shops and facilities with electric arc furnaces and
cupolas. It is important that this type of clothing be
chemically treated after each washing.
12.2.3.3 Disposable Outer Garments
Disposable outer garments (e.g. Polyethylene, Saran
Coated or Tyvek) may, in some cases, be preferable to
reusable ones. Examples include the handling of quantities of
highly toxic or carcinogenic materials. Disposable full
length suits are recommended for high risk situations;
however, many disposable garments offer limited protection
from vapor penetration and their use should be determined by
the supervisor.
12.2.3.4 Disposal of Contaminated Garments
Garments should be disposed of in accordance with
disposal and decontamination procedures provided by the
provisions of the Specific Site Safety Plan or SOP or similar
rule.
12.2.4 Gloves
Gloves will be worn when it is necessary to handle
corrosive materials, sharp or rough objects, hot or cold
materials, or when there is a possibility of exposure to
chemicals. Gloves will not be worn near machinery if they may
cause bodily injury as a result of being caught in the
machine.
The following additional requirements will be met:
1. Gloves will be selected based on their intended use,
the hazard involved and their suitability for the job.
2. Before use, gloves will be inspected for punctures,
tears or discoloration.
3. Gloves will be appropriately cleaned before removal.
4. Leather gloves will be used for handling broken
glassware, for inserting rubber stoppers into glass tubes, and
for similar operations where protection from chemicals is not
needed. Leather gloves will be used for protection against
rough or sharp-edged objects, hot or cold materials, or when
there is a possibility of exposure to chemicals. Gloves will
not be worn near machinery if they may cause bodily injury as
a result of being caught in the machine.
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5. Specialized gloves are manufactured for specialized
activities. These activities include:
A. Electrical operations or fish shocking activities
where the use of rubber insulated gloves meet
OSHA regulations.
*<
B. Working at temperature extremes where the use of
gloves made with such materials as Nomex or Kevler
or in combination with other materials is required.
12.2.5 Foot Protection
All safety footwear must meet the requirements of OSHA
regulations. Shoes must be worn at all times in areas where
chemicals are stored or used. Perforated shoes, sandals or
cloth sneakers must not be worn in laboratories or during any
field work. Safety-toe shoes must be worn by all Region 5
employees who regularly engage in moving, lifting, handling or
carrying supplies, materials, equipment, furniture, or other
objects of such weight, that accidental injury to the toes
from falling or shifting of such objects may result. Foot
protection other than ordinary shoes may be required in
special cases. Safety-toe shoes or safety-toe boots are
required for most field activities. Rubber boots or plastic
shoe covers are to be worn over safety-toe shoes to avoid
possible exposure to corrosive chemicals or to large
quantities of solvents or water that may penetrate normal foot
gear (e.g., during clean-up operations.) Because these types
of boots and covers may increase the risk of static spark,
precautions should be taken in their use in hazardous
locations.
12.2.6 Respiratory Protection
Approved respirator protection will be worn by Region 5
employees when they are working in, or when they encounter
hazardous atmospheres exceeding the Permissible Exposure
Limits in suspected oxygen deficient atmospheres, or where
there is imminent danger of release of airborne toxic
substances.
The selection and use of respiratory protection will be
made in accordance with the requirements of EPA Order 1440.3
Respirator Protection with other EPA SHEMD guidelines (HQ) and
With OSHA 29 CFR 1910.134.
12.2.6.1 General Requirements
As a general requirement, respirators should be selected
based on toxicity, maximum expected concentration, oxygen
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percentage (possible deficiency), immediate danger to life and
health (IDLH), warning properties (adequate or not), sorbent
limitations, face piece fit, mobility requirements and type of
use (routine, escape, or emergency entry).
12.2.6.2 Basic Criteria
Specific selection of respirators is based on a decision
logic system using basic criteria: skin absorption, sorbent
efficiency, eye irritation, IDLH assessment, etc. Specific
respirator selection will be made in accordance with Region 5
Respirator Protection Program.
12.2.6.3 Full Face Piece Protection
Full face piece respirators are required for Remedial and
Spill Response personnel. At present, half mask chemical
cartridge respirators are approved for industrial inspections
when skin and eye irritants are not present. Proposed OSHA
standards will not approve the use of half mask chemical
cartridge respirators.
12.2.6.4 Air Purifying Respirators
Air purifying respirators shall not be worn:
1. In oxygen deficient atmospheres.
2. If the substance involved in the contaminated
atmosphere has poor warning properties. Warning properties
are odor, taste, eye irritation, and respiratory irritation.
Warning properties may be assumed to be adequate when odor,
taste or irritation effects of substance can be detected and
are persistent at concentrations at or below the permissible
exposure limit (PEL).
12.2.6.5 Self Contained Breathing Apparatus
Only approved pressure demand Self-Contained Breathing
Apparatus (SCBAs) are allowed. An airline is an appropriate
equipment item in addition to a SCBA provided that it is
equipped with an appropriate self-contained emergency escape
air supply.
12.2.7 Non-Personal Protective/Safety Equipment
In Laboratories
Emergency alarm systems, safety showers, eye wash
fountains, fire extinguishers, and other such equipment will
be provided as part of the laboratory work place. The
requirements and technical standards are set forth in 29 CFR
1910.
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12.2.8 Emergency Equipment
The following equipment is required for laboratory
emergencies. The equipment should be stored together in a
central location or located closest to the laboratory
operation having the highest risk of an emergency situation.
it
Quantity Description
2 Positive pressure (pressure demand) self
contained breathing apparatus (SCBA)
(MSHA, NIOSH approved)
2 Fully encapsulated suits*
2 Hooded, chemical splash suits
2 Chemical resistant disposable coveralls
1 Spill control cart with spill control
equipment
1 Thin window geiger counter (o-5mr/hr)
minimum*
*Optional
Several pairs of gloves are also required. The gloves
should be selected to protect against a variety of corrosive
or toxic materials. Leather and insulated gloves should also
be included in the selection.
All of the above equipment should be inspected
periodically (at least every six months.) The SCBAs should be
inspected after each use or at least once a month.
12.2.9 Additional Protective Requirements
To prevent injury and protect the skin, laboratory
personnel may not wear loose, ragged or torn clothing or
laboratory coats, meager or insufficient clothes (e.g., shorts
and/or halter tops) or unrestrained hair.
12.3 ISSUANCE AND TRAINING IN THE USE OF PROTECTIVE CLOTHING
AND SAFETY EQUIPMENT
All of the protective clothing/equipment listed in this
manual for specified use for laboratory work or field
operations must be issued to the employee or must be
available. If PPE is required for the task, it must be taken
to the point of operation. It must be worn and/or utilized as
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necessary in performing the activity. For laboratory work,
clothing/equipment available on site satisfies the intent of
this manual.
12.3.1 Issuance of Protective Clothing/Equipment
12.3.1.1 Standard Level of Protection Provided
The Agency will provide each employee substantially and
regularly engaged in field work as appropriate with the
following: safety toe shoes; or toe caps, safety
glasses/goggles and face shield (prescription safety glasses
will be provided when safety goggles do not fit over regular
prescription glasses), and an approved hard hat.
12.3.1.2 Field Work of a Hazardous Nature
In addition to the above, the Agency will provide each
employee assigned to field work of a hazardous or potentially
hazardous nature the following items: disposable coveralls,
disposable gloves, pull on safety toe rubber boots (knee
high), and a respirator (as appropriate.)
12.3.1.3 Specialized Field Work
The Agency will provide personnel assigned to specialized
field work (e.g., GLNPO and CERCLA personnel) work
clothing/equipment as necessary. This may include: life
preserver; exposure suit; waders, or fully encapsulated
protective suit. Employees assigned to field work, when there
is the potential of fire, will be issued fire resistant
coveralls and jackets (e.g., Nomex.) Employees who need
respiratory protection and prescription lenses will be
provided prescription lenses mounted in a special frame to fit
the respiratory equipment.
12.3.2 Training
All employees engaged in field work will receive training
and certification in compliance with the provisions of EPA
Order 1440.2 and 1440.3. Employees shall not be permitted to
engage in routine field activities unless they have been
trained and certified to a level commensurate with the degree
of anticipated hazards. All employees shall be provided with
a minimum of 24 hours of health and safety training prior to
their becoming involved in normal routine field activities.
In addition, employees engaged in field activity requiring the
use of respiratory protective devices must be properly trained
in the selection and use of such devices and certified that
he/she is physically capable of wearing such equipment.
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Chapter 13 - RESPIRATORS
13.1 PURPOSE
f *
The purpose of this program description is to provide
written standard operating procedures governing the selection
and use of respirators as required by EPA Order 1440.3,
Respiratory Protection and by the Occupational Safety and
Health Administration (OSHA) Regulations 29 CFR 1910.134.
13.2 BACKGROUND
OSHA has set permissible exposure limits for many
workplace airborne toxic materials. If employee exposure to
the substances exceeds these limits, the regulations require
that feasible engineering controls and/or administrative
controls be installed/instituted. If engineering/
administrative controls cannot be implemented, 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. 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.
EPA Order 1440.3, Respiratory Protection, sets out the
Agency policy, responsibilities, and basic requirements 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 for the Region and its
employees, who engage in activities that 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 imminent release of toxic agents.
Respiratory protection may also be necessary for routine but
infrequent operations and for non-routine operations in which
the employee is exposed briefly to high concentrations of a
hazardous substance.
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13.3 SELECTION OF RESPIRATORY PROTECTIVE DEVICES
The proper selection of respiratory protective devices
basically involves three steps:
1. Identification of the hazard.
f.
2. Evaluation of the hazard.
3. Selection of the appropriate approved respiratory
protective device based on the first two considerations.
13.3.1 Identification of the Hazard
To identify respiratory hazards, it is important to know
something about the different kinds of hazardous atmospheres
which may require the use of respirators. Contaminated
atmospheres and oxygen-deficient atmospheres are the two types
of atmospheres which present respiratory hazards.
13.3.1.1 Contaminated Atmospheres
Toxic materials can enter the body primarily in three
ways: (l) by ingestion, through the gastro-intestinal tract,
(2) by absorption through the skin or through cuts and
punctures, and (3) by inhalation through the respiratory
system. The respiratory system not only presents the quickest
and most direct avenue of entry into the body, but for many
agents the lungs are also the critical target. Airborne
contaminants include solid and liquid particulate matter and
gaseous material, whether a true gas or vapor, or a
combination of these.
1. Gaseous Contaminants: These contaminants are of two
types:
A. 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 temperature or much higher
pressures than are commonly found in the work
environment. Carbon dioxide, is a gas at room
temperature, but it occurs as solid "dry ice" at low
temperature, or as a liquid in a pressurized tank.
B. Vapors are a 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.
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2. Particulate 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:
A. Dusts are solid particles produced by such processes
as grinding, crushing, and mixing of powder
compounds.
B. Mists are tiny liquid droplets suspended whenever a
liquid is sprayed, vigorously mixed, or otherwise
agitated.
C. Fumes are solid condensation particles of extremely
small particle size.
3. Combination Contaminants: The two basic forms of
contaminated atmospheres - gaseous and particulate
frequently occur together.
13.3.1.2 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 commonly found in
confined and usually poorly ventilated spaces. Oxygen
deficient atmospheres are classified as either immediately
dangerous to life or health (IDLH) or not immediately
dangerous to life or health depending on the oxygen
concentration in the atmosphere. (An oxygen deficient
atmosphere that contains less than 16 volume percent of oxygen
in the atmosphere at sea level is IDLH. 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.
Normal oxygen content is 20.9 volume percent in the
atmosphere.)
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.
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Effects of Oxygen Deficiency
O2 Vol %
at Sea Level Physiological Effect
16-12 Increased breathing volume.
f. Accelerated heartbeat.
Impaired attention and thinking.
Impaired coordination.
14-10 Very faulty judgement.
Very poor muscular coordination.
Muscular exertion causes rapid
fatigue that may cause permanent
heart damage.
Intermittent respiration.
10-6 Nausea.
Vomiting.
Inability to perform rigorous
movement, or loss of all movement.
Unconsciousness, followed by death.
Less than 6 Spasmatic breathing.
Convulsive movements.
Death in minutes.
13.3.2 Evaluation of the Hazard
Respiratory protective devices, according to Agency
policy and OSHA regulations shall be required in the following
types of situations:
1. When there is a high potential for sudden release of
toxic airborne substances or there has been such a release.
2. When making entries into environments or locations
where it is known that there is a reasonable belief that a
hazardous environment is present; e.g., entering hazardous
waste or spill sites and manholes.
3. During infrequent, but routine operations, where
engineering controls are not feasible or adequate for the
toxicity of the material involved.
It is important to assess the potential hazards and the
degree of control that can be exercised over each situation.
Responsibility resides with the project leader /inspector. The
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respiratory protective device selected in each situation will
depend on the information from the qualitative and
quantitative determination of the hazard.
The person who evaluates the respiratory hazard must have
the cooperation of others in obtaining information on the work
area, work activities and other materials to properly evaluate
and determine the appropriate respiratory protective device
that will provide the best protection. Consideration of these
questions will help in the selection of the correct equipment:
1. Does the atmosphere oxygen level meet with
standards? Is the atmosphere oxygen level expected to
remain constant or decrease?
2. What is the contaminant? Is it a gas, vapor, mist
dust, or fume?
3. 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
estimated concentration? Is eye protection also needed?
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 canister?
11. Can the contaminant be absorbed through the skin?
If it can, will it result in a serious injury?
12. Does the facility require use of respiratory
protection? Is there a facility/site specific safety plan
available? Does it specify respiratory protection
requirements?
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13. Is there any on site screening or test data
available?
14. Are OSHA respiratory protection requirements
applicable to the facility, site or activity?
13.3.3 Selection **of Approved Respiratory Protective Devices
The selection of approved respiratory protective devices
shall be based on these considerations:
1. The nature of the hazardous operation or process.
2. The type of respiratory hazard.
3. The location of the hazardous area in relation to the
nearest area having respirable air.
4. The period of time the respiratory protection will be
needed.
5. The employee's activities in the hazardous area.
6. The physical characteristics, functional
capabilities, protection factors and limitations of the
respiratory protection devices.
The NIOSH approval on a respirator has the following
information:
- An assigned identification number placed on each unit.
- A label identifying the type of hazard for which the
respirator is approved.
- Additional information on the label which give
limitations and identifies the component parts for use
with the basic unit.
Attachment A to EPA Order 1440.3 (Appendix B) provides a
"Decision Logic Table for Respiratory Protective Device
Selection." These are general guidelines. Written standard
operating procedures governing the selection and use of
respiratory protective devices shall be established for
specific situations, where necessary. These may be in the
form of facility/site specific plans or program-specific
safety plans, such as for NESHAP-Asbestos inspections
(Appendix C) . Types of respiratory protective devices are
summarized in Appendix D.
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13.4 USE OF RESPIRATORY PROTECTIVE DEVICES
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 training users
in selection, use, and maintenance of respiratory devices.
*•
13.4.1 Training and Fit Testing
13.4.1.1 Training
EPA Order 1440.3 requires that employees receive a
minimum of six hours of training initially, and two to four
hours annually, thereafter in respiratory protection.
Training will be provided initially as part of Region 5's "24
Hour Health and Safety Training for Field Personnel" course,
and subsequent training will be provided as part of Region 5's
required annual "8 Hour Refresher Training" course, and
recorded via Region 5's normal safety record keeping and
tracking system.
13.4.1.2 Fit Testing
The proper fitting of respiratory protective devices
requires the use of some type of fit test. The fit test is
needed to determine the proper match between the facepiece of
the respirator and the face of the user. Two types of tests
are necessary, qualitative tests and quantitative tests.
1. Qualitative Tests: Fast, requiring no complicated
expensive equipment, and are easily performed. Qualitative
fit tests may be used, but are not a substitute for annual
quantitative fit tests which are required for all respirator
users. There are five types of qualitative tests:
A. Isoamyl acetate, a low toxicity substance 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 a cotton
wad inside an enclosure. The enclosure can be put
together by the use of a plastic bag, several
hangers, and some cotton. The user should put on
the respiratory protective device in some area away
from the test enclosure so that there is no prior
contamination of the cartridge or "pre-exposure" to
the isoamyl acetate.
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The user should perform the following steps in
order:
Normal breathing.
—•' Deep breathing, as during heavy exertion.
This should not be done long enough to
cause hyperventilation.
Side-to-side and up-and-down head
movements. These movements should not 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 isoamyl test is that
the odor threshold varies widely among individuals.
Also, the sense of smell is easily dulled and may
deteriorate during the test so that the use 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 a 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 the test must sometimes be suspect.
B. Irritant Smoke Test - The irritant smoke test,
similar to the isoamyl acetate test in concept, is
used widely in testing the facepiece fit of high
efficiency 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 passes through
them, a dense irritating smoke is emitted. If the
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user detects any of the irritant smoke, it means a
defective fit, and adjustment or replacement if 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.
Irritant smoke tests are ineffective for positive
pressure respirators operating in the demand and
continuous mode.
C. Taste Test - Utilizing sodium saccharin and placing
hood over wearers head is an acceptable method for
Atmosphere Supplying Respirator. (Normally for
single use respirators.)
D. 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 ten seconds.
If the facepiece remains slightly collapsed and
no inward leakage is detected, the respirator has
been properly donned and the exhalation valve and
facepiece are not leaking. This test, of course,
can only be used on respirators 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 his/her face. This handling can
modify the facepiece seal. A second drawback is
that with a negative pressure in a facepiece, a
leaking facepiece may be drawn tightly to the face
to form a good seal, giving a false reading of a
good seal.
E. Positive Pressure Test - This test, similar to the
negative pressure test, is conducted by closing if
the exhalation valve or breathing tube 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
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method requires that the wearer remove the
exhalation valve cover; this often disturbs the fit
of the respirator to the wearer. 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 pert 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
non-toxic gas, vapor or aerosol. The atmosphere 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 "percentage of penetration," or simply "penetration."
The greatest advantage of a quantitative test is that it
indicates respirator fit numerically, and does not rely on a
subjective response.
Employees are required to receive an annual quantitative
fit test as arranged by the Regional Safety Officer. The
irritant smoke qualitative test will be used as an interim
measure. (This method is less subjective than the isoamyl
acetate method.) Either the negative or positive pressure
test will be used by the employee when donning a respirator to
check the seal. Blue certification cards must be signed by
the individual performing the fit test.
13.4.2 Medical Monitoring
Employees performing tasks requiring the use of
respiratory protective devices must be certified physically
capable of performing the work while wearing the devices as
part of the annual medical monitoring examination. A blue
certification card will be issued to employees by a physician
certifying that the employee is physically able to wear a
respirator. The certification card must be available at the
time of the respirator fit test and signed by the fit test
operator.
13.4.3 Inventory and Personal Issuance
13.4.3.1 Inventory
The Regional Safety Manager shall maintain a general
inventory of respiratory equipment and supplies in his/her
custody, and administer the regional budget for equipment
purchases, for non-CERCLA activities. Part of the Regional
Safety Manager's budget is administering funds for all
personal protective equipment including purchase for all
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respiratory equipment and respiratory equipment supplies.
When additional respirators or respiratory equipment are
needed, those needs should be transmitted to the Regional
Safety Manager as soon as possible and the procurement should
be coordinated with him/her.
Additionally, in each Branch where employees use
respiratory protection devices, a general inventory of
respiratory equipment and supplies may be kept by the Branch
Safety Officer or other appropriate individuals, but if kept
shall be the responsibility of the Branch Supervisor. This
inventory shall be available to the Regional Safety Manager
for his/her annual inspection.
13.4.3.2 Personal Issuance
Field and laboratory personnel subject to contaminated
atmospheres (as previously defined) will be issued an
appropriate respirator with an initial supply of filters.
Other equipment may be personally issued as needed. The
immediate supervisor of his/her designee, is responsible for
issuing equipment and maintaining records of the issuances.
Respirators should be the full face type whenever possible.
13.4.4 Special Considerations in Respirator Use
l. Respiratory protective devices shall not be worn
when any condition prevents a good seal. Specific conditions
not permitted are as follows:
A. Any facial hair lying between the sealing surface of
a respirator facepiece and the wearer's skin that
will prevent a good seal shall not be allowed. This
includes stubble, a moustache, sideburns or a beard
that extends outward between the face and the
sealing surface of the respirator.
B. Spectacle temple bars or straps that pass between
the sealing surface of a facepiece and the wearer's
face prevent a good seal and, therefore, shall not
be permitted with a full-face respiratory protective
device. Individualized eye glasses mounted to the
facepiece will be furnished.
2. Employees with perforated eardrums shall not wear
respirators.
3. Contact lenses shall not be permitted while wearing
a respirator.
4. Gum and tobacco chewing shall not be permitted while
wearing a respirator.
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13.5 INSPECTION. MAINTENANCE. REPAIR. AND STORAGE OF
RESPIRATORY PROTECTIVE DEVICES
Proper inspection, maintenance, storage, and repair of
respiratory devices are mandatory to insure that these devices
protect the health and safety of the employees when in use.
<•
13.5.1 Inspection
An important part of respirator maintenance program is
the inspection of the devices. If performed carefully,
inspections will identify damage or malfunctioning respirators
and help to maintain their state of readiness. All
respiratory protective devices must be inspected monthly or
before each use. A record must be kept of inspection dates
and findings. Responsibility for inspection and record
keeping resides with the supervisor (who may delegate the
responsibility to the Branch Safety Officer) , for equipment in
general inventory and the employee for personally issued
equipment. Inspection guidelines for various respiratory
protection devices are provided in Appendix E.
13.5.2 Maintenance
All respiratory protective devices shall be cleaned and
disinfected after each use by the user.
The actual cleaning methods may be done in a variety of
ways:
1. 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.
2. A standard domestic 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 where respirator usage is
extensive. *Handy-wipe disinfectants may be used as a
substitute for the above methods.
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 available, a
detergent may be used, followed by a disinfecting rinse.
Reliable disinfectants may be made from some available
household solutions.
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1. Hypochlorite solution [50 parts per million (ppm) of
chlorine] made by adding approximately two tablespoons of
chlorine bleach per gallon of water. A two-minute immersion
is sufficient to disinfect the respirator.
2. Aqiaeous solution of iodine (0.8ml tincture of iodine
in one liter. The iodine 7% ammonium and potassium iodine,
45% alcohol and 48% water.) Again, a two-minute immersion is
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.
If the respirators are washed by hand, a separate
disinfecting rinse may 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 the
time will have to be measured to determine the correct amount
of disinfectant to be added.
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. This is very important to prevent dermatitis.
Drying: The respirators may be allowed to dry by
themselves on a clean surface. They may also be hung from a
horizontal wire, like drying clothes, but care must be taken
not to damage the facepieces.
13.5.3 Repair
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). Equipment in need of
repair will be given to the Supervisor or Safety Officer
designee, who will either arrange for the repair of the
equipment or its disposal if it is not repairable.
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
information. The manufacturer will also provide replacement
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.
(All respirators and parts shall be NIOSH or MSHA approved
with the appropriate TC number.)
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Defective air-supplying respiratory 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 or
certified repair person for adjustment or repair.
13.5.4 Storage
All the care that has gone into repair 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 plastic bags capable of being
sealed 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."
Equipment in general inventory will be stored in
designated lockers or chests provided with the equipment.
Personally issued equipment when not in use will be stored in
a personally issued equipment locker. In the field, the
equipment will be transported in the chests provided with the
equipment or in a duffle bag.
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ATTACHMENTS
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ADMINISTRATIVE RESPIRATORY PROTECTION PROGRAM
(To be Distributed to Employees When Issued Respirators)
GENERAL
The OSHA General Industry standard for respiratory
protection 2» CFR 1910.134 requires that a written respiratory
protection program be established by an employer. The
following procedures are based on the nine commandments as
established by the Occupational Health and Safety
Administration.
GUIDELINES
1. The guidelines in this program are designed to help
reduce employee exposures against occupational dust, fumes,
mists, radionuclides, gasses, and vapors.
2. The primary objective is to prevent excessive exposure to
these contaminants.
3. Where feasible, exposure to contaminants will be
eliminated by engineering controls (example, general and local
ventilation, enclosure or isolation, and substitution of a
less hazardous process or material.)
4. When effective engineering controls are not feasible, use
of personal respiratory protective equipment may be required
to achieve the goal.
RESPONSIBILITIES
l. Management
It is management's responsibility to determine what
specific applications require use of respiratory equipment.
Management must also provide proper respiratory equipment to
meet the needs of each specific application. Employees must
be provided with adequate training and instruction on all
equipment.
2. Management/Supervisory
Superintendents, supervisors, foremen, or group leaders
of each area are responsible for insuring that all personnel
under their control are completely knowledgeable of the
respiratory protection requirements for the areas in which
they work. They are also responsible for insuring that their
subordinates comply with all facets of this respiratory
program, including respirator inspection and maintenance.
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3. Employees
It is the responsibility of the employee to have an
awareness of the respiratory protection requirements for their
work areas (as explained by management.) Employees are also
responsible for wearing the appropriate respiratory equipment
according to proper instructions and for maintaining the
equipment in a clean and operable condition.
ADMINISTRATION
1. Name: Signature:
Regional Health & Safety Hanager
is responsible for overall program administration.
2. Name: Signature:
Physician, Occupational Health Nurse
is responsible for monitoring the health of company
employees via a comprehensive medical and health program,
including physical examinations.
3. Name: signature:
Either Regional Health 6 Safety Manager or Supervisor
is responsible for selection of issuance, training, and
fit testing of all respirators used in this Agency
including recordkeeping of the "Respirator Issuance and
Training" card and "Job Description - Respirator
Specification" form.
RECOMMENDED RESPIRATORY PROTECTION PROGRAM
WORK AREA MONITORING
Although it is not specifically discussed in the nine
commandments, to assure the adequacy of a respiratory
protection program, monitoring should be conducted on a
periodic basis to provide a continuing healthful environment
for employees. Personal sampling equipment may be used in
accordance with accepted industrial hygiene standards to
sample each work area. Results of these samples will pinpoint
areas where respiratory protection is required. A "Job
Description - Respirator Specification" From will also
document what type of equipment should be worn for specific
hazards present.
EMPLOYEE MEDICAL MONITORING
1. Pre-employment physical examinations are conducted on all
employees to assure that they are in adequate healthy
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condition (physically able to perform their work and can use
respiratory equipment as required.)
2. Yearly physical examinations will be given to regular
employees in order to assist them in maintaining their health.
(At option of employer/physician or where such exams are
required by Local, State, and/or Federal Regulations.)
3. Biological monitoring in the form of blood and/or urinary
analysis will be conducted on a yearly basis for all employees
if appropriate (Employer/Physician determination.)
RESPIRATOR SELECTION
Respirators are selected and approved by management. The
selection is based upon the physical and chemical properties
of air contaminants and the concentration level likely to be
encountered by the employee. A "Respirator Issuance and
Training" card (see attached) is available for each job where
respirators are required. This card specifies what respirator
is required for each application. The respirator program
administrator will make a respirator available immediately to
each employee who is placed as a new hire or as a transferee
in a job that requires respiratory protection. Replacement
respirators/pre-filters will be made available as required.
EMPLOYEE FIT TESTING
Employees required to wear a respirator must be fitted
properly and tested for a face seal prior to use of the
respirator in a contaminated area. Manufacturers provide
fitting instructions and limitations on the product packaging.
Qualitative fit testing is acceptable for most hazards in
the workplace. (Refer to OSHA standards for specific
direction.) In addition, we require quantitative fit testing
of all employees issued respirators.
NOTE: Include the fit test method used on the "Respirator
Issuance and Training" card. If it is an adequate
fit or face seal with any negative pressure
respirator, a powered air purifying or air supplied
respirator may be required instead.
RESPIRATOR INSPECTION AND MAINTENANCE
The following points should be considered for respirator
inspection and maintenance:
1. The wearer of the respirator should inspect it daily
whenever it is in use.
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2. Respirators not discarded after one shift use, will be
cleaned on a daily basis, according to the manufacturer's
instructions, by the assigned employee or other person
designated by the respirator program coordinator.
3. Respirators not discarded after one shift use, will be
stored in a suitable container away from areas of
contamination.
4. Whenever feasible, respirators not discarded after one
shift use, will be marked or stored in such a manner to assure
that they are worn only by the assigned employee. If use by
more than one employee is required, the respirator must be
cleaned between uses.
EMERGENCY RESPIRATORY EQUIPMENT
Self contained breathing apparatus may be required in
specific areas for emergency use. This equipment will be used
only by trained personnel when it is necessary to enter
hazardous atmospheres. The following points should be
considered.
1. All potential users will be fully trained in the use of
this equipment.
2. When the equipment is used, it will be tested in an
uncontaminated atmosphere prior to entering the hazardous area
if possible.
3. An employee will not work with this apparatus in a
hazardous atmosphere on an individual basis. At least one
additional employee suitably equipped with a similar breathing
apparatus must be in contact with the first employee and must
be available to render assistance if necessary.
4. This equipment will be inspected monthly and trained
department or group personnel. Inspection and maintenance
information will be maintained by the Branch Supervisor Safety
Officer.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
OSHA'S REQUIREMENTS FOR A MINIMAL RESPIRATOR PROGRAM
1. "Written standard operating procedures (S.O.P.) 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. (RESERVED) "where practicable, the respirators should be
assigned to individual workers for their exclusive use."
(OSHA recommended only.)
5. "Respirators shall be regularly cleaned and disinfected.
Those used by more than one worker shall be thoroughly cleaned
and disinfected after each use."
6. "Respirators shall be stored in convenient, clean, and
sanitary location."
7. "Respirators used routinely shall be inspected during
cleaning. Worn or deteriorated parts shall be replaced.
Respirators for emergency use, such as self-contained
breathing devices, shall be thoroughly inspected at least once
a month and after each use."
8. "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 annually."
9. "Approved or accepted respirators shall always be used."
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R5 1440 (9/29/91)
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Region 5 Health and Safety Manual RS 1440 (9/29/91)
JOB DESCRIPTION - RESPIRATOR SPECIFICATION FORM
JOB
DESCRIPTION
ContaminantConcentration X.ppmmg/m3
Recommended Respiratory Protection
First Choice Second Choice
NIOSH Approval Numbers
OSHA Standard for Contaminant
This form and the "blue cards" should be presented by the
employee at the time of the fit testing. The form should also
be filled out by the Public Health Service and by the person
conducting the fit test and forwarded to the Regional Health
and Safety Manager.
RESPIRATOR ISSUANCE AND TRAINING
EmployeeEmployee #TitleDate
Respirator: Self-Contained Supplied Air
Powered Air HEPA Filter
Dust/Mist Filter Chemical Cartridge
Dust/Fume/Mist Filter Chemical Cartridge
w/pre-filter
ModelApplicationNIOSH Approval #
Limitations: Beard Denture Glasses None
Explain:
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Fitting: Satisfactory Satisfactory
Positive Pressure Isoamyl Acetate Test
Test
Satisfactory Satisfactory
Negative Pressure Sweetener Test
Test
Maintenance:Cleaning; DailyWeeklyOther
Disposal: Daily Weekly Other
Individual Plant Other
Indicator
Employee Signature Date
Approved Date
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
FIT TESTING POLICY
The OSHA Respiratory Protection Standard addresses the
issue of respirator use and facial hair [29 CFR 1910.134
(e)(5)(i)]. The actual wording of this standard is often a
point of confusion. OSHA's intent and their enforcement
position may«be helpful.
A number of letters from OSHA help define their position.
For example, a letter to Melodye Turek from Ed Baier dated
December 13, 1983 states that it is OSHA's interpretation that
it is a "...violation of the standard if employees are allowed
to wear respirators over facial hair at the sealing surface of
the respirator." Letters to Congressman Field and Robert
Elswick, dated August 23, 1982 and August 20, 1984,
respectively stated that "a respirator user's face must be
clean shaven where the respirator seals against it."
The American National Standards Institute (ANSI) position
in Practices for Respiratory Protection. Z88.2-1980. and its
proposed revision is straightforward. ANSI .declares that "a
person who has hair (stubble, moustache, sideburns, beard, low
hairline, bangs) which pass between the face and the sealing
surface of the facepiece of the respirator shall not be
permitted to wear such a respirator." They further state that
"a person who has hair (moustache, beard) which interferes
with the function of a respirator valve(s) shall not be
permitted to wear the respirator."
The more recent OSHA health standards for asbestos,
benzene, and formaldehyde, prohibit fit testing of employees
if any hair growth, such as stubble beard growth, beard or
long sideburns, between the skin and facepiece sealing surface
(1910.1001 and 1920.58, Appendix C; 1910.1028 Appendix E;
1910.1048 Appendix E, respectively.)
We are in full agreement with OSHA and ANSI that facial
hair should not be permitted in the sealing area of a
respirator or allowed to interfere with respirator valve
function and that respirator fit testing should not be
conducted on these people. Therefore, EPA adopts the
following policy of not conducting either qualitative or
quantitative fit tests on workers with any facial hair that
extends under the respirator seal or interferes with valve
function. This includes all negative pressure respirators
(half and full face air purifying respirators) and positive
pressure tight fitting respirators [e.g. Easi-Air 7800 Airline
and Whitecap Powered Air Purifying Respirator (PAPR) with 7800
full facepiece.] Similarly, these respirators should not be
used on such workers.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Chapter 14 - CONFINED SPACE ENTRY; REGIONAL POLICY
14.1 PURPOSES
The U.S. EPA Personnel will comply with all rules and
policies of the host company unless the rule conflicts with
the U.S. EPA Regional policy or office Standard Operating
Procedures (SOP). Each Division office or other unit of U.S.
EPA is responsible for establishing a specific SOP for each
area of potential confined space entry and reflecting all
activities, specific needs, and exposure possibilities.
14.2 CONFINED SPACE DEFINED
A tank, vessel, silo, vault, pit, open topped space,
pipeline, duct, sewer, tunnel, or any other spaces having
limited means of egress, not designed for continuous employee
occupancy and contains a hazardous atmosphere or the potential
for such.
14.2.1 Hazardous Environment or Atmosphere
An atmosphere presenting a potential for death,
disablement, injury, or acute illness from one or more of the
following causes:
1. Less than 19.5 percent or more than 23.5% oxygen;
2. A flammable gas, or vapor, in excess of 10% of its
lower flammable limit (LFL) or lower explosive limit (LEL);
3. An airborne combustible dust at a concentration that
obscures vision at a distance of five feet or less;
4. An atmospheric concentration that exceeds the listed
numerical value of any toxic, corrosive, or asphyxiant
substance listed in the TLV booklet (ACGIH) or the PEL (OSHA)
that can reasonably be expected to be present.
5. Electrical, thermal or mechanical hazards.
14.2.2 Requ i reroent s
1. All confined spaces are considered Immediately
Dangerous to Life or Health (IDLH) until proven otherwise.
IDLH means any condition which poses an immediate threat of
loss of life; may result in irreversible or immediate-severe
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
health effects; may results in eye damage; irritation or other
conditions which could impair escape from the permit space.
2. All entry into confined spaces requires a permit of
entry. (Appendix A)
3. Prior to*«ntry into any confined space, the U.S.EPA
inspector will contact the Region to provide an individual
competent of issuing a permit.
4. The U.S. EPA's permit issuer responsible for issuing
the permit can use the company's data, as long as
the EPA's PI considers it valid.
5. Neither the U.S. EPA inspector, nor the individual
who will sign off on the EPA permit will sign off on the
company's permit.
6. All confined spaces will be identified by a sign,
placard, or other equally effective means.
7. Confined spaces that have been identified as needing
a permit will be guarded against unauthorized entry and
positive lockout procedures will be ensured when entering.
Positive lockout will include but not limited to mechanical:
(prevent all mechanical movement, such as rotating gears,
mixing blades, shaft rotation, etc.); hydraulic: (all
pressurized fluid lines leading to space are positively locked
out or bled to prevent accidental energy release) ; electrical:
(all power to space are positively controlled not to present
a hazard); pneumatic: (all air lines controlling rotating
parts connected to the space are bled, locked, or controlled
by other means not to create a hazard).
8. An entry permit will be a written authorization by a
qualified person that provides for safe work practices in a
confined space.
9. No entry will be allowed by EPA Personnel into a
confined space without assuring adequate training. A question
and answer sheet has been provided to assess adequate training
requirements of employees (See Appendix B).
10. Permit issuers are qualified persons and require
written certification by the Director of the Region or their
designated representative. A question and answer sheet has
been provided to assess qualified permit issuers (See Appendix
C) . Qualified person is a person designated in writing as
capable of anticipating confined space hazards and
recommending controls, by virtue of their education, training,
experience or combination to assure safe entry.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
It will be the Regional Health and Safety Manager's
responsibility to assure adequate training is provided and to
assure enough permit issuers are certified to carry out the
mission of the agency.
11. All personal protective equipment must be approved
for the hazards of the space. See Health and Safety Manager
for approved equipment.
12. Entry will be made only with a backup person.
Suitable PPE varies with the work to be performed and the type
of atmosphere present. At a minimum, EPA Personnel's PPE will
include:
- approved safety glasses ANSI Z-87.1
- approved steel toed shoes ANSI Z-41
- approved hard hat ANSI Z-89.1
- approved flashlight FM-UL Class I, Div. 1,
Group A, B, C, D
- additionally, approved escape SCBA
(ELSA) (North) may be required.
13. All U.S. EPA personnel entering the confined space
will have a portable direct reading monitor or combination of
monitors calibrated prior to entering that test for:
- Oxygen content by percent volume
- Flammables & combustibles reading percent LEL
(Lower Explosive Limit)
- Toxics - carbon monoxide, hydrogen sulfide,
chlorine, chlorinated solvents, phosgene,etc.
(Whatever is present and appropriate)
Readings will be taken at several levels of elevation.
14. Any U.S. EPA Personnel entering concentrations above
the PEL or entering any oxygen deficient atmosphere will
receive written permission from the Branch Chief or equivalent
for continued entry. If written approval is granted, the EPA
Personnel will be protected by the appropriate approved
respiratory protective devices, harness life lines, rescue
equipment, and attendant.
15. Do not enter radioactive areas without consulting
with the Regional Health and Safety Manager and following
EPA's radiation policy.
16. All entries will cease and all U.S. EPA Personnel
will immediately leave the confined space should a non-
permitted condition exist. This would include alarm signal(s)
or other warnings such as employee symptoms of over exposure
or sudden leaks of liquid or gas. An alarm would be an
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
individual being warned of an unsafe condition such as an
audible warning indicating an oxygen deficient atmosphere
(less than 19.5% (O2); or a potential flammable hazard
(greater than 10% LEL); or toxic gas alarm greater that 35
parts per million (ppm) Carbon Monoxide (CO) or 10 ppm
Hydrogen Sulfide (H2S) or any other means of warning the EPA
Personnel of a non»rpennitted condition. (Other examples may be
a signal line, siren, commercial radio, etc.)
17. All permits will be filled out completely by the
qualified person and kept in the local U.S. EPA office for a
period of five years.
18. All training and calibration records will be kept in
the local EPA office for a period of five years.
19. All EPA Personnel entering confined spaces will
receive and pass a physical assuring they are physically able
to perform the activities and use the monitoring, rescue and
respiratory equipment.
20. All respirator users will be fit-tested and trained
on the devices they will use during normal confined space
activities and during emergencies.
21. All entrants will be briefed to the hazards of the
space and the purpose of the entry.
22. All entrants' PPE will be decontaminated, discarded
or otherwise treated to assure no hazards are removed from the
confined space.
23. Rescue provisions will be ensured by the permit
issuer prior to entry.
14.3 REFERENCES
Safety Requirements for Working in Tanks and Other
Confined Spaces, American National Standards Institute,
Z117.1.1977
Safety Requirements for Confined Spaces, American
National Standards Institute, Z117.1.1989
Criteria for a Recommended Standard..Working in Confined
Space, National Institute for Occupational Safety and
Health, December, 1979
Permit Required for Confined Spaces, Federal Register,
29 CFR 1910.146, Vol. 54, No. 106
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
APPENDIX A
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Region 5 Health and Safety Manual
R5 1440 (9/29/91)
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
CONFINED SPACE ENTRY PERMIT
(Check or fill in all blanks that apply)
Today's Date:.
Time of Entry: Date Time Safety Permit No..
Purpose of Entry: Inspection Other
Brief Description of Purpose.
Location of Entry (Be specific)
The US EPA Personnel or SUB CONTRACTORS ENTERING
Name Time In Time Out Name Time In Time Out
Have all personnel gone through a pre-entry briefing? Yes No_
space Tested by (Name/Title) Date Time
Type & S/N of Sampling Eguip-Make SN Calib.Date
Type & S/N of Sampling Eguip-Make SN Calib.Date
Pre Entry Reading Taken? Yes No
Document later readings on back.
% Oxycren-Openinq Middle Bottom Other All
% LEL-Ooenincr Middle Bottom Other All
Toxic Readincr-CO HoS Other All
Are all power sources intrinsically safe? Yes
Have all personnel been criven the proper PPE? Yes
19.5%
10% LEL
PEL
No
No
Have all personnel been trained to work safely and use equipment?
Yes No
Is a rescue plan in place? Yes No Why Not?
Has area been secured & all energy sources locked & Tagged?
Yes No
Is there any possibility of entrapment or engulfment by Particulate
Matter? Yes No If yes, has provision been made to
work safely in such an area? Yes No . Is O2, LEL, and
toxics within safe limits? Yes No
I certify the above conditions are accurate and validate the entry
only for the stated purpose, time and identified employees not to
exceed work for one shift. If any question was answered no and a
satisfactory answer was not give DO NOT ISSUE PERMIT.
DATE SIGNATURE TITLE
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Region 5 Health and Safety Manual
R5 1440 (9/29/91)
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
APPENDIX B
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Region 5 Health and Safety Manual . R5 1440 (9/29/91)
CONFINED SPACE ENTRY
*1 W. KRUG, CIH
1. NORMAL ATMOSPHERIC AIR CONTAINS WHAT PERCENTAGE OF OXYGEN?
2.
3.
4.
A. 21.9%
B. 22.0%
C. 19.5%
D. 20.9%
OXYGEN'S CHEMICAL SYMBOL IS:
A. OX
B. 02
C. 0
D. OA
OXYGEN AND NITROGEN MAKE UP THE HIGHEST PERCENT OF OUR
ATMOSPHERE. WHAT IS THE NEXT LARGEST PERCENT MEMBER?
A. ARGON
B. CO2
C. HYDROGEN
D. CO
HOW MANY PARTS PER MILLION IS
A. 1,000
B. 400
C. 9,000
D. 10,000
THE THIRD HIGHEST % ELEMENT?
A FIRE CAN SUSTAIN COMBUSTION AT 12% OXYGEN?
A. YES
B. - NO
C. NOT VERY LIKELY
D. YES, VIOLENTLY
THE MINIMUM % OF OXYGEN NEEDED TO SUSTAIN LIFE AT REST IS:
A. 8%
B. 12%
C. 16%
D. 19.5%
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
7. CANDLE WILL GO OUT AT BELOW WHAT % 02?
A. 12%
B. 19.5% f
C. 21%
D. 16%
8. GASES THAT ARE CONSIDERED SIMPLE ASPHYXIANT ARE?
A. N2
B. CO
C. CO2
D. A AND C
9. WE EXHALE % OF OXYGEN?
A. 16
B. 19.5
C. 21
D. <5
10. WE EXHALE PARTS PER MILLION OF CARBON DIOXIDE?
A. 20,000
B. 50,000
C. 400
D. 1000
11. WHAT PERCENTAGE OF NORMAL ATMOSPHERIC NITROGEN WOULD BE LEFT
AFTER AN INFLUX OF 10% ARGON?
A. 10
B. 68
C. 78
D. 70
12. AFTER A FIRE, WHAT TYPE OF TOXIC GASES ARE LEFT?
A. CO
B. C02
C. CH4
D. 02
13. WHICH OF THE FOLLOWING COULD CAUSE AN OXYGEN DEFICIENT
ATMOSPHERE?
A. INCREASE IN C02
B. INCREASE IN CH4
C. DRYING OF PAINTS
D. ALL OF THE ABOVE
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
14. WHICH WOULD NOT CAUSE AN OXYGEN DEFICIENT ATMOSPHERE?
A. FIRE «
B. LEAKING OXYGEN CYLINDER
C. CURING OF CEMENT
D. BACTERIAL ACTION OF FERMENTATION
15. WHAT PERCENT OF ATMOSPHERIC OXYGEN IS THERE AT 10,000 FEET?
A. 19.5%
B. 16.0
C. 20.9
D. 12.0
16. WHICH OF THE FOLLOWING IS CONSIDERED A CHEMICAL ASPHYXIANT?
A. HCN
B. C02
C. CO
D. A AND C
17. GRADE D BREATHING AIR IS COMPOSED OF WHAT RANGE OF OXYGEN
PERCENT?
A. 20-21
B. 19.5-22.5
C. 19.5-23.5
D. 16-21
18. IN FLAMMABLE SPRAY PAINTING OPERATIONS, THE OXYGEN CONTENT
IS USUALLY?
A. 20.9%
B. 16.0%
C. 19.5%
D. 25%
19. AN AIR LINE RESPIRATOR SHOULD BE USED FOR OXYGEN DEFICIENT
ATMOSPHERES.
A. YES
B. NO
C. DON'T KNOW
D. ONLY IF YOU HAVE AN ESCAPE RESPIRATOR WITH YOU
20. ACGIH OXYGEN DEFICIENT ATMOSPHERE IS CONSIDERED?
A. 16%
B. 18%
C. 19.5% 14-13
D. 21%
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Region 5 Health and Safety Manual . R5 1440 (9/29/91)
CONFINED SPACE ENTRY
T. W. KRDG, CIH
21. A FIRE OR EXPLOSION CAN EXIST BELOW THE LEL?
A. NO
B. YES «
C. YES, ONLY IF ABOVE 19% OXYGEN
D. YES, ONLY IF THE RATE OF COMBUSTION EQUALS THE FLASH
POINT
22. THE MINIMUM TEMPERATURE AT WHICH A FIRE CAN EXIST IS CALLED?
A. SPONTANEOUS IGNITION
B. HEAT OR FUSION
C. FLASH POINT
D. A AND C
23. MOST FLAMMABLE GASES AND VAPORS ARE AT THEIR LEL WHEN THE
PERCENT BY VOL IN AIR EQUALS ?
A. 1-5%
B. 40-50%
C. .01% OF THE UEL
D. THE VAPOR PRESSURE
24. THE THREE COMPONENTS NECESSARY TO HAVE A FIRE ARE?
A. 8%O2 - FUEL - SPARK
B. 19.5%02 - TEMP ABOVE 100CF - HEAT
C. AIR - FUEL - HEAT
D. IGNITION SOURCE - OXYGEN - 10% LEL
25. HOW MANY PARTS PER MILLION IS 10% BY VOLUME?
A. 1000
B. 10,000
C. - 100,000
D. 1,000,000
26. IF THE LEL OF A FLAMMABLE VAPOR IS 1% BY VOL, HOW MANY PARTS
PER MILLION IS 1% OF THE LEL?
A. 10 PPM
B. 100 PPM
C. 1,000 PPM
D. 10,000 PPM
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
27. ACCORDING TO THE PROPOSED 1910.146 CONFINED SPACE STANDARD,
WHAT IS THE UPPER LIMIT OF PERCENT LEL OF FLAMMABLE GAS OR
VAPOR ALLOWED?
A. 50%
B. 1%
C. 10%
D. 20%
28. WHICH OF THE FOLLOWING IS A FLAMMABLE GAS?
A. C02
B.
C. CCL4
D. NH4
29. WHICH OF THE FOLLOWING IS N^T A FLAMMABLE GAS?
A. DIESEL FUEL
B. GASOLINE
C. CARBON MONOXIDE
D. A AND B
30. A COMBUSTIBLE GAS METER READS IN
A. % LEL
B. % UEL
C. % VOLUME
D. % OXYGEN
31. MOST COMBUSTIBLE GAS METERS MEASURE ONLY PURE GASES?
A. TRUE
B. FALSE
32. THE PRINCIPLE OF OPERATION OF THE COMBUSTIBLE GAS METER IS?
A. ELECTRIC ARC
B. OXIDATION/REDUCTION
C . ELECTRO-OXIDATION
D. WHEAT STONE BRIDGE
33. IF THE LEL OF A CERTAIN GAS IS 5% BY VOLUME AND THE UEL IS
15% BY VOLUME, THEORETICALLY, WHAT READING SHOULD YOU GET ON
A CGM WHEN YOU USE A 2% VOLUME MIXTURE WITH A BALANCE OF
NITROGEN?
A. 10,000 PPM
B. 40% LEL
C. ZERO 14-15
D. 80% OF FLASH POINT
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
34. THE PRECEEDING QUESTION USING 2% VOLUME MIXTURE WITH A
BALANCE OF AIR?
A. 10,000 t>PM
B. 40% LEL
C. ZERO
D. 80% OF FLASH POINT
35. COMBUSTIBLE GAS METERS CAN MEASURE ALL TYPES OF GAS?
A. TRUE
B. FALSE
36. COMBUSTIBLE GAS METERS WILL INDICATE THE LOWER EXPLOSIVE
LIMIT FOR EXPLOSIVE DUSTS?
A. TRUE
B. FALSE
37. THE PERCENT OF OXYGEN WILL NOT AFFECT THE OPERATION OF CGM.
A. TRUE
B. FALSE
38. AN ORDINARY CLEAN RUBBER HOSE CAN BE USED TO EXTEND THE
SAMPLING DISTANCE WITH A CGM?
A. TRUE
B. FALSE
39. THE ACCURACY OF A CGM CAN BE 50% INACCURATE?
A. TRUE
B. FALSE
40. PRE-CALIBRATION ISN'T NECESSARY FOR A CGM BECAUSE IT'S DONE
AT THE FACTORY?
A. TRUE
B. FALSE
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
CONFINED SPACE ENTRY
T. W. KRUG, CIH
41. CARBON MONOXIDE (CO) IS A TOXIC GAS THAT CAN KILL A HUMAN IN
LESS THAN ONE HALF HOUR AT HOW MANY PART PER MILLION?
A. 400
B. 35
C. 1000
D. 2000
42. HYDROGEN SULFIDE'S (H2S) IDLH (IMMEDIATELY DANGEROUS TO LIFE
OR HEALTH) AIR LEVEL IS USUALLY CONSIDERED TO BE ?
A. 100 PPM
B. 20 PPM
C. 400 PPM
D. 1000 PPM
43. CARBON DIOXIDE IS FOUND AS A BY PRODUCT OF?
A. FIRE
B. CEMENTING
C. HUMANS
D. TWO OF ABOVE
44. CARBON DIOXIDE IS EXHALED AT WHAT PERCENT BY VOLUME?
A. 3-5%
B. .04%
C. 16%
D. 12%
45. METHANE IS A TOXIC GAS TO HUMANS?
A. - TRUE
B. FALSE
46. METHANE SMELLS LIKE ?_
A. NATURAL GAS
B. ROTTEN EGGS
C. SWEET VIOLETS
D. NO SMELL AT ALL
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Region 5 Health and Safety Manual K5 1440 (9/29/91)
47. OXYGEN DEFICIENCY CAN OCCUR FROM THE FOLLOWING?
A. INFLUX OF SIMPLE ASPHYXIANT GASES IE., CO2/ N2, ARGON,
B. ROTTING OR DECOMPOSITION OF ORGANIC MATERIAL
C. THE RUSTING OF IRON OR DRYING OF PAINTS
D. THE CURING OF CEMENT
E. ALL OF THE ABOVE
48. HALO AROUND LIGHTS AND A BROWN COPPER TINT TO SILVER COINS
IS AN INDICATION OF WHAT TOXIC GAS?
A. CHLORINE
B. BROMINE
C. HYDROGEN SULFIDE
D. SULFUR DIOXIDE
49. BLUING OF THE LIPS AND FINGERNAIL BEDS IS INDICATIVE OF WHAT
TYPE EXPOSURE?
A. CARBON MONOXIDE
B. HYDROGEN SULFIDE
C. HYPOXIA
D. FROSTBITE
E. TWO OF THE ABOVE
50. CARBON MONOXIDE POISONING SYMPTOMS ARE?
A. HALOS AROUND LIGHTS YELLOW COPPER TINT TO SILVER COINS
B. REDDENING OF THE EYES AND DILATION OF THE PUPILS
C. CHERRY RED LIPS AND FINGERNAIL BEDS
D. TWO OF THE ABOVE
51. CARBON MONOXIDE IS LIGHTER THAN AIR?
A. TRUE
B. - FALSE
C. SAME
52. METHANE IS HEAVIER THAN AIR?
A. TRUE
B. FALSE
C. DEPENDS ON AIR DENSITY
53. WHICH OF THE FOLLOWING ARE CHEMICAL ASPHYXIANTS?
A. CARBON MONOXIDE
B. HYDROGEN CYANIDE
C. HYDROGEN SULFIDE
D. ALL OF THE ABOVE 14-18
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Region 5 Health and Safety Manual - R5 1440 (9/29/91)
54. DETECTOR TUBE SAMPLING HAS WHAT PERCENT ERROR?
A. 1-2%
B. 5-10%
C. 25-35%
D. OVER 50%
55. PRESENTLY THE GUIDELINES TO FOLLOW WHEN ASSESSING TOXICS IN
CONFINED SPACES DEPENDS ON?
A. THE MATERIAL STORED PREVIOUSLY AND PRESENTLY
B. THE SPECIFIC GRAVITY OF THE GAS OR VAPOR
C. THE IDLH LEVELS AND PEL OR TLV LEVELS
D. ALL OF THE ABOVE
E. NONE OF THE ABOVE
56. AFTER THE INITIAL ASSESSMENT FOR TOXICS THE AIR CONTAMINANT
LEVELS MUST BE DOCUMENTED AND FURTHER TESTS NEED NOT BE DONE
UNTIL THE ENTRY PERMIT IS REVOKED?
A. TRUE
B. FALSE
57. WHICH CURRENT FEDERAL STANDARD STATES THE EMPLOYEES MUST
HAVE A WRITTEN CONFINED SPACE PROGRAM?
A. 29CFR 1926.21
B. 29CFR 1910.146
C. 29CFR 1910.134(E)(3)
D. 29CFR 1910.94(D)
E. TWO OF THE ABOVE
58. WHICH FEDERAL REGULATION DOES NOT REQUIRE TRAINING OF
EMPLOYEE REGARDING THE POTENTIAL HAZARD OF THEIR JOB AND
MEANS OF ASSURING PROTECTION?
A. - 29CFR 1926.21
B. 29CFR 1910.67
C. 29CFR 1910.1200
D. 29CFR 1910.94
E. TWO OF THE ABOVE
59. THE SENSE OF SMELL CAN BE RELIED ON TO ASSESS TOXICS IN
CONFINED SPACES BECAUSE ALL TOXIC GASES HAVE A UNIQUE
IRRITANT SMELL THAT ADEQUATELY WARNS THE ENTRANT?
A. TRUE
B. FALSE
C. SOMETIMES
D. DON'T EVEN THINK OF USING YOUR SENSES TO ACCESS A
CONFINED SPACE
14-19
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Region 5 Health and Safety Manual R5 144Q <9/29/91)
60. WET CARDBOARD IN A CONFINED SPACE WILL?
A. INCREASE OXYGEN LEVELS
B. DECREASE OXYGEN LEVELS
C. INCREASE HUMIDITY
D. INCREASE FUNGAL SPORE PRODUCTION
E. TWO OF THE ABOVE
14-20
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Region 5 Health and Safety Manual _ R5 1440 (9/29/91)
CONFINED SPACE ENTRY
T. W. KRUG, CIH
61. RESPIRATORS ARE REQUIRED FOR ALL CS (CONFINED SPACE WORK?
A. TRUE
B. FALSE
C. DEPENDS ON THE HAZARDS
D. ONLY IF DIRECTED BY YOUR SUPERVISOR
62. RESPIRATORS ALLOWED FOR ENTRY INTO AND ESCAPE FROM IDLH
ATMOSPHERES ARE?
A. AIRLINE
B. SCBA
C. GAS MASK
D. AIR PURIFYING
E. B AND C
63. RESPIRATORS THAT ARE NIOSH APPROVED FOR ESCAPE FROM IDLH
ATMOSPHERES ARE ___ ?
A. SCBA
B. AIR PURIFYING MOUTH PIECE RESPIRATORS
C. GAS MASK WITH CANISTER
D. ALL OF THE ABOVE
64. RESPIRATORS KEPT FOR EMERGENCY ESCAPE MUST BE CHECKED?
A. DAILY
B . WEEKLY
C. MONTHLY
D. BIMONTHLY
65. THE PROTECTION FACTOR ASSIGNED TO A HALF MASK RESPIRATOR IS
A. 2
B. 5
C. 10
D. 100
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Region 5 Health and Safety Manual ^5 1440 (9/29/91)
66. THE NUMBER TC-23C- ASSIGNED_TO A RESPIRATOR INDICATES
ITS APPROVED FOR?
A. IDLH ENTRY '
B. ANY Alff CONTAMINANT
C. GASES OR VAPORS
D. DUSTS, MISTS, FUMES
67. ALL RESPIRATORS MUST BE INSPECTED BY THE USER PRIOR TO
DONNING?
A. TRUE
B. FALSE
C. DEPENDS, IF ITS AN ESCAPE RESPIRATOR THEN NO
68. ALL RESPIRATORS MUST BE FIT TESTED PRIOR TO USE?
A. TRUE
B. FALSE
C. I DON'T KNOW
D. I DON'T CARE
69. WHICH OF THE FOLLOWING RESPIRATORS MUST THE USER BE TRAINED
ON TO ASSURE PROPER USAGE?
A. SCBA
B. AIRLINE
C. AIR PURIFYING
D. ALL OF THE ABOVE
70. HOW DO YOU KNOW WHEN TO CHANGE THE FILTER ON A DUST MIST
FUME TYPE RESPIRATOR?
A. THE FILTER MUST BE CHANGED DAILY
B. WHEN THE FILTER TURNS COLOR
C. WHEN THE USER SMELLS THE CONTAMINANT INSIDE THE RESPIR-
. ATOR
D. WHEN BREATHING BECOMES DIFFICULT
71. WHEN DO YOU CHANGE A CHEMICAL CARTRIDGE ON A RESPIRATOR?
A. WHEN THE CARTRIDGE CHANGES COLOR
B. WHEN BREATHING BECOMES DIFFICULT
C. WHEN YOU SMELL OR TASTE THE CONTAMINANT INSIDE
D. WHEN YOUR SUPERVISOR ADVISES YOU TO CHANGE THEM
14-22
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Region 5 Health-and Safety Manual - R5 1440 (9/29/91)
72. WHAT IS THE BEST GLOVE FOR CHLORINATED SOLVENTS LIKE
. TRICHLORETHYLENE?
A. COTTON
B. LEATHER
C. BUTYL RUBBER
D. NITRILE
73. WHAT IS REQUIRED PPE FOR ENTRY INTO IDLH ATMOSPHERE?
A. SCBA RESPIRATOR
B. AIRLINE RESPIRATOR
C. LIFE LINE AND HARNESS
D. TWO OF THE ABOVE
74. A GOOD GLOVE FOR PROTECTION AGAINST ACIDS SUCH AS 10%
SULFURIC OR 10% HYDROCHLORIC IS ?
A. RUBBER
B. NROPHRENE
C. NITRILE
D. LEATHER
E. A, B & C
75. WHEN WORKING WITH CAUSTICS OR ACIDS THERE MUST BE IN THE
AREA FOR IMMEDIATE USE?
A. AN EYE WASH AND SHOWER
B. A FIRST AID KIT WITH 3% BORIC ACID SOLUTION
C. AN ANSI APPROVED EYE OINTMENT
D. A COPY OF THE OSHA 1910.STD
76. NON SLIP FOOTWEAR IS RECOMMENDED FOR ALL ENTRANTS IN A
CONFINED SPACE. WHAT ANSI STD COVERS TESTING AND CERTIFYING
FOOT PROTECTION?
A. . ANSI Z1117.1
B. ANSI Z89.1
C. ANSI Z41.1 1967
D. ANSI Z87.1
77. THE ANSI STD THAT ADDRESSED CONFINED SPACES BEING HAZARDOUS
UNTIL PROVEN OTHERWISE IS?
A. Z49.2
B. Z117.1
C. Z89.2 1980
D. Z88.2 1980
E. B AND D
14-23
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
78. THE NIOSH DOCUMENT THAT ADDRESSES HAZARDS OF CONFINED SPACES
AND CLASSIFIES THEM AS A, B OR C IS?
A. 80-104 1980
B. . 80-106 ''1979
C. 90-104 1990
D. 60-210 1987
79. THE MAIN PROBLEM GAS WITH SUPPLIED AIR RESPIRATORS USING A
COMPRESSOR IS?
A. HYDROGEN
B. HYDROGEN CYANIDE
C. CARBON MONOXIDE
D. CARBON DIOXIDE
80. AN AIR LINE RESPIRATOR CAN BE USED FOR PROTECTION AGAINST
AIR-BORNE CARBON MONOXIDE?
A. YES
B. NO
C. YES, IF GRADE D AIR IS ASSURED
D. YES, IF AMBIENT AIR IS BELOW IDLH LEVELS FOR CO
E. C AND D
81. THE PROPER TESTING SEQUENCE FOR CONFINED SPACES IS THE
FOLLOWING?
A. TOXICS, FLAMMABLE, OXYGEN
B. FLAMMABLES, TOXICS, OXYGEN
C. OXYGEN, TOXICS, FLAMMABLES
D. OXYGEN, FLAMMABLES, TOXICS
82. SCBA'S WITH ALUMINUM TANKS MUST BE HYDROSTATICALLY TESTED AT
WHAT INTERVAL?
A. EVERY THREE YEARS
B. EVERY FIVE YEARS
C. EVERY YEAR
D. ONCE AT THE FACTORY UNLESS DAMAGED
83. SCBA REGULATORS CAN BE INSPECTED AND REPAIRED BY THE USER TO
ASSURE PROPER AIR FLOW.
A. TRUE, IF THE DIAPHRAGM IS DAMAGED
B. FALSE
C. TRUE, IF AUTHORIZED BY YOUR SUPERVISOR
D. A AND C
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
84. THE MAXIMUM AIR PRESSURE ALLOWED FOR A 2015 PSI RATED SCBA
TANK IS?
A. 2015
B. 2070 t-
C. 2216
D. 3000
85. HOW MANY CU. FEET OF AIR IS IN AN AVERAGE SCBA TANK (30
MINUTE)?
A. 40-45
B. 200
C. 100
D. 80
-•*»*
86. THE MAXIMUM WEIGHT OF AN SCBA IS?
A. 25LBS
B. 35LBS
C. 50LBS
D. 15LBS
87. THE NORMAL HUMAN USES HOW MANY CUBIC FEET OF AIR PER HOUR
(AVERAGE WORK RATE)?
A. 10
B. 35
C. 85
D. 125
E. 5
88. BEFORE ENTERING A CONFINED SPACE FOR WORK, WHAT IS NEEDED TO
ASSURE A SAFE CONFINED SPACE ENTRY?
A. HAZARD PAY
B. _ A PERMIT
C. TRAINING CLASS
D. RESCUE EQUIPMENT AND PPE
E. B, C AND D
89. IN IDLH ENTRIES, WHAT IS THE MINIMUM NUMBER OF SCBA'S
REQUIRED?
A. 1
B. 2
C. 3
D. 4
E. NONE
14-25
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Region 5 Health and Safety Manual , R5 1440 (9/29/91)
90. WHEN INITIAL TESTING SHOWS 16% OXYGEN ON YOUR MONITOR WHAT
IS THE RECOMMENDED PRACTICE?
A. GET OUT AND VENTILATE
B. IF IN, ,GET bUT, INVESTIGATE WHY, THEN MAKE
RECOMMENDATIONS
C. CHECK MONITOR FOR ERROR THEN RECHECK
D. GET OUT AND CALL THE FIRE DEPARTMENT
E. A AND C
91. INERTING A SPACE WITH CO2 IS A GOOD PRACTICE?
A. WHEN HOT WORK IS NEEDED
B. AS LONG AS THE OXYGEN LEVEL IS KEPT BELOW 19.5%
C. AS LONG AS THE OXYGEN LEVEL IS KEPT BELOW 8%
D. PROVIDING EMPLOYEES IN THE SPACE WEAR SCBA'S
E. A, C AND D
92. THE FOLLOWING CAN BE USED FOR INERTING SUBSTANCES.
A. CO
B. STEAM
C. CO,
2
E. ALL BUT ONE OF THE ABOVE
D. N2
93. LIGHTING IN A CONFINED SPACE CONTAINING FLAMMABLES NEED TO
CONFORM TO?
A. OSHA APPROVAL STATUS
B. CLASS II, DIVISION I, GROUP C ATMOSPHERE
C. CLASS I, DIVISION I, GROUP D ATMOSPHERE
D. ILLUMINATION ANSI PAMPHLET 205-10
94. THE AMOUNT OF OXYGEN LEFT AFTER AN EXPLOSION OR FIRE IS
APPROXIMATELY?
A. " 8%
B. 16%
C. 19.5%
D. 21%
95. TP=SP+VP IS A TOXIC METABOLIC FORMULA.
A. TRUE
B. FALSE
C. TRUE IF TOXIC PRODUCT IS GREATER THAN 1
D. FALSE, ITS A BREAK HORSEPOWER FORMULA
14-26
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4
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
96. IN THE VENTILATION FORMULA Q=VA, THE Q STANDS FOR ?
A. QUOTANT
B. QUIET AIR -
C. CUBIC FEET PER MINUTE
D. CUBIC FEET
97. VELOCITY PRESSURE IS ALWAYS NEGATIVE.
A. TRUE
B. FALSE
C. I DON'T KNOW
D, I DON'T CARE
98. ONE PERCENT BY VOLUME OF ANY GAS IS EQUAL TO HOW MANY PARTS
PER MILLION?
A. 10 PPM
B. 100 PPM
C. 1,000 PPM
D. 10,000 PPM
99. AIR CONCENTRATION CAN BE EXPRESSED IN PARTS PER MILLION OR
A. FT/MIN
B, MG/M3
C. CUBIC FEET PER MIN. CFM
D. B OR E
E. MPPCF
100. THE ANSI STD FOR REQUIREMENTS FOR WORKING IN CONFINED SPACES
IS ?
A. ANSI Z117.7
B. ANSI Z80-106
C. 1910.134
D. ' Z117.1
14-27
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Region 5 Health and Safety Manual
R5 1440 (9/29/91)
APPENDIX C
14-28
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
CONFINED SPACE ENTRY
T. W. KRUQ, CIH
<•
1. NORMAL ATMOSPHERIC AIR CONTAINS WHAT PERCENTAGE OF OXYGEN?
2.
3.
4.
A. 21.9%
B. 22.0%
C. 19.5%
D. 20.9%
OXYGEN'S CHEMICAL SYMBOL IS:
A. OX
B. 02
C. 0
D. 0^
—
OXYGEN AND NITROGEN MAKE UP THE HIGHEST PERCENT OF OUR
ATMOSPHERE. WHAT IS THE NEXT LARGEST PERCENT MEMBER?
A. ARGON
B. CO2
C. HYDROGEN
D. CO
HOW MANY PARTS PER MILLION IS THE THIRD
A. 1,000
B. 400
C. 9,000
D. 10,000
HIGHEST % ELEMENT?
5. A FIKE CAN SUSTAIN COMBUSTION AT 12% OXYGEN?
A. YES
B. - NO
C. NOT VERY LIKELY
D. YES, VIOLENTLY
6. THE MINIMUM % OF OXYGEN NEEDED TO SUSTAIN LIFE AT REST IS:
A. 8%
B, 12%
C. 16%
D. 19.5%
14-29
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Region 5 Health and Safety Manual . R5 144Q ,9/29m)
7. CANDLE WILL GO OUT AT BELOW WHAT % 02?
A. 12%
B. 19.5%
C. 21% «
D. 16%
8. GASES THAT ARE CONSIDERED SIMPLE ASPHYXIANT ARE?
A. H-
B. CO
C. CO,
D. A AND C
9. WE EXHALE % OF OXYGEN?
A. 16
B. 19.5
C. 21
D. <5
10. WE EXHALE PARTS PER KILLION OF CARBON DIOXIDE?
A. 20,000
B. 50,000
C. 400
D. 1000
11. WHAT PERCENTAGE OF NORMAL ATMOSPHERIC NITROGEN WODLD BE LEFT
AFTER AN INFLUX OF 10% ARGON?
A. 10
B. 68
C. 78
D. 70
12. AFTER A PIRE, WHAT TYPE OF TOXIC GASES ARE LEFT?
A. CO
B, CO-
C. CH4
D. O2
13. WHICH OF THE FOLLOWING COULD CAUSE AN OXYGEN DEFICIENT
ATMOSPHERE?
A. INCREASE IN CO2
B. INCREASE IN CH4
C. DRYING OF PAINTS
D. ALL OF THE ABOVE
14-30
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Region 5 Health and Safety Manual R5 1440 (9/29/91;
14. WHICH WOULD NOT CAUSE AN OXYGEN DEFICIENT ATMOSPHERE?
A. FIRE
B. LEAKING OXYGEN CYLINDER
C. CORING*OF CEMENT
D. BACTERIAL ACTION OF FERMENTATION
15. WHAT PERCENT OF ATMOSPHERIC OXYGEN IS THERE AT 10,000 FEET?
A. 19.5%
B. 16,0'
C. 20,9
D. 12.0
16. WHICH. OF THE FOLLOWING IS CONSIDERED A CHEMICAL ASPHYXIANT?
A. HCN
B.. CO2
C. CO
D. A AND C
17. GRADE D BREATHING AIR IS COMPOSED OF WHAT RANGE OF OXYGEN
PERCENT?
A. 20-21
B. 19.5-22.5
C. 19.5-23.5
D. 16-21
18. IN FLAMMABLE SPRAY PAINTING OPERATIONS, TrtJC UAX^rtfl CONTENT
IS USUALLY?
A. 20.9%
B. 16.0%
C. 19.5%
D. c 25%
19. AN AIR LINE RESPIRATOR SHOULD BE USED FOR OXYGEN DEFICIENT
ATMOSPHERES.
A. YES
B. NO
C. DON'T KNOW
D. ONLY IF YOU HAVE AN ESCAPE RESPIRATOR WITH YOU
20. ACGIH OXYGEN DEFICIENT ATMOSPHERE IS CONSIDERED?
A. 16%
B. 18%
C. 19.5%
D. 21%
.14-31
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Region 5 Health and Safety Manual RS 1440 (9/29/9l)
CON7HTED SPACE EHTRY
T. W* KRUQ, CZE
21. A FIRE OR EXPLOSION CAN EXIST BELOW THE LEL?
«•
A. HO
B. YES
C. YES, ONLY IF ABOVE 19* OXYGEN
D. YES, ONLY IF THE RATE OF COMBUSTION EQUALS THE FLASH
POINT
22. THE MINIMUM TEMPERATURE AT WHICH A FIRE CAN EXIST ^LS CALLED?
A. SPONTANEOUS IGNITION
B. HEAT OR FUSION
C. FLASH POINT
D. A AND C
23. MOST" FLAMMABLE GASES AND VAPORS ARE AT THEIR LEL WHEN TEE
PERCENT BY VOL IN AIR EQUALS ?
A. 1-5*
B. 40-50%
C. '.01% OF THE UEL
D. THE VAPOR PRESSURE
24. THE THREE COMPONENTS NECESSARY TO HAVE A FIRE ARE?
A. 8%0- - FUEL - SPARK
B. 19..5%O2 - TEMP ABOVE 100"F - HEAT
C. AIR - FUEL - HEAT
D. IGNITION SOURCE - OXYGEN - 10% LEL
25, HOW MANY PARTS PER MILLION IS 10% BY VOLUME?
A. 1000
B. ' 10/000
C. 100,000
D. 1,000,000
26. IF THE LEL OF A FLAMMABLE VAPOR IS 1% BY VOL, HOW MANY PARTS
PER MILLION IS 1% OF THE LEL?
A. 10 PPM
B. 100 PPM
C. 1,000 PPM
D. 10,000 PPM
14-32
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
27. ACCORDING TO THE PROPOSED 1910.146 CONFINED SPACE STANDARD,
WHAT IS THE UPPER LIMIT OF PERCENT LET. OF FLAMMABLE GAS OR
VAPOR ALLOWED?
A. 50%
B. 1%
C. 10%
D. 20%
28. WHICH OF THE FOLLOWING IS A FLAMMABLE GAS?
A. C02
C. CCL4
B.
C.
D.
29. WHICH OF THE FOLLOWING IS NOT A FLAMMABLE GAS?
A. DIESEL FUEL
B. GASOLINE
C. CARBON MONOXIDE
D. A AND B
30. A COMBUSTIBLE GAS METER READS IN
A. % LEL
B. % UEL
C. % VOLUME
D. % OXYGEN
31. MOST COMBUSTIBLE GAS METERS MEASURE ONLY PURE GASES?
A- TRUE
B. FALSE
32. THE PRINCIPLE OF OPERATION OF THE COMBUSTIBLE GAS METER IS?
A. ELECTRIC ARC
B. OXIDATION /REDUCTION
C. ELECTRO-OXIDATION
D. WHEAT STONE BRIDGE
33. IF THE LEL OF A CERTAIN GAS IS 5% BY VOLUME AND THE UEL IS
15% BY VOLUME, THEORETICALLY, WHAT READING SHOULD YOU GET ON
A CGM WHEN YOU USE A 2% VOLUME MIXTURE WITH A BALANCE OF
NITROGEN?
A. 10,000 PPM
B. 40% LEL 14_
C. ZERO JJ
D. 80% OF FLASH POINT
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Region 5 Health and Safety Manual R5 144Q <9/29/91)
34. THE FRECEED±NG. QUESTION USIHG 2% VOLUME MIXTURE WITH A
BALANCE OF AIR?
A. 10,000 PPM
B. 40* LEL
C •ZERO
D! 80% OF FLASH POINT
35. COMBUSTIBLE GAS METERS CAN MEASURE ALL TYPES OF GAS?
A. TRUE
B. FALSE
36. COMBUSTIBLE GAS MhTERS WILL INDICATE THE LOWER EXPLOSIVE
LIMIT FOR EXPLOSIVE DUSTS?
A, TRUE
B. FALSE
37. THE PERCENT OF OXYGEN WILL NOT AFFECT THE OPERATION OF CGM.
A, TRUE
B. FALSE
38. AN ORDINARY CLEAN RUBBER HOSE CAN BE USED TO EXTEND THE
SAMPLING DISTANCE WITH A CGM?
A. TRUE
B, FALSE
39. THE ACCURACY OF A CGM CAN BE 50% INACCURATE?
A. TRUE
B. FALSE
40. PRE-CALIBRATION ISN'T NECESSARY FOR A CGM BECAUSE IT'S DONE
AT THE FACTORY?
A. TRUE
B. FALSE
14-34
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
CONFUTED SPACE ENTRY
T. W. KRUG, CZE
41. CARBON MONOXIDE (CO) IS A TOXIC GAS THAT CAN KILL A HUMAN IK
LESS THAN ONE HALF HOUR AT HOW MANY PART PER KILLION?
A. 400
B. 35
C. 1000
D. 2000
42. HYDROGEN SULFIDE'S (H-S) IDLH (IMMEDIATELY DANGEROUS TO LIFE
OR HEALTH) AIR LEVEL IS USUALLY CONSIDERED TO BE ?
A. 100 PPM
B. 20 PPM
C. 400 PPM
D. 1000 PPM
43. CARBON DIOXIDE IS FOUND AS A BY PRODUCT OF?
A. FIRE
B. CEMENTING
C. HUMANS
D. TWO OF ABOVE
44. CARBON DIOXIDE IS EXHALED AT WHAT PERCENT BY VOLUME?
A. 3-5%
B. .04%
C. 16%
D. 12%
45. METHANE IS A TOXIC GAS TO HUMANS?
A.. TRUE
B. FALSE
46. METHANE SMELLS LIKE
A. NATURAL GAS
B. ROTTEN EGGS
C. SWEET VIOLETS
D. NO SMELL AT ALL
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Region 5 Health and Safety Manual - R5 1440 (9/29/91)
47. OXYGEN DEFICIENCY CAN OCCUR FROM THE FOLLOWING?
A. INFLUX OF SIMPLE ASPHYXIANT GASES IE., CO2, N2, ARGON,
CH. "••
B. ROTTING OR DECOMPOSITION OF ORGANIC MATERIAL
C. THE RUSTING OF IRON OR DRYING OF PAINTS
D. THE CURING OF CEMENT
E. ALL OF THE ABOVE
48. HALO AROUND LIGHTS AND A BROWN COPPER TINT TO SILVER COINS
IS AN INDICATION OF WHAT TOXIC GAS?
A. CHLORINE
B. BROMINE
C. HYDROGEN SULFIDE
D. SULFUR DIOXIDE
49. BLUING OF THE LIPS AND FINGERNAIL BEDS IS INDICATIVE OF WHAT
TYPE EXPOSURE?
A. CARBON MONOXIDE
B. HYDROGEN SULFIDE
C. HYPOXIA
D. FROSTBITE
E. TWO OF THE ABOVE
50. CARBON MONOXIDE POISONING SYMPTOMS ARE?
A. HALOS AROUND LIGHTS YELLOW COPPER TINT TO SILVER COINS
B. REDDENING OF THE EYES AND DILATION OF THE PUPILS
C. CHERRY RED LIPS AND FINGERNAIL BEDS
D. TWO OF THE ABOVE
51. CARBON MONOXIDE IS LIGHTER THAN AIR?
A. ' TRUE
B. FALSE
C. SAME
52. METHANE IS HEAVIER THAN AIR?
A. TRUE
B. FALSE
C. DEPENDS ON AIR DENSITY
53. WHICH OF THE FOLLOWING ARE CHEMICAL ASPHYXIANTS?
A. CARBON MONOXIDE
B. HYDROGEN CYANIDE
C. HYDROGEN SULFIDE
D. ALL OF THE ABOVE 14-36
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Region 5 Health and Safety Manual . R5 144Q (9/29/91)
54. DETECTOR TUBE SAMPLING HAS WHAT PERCENT ERROR?
A. 1-2%
B. 5-10%
C. 25-35%
D. OVER 50%
55. PRESENTLY THE GUIDELINES TO FOLLOW WHEN ASSESSING TOXICS IN
CONFINED SPACES DEPENDS ON?
A. THE MATERIAL STORED PREVIOUSLY AND PRESENTLY
B. THE SPECIFIC GRAVITY OF THE GAS OR VAPOR
C. THE IDLH LEVELS AND PEL OR TLV LEVELS
D. ALL OF THE ABOVE
E. NONE OF THE ABOVE
56. AFTER THE INITIAL ASSESSMENT FOR TOXICS THE AIR CONTAMINANT
LEVELS MUST BE DOCUMENTED AND FURTHER TESTS NEED NOT BE DONE
UNTIL THE ENTRY PERMIT IS REVOKED?
A. TRUE
B. FALSE
57. WHICH -CURRENT FEDERAL STANDARD STATES THE EMPLOYEES MUST
HAVE A WRITTEN CONFINED SPACE PROGRAM?
A. 29CFR 1926.21
B. 29CFR 1910.146
C. 29CFR 1910.134(E)(3)
D. 29CFR 1910.94(D)
E. TWO OF THE ABOVE
58. WHICH FEDERAL REGULATION DOES NOT REQUIRE TRAINING OF
EMPLOYEE REGARDING THE POTENTIAL HAZARD OF THEIR JOB AND
MEANS OF ASSURING PROTECTION?
A. 29CFR 1926.21
B. 29CFR 1910.67
C. 29CFR 1910.1200
D. 29CFR 1910.94
E. TWO OF THE ABOVE
59. THE SENSE OF SMELL CAN BE RELIED ON TO ASSESS TOXICS IN
CONFINED SPACES BECAUSE ALL TOXIC GASES HAVE A UNIQUE
IRRITANT SMELL THAT ADEQUATELY WARNS THE ENTRANT?
A. TRUE
B. FALSE
C. SOMETIMES ... -_
D. DON'T EVEN THINK OF USING YOUR SENSES TO ACCESS A
CONFINED SPACE
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
60. WET CARDBOARD IN A CONFINED SPACE WILi?
A. INCREASE OXYGEN LEVELS
B» DECREASE OXYGEN LEVELS
C. INCREASE HUMIDITY
D. INCREASE FUNGAL SPORE PRODUCTION
E. TWO OF THE ABOVE
. 14-38
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Region 5 Health and Safety Manual R5 1M(J (9/29/gl)
COKPIXSD 8P*CK KNTRT
T. W. KRUG, CIS.
1*.
61. RESPIRATORS ARE REQUIRED FOR ALL CS (CONFINED SPACE WORK?
A. TRUE
B. FALSE
C. DEPENDS ON THE HAZARDS
D. ONLY IF DIRECTED BY YOUR SUPERVISOR
62. RESPIRATORS ALLOWED FOR ENTRY INTO AND ESCAPE FROM IDLH
ATMOSPHERES ARE?
A. ' AIRLINE
B. SCBA
C. GAS MASK
D. AIR PURIFYING
E. B AND C
63. RESPIRATORS THAT ARE NIOSH APPROVED FOR ESCAPE FROM TDT.H
ATMOSPHERES ARE ?
A. SCBA
B. AIR PURIFYING MOUTH PIECE RESPIRATORS
C. GAS MASK WITH CANISTER
D. ALL OF THE ABOVE
64. RESPIRATORS KEPT FOR EMERGENCY ESCAPE MUST BE CHECKED?
A. DAILY
B. WEEKLY
C. MONTHLY
D. BIMONTHLY
65. THE" PROTECTION FACTOR ASSIGNED TO A HALF MASK RESPIRATOR IS
A. 2
B, 5
C. 10
D. 100
.14-39
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Region 5 Health and Safety Manual
R5 1440 (9/29/91)
66. THE NUMBER TC-23C- ASSIGNED TO A RESPIRATOR INDICATES
ITS APPROVED FOR?
f.
A. IDLH ENTRY
B. ANY AIR CONTAMINANT
C. GASES OR VAPORS
D. DUSTS/ MISTS, FUMES
67. ALL RESPIRATORS MOST BE INSPECTED BY THE USER PRIOR TO
DONNING?
A. TRUE
B. FALSE
C. DEPENDS, IF ITS AN ESCAPE RESPIRATOR THEN NO
68. ALL RESPIRATORS MUST BE FIT TESTED PRIOR TO USE?
A. TRUE
B. FALSE
C. I DON'T KNOW
D. I DON'T CARE
69. WHICH OF THE FOLLOWING RESPIRATORS MUST THE USER BE TRAINED
ON TO ASSURE PROPER USAGE?
A. SCBA
B. AIRLINE
C. AIR PURIFYING
D. ALL OF THE ABOVE
70. HOW DO YOU KNOW WHEN TO CHANGE THE FILTER ON A DUST MIST
FUME TYPE RESPIRATOR?
A. THE FILTER MUST BE CHANGED DAILY
B. WHEN THE FILTER TURNS COLOR
C. - WHEN THE USER SMELLS THE CONTAMINANT INSIDE THE RESPIR-
ATOR
D. WHEN BREATHING BECOMES DIFFICULT
71. WHEN DO YOU CHANGE A CHEMICAL CARTRIDGE ON A RESPIRATOR?
A. WHEN THE CARTRIDGE CHANGES COLOR
B. WHEN BREATHING BECOMES DIFFICULT
C. WHEN YOU SMELL OR TASTE THE CONTAMINANT INSIDE
D. WHEN YOUR SUPERVISOR ADVISES YOU TO CHANGE THEM
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72. WHAT IS THE BEST GLOVE FOR CHLORINATED SOLVENTS LIKE
TRICHLORETHYLENE?
A. COTTON f,
B. LEATHER
C. BUTYL RUBBER
D. NITRILE
73. WHAT IS REQUIRED PPE FOR ENTRY INTO IDLH ATMOSPHERE?
A. SCBA RESPIRATOR
B. AIRLINE RESPIRATOR
C. LIFE LINE AND HARNESS
D. TWO OF THE ABOVE
74. A GOOD GLOVE FOR PROTECTION AGAINST ACIDS SUCH AS 10%
SULFURIC OR 10% HYDROCHLORIC IS ?
A. RUBBER
B. NROPHRENE
C. NITRILE
D. LEATHER
E. A, B & C
75. WHEN WORKING WITH CAUSTICS OR ACIDS THERE MUST BE IN THE
AREA FOR IMMEDIATE USE?
A. AN EYE WASH AND SHOWER
B. A FIRST AID KIT WITH 3% BORIC ACID SOLUTION
C. AN ANSI APPROVED EYE OINTMENT
D. A COPY OF THE OSHA 1910.STD
76. WON SLIP FOOTWEAR IS RECOMMENDED FOR ALL ENTRANTS IN A
CONFINED SPACE. WHAT ANSI STD COVERS TESTING AND CERTIFYING
FOOT PROTECTION?
A. " ANSI 21117.1
B. ANSI 289.1
C. ANSI Z41.1 1967
D. ANSI 287.1
77. THE ANSI STD THAT ADDRESSED CONFINED SPACES BEING HAZARDOUS
UNTIL PROVEN OTHERWISE IS?
A. Z49.2
B. Z117.1
C. Z89.2 1980
D. Z88.2 1980
E. B AND D
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78. THE NIOSH DOCt3KENT THAT ADDRESSES HAZARDS OF CONFINED SPACES
AND CLASSIFIES THEM AS A, B OR C IS?
A. 80-104 1980
B.. 80-106 1979
C. 90-104 1990
D. 60-210 1987
79. THE MAIN PROBLEM GAS WITH SUPPLIED AIR RESPIRATORS USING A
COMPRESSOR IS?
A. HYDROGEN
B. HYDROGEN CYANIDE
C. CARBON MONOXIDE
D. CARBON DIOXIDE
80. AN AIR LINE RESPIRATOR CAN BE USED FOR PROTECTION AGAINST
AIR-BORNE CARBON MONOXIDE?
A. YES
B. NO
C. YES, IF GRADE D AIR IS ASSURED
D. YES, IF 'AMBIENT AIR IS BELOW IDLH LEVELS FOR CO
E. C AND D
81. THE PROPER TESTING SEQUENCE FOR CONFINED SPACES IS THE
FOLLOWING?
A, 'TOXICS, FLAMMABLE, OXYGEN
B. FLAMMABLES, TOXICS, OXYGEN
C. OXYGEN, TOXICS, FLAMMABLES
D. OXYGEN, FLAMMABLES, TOXICS
82. SCBA'S WITS ALUMINUM TANKS MUST BE HYDROSTATICALLY TESTED AT
WHAT INTERVAL?
A. EVERY THREE YEARS
B, EVERY FIVE YEARS
C, EVERY YEAR
D. ONCE AT THE FACTORY UNLESS DAMAGED
83. SCBA REGULATORS CAN BE INSPECTED AND REPAIRED BY THE USER TO
ASSURE PROPER AIR FLOW.
A. '. TRUE, IF THE DIAPHRAGM IS DAMAGED
B. FALSE
C. TRUE, IF AUTHORIZED BY YOUR SUPERVISOR
D. A AND C
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84. THE MAXIMUM AIR PRESSURE ALLOWED FOR A 2015 PSI RATED SCBA
TANK IS?
A. 2015
B. 2070
C. 2216
D. 3000
85. HOW MANY CU. FEET OF AIR IS IN AN AVERAGE SCBA TANK (30
MINUTE)?
A. 40-45
B. 200
C. 100
D. 80
86. THE MAXIMUM WEIGHT OF AN SCBA IS?
A. 25LBS
B. 35LBS
C. 50LBS
D. 15LBS
87. THE NORMAL HUMAN USES HOW MANY CUBIC FEET OF AIR PER HOUR
(AVERAGE WORK RATE)?
A. 10
B. 35
C. 85
D. 125
E. 5
88. BEFORE ENTERING A CONFINED SPACE FOR WORK, WHAT IS NEEDED TO
ASSURE A SAFE CONFINED SPACE ENTRY?
A. HAZARD PAY
B. - A PERMIT
C. TRAINING CIASS
D. RESCUE EQUIPMENT AND PPE
E. B, C AND D
89. IN IDLE ENTRIES, WHAT IS THE MINIMUM NUMBER OF SCBA'S
REQUIRED?
A. 1
B. 2
C. 3
D. 4
E. HONE
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90. WHEN INITIAL TESTING SHOWS 16% OXYGEN ON YOUR MONITOR WHAT
IS THE RECOMMENDED PRACTICE?
A. GET OUT AND VENTILATE
B. 'IF IN, GET OUT, INVESTIGATE WHY, THEN MAKE
RECOMMENDATIONS
C. CHECK MONITOR FOR ERROR THEN RECHECK
D. GET OUT AND CALL THE FIRE DEPARTMENT
E. A AND C
91. INERTING A SPACE WITH COj IS A GOOD PRACTICE?
A. .WHEN HOT WORK IS NEEDED
B. AS LONG AS THE OXYGEN LEVEL IS KEPT BELOW 19.5%
C". AS LONG AS THE OXYGEN LEVEL IS KEPT BELOW 8%
D. PROVIDING EMPLOYEES IN THE SPACE WEAR SCBA'S
E. A, C AND D
92. THE FOLLOWING CAN BE USED FOR INERTING SUBSTANCES.
A. CO
B. STEAM
C. CO-
D. N2
E. ALL BUT ONE OF THE ABOVE
93. LIGHTING IN A CONFINED SPACE CONTAINING FLAMMABLES NEED TO
CONFORM TO?
A« OSHA APPROVAL STATUS
B. CLASS II, DIVISION I, GROUP C ATMOSPHERE
C. CLASS I, DIVISION I, GROUP D ATMOSPHERE
D, ILLUMINATION ANSI PAMPHLET 205-10
94. THE AMOUNT OF OXYGEN LEFT AFTER AN EXPLOSION OR FIRE IS
APPROXIMATELY?
A. 8%
B. 16%
C. 19.5%
D. 21%
95. TP=SIN-VP IS A TOXIC METABOLIC FORMULA.
A. TRUE
B. FALSE
C. TRUE IF TOXIC PRODUCT IS GRFATER THAN 1
D. FALSE, ITS A BREAK HORSEPOWER FORMULA
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Chapter 15 - HAZARDOUS WASTE SITES
15.1 GENERAL REQUIREMENTS
i>
Primary guidance for personnel working at all Hazardous
Waste Sites and incidents is provided in 29 CFR 1910.120, EPA
540/G-89/004 OSWER Directive 9355.3-01 dated October 1988, EPA
Order 1440.2, and numerous additional EPA regulations and
guidances. All Hazardous Waste Sites (including uncontrolled
Superfund/RCRA Waste Sites, and permitted Waste Sites such as
TSDs and all others) are required to have a written health and
safety program for all personnel involved in hazardous waste
operations. This program must be designed to identify,
evaluate, and control safety and health hazards, and provide
for emergency response for hazardous waste operations. This
safety and health program must incorporate the following: an
organizational structure, a comprehensive workplan, a site-
specific health and safety plan, a health and safety program,
a medical surveillance or monitoring program, standard
operating procedures for health and safety, and any necessary
interface between the general program and site-specific
activities.
The previous paragraph provides an overall summary of
Hazardous Waste Safety Requirements; more specific guidance
can be found in 29 CFR 1910.120 and related EPA regulations
previously referenced. Furthermore, it should be noted that
Superfund site personnel are required to take the 40 Hour
Superfund Field Safety Training Course and a yearly 8 Hour
Refresher Course; and RCRA personnel must take the 24 Hour
Field Safety Training Course and a yearly 8 Hour Refresher
Course. All field certification by a supervisor both
initially and yearly is required for all Superfund and RCRA
Waste Site personnel (training requirements are covered in
more detail in Chapter 5 of this manual or contact the Health
and Safety Manager for further details.)
Additionally, baseline and yearly (every 12 months)
medical monitoring physical exams are required for all
Superfund and RCRA waste site personnel in addition to
quantitative and qualitative respirator fit testing (for
further information, see Chapter 10 of this manual on Medical
Monitoring and Chapter 13 on Respirators.) All of the
referenced training and medical monitoring programs are
administered by the Regional Health and Safety Manager.
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15.2 SAFETY PLANS
In addition to site Health and Safety Programs, specific
site safety plans are required at hazardous waste sites where
regional personnel are present. The principal elements of a
site safety plan are:
«»
1. The name of a Site Health and Safety Officer and the
names of key personnel and alternates responsible for
site safety and health
2. A health and safety risk analysis for existing site
conditions, and for each site task and operation
3. Employee training assignments
4. A description of personal protective equipment to be
used by employees for each of the site tasks and
operations being conducted
5. Medical surveillance requirements
6. A description of the frequency and types of air
monitoring, personnel monitoring, and environmental
sampling techniques and instrumentation to be used
7. Site control measures
8. Decontamination procedures
9. Standard operating procedures for the site
10. A contingency plan that meets the requirements of
29 CFR 1910.120(1)(1) and (1)(2)
11. Entry procedures for confined spaces.
For more specific information on site safety plans, consult
29 CFR 1910.120 or previously referenced EPA regulations and
guidelines or contact the Regional Health and Safety Manager
or Division or Branch Safety Officer.
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Chapter 16 - LABORATORY SAFETY
16.1 GENERAL- LABORATORY SAFETY RULES
All laboratories and analytical procedures have certain
dangers in common. Almost all analytical procedures use
chemicals that are considered toxic or hazardous; examples
include acids, bases, and organic solvents. The samples for
analysis often contain unknown biological hazards or hazardous
and toxic chemicals. For these reasons, certain safety
precautions are necessary throughout all laboratories and
whenever handling an unknown sample.
Each laboratory and test procedure will have safety rules
specified in the Laboratory Safety manual or Standard
Operating Procedure for the test. These manuals and
procedures are in addition and add specifics to the general
lab rules listed in this chapter. There are certain safety
rules that will apply in all laboratories in Region 5. These
basic rules are listed below:
1. All exits and passageways must be unobstructed and
allow free exit.
2. Eating, drinking or smoking in the laboratory is
prohibited.
3. Appropriate personal protective equipment must be
worn for each procedure. This includes lab coats, gloves,
safety glasses, goggles, and occasionally respirators.
4. Pipetting by mouth is prohibited.
5. All safety signs should be observed and obeyed.
6. All toxic waste must be properly disposed according
to RCRA regulations.
7. Flammable, toxic or radioactive material must be
stored in approved containers.
8. All containers of chemicals and samples shall be
labeled clearly and correctly.
9. All gas cylinders must be firmly secured to prevent
falling.
10. All electrical equipment should be properly grounded
and electrical cords inspected periodically to ensure that
they are in good working condition.
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11. Floors and surface working areas are to be kept
clean, dry and free from corrosive chemicals. Spills must be
cleaned up immediately.
12. Initiation of a laboratory analysis or experiment,
not fully described in Standard Methods, AQC Manual or other
procedural source^must be preceded by a survey of existing
literature. The toxicity and other hazards connected with the
reactants and products should be investigated thoroughly
before starting any laboratory reaction.
16.2 HAZARD COMMUNICATION AND IDENTIFICATION
All EPA Region 5 laboratories will comply with the OSHA
Hazard Communication Standard 29 CFR 1910.1200. Compliance
with this standard includes training of employees, proper
labeling of chemicals and availability of Material Safety Data
Sheets (MSDS) to all employees.
It is important that any hazards are identified and
communicated to any and all personnel who might encounter them
in the laboratory. This would include all personnel who work
in the laboratory, all maintenance personnel, and any
visitors. Most hazards are identified through the use of
signs. All areas with radiation, PCBs greater than 50 ppm,
biological hazards, etc. should be posted with the appropriate
signs to alert personnel. The laboratory area should be
posted as a nonsmoking, no eating or drinking area. Proper
signs are the first step in hazard communication.
All labels on incoming containers are not to be removed
or defaced. The labels contain important information on the
hazards of the substance and identify the substance in the
container.
Material Data Safety Sheets (MSDS) for any chemicals used
by the laboratory must be accessible to all personnel. The
MSDS contains valuable information on toxicity, first aid,
fire prevention etc.
The safety training provided to all employees is an
important part of the hazard communication process. Safety
training for laboratory employees is detailed in Chapter 5 on
Safety Training. Maintenance personnel must be trained to
look for and spot hazards in the laboratory or be accompanied
by a laboratory representative.
The Chemical Hygiene Plan, safety manual, standard
operating procedure, and toxic substance safety plan are all
used in planning a safe operation. Always have safety
documents available to the employees.
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16.3 CONTINGENCY PLANS
Contingency plans are used in cases of accidents or
emergency. A spill contingency plan is necessary whenever
toxic or hazardous substances are on site. Personnel must be
trained in spill cleanup procedures. Depending on the size of
the laboratory and the operations performed in the laboratory,
a special team may be needed for emergencies. At smaller
installations, the local fire department or emergency response
team can be relied on for any emergencies. Emergency response
teams may require training in respiratory protection, first
aid, and spill cleanup. The duties of the team should be
clearly delineated. Evacuation plans should be distributed,
posted and updated yearly.
16.4 VENTILATION REQUIREMENTS
Proper ventilation must be provided for the analytical
process used. Whenever hazardous or toxic substances will be
used, proper ventilation must be provided. In most cases,
this will be primary containment equipment such as a
laboratory fume hood. Fume hoods must be tested at least
annually to assure proper flow rates and containment.
Maintenance must be provided on a regular basis to assure
proper functioning.
A mechanical exhaust ventilation system must be provided
for controlling laboratory room air movement. The movement of
air must be from areas of lower contamination potential to
areas of higher contamination potential (i.e. from entry
corridors to the laboratory). The exhaust air from laboratory
areas must be discharged outdoors in a way that entry into a
buildings air supply is minimized. Exhaust air from
laboratory areas which is not derived from primary containment
equipment can be discharged to the outdoors without being
treated.
The exhaust air from glove boxes must be treated by
filtration, reaction, absorption, adsorption, electrostatic
precipitation or incineration, as appropriate, depending on
the nature of the compound. The need for, and type of,
treatment for other primary containment equipment, including
laboratory fume hoods and biological safety cabinets, must be
determined by the OHSD. All exhaust air from primary
containment equipment must be discharged by roof mounted
blowers to the outdoors so that such air is dispersed clear of
occupied buildings and air intakes.
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Other facility safety equipment must include a
handwashing facility, eye wash facility and shower facility.
This equipment is necessary whenever hazardous or toxic
materials (including unknown samples) may be used in the
analysis.
16.5 STORAGE REQUIREMENTS
Proper storage techniques must be followed and are
detailed in the following paragraphs.
16.5.1 Storage of Compressed Gas Cylinders
Only the cylinders required for immediate use are to
remain in the laboratory work area. Separate storage areas
should be provided for gas cylinders. Empty and full
cylinders should not be stored together. Oxygen cylinders
must not be stored near flammable gas cylinders. Cylinders of
compressed gases must be stored valve end up securely fastened
to a wall or otherwise immovable storage to prevent the
cylinder from falling. At all times, whether in use or
storage, cylinders will be securely fastened (strapped or
chained) to prevent falls. Cylinders should always be kept
away from sources of heat.
16.5.2 Storage of Chemicals
When dealing with any chemical or waste chemicals,
whether in the laboratory, in the stockroom, or in bulk
storage, incompatible chemicals must be stored separately.
Storage control will minimize the consequences of accidental
mixing by spillage, breakage, or fire. In general, four major
areas are needed: flammable solvents, corrosive liquids,
strong oxidizers, and main bulk of chemicals. Other groupings
that might be needed would include radioactive materials,
biological hazards, highly toxic materials and compressed
gases .
In the main laboratory work areas, only a working amount
of the chemical should be stored. Separate storage areas
(stockrooms) should be provided for the main bulk of
chemicals. In the laboratory, incompatible chemicals should
be stored in separate safety storage cabinets, or be divided
by a wall or enclosed by a tray to prevent accidental mixture.
These should always be properly labeled.
The main storage areas should be divided to accommodate
incompatible chemicals. Depending on the amount of chemicals
in storage, separate approved safety storage cabinets can be
used or separate rooms can be provided.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
No more than five one-liter containers of Class I and II
material should be stored in glass in the open laboratory
areas. Open areas include open reagent shelves and bench
tops. All glass containers must be inside of a protective
outer sheath or be made of the unbreakable glass.
Separate* areas for waste collection should be provided
and properly labeled. Proper dikes and separation of
incompatible waste must be considered.
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Chapter 17 - ENVIRONMENTAL COMPLIANCE
Executive Order 12088, signed by President Jimmy Carter
in 1978, requires Federal Agencies to comply with all
requirements of Federal, State, and local environmental
regulations. EPA Region 5 is subject to a variety of
regulations concerning air, water, hazardous and nonhazardous
waste, toxic substance control, emergency planning, and
community right-to-know.
Region 5 is committed to complying with all applicable
regulations and serving as a model to other regions in the
areas of environmental health and safety.
The body of applicable regulations is quite voluminous.
Not only does the Federal government promote regulations
pursuant to Federal statutes, but it also allows and
encourages State and local agencies to adopt additional
regulations which may often be more stringent. State and
local agencies have responded to this encouragement by
promulgating a series of environmental laws and regulations
that must be complied with in addition to the Federal
regulations.
This chapter is intended to orient Regional employees to
the existence of environmental regulations that may apply to
their work activities. Each Division is required to establish
procedures to comply with regulations that impact their
operations. If compliance assistance is required, the
Division is encouraged to contact the appropriate authorities.
17.1 RESPONSIBILITIES
All EPA employees, contractors, and their representatives
are required to act in an environmentally responsible manner
to protect themselves, the public, and the environment from
harm.
17.2 AIR
The Clean Air Act (CAA) , as amended, is a Federal statute
mandating the prevention and control of air pollution from
both stationary and mobile sources. The CAA specifies that
states must enforce pollution abatement requirements for
existing and new sources. State and local agencies have the
option of developing more stringent standards than those set
by the Federal government. Regulated entities must comply
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
with the most stringent emission standards, whether the
standards are Federal, State or local. National Emission
Standards for Hazardous Air Pollutants are found in 40 CFR,
Part 61.
Employees must never "dispose" of chemicals by allowing
them to evaporate* This would be a violation of Resource
Conservation and Recovery Act regulations as well as a poor
work practice.
Bottles of reagents and solvents should be kept closed
when not in use. In the case of solvents with high
volatility, a great deal of solvent may enter the room
atmosphere potentially exposing employees to harmful levels of
the solvent and also allowing the release of unnecessary
guantities of a particular chemical. Substances whose vapors
have a potential for toxicity, corrosivity, reactivity or
other hazards must be used with caution and be properly
stored.
17.3 DRINKING WATER
EPA policies require that EPA facilities monitor drinking
water for lead and take appropriate action if lead levels
reach or exceed the action level. Region 5 complies with this
policy through the monitoring of drinking fountains and sink
faucets used as sources of drinking water.
17.4 WATER POLLUTION
U.S. EPA Regulations under the Clean Water Act (CWA), as
amended, set forth limits for the discharge of pollutants to
waterways. States and localities typically promulgate
additional regulations to be complied with in addition to the
Clean Water Act. Employees must never dispose of chemicals
via disposal to drain without receiving authorization from a
supervisor who is familiar with State and local requirements.
17.5 NONHAZARDOUS SOLID WASTE
Subtitle D of the Resource Conservation and Recovery Act
(RCRA) established Federal standards for managing nonhazardous
solid wastes. Section 6001 of RCRA requires Federal Agencies
to comply with the guidelines set forth in the Act. The
guidelines apply to all nonhazardous solid waste generated by
Federal Agencies, regardless of whether it is processed or
disposed of on Federal property. Nonhazardous solid waste
regulations applicable to Federal facilities are set out at 40
CFR Parts 240-249. These regulations relate to the
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nonhazardous waste disposal facility's compliance and to
recycling.
Region 5 generates three types of nonhazardous solid
waste: trash designated for a land disposal facility, broken
glassware, and recyclable cans and paper. A brief discussion
of each type follows.
17.5.1 Trash Designated for a Land Disposal Facility
Trash that cannot be recycled is placed in garbage cans
located throughout office and laboratory areas. Examples of
such trash include laboratory towels, labware (excluding
glass) that is not contaminated, and solid samples that are
not designated as hazardous waste.
17.5.2 Recyclable Waste
Region 5 operates a recycling program for newspapers,
white paper, uncontaminated glassware and aluminum cans.
Recycling containers are located throughout offices and
laboratories for employee use.
17.6 HAZARDOUS WASTE
The Resource Conservation and Recovery Act (RCRA), as
amended, regulates the generation, treatment, storage, and
disposal of hazardous waste from "cradle to grave." Section
6001 of RCRA mandates that Federal facilities comply with all
applicable Federal, State, and local requirements dealing with
hazardous waste. Hazardous waste regulations are found at 40
CFR Parts 260-272. States are encouraged under RCRA to
promote regulation. Therefore, Region 5 employees must be
familiar with State regulations when disposing of hazardous
wastes.
17.6.1 Waste Minimization
Region 5 encourages minimizing hazardous waste generation
where possible. Minimizing wastes reduces potential hazards
to employees, the public and the environment. In addition,
in most instances, disposing of a chemical is much more
expensive than the original cost of the waste chemical.
17.6.2 Training
Federal and State regulations require that workers be
provided with annual training relating to waste generation,
handling, and disposal. Initial training is provided to new
employees who work directly with hazardous waste and on an
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annual basis thereafter. The training is designed to
familiarize the employees with the waste handling procedures
in place at Region 5 and emergency response procedures.
17.6.3 Emergency Response
The Region 5,, laboratories and research vessel have a
program for responding to fires, explosions, and releases to
the environment involving hazardous wastes and materials. Lab
and boat employees are responsible for knowing whom to contact
in the event of an emergency in order to implement this
contingency plan. Furthermore, phone numbers for these
points-of-contact should be readily available.
17.7 ASBESTOS
Requirements pertaining to asbestos are included in
regulations promulgated pursuant to the Clean Air Act (CAA)
and the Toxic Substances Control Act (TSCA) . For the most
part Federal and State environmental regulations pertain to
asbestos contained within a building structure. For example,
the regulations require notification of asbestos-containing
materials in the building, such as pipe lagging, and of
removal projects. Region 5 tests for asbestos materials on an
"as-needed" basis and works with the General Services
Administration (GSA) to ensure that EPA employees are
protected from potential exposure to asbestos located within
buildings.
The Central Regional Laboratory processes asbestos-
containing samples as part of its support of EPA programs.
Therefore, CRL is required to comply with the TSCA regulations
that relate to sample receiving, labeling, storage, and
disposal.
17.8 POLYCHLORINATED BIPHENYLS (PCBs)
PCB management is governed under Section 6 of TSCA and
the regulations are codified at 40 CFR Part 761. TSCA
primarily applies to manufacturers, distributors, processors,
and importers of chemicals. All Federal facilities, however,
who use or dispose of any PCB items are subject to TSCA
regulations.
CRL uses and disposes of samples, standards, and stock
solutions containing PCBs, so is subject to those regulations
relating to PCB labeling, storage, dilution, spill cleanup,
and disposal.
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Chapter 18 - MARINE SURVEY SAFETY
18.1 RESEARCH VESSEL
i',
Standards for research vessel safety are outlined in the
Occupational Safety and Health Program For Employees Working
Aboard the R/V Roger R. Simons and R/V Lake Guardian, a
document developed for the EPA by Seaward Services, Inc. in
June of 1990. (A copy of this document is on file in the
Regional Health and Safety Office.) Research vessel
operations must adhere to OSHA standards outlined in 29 CFR
1910 and 29 CFR 1926. (Also available in the Regional Health
and Safety Office.)
18.1.1 Training
Research vessel employees will be trained continuously
from the time of hire in elements of health, safety, and fire
prevention. Areas covered will include: types of equipment
to be used, modes of safe operation, general safety rules,
standard of expected performance, reporting of injuries and
unsafe conditions, etc.
18.1.2 Inspections
Research vessels should be inspected on a regular basis
in order to keep hazards at the lowest possible working level.
On a monthly basis, a formal inspection should be conducted by
an employee who is well versed in OSHA standards for research
vessels. Twice a year, the research vessel will be inspected
by the Regional Health and Safety Manager.
18.1.3 Safety
A safety committee should be formed for each vessel and
monthly committee meetings should be held to address concerns.
These concerns might include accidents, investigations,
complaints, etc. Meeting minutes should be taken and
maintained on file for future reference.
18.1.4 Personal Protective Equipment
Employees will be provided with personal protective
equipment and trained on the use and care of this equipment,
i.e., safety shoes, hearing protection, eye protection,
respiratory protection, etc. In compliance with OSHA 1910
standards, vessel employees are required to adhere to any and
all policies regarding personal protective equipment for their
own well being.
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18.2 SMALL BOATS
1. Boats will be operated only by EPA employees
certified as completing U.S. Power Squadron Safe Boating
Course or its equivalent. This certification shall be
documented in the personnel file. Boat operators must also
complete emergency; first aid training.
2. The boat operator is responsible for the safety of
all persons and the integrity of all equipment on board, and
must provide a boat-safety briefing for all occupants prior to
entering the water.
3. During boat operations, life jackets are to be worn
at all times by the occupants. Minimum personal protective
equipment (i.e., non-skid, soft soled footwear, water
repellent clothing, etc.) should be brought on board in order
to assure safe working conditions.
4. For night operations, night lights must be operated
according to established regulations.
5. At least the minimum safety equipment, as prescribed
by the U.S. Coast Guard, will be on board at all times.
6. Fueling of boats is to be done with extreme caution.
Auxiliary fuel should be stored in safety cans, secured to
prevent spillage, away from sources of heat and sparks.
(Every motorboat shall have a fire extinguisher approved for
righting electrical fires or burning liquid, e.g., gasoline
fires.)
7. The load capacity should be displayed on a plate
mounted in the boat. A certificate of compliance for an
outboard motorboat shows the manufacturer's rating of maximum
horsepower of an engine that can be safely used on the boat.
A combination capacity plate will also list the maximum number
of persons and the maximum weight of persons that can be
carried safely, as well as the maximum weight (of persons,
motor, and gear) which can be carried safely by the boat.
For more detailed information, refer to U.S. EPA Office
of Enforcement and Compliance Monitoring. Boating Safety
Guidelines, November 1987, on file in the Health and Safety
Office.
18.3 DIVING OPERATIONS
EPA's Region 5 Diving Policy is detailed in the following
paragraphs.
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18.3.1 Purpose
EPA Region 5's diving operations will comply with Chapter
10 of the EPA's Occupational Health and Safety Manual. This
chapter establishes the Agency's policy regarding diving
operations in accordance with the U.S. Department of Labor,
OSHA Regulations 29 CFR 1910, Subpart T. Its purpose is to
assure that all diving operations, including contractors,
performed under the auspices of EPA are conducted in a safe
manner, according to uniform procedures, and by sufficiently
trained personnel.
18.3.2 Scope
The requirements and procedures specified in Chapter 10
shall apply to all diving operations involving any project of
the Agency and carried out by any employee or contractor of
the Agency. A dive plan detailing all dive procedures and
associated requirements for each dive operation shall be
reviewed and approved by an EPA Unit Diving Officer. EPA's
Region 5 Unit Dive Officer is Walter Nied and he can be
reached at (312) 886-4466. Chapter 10 shall apply to any type
of diving operations, including, but not limited to: 1)
research projects, 2) monitoring projects, 3) sample
collections, 4) emergency response/removal actions regarding
hazardous substances, and 5) equipment maintenance.
For specific details on diving requirements, refer to
Chapter 10 of the Occupational Health and Safety Manual,
entitled "EPA Diving Safety Policy," dated September 1988 (EPA
1440.)
18.4 HELICOPTER OPERATIONS
EPA's policies with regard to helicopter operations and
safety are detailed in the following paragraphs.
18.4.1 Purpose
The purpose of EPA Region 5's safety policies specific to
helicopter operations is to ensure the use of correct and safe
techniques during helicopter use. Helicopter surveillance is
often necessary during winter operations and therefore,
specific guidelines have been developed to prevent accidents.
18.4.2 Overview
During the winter months, helicopters are used for Great
Lakes surveillance and sampling in lieu of ships. (The water
is often impassable due to ice and wave conditions.
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The three essential elements factoring into a safe
helicopter sampling operation are the aircraft itself, the ice
conditions, and wave heights. First, in cooperation with the
U.S. Coast Guard and the Department of the Interior Office of
Air Craft Services, a seven passenger Sikorski 61 or HH3-f
twin engine helicopter or equivalent equipped with pontoons,
will be used tow sample water during winter ice cover.
Pontoons are necessary for an ice or water landing. Second,
the ice must be thick enough to support the helicopter, four
to eight inches thick, depending on ice cover. Third, flying
over open water, wave heights must be two feet or less for
safe operation of a single engine helicopter. More specific
helicopter guidelines are available through the Occupational
Health and Safety Office.
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
Chapter 19 - RADIATION SAFETY
19.1 DEPARTMENT OF ENERGY PLANTS
Radiation Plans differ from one Department of Energy
(DOE) Plant to the next. Chapter 19 overviews radiation
safety plans for Region 5 facilities.
19.1.1 Portsmouth Gaseous Diffusion Plant (PORTS)
The PORTS facility is operated by Martin Marietta Energy
Systems under a management and operation contract with the
United States Department of Energy (DOE). The principal
process at the plant is the separation of uranium isotopes via
gaseous diffusion. Because of the nature of the process at
the plant, the types of wastes generated include: low level
radioactive wastes, PCB contaminated oils, heavy metals
(nickel, chromium, cadmium, etc.) and various types of spent
solvents (volatile organic compounds). Support operations
include the feed and withdrawal of materials from the primary
process, treatment of water for both sanitary and cooling
purposes, decontamination of equipment removed from the plant
for maintenance or replacement, treatment of sewage wastes and
cooling water blowdown.
19.1.2 Mound Facility
The early Mound Plant programs investigated polonium-210
and its applications, such as the fabrication of neutron and
alpha sources for weapon and nonweapon use. Investigations
were also performed from 1950 to 1963 involving uranium,
protactinium-231 and plutonium-239. In 1954, separation of
the stable isotopes of noble gases was begun. Mound Plant now
is an integrated research, development and production facility
that operates in support of the DOE weapons and energy
programs. The Mound facility currently processes two
radioisotopes: plutonium-238 (used for compact power sources) ,
and tritium (used in the weapons program). Access to the
process area is highly restricted for security reasons as well
as for radiation protection.
19.1.3 Feed Materials Production Center (FMPC)
The U.S. Atomic Energy Commission (AEC), predecessor to
DOE, established FMPC for processing uranium metal from
natural uranium ore concentrations for U.S. Government
military needs. The production facility began operations in
the early 1950's. In 1986, Westinghouse Electric Corporation,
assumed management of the site for a minimum 5-year period.
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Many areas on-site have radiation levels which are elevated
above background radiation levels. A few areas (e.g. near the
K-65 silos and thorium storage areas) have levels which are
sufficiently high as to require posting of warning signs and
restriction of access by a physical barrier. Off-site
environments are known to have contaminated soils. External
radiation exposure may also arise through contamination of
skin or clothing, with radiation dust, soils or other
material.
Airborne radioactive material, predominately uranium with
a uranium-235 content, is present in the process area and may
be present in resuspended dusts in the waste pit areas and
other areas on site. To a much lesser extent there may be a
potential for resuspended dusts and other airborne
particulates in off-site affected environments. Thorium is
present in substantial quantities in certain areas of the
plant. Materials contaminated with trace quantities of
fission products may be present periodically.
19.1.4 Site Health And Safety
Each of these DOE facilities has their own site specific
Radiological Health and Safety Plan that has been developed by
U.S. EPA Region 5 Radiation Staff. The provisions of each
plan applies to all U.S. EPA staff and U.S. EPA contractors
and visitors who visit any DOE facility. U.S. EPA staff, such
as field inspectors or health physics staff, and USEPA
contractors who enter on-site Controlled Areas or Radiological
Areas or who engage in field surveillance at off-site affected
areas will be classified as occupationally exposed while other
U.S. EPA staff who visit Uncontrolled Areas will be classified
depending on their activities on site. Visitors to controlled
areas will not be reclassified as occupationally exposed.
Visitors will not be allowed to enter Radiological Areas. The
determination will be made by the Regional Health and Safety
Manager. The provisions of all Radiological Health and Safety
Plans will be implemented to maintain exposures to all staff
As Low As Reasonably Achievable (ALARA) (in general
conformance with U.S. Nuclear Regulatory Commission (NRC)
Regulatory Guide 8.8 and DOE publication PNL-6577).
19.1.5 Training
All U.S. EPA staff, USEPA contractors and visitors must
receive basic radiation training, provided by or approved by
U.S. EPA Regional Radiation staff, before being allowed access
to any DOE facility. In addition, all site field workers
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shall be required to attend site specific training provided by
the desired DOE facility. Any U.S. EPA staff member who may
have to visit a DOE facility must contact the Regional Health
and Safety Manager.
V.
All other requirements needed before entering a DOE'
facility (e.g. personnel monitoring, protective clothing,
bioassay) will be covered in the site specific health and
safety plans.
19.2 LABORATORIES
(
Radiation plans specific to U.S. EPA laboratories are '• •
detailed in the following paragraphs. :o
i'3q
19.2.1 Central Regional Laboratory -.a
,' .. -4
Central Regional Laboratory (CRL), Region 5 is a service «
laboratory operated by the U.S. EPA. CRL provides analytical
services in support of enforcement of the Clean Water Act,-
Safe Drinking Water Act, Clean Air Act, Resource Conservation
and Recovery Act, CERCLA, the Toxic Substances Control Act,
NPDES, and the Great Lakes Water Quality Agreement between U.S l
and Canada. In order to perform analyses, the laboratory T
maintains toxic chemicals and sophisticated electronic f.q
equipment on-site. Some of these chemicals used and/or stored"17
at CRL include minute quantities of radioisotopes, primarily £
Carbon-14. Also sealed radiation source devices are present:-
for use with Gas Chromatographs and on rare occasions where i-*
samples containing low levels of radioisotopes are analyzed by:K
CRL.. ,: . J
CRL works in conjunction with the Great Lakes National!-
Program Office (GLNPO) to support the Great Lakes Water
Quality Agreement. GLNPO operates the R.V. Roger R. Simons;'-^
a research vessel, on the Great Lakes for research and i
development purposes. The vessel carries small quantities oft0.
Carbon-14 and sealed radiation sources for analytical A
purposes. . , ;:
,* *.*""
19.2.2 Radiation Safety
<~ . ' ^ !
Activities involving radioisotopes at either the CRL or
GLNPO are governed under their current NRC license. CRL'has
established, as part of its overall safety program, a-1-
radiation safety manual, to provide guidelines for safety and ;<
well-being of personnel involved in radiation work. All
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persons performing laboratory procedures involving
radioisotopes must adhere to these guidelines in order to
prevent unnecessary radiation exposure and/or contamination.
19.3 WASTE SITES
All waste sites whose radiation potential has been
characterized have their own site specific health and safety
plans which must be followed at all times while on the
premises. U.S. EPA contractors working at waste sites that
have a potential for radiation exposure and have not been
characterized must follow the Safety Plan for Initial Site
Investigations developed by the Radiation Program Staff. These
contractors will be developing health and safety plans which
will be reviewed by the Radiation Program Staff.
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Chapter 20 - OFFICE AND TRAFFIC SAFETY
20.1 OFFICE SAFETY
fi>
It is the policy of EPA Region 5 to provide employees j,
with a safe and healthful working environment. Total support
is expected of each employee in complying with applicable
OSHA, EPA, and related health and safety standards and
requirements. , Employees are responsible for detecting and .,\
promptly reporting work hazards, risks or unhealthful -and.q
unsafe working conditions. EPA management is responsible for rf
promptly correcting these reported conditions. Further j,, :
employees are responsible for maintaining an uncluttered and^i
safe office work space. Such areas must meet applicable: 3
health and safety standards. r Li*
The following is a list of common office hazards which
can lead to injury and should be reported to the immediate
supervisor in the area:
1. Litter or spilled liquid on the floor;
2. Tripping hazards such as floor holes, electrical
cords and the like;
3. Overloaded and frayed extension cords;
4. Table and floor fans with broken guards;
5. Open electrical outlet boxes and other exposed
electrical equipment;
6. Excessive amounts of paper or boxes in a work area;
7. Poor lighting;
8. More than one file drawer open at on time;
9. Unguarded hand paper cutters; and
10. Improperly stored flammable and combustible
materials and liquids.
20.2 FIRE EVACUATION PLANS
All employees will participate in building fire safety
training exercises or drills. All employees are expected to
be familiar with the operational procedures identified in the
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Occupant Emergency Plan for their building. Furthermore, they
are expected to cooperate fully with the instructions provided
by the fire wardens, quickly exiting the area or building as
instructed at the initial sounding of the fire alarm.
In case of fire or other emergency, every employee is
responsible for knowing:
. . <'.
1. Two escape exits other than the elevator (which
of course will not be used);
2. How to sound the alarm;
" -3. The difference between the sound of the fire alarm
and other signals in the building;
4. Safe areas in your building; and
5. Who is the designated floor warden for your area.
, Further, it should be noted that the Occupant Emergency
Plan is updated yearly by the Regional Health and Safety
Manager, for each building occupied by Regional personnel as
required by GSA regulations. This includes yearly revisions
of agency Fire Evacuation Personnel rosters (which include
flooifwardens, handicap assistants, etc.) and related matters.
20.3 DEFENSIVE DRIVING
Driving a car, van or truck need not be a dangerous or
frustrating experience. It will be, however, if you don't
keep your wits about you. If you have to drive a GSA-owned,
EPA-owned, rental or privately owned vehicle in the
performance of your duties, keep in mind the points listed
below.
20.3.1 Seat Belts
Drivers and passengers are required to use seat belts
while a vehicle is moving. Many States now have mandatory
seat belt laws. EPA definitely has one. A seat belt or other
restraining device must be adjusted properly if it is to
provide the protection for which it was designed.
20.3.2 Accidents
If you have a vehicle accident while on official duty,
you must report it to your supervisor and the appropriate
fleet management or rental office. Your first responsibility
in the event of an accident is to care for the injured.
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20.3.3 Operating Conditions .r, •:
- , • r *.' ."'
Do not depend on anyone other than yourself to, makerr
certain that the vehicle you are about to drive is in good
operating order -and safe for driving. Check tires, brakes,
wipers, fluid levels, and lights. Move the vehicle a few-,feet-•-...
and check the? pavement for leaks. Your life could depend on
it. .. .
-•--..jr-rj f.o
20.3.4 Laws
•- >,,
All states have traffic laws, and you must obey these
laws while you are driving on official duty. If you do not
have a license to drive issued by your State of residence or:,: •:>
State of employment (including the District of Columbia), you
are not permitted to drive a GSA motor vehicle. Penalties for
violations of traffic or parking laws are the responsibility
of the, offender.
... Finally, never drive under the influence of alcohol or
drugs, including some prescription drugs. The Federal Af
Government may refuse to accept responsibility where grossisM
negligence is established. . _L DO :
Driving.a motor vehicle is a privilege granted by the?I r
State - and by the EPA if you are on official duty. This
privilege can be revoked at any time if you do not follow the
rules of safe driving. T~:; ;.c;
.-.:/: 73 J^ uf
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.= V
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ACRONYMS
AA
AEC
ALARA
ANSI
AO
CFR
CERCLA
CO
DD
DFEOH
DOE
DOL
DOT
EC
EDO
EPA
FIT
FY
GLNPO
HASH
HRS
IA6
IDLE
LEL
Assistant Administrator
Atomic Energy Commission
As Low As Reasonably Achievable
American National Standards Institute
Administrative Officer
Code of Federal Regulations
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980
Contracting Officer
Division Director
Division of Federal Employee Occupational
Health
Department of Energy
Department of Labor
Department of Transportation
Environmental Compliance
Eastern District Office
Environmental Protection Agency
Field Investigation Team
Fiscal Year
Great Lakes National Program Office
Health And Safety Manager
Hazard Ranking System
Interagency Agreement
Immediate Danger to Life and Health
Lower Explosive Limit
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O
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LFL
MARSEA-14
M8D8
MSHA
NESHAP
NFPA
NIO8H
NOAEL
NPDES
NRC
OEP
OERR
O8HA
PCB
PEL
PH8
PPE
PR
RA
RCRA
RH8N
RV
SCBA
SOP
T8D
Lower Flammable Limit
(Now called "The Lake Guardian")
Material Safety Data Sheets
Mine Safety and Health Association (DOL)
National Emissions Standards for Hazardous Air
Pollutants (CAA)
National Fire Prevention Association
National Institute of Occupational Safety and
Health
No Observed Adverse Effect Level
National Pollutant Discharge Elimination
System
National Regulatory Commission
Occupant Emergency Plan
Office of Emergency and Remedial Response
Occupational Health and Safety Administration
Polychlorinated Biphenyls
Permissible Exposure Limit
Public Health Service
Personal Protective Equipment
Procurement Request
Regional Administrator
Resource Conservation and Recovery Act of 1976
Regional Health and Safety Manager
Research Vessel
Self-contained Breathing Apparatus
Standard Operating Procedures
Technical Support Document
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Region 5 Health and Safety Manual R5 1440 (9/29/91)
US United States
U8T Underground Storage Tank
VOC Volatile Organic Compound
VSI »« Visual Site Inspection
YTD Year To Date
ZRL Zero Risk Level
*** For further reference, see EPA Document 19K-1002,
"Glossary Of Environmental Terms And Acronym List"
(December 1989).
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