United States
           Environmental Protection
           Agency
            Office of Emergency and
            Remedial Response
            Emergency Response Division
Environmental
Response
Team
xvEPA
Safety and Health
Decision-Making
for Managers
           Environmental Response
           Training Program

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      SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS
                                        (165.8)

                                        3 DAYS
This course is for experienced personnel responsible for developing, implementing or managing
safety programs for hazardous waste clean-up operations, treatment, storage and disposal facilities,
or responding to chemical emergencies. This advanced course compliments EPA basic safety courses
and provides  a forum for information and idea exchanges among instructors and participants on
hazardous waste operations and emergency response safety topics. Greater than fifty percent of class
time involves problem solving and class discussion.
The objectives of this course are:

       •     To discuss the impact of 29 CFR 1910.120 and other related OSHA, EPA,
             NIOSH,  NFPA, and ANSI standards on personnel at hazardous waste
             operations and emergency response.

       •     To detail the elements and development of a  site-specific safety plan which
             includes  personnel  training,  medical  monitoring,  personal  protective
             equipment selection, air surveillance strategies, and emergency/contingency
             planning.
Upon completion of this course, participants will be able to organize essential information into a site-
specific safety plan  and  better understand the  decision-making associated with hazardous waste
operations and emergency response safety programs.
                      U.S. ENVIRONMENTAL PROTECTION AGENCY
                         Office of Emergency and Remedial Response
                              Environmental Response Team

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                         FOREWORD
This manual is for reference use of students enrolled in scheduled
training courses of the U.S. Environmental Protection Agency. While
it will be useful to anyone  who needs  information on the subjects
covered, it will have it's  greatest value as an adjunct to classroom
presentations involving give  and take discussions among the students
and the instructional staff.

This manual has been developed with a goal of providing the best
available current  information.  Individual  instructors  may provide
additional material to cover  special aspects of their presentations.

Due to the limited availability of the manual, it should not be cited in
bibliographies or other publications.

References to products and  manufacturers are for illustration only:
they do not imply endorsement by the U.S. Environmental Protection
Agency.

Constructive suggestions for  the improvement in the coverage, content
and format of the manual  are welcome.

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     SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS

                          TABLE OF CONTENTS
SECTION                           UNIT                           PAGE NO.
  1   OCCUPATIONAL HEALTH AND SAFETY STANDARDS

      Part 1:       OSHA 29 CFR 1910.120 - Hazardous Waste Operations
                  and Emergency Response Standard  	1

      Part 2:       EPA Order 1440.2 -  Health and Safety Requirements for
                  Employees Engaged in Field Activities	37

      Part 3:       Other OSHA, Federal, and NFPA Regulations and
                  Standards Related to  Hazardous Waste Operations and
                  Emergency Response Worker Protection	47

      Part 4:       NIOSH Criteria for Recommended Standard for Working
                  in Confined Spaces	61

      Part 5:       OSHA 29 CFR 1910.1200 -  Hazard  Communication
                  Standard	  139
  2   OCCUPATIONAL HEALTH AND SAFETY GUIDANCE DOCUMENTS

      Part 1:       USEPA Office of Solid Waste and Emergency Response
                  (OSWER) Integrated Health and Safety Policy for Field
                  Activities 	1

      Part 2:       USEPA Environmental Response Team (ERT) Occupational
                  Medical Monitoring Program Guidelines for SARA Hazardous
                  Waste Field Activity Personnel	33
  3   QUICK REFERENCE FACT SHEETS

      Part 1:       Health and Safety Roles and Responsibilities at Remedial
                  Sites	  1
12/92

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     SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS

                           TABLE OF CONTENTS
SECTION                           UNIT                            PAGE NO.
      Part 2:       Establishing Work Zones at Uncontrolled Hazardous
                  Waste Sites	9

      Part 3:       Hazardous Waste Operations and Emergency Response:
                  RCRA TSD and Emergency Response Without Regard to
                  Location	23

      Part 4:       Hazardous Waste Operations and Emergency Response:
                  Uncontrolled Hazardous Waste Sites and RCRA
                  Corrective Actions  	37

      Part 5:       Hazardous Waste Operations and Emergency Response:
                  General Information and Comparison	55

      Part 6:       Hazardous Waste Operations and Emergency Response:
                  Available Guidance	67
  4   AIR SURVEILLANCE

      Part 1:       Characteristics and Types of Air Surveillance Equipment	1

      Part 2:       Manufacturers and Suppliers of Air Monitoring and
                  Sampling Equipment	37


  5   PERSONAL PROTECTIVE EQUIPMENT

      Part 1:       Introduction to Respiratory Protection  	1

                  Appendix I:   NIOSH Certified Equipment List-Example  	  13
 12/92

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     SAFETY AND HEALTH DECISION-MAKING FOR MANAGERS

                            TABLE OF CONTENTS
SECTION                             UNIT                             PAGE NO.


      Part 2:       Air Purifying Respirators  	 15

                   Appendix I:   References for Respirator Cartridges
                                Efficiency Studies   	27
                   Appendix II:   Respirator Fit Testing	29
                   Appendix III:  Respirator Negative and Positive Pressure Test  	33
                   Appendix IV:  Care and Cleaning of Respirators	 35
                   Appendix V:   Warning Concentrations of Various Chemicals	39

      Part 3:       Self-Contained Breathing Apparatus	69

      Part 4:       NIOSH Respirator Decision Logic	81

      Part 5:       USEPA Respiratory Protection Program Guidelines	-145

      Part 6:       Chemical Protective Clothing	  201

                   Appendix I:   Permeation References   	  225
                   Appendix II:   Donning and Doffing of Fully Encapsulating
                                Suits (FES) and Self-Contained Breathing
                                Apparatus (SCBA)	  227

      Part 7:       Personal Protective Equipment Regulations - 29 CFR
                   1910.132-136  	  233

      Part 8:       Manufacturers and Suppliers of Personal Protective
                   Equipment  	  241


  6   REFERENCES AND GLOSSARY

      Part 1:       References and Resources	1

      Part 2:       Glossary and Acronyms  	 15
12/92

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           SECTION 1
OCCUPATIONAL SAFETY AND HEALTH
   REGULATIONS AND STANDARDS

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                 OCCUPATIONAL SAFETY AND HEALTH
                     REGULATIONS AND STANDARDS
SECTION OBJECTIVE

The objective of this section is to provide students with a copy of the following occupational health
and safety standards and guidance documents:

      •     U.S. Department of Labor/Occupational Safety and Health Administration Hazardous
            Waste Operations and Emergency Response Worker Protection Standard 29 CFR
            1910.120(1989)

      •     U.S.  Environmental  Protection  Agency  Health  and Safety  Requirements for
            Employees Engaged in Field Activities Order 1440.2 (1981)

      •     Other OSHA, Federal, and  NFPA Regulations and Standards Related to Hazardous
            Waste Operations and Emergency Response Worker Protection

      •     NIOSH Criteria for Recommended Standard for Working in Confined Spaces (1979)

      •     U.S. Department of Labor/Occupational Safety and Health Administration Hazard
            Communication Standard 29 CFR 1910.1200 (1985)
STUDENT PERFORMANCE OBJECTIVES

After completing this section and related lesson(s), the student will be able to:

      •      Discuss each paragraph and appendixes of OSHA's 29 CFR 1910.120.

      •      Identify other OSHA, Federal, and NFPA regulations and standards related to
             occupational health and safety at hazardous waste operations and emergency response.

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           SECTION 1

OCCUPATIONAL SAFETY AND HEALTH
   REGULATIONS AND STANDARDS

            PART 1

         29 CFR 1910.120

HAZARDOUS WASTE OPERATIONS AND
      EMERGENCY RESPONSE

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                                                         OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
              1910.120-HAZARDOUS WASTE  OPERATIONS
                        AND  EMERGENCY  RESPONSE
(a) Scope, application, and definitions.

  (1) Scope. This section covers the following oper-
  ations, unless the employer can demonstrate
  that the operation does not involve employee
  exposure or the reasonable  possibility for
  employee exposure to safety or health hazards:

   (i) Clean-up operations required by a govern-
   mental body, whether Federal, state, local or
   other involving hazardous substances that are
   conducted at uncontrolled hazardous waste
   sites (including, but not limited to, the EPA's
   National Priority  Site List (NPL), state pri-
   ority site lists, sites recommended for the
   EPA NPL, and initial investigations of gov-
   ernment identified sites which are conducted
   before the presence or absence of hazardous
   substances has been ascertained);

   (ii) Corrective  actions involving cleanup oper-
   ations at sites covered by the Resource Con-
   servation and Recovery Act of 1976 (RCRA)
   as amended .(42 U.S.C. 6901 et seq.);

   (iii) Voluntary clean-up operations at sites rec-
   ognized by Federal, state, local or other gov-
   ernmental bodies as uncontrolled hazardous
   waste sites;

   (iv)  Operations involving hazardous wastes
   that are conducted at treatment, storage, and
   disposal (TSD) facilities regulated  by 40 CFR
   Parts 264 and  265 pursuant to RCRA; or by
   agencies under agreement with U.S.E.P.A. to
   implement RCRA regulations; and

   (v)  Emergency  response  operations for
   releases of, or substantial threats of releases
   of, hazardous  substances without regard to
   the location of the hazard.

  (2)  Application.

   (i) All requirements of Part  1910 and Part
   1926 of Title 29 of the Code of Federal Reg-
   ulations apply pursuant to their terms to haz-
   ardous waste and emergency  response
   operations whether covered by this section or
      not. If there is a conflict or overlap, the provi-
      sion more protective of employee safety and
      health shall apply without regard to 29 CFR
      (ii) Hazardous substance clean-up operations
      within the scope  of  paragraphs (a)(l)(i)
      through (a)(l)(iii) of this section must comply
      with all paragraphs of this section except
      paragraphs (p) and (q).

      (iii) Operations within the scope of paragraph
      (a)(l)(iv) of this section must comply only with
      the requirements of paragraph (p) of this sec-
      tion.

        Exceptions: For large quantity generators
      of hazardous waste who store those wastes
      less than 90 days and for small quantity gen-
      erators  of hazardous wastes,  who  have
      emergency response teams that respond to
      releases of, or substantial threats of releases
      of, hazardous substances,  for their RCRA
      workplaces only paragraph  (p)(8) of this sec-
      tion is applicable. Such generators of haz-
      ardous wastes who do not  have emergency
      response teams that respond to releases of, or
      substantial threats of releases of,  hazardous
      substances are exempt from the requirements
      of this section.

      (iv) Emergency response operations for
      releases of, or substantial threats of releases
      of, hazardous substances which are not cov-
      ered by paragraphs (a)(l)(i) through (a)(l)(iv)
      of this section must only comply with the
      requirements of  paragraph (q) of this section.

    (3) Definitions."Buddy system" means a system
    of organizing employees into work  groups in
    such a manner that each employee of the work
    group is designated to be observed by at  least
    one  other employee in the work group. The pur-
    pose of the buddy system is  to provide rapid
    assistance to employees in  the event  of an
    emergency.

      "Clean-up operation" means an  operation
    where hazardous substances are removed, con-
 l'J10.I20(a)Cl)
330

  3
                                                                                  Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                     1910.120(a)<3)
                                                            STANDARDS AND INTERPRETATIONS
  tained, incinerated, neutralized, stabilized,
  cleared-up, or in any other manner processed or
  handled with the ultimate goal of making the
  site safer for people or the environment.

   "Decontamination" means the removal of haz-
  ardous substances from employees and  their
  equipment to the extent necessary to preclude
  the occurrence of foreseeable adverse health
  affects.

   "Emergency response" or "responding to
  emergencies"  means  a  response effort  by
  employees from outside the immediate release
  area or by other designated responders (i.e.,
  mutual-aid groups, local fire departments, etc.)
  to  an occurrence which results or is likely to
  result, in an uncontrolled release of a hazardous
  substance. Responses to incidental releases of
  hazardous substances where the substance can
  be absorbed, neutralized, or otherwise con-
  trolled at the time of release by employees in
  the immediate release area, or by maintenance
  personnel  are not considered to be emergency
  responses within the scope  of this standard.
  Responses to releases of hazardous substances
  where there is no potential safety or health haz-
  ard (i.e., fire, explosion, or chemical exposure)
  are not considered to be emergency responses.

  "Facility" means (A) any building, structure,
  installation, equipment,  pipe or pipeline (includ-
  ing any pipe into a sewer or publicly owned
  treatment works),  well, pit, pond,  lagoon,
  impoundment, ditch, storage container,  motor
  vehicle, rolling stock, or aircraft, or (B) any site
  or area where a hazardous substance has been
  deposited, stored, disposed of, or placed, or oth-
  erwise come to be located; but does not include
  any consumer product in consumer use or any
  water-borne vessel.

  (3) "Hazardous materials response (HAZMAT)
  team" means an organized group of employees,
  designated by the employer, who are expected
  to perform work to handle and control actual or
  potential leaks or spills  of hazardous substances
  requiring possible close approach to the sub-
  stance. The team members perform responses to
  releases or potential releases of hazardous sub-
  stances for the purpose of control or stabilization
  of the  incident. A HAZMAT team is not a fire
  brigade nor is a typical  fire brigade a HAZMAT
  team.  A HAZMAT team, however, may be a
  separate  component of a fire brigade or fire
  department.
        "Hazardous substance" means any substance
      designated or listed under paragraphs (A)
      through (D) of this definition, exposure to which
      results or may result in adverse affects on the
      health or safety of employees:

      (a) Any substance defined under section 101(14)
    of CERCLA;

      (b) Any biological agent and other disease-
    causing agent as defined in section 101(33) of
    CERCLA;

      (c) Any substance listed by the U.S. Depart-
    ment of Transportation as hazardous materials
    under 49 CFR 172.101 and appendices; and

      (d) Hazardous waste as herein defined.

      "Hazardous waste" means

      (a) A waste or combination of wastes as defined
    in 40 CFR 261.3, or

      (b) Those  substances  defined as hazardous
    wastes in 49 CFR 171.8.

      "Hazardous waste operation" means any opera-
    tion conducted within the scope of this standard.

      "Hazardous waste site" or "Site" means any
    facility or location within the scope  of this stand-
    ard at which hazardous waste operations take
    place.

      "Health hazard" means a chemical, mixture of
    chemicals or a pathogen for which there is statis-
    tically  significant evidence based on at least one
    study conducted in accordance with established
    scientific principles that acute or chronic health
    effects may occur in exposed employees, the term
    "health hazard" includes chemicals which are car-
    cinogens,  toxic or highly toxic agents, reproduc-
    tive toxins, irritants, corrosives, sensitizers,
    heptaotoxins, nephrotoxins,  neurotoxins, agents
    which act on the hematopoietic system, and agents
    which  damage the lungs, skin, eyes, or mucous
    membranes. It also  includes stress due to tem-
    perature extremes. Further definition of the terms
    used above can be found in Appendix A to 29 CFR
    1910.1200.

      "IDLH" or "Immediately  dangerous to  life or
    health" means an atmospheric concentration of any
    toxic, corrosive or asphyxiant substance that poses
    an  immediate threat to life or would cause irrever-
 Change 51
330.1

 4
1910.120
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1910.120(n)<3>
                                                           OCCUPATIONAL SAFETY AXD HEALTH
STANDARDS AND INTERPRETATIONS
sible or delayed  adverse health effects or would
interfere with an  individual's ability to escape from
a dangerous atmosphere.

  "Oxygen deficiency" means that concentration of
oxygen by volume below which atmosphere sup-
plying respiratory protection must be provided. It
exists in atmospheres  where the percentage of
oxygen by volume is less than 19.5 percent oxy-
gen.

  "Permissible  exposure  limit"  means  the
exposure,  inhalation  or  dermal  permissible
exposure limit specified  in 29 CFR Part 1910, Sub-
parts G and Z.

  "Published  exposure level" means the exposure
limits published in "NIOSH Recommendations for
Occupational Health Standards" dated 1986 incor-
porated by reference, or if none is specified, the
exposure limits published  in the standards spec-
ified by the American Conference of Governmental
Industrial Hygienists in their publication "Thresh-
old  Limit Values and Biological  Exposure Indices
for  1987-88" dated 1987  incorporated by reference.

  "Post emergency response" means that portion
of an emergency response performed after the
immediate threat of a release has been stabilized
or eliminated  and clean-up of the site has begun. If
post emergency response is performed by an
employer's own employees who were part of the
initial emergency response, it is considered to be
part of the initial  response and not post emergency
2'esponse.  However, if a group of an employer's
own employees, separate from the group providing
initial response, performs the clean-up operation,
then the separate group of employees would be
considered to be  performing  post-emergency
response and subject to paragraph (g)(ll) of this
section.

  "Qualified person" means a person with specific
training, knowledge and experience in the area for
which the person has the  responsibility and the
authority to control.

  "Site safety and health supervisor (or official)"
means the individual located on a hazardous waste
site who is responsible to the  employer and has the
authority and knowledge necessary to implement
the site safety and health plan and verify  com-
pliance with applicable  safety and health require-
ments.
  "Small quantity generator" means a generator of
hazardous wastes who in any calendar month gen-
erates  no more than  1,000  kilograms (2,205
pounds) of hazardous waste in that month.

  "Uncontrolled hazardous waste site" means an
area where an accumulation of hazardous waste
creates a threat to the health and safety of individ-
uals or  the environment or both. Some sites are
found on public lands, such as those created by for-
mer municipal, county or state  landfills where ille-
gal or poorly managed waste  disposal has  taken
place. Other sites are found on private property,
often belonging to generators or former  genera-
tors of hazardous waste. Examples of such sites
include, but are not limited to, surface impound-
ments, landfills, dumps, and tank or drum farms.
Normal operations at TSD  sites are not covered by
this definition.

(b) Safety and  health program.

  Note  to (b):  Safety and  health  programs
developed and implemented to meet other Fed-
eral, state, or local  regulations are considered
acceptable in meeting this requirement if they
cover or are modified to cover  the topics required
in this paragraph. An additional or separate safety
and health program is not required by this  para-
graph.

  (1) General.

    (i) Employers shall develop and implement a
    written safety and health program for their
    employees involved in  hazardous waste opera-
    tions. The program shall be designed  to iden-
    tify, evaluate, and control safety and health
    hazards, and provide for emergency response
    for  hazardous waste operations.

    (ii)  The written safety and health program
    shall incorporate the following:

      (a) An organizational structure:

      (b) A comprehensive workplan:

      (c) A site-specific safety and health plan
      which need not repeat the employer's stand-
      ard operating procedures required  in para-
      graph (b)(l)(ii)(F) of this section;

      (d) The  safety and health training program:
                                            330.2

                                               5
                                     Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                                             STANDARDS AND INTERPRETATION'S
      (e) The medical surveillance program;

      (f) The employer's standard operating pro-
      cedures for safety and health; and

      (g) Any necessary interface between gen-
      eral program and site specific activities.

    (iii) Site excavation. Site excavations created
    during initial site preparation or during haz-
    ardous waste operations shall be shored or
    sloped as appropriate to prevent accidental
    collapse in accordance with Subpart P of 29
    CFR Part 1926.

    (iv)  Contractors  and  sub-contractors.  An
    employer who retains contractor or sub-
    contractor services for work in hazardous
    waste operations shall inform those contrac-
    tors, sub-contractors, or their representatives
    of the site emergency  response procedures
    and any potential  fire,  explosion, health,
    safety or other hazards of the hazardous
    waste operation that have been identified by
    the employer, including those identified in the
    employer's information program.

    (v) Program  availability.  The written  safety
    and health program shall be made available to
    any contractor or subcontractor or their rep-
    resentative who will be  involved with the haz-
    ardous waste operation; to employees; to
    employee designated  representatives; to
    OSHA personnel, and  to personnel of other
    Federal, state, or local agencies with regula-
    tory authority over the  site.

  (2)  Organizational  structure part of the site pro-
  gram.

    (i) The organizational  structure part of the
    program shall establish the specific chain of
    command and specify the overall respon-
    sibilities of supervisors and employees.  It
    shall include, at a minimum, the following ele-
    ments:

       (a)  A general  supervisor who has the
       responsibility and authority  to direct all
       hazardous waste operations.

       (b) A site safety and health supervisor who
       has  the  responsibility and  authority  to
       develop and implement the site safety and
       health plan and verify compliance
          (c)  All other personnel  needed for haz-
          ardous waste site operations and emergency
          response and their general functions and
          responsibilities.

          (d) The lines of authority, responsibility,
          and communication.

        (ii) The organizational structure shall be
        reviewed and updated as necessary to reflect
        the current status of waste site operations.

      (3) Comprehensive workplan  part of the site pro-
      gram. The comprehensive workplan part of the
      program shall address the tasks and objectives
      of the site operations and the logistics and
      resources required to reach  those tasks and
      objectives.

        (i) The comprehensive workplan shall address
        anticipated clean-up activities as well as nor-
        mal operating procedures which need not
        repeat the employer's procedures available
        elsewhere.

        (ii) The comprehensive workplan shall define
        work tasks and objectives  and identify the
        methods for accomplishing those tasks and
        objectives.

        (iii) The comprehensive workplan shall estab-
        lish personnel requirements  for implementing
        the plan.

        (iv) The  comprehensive  workplan  shall
        provide for the implementation of the training
        required in paragraph (e) of this section.

        (v) The comprehensive workplan shall  provide
        for the implementation of the required infor-
        mational programs required in paragraph (i)
        of this section.
        (vi)
(vi)  me  comprehensive  workplan  snail
provide for the implementation of the medical
surveillance program described in paragraph
(f) of this section.
      (4) Site-specific safety and health plan part of the
      program.

        (i) General. The site safety and health plan,
        which must be kept on site, shall address the
        safety and health hazards of each phase of site
        operation and include the requirements and
        procedures for employee protection
 Change 51
330.3

 6
                                                                                  1910.120(b)(4)(i)

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1910.120(b)(4Kii)
                                                             OCCUPATIONAL SAFETY A.VD HEALTH
STANDARDS AND INTERPRETATIONS
    (ii) Elements. The site safety and health plan,
    as a minimum, shall address the following:

      (a) A safety and health risk or hazard anal-
      ysis for each site task and operation found
      in the workplan.

      (b)  Employee  training assignments  to
      assure compliance with paragraph (e) of this
      section.

      (c) Personal  protective  equipment to be
      used by employees for each of the site tasks
      and operations being conducted as required
      by the personal protective equipment pro-
      gram in paragraph (g)(5) of this section.

      (d) Medical surveillance requirements in
      accordance with the program in paragraph
      (f) of this section.

      (e) Frequency and types of air monitoring,
      personnel monitoring,  and environmental
      sampling  techniques and instrumentation to
      be used,  including methods of maintenance
      and calibration of monitoring  and  sampling
      equipment to be used.

      (f) Site control measures in accordance with
      the site control program  required in para-
      graph (d) of this section.

      (g) Decontamination procedures in accord-
      ance with paragraph (k) of this section.

      (h) An emergency response  plan meeting
      the  requirements of paragraph (1) of this
      section for safe  and effective responses to
      emergencies,  including the necessary PPE
      and other equipment.

      (i) Confined space entry procedures.

      (j) A spill containment program meeting the
      requirements of paragraph (j) of  this sec-
      tion.

    (iii)  Pre-entry briefing. The site specific safety
    and health  plan shall provide for pre-entry
    briefings to be held prior to  initiating any site
    activity, and at such  other times as necessary
    to ensure that employees are apprised of  the
    site safety and health plan and that  this plan
    is being followed.  The information  and data
    obtained from site characterization and anal-
    ysis work required in paragraph (c) of this
    section shall be used to prepare and update
    the site safety and health plan.

    (iv) Effectiveness of site safety and health plan.
    Inspections shall  be conducted by the site
    safety and health  supervisor or, in  the
    absence of that individual, another individual
    who  is knowledgeable in occupational safety
    and health, acting on behalf of the employer
    as necessary to determine the effectiveness of
    the site safety and health plan. Any deficien-
    cies in the effectiveness of the site safety and
    health  plan  shall  be  corrected  by  the
    employer.

(c) Site characterization and analysis.

  (1) General. Hazardous  waste sites shall be eval-
  uated in accordance with this paragraph to iden-
  tify specific site hazards and to determine the
  appropriate safety and health control procedures
  needed to protect employees from the identified
  hazards.

  (2) Preliminary evaluation. A preliminary evalua-
  tion of a site's characteristics shall be performed
  prior to site entry by a qualified person in order
  to aid in the selection  of appropriate employee
  protection methods prior  to site entry. Imme-
  diately after initial site entry, a more detailed
  evaluation of the site's specific  characteristics
  shall be performed by a qualified  person in order
  to further identify existing site  hazards and to
  further aid in the selection of the appropriate
  engineering  controls and personal protective
  equipment for the tasks to be performed.

  (3) Hazard identification. All suspected conditions
  that may pose inhalation or skin  absorption haz-
  ards that are immediately dangei'ous to life or
  health  (IDLH), or other conditions that may
  cause death or serious  harm, shall be identified
  during the preliminary survey and evaluated
  during the detailed  survey. Examples of such
  hazards include, but are not limited to, confined
  space entry,  potentially explosive or flammable
  situations, visible vapor clouds,  or areas where
  biological indicators such as dead animals or veg-
  etation are located.

  (4) Required information. The following informa-
  tion to  the  extent available shall be obtained by
  the employer prior to allowing employees to
  enter a site:

    (i) Location and approximate size of the site.
191Q.120(cX4MO
                                            330.4

                                                 7
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OCCUPATIONAL SAFETY AND HEALTH
                                                             STANDARDS AND INTERPRETATIONS
  (ii) Description of the response activity and/or
  the job task to be performed.

  (iii)  Duration  of the  planned  employee
  activity.

  (iv) Site topography  and accessibility by air
  and roads.

  (v) Safety and health  hazards expected at the
  site.

  (vi) Pathways for hazardous substance disper-
  sion.

  (vii)  Present status  and  capabilities  of
  emergency response teams  that would provide
  assistance to hazardous waste clean-up site
  employees at the time of an emergency.

  (viii) Hazardous substances and health haz-
  ards involved or expected at the site, and
  their chemical and physical properties.

(5) Personal protective equipment. Personal pro-
tective equipment (PPE) shall be provided and
used during initial site entry  in accordance with
the following requirements:

  (i) Based upon the results  of the preliminary
  site evaluation, an ensemble of PPE shall be
  selected and  used during initial site entry
  which will provide protection to a level of
  exposure below permissible exposure limits
  and published exposure levels for known or
  suspected hazardous substances and health
  hazards, and which  will provide protection
  against other known and suspected hazards
  identified during the  preliminary site evalua-
  tion.  If there is no permissible exposure limit
  or  published  exposure level,  the employer
  may use other published studies and informa-
  tion as a guide to appropriate personal protec-
  tive equipment.

  (ii)   If  positive-pressure self-contained
  breathing apparatus is not  used as part of the
  entry ensemble, and  if respiratory protection
  is warranted by the potential hazards identi-
  fied during the preliminary site evaluation, an
  escape self-contained breathing apparatus of
  at least five minute's  duration shall be carried
  by employees during  initial site entry.

  (iii) If the preliminary site evaluation does not
  produce sufficient information to identify the
                                                    hazards or suspected hazards of the site,  an
                                                    ensemble providing protection equivalent to
                                                    Level B  PPE shall be provided as minimum
                                                    protection, and direct reading instruments
                                                    shall be used as appropriate for identifying
                                                    IDLH conditions. (See Appendix  B for a
                                                    description of Level B hazards and the recom-
                                                    mendations for Level B protective equip-
                                                    ment.)

                                                    (iv)  Once the hazards of the site have been
                                                    identified, the appropriate  PPE shall  be
                                                    selected and used in accordance with para-
                                                    graph (g) of this section.

                                                   (6) Monitoring. The following monitoring shall be
                                                   conducted during initial site entry when the site
                                                   evaluation produces information  that shows the
                                                   potential for ionizing radiation or IDLH condi-
                                                   tions,  or when the site information is not suffi-
                                                   cient  reasonably to eliminate  these possible
                                                   conditions:

                                                     (i) Monitoring with direct reading instruments
                                                     for hazardous levels of ionizing radiation.

                                                     (ii) Monitoring the air with appropriate direct
                                                     reading test equipment (i.e., combustible gas
                                                     meters, detector tubes)  for IDLH and other
                                                     conditions that may cause death or serious
                                                     harm (combustible or explosive atmospheres.
                                                     oxygen deficiency, toxic substances).

                                                     (iii) Visually observing for signs of actual or
                                                     potential  IDLH or other dangerous condi-
                                                     tions.

                                                     (iv) An ongoing air monitoring  program in
                                                     accordance with paragraph (h) of this section
                                                     shall be implemented after site characteriza-
                                                     tion has determined the site is safe for  the
                                                     startup of operations.

                                                   (7) Risk identification. Once the presence and
                                                   concentrations of specific hazardous substances
                                                   and health hazards have been established,  the
                                                   risks  associated with these substances shall be
                                                   identified. Employees who will be working on
                                                   the site shall be informed of any risks that have
                                                   been  identified. In situations  covered by  the
                                                   Hazard Communication  Standard.  29  CFR
                                                   1910.1200,  training required by that  standard
                                                   need not be  duplicated.

                                                   Note  to (c)(7).—Risks to consider include,  but
                                                   are not limited to:
Change 51
                                           330.5


                                            8

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1910.120(c)<7)(a)
                                                            OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
   (a) Exposures  exceeding the  permissible
   exposure limits and published  exposure levels.

   (b) IDLH concentrations.

   (c) Potential skin absorption and irritation
   sources.

   (d) Potential eye irritation sources.

   (e) Explosion sensitivity and flammability
   ranges.

   (f) Oxygen deficiency.

 (8) Employee notification. Any information con-
 cerning the chemical, physical, and toxicologic
 properties of each substance known or expected
 to be present on site  that is available to the
 employer and relevant to the duties an employee
 is expected to perform shall be made available to
 the affected employees prior to the commence-
 ment of their work activities. The employer may
 utilize information  developed for the hazard
 communication standard for this purpose.

(d) Site control.

  (1) General. Appropriate site control procedures
  shall be implemented to control employee
  exposure to hazardous substances before  clean-
  up work begins.

  (2)  Site control  program. A site control program
  for protecting employees which is part of the
  employer's site safety and health program
  required in paragraph (b) of this* section shall be
  developed during the planning stages of a haz-
  ardous waste clean-up operation and modified as
  necessary as new information becomes available.

  (3) Elements of the site control program.  The  site
  control program shall, as a minimum,  include: A
  site map; site work zones; the use of a "buddy
  system"; site communications including alerting
  means for emergencies; the standard operating
  procedures or safe work practices; and, identi-
  fication of the nearest medical assistance. Where
  these requirements  are covered elsewhere they
  need not be repeated.

(e) Training.

  (I) General.

    (i) All employees working on site (such as but
  not limited to  equipment operators,  general
  laborers  and others)  exposed to hazardous
  substances, health hazards, or safety  hazards
  and  their  supervisors  and  management
  responsible for the site shall receive training
  meeting the requirements of this paragraph
  before they  are permitted to engage in haz-
  ardous waste  operations that could expose
  them to  hazardous substances, safety,  or
  health hazards, and they shall receive review
  training as specified in this paragraph.

  (ii) Employees shall not be permitted to par-
  ticipate in or supervise field activities until
  they have been trained to a level required  by
  their job  function and responsibility.

(2) Elements to be covered. The training shall
thoroughly  cover the following:

  (i) Names of personnel and alternates respon-
  sible for  site safety and health;

  (ii) Safety, health and other hazards present
  on the site;

  (iii) Use of personal protective equipment;

  (iv) Work practices by which the employee can
  minimize risks from hazards;

  (v) Safe use  of engineering controls and equip-
  ment on  the site;

  (vi) Medical  surveillance requirements, includ-
  ing recognition of symptoms and signs which
  might indicate overexposure to hazards; and

  (vii) The contents of paragraphs (g) through
  (j) of the site safety and health plan set forth
  in paragraph (b)(4)(ii) of this section.

 (3) Initial training.

  (i) General  site workers (such as equipment
  operators, general laborers and supervisory
  personnel)  engaged in hazardous substance
  removal  or  other activities which expose or
  potentially expose workers to hazardous sub-
  stances  and health  hazards shall receive a
  minimum of 40  hours of instruction off  the
  site, and a minimum of three clays actual field
  experience  under the  direct supervision of a
  trained,  experienced supervisor.
                                              330.6
                                                                                      Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                                             STANDARDS AND INTERPRETATIONS
    (ii) Workers on site only occasionally for a spe-
    cific limited task (such as. but not limited to,
    ground water monitoring, land surveying, or
    geo-physical surveying) and who  are unlikely
    to  be exposed  over permissible exposure
    limits and published exposure  limits shall
    receive a minimum of 24 hours of instruction
    off the site, and  the  minimum of one day
    actual field experience under the direct super-
    vision of a trained, experienced supervisor.

    (iii) Workers regularly on site who work in
    areas which have been monitored and fully
    characterized  indicating that exposures  are
    under permissible exposure limits and pub-
    lished exposure limits where respirators are
    not necessary, and the characterization indi-
    cates that there are no health hazards or the
    possibility of an emergency developing, shall
    receive a minimum of 24 hours of instruction
    off the site and the minimum of one day actual
    field experience under the direct supervision
    of a trained, experienced supervisor.

    (iv) Workers with 24 hours of training who are
    covered by paragraphs (a)(3)(ii)and (a)(3)(iii)
    of this section, and who become  general site
    workers or who are required to wear respira-
    tors, shall have the additional 16 hours and
    two days of training necessary  to total the
    training specified in paragraph  (e)(3)(i).

  (4) Management and supervisor training. On-site
  management and supervisors directly  respon-
  sible for, or who supervise employees engaged
  in, hazardous waste operations shall receive 40
  hours initial training, and three  days of super-
  vised field experience  (the training may be
  reduced to 24 hours  and one day if the only area
  of their responsibility is employees covered by
  paragraphs (e)(3)(ii) and (e)(3)(iii)  and  at  least
  eight additional hours of specialized training at
  the time of job assignment on such topics as, but
  not  limited to, the employer's safety and health
  program and the  associated employee training
  program,  personal  protective equipment pro-
  gram,  spill containment program, and health
  hazard monitoring procedure and techniques.

  (5) Qualifications  for trainers. Trainers shall be
  qualified to instruct employees about the subject
  matter that is being presented in training.  Such
      trainers shall have satisfactorily completed a
      training program for teaching the subjects they
      are expected to teach,  or they  shall have the
      academic credentials and instructional experi-
      ence  necessary  for teaching  the subjects.
      Instructors  shall   demonstrate  competent
      instructional skills and knowledge of the applica-
      ble subject matter.

      (6) Training certification. Employees and super-
      visors that have received and successfully com-
      pleted the training and field experience specified
      in paragraphs (e)(l) through (e)(4) of this section
      shall be certified by their instructor or the head
      instructor and trained supervisor as having suc-
      cessfully completed the necessary  training.  A
      written certificate shall  be given to  each person
      so certified.  Any person who has not been so
      certified or who does not meet the requirements
      of paragraph (e)(9) of this section shall be pro-
      hibited from engaging in hazardous waste opera-
      tions.

      (7) Emergency response. Employees who are
      engaged in responding to hazardous emergency
      situations at hazardous waste clean-up sites that
      may expose them to hazardous substances shall
      be trained in how to respond to such expected
      emergencies.

      (8) Refresher training.  Employees  specified in
      paragraph (e)(l) of this section, and managers
      and supervisors specified in paragraph (e)(4) of
      this  section,  shall receive eight hours  of
      refresher training  annually on the items spec-
      ified in paragraph (e)(2) and/or (e)(4) of this sec-
      tion,  any critique of incidents that have occurred
      in the past year that can serve as training exam-
      ples of related work, and other relevant topics.

      (9) Equivalent training. Employers who can show
      by documentation or certification that  an
      employee's work experience and/or training has
      resulted in training equivalent to that training
      required  in paragraphs (e)(l) through (e)(4) of
      this section shall not be required to provide the
      initial training requirements of those paragraphs
      to  such  employees.   However,  certified
      employees new to a site shall receive appropri-
      ate, site specific training before site entry and
      have appropriate supervised field experience at
       the new site. Equivalent training  includes any
 Change 51
330.7

10
                                                                                     1910.120
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 1910.120
                                                           OCCUPATIONAL SAFETY AXD HEALTH
STANDARDS AND INTERPRETATIONS
  academic training or the training that existing
  employees might have  already received from
  actual hazardous waste site work experience.

(f) Medical surveillance.

  (1) General. Employers  engaged in operations
  specified  in  paragraphs  (a)(l)(i)  through
  (a)(l)(iv) of this section and not covered by
  (a)(2)(iii) exceptions and employers of employees
  specified in paragraph  (g)(9) shall institute a
  medical surveillance program in accordance with
  this paragraph.

  (2) Employees  covered. The medical surveillance
  program shall  be  instituted by the employer for
  the following employees:

    (i) All employees who  are or may be exposed
    to hazardous substances or health hazards at
    or above the permissible exposure limits or, if
    there is no permissible exposure limit, above
    the  published exposure levels for these sub-
    stances, without regard to the use of respira-
    tors, for 30 days or more a year;

    (ii) All employees who wear a respirator for 30
    days or more  a year or  as  required by §
    1910.134;

    (iii) All employees who are  injured due to
    overexposure from an emergency incident
    involving hazardous substances or health haz-
    ards; or

    (iv) Members of HAZMAT teams.

  (3) Frequency of medical examinations and con-
  sultations.

  Medical examinations  and consultations shall be
  made available  by  the employer to each
  employee covered under paragraph (f)(2) of this
  section on the  following schedules:

    (i) For employees covered  under paragraphs
    (f)(2)(i), (f)(2)(ii), and (f)(2)(iv):

      (a) Prior to assignment;

      (b) At least once every  twelve months for
      each employee covered unless the attending
      physician believes  a longer interval (not
      greater than  biennially) is appropriate;

      (c) At termination of employment or reas-
    signment to an area where the employee
    would not be covered if the employee has
    not had an examination within the last six
    months;

    (d) As soon as possible upon notification by
    an  employee  that  the  employee  has
    developed signs or symptoms indicating
    possible overexposure to  hazardous sub-
    stances  or health hazards, or  that the
    employee has  been injured  or exposed
    above the permissible exposure limits or
    published exposure levels in an emergency
    situation;

    (e) At more frequent times, if the examin-
    ing physician  determines that an  increased
    frequency of examination is medically nec-
    essary.

  (ii) For employees covered under paragraph
  (f)(2)(iii) and for all employees including those
  of employers covered  by paragraph (a)(l)(v)
  who may have been injured, received a health
  impairment,  developed signs or symptoms
  which may have resulted from  exposure to
  hazardous  substances resulting  from  an
  emergency incident, or exposed  during an
  emergency incident to  hazardous substances
  at concentrations above the  permissible
  exposure limits or the published exposure lev-
  els without the  necessary personal protective
  equipment being used:

    (a)  As  soon as possible following the
    emergency incident or development of signs
    or symptoms;

    (b) At additional times, if the examining
    physician determines that  follow-up exam-
    inations or consultations are medically nec-
    essary.

(4)  Content of medical examinations and con-
sultations.

  (i) Medical examinations required by para-
  graph (f)(3) of this section shall include a med-
  ical and work history (or updated  history if
  one is  in the employee's file) with special
  emphasis on symptoms related to the handling
  of hazardous substances and health hazards.
  and to  fitness for duty including the ability to
  wear any required PPE under conditions (i.e..
  temperature extremes) that may be expected
  at the work site.
                                            330.8


                                                11
                                   Change 51

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OCCUPATIONAL SAFETY AXD HEALTH
                                                            STANDARDS AND INTERPRETATIONS
   (ii) The content of medical examinations or
   consultations made available to employees
   pursuant to paragraph (f) shall be determined
   by the attending physician. The guidelines in
   the Occupational Safety and Health Guidance
   Manual for Hazardous Waste Site Activities
   (See Appendix D, Reference #10) should be
   consulted.

 (5)  Examination by a physician and  costs. All
 medical examinations and procedures shall be
 performed by or under the supervision of a
 licensed physician, preferably one knowledge-
 able in occupational medicine, and shall be
 provided without cost to the employee, without
 loss of pay, and at a reasonable time and place.

 (6)  Information provided to the physician. The
 employer shall provide one copy of this standard
 and its appendices to the attending physician,
 and in  addition the following for each employee:

   (i) A description of the employee's duties as
   they relate to the employee's exposures.

   (ii) The employee's exposure levels or antici-
   pated exposure levels.

   (iii) A description of any personal protective
   equipment used or to be used.

   (iv) Information from previous medical exam-
   inations of the employee which  is not readily
   available to the examining physician.

   (v) Information required by §1910.134.

 (7)  Physician's written opinion.

   (i) The employer shall obtain and furnish the
   employee with a copy of a written opinion
   from the attending physician containing the
   following:

     (a) The physician's opinion as to whether
     the employee has any detected medical con-
     ditions which would place the employee at
     increased risk of material impairment of the
     employee's health from  work in  hazardous
     waste operations or emergency response, or
     from respirator use.

     (b) The physician's recommended limita-
     tions upon the employee's assigned work.
          (c) The results of the medical examination
          and tests if requested by the employee.

          (d) A statement that the employee has been
          informed by the physician of the results of
          the medical examination and any medical
          conditions  which require further examina-
          tion or treatment.

        (ii)  The written opinion obtained by the
        employer shall not reveal specific findings or
        diagnoses unrelated to  occupational ex-
        posures.

      (8) Recordkeeping.

        (i) An accurate record of the medical sur-
        veillance required by paragraph (f) of this sec-
        tion shall be retained. This record  shall be
        retained for the period specified and meet the
        criteria of 29 CFR 1910.20.

        (ii) The record required in paragraph (f)(8)(i)
        of this section shall include at least the follow-
        ing information:

          (a) The name and social security number of
          the employee;

          (b)  Physician's written opinions, recom-
          mended limitations, and results of examina-
          tions and tests;

          (c)  Any  employee  medical  complaints
          related  to exposure to hazardous sub-
          stances;

          (d) A copy of the information provided to
          the examining physician by the employer,
          with the exception of the standard and its
          appendices.
    (g) Engineering  controls,  work practices, and
    personal  protective equipment for employee
    protection.

    Engineering controls, work practices, personal
    protective equipment,  or a combination of these
    shall be implemented in accordance with this para-
    graph to protect employees  from exposure to haz-
    ardous substances and safety and health hazards.
Change 51
330.9

12
1910.120(g)

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1910.120
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OCCUPATIONAL SAFETY AND HEALTH
                                                             STANDARDS AND INTERPRETATIONS
  (4) Totally-encapsulating chemical protective
  suits.

    (i) Totally-encapsulating suits shall protect
    employees from the  particular hazards which
    are identified during site characterization and
    analysis.

    (ii) Totally-encapsulating suits shall be capable
    of maintaining positive air pressure. (See
    Appendix A for a test method which may be
    used to evaluate this requirement.)

    (iii) Totally-encapsulating suits shall  be capa-
    ble of preventing inward test gas leakage of
    more than 0.5 percent. (See Appendix A for a
    test method which may be used to evaluate
    this requirement.)

  (5) Personal protective equipment (PPE) program.
  A written personal protective equipment pro-
  gram, which is part of the employer's safety and
  health program required in paragraph (b) of this
  section or required in paragraph  (p)(l) of this
  section  and which  is  also a part of the site-
  specific  safety and health plan shall be  estab-
  lished. The PPE  program shall address the ele-
  ments listed below. When elements, such as
  donning  and doffing procedures, are provided by
  the manufacturer of a piece of equipment and
  are attached to the plan, they  need not be
  rewritten into the plan  as long  as they ade-
  quately address the procedure or element.

    (i) PPE selection based upon site hazards,

    (ii) PPE use and limitations of the equipment,

    (iii) Work mission duration,

    (iv) PPE maintenance and storage,

    (v) PPE decontamination and disposal,

    (vi) PPE training and proper fitting,

    (vii) PPE donning and doffing procedures,

    (viii) PPE inspection procedures  prior to, dur-
    ing,  and after use,

    (ix) Evaluation  of the effectiveness of the PPE
    program, and

    (x) Limitations during temperature extremes,
    heat stress, and other  appropriate medical
    considerations.
     (h) Monitoring.

       (1) General.

         (i) Monitoring shall be performed in accord-
         ance with this paragraph where there may be
         a question of employee exposure to hazardous
         concentrations of hazardous  substances in
         order to assure proper selection of engineer-
         ing controls,  work practices and personal pro-
         tective equipment so that employees are not
         exposed to levels which exceed permissible
         exposure limits or published exposure levels
         for hazardous substances.

         (ii) Air monitoring shall be used to identify
         and quantify airborne levels of hazardous sub-
         stances and safety and health hazards in order
         to   determine the appropriate  level of
         employee protection needed on site.

       (2) Initial entry. Upon initial entry, representa-
       tive air monitoring shall be conducted to identify
       any IDLH condition, exposure over permissible
       exposure limits or published exposure levels,
       exposure over a radioactive material's dose
       limits or other dangerous condition such as the
       presence of flammable atmospheres or oxygen-
       deficient environments.

       (3) Periodic monitoring. Periodic monitoring shall
       be conducted when the  possibility of an IDLH
       condition  or  flammable  atmosphere  has
       developed or when there is indication that
       exposures may have risen over permissible
       exposure limits or published exposure  levels
       since  prior monitoring. Situations where it shall
       be considered whether the  possibility that
       exposures have risen are as  follows:

         (i) When work begins on a different portion of
         the site.

         (ii)  When contaminants other than those pre-
         viously identified are being handled.

         (iii) When a different type of operation is initi-
         ated (e.g., drum opening as opposed to explor-
         atory well drilling).

          (iv) When employees are handling leaking
          drums or containers or working in areas with
          obvious liquid contamination  (e.g.,  a spill or
          lagoon).
        (4) Monitoring of high-risk employees. After the
        actual clean-up phase of any hazardous waste
Change 51
330.11

 14
                                                                                   iai(U20(h)(4)

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 1910.120(h)(4)
                                                           OCCUPATIONAL SAFETY AND HEALTH
 STANDARDS AND INTERPRETATIONS
  operation commences; for example, when soil,
  surface water or containers are moved or dis-
  turbed; the employer  shall  monitor  those
  employees likely to have the highest exposure to
  hazardous substances and health hazards likely
  to be present above permissible exposure limits
  or published exposure levels by using personal
  sampling frequently  enough to characterize
  employee exposures. If the employees  likely to
  have the highest exposure are over permissible
  exposure limits or published exposure limits,
  then monitoring shall continue to determine all
  employees likely to be above those limits. The
  employer may utilize a representative sampling
  approach by documenting that the employees
  and chemicals chosen for monitoring are based
  on the criteria stated above.

  Note to (h): It  is not  required to  monitor
  employees engaged in site characterization oper-
  ations covered by paragraph (c) of this section.

(i) Informational programs.

Employers shall develop and implement a pro-
gram, which is part of the employer's safety and
health program required in paragraph (b) of this
section, to inform employees, contractors, and
subcontractors (or their representative)  actually
engaged in hazardous waste operations of the
nature, level  and degree of exposure likely as a
result of participation in such hazardous  waste
operations.  Employees, contractors and sub-
contractors working outside of the operations part
of a site are not covered  by this standard.

(j) Handling  drums and containers.

  (1) General.

    (i) Hazardous substances and contaminated
    soils, liquids, and other residues shall be han-
    dled, transported,  labeled, and disposed of in
    accordance with this paragraph.

    (ii) Drums and containers used during the
    clean-up shall meet the appropriate DOT,
    OSHA, and EPA regulations for the wastes
    that the}' contain.

    (iii) When practical, drums and containers
    shall be inspected and  their integrity shall be
    assured prior to being moved. Drums or con-
    tainers that cannot be  inspected before being
    moved because of storage conditions (i.e., bur-
    ied beneath the earth, stacked behind other
        drums, stacked several tiers high in a pile,
        etc.) shall be moved to an accessible location
        and inspected prior to further handling.

        (iv) Unlabeled drums and containers shall be
        considered  to contain hazardous substances
        and handled accordingly until the contents are
        positively identified and labeled.

        (v) Site operations shall be organized to mini-
        mize the amount of drum or container move-
        ment.

        (vi) Prior  to movement of drums or con-
        tainers, all employees exposed to the transfer
        operation shall be warned of the potential haz-
        ards associated with the contents of the drums
        or containers.

        (vii) U.S. Department of Transportation spec-
        ified salvage drums or containers and suitable
        quantities of proper absorbent shall be kept
        available and used in areas where spills, leaks,
        or ruptures may occur.

        (viii) Where major spills may occur,  a spill
        containment program, which is part of the
        employer's safety  and  health  program
        required in paragraph (b) of this section, shall
        be implemented to contain and isolate the
        entire volume of the hazardous substance
        being  transferred.

        (ix) Drums and containers that cannot be
        moved without rupture, leakage, or spillage
        shall be  emptied into a sound  container using
        a device classified for the material being
        transferred.

        (x) A  ground-penetrating system or other
        type of detection system or device shall be
        used to estimate the location and depth of bur-
        ied drums or containers.

        (xi) Soil or covering material shall be removed
        with caution to  prevent drum or container
        rupture.

        (xii) Fire extinguishing equipment meeting
        the requirements of 29 CFR Part 1910, Sub-
        part L, shall be on hand and ready for use to
        control incipient  fires.

      (2) Opening drums and containers. The following
      procedures shall be followed in areas where
      drums or containers are being opened:
 1910.120(j)(2)
330.12

  15
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OCCUPATIONAL SAFETY AND HEALTH
                                                            STANDARDS AND INTERPRETATIONS
   (i) Where an airline respirator system is used,
   connections to the source of air supply shall be
   protected from contamination and the entire
   system  shall be  protected from physical
   damage.

   (ii) Employees not actually involved in open-
   ing drums or  containers shall be kept a safe
   distance from the  drums or containers being
   opened.

   (iii) If employees must work near or adjacent
   to drums or containers being opened, a suita-
   ble shield that  does not interfere with the
   work operation  shall be placed between the
   employee and the  drums or containers being
   opened to protect the employee in case of acci-
   dental explosion.

   (iv) Controls  for drum or container opening
   equipment, monitoring equipment, and fire
   suppression equipment shall be located behind
   the explosion-resistant barrier.

   (v) When there  is a reasonable possibility of
   flammable atmospheres being present, mate-
   rial handling equipment and hand tools shall
   be of the type to prevent sources of ignition.

   (vi) Drums and  containers shall be opened in
   such  a manner that excess interior pressure
   will be safety  relieved.  If pressure can not be
   relieved from a  remote location, appropriate
   shielding  shall be  placed  between  the
   employee and  the  drums or  containers to
   reduce the risk of employee injury.

   (vii) Employees shall not stand upon or work
   from drums or containers.

 (3)  Material handling  equipment.  Material hand-
 ling equipment used to transfer drums and con-
 tainers shall  be selected,  positioned  and
 operated to minimize sources of ignition related
 to the equipment  from igniting vapors released
 from ruptured drums or containers.

 (4) Radioactive wastes.  Drums and containers
 containing radioactive wastes shall not be han-
 dled until  such  time  as  their  hazard  to
 employees is  properly assessed.

 (5) Shock sensitive wastes. As a minimum,  the
 following special precautions shall be taken
 when drums and  containers containing or sus-
 pected  of containing shock-sensitive wastes are
 handled:
 Change 51
        (i) All non-essential employees shall be evacu-
        ated from the area of transfer.

        (ii) Material handling equipment shall be
        provided with explosive containment devices
        or protective shields  to protect equipment
        operators from exploding containers.

        (iii) An employee alarm  system capable of
        being perceived above surrounding light and
        noise conditions shall be used to signal the
        commencement and completion of explosive
        waste handling activities.

        (iv) Continuous communications (i.e., portable
        radios, hand signals, telephones, as appropri-
        ate)   shall  be  maintained  between  the
        employee-in-charge of the immediate handling
        area and both the site safety and health super-
        visor and the command post until such time as
        the handling operation is completed. Com-
        munication equipment or methods that could
        cause shock sensitive materials to explode
        shall not be  used.

        (v) Drums and containers under pressure, as
        evidenced by bulging or swelling, shall not be
        moved until such time as the cause for excess
        pressure is determined and appropriate con-
        tainment procedures have been implemented
        to protect employees from explosive relief of
        the drum.

        (vi) Drums  and containers containing pack-
        aged laboratory wastes shall be considered to
        contain shock-sensitive or explosive materials
        until they have been characterized.

        Caution: Shipping of shock sensitive  wastes
        may be prohibited under  U.S. Department of
        Transportation regulations.  Employers  and
        their shippers should  refer to 49 CFR 173.21
        and 173.50.

       (6) Laboratory waste  packs. In addition to the
       requirements  of paragraph (j)(5) of this section,
       the following precautions shall be  taken, as a
       minimum, in  handling laboratory waste packs
       (lab packs):

        (i) Lab packs shall be opened only when neces-
        sary and then only by an individual  knowl-
        edgeable in the inspection, classification,  and
        segregation of the containers within the  pack
        according to the hazards of the wastes.

        (ii) If crystalline material is noted  on any con-

330.13                                i'Jio.i2()(j)(6)(ii)
                                            16

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1910.120(j)(6Kii>
                                                           OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
    tainer, the contents shall be handled as a
    shock-sensitive waste until the contents are
    identified.

  (7) Sampling of drum and container contents.
  Sampling of containers and drums shall be done
  in accordance with a sampling procedure which
  is part  of  the site  safety  and health plan
  developed for and available  to employees and
  others at the specific worksite.

  (8) Shipping and transport.

    (i)  Drums and containers shall be identified
    and classified prior to packaging for shipment.

    (ii) Drum or container staging areas shall be
    kept to the minimum number necessary to
    identify and classify materials safely and pre-
    pare them for transport.

    (in) Staging areas shall be provided with ade-
    quate access and egress routes.

    (iv) Bulking of hazardous wastes shall be per-
    mitted only after a thorough characterization
    of the materials has been completed.

  (9) Tank and vault procedures.

    (i)  Tanks  and vaults containing  hazardous
    substances shall be handled in a manner simi-
    lar to that  for drums and containers, taking
    into consideration  the size of the tank or
    vault.

    (ii) Appropriate tank or vault entry proce-
    dures as described in the  employer's safety
    and health plan shall be followed whenever
    employees must enter a tank or vault.

(k) Decontamination.

  (1) General. Procedures for all phases of decon-
  tamination shall be developed and implemented
  in accordance with this paragraph.

  (2) Decontamination procedures.

    (i)  A  decontamination procedure shall  be
    developed,  communicated  to  employees and
    implemented before any employees or equip-
    ment may enter areas on site where potential
    for exposure to hazardous substances exists.
        (ii) Standard operating procedures shall  In-
        developed to minimize employee contact with
        hazardous substances or with equipment that
        has contacted hazardous substances.

        (iii) All employees leaving a contaminated
        area shall be appropriately decontaminated:
        all contaminated clothing and equipment leav-
        ing a contaminated area shall be appropriately
        disposed of or decontaminated.

        (iv) Decontamination procedures shall  be
        monitored by the site safety and health super-
        visor to determine their effectiveness.  When
        such procedures are found to be ineffective.
        appropriate steps shall be taken to correct any
        deficiencies.

      (3) Location. Decontamination shall be performed
      in geographical areas that will minimize the
      exposure of uncontaminated employees or equip-
      ment to contaminated employees or equipment.

      (4) Equipment and solvents. All equipment and
      solvents used for decontamination shall  be
      decontaminated or disposed of properly.

      (5) Personal protective clothing and equipment.

        (i) Protective clothing and equipment shall  be
        decontaminated, cleaned,  laundered,  main-
        tained or replaced as needed to maintain their
        effectiveness.

        (ii)  Employees whose  non-impermeable
        clothing becomes wetted with hazardous sub-
        stances  shall   immediately  remove  that
        clothing and proceed to shower. The clothing
        shall be disposed of or decontaminated before
        it is removed from  the work zone.

      (6) Unauthorized employees.  Unauthorized
      employees shall not remove protective clothing
      or equipment from change rooms.

      (7)  Commercial laundries or cleaning establish-
      ments. Commercial laundries  or cleaning  estab-
      lishments   that   decontaminate  protective
      clothing or equipment shall be informed  of the
      potentially harmful effects of exposures lo haz-
      ardous substances.

      (8) Showers and change rooms. Where  the decon-
      tamination procedure indicates a need for regu-
      lar showers and  change rooms outside of a
 1910.120(k)(8>
330.14

     17
                                                                                     Change .">!

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OCCUPATIONAL SAFETY AND HEALTH
                                                                                 1910.120(k»8)
                                                            STANDARDS AND INTERPRETATIONS
  contaminated area, they shall be provided and
  meet the requirements of 29 CFR 1910.141.  If
  temperature conditions prevent the effective use
  of water, then other effective means for cleans-
  ing shall be provided and used.

(I) Emergency  response by  employees at
uncontrolled hazardous waste  sites.

  (1) Emergency response plan.

    (i) An emergency  response plan shall be
    developed and implemented by all employers
    within the scope of this  section to handle
    anticipated emergencies prior to the com-
    mencement of hazardous  waste operations.
    The plan shall be in writing and available for
    inspection and copying by employees, their
    representatives,  OSHA personnel and other
    governmental agencies with  relevant respon-
    sibilities.

    (ii)  Employers  who  will  evacuate  their
    employees  from the  workplace  when an
    emergency occurs, and who do not permit any
    of their  employees to assist in handling the
    emergency,  are exempt from the require-
    ments of this paragraph if they provide an
    emergency action plan complying with section
    1910.38(a) of this part.

  (2) Elements of  an emergency response plan. The
  employer shall develop an emergency response
  plan for emergencies  which  shall address, as a
  minimum the following:

    (i) Pre-emergency planning.

    (ii) Personnel roles, lines of authority, and
    communication.

    (iii) Emergency recognition and prevention.

    (iv) Safe distances and places of refuge.

    (v) Site security and control.

    (vi) Evacuation routes and procedures.

    (vii)  Decontamination  procedures which are
    not covered by the site safety and health plan.

    (viii) Emergency medical treatment and first
    aid.
         (ix) Emergency alerting and response proce-
         dures.

         (x) Critique of response and follow-up.

         (xi) PPE and emergency equipment.


       (3) Procedures for  handling emergency incidents.

         (i) In  addition  to the elements for the
         emergency response plan required in para-
         graph (1)(2) of  this section, the following ele-
         ments shall  be  included  for emergency
         response plans:

           (a) Site  topography, layout, and  prevailing
           weather conditions.

           (b) Procedures for reporting incidents to
             al, state, and federal governmental agen-
         (ii) The emergency response plan shall be a
         separate section of the Site Safety and Health
         Plan.

         (iii) The emergency  response plan shall be
         compatible and integrated with the disaster,
         fire and/or emergency response plans of local,
         state, and federal agencies.

         (iv) The emergency  response plan shall be
         rehearsed regularly as part of the overall
         training program for  site operations.

         (v) The site emergency response plan shall be
         reviewed periodically and, as  necessary, be
         amended to  keep it current with new or
         changing site conditions or information.

         (vi)  An  employee alarm  system shall be
         installed in accordance with 29 CFR 1910.165
         to notify employees of an emergency situation;
         to stop work activities if necessary: to lower
         background noise in order to speed communi-
         cation; and to begin emergency procedures.

         (vii) Based upon the  information available at
         time of the emergency,  the employer shall
         evaluate the incident and the site response
         capabilities and proceed  with the appropriate
         steps  to implement the site emergency
         response plan.
  Change 51
330.15


 18

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                                                             OCCL'PATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
(m) Illumination.

  Areas accessible to employees shall be lighted to
  not less than the minimum illumination inten-
  sities listed in the following Table H-120.1 while
  any work is in progress:
   TABLE H-120.1—MINIMUM ILLUMINATION
        INTENSITIES IN FOOT-CANDLES
 Foot-
candles
         Area or operations
10
General site areas.
Excavation and waste areas, access-
  ways, active storage areas, loading
  platforms, refueling, and field main-
  tenance areas.
Indoors: Warehouses, corridors, hall-
  ways, and exitways.
Tunnels, shafts, and general under-
  ground work areas. (Exception:
  Minimum of 10 foot-candles is
  required at tunnel and shaft heading
  during drilling mucking, and scaling.
  Mine Safety and Health Administra-
  tion approved cap lights shall be
  acceptable for use in the tunnel head-
  ing).
General shops (e.g., mechanical and
  electrical equipment rooms, active
  storerooms, barracks or living quar-
  ters, locker or dressing rooms,
  dining areas, and indoor toilets and
  workrooms.)
First aid stations, infirmaries, and
  offices.
(n) Sanitation at temporary workplaces.

  (1) Potable water.

    (i) An adequate supply of potable water shall
    be provided on the site.

    (ii) Portable  containers used  to  dispense
    drinking  water shall be capable  of being
    tightly closed,  and equipped with a tap. Water
    shall not be clipped from containers.

    (iii) Any container used to distribute drinking
    water shall be clearly marked as to the nature
    of its contents and not used for any other pur-
    pose.
30
    (iv) Where single service cups (to be used but
    once) are supplied, both a sanitary container
    for the unused cups and a receptacle for dis-
    posing of the used cups shall be provided.

  (2) Nonpotable water.

    (i) Outlets for nonpotable water,  such as
    water for firefighting purposes, shall be iden-
    tified to indicate clearly that the water is
    unsafe and is not to be used for drinking,
    washing, or cooking purposes.

    (ii) There shall be no cross-connection, open or
    potential, between a system furnishing pota-
    ble water and a system furnishing nonpotable
    water.

  (3) Toilet facilities.

    (i) Toilets shall be provided for employees
    according to the following Table H-120.2.

      TABLE H-120.2—TOILET FACILITIES
                                                   Number of employees
                          Minimum number of
                               facilities
20 or fewer	  One.
More than  20, fewer  One toilet seat and one
  than 200.                urinal per 40
                          employees.
More than 200	  One toilet seat and one
                          urinal per 50
                          employees.

    (ii) Under temporary field conditions, provi-
    sions shall be made to assure that at least one
    toilet facility is available.

    (iii) Hazardous waste sites not provided with a
    sanitary sewer shall be provided with the fol-
    lowing toilet facilities unless prohibited by
    local codes:

      (a) Chemical toilets;

      (b) Recirculating toilets:

      (c) Combustion toilets; or

      (d) Flush toilets.

    (iv) The requirements of this paragraph  for
    sanitation facilities shall not apply  to mobile
    crews having transportation readily available
    to nearbv toilet facilities.
 l»10.120(n)CJ)fiv)
                                            330.16

                                                19
                                                                              Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                    1910.120(n)(3Xv)
   (v) Doors entering toilet  facilities  shall be
   provided with entrance locks controlled from
   inside the facility.

  (4)  Food handling. All food service facilities and
  operations for employees shall meet the applica-
  ble laws, ordinances,  and regulations of the
  jurisdictions in which they are located.

  (5)  Temporary  sleeping quarters. When tempo-
  rary sleeping quarters  are provided, they shall
  be heated, ventilated, and lighted.

  (6) Washing  facilities.  The employer  shall
  provide  adequate  washing  facilities   for
  employees engaged  in operations where haz-
  ardous  substances  may   be  harmful  to
  employees. Such facilities shall be in near prox-
  imity to the worksite; in areas where exposures
  are below permissible exposure limits  and pub-
  lished exposure levels and which are under the
  controls  of the  employer;  and shall  be so
  equipped as to enable employees to remove haz-
  ardous substances from themselves.

  (7) Showers and change rooms. When hazardous
  waste clean-up or removal operations commence
  on  a site and the duration  of the work will
  require six months or greater time to complete,
  the employer shall provide showers and change
  rooms for all employees exposed to hazardous
  substances and health  hazards involved in haz-
  ardous waste clean-up or removal operations.

   (i) Showers shall  be provided and shall be
   provided and shall meet the requirements of
   29  CFR 1910.141(d)(3).

   (ii) Change  rooms  shall be provided  and shall
   meet the requirements of 29 CFR 1910.141(e).
   Change rooms shall consist of two  separate
   change areas separated by the shower area
   required in paragraph (n)(7)(i) of this section.
   One change area, with an exit leading off the
   worksite, shall provide employees with a clean
   area where they can remove, store, and put
   on street clothing. The second area, with an
   exit to the worksite, shall provide employees
    with an area where  they can put on, remove
   and store work clothing and personal protec-
    tive equipment.

    (iii) Showers  and change rooms  shall be
    located in areas where exposures are below
    the permissible exposure limits and  published
    exposure levels.  If this cannot be accom-
                 STANDARDS AND INTERPRETATIONS

        plished,  then a ventilation system shall be
        provided that will supply air that is below the
        permissible exposure limits  and published
        exposure levels.

        (iv) Employers shall assure that employees
        shower at the end of their work shift and
        when leaving the hazardous waste site.

     (o) New technology programs.

       (1) The employer shall develop  and implement
       procedures for the  introduction of effective new
       technologies and equipment developed for the
       improved protection of employees working with
       hazardous  waste clean-up operations, and the
       same shall be implemented as part of the site
       safety  and health program to assure that
       employee protection is being maintained.

       (2) New technologies, equipment or control
       measures available to the industry, such as the
       use of foams, absorbents, adsorbents, neu-
       tralizers, or other means to suppress the level of
       air contaminants while excavating the site or for
       spill control, shall be evaluated by employers or
       their representatives. Such an evaluation shall
       be done to determine the effectiveness of the
       new methods, materials, or equipment before
       implementing their use on a  large scale for
       enhancing employee protection.  Information and
       data from manufacturers or suppliers may be
       used as part of the employer's evaluation effort.
       Such evaluations shall be made available to
       OSHA upon request.

     (p) Certain  Operations Conducted  Under the
     Resource Conservation and  Recovery  Act of
     1976 (RCRA).

       Employers conducting operations at treatment,
       storage, and disposal (TSD) facilities specified in
       paragraph (a)(l)(iv) of this section not exempted
       by paragraph (a)(2)(iii) of this section shall
       provide and implement the programs specified
       in this paragraph.

       (1) Safety and health program. The employer
       shall develop and implement a written safety
       and health program for employees involved in
       hazardous waste operations that shall be avail-
       able for inspection by employees, their  repre-
       sentatives and OSHA personnel. The program
       shall be designed to identify, evaluate and con-
       trol safety and health hazards in their facilities
 Change 51
330.17
1910.l20(p)(l)
                                            20

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                                                           OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
  tor the purpose of employee  protection, to
  provide for emergency response meeting the
  requirements of paragraph (p)(8) of this section
  and to address as appropriate site analysis, engi-
  neering controls, maximum exposure limits, haz-
  ardous waste handling procedures and uses of
  new technologies.

  (2)  Hazard  communication  program. The
  employer shall implement a hazard communica-
  tion program meeting the requirements of 29
  CFR 1910.1200 as part of the employer's safety
  and program.

  Note to 1910.120.—The exemption  for haz-
  ardous waste provided in §1910.1200 is applica-
  ble to this section.

  (3) Medical surveillance program. The employer
  shall develop and implement a medical sur-
  veillance program meeting the requirements of
  paragraph (f) of this section.

  (4) Decontamination program. The employer
  shall develop and implement a decontamination
  procedure meeting the requirements of para-
  graph (k) of this section.

  (5) New technology program. The employer shall
  develop and implement procedures meeting the
  requirements of paragraph (o) of this section for
  introducing new and innovative equipment into
  the workplace.

  (6) Material handling program. Where employees
  will be handling drums or containers, the
  employer shall develop and implement proce-
  dures meeting the requirements of paragraphs
  (j)(l)(ii) through  (viii) and'(xi) of this section, as
  well as (j)(3) and (j)(8)  of this section prior to
  starting such work.

  (7) Training program.

    (i) New  employees. The employer shall
    develop  and implement a training program,
    which is part of the  employer's safety and
    health program, for employees involved with
    hazardous  waste  operations to  enable
    employees to perform their assigned duties
    and functions in a safe and healthful manner
    so as not to endanger themselves  or other
    employees. The initial training shall  be for 24
    hours and refresher training shall be for eight
    hours annually. Employees who have received
  the initial training required by this paragraph
  shall be given a written certificate attesting
  that they have successfully completed the nec-
  essary training.

  (ii) Current employees. Employers who can
  show by an employee's previous work experi-
  ence and/or training that the employee has
  had training equivalent to the initial training
  required by this paragraph, shall be consid-
  ered as meeting the initial training  require-
  ments of this paragraph as to that employee.
  Equivalent training includes the training that
  existing  employees might  have  already
  received from actual site work experience.
  Current employees shall receive eight hours
  of refresher training annually.

  (iii)  Trainers. Trainers who teach initial train-
  ing shall have satisfactorily completed a train-
  ing course for teaching the subjects they are
  expected to teach or they shall have the aca-
  demic credentials and instruction experience
  necessary to demonstrate a good command of
  the  subject matter of the courses and compe-
  tent instructional skills.

(8) Emergency response program.

  (i) Emergency response plan. An emergency
  response plan shall be developed and imple-
  mented by all employers. Such plans need not
  duplicate any of the subjects fully addressed
  in  the employer's  contingency  planning
  required by permits, such as those issued by
  the  U.S. Environmental Protection  Agency,
  provided that the contingency plan is made
  part of the emergency response plan shall be a
  written portion of the employers safety  and
  health program required in paragraph (p)(l) of
  this section.  Employers  who will evacuate
  their employees from the worksite location
  when an emergency occurs and who do not
  permit any of their employees to assist in
  handling the emergency are exempt from the
  requirements of paragraph (p)(8) if they
  provide an emergency action plan complying
  with §1910.38(a) of this part.

  (ii)  Elements of  an  emergency response plan.
  The employer  shall develop an emergency
  response plan  for  emergencies  which shall
  address, as a minimum, the following areas to
  the  extent that  they are not addressed in any
  specific program required in this paragraph:
                                           330.18

                                                21
                                   Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                                            STANDARDS AND INTERPRETATIONS
     (a) Pre-emergency planning and coordina-
     tion with outside parties.

     (b) Personnel roles, lines of authority, and
     communication.

     (c) Emergency recognition and prevention.

     (d) Safe distances and places of refuge.

     (e) Site security and control.

     (f) Evacuation routes and procedures.

     (g) Decontamination procedures.

     (h) Emergency medical treatment and first
     aid.

     (i) Emergency alerting and  response proce-
     dures.

     (j) Critique of response and  follow-up.

     (k) PPE and emergency equipment.

   (iii) Training.

   (a)  Training  for  emergency  response
   employees shall be completed  before they are
   called upon to perform in real emergencies.
   Such training shall include the elements of the
   emergency response plan, standard operating
   procedures the employer has established for
   the job, the personal protective equipment to
   be  worn  and  procedures   for  handling
   emergency incidents.

   Exception #1: An employer need not train all
   employees to the  degree specified if the
   employer divides the work force in a manner
   such that a sufficient number of employees
   who have responsibility to control emergencies
   have the training  specified, and all other
   employees, who may first  respond  to an
   emergency incident, have sufficient awareness
   training to recognize  that  an emergency
   response situation  exists and that they are
   instructed in that case to summon the fully
   trained employees  and not attempt control
   activities for which they are not trained.

   Exception #2: An employer need not train all
   employees to the degree specified if arrange-
   ments have been  made in  advance for  an out-
   side fully-trained emergency response team to
Change 51
        respond  in a  reasonable period  and all
        employees, who may come to the incident
        first, have sufficient awareness training to rec-
        ognize that an emergency  response situation
        exists and they have been instructed to call
        the   designated   outside   fully-trained
        emergency response team for assistance.

        (b)  Employee members  of TSD  facility
        emergency response organizations  shall  be
        trained to a level of competence in the recogni-
        tion of health and  safety hazards to protect
        themselves and other employees. This would
        include training in  the methods used to mini-
        mize the risk from  safety and health  hazards;
        in the safe use of control  equipment; in the
        selection and use of appropriate personal pro-
        tective equipment; in the safe operating proce-
        dures to be used at the incident scene; in the
        techniques  of  coordination  with  other
        employees to minimize risks; in the appropri-
        ate response to over exposure from health haz-
        ards  or injury to themselves  and other
        employees; and in the recognition of subse-
        quent symptoms which may result from over
        exposures.

        (c) The employer shall certify that each cov-
        ered employee has  attended and successfully
        completed the training required in paragraph
        (p)(8)(iii) of this section, or shall certify the
        employee's competency  at least yearly. The
        method  used  to demonstrate competency for
        certification of training shall be recorded and
        maintained by the employer.


        (iv) Procedures for  handling emergency inci-
        dents.

          (a) In addition  to the  elements for the
          emergency response plan required in para-
          graph  (p)(8)(ii) of this section, the following
          elements shall be included  for emergency
          response plans to the extent  that they do
          not repeat any information already con-
          tained in the emergency  response plan:

            (1) Site topography, layout, and prevail-
            ing weather conditions.

            (2) Procedures for reporting incidents to
            local, state, and federal governmental
            agencies.

          (b) The emergency response plan shall be
          compatible and integrated  with the disas-

330.19                             1910.120(p)(8)(iv)(b)
                                           22

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1910.120(p)(8)(iv)(b)
                                                           OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
      ter, fire and/or emergency response plans of
      local, state, and federal agencies.

      (c) The emergency response plan shall be
      rehearsed regularly as part of the overall
      training program for site operations.

      (d) The site emergency response plan shall
      be reviewed periodically and, as necessary,
      be amended to keep it current with -new or
      changing site conditions or information.

      (e) An employee  alarm system  shall be
      installed in accordance  with  29  CFR
      1910.165  to notify  employees of  an
      emergency situation; to stop work activities
      if necessary; to lower background noise in
      order to speed communication; and to  begin
      emergency procedures.

      (f) Based upon the information available at
      time of the emergency, the employer shall
      evaluate the  incident and the site  response
      capabilities and proceed with the appropri-
      ate steps to implement the site emergency
      response plan.

(q) Emergency response to hazardous sub-
stance releases.

This  paragraph  covers  employers  whose
employees are engaged in emergency response no
matter where it occurs  except that it  does  not
cover employees engaged in operations specified in
paragraphs (a)(l)(i) through (a)(l)(iv) of this sec-
tion. Those emergency response organizations who
have developed and implemented programs equiv-
alent to this paragraph  for handling releases of
hazardous substances pursuant to section 303 of
the Superfund Amendments and Reauthorization
Act of 1986 (Emergency Planning and Community
Right-to-Know Act of 1986, 42 U.S.C. 11003) shall
be deemed to have met  the requirements of  this
paragraph.

  (1) Emergency response plan. An emergency
  response plan shall be developed and imple-
  mented to handle anticipated emergencies prior
  to the commencement of emergency response
  operations. The plan shall be in writing  and
  available for  inspection  and  copying  by
  employees, their representatives and OSHA
  personnel. Employers who will evacuate their
  employees  from  the workplace  when  an
  emergency occurs, and who do not permit  any of
  their employees to  assist in handling  the
      emergency, are exempt from the requirements
      of this paragraph if they provide an emergency
      action plan in accordance with §1910.38(a) of this
      part.

      (2) Elements of an emergency response plan. The
      employer shall develop an emergency response
      plan for emergencies which shall address, as a
      minimum,  the following to the extent that they
      are not addressed elsewhere:

        (i) Pre-emergency planning and coordination
        with outside parties.

        (ii) Personnel roles, lines of authority, train-
        ing, and communication.

        (iii) Emergency recognition and prevention.

        (iv) Safe distances and places of refuse.

        (v) Site security and control.

        (vi) Evacuation routes and procedures.

        (vii) Decontamination.

        (viii) Emergency medical treatment and first
        aid.

        (ix) Emergency alerting and response proce-
        dures.

        (x) Critique of response and follow-up.

        (xi) PPE and Emergency equipment.

        (xii)  Emergency response organizations may
        use the local emergency response plan or the
        state emergency response plan or  both, as
        part of their emergency response plan to
        avoid  duplication.  Those  items of  the
        emergency response plan that are being prop-
        erly addressed by the SARA Title III plans
        may be substituted into their emergency plan
        or otherwise kept together for the employer
        and  employee's use.

      (3) Procedures for handling emergency response.

        (i) The senior emergency response official
        responding to an emergency shall become the
        individual in charge of a site-specific Incident
        Command System  (ICS).  All  emergency
        responders and their communications shall be
        coordinated and controlled through  the indi-
        vidual in  charge of the ICS assisted by the
        senior official present for each employer.
 1910.120(q)(3)(i)
330.20
  23
Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                                                                1910.120(q)(3)(i>
                                                            STANDARDS AND INTERPRETATIONS
   Note to (q)(3)(i).—The "senior official" at an
   emergency response is the most senior official
   on the site who has the responsibility for con-
   trolling the operations at the site. Initially it
   is the senior officer on the first-due piece of
   responding emergency apparatus to arrived
   on the incident scene.  As more senior officers
   arrive (i.e., battalion chief, fire chief, state
   law enforcement official,  site coordinator,
   etc.)  the  position is  passed up th.e. line of
   authority which has been previously estab-
   lished.

   (ii) The individual in charge of the ICS shall
   identify, to the extent possible, all hazardous
   substances or conditions present and shall
   address as appropriate site analysis, use of
   engineering controls, maximum exposure
   limits, hazardous substance handling proce-
   dures, and use of any new technologies.

   (iii) Based on the hazardous substances and/or
   conditions present, the individual in charge of
   the   ICS  shall implement  appropriate
   emergency operations, and assure that the
   personal protective equipment  worn is appro-
   priate for the hazards to be encountered.
   However, personal protective equipment shall
   meet, at a minimum, the criteria contained in
   29 CFR 19l0.156(e) when worn while per-
   forming fire fighting  operations beyond the
   incipient stage for any incident or site.

   (iv)  Employees engaged in  emergency
   response and exposed to hazardous substances
   presenting an  inhalation hazard or potential
   inhalation hazard shall wear positive pressure
   self-contained breathing apparatus while
   engaged in emergency response, until such
   time that  the individual in charge of the ICS
   determines through  the use of air monitoring
   that a decreased level of respiratory protec-
   tion will not result in  hazardous exposures to
   employees.

   (v) The individual in charge of the ICS shall
   limit the number of emergency response per-
   sonnel at the emergency site, in those areas of
   potential or actual exposure to  incident or site
   hazards, to those who are actively performing
   emergency operations. However, operations
   in hazardous areas shall be performed using
   the buddy system in groups of two or more.

   (vi) Back-up personnel shall  stand  by  with
   equipment ready to  provide assistance or res-
        cue. Advance first aid support personnel, as a
        minimum, shall also stand by with medical
        equipment and transportation capability.

        (vii) The individual in charge of the ICS shall
        designate a safety official, who is knowledge-
        able in the operations being implemented at
        the emergency response site, with specific
        responsibility to identify and evaluate hazards
        and to provide direction with respect to the
        safety of operations for the emergency at
        hand.

        (viii) When activities are judged by the safety
        official to be an IDLH condition and/or to
        involve an imminent danger condition, the
        safety official shall have the authority to alter,
        suspend, or terminate those activities. The
        safety official shall immediately inform the
        individual in charge of the ICS of any actions
        needed to be taken to correct these hazards at
        an emergency scene.

        (ix) After  emergency operations have termi-
        nated, the individual  in charge of the ICS
        shall implement appropriate decontamination
        procedures.

        (x) When deemed necessary for meeting the
        tasks at hand, approved self-contained com-
        pressed air breathing apparatus may be used
        with approved cylinders from other approved
        self-contained compressed air breathing appa-
        ratus provided that such cylinders are of the
        same capacity and pressure rating. All com-
        pressed air cylinders used with self-contained
        breathing  apparatus shall meet U.S. Depart-
        ment of Transportation and National Institute
        for Occupational Safety and Health criteria.

       (4) Skilled support personnel. Personnel, not nec-
       essarily an employer's own employees, who are
       skilled in the operation of certain equipment,
       such as mechanized earth moving or digging
       equipment or crane and hoisting equipment, and
       who are needed temporarily to perform immedi-
       ate emergency support work that cannot  reason-
       ably be  performed  in a timely fashion by an
       employer's own employees, and who will be or
       may be exposed to the hazards at an emergency
       response scene, are not required to meet the
       training required  in this paragraph for  the
       employer's regular employees. However, these
       personnel shall be given an initial briefing at the
       site  prior   to  their  participation  in  any
       emergency  response. The initial briefing shall
Change 51
330.21
  24
m0.120(q)U)

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I910.120(q)(4)
                                                           OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
 include instruction in the wearing of appropriate
 personal protective equipment, what chemical
 hazards are involved, and what duties are to be
 performed. All other appropriate safety and
 health precautions provided to the employer's
 own employees shall be used to assure the
 safety and health of these personnel.

 (5) Specialist employees. Employees who, in the
 course of their regular job duties, work with and
 are trained in the hazards of specific hazardous
 substances,  and  who will be called  upon to
 provide technical advice or assistance at a haz-
 ardous substance release incident to the individ-
 ual  in  charge,  shall  receive  training  or
 demonstrate competency in the area of their
 specialization annually.

 (6) Training. Training shall be based on the
 duties and function to be performed by each
 responder of an emergency response organiza-
 tion. The skill and knowledge levels required for
 all new responders, those hired after the effec-
 tive date of this standard, shall be conveyed to
 them through training before they are permitted
 to take part in actual emergency operations on
 an incident. Employees who participate, or are
 expected to participate, in emergency response,
 shall be given training in accordance  with the
 following paragraphs:

   (i)  First  responder awareness level.  First
   responders at the awareness  level are individ-
   uals who are likely to witness or discover  a
   hazardous substance  release and who have
   been  trained  to  initiate  an  e.mergency
   response sequence by notifying the proper
   authorities of the release. They would take no
   further action beyond notifying the authorities
   of the release. First responders at the aware-
   ness  level shall have  sufficient training to
   have had sufficient experience to objectively
   demonstrate competency in the following
   areas.

      (a) An understanding of  what hazardous
      materials are, and the risks associated with
      them in an incident.

      (b) An understanding of the potential out-
      comes associated with an emergency cre-
      ated when hazardous materials are  present.

      (c) The ability to recognize the presence of
      hazardous materials in an emergency.
          (d) The ability to identify the hazardous
          materials, if possible.

          (e) An understanding of the role of the first
          responder  awareness individual in  the
          employer's emergency response plan includ-
          ing the site security and control and the
          U.S.  Department  of  Transportation's
          Emergency Response Guidebook.

          (f) The ability to realize the need for addi-
          tional resources, and to make appropriate
          notifications to the communication center.

        (ii) First responder operations level. First
        responders at the operations level are individ-
        uals who respond to releases or  potential
        releases of hazardous substances as part of
        the initial response to  the site for the purpose
        of protecting nearby persons, property, or the
        environment  from the effects of the release.
        They are trained to respond in a  defensive
        fashion without actually trying to stop  the
        release. Their  function is to contain  the
        release from a safe distance, keep it from
        spreading, and prevent exposures. First
        responders at the operational level  shall have
        received at least eight hours of training or
        have had sufficient experience to objectively
        demonstrate competency in the  following
        areas in addition to those listed for the aware-
        ness level and the employer shall so certify:

           (a) Knowledge of the basic hazard and risk
           assessment techniques.

           (b) Know how to select and use proper per-
           sonal protective equipment provided to the
           first responder operational level.

           (c) An understanding of basic hazardous
           materials terms.

           (d) Know how to perform basic control, con-
           tainment and/or confinement operations
           within the  capabilities of the resources and
           personal protective equipment available
           with their unit.

           (e) Know how to implement basic decon-
           tamination  procedures.

           (f) An understanding of the relevant stand-
           ard operating procedures and termination
           procedures.
1910.120(q)(h)ui)(0
330.22
   25
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OCCUPATIONAL SAFETY AND HEALTH
                                                            STANDARDS AND INTERPRETATIONS
   (iii) Hazardous materials technician. Hazardous
   materials technicians are individuals who
   respond to releases or potential releases for
   the purpose of stopping the release. They
   assume a  more aggressive role than a first
   responder at the operations level in that they
   will approach the point of release in order to
   plug, patch or otherwise stop the release of a
   hazardous substance. Hazardous materials
   technicians shall have received at- least 24
   hours of training equal to the first responder
   operations level and in addition have compe-
   tency in the following areas and the employer
   shall so certify:

     (a) Know how to implement the employer's
     emergency response plan.

     (b) Know the classification, identification
     and  verification of known and  unknown
     materials by using field survey instruments
     and equipment.

     (c) Be able to function within an assigned
     role  in the Incident Command System.

     (d) Know how to select and use proper spe-
     cialized  chemical personal protective equip-
     ment provided to the hazardous materials
     technician.

     (e) Understand hazard and risk assessment
     techniques.

     (f) Be able to perform advance control, con-
     tainment, and/or confinement operations
     within the capabilities of the resources and
     personal protective equipment available
     with the unit.

     (g)  Understand  and implement  decon-
     tamination procedures.

     (h) Understand termination procedures.

     (i) Understand basic chemical and tox-
     icological terminology and behavior.

    (iv)  Hazardous materials specialist.  Hazardous
    materials specialists are  individuals who
    respond  with and provide  support to haz-
    ardous materials technicians. Their duties
    parallel those of the hazardous materials tech-
    nician, however, those duties require a more
    directed or specific knowledge of the various
    substances they may be called upon  to con-
         tain. The hazardous materials specialist would
         also act as the site liaison with Federal, state,
         local  and other government authorities in
         regards to site activities. Hazardous materials
         specialists shall have received at least 24
         hours of training equal to the technician level
         and in addition have competency in the follow-
         ing areas and the employer shall so certify:

           (a) Know how to implement  the local
           emergency response plan.

           (b) Understand classification, identification
           and verification of known  and unknown
           materials by using advanced survey instru-
           ments and equipment.

           (c) Know of the state emergency response
           plan.

           (d) Be able to select and use roper spe-
           cialized chemical personal protective equip-
           ment provided to the hazardous materials
           specialist.

           (e) Understand in-depth hazard and risk
           techniques.

           (f) Be able to perform specialized control,
           containment, and/or confinement operations
           within the capabilities of the resources and
           personal protective equipment available.

           (g) Be able to determine  and implement
           decontamination procedures.

           (h) Have the ability to develop a site safety
           and control plan.

           (i) Understand chemical, radiological and
           toxicological terminology and behavior.

         (v) On scene incident commander.  Incident
         commanders, who will assume control of the
         incident scene beyond the first responder
         awareness level, shall receive at least 24
         hours of training equal to the first responder
         operations level and in addition have compe-
         tency in the  following areas and the employer
         shall so certify:

            (a) Know  and be  able to implement the
            employer's incident command system.

            (b) Know how to implement the employer's
            emergency response plan.
 Change SI
330.23
  26
1910.120(q)(6)(v)(b)

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1910.120
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 OCCUPATIONAL SAFETY AND HEALTH
                                           1910.120 Appendix A
                                                                              STANDARDS AND INTERPRETATIONS
encapsulating chemical protective suit material, seams, and clo-
sures to maintain a fixed positive pressure. The results of this
practice allow the gas tight integrity of a totally-encapsulating
chemical protective suit to be evaluated.

  1.2 Resistance of the suit materials to permeation, penetra-
tion, and degradation by specific hazardous substances is not
determined by this test method.

  2.0—Definition of terms

  2.1 "Totally-encapsulated chemical  protective suit (TECP
suit)" means a full body garment which is constructed of protec-
tive clothing materials; covers the wearer's torso, head, arms,
legs and respirator; may cover the wearer's hands and feet with
tightly attached gloves and boots; completely encloses the
wearer and respirator by itself or in combination with the
wearer's gloves and boots.

  2.2 "Protective clothing material"  means any material or
combination of materials used in an item of clothing for the pur-
pose of isolating parts of the  body from direct contact with  a
potentially hazardous liquid or gaseous chemicals.

  2.3 "Gas tight" means, for the purpose of this test method,
the limited flow of a gas under pressure from the inside of a
TECP suit to atmosphere at a prescribed pressure and  time
interval.

  3.0—Summary of test method

  3.1 The TECP suit is visually inspected and modified  for the
test. The test apparatus is attached to the suit to permit infla-
tion to the pre-test suit expansion pressure for removal of suit
wrinkles and creases. The pressure is lowered to the test pres-
sure and monitored for three minutes. If the pressure drop  is
excessive, the TECP suit fails the test and is removed  from
service. The test is repeated after leak location and repair.

  4.0—Required Supplies

  4.1 Source of compressed air.

  4.2  Test apparatus for suit testing,  including a pressure
 measurement device with a sensitivity of at least Vi inch water
 gauge.

  4.3  Vent valve closure plugs or sealing  tape.

  4.4  Soapy water solution and soft brush.

   4.5  Stop watch or appropriate timing device.

   5.0—Safety Precautions

   5.1  Care shall be taken to provide the correct pressure safety
 devices required for the source of compressed air used.

   6.0—Test Procedure

   6.1 Prior to each test,  the tester shall perform a visual
 inspection of the suit. Check  the suit for seam integrity by vis-
 ually  examining the seams and gently  pulling on the seams.
 Ensure that all air supply lines, fittings, visor, zippers, and
 valves are secure and show no signs of deterioration
        6.1.1 Seal off the vent valves along with any other normal
      inlet or exhaust points (such as umbilical air line fittings or face
      piece opening) with tape or other appropriate means (caps,
      plugs, fixture, etc.).  Care should be exercised in the sealing
      process not to damage any of the suit components.

        6.1.2 Close all closure assemblies.

        6.1.3  Prepare the suit  for  inflation by  providing  an
      improvised connection point on the suit for connecting an air-
      line. Attach the pressure test apparatus to the suit to permit
      suit inflation from a compressed air source equipped with a
      pressure indicating regulator. The leak tightness of the pres-
      sure test apparatus should be tested before and after each  test
      by closing off the end of the tubing attached to  the suit and
      assuring a pressure of three inches water gauge for three min-
      utes can be maintained. If a component is removed for the test,
      that component shall be replaced and a second test conducted
      with another component removed to permit  a complete test of
      the ensemble.

        6.1.4 The pre-test expansion pressure (A) and the suit test
      pressure (B) shall be supplied by the suit manufacturer, but in
      no case shall they be less than: (A)=three inches water gauge;
      and (B) = two inches water gauge. The ending suit pressure (C)
      shall be no less than 80  percent of the test pressure (B);  i.e.,
      the pressure drop shall not exceed 20 percent of the test pres-
      sure (B).

        6.1.5 Inflate the suit until the pressure inside is equal to
      pressure (A), the pre-test expansion suit pressure. Allow at
      least one minute to fill out the wrinkles in the suit. Release suf-
      ficient air to reduce the suit pressure to pressure (B), the suit
      test pressure. Begin timing. At the end of three minutes, rec-
      ord the suit pressure as  pressure (C), the ending suit pressure.
      The difference between the suit test pressure and the ending
      suit test pressure (B-C) shall be defined as the suit pressure
      drop.

         6.1.6 If the  suit pressure drop is more than 20 percent of the
      suit test pressure (B) during the three-minute test period, the
      suit fails the test and shall be removed from  service.

         7.0—Retest Procedure

         7.1 If the suit fails the test check for leaks by inflating the
      suit to pressure (A) and brushing or wiping the entire suit
      (including seams, closures, lens gaskets, glove-to-sleeve joints,
      etc.) with a mild soap and water solution. Observe the suit for
      the formation of soap bubbles, which is an indication of a leak.
      Repair all identified leaks.

         7.2 Retest the TECP suit as outlined in Test procedure 6.0.

         8.0—Report

         8.1 Each TECP suit tested by this practice shall have the fol-
      lowing information recorded:

         8.1.1 Unique identification number, identifying brand name,
       date of purchase, material of construction, and unique fit fea-
       tures, e.g., special breathing apparatus.


         8.1.2 The actual values for test pressures (A), (B), and (C)
       shall be recorded along with the specific observation times.  If
       the ending pressure (C) is less than 80 percent of the test pres-
 Change 51
330.25
   28
1910.120 Appendix A

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1910.120 Appendix A
                                                                           OCCUPATIONAL SAFETY AXD HEALTH
STANDARDS AND INTERPRETATIONS
sure (B), the suit shall be identified as failing the test. When
possible, the specific leak location shall be identified in the test
records. Retest pressure data shall be recorded as an additional
test.

  8.1.3 The source of the test apparatus used shall be identified
and the sensitivity of the pressure gauge shall be recorded.

  8.1.4 Records shall  be kept for each pressure test even if
repairs are being made at the test location.

Caution

  Visually inspect all parts of the suit to be sure they are posi-
tioned correctly and secured tightly before putting the suit
back into service. Special care should be taken to examine each
exhaust valve to make sure it is not blocked.

  Care should also be exercised to assure that the inside and
outside of the suit is completely dry before it is put into stor-
age.
B. Totally-encapsulating chemical protective suit qualitative
leak test.
  1.0—Scope

  1.1 This practice semi-qualitatively tests gas tight totally-
encapsulating chemical protective suit integrity by detecting
inward leakage of ammonia vapor. Since no modifications are
made to the suit to carry out this test, the results from this
practice provide a realistic test for the integrity of the entire
suit.

  1.2 Resistance of the suit materials to permeation, penetra-
tion, and degradation is not determined by this test method.
ASTM test methods are available to test suit materials for
these characteristics and the tests are usually conducted by the
manufacturers of the suits.

  2.0—Definition of terms

  2.1 'Totally-encapsulated chemical protective suit (TECP
suit) means a full body garment which is constructed of protec-
tive clothing materials; covers the wearer's torso, head, arms,
legs and respirator; may cover the wearer's hands and feet with
tightly attached gloves and boots; completely encloses the
wearer and respirator by itself or in combination with the
wearer's gloves, and boots.

  2.2 "Protective clothing material" means any material or
combination of materials used in an item of clothing for the pur-
pose of isolating parts of the body from direct contact with a
potentially hazardous liquid or gaseous chemicals.

  2.3 "Gas tight" means, for the purpose of this test method,
the limited flow of a gas under pressure from the inside of a
TECP suit to atmosphere at a prescribed  pressure and  time
interval.

  2.4 "Intrusion Coefficient" means a number expressing the
level of protection provided by a gas tight totally-encapsulating
chemical protective suit. The intrusion coefficient is calculated
by dividing the test room challenge agent concentration by the
      concentration of challenge agent found inside the suit. The
      accuracy of the intrusion coefficient is dependent on the chal-
      lenge agent monitoring methods. The larger the intrusion
      coefficient the greater the protection  provided by the TECP
      suit.

        3.0—Summary of recommended practice

        3.1 The volume of concentrated aqueous ammonia solution
      (ammonia hydroxide NH,OH) required to generate the test
      atmosphere is determined using the directions outlined in 6.1.
      The suit is donned by a person wearing the appropriate respira-
      tory equipment (either a positive pressure self-contained
      breathing apparatus or a positive pressure supplied air respira-
      tor) and worn inside  the enclosed test  room. The concentrated
      aqueous ammonia solution is taken by the suited individual into
      the test room and poured into an open plastic pan. A two-
      minute evaporation period is observed before the test room
      concentration is measured, using a high range ammonia  length
      of stain detector tube. When the ammonia vapor reaches a con-
      centration of between 1000 and 1200 ppm, the suited individual
      starts a standardized exercise protocol to stress and flex the
      suit. After this protocol is completed, the test room concentra-
      tion is measured again.  The suited individual exits the test
      room and his stand-by person measures the ammonia con-
      centration inside the suit using a low range ammonia length of
      stain detector tube or other more sensitive ammonia detector.
      A stand-by person is required to observe the test individual
      during the test procedure; aid the person in donning and doff-
      ing the TECP suit; and monitor the suit interior. The intrusion
      coefficient of the suit can be calculated by dividing the average
      test area concentration by the interior suit concentration. A
      colorimetric ammonia indicator strip  of bromophenol blue or
      equivalent is  placed on the inside  of the suit face piece lens so
      that the suited individual is able to detect a color change and
      know if the suit has a significant leak. If a color change is
      observed the individual shall leave the test room immediately.

        4.0—Required supplies

        4.1 A supply of concentrated aqueous (58 percent ammonium
      hydroxide by weight).

        4.2 A supply of bromophenol/blue indicating paper or equiv-
      alent, sensitive to 5-10 ppm ammonia or greater over  a two-
      minute period of exposure. [pH 3.0 (yellow) to pH 4.6 (blue)]

        4.3 A supply of high range (0.5-10 volume percent) and low
      range (5-700 ppm) detector tubes for  ammonia and the corre-
      sponding sampling pump. More sensitive ammonia detectors
      can be substituted for the low range detector tubes to improve
      the sensitivity of this practice.

        4.4 A shallow plastic pan (PVC) at least 12":14":1" and a half
      pint plastic container (PVC) with tightly closing lid.

        4.5 A graduated cylinder or other volumetric  measuring
      device of at least 50 milliliters in volume with an accuracy of at
      least ± 1 milliliters.

        5.0—Safety precautions

        5.1 Concentrated aqueous ammonium hydroxide. NH,OH. is
      a corrosive volatile liquid requiring eye, skin, and  respiratory
      protection. The person  conducting the test shall review the
      MSDS for aqueous ammonia.
 1910.120 Appendix A
330.26
     29
                                                                                                            Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                           1910.120 Appendix A
                                                                              STANDARDS AND INTERPRETATIONS
  5.2 Since the established permissible exposure limit for
ammonia is 50 ppm, only persons wearing a positive pressure
self-contained breathing apparatus or a positive pressure sup-
plied air respirator shall be in the chamber. Normally only the
person wearing the totally-encapsulating suit will be inside the
chamber. A stand-by person shall have a positive pressure self-
contained breathing apparatus, or a  positive pressure supplied
air respirator available to enter the test area should the suited
individual need assistance.

  5.3 A method to monitor the suited individual must be used
during this test. Visual contact is the simplest but other
methods using communication devices are acceptable.

  5.4 The test room shall be large enough to allow the exercise
protocol to  be carried out and then to be ventilated to allow for
easy exhaust of the ammonia test atmosphere after the test(s)
are completed.

  5.5 Individuals shall be medically screened  for the use of res-
piratory protection and checked for allergies to ammonia before
participating in this test procedure.

  6.0—Test procedure

  6.1.1 Measure the test area to the nearest foot and calculate
its volume  in cubic feet. Multiply the test area volume by 0.2
milliliters of concentrated aqueous ammonia  solution per cubic
foot of test area volume to determine the approximate volume
of concentrated aqueous ammonia required to generate 1000
ppm in the test area.

  6.1.2 Measure this volume from the supply of concentrated
aqueous ammonia and place it into a closed pfastic container.

  fi.1.3 Place the container, several high range ammonia detec-
tor tubes, and the pump in the clean test pan and locate it near
the test area entry door so that the suited individual has easy
access to these supplies.

  6.2.1 In  a non-contaminated atmosphere,  open a pre-sealed
ammonia indicator strip and fasten  one  end  of the strip to the
inside of the suit face shield lens where it can be seen by the
wearer. Moisten the indicator strip with distilled  water. Care
shall be taken not  to contaminate the detector part of the
indicator paper by touching it.  A small piece  of masking tape or
equivalent should be used to attach the indicator strip to the
interior of the suit face shield.

   ti.2.2 If problems are encountered with this method of attach-
 ment, the  indicator  strip can be attached to the outside of the
 respirator  face piece lens being used di'ring  the test.

   6.3 Don  the respiratory protective device normally used with
 the suit, and then don the TECP suit to be tested. Check to be
 sure all openings which are intended  to be sealed (zippers.
 cloves, etc.) are completely sealed. DO NOT. however, plug off
 any venting valves.

   H.4 Step into the  enclosed test room such as a  closet, bath-
 room, or test booth,  equipped with an exhaust  fan. No air
 should be exhausted from the chamber during the test because
 this will dilute the ammonia challenge concentrations.

   li.5 Open the container with the premeasured volume of con-
 centrated aqueous ammonia within the enclosed test room, and
     pour the liquid into the empty plastic test pan. Wait two min-
     utes to allow for adequate  volatilization of the concentrated
     aqueous ammonia. A small mixing fan can be used near the
     evaporation pan  to increase the evaporation rate of the
     ammonia solution.

       6.6 After two minutes a determination of the ammonia con-
     centration within the chamber should be made using the high
     range colorimetric detector tube. A concentration of 1000 ppm
     ammonia or greater shall be generated before the exercises are
     started.

       6.7 To test the integrity of the suit the following four minute
     exercise protocol should be followed:

       6.7.1 Raising the arms above the head with at least 15 raising
     motions completed in one minute.

       6.7.2 Walking in place for one minute with at least 15 raising
     motions of each leg in a one-minute period.

       6.7.3 Touching the toes with at least  10 complete motions of
     the arms from above the head  to touching of the toes in a one-
     minute period.

        6.7.4 Knee bends with at least 10 complete standing and
     squatting  motions in a one-minute period.

        6.8 If at any time during the test the colorimetric indicating
      paper should change colors, the test should be stopped and sec-
      tion 6.10 and 6.12 initiated (See H4.2).

        6.9 After completion of the  test exercise, the test area con-
      centration should be measured again using the high range col-
      orimetric  detector tube.
        6.10 Exit the test area.

        6.11 The opening created by the suit zipper or other appro-
      priate suit penetration  should be used  to determine  the
      ammonia concentration in  the suit with the low range length of
      stain detector tube or other ammonia monitor. The internal
      TECP suit air should  be sampled far enough from the enclosed
      test area to prevent a false ammonia reading.


        6.12 After completion of the measurement of the suit interior
      ammonia concentration the test is concluded and the suit is
      doffed and the respirator removed.


        6.13 The ventilating fan for the test room should be turned
      on and allowed to run for  enough time to remove the ammonia
      gas. The fan shall be vented to the outside of the building.

        6.14 Any detectable ammonia in the suit interior (five ppm
      ammonia (NHn) or more for the length of stain detector tube)
      indicates that the suit has failed the test. When other ammonia
      detectors are  used a lower level of detection is possible, and it
      should be specified as the  pass/fail criteria.

        6.15 By following this test method, an intrusion coefficient of
      approximately 200 or more can be measured with the suit  in a
      completely operational condition. If the intrusion coefficient is
      200 or more,  then the suit is suitable for emergency response
      and field  use.
 Change 51
330.27

   30
1910.120 Appendix A

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1910.120 Appendix A
                                                                          OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
  7.0—Retest procedures

  7.1 If the suit fails this test, check for leaks by following the
pressure test in test A above.

  7.2 Retest the TECP suit as outlined in the test procedure
6.0.

  8.0—Report

  8.1 Each gas tight  totally-encapsulating chemical protective
suit tested by this practice shall have the following information
recorded.

  8.1.1 Unique identification number,  identifying brand name,
date of purchase, material of construction, and unique suit fea-
tures; e.g., special breathing apparatus.

  8.1.2 General description of test room used for test.

  8.1.3 Brand name and purchase  date of ammonia detector
strips and color change data.

  8.1.4 Brand name, sampling range, and expiration date of the
length of stain ammonia detector tubes. The brand name and
model of the sampling pump should also be recorded.  If another
type of ammonia detector is used, it should be identified along
with its minimum detection limit for ammonia.

  8.1.5 Actual test results  shall list the two test area con-
centrations, their average, the interior suit concentration, and
the calculated intrusion coefficient. Retest data shall be
recorded  as an additional test.

  8.2 The evaluation of the data shall be specified as "suit
passed" or "suit failed," and the date of the test. Any detect-
able ammonia (five ppm or greater for the length of stain detec-
tor tube) in the suit interior indicates the suit has  failed this
test. When other ammonia detectors are used, a lower level of
detection is possible and it should be specified as the pass fail
criteria.

Caution

  Visually inspect all  parts of the suit to be sure they are posi-
tioned correctly and secured tightly before putting the suit
back into service. Special care should be taken to examine each
exhaust valve to make sure it is not blocked.

  Care should also be exercised to  assure that the  inside and
outside of the  suit is  completely dry before it is put into stor-
age.
Appendix B—General Description and Discussion of the
Levels of Protection and Protective Gear
  This appendix sets forth information about personal protec-
tive equipment (PPE) protection levels which may be used to
assist employers in complying with the PPE requirements of
this section.
        As required by the standard, PPE must be selected which
       will protect employees from the specific hazards which they are
       likely to encounter during their work on-site.

        Selection of the appropriate PPE is a complex process which
       should take into consideration a variety of factors.  Key factors
       involved in this process are identification of the hazards, or sus-
       pected hazards; their routes of potential hazard to employees
       (inhalation, skin absorption, ingestion, and eye or skin contact);
       and the performance of the PPE materials (and seams) in
       providing a barrier to these hazards. The amount of protection
       provided by PPE is material-hazard specific. That is, protective
       equipment materials will protect well against some hazardous
       substances and poorly, or not at all, against others. In many
       instances, protective equipment materials cannot be found
       which will provide continuous protection from the particular
       hazardous substance. In these cases the breakthrough time of
       the protective material should exceed the work durations, or
       the exposure after breakthrough may not pose a hazardous
       level.

        Other factors in this selection process to be considered are
       matching the PPE to the employee's work requirements and
       task-specific conditions. The durability of PPE materials, such
       as tear strength and seam strength, should be considered in
       relation to the employee's tasks. The effects of PPE in  relation
       to heat stress and task duration are a factor in selecting and
       using PPE. In  some cases layers of PPE may be necessary to
       provide sufficient protection, or to protect expensive PPE
       inner garments, suits or equipment.

        The more that is known about the hazards at the site, the
       easier the job of PPE selection becomes. As more information
       about the hazards and conditions at the site becomes available,
       the site supervisor can make decisions to up-grade or down-
       grade the level of PPE protection to match the tasks at hand.

        The following are guidelines which an employer can use to
       begin the selection of the appropriate PPE. As noted above,
       the site information may suggest the use of combinations of
       PPE selected from the different protection levels (i.e., A,  B, C,
       or D) as being more suitable to the hazards of the work. It
       should be cautioned that the listing below does not fully
       address the performance of the specific PPE material in rela-
       tion to the specific hazards at the job site, and that PPE selec-
       tion, evaluation and re-selection is an ongoing process until
       sufficient information about the hazards and PPE performance
       is obtained.

        Part A. Personal  protective equipment is divided into four
       categories based on the degree of protection afforded. (See
       Part B of this appendix for further explanation of Levels  A, B,
       C, and D  hazards.)

         I. Level A—To  be selected when the greatest level of skin,
       respiratory, and eye protection is required.

        The following constitute  Level A equipment; it may be used
       as appropriate:

         1.  Positive pressure, full  face-piece self-contained breathing
       apparatus (SCBA), or positive pressure supplied air respirator
       with escape SCBA. approved by the National Institute for
       Occupational Safety and Health (NIOSH).

         2. Totally-encapsulating chemical-protective suit.
 1910.120 Appendix B
330.28

     31
Change 51

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 OCCUPATIONAL SAFETY AND HEALTH
                                                                                                   1910.120 Appendix B
                                                                              STANDARDS AND INTERPRETATION'S
  3. Coveralls.1

  •I. Long underwear.1

  5. Gloves, outer, chemical-resistant.

  6. Gloves, inner, chemical-resistant.

  7. Boots, chemical-resistant, steel toe and shank.

  8. Hard hat (under suit).1

  9. Disposable protective suit, gloves and boots (depending on
suit construction, may be worn over totally-encapsulating suit).

  II. Level B—The highest level of respiratory protection is
necessary but a lesser level of skin protection is needed.

  The following constitute Level B equipment; it  may be used
as appropriate.

  1. Positive pressure, full-facepiece self-contained breathing
apparatus (SCBA), or positive pressure supplied air respirator
with escape SCBA (NIOSH approved).

  2. Hooded chemical-resistant clothing (overalls and long-
sleeved jacket; coveralls; one or two-piece chemical-splash suit;
disposable chemical-resistant overalls).

  3. Coveralls.1

  4. Gloves, outer, chemical-resistant.

  5. Gloves, inner, chemical-resistant.

  6. Boots, outer, chemical-resistant steel toe and shank.

  7. Boot-covers, outer, chemical-resistant (disposable).1

  8. Hard hat.1

  9. [Reserved]

   10. Face shield.1

   III. Level C—The concentration(s) and type(s) of airborne
substance(s) is known and the  criteria for using air purifying
respirators are met.

  The following constitute Level C equipment; it may be used
as appropriate.

   1. Full-face or half-mask, air purifying respirators (NIOSH
approved).

  2. Hooded chemical-resistant clothing (overalls;  two-piece
chemical-splash suit; disposable chemical-resistant overalls).

  3. Coveralls."

  •1. Gloves, outer, chemical-resistant.
   'Optional, as applicable.
 Change 51
        5. Gloves, inner, chemical-resistant.

        6. Boots (outer), chemical-resistant steel toe and shank.1

        7. Boot-covers, outer, chemical-resistant (disposable).1

        8. Hard hat.1

        9. Escape mask.1

        10. Face shield.1

        IV. Level D—A work uniform affording minimal protection.
      used for nuisance contamination only.

        The following constitute Level D equipment; it may be used
      as appropriate:

        1. Coveralls.

        2. Gloves.1

        3. Boots/shoes, chemical-resistant steel toe and shank.

        4. Boots, outer, chemical-resistant (disposable).1

        5. Safety glasses or chemical splash goggles*.

        6. Hard hat.1

        7. Escape mask.1

        8. Face shield.1


        Part B. The types of hazards for which levels A, B, C, and D
      protection are appropriate are described below:

        1. Level A—Level A protection should be used when:

        1. The hazardous substance has been identified and requires
      the highest level  of protection for skin, eyes, and the respira-
      tory system  based on either the measured (or potential for)
      high concentration of atmospheric vapors, gases, or particu-
      lates; or the  site  operations and work functions involve a high
      potential for splash, immersion, or exposure to unexpected
      vapors, gases, or participates of materials that are harmful to
      skin or capable of being absorbed through the skin:

        2. Substances with a high degree of hazard to the skin  are
      known or suspected  to be present, and skin contact is possible;
         3. Operations are being conducted in confined, poorly venti-
       lated areas, and the absence of conditions requiring Level A
       have not yet been determined.

         II. Level B—Level B protection should be used when:

         1. The type and atmospheric concentration of substances
       have been  identified and require a high level of respiratory pro-
       tection, but less skin protection;

         2. The atmosphere contains less than 19.5 percent oxygen: or

         3. The presence of incompletely  identified vapors or gases is
       indicated by a direct-reading organic vapor detection instru-
       ment, but vapors and gases are not suspected of containing
       high levels of chemicals harmful to skin or capable of being
       absorbed through the skin.
330.29

  32
1910.120 Appendix B

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 1910.120 Appendix B
                                                                           OCCUPATIONAL SAFETY AND HEALTH
 STANDARDS AND INTERPRETATIONS
  Note: This involves atmospheres with IDLH concentrations
of specific substances that present severe inhalation hazards
and that do not represent a severe skin hazard: or that do not
meet the criteria for use of air-purifying respirators.

  III. Level C—Level C protection should be used when:

  1. The atmospheric contaminants,  liquid splashes, or other
direct contact will not adversely affect or be  absorbed through
any exposed skin:

  2. The types of air contaminants have  been identified, con-
centrations measured, and an air-purifying respirator is avail-
able that can remove the contaminants; and

  3. All criteria for the use of air-purifying respirators are met.

  IV. Level D—Level D protection should be used when:

  1. The atmosphere contains no known hazard; and

  2. Work functions preclude splashes, immersion,  or the
potential for unexpected inhalation of or contact with hazardous
levels of any chemicals.

  Note: As stated before, combinations of personal protective
equipment other than those described for Levels A, B,  C. and
D protection may be more appropriate and may be used to
provide the proper level of protection.

  As an aid in selecting suitable chemical protective clothing, it
should be noted that the National Fire Protection Association is
developing standards on chemical protective clothing. These
standards are currently undergoing public review prior to
adoption, including:

N'FPA 1991—Standard on Vapor-Protective Suits for  Haz-
  ardous  Chemical  Emergencies (EPA Level  A Protective
  Clothing)

NFPA 1991—Standard on Liquid Splash-Protective Suits for
  Hazardous Chemical Emergencies  (EPA Level B Protective
  Clothing.)

NFPA 1993—Standard on Liquid Splash-Prptectwe Suits for
  Non-emergency, Non-flammable Hazardous Chemical Situa-
  tions (EPA Level  B Protective Clothing)

  These standards would apply documentation and perform-
ance requirements to the manufacture of chemical protective
suits. Chemical protective suits  meeting these requirements
would be  labelled as compliant with  the appropriate standard.
When these standards are adopted by the National Fire  Protec-
tion Association, it  is recommended that chemical protective
suits  which meet these standards be  used.
 Appendix C—Compliance Guidelines


   1. Occupational Safety and Health Program.  Each haz-
 ardous waste site clean-up effort will require an occupational
 safety and health program headed by the site coordinator or
 the employer's representative. The purpose of the program will
 be the protection of employees at the site and will be an exten-
 sion of the employer's overall safety and health program. The
 program will need to be developed before work begins on the
 site and implemented as work proceeds as stated in paragraph
 (b). The program is to facilitate coordination and communica-
      tion of safety and health issues among personnel responsible for
      the various activities which will take place at the site. It will
      provide the overall means for planning and implementing the
      needed safety and health training and job orientation ot
      employees who will be working at the site. The program will
      provide the means for identifying and controlling worksite haz-
      ards and the means for monitoring program effectiveness. The
      program will need to cover the responsibilities and authority of
      the site coordinator or the employer's manager on the site for
      the safety and health of employees at the site, and the relation-
      ships with contractors or support services  as  to what each
      employer's safety and health responsibilities  are for their
      employees on the site. Each contractor on the  site needs to
      have its own safety and health program so structured that it
      will smoothly interface with the program of the site coordinator
      or principal contractor.

        Also those  employers involved with treating, storing or dis-
      posal of hazardous waste as covered in paragraph (p) must have
      implemented  a safety and health program for their employees.
      This program is to include the hazard communication program
      required in paragraph (p)(D and the training  required in para-
      graphs (p)(7) and (p)(8) as parts of the employers comprehen-
      sive overall safety and health program. This program is to be in
      writing.

         Each site or workplace safety and health program will need
      to include the following: (1) Policy statements of the line of
      authority and accountability for implementing the program, the
      objectives of the program and the role of the site safety and
      health supervisor or manager and staff; (2) means or methods
      for the development of procedures for identifying and controll-
      ing workplace hazards at the site; (3) means or methods for the
      development and communication to employees of the various
      plans, work rules, standard operating procedures and practices
      that pertain to individual employees and supervisors; (4) means
      for the training of supervisors and employees to develop the
      needed skills and knowledge to perform their work in a safe
      and healthful manner; (5) means to anticipate and prepare for
      emergency situations; and (6) means for obtaining information
      feedback to aid in evaluating the program and  for improving
      the effectiveness  of the program.  The management and
      employees should be trying continually to improve the effec-
      tiveness of the program thereby enhancing the protection being
      afforded those working on the site.

         Accidents on the site or workplace should be investigated to
       provide information on how such occurrences can be avoided in
      the future. When injuries or illnesses occur on the site or work-
      place, they will need to be investigated to determine what
      needs to be done to prevent this incident from occurring again.
      Such information will need to be used as feedback on the effec-
       tiveness of the program and the information turned into posi-
       tive steps to prevent any reoccurrence.  Receipt of employee
       suggestions or complaints relating to safety and health issues
       involved with site  or workplace activities is also a feedback
       mechanism that can be used effectively to improve the program
       and may serve in part as an evaluative tool(s).

         For the development and implementation  of the program to
       be the most  effective, professional  safety and health personnel
       should be used. Certified Safety Professionals, Board Certified
       Industrial Hygienists or Registered Professional Safety Engi-
       neers are good examples of professional stature for safety and
       health managers who will administer the employer's program

         2. Training. The training programs for employees subject to
       the requirements  of paragraph (e) of this standard should
       address: the  safety and health hazards employees should expect
 1910.120 Appendix C
330.30

      33
Change 51

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OCCUPATIONAL SAFETY AND HEALTH
                                                                                                1910.120 Appendix C
                                                                           STANDARDS AND INTERPRETATIONS
to find on hazardous waste clean-up sites; what control meas-
ures or techniques are effective for those hazards; what
monitoring procedures are effective in characterizing exposure
levels; what makes an effective employer's safety and health
program; what a site safety and health plan should include;
hands on training with personal protective equipment and
clothing they  may be expected to use; the contents of the
OSHA standard relevant to the employee's duties and function;
and, employee's responsibilities under OSHA and other regula-
tions. Supervisors will need training in their responsibilities
under the safety and health program and its subject areas such
as the spill containment program, the personal protective
equipment program, the medical surveillance program, the
emergency response plan and other areas.

  The training; programs for employees subject to the require-
ments of paragraph (p) of this standard should address: the
employers  safety and health program elements impacting
employees; the hazard communication program; the medical
surveillance program; the hazards and the controls for such
hazards that employees need to know for their job duties and
functions. All require annual refresher training.

  The training programs for employees covered by the require-
ments of paragraph (q)  of this standard should address those
competencies required for the various levels of response such
as: the hazards associated with hazardous substances; hazard
identification and awareness; notification of appropriate per-
sons;  the need for and use of personal protective equipment
including respirators; the decontamination procedures to be
used;  preplanning activities for hazardous  substance incidents
including the  emergency response plan;  company standard
operating procedures for hazardous substance  emergency
responses; the use of the incident command system and other
subjects. Hands-on training should be stressed whenever possi-
ble. Critiques  done after an incident which include an evalua-
tion of what worked and what did  not and  how could the
incident be better handled the next time  may be counted as
training time.

  For hazardous materials specialists (usually members of haz-
ardous materials  teams), the training should address the care,
use and/or testing of chemical protective clothing including
totally encapsulating suits, the medical surveillance program,
the standard operating procedures for the hazardous materials
team  including the use of plugging and patching equipment and
other subject areas.

  Officers and  leaders who may be expected to be in charge at
an incident should be fully knowledgeable of their company's
incident command system. They should know where and how to
obtain additional assistance and be familiar with the local dis-
trict's emergency response plan and the state  emergency
response plan.

  Specialist employees such as technical experts, medical
experts or environmental experts that work with hazardous
materials in their regular jobs, who may be sent to the incident
scene by the shipper, manufacturer or governmental agency to
advise and assist the person in charge of the  incident should
have training on  an  annual basis. Their training should include
the care and use of personal protective equipment including
respirators; knowledge of the incident command  system and
how they  are  to relate to it; and those areas needed  to keep
them current in their respective field as it relates to safety and
health involving specific hazardous substances.

  Those skilled  support  personnel,  such as employees who
work for public  works departments  or equipment operators
     who operate bulldozers, sand trucks, backhoes, etc., who may
     be called to the incident scene to provide emergency support
     assistance, should have at least a safety and health briefing
     before entering the area of potential or actual exposure. These
     skilled support personnel, who have not been a part of the
     emergency response plan and do not meet the training require-
     ments, should be made aware of the hazards they face and
     should be provided all necessary protective clothing and equip-
     ment  required for their tasks.

       3. Decontamination. Decontamination  procedures should be
     tailored to the specific hazards of the site, and may  vary in
     complexity and number of steps, depending on the level of haz-
     ard and the employee's exposure  to the hazard. Decontamina-
     tion procedures and  PPE decontamination methods will vary
     depending upon the specific substance, since one procedure or
     method  may not work for all substances. Evaluation of decon-
     tamination methods  and procedures should  be performed, as
     necessary, to assure that employees are not exposed  to hazards
     by re-using PPE. References in Appendix F may be used for
     guidance in establishing an effective decontamination program.
     In addition, the U.S. Coast Guard's Manual, "Policy Guidance
     for Response to Hazardous Chemical  Releases." U.S.  Depart-
     ment of Transportation, Washington, DC (COMDTINST
     M16465.30) is a good reference for establishing an effective
     decontamination program.

       4. Emergency response plans. States,  along with designated
     districts within the states, will be developing or have developed
     local  emergency response plans. These state and district plans
     should be utilized in the emergency response plans called for in
     the standard. Each employer should assure that its emergency
     response plan is compatible with the local plan. The major ref-
     erence being used to aid in developing the state and local dis-
     trict  plans is the  Hazardous Materials Emergency Planning
     Guide,  NRT—1. The current Emergency Response  Guidebook
     from  the U.S. Department of Transportation, CMA's CHEM-
     TREC  and the Fire Service Emergency Management Hand-
     book  may also be used as resources.

        Employers involved with treatment,  storage, and  disposal
     facilities for hazardous waste, which have the  required con-
     tingency plan called for by their permit, would not need to
     duplicate  the same planning elements. Those  items of the
      emergency response plan that are properly addressed in the
      contingency plan may be substituted into the emergency
      response plan required in  1910.120 or otherwise kept  together
      for employer and employee use.

        5.  Personal protective equipment programs. The purpose of
      personal protective clothing and  equipment (PPE)  is  to shield
      or isolate individuals from the chemical, physical, and biologic
      hazards that may be encountered at a hazardous substance site.

        As discussed in Appendix  B, no single  combination of protec-
      tive equipment and clothing is capable of protecting against all
      hazards. Thus PPE  should be used in conjunction  with other
      protective methods and its effectiveness evaluated periodically.

        The use of PPE can itself create significant worker hazards,
      such as heat stress, physical and psychological stress, and
      impaired vision,  mobility, and communication. For any given
      situation, equipment and clothing  should be  selected that
      provide an adequate level of protection. However, over-
      protection, as well as under-protection, can be hazardous and
      should  be avoided where possible.

        Two  basic objectives of any PPE program should be to pro-
      tect  the wearer from safety  and health hazards, and to prevent
 Change 51
330.31
1910.120 Appendix C
                                                      34

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 1910.120 Appendix C
                                                                          OCCUPATIONAL SAFETY AND HEALTH
 STANDARDS AND INTERPRETATIONS
injury to the wearer from incorrect use and/or malfunction of
the PPE. To accomplish these goals, a comprehensive PPE pro-
gram should include hazard identification, medical monitoring,
environmental surveillance, selection,  use, maintenance, and
decontamination of PPE and its associated training.

  The written  PPE  program should include policy statements,
procedures, and guidelines. Copies should be made available to
all employees, and a reference copy should be made available at
the worksite. Technical data on equipment, mainte.iance man-
uals, relevant regulations, and other essential information
should also .be collected and maintained.        - .

  6.  Incident   command  system  (ICS).   Paragraph
1910.120(q)(3)(ii) requires the implementation of an ICS. The
ICS is an organized approach to effectively control and manage
operations at an emergency incident. The individual in charge
of the ICS is the senior official responding to the incident. The
ICS is not much different than the "command post" approach
used for many  years by the fire service. During large complex
fires involving several companies and many pieces of appa-
ratus, a command post would be established. This enabled one
individual to be in charge of managing the incident, rather than
having several officers from different companies making sepa-
rate, and sometimes conflicting, decisions. The individual in
charge of the command post would delegate responsibility for
performing various tasks to subordinate officers. Additionally,
all communications were routed through the command post to
reduce the number of  radio transmissions and eliminate confu-
sion. However, strategy, tactics, and all decisions were made
by one individual.

  The ICS is a very similar system, except it is implemented
for  emergency response to all incidents, both large and small,
that involve hazardous substances.

  For a small incident, the individual in charge of the ICS may
perform many tasks of the ICS. There may not be any, or little,
delegation of tasks to  subordinates. For example, in response
to a small incident, the individual in charge of the ICS, in addi-
tion to normal command activities, may become the safety
officer and may designate only  one employee (with proper
equipment) as a backup to provide assistance if needed. OSHA
does recommend, however, that at least two employees be des-
ignated  as back-up personnel since the assistance needed may
include rescue.

  To illustrate  the operation of the ICS, the following scenario
might develop  during  a small incident, such as an overturned
tank truck with a small leak of flammable liquid.

  The first responding senior officer would implement and take
command of the ICS.  That person would size-up the incident
and determine if additional personnel and apparatus were nec-
essary;  would  determine what actions to take to control the
leak; and, determine  the proper level of personal protective
equipment. If additional assistance is not needed, the individual
in charge of the ICS would implement actions to stop and con-
trol the leak using  the fewest number of personnel that can
effectively accomplish  the tasks. The individual in charge of the
ICS then would designate himself as the safety officer and two
other employees as a back-up in case rescue may become neces-
sary. In this scenario, decontamination procedures would not
be necessary.

  A large complex incident may require many employees and
difficult,  time-consuming efforts to control. In these situations,
the individual  in charge of the ICS will want to delegate dif-
ferent tasks to subordinates in order to maintain a span of con-
trol that will  keep the number of subordinates, that  are
reporting, to a manageable level
         Delegation of task at large incidents may be by location.
       where the incident scene is divided into sectors, and subordi-
       nate officers coordinate activities within the sector that they
       have been assigned.

         Delegation of tasks can also be by function. Some of the func-
       tions that the individual in charge of the ICS may want to dele-
       gate at a large incident are: medical services; evacuation; water
       supply; resources (equipment, apparatus);  media relations;
       safety; and,  site control (integrate activities with  police for
       crowd and traffic control). Also for a large incident, the individ-
       ual in  charge of the ICS will designate several employees as
       back-up personnel; and a number of safety officers to monitor
       conditions and recommend safety precautions.

         Therefore, no matter what size or complexity an incident
       may be, by implementing an ICS there will be one individual
       in charge who makes the decisions and gives directions; and, all
       actions, and communications are coordinated  through one cen-
       tral point of command. Such a system should reduce confusion,
       improve safety, organize  and coordinate actions, and should
       facilitate effective management of the incident.

         7. Site Safety and Control Plans. The safety and security of
       response personnel and others in the  area of an emergency
       response incident site should be of primary concern to the inci-
       dent commander. The use of a site safety and control plan could
       greatly assist those in charge of assuring the safety and health
       of employees on the site.

         A comprehensive site safety and control plan should include
       the following: summary analysis of hazards on the site and a
       risk analysis of those  hazards; site map or sketch; site work
       zones  (clean zone, transition or decontamination zone, work or
       hot zone); use of the buddy system; site communications; com-
       mand  post or command center; standard operating procedures
       and safe  work practices; medical assistance and triage area;
       hazard monitoring plan (air contaminate monitoring,  etc.);
       decontamination procedures and area; and other relevant areas.
       This plan should be  a part  of the employer's emergency
       response  plan or an extension of it to the specific site.

         8. Medical surveillance programs.  Workers handling haz-
       ardous substances may be exposed to  toxic chemicals, safety
       hazards, biologic hazards, and radiation. Therefore, a medical
       surveillance program is essential to assess and monitor
       workers' health and fitness for employment in hazardous waste
       operations  and during  the course  of  work;  to provide
       emergency and  other treatment as needed: and to keep accu-
       rate records for future reference.

         The Occupational Safety and Health Guidance Manual for
       Hazardous Waste Site Activities developed by the National
       Institute for Occupational Safety and Health"(NIOSH), the
       Occupational Safety and Health Administration (OSHA), the
       U.S.  Coast Guard (USCG). and the Environmental  Protection
       Agency (EPA); October 1985 provides an excellent example of
       the types of medical testing that should be  done as part of a
       medical surveillance program.
       Appendix D—References

         The following references may be consulted for further infor-
       mation on the subject of this standard:
         1. OSHA Instruction DFO CPL 2.70—January 29. 1986, Spe-
       cial Enipkasts Program: Hazardous Waste .Sites.
1910.120 Appendix U
330.32
                                                                                                           Change 51
                                                           35

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OCCUPATIONAL SAFETY AND HEALTH
                                       1910.120 Appendix D
                                                                        STANDARDS AND INTERPRETATIONS
  2. OSHA Instruction DFO CPL 2-2.37A-January 29, 1986,
Technical Assistance and Guidelines for Superfund and Other
Hazardous Waste Site Activities

  3. OSHA Instruction DTS CPL 2.74—January 29, 1986, Haz-
ardous Waste Activity Form, OSHA 175.

  4. Hazardous  Waste Inspections Reference Manual, U.S.
Department of Labor, Occupational Safety and Health Admin-
istration, 1986.

  5. Memorandum of Understanding Among the National
Institute for Occupational Safety and Health, the Occupational
Safety and Health Administration, the United States Coast
Guard, and the United States Environmental Protection
Agency, Guidance for Worker Protection During Hazardous
Waste Site Investigations and Clean-up and Hazardous Sub-
stance Emergencies. December 18,  1980.

  6. National Priorities List, 1st Edition, October 1984; U.S.
Environmental Protection Agency, Revised periodically.

  7. The Decontamination of Response Personnel, Field
Standard Operating Procedures (F.S.O.P.) 7; U.S. Environ-
mental Protection Agency, Office of Emergency and Remedial
Response, Hazardous Response Support Division, December
1984.

  8. Preparation of a Site Safety Plan, Field Standard Oper-
ating Procedures (F.S.O.P.) 9; "U.S. Environmental Protection
Agency, Office of Emergency and Remedial Response, Haz-
ardous Response Support Division, April 1985.

  9. Standard Operating Safety Guidelines; U.S. Environ-
mental Protection Agency, Office of Emergency and Remedial
Response, Hazardous Response Support  Division, Environ-
mental Response Team; November 1984.

  10.  Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities, National  Institute for
Occupational Safety and Health (NIOSH), Occupational Safety
and  Health Administration (OSHA),  U.S. Coast  Guard
(USCG),  and Environmental Protection Agency (EPA); Octo-
ber 1985.

  11. Protecting Health and Safety at Hazardous Waste
Sites; An Overview, U.S. Environmental Protection Agency,
EPA/625/9—85/006; September 1985.
      12. Hazardous Waste Sites and Hazardous Substance
     Emergencies, NIOSH Worker Bulletin, U.S. Department of
     Health and Human Services, Public Health Service, Centers
     for Disease Control, National Institute for Occupational Safety
     and Health; December 1982.

      13. Personal Protective Equipment for Hazardous Mate-
     rials Incidents: A Selection Guide; U.S. Department of
     Health and Human Services, Public Health Service, Centers
     for Disease Control, National Institute for Occupational Safety
     and Health; October 1984.

      14. Fire Service Emergency Management Handbook,
     International  Association of Fire Chiefs Foundation, 101 East
     Holly Avenue, Unit 10B, Sterling, VA 22170, January 1985.

       15. Emergency Response Guidebook, U.S. Department of
     Transportation, Washington, DC, 1987.

       16. Report  to the Congress on Hazardous Materials Train-
     ing, Planning and Preparedness,  Federal Emergency Man-
     agement Agency, Washington, DC, July 1986.

       17. Workbook for Fire Command, Alan V. Brunacini and J.
     David Beageron,  National Fire Protection Association,  Bat-
     terymarch Park, Quincy, MA 02269, 1985.

       18. Fire Command, Alan V.  Brunacini, National Fire Pro-
     tection, Batterymarch Park, Quincy, MA 02269,  1985.

       19. Incident  Command System, Fire Protection Publica-
     tions, Oklahoma State University, Stillwater, OK 74078, 1983.

       20. Site Emergency Response Planning, Chemical Manufac-
     turers Association, Washington, DC 20037, 1986.

       21. Hazardous Materials Emergency  Planning Guide,
     NRT-1,  Environmental Protection  Agency, Washington,  DC,
     March 1987.

       22. Community Teamwork: Working Together to Promote
     Hazardous Materials Transportation Safety. U.S. Depart-
     ment of Transportation, Washington, DC, May 1983.

       23. Disaster Planning Guide for Business and Industry,
     Federal Emergency Management Agency, Publication No.
     FEMA 141, August 1987.

     (The Office of Management and Budget has approved the infor-
     mation  collection requirements in  this section under control
     number 1218-0139)
 Change 51
330.33

36
                                                                                              1910.120 Appendix D

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                   SECTION 1

        OCCUPATIONAL SAFETY AND HEALTH
          REGULATIONS AND STANDARDS

                    PART 2

EPA ORDER 1440.2 - HEALTH AND SAFETY REQUIREMENTS
    FOR EMPLOYEES ENGAGED IN FIELD ACTIVITIES
                      37

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 ENVIRONMENTAL

 PROTECTION                  ORDER            1440.2


 AGENCY                                    July 12,  1981


                   PROTECTIVE  SERVICES - SAFETY
      HEALTH AND  SAFETY REQUIREMENTS FOR EMPLOYEES ENGAGED
                       IN FIELD ACTIVITIES
1.    PURPOSE.   This order establishes policy, responsibilities,
and mandatory requirements for occupational health and safety
training and certification, and occupational medical monitoring
of  Agency employees engaged in field activities.

2.    DEFINITIONS.
     a.  The term "field activities" as used in this Order means
EPA program activities that are conducted by EPA employees
outside of EPA administered facilities.  These activities include
environmental and pesticides sampling, inspection of water and
wastewater treatment plants, and hazardous material spills and
waste site investigations, inspections, and sampling.

     b.  The term "health and safety training" means scheduled,
formal or informal training courses, approved and sponsored by
EPA and conducted by EPA or its contracted agents which is
designed to develop, improve and upgrade the health and safety
knowledge of EPA employees involved in field activities.

     c.  The term "occupational medical monitoring" means
surveillance over the health status of employees by means of
periodic medical examinations or screening in accordance with the
Agency's Occupational Medical Monitoring guidelines.

     d.  The term "certification" as used in this Order means
that the employee has successfully completed the minimum
classroom and field training requirements for the specified level
of training and the Agency has issued a certificate attesting
that the employee met those requirements.
Dist:  Directives Distribution          Initiated by:  PM-273
                              39

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                                                  1440.2
                                    ORDER
                                             July 12,  1981
3.   REFERENCES.

     a.  29 CFR 1910,  Parts 16,  94,  96,  106,  109, 111,  134, 151,
1000, Occupational Health and Safety Standards

     b.  Executive Order 12196,  Section 1-201, Sec.  (k),
Occupational Health and Safety Programs for Federal Employees.

     c.  29 CFR 1960.59(a), Occupational Safety and Health for
the Federal Employee.
7(b)
     d.  EPA Occupational Health and Safety Manual, Chapter 7(1).

     e.  EPA Training and Development Manual, Chapter 3, Par
     f.  Occupational Health and Safety Act of 1971, P.L. 91-596,
Sec. 6.

     g.  EPA Order on Respiratory Protection (Proposed).

     h.  49 CFR, Parts 100-177, Transportation of Hazardous
Materials.

     i.  EPA Order 1000.18, Transportation of Hazardous
Materials.

     j.  EPA Order 3100.1, Change 1, Uniforms, Protective
Clothing, and Protective Equipment.

4.   BACKGROUND.  Field activities are a critical part of most
EPA programs.  These activities range from routine environmental
reconna-isance sampling, inspections, and monitoring, to entering
and working in environments with known and unknown hazards.
Since protection cannot be engineered into the field working
situation,  the protection of personnel engaged in field
activities involves training employees in safe operational
procedures and the proper use of appropriate personal protective
clothing and equipment.

5.   APPLICABILITY.  This Order applies to all EPA organizational
units which have employees engaged in field activities.

6.   POLICY.  It is the policy of the Environmental Protection
Agency to carry out its field activities in a manner that assures
the protection of its  employees.
                                40

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                                    ORDER        144°'2
                                             July 12, 1981
7.   RESPONSIBILITIES.

     a.  Assistant Administrators, Regional Administrators,
Deputy Assistant Administrators, Laboratory Directors, and
Division Directors.  These officials are responsible within their
jurisdictions for implementing the provisions of this Order and
for budgeting the necessary funds for employee training and
certification, personal protective clothing and equipment, and
occupational medical monitoring programs.

     b.  Supervisors.  Supervisors are responsible for complying
with the requirements of this Order for employee training and
certification, and occupational medical monitoring programs.
They will identify those employees who require training and
certification, and occupational medical monitoring, and assure
they receive it to comply with the provisions of this Order and
will insure these requirements are properly contained in position
descriptions and job postings.

     c.  Employees.  Employees are responsible for making known
upon request from their supervisors the extent of their
individual occupational health and safety training and the
history of their occupational medical monitoring participation.
Employees should notify their supervisor of any hazardous work
situation and make suggestions for corrective measures.
Employees are responsible for applying the knowledge, skills, and
techniques acquired through training in a manner that will help
assure their health and safety and that of fellow workers.

     d.  Occupational Health and Safety Designees.  The
Occupational Health and Safety Designees are responsible  for
identifying program areas that require training and
certification, and occupational medical monitoring; recommending
or providing training and certification resources to meet the
requirements of this Order; and maintaining records of persons
receiving training and certification.

     e.  Office of Occupational Health and Safety.  The Director,
Office of Occupational Health and Safety is responsible for
establishing policy and requirements for adequate training and
certification programs for field activities, developing and
maintaining an occupational medical monitoring program, approving
health and safety training and certification programs for
employees involved in field activities, and for evaluating the
results of these training and certification programs.
                              41

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                                    ORDER        144°'2
                                             July 1'2, 1981
8.    OBJECTIVES.
     a,  Training and Certification.  The objectives of the
health and safety training and certification programs for
employees involved in field activities are:

          (1)  To assure that EPA employees are aware of the
potential hazards they amy encounter during the performance of
field activities;

          (2)  To provide the knowledge and skills necessary to
perform the work with the least possible risk to personal health
and safety;

          (3)  To assure that Agency program goals are
accomplished in as safe and healthful manner as feasible; and

          (4)  To assure that EPA employees can safely disengage
themselves from an actual hazardous situation which may occur
during a field activity.

     b.  Occupational Medical Monitoring.  The objectives of the
occupational Medical Monitoring program are:

          (1)  To detect any adverse effects of occupational
exposure on the employees health and to initiate prompt
corrective actions when indicated;  and

          (2)  To assure that employees assigned arduous or
physically taxing jobs or jobs requiring unique skills are able
to perform those jobs without impairing their health and safety
or the health and safety of others.

9.   TRAINING AND CERTIFICATION REQUIREMENTS.  Employees shall
not be permitted  to engage in routine field activities until
they have been trained and certified to a level commensurate with
the degree of anticipated hazards.

     a.  Basic Level.  All employee shall be provided  a minimum
of 24 hours of health and safety training.prior to  their becoming
involved in normal, routine field activities.  The  training shall
include but not be limited to classroom instruction in all the
following subject areas:
                                42

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                                    ORDER        1440'2

                                             July 12, 1981
          (1)   Employee Rights and Responsibilities;
          (2)   Nature of Anticipated Hazards;
          (3)   Emergency Help and Self-Rescue;
          (4)   Vehicles - Mandatory Rules and Regulations;
          (5)   Safe Use of Field Equipment;
          (6)   Use, Handling, Storage, and Transportation of
Hazardous Materials;
          (7)   Personal Protective Equipment and Clothing, Use
and Care;
          (8)   Safe Sampling Techniques.

In addition to classroom instruction, the employee shall
accompany an employee experienced in field activities and perform
actual field tasks for a minimum of three days within a period of
three months after classroom instruction.  Employees
satisfactorily completing these requirements will receive
certification at the Basic Level of training from the
Occupational Health and Safety Designee at the Reporting Unit.

     b.  Intermediate Level.  All inexperienced employees who are
to work with experienced employees in uncontrolled hazardous
waste and hazardous spill sites investigations or employees
engaged in other activities which at a later date are determined
by the Director, Office of Occupational Health and Safety, to
present unique hazards requiring additional training, shall be
provided a minimum of 8 hours of additional health and safety
training.  This training shall include (in addition to the Basic
Level requirements) but not be limited to the following subject
manner:

          (1)   Site surveillance, observation, and safety plan
development;
          (2)   Use and decontamination of totally enclosed
protective clothing and equipment;
          (3)   Use of field test equipment for radioactivity,
explosivity, and other measurements,- and
          (4)   Topics specific to other identified activities.

In addition to classroom instruction, the employee shall
accompany another employee experienced in hazardous waste and
spill site investigations and/or cleanup operations and perform
actual field tasks for a minimum of three days within a period of
three months after classroom instruction.  The employee should
also be able to provide on-the-job training and instructions to
inexperienced employees during normal, routine field activities
(as required above).   Employees satisfactorily completing these
requirements will be certified at the Intermediate Level by the
Occupational Health and Safety Designee and the Reporting Unit.
                              43

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                                    ORDER
                                                  1440.2
                                             July 12,  1981
     c.  Advanced Level.   All employees who manage uncontrolled
hazardous waste site and spill site monitoring,  sampling,
investigations, and cleanup operations shall be  provided a
minimum of 8 hours additional health and safety  training.  The
classroom training shall include but not be limited to (in
addition to the Basic and Intermediate Level requirements),
instruction in the following subject areas:

          (1)  Management of'restricted and safe zones;
          (2)  Rules of Handling the Press and VIP's; and
          (3)  Safe Use of Specialized Sampling Equipment.

In addition to classroom instruction, the employee shall
accompany another employee with experience in managing hazardous
waste and spill site investigations or cleanup operations and
perform actual field tasks for a minimum of three days within a
three month period after receiving classroom instruction.  After
satisfactorily completing these requirements, employees will
receive Advanced Level certification from the Occupational Health
and Safety Designee at the Reporting Unit.

     d.  General.

          (1)  An employee may receive certification at the next
higher level by completing only the additional training
requirements if certified at the next lower level within the
previous one-year period.

          (2)  The Director, Office of Occupational Health and
Safety, may certify employees based on an evaluation of previous
training, education, and experience.  Recommendations for this
type certification should be made to the Director by the
Occupational Health and Safety Designee at the Reporting Unit.

10.  FREQUENCY OF TRAINING.  Employees at the Basic, Intermediate
and Advanced Levels shall complete a minimum of 8 hours of
refresher classroom instruction annually consisting of a review
of all subject areas to maintain their certification.  In
addition to the classroom instruction, employees  shall have
demonstrated by having performed actual field tasks that they
have sufficient practical experience to perform their  assigned
duties in a sage and healthful manner.

11.  RECORD OF TRAINING

     a.  A record of the level of training  and certification
shall be maintained in the employee's official personnel  file.
                                44

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                                                  1440.2
                                    ORDER
                                             July 12,  1981
     b.  The Occupational  Health and Safety Designee shall
maintain a roster  of  employee training and certification so that
a schedule of annual  training can be established.

     c.  The Occupational  Health and Safety Designee shall issue
a certificate to the  employee showing the level of training and
certification.

12.   OCCUPATIONAL  MEDICAL  MONITORING REQUIREMENTS.  All employees
routinely engaged  in  field activities which present the
probability of exposure to hazardous or toxic substances, which
are arduous or physically  taxing, or which require the use of
respiratory protective equipment shall be included in the
Agency's Occupational Medical Monitoring Program.   Employees
should not be permitted to engage in field activities unless they
have undergone a baseline  medical examination (as defined in the
Agency's Occupational Medical Monitoring Guidelines), which will
show physical fitness and  provide a base to measure any adverse
effects their activities may have on these individuals.

13.   SAVINGS PROVISION. Changes in the Act, Executive Order, or
EPA and OSHA standards and guidelines which occur after the
effective date of  this Order will automatically come under the
purview of this Order on the effective date of the change.

Full implementation of this Order shall be within one year of its
effective date.
                        Edward  J. Hanley
                 Director,  Office of  Management
                Information and Support Services
                              45

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                     SECTION 1

          OCCUPATIONAL SAFETY AND HEALTH
             REGULATIONS AND STANDARDS

                      PART 3

    OTHER OSHA, FEDERAL, AND NFPA REGULATIONS AND
STANDARDS RELATED TO HAZARDOUS WASTE OPERATIONS AND
       EMERGENCY RESPONSE WORKER PROTECTION
                        47

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RELATED OSHA REGULATIONS
GENERAL   DUTY   CLAUSE  OF  THE
OCCUPATIONAL SAFETY AND HEALTH
ACT (OSH Act) OF 1970

The OSH Act, Section 5(a)(l) states that each
employer "shall furnish to each of his employees
employment and a place of employment which

causing or are likely to  cause death or serious
physical harm to his employees".
LOG   AND   SUMMARY
OCCUPATIONAL
ILLNESSES
INJURIES
 O F
AND
29 CFR 1904.24 requires that each employer
maintain a log of all recordable occupational
injuries and illnesses and that the information be
recorded in the log within six working days of
the receipt of the information. Form OSHA No.
200 or its equivalent is to be used for  this
purpose.
ACCESS TO EMPLOYEE EXPOSURE AND
MEDICAL RECORDS

29 CFR  1910.20 requires that an  employer
provide  exposure and  medical records  to  an
employee or designated representative  within
fifteen  days after the request for  access  to
records. If the employee requests copies  of this
information, the employer must make  the  copies
available  to  the  employee at no cost.   All
employee medical records  must be maintained
by the employer for the duration of employment
plus 30 years.
EMPLOYEE EMERGENCY PLANS AND
FIRE PREVENTION PLANS

29 CFR 1910.38 applies to all emergency
                         action plans and fire prevention plans required
                         by particular OSHA standards.  With the ex-
                         ception of employers with 10 or  fewer  em-
                         ployees, both the emergency action plan and the
                         fire prevention  plan are required  in writing.
                         The required elements of each of these plans are
                         provided in the regulation. If the employer has
                         10 or fewer employees,  the elements of both
                         types  of plans  must be provided orally to
                         employees.  The employer shall also perform
                         housekeeping and maintenance of equipment and
                         systems as part of the fire prevention plan.
                         OCCUPATIONAL NOISE AND EXPOSURE

                         29 CFR 1910.95 states that it is important that
                         area and personal noise surveys be conducted
                         to categorize noise  levels appropriately.  A
                         sound level  meter  that has  the capability to
                         integrate  and average  sound levels over the
                         course of a work day is required. The OSHA-
                         Permissible Exposure Limit  for an eight-hour

                         recorded  on a sound  level  meter  on the A
                         weighted scale. An employer shall implement a
                         hearing conservation program  if 8-hour time
                         weighted  average noise  exposures  equal  or
                         exceed  85 decibels on the A scale.  Continuous
                         intermittent and impulsive sound levels  of 80
                         dBA  or greater shall  be integrated into the time
                         weighted average.
                         IONIZING RADIATION

                         29 CFR  1910.96 covers employee protection
                         measures related to the possession,  use,  or
                         transfer of ionizing  radiation.  The regulations
                         set limitations on employee exposure to ionizing
                         radiation  and provide methods for establishing
                         precautionary   procedures  and  personnel
                         monitoring,  including  surveys   of  radiation
                         hazards, monitoring equipment, marking of
                                           49

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radiation areas, emergency evacuation warning
signals,  and  personnel  instruction.     The
regulations require notification of incidents  of
releases, overexposure,  or excessive levels  or
concentrations of radiation,  and specify that
employer  must  keep  records  of  employee
exposure  and disclose  the  information  upon
request from  a former employee.
CHEMICAL PROCESS SAFETY

29 CFR 1910.119 establishes procedures for
process safety  management that  will protect
employees  by  preventing  or  minimizing  the
consequences of chemical  accidents involving
highly hazardous chemicals.
PERSONAL PROTECTIVE EQUIPMENT

29   CFR   1910.132-1910.136  requires   the
provision of personal protective equipment for
eye, face, head,  and extremities in  hazardous
environments.  This  protective equipment must
be provided, used,  and maintained in  sanitary
and reliable condition. Specific requirements are
described as follows:

Section 133 - Eye and Face Protection

29   CFR   1910.133  requires  provision  of
protective eye and face equipment when there is
the  potential  for on-site  injury.    Particular
information  on  goggles, spectacles, and  face
protection is included.   Design, construction,
testing, and use of such devices must be in
accordance   with   ANSI   Z87.1-1968
specifications. The regulation also addresses the
proper  use,  maintenance,  and  repair  of the
equipment.

Section 134 - Respiratory Protection

29   CFR  1910.134  presents  guidance  for
respiratory protective equipment. It requires the
provision and  use  of  appropriate respirators
when engineering controls are not feasible to
control atmospheric contamination. Employers
must   develop   atmospheric  protection   for
workers,  provide  and  maintain  respiratory
equipment, establish operating procedures and
employee training for respirator use, and adhere
to air  quality requirements.  Employers must
also set up a program  of regular inspection of
respirators  for defects  and  repair needs.  Gas
mask canisters must be appropriately identified
through use of a color code.

Section 135 - Occupational Head Protection

29 CFR 1910.135 requires head protection for
on-site  workers  in  the  following situations:
presence of  overhead  objects,f  operation  of
heavy equipment, potential  for flying objects in
the work  area,  and possible electrical shock
hazard. In addition to  protecting workers from
falling  or flying objects, head protection affords
limited protection from electric shock and burn.
Head protection must meet ANSI Z89.1 -1969
specifications.

Section 136 - Occupational Foot Protection

29  CFR  1910.136 requires  that  safety  toe
footwear for employees meet ANSI Z41.1-1967
standards.   In  general, workers at hazardous
waste sites must wear  leather or rubber boots
with steel toes and steel shanks.
SANITATION

29   CFR  1910.141   contains   specifications
conccerning appropriate  housekeeping,  waste
disposal, vermin control, water  supply, toilet
and washing facilities,  showers, change rooms,
waste disposal containers, sanitary storage,  and
food   handling   for   permanent  places   of
employment are  provided in this regulation.
MEDICAL SERVICES AND FIRST AID

29 CFR 1910.151 states that if a medical facility
is not located in proximity to the workplace,
there shall be a person or persons on-site with
adequate first-aid training.  First aid supplies
                                              50

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approved by  a consulting physician  shall  be
available on-site.   If there is  a potential for
corrosive materials  on-site,  suitable  facilities
shall be available for drenching of eyes and skin.
FIRE BRIGADES

29  CFR 1910.156  applies to fire  brigades,
industrial fire departments, and contractual-type
fire  departments.   The  requirements  cover
organization, training, and personal protective
equipment (PPE) for fire brigades whenever they
are established by the employer.
EMPLOYEE ALARM SYSTEMS

29 CFR 1910.165 states that the employee alarm
system  shall  be  recognizable to  all  on-site
employees. The signal from the employee alarm
system shall  be  audible to  employees in the
event of  a  need to warn  employees of an
evacuation from work areas.
                                         29 CFR 1910.1016
                                         29 CFR
                                         29 CFR
                                         29 CFR
                                         29 CFR
                                         29 CFR
                                         29 CFR
                                    1910.1017
                                    1910.1018
                                    1910.1025
                                    1910.1028
                                    1910.1029
                                    1910.1044
                                         29 CFR 1910.1045
                                         29 CFR 1910.1047
                                         29 CFR 1910.1048
                     N-nitrosodi-
                     methylamine
                     Vinyl chloride
                     Inorganic arsenic
                     Lead
                     Benzene
                     Coke oven emissions
                     1,2-dibromo-3-chloro-
                     propane
                     Acrylonitrile
                     Ethylene oxide
                     Formaldehyde
                                         BLOODBORNE PATHOGENS

                                         29  CFR   1910.1030  requires  occupational
                                         exposure to blood or other potentially infectious
                                         materials be minimized or eliminated using a
                                         combination of engineering and work practice
                                         controls,  personal  protective  clothing  and
                                         equipment,  training,   medical  surveillance,
                                         Hepatitis B vaccination,  signs and labels, and
                                         other provisions.
TOXIC AND HAZARDOUS  SUBSTANCES

In Subpart Z, 29 CFR  1910.1000,  there are
other  applicable OSHA standards that refer to
particular air sampling procedures for chemical
contaminants, PPE  requirements,  and record
keeping for a variety of compounds.
29 CFR 1910.1001
29 CFR 1910.1002
29 CFR 1910.1003
29 CFR 1910.1004
29 CFR 1910.1006
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
29 CFR
1910.1007
1910.1008
1910.1010
1910.1011
1910.1012
1910.1013
1910.1014
1910.1015
Asbestos
Coal tar pitch volatiles
4-nitrobiphenyl
Alpha-Naphthylamine
Methyl   chloromethyl-
ether
3,3'-dichlorobenzidine
bis-chloromethyl ether
Benzidine
4-aminodiphenyl
Ethyleneimine
bata-propiolactone
2-acetylaminofluorene
4-dimethylaminoazo-
benzene
HAZARD COMMUNICATION
STANDARD

29 CFR  1910.1200 ensures  that produced or
imported  chemical  hazards  are  evaluated and
information concerning these hazards
is  communicated  to  affected employers  and
employees.  This is accomplished through
hazard communication programs  which include
container labels and warnings, material safety
data sheets, and employee information training.
These requirements apply to any chemical which
is  known to  be present  in the  workplace to
which  employees  may   be  exposed.   Any
chemical  produced in  or   imported  to the
workplace must be evaluated to determine if it is
hazardous.    If  a  chemical  is  identified  as
hazardous,  the employer must develop  and
implement  certain  standards  (i.e., warnings,
labels, data sheets, employee information, and
training)  to   ensure  employee  safety   and
protection.   Section  1200 also  defines health
hazards related to chemicals, explains mandatory
                                            51

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hazard determination, lists information sources
for hazard determination, and discusses the issue
of trade secrets in the  context of  chemical
hazards.
HAZARDOUS
LABORATORIES
CHEMICALS   IN
29 CFR 1910.1450 requires the forrmationand
implementation  of a Chemical  Hygiene Plan
(CHP) to  maintain employee exposures  at or
below  permissible exposure  levels (PELs) in
laboratories.  The CHP must include necessary
work  practices,  procedures,  and policies to
ensure that employees  are protected  from all
potentially hazardous chemicals in use in their
work area.
SAFETY  AND  HEALTH REGULATIONS
FOR CONSTRUCTION

29  CFR  1926 sets  forth  safety and  health
standards  under  Section  107  of the  Contract
Work Hours  and Safety  Standards Act.   The
regulations  state  that  no   contractor  or
subcontractor can require laborers or mechanics
to work under conditions that are unsanitary,
hazardous, or  dangerous  to health and safety.
Safety   training   and   education  programs
concerning recognition and prevention of unsafe
conditions  will be established by OSHA and
used by  employers  to control  or  eliminate
hazards.   Employers  must practice proper fire
prevention, housekeeping, and sanitation.  Part
1926 is divided into twenty-four specific areas
including:
    Subpart A
    Subpart B
    Subpart C

    Subpart D

    Subpart E

    Subpart F
 General
 General Interpretations
 General   Safety   and
 Health Provisions
 Occupational Health and
 Environmental Controls
 Personal Protective and
 Life Saving Equipment
 Fire   Protection   and
 Prevention
Subpart G        Signs,   Signals,   and
                 Barricades
Subpart H        Materials   Handling,
                 Storage,   Use,   and
                 Disposal
Subpart I         Tools - Hand and Power
Subpart J         Welding and Cutting
Subpart K        Electrical
Subpart L        Ladders and Scaffolding
Subpart M        Floors   and  Wall
                 Openings,   and
                 Stairways
Subpart N        Cranes,  Derricks,
                 Hoists,  Elevators, and
                 Conveyors
Subpart O        Motor   Vehicles,
                 Mechanized Equipment
                 and Marine Operations
Subpart P        Excavations,Trenching,
                 and Shoring
Subpart Q        Concrete,  Concrete
                 Forms, and Shoring
Subpart R        Steel Erection
Subpart S        Tunnels   and  Shafts,
                 Caissons, Cofferdams,
                 and Compressed Air
Subpart T        Demolition
Subpart U        Blasting  and   Use  of
                 Explosives
Subpart V        Power Transmission and
                 Distribution
Subpart W        Rollover   Protective
                 Structures;   Overhead
                 Protection
Subpart X        Effective Dates
                                             52

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FEDERAL REGULATIONS RELATED  TO WORKER
PROTECTION
RESPIRATORY PROTECTIVE DEVICES

30 CFR Part 11 is the Mine Safety and Health
Administration  (MSHA)  program  to  certify
respiratory protective devices.  It requires that
NIOSH  (National Institute  for  Occupational
Safety and Health) and/or MSHA certify any
respiratory protective device before it  can be
used.    Respirators  for use   in  hazardous
atmospheres  must  be  approved,  used,  and
maintained in accordance with the provisions of
American  National   Standard   Practices   for
Respiratory  Protection.    Thirteen subparts
outline procedures for the approval process for
respirators as well as inspection, examination,
and testing requirements:

    Subpart A  General Provisions
    Subpart B  Application for Approval
    Subpart C  Fees
    Subpart D  Approval and Disapproval
    Subpart E  Quality Control
    Subpart F  Classification  of   Approved
              Respirators; Scope of Approval;
              Atmospheric  Hazards;  Service
              Time
    Subpart G  General   Construction  and
              Performance  Requirements
    Subpart H  Self-Contained   Breathing
              Apparatus
    Subpart I  Gas Masks
    Subpart J  Supplied-Air Respirators
    Subpart K  Dust,   Fume,   and   Mist
              Respirators
    Subpart L  Chemical Cartridge Respirators
    Subpart M  Pesticide Respirators
    Subpart N  Special Use Respirators
NATIONAL CONTINGENCY PLAN

The National Contingency Plan is required by
the Comprehensive Environmental Response,
Compensation,  and  Liability  Act  of  1980
(CERCLA),   as   amended   by   Superfund
Amendments and Reauthorization Act of 1986
(SARA).  The revised National Oil and
Hazardous  Substances Pollution Contingency
Plan (National Contingency Plan or  NCP) was
signed by the EPA Administrator on February 2,
1990.  The NCP covers discharges  of oil into
navigable  waters  and releases  of  hazardous
substances into the environment. It provides for
efficient,  coordinated, and  effective  response to
discharges  of  such  substances.    The  NCP
consists of the following Subparts:

    Subpart A  Introduction
    Subpart B  Responsibility and Organization
              for Response
    Subpart C  Planning and Preparedness
    Subpart D  Operational Response Phases for
              Oil Removal
    Subpart E  Hazardous  Substance Response
    Subpart F  State Involvement in  Hazardous
              Substance Response
    Subpart G  Trustees for Natural Resources
    Subpart H  Participation by Other Persons
    Subpart I  Administrative   Record   for
              Selection of Response Action
    Subpart J  Use of Dispersants  and Other
              Chemicals
    Subpart K  Federal Facilities (Reserved)

The NCP requires planning and coordination for
response to oil and hazardous substance releases
and it requires that the National Response Center
(NRC)  be notified of a release.  The National
Response  Team  (NRT)  is  responsible  for
national planning and coordination of response
actions and the Regional Response Team (RRT)
is   responsible  for  regional  planning  and
preparedness activities. The RRT also provides
assistance  and  advice   to  the   On-Scene
Coordinator (OSC) who directs the response to
the release.
                                            53

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HAZARDOUS MATERIALS
TRANSPORTATION REGULATIONS

49  CFR specifies shipping regulations for a
variety  of different  materials.    All  parties
involved  with  the   shipment  of  hazardous
materials must be cognizant of the restrictions
that apply to these materials. These restrictions
regulate  hazardous   materials  transport   for
aircraft, motor carriers, rail carriage, and vessel
carriage.    49  CFR  provides  a  hazardous
materials table referencing appropriate packaging
and  labeling  requirements.   The regulations
require notification to Federal authorities in the
event of a release of a hazardous material.
The RQ program is a integral part of Superfund.
To  control acute threats,  Federal,  State, and
local  emergency responnseauthorities need to
know  about  them.    The  release  reporting
requirements  of Superfund  are quite broad.
Although  several  reporting exemptions are
provided, thousands of reports are still required
each year to the National Response Center, State
emergency  response  commissions,  and  local
emergency planning committees.  Because the
potential liability for failure  to notify is great,
and the effort required to comply generally  is
quite small, it is of interest to all organizations
that handle hazardous substances to  learn and
understand their reporting obligations.
THE   REPORTABLE   QUANTITIES
PROGRAM

The purpose of the "reportable quantities" (RQ)
program is to alert  Federal,  State,  and local
response authorities  of releases of hazardous
substances that may potentially pose a threat to
public  health, welfare,  or the environment.
These government authorities are notified when
a certain threshold,  or RQ,  of the hazardous
substance is released  into the environment.

Specifically, CERCLA section 103  requires the
release of a CERCLA hazardous substance in an
RQ or more to be reported immediately to the
National Response Center (NRC). If the release
is less than an RQ, no report is necessary. RQs
serve  as  a  trigger  for  informing  response
authorities of a hazardous substance release so
that they can evaluate the need for a response
action, and undertake any necessary action in a
timely   fashion.      RQs   do  not  reflect a
determination that a release of a substance will
be hazardous at the RQ level and not hazardous
below   that  level.    A  Federal  On-Scene
Coordinator makes the risk determination based
on  the unique circumstances of  the release.
Title  III  of  SARA supplements  this  NRC
reporting with additional emergency notification
requirements  to   State  and   local   response
officials.
REIMBURSEMENT   TO   LOCAL
GOVERNMENT   FOR   EMERGENCY
RESPONSE TO HAZARDOUS SUBSTANCE
RELEASES

40 CFR Part 310 contains regulations, developed
under  section  123  of  CERCLA,  concerning
procedures for  reimbursing local governments
for expenses incurred in carrying out temporary
emergency measures in response to hazardous
substance threats.   These  measures  must be
necessary to prevent or mitigate injury to human
health and the environment from a release of a
hazardous  substance   or   a   pollutant  or
contaminant.  Temporary emergency measures
may include such activities as erecting security
fencing to limit access, responding to  fires and
explosions  and  other measures  that  require
immediate response at a local level. The  intent
of the reimbursement program  is to  alleviate
significant   financial   burden   on   a  local
government resulting from such responses.
                                              54

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Office of Solid Waste and Emergency Response                                December 1989
Office of Emergency and Remedial Response
Emergency Response Division — MS-101

    SARA TITLE I/TITLE III EMERGENCY RESPONSE PLANNING REQUIREMENTS
TITLE I EMERGENCY RESPONSE                     TITLE III PLANNING
  PLANNING REQUIREMENTS                        REQUIREMENTS FOR
     29 CFR 1910.120 (q)(2)                                    LEPCs
(i)     Pre-emergency  planning  and  coord-       •      Identify  facilities  and  transportation
       ination with outside parties                         routes   of   extremely   hazardous
                                                       substances (EHSs)

       The LEPC plan must only cover EHSs; the Title I plan will need to include more hazardous
       chemicals (e.g., CERCLA hazardous substances, RCRA hazardous wastes).
(ii)     Personnel  roles,  lines of  authority,       •      Designate a community coordinator and
       training, and communications                       facility coordinator(s) to implement the
                                                       LEPC plan

       Title III simply requires the identification of community and facility emergency coordinators.
       Although some explanation of the individuals' responsibilities should be included in the LEPC
       plan, the plan will not cover the specifics  of an Incident Command System (ICS) or the lines of
       authority below the coordinators that the Title I plan requires.  The site security  and control
       requirements under Title I refers to procedures that limit personnel on site to those who are
       actively performing emergency operations. The LEPC plan would probably not include detailed
       emergency response information of this type.


(iii)    Emergency recognition and prevention        •      Describe methods  for determining the
                                                       occurrence of a release and the probable
                                                       affected area and population

       The LEPC plan should contain specific guidelines for approach, recognition, and evaluation of
       releases. This may include generic types of hazards and guidance. The Title I requirements must
       include the same type of information. The LEPC requirement includes specifics on determining
       the probable affected area because the LEPC plan is community oriented. The Title I plan should
       contain more specifics geared towards the actual responders.
                                            55

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    SARA TITLE I/TITLE III EMERGENCY RESPONSE PLANNING REQUIREMENTS
TITLE I EMERGENCY RESPONSE                     TITLE III PLANNING
  PLANNING REQUIREMENTS                        REQUIREMENTS FOR
      29 CFR 1910.120 (q)(2)                                     LEPCs
(iv)    Safe distances and places of refuge           •      Outline evacuation plans

       These  planning elements overlap.   The plans must identify potential conditions requiring
       evacuation, an indication of how evacuation distances are determined, the designated authority
       for ordering evacuations, shelter facilities,  means for  locating "sensitive populations"  (e.g.,
       elderly, handicapped), evacuation routes and procedures, and designated authority to make re-
       entry decisions.
(v)     Site security and control

                                      See paragraph (ii)


(vi)    Evacuation routes and procedures

                                      See paragraph (iv)
(vii)   Decontamination                           •      Describe  emergency  response
                                                        procedures, on-site and off-site

       Overlap may exist to some extent.  Both plans must address alternate means of communication
       and  public altering procedures, and  should designate a person to be in charge of public
       information during an incident.  The Title I decontamination requirement is a specific emergency
       response procedure.  The LEPC plan requirements are intended to include standard emergency
       response procedures; LEPC plans  may not be sufficiently specific to satisfy the requirements
       under Title I.
(viii)   Emergency medical treatment and first       •      Describe community and industry emer-
       aid                                              gency equipment and facilities, and the
                                                        identity of persons responsible for them

       Both  rules require equipment to be identified for various levels and types of emergencies.
       References to neighboring jurisdictions' equipment and facility resources should be included and
       arrangements, either formal or informal, should  be made for  their use during an emergency.
       Maintenance schedules may also be included in both plans. PPE is a specific type of equipment
       that must be addressed in the Title I plan.  Emergency medical treatment and first aid must be
       addressed explicitly in the Title I plan.
                                             56

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    SARA TITLE I/TITLE III EMERGENCY RESPONSE PLANNING REQUIREMENTS
TITLE I EMERGENCY RESPONSE
  PLANNING REQUIREMENTS
     29 CFR 1910.120 (q)(2)
TITLE III PLANNING
REQUIREMENTS FOR
        LEPCs
(ix)    Emergency alerting and response
Outline   emergenc
procedures procedures
notification
                                    See paragraph (vii)
(x)     Critique of response and follow-up
Present  methods  and  schedules  for
exercising emergency response plans
       These two criteria are different and complementary.  The LEPC requirement refers to table-top
       exercises  or  simulated accidents to  test  a  variety  of local  response systems.   The Title I
       requirement specifies that following an actual event, participants critique the response in order
       to  improve  capabilities  for the next accident.  The two requirements together provide an
       opportunity to test the plan and learn  from the results of a response.
(xi)    PPE and emergency requirements
                                    See paragraph (viii)
(xii)    Emergency response organizations may
       use the local emergency response plan
       or the State emergency response plan or
       both,  as  part  of  their  emergency
       response  plan  to  avoid  duplication.
       Those items of the emergency response
       plan that are being properly addressed
       by the  SARA Title III plans may be
       substituted into their emergency plan or
       otherwise kept together for the employer
       and employee's use.
The LEPC may develop their plan based
on  the  guidance  provided   by  the
National  Response Team  (Hazardous
Materials Emergency Planning Guide,
NRT-1).    This  document  provides
additional  information  on  the  nine
general  planning  requirements  and
reinforces   the   importance   of  the
planning process for the community.
                                           57

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     SARA TITLE I/TITLE III EMERGENCY RESPONSE TRAINING REQUIREMENTS
TITLE I EMERGENCY RESPONSE
  TRAINING REQUIREMENTS
     29 CFR 1910.120 (q)(6)
TITLE III TRAINING
REQUIREMENTS FOR
        LEPCs
       Training shall be based on duties and
       functions  to be  performed  by each
       responder of an  emergency  response
       organization
Describe a training program for
emergency response personnel (including
schedules)
       Title I requires specific training for employees  engaged in emergency response, based on 5
       categories of responders:  first responder awareness  level, first responder operations level,
       hazardous materials technician, hazardous materials specialist, and on-scene incident commander.
       The Title III planning requirements were developed prior to the OSHA regulations and thus may
       not  specifically address the training programs and schedules necessary to fulfill  the OSHA
       requirements.
SUMMARY OF COMPARISON   The primary difference between the Title I and the Title III
requirements is the  intended audience.  Title III has nine very general planning elements that allow a
community to develop emergency plans based on their perceived needs.  Title I contains the federally-
determined, specific criteria for employer plans to protect emergency responders. A good LEPC plan
may significantly overlap with the Title I plan; however a good LEPC plan may also be too general for
Title I purposes.
                                            58

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RELATED NATIONAL FIRE PROTECTION ASSOCIATION
STANDARDS
RESPONDING TO HAZARDOUS
MATERIALS INCIDENTS

 NFPA  471  recommends  procedures  and
practices for  mitigating hazardous  materials
incidents.   Topics  include  decontamination,
methods  of  mitigation, chemical  protective
clothing, and safety.
PROFESSIONAL   COMPETENCE  OF
RESPONDERS  TO   HAZARDOUS
MATERIALS INCIDENTS

 NFPA 472 deals with training and capabilities
that are required at various levels of response to
hazardous materials  incidents, including First
Responder Awareness  and Operational  levels;
the  Technician level; and the Specialist level.
An  appendix deals  with management  of an
incident.
PROFESSIONAL   COMPETENCE  OF
EMERGENCY   MEDICAL   SERVICES
RESPONDERS  TO   HAZARDOUS
MATERIALS INCIDENTS

 NFPA 473 identifies the level of competence
required   of  emergency   medical  services
personnel who respond to hazardous materials
incidents. The competencies outlined have been
prepared to reduce the numbers of accidents,
exposure, and injuries resulting from HAZMAT
incidents.
IDENTIFICATION  OF   THE   FIRE
HAZARDS OF MATERIALS

 NFPA 704 presents a system of recognizable
markings ("Hazard Diamond") that indicate the
relative reactivity, flammability, and health
hazards of materials in storage. Includes
expanded  definitions  for  the  Health  and
Reactivity Hazard Ratings.
FIRE  DEPARTMENT   OCCUPATIONAL
SAFETY AND HEALTH PROGRAM

 NFPA 1500  provides   minimum  standard
requirements   for  a  fire  service  related
occupational safety and health program for all
career  and  volunteer  departments.   Covers
organization,  training and education, vehicles
and equipment, protective clothing, protective
equipment,   facilities,  safety,   medical   and
member assistance programs.
FIRE DEPARTMENT SAFETY OFFICER

 NFPA  1501 outlines  the duties of a Fire
Department Safety Officer, and requires every
department to have a safety officer.
FIRE   DEPARTMENT
MANAGEMENT SYSTEM
INCIDENT
 NFPA  1561  provides  minimum  criteria for
emergency incident management. Such incident
management systems are intended to provide
structure, coordination, and effectiveness of all
emergency incidents to enhance safety and health
of fire department members and other persons
involved.
FIRE   DEPARTMENT
CONTROL PROGRAM
                                                                       INFECTION
 NFPA 1581 specifies minimum requirements
for infection control practices for public safety
and emergency response personnel providing
EMS  care  and  in  contact with potentially
infectious  persons and materials in emergency
                                         59

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settings,  and for  universal  precautions for
infection control in routine or non-emergency
settings.
PROTECTIVE   CLOTHING   AND
EQUIPMENT  FOR   STRUCTURAL
FIREFIGHTING AND STATION / WORK
UNIFORMS

       NFPA 1971-Protective Clothing

 NFPA 1971 specifies minimum performance,
design, and testing requirements for protective
coats, trousers and hoods.

       NFPA 1972-Helmets

 NFPA 1971 specifies performance criteria and
test methods for helmets.

       NFPA 1973-Gloves

 NFPA 1972 specifies minimum  performance
criteria and test methods for the materials and
construction of gloves.

       NFPA 1974-Footwear

 NFPA  1974  specifies  minimum  standard
design, performance,  and  testing requirements
for protective footwear.

       NFPA 1975-Station/Work Uniforms

 NFPA 1975 specifies performance criteria and
test  methods    for  uniforms  worn  under
protective clothing.
OPEN-CIRCUIT  SELF-CONTAINED
BREATHING APPARATUS

  NFPA 1981 specifies performance criteria and
testing methods for open-circuit self-contained
breathing  apparatus  (SCBA)  in  addition  to
NIOSH/OSHA certification.
VAPOR-PROTECTIVE   SUITS
HAZARDOUS CHEMICALS
EMERGENCIES
FOR
 NFPA  1991  specifies   minimum  design,
performance,   testing,   and   documentation
requirements for vapor-protective suits for
protection from exposure to specified chemicals
in  vapor and  splash environments.   Covers
technical documentation, chemical permeation
resistance, suitpressurization, water permeation,
penetration resistance of closures, exhaust valve
leaking and cracking pressure; and materials for
testing for burst, tear, abrasion, flammability,
cold performance and flexural fatigue.
LIQUID SPLASH-PROTECTIVE SUITS
FOR   HAZARDOUS   CHEMICALS
EMERGENCIES

  NFPA  1992  specifies  minimum  design,
performance,   testing,   and   documentation
requirements for liquid splash-protective  suits
for protection  from  exposure  to  specified
chemicals in liquid splash environments. Covers
technical documentation,  chemical  permeation
resistance, and water permeation; and materials
for  testing  for   burst,   tear,    abrasion,
flammability,  cold  performance and  flexural
fatigue.
SUPPORT FUNCTION GARMENTS  FOR
HAZARDOUS CHEMICALS OPERATIONS

  NFPA  1993  specifies  minimum  design,
performance,   testing,   and   documentation
requirements  garments  worn  by  personnel
performing  support   functions  in  known,
controlled atmospheres outside the "hot zone" at
a hazardous material incident.
          NFPA STANDARDS ARE AVAILABLE FROM:

        National Fire Protection Association
              1 Batterymarch Park
                P.O.  Box 9101
            Qunicy, MA 02269-9101
                (617) 770-3000
                                            60

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                  SECTION 1

       OCCUPATIONAL SAFETY AND HEALTH
          REGULATIONS AND STANDARDS

                   PART 4

NIOSH CRITERIA FOR A RECOMMENDED STANDARD FOR
          WORKING IN CONFINED SPACES
                     61

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criteria for a  recommended standard. .
  WORKING  in CONFINED SPACES
    U. S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
                Public Health Service
               Center for Disease Control
        National Institute for Occupational Safety and Health
                December 1979
            For ••!<• by the Superintendent of Document*. U.S Cov

               Printing Office. Wm.hington. D C. 2040?
                       63

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DHEW (NIOSH) Publication No. 80-106

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                                   PREFACE
    The  Occupational  Safety  and  Health Act of 1970 emphasizes the need for
standards to protect the health and safety of  workers  exposed  to  an  ever-
increasing number of potential hazards in their workplace.

    The   National  Institute  for  Occupational  Safety  and  Health  (NIOSH)
evaluates all available research data and criteria  and  recommends  standards
for  safe  work  practices and occupational exposure to toxic substances.  The
Secretary  of  Labor  will  weigh  these  recommendations  along  with   other
considerations,   such   as   feasibility  and  means  of  implementation,  in
promulgating regulatory standards.

    NIOSH  will  periodically  review  the  recommended  standards  to  ensure
continuing protection of workers and  will  make  successive  reports  as  new
research  and  epidemiologic studies are completed and as engineering controls
for the workers safety are developed.

    The  contributions  to  this  document  on  working  in confined spaces by
members of the NIOSH staff, other Federal agencies or departments, the  review
consultants,  and  Robert  B. O'Connor, M.D., NIOSH consultant in occupational
medicine, are gratefully acknowledged.

    The  views  and  conclusions expressed in this document, together with the
recommendations for a standard, are those of NIOSH.  They are not  necessarily
those  of  the  consultants,  the reviewers selected by professional and trade
associations, or other Federal agencies.  However, all  comments,  whether  or
not  incorporated,  were  considered carefully and were sent with the criteria
document  to  the  Occupational   Safety   and   Health   Administration   for
consideration in setting the standard.  The review consultants and the Federal
agencies which received the document for review  appear  on  pages  v  and  vi
respectively.
                                               Anthony Robbins, M.D.
                                               Director, National Institute for
                                                 Occupational Safety and Health
                                     iii

                                       65

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    The  Division  of   Safety   Research,   National  Institute for  Occupational
Safety and Health,  had  primary   responsibility  for  the  development   of   the
criteria  and  recommended   standard   for  confined  spaces.   This document on
entering, working in, and exiting  from confined spaces was prepared by:

         Ted A. Pettit
         Criteria Manager
         Division of Safety  Research

         Patricia M. Gussey
         Chemist
         Division of Safety  Research

         Rebecca S. Simons
         Occupational Health Nurse
         Division of Safety  Research

    The  Division  of Safety Research review for this document was provided by
Earle P. Shoub and James A.  Oppold, Ph.D.

    NIOSH  review  of this  document was provided by Edward J. Baler (Office of
the Director), Vernon E. Rose,  Ph.D.,  Irwin  P.  Baumel,  Ph.D.,  Frank  L.
Mitchell,  D.O.,  Jerry L.  Chandler, Ph.D., Jack McCracken,  Ph.D., David West
(Division of Criteria Documentation and  Standards  Development),   and  Robert
0'Conner, M.D., (NIOSH  Consultant).
                                      iv
                                       66

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                REVIEW CONSULTANTS
O.C. Amrhyn, P.E., C.S.P.
Assistant Manager, Outside Plant
American Telephone and Telegraph
295 North Maple Avenue
Basking Ridge, New Jersey  07920

Colin G. Drury, Ph.D.
Associate Professor
State University of New York at Buffalo
Department Industrial Engineering
Amherst, New York  14260

Richard L. Miller, Ph.D.
Research Chemical Engineer
USAP School of Aerospace Medicine (VNL)
Brooks Air Force Base, Texas  78235

John B. Moran
Director, Industrial Hygiene &
  Professional Services
American Optical Corporation
14 Mechanic Street
Southbridge, Massachusetts  01550

Rafael Moure
Industrial Hygienist
Oil, Chemical, and Atomic Workers
  International Union
1626 Champa Avenue
Denver, Colorado  80201

Gerald R. Williams, M.D., J.D.
Medical Director Watson Refinery
Atlantic-Richfield Company
1801 E. Sepulvada
Carson, California  90747

Philip Zullo
Industrial Hygienist
227 Indian Creek Drive
Mechanicsburg, Pennsylvania  17055
                          67

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                 FEDERAL AGENCIES
Department of Defense

  Department of the Army
    Environmental Hygiene Agency

  Department of the Navy
    Naval Regional Medical Center

Department of Commerce
  Maritime Administration

Department of Health, Education, and Welfare
  National Institute of Health

Department of Interior
  Bureau of Mines

Department of Labor
  Mine Safety and Health Administration
  Occupational Safety and Health Administration

National Aeronautics and Space Administration
                        vi
                            68

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                                   CONTENTS


                                                                    Page

PREFACE                                                             iii

REVIEW CONSULTANTS                                                     v

FEDERAL AGENCIES                                                      vi

   I.  RECOMMENDATIONS FOR A STANDARD FOR
       WORKING IN CONFINED SPACES                                      1

       Section 1 - Definitions                                         1
       Section 2 - Entry and Rescue                                    3
       Section 3 - Permit System                                       6
       Section 4 - Medical                                             8
       Section 5 - Training                                            8
       Section 6 - Testing and Monitoring                              9
       Section 7 - Labeling and Posting                               10
       Section 8 - Safety Equipment and Clothing                      11
       Section 9 - Work Practices                                     13

  II.  INTRODUCTION                                                   18

 III.  CONFINED SPACE HAZARDS                                         19

       Overview and Magnitude of the Problem                          19
       Hazardous Atmospheres                                          21
       General Safety Hazards                                         28
       Statistical Data                                               31

  IV.  DEVELOPMENT OF THE STANDARD                                    37

       Previous Standards                                             37
       Basis for Recommended Standard                                 38

   V.  TRAINING GUIDELINES                                            43

  VI.  RESEARCH NEEDS                                                 46

 VII.  REFERENCES                                                     47

VIII.  APPENDIX I - Cross Reference - NIOSH Recommended
                    Standard for Working In Confined Spaces to
                    the OSHA Standard                                 54

  IX.  APPENDIX II - Recommended Respiratory Selection Guide          58

   X.  APPENDIX III - Sample Permit - Confined Space Entry            61

  XI.  APPENDIX IV - Characteristics of Cases Included as Confined
                     Space Related                                    63
                                     VII
                                       69

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                    I.   RECOMMENDATIONS  FOR A STANDARD FOR
                          WORKING IN CONFINED SPACES
    NIOSH  recommends  the procedures set forth in the following sections as  a
means of protecting the health,  and significantly reducing  accidental  injury
and  death  associated  with  entering,   working in, and exiting from confined
spaces.  The standard is designed not only to make the confined space safe for
the  worker,  but  also to make  the worker cognizant of the hazards associated
with this work area and the safe work practices necessary to deal  with  these
hazards.  The criteria and standard will be reviewed and revised as necessary.
Section 1 - Definitions - For Purposes of this Document

Atmosphere
Ceiling Level
Combustible Dust
Confined Space
 Confined  Space,  Class  "A1
 Confined  Space,  Class  "B
 Confined  Space,  Class  "C
Refers  to  the gases, vapors, mists, fumes,
and dusts within a confined space.

The  maximum  airborne  concentration  of  a
toxic agent to  which  an  employee  may  be
exposed for a specified period of time.

A  dust  capable of undergoing combustion or
of burning when subjected  to  a  source  of
ignition.

Refers  to  a  space  which  by  design  has
limited  openings  for   entry   and   exit;
unfavorable  natural ventilation which could
contain    or    produce    dangerous    air
contaminants,  and which is not intended for
continuous  employee  occupancy.    Confined
spaces   include  but  are  not  limited  to
storage  tanks,   compartments   of   ships,
process    vessels,   pits,   silos,   vats,
degreasers,   reaction   vessels,   boilers,
ventilation   and   exhaust  ducts,  sewers,
tunnels,  underground  utility  vaults,  and
pipelines.

A  confined  space that presents a situation
that  is immediately   dangerous  to   life  or
health   (IDLH).   These  include but are not
limited  to oxygen deficiency,   explosive  or
flammable atmospheres, and/or concentrations
of toxic substances.

A  confined space that has  the  potential for
causing  injury and  illness,  if  preventive
measures  are  not used, but  not  immediately
dangerous to life and health.

A  confined  space  in  which   the potential
hazard  would  not    require    any   special
modification of  the work procedure.
                                       1
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Hot Work
Inerting
Any   work   involving   burning,   welding,
riveting,   or   similar   fire    producing
operations, as well as work which produces a
source  of  ignition,  such   as   drilling,
abrasive blasting, and space heating.

Displacement  of  the  atmosphere  by a non-
reactive gas (such as nitrogen) to  such  an
extent  that  the  resulting  atmosphere  is
noncombustible.
Isolation
Lower Flammable Limit (LFL)
Oxygen Deficiency
Oxygen Enriched Atmosphere
A  process  whereby  the  confined  space is
removed   from   service   and    completely
protected against the inadvertent release of
material by  the  following:   blanking  off
(skillet  type metal blank between flanges),
misaligning sections of all lines and pipes,
a  double block and bleed system, electrical
lockout  of  all  sources  of   power,   and
blocking  or  disconnecting  all  mechanical
linkages.

The  minimum  concentration of a combustible
gas or vapor in air  (usually  expressed  in
percent  by volume at sea level), which will
ignite if  an  ignition  source  (sufficient
ignition energy) is present.

Refers   to  an  atmosphere  with  a  partial
pressure of oxygen (P02) less  than  132  mm
Hg.    Normal  air  at  sea  level  contains
approximately 21% oxygen at a PO2 of 160  mm
Hg.  At an altitude of 5,280 feet normal air
contains approximately 21% 02 at  a  P02  of
132 mm Hg.

Any  oxygen  concentration  greater than 25%
(P02 - 190  mm  Hg)  at  normal  atmospheric
pressure.
Permissible Exposure Limit  (PEL)  The  maximum 8-hour  time weighted average of
                                  any  airborne  contaminant    to   which   an
                                  employee  may  be exposed.  At no time shall
                                  the  exposure  level   exceed   the   ceiling
                                  concentration for that contaminant as listed
                                  in 29 CFR Part 1910  Sub Part  Z.
Purging
Qualified Person
The  method  by which  gases, vapors,  or other
airborne  impurities   are  displaced  from  a
confined  space.

A  person designated by   the   employer, in
writing,  as   capable   (by   education and/or
specialized    training)   of    anticipating,
recognizing,   and     evaluating    employee
                                       71

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Respirator (Approved)
Standby Person
exposure  to  hazardous  substances or other
unsafe conditions in a confined space.  This
person   shall   be  capable  of  specifying
necessary control and/or  protective  action
to insure worker safety.

A  device  which has met the requirements of
30 CFR Part 11 and is  designed  to  protect
the   wearer   from  inhalation  of  harmful
atmospheres and has  been  approved  by  the
Bureau  of  Mines and the National Institute
for Occupational Safety and Health, and Mine
Safety  and Health Administration (formerly,
Mining      Enforcement      and      Safety
Administration).

A   person    trained   in  emergency  rescue
procedures and assigned  to  remain  on  the
outside  of   the confined space and to be in
communication with those working inside.
Section 2 - Entry and Rescue

    The  Confined Space Classification Table on page 4 is based on existing or
potential hazards relative to the confined space.  The classification is based
upon the characteristics of the confined space, oxygen level, flammability and
toxicity.  If any of the hazards present  a  situation  which  is  immediately
dangerous  to  life  or  health (IDLH), the confined space shall be designated
Class A.  The  classification  shall  be  determined  by  the  most  hazardous
condition  of  entering,  working  in,  and exiting a confined space.  Class B
confined space has the potential for causing injury and  illness  but  is  not
immediately  dangerous  to  life  and health.  A Class C entry would be one in
which the hazard potential would not require any special modification  of  the
work procedure.

    The  Check  List  of  Consideration  on  page  5  delineates  the  minimum
preparation  required  for  each  class  of  confined  space  entry.   In  the
recommended standard where specific procedures, activities or requirements are
correlated with a classification:  the procedure,  activity or  requirement  is
mandatory.   As an example, Section 3  - Permit System  (Class A, B and C) means
that a permit is mandatory for Class A, B, and C confined space entry.
                                       3

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                                CONFINED SPACE CLASSIFICATION TABLE
Parameters
     Class A
  Class B
   Class C
Characteristics
 Oxygen
 Flammability
   Characteristics

 Toxicity
immediately dangerous to
life - rescue proced-
ures require the entry
of more than one
individual fully
equipped with life
support equipment -
maintenance of com-
munication requires an
additional standby
person stationed
within the confined
space
16% or less
*(122 mm Hg)
greater than
*(190 mm Hg)
                                      or
                                      25%
20% or greater of LFL
**IDLH
dangerous, but not
immediately life
threatening - rescue
procedures require the
entry of no more than
one individual fully
equipped with life
support equipment -
indirect visual or
auditory communication
with workers
16.1% to 19.4%
*(122 - 147 mm Hg)
or 21.5% to 25%
(163 - 190 mm Hg)

10% - 19% LFL
greater than contamina-
tion level, referenced
in 29 CFR Part 1910
Sub Part Z - less than
**IDLH
potential hazard -
requires no modif-
ication of work
procedures - standard
rescue procedures -
direct communication
with workers, from
outside the confined
space
19.5% - 21.4%
*(148 - 163 mm Hg)
10% LFL or less
less than contamination
level referenced in
29 CFR Part 1910
Sub Part Z
*Based upon a total atmospheric pressure of 760 mm Hg (sea level)
**Immediately Dangerous to Life or Health - as referenced in NIOSH Registry of Toxic
and Chemical Substances,  Manufacturing Chemists data sheets, industrial
hygiene guides or other recognized authorities.

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       CHECK LIST OF CONSIDERATIONS FOR ENTRY,
        WORKING IN AND EXITING CONFINED SPACES
ITEM
CLASS A
CLASS B
CLASS C
1.
2.
3.
4.
5.
6.
7.





8.





9.









10.
11.
X -
0 -
Permit
Atmospheric Testing
Monitoring
Medical Surveillance
Training of Personnel
Labeling and Posting
Preparation
Isolate/lockout/tag
Purge and ventilate
Cleaning Processes
Requirements for special
equipment/ tools
Procedures
Initial plan
Standby
Communications/observation
Rescue
Work
Safety Equipment
and Clothing
Head protection
Hearing protection
Hand protection
Foot protection
Body protection
Respiratory protection
Safety belts
Life lines, harness
Rescue Equipment
Recordkeeping/Exposure
indicates requirement
indicates determination by the qualified
X
X
X
X
X
X

X
X
0
X


X
X
X
X
X


0
0
0
0
0
0
X
X
X
X

person
X
X
0
X
X
X

X
X
0
X


X
X
X
X
X


0
0
0
0
0
0
X
0
X
X


X
X
0
0
X
X

0
0
0
0


X
0
X
X
X


0
0
0
0
0

X

X



                          74

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    If  the  work practice involved in the confined space has the potential to
increase existing hazards' or generate additional ones, it shall  be  necessary
to  frequently  evaluate  the space to determine if a classification change is
warranted.

    Rescue  procedures  shall  be  specifically designed for each entry.  If a
confined space has an A or B Classification, there shall be a trained  standby
person  assigned  to  that  confined  space  with  a  fully  charged, positive
pressure, self-contained  breathing  apparatus  (SCBA)  at  hand.   Additional
duties  of  the  standby  person  are  to maintain unobstructed life lines and
communications to all workers within the confined space, and to summon  rescue
personnel  if necessary.  Under no circumstances will the standby person enter
the confined  space  until  he  is  relieved  and  is  assured  that  adequate
assistance  is  present.  However, while awaiting rescue personnel the standby
person will make rescue attempts utilizing the life  lines  from  outside  the
confined  space.  Rescue teams entering a Class A or B confined space shall be
equipped with all the aforementioned safety equipment of  the  standby  person
and required life lines.

    In the event of a Class C confined space rescue, a supplied-air respirator
or a self-contained breathing apparatus shall be used.  A person  summoned  or
one who recognizes the need for rescue shall summon assistance and await their
arrival outside the confined space.   Respirators  and  life  lines  shall  be
donned  by  rescue  personnel  with  necessary  equipment  for  removal of the
victim(s).
Section 3 - Permit System  (Class A, B, and C)

    Entry  into  a  confined  space shall be by permit only.  The permit is an
authorization and approval in writing that specifies the location and type  of
work  to  be done, and certifies that all existing hazards have been evaluated
by the qualified person, and necessary protective measures have been taken  to
insure the safety of each worker.

    The supervisor or a qualified person shall be responsible for securing the
permit and both shall sign off when the following areas and actions have  been
reviewed and confirmed:

    (a)  Location and description of the work to be done.
         (Class A, B, and C)

    (b)  Hazards that may be encountered.
         (Class A, B, and C)

    (c)  Complete isolation checklist.
         (Class A, B, and C)

         (1)  Blanking and/or disconnecting.

         (2)  Electrical lockout.

         (3)  Mechanical lockout.
                                         75

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    (d)   Special  clothing  and  equipment.
         (Class A and B)

         (1)   Personal  protective  equipment  and clothing

         (2)   Safety harness and/or  lines.

         (3)   Tools approved for use in  accordance with the
              Hazardous Location Classification (NEC-1978).

         (4)   Approved  electrical  equipment.

    (e)   Atmospheric test  readings.
         (Class A, B, and  C)

         (1)   Oxygen level.

         (2)   Flammability and/or  explosive  levels.

         (3)   Toxic substance  levels.

    (f)   Atmospheric monitoring while work is being performed.
         (Class A on a  continuous  basis  and  Class B as determined
         by the Qualified  Person)

    (g)   Personnel training and complete understanding of the hazards.
         (Class A, B, and  C)

    (h)   Standby  person(s) as  named  on the permit.
         (Class A and B)

    (i)   Emergency procedures  and  location of first aid equipment.
         (Class A, B and  C)

    (j)   Confined space classification A, B, and C.

    This permit  shall be  dated and carry an expiration time that will be valid
for one  shift only.  The  permit shall be updated- for each shift with the  same
requirements.

    The   permit   for  a  Class A   or  B  confined  space shall be  posted in a
conspicuous place, close  to the  entrance,  with  a  copy  on  file  with  the
employer.

    The   sample   permit  in  Appendix  III  should serve as a guide and not be
limited  to the  areas   mentioned.    The  training  requirements  of  personnel
entering and/or  working in confined spaces shall be suitable for the nature of
the hazard and the work to be  performed  and  will  therefore  vary  with  the
confined   space   classification.   The  permit  will  vary  among  different
industrial activities.   However,  it should serve  the  same  purpose  for  all
industries, to insure  the safety  of the worker.
                                      7


                                    76

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Section 4 - Medical  (Class A,  B)

    (a)  Workers  who  enter  a  Class A or B confined space shall have a pre-
placement physical examination made available to  them.   The  employer  shall
provide   to   the   physician  performing  or  responsible  for  the  medical
surveillance program information such  as  the  type  of  confined  space  the
employee  may  be  required  to enter, the type of substances the employee may
encounter, and a description  of  any  protective  devices  or  equipment  the
employee may be required to use.  The physical examination shall include:

         (1)  A  demonstration  of  the  worker's  ability to use negative and
positive pressure respirators as cited in 29 CFR 1910.134.

         (2)  A demonstration of the workers ability to see and hear warnings,
such as flashing lights, buzzers or sirens.

         (3)  The  examination should place emphasis on general evaluations of
the employee's ability to carry out his assigned duties and the  detection  of
any  diseases  or  abnormalities  which  may  make it difficult to work within
confined spaces.

    (b)  Following completion of the examinations, the physician shall give to
the employer a written statement specifying any condition or abnormality found
which  would  increase  risk  to  the employee's health by working in confined
spaces.

    (c)  Periodic medical examinations shall be made available to employees
required to work in Class A or B confined spaces.

    (d)  First Aid Provisions

         (1)  For  Class  A  and B entry there shall always be someone readily
available in the area of the  confined  space  who  is  currently  trained  in
cardio-pulmonary resuscitation (CPR) and basic first-aid procedures.

         (2)  Employees  shall  be aware of the location of the nearest first-
aid equipment, and how to obtain emergency assistance and  medical  attention.
An  adequate  supply of first-aid equipment shall be within easy access of the
confined space.

    (e)  Records of exposure to known health hazards shall be included in that
employee's medical record.  These records  shall  be  made  available  to  the
designated  medical  representatives of the Secretary of Health, Education and
Welfare, of the Secretary of Labor, of the employer and  of  the  employee  or
former employee.
Section 5 - Training  (Class A, B, and C)

    The  employer  shall  be  responsible  for  training personnel and for the
safety of the entire  operation.   Personnel  who  work  in  the  vicinity  of
confined  spaces  shall  be made aware of the hazards associated with confined
spaces during orientation.  Personnel who are required to work in  a  confined
space,  or  in  support  of  those  working  in  a  confined  space shall have
additional training in the following areas:

                                      8

                                         77

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    (a)  Emergency entry and exit procedures (Class A, B, and C) ;

    (b)  Use of applicable respirators (Class A, B, and C) ;

    (c)  First aid (Class A, B);

    (d)  Lockout procedures (Class A,  B, and C);

    (e)  Safety equipment use (Class A, B, and C);

    (f)  Rescue  and training drills designed to maintain proficiency shall be
given initially to new employees, and thereafter, at  least  annually,  or  at
lesser  intervals  as  determined  necessary  by  the judgment of  the employer
(Class A, B, and C);

    (g)  Permit system (Class A,  B and C); and

    (h)  Work practices as recommended in Section 9 of this proposed standard.
(Class A, B and C)

    Training shall not be considered as complete until the supervisor or other
employer-designated official, safety or  training  officer,  judges  that  the
employee  has  attained  an  acceptable degree of proficiency for  entering and
working in confined spaces.  The trainee's judgment of  the  adequacy  of  his
training should be properly considered.


Section 6 - Testing and Monitoring  (Class A, B, and C)

    Entry  into  a  confined  space is prohibited until initial testing of the
atmosphere has been done from the outside .  Appropriate tests shall  be  made
to  insure  that  the  atmosphere  is safe.  The tests performed shall include
those for oxygen content, flammability, and toxic  materials.   Any  necessary
additional  tests  will  be  selected and performed to the satisfaction of the
qualified person.  Monitoring of a Class A confined space shall be done  on  a
continuous  basis.   Class  B  and  C  shall be monitored as determined by the
qualified person.

    Entry  into  a confined space for any type of hot work shall be prohibited
when tests indicate the concentration of flammable gases in the atmosphere  is
greater  than  10%  of the lower flammability limit (LFL).  It is necessary to
determine the oxygen level (by appropriate testing)  prior  to  measuring  the
range  of  flammability  to  make  necessary  corrections  in the flammability
measurement.  Monitoring of the atmosphere shall be  performed  in  accordance
with  the  permit.   Equipment  for  continuous monitoring of gases and vapors
shall be explosion  proof  and  equipped  with  an  audible  alarm  or  danger
signaling  device  that  will  alert  employees  when  a  hazardous  condition
develops.  Instruments used for testing the atmosphere  in  a  confined  space
shall   be   selected  for  their  functional  ability  to  measure  hazardous
concentrations.  Instruments  shall  be  calibrated  in  accordance  with  the
manufacturer's  guidelines  or  manuals.   Each calibration shall be recorded,
filed by the employer, and available for inspection for 1 year after the  last
calibration date.
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    In  any  confined  space  classified  as a Class II or Class III hazardous
location according to the 1978 National Electrical Code, Article 500  Sections
5 and 6, a fire watch shall be established as part of the entry procedure.  In
such areas surface dust and fibers shall be removed and no hot work  shall  be
initiated until the airborne particulate level is below 10% of the LFL for the
material.  When combustible dusts or ignitable fibers/flyings are present, all
equipment and ventilation systems used in the confined space shall comply with
Articles 502 and 503 of the National Electrical Code.

    The  percentage of oxygen for entry into a confined space shall be no less
than 19.5% nor greater than 25% at  760  mm  Hg.   At  sea  level  the  normal
atmospheric  pressure  for air (20.9% 02 + 78.1% N2 + 1% Ar + trace amounts of
various inert gases) is 14.7 psi or 760 mm Hg absolute.  The partial  pressure
of  oxygen  (PO 2)  at  sea  level will be approximately 160 mm Hg.  P02 can be
reduced by reducing the 02 level in  air  at  a  given  elevation  or  through
increasing  altitude.   If  tests indicate the oxygen level to be greater than
25% hot work is prohibited  until  ventilating  techniques  have  reduced  the
oxygen  level  to  approximately 21%.  If the percentage of oxygen falls below
19.5% approved respiratory equipment shall be used in accordance with  Section
8 and Appendix II.

    When  the contaminants in the atmosphere cannot be kept within permissible
exposure levels as set down in 29 CFR Part 1910 Sub Part Z, then the  employee
shall wear an approved respirator.


Section 7 - Labeling and Posting  (Class A, B, and C)

     (a)  All  warning  signs  shall  be  printed  both  in  English and in the
predominant  language  of  non-English  reading  workers.   Where  established
symbols  exist,  they  shall  also be used.  Workers unable to read labels and
posted signs shall receive information regarding hazardous areas and shall  be
informed of the instructions printed on the signs.

     (b)  All  entrances  to  any  confined space shall be posted.  Signs shall
include but not necessarily be limited to the following information:
                                    DANGER

                                CONFINED SPACE

                               ENTRY BY PERMIT
                                     ONLY
    (c)  When  a  specific  work  practice  is  performed  or  specific safety
equipment is necessary, the following  statement  shall  be  added,  in  large
letters, to the warning sign:
                             RESPIRATOR REQUIRED
                                  FOR ENTRY
                                     10
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                              LIFELINE REQUIRED
                                  FOR ENTRY
                              HOT WORK PERMITTED
                                      OR
                                 NO HOT WORK
    (d)  Emergency procedures, including phone numbers of fire departments and
emergency medical services shall be posted conspicuously within the  immediate
area  of  the  confined  space,  or  at the telephone from which help would be
summoned.
Section 8 - Safety Equipment and Clothing  (Class A, B, and C)

    The entry permit shall include a list of necessary protective equipment to
be used in the confined space as determined  by  the  qualified  person.   The
employer  shall be responsible for the proper use of the safety equipment, and
the inspection and maintenance procedures performed on the  safety  equipment.
The type of protective equipment required, will be determined by the qualified
person.

    Those  items  normally  used  to protect against traumatic injury include:
safety glasses, hardhats, footwear and protective clothing.

    (a)  Eye and Face Protection - For persons who wear corrective spectacles,
either prescription ground safety glasses or piano-goggles shall be  provided.
Additionally if eye-irritating chemicals, vapors, or dusts are present, safety
goggles shall be required, and if both the face and  eyes  are  exposed  to  a
hazard,  as  during  scrapping  scale  or cutting rivets, a full coverage face
shield with goggles shall be used.   During  welding  operations  the  special
goggles or shields required shall be in accordance with 29 CFR 1910.252.

    (b)  Head  Protection  - Hard hats shall meet the requirements cited in 29
CFR 1910.135.

    (c)  Foot  Protection  -  All  foot  protection  shall  meet or exceed the
requirements cited in 29 CFR  1910.136  and  shall  provide,  in  addition  to
protection  from  falling objects, protection from any other hazard identified
by the qualified person.

    (d)  Body  Protection - All personnel entering a confined space shall wear
full coverage work clothing as specified by the qualified person.  Gloves  and
clothing  made  of  impervious  rubber  or  similar material are to be worn to
protect against toxic or irritating materials.  If the hazards of heat or cold
stress  exist in the confined space, clothing which has been tested to provide
protection from over-exposure to these hazards  shall  be  worn.   Other  body
protection  required  in  specific operations such as welding (flame proofed),
riveting (heat resistant) and abrasive blasting (abrasion resistant) shall  be
provided to insure worker safety.
                                     11
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    (e)   Hearing Protection - Shall be required when engineering technology is
insufficient to control the  noise  level,  and  the  ambient  exposure  limit
exceeds  those allowed in Table G-16 of 29 CFR 1910.95.  Emergency alarms shall
be distinguishable when hearing protection is worn.  The  sound  level  meters
used to  measure noise levels shall be certified by NIOSH in accordance with 24
CFR 82.   Where the potential for explosion  exists,  the  sound  level  meters
shall be of an explosion proof design.

    (f)   Respiratory  Protection - Shall be determined by the qualified person
based upon conditions and test results of the confined  space,  and  the  work
activity to be performed.  Halfmask respirators are not recommended for use in
any atmosphere greater than 10 x PEL because of the probability of  accidently
breaking  the  facepiece  to face seal due to the work condition in a confined
space.  Also, gas masks designed for the same respiratory  protection  may  be
substituted for chemical cartridge respirators in the table (see Appendix II),
but they are more cumbersome and restrictive to movement.  The minimum service
time  of  self-contained  breathing apparatus shall be calculated on the entry
time, plus the maximum work period, plus twice the estimated escape  time  for
safety margin.

    The  respirators used shall be NIOSH and MSHA approved devices and shall be
fitted and maintained in accordance with 29 CFR 1910.134.  However,  supplied-
air respirators purchased before 1975 and bearing Bureau of Mines approval may
be used  until  March  31,  1980.   Self-contained  breathing  apparatus,  with
audible   alarms and all gas masks, approved by the Bureau of Mines may be used
until further notice.

    (g)   Hand  Protection  -  If  hands are exposed to rough surfaces or sharp
edges, the degree of protection can range from canvas to  metal  mesh  gloves,
depending  on  the  material  handled.   Gloves  made  of impervious rubber or
similar  material are to  be  worn  to  protect  against  toxic  or  irritating
materials.   Heat protective gloves are required when employees handle objects
with temperatures greater than 60 C (140 F).  Where a current flow through the
body  of  more  than  5  milliamperes  may  result from contact with energized
electrical equipment, employees shall wear insulating gloves  that  have  been
visually  inspected  before  each  use.   Above  5,000 volts, rubber gloves in
accordance with 29 CFR 1910.137 shall be worn.

    Additional safety equipment that is necessary to protect the worker in the
environment of a confined space:  a safety belt with "D" rings for attaching a
life line shall be worn at all times; the combination of a body harness and/or
safety belt with life line shall be used when an employee is required to enter
to  complete  the  gas  analysis; when an employee is working in an area where
entry for purposes of rescue would be contraindicatec (special limitations  or
fire  hazard);  when  any  failure  of ventilation would allow the build-up of
toxic or explosive gases within the time necessary to evacuate  the  area,  or
when the atmosphere is immediately dangerous to life and health.  Safety belts
may be used as the primary means of suspension for the  life  line  only  when
rescue  may  be  made  by  keeping  the  disabled body in a position that will
maintain easy passage through exit openings.  If the exit opening is less than
18  inches (45 cm) in diameter, then a wrist type harness shall be used.  When
it is determined by the qualified person that  none  of  the  special  hazards
associated  with  confined  spaces  pose  an immediate threat to life, as in a
Class C  entry, then life lines shall be readily available but not used  during
entry and work procedures.

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    Other  protective  measures  shall  include:   safety nets used to protect
employees working 10 feet (3  m)  above  ground  or  grade  level  when  other
protective  devices  are  impractical;  life  jackets  worn if the workers are
exposed to falls into liquid over 4 feet (1.2 m) in depth; and insulated floor
mats when hot work requires use of electrical energy.

    When  employees  enter  a  confined space, a barricade shall be erected if
inadvertent entry poses a problem.  The barricade shall have  a  mechanism  to
prevent  closure  of  the  escapeway,  signs  warning of the danger present, a
physical barrier (fence) to keep the area clear, and an adequate  platform  (3
feet  x  3  feet  as  a  minimum) for entry or exit.  Such added features as a
tripod with block and tackle for  safety  lines  and  communication  equipment
should be considered when the entry plan is formulated.  The employer shall be
responsible for maintenance of the barricade system.


Section 9 - Work Practices  (Class A, B, and C)

    Before  entering  a  confined  space,  employees shall review the specific
guidelines appropriate for safe entry and emergency exit.  These guidelines or
standards  shall  be compiled by the qualified person and be definitive on all
the possible hazards.  Areas covered by  such  guidelines  shall  follow  this
recommended standard.

    (a)  Purging and Ventilating  (Class A, B)

    Environmental  control  within a confined space is accomplished by purging
and ventilating.  The method used will be determined by the potential  hazards
that  arise due to the product stored or produced, suspected contaminants, the
work to be performed, and the design of the confined space.  When  ventilating
and/or purging operations are to be performed, the blower controls shall be at
a safe distance from the confined space.  In  a  Class  A  entry,  an  audible
warning  device  shall be installed in all equipment to signal when there is a
ventilation failure.  When a  ventilation  system  is  operational,  air  flow
measurements  shall  be  made  before  each  workshift  to  ensure that a saf°.
environmental level is maintained.  Initial testing of the atmosphere shall be
performed  from  outside  the  confined  space  before  ventilation  begins to
determine what precautions are necessary in purging and ventilating.   Testing
of  more  remote  regions  within the confined space may be performed once the
immediate area within the confined space has been made safe.  Exhaust  systems
shall be designed to protect workers in the surrounding area from contaminated
air.  If flammable concentrations are present all electrical  equipment  shall
comply with the requirements of NEC  (NFPA no. 70) hazardous locations, and the
bonding  requirements  of  Article  250  of  NEC,  1978.    Where   continuous
ventilation  is not a part of the operating procedure, the atmosphere shall be
tested until continuous acceptable  levels  of  oxygen  and  contaminants  are
maintained  for  three  tests  at  5-minute intervals.  Care shall be taken to
prevent  recirculation  of  contaminated  air  and  interaction  of   airborne
contaminants.

    Continuous general ventilation shall be maintained where toxic atmospheres
are produced as part of a work procedure, such  as  welding  or  painting,  or
where  a toxic atmosphere may develop due to the nature of the confined space,
as in the case of desorption from walls, or evaporation of residual chemicals.
General  ventilation  is  an effective procedure for distributing contaminants

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from a local generation point throughout the  work  space  to  obtain  maximum
dilution.   However,  special  precautions  shall  be taken if the ventilating
system partially blocks the exit opening.   These precautions include a  method
for  providing  respirable air to each worker for the time necessary for exit,
and a method of maintaining communications.

    Local  exhaust  ventilation  shall be  provided when general ventilation is
not effective  due  to  restrictions  in  the  confined  space  or  when  high
concentrations  of  contaminants  occur  in  the breathing zone of the worker.
Local high concentrations of contaminants  may  occur  during  work  activities
such  as  welding,  painting,  and chemical cleaning.  The worker shall not be
exposed to concen rations of contaminants  in excess of those specified  in  29
CFR  Part  1910 Sub Part Z.  Therefore, respiratory protection, as recommended
in Section 8, may be needed in addition to engineering controls.  The  use  of
respiratory  protection  will be determined by the qualified person.  However,
when fumes may be generated that contain highly toxic or other airborne  metal
contaminants,  the  provisions  of  29  CFR  1910.252 shall be observed.  When
freely moving exhaust hoods are used to provide  control  of  fumes  generated
during welding, such hoods shall maintain  a velocity of 100 feet per/minute in
the zone of the welding.  The effective force of freely moving  exhaust  hoods
is  decreased by approximately 90% at a distance of one duct diameter from the
plane of the exhaust opening.  Therefore,  to obtain maximum effectiveness  the
welder  shall  re-position the exhaust hood as he changes welding locations to
keep the hood in close proximity to the fume source.

    Special  precautions  shall  be  taken  when outgassing or vaporization of
toxic and/or flammable substances are likely.  If  the  vapor-generating  rate
can  be  determined, the exhaust rate required can be calculated to dilute the
atmosphere below the PEL and/or 10% of the LFL, whichever is the lower.   This
shall  be  the  lowest acceptable ventilation rate.  If the area of concern is
relatively small, diffusion of the contaminants may be controlled by enclosure
with  a relatively low volume exhaust for  control, or by exhaust hoods located
as close as possible to the area of vaporization or outgassing.  If  the  area
to  be  ventilated  is  too  extensive to  be controlled by local exhaust, then
general ventilation procedures shall be used to control the contaminant level.
When  the  problem  of  outgassing  is  due  to  the application of protective
coatings or paint, ventilation shall be continued  until  the  build-up  of  a
flammable and/or toxic atmosphere is no longer possible.

    There  are three components necessary  for combustion  fuel,  oxygen, and a
source of ignition.  If work with fire becomes necessary in a  confined  space
and  the  source  of  fuel  cannot be controlled, then the atmosphere shall be
inerted.  This is a highly hazardous work  situation, and continuous monitoring
of  the inert make-up ventilation is mandatory.  Monitoring shall include flow
measurement as  well  as  gas  analysis.   The  inerting  operation  shall  be
continuously  monitored  and  supervised by the qualified person.   Since every
confined space will have its own infiltration rate,  inerting  shall  continue
for  the  entire  duration  of  the  work  at a rate that will prevent air from
entering the confined space.

    (b)  Isolation/Lockout/Tagging  (Class A, B)

    The  isolation  procedures  shall  be   specific  for each type of confined
space.  Safety equipment required during this procedure shall be  designated by
the  qualified person and be dependent upon the potential hazards involved.  A
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Class A or B confined space  shall  be  completely  isolated  from  all  other
systems by physical disconnection, double block and bleed, or blanking off all
lines.  In continuous systems, where complete isolation is not possible,  such
as  sewers  or  utility  tunnels,  specific written safety procedures that are
approved and enforced by the employer shall be used.  Blanks used to seal  off
lines shall be capable of withstanding the maximum working pressure or load of
the line (with a minimum safety factor of 4) , be provided with a gasket on the
pressure  side  to  insure  a  leakproof  seal, and be made of chemically non-
reactive material.  Shutoff valves serving the confined space, shall be locked
in  the  closed  position  and  tagged  for  identification.   In  addition to
blanking, pumps and compressors serving  these  lines  entering  the  confined
space shall be locked out to prevent accidental activation.

    All blanks for that specific confined space shall be recorded on the entry
permit and recorded in the employer's  file,  which  shall  be  available  for
inspection.

    If  a  drain line is located within the confined space, provision shall be
made when necessary to tag it and leave it open.  This shall also be  recorded
on the entry permit.

    Additional procedures, which are necessary when the confined space is of a
double wall type construction, eg, water jacketed or similar  type,  shall  be
determined by the qualified person and noted on the entry permit.

    Electrical   isolation   of  the  confined  space  to  prevent  accidental
activation of moving parts that would be hazardous to the worker  is  achieved
by locking circuit breakers and/or disconnects in the open  (off) position with
a key-type padlock.  The only key is to remain with the person working  inside
the  confined  space.   If  more than one person is inside the confined space,
each person shall place his own lock on the circuit breaker.  In  addition  to
the  lockout  system,  there  must  be an accompanying tag that identifies the
operation and prohibits use.

    Mechanical  isolation  of  moving  parts  can be achieved by disconnecting
linkages, or removing drive belts or chains.  Equipment with moving mechanical
parts  shall  also be blocked in such a manner that there can be no accidental
rotation.

    (c)  Cleaning  (Class A, B, and C)

    Procedures  and  processes  used  to  clean the inside of a confined space
shall be reviewed and authorized by the qualified person.  The  method  to  be
prescribed  shall be dependent upon the product in  the space.  If the confined
space contains a flammable atmosphere above  the  upper   flammable  limit,  it
shall  be  purged  with  an inert gas to remove the flammable substance before
ventilating with air.  Initial cleaning shall be done from  outside the  tank if
at all possible.

    Special  procedures should be adopted to handle the hazards created by the
cleaning process itself.  For example:  if  the tank is steamed,  (1)  it  shall
be  allowed to cool prior to entry; (2) ventilation shall be maintained during
neutralization procedures to prevent build-up of toxic materials;  (3) steaming
shall  not  be  used as a cleaning method when the  product stored was a liquid
with an autoignition temperature  120% or less of the  steam   temperature,  and

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 (4)  the  pipe  or  nozzle  of  the  steam hose shall be bonded to the tank to
decrease the generation of static electricity that could accumulate  in  tanks
during  steaming  procedures.   These  and other hazards and controls shall be
evaluated by the qualified person.

    (d)  Equipment and Tools  (Class A, B, and C)

    Equipment  and  tools  to  be  used in a confined space shall be carefully
inspected and shall meet the following requirements:

         (1)  Hand tools shall be kept clean and in good repair.

         (2)  Portable  electric  tools,  equipment,  and  lighting  shall  be
approved in accordance with 29 CFR Part 1910 Sub Part S and be equipped with a
ground  fault  circuit  interrupter  that  meets  the  requirements  of 29 CFR
1910.309.  All grounds shall be checked before electrical equipment is used in
a confined space.

         (3)  All  electrical  cords,  tools,  and equipment shall be of heavy
duty type with heavy duty insulation and  inspected  for  visually  detectable
defects before use in a confined space.

         (4)  Air  driven power tools shall be used when flammable liquids are
present.  The use of air driven power tools will reduce the risk of explosion,
not  eliminate  it.   Explosions  can  arise  by tools overheating (drilling),
sparks produced by striking (percussion), grinding or discharge of accumulated
electrostatic charges developed from the flow of compressed air.

         (5)  Lighting  used  in  Class  A  and  B confined spaces shall be of
explosion proof design  and  where  necessary,  equipped  with  guards.   Only
equipment  listed  by  the  Underwriters  Laboratories  for use in Division 1,
atmospheres of the appropriate class and group, or approved by U.S. Bureau  of
Mines  or  Mining  Enforcement  and  Safety  Administration or Mine Safety and
Health Administration, or the US Coast Guard shall be  used.   Lighting  shall
not  be hung by electric cords, unless specifically designed for that purpose.
The illumination of the work area shall be sufficient to provide for safe work
conditions  as  referenced  in  the ANSI standard All-1-1965, or the revision,
1970.  Under no circumstances will  matches  or  open  flames  be  used  in  a
confined space for illumination.

         (6)  Cylinders  of  compressed  gases  shall  never  be  taken into a
confined space, and shall be turned off at the cylinder valve when not in use.
Exempt  from this rule are cylinders that are part of self-contained breathing
apparatus or resuscitation equipment.

         (7)  Ladders  shall  be  adequately  secured,  or of a permanent type
which provides the same degree cf safety as cited in 29 CFR Part 1910 Sub Part
D.

         (8)  Scaffolding  and  staging  shall  be  properly designed to carry
maximum expected load (safety factor of 4), be  equipped  with  traction  type
planking, and meet the requirements of 29 CFR 1910.28.
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         (9)  Electrical   lines,  junctions  and  appurtenances  will  be  in
accordance with National Electrical Code (NEC)  and National Fire code (NFC)  as
cited in 29 CFR 1910.309.

         (10) Only  hose  lines  and  components  designed  specially  for the
compressed gas and working pressure shall be used, and such systems shall have
a pressure relief valve outside the confined space.

         (11) All  equipment  that may be used in a flammable atmosphere shall
be approved as explosion  proof  or  intrinsically  safe  for  the  atmosphere
involved  by  a  recognized testing laboratory such as the US Bureau of Mines,
MESA, or MSHA for methane and by the Underwriters Laboratories or  by  Factory
Mutual for all cases.

    (e)  Recordkeeping  (Class A, B)

    The  employer shall maintain a written record of training including safety
drills, inspections, tests, and maintenance.  The records shall be retained  1
year  after  the  last date of training, inspection, test, or maintenance.  In
the event of separation of the employee, disposal of equipment  or  appliance,
records may be disposed of after 1 year.

    Where  atmospheric  testing  indicates  the presence of a toxic substance,
records  shall  be  maintained  in  accordance  with  the   existing   Federal
regulation(s).    These   records   shall  include  the  dates  and  times  of
measurements, duties and location of the employees within the confined  space,
sampling  and  analytical  methods  used, number, duration, and results of the
samples taken, PEL  concentrations  estimated  from  these  samples,  type  of
personal  protective  equipment  used,  if  any,  and employees' names.  These
records shall be made available  to  the  designated  representatives  of  the
Secretary of Labor, of the Secretary of Health, Education, and Welfare, of the
employer, and of the employee or former employee.
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                              II.  INTRODUCTION
    This  document  presents  the  criteria and the recommended standard based
thereon that were prepared  to  meet  the  need  for  preventing  occupational
injuries  and deaths associated with persons entering, working in, and exiting
confined spaces.  This document does not  address  the   specialized  areas  of
radiation,  inert  atmospheres  or hyperbaric atmospheres;  except to recognize
they do exist  and  represent  a  potential  hazard.   The   criteria  document
fulfills  the  responsibility  of  the  Secretary  of  Health,  Education, and
Welfare, under Section 20(a)(2) of the Occupational Safety  and Health  Act  of
1970  to  "...develop and establish recommended occupational safety and health
standards."

    After  reviewing data and consulting with others, NIOSH developed criteria
upon which standards can be established to protect the health and  to  provide
for the safety of workers exposed to occupational hazards.   It should be noted
that criteria for a recommended standard should enable management and labor to
develop better work practices and more appropriate training programs that will
result in safer work environments.   Simply  complying   with the  recommended
standard should not be the final goal.

    The  worker  who  enters  a  confined space may be,  or  often is exposed to
multiple hazards due primarily either to ignorance of the potential hazards or
negligence in the enforcement of safety regulations.  Ignorance and negligence
have led to deaths by asphyxiation,  by  fire  and  explosion,  and  by  fatal
exposure  to  toxic  materials.   NIOSH is aware that a  number of deaths occur
each year when workers must enter  and  work  in  a  confined  space,  and  it
recognizes  that  due  to  current data collection methods, an estimate of the
injuries and deaths which do occur will be inaccurate.   Also, since  there  is
no specific Standard Industrial Classification where these  injuries and deaths
are recorded for confined spaces,  they  are  recorded   in   several  different
categories, thereby giving the appearance of a limited exposure to the hazard.

    These  criteria  for  a  standard  are  a  part  of  a continuing series of
documents published by NIOSH.  The proposed standard applies only to  entering
into,  working  in,  and  exiting from confined spaces as applicable under the
Occupational Safety and Health Act of 1970.

    The  method  used  in  this study consisted of developing, evaluating, and
recording information from  extensive  literature  searches, site  visits  to
various  industries,  and  consultation  with  reviewers knowledgeable on the
subject of confined spaces.

    Standards  covering  issues  of occupational safety  and health that are of
general application without regard to any specific industry are intended to be
applicable  to  this recommended standard even though no specific reference is
made to them.  Examples  of  these  general  areas  are:    exposure  to  toxic
chemicals, noise, temperature extremes, and general duty requirements.
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                         III.  CONFINED SPACE HAZARDS
Overview and Magnitude of the Problem

    (a)  Overview

    The  hazards  encountered  and  associated  with  entering  and working in
confined spaces are capable of causing bodily injury, illness,  and  death  to
the  worker.   Accidents  occur  among workers because of failure to recognize
that a  confined  space  is  a  potential  hazard.   It  should  therefore  be
considered  that  the most unfavorable situation exists in every case and that
the danger of explosion, poisoning, and asphyxiation will be  present  at  the
onset of entry.

    Before  forced  ventilation  is  initiated, information such as restricted
areas within the  confined  space,  voids,  the  nature  of  the  contaminants
present,  the  size  of  the  space, the type of work to be performed, and the
number of people involved should be considered.  The  ventilation  air  should
not create an additional hazard due to recirculation of contaminants, improper
arrangement of the inlet duct, or by the substitution of anything  other  than
fresh  (normal)  air  (approximately  20.9% oxygen, 79.1% nitrogen by volume).
The terms air and oxygen are sometimes considered synonymous.   However,  this
is  a dangerous assumption, since the use of oxygen in place of fresh (normal)
air for ventilation will expand the limits of flammability  and  increase  the
hazards of fire and explosion.

    Hazardous  conditions  to be discussed in this Chapter include:  Hazardous
Atmospheres (flammable, toxic, irritant, and asphyxiating), and General Safety
Hazards (mechanical, communications, entry and exit, and physical).

    An  estimation  of  the  number of workers potentially exposed to confined
spaces would be difficult to produce.  A report prepared  under  contract  for
NIOSH  [1]  shows  that  the  rate  of  confined space related injuries in the
shipbuilding and repair industry is 4.8%.   Projected  on  a  national  level,
2,448  accidents  per  year  may  be  attributed  to the hazards of working in
confined spaces in this single industry.  The Bureau of Labor Statistics shows
that the Standard Industrial Classification (SIC) 373, Shipbuilding and Repair
Industry, has a 23.9% injury rate.  Based  on  this  injury  rate  5%  of  all
accidents  in  the Shipbuilding and Repair Industry occur while working in and
around confined spaces.  Because of the lack of data it  is  not  possible  at
this  time  to  project  this proportion of confined space related injuries to
other industries [2] .  Based on  the  total  working  population  of  selected
specific  SIC  codes,  and a rough estimate of the percentage of each category
who may work in confined spaces at some time, NIOSH estimates that millions of
workers may be exposed to hazards in confined  spaces each year.

    (b)  Types of Confined Spaces

    Confined  spaces  can be categorized generally as those with open tops and
with a depth that will restrict the natural  movement  of  air,  and  enclosed
spaces with very limited openings for entry [3].  In either of these cases the
space may contain mechanical equipment with moving parts.  Any combination  of
these   parameters   will  change  the  nature  of  the  hazards  encountered.
Degreasers, pits, and certain types of storage tanks may be classified as open

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topped  confined  spaces that usually contain no moving parts.  However, gases
that are heavier than air (butane, propane, and other hydrocarbons)  remain  in
depressions  and  will  flow  to low points where they are difficult to remove
[4].   Open  topped  water  tanks  that  appear  harmless  may  develop  toxic
atmospheres  such  as  hydrogen  sulfide from the vaporization of contaminated
water [5].  Therefore, these gases (heavier than air) are  a  primary  concern
when  entry  into  such  a confined space is being planned.  Other hazards may
develop due to the  work  performed  in  the  confined  space  or  because  of
corrosive  residues  that accelerate the decomposition of scaffolding supports
and electrical components.

    Confined  spaces  such  as  sewers,  casings,  tanks,  silos,  vaults, and
compartments of ships usually have limited access.  The  problems  arising  in
these  areas  are  similar to those that occur in open topped confined spaces.
However, the limited access increases the risk of  injury.   Gases  which  are
heavier  than  air  such  as  carbon dioxide and propane, may lie in a tank or
vault for hours or even days  after  the  containers  have  been  opened  [6].
Because  some  gases  are  odorless,  the  hazard may be overlooked with fatal
results.  Gases that are lighter than  air  may  also  be  trapped  within  an
enclosed  type confined space, especially those with access from the bottom or
side.

    Hazards  specific  to  a confined space are dictated by:  (1) the material
stored or used in the confined space; as an example, damp activated carbon  in
a  filtration  tank  will  absorb  oxygen  thus  creating  an oxygen deficient
atmosphere [7]; (2) the activity carried out,  such  as  the  fermentation  of
molasses that creates ethyl alcohol vapors and decreases the oxygen content of
the atmosphere [8]; or (3) the external environment, as in the case  of  sewer
systems  that  may be affected by high tides, heavier than air gases, or flash
floods [9].

    The  most  hazardous  kind  of  confined  space  is the type that combines
limited access and mechanical devices.   All  the  hazards  of  open  top  and
limited  access  confined  spaces  may be present together with the additional
hazard of moving parts.  Digesters and boilers  usually  contain  power-driven
equipment  which,  unless  properly  isolated,  may be inadvertently activated
after entry.  Such equipment may also contain physical  hazards  that  further
complicate the work environment and the entry and exit process.

    (c)  Reasons for Entering Confined Spaces

    Entering  a  confined space as part of the industrial activity may be done
for various reasons.  It is done usually to perform a necessary function, such
as   inspection,  repair,  maintenance  (cleaning  or  painting),  or  similar
operations which would be an infrequent or irregular  function  of  the  total
industrial activity [10].

    Entry  may also be made during new construction.  Potential hazards should
be easier to recognize during construction since the confined  space  has  not
been used.  The types of hazards involved will be limited by the specific work
practices.  When the area  meets  the  criteria  for  a  confined  space,  all
ventilation and other requirements should be enforced.
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    One  of  the  most  difficult  entries  to control is that of unauthorized
entry, especially when there are large numbers of workers and trades involved,
such as welders, painters, electricians, and safety monitors.

    A  final  and  most  important reason for entry would be emergency rescue.
This, and all other reasons for entry, must be  well  planned  before  initial
entry is made and the hazards must be thoroughly reviewed.  The standby person
and all rescue personnel should be aware  of  the  structural  design  of  the
space, emergency exit procedures, and life support systems required.
Hazardous Atmospheres

    Hazardous  atmospheres  encountered in confined spaces can be divided into
four distinct categories:  (a)  Flammable,  (b)  Toxic,  (c)  Irritant  and/or
Corrosive, and (d) Asphyxiating.

    (a)  Flammable Atmosphere

    A  flammable atmosphere generally arises from enriched oxygen atmospheres,
vaporization of flammable liquids, byproducts  of  work,  chemical  reactions,
concentrations  of  combustible  dusts, and desorption of chemicals from inner
surfaces of the confined space.

    Alther  [11]  reported  on  a case involving workers in an enriched oxygen
atmosphere.  Two men entered a newly constructed tank to repair a bulge  which
had  formed  after  the  flange  of  the  manhole was welded to the tank.  The
planned repair procedure was to have two men enter the tank  with  a  jack  to
force  the  flange  of  the manhole into place while a third worker heated the
bulge from the outside.  To accomplish this procedure the men had to close the
manhole.   To  improve  the  air  within the tank, oxygen used for welding was
blown in through an opening.  A worker on  the  outside  noticed  through  the
opening that the hair of one of the workmen inside was on fire.  The cover was
immediately removed and one of the workers managed to escape, his clothing was
burning  rapidly,  the  second  worker  had collapsed and remained unconscious
inside.  It became necessary to invert the  tank  to  remove  the  unconscious
workman.   Both workmen who were doing the work inside suffered serious burns.
One died a short time later; the second was hospitalized for  several  months.
A rescuer in the operation was burned on the hands.

    Investigation  of  the  accident  revealed  the  use of oxygen in place of
normal air increased the flammability range of  combustibles.   Enrichment  of
the  atmosphere  with  only  a  few  percent of oxygen above 21% will cause an
increase in the range of flammability, hair as well as  clothing  will  absorb
the  oxygen  and burn violently.  Enriched oxygen atmospheres which expand the
region of flammability could be the result of improper blanking off of  oxygen
lines,  chemical reactions which liberate oxygen, or inadvertently purging the
space with oxygen in place of air [11].

    An  atmosphere  becomes  flammable when the ratio of oxygen to combustible
material in the air is neither too rich nor too lean for combustion to  occur.
Combustible   gases  or  vapors  will  accumulate  when  there  is  inadequate
ventilation in areas such as  a  confined  spa,ce.   Flammable  gases  such  as
acetylene,  butane,  propane, hydrogen, methane, natural or manufactured gases
or vapors from liquid hydrocarbons can be  trapped  in  confined  spaces,  and

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since many gases are heavier than air, they will seek lower levels as in pits,
sewers, and various types of storage tanks and vessels [12,13).  In  a  closed
top  tank,  it  should  also be noted that lighter than air gases may rise and
develop a flammable concentration if trapped above the opening.

    The  byproducts  of  work  procedures  can generate flammable or explosive
conditions within a confined space.  Specific kinds  of  work  such  as  spray
painting  can  result in the release of explosive gases or vapors [14].  Table
III-3  shows  that  approximately  one-third  of  the  events  identified   as
"atmospheric  condition"  were the result of the victims performing activities
that generated fumes or depleted the oxygen supply.  The most common of  these
activities was welding in a confined space.  Welding in a confined space was a
major cause for explosions in areas that contained combustible gas [1].

    Chemical  reactions  forming flammable atmospheres occur when surfaces are
initially exposed to  the  atmosphere,  or  when  chemicals  combine  to  form
flammable  gases.  This condition arises when dilute sulfuric acid reacts with
iron to form hydrogen or when calcium carbide makes contact with water to form
acetylene.   Other examples of spontaneous chemical reactions that may produce
explosions from  small  amounts  of  unstable  compounds  are  acetylene-metal
compounds,  peroxides,  and nitrates.  .In a dry state these compounds have the
potential to explode upon percussion or  exposure  to  increased  temperature.
Another class of chemical reactions that form flammable atmospheres arise from
deposits of pyrophoric substances (carbon,  ferrous  oxide,  ferrous  sulfate,
iron,  etc)  that  can  be  found  in tanks used by the chemical and petroleum
industry.  These  tanks  containing  flammable  deposits,  will  spontaneously
ignite upon exposure to air [15].

    Combustible  dust  concentrations  are usually found during the process of
loading, unloading, and conveying grain products, nitrated fertilizers, finely
ground  chemical  products,  and  any other combustible material.  It has been
reported that high charges of static  electricity,  which  rapidly  accumulate
during  periods  of  relatively  low  humidity  (below 50%) , can cause certain
substances to accumulate electrostatic charges of sufficient energy to produce
sparks  and  ignite  a flammable atmosphere [14].  These sparks may also cause
explosions when the right air or oxygen to dust or gas mixture is present.

    Desorption  of  chemicals  from  the inner surfaces of a confined space is
another process that may produce a flammable  atmosphere.   This  is  often  a
natural  phenomenon in which the partial pressure at the interface between the
surfaces and the stored chemical is radically  reduced.   For  example,  after
liquid  propane  is  removed  from  a storage tank the walls of the vessel may
desorb the remaining gas from the porous surface of the confined space.

    Dorias  [16]  reported  on  an  explosive  gas-air mixture in a horizontal
cylindrical container (1000 m3), which  had  contained  liquid  propane.   The
cylinder was emptied to check for stress cracking.  The space was to be filled
with water to expell the gas, and drained so it could automatically fill  with
normal  air.   The  container was presumably filled full of water and drained.
The gas analysis of the resulting space showed an explosive  gas-air  mixture.
The  procedure  of  filling  with water and draining was repeated and the test
results were the same, an explosive gas-air mixture.  To speed up the process,
a  man  climbed  into  the  cylinder and sprayed the interior with water for 3
hours, and allowed the interior to air  dry.   On  the  4th  day,  a  mechanic
entered the tank and prepared the areas to be inspected for stress.   Following

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this,  a  man  entered the tank with a test device and a Katel lamp (220 volts
not of an explosion-proof design).   There was a  sudden  explosion  and  flame
streamed  out  of  the  entry manhole.  The man who was testing the atmosphere
suffered severe injuries from which he died 6 days  later.    Investigation  of
the  events  revealed  that the tanks were filled only 50% full the first time
and only 80-90% full the second time.  Therefore, it was concluded  the  space
was  never  thoroughly  emptied  of  all gas.  Reconstruction of the operation
showed that the spraying operation did not remove all the propane, and left  a
gas-air  mixture of approximately 5% propane by volume, an extremely explosive
condition [16].

    (b)  Toxic Atmospheres

    The  substances  to be regarded as toxic in a confined space can cover the
entire spectrum of gases, vapors, and finely-divided airborne dust in industry
[17].   The  sources  of  toxic  atmospheres  encountered  may  arise from the
following:

         (1)  The  manufacturing  process (for example, in producing polyvinyl
chloride, hydrogen chloride is used as well as vinyl chloride monomer which is
carcinogenic).

         (2)  The  product stored (removing decomposed organic material from a
tank can liberate toxic substances such as HjS) .

         (3)  The  operation  performed  in  the  confined space (for example,
welding or brazing with metals capable of producing toxic fumes).

    Zavon  [18] reported, in 1970, that four employees of a local utility were
repairing a water meter in an underground vault 18 feet x 6 feet x 5 feet with
an  opening  24  inches in diameter.  To make the repairs, it was necessary to
cut 26 cadmium plated bolts with an oxygen propane torch.  Two men  worked  in
the vault with one man cutting and the other standing beside him.  Neither man
wore a respirator and no ventilation was provided.  Two other men remained  on
the surface.  During the cutting of the bolts with the oxygen propane torch, a
"heavy blue smoke" filled the vault.   This  smoke  was  exhausted  after  the
cutting was completed.

    The 56-year-old man who had cut the bolts died 17 days after exposure.  He
became nauseated shortly after the job and was seen by  his  family  physician
the  next  day  for fever (102-103 F), chest pain, cough, and sore throat.  On
the 4th day following  the  incident  he  was  in  greater  distress  and  was
hospitalized.   Death  occurred  in   2  weeks  and  was  attributed to massive
coronary infarction and  corpulmonale.  The 29-year-old assistant complained of
chills,  nausea,  cough  and  difficulty  in  breathing.   He  was treated for
pneumonia and made a slow recovery.   A reenactment of  the  work  demonstrated
that   the exposure to cadmium was well above the  threshold limit value of "0.1
mg/m3"  [18].   Symptoms attributed  to  cadmium poisoning include: severe labored
breathing  and  wheezing,   chest pain, persistent cough, weakness and malaise,
and loss of appetite.  The  clinical course is  similar  in  most  cases.   The
injured  frequently  are well enough  to work the  day  after exposure, but their
conditions deteriorate until approximately the  5th day.  At  this  point,  the
exposed worker will either  get much worse or begin to  improve  [19].
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    Toxic gases may be evolved when acids are used for cleaning.  Hydrochloric
acid can react chemically with iron sulfide to produce hydrogen sulfide  [20].
Iron sulfide is formed on the walls of cooling jackets when only several parts
per million sulfide are in the water used  in  the  cooling  process.   As  an
example,  5  men  were  overcome  while  cleaning  a  heat  exchanger  using a
hydrochloric acid solution [20].

    Another  area  where  the hydrogen sulfide hazard exists is in the tanning
industry.  Lime pits used in the process  of  removing  hair  from  the  hides
contain  in  addition to lime, a 1% solution of sodium sulfate  (Na2SOi»).  Acid
dichromate solution is also  used  in  the  tanning  process.   If  these  two
solutions  (sodium  sulfate  and  acid  dichromate) are combined accidentally,
hydrogen sulfide (H2S) will be produced.   One  such  incident  occurred  when
several unused pits at a tannery were Being cleaned.  Sludge had formed on the
bottom of the pit due to drainage from the hides when they  had  been  treated
with  lime  and  acid dichromate.  When men entered the pit to  clear the drain
line, they were overcome.  Because of the high specific  gravity  of  hydrogen
sulfide,  the gas formed by the sodium sulfide-dichromate reaction had settled
in the pit, and when the sludge was stirred  the  released  gas  overcame  the
workers.   In  this instance, 5 men became unconscious and two  died [21].  The
particular hazard associated with hydrogen sulfide at higher concentrations is
due  to its physiological effect of anesthetizing the olfactory nerves and can
also  cause  a  loss  of  reasoning,  paralysis  of  the  respiratory  system,
unconsciousness, and death [22,23].

    During  loading, unloading, formulation, and production, mechanical and/or
human error may also produce toxic gases which are not  part  of  the  planned
operation.

    Toxic  solvents,  which  present problems [24], such as trichloroethylene,
methyl chloroform, and dichloromethane, are used in industry for cleaning  and
degreasing.   Acrylonitrile,  infrequently  used,  has  been encountered as an
ingredient in a protective coating applied to tank interiors [17].

    Trichloroethane and dichloroethane are widely used in industry as cleaning
solvents because they are among the least toxic of the  chlorinated  aliphatic
hydrocarbons.   These  solvents  have  been  used  as a replacement for carbon
tetrachloride and trichloroethylene [25-27].

    In a case report by Hatfield and Maykoski [28] trichloroethane, also known
as methyl chloroform was substituted for trichloroethylene because of the high
toxicity  of  the latter.  A radiator and metal tank repairman was involved in
an aircraft tip tank  cleaning  and  assembly  operation.   The  technique  of
cleaning  the  interior of the tanks varied among workers.  Some workmen would
moisten a pad with solvent and would hand wipe the metal surfaces by  reaching
through an opening on the end of the tank; some would use pads  on the end of a
shaft, while others would climb inside and clean.  One particular worker would
saturate  a pad with solvent and lower himself head first into  the down-tilted
tip of the tank and clean as fast as possible.  This worker was found with his
legs   protruding  from  the  upper  end  of  the  450  gallon  tank  and  was
unresponsive.  He was removed immediately and was given artificial respiration
until a physician arrived and pronounced him dead.

    Reconstruction  of the fatal accident revealed the concentration of methyl
chloroform in the tank had reached 62,000 ppm.  The workers assumed that since

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the  new  cleaning  solvent was less toxic than the one previously used, there
was less danger.  However, the new cleaning solvent, methyl chloroform,  is  a
potent  anesthetic  at  30,000 ppm, which was less than half the concentration
level in the worker's breathing zone.

    The  compatibility of materials must be considered when structural members
and equipment are introduced in confined spaces.  The previous history of  the
confined  space  must  be carefully evaluated to avoid reactions with residual
chemicals, wall scale, and sludge which can be highly reactive.  One such case
was reported in May of 1968, when an aluminum ladder was used for entry into a
chemical evaporating tank which had contained aqueous sodium arsenite (Na As02
H20)  and  sodium  hydroxide (NaOH).  The aluminum reacted with the NaAs02  and
the NaOH to liberate hydrogen, which in turn reacted with the arsenic to  form
arsine  [29].   Other  cases of incompatability arise from the use of chemical
cleaning agents.  The  initial  step  in  chemical  cleaning  usually  is  the
conversion  of  the  scale  or  sludge  into  a  liquid  state which may cause
poisonous gases to be liberated.  In 1974, several employees who were cleaning
a  boiler  tank  prior  to repairing a leak used a cleaning fluid, Vestan 675.
The cleaning action caused the release of ammonia fumes that were not properly
exhausted.   The  men were hospitalized with severe chest pains, but recovered
[29].

    Another  hazardous  gas  that  may  Build up in a confined space is carbon
monoxide (CO).  This odorless colorless gas that has  approximately  the  same
density  of air is formed from incomplete combustion of organic materials such
as wood, coal, gas, oil, and gasoline [30]; it can be  formed  from  microbial
decomposition  of  organic  matter  in  sewers, silos, and fermentation tanks.
Carbon monoxide is  an  insidious  toxic  gas  because  of  its  poor  warning
properties.   Early  stages  of  carbon  monoxide  intoxication are nausea and
headache.  Carbon monoxide may be fatal at 1000 ppm in air, and is  considered
dangerous  at  200  ppm, because it forms carboxyhemoglobin in the blood which
prevents the distribution of oxygen in the body.

    Carbon  monoxide  (CO)  is  a relatively abundant colorless, odorless gas,
therefore, any untested atmosphere must be suspect.  It  must  also  be  noted
that  a safe reading on a combustible gas indicator does not ensure that CO is
not present  [14].  Carbon monoxide  must  be  tested  for  specifically.   The
formation  of  CO  may  result  from  chemical  reactions  or work activities,
therefore, fatalities due to CO poisoning are not confined to  any  particular
industry.   There have been fatal accidents in sewage treatment plants  [8] due
to decomposition products and lack of ventilation in confined spaces.  Another
area  where  CO  results  as a product of decomposition is in the formation of
silo gas in grain storage elevators  [8] .  In another area, the paint industry,
varnish  is manufactured by introducing the various ingredients into a kettle,
and heating  them in an inert atmosphere, usually town gas, which is a  mixture
of  carbon  dioxide  and  nitrogen.   In  one  accident  report, a maintenance
engineer entered a kettle that had been vented for  12-24  hours  to  check  a
blocked  sampling  tube.  He was found dead some time later.  Death was due to
carbon monoxide poisoning.  Investigation into the  inert  gas  supply  system
revealed  that  the  CO   content of  the town gas was over 1%  (10,000 ppm), and
that there were minor faults in the  protective valves into the kettle so  that
a  small leak was occurring.  The employee had entered an atmosphere of reduced
oxygen partial pressure  containing CO and had succumbed before he  could  save
himself   [21].   In  many   cases  CO  poisoning  occurs  because  of poor work
practices .

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    In  welding  operations,  oxides  of nitrogen and ozone are gases of major
toxicologic importance, and incomplete oxidation may occur and carbon monoxide
can  form  as a byproduct [31].  One such case, documented in the Pennsylvania
Occupational Injury Files of 1975, involved an employee who  was  overcome  by
carbon monoxide while welding inside a copper heat-treating oven with the door
partially closed.

    Another   poor  work  practice,  which  has  led  to  fatalities,  is  the
recirculation of  diesel  exhaust  emissions  [32].   Tests  have  shown  that
although the initial hazard due to exhaust toxicants may be from increased CC>2
levels (or depleted 02), the most immediate hazard to  life  processes  is  CO
[33].   Increased  CO  levels  can  only be prevented by strict control of the
ventilation or the use of catalytic converters.

    (c)  Irritant (Corrosive) Atmosphere

    Irritant  or  corrosive  atmospheres  can  be  divided  into  primary  and
secondary groups.  The primary  irritants  exert  no  systemic  toxic  effects
because  the  products  formed by them on tissues of the respiratory tract are
non-irritant, and other irritant effects are so  violent  as  to  obscure  any
systemic  toxic  action.   Examples  of  primary irritants are chlorine (Cla),
ozone (03), hydrochloric acid (HC1), hydrofluoric  acid  (HF),  sulfuric  acid
(H2SO,,),  nitrogen  dioxide (N02) , ammonia (NH3), and sulfur dioxide (S02).  A
secondary irritant is one that may produce systemic toxic effects in  addition
to  surface  irritation.   Examples  of  secondary  irritants  include benzene
(C6H6),   carbon   tetrachloride   (CC1, ),    ethyl    chloride    (CH3CH2C1),
trichloroethane  (CHdCCL3),  trichloroethylene  (CHC1CC12),  and chloropropene
(allyl chloride-CH2CHCH2C1) [34].

    Irritant  gases  vary widely among all areas of industrial activity.  They
can be found in plastics plants,  chemical  plants,  the  petroleum  industry,
tanneries,   refrigeration   industries,   paint   manufacturing,  and  mining
operations [17].

    Prolonged  exposure  at irritant or corrosive concentrations in a confined
space may produce  little  or  no  evidence  of  irritation.   This  has  been
interpreted   to  mean that the worker has become adapted to the harmful agent
involved.  In reality, it means there has been  a  general  weakening  of  the
defense  reflexes  from  changes  in  sensitivity,  due to damage of the nerve
endings in the mucous membranes of  the  conjunctivae  and  upper  respiratory
tract.   The  danger in this situation is that the worker is usually not aware
of any increase In his exposure to toxic substances [17].

    (d)  Asphyxiating Atmosphere

    The  normal atmosphere is composed approximately of 20.97. oxygen and 78.1%
nitrogen, and 1Z argon with small amounts of various other  gases.   Reduction
of  oxygen (Oj) in a confined space may be the result of either consumption or
displacement [35].

    The  consumption  of  oxygen  takes  place  during combustion of flammable
substances, as in welding, heating,  cutting,  and  brazing.   A  more  subtle
consumption  of  oxygen occurs during bacterial action, as in the fermentation
process.  Oxygen may also be consumed during  chemical  reactions  as  in  the
formation  of  rust on the exposed surface of the confined space (iron oxide).

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The number of people working in a confined  space  and  the  amount  of  their
physical activity will also influence the oxygen consumption rate.

    A  second  factor  in  oxygen  deficiency  is displacement by another gas.
Examples of gases that are used to displace  air,  and  therefore  reduce  the
oxygen level are helium, argon, and nitrogen.  Carbon dioxide may also be used
to displace air and can  occur  naturally  in  sewers,  storage  bins,  wells,
tunnels,  wine  vats, and grain elevators.  Aside from the natural development
of these gases, or their use in the chemical process, certain gases  are  also
used as inerting agents to displace flammable substances and retard pyrophoric
reactions.  Gases such as nitrogen, argon, helium,  and  carbon  dioxide,  are
frequently  referred  to  as non-toxic inert gases but have claimed many lives
[36].   The use of nitrogen to inert a confined space has  claimed  more  lives
than  carbon dioxide.  The total displacement of oxygen by nitrogen will cause
immediate collapse  and  death.   Carbon  dioxide  and  argon,  with  specific
gravities  of  1.53  and  1.38,  respectively,  (air = 1) may lie in a tank or
manhole for hours or days after opening [36].  Since these gases are colorless
and  odorless,  they  pose  an  immediate  hazard to health unless appropriate
oxygen measurements and ventilation are adequately carried out.

    In  a report by the Ontario (Canada) Health Department, an underground oil
storage tank which required cleaning, had  been  blanketed  with  nitrogen  to
prevent  oxidation  of the oil.  The man assigned to clean the tank dropped an
air hose into the tank before entering.  As  he  reached  the  bottom  of  the
ladder,  he  passed  out.   His  helper  outside  the tank went in to help and
feeling faint, left without getting the man out.  He went  to  get  assistance
from  a  nearby maintenance shop.  Three men came to the tank and climbed down
and all were overcome.  Finally, after about 20 minutes,  all  four  men  were
recovered  with  the  help of the fire department.  The only reason that there
were no fatalities was that an airline in the tank was blowing  air  into  the
vicinity of the fallen workers [37].

    Oxygen  deprivation is one form of asphyxiation.  While it is desirable to
maintain the atmospheric oxygen level at 21% by volume, the body can  tolerate
deviation from this ideal.  When the oxygen level falls to 17%, the first sijn
of hypoxia is a deterioration to night vision which is not noticeable until  a
normal  oxygen  concentration  is restored.  Physiologic effects are increased
breathing  volume  and  accelerated  heartbeat.   Between  14-16%  physiologic
effects  are  increased  breathing  volume,  accelerated  heartbeat, very poor
muscular coordination, rapid fatigue, and intermittent  respiration.   Between
6-10%   the   effects   are   nausea,  vomiting,  inability  to  perform,  and
unconsciousness.  Less than 6%, spasmatic breathing, convulsive movements, and
death in minutes [12,38].

    In  discussing  oxygen and what constitutes an oxygen deficient atmosphere
from a physiologic view, one must address the concept  of  partial  pressures.
At sea level the normal atmospheric pressure for air (20.9% 02 + 78.1% N2 + 1%
Ar + trace amounts of various inert gases)  is 14.7 psi or 760 mm Hg  absolute.
The partial pressure of 02 (POj) at sea level will be approximately 160 ram Hg.
The concept of partial pressures is that in any mixture of  gases,  the  total
gas pressure is the sum of the partial pressures of all the gases  [39].

    The  P02 in ambient air can be decreased by a reduction in the 02 level at
constant pressure  or  by  maintaining  the  percentage  of  02  constant  and
decreasing  the  total  atmospheric pressure as in the case at high altitudes.

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It is important not only to know the Oa percent by volume, but  to  understand
the  relationship  of 02 to altitude and the concept of partial pressure.  For
example, 20.9% 02 in air at sea level constitutes a greater POa than 20.9%  Qj
at  5,000  feet  because the total atmospheric pressure at 5,000 feet is less.
As the P02 in the atmosphere drops, the volume of air required to  maintain  a
POa  of 60 mm Hg in the alveolar space of the lungs increases.  A PO2 below 60
mm Hg in the alveolar space is considered oxygen deficient [39].

    Absorption  of  oxygen  by  the  vessel  or  the product stored therein is
another mechanism by which the PO2 may be reduced  and  result  in  an  oxygen
deficient atmosphere.  For example, activated carbon, usually considered as an
innocuous material free of occupational hazard and toxicity,  was  responsible
for two fatalities in a carbon filtration tank.  Damp activated carbon absorbs
oxygen and has been known to decrease the oxygen level from 21%  to  4%  in  a
closed vessel [7].

    Montgomery  et  al  [7]  reported  on  two fatalities caused by the use of
activated carbon in a water filtration vessel, (12.5 feet in diameter  and  17
feet  high).   The  space  was newly constructed, filled halfway with granular
carbon in a slurry form (water medium), the water was drained  off  through  a
bottom drain, and the tank was closed off to protect it from the weather.  The
next morning two workers entered the filtration vessel  to  perform  necessary
adjustments  to the carbon bed and the interior sprinkler mechanism.  When the
workmen failed to appear at lunch time, they were found  dead  on  the  carbon
bed.   However,  a  rescuer  entered  the tank without any type of respiratory
protection and with no ill affects.  Tests of the atmosphere revealed no cause
of  death,  the  oxygen  level was 21%, hydrocarbon and hydrogen sulfide tests
were negative.

    The  investigation of the fatalities revealed the following:  the tank was
re-closed and re-opened  the  following  day.   No  toxic  gases  were  found;
however,  the  oxygen  level  had  dropped  from  21% to 12% by volume.  Other
vessels checked at this location which  had  been  closed  for  several  weeks
revealed the oxygen level was down to 2%.

    In  summary, it was discovered that dry carbon would not reduce the oxygen
level significantly.  Damp activated carbon, however, supposedly an  innocuous
material  and free from toxicity, contributed to the death of two workers as a
result of  selective  absorption  of  oxygen  in  a  confined  space  with  no
ventilation.
General Safety Hazards

    (a)  Mechanical

    If  activation  of  electrical or mechanical equipment would cause injury,
each piece of equipment should be manually  isolated  to  prevent  inadvertent
activation  before  workers  enter  or  while  they  work in a confined space.
[12,40].  The interplay of hazards associated with a confined space,  such  as
the  potential of flammable vapors or gases being present, and the build-up of
static charge due to mechanical  cleaning,  such  as  abrasive  blasting,  all
influence the precautions which must be taken.
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    To  prevent  vapor  leaks,  flashbacks,  and other hazards, workers should
completely isolate the space [41].  To completely isolate a confined space the
closing   of   valves  is  not  sufficient.   All  pipes  must  be  physically
disconnected  or  isolation  blanks  bolted  in  place  [5] .    Other   special
precautions  must  be taken in cases where flammable liquids  or vapors may re-
contaminate the confined space.  The pipes blanked or disconnected  should  be
inspected  and tested for leakage to check the effectiveness  of the procedure.
Other areas of concern are steam valves, pressure lines, and  chemical transfer
pipes.   A  less  apparent  hazard is the space referred to as a void, such as
double walled vessels, which must be given special consideration  in  blanking
off and inerting.

    (b)  Communication Problems

    Communication  between the worker inside and the standby person outside is
of utmost importance.  If the worker should suddenly feel distressed  and  not
be  able  to  summon help, an injury could become a fatality.  Frequently, the
body positions that are assumed in a confined space make it difficult for  the
standby  person  to detect an unconscious worker [10].  When visual monitoring
of the worker is not possible because of the design of the confined  space  or
location  of  the entry hatch, a voice or alarm-activated  explosion proof type
of communication system will be necessary  [15].

    Suitable   illumination  of  an  approved  type  is  required  to  provide
sufficient visibility for work in accordance with the recommendations made  in
the Illuminating Engineering Society Lighting Handbook.

    (c)  Entry and Exit

    Entry  and exit time is of major significance as a physical limitation and
is directly related to the potential hazard of the confined space.  The extent
of  precautions  taken and the standby equipment needed  to  maintain a safe work
area will be determined by the means of  access  and  rescue.   The  following
should  be  considered:   type  of  confined space to be  entered,  access to the
entrance, number  and  size  of   openings,  barriers  within   the  space,  the
occupancy  load,  and  the  time  requirement for exiting  in  event of  fire, or
vapor  incursion, and  the time required  to  rescue injured workers  [41].

    (d)  Physical

    The  hazards  described   in this section include non-chemical, physiologic
stressors.  These include thermal effects  (heat  and cold), noise,  vibration,
radiation, and  fatigue while working in a  confined space.

          (1)  Thermal Effects

    Four  factors  influence   the  interchange   of  heat  between man and his
environment.    They   are:    (1)    air   temperature,   (2)   air velocity,   (3)
moisture  contained  in  the air, and (4)   radiant heat  [42,43].  Because of  the
nature and design of most confined  spaces, moisture content  and   radiant  heat
are   difficult   to   control.   As  the   body   temperature  rises progressively,
workers will  continue to  function until the body temperature   reaches   38.3  -
39.4   C.   When   this  body   temperature  is   exceeded,   the   workers  are less
efficient, and  are prone  to heat  exhaustion, heat  cramps,  or  heat stroke  [44].
In a cold   environment   certain physiologic mechanisms come into play, which

                                      29
                                      98

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tend  to limit heat loss and increase heat production.   The most severe strain
in cold conditions  is  chilling  of  the  extremities   so  that  activity  is
restricted  [42] .    Special  precautions must be taken  in cold environments  to
prevent frostbite, trench foot, and general hypothermia.

    Protective  insulated clothing for both hot and cold environments will add
additional bulk to the worker and must be considered in allowing for  movement
in  the  confined   space  and  exit  time.   Therefore, air temperature of the
environment  becomes  an  important  consideration  when  evaluating   working
conditions in confined spaces.

         (2)  Noise

         Noise problems are usually intensified in confined spaces because the
interior tends to  cause sound to reverberate and thus  expose  the  worker  to
higher sound levels than those found in an open environment.  This intensified
noise increases the risk of hearing damage to workers which  could  result  in
temporary  or  permanent loss of hearing.  Noise in a confined space which may
not be intense enough  to  cause  hearing  damage  may   still  disrupt  verbal
communication  with  the  emergency  standby  person  on  the  exterior of the
confined space.  If the workers inside are not able to  hear commands or danger
signals  due  to  excessive  noise,  the  probability  of severe accidents can
increase [42].

         (3)  Vibration

         Wholebody  vibration  may be regarded as a "generalized stressor" and
may affect multiple  body  parts  and  organs  depending  upon  the  vibration
characteristics.   Segmental vibration, unlike wholebody vibration, appears  to
be more localized  in creating injury to the fingers and hands of workers using
tools,  such  as  pneumatic hammers, rotary grinders or other hand tools which
cause vibration [42].

         (4)  General/Physical

    Some  physical  hazards  cannot be eliminated because of the nature of the
confined space or  the work to be performed.  These hazards include such  items
as  scaffolding,  surface  residues,  and  structural  hazards.   The  use  of
scaffolding in confined spaces has contributed to  many  accidents  caused  by
workers  or  materials  falling,  improper  use  of  guard  rails, and lack  of
maintenance to  insure  worker  safety.   The  choice  of  material  used  for
scaffolding  depends  upon  the  type  of work to be performed, the calculated
weight to be supported, the surface on which the scaffolding  is  placed, and
the substance previously stored in the confined space.

    Surface  residues  in  confined  spaces can increase the already hazardous
conditions of electrical shock, reaction of incompatible materials, liberation
of  toxic  substances,  and  bodily  injury  due  to slips and falls.  Without
protective clothing, additional hazards to health may  arise  due  to  surface
residues.

    Structural  hazards  within a confined space such as baffles in horizontal
tanks, trays  in  vertical  towers,  bends  in  tunnels,  overhead  structural
members, or scaffolding installed for maintenance constitute physical hazards,
which  are  exacerbated  by  the  physical  surroundings.   In  dealing   with

                                     30


                                        99

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structural  hazards,   workers  must  review  and enforce safety precautions to
assure safety.

    Rescue  procedures  may  require  withdrawal  of an injured or unconscious
person.  Careful planning must  be  given  to  the  relationship  between  the
internal  structure,  the exit opening, and the worker.  If the worker is above
the opening, the system  must  include  a  rescue  arrangement  operated  from
outside  the confined space, if possible, by which the employee can be lowered
and removed without injury

Statistical Data

    Accidents  in  confined  spaces,  like all others, are required by Federal
regulations to be reported only if medical attention  or  loss  of  time  from
work,  or  death  is involved.  Some states and workers' compensation carriers
have slightly more stringent requirements, but none require the  reporting  of
incidents  which can be considered near misses.  The report by Safety Sciences
prepared under contract for NIOSH [1] tended to show that fatalities  occurred
more  frequently in confined spaces.  For example, death by asphyxiation would
be reported; however, if  an  employee  experienced  shortness  of  breath  or
dizziness,  but managed to escape the confined space, and was not treated by a
physican, this would probably not be a reported case.

    The criteria used in selecting cases was based on the definition published
in the Federal Register 42:213, November 4, 1977  and  specific  circumstances
likely to be found on injury and fatality records.

    Table  III-l  shows  the number of "events", injuries, and fatalities from
each data source.  "Events" refers to the  number  of  separate  occasions  in
which one or more confined space-related injuries or illnesses occurred  [1].

    Table  III-2  shows the number of events, injuries and fatalities obtained
for each of the  15 basic accident and illness types  which  are  described  in
Appendix  4  of  this  document.  A total of 276 confined space related  events
were identified, which resulted in a  total of 234 injuries and 193 fatalities.
The  table  shows that the most hazardous conditions  in a confined space are  a
result of atmospheric related  events  [1].

    Table  111-3  shows   the   number  of  events by  SIC  code for each  of  the 15
confined space-related accident and illness  types  [1].
                                      31
                                      100

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                                 TABLE  III-l
        NUMBER OF CONFINED SPACE-RELATED CASES OBTAINED  BY DATA SOURCE

1.
2.
3.
A.
Data Source
First Reports
from Previous
NIOSH Study 1974-75
OSHA 36's 1976-77
Equifax, Inc.
"Occupational
Death Reports"
8/76-12/76
Shipbuilding and
Repair Cases 1976-77
Totals
Approx . No . of
Cases Reviewed
20,000
6,000
1,700
750
28,450
No. of
Events
67
132
41
36
276
No. of
Injuries
66
130
2
36
234
No. of
Fatalities
1
143
49
0
193
Safety Sciences, San Diego,  California - 1977 [1]
                                     32
                                       101

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       TABLE III-2
ACCIDENT AND ILLNESS TYPE
   CONFINED SPACE (CS)
Ref .
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Totals
Safety


Accident and Illness Type
Atmospheric Condition in CS
Explosion or Fire in CS
Explosion or Fire at Point-of-Entry
to CS
Electrocution or Electrical Shock
Caught In/Crushing of CS
Trapped in Unstable Materials in CS
Struck by Falling Objects in CS
Falls (while in CS; not into CS)
Ingress/Egress of CS
Insufficient Maneuverability in CS
Eye Injury in CS
Contact with Temperature Extreme
in CS
Noise in CS
Vibration in CS
Stress from Excess Exertion in CS

Sciences, San Diego, California - 1977
33
102
Events
80
15
23
11
10
16
15
27
33
15
10
7
1
1
12
276
[1]


Injuries
72
49
20
2
3
0
1
26
30
15
10
4
1
1
0
234



Fatalities
78
15
32
9
10
16
14
1
3
0
0
3
0
0
12
193




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U)
                                                  TABLE III-3






                          CONFINED SPACE EVENTS BY SIC CODE AND ACCIDENT/ILLNESS TYPE
SIC
01
02
07
09
13
15
16

17

20
23
24

25
26
28
29

30
31
32

33
34

Name of Industry
Agricultural Products - Crops
Agricultural Products - Livestock
Agricultural Services
Fishing, Hunting, and Trapping
Oil and Gas Extraction
Building Construction
Construction Other Than Building
Construction
Construction - Special Trade
Contractors
Food and Kindred Products
Apparel
Lumber and Wood Products, Except
Furniture
Furniture and Fixtures
Paper and Allied Products
Chemicals and Allied Prodycts
Petroleum Refining and Related
Industries
Rubber and Misc. Plastic Products
Leather and Leather Products
Stone, Clay, Glass, and Concrete
Products
Primary Metal Industries
Fabricated Metal Products, Ex.
Machinery and Transportation Equip.
*1
4



6
2

6

8
1


1
1
1
8


1
1


1

4
*2 *3 *4 *5 *6 *7 *8 *9 *10 *
1 1 1
1
1
1
1 1 1
22 1 3

3 1 2

41 113
11122131
3

3 1

3 1 1
222 1 1

1
2
1

13 12
1 1 1311

111 1
•11 *12 *13 *14 *15
1




1

1 3

2
1




2 1
1






2 1

1

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                                   TABLE III-3 (CONTINUED)


                 CONFINED SPACE EVENTS BY SIC CODE AND ACCIDENT/ILLNESS TYPE
SIC
35
36
37
3731
38
Name of Industry
Machinery, Except Electrical
Electrical and
Transportation
Shipbuilding
Measuring, Ana]
Electronic Equip.
Equip.

Lyzing, and Controlling
*1 *2 *3 *A *5 *6 *7 *8
2 1 1
1 1
3 2 1
4 1 1

2 2
1
2
8

*9 MO *11 *12 *13 *U *15
1 1
1
4 I
13 7 1



I 1 1
1

       Instruments.; Photographic, Medical,
       and Optical Goods; Watches and
       Clocks                                              1     1
42   Motor Freight Transportation and
       Warehousing                             31           31
44   Water Transportation                      3                 1
45   Transportation by Air                     1                 1
47   Transportation Services                   1     1
48   Communication          ,                   3
49   Electric, Gas, and Sanitary Services      31         1
50   Wholesale Trade - Durable Goods           124        1
51   Wholesale Trade - Nondurable Goods        12         11
54   Food Stores                                                    1
55   Auto Dealers and Gas Stations                                  1
58   Eating and Drinking Places
59   Misc. Retail                                             1
65   Real Estate                               1

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o
                                                     TABLE III-3  (CONTINUED)


                                   CONFINED SPACE EVENTS BY SIC CODE AND ACCIDENT/ILLNESS TYPE
                  SIC              Name of Industry              *1 *2 *3 *A *5 *6 *7 *8 *9 *10 *11 *12 *13 *14 *15
70
73
75
76
82
91

93


*1
*2
*3 -
Hotels, Camps, and Other Lodging Places
Business Services
Automotive Repair
Misc. Repair Services
Educational Services
Executive, Legislative, and General
Government
Public Finance, Taxation, and
Monetary Policy
Unknown
Atmospheric Condition
Explosion or Fire
Explosion or Fire at Point-of-Entry
1
1
1
1
1

1

1
1





1
2









                *4    - Electrocution or Electrical Shock
                *5    - Caught In/Crushing
                *6    - Trapped in Unstable Materials
                *7    - Struck by Falling 'Objects
                *8    - Falls
                *9    - Ingress/Egress
                *10   - Insufficient Maneuverability
                *11   - Eye Injury
                *12   - Contact with Temperature Extreme
                *13   - Noise
                *14   - Vibration
                *15   - Stress from Excess Exertion
               Safety Sciences, San Diego, California - 1977  [1]

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                       IV.   DEVELOPMENT OF THE STANDARD
Previous Standards

    The  basis  for  most of the previous standards  were safety  codes  designed
for specific industrial activities,  and dealt  with areas such as open   surface
tanks, welding and cutting,  and the  pulp and paper,  and shipping industries.

    The  most  recent  standard  published on  confined spaces  is  the 12-year
effort compiled by the American  National  Standards  Institute,  Z117.1-1977.
Despite  the  effort, the ANSI standard does not address the vitally important
areas of training of personnel and specific recommendations  for   the  safety
equipment  required in a confined space.  All  personal protective equipment  is
referenced to different ANSI Standards, which   are  broad   based  and   do  not
address the specific problems of confined spaces.

    The-  ANSI Standard also accepts  the use of tagging as  a reliable method  of
locking out a potentially  hazardous  situation.  The tagging  system as   a
substitute  for  locking out all lines or pipes, or  de-energizing systems  of a
confined space does not provide sufficient protection to   the  worker   against
accidental activation.

    The  ANSI  Standard  does mention the use  of life lines; however,  the  only
recommendation is for their use in an oxygen  deficient atmosphere.

    The  General  Industry  Safety  and  Health  Standards of  the Occupational
Safety and Health Administration (OSHA) address safety in  confined   spaces  in
over  50  different  sections  of  29  CFR 1910.  The defining  parameters  of a
confined space as given in the OSHA regulations are:   (1)  limited means  of
exit,  (2)  a space subject to accumulation of toxic or flammable  contaminants
or, (3) one where an oxygen deficient atmosphere may develop.   It  includes but
is not limited to such spaces as storage tanks, process vessels, bins, boilers
and open top spaces more than A feet in depth.  This is  essentially  the  same
definition  used to establish the scope of this recommended criteria.   However
the "Classification of open-surface tank operation"   (1910.94(d)  (2)   (i-ii))
differs  from  the  classification  system  proposed  in   this  document.  This
proposed classification system is intended to apply to all confined spaces and
is  based  upon  the  evaluation  of  several  additional   parameters.  Such a
classification will allow the application of  a wider range of  safety  measures
and   ease  the  enforcement  of  the  OSHA  regulation.    The  confined  space
classification system was designed to create a focal point by drawing together
over  140 references in the OSHA standards.  For  example,  the use of life lines
in all confined spaces, has been addressed in this document and a solution  to
their  excessive use has been proposed.  The two documents agree on many areas
of good work practices, such as the  use  of  standby  personnel,   blanked-off
lines,  and  main shutoff valves.  Another area  of agreement is the acceptance
of 19.5% as the minimal oxygen level for safe work practice.   There  are  some
areas  of  the  OSHA regulations that appear to  accept tagging as a sufficient
measure to ensure against opening of valves  or   energizing  equipment  during
entry  or  while  working  in  confined  spaces.  The  proposed standard is more
stringent  in  that  only  locking-out,  blanking-off  or  disconnection   are
acceptable.
                                     1306

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    Canadian [45]  and Australian [46,47] regulations and standards  on confined
space entry were reviewed.   The Canadian Standard  uses  a  hazard   evaluation
report, which appears to be a condensed form of the recommended  permit system.
The Canadian Standard also  relies on the qualified person  to make  decisions
for  entry  and   necessary  precautions for working in and for making emergency
escape.  A minimum safe level of oxygen for entry is not stated,  only what  is
considered  an  oxygen  deficient  atmosphere  (less than 17% by volume).   The
Australian Standard,  which  comes under the Factories' Regulations,  states   the
confined  space   shall  be   emptied and flushed of hazardous substances and be
ventilated with  fresh air before entry.  The Australian Standard is  concerned
primarily  with   entry and  exit, not with isolation or safe oxygen  level.   The
Australian Standard does; however, refer to a competent person similar to   the
qualified  person  for  testing  the  atmosphere  for  flammable level. Other
countries [14,48-50]   published  guidelines  or  standards  for   entering   and
working  in  confined  spaces.   Many of those reviewed follow recommendations
similar to the Australian and Candadian standards.   Therefore,   it  would  be
redundant  to make  a  lengthy  comparative  list  of  standards.    The state
standards reviewed [8,12,51-54] and those from industry [40,55-68]   were  also
closely  evaluated.  The number of references involved prohibits the citing of
each one, although valuable concepts were obtained.
Basis for the Recommended Standard

    Workers  who  enter  and  work in confined spaces are confronted with many
potentially hazardous conditions.   The  hazards  can  range  from  an  oxygen
deficient  atmosphere  or liberation of a toxic agent, to mechanical equipment
accidentally energized.  The hazardous atmospheres that can be encountered  in
a  confined  space  are;  flammable,  toxic,  irritant  and/or  corrosive, and
asphyxiation.  These atmospheric conditions  are  discussed  in  Chapter  III,
along  with  cited  accident  cases  to  emphasize  the  hazards involved with
confined space entry.

    The  limited statistical data available on accidents and injuries directly
related to confined  spaces  indicate  a  very  high  mortality  level.   This
disproportionately  high  mortality level for the number of reported accidents
and injuries could be the result  of  inadequate  reporting  methods,  as  not
reporting a near miss with death, or data collection systems failing to list a
confined space as a causative or other factor in traumatic accidents.  In  the
accident  and injury cases tabulated for this document, atmospheric conditions
in confined spaces were responsible for the most  frequent  accident  type  in
terms of events and number of persons killed or injured [1] .

    The  work  practices  section in Chapter I of the recommended standard was
developed  after  extensive  review   of   published   literature,   [2,11,15-
17,31,33,36,55-92]  the  current  Federal,  State, and local applicable codes,
[8,12,51-54,93-101], international codes or recommendations [3,45-50,102], and
site  visits  to  facilities  where  working in confined spaces is part of the
industrial activity.

    (a)  Testing and Monitoring

    Prior  to  entry  into  a  confined space, workers should know the space's
potential hazards.  Deaths have occurred because a presumably safe  space  was
not  tested  prior to initial entry [7,13],  The various tests to be performed

                                     38


                                       107

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prior'to entry shall  include  tests  for  flammability,   toxic   agents,  oxygen
deficiency,  and   harmful   physical agents.   Specific  instruments  are required
for  testing  the  atmosphere  for  flammability,   oxygen   deficiency,  carbon
monoxide,  and physical  agents.   For example,  combustible gas indicators  are
designed for the  purpose of measuring the concentration of flammable  gases ,
and  will  not measure or  indicate the presence of  carbon monoxide at  toxic
levels, conversely a  carbon monoxide detector is designed  for  the  measurement
of  carbon  monoxide  only. It should be noted that combustible gas  indicators
respond  differently   to  different  flammable  hydrocarbons  and  should   be
calibrated   for    the  specific  contaminant  if  known.   The  flammability
measurement may be erroneous  if the oxygen  level  is   less or  greater   than
normal  atmospheric  concentrations.   Therefore,  it   is  recommended  that the
oxygen level be determined prior to flammability testing to make any necessary
corrections in the flammability measurement.

    When   the   materials may  form  a  combustible   dust mixture,   special
precautions must  be taken  to  prevent an explosive atmosphere from developing.
There   are   numerous  instruments  available  for measuring  airborne  dust
concentrations; however, none appear to have automatic alarm systems and would
require  constant  personal  monitoring.   The  only practical approach to the
control of  combustible dusts  is  to  eliminate  the  hazard  by  preventive
measures,  such  as,   (1)   engineering  controls,  (2)  good housekeeping, (3)
elimination of ignition sources,  (4) isolation of  dust  producing  operations
and, (5) training and education of the employees.

    The  oxygen  deficiency  measuring  instrument  is designed to measure the
volume of  oxygen present,  usually scaled with a  range  of  0.0-25%.   If  the
percentage of  oxygen  in  a  confined space atmosphere is less than 19.5% or
greater than 25%, special  precautions, as determined by the qualified  person,
shall  be   taken.   In  accordance with OSHA Safety and Health Standard 29 CFR
Part 1910  and other references [12,33,51,76,87], a  minimum  oxygen  level  of
19.5% has  been adopted for worker safety.  The upper oxygen limit has been set
at  25% because an increase above  this  level will greatly increase the rate  of
combustion of flammable materials  [11].

    Continuous and/or frequent monitoring becomes necessary in cases where the
work being performed within  the confined  space has the potential of generating
toxic agents  [4,5,14,54,58,64,74,81,83,84,86,87].  Data collected for NIOSH by
Safety Sciences  [1] shows  that in 28 out  of  80 accident events, the toxic  gas
or  oxygen deficiency was not in the  confined space at the time of entry, but
was either generated by the work  occurring  in   the  space,  or by  gas  being
unexpectedly  admitted  into   the confined  space  after  the worker had entered.
In  these cases,  only continuous and/or frequent monitoring would be a possible
countermeasure.

     (b)  Medical

    Medical  requirements  for workers who  might  enter  a  confined space  should
take into  consideration the  increased  hazard  potential  of  confined  spaces.  In
this  setting, the workers must rely more heavily upon  their  physical, mental,
and sensory attributes, especially  under  emergency  conditions. Workers  should
be  evaluated  by  competent  medical personnel to  insure  that they are physically
and mentally  able  to wear  respirators  under   simulated   and   actual  working
conditions.   Because   of  the additional stress  placed on the cardiopulmonary
system,  some  pathologic conditions,  such  as cardiovascular diseases  or   those

                                      39
                                     108

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associated  with  hypoxemia, should preclude the use of  respiratory  protective
devices [101].

    In areas where the hazard potential is high, a person certified  in CPR and
first aid should be in attendance.  Since irreversible brain damage  can  occur
in  approximately 4 minutes in an oxygen deficient atmosphere,  it  is essential
that resuscitation attempts occur within that time [102],

    (c)  Safety Equipment and Clothing

    Many  cases  of  accidental  dermal  exposure,  respiratory  distress, and
traumatic injury due to falling objects  have  occurred   in  confined  spaces;
therefore,  a general safety, standard should address the problem of  whole body
protection [3] .  Another area of concern is the  use  of  life  lines  in  all
confined  spaces.  Part of the recommended standard should be an evaluation of
the confined space to define when life lines shall be used and when   a  safety
belt   with   D   rings   for   attaching   life  lines   would  be  sufficient
[12,14,17,53,58,61,73,93,97,103,104],

    (d)  Training

    Training  of  employees  for  entering  and  working in confined spaces is
essential because of  the  potential  hazards  and  the  use  of  life  saving
equipment.  To insure worker safety, the training program should be  especially
designed for the type of confined space involved and the  problems  associated
with entry and exit.  If different types of confined spaces are involved, this
will require  additional  training.   Areas  that  should  be  covered  in  an
effective training program are:

    1.   Emergency entry and exit procedures
    2.   Use of applicable respiratory equipment
    3.   First Aid and Cardio-Pulmonary Resuscitation (CPR)
    4.   Lockout procedures
    5.   Safety equipment use
    6.   Rescue drills
    7.   Fire protection
    8.   Communications

    Training  of  employees  should be done by  the qualified person or someone
knowledgeable  in  all  relevant  aspects  of   confined  space  entry,  hazard
recognition,  use of safety equipment, and rescue  [3,33,53,58,63,68,84,90,97].

    For  training to be effective, classroom sessions, on-the-job training, or
simulated conditions, appear to be the most satisfactory  methods.   Classroom
sessions  should  include all applicable Federal, state, and local regulations
that govern the specific industrial activity in which  the  employee  will  be
working,  as  well as the hazards of a confined space (physical and chemical).
The training guidelines in Chapter V can be used as a  format  for  additional
classroom  activity.   On-the-job  training should be closely supervised until
the employee has a complete understanding of all potential  hazards.   Testing
of  the  employee  should  take   place to evaluate  the person's competency and
determine if retraining is necessary.
                                      40
                                       109

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    (e)  Work Practices

         (1)   Purging and ventilation - poor natural ventilation  is  one  of  the
defining parameters of a confined  space,   therefore   purging   and   mechanical
ventilation  must   be closely evaluated when safe work practices  are developed
for entering  and working in confined spaces.  Purging  is  the initial  step   in
adjusting  the atmosphere in a confined space to acceptable standards  (PEL's,
LEL's, and LFL's).   This is accomplished either by  displacing   the   atmosphere
in  the  confined   space  with  fluid or vapor (inert  gas, water, steam  and/or
cleaning solution) , or by forced air ventilation.   According to the  literature
[11]  20  air  changes  should bring the atmosphere in the confined  space into
equilibrium with  the external environment.

    After purging,  one establishes general  and/or local exhaust ventilation to
maintain a safe uncontaminated level.  Guidelines for  establishing ventilation
rates   are  referenced  in  the  ANSI  Standard Z9.2-1972   [105]   and  NIOSH
Recommended Industrial  Ventilation  Guidelines  [106].  In   addition,  other
information  applicable  to  the  special  problems of confined spaces must be
considered such  as  the  Occupational  Safety  and Health  Standard   29   CFR
1-915.31(b)  [31,45,69,107-109].   Entering   into an inert atmosphere is  one of
the most hazardous  activities associated with working   in a   confined  space.
Work in an inert  atmosphere is usually performed by employees  of  companies  who
specialize in this  because of the high degree of training and  expertise  needed
to  perform  inert   entry operations safely.  The scope of this document deals
with the necessary  precautions but does not cover the  specialized training  for
entry into a  confined space containing an inert atmosphere  [11,106].

         (2)   Isolation/Lockout/Tagging  -   a  review   of the  statistical  data
provided to NIOSH [1] demonstrated an obvious  need for  lockout  procedures.
The  use  of   tags,  while  valuable  for  identification  and/or  information
purposes, appears to have been inadequate in preventing accidents.    A  review
of  the  literature has shown that proper isolation and lockout procedures  are
more effective than tagging [5,6,12,45,55,57,61,64,88,103].

         (3)   Cleaning  -  decontaminating a space  by  cleaning is necessary to
provide for worker  safety.  However, it must be recognized  that  the  cleaning
process  itself  can  generate additional hazards.   Continuous and/or frequent
monitoring is  required  during  this  process  to   determine  that  flammable
mixtures  and  hazardous concentrations of  contaminants are adequately diluted
before safe entry can be made  [3,5,15,20,48,49,59,61,79,80,91].

         (4)   Equipment and tools -  the literature  reviewed  [15,58,63,64,109],
has shown the potential for explosion  is   greatly  increased  when  explosion
proof  equipped  tools  and  equipment  are not used  or improperly maintained.
Also the potential  for electrocution is increased when low voltage  or  ground
fault  circuit interrupters are not used.

          (5)   Permit  System - the inherent dangers associated with a confined
space  clearly indicate the need for  strict  control measures of  employees  and
equipment.   The literature has shown  [50,52,55,56,63,69,77,86,88,90] that the
use of a permit system is a very effective  method of attaining  control.   The
permit  provides  written  authorization  for  entering and working  in confined
spaces, clearly states all known or  potential  hazards,  and  identifies  the
safety equipment required to insure  the safety  of  the worker.
                                     41
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         (6)   Entry  and  Rescue  -  the  potential  hazards  associated  with  a
confined space must be evaluated prior to entry.   These hazards  would  include
the  following:  oxygen level, flatnmability characteristics,  toxic  agents,  and
physical hazards ie, limited openings and communications.   To simplify   entry
and  rescue  it would appear logical to set up a classification  table  for easy
reference.  The literature reviewed [5,12,51,63,69,76]  has provided necessary
information  to set up an entry classification table and allow for  flexibility
in the selection of personal protective equipment.

    It  is essential that well planned rescue procedures and  the proper  use of
personal protective equipment be followed.  The literature and  data  reviewed
have  shown  a  very  poor  record  in successful rescue efforts.  Spontaneous
reaction instead of well planned and executed rescue  procedures  has   led  to
multiple fatalities in confined spaces.  In 19 of the 25 cases in which  rescue
was attempted, the rescuers were injured or killed.  These cases  resulted  in
13  deaths  and  30  injuries  to  rescuers,  even  though only  5 victims were
successfully saved.  One particular case resulted in injury  to   15  rescuers;
however,  they  were successful in saving 3 lives [1].  Therefore,  the standby
and/or rescue team shall be properly equipped and trained in  all  aspects  of
rescue.

          (7)  Recordkeeping  - from a review of the limited data available (no
SIC code for confined spaces) and the information  collected  from  the  plant
site visits on accidents in confined spaces, it is apparent that recordkeeping
systems must be changed to identify  areas  where  accidents  occur,  so  that
underlying  causes  can be determined.  The records to be kept by the employer
should  contain  such  information  as  employee  name,  age,  training,   job
description,  number  of  years  on  the  job, accident location and severity,
underlying causes, and action taken to insure future worker safety.
                                     A2

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                           V.   TRAINING GUIDELINES


    The  very  nature  of   the  hazards  encountered  in  a  confined  space is  of
paramount importance in structuring an effective training  program  which  will
provide  for  safe work practices and techniques.   The training  program should
be based on the specific hazards to be  encountered,  approved   by   a  trained
safety person and given to all individuals who will perform the  work or may  be
assigned as standby or rescue persons.

    (a)  Qualifications of Training Personnel

    It  is  essential  that the person in charge of training know the relevant
aspects of safety as they  relate to confined spaces.  The   instructor(s)  must
have a thorough working knowledge of the following:

         (1)  Type(s)  of   confined  spaces  associated  with  the   industrial
activity.

         (2)  Hazards involved

              (A)  Chemical

              (B)  Physical

         (3)  Work practices and techniques

         (4)  Testing requirements, PEL's, etc.

         (5)  Safety equipment

              (A)  Respirators

              (B)  Clothing

              (C)  Other protection  (shields, helmets,  etc)

         (6)  Rescue procedures

         (7)  Knowledge of applicable Federal,  state, and local regulations

         (8)  Evaluation and test methods

    (b)  Training methods

    The  method  and  approach   of training will be determined by  the  previous
experience  and skills of the employee, with  the exception  of  a   newly   hired
person  who should receive a complete and  thorough safety orientation.   Basic
types of training prescribed are:

         (1)  Orientation  of   all new employees.  This type of  training  would
consist of  classroom sessions along  with  a walk-through of the physical   plant
layout  to give the  trainee a basic understanding of the industrial activity.
                                      A3

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         (2)   On-Che-job  training.  This would be a second  phase  of  training.
After  classroom  sessions  and  after  the  trainee  has   gained   a   basic
understanding  of  the  operation and hazards involved,  on-the-job instruction
should include observation and closely supervised participation in actual work
practices or  simulated conditions.

         (3)   Retraining.   This  should  be  performed  periodically  and  as
frequently as needed.   Many  industrial  activities  are  quite  complex  and
operations  are  frequently updated to keep up with modern innovations.  It is
necessary, therefore, for a formal retraining program to be  planned   so  that
all  personnel  concerned  may  be kept abreast of changes.   Retraining should
also be considered necessary if a supervisor notices a  weakness  in   employee
performance.

    (c)  Training Evaluation

    The effectiveness of the training program can be determined by observation
of the employee by the qualified person to see  if  safe  work  practices  are
being  followed,  testing  the  employee  for  knowledge of the operations and
hazards, and a reduction in the accident rate due to safe work  practices  and
techniques which have been learned and are being practiced.

    (d)  Training Program

    The  work  practices  section presented in Chapter I was designed to set a
formalized standard that could, when  complied  with,  eliminate  or  minimize
accidents  and  injuries occurring in confined spaces.  The standard would not
be sufficient without a formal written training program and  job  planning  to
convey safe work practices and their relationship to the entire operation.

    The  employer is responsible for ensuring  that  each employee is adequately
trained and given refresher courses in assigned duties, and that the  employee
understands  and  applies  safe work practices.  The following are recommended
areas that should be covered thoroughly in training:

         O)  The  types  of  confined spaces  that  are found in the industrial
complex.  This  should  cover  physical  location,  size,  and  any  pertinent
information that would inform the worker of its function.

          (2)  Physical  and  chemical  hazards involved.  The  physical hazards
would include structural members within a confined  space, equipment that  will
be  used,  eg,  scaffolding or ladders, size of openings, flooring, and other.
Chemical hazards discussed will cover  the  product  which  has  been  stored,
chemical cleaners used, and air contaminants which  can be liberated due to the
work practices.

          (3)  Atmospheric  testing  of   the  confined space.  This phase of the
instruction should emphasize  the  contaminants  which should be  tested   for  and
the safe levels for  entry.

          (4)  Cleaning  and  purging.  Cleaning methods  to be  discussed should
include steaming, water rinses, chemical cleaners,  or other specific processes
used .
                                      44


                                        113

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         (5)   Ventilation  of  the  space  by  mechanical methods  to  reduce  or
eliminate toxic  airborne  contaminants.    This  category   should   be  covered
sufficiently   to  alert  the  employee  of potential hazards,  and  the need for
warning devices to signal when there is a ventilation failure.

         (6)   Isolation  and lockout of the confined space.  The worker should
be able to recognize a hazard by visual observation of the  connecting lines  to
a   confined   space.   The  lockout  of  electrical  circuits   and mechanical
disconnects to complete confined space isolation should be  explained  as should
the employees' responsibilities in this area.

         (7)   Safety  equipment  and  clothing.  The worker should be aware  of
the proper use and care required for his personal protective equipment.   This
should  include  the  type  of  protective  shoes,  gloves,  face   protection,
protective clothing, head protection, and safety belts and  harnesses  that  are
to  be  worn   as  well  as  the rationale for their use. A major  area in this
section will  be the use  of  respirators:   the  types  required,   their  use,
quantitative   fit  (test), respirator cleaning procedures,  and proper storage.
It should be  emphasized that  different  type  respirators   are  required  for
different  atmospheres  and  the  dangers involved when the wrong  type is used
[39].  The mandatory wearing of safety belts should be stressed.   The  use  of
safety  belts  and  harnesses  should  be demonstrated so  that each individual
understands  the  importance  of  having  the  rescue  system  available,  and
operative,  and  is  constantly  aware  of the necessity of keeping life lines
clear to the  point of exit.

         (8)   Buddy system and use of a standby person.

         (9)   Communication systems and emergency signals.

         (10) Rescue  procedures.   All  employees  working  in  or  around  a
confined space should be fully trained in emergency entry and exit  procedures
and  be  trained  in first aid and CPR.  This  should include on-site entry and
rescue drills.

         (11) Permit  system used by  the employer.  Information covered on the
permit should include:  purpose of the permit;  location where permit  will  be
posted;   responsible  persons;   emergency   information,  and  hazards  to  be
encountered.

         (12) Documentation  of   Training.    Satisfactory   completion  of this
safety training, and refresher courses, should be entered into the   employee's
permanent record.
                                      45

                                      114

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                             VI.   RESEARCH NEEDS
    The  primary  research  need  in  the  area  of   confined  spaces   is   the
development of a data system that  would  have  the   capability  of  recording
injury and mortality information specific to the causative factor eg,  confined
space and be readily accessible.   It  is  now  impossible  to  retrieve   data
directly  related  to  confined  space  injuries and  mortality, since  data are.
currently  collected  by   general  classifications,    such   as   SIC   codes.
Feasibility  studies  are  being  done by NIOSH on a  system that could correct
this weakness in data recording and retrieval  and provide  a  more  accurate
picture  in areas such as confined space hazards.  These data are essential to
the proper evaluation of  the .causes of injuries  and   deaths.   Specific   data
will  provide  a  base  for establishing training programs and standards  aimed
toward  the  more  hazardous  areas  and  permit  the  evaluation  of   current
standards.   These  data would also provide a background for analyzing unusual
accidents to establish causal factors and prevent recurrence.

    A  final  step  that  would  be  accomplished  by an approved data base on
confined spaces would be to  standardize  the  degree  of  hazards  throughout
industry  and  provide  justification  for  a  uniform standard.  This uniform
standard would serve as the basis for  a  training  program,  which  could  be
tailored to meet the needs of large as well as small  industries.

    The second area of research needed is development of more adequate methods
for preventing and detecting gas leaks into confined  spaces.   Many  accidents
have  occurred  because the atmosphere in a confined  space, which was  presumed
to be safe by the nature of the  contents  or  obvious  safe  history   of  the
confined  space,  had  suddenly become lethal.  Historical cases reported have
shown that faulty seals in storage or processing  vessels  may  allow  seepage
from  an  external  source,  which  could  be naturally lethal or could form a
lethal substance when combined with residual material in the tank.

    A  third  area  for  research  is  the analytical devices used in confined
spaces, such as intrinsically safe continuous monitors for gases  as  well  as
explosive  dusts,  personal  dosimeters, and test meters designed to withstand
rugged field use and  maintain  their  integrity.   It  becomes  difficult  to
calibrate  a  gas  detection meter after continued field use and to be sure of
its accuracy.  The instrument, for  field  use,  should  be  of  the  internal
calibration type that will allow for more accurate testing.

    A  fourth area of research is the need to define and evaluate the  stresses
on employees who are required to work in  confined  spaces.   This  evaluation
should  include  physical  stressors  (eg heat stress, cold stress) and sensory
deprivation with respect to the work practice and length of work period.
                                     46

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                             VII.   REFERENCES
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11.  Alther T:  Protective Measures Applicable  to Welding, Oxygen Cutting and
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16.'  Dorias   H:    Explosive Gas-Air Mixtures.  Die Berufsgenossenschaft.  No.
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17.   Encyclopaedia  of   Occupational Health  and Safety.  1: 330-31, 441, 519-
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18.   Zavon  MR,   Meadows DC:   Vascular Sequalae to Cadmium Fume Exposure.  Am
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23.   Three  Die   in Mill Accident.  The Paperworker  4(6):  1,2.  United Paper
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25.   Saunders RA:   A   New Harard in Closed Environmental Atmospheres.  Arch
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26.   Stahl   CJ,    Abdullah  V,  Fatteh  MB,  Dominguez  AM:  Trichloroethane
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27.   Hadengue A:   A  Case of Fatal Poisoning by Mchlorethane.   Ann Med Log
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29.   Levinsky WJ,  Smalley  RV,  Hillyer PN, Shindler RL:  Arsine Hemolysis.
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30.   The Effects of Carbon  Monoxide.  Fire Journal.  July  1967, pp 46-47

31.   Brief RS, Raymond  LW,  Meyer WH, Yoder JD:  Better Ventilation for  Close-
     Quarter Work Spaces.  Air Conditioning, Heating, and  Ventilation,  1961,
     pp  74-88

32.   Marshall WF,  Hum  RW:   Hazard  from  Engines  Rebreathing Exhaust  in
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33.   Preventing    Confined   Space  Accidents.  MOH,  22(2):   1-8.  Lansing,
     Michigan.  Michigan Department of Public Health, 1977

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34.   Henderson Y, Haggard H:  Noxious Gases and the Principles of Respiration
     Influencing their  Action.  Chapters 8 and 9.  New  York,  Reinhold  Pub.
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35.   Working Safely  in Confined  Spaces.  Safety Newsletter.  Pulp, Paper and
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36.   Allison WW:   Work in  Confined Areas.  National Safety News.  Chicago,
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37.   Entry  Into Confined Spaces.   Occupational Health in Ontario.   22: 13-16.
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38.   Walters JD:  Physiological and  Hygiene Problems Involved in  the Study of
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39.   Pritchard  JA:   A Guide  to  Industrial  Respiratory Protection.  DHEW
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40.   Confined  Space  Entering Safety and Health Procedure.  Bulletin No. 124.
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41.   Clarke JP:   Fertilizer Sessions,  Confined Space Hazards.   Transactions
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42.   Occupational  Diseases,  A  Guide   to  Their  Recognition.   DHEW  (NIOSH)
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47.  South Australia-Regulations Under  the Industrial Code.  Part III General
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                                    49

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48.'  Annual Report on Health  and  Safety  Industry and Services, Confined Space
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49.   Norway State Labor Inspection  Directorate.  Safety Rules No. 34, Work in
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50.   Safe  Work  in  Confined  Spaces,   p   69,  2nd ed. Voorburg, Netherlands,
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51.   Hot,  Flammable, Poisonous,  Corrosive  and  Irritant Substances.  Title 8,
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53.   Work   in Confined  Spaces,  New   Jersey   Administrative  Code  12:170.
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54.   Kentucky  Occupational Safety  and Health General Industry Standards, 803
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                                    50

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64.   Vessel and Confined Space Entry Procedure.  Wilmington, Delaware.  E. I.
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65.   Confined Space Entry Procedure.  Midland, Michigan.  Dow Chemical Co.

66.   Confined Space Entry Procedure.  South Charleston, West Virginia.  Union
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67.   Confined  Space  Entry, Safety Standard No. K-SS-8.2.  Oak Ridge Gaseous
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68.   NASSCO Repair  Dept.  Safety  Manual.  San Diego, California.  National
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69.   Vessel Entry  in the Rubber Industry.  Data Sheet 458.  Chicago, National
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70:   Rames  J:   Welding  in  Confined Spaces.  Metal Construction, p 493-94.
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71.   Cleaning  or  Safeguarding Small Tanks and Containers.  NFPA Standard No.
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72.   Pulp  Mill Digesters.  Data sheet 340.  Chicago, National Safety Council.
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73.   How  to Build  a Breathing Protection Program.  Occup. Hazards, p 46-47.
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74.   Brief  RS,  Confer RG:  Combustible  Gas  Indicator  Response in Low Oxygen
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75.   DeVanna L, Doulames G:  Planning is the Key  to LNG  Tank Purging, Entry,
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76.   Safety Requirements  for  Working   in   Tanks  and  Other Confined Spaces.
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77.   Stephens  KM:  Safer Tank Entry.  Paper  presented  at the National Safety
     Congress.   Chicago.  October  1977,  17 pp

78.   Venting Atmospheric and Low-Pressure Storage Tanks.  API Standard  2000,
     2nd ed. Washington, American Petroleum  Institute.  December  1973,  8 pp

79.   Cleaning   Petroleum   Storage  Tanks.   API Pub.  2015,  2nd ed.   Washington,
     American Petroleum Institute.   November  1976,  15  pp

80.   A  Guide   for Controlling  the Lead  Hazard  Associated with Tank  Entry and
     Cleaning.   API  supplement  to  RP 2015.    Washington,   American  Petroleum
     Institute.   May 1975,  5  pp

81.   Preparation  of  Equipment  for  Safe Entry and Work.   Chap  5  in  Guide for
     Inspection  of   Refinery  Equipment,  2nd  ed.    Washington,    American
     Petroleum Institute.   1972

                                    51
                                     120

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82.'  Inspection,  Rating,   Repair   of  Pressure Vessels in Petroleum Refinery
     Service.  API RP  510,  3rd  ed.  Washington, American Petroleum Institute.
     July  1975,  14 pp

83.   Procedure    for   Entering/Working   in  Vaults  and  Manholes.   Phoenix,
     Arizona.  Salt River Project.  June 1977

84.   Standard  for  the  Control  of  Gas  Hazards on Vessels  to be Repaired.
     National Fire Codes.    10:306-1-1,   306-3-4.2.   Boston,  National  Fire
     Protection  Association.   1978

85.   Control of Flammable  and  Combustible  Liquids and Gases in Manholes,
     Sewers, and Similar   Underground   Structures.   Boston,  National  Fire
     Codes.  13;328-3, 328-18.   National Fire Protection Association.  1971

86.   Work   in  Confined  Spaces.   Procedure  Number  0727-006: 1-7.  Cummins
     Engine Co., Inc.  November 1977

87.   A  Primer   on  Confined  Area Entry.  Malvern, Pennsylvania.  Bio Marine
     Industries, Inc., 17 pp

88.   Neoprene  Latex   Tank   Entry   Procedures.    Louisville,   Kentucky.  E.I.
     Dupont De Nemours and  Company.  July 1975, pp 1—3

89.   Safety Procedure for  Entry and  Work Inside  12' Bubble Vessel.  Appendix
     6. Argonne, Illinois.  Argonne  National Laboratory.  1977

90.   Working in  Confined Areas. Research and Development  Section Fact Sheet.
     Chicago, National Safety Council

91.   Entering  Tanks   and   Other  Enclosed  Spaces.   MCA  Safety Guide SG-10.
     Washington, Manufacturing Chemists  Association.   1961

92.   Meyer.   (Safe  Portable  Electric  Tools.)   Eisen and Stahl.  5:184-205.
     Germany.   1974

93.   Criteria  for  a  Recommended  Standard...Emergency Egress from Elevated
     Workstations.   DHEW   (NIOSH) Publication   No.    76-128.    Rockville,
     Maryland.    U.S.    Department  of   Health, Education  and  Welfare, Public
     Health Service, Center  for  Disease  Control,  National  Institute   for
     Occupational Safety and Health.   1975

94.   Recommended Occupational  Health   Standard...  Occupational Exposure to
     Vinyl Chloride.   DHEW  (NIOSH), Rockville, Maryland.   U.S. Department   of
     Health, Education and  Welfare, Public  Health Service, Center for Disease
     Control, National Institute for  Occupational Safety and Health.  1974

95.   Naval  Engineering  Manual.   Chap   9920,  NSTM.  Washington, U.S. Coast
     Guard

96.   Maintenance of Permanently Installed  Storage and Dispensing Systems  for
     Petroleum  and Unconventional   Fuels.  Air   Force  Manual 85-16.   U.S.
     Department  of  the Air  Force.   May  1965
                                    52


                                       121

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 97.   Safety  Procedures  and  Equipment  for  Confined Space Entry (Including
      Missile Propellant  Tanks).   Technical  Manual  T.O.  00-25-235.   U.S.
      Department of  the Air Force.  January 1974

 98.   Fire  Marshall and Gas Free Engines Manual.  Washington, B.C.  Bureau of
      Naval Personnel.  1971,  80 pp

 99.   Tank   and  Confined  Space  Entry.   Procedures  Number  BCO-O-PEM-097.
      National Aeronautics and Space Administration.  1976

100.   Confined  Space  Entry   Procedure.   Los  Angeles,  Los  Angeles  County
      Sanitation District.  1977

101.   Manual of Respiratory Protection Against Airborne Radioactive Materials.
      NUREG-0041.  U.S. Nuclear Regulatory Commission.  1976

102.   Safe  Practices  in  Confined  Work Areas.  Toronto, Industrial Accident
      Prevention Assn.  1972

103.   Birkhahn  W:   Entering  Confined  Spaces.   Sicherheitsingenieur, 4(5):
      230-241.  Heidelberg, Germany.  May 1973

104.   Olishifski  JB:   Respiratory  Hazards.  National Safety News.  Chicago,
      National Safety  Council.  July 1971, pp 91-95

105.   American  National  Standard.   Z9.2-1971,  Fundamentals  Governing  the
      Design and Operation of  Local Exhaust Systems.  New York, ANSI, 1971

106.   Hagopian   JH,  Bastress   EK:    Recommended   Industrial  Ventilation
      Guidelines, DHEW  (NIOSH)  Publication  No.   76-162.    Cincinnati,  U.S.
      Department  of  Health,  Education and  Welfare, Public Health Service,
      Center for Disease Control, National Institute  for  Occupational  Safety
      and Health, Division of  Physical  Sciences  and Engineering.   1976

107.   Accident  Prevention Manual for Industrial Operations.  6th  ed: 896-916.
      Chicago, National  Safety Council.   1969

108.   TLVs-Threshold  Limit Values  for  Chemical  Substances  and Physical Agents
      in the Workroom  Environment with  Intended  Changes for 1977.  Cincinnati,
      American Conference  of  Government Industrial  Hygienizts.   1977

109.   National Electric  Code,  NFPA  No.  70-1978,  Articles  500 and  555.  Boston,
      National Fire Protection Association.   1978

111).   Safety  Engineering  Tables,  in Accident  Prevention  Manual  for  Industrial
      Operations.   7th ed.  Chap.   46,   1447-1449.   Chicago, National  Safety
      Council.   1974
                                     53
                                     122

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                             VIII.   APPENDIX I
        CROSS  REFERENCE - NIOSH RECOMMENDED STANDARD FOR WORKING IN
                    CONFINED SPACES TO THE OSHA STANDARD
   NIOSH Recommended Standard
     OSHA Standard
Confined Space Definition
Training of Personnel

Isolation,  Lockout,  and Tagging
1926.21(b)(6)(ii)
1915. 2(n)
1916. 2(n)
1917. 2(n)
Standards Notice 20

1926.21(b)(6)(i)

1910.252(d)(3)(i)
1910.261(b)(5)
                                     1910.261(f)(6)(i)
                                     1910.261(g)(4)(ii
                                     1910.261(g)(15)
                                     1910.262(p) and (g)
                                     1910.263(d)(6)(ii)
Cleaning


Testing
1910.252(d)(2)(vi)(c)
1910.261(g)(4)(i)
1915
1917
1915
1916
1917
1915
1916
1915
1916
1926
1926
1926
1926
1926
                                          11
                                          11
                                          33(c)
                                          33(c)
                                          33(c)
                                          33(d)
                                          33(d)
                                          33(e)
                                          33(e)
                                          651(v)
                                          850(e)
                                          956(a)(3)(i)
                                          956(a)(3)(ii)
                                          956(b)(3)
                                       123

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                          APPENDIX I  (CONTINUED)
        CROSS  REFERENCE  - NIOSH  RECOMMENDED STANDARD FOR WORKING IN
                    CONFINED SPACES TO THE OSHA STANDARD
 NIOSH Recommended  Standard              OSHA Standard
Ventilation and  Purging               1910. 94 (d) (11) (iv)
                                     1910.252(e)(4)(ii)
                                     1910.252(f)(2)(i)
                                     1910.252(f)(2)(ii)
                                     1910.252(f)(3)(i)
                                     1910.252(f)(3)(ii)
                                     1910.252(f)(4)(i)
                                     1910.252(f)(4)(li)
                                     1910.252(f)(5)(ii)
                                     1910.261(g)(4)(i)
                                     1910.261(g)(6)
                                     1910.261(g)(15)
                                     1910.261(g)(22)
                                     1910.265(f)(4)
                                     1915. 3L(b)
                                     1916. 31(b)
                                     1917. 31(b)
                                     1918.93
                                     1926.154(a)(2)
                                     1926.353(b)(l)
                                     1926.353(b)(2)
                                     1926.353(c)(l)
                                     1926.353(c)(2)
                                     1926.651 (v)
                                     1926.850 (e)
                                     1926.956(a)(3)(i)
                                     1926.956(a)(3)(ii)
                                     1926.956(a)(3)(iii)
                                     1926.956(b)(2)

Equipment and Tools                  1910. 252 (a) (1)  (ii)
                                     1910.252(e)(4)(iii)
                                     1910.261(g)(15)
                                     1910.263(d)(6)(iii)
                                     1910.265(f)(4)
                                     1915.35(b)(4)
                                     1916.35(b)(4)
                                     1917.35(b)(4)
                                     1915. 32(g)
                                     1916. 32(g)
                                     1917. 32(a)
                                     1926.350(b)(4)
                                     1926.352(g)
                                     55
                           124

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                           APPENDIX I (CONTINUED)
        CROSS REFERENCE - NIOSH RECOMMENDED STANDARD FOR WORKING IN
                    CONFINED SPACES TO THE OSHA STANDARD
   NIOSH Recommended Standard             OSHA Standard
Personal Protective Equipment        1910. 94(a) (5)
                                     1910.94(d)(9)(vi)
                                     1910.94(d)(ll)(v)
                                     1910.134(e)(3)
                                     1910.252(e)(4)(iv)
                                     1910.252(f)(4)(ii)
                                     1910.252(f)(4)(iii)
                                     1910.252(f)(4)(iv)
                                     1910.261(b) (5)
                                     1910. 261 (g) (4) (i)
                                     1910. 261 (g) (6)
                                     1910. 261 (g) (8)
                                     1910. 261 (g) (15)
                                     1915.23(a)(4)
                                     1916.23(a)(4)
                                     1915. 23 (b)
                                     1916. 23(b)
                                     1917. 23 (b)
                                     1915. 24(a)
                                     1916. 24(a)
                                     1916.82
                                     1917.82
                                     1918.82
                                     1926. 21(b) (6) (i)
                                     1926. 103 (b) (3)
                                     1926.104(a)
                                     1926. 104 (b)
                                     1926.104(d)
                                     1926.104(f)
                                     1926.250(b)(2)
                                     1926. 353 (b) (2)
                                     1926.353(c)(2)
                                     1926. 354 (c)
                                     1926.651(v)
                                     1926.957(h)(2)

Standby Person and Rescue            1910.134(e) (3)
                                     1910.134(e)(3)(i)
                                     1910.252(e)(4)(iv)
                                     1910.252(f)(4)(iv)
                                     1910.261(b)(5)
                                    56


                                       125

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                            APPENDIX I (CONTINUED)
         CROSS REFERENCE - NIOSH RECOMMENDED STANDARD FOR WORKING IN
                     CONFINED SPACES TO THE OSHA STANDARD
    NIOSH Recommended Standard             OSHA Standard
Standby Person and Rescue             1910.261 (g) (4)(ii)
                                      1910.261(g)(8)
                                      1910.261(J)(5)(ii)
                                      1910.268(0)(l)(i)
                                      1910.268(0)(l)(ii)
                                      1910.268(0)(2)(i)
                                      1910.268(0)(2)(ii)
                                      1910.268(0)(2)(iii)
                                      1910.268(0)(3)
                                      1910.268(0)(4)
                                      1910.268(0)(5)(i)
                                      1910.268(0)(5)(ii)
                                      1915.46(b)
                                      1916.46(b)
                                      1917.46(b)
                                      1915.54
                                      1916.54
                                      1917.54
                                      1926.353(b)(2)
                                      1926.956(b)(l)
                                      57

                           126

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                                          IX.   APPENDIX II

                              RECOMMENDED RESPIRATORY SELECTION GUIDE
    Hazard
                                   Concentration*
                                Less Than  or Equal To
                    Respirator**
K^    O3
to
particulate

particulate

particulate




particulate


particulate
                                    5  x PEL

                                   10  x PEL

                                   50  x PEL
                                 2000 x PEL
                                 greater than
                                 2000 x PEL
 known gas
 or vapor
 contaminant****
                                 50 x PEL
single use respirator***

any dust respirator***

full facepiece respirator with high efficiency
  filter(s)  or self-contained breathing
  apparatus  with full facepiece operated in
  the demand mode

supplied-air respirator with full facepiece
  operated in any positive pressure mode

self-contained breathing apparatus with
  full facepiece operated in the pressure
  demand mode or a supplied-air respirator
  with full  facepiece operated in any
  positive pressure mode with an auxiliary
  self-contained breathing apparatus

chemical cartridge respirator with full
  facepiece  and cartridges approved for the
  specific contaminant(s) or a full face-
  piece self-contained breathing apparatus
  operated in the demand mode

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                                               APPENDIX II  (CONTINUED)
             Hazard
                      Concentration*
                   Less Than or Equal To
                    Respirator**
          known  gas
          or vapor
          contaminant***
                    2000 x PEL
                               greater  than
                               2000 x PEL
to
oo
combination
of particulates
and gases
or vapors****
                               50 x PEL
Supplied-air respirator with full facepiece
  operated in any positive pressure mode
Self-contained breathing apparatus with full facepiece
  operated in the pressure-demand mode or
  combination supplied-air respirator with
  full facepiece operated in any positive
  pressure mode with an auxiliary self-
  contained breathing apparatus

a full facepiece combination respirator
  approved for dusts and mists and the
  specific contaminant(s) (gases or vapors)
                               1000 x PEL
                               2000 x PEL
                              greater than
                              2000 x PEL
                                              powered air-purifying full facepiece
                                                combination respirator with high
                                                efficiency filter and chemical
                                                cartridge approved for the specific
                                                gas or vapor

                                              supplied-air respirator with full
                                                facepiece operated in any positive
                                                pressure mode

                                              self contained breathing apparatus with
                                                full facepiece  operated in the
                                                pressure-demand mode or combination
                                                supplied-air respirator with full
                                                facepiece operated in any positive
                                                pressure mode with an auxilary self-
                                                contained breathing apparatus

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                                                  APPENDIX II (CONTINUED)
                Hazard
   Concentration*
Less Than or Equal To
                  Respirator**
             unknown
             contaminant
 undetermined
to
             inert and other
             atmospheres
             where the oxygen
             level is below
             17%
             emergency
             entry
                                 unknown
self-contained breathing apparatus with
  full facepiece operated in the positive
  pressure mode or a supplied-air
  respirator with full facepiece operated
  in any positive pressure mode with an
  auxilary self-contained breathing
  apparatus

self-contained breathing apparatus with
  full facepiece operated in the pressure
  demand mode or a combination supplied
  air respirator with full facepiece
  operated in any positive pressure mode
  with an auxiliary self-contained
  breathing apparatus

self-contained breathing apparatus with full
  facepiece operated in the pressure demand
  mode or a combination supplied-air
  respirator with full facepiece operated
  in any positive pressure mode with an
  auxilary self-contained breathing
  apparatus
            *If the concentration forms  a flammable  atmosphere  only  the  self-contained breathing
            apparatus with full facepiece operated in  the  pressure-demand mode may be used.
            **Any respirator recommended for  a higher  concentration  may  be used at a lower concentration.
            ***These respirators  may  not be used if  the  toxic material is carcinogenic.
            ****If the concentration  forms an atmosphere which  is immediately dangerous to life
            then only the self-contained breathing apparatus operated in the pressure mode or the
            combination supplied-air  respirator with full  facepiece  operated in any positive mode
            with an auxilary self-contained breathing  apparatus may  be used.

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                               X.  APPENDIX III

                                SAMPLE PERMIT

                             CONFINED SPACE ENTRY
                                                            CLASS
Location of Work:  	
Description of Work (Trades):
Employees Assigned:
Entry Date:	,	   Entry Time:
Outside Contractors:  	
Isolation Checklist:

    Blanking and/or Disconnecting
    Electrical
    Mechanical
    Other

Hazardous Work:

    Burning
    Welding
    Brazing
    Open Flame
    Other

Hazards Expected:

    Corrosive Materials
    Hot Equipment
    Flammable Materials
    Toxic Materials
    Drains Open
    Cleaning (Ex: chemical or water lance)
    Spark Producing Operations
    Spilled Liquids
    Pressure Systems
    Other

Vessel Cleaned:
    Deposits
    Method
    Inspection  	
    Neutralized with
Fire Safety Precautions:
                                      61
                              130

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Personal Safety:

    Ventilation Requirements
    Respirators
    Clothing
    Head, Hand, and Foot Protection
    Shields
    Life Lines and Harness
    Lighting
    Communications
    Employee Qualified
    Buddy System
    Standby Person
    Emergency Egress Procedures
    Training Sign Off (Supervisor or Qualified Person)_
    Remarks:
Atmospheric Gas Tests

         Tests Performed    -    Location    -    Reading

Example:     (Oxygen)	         	         (19.5%)
Example:     (Flammability)          	         (Less  than 10% LFL)
Remarks:
Test Performed By:
                                       Signature

Time:
Authorizations:

    Supervisor:
    Prod Supervisor:
    Line Supervisor:
    Safety Supervisor:
    Etc.:
Entry and Emergency Procedures Understood:
    Standby Person
    Rescue
    Telephone

Permit Expires:

Classification:
                                     62
                                       131

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                                                   XI.  APPENDIX IV
                            CHARACTERISTICS OF CASES INCLUDED AS "CONFINED SPACE RELATED"
         Ref.   Accident Type
         No.    or Illness
Characteristics of Included Cases
Related, but Excluded, Cases
              Atmospheric
              Condition in
              CS
OJ
to ON
Toxic levels in CS of substances:
- contained in CS
- from decomposition of substances
  in CS
- from mixture of substances in CS
- substances being used in CS,
  eg, cleaning solvents
- catalytic heaters
- vapors left from previously
  emptied CS
- welding fumes

Oxygen deficiency, due to:
- fermentation
- rust
- use of other gases, eg, nitrogen
  to clear combustible gases
- welding in CS

Includes cases in which the
employee was at the point of entry
to the CS (eg, leaning into CS
to measure)  and was overcome.

Includes allergic reactions to
substances inhaled.
Falls or other types which are
not the result of hazardous atmos-
pheric conditions, eg, due to
surface condition of CS, are covered
under other Accident .'Types such as
Ref. No. 8.
           (*Note:   all  cases  involving mining,  tunneling  are  excluded.)

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                                      APPENDIX IV (CONTINUED)
                   CHARACTERISTICS OF CASES INCLUDED AS "CONFINED SPACE RELATED"
Ref.   Accident Type
No.    or Illness
 Characteristics of Included Cases
Related, but Excluded, Cases
                      Includes falls and other accident
                      types even if  the  employee was
                      outside the CS before he fell, if,
                      and.only ifj they  were the result
                      of  being overcome  by atmospheric
                      substances.
                      Examples:   employee was sitting on
                      top of silo and was overcome by
                      gas from fermenting corn and fell
                      into silo;  employee fell from
                      ladder,  when he was overcome by
                      gas in CS;  employee drowned when
                      he  was overcome by gas and fell
                      into 12" deep  water in CS.
    Explosion or
    Fire  in  CS
Only includes cases in which one or
more victims were in the CS at the
time.

May be able to identify a. spark -
generating activity that occurred
in CS, eg,
- dip testing tank
- welding
- electrical tools
- light bulbs
- matches

Usually the result of a
combination of combustible gases
in CS and spark from activity of
employee in CS.
Cases in which a CS exploded but no
victim was inside.

Cases in which the CS exploded for
"no apparent reason" or a reason
not connected with the activities
of those in the CS.

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                                             APPENDIX IV  (CONTINUED)
                           CHARACTERISTICS OF CASES INCLUDED AS "CONFINED SPACE RELATED"
       Ref.  Accident Type
       No.    or Illness
Characteristics of Included Cases
Related, but Excluded, Cases
            Explosion or
            Fire at
            Point-of-Entry
            of CS
ON
           Electrocution
           or Electrical
           Shock
Cases in which an employee was
welding, using a power tool, or
some other spark generating
activity at. the entry point
to the CS.

Driving an automobile near to
a CS containing combustible
materials.
Must appear to be result, at
least in part, of the CS.

Frequently the result of the
conductive walls of the CS.
Cases in which a CS exploded for "no
apparent reason" or for a reason
unconnected with the activity of
the employee near the CS, eg,
"just walking by and it blew up."

Cases in which the employee was
welding (or performing some other
spark-generating activity) on a
CS which is too small for, and
would almost certainly never be
used to contain an employee,
eg, 55 gal oil drums.  Welding
drums containing flammable liquids
or left over vapors is an extremely
common cause of fatalities, and has
causal factors similar to CS-
related cases were not typical
of the problem NIOSH is addressing.

Cases in which an electrically "hot"
source just happened to be in a
CS eg, "I picked up a cable
with a frayed wire".

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                                      APPENDIX IV (CONTINUED)
                   CHARACTERISTICS OF CASES INCLUDED AS "CONFINED SPACE RELATED"
Ref.   Accident Type
No.    or Illness
Characteristics of Included Cases
Related,but Excluded, Cases
    Caught In/
    Crushing
    of CS
Cases in which an employee
entered a machine and failed to
"lock-out".  The machine is
activated and the employee is
crushed inside the machine.

The victim must be inside a
machine which it was intended
that he should enter and he
must have entered deliberately.

Elevator shafts, or cases in
which the employee was on top
of an elevator and crushed in
the "CS" when it was elevated.
Cases in which the machine is too
small for the employee to ever
place his entire body inside
eg, caught in conveyor gear's.

Cases in which the employee was
under (not in) a machine or
machine part.  In particular,
being trapped under a vehicle
eg, when the jack slips or
under a falling bed of a dump
truck are not included.

Cases in which the employee is
drawn into the machine.
                      Examples of such machines
                      include rock crushers.
                                       Elevator injuries if person is
                                       inside the elevator.
     Trapped in
     Unstable
     Materials
     in CS
"Quicksand" effect of standing
in silos containing fine grain or
beans.

Employee must have been in the CS
before the surface gave way
eg, unjamming blockage or
intentionally stepped into CS
with the unstable surface
material.
Falls into machines.

Falls into CS containing such
the result of atmospheric
conditions (Ref. No. 1) .

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                                      APPENDIX IV (CONTINUED)
                   CHARACTERISTICS OF CASES INCLUDED AS "CONFINED SPACE RELATED"
Ref.   Accident Type
No.    or Illness
Characteristics of Included Cases
Related, but Excluded, Cases
     Struck by
     Falling
     Objects in CS
     Falls
     (while in CS)
Employee is struck by objects
falling from walls of CS or through
point of entry of CS.
Related in that employee is
unable to maneuver to safety
in a CS.

Includes being suffocated when
a CS is accidentally filled
while the employee is in it..

Only to employees in CS
due to surface condition eg,
wet, oil; configuration eg,
a rolling barrel; or other
characteristics of the CS.

Falls through holes in or
breaking part of CS, eg,
employee goes through weak part
of ventilation duct as he crawls
through it.

Falls over objects or tools, eg,
holes,  on floor of CS when it  is
not possible to locate elsewhere.

Falls due to poor lighting in  CS.
(Eye injuries are covered in
Ref. No. 11.)
                                                             Does not include cave-ins of
                                                             trenches as these have not been
                                                             considered to be CS's.
Falls into a CS eg, uncovered man-
hole.  Atmospheric condition of CS
                                                             Falls in CS where no characteristic
                                                             of the CS was involved.

                                                             (Falls while leaving or  entering
                                                             the CS are covered in Ref. No. 9.)
                      Falls  due  to  uneven  surface of  CS,

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                                             APPENDIX  IV  (CONTINUED)
                           CHARACTERISTICS OF CASES INCLUDED AS  "CONFINED SPACE RELATED"
        Ref.   Accident  Type
        No.     or  Illness
Characteristics of Included Cases
Related, but Excluded, Cases
             Ingress/Egress
        10   Insufficient
            Maneuver
ON
CO
Strains, bodily reactions,
abrasions, or falls as the result
of entering or leaving a cramped,
sharp-edged, high-level, or
otherwise hazardous point-of-
entry to a CS.

Strains, bodily reactions,
abrasions, contact with caustic
substances, etc. when they are in
part the result of attempting to
maneuver in a CS.

Includes striking self or being
struck by fellow employee as the
result of a CS.

Low head room eg,  striking
head.
(Must be a bonafide CS, eg,
ingress/egress of vehicle cabs,
though subject to similar hazards,
are not included because they
are not a CS.)
Cases of insufficient space when
the employee is working under
a machine (even though cramped),
because these are not
considered a CS.
       11   Eye Injury       From dust falling from walls of
            in CS            CS, generated by activity in CS,
                             or from materials in CS.
       12   Contact with
            Temperature
Welding arc when unable to use
face shield because  of CS.

Burns or scalds from hot steam
discharged into CS.

Heat exhaustion or frost bite
from temperature of CS.
       Safety Sciences, San Diego, California - 1977 [1]

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           SECTION 1

OCCUPATIONAL SAFETY AND HEALTH
   REGULATIONS AND STANDARDS

            PARTS

      OSHA 29 CFR 1910.1200
HAZARD COMMUNICATION STANDARD
              139

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• iiVU'ATlONAl. r-AFETY AND HEALTH
                                                             STANDARDS AND INTEKPKETATIUNS
                1910.1200—HAZARD  COMMUNICATION
Note: The Office of Management and Budget has disap-
proved, under the Paperwork Reduction Act. three applica-
tions of the Hazard Communication Standard:

  (1) The requirement that material safety data
  sheets be provided on multi-employer worksites:

  (2) Coveraere of any consumer product excluded
  from the definition of "hazardous chemical"
  under section 311(e)(3) of the Superfund Amend-
  ments and Reauthorization Act of 1986: and

  (3) Coverage of any drugs regulated by the U.S.
  Food and Drug Administration in the non-man-
  ufacturing sector.

(a) Purpose.

   (1) The purpose of this section is to ensure that
   the hazards of all  chemicals produced  or
   imported are evaluated, and that information
   concerning their hazards  is transmitted to
   employers and employees. This transmittal of
   information is  to be accomplished by means of
   comprehensive  hazard  communication pro-
   grams, which are to include container labeling
   and other forms of warning, material safety
   data sheets and employee training.

   (2) This occupational safety and health stand-
   ard is intended to address comprehensively the
   issue of evaluating the potential hazards of
   chemicals, and communicating information con-
   cerning hazards and appropriate protective
   measures to employees, and to preempt any
   legal requirements of a state, or political sub-
   division of a state, pertaining to the subject.
   Evaluating the potential hazards of chemicals,
   and communicating information concerning haz-
   ards and appropriate protective measures to
   employees, may include, for example, but  is not
   limited to, provisions for. developing and  main-
   taining a written hazard communication pro-
   gram for the workplace,  including lists of
   hazardous chemicals present: labeling of con-
   tainers of chemicals in the workplace, as well as
   of containers  of chemicals being shipped to
   other workplaces: preparation and distribution
   of material safety data sheets to employees and
   downstream employers:  and development and
   implementation of employee training programs
  regarding hazards of chemicals and protective
  measures. Under section 18 of the Act. no state
  or political subdivision of a state may adopt or
  enforce, through any  court or agency, any
  requirement  relating to the issue addressed by
  this Federal standard,  except pursuant to a
  Federally-approved state plan.

(b)  Scope and application.

  (1) This section  requires chemical manufac-
  turers or importers to  assess the hazards of
  chemicals which they produce or import, and all
  employers  to provide  information to  their
  employees about the hazardous chemicals  to
  which they are exposed, by means of a hazard
  communication program, labels and other  forms
  of warning, material safety data sheets, and
  information  and training. In addition, this sec-
  tion requires  distributors to transmit the
  required information to employers.

  (2) This section applies to any chemical  which is
  known to be present in the workplace in such a
  manner that employees may be exposed  under
  normal conditions of use or in a foreseeable
  emergency.

  (3) This section applies to laboratories only as
  follows:

     (i) Employers shall ensure that labels on
     incoming containers of hazardous chemicals
     are not removed or defaced:

     (ii) Employers shall  maintain  any  material
     safety data sheets that are received with
     incoming shipments of hazardous chemicals.
     and ensure that they are readily accessible to
     laboratory employees: and.

     (iii) Employers shall ensure that laboratory
     employees are apprised of the  hazards of the
     chemicals in their workplaces in accordance
     with paragraph (h) of this section.

   (4) In work operations where employees only
   handle chemicals in sealed containers which are
   not opened under normal conditions of use (such
   as are found in marine cargo handling,  ware-
                                           806.15
                                               141
                                   19IO.r_>00(b)(4)

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|«lu.l:!0(libMi                                                  "CCUPATIONAL SAFETY AND HEALTH

STANDAIlDs AND INTERPRETATIONS

  housing, or retail sales), this section applies to         material safety data sheets that are received
  ihese operations only as follows:                       w'th  incoming shipments of the sealed con-
                                                      tainers of hazardous chemicals, shall obtain a
                                                      material safety data sheet  for  sealed con-
     (i) Employers shall ensure that labels on         tainers of hazardous chemicals received with-
     incoming containers of hazardous chemicals         Out a  material  safety  data  sheet if  an
     are not removed or defaced:                        employee requests the material safety data
                                                      sheet, and shall ensure that the material
     (ii) Employers shall maintain  copies of any         safety data sheets are readily accessible dur-
  l«lU.1200(b)(4)(ii)                               Jdgfc.16                                     Chance-19

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i HVITATIONAL SAFETY AN1> HKAl.TH
                                                                 STAN'liAl:l)S ANIi INTI.IM'KI'.TAT
                                             806.16.2
                                                    143

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I'MIU.'mullii-I i
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OCCUPATIONAL SAFETY AND HEALTH
                                                              STANDARDS AND INTERPRETATIONS
retary of Labor  for Occupational Safety and
Health, U.S. Department of Labor, or designee.

  "Chemical" means any element, chemical com-
pound or mixture of elements and/or compounds.

  "Chemical manufacturer" means an employer
with a workplace where chemical(s) are produced
for  use or distribution.

  "Chemical name" means the scientific designa-
tion of a chemical in accordance with the nomencla-
ture system developed by the International Union
of Pure and Applied  Chemistry (IUPAC)  or the
Chemical Abstracts Service (CAS) rules of nomen-
clature, or a name which will clearly identify the
chemical for the purpose of conducting a hazard
evaluation.

  "Combustible liquid" means any liquid having a
flashpoint at or above 100 °F (37.8 °C), but below
200 °F (93.3 °C), except any mixture having com-
ponents  with flashpoints of 200 °F (93.3 °C), or
higher, the total volume of which make up 99 per-
cent or more of the total volume of the mixture.

  "Common name" means any designation or iden-
tification such as code name, code number, trade
name, brand name or generic name used to iden-
tify a chemical other than by its chemical name.

  "Compressed gas" means:

     (!) A gas  or mixture  of gases having, in a
     container, an absolute pressure exceeding 40
     psi  at 70 °F (21.1 °C); or

     (ii)  a gas or mixture of gases having, in a con-
     tainer, an  absolute pressure exceeding  104 psi
     at 130 °F (54:4 °C) regardless of the pressure
     of70°F(21.1°C);or

     (iii) A liquid having a vapor pressure exceed-
     ing 40 psi at 100 °F (37.8 °C) as determined
     by ASTM  D-323-72.

  "Container" means any bag, barrel, bottle, box,
can, cylinder, drum, reaction vessel, storage tank,
or the like that  contains a hazardous chemical. For
purposes of this section, pipes or piping systems,
and engines, fuel tanks, or other operating sys-
tems in a vehicle,  are not considered to be
containers.

  "Designated representative" means any individ-
ual or organization to whom an employee gives
     written authorization to exercise such employee':-
     rights under this section. A recognized or certified
     collective bargaining agent shall be treated auto-
     matically as a designated representative without
     regard to written employee authorization.

       "Director"  means  the  Director, National
     Institute for Occupational Safety and Health. U.S.
     Department of Health and Human Services, or
     designee.

       "Distributor" means a business, other than a
     chemical manufacturer or importer, which supplies
     hazardous chemicals to other distributors or to
     employers.

       "Employee" means a worker who may  be
     exposed  to hazardous chemicals under normal
     operating conditions  or in foreseeable emergen-
     cies. Workers such  as office  workers or bank
     tellers who  encounter hazardous chemicals only in
     non-routine, isolated instances are not covered.

       "Employer" means a person engaged in a busi-
     ness where chemicals are either used, distributed,
     or are produced for use or distribution, including a
     contractor or subcontractor.

       "Explosive"  means a chemical that causes a sud-
     den, almost instantaneous release of pressure, gas,
     and heat when subjected to sudden shock, pres-
     sure, or high temperature.

       "Exposure" or "exposed" means that  an em-
     ployee  is subjected to  a hazardous chemical in  the
     course  of employment through any route of entry
     (inhalation, ingestion,  skin contact or absorption,
     etc.), and includes potential (e.g. accidental or pos-
     sible) exposure.

       "Flammable" means a chemical that falls into
     one of the following categories:

          (i) "Aerosol,  flammable"  means an  aerosol
          that, when tested by the method described in
          16 CFR  1500.45, yields a flame projection
          exceeding 18 inches at full valve opening, or
          a flashback (a flame extending back to  the
          valve) at any degree of valve opening;

          (ii)  "Gas, flammable" means:

             (a) A gas that, at ambient  temperature
             and pressure, forms a flammable mixture
             with air at a concentration of thirteen  (13)
             percent by volume or less: or
 Change 48
806.17
                                          19)0.1200(0
                                                145

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                                                            OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATION'S
       (b) A gas that, at ambient temperature
       and pressure, forms a range of flammable
       mixtures with air wider than twelve (12)
       percent by volume, regardless of the lower
       limit;

    (iii)  "Liquid, flammable" means any liquid
    having a flashpoint below 100 °F (37.8 °C),
    except any mixture having components with
    flashpoints of 100  °F (37.8 °C) or higher,  the
    total of which make up 99 percent or more of
    the total volume of the mixture;

    (iv) "Solid, flammable" means a solid, other
    than a blasting agent or explosive as defined
    in § 190.109U), that is liable to cause fire
    through friction,  absorption of moisture,
    spontaneous chemical change, or  retained
    heat from manufacturing.or processing, or
    which can be ignited readily and when ig-
    nited burns so vigorously  and persistently as
    to create a serious hazard. A chemical shall
    be considered to  be a flammable solid if,
    when tested by the method described in 16
    CFR 1500.44, it ignites and burns with a self-
    sustained flame at a rate greater than one-
    tenth of an inch per second along its major
    axis.
  "Flashpoint" means the minimum temperature
at which a liquid gives off a vapor in sufficient con-
centration to ignite when tested as follows:

     (!) Tagliabue  Closed Tester (See American
     National Standard Method of Test for Flash
     Point by Tag Closed Tested, Zll.24-1979
     (ASTM D 56-79)) for liquids with a viscosity
     of less than 45 Saybolt University Seconds
     (SUS) at 100 °F (37\8 °C), that do not contain
     suspended solids and do not have a tendency
     to form a surface film under test; or

     (ii)  Pensky-Martens  Closed Tester (See
     American National Standard Method of Test
     for  Flash Point by Pensky-Martens Closed
     Tester, Zll.7-1979 (ASTM D 93-79)) for liq-
     uids with a viscosity equal to  or greater than
     45 SUS at 100 °F (37.8 °C), or that contain
     suspended solids, or that have a tendency  to
     form a surface film under test; or

     (iii) Setaflash Closed Tester (see American
     National Standard Method of Test for Flash
     Point by Setaflash Closed Tester (ASTMD
     3278-78))
    Orpanic peroxides, which undergo autoaccelerat-
    ing thermal decomposition, are excluded from any
    of the flashpoint determination methods specified
    above.

      "Foreseeable emergency" means any potential
    occurrence such as, but not limited  to, equipment
    failure, rupture of containers, or failure of control
    equipment which could result in an uncontrolled
    release of a hazardous chemical into  the workplace.

      "Hazardous chemical" means any chemical which
    is a physical hazard or a health hazard.

      "Hazard warning" means any words, pictures,
    symbols, or combination  thereof appearing on a
    label or other appropriate form of warning which
    convey the hazard(s) of the chemicaHs) in the con-
    tainer(s).

      "Health hazard" means a chemical for which
    there is statistically significant evidence based on
    at least one study  conducted  in accordance with
    established  scientific  principles  that acute or
    chronic health  effects may occur  in exposed
    employees. The term  "health hazard" includes
    chemicals which are carcinogens, toxic or highly
    toxic agents, reproductive toxins, irritants, corro-
    sives,  sensitizers, hepatotoxins,  nephrotoxins,
    neurotoxins, agents which act on the hematopoie-
    tic system, and  agents which damage the lungs.
    skin, eyes, or mucous membranes. Appendix A
    provides further definitions and explanations of
    the scope of health hazards covered by this sec-
    tion, and Appendix B  describes the criteria to be
    used to determine whether or not a chemical is to
    be considered hazardous for purposes of this
    standard.

       "Identity" means any chemical or common name
    which is indicated on the material safety data
    sheet (MSDS) for the  chemical. The identity used
    shall permit  cross-references to be made among
    the required list of hazardous chemicals, the label
    and the MSDS.

       "Immediate use" means that the hazardous
    chemical will  be under the control of and used only
    by the person who transfers it from a labeled con-
    tainer  and only within the work shift in which it is
    transferred.

       "Importer" means the first  business  with
    employees within the Customs Territory of the
     United States which receives hazardous chemicals
    produced in other countries for the  purpose of sup-
1910.1200(c)
806.1!
146
                                                                                      Change 48

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OCCUPATIONAL SAFETY AND HEALTH
                                                                                     191U.1200IC)
                                                              STANDARDS AND INTERPRETATIONS
plying them to distributors or employers within
the United States.

  "Label" means  any written, printed, or graphic
material, displayed on or affixed to containers of
hazardous chemicals.

  "Material safety data sheet (MSDS)" means
written or printed material concerning a hazardous
chemical which is prepared in accordance with
paragraph (g) of this section.

  "Mixture" means any combination of two or
more chemicals if the combination is not, in whole
or in part, the result of a chemical reaction.

  "Organic peroxide" means an organic compound
that  contains the bivalent -0- 0-structure and
which may be considered to be a structural deriva-
tive of hydrogen peroxide where one or both of the
hydrogen atoms has been  replaced by an organic
radical.

  "Oxidizer" means a chemical other than a blast-
ing agent or explosive as defined in § 1910.l09(a),
that  initiates or  promotes combustion in other
materials,  thereby causing fire either of itself or
through the release of oxygen or other gases.

  "Physical hazard" means a chemical for which
there is scientifically valid evidence  that it  is a
combustible liquid, a compressed gas, explosive,
flammable, an organic peroxide, an oxidizer,
pyrophoric, unstable (reactive) or water-reactive.

  "Produce" means to manufacture, process,  for-
mulate, or repackage.

  "Pyrophoric" means a chemical that will ignite
spontaneously in air at a  temperature of 130 °F
(54.4 °C) or below.

  "Responsible party" means someone who  can
provide additional information on  the hazardous
chemical and appropriate emergency procedures,
if necessary.

  "Specific chemical identity"  means the chemical
name, Chemical Abstracts  Service (CAS) Registry
Number, or any other information that  reveals the
precise  chemical designation of the substance.

  "Trade secret"  means  any confidential formula,
pattern, process,  device, information or compila-
tion of information that is used in an  employer's
      business, and that gives the employer an oppor-
      tunity to obtain an advantage over competitors
      who do not know or use it.  Appendix D sets out
      the criteria to be used in evaluating trade secrets.

        "Unstable (reactive)" means a chemical which in
      the pure state, or as produced or transported, will
      vigorously polymerize,  decompose, condense, or
      will become self-reactive  under conditions of
      shocks, pressure or temperature.

        "Use" means to package,  handle, react, or
      transfer.

        "Water-reactive" means a chemical that reacts
      with water to release a gas that  is either flam-
      mable or presents a health hazard.

        "Work area" means a  room or defined space in a
      workplace where hazardous chemicals are pro-
      duced or used, and where employees are  present.

        "Workplace" means an establishment, job site,
      or project, at one geographical location containing
      one or more work areas.

      (d)  Hazard determination.

         (1) Chemical manufacturers and  importers shall
         evaluate chemicals produced in their workplaces
         or imported by them to determine if they are
         hazardous. Employers are not required  to eval-
         uate chemicals unless they choose not to rely on
         the evaluation performed  by the chemical man-
         ufacturer or importer for the chemical to satisfy
         this requirement.

         (2) Chemical manufacturers,  importers or
         employers evaluating chemicals shall identify
         and  consider the available scientific evidence
         concerning such hazards. For health hazards,
         evidence which is statistically  significant and
         which is based on at least one positive study
         conducted in accordance with established scien-
         tific principles is considered to  be sufficient to
         establish a hazardous effect if the results of the
         study meet the definitions of health hazards in
         this  section. Appendix A  shall be consulted for
         the  scope of health  hazards covered,  and
         Appendix B shall be consulted for the criteria to
         be followed with respect to  the  completeness of
         the evaluation, and the data to be reported.

         (3) The chemical manufacturer, importer or
         employer evaluating chemicals shall treat the
Change 48
806.19
                                         1910.1200(d)(3)
                                                147

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                                                            OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
  following sources as establishing that the chemi-
  cals listed in them are hazardous:

     (i) 29 CFR Part  1910, Subpart Z. Toxic and
     Hazardous Substances, Occupational Safety
     and Health Administration (OSHA); or,

     (ii) Threshold Limit Values for Chemical
     Substances and Physical Agents in Ike Work
     Environment, American Conference of Gov-
     ernment Industrial Hygienists (ACGIH)
     (latest edition).

  The chemical manufacturer, importer, or em-
ployer is still responsible for evaluating the haz-
ards associated with the chemicals in these source
lists in accordance with the requirements of this
standard.

  (4) Chemical manufacturers,  importers and
  employers evaluating chemicals shall treat the
  following sources as establishing that a chemical
  is a carcinogen or potential carcinogen for haz-
  ard communication purposes:

     (i) National Toxicology  Program (NTP), An-
     nual Report on Carcinogens (latest edition);

     (ii)  International Agency for Research on Can-
     cer (IARC) Monographs (latest editions);  or

     (iii) 29 CFR Part 1910,  Subpart Z, Toxic and
     Hazardous Substances, Occupational Safety
     and Health Administration.

      Note—The Registry of Toxic Effects of
     Chemical Substances published  by the
     National Institute for Occupational Safety
     and Health indicates whether a chemical has
     been found by NTP or IARC to be a poten-
     tial carcinogen.

  (5) The chemical manufacturer,  importer or
  employer shall  determine the hazards of mix-
  tures of chemicals as follows:

     (i) If a mixture has been tested as a whole to
     determine its hazards, the results of such
     testing shall be  used to determine whether
     the mixture is hazardous;

     (ii) If a  mixture has not been tested as a
     whole to determine whether the mixture is a
     health hazard, the mixture shall be assumed
     to present the same health hazards as do the
        components which comprise one percent (by
        weight or volume) or greater of the mixture,
        except that the mixture shall be assumed to
        present a carcinogenic hazard if it contains a
        component in concentrations of 0.1 percent or
        greater which is considered to be a carcinogen
        under paragraph (d)(4) of this section:

        (iii) If a mixture has  not been tested as a
        whole to determine whether the mixture is a
        physical hazard, the chemical  manufacturer,
        importer, or employer may use whatever sci-
        entifically valid data is available to evaluate
        the physical hazard potential of the mixture:
        and,

        (iv) If the chemical manufacturer, importer,
        or employer has evidence to indicate that  a
        component present in the mixture in con-
        centrations of less than one percent (or in the
        case of carcinogens, less than 0.1  percent)
        could be released in concentration? which
        would exceed an established OSHA  permissi-
        ble exposure limit or ACGIH Threshold
        Limit Value,  or could present a health hazard
        to employees in those concentrations,  the
        mixture shall be assumed to present  the
        same hazard.

      (6)  Chemical manufacturers,  importers, or
      employers evaluating chemicals shall describe in
      writing the procedures they use to determine
      the hazards of the chemical they evaluate. The
      written procedures are to be made available,
      upon  request, to employees, their designated
      representatives,  the Assistant  Secretary  and
      the Director. The written description may be
      incorporated  into the written hazard  communi-
      cation program required under paragraph (e)  of
      this section.

    (e) Written  hazard communication pro-
    gram.

      (1) Employers shall develop, implement,  and
      maintain at  the  workplace, a written hazard
      communication program for their workplaces
      which at least describes how the criteria spec-
      ified  in paragraphs (0. (gJ. and (h) of this sec-
      tion  for labels and other  forms of warning,
      material safety data sheets, and employee infor-
      mation and training will be met.  and which also
      includes the following:

         (i)  A list of the hazardous chemicals known
         to  be present using an identity that is refer-
1910.1200(e)U)(>>
I4g)6.20
Change JS

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OCCUPATIONAL SAFETY A.VD HEALTH
                                                                                 l910.1200(eKI)(i)
                                                              STANDARDS AND INTERPRETATIONS
     encecl on the appropriate material safety data
     sheet (the list may be compiled for the work-
     place as a  whole or for individual work
     area?): and,

     (ii) The methods the employer will use to
     inform employees of the hazards of non-rou-
     tine tasks (for example,  the cleaning of reac-
     tor vessels), and the hazards associated with
     chemicals contained in unlabeled pipes in
     their work areas.

   (2) Multi-employer workplaces.  Employers who
   produce, use,  or store hazardous chemicals at a
   workplace in such a way that the employees of
   other employer(s) may be exposed (for example,
   employees of a construction contractor working
   on-site) shall additionally ensure that the hazard
   communication programs developed and  imple-
   mented under  this paragraph (e) include the fol-
   lowing:

     (i).The methods the employer will use to
     provide the other employer(s) with a copy of
     the material safety data sheet, or to make it
     available at a  central location in the work-
     place, for each hazardous chemical the other
     employer(s)' employees may be exposed to
     while working;

     (ii)  The methods  the employer will  use to
     inform the  other employer(s) of any precau-
     tionary measures that need to be taken to
     protect employees  during the workplace's
     normal operating conditions and in foresee-
     able emergencies; and,

     (iii) The methods the employer will use to
     inform the  other employer(s) of the labeling
     system used in the workplace.

   (3) The employer may rely on an existing haz-
   ard communication  program  to comply with
   these requirements, provided that it meets  the
   criteria established in this  paragraph (e).

   (4) The employer shall make the written hazard
   communication  program  available,   upon
   request,  to employees, their designated repre-
   sentatives, the Assistant Secretary and  the
   Director, in accordance with the requirements
   of29CFR  19l0.20(e).

(f) Labels and  other forms of warning.

   (1) The chemical manufacturer, importer, or

Change 48                                 806.21
distributor shall ensure that each container of
hazardous chemicals leaving the workplace is
labeled, tagged or marked with the following
information;

  (i) Identity of the hazardous chemical(s);

  (ii) Appropriate hazard warnings; and

  (iii)  Name and address of the chemical manu-
  facturer, importer, or other responsible party.

(2)  For solid metal (such as a steel beam or a
metal casting) that is not exempted as an article
due to its downstream use,  the required label
may be transmitted to the customer at the time
of the initial shipment, and need not be included
with subsequent shipments to the same employ-
er unless the information on the label changes.
The label may  be transmitted with the initial
shipment itself, or with the material safety data
sheet that is to be provided prior to or at the
time of the first shipment.  This  exception to
requiring labels on every container of hazardous
chemicals is only for the solid metal itself and
does not apply to hazardous chemicals used in
conjunction with, or known to  be present with,
the metal and to which employees  handling the
metal may be exposed (for example, cutting flu-
ids or lubricants).

(3)  Chemical manufacturers, importers, or dis-
tributors shall ensure that each  container of
hazardous chemicals leaving the  workplace is
labeled, tagged, or marked in accordance with
this section in a manner which does not conflict
with the requirements of the Hazardous Mate-
rials Transportation Act (49 U.S.C. 1801 et seq.)
and regulations issued under that Act by the
Department of Transportation.

(4) If  the  hazardous chemical is  regulated by
OSHA in a substance-specific  health standard,
the chemical manufacturer,  importer, distribu-
tor or employer shall ensure that  the labels or
other forms of warning used are in accordance
with the requirements  of that standard.

(5) Except as provided in paragraphs (f)(6) and
(0(7) the  employer shall ensure that each con-
tainer of hazardous chemicals  in the workplace
is labeled, tagged or marked with  the following
information:

   (i) Identity of the hazardous chemical(s) con-
   tained therein; and

                                1910.1200(f)(5)(i)
                                                 149

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                                                            UUTl'ATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
    (ii)  Appropriate hazard warnings.

  (6)  The employer may use signs, placards.
  process sheets, batch tickets, operating proce-
  dures, vr other such written materials in lieu of
  affixing labels to individual stationary process
  containers, as long as the  alternative method
  identifies the containers to which it is applicable
  and conveys the information required by para-
  graph (f)(5) of this section to be on a label. The
  written materials shall be readily accessible to
  the employees in their work area throughout
  each work shift.

  (7)  The employer is not required to label port-
  able containers into which  hazardous chemicals
  are transferred from labeled containers, and
  which are intended only for the immediate use
  of the employee who performs the transfer.

  (8)  The employer  shall not remove or deface
  existing labels or incoming containers of haz-
  ardous chemicals unless the container is imme-
  diately marked with the required information.

  (9) The employer shall  ensure that labels or
  other forms of warning are legible, in English,
  and prominently displayed on the container, or
  readily available in the work area throughout
  each work shift. Employers having employees
  who speak other languages may add the infor-
  mation in their language  to the material pre-
  sented, as long as  the information is presented
  in English as well.

   (10) The chemical  manufacturer, importer, dis-
   tributor or employer need not affix new labels
   to  comply with  this section if existing labels
   already convey the required information.

 (g) Material safety data sheets.

   (1) Chemical manufacturers and importers shall
   obtain or develop  a material safety data sheet
   for each hazardous  chemical they produce or
   import. Employers shall have a material safety
   data  sheet for each  hazardous  chemical which
   they  use.

   (2) Each material safety data sheet shall be in
   English and  shall contain  at least the following
   information:

      (i)  The identity  used  on  the label, and.
      except as  proxided for in paragraph (i) of this
      section  on trade secrets:
      la) If the hazardous chemical is a simile
      substance,  us  chemical  and common
      namelsj:

      (b) If the hazardous chemical is a mixture
      which has been tested as a whole to deter-
      mine its hazards, the chemical and com-
      mon  nameis) of the  ingredients which
      contribute to these known hazards, and
      the common nanie(s) of the mixture itself:
      or.

      (c) If the hazardous chemical is a mixture
      which has not been tested as a whole:

         (1) The chemical and common nameisi
         of all ingredients which  have been
         determined to be health hazards, and
         which comprise  17r or greater of the
         composition, except that chemicals iden-
         tified as  carcinogens under paragraph
         (d)(4) of this section shall be listed if the
         concentrations are 0.1% or greater: and.

         (2) The chemical and  common name(s)
         of all  ingredients which  have been
         determined to be health hazards,  and
         which comprise less than 1% (0.19c for
         carcinogens)  of the mixture, if there  is
         evidence that the ingredient(s) could be
         released  from the mixture in concentra-
         tions which would exceed an established
         OSHA permissible exposure  limit or
         ACGIH Threshold  Limit Value, or
         could  present  a health hazard to
         employees: and.

         (3) The  chemical and common namets)
         of all ingredients which have been
         determined to present a physical hazard
         when present in the mixture:

     (ii)  Physical and chemical  characteristics  of
     the hazardous chemical (such as vapor pres-
     sure, flash point):

     (iii) The physical  hazards  of the hazardous
     chemical, including the potential  for fire.
     explosion, and reactivity;

     (iv) The health hazards of the hazardous
     chemical, including signs  and symptoms of
     exposure, and any medical conditions which
     are generally recognized as being aggravated
     by exposure to the chemical.
                                            15CP
06.22
                                      Chaniie -48

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iKTlTATIONAl. SAFETY AND HEALTH
                                                                                191(1.12lXHK>(2Hri
                                                              STAXDARPS AND INTERPRETATIONS
     (v) The primary route(s) of entry;

     (vi) The OSHA permissible exposure limit.
     ACGIH Threshold  Limit Value, and  any
     other exposure limit  used or recommended
     by the chemical manufacturer, importer, or
     employer preparing the material safety data
     sheet, where available:

     (vii) Whether the hazardous chemical  is
     listed in the National Toxicology. Program
     (XTP) Annual Report on Carcinogens (latest
     edition) or has been found to be a potential
     carcinogen in the International Agency for
     Research on Cancer (IARC)  Monographs
     (latest editions), or by OSHA;

     (viii) Any generally applicable precautions
     for safe handling and use which are known to
     the chemical  manufacturer,  importer or
     employer preparing the material safety  data
     sheet, including appropriate hygienic prac-
     tices, protective measures during repair and
     maintenance of contaminated equipment, and
     procedures for clean-up of spills and leaks;

     (ix) Any  generally applicable control meas-
     ures which are known to the chemical man-
     ufacturer, importer or employer preparing
     the material safety data sheet, such as appro-
     priate engineering controls, work practices,
     or personal protective equipment;

     (x) Emergency and first aid procedures;

     (xi) The date of preparation of the material
     safety data sheet or the last  change to it; and,

     (xii) The name, address and telephone num-
     ber of the chemical manufacturer, importer,
     employer or other responsible  party prepar-
     ing or distributing the material safety  data
     sheet, who can provide additional information
     on the hazardous chemical and appropriate
     emergency procedures, if necessary.

   (3)  If not relevant information is  found for any
   given category  on  the material safety  data
   sheet, the chemical manufacturer, importer or
   employer preparing the  material safety  data
   sheet shall mark it to indicate that no applicable
   information was found.

   (4)  Where complex mixtures have similar haz-
   ards and contents (i.e.  the chemical ingredients
        are essentially the same, but the specific com-
        position varies from mixture to mixture), the
        chemical manufacturer, importer or employer
        may prepare one material safety data sheet to
        apply to all of these similar mixtures.

        (5) The chemical manufacturer, importer or
        employer preparing the material safety data
        sheet shall ensure that the information recorded
        accurately reflects the scientific evidence used
        in making the hazard determination. If the
        chemical manufacturer, importer or employer
        preparing  the material  safety  data sheet
        becomes newly aware  of any significant infor-
        mation regarding the hazards of a chemical, or
        ways to protect against the hazards, this new
        information shall  be  added to the  material
        safety  data sheet within three months. If the
        chemical is not  currently being produced or
        imported the chemical  manufacturer or import-
        er shall add the information to the material
        safety  data sheet before the chemical is intro-
        duced into the workplace again.

        (6) Chemical manufacturers or importers shall
        ensure that distributors and employers are
        provided an appropriate material safety data
        sheet with their initial shipment, and with the
        first shipment after a material safety data sheet
        is updated. The  chemical manufacturer or im-
        porter  shall either provide material safety data
        sheets  with the shipped containers or send them
        to the  employer prior to or at the time of the
        shipment. If the material safety data sheet is
        not provided  with a shipment that  has been
        labeled as a hazardous chemical, the employer
        shall obtain one from the chemical manufacturer.
        importer, or distributor as soon as possible.

        (7) Distributors shall  ensure that material
        safety data sheets, and updated information,
        are provided to  other distributors and employ-
        ers. Retail distributors  which sell hazardous
        chemical to commercial customers shall provide
        a material safety data sheet to  such employers
        upon request, and shall post a sign or otherwise
        inform them that a material safety data sheet is
        available. Chemical manufacturers, importers.
        and distributors need  not provide material
        safety data sheets to  retail distributors which
        have informed them that the retail distributor
        does   not  sell  the  product   to  commercial
        customers or open the sealed container to use it
        in their own workplaces.

        (8) The employer shall  maintain  copies of the
 Change -18
806.23
                                                                                    1910.1200(K)<8)
                                                 151

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                                                            OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
  required material safety data sheets for each
  hazardous chemical in the workplace, and shall
  ensure that they are readily accessible during
  each work shift to employees when they are in
  their work area(s).

  (9) Where employees must  travel between
  workplaces during a workshift, i.e.. their work
  is carried out at more than one geographical
  location, the material safety data sheets may be
  kept at  a central location at the primary work-
  place facility. In this situation, the employer
  shall ensure  that employees can immediately
  obtain the required information in an emer-
  gency.

  (10) Material safety data sheets may be kept in
  any form, including operating procedures,  and
  may be designed to cover groups of hazardous
  chemicals in a work area where it may be more
  appropriate to address the  hazards of a process
  rather  than  individual hazardous chemicals.
  However, the employer shall ensure that in all
  cases the required information is provided  for
  each hazardous chemical, and is readily accessi-
  ble during each work shift  to employees when
  they are in their work area(s).

  (11) Material safety data  sheets shall also be
  made readily available, upon request, to desig-
  nated representatives and to the Assistant Sec-
  retary,  in accordance with the requirements of
  29 CFR 19l0.20(e). The Director shall also be
  given access to material safety data sheets in
  the same manner.

(h)  Employee information and  training.

  Employers shall provide employees with infor-
mation  and training on hazardous chemicals in
their work area at the time of their initial assign-
ment, and whenever a new hazard is introduced
into their  work area.

   (1) Information. Employees shall be informed
   of:

      (i) The requirements of this section;

      (ii) Any operations in their work area where
      hazardous chemicals are  present: and,

      (iii) The location and availability of the writ-
      ten hazard communication program, includ-
      ing  the   required  list(s)   of  hazardous
   chemicals, and material safety data sheets
   required by this section.

 (2)  Training. Employee training shall include at
 least:

   (i)  Methods and observations that may be
   used  to detect the presence or release  of a
   hazardous chemical in the work area (such as
   monitoring conducted by the employer,  con-
   tinuous monitoring devices, visual appear-
   ance  or odor of hazardous  chemicals when
   being released, etc.):

   (ii) The  physical and health hazards of the
   chemicals in the work area:

   (iii) The measures employees can take to
   protect  themselves from  these hazards.
   including specific procedures  the employer
   has implemented to protect employees from
   exposure to hazardous chemicals, such as
   appropriate work practices, emergency  pro-
   cedures, and  personal protective equipment
   to be used;  and,

    (iv) The details of the hazard communication
    program developed by  the employer,  includ-
    ing an explanation of the labeling system and
    the material safety data  sheet, and  how
    employees can obtain and use the appropriate
    hazard information.


(i) Trade secrets.

  (1) The chemical manufacturer,  importer, or
  employer may withhold the  specific chemical
  identity, including the chemical name and  other
  specific identification of a hazardous chemical.
  from the material safety data sheet, provided
  that:

     (i) The claim that the information withheld is
     a trade secret can be supported;

     (ii)  Information contained in  the  material
     safety data sheet concerning the properties
     and effects of the hazardous chemical is
     disclosed;

     (iii)  The material safety data sheet indicates
     that the specific chemical identity is  being
     withheld as a trade secret; and.

     (iv) The specific chemical identity  is  made
                                              806.24

                                             152
                                      Chance -18

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OCCUPATIONAL. SAFETY AND HEALTH
                                                              STANDARDS AND INTERPRETATIONS
     available to health professionals, employees.
     and designated representatives in accordance
     with  the  applicable provisions  of this
     paragraph.

  (2) Where a treating physician or nurse deter-
  mines that a medical emergency exists and the
  specific  chemical identity of a hazardous chemi-
  cal is necessary for emergency or first-aid treat-
  ment, the chemical manufacturer, importer, or
  employer shall immediately disclose the specific
  chemical identity of a trade secret chemical to
  that treating physician or nurse, regardless of
  the existence of a written statement of need of a
  confidentiality agreement.  The chemical man-
  ufacturer, importer, or employer may require a
  written statement of need and confidentiality
  agreement, in accordance with the provisions of
  paragraphs (i)(3) and (4) of this section, as soon
  as circumstances permit.

  (3) In non-emergency  situations, a chemical
  manufacturer, importer,  or employer shall,
  upon request, disclose a specific  chemical iden-
  tity, otherwise permitted to be withheld under
  paragraph (i)(l) of this section, to a health pro-
  fessional (i.e. physician, industrial hygienist,
  lexicologist, epidemiologist,  or occupational
  health  nurse)  providing medical  or other
  occupational health services to  exposed em-
  ployee(s), and to employees or designated rep-
  resentatives, if:

     (i)  The request is in writing;

     (ii) The request describes with reasonable
     detail one or more of the following occupa-
     tional health needs for the information:

       (a) To assess the hazards of the chemicals
       to which employees will be exposed;

       (b) To conduct or assess sampling of the
       workplace atmosphere to determine em-
       ployee exposure levels;

       (c) To conduct pre-assignment or periodic
       medical surveillance  of  exposed em-
       ployees;

       (d) To  provide medical treatment to ex-
       posed employees;

       (e) To  select or assess appropriate per-
       sonal protective equipment for exposed
       employees:
             (f) To design or assess engineering con-
             trols or other protective measures for
             exposed employees: and,

             (g) To  conduct studies to determine the
             health effects of exposure.

           (iii) The request  explains in detail why the
           disclosure of the specific chemical identity is
           essential  and that, in lieu thereof, the dis-
           closure of the following information to the
           health professional, employee, or designated
           representative, would not satisfy the pur-
           poses described in paragraph (i)(3)(ii) of this
           section:

             (a) The properties and effects of the
             chemical;

             (b) Measures for controlling workers' ex-
             posure  to the chemical;

             (c) Methods of monitoring and analyzing
             worker exposure to the chemical; and,

             (d) Methods of diagnosing and  treating
             harmful exposures to the chemical;

           (iv) The request includes a description of the
           procedures to be used to maintain the con-
           fidentiality of the disclosed information; and,

           (v)  The  health  professional,   and  the
           employer or contractor of the  services of the
           health  professional  (i.e.  downstream
           employer, labor  organization, or individual
           employee), employee, or designated repre-
           sentative, agree  in a  written  confidentiality
           agreement that  the health  professional,
           employee, or designated  representative, will
           not use the trade secret information for any
           purpose  other  than the  health need(s)
           asserted  and agree not to release the  infor-
           mation under any circumstances other than
           to OSHA, as provided in paragraph (i)(6) of
           this  section, except as authorized by the
           terms of  the agreement or by the  chemical
           manufacturer, importer, or employer.
          (4) The confidentiality agreement authorized by
          paragraph (i)(3)(iv) of this section;

            (i) May restrict the use of the information to
            the health purposes indicated in the written
            statement of need;
Change -18
806.25
                                                  153

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1910.12000 M4 Mil
                                                            OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS

    (ii)  May provide for appropriate  legal reme-
    dies in the event of a breach of the agree-
    ment, including stipulation of a reasonable
    pre-estimate of likely damages: and,

    (Hi) May not include  requirements for the
    posting of a penalty bond.

  (5)  Nothing in this standard is meant to pre-
  clude  the parties from pursuing non-contractual
  remedies to the extent permitted by law.

  (6)  If the health professional, employee, or des-
  ignated representative receiving the trade
  secret information decides that  there is a  need
  to disclose it to OSHA, the chemical  manufac-
  turer, importer, or employer who provided the
  information shall be informed by the health pro-
  fessional, employee, or designated  representa-
  tive prior to, or at the same  time as,  such
  disclosure.

  (7)  If the chemical manufacturer, importer, or
  employer denies a written request for dis-
  closure of a specific chemical identity,  the denial
  must:

    (i)  Be provided to the health professional,
    employee, or  designated representative,
    within thirty days of the request;

    (ii) Be in writing;

    (iii) Include evidence to support  the  claim
    that the specific chemical identity  is a  trade
    secret;

    (iv) State the specific reasons  why the
    request is being denied; and,
     (v) Explain in detail how alternative informa-
     tion may  satisfy the  specific medical or
     occupational health need  without revealing
     the specific chemical identity.

  (8) The health professional, employee, or desig-
  nated representative whose request for infor-
  mation is denied under paragraph (i)(3) of this
  section may refer the request and the written
  denial of the request to OSHA for considera-
  tion.

  (9) When a health  professional,  employee, or
  designated representative refers the denial to
  OSHA under paragraph (i)(8) of this section,
       OSHA shall consider the evidence to determine
       if:

         (i) The chemical manufacturer, importer,  or
         employer has supported the claim thai the
         specific chemical identity is a trade secret:

         (ii) The health professional, employee,  or
         designated representative has supported the
         claim that there is a medical or occupational
         health need for the information; and,

         (iii) The health professional,  employee,  or
         designated representative has  demonstrated
         adequate  means to  protect  the  confi-
         dentiality.

       (10)

         (i) If OSHA determines that the specific
         chemical identity requested under paragraph
         (i)(3)  of this section is not a bona fide trade
         secret, or that it is a trade secret, but the
         requesting health professional, employee, or
         designated representative  has a legitimate
         medical or occupational health need  for the
         information, has executed a written con-
         fidentiality agreement,  and has  shown ade-
         quate means to protect the confidentiality of
         the information, the chemical  manufacturer.
         importer, or  employer will be subject to cita-
         tion by OSHA.

         (ii) If a chemical manufacturer, importer, or
         employer  demonstrates to OSHA that the
         execution of a confidentiality  agreement
         would  not provide  sufficient protection
         against  the  potential  harm  from  the
         unauthorized disclosure of a trade secret spe-
         cific chemical identity, the Assistant Secre-
         tary  may  issue such  orders or impose such
         additional limitations or conditions upon  the
         disclosure of the requested  chemical informa-
         tion as may be appropriate  to assure that  the
         occupational health  services are provided
         without an undue risk of harm to the chemi-
         cal manufacturer, importer, or employer.

        (11) If  a citation for a failure  to release specific
        chemical identity information is contested by
        the  chemical  manufacturer,  importer,  or
        employer, the matter will be adjudicated before
        the  Occupational Safety  and Health  Review
        Commission in  accordance  with the Act's
        enforcement scheme and  the applicable Com-
        mission rules of procedure. In accordance with
 1910.1200(11(11)
  806.26

154
                                                                                       Change 48

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OCCUPATIONAL SAFETY AND HEALTH
                                                                        STANDARDS AND INTERPRETATIONS
   the Commission rules, when  a chemical man-
   ufacturer, importer, or employer continues to
   withhold the information during the contest, the
   Administrative La\v Judge may review the cita-
   tion  and supporting documentation in camera
   or issue appropriate orders to protect the con-
   fidentiality of such matters.

   (12)  Notwithstanding the existence of a trade
   secret claim, a chemical manufacturer," import-
   er, or employer shall, upon request, disclose to
   the Assistant  Secretary any information which
   this section requires the chemical manufacturer.
   importer,  or  employer  to  make available.
   Where there is a trade secret claim, such claim
   shall be made no later than at the time the
   information  is provided to the Assistant  Secre-
   tary  so that suitable determinations of trade
   secret status can be made and the  necessary
   protections can be implemented.

   (13)  Nothing in this paragraph shall be con-
   strued as requiring the disclosure under any cir-
   cumstances  of process or percentage of mixture
   information  which is a trade secret.
 (j) Effective dates.

   (1) Chemical manufacturers, importers,  and
   distributors  shall  ensure that material safety
   data sheets  are provided  with the next ship-
   ment of hazardous chemicals to employers after
   September 23. 1987.

   (2) Employers in the  nonmanufacturing sector
   shall be in compliance  with all provisions of this
   section by May 23, 1988. (Note: Employers in
   the manufacturing sector (SIS Codes 2 thru 39)
   are  already required  to be in compliance with
   this section.)

             APPENDIX A TO  1910.1200
    HEALTH HAZARD  DEFINITIONS (MANDATORY)

  Although safety hazards related to the physical characteris-
 tics of a chemical can be objectively defined in terms of testing
 requirements (e.g.  flammabiliiy), health hazard definitions are
 less precise and more subjective. Health hazards may cause
 measurable changes in the body—such as decreased pulmonary
 (unction. These changes are generally indicated by the occur-
 rence of signs and  symptoms in the  exposed employees—such
 as shortness of breath, a non-measurable, subjective feeling
 Employees exposed to such hazards must be apprised of both
 the change in body function and the signs and symptoms that
 nay occur to signal  that change.

  The determination of occupational health  hazards is compli-
 cated by the fact that  many of the effects or signs and symp-
         toms occur commonly in non-occupationally exposed popula-
         tions, so that effects of exposure are difficult to separate from
         normally occumnc illnesses. Occasionally, « substance cau.-e:-
         an effect thai is rarely frvn in the population at large, such a.-
         anpiosarcomas caused by vinyl chloride exposure, thus makmp
         it easier to ascertain that the occupational exposure was the
         primary causative factor. More often, however, the effects are
         common, such as lung cancer.  The situation is further compli-
         cated by the fact that most chemicals have not been adequately
         tested to determine their health  hazard potential, and data do
         not exist to substantiate these effects.

           There have been many attempts to categorize effects and to
         define them in various ways. Generally, the terms "acute" and
         "chronic" are used to delineate between effects on the basis of
         severity or duration. "Actue". effects usually occur rapidly as  a
         result of short-term exposures, and are of short duration.
         "Chronic" effects generally  occur as  a  result  of long-term
         exposure, and are of long duration.

           The acuie effects referred to most frequently are those
         defined by the American National Standards Institute (ANSI)
         standard for Precautionary Labeling of Hazardous Industrial
         Chemicals (Z129.1-1982)—irritation,  corrosivity,  sensitization
         and lethal dose. Although these are important health effects.
         they do not adequately cover the considerable range of acute
         effects which may occur as a result of occupational exposure.
         such as. for example, narcosis.

           Similarly, the term chronic effect is often used to cover only
         carcinogenicity, leratogenicky. and mutagenicity. These effects
         are obviously a concern in the workplace, but again, do not ade-
         quately cover the area of chronic effects, excluding, for exam-
         ple, blood dyscrasias (such as enemia), chronic bronchitis and
         liver atrophy.

           The goal of defining precisely, in measurable terms, every
         possible health effect that may occur in the  workplace as a
         result of chemical exposures cannot realistically be accom-
         plished. This does not negate the need for employees to be
         informed of such effects and protected from them. Appendix B.
         which is also mandatory, outlines the principles and procedures
         of hazardous assessment.

            For purposes of this section, any chemicals which meet any
          of the following definitions, as determined by the criteria set
          forth in Appendix B are health hazards:

          1.  Carcinogen: A chemical is considered to be a carcinogen  if:

          (a) It  has been evaluated by the  International Agency for
          Research  on Cancer (1ARC). and found to be a carcinogen or
          potential carcinogen: or

          (b) It is listed as a carcinogen  or potential carcinogen in the
          Annual Report on Carcinogens published by the National Tox-
          icology- Program (NTP) (latest edition): or.

          (c) It is regulated by OSHA as  a carcinogen.
          2.  Corrosive: A chemical that causes visible destruction of. or
          irreversible alterations in. living tissue by chemical action at
          the site of contact. For example, a chemical is considered to be
          corrosive if. when tested on the intact skin of albino rabbits by
          tne method described  by the  U.S. Department of Transporta-
          tion in Appendix A to -19 CFR Pan 173. it destroys or changes
          irreversibly the structure of the tissue at the site of contact fol-
          low ing an exposure period of four hours. This term shall not
          refer to action or inanimate surfaces.
 Chance 48
806.27
1910.1200 Appendix A
                                                        155

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ISIO.IL'IHI Appendix A
              UCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
3. Highh loxic: A chemical falling within any of the following
categories:

(at A chemical that has a median lethal dose (LDyit of 50 milli-
grams or less per kilogram of body weight when administered
orally to albino rats weighing between 200 and 300 grams each

(h) A chemical that has a median lethal dose (LDy,i of 200 milli-
grams or less per kilogram of body weight when aamimsiered
by continuous contact for 2-1 hours lor less if death  occurs
within 2-J  hours) with the bare skin of albino rabbits weighing
between two and three kilograms each.

(c) A chemical that has a median lethal concentration (LCW) in
air of 200 parts per million by volume or less of gas or vapor, or
2 milligrams per liter or less of mist. fume, or dust, when
administered by continuous inhalation for one hour lor less if
death occurs within one  hour) to albino rats weighing between
200 and 300 grams each

•I. Irritant: A  chemical, which is  not corrosive, but which
causes a reversible  inflammatory effect on living tissue by
chemical action  at the sue of contact. A chemical is a skin irri-
tant if. when tested on the intact skin of albino rabbits by the
methods of 16 CFR 1500.41 for four hours exposure or by other
appropriate techniques,  it results in an empirical score of five
or more. A chemical is an eye irritant if EO determined under
the procedure listed in  16 CFR 1500.42 or other appropriate
techniques.

5. Sensitizer: A chemical that causes a substantial proportion
of exposed people  or animals to develop an allergic reaction in
normal tissue after repeated exposure to the chemical.

 6. Toxic. A chemical  falling  within any of the following
 categories:

 (a) A chemical that has a median lethal dose (LDjo) of more
 than 50 milligrams per  kilogram but not more than 500 milli-
 grams per kilogram of body weight when administered orally to
 albino rats weighing between 200 and 300 grams each.

 (b) A chemical that has a median lethal dose (LDW) of more
 than 200 milligrams per kilogram but not more than 1.000 milli-
 grams per kilogram of body weight  when administered by con-
 tinuous contact for 2-1 hours (or less if death occurs within 24
 hoursl with the bare skin of albino rabbits weighing between
 two and three kilograms each.

 (c) A chemical that has a median lethal concentration (LCy>) in
 air of more than 200 parts per million but not more than 2.000
 parts per million by volume of gas or vapor,  or more than two
 milligrams per liter but  not more than 20 milligrams per liter of
 mist. fume, or dust, when administered by continuous inhala-
 tion for one hour  (or less if death occurs within one hour) to
 albino rats weighing between 200 and 300 grams each.

  7. Target organ effects. The following is a target  organ cate-
  gorization of effects which may occur, including examples of
  signs and symptoms and chemicals which have been found to
  cause such effects. These examples are presented to illustrate
  the range and diversity of effects and hazards found in  the
  workplace, and the broad scope employers must consider in this
  area, but are not intended to be all-inclusive.

  a Hepatotoxins:  Chemicals which produce liver damage
    Signs & Symptoms:  Jaundice: liver enlargement
    Chemicals' Carbon tetrachloride; mtrosamines
b.  N'ephrotoxms: Chemicals which produce kidney damage
   Signs & Symptoms: Edema: protemuria
   Chemicals: Halogenated hydrocarbons: uranium

c.  Neurotoxins: Chemicals which produce their primary toxic
     effects on the nervous system
   Signs & Symptoms: Narcosis: behavioral changes: decrease
     in motor functions
   Chemicals: Mercury; carbon disulfide

d.  Agents which act on the blood or hematopoietic system:
     Decrease hemoglobin function: deprive the body tissue of
     oxygen
   Signs & Symptoms: Cyanosis: loss of consciousness
   Chemicals: Carbon monoxide: cyanides

c.  Agents which damage the lung:  Chemicals which irritate or
     damage the pulmonary tissue
   Signs &. Symptoms: Cough: tightness in chest: shortness of
     breath
   Chemicals: Silica; asbestos

f.  Reproductive toxins: Chemicals  which affect the reproduc-
     tive capabilities including chromosomal damage imuta-
     tions) and effects on fetuses (teratogenesis)
   Signs & Symptoms: Birth defects; sterility
   Chemicals: Lead; DBCP

g. Cutaneous hazards: Chemicals which affect the dermal layer
     of the boy
   Signs & Symptoms: Defattinp of the skin: rashes:  irritation
   Chemicals: Ketones; chlorinated compounds

 h. Eye hazards: Chemicals which affect the eye or visual
     capacity
   Signs & Symptoms: Conjunctivitis: corneal damage
   Chemicals: Organic solvents; acids


             APPENDIX B TO § 1910.1200
       HAZARD DETERMINATION (MANDATORY)

   The quality of a hazard communication program is largely
 dependent upon the adequacy and accuracy of the hazard deter-
 mination. The hazard determination  requirement of this stand-
 ard  is performance-oriented.  Chemical  manufacturers.
 importers,  and employers evaluating chemicals are not re-
 quired to follow any specific  methods for determining hazards.
 but  they must be able to demonstrate that they  have ade-
 quately ascertained the hazards of the chemicals produced or
 imported in accordance with the  criteria set forth in this
 Appendix.

   Hazard evaluation is a process which relies heavily on the
 professional judgment of the evaJualor. particularly in the area
 of chronic hazards. The performance-orientation of the hazard
 determination does not diminish the duty of the chemical man-
 ufacturer, importer or employer to conduct a thorough evalua-
 tion, examining all relevant data and producing a scientifically
 defensible evaluation. For purposes of this standard, the fol-
 lowing criteria shall be  used  in making hazard determinations
 mat meet the requirements of this standard.

 1. Carcinofrenicity: As described in paragraph  (d)(4)  and
 Appendix A of this section,  a determination by the National
 Toxicology' Program  the International Agency for Research on
 Cancer, or  OSHA that a chemical is a carcinogen or potential
 carcinogen will be considered conclusive evioence for purposes
 of this section
 1910.1200 Appendix B
                                                        156
806.28
                                                Change 48

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OCCUPATIONAL SAFETY AND HEALTH
                                             1910.1200 Appendix B
                                                                           STANDARDS AND INTERPRETATIONS
2. Human data: Where available, epidemiological studies and
case reports of adverse health effects shall be considered in the
evaluation.

3. Animal data: Human evidence of health effects in exposed
populations is generally not available for the majority of chem-
icals produced or used in the workplace.  Therefore,  the avail-
able results of lexicological testing in animal populations shall
be used to predict the health effects that may be experienced
by exposed workers. In particular, the definitions of certain
acute hazards refer to specific  animal  testing results (see
Appendix A).

-I. Adequacy and reporting of data. The  results of any studies
which are designed and conducted according to established sci-
entific principles, and which report statistically significant con-
clusions regarding the health effects  of a chemical,  shall be a
sufficient basis for a hazard determination »nd reported on any
material safety data, sheet. The chemical manufacturer, import-
er, or employer may also report the results of other scien-
tifically valid studies which tend to refute the findings of
hazard.
           Toxicology of the Eye. by W. Morion Grant
            Charles C. Thomas. 301-327 East Lawrence Avenue. Spring-
              field.  IL.

           Recognition of Health Hazards in Industry
            William  A. Burgess. John Wiley and Sons. 605 Third Avenue.
              New York. NY 10158.

           Chemical  Hazards of the Workplace
            Nick H. Proctor and James P. Hugrhes, J.P. Lipincott Com-
              pany, 6 Winchester Terrace, New York. NY 10022.

           Handbook of Chemistry and Physics
            Chemical  Rubber Company, 18901 Cranwood Parkway.
              Cleveland. OH 44128.

           Threshold Limit Values for Chemical Substances and Physical
              Agents in the Work Environment and Biological Exposure
              Indices with Intended Changes
            American Conference of Governmental Industrial Hygienists
              (ACGIH). 6500 Glenway Avenue, Bldg. D-5. Cincinnati,
              OH 45211.
           Information on the physical hazards of chemicals may be found
            in publications of the National Fire Protection Association.
            Boston, MA.
             APPENDIX C TO 1910.1200
        INFORMATION SOURCES  (ADVISORY)

  The following is a list of available data sources which the
chemical manufacturer, importer, distributor, or employer may
wish to consult to evaluate the hazards of chemicals they pro-
duce or import:
  —Any information in their own company files, such as tox-
icity testing results or illness  experience of  company
employees.
  —Any information obtained from the supplier of the chemi-
cal, such as material safety data  sheets or product safety
bulletins.
  —Any pertinent information obtained from the following
source list (latest editions should be used):
Condensed Chemical Dictionary
  Van Nostrand Reinhoid Co., 135 West 50th Street. New
  York. NY 10020.

The Merck Index: An Encyclopedia of Chemicals and Drugs
  Merck and Company, Inc.,  126 E. Lincoln Ave., Rahway, NJ
    07065.

I ARC Monographs on the Evaluation of the Carcinogenic Risk
    of Chemicals to Man
Geneva: World Health  Organization, International Agency for
  Research on Cancer,  1972-Present. (Multivolume work).
  Summaries are available in supplement volumes. 49 Sheridan
  Street, Albany, NY 12210.

Industrial Hygiene and Toxicology, by F.A. Patty
  John Wiley £ Sons, Inc., New York.  NY (Multivolume work).

Clinical Toxicology of Commercial  Products
  Gleason, Gosselin, and Hodge

Casarelt and Doull's Toxicology; The Basic Science of Poisons
  Doull, Klaassen. and  Amdur, Macmillan Publishing Co., Inc.
    New York. NY.

Industrial Toxicology, by Alice Hamilton and Harriet L. Hardy
  Publishing Sciences Group, Inc., Acton. MA.
             Note.—The following documents may be purchased from the
           Superintendent of Documents, U.S. Government Printing
           Office, Washington, DC 20402.

           Occupational Health Guidelines
             NIOSH/OSHA (NIOSH Pub. No. 81-123)

           NIOSH Pocket Guide to Chemical Hazards
             NIOSH Pub. No. 85-114

           Registry of Toxic Effects of Chemical Substances
             NIOSH Pub. No. 80-102

           Miscellaneous Documents published by  the National Institute
               for Occupational Safety and Health:
             Criteria documents.
             Special Hazard Reviews.
             Occupational Hazard Assessments.
             Current  Intelligence Bulletins.

           OSHA's General Industry Standards (Z9 CFR Part 1910)

           NTP Annual Report on Carcinogens and Summary of the
               Annual Report on Carcinogens.
             National Technical  Information Service (NT1S). 5285 Port
               Royal  Road, Springfield, VA 22161: (703) 487-4650.

                       BIBLIOGRAPHIC  DATA BASES
                 S«rvic« Provider
                                                 File name
           Bibliographic Retrieval Services
             (BRS). 1200 Route 7. Latham.
             NY 12110.
Biosis Preview*
CA Search
Medlorj
NTIS
Hoiordline
American Chemical Society
  Journal
Excerpio Medico
IRCS Medical Science  Journo'
Pre-Med
Change 48
806.29
                                                                                               1910.1200 Appendix C
                                                          157

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1910.1200 Appendix I)
                                                                            OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
Lockheed—DIALOG  Informo-
  lion Service. Inc .  3460 Hill-
  view Avenue. Polo Aho. CA
  94304
SDC—Orbii. SDC Informoiion
  Service, 2500 Colorodo Ave-
  nue,  Sonlo  Monico,  CA
  90406.
Nolionol Library o( Medicine,
  Deporlmeni of Heollh ond
  Homon • Services,  Public
  Heolth  Service.  Nolionol
  Institute of Heollh. Bethesdo,
  MD 20209.

Pergomon Iniernolionol Infor-
  motion Corp.,  1340 'Old
  Choin Bridge Rd,. McLeon,
  VA 22101.
Qoeslel. Inc.. 1625 Eye Street.
  NW, Suite 818, Woshinglon,
  DC 20006
Chemicol Informoiion System
   ICI (ICIS). Bureou of Notional
   Affoirs. 1 133 15th Street.
   NW, Suite 300. Washington,
   DC 20005.
 Occupational Heolth Services.
   400 Plozo Drive. Secoucus.
   NJ 07094
Intl. Pharmaceutical Abstracts
Paper Chem
BIOSIS Prev. Files
CA Search files
CAB Abstracts
Chemicol Exposure
Chemnome
Chemsis Files
Chemzero
Embose Files
Environmental Bibliographies
Envirolme
Federal Research m-Progress
IRL Life Science Collection
NTIS
Occupational Safely ond
  Health (NIOSH)
Paper Chem
CAS Files
Chemdex. 2, 3
NTIS

Hazardous Substances Data
  Bonk (NSDB)
Medline  files
Toxline Files
Concerlit
RTECS
Chemlme
Laboratory Hazard  Bulletin
 CIS/ILO
 Concernei

 Structure ond Nomenclature
   Search System (SANSS)
 Acute Toxicily (RTECS)
 Clinical Toxicology of Commer-
   cial Products
 Oil and Hazardous Materials
   Technical Assistance Do to
   System
 CCRIS
 CESARS
 MSDS
 Hozordline
               APPENDIX D TO 1910.1200
    DEFINITION OF "TRADE SECRET" (MANDATORY)

   The following is a reprint of the Restatement of Torts section
  757, comment 6 (1939):

  b. Definition of trade secret. A trade secret may consist of
  any formula, pattern, device or compilation of information
  which is used in one's business, and which gives him an oppor-
  tunity to obtain an advantage over competitor? who do not
  know or use it. It  may be a formula for a chemical compound.
  process of manufacturing, treating or preserving materials, a
  pattern for a machine or other device, or a list of customers. It
  differs from other secret information in a business (see !: 759 of
  the Restatement of Torts which is not included in this AppendiN
  in that it is not simply information as to single  or ephemeral
  events in  the conduct of the business, as. for  example, the
amount or other term? ol' a secret bid for u contract or the- ;-al-
ary of certain employees, or the security investments made or
contemplated, or the tlatf fixed for the announcement of a new
policy or for bringing out  a new model or the like. A trade
secret is a process or device for conlinuou.- use in the opera-
tions of the business. Generally it relates to the production of
goods. a.<. for example, a machine or formula for the production
of an article. It may. however, relate to the sale of goods  or to
other operations in the business, such as a code for determining
discounts, rebates or other concessions in a price list or  cata-
logue, or a list of specialized customers, or a method of book-
keeping or other office management.
  Secrecy. The subject matter of a trade secret must be secret.
Matters of public knowledge or of general knowledge in an
industry cannot be appropriated by one as his secret. Matters
which are completely disclosed by the goods which one markets
cannot be his secret. Substantially, a trade secret is known only
in the particular business in which it is used. It is not requisite
that only the proprietor of the business know it. He may. with-
out losing his protection, communicate it to employees involved
in its use.  He may likewise communicate it to others pledged to
secrecy. Others may also know of it independently, as.  for
example, when  they have discovered the process or formula by
independent invention and are keeping it secret.  Nevertheless.
a substantial element of secrecy must exist, so that, except by
the use of improper means, there would be difficulty in acquir-
ing the information. An exact definition of a trade secret is not
possible. Some factors to be considered in determining whether
given information is one's trade secret are: (1)  The extent to
which  the information is known outside of his business: (2) the
extent to which it is known by employees and others involved
in his  business: (3) the extent of measures taken by him to
guard  the secrecy of the information;  (4) the value of the infor-
mation to him and his competitors: (5) the amount of effort or
money expended by him in developing the information: (6) the
ease or difficulty with which the information  could be properly
 acquired or duplicated by others.
   Xovelty and prior nrt. A trade secret may be a device or
 process which is patentable: but it need not be that. It may be a
 device or process which is clearly anticipated in the prior an or
 one which is merely a mechanical improvement ihat a good
 mechanic can make. Novelty and invention are not requisite for
 a trade secret as they are for patentability. These requirement?
 are essential to patentability because a patent protects against
 unlicensed use of the patented device or process even by one
 who discovers it properly through independent  research.

 The patent monopoly is  a reward to the inventor. But such is
 not the case with a trade secret. Us protection is not based on a
 policy of rewarding or otherwise encouraging the development
 of secret processes or devices. The protection is merely against
 breach of faith and reprehensible means of learning another's
 secret.  For this limited protection  it is  not appropriate  to
 require also the kind of novelty and invention which is a requi-
 site of patentability. The nature of the secret is. however, an
 important factor in determining the kind of relief that is appro-
 priate apainst  one who if subject to liability unrter the rule
 stated in this section. Thus, if the secret consists of a device or
 process which i* a novel  invention, one who acquires the secret
 wrongfully is ordinarily enjoined  from further use of it and is
 required to account for the profits derived from hi? past u?e.  If.
 on the other hand, the secret consists of mechanical improve-
 ment? that  a pood mechanic  can  make without resort to the
 secret,  the  wrongdoer's liability may be limned to damages.
 ami an injunction againM. future use of the improvements made
 with the aid of the secret may be inappropriate.
  1910.1200 Appendix D
                                                              806.30
                                                                                 Change -IS
                                                          158

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otViTATIOXAL.SAFETY AXD HKALTH
I'Uii.l.'u A|)|ifmli\ I)
                                                                               STAXDAKUS AXIl INTF.KI'KKTATIdXS
                               < Approved by the Dffict- »f .M.ui.iL'rineni ;ii)(l IHidnel undei
                               I'umrol Xl "hazardous chemical" under Section :tl lie)(3i "I
                               the Sii]>ertii!Hl .•\iiiendnieni< and Renuthorization  Act  ol  ISiMi.
                               and Cil coveMUe of any drujr.4 ret:ulaled by the Kood and l)ru.u
                               Administration in the nun-maiiul'aciurinj: sector, i

                                              153 K.K.  15035. April 27.  19S8]
                                                        806.31

                                                              159
          Chanuo

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        SECTION 2
  OCCUPATIONAL HEALTH
           AND
SAFETY GUIDANCE DOCUMENTS

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                         OCCUPATIONAL HEALTH
                                      AND
                     SAFETY GUIDANCE DOCUMENTS
SECTION OBJECTIVE

The objective of this section is to provide students with a copy of the following US EPA health and
safety guidance documents:

      •     US EPA Office of Solid Waste and Emergency Response (OSWER) Integrated Health
            and Safety Policy for Field Activities (1988)

      •     US EPA Environmental Response Team's (ERT) Occupational Medical Monitoring
            Program  Guidelines for SARA Hazardous  Waste  Field  Activity  Personnel
            (Publication 9285.3-04-1990)
STUDENT PERFORMANCE OBJECTIVES

After completing this section and related lesson(s), the student will be able to:

      •      Discuss elements of an employer's overall safety and health program.

      •      Discuss recommended guidelines  for  implementation  of a medical surveillance
             program, including purpose, frequency, and recommended test protocol for medical
             examinations.

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                    SECTION 2

               OCCUPATIONAL SAFETY
                       AND
            HEALTH GUIDANCE DOCUMENTS

                      PART 1

US EPA OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
                     (OSWER)
       INTEGRATED HEALTH AND SAFETY POLICY
                FOR FIELD ACTIVITIES

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OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE


     INTEGRATED HEALTH  AND SAFETY  POLICY


                     FOR


              FIELD ACTIVITIES
          ASSISTANT ADMINISTRATOR

OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
              401 M Street, NW
            Washington  DC  20460
                                           May 15, 1988

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                                   ABSTRACT


PURPOSE:  The purpose of this document is to establish an Integrated Health
and Safety Policy for all Office of Solid Waste and Emergency Response
(OSWER) Superfund Amendment Reauthorization Act field activity employees who
are engaged in hazardous substances or related activities.

BACKGROUND:  The Environmental Protection Agency (EPA) is mandated by a
number of laws and regulations to safeguard the health and safety of its
employees.  While the Occupational Health and Safety Staff (OHSS), within
the Office of Administration and Resources Management's (OARM) Office of
Administration (OA), has overall responsibility for the development,
organization, and administration of EPA's Health and Safety Programs, the
responsibilities for establishing, implementing, and enforcing an
Occupational Health and Safety Program have been delegated to Assistant
Administrators (AA) and Regional Administrators (RA) by the EPA Occupational
Health and Safety Manual (EPA Order 1440).  Since OSWER has the
responsibility for developing and implementing specific health, safety, and
training programs for its employees, this document is intended to inform the
field activity employee of his/her duties and responsibilities in regard to
specific health and safety policies, and to demonstrate OSWER's overall
commitment to the protection of its employees.

APPLICABILITY:  This policy is effective for all OSWER field activity
employees who are either actively or potentially involved in various
hazardous substances field activities (i.e., RCRA major corrective actions
and RCRA storage, treatment, and disposal facilities regulated under 40 CFR
parts 264 and 265; Hazardous Waste & Emergency Response; Chemical
Preparedness; Underground Storage Tanks; Solid Wastes; etc., and other field
activities involving hazardous or potentially hazardous substances ).
Applicability of this policy also extends to persons who are not employed by
OSWER, but are either under a specific contract or otherwise under the
jurisdiction of OSWER.
                                                           May  15,  1988

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                                  CONTENTS


 1.0   PURPOSE                                            1

 2.0   OSWER  POLICY                                       1

 3.0   AUTHORITY                                          2

 4.0   RESPONSIBILITY                                     2

         4.1  ADMINISTRATIVE                            2

         4.2  TRAINING                                  3

         4.3  MEDICAL SERVICES                          3

         4.4  OSWER  INTEGRATED HEALTH
              AND SAFETY PROGRAM                        4

 5.0   FIELD ACTIVITY  CATEGORIES
      AND PROCEDURES                                     4

         5.1  DEFINITION OF CATEGORIES                  4

         5.2  CATEGORY REQUIREMENTS                     6

         5.3  STANDARD OPERATING GUIDELINES             7

 6.0   MEDICAL BASELINE AND MONITORING PROGRAMS           9

 7.0   TRAINING REQUIREMENTS                              9

 8.0   HAZARD COMMUNICATION/RIGHT-TO-KNOW                10

 APPENDIX A OSWER INCIDENT SAFETY CHECK-OFF SHEET       12

 APPENDIX B OSWER MEDICAL MONITORING REQUIREMENT        13

 APPENDIX C SUMMARY OF THE OSWER HEALTH AND
             SAFETY TRAINING REQUIREMENTS              14

APPENDIX D OSWER RESPIRATORY PROTECTION PROGRAM        15

APPENDIX E OSWER INTEGRATED HEALTH i SAFETY
           WORK GROUP ORGANIZATIONAL CHART             22

APPENDIX F EPA HEALTH AND SAFETY REQUIREMENTS
           AND GUIDELINES                              23

APPENDIX G GENERAL DESCRIPTION OF THE OERR LEVELS
           OF PROTECTION AND PROTECTIVE GEAR           24
                                                           May 15, 1988

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1.0  PURPOSE

     The purpose of this document is to establish an Integrated Health and
     Safety Policy for all OSWER employees who are presently, or who may
     be engaged 1n the future field activities (e.g. hazardous substance
     field activities and related activities involving hazardous
     chemicals/ substances).

     1.1  Each OSWER employee involved in field activities shall receive
          appropriate training,  equipment, and medical monitoring in
          accordance with the U.S. EPA Occupational Health and Safety
          Manual (Order 1440), U.S. EPA Orders 1440.2 and 1440.3, the
          Office of Emergency and Remedial Response (OERR), Hazardous
          Response Support Division Standard Operating Safety Guides, as
          well as other appropriate Federal/State requirements and
          guidelines such as 29 CFR 1910/1926.

     1.2  Any extension of duty associated with hazardous substances or
          other similar OSWER field activities beyond the specific field
          category to which a particular employee 1s assigned or for which
          he/she 1s specifically qualified by training and practical
          experience is prohibited.  No supervisor is authorized to order,
          direct, or otherwise instruct an employee to enter a situation
          that is more hazardous than that employee's field training
          certification (e.g., Occupational Health and Safety Manual
          [Chapter 7], EPA Order 1440.2 and 29 CFR 1910.120).  Such an
          assumption of duty by an employee involves the concomitant
          assumption of all risks on the part of that individual should
          the employee be specifically informed.that the assumption or
          duty is beyond the scope of his/her training.

2.0  OSWER POLICY

     2.1  All employees who participate in field activities must be
          classified into field activity categories.

     2.2  An employee must receive the required training and health
          monitoring prior to performing field activities.

     2.3  All organizations that have their own health and safety
          programs, including private contractors and other Federal, state
          and local agencies, shall utilize and be responsible for the
          administration of their individual programs as long as these
          programs are at least as stringent as the OSWER requirements and
          OSHA standards.

     2.4  EPA has delegated to the AA, OSWER, the Health and Safety
          responsibility for OSWER employees.  It is OSWER policy that
          contractors shall be responsible for implementing the Office of
          Emergency and Remedial Response  (OERR) Standard Operating Safety
          Guides (SOSG) for its employees  and operations, including
          employee rights to know.  In this regard, EPA at a minimum


                                                           May  15,  1988

-------
          requires that each contractor know and adhere to HRSD'S SOSG, 29
          CFR 1910.120, and 29 CFR 1910/1926.  EPA has chosen to implement
          this policy by allowing the contractor to design an internal
          health and safety program and to certify to EPA that the
          company's program complies with the SOSG and 29 CFR 1910/1926.
          Where a contractor's health and safety program differs from the
          SOSG, the contractor must certify to EPA that his program is at
          least as stringent as EPA requirements.

3.0  AUTHORITY

     The authority for this program is derived from:  U.S. EPA, OHSS,
     Occupational Health and Safety Manual, U.S. EPA Order 1440, 1440.2,
     and 1440.3, and all applicable Federal requirements.

4.0  RESPONSIBILITY

     4.1  ADMINISTRATIVE

          4.1.1   CATEGORIZATION - This order identifies four distinct
                  field activity categories into which employees are
                  assigned based upon their field training certification
                  classification (EPA Order 1440.2 and 29 CFR 1910.120)
                  and exposure potential.  The categories are defined and
                  outlined in Section 5.0. (Procedures and Duty
                  Categories) of this document.

          4.1.2   Office Directors are delegated the authority and
                  responsibility to implement and enforce this policy.  To
                  ensure a truly integrated/coordinated program, each
                  Office Director is required to assign at least one
                  occupational and safety health person to serve as
                  liaison on the OSWER Integrated Health and Safety
                  Workgroup chaired by the Environmental Response Team
                  (ERT), Edison, N.J.

          4,1.3   Division Directors are delegated the authority to
                  identify each field activity position in their
                  Divisions.

                  Budgeting of funds for safety  training and for the
                  purchase, maintenance and storage of employee safety
                  equipment is the responsibility of the Division
                  Director.

          4.1.4   Branch Chiefs are responsible  for assigning field
                  activity categories to Section Chiefs/first line
                  supervisors.

                  The Branch Chiefs are also responsible for maintaining
                  Employee Safety and Training Records, which contain all
                  safety-related matters.


                                                           May 15,  1988

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     4.1.5   Section  Chiefs/first line supervisors  are  responsible
             for assigning field activity categories  to an  individual
             employee.   Each employee  shall  be  provided with  a
             complete description of the  field  activity categories.
             The Section Chief or designee is responsible  for
             purchasing, issuing, and  training  his/her  personnel
             concerning  any phase of respiratory  protection.

     4.1.6   Employee must read and  fully understand  the OSWER policy
             and sign a  statement attesting  to  that fact.

     4.1.7   OSWER  Integrated Health and  Safety Workgroup will
             coordinate  the implementation and  maintenance  of this
             policy.  The Workgroup  representative  is the  focal  point
             for coordinating the office's activities with  regard to
             OSWER  employee occupational  health and safety
             activities.

4.2  TRAINING

     4.2.1   The development, implementation, and maintenance of
             safety training programs  shall  be  the  highest  OSWER
             training priority.  The AA,  OSWER, or  designee,  is
             ultimately  responsible  for ensuring  that all OSWER
             employees and contractors receive  the  appropriate safety
             equipment and training  or equivalent in  accordance  with
             U.S. EPA Orders (e.g.,  1440,  1440.2, 1440.3)  and 29 CFR
             1910/1926.

     4.2.2   The responsibility for  ensuring that all employees
             receive  the appropriate mandatory  safety training is
             shared jointly by the OSWER  Office Directors,  Division
             Directors,  Branch Chiefs, Section  Chiefs/first line
             supervisors, and employee.

     4.2.3   All supervisors equivalent to or lower than Section
             Chiefs in charge of field activity employees  should
             receive  commensurate safety  training in  all applicable
             field  safety categories.

4.3  MEDICAL  SERVICES

     4.3.1   The AA,  OSWER, (or designee) is ultimately responsible
             for ensuring that all field  activity employees actively
             participate in a Medical  Monitoring  Program (See
             Appendix B).

     4.3.2   It is  the employee's responsibility  to seek medical
             assistance  and advise his/her supervisor in the event of
             exposure or potential exposure to  a  contaminant.  In
             addition, the employee  must  report all accidents/
                                                      May 15, 1988

-------
                  exposure to his supervisor so the required workers'
                  compensation form can be carried to the medical
                  provider.

          4.3.3   If an emergency exists,  the employee must contact the
                  supervisor and complete  the necessary forms as soon as
                  possible (see EPA Occupational  Health and Safety Manual,
                  Order 1440, Chapter 3).

     4.4  OSWER INTEGRATED HEALTH AND SAFETY PROGRAM

          The Agency's Occupational  Health and Safety Manual (EPA ORDER
          1440),  particularly Chapter 9,  establishes occupational health
          and safety policy and requirements, and assigns responsibilities
          for EPA employees engaged in hazardous  substance field
          activities.   In order to meet these requirements, the
          Environmental Response Team (ERT), Edison, NJ has been delegated
          the responsibility to manage the OSWER  Integrated Health and
          Safety  Program.  The primary objective  of the program Is to
          ensure  that  all aspects of the  safety and occupational health
          requirements are met in a timely fashion to afford each employee
          proper  protection.

5.0  FIELD ACTIVITY CATEGORIES AND PROCEDURES

     5.1  DEFINITION OF CATEGORIES

          In order to  meet the specific needs of  the individual OSWER
          employees, this policy requires  additional administrative
          controls over those of EPA Orders 1440.2 and 1440.3.   The
          administrative control  is  a further restriction to EPA Order
          1440.2  "Basic, Intermediate and  Advanced" training
          certification, and is accomplished by assigning Categories No.
          1-4 to  the appropriate field activity personnel.   Because of
          these additional  administrative  controls, Categories  2 and 3
          employees are exempt from the EPA Order 1440.2 requirement of
          three days of on-the-job training within three months of
          classroom training unless  requested by  the employee.   However,
          when applicable,  they are  still  required to meet the  three days
          of on-the-job training.

          The employee's category assignment may  be changed by  the first
          line supervisor via written notification to the Manager, OSWER
          Integrated Health and Safety Program, U.S. EPA-ERT,  (Mall Code
          HS101)  Raritan Depot, Bldg. 10,  Woodbridge Ave.,  Edison, NJ
          08837 (FTS 340-6740).  This notification consists of  Identifying
          the employee's necessary change(s) and  verifying that the
          appropriate  training, equipment,  and medical  examination have
          been provided to the employee for the reclass1f1cat1on.
                                                           May 15,  1988

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          5.1.1   Category  1  is established  as  the OSVER highest  risk
                 category.   This category Includes  all employees whose
                 job description/critical job  elements require handling
                 of, or  potential exposure  to,  Identified  or  unidentified
                 hazardous chemicals.   For  example, employees responding
                 to spill  emergencies,  uncontrolled hazardous waste
                 sites,  etc.  (i.e., ERT personnel)  are in  this category.
                 These employees are authorized to wear OERR  Levels  of
                 Personnel Protective Equipment A,  B, C, and  D.   Medical
                 examinations are given every  six months.   See Appendix G
                 for details.

          5.1.2   Category  2  includes those  OSWER personnel  who are
                 required  to enter the  "Exclusion Zone* or a  facility's
                 "Treatment/Storage Activity Area" where there is the
                 potential of exposure  to identified or unidentified
                 hazardous chemicals, for   more than approximately 20
                 days per  calendar year.   Sampling and corrective
                 action  activities are  some examples of the job
                 function.   These employees are authorized to wear OERR
                 Levels  of Personnel Protective Equipment  C and  D, and
                 receive Medical Examinations  annually.  (Those  employees
                 that will only engage  in RCRA activities  will receive a
                 Category  2A Listing.)  See Appendix G for details.

          5.1.3   Category  3  includes those  OSHER personnel  who are
                 required  to enter the  "Exclusion Zone" or a  facility's
                 "Treatment/Storage Activity Area" where there is the
                 potential of exposure  to identified or unidentified
                 hazardous chemicals situations, etc., for less  than
                 approximately 20 days  per  calendar year .  Sampling
                 and corrective action  activities are some examples  of
                 the job function.  (Those  employees that  will only
                 engage  in RCRA activities  will receive a  Category 3A
                 Listing.)   See Appendix G  for details.

                 Medical examinations are scheduled based  on  the
                 employee's  number/frequency of hours of potential
                 exposure.   This period may range from 1-4 years. These
                 employees are authorized to wear OERR Levels of
                 Personnel Protective Equipment C and D.   See Appendix G
                 for details.

          5.1.4   Category  4  includes all other OSWER field activity
                 personnel not specifically addressed in Categories  1-3,
                 but who are required to perform his/her job  function in
                 a  "Secure/Clean Area"  of those activities Identified in
                 Categories  1 through 3.  These employees  are not
                 authorized  to wear OERR Levels of  Personnel  Protective
                 Equipment.
  The period of potential  exposure  of greater  than  or  less  than  20 days
is derived from the  30-day standard in  29  CFR  1910.120 and  may be  modified
as appropriate  per supervisor  and employee agreement.


                                                           May 15, 1988

                                    10

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             Examples of this type of employee are:  Certain
             operations conducted under RCRA as described 1n 29 CFR
             1910.120(0); employees and supervisors who perform
             activities In the "Support Zone" at hazardous waste site
             emergency spills.

5.2  CATEGORY REQUIREMENTS

     This section of the OSWER policy provides a basic framework for
     the safe conduct of Category 1-4 personnel while being directly
     or indirectly involved in a hazardous substance activity.

     5.2.1   OSWER field activity personnel must be aware, 1n
             advance, of the objectives of each site visit and  must
             be prepared to employ safe operations to avoid potential
             hazards.  Each employee is required to enforce and
             comply with this policy and exercise good personal
             judgement and technical expertise on a case-by-case
             basis.

     5.2.2   Whenever applicable, OSWER field activity personnel are
             required to implement the OERR, HRSD, Standard Operating
             Safety Guides for guidance and selection criteria.
             OSWER personnel must exercise extreme caution to prevent
             loss of life, injury, or health hazards to themselves
             and to the general  public.  OSWER field activity
             personnel  are required to adhere to this policy whether
             or not the Regional  requirements are as specific as this
             policy.

     5.2.3   In the event of conflicting safety regulations, the
             employee must implement those safety practices affording
             the highest level of protection 'for everyone Involved.

             5.2.3.1   Qualifications

                      To be eligible to perform Category 1-3 duties,
                      the employee must:

                      a)  be assigned to the on-site work by his/her
                          supervisor;
                      b)  complete a Baseline Medical Examination and
                          participate in a medical monitoring
                          program;
                      c)  complete the appropriate health and safety
                          training program as per U.S. EPA Order
                          1440.2, 1440.3,  and 29 CFR 1910.120 prior
                          to involvement in field activities, and/or
                          other types of similar field activities;
                      d)  be assigned the  appropriate Field Activity
                          Category.
                                                      May 15,  1988
                                      11

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5.3  STANDARD OPERATING GUIDELINES

     5.3.1   Pre-arrlval Planning

             In planning a field activity, it 1s the employee's
             responsibility to be aware of the purpose of the field
             activity and comply with the OSWER Integrated Health and
             Safety Policy, OHSS Occupational Health & Safety Orders,
             29 CFR 1910.120, and all applicable requirements.

             5.3.1.1  PRIOR to arrival  at a field activity location,
                      the employee shall  complete Part One of the
                      OSWER Incident Safety Check Sheet (refer to
                      Appendix A) and furnish it to the first line
                      supervisor or designee for review.  It is
                      recognized that lead time and availability of
                      information are usually limited; however, the
                      employee must attempt to complete this form
                      (preferably prior to office departure).  If any
                      emergency arises, it is recommended that, the
                      employee and his/her supervisor contact the
                      Environmental Response Branch's Edison, NJ
                      Hotline (201-321-6660) for technical
                      assistance.

             5.3.1.2  When Applicable,  Site Safety Plans shall be
                      completed and submitted in accordance with 29
                      CFR 1910.120, OHSS, Occupational Health and
                      Safety Manual, and OERR, HRSD, Standard
                      Operating Safety Guides.

     5.3.2   Safety Onsite (When Applicable)

             OSWER personnel shall implement on-site evaluation and
             inspection in accordance with the OERR, HRSD, Standard
             Operating Safety Guides.

             5.3.2.1  The buddy system shall be utilized in the
                      field; OSWER field personnel shall not enter an
                      "Exclusion Area" or a RCRA hazardous waste TSD,
                      etc., alone.  Employees shall make use of their
                      practical experience and technical expertise to
                      keep alert to potentially dangerous
                      situations.  Guidance for these types of
                      precautionary measures and procedures is
                      provided 1n the OERR, HRSD, Standard Operating
                      Safety Guides and other state-of-the-art
                      technology documents.
                                                      Hay 15, 1988
                                12

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             5.3.2.2  If any condition suggestive of a situation more
                      hazardous than anticipated 1s discovered, all
                      field activity shall temporarily stop for a
                      revaluation of the hazard and the level  of
                      protection required.

             5.3.2.3  In the event that an OSWER Held activity
                      employee experiences any adverse effects or
                      symptoms of exposure while engaged In field
                      activities, he/she must immediately leave the
                      site/area, and contact the site/facility
                      supervisor (OSC, etc.), and seek appropriate
                      medical attention.  Such incidents must be
                      reported in accordance with Chapter 3 of the
                      EPA Occupational Health and Safety Manual (EPA
                      Order 1440).

5.4  Personnel  Protection

     If OSWER personnel  are required to enter any area 1n which there
     is a risk of potential exposure or in which respiratory
     protection is needed, e.g., a hazardous site/spill exclusion
     zone, RCRA storage facility, manufacturers production area,
     etc., they are required to adhere to this Integrated Health and
     Safety Policy whether or not the Regions have a policy or a
     specific site safety plan.  Employees are required to refer to
     the OERR,  HRSD, Standard Operating Safety Guides for a detailed
     description of the levels of protection and selection criteria.

5.5  Site Departure and Decontamination Procedures

     Disposable safety clothing and sampling equipment shall be
     properly disposed.   If appropriate disposal facilities are not
     available, safety clothing, and sampling equipment shall be
     placed in a suitable container pending proper disposal.
     Nondisposable safety clothing and sampling equipment shall be
     decontaminated (preferably on-site) in accordance with the OERR,
     HRSD, Standard Operating Safety Guides.  In the event that the
     adequacy of these procedures is questionable, nondisposable
     equipment shall be placed in appropriate containers until  the
     exact nature of the sampled material is known.  Suitable
     decontamination procedures shall then be employed to clean the
     equipment, or the equipment shall be properly disposed of at an
     approved RCRA hazardous waste facility that meets the
     requirements of the EPA offsite policy (OSWER Directive 9834.11)
     and EPA Land Disposal Restrictions (RCRA sections 268.30 and
     268.32).
                                                      Hay 15, 1988
                                      13

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6.0  MEDICAL BASELINE AND MONITORING PROGRAMS

     Based on their field exposure classification, OSWER field activity
     employees shall undergo routinely scheduled examinations to determine
     the possible health effects of such activity.  A medical baseline
     health profile shall be established for this purpose.  As a minimum,
     the OSWER medical monitoring program shall consist of OHSS guidelines
     and requirements.  In general, the medical monitoring program shall
     be apportioned into three classes on the basis of employee field
     activities and potential exposure.  In addition, OSWER field activity
     personnel shall immediately receive post-exposure medical/treatment
     examinations upon notifying their Section Chief(s) of an exposure.  A
     tabular summary of the OSWER Medical Monitoring Requirements
     according to Field Activity Category is included in Appendix B of
     this document.

7.0  TRAINING

     An adequate training program is essential for proper implementation
     of this Integrated Health and Safety Policy.  The complexities of the
     topics of interest, the variety of courses offered, and the need for
     specific training within each category necessitates formulation of
     certain ground rules.

     7.1  Each OSWER field activity employee shall receive safety training
          commensurate with the job requirements and field exposure
          classification.  First line supervisors shall recommend
          additional safety training courses for an employee's future
          needs.

     7.2  A series of core topics are designated for each category as
          tabulated in the Summary of the OSWER Health and Safety Training
          Requirements (Appendix C).  These core topics are mandatory of
          all OSWER Field Activities Category Employees.  The other topics
          identified as "desirable" should be taken by employees based
          upon the recommendations of their supervisors.  The level of
          training provided shall be consistent with the employee's job
          function and responsibilities.  Supervisors are responsible for
          insuring that their employees are properly trained.

     7.3  The training plans and programs must remain flexible enough to
          include/delete any additional/obsolete topics as the need arises
          or new ideas are introduced.  As per EPA Order 1440.2 and 29 CFR
          1910.120, 8 hours of refresher training are required annually of
          most OSWER field activity personnel.

     7.4  Training hour requirements vary on the specific field activity.
          The following summarizes the 29 CFR 1910.120 training
          requirements as it relates to the OSWER Field Activity
          Categories:
                                                           May 15, 1988
                                   14

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          Category  1:  Forty hours of training, plus 3 days  of  actual
          field experience under the direct supervision of a trained,
          experienced supervisor.  (Field supervisor in this category will
          be required to have an additional 8 hours of "Supervisor
          Training.")  All employees shall receive 8 hours of refresher
          training  annually.

          Category  2:  Hazardous waste site and corrective action site
          workers are required to have the same as Category  1 (above).
          All other Category 2 personnel that do not enter an Exclusion
          Zone or equivalent area,  may qualify for 29 CFR 1910.120(0)
          training  requirements of 24 hours initial training and 8 hours
          refresher training annually.

          Category  3:  Hazardous waste site and corrective action site
          workers are required to have the same as Category  1 (above).
          All other Category 3 personnel that do not enter an Exclusion
          Zone or equivalent area,  may qualify for 29 CFR 1910.120(0)
          training  requirements of 24 hours initial training and 8 hours
          refresher training annually.

          Category  4:  Although not required by 29 CFR 1910.120, all
          Category  4 employees are  required to have a minimum of 4 hours
          of training in those areas identified in Appendix C.

8.0  HAZARD COMMUNICATION/RIGHT-TO-KNOW

     8.1  The EPA is required to communicate the hazards associated with
          the workplace to all  EPA  employees.   EPA Order 1440.7, Hazard
          Communication,  requires that employees be given information and
          training  on hazardous substances in their work areas.

     8.2  It is EPA policy that it  will  extend the hazardous
          communication/right-to-know requirement to its contractors or
          contractor representatives.  At a minimum,  OSWER employees and
          contractors and their representatives must be informed of the
          physical  and health hazards of known substances in  the work
          area, methods to detect hazardous substances, and measures
          employees can take to protect themselves from the hazards.  In
          the case  of OSWER employees,  the hazardous substances  are often
          unknown.

     8.3  All parties working together at hazardous waste sites  or spill
          emergencies/accidents must  share all available information on
          the possible hazards  involved.

     8.4  As part of the  hazard communication, employees are  to  be
          informed of the threat to human reproduction  by chemicals  1n the
          workplace.  OSWER employees (both male and female)  who are
          potentially exposed to chemicals that affect  reproduction,  such
          as teratogens,  mutagens,  and chemicals that alter fertility,
                                                           May 15,  1988
                                      15

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have the right to request a temporary  change 1n  job assignment
as needed to allow conception or to  protect  an unborn child.
Each request will be handled on an  individual basis.   For each
request the supervisor has the responsibility to assess the
reproductive hazards associated with the  job and to make
reasonable accommodations of equal professional  status.
                                                 May 15, 1988
                        16

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                                    Appendix A
                       OSWER INCIDENT SAFETY CHECK-OFF LIST
 I.  BEFORE FIELD ACTIVITY       Employee
 1.  Incident: Site	      City	    State.
    a. Response Dates,
    Activity Description:  Environmental  Sampling	 Product Sampling,
    Residential	 Site Evaluation	 Containment	 Well  Drilling_
    Facility Inspection.
3.  Type of Response:  Spill	 Site 	  Facility	 Other	
4.  Site Topography:  Mountains	 Rivers	  Valley	 Rural.
    Suburban	 Urban	 Level	 Slopes	
    Facility	
5.  Incident Safety Plan:  Not Developed 	  Reviewed 	
    (when applicable)      Region        	  Briefed   	
                           ERT           	

6.  Site Accessibility:  Road:  Good	 Air:  Good	
    (when applicable)           Fair	       Fair	
                                Poor	    Poor	
7.  Suspected chemical(s) and pathway with source(s) involved:   (A)	
    (B)	 (C) 	 (D).
8.  Emergency Response Teams present for First Aid, etc. Yes	 No
9.  Protective Level(s) Selected:  (A)	  (B)	  (C)	  (D)	~
   (a) If Level "C," Identify Canister
       If Level "D," JUSTIFY:  write in comments section  at  bottom  of page
10.  If SCBA, Identify Buddy System:  Office/Name.
11.  Last Response:  (a)  Level Used:  (A)	 (B)	  (C)	  (D)	
                     (b)  Medical Attention/Exam Performed:  Yes	 No_

II.  AFTER RESPONSE

1.  Protective Level  Used:  (A)	 (B)	 (C)	  (D)	
  a.  Level "C," identify canister: 	 b. Level "D"  (comment  below)
  c.  Level B/C skin protection: Tyvek	 Tyvek/Saran	 Acid/Rain	
      Other	

2.  List possible chemical exposure:  Same as above:  (A)	
(B)	 (C)	 (D).
3.  Equipment Decontamination:  (a) clothing (b) respirator  (c) monitoring
              Disposed:
Cleaned:
No Action:
4. Approximate time in
PART I: Date Prepared
PART II: Date Prepared


exclusion area:
Reviewed by
Reviewed by


hr/day for days
Date
Date
                                                           May 15, 1988
                                       17

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                                  APPENDIX B
              SUMMARY OF OSWER MEDICAL MONITORING  REQUIREMENTS
                            PER EMPLOYEE CATEGORY
EMPLOYEE
CATEGORY 1
2
3
4
  Examination
    Class*
N/A
Base line plus
 Medical
 Monitoring
 Exam every

 6 months
Base line
 Annual
 Medical
 Monitoring

 Exam
                                            plus
Base line plus
periodic medi-
cal  monitoring
exam based on

potential exp-
osure freq.
(avg 1-4 yr)
* Examination rate may increase with increasing incidence of exposure.

NOTE:  A "calendar year"  is a somewhat arbitrary term when discussing a
       measurement of exposure.  For example, 8 one-day visits to a site
       where the exposure is great or the toxicity is high may be more
       critical to the health of the individual than 19 visits at another
       site.  Therefore,  all factors must be considered when selecting the
       Medical Monitoring Exam schedule.
                                                           May 15, 1988
                                   18

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                                                      APPENDIX C

                        SUMMARY Of THE OSUER HEALTH AND SAFETY TRAINING COURSE REQUIREMENTS
          OERR
         levels
  Cate-  of Pro-       EPA Order        OSUER Policy   OERR  Standard Operatic   Properties of
  gory   tection 1440.2 Classification    Document          Safety Guides        Hazardous Htl«.    Toxicology
1
2
3
4
A,B.C
C
C
MOHE
Advance
Intermediate/Basic
Intermediate/Basic
N/A
X
X
X
X
X
X
X
X
X
X
X
N/A
X
X
X
N/A
                                                                                         Employee
                                                                                        Right* and
  Cate-  Basic Office Basic Field     Protective Respiratory D«conta»ination    Entry    Responsi-  Defensive
  gory    First Aid    First Aid  CPR   Clothing   Protection   Procedures    Procedures   bilities    Driving
1
2
3
4
0
0
0
0
X
X
X
0
0
0
0
0
X
X
X
N/A
X
X
X
N/A
X
X
X
N/A
X
X
X
N/A
X
X
X
X
X
X
X
X
Key:   X " Mandatory, Core Topics
       0 > Desirable, lut Not Mandatory
     N/A » Not Applicable
       * ' CardIopuInonary Resuscitation
                                                                                       May 15,  1988
                                                      19

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                                 APPENDIX D

                    U.S.  ENVIRONMENTAL PROTECTION AGENCY
                OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
                      RESPIRATORY  PROTECTION PROGRAM
                            (Revised  March 1988)
I.    Purpose
      The Office of Solid Waste and Emergency Response (OSWER) respiratory
      protection program is intended to control exposures to those agents
      that may cause occupational diseases when air is contaminated with
      harmful dusts, fogs,  fumes, mists, gases, smokes, sprays, or vapors.
II.   Objective
      Respiratory protection may be properly worn when effective
      engineering control  methods are not feasible, while they  are being
      implemented, or in emergencies.  Generally, most corrective actions
      do not lend themselves to effective engineering controls.
      Therefore, respiratory protection is judged to be the best approach
      to ensure employee health protection.  It is important to note,
      however, that effective work practices can minimize reliance on such
      devices. The primary objective of this program is to protect the
      employee against "potential" exposure as well as measured exposure.

III.  Scope

      This respiratory protection program is intended to address all OSWER
      field activity employees.

IV.   Responsibility

      It is the responsibility of Section Chiefs/first line supervisors to
      administer this program in close liaison with medical monitoring
      personnel.  Supervisors are required to provide both the appropriate
      training and respiratory protection employees need, at no cost to
      the employee.

      Employees shall use the respiratory protection provided in
      accordance with instructions and training received.  Each employee
      shall guard against damage to the respirator, and report any
      respirator malfunctions to the supervisor.

V.    Program Elements

      A.  The OSWER respiratory protection program meets all provisions of
          29 CFR 1910.134 and 29 CFR 1910.120.  In addition, it meets all
          EPA, OHSS's Occupational Health and Safety requirements and the
          OERR's, HRSD Standard Operating Safety Guides.
                                                           May 15, 1988
                                   20

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B.  Program Elements

    1.  Standard Operating Procedures.  This respiratory protection
        program shall function as the written standard operating
        procedures governing the selection and use of respiratory
        protection for OSWER personnel.

    2.  Respirator Fitting and Selection

        a.  The selection of the proper type of respiratory
            protection shall be based primarily on, but not limited
            to the:

            1)  Nature of the field activity;
            2)  Type of respiratory hazard;
            3)  Location of the hazardous area;
            4)  Period of time for which respiratory protection must
                be provided;
            5)  Employee's potential exposure;
            6)  Employee's activities;
            7)  Employee's physical characteristics and functional
                activities;
            8)  Limitations of the various types of respirators; and
            9)  Respirator protection factors/respirator fit.

        b.  Factors  concerning both the potential  and the measured
            hazard shall be considered when requiring the use of
            respiratory protection.  These factors shall  include,
            but not  be 1imited to:

            1)  Types of hazard;
            2)  Physical and chemical properties;
            3)  Physiological effects on the^body;
            4)  Expected concentration/level;
            5)  Established ACGIH TLV's, OSHA PEL'S,  AIHA WEEL's.
            6)  IDLH considerations; and
            7)  Agent warning properties.

        c.  U.S. EPA Environmental  Response Team's (ERT)  Air
            Monitoring Guidelines (FSOP 18) shall  be followed, when
            applicable, to Identify the type of respiratory hazards,
            define their nature and potential (i.e.,  vapor,
            particulate, etc.), and determine the  concentration in
            the work area.

        d.  Factors  concerning potential and actual site activities
            shall  be taken into account in selecting proper
            respiratory protection.  These factors include a
            description of work activities; description of the
            potential hazards; agents of health concern,  employee
            exposure potential and work activities.  The selected
            respirator protection must be continuously evaluated to
            reflect  changes in conditions or factors.
                                                     Hay 15, 1988

                                      21

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e.  The work activity location, with respect to a safe/clean
    area, shall be considered in selecting respirator
    protection.  Not only does this permit for a well
    identified contamination reduction zone, but also
    requires the presence of emergency access and exit
    areas.

f.  The period of time a respirator is to be worn shall be
    considered when selecting respiratory protection.

g.  Worker activities and locations during site activities
    shall be considered when selecting proper respiratory
    protection.

h.  The physical characteristics,  functional capabilities,
    and performance limitations of various types of
    respiratory protection shall  be considered when
    selecting a respirator.

i.  The hazards for which a  particular respirator is
    designed shall  be considered when selecting a
    respirator.

j.  A qualitative respirator fit test shall  be performed on
    each user to determine a satisfactory fit with negative
    pressure respirators.  Test results shall be used to
    select specific types, makes,  and models for individual
    workers.  All OSWER Category 1 and 2 employees will be
    fit tested at least annually.   Category 3 personnel will
    be fit tested before each respirator use after the
    initial  testing.  Fit testing  is not required for
    positive pressure respirators  (e.g., SCBA units).
    Individual workers shall be trained to qualitatively
    check respirator fit via the positive-negative pressure
    method each time a unit  is donned.  Whenever possible, a
    quantitative fit test shall  be incorporated.

k.  Respirators shall not be worn  when conditions prevent a
    good seal.  Employees shall  not wear respirator temple
    bars, straps, head coverings,  etc. between the sealing
    surface of the respirator.  Neither shall respirators be
    worn if facial  hair, features, etc., prevent a good fit.

1.  Respirator fit testing records shall be kept.  Records
    shall include type of fit-test method used, specific
    make and model  of respirator tested, name of worker
    tested,  name of test operator, date of test,  and results
    of fit testing.

m.  A variety of sizes of respirator facepieces shall be
    available to OSWER personnel  to accommodate the wide
    range of facial shapes and dimensions among personnel.
                      -17-
                                             May 15, 1988
                      22

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    n.  Employee preference for a particular respirator model
        shall be considered when selecting suitable respiratory
        protection.  This Includes such factors such as comfort,
        breathing resistance,  weight,  field of vision, etc.
        However, the preferred model  must have a satisfactory
        fit test.

    o.  Where feasible, respirators shall be individually
        assigned to workers for their exclusive use.  If a
        respirator is marked for identification purposes, the
        marking shall not affect the  respirator performance.

3.   Training and Education

    a.  Each respirator wearer shall  be given training that
        shall include explanations and discussions of
        respiratory hazards and misuse; the need for respiratory
        protection; the reason for selecting a particular
        respirator; the function,  capabilities,  and limitations
        of the selected respirator; the method for donning the
        respirator and checking its fit and operation; proper
        wearing instructions;  respirator maintenance;
        recognizing and handling emergencies; special
        instructions as required;  regulations concerning
        respirator use; and identification of respirator
        cartridges and canisters by color code.

    b.  The training shall  include a  hands-on portion that
        covers donning, wearing, and  removing the respirator;
        adjusting the respirator for  proper fit;  wearing the
        respirator in a safe atmosphere and in a  test
        atmosphere.

    c.  The Section Chief or designee  is responsible for
        purchasing, issuing, and training his/her personnel
        concerning any phase of respiratory protection.

    d.  Trainers, employees, and others associated with  the
        respiratory protection program shall  be  trained  to
        ensure the proper use  of respirators.  Training  shall
        include basic respiratory  protection  practices,  the
        nature and extent of expected  respiratory hazard
        exposure, principles and criteria for selecting
        respirators,  using  respirators and monitoring their use,
        maintenance and storage,  and regulations  governing
        respirator use.

    e.  Each respirator wearer shall be retrained and fit tested
        at least annually or as appropriate (e.g.,after  large
        changes in body weight,  dental  surgery, etc.)  when
        facial  size or shape significantly changes (see
        Paragraph V.B.2.J).
                                                May  15,  1988


                                     23

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4.  Cleaning and Disinfecting

    a.  Respirators shall  be regularly cleaned and disinfected.
        Those issued for the exclusive use of one worker should
        be cleaned after each day's use, or more often if
        necessary.  Those  used by more than one worker shall be
        thoroughly cleaned and disinfected after each use (e.g.,
        routine, non-routine, emergency, or rescue units).

5.  Equipment Storage

    a.  Respirators shall  be stored in a convenient, clean,  and
        sanitary location  so that they are protected against
        dust,  sunlight,  extreme temperature,  excessive moisture,
        or damaging chemicals.

    b.  Respirators shall  be stored to prevent distortion of
        rubber or other  elastomeric parts.  Respirators shall
        not be stored in such places as lockers and tool  boxes
        unless they are  adequately protected  from contamination,
        distortion, and  damage.  Consult the  "use and care"
        instructions,  usually mounted inside  the carrying case
        lid,  for proper  storage of emergency  respirators.

6.  Inspection and Repair

    a.  Each respirator  shall be inspected routinely before  and
        after each use.  A respirator shall be inspected  by  the
        user immediately before each use to ensure that it is in
        proper working condition.

    b.  After cleaning and sanitizing, each respirator shall be
        inspected to determine if it is in proper working
        condition, if it needs replacement parts or repairs, or
        if it should be  discarded.  Each respirator stored for
        emergency or rescue use shall  be inspected at least
        monthly and after  each use by an experienced person.
        Respirator inspection shall include a check for
        tightness of connections; for the conditions of the
        respiratory inlet  covering, head harness, valves,
        connecting tubes,  harness assembly, filter(s),
        cartridges, canister, end-of-service-life indicator, and
        shelf life date(s); and for the proper function of
        regulators, alarms, and other warning systems.

    c.  Each rubber or elastomeric part shall be inspected for
        pliability and signs of deterioration.  Each air  and
        oxygen cylinder  shall be inspected to ensure that it is
        fully charged according to the manufacturer's
        instructions.
                                                 May 15,  1988
                          24

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    d.  Only parts designed for a specific respirator shall be
        used in Us repair.  Do not replace components or make
        adjustments or repairs beyond the manufacturer's
        recommendations.  Reducing and admission valves or
        regulators shall be returned to the manufacturer or to a
        trained technician for adjustment or repair.

    e.  A record of inspection dates, findings, and remedial
        actions shall be kept for each SCBA respirator
        maintained for emergency or rescue use.

7.  Surveillance

    Appropriate surveillance or work area conditions and degree
    of employee exposure or stress shall  be maintained.

8.  Evaluation of Respiratory Protection  Program

    a.  There shall be periodic (at least annual) inspection and
        evaluation to determine the continued effectiveness of
        the respiratory protection program.  It is essential to
        ensure that all employees are provided with adequate
        protection.  The program should be improved and
        deficiencies should be eliminated based on evaluation
        results.

    b.  Respirator wearers shall  be consulted periodically about
        their acceptance of respirators.   Frequent Inspection of
        the program shall be conducted to ensure that proper
        types of respirators are selected, that users are
        properly trained, that appropriate equipment is Issued
        and used,  that respirators are worn properly, that
        respirators are in good operating condition, that
        respirators are inspected and maintained properly, that
        respiratory storage is acceptable, that respiratory
        hazards are monitored, and medical examinations are
        given as necessary, to evaluate user health.

    c.  The results of the inspection and evaluation shall be
        utilized to improve or maintain elements of the program
        as appropriate.  Follow up investigations shall  be
        conducted  to ensure that sources  of concerns are
        identified and corrected.  Evaluation findings shall be
        documented.  Plans to correct program concerns shall be
        documented (I.e., problem,  target dates, responsibility,
        etc.).

9.  Medical Approval

    a.  Each employee shall have a medical evaluation to
        determine  fitness to wear respiratory protection and
        potential  exposure.  Adequate medical  data shall  be
        provided as part of the preplacement examination and all
                                                 May 15, 1988

                                     25

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                   subsequent examinations to allow a physician to make a
                   judgement on each worker's fitness (Refer to Appendix B
                   of the Integrated Health and Safety Policy for Field
                   Activities for examination schedule).

               b.   Employees shall show the examining physician their
                   exposure records (e.g., Incident Safety Check-off Sheet
                   [See Appendix A of the Integrated Health and Safety
                   Policy for Field Activities]) since the last
                   examination.

          10.   Approved Respiratory Protection

               Only approved respiratory protection shall be selected when
               available.  Any modification of an approved respirator that
               is  not authorized by the approval agencies (e.g., MSHA and
               NIOSH) voids the respirator approval.

VI.    Air Quality

      A.   Compressed air, compressed oxygen,  liquid air, and liquid oxygen
          used for respiratory protection shall  be of high purity.
          Compressed air should be the principle source of breathing air.
          Compressed gaseous air shall meet at least the requirements for
          Type 1  - Grade D breathing air of Compress Gas Association
          Commodity Specification G-7.1-1966.

      B.   Breathing air should be supplied to respirators from cylinders.
          11  cylinders shall be tested for quality and maintained in
          accordance with applicable DOT specifications for shipping
          containers (Title 4-9, Code of Federal Regulations,  Parts 173
          and 178).

      C.   Breathing air containers shall be marked in accordance with ANSI
          Z48.1-1954 (R1971) or Interim Federal  Specification  GG-B-675b,
          September 23, 1976.
                                                           Hay 15, 1988
                                    26

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                                           Appendix E

                        OSWER  INTEGRATED  HEALTH AND  SAFETY WORKGROUP
                                       Rodney D. Turpin
                             Occupational Health and Safety Manager
                                    Environmental Response Team
                                       Edison, NO 08837
                               FTS:  340-6741 - COMM: 201 321-6741
  OCCUPATIONAL HEALTH AND SAFETY STAFF

         Sheldon Rabinovitz
   FTS: 382-3649 - MAIL CODE: PM 273F
         David Weitzman (Alt.)
   FTS: 382-3640 - MAIL CODE: PM 273F
  OFFICE OF WASTE PROGRAMS ENFORCEMENT

           Charlotte White
    FTS: 382-4846 - MAIL CODE: WH 527
               Rolf Hill (Alt.)
    FTS: 475-7037 - MAIL CODE: WH 527
             Steve Henne (Alt.)
    FTS: 475-7030 - MAIL CODE: WH 527
                                OSWER - ANALYSIS & EVALUATION STAFF

                                           Kate Connors
                                FTS: 382-6647 - MAIL CODE: WH 562A
                                           Jim Cruickshank
                                FTS: 475-4515 - MAIL CODE: WH 562A
                                     OSWER - PREPAREDNESS STAFF

                                         Elaine Davies
                                FTS: 475-8600 - MAIL CODE: WH 562A
FOFFICF OF EMERGENCY
ANH RFHFHTAI  RFSPQNSF
                                                     OFFICE OF UNDERGROUND STORAGE TANKS

                                                               John Heffel finger
                                                     FTS: 382-7950 - MAIL CODE: WH 565A
                                                           OFFICE OF SOLID WASTE

                                                                 Jim O'Leary
                                                     FTS: 382-4649 - MAIL CODE: WH562

                                                               Cynthia Folkerts
                                                     FTS: 382-7917 - MAIL CODE: WH 565A
     HAZARDOUS SITE CONTROL]
            DIVISION

          John J. Smith
      FTS: 382-7996
     MAIL CODE: WH 548E
        Nancy Willis (Alt.)
         FTS: 382-2347
      MAIL CODE: WH 548E
            EMERGENCY RESPONSE
                  DIVISION

              Victoria van Roden
              FTS: 382-2188
             MAIL CODE: WH 548B
    HAZARDOUS SITE EVALUATION
            DIVISION

         Robert Heffernan
FTS: 475-9748 - MAIL CODE:  WH548A
   Scott Fredericks (Alt.)
FTS: 382-2467 - MAIL CODE:  WH548A
             ENVIRONMENTAL RESPONSE
                      TEAM

             Vickie L. Santoro
             FTS: 340-6917
             MAIL CODE:  MS101
                                         27
                                      May 15,  1988

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                                 APPENDIX F

              EPA HEALTH AND SAFETY REQUIREMENTS AND GUIDELINE


1.  EPA Occupational Health and Safety Manual (1440)

    Chapter 1.   Policy  and Responsibilities
    Chapter 2.   Occupational Health and Safety Program
                 Administration
    Chapter 3.   Accident and Illness Investigation, Reporting,
                 and Recordkeeping Requirements
    Chapter 4.   Inspections and Correction of Unhealthful or
                 Unsafe  Working Conditions
    Chapter 5.   Occupational Health and Safety Committees
    Chapter 6.   Occupational Health and Safety Standards
    Chapter 7.   Occupational Health and Safety Training
    Chapter 8.   Laboratory Use of Toxic Substances
    Chapter 9.   Hazardous Substances Responses
    Chapter 10.  EPA Diving Safety Policy

2.  EPA Health and Safety Orders

    1440.2 - Field Activities
    1440.3 - Respiratory Protection
    1440.4 - Health and Safety Training Requirements for Mine
             Safety
    1440.5 - Qualifications and Training Requirements for
             Occupational Health and Safety Program Personnel
    1440.6 - Motor Vehicle Occupant Restraining Systems
    1440.7 - Hazard Communication

3.  Health and Safety Guidelines

    Respiratory  Protection Program Guideline
    Eye Protection Program Guidelines
    Occupational Safety and Health Guidance Manual for
    Hazardous Waste Site Activities
    Medical Monitoring  Program Guidelines
    Health and Safety Guidelines for EPA Asbestos Inspections
    Guidelines for the  Selection of Chemical Protective
    Clothing, Second Edition
                                                           May 15,  1988
                                28

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                                 APPENDIX G

  GENERAL DESCRIPTION OF THE OERR LEVELS OF PROTECTION AND PROTECTIVE GEAR


Personal protective equipment has been divided into four categories  based
on the degree of protection afforded and are as follows:

Level A  - To be selected when the greatest level of skin, respiratory,  and
eye protection is required.

Level A  equipment; used as appropriate:

1.   Pressure-demand, self-contained breathing apparatus, approved by the
     Mine Safety and Health Administration (MSHA) and National Institute
     of Occupational Safety and Health (NIOSH).

2.   Fully encapsulating chemical-resistant suit.

3.   Coveralls*

4.   Long Underwear*

5.   Gloves (outer) chemical-resistant

6.   Gloves (inner) chemical-resistant

7.   Boots, chemical-resistant,  steel toe and shank.   (Depending on  suit
     construction, worn over/or under suit boot.)

8.   Hard hat (under suit)*

9.   Disposable protective suit,  gloves, and boots (Depending on suit
     construction, may be worn over fully encapsulating suit boot.)

10.   Two-way radios (worn inside  encapsulating suit).
* Optional,  as appropriate
                                                           May 15,  1988
                                       29

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Level B - The highest level of respiratory protection is necessary but a
lesser level of skin protection is needed.
Level B equipment; used as appropriate:
1.   Pressure-demand, self-contained breathing apparatus (MSHA/NIOSH
     approved), or airline respirator.
2.   Hooded chemical-resistant clothing (overalls and long-sleeved jacket;
     coveralls; one or two-piece chemical-splash suit; disposable
     chemical-resistant overalls).
3.   Coveralls*
4.   Gloves (outer) chemical-resistant
5.   Gloves (inner) chemical-resistant
6.   Boots (outer), chemical-resistant, steel toe and shank.
7.   Boot covers (outer), chemical-resistant (disposable)*.
8.   Hard hat (face shield)*
9.   Two-way radios (worn inside encapsulating suit).
* Optional, as appropriate
                                                           May 15, 1988
                                   30

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 Level  C  -  The  concentration(s)  and type(s)  of airborne substance(s)  is
 known  and  the  criteria  for using air purifying respirators  are met.
 Level  C  equipment;  used as appropriate:
 1.   Full-face,  air purifying,  canister-equipped  respirators  (MSHA/NIOSH
     approved).
 2.   Hooded chemical-resistant  clothing  (overalls;  two-piece
     chemical-splash suit; disposable chemical-resistant overalls).
 3.   Coveralls*
 4.   Gloves (outer) chemical-resistant
 5.   Gloves (inner) chemical-resistant*
 6.   Boots (outer), chemical-resistant,  steel  toe and  shank*.
 7.   Boot  covers  (outer), chemical-resistant  (disposable)*.
 8.   Hard  hat  (face shield)*
 9.   Escape Mask *
 10.  Two-way radios (worn under outside protective  clothing).
* Optional, as appropriate
                                                           May 15, 1988
                                       31

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Level D  - A work uniform.
Level D  equipment; used as appropriate:
1.   Coveralls
2.   Gloves*
3.   Boots/shoes, leather or chemical-resistant, steel toe and shank.
4.   Boots (outer), chemical-resistant (disposable)*.
5.   Safety glasses or chemical splash goggles*
6.   Hard hat (face shield)*
7.   Escape Mask*
* Optional, as appropriate
                                                           May 15, 1988
                                32

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                     SECTION 2

               OCCUPATIONAL SAFETY
                       AND
            HEALTH GUIDANCE DOCUMENTS

                      PART 2

        US EPA ENVIRONMENTAL RESPONSE TEAM'S
OCCUPATIONAL MEDICAL MONITORING PROGRAM GUIDELINES
 FOR SARA HAZARDOUS WASTE FIELD ACTIVITY PERSONNEL
                        33

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                                                  Publication 92853-04
                         U.S. EPA




           ENVIRONMENTAL RESPONSE TEAM'S




    OCCUPATIONAL MEDICAL MONITORING PROGRAM




                       GUIDELINES




FOR SARA HAZARDOUS WASTE FIELD ACTIVITY PERSONNEL



                         January 1990
                Office of Solid Waste and Emergency Response




                 Office of Emergency and Remedial Response




                     Emergency Response Division
                                  35

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                                 ABSTRACT
PURPOSE:  The purpose of this document is to suggest guidelines covering
the requirements for a comprehensive occupational medical monitoring
program for those personnel  involved in SARA hazardous waste field
activity.

BACKGROUND:  Occupational  medical  monitoring is  the surveillance of the
health status of selected  employees by means of  periodic examinations.
Occupational medical monitoring assists in the early detection and
prevention of adverse effects from occupational  exposure to hazardous
agents and physical  stress.   Specifically, such  a program would provide:

o   Early recognition of effects from unsuspected hazards;
o   Evaluation of health status with respect to  work assignments;
o   Indication of effectiveness of protective measures taken for known
    hazards;
o   Data for studies of the  longterm subtle effects of occupational
    exposures;
o   Assurance from a physician that employees are physically able to work
    under unique physical  stresses, such as wearing respirators.

APPLICABILITY:  It is EPA's  policy that a program of medical surveillance
must be instituted for each  employee exposed to  potentially hazardous
working conditions (i.e.,  SARA hazardous waste field activity).
Furthermore, the Agency's  Occupational Medical Monitoring Program must
accommodate changes  associated with variation in working conditions,
advances in the practice of  occupational medicine, current health and
safety standards and regulations,  and changes indicated by findings from
medical examinations.
                                                         January  10,  1990

                                 36

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                                  CONTENTS


1.0  PURPOSE                                                           1

2.0  GENERAL REQUIREMENTS                                              1

     2.1  PHYSICIAN REQUIREMENTS                                       1
     2.2  PRIVACY ACT                                                  1
     2.3  MEDICAL HISTORY                                              1
     2.4  NATURE OF EXAMINATION
     2.5  MINIMUM EXAMINATION TYPES AND CONTENTS                       1

3.0  BASELINE                                                          1

4.0  PERIODIC EXAMINATION                                              2

5.0  UNSCHEDULED EXAMINATION                                           2

     5.1  TIMING OF EPISODIC EXAMINATION                               2

6.0  TERMINATION EXAMINATION                                           2

7.0  REPORTING REQUIREMENTS                                            2

     7.1  EMPLOYEE COPY                                                2
     7.2  NON-OCCUPATIONALLY-RELATED SYMPTOM REPORTING
          (TO EMPLOYEE)                                                2
     7.3  OCCUPATIONALLY-RELATED SYMPTOM REPORTING
          (OCCUPATIONAL MEDICAL MONITORING COORDINATOR)                2
     7.4  WRITTEN CLEARANCE FOR JOB CONDITIONS                         3

8.0  SPECIAL REQUIREMENTS                                              3

     8.1  IMMUNIZATIONS                                                3
     8.2  RESEARCH TESTS                                               3
     8.3  REPRODUCTIVE HAZARDS                                         3

9.0  RELATIONSHIP BETWEEN OCCUPATIONAL MEDICAL MONITORING
     AND WORKERS' COMPENSATION                                         3

APPENDIX A   TABLE OF MINIMUM EXAMINATION TYPES AND CONTENTS         A-l

APPENDIX B   GUIDELINES FOR IMMUNIZATION REQUIREMENTS                B-l

REFERENCES                                                            iv
                                                        January 10,  1990
                                     37

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                                 REFERENCES

1.  Title 5, United States Code, Sections  7901 and 7902.

2.  Executive Order 12196, Occupational Safety and Health Programs for
    Federal Employees.

3.  29 CFR 1960, Basic Program Elements for Federal Employee Occupational
    Safety and Health, Occupational Safety and Health Administration
    (OSHA), Department of Labor.

4.  0PM, Federal Personnel Manual, Chapter 339, Medical Examinations for
    Appointment.

5.  0PM, Federal Personnel Manual, letter  293-20.

6.  EPA, Occupational  Health and Safety Manual, Chapter 8, Laboratory Use
    of Toxic Substances.

7.  EPA, Order 1440.2, Health and Safety Requirements for Employees
    Engaged in Field Activities.

8.  EPA, Order 1440.3, Respiratory Protection.

9.  EPA, Occupational  Medical Monitoring Guidelines.

10. 29 CFR 1910.20, General Industry Standards, OSHA, Department of Labor.

11. 29 CFR 1910.20, General Industry Standards, OSHA, Department of Labor.
                                                          January 10,  1990


                                  38

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1.0  PURPOSE

     The purpose of this document is to suggest guidelines covering the
     requirements for an occupational  medical  monitoring program for those
     personnel involved in SARA hazardous waste field activity.

2.0  GENERAL REQUIREMENTS

     2.1  All occupational medical  monitoring  examinations and procedures
          must be performed by or under the supervision of a licensed
          physician.  The physician chosen should be experienced and/or
          board certified in occupational medicine.  If a specialist in
          occupational medicine is  not available, a local physician should
          be chosen who is equipped to conduct thorough physical
          examinations and who is familiar with, or is willing to become
          familiar with the Agency's programs  and the hazards to which its
          employees could potentially be exposed.  All examinations must
          be handled through the medical provider, and employees may not
          substitute an examination by his/her personal physician.

     2.2  All federal employees participating  in the occupational medical
          monitoring program must read and sign a copy of the Privacy Act
          Statement.  The original  form must be filed with the employee's
          official occupational medical monitoring records, and a copy
          should be provided to the employee.

     2.3  Each employee who is required to have an examination or medical
          certificate before assignment, should complete a medical history
          form and give the form to the physician at the time of the
          examination.

     2.3  The nature and extent of  the medical examinations must be based
          on the individual's potential for exposure.

     2.4  Each employee is required to have baseline, periodic,
          termination, and unscheduled examinations.  Each of these
          examinations is briefly described below.  Complete descriptions
          of each type of examination are identified in Appendix A.

3.0  BASELINE

     The baseline or preemployment/preplacement medical examination is
     given to ensure that employees are physically able to perform the
     duties of their intended positions without danger to themselves
     and/or others.  This examination is a comprehensive medical
     evaluation intended to provide reference  information for the
     evaluation of subsequent examination findings.  These examinations
     are a condition of employment  for otherwise acceptable applicants for
     positions that require such an examination, or which require a
     medical certificate before assignment.
                                                         January 10, 1990


                                    39

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4.0  PERIODIC EXAMINATION

     Periodic examinations are regularly scheduled examinations to
     identify physical  changes or illnesses thereby ensuring that prompt
     treatment and remedial  actions can be taken.  The interval or
     frequency of these examinations must be based on recommendations made
     by the Employer's  Occupational Medical Monitoring Coordinator.

5.0  UNSCHEDULED EXAMINATION

     Unscheduled examinations are conducted to determine adverse health
     effects of exposure to specific significant hazards or stresses, or
     where results of a periodic, baseline or exit examination have
     indicated an actual or potential health problem.

     5.1  An episodic examination should be given whenever there is a
          direct question about an employee's continued capacity to meet
          the physical  or medical requirements of the position (i.e.,
          employee's direct exposure to hazardous materials).

6.0  TERMINATION EXAMINATION

     A termination examination can be the same comprehensive examination
     as the baseline or preemployment/preplacement examination.  This
     examination documents the health status of the employee at the end of
     employment and provides information on any changes that have occurred
     during the employment period.

7.0  REPORTING REQUIREMENTS

     Any physician or medical facility that conducts a medical examination
     should be required to meet the following criteria:

     7.1  After each examination, furnish the employee with a written,
          nontechnical  evaluation report of examination findings, and a
          statement of the employee's fitness for the position.  The
          employee should be provided with the opportunity to discuss the
          results with the examining physician.

     7.2  Advise the employee of abnormal test results that are felt to be
          the results of non-occupationally-related causes so  that the
          employee may contact his/her private physician for follow-up.

     7.3  Notify the employee first, and second, notify the Occupational
          Medical Monitoring Coordinator, of abnormal occupational -
          related findings so that any follow-up examinations  or treatment
          can be scheduled, or so that remedial  actions can be taken in
          the employee's workplace.
                                                          January  10,  1990


                                   40

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          (The Medical Monitoring Coordinator should notify the employee's
          supervisor and/or the Director,  Occupational Health and Safety
          Staff, of abnormal test results  within 48 hours of receipt of a
          report of occupational-related positive findings.  This notice
          should be general in nature to protect the employee's
          Confidentiality Rights.)

     7.4  Furnish the employee with a written statement that his/her
          health and physical  condition are satisfactory to wear
          respiratory protective devices.

8.0  SPECIAL REQUIREMENTS

     8.1  Immunizations.  The special situations where immunizations are
          recommended are outlined in the  U.S. EPA Occupational Medical
          Monitoring Guidelines, Washington D.C.  See Appendix B for
          general information regarding immunizations.

     8.2  Research Tests.  Research tests  for the purpose of investigation
          or experimentation aimed at the  discovery and interpretation of
          medical facts, revision of accepted theories in the light of new
          facts, or practical  application  of such new or revised theories
          are not recommended as a part of the occupational medical
          monitoring program because of their limited clinical value.

     8.3  Reproductive Hazards.  Extreme caution must be exercised to
          ensure that employees are not exposed to harmful quantities of
          classified or unclassified substances that are known or
          suspected of affecting reproduction in both males and females.

          As part of a hazardous substances communication, employees are
          to be informed of the threat to  human reproduction by chemicals
          in the workplace.  Employees (both male and female) who can
          potentially be exposed to chemicals that effect reproduction,
          such as teratogens,  mutagens, and chemicals that alter
          fertility, have the right to request a temporary change in job
          assignment as needed to allow conception or to protect an unborn
          child.  Each request should be handled on an individual basis
          and each supervisor should have  the responsibility to assess the
          reproductive hazards associated  with the job and to make
          reasonable accommodations of equal professional status.

8.0  RELATIONSHIP BETWEEN OCCUPATIONAL MEDICAL MONITORING AND WORKERS'
     COMPENSATION

     The intent of the Occupational Medical Monitoring Program is to
     detect the deleterious consequences of occupational exposure to
     hazardous substances or conditions, or harmful physical agents.  Once
     such a possibility is detected, the employee may file a claim for
     worker's compensation.  The federal employee's medical expenses from
     that point are covered by the Office  of Worker's Compensation (OWCP),
     U.S. Department of Labor.  If the claim is disallowed by OWCP, the
     employee may use his/her medical coverage to pay the costs.
                                                         January 10, 1990


                                      41

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                 APPENDIX A  -  MINIMUM  EXAMINATION TYPES AND CONTENT


                                     BASELINE  PERIODIC   TERMINATION   UNSCHEDULED

History and Physical Exam

Complete Medical History                X                      XX
Interval History                                  X
Physical Examination by Physician       XXX             X
Visual Acuity                           XXX             0

Routine Laboratory Tests/Procedures

Pulmonary Function                      XXX             0
Audiometry                              XXX             0
Electrocardiogram                       X         0            X             0
Chest x-ray                             X         0            X             0
Complete Blood Count                    XXX             0
Routine Urinalysis                      XXX             0
Blood Chemistry                         XXX             0

Special Tests*

Cholinesterase                          X         0            0             0
Methemoglobin                           000             0
Heavy Metal Screen                      X         0            0             0
Urine and Sputum Cytology               000             0
Polychlorinated Biphenyl (PCB)          000             0
Cardiovascular Stress Test              X         0            -

X - Recommended
0 - As indicated
* Any special test which may be considered on  a  periodic basis should be included
  in the baseline test.


                                                          January 10,  1990


                                          42

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What are the basic laboratory tests to be included for each participant
for the baseline,  periodic,  and termination examinations?

A.  Blood Tests

    Each individual should receive a basic panel  of blood counts and
    chemistries to evaluate blood-forming organs, kidney, liver, and
    endocrine/metabolic function.   The following  blood tests are
    considered to be the minimum desirable:

                                          o            White blood cell
                                                       count and
                                                       differential cell
                                                       count

                                          o            Hemoglobin and/or
                                                       hematocrit

                                          o            Albumin, globulin,
                                                       and total protein

                                          o            Serum glutamic
                                                       oxalacetic
                                                       transaminase (SGOT)

                                          o            Lactic
                                                       dehydrogenase (LDH)

                                          o            Alkaline
                                                       phosphatase
B.  Urinalysis
                                          o

                                          o

                                          o

                                          o

                                          o

                                          o
Calcium

Phosphorus

Uric acid

Creatinine

Urea nitrogen

Cholesterol

Glucose
    Each employee should have a routine urinalysis that consists of the
    following:
                                          o

                                          o
Specific gravity

PH
                                                         January 10,  1990
                                    43

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                                          o            Microscopic
                                                       examination

                                          o            Protein

                                          o            Acetone

                                          o            Glucose

For further information in determining the content of medical examination
with regard to specific hazardous materials, refer to Chapter Five of the
NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance.
                                                          January 10,  1990


                                  44

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               APPENDIX  B -  GUIDELINES FOR IMMUNIZATION  REQUIREMENTS
Immunization of adult  employees  is rarely required after  the  18th  birthday.

Hepatitis Vaccine -  Pre-exposure prophylaxis (Hepatitis A -  ISG)  for personnel  in
close contact with newly imported primates is recommended every four months.
Emphasis should be also be placed on other measures such  as  scrupulous hygiene
practices,  use of protective clothing and the limiting  of human contact with
animals.

Tetanus prophylaxis  -  Should be  the responsibility of the examining physician
when an employee is  wounded.  Managing of the wounded employee should be based  in
the history of previous tetanus  vaccinations and the condition of the wound.

Poliomyelitis vaccine  - Routine  primary polio vaccination of adults (those past
the 18th birthday) residing in the United States is not necessary.  Most adults
are already immune and have a very small risk of exposure to poliomyelitis.
Those at increased risks such as laboratory workers handling specimens which may
contain the polioviruses should  receive the vaccine as adults.  Unvaccinated
adults and incompletely immunized adults (at increased risks) should be given a
full course.

Rabies prophylaxis - Local and state public health officials should be consulted
if questions arise about the need for prophylaxis.
Plague vaccine - (Infection of humans resulting from exposure to wild
rodents/their fleas occurring mostly in the western part of the United States.)
Routine bacteriologic precautions are sufficient to prevent accidental infection
with plague.

Guidelines for Female Field Investigators

Female employees of child-bearing age should not be exposed to large quantities
of unclassified chemicals.  Since the teratogenic effect of some chemical
exposures on the unborn fetus is not known, extreme caution should be exercised
in said situation.  Reassignment of the female should be made to nonhazardous
duties as soon as pregnancy is diagnosed.
*  CDC Monograph, September, 1980.
                                                          December  6,  1988
                                      45

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         SECTION 3
QUICK REFERENCE FACT SHEETS

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                     QUICK REFERENCE FACT SHEETS
SECTION OBJECTIVE

The objective of this section is to provide students with a copy of the following U.S. Environmental
Protection Agency Environmental Response Team (USEPA-ERT) Health and Safety Quick Reference
Fact Sheets:

       •      Publication 9285.1-02:             Health and Safety Roles and Responsibilities at
                                             Remedial Sites

       •      Publication 9285.2-06FS:          Establishing  Work  Zones at Uncontrolled
                                             Hazardous Waste Sites

       •      Publication 9285.2-07FS:          Hazardous Waste Operations and Emergency
                                             Response:  RCRA  TSD   and  Emergency
                                             Response Without Regard to Location

       •      Publication 9285.2-08FS:          Hazardous Waste Operations and Emergency
                                             Response:  Uncontrolled  Hazardous  Waste
                                             Sites and RCRA Corrective Actions

       •      Publication 9285.2-09FS:          Hazardous Waste Operations and Emergency
                                             Response:   General  Information   and
                                             Comparison

       •      Publication 9285.2-10FS:          Hazardous Waste Operations and Emergency
                                             Response: Available Guidance
STUDENT PERFORMANCE OBJECTIVES

After completing this section and related lesson(s), the student will be able to:

       •      Understand the historical development of hazardous waste and emergency response
             worker protection standards.

       •      Identify key occupational health and safety standards and guidance documents.

       •      Identify to whom and to what operations OSHA 29 CFR 1910.120 applies, and the
             major legal requirements under paragraphs (a) through (q) in 1910.120.

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                 SECTION 3

        QUICK REFERENCE FACT SHEETS

                  PARTI

HEALTH AND SAFETY ROLES AND RESPONSIBILITIES
             AT REMEDIAL SITES

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                     United States
                     Environmental Protection
                     Agency
Office of
Solid Waste and
Emergency Response
Publication
  9285.1-02
  July 1991
        EPA      HEALTH  AND  SAFETY  ROLES
                       AND RESPONSIBILITIES  AT
                       REMEDIAL  SITES
  Office of Emergency and Remedial Response
  Hazardous Stte Control Division OS - 220W
                       Quick Reference Fact Sheet
 Additional fact sheets which address health and safety at Superfund sites have been compiled by the
 Environmental Response Team (ERT). The ERT Fact Sheets are listed in the Bibliography on page 6.
 INTRODUCTION
     The complex inter-relationships between the many
parties involved in remedial activities make it difficult to
administer the health and safety program. To implement an
effective, well coordinated program all participants must be
made aware of the health and safety roles and
responsibilities of all parties involved in site remediation.

     The purpose of this fact sheet is to define the major
components of the health and safety program and to
delineate the health and safety roles and responsibilities for
Remedial Project Managers (RPM), lead parties/agencies,
and contractors during the remedial action phase of Super-
fund clean-ups. It addresses the various roles of all parties
in the overall health and safety program for a site, with
emphasis on Occupational Safety and Health Act/Agency
(OSHA) compliance. More detailed health and safety
guidance documents are available through the Environ-
mental Protection Agency's (EPA's) Environmental
Response Team (ERT), Edison, NJ, (908) 321-6740 and
OSHA.
OCCUPATIONAL HEALTH &
SAFETY OVERVIEW
     All governmental agencies and private employers are
directly responsible for the health and safety of their
 mployees. This general rule applies to the many parties
involved in the hazardous waste clean-up at Superfund sites
(i.e. OSHA citations to abate unsafe or unhealthful working
conditions would be written to the party whose employees
are at risk).
     OSHA requires that a written (site-specific) occupa-
 tional safety and health program, that includes a safety and
 health plan, be in place for remedial activities at all Super-
 fund sites. EPA, OSHA, and the U.S. Army Corps of
 Engineers (USAGE) often use different terminology to
 describe written safety and health programs and plans. EPA
 uses the term Health and Safety Plan (HASP), OSHA uses
 Safety and Health Program and/or Plan, while USAGE uses
 the term Site Safety and Health Plan (SSHP). In this
 document the term HASP is used. The objective of the
 HASP is to protect workers through the identification,
 evaluation, and control of health and safety hazards and to
 provide for emergency response contingency planning.

     The party responsible for the HASP should be
 identified in the work plan. It is usually developed and
 implemented by the prime contractor's site coordinator, and
 reviewed and accepted by the construction manager for
 Fund-Lead projects and by the RPM and oversight official
 for enforcement lead projects. The construction manager is
 usually USAGE, the U. S. Bureau of Reclamation (USER),
 or an Alternative Remedial Contracting Strategy (ARCS)
 contractor. Accepted means the HASP  has been reviewed
 by the construction manager/oversight official and any
 deficiencies have been identified and corrected prior to the
 start of work. OSHA requires the HASP to be developed
 and implemented before work begins at the site.

     The HASP shall include a written statement delineat-
 ing the responsibilities, authority, and accountability of the
 various parties involved in the remedial action. A goal of
 the HASP is to facilitate coordination and communication of

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health and safety issues among personnel responsible for
the various activities. The HASP is mandated by OSHA
and/or the construction contract as the legally enforceable
plan for the job site. The prime contractor is usually re-
sponsible for review and approval (after acceptance by the
RPM and construction manager) of subcontractor health
and safety programs. The HASP will be incorporated into
each subcontractor health and safety program.

      The EPA must be provided an original and a copy of
all changes to the HASP prior to implementation, as they
may affect public health, the environment, overall cost,
scheduling, or technical quality of a project It is an RPM's
responsibility to insure that all Federal safety and health re-
quirements are met at a site, however the construction
manager, not the RPM, accepts and enforces changes to the
HASP.

      Specific topics/statements in the HASP include:

  Training
      The HASP shall specify that a training plan comply-
ing with OSHA training requirements outlined in 29 CFR
1910.120 (e) and the Hazard Communication Standard, 29
CFR 1926.59 for construction, will be implemented (it is
usually the prime contractor's responsibility). OSHA
requires both on-site and off-site training for workers at RA
sites. Increased OSHA enforcement of the training require-
ments of these standards is likely at RA sites as exemplified
by recent OSHA  enforcement actions. For specific require-
ments, consult the sources of information listed at the end
of this fact sheet.

      The requirements for off-site training are a function
of both the potential for exposure and management respon-
sibility. Information pertaining to off-site (initial) training
is available through a number of sources including courses
offered by ERT, USAGE (Huntsville Division) and
through the National Clearinghouse on Occupational and
Environmental Health (funded by a National Institute of
Environmental Health Sciences Grant). Additional sources
of information are listed at the end of this fact sheet.

      EPA employees who have not had the 40-hours
training are not permitted to enter areas where occupational
exposures above  established limits are likely. The use of
respirators implies that exposures are likely. Exceptions
are strongly discouraged, but can be made on a case-by-
case basis with the approval of the site safety and health
officer if respirators are NOT required, lime on site is
limited, and visitors are given a pre-entry site briefing and
accompanied by trained personnel at all times.

      On-site construction managers normally are required
to have completed a 40 hour off-site course. For those con-
struction managers who have on-site supervisory responsi-
bilities, an additional 8-hour supervisory training is
required.  An 8-hour annual refresher training is required
for all site workers.  Training requirements for entry to sites
where occupational exposures above established limits are
likely, or where respirators or other personal protective
equipment are required are described in the ERT Fact
Sheets listed at the end of this publication.

      On-site training must be tailored to the conditions of
individual sites.  At RA sites, construction managers,
RPMs, and authorized visitors must receive on-site training
prior to  entering restricted areas.

  Logistics and Resources
      The HASP should specify that the party  responsible
for health and safety plan implementation (i.e.the prime
contractor) will provide for logistics and resources, such as
qualified health and safety managers to meet plan tasks and
objectives.

  The  Site-Specific HASP
      OSHA, 29 CFR 1910.120 (b), requires that a site
HASP be developed and reviewed by qualified personnel
for each remedial action.  Subcontractors can modify the
plan to account for their own work. However, their plan or
modifications shall be formally incorporated into the
general  site plan. Only one HASP is applicable  to a
particular site. It must be kept on site and shall be made
available for review by employees,  emergency response
personnel, or, if applicable, employee representatives.

        The plan should not be generic, but should be
based on specific site characterizations, anticipated hazards
and expected work conditions at the site. OSHA requires
the plan address the following elements:
    (1) A safety and health risk or hazard analysis for each
        site task and operation found in the workplan.
    (2) Employee training.

    (3) Personal protective equipment for each task or
        operation.

    (4) Medical surveillance.

    (5) Frequency and types of air monitoring, personal
        monitoring, environmental sampling techniques,
        instrumentation, and methods to be used.

    (6) Site control measures.

    (7) Decontamination procedures.

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    (8) An Emergency Response Plan.

    (9) Confined Space entry procedures

    (10) A spill containment program.


  Emergency Response
       Most sites are too small to warrant fully staffed on-
site medical and fire fighting facilities. Where services can
be provided by surrounding communities, EPA may
provide limited training and  support to compensate for
OSHA requirements specific to hazardous waste response
training and support on a case-by-case basis. The amount
of training and support that local fire fighting and emer-
gency response personnel will require for OSHA compli-
ance (Paragraph (q) of the Worker Protection Standard if
off-site responders) depends on site-specific conditions and
on Response Tasks (i.e. off-site training duration can vary
between 24 and 40 hours). Examples of the types of
support that may be provided by EPA to local responders
on a case-by-case basis include off and on-site training, no-
cost personal  protective equipment and specialized haz-mat
equipment loans, medical surveillance, and reimbursement
of response funds.

     As a minimum, the emergency response plan should
be a separate section of the site HASP. The designer (for
design operations involving site entry) and the party
responsible for the  remedial  action health and safety plan
(usually the prime contractor) have the responsibility to
arrange for emergency response support and written
agreements prior to commencement  of operations involving
site entry. This will entail an evaluation of the capabilities
of local fire departments, hospitals, police departments, etc.
to provide coordinated and integrated services to the RD
and RA. Selection  of the provider should be based on an
evaluation of current capabilities, required support levels,
response lime, jurisdictional  authority, and cost to the
Government.  This  information is often available from
information obtained during  pre-design activities. Because
failure to secure agreements  can result in remedial project
delays or work stoppage, it is important for the RPM to
address emergency response in pre-design work plans, etc.
and solicit early involvement with community relations
staff in the process.

     The site safety officer (or equivalent position) should
make a copy of the HASP (to include the emergency
response plan) available, and provide on-site training for
local fire fighting and emergency response personnel
subject to respond to calls at  Superfund RA sites.
  Health and Safety Plan Improvements
      Feedback or communications from safety meetings,
training and inspections should be openly encouraged so
that the HASP can be adjusted and improved. EPA strongly
endorses an open communication policy in which all health
and safety inquiries receive a prompt, professional re-
sponse. The HASP should outline procedures for response
to health and safety inquiries and for modifications.  Con-
sistent with the OSHA worker protection standard, on-
going inspections and/or monitoring will, at times, require
changes to the HASP.  Modifications should be drafted by
professional staff (i.e. the prime contractor's industrial
hygienist) and approved by the construction manager.


INSPECTIONS
      Health and safety program oversight is an RPM
responsibility, however, the RPM is not required to conduct
health and safety inspections. Inspections for enforcement
purposes are the responsibility of OSHA. If inspections
uncover conditions that may adversely affect public (or
worker) health and/or the environment-, the overall cost,
scheduling, or technical quality of the project, then prompt
lead party and RPM notification is necessary. For RA
projects the construction manager or oversight official is re-
sponsible for enforcing the terms of the contract or settle-
ment agreement to include the issuance of stop work orders
in situations where the health and safety provisions of the
contract are violated.

  Employee Representatives
      A worker representative (if applicable, the Union
health and safety representative) should be given the oppor-
tunity to accompany the inspector during non-OSHA health
and safety inspections or evaluations. For OSHA inspec-
tions, the worker representative has the right to accompany
the inspector.  In situations where more than one union
represents workers at the site being inspected, the inspect-
ing official should select a health and safely representative
for  each area being inspected. The selection  and participa-
tion of the employee health and safely representative during
inspections and evaluations should be addressed in the
HASP.

  Imminent Danger
      Whenever, and as soon as the RPM (or any other
party) is made aware of a  danger which could reasonably be
expected to cause death or serious physical harm, thai
person has the responsibility to IMMEDIATELY notify the
affected employees, and parties with ihe responsibility and
authority to remove the danger. In situations where an
imminent danger exists, both the prime contractor's site
coordinator and the construction manager's on-site repre-
sentative (or equivalent) have the responsibility and

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authority to stop all activities or withdraw employees. The
RPM does NOT shut down or remove personnel from
unsafe operations, but recommends action for decisions by
lead agency officials. If steps are not taken to remove the
danger, OSHA shall be consulted.

  Other Unsafe or Unhealthful Working
  Conditions
     For Federal-lead RA projects, health and safety
inquiries should be channeled through the construction
manager, who has the responsibility to notify the site
coordinator verbally and in writing of the unsafe or
unhealthful condition. For other than Federal-lead
projects, the RPM should notify the site coordinator (or
responsible party) verbally and in writing of unsafe or un-
healthful working conditions. IF NOT SATISFIED
WITH THE CORRECTIVE ACTION TAKEN, THE
RPM SHOULD CONSULT WITH THE REGIONAL
SAFETY AND HEALTH OFFICER, THE ENVIRON-
MENTAL RESPONSE TEAM (ERT) ((908) 321-6740)
OR THE HEADQUARTERS HAZARDOUS  SITE
CONTROL DIVISION (HSCD) ((703) 308-8393) PRIOR
TO SEEKING INTERVENTION FROM OSHA.


OSHA  STANDARDS
     OSHA Standards are found in Tide 29 of the Code
of Federal regulations (29 CFR). Two pans must be
followed during remediation activities: Part 1910,
General Industry Standards and Part 1926, Construction
Standards. The interpretation as to which parts of Title 29
apply to a particular activity is often complex. EPA Stan-
dard Operating Safety Guides (and USACE regulations for
USAGE managed projects) supplement OSHA regulations.
If a conflict arises, the more protective standard should be
applied to a particular operation.

  Worker  Protection
      OSHA's Worker Protection Standard for Hazardous
Waste Operations and Emergency Response, 29 CFR
1910.120, will have the most applicability to remediation
activities.  Guidance on interpretation of the Standard can
be found in ERT Fact Sheets. Compliance with the
standard should be addressed in the preliminary assess-
ment/site inspection stage, during the remedial investiga-
tion/feasibility study stage, and through the remedial
design and remedial action.  The delineation of a site into
work zones where the worker protection standard applies
should be addressed in the remedial design site HASP. In
situations where competent health and safety professionals
lack sufficient information to conclude that occupational
exposure will be well within limits considered acceptable,
a protective interpretation of the standard is recommended
(However, overprotection, as well as underprotection can
be hazardous and should be avoided wherever possible).
                                               6
  Hazard Communication
     The OSHA hazard communication standard(s), 29
CFR 1926.59 for construction and 1910.1200 for general
industry, require that all hazardous chemicals on a site be
identified.  Every potentially exposed worker must be
given hazard communication training at the time of initial
work assignment and each time a new hazard is intro-
duced into a work area. Material Safety Data Sheets
(MSDS) must be available for all hazardous materials
brought onto the site except hazardous wastes, as defined
by the Resource Conservation and Recovery Act (RCRA),
which are exempt  Training centers around information
contained in the MSDS. Similar requirements are con-
tained in the worker protection standard, 29 CFR
1910.120, which requires a worker risk assessment for
hazardous  materials found on-site. Problem areas com-
monly encountered include the lack of access to and the
quality  of information in Material Safety Data Sheets
(MSDS).


ROLES AND RESPONSIBILITIES
     The basic health and safety responsibilities of the
various parties  involved in the RD and RA phases of work
at Superfund sites follow:

  Remedial  Design
     The remedial design contractor is  responsible for the
development and implementation of a HASP for all on-
site RD activities; for the development of specifications
for the  remedial action site health and safety plan; and for
the description  of minimum requirements for health,
safety,  and emergency response. The following should be
specified in the final design:

    1.   An estimate of increased hazards (over back-
        ground).

    2.   The degree of existing hazard based on contami-
        nation identified in the site characterization
        report, on the Agency for Toxic Substances and
        Disease Registry (ATSDR) Health Assessment,
        and on the short term effects component of the
        feasibility study.
     3. Minimal acceptable standards  for
        -Worker protection
        -The general public
        -Monitoring, reporting and interpretation (what
        constitutes acceptable concentration)
        -Emergency response and evacuation
        -Site control; decontamination of personnel and
        equipment; clean-up procedures

     During the design phase, it is the  responsibility of
 the designer to establish site boundaries where 29 CFR

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1910.120 applies and to describe criteria utilized in such
determinations. These boundaries should be reviewed and
approved by a qualified health and safely professional
such as a certified industrial hygienist, certified health
physicist, etc.

Remedial Action
OSHA, or its State counterpart, has Occupational
Safety and Health Act enforcement authority at RA sites.
In addition to complying with Federal standards, the prime
contractor must also comply with contractual health and
safety policies and guidelines from EPA. For Alternative
Remedial Contract Strategy (ARCS), the U.S. Army Corps
of Engineers (USAGE), and the U.S. Bureau of Reclama-
tion (BUREC) managed projects, health and safety
enforcement responsibilities under the contract are dele-
gated to the construction manager's resident inspector (or
equivalent position). For State lead projects these respon-
sibilities are delegated to the State's on-site official; and
for Potentially Responsible Party (PRP) projects, health
and safety enforcement is the responsibility of EPA 's
oversight official. The resident inspector must be
certified to be on site (i.e. have a medical examination,
training, experience, etc.), conduct health and safety
inspections and evaluations of contractor compliance with
the health and safety contract provisions, and possess a
complete understanding of the contract




















Implementation of the health and safety program is
the responsibility of the prime contractor. The State's on-
site official or the PRP oversight official is responsible for
health and safety during the implementation of the operation
and maintenance phase.
HEALTH & SAFETY PROGRAM
OVERSIGHT

RPM Responsibilities
As the EPA's prime contact or representative for a
site, it is important for the RPM to be a strong health and
safety advocate. The RPM has the responsibility to coordi-
nate, direct, and review the work of EPA contractors
responsible parties and other agencies to assure compliance
with the National Contingency Plan. As such the RPM
oversees compliance with occupational health and safety
programs. The RPM normally does not have direct line
authority over the RA prime contractor but recommends
action through the lead agency or PRPs. The RPM will be
informed of situations where health and safety issues impact
overall project cost, scheduling, technical quality or public
health/environmental protection. However, the RPM's
primary responsibility is oversight, not action. Items
requiring action should be referred to the appropriate indi-
viduals or agencies (Prime contractor, USAGE, BUREC,
ARCS, Responsible Party, the State, or OSHA).
SOURCES OF INFORMATION

For questions about OSHA regulations or EPA/
OSHA relationships, how to contact Regional or Federal
OSHA representatives, and/or HASP computer software
package, contact:


Rod Turpin
USEPA Environmental Response Team
2890 Woodbridge Avenue
Building 18 (MS- 101)
Edison, NJ 08837-3679
(908) 321-6740 or FTS 340-6740
For OSHA publications contact:
U.S. Department of Labor - OSHA
Publications Office, Room N3101
200 Constitution Avenue N.W.
Washington, D.C. 20210
(202) 523-9667
For questions pertaining to health and safety during
remedial design/remedial action, contact:

Joe Cocalis
USEPA Hazardous Site Control Division
Design and Construction Management Branch
MailstopOS-220W
40 1 M. Street SW
Washington, D.C. 20460
(703) 308-8356 or FTS 398-8356








7

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                             SOURCES OF INFORMATION
                                          (continued)
     For information pertaining to health and safety training contact ERT or the National Institute for Environmental
Health Sciences Training Grant Clearinghouse:

                             USEPAERT
                             26 West Martin Luther King
                             Cincinnati, OH 45268
                             (513)569-7537

                             or

                             National Clearinghouse on Occupational & Environmental Health
                             c/o Workplace Health Fund
                             815 16th Street, N.W. Suite 301
                             Washington, D.C. 20006
                             (202) 842-7833
                                     BIBLIOGRAPHY
        29 CFR 1910, OS HA General Industry Standards

                             (1)  1910.120 Hazardous Waste Operations and Emergency Response
                             (2)  1910.134 Respiratory Protection
                             (3)  1910.1200 Hazard Communication

        29 CFR 1926, OSHA Construction Industry Standards

        OSWER Directive 9285-01, Health and Safety Plan (HASP), June 1989.

        ERT Fact Sheets

        A.      Hazardous Waste Operations and Emergency Response: General Information and Compari-
               son (#9285.2 - 09fs)

        B.      Establishing Work Zones at Uncontrolled Hazardous Waste Sites (#9285.2 - 06fs)

        C.      Hazardous Waste Operations and Emergency Response: Uncontrolled Hazardous Waste Sites
               and RCRA Corrective Action (#9285.2 - 08fs)

        D.      Hazardous Waste Operations and Emergency Response: RCRA TSD and Emergency
               Response Without Regard to Location (#9285.2 - 07fs)

        E.      Hazardous Waste Operations and Emergency Response: Available Guidance (#9285.2- lOfs)

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              SECTION 3

     QUICK REFERENCE FACT SHEETS

                PART 2

       ESTABLISHING WORK ZONES
AT UNCONTROLLED HAZARDOUS WASTE SITES

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&EPA
                          United States
                          Environmental Protection
                          Agency
                            Office of
                            Solid Waste and
                            Emergency Response
Publication 9285.2-06FS
April 1991
Establishing Work  Zones  at
Uncontrolled  Hazardous
Waste  Sites
Office of Emergency and Remedial Response
Emergency Response Division      MS-101
                                                   Quick Reference Fact Sheet
      Under the authority  of section 126 of the
  Superfund Amendments and Reamhorization Act
  of  1986  (SARA),  the  U.S.  Environmental
  Protection  Agency   (EPA)   and   the   U.S.
  Occupational  Safety and  Health Administration
  (OSHA) promulgated identical health and safety
  standards to protect workers engaged in hazardous
  waste operations and emergency response.  The
  OSHA   regulations   became   effective  on
  March 6, 1990 and are  codified  at  29  CFR
  1910.120 (54 FR 9294, March 6, 1989); the EPA
  regulations also became fully effective on March 6,
  1990 and are codified at  40 CFR 311 (54 FR
  26654, June 23,  1989).   The EPA regulations
  incorporate the OSHA standards by reference.

      Although the  two sets of standards contain
  identical substantive provisions,  EPA and OSHA
  address different audiences. In  states without an
  OSHA-approved  program,   federal   OSHA
  standards protect all private and federal employees
  engaged  in   hazardous  waste   operations  and
  emergency response; the EPA worker protection
  standards protect all state and local government
  employees.   In states with an  OSHA-approved
  program, the state program covers all private,
  state, and local government employees; OSHA
  covers federal employees in those states.  Another
  Fact  Sheet,  Hazardous  Waste  Operations  and
  Emergency  Response:    Uncontrolled Hazardous
  Waste Sites and RCRA Corrective Action (OS WER
  Publication No. 9285.2-08FS), provides a general
  overview of the worker protection standards as
  they apply to operations conducted at uncontrolled
  hazardous waste sites.

      The  purpose of  this  Fact  Sheet  is  to
  summarize  the procedures and requirements for
                        establishing and maintaining work zones, including
                        Support Zones,  at hazardous waste sites.  This
                        Fact  Sheet is divided into five  parts.  The first
                        provides definitions for the work zones that are
                        commonly designated at  hazardous waste sites.
                        The   second  describes   the  data  collection
                        requirements for the initial site characterization.
                        Part 3 discusses evaluation of site data and other
                        considerations in work zone selection.   Part 4
                        describes methods for ensuring  the integrity of
                        Support Zones during remedial or removal actions.
                        The  final part of  this   Fact  Sheet  provides
                        additional references and contacts for further
                        information.

                        PART 1: INTRODUCTION TO WORK ZONES

                           The worker protection standards at 29 CFR
                        1910.120(b) require that employers with employees
                        engaged  in   hazardous  waste  operations  at
                        uncontrolled hazardous- waste sites develop  and
                        implement a written health and safety program for
                        their employees. The purpose of this program is
                        to identify, evaluate, and control safety and health
                        hazards,  and provide  for emergency  response
                        during hazardous waste operations.  As part of the
                        overall  health  and  safety program,  29  CFR
                        1910.120(d) specifies that appropriate site control
                        procedures must be implemented before clean-up
                        work  begins, to minimize  employee exposure to
                        hazardous substances. One of the basic elements
                        of a  site control program is the delineation of
                        work zones.  This delineation specifies the type of
                        operations that will occur in each zone, the degree
                        of hazard at different locations within the site, and
                        the areas at the site that should be avoided by
                        unauthorized or unprotected employees.
                                               11

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                                           EXHIBIT 1
                              Illustration of Typical Work Zones
          Exclusion
            Zone
                               Estimated Boundary
                               Of Area With Highest
                                 Contamination
                                  Access
                               Control Points
                                                              Contamination
                                                            Reduction Corridor
                       Contamination
                      Reduction Zone
                                Command Post
    Contamination
      Control Line
                                                                      Prevailing wind direction
   Note: Area dimensions not to scale. Distances between points may vary.
    EPA's  Standard  Operating  Safety   Guides
describes  the   process  for  establishing  and
maintaining work zones.  Although a site may  be
divided into as many zones as necessary to ensure
minimal   employee  exposure  to  hazardous
substances, the  three most  frequently identified
zones are the Exclusion Zone, the Contamination
Reduction Zone (CRZ), and the Support Zone.
The purpose of establishing the zones  is to (1)
reduce   the  accidental  spread  of  hazardous
substances  by workers  or  equipment from the
contaminated areas to the clean areas; (2) confine
work activities  to  the appropriate areas, thereby
minimizing the likelihood of accidental exposure;
and (3) facilitate the  location  and  evacuation of
personnel in case of an emergency.  Movement of
personnel and  equipment among these zones  is
minimized and restricted to specific access control
points   to   prevent  cross-contamination  from
contaminated   areas   to   clean   areas.     A
representation  of  the  three  most  commonly
designated work zones is found in  Exhibit 1.  A
description of each zone is provided below.

Exclusion Zone

    The   Exclusion  Zone  is  the  area where
contamination does or could occur and the greatest
potential for exposure exists. In order to separate
the Exclusion Zone from the rest of the site, the
outer boundary of the Exclusion Zone,  known as
the Hotline, should be clearly marked.  Access of
personnel  and  equipment to  and  from  the
Exclusion Zone  should be restricted  by access
control points on the zone's periphery. All persons
who enter the Exclusion Zone should  wear the
appropriate  level  of personal protective equipment
(PPE) for the degree and types of hazards  at the site.
                                             12

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    The Exclusion Zone also may be subdivided
into different areas of contamination, based on the
known or expected type and degree of hazard or
the incompatibility  of waste streams.   If  the
Exclusion Zone  is  subdivided  in  this manner,
additional demarcations and access control points
may be necessary.

Contamination Reduction Zone

    As  the   transition   area   between   the
contaminated area and the clean area, the CRZ is
the area in which decontamination procedures take
place.   This zone  is  designed to  reduce  the
probability that the Support Zone will become
contaminated or affected by other site hazards.
Due  to  both  distance  and   decontamination
procedures, the degree of contamination in the
CRZ generally will  decrease as  one moves  from
the Hotline to  the Support Zone.

Support Zone

    The  Support   Zone  is   defined  as  the
uncontaminated area where workers should not be
exposed to hazardous conditions. Any potentially
contaminated clothing, equipment, and samples
must remain outside of the Support Zone until
decontaminated.    The  Support Zone  is  the
appropriate  location  for  the  command  post,
medical station, equipment and supply center, field
laboratory, and any other administrative or support
functions that are necessary to keep site operations
running efficiently.  Because the Support Zone is
free from contamination, personnel working within
it may wear normal work clothes,  and access to
and from the area is not restricted for authorized
site personnel.  Such personnel, however, should
receive  instruction  in  the proper  evacuation
procedures   in  case of  a  hazardous  substance
emergency.

PART 2:  SITE CHARACTERIZATION -- DATA
COLLECTION

    To establish  a Support  Zone,  the  specific
hazards  and the degree of potential employee
exposure at the site must be considered. The site
characterization,   as   specified  in   29   CFR
 1910.120(c), is the basis for developing the site
health and  safety  plan  (HASP),  and  provides
information needed to identify site hazards, select
proper PPE, and implement safe work practices.
Site characterization generally proceeds in three phases:
    •   Prior   to   site   entry,   an   off-site
        characterization, including data gathering
        and perimeter reconnaissance.

    •   An on-site survey.

    •   Ongoing   monitoring   to   provide  a
        continuous source of information about
        site conditions.

    Off-site characterization and the on-site survey
are  discussed  below.   Ongoing monitoring  is
discussed  in Part 4 of this Fact Sheet,  Ensuring
Integrity of Work Zones.

Data-Gathering Prior to Initial Site Entry

    The initial stages of site characterization must
be accomplished off-site, so as not to endanger the
health and safety of workers.  For example, at new
uncontrolled hazardous  sites,  or at those sites with
areas that have not been  evaluated, the range of
potential  hazards and exposure risks is unknown.
As  much information as   possible  should  be
obtained   during   off-site   characterization   to
evaluate  the  hazards and  institute preliminary
controls  for  protecting initial  entry personnel.
Once the off-site characterization is completed and
the  appropriate   information  is  obtained,  the
information is used to  develop an initial draft of
the site-specific HASP.  (For  more information on
developing  a  HASP,  refer  to  the fact  sheet
Hazardous  Waste  Operations  and  Emergency
Response: Uncontrolled Hazardous Waste Sites and
RCRA Corrective Action, OSWER Publication No.
9285.2-08FS,  1991.)

     29 CFR  1910.120(c)(i)  through  (c)(viii)
identifies  the  generic information  that must  be
considered  and  evaluated   before  designated
personnel enter a site.  These requirements are
listed  in Exhibit 2, along with resources that can
be useful for  obtaining the required information.
These  information   sources   include  general
background  documents  (e.g., area maps),  site
records,  interviews  with   persons  who  have
knowledge   about   the   site,   and   perimeter
reconnaissance.

     Interview/Records Research. Records of the
site  or  interviews  with   persons  who  have
knowledge of  the   site  can  provide  useful
information about the  potential hazards at a site.
                                                  13

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EXHIBIT 2
Information Required Prior to Site Entry
29 CFR 1910.120(c)(4)
Regulatory Requirements:
Location, Size of Site (c)(4)(i)
Description of Job or Activity
to be Performed (c)(4)(ii)
Activity Duration (c)(4)(in)
Site Topography and
Accessibility (c)(4)(iv)
Safety and Health Hazards at
Site (c)(4)(v)
Pathways for Hazardous
Substance Dispersion
(C)(4)(vi)
Status of Response Teams
(c)(4)(vii)
Hazardous Substances and
Health Hazards (c)(4)(vm)
Sources of Information
General
Background
References
/


/
/


/
Records/Interviews
Site-Specific
/


/
/
/

/
Interviews




/


/
Perimeter Reconnaissance
Visual
/


/
/
/

/
Sampling
/


/
./
/

/
Site
Manager
Assessment

S
/



/

Examples of records that may be useful are found
in Exhibit 3.

    Perimeter Reconnaissance. In addition to the
interview/records research, data-gathering  at the
site perimeter may help in identifying site hazards
and determining the appropriate level of PPE for
the initial site entry.  Many of the activities that
occur during perimeter reconnaissance, including
making  visual   observations,   monitoring
atmospheric concentrations of airborne pollutants,
and  collecting soil samples,  are  similar  to the
activities  that occur during the initial site entry.
Perimeter reconnaissance activities, however, are
generally not  as extensive or  specific as the
activities undertaken during the on-site survey. To
determine the scope and level of effort for the
perimeter reconnaissance, the information from
the interview/records research should be evaluated.
Historical data on chemicals stored at the site, for
example, may help to identify the appropriate air
monitoring   techniques    for   the   perimeter
reconnaissance.
Initial Site Entry and Data Collection

    The goal of the on-site survey is to gather the
additional information needed to identify the risks
and hazards presented by the site, so that the work
zones  can be  established and the  appropriate
controls, PPE,  and medical monitoring program
can be selected  for the tasks that will be performed
at the site.  Risks that should be considered  are
specified in 29  CFR Part 1910.120 (c)(7) and are
listed in Exhibit 4.

    Immediately  upon entering the  site, entry
personnel should monitor the air for  immediately
dangerous to life and health (IDLH)  and other
conditions that may cause death or serious harm
(e.g., combustible or explosive atmospheres, oxygen
deficiency,  toxic  substances)  and  monitor  for
ionizing radiation.  In addition, entry personnel
should visually observe  for  signs of actual  or
potential  IDLH  hazards  or  other  dangerous
conditions. Exhibit 5 provides examples of visible
indicators of potential IDLH  hazards and other
dangerous conditions.
                                                14

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I
                   EXHIBIT 3
     Sources of Site-Specific Information
         Company records, receipts, logbooks, or
         ledgers that describe the activity that
         occurred at the site.

         Waste storage inventories and manifests
         or shipment papers.

         Records from state and federal pollution
         control regulatory and enforcement
         agencies, state Attorney General's Office,
         state occupational safety and health
         agencies, state Fire Marshal's office.

         Water and sewage district records.

         Previous survey, sampling, and monitoring
         results.

         Local fire and police department records.

         Site and aerial photos.

         Media reports (all information from the
         media should be  verified).

         Interviews with personnel (all interview
         information should be verified).

         Interviews with nearby residents (note
         possible site-related medical  problems and
         verify all information from interviews).

         Maps (e.g., USGS, land use, etc.).

         Meteorological data (e.g., wind direction,
         temperature profiles).
     If IDLH hazards or other dangerous conditions
are not present, or if proper precautions can be
taken, the survey can continue. At a minimum, the
initial on-site survey should consist of a visual survey
for potential hazards and air monitoring.

     Visual    Survey.       An   accurate   and
comprehensive visual survey of the site will assist
in  identifying  potential  hazards and determining
where additional information (e.g., air monitoring,
sampling of soil or containers) may be needed.
               EXHIBIT 4
           Risks to Consider
        29 CFR 1910.120 (c)(7)
Risks to consider include, but are not limited
to:

•   Exposure exceeding the permissible
    exposure limits (PELs) and published
    exposure levels.

    IDLH concentrations.

•   Potential skin absorption and irritation.

•   Potential eye irritation.

•   Explosion sensitivity and flammability
    ranges.

•   Oxygen deficiency.
               EXHIBIT 5
          Visible Indicators of
       Potential IDLH and Other
         Dangerous Conditions
     Large containers or tanks that must be
     entered.

     Enclosed spaces such as buildings or
     trenches that must be entered.

     Potentially explosive or flammable
     situations (indicated  by bulging drums,
     effervescence, gas generation, or
     instrument readings)

     Extremely hazardous materials (such as
     cyanide, phosgene, or radiation sources).

     Visible vapor clouds.

     Areas where biological indicators (such as
     dead animals or vegetation) are located.
                                                   15

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    This visual survey should include the following
activities:

    •   Noting    the   types   of   containers,
        impoundments,  or other storage systems
        (e.g., paper or wood packages, barrels or
        drums, tanks, lagoons).

    •   Noting the condition of waste  containers
        and  storage  systems  (e.g.,  undamaged,
        rusted or corroded, leaking).

    •   Noting   the   types   and  quantities  of
        material in containers  (e.g., full or empty;
        labels   indicating  corrosive,  explosive,
        flammable, radioactive, or toxic materials).

    •   Noting  the  physical  condition  of the
        materials  (e.g., solid,  liquid,  or  gas;
        conditions conducive to contact).

    •   Noting   any  unusual  conditions  (e.g.,
        clouds,   discolored   liquids,   oil  slicks,
        discolored   soil,   free-standing   liquid,
        stressed vegetation).

    •   Determining  the potential  pathways  of
        exposure and  dispersion (e.g., air,  soil,
        surface water, ground water).

     •   Noting   any   indicators   of  potential
        exposure to hazardous substances (e.g.,
        dead fish, animals, or  vegetation; pools of
        liquids; foams or oils on liquid surfaces;
        deteriorating containers; discolored soils).

     •   Identifying  natural wind barriers (e.g.,
         buildings, hills, tanks).

     The  results of the  visual  survey may help to
 identify a potential location for the Support Zone,
 which can be confirmed through air  monitoring
 and soil  sampling.

     Air  Monitoring.     The  purpose   of   air
 monitoring is  to identify and quantify airborne
 contaminants in  order to determine the level of
 worker protection and  identify additional medical
 monitoring needs in any given area of the site. Air
 monitoring should  be used to confirm  that the
 areas considered for  the Support  Zone do not
 contain  concentrations of hazardous  substances
 that require worker protection. The two methods
 that  generally are available for identifying and/or
quantifying airborne contaminants are (1) on-site
use   of   direct-reading   instruments   and
(2) laboratory analysis of air samples obtained by
gas  sampling  bag,   filter,  sorbent,   or   wet-
contaminant  collection methods.

    Direct-reading  instruments  may be used to
rapidly detect flammable or explosive atmospheres,
oxygen  deficiency, certain  gases and vapors,  and
ionizing radiation, as well as to identify changing
site conditions. Because direct-reading instruments
provide information at the time of  sampling and
allow  for  rapid decision-making,  they are the
primary tools of initial site characterization.  All
direct-reading instruments, however,  have inherent
constraints  in  their  ability  to  detect hazards.
Direct-reading instruments  detect  and/or measure
only specific classes of chemicals  and are  usually
not  designed to detect airborne concentrations
below 1 ppm.  In addition, many  of the direct-
reading instruments  that have been designed to
detect one particular  substance also detect other
substances  and,  consequently,  may  give  false
readings.     Direct-reading  instruments  must be
operated,  and  their data interpreted, by qualified
individuals using properly calibrated instruments and
relying  on chemical response curves.  Additional
monitoring should be conducted  at any location
where a positive instrument response occurs.

     Exhibit    6   lists   several    direct-reading
 instruments  and the conditions and/or substances
 they measure. Additional information concerning
 direct-reading  instruments is  available  in  the
 references.

     Because   direct-reading   instruments   are
 available for only a few specific substances and are
 rarely   sensitive   enough  to    detect    low
 concentrations of hazardous substances that may
 nonetheless present health risks, air samples must
 also be collected and analyzed in  a  laboratory.

     Exhibit 7  lists some  sample  collection  and
 analytical methods that are appropriate for certain
 types  of  substances  that  are   likely   to  be
 encountered at hazardous waste sites.  Additional
 information   concerning   air   sampling   and
 monitoring  is available in  the references listed in
 Part 5 of this Fact Sheet.

     Other  Information.    At  some  sites,  air
 monitoring, the visual survey, and consideration of
 activities that will be occurring at  the site will be
                                                     16

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EXHIBIT 6
Some Direct-reading
Air Monitoring Instruments
Instrument Hazard Monitored
Combustible Gas Combustible gases
Indicator (CGI) and vapors

Flame lonization Many organic gases
Detector (FID) and vapors
with Gas Chromo-
tography Option
Gamma Radiation Gamma radiation
Survey Instrument
Portable Infrared Many gases and
(IR) Speclro- vapors
photometer
Ultraviolet (UV) Many organic and
Photoionization some inorganic
Detector (PID) gases and vapors

Direct-reading Specific gases and
Colorimetric vapors
Indicator Tube
Oxygen Meter Oxygen (O2)



























adequate to determine the appropriate level of
PPE, to establish additional medical monitoring
needs, and to define work zones. For many sites,
however, consideration of planned site activities
may reveal the need for more extensive
environmental sampling. Analysis of surface soil
and soil borings may be required if site workers are
expected to be exposed to surface and subsurface
soil that may be contaminated. Ground water or
surface water sampling may be necessary if site
workers are likely to be exposed via these media.






























EXHIBIT 7
Some Air Sampling
Collection Methods
Substance Collection Device
Anions: Prewashed silica
Bromide gel tube
Chloride
Fluoride
Nitrate
Phosphate
Sulfate
Aliphatic or Silica gel
aromatic amines
Asbestos Mixed cellulose
Metals ester filter
Particulates (MCEF)
High MW Tenax/Chromosorb
hydrocarbons
Organophosphorus
compounds
Selected pesticides

Organics Charcoal tube
PCBs Glass fiber filter
and flonsil tube
Pesticides 13mm glass fiber
filter/chromosorb
102 tube
PUF/filter


considered for the Support Zone, both air and
surface soil samples should be collected and
compared with on-site and off-site background
samples.

Soil sampling can be simple or complex
    To determine whether additional monitoring is
required to designate work zones, the results of the
air monitoring survey and visual characterization of
site hazards and contaminants should  be reviewed
and potential pathways of contaminant dispersion
should be evaluated.  If there is any question that
contaminants may have  migrated  into the  area
depending on  site  conditions.   Sampling  plan
designs routinely fall into the following categories:
judgmental random, stratified random, systematic,
and  search.   Prior to  beginning  any sampling
activities, it is imperative that the purpose of the
effort  and ultimate use of the acquired data  be
established. Strategies should be selected based on
the   information   required.     Certain   target
                                                17

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contaminants may warrant special considerations.
For example,  when  sampling for  the  extent  of
contamination of a dioxin site, tiered sampling and
designed  grid-laying  approaches   should   be
considered to  achieve the 95 percent confidence
level.    Additional  information  concerning soil
sampling is  available in  the  references listed  in
Part 5 of this Fact Sheet.

PART 3: SITE CHARACTERIZATION --
SELECTION OF WORK ZONES

    After the  off-site and on-site data  collection
are complete,  the collected information is used to
establish work zones.  In addition, the HASP is
revised  to address the specific on-site hazards.

Data Compilation

    All of the information should be compiled in
a format that  facilitates a decision concerning the
placement of work zones. A site map can provide
a useful format for compiling the collected data.
The locations of all the potential hazards that were
identified through the interview/records research,
the perimeter reconnaissance, and the  initial on-
site survey should be plotted on the map.  The
map should indicate both the hazards that were
observed and  any areas that interviews  or records
suggest  may  be contaminated  with  hazardous
wastes. In addition, all sampling results from the
on-site and off-site surveys should be  plotted  on
the map.  It is important  to record locations where
hazardous substances were detected and locations
where  hazardous substances were not detected.
 The absence  of  sampling results  should  not  be
considered  evidence   that  an  area   is   clean.
Information   concerning   exposure   pathways,
 particularly the predominant wind direction, also
should be included on the map.

 Data Evaluation

    After  all  available site characterization data
 have been compiled, the data are used to select a
 location for the Support Zone.  One of the most
 important criteria for selection of an area for  the
 Support Zone is that it must be located in a clean
 area.  The Support Zone should be in an area that
 is  known to be free of  elevated (i.e. higher than
 background)   concentrations   of   hazardous
 substances.         When   evaluating   on-site
 concentrations of  hazardous  substances, it is
 important   to   consider  the  background
concentrations  of  these substances in the area.
Non-zero background concentrations of hazardous
substances may be  present at some sites.
   SUPPORT ZONE MUST BE CLEAN
Other Considerations

    The  size and position  of  the Support Zone
also may be directly affected  by  the size of the
exclusion and contamination reduction zones. For
example, the Support Zone may be constrained by
the distances needed to prevent an explosion  or
fire from affecting personnel outside the Exclusion
Zone, or the physical area required for activities in
the Exclusion Zone.   In addition, the  Support
Zone should, whenever possible, be upwind from
the Exclusion Zone. The Support Zone should be
located  as  far  from   the  Exclusion  Zone  as
practicable.   Whenever  possible,  line-of-sight
contact with all activities in the Exclusion Zone
should be maintained.  Accessibility to  support
services (e.g., power lines, access roads, telephones,
shelter,  and water) also must be considered in
selecting a Support Zone. The expected duration
of the removal action also will affect the placement
of work  zones.

    It  is also  conceivable that the Support Zone
may inadvertently become contaminated after site
remediation begins, despite everyone's best efforts.
For example, changes in wind speed and direction,
temperature, and rainfall may result  in exposures
different from those experienced during the initial
on-site survey. The integrity of the Support Zone
should be reconfirmed during remedial activities.
 PART 4:
 ZONES
ENSURING INTEGRITY OF WORK
     Several procedures can be used to ensure that
 the area chosen for the Support Zone remains
 clean during removal or remedial operations.  Use
 of site  controls will  minimize  the transfer  of
 contamination to the Support Zone.  In addition,
 periodic monitoring of the Support Zone will
 indicate  whether  changes  in site  activities  or
 conditions have resulted in contamination.  In the
 event  that   contamination  has  occurred,   the
 boundaries of work zones should be reevaluated.
                                                18

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Use of Site Controls

    The CRZ is designed to reduce the probability
that   the  clean   Support  Zone  will  become
contaminated or affected by other site hazards.
The  distance between the Exclusion and Support
Zones  provided  by the  CRZ,  together  with
decontamination of workers and equipment, limits
the physical transfer of hazardous substances into
clean areas.  The  boundary between the Support
Zone  and the  CRZ, called  the  contamination
control line,  separates the Support Zone from an
area of possible low contamination. Access to the
CRZ from the Support Zone should be through
two  access control  points, if feasible:   one  for
personnel  and  one for  equipment.   Persons
entering the  CRZ should be required to wear PPE
appropriate  for the degree and types of hazards
they may encounter when working in this area.  To
reenter the Support Zone from the CRZ, workers
should remove gross  contamination,  doff any
protective clothing,  leave equipment in the  CRZ,
and  exit through  the  personnel  access control
point.

Periodic Monitoring of Support Zone

     A monitoring and sampling program for  the
Support Zone should be established to ensure that
this  area  remains  free  from  contamination.
Monitoring  should  take place on a routine basis
and  whenever  exposure  is  likely  to  change.
Situations where  additional monitoring  may  be
appropriate  are  specified in 29  CFR 1910.120
(h)(3)  and  are listed  in  Exhibit  8.   Increased
concentrations of hazardous substances  in air, soil,
or other  environmental media may  indicate  a
breakdown in site control procedures or a change
in on-site conditions. In addition, site personnel
should  be  constantly  alert to  changes in  site
conditions  or the  presence  of  any  potentially
dangerous   situations.     Exhibit  9  lists  the
 monitoring  and sampling activities that may  be
 conducted   to  ensure  that the  Support  Zone
 remains clean.

 Considering Additional  Site  Characterization
 Information

     Additional information concerning locations of
 contaminated  environmental  media  may become
 available during monitoring or  in the later stages
 of site investigation and clean up,  particularly for
 remedial actions. For example, more detailed soil
                 EXHIBIT 8
     Conducting Additional Monitoring
           29 CFR 1910.120 (h)(3)
   Situations that require consideration of the
   possibility that exposures have risen are:

   •   When work begins on a different portion
       of ihe site.

   •   When contaminants other than those
       previously identified are being handled.

   •   When a different type of operation is
       initiated (e.g., drum opening as opposed to
       exploratory well drilling).

   •   When employees are handling leaking
       drums or containers or working in areas
       with obvious liquid contamination (e.g., a
       spill or lagoon).
sampling will occur during the sue inspection (SI)
and remedial  investigation (RI).  This additional
information  may  indicate  that  areas   initially
considered clean are, in fact, contaminated.  The
location  of  the   Support  Zone  should  be
reevaluated whenever  new site  characterization
studies are conducted.
                  EXHIBIT 9
            Periodic Support Zone
             Monitoring Activities
        Air monitoring using direct-reading
        instruments.

        Collecting air samples for paniculate, gas,
        or vapor analysis.

        Analysis of soil samples from heavily
        trafficked areas.

        Occasional swipe tests in trailers and other
        areas used by personnel.
                                              19

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PART 5:  CONSULTATION AND REFERENCES

    For more information regarding work zones,
the following references may be consulted.

Federal Regulations

    •  OSHA Regulations (particularly 29 CFR
        1910 and  1926)

    •  EPA Regulation 40 CFR 311

Guidance Documents

    The  following  publications  explain  site
operating procedures  and guidelines, including
safety    procedures   for   decontamination,
considerations for establishing work zones, and
sampling and monitoring  programs:

    •  EPA Standard Operating Safety  Guides',
        U.S. Environmental  Protection  Agency,
        Office  of  Emergency  and  Remedial
        Response, Environmental Response Team,
        OSWER  Directive 9285.1-01C, 1988.

    •   Field Standard Operating Procedures for
        Establishing Work Zones F.S.O.P.  6;  U.S.
        Environmental Protection Agency, Office
        of  Emergency and Remedial Response,
        OSWER Directive 9285.2-04, 1985.

    •   Field Standard Operating Procedures for Air
        Surveillance   F.S.O.P.   8;   U.S.
        Environmental Protection Agency, Office
        of  Emergency and Remedial Response,
        OSWER Directive 9285.2-03, 1985.

     •   Environmental Response  Team  (ERT)
        Standard  Operating  Procedures,  Soil
        Sampling   SOP   #   2012,  U.S.
        Environmental   Protection   Agency,
        Environmental Response Team,  1988.

     •   Occupational  Safety and Health Guidance
        Manual for Hazardous Waste Site Activities;
        NIOSH/OSHA/USCG/EPA,   DHHS
         (NIOSH) Publication  Number  85-115,
        GPO No. 017-033-00419-6, 1985.

     The following publication provides step-by-step
 guidance for assessing  preliminary evaluations,
 health and safety plans, and off-site emergency
 response plans:
    •  EPA Health and Safety Audit Guidelines;
       U.S. Environmental  Protection Agency,
       Office of Solid Waste and  Emergency
       Response, Emergency Response Division,
       EPA-540/G-89/010,   OSWER  Directive
       9285.8-02, 1989.

    The  following  publications provide  general
information concerning the development  of a
specific health and  safety program for workers at
hazardous waste sites:

    •  EPA  Standard Operating  Safety  Guides;
       U.S.  Environmental  Protection Agency,
       Office  of  Emergency  and  Remedial
       Response, Environmental ResponseTeam,
       OSWER Directive 9285.1-01C, 1988.

    •  Field Standard Operating  Procedures for
       Site  Safety' Plan   F.SO.P.   9;     U.S.
       Environmental Protection Agency, Office
       of Emergency and  Remedial  Response,
       OSWER Directive 9285.2-05, 1985.

    •  Generic   Site  Safety  Plan;   U.S.
       Environmental  Protection  Agency,
       OSWER Directive 9285.8-01.

    •  Occupational Safety and Health Guidance
       Manual for Hazardous Waste Site Activities;
        NIOSH/OSHA/USCG/EPA,  DHHS
        (NIOSH)  Publication   Number  85-115,
        GPO No. 017-033-00419-6, 1985.

    The    following   two  volumes   entitled
Characterization  of Hazardous  Waste Sites - A
Methods   Manual   address  issues   related  to
characterization  of hazardous  waste sites,  from
preliminary data gathering  to sampling  and
analysis:

     •   Volume  I -  Site  Investigations;  U.S.
        Environmental Protection Agency, Office
        of   Research   and   Development,
        Environmental   Monitoring   Systems
        Laboratory,   Las  Vegas,   NV,  EPA-
        600/4-84/075, 1985.

     •   Volume  II - Available  Sampling Methods,
        Second  Edition;   U.S.  Environmental
        Protection Agency, Office of Research and
        Development, Environmental Monitoring
        Systems Laboratory, Las Vegas, NV, EPA-
        600/4-84/076, 1984.
                                                 20

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    The following publication provides information
on  sampling  design  and  associated  statistical
methods    for   determining   contaminant
concentrations:

    •   Methods for Evaluating the Attainment of
        Cleanup Standards, Volume I:   Soil and
        Solid   Media;   U.S.   Environmental
        Protection Agency,   Office of  Policy,
        Planning,   and   Evaluation,   EPA-
        230/02-89-042, 1989.

    The following publication provides guidance
for  using   portable  instruments for  assessing
airborne pollutants arising from  hazardous waste:

    •   Draft International Document on Guide to
        Portable Instruments for Assessing Airborne
        Pollutants Arising from Hazardous Wastes;
        U.S. National Working Group (NWG-4
        OIML)   Pilot   Secretariat  PS-17:
        "Measurement  of  Pollution"  Reporting
        Secretariat  RS-5:    "Measurement  of
        Hazardous  Waste  Pollution." ISBN:  0-
        936712-75-9.

    The  following  four  volumes  collectively
entitled Procedures for  Conducting  Air Pathway
Analyses for  Superfund  Applications  address  a
variety  of  issues relevant to  the air impacts at
Superfund sites:

    •   Volume I:   Application of  Air Pathway
        Analyses for Superfund Applications; U:S.
        Environmental Protection Agency, EPA-
        450/1-89-001,   1989.      NTIS   PB90
        113374/AS.

    •   Volume II:  Estimation of Baseline Air
        Emissions  at   Superfund  Sites;  U.S.
        Environmental Protection Agency, EPA-
        450/1-89-002,   1989.      NTIS   PB89
        180053/AS.

    •   Volume III:  Estimation of Air Emissions
        from Clean-up Activities  at Superfund Sites;
        U.S.  Environmental  Protection Agency,
        EPA-450/1-89-003,  1989.   NTIS  PB89
        180061/AS.

     •   Volume IV:   Procedures for Dispersion
        Modelling and Air Monitoring for Superfund
Air  Pathway  Analysis;   U.S.   Environmental
Protection Agency, EPA-450/1-89-004,1989. NTIS
PB90 113382/AS.

Fact Sheets

    The following fact sheet provides a summary of
the federal regulations at 29 CFR 1910.120 and 40
CFR 311, as they pertain to worker protection at
uncontrolled hazardous waste sites:

     •   Hazardous   Waste   Operations   and
        Emergency   Response:      Uncontrolled
        Hazardous   Waste   Sites   and   RCRA
        Corrective Action;   U.S.  Environmental
        Protection   Agency,  Environmental
        Response Team, OSWER Publication No.
        9285.2-08FS, 1991.

     The following fact sheet provides  a  list and
description of computer  software,  fact  sheets,
guidance  documents and ERT training programs
that pertain to the worker protection standards:

     •   Hazardous   Waste   Operations   and
        Emergency Response: Available Guidance;
        U.S.  Environmental Protection  Agency,
        Environmental Response Team, OSWER
        Publication No. 9285.2-10FS, 1991.

Contact Persons  or Groups

     Several contact persons or groups can provide
additional  information on the establishment of
work zones at uncontrolled hazardous waste sites.
These contacts include:

 •   U.S. EPA's Environmental Response Team
     2890  Woodbridge Avenue
     Building  18 (MS-101)
     Edison, NJ 08837-3679
     (908) 321-6740 or (FTS) 340-6740

 •   U.S. Department of Labor, OSHA
     Office of Health Compliance Assistance
     200 Constitution Avenue, NW
     Washington, D.C.  20210
     (202) 523-8036 or (FTS) 523-8036

     In addition, addresses and telephone numbers
 for  EPA  and OSHA regional offices are listed in
 Exhibit 10.
                                               21

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                                     EXHIBIT 10
                     Regional Addresses and Telephone Numbers
EPA Regional Offices

•    EPA Region 1
     John F. Kennedy Federal Building
     Room 2203
     Boston, MA 02203
     (617) 565-3715 or (FTS) 835-3715

•    EPA Region 2
     Jacob K. Javitz Federal Building
     26 Federal Plaza
     New York, NY 10278
     (212) 264-2657 or (FTS) 264-2657

•    EPA Region 3
     841 Chestnut Building
     Philadelphia, PA  19107
     (215) 597-9800 or (FTS) 597-9800

•    EPA Region 4
     345 Courtland Street, NE
     Atlanta, GA 30365
     (404) 347-4727 or (FTS)  257-4727

•    EPA Region 5
     230 South Dearborn Street
     Chicago, IL 60604
     (312) 353-2000 or (FTS) 353-2000

     EPA Region 6
     1445 Ross Avenue,  9th Floor
     Dallas, TX 75202
     (214) 655-6444 or (FTS) 255-6444

     EPA Region 7
     726 Minnesota Avenue
     Kansas City, KS 66115
     (913) 551-7000 or (FTS) 276-7000

     EPA Region 8
     999 18th Street, Suite 500
     Denver, CO 80202-2405
     (303) 293-1603 or (FTS) 293-1603

 •   EPA Region 9
     215 Fremont Street
     San Francisco, CA  94105
     (415) 556-6322 or (FTS) 556-6322

 •   EPA Region 10
      1200 6th Avenue
     Seattle, WA 98101
      (206) 442-1200 or (FTS) 399-1200
OSHA Regional Offices

•     OSHA Region 1
      133 Portland Street, 1st Floor
      Boston, MA 02114
      (617) 565-7164 or (FTS) 835-7164

•     OSHA Region 2
      201 Varick Street, Room 670
      New York, NY  10014
      (212) 337-2325 or (FTS) 660-2378

•     OSHA Region 3
      Gateway Building, Suite 2100
      3535 Market Street
      Philadelphia, PA 19104
      (215) 596-1201 or (FTS) 596-1201

•     OSHA Region 4
      •1375 Peachtree Street, NE, Suite 587
      Atlanta, GA  30367
      (404) 347-3573 or (FTS) 257-3573

•     OSHA Region 5
      230 South Dearborn Street
      32nd Floor, Room 3244
      Chicago, IL 60604
       (312) 353-2220 or (FTS) 353-2220

•     OSHA Region 6
      525 Griffin Street, Room 602
       Dallas, TX 75202
       (214) 767-4731 or (FTS) 729-4731

 •      OSHA Region 7
       911 Walnut Street
       Kansas City, MO 64106
       (816) 426-5861 or (FTS) 867-5861

       OSHA Region 8
       1951 Stout Street
       Denver, CO  80204
       (303) 844-3061 or (FTS) 564-3061

 •     OSHA Region 9
       71 Stevenson Street,  Suite 415
       San Francisco, CA 94105
       (415) 744-6670 or (FTS) 484-6670

 •     OSHA Region 10
       1111 Third Avenue, Suite 715
       Seattle, WA 98101-3212
       (206)  442-5930 or (FTS) 399-5930
                                           22

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                    SECTION 3

            QUICK REFERENCE FACT SHEETS

                      PART 3

HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
     RCRA TSD AND EMERGENCY RESPONSE WITHOUT
               REGARD TO LOCATION
                        23

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 &EPA
                      United States
                      Environmental Protection
                      Agency
                         Office of
                         Solid Waste and
                         Emergency Response
Publication 9285.2-07FS
April 1991
Hazardous  Waste  Operations
and  Emergency  Response:
RCRA TSD and Emergency Response
Without Regard to Location
 Office of Emergency and Remedial Response
 Emergency Response Division     MS-101
                                            Quick Reference Fact Sheet
INTRODUCTION
                Under the authority of section
                126 of the Superfund Amend-
                ments and Reauthorization Act
                of  1986 (SARA),  the  U.S.
                Environmental  Protection
                Agency (EPA) and the U.S.
                Occupational   Safety  and
Health  Administration  (OSHA)   promulgated
identical health and safety standards to  protect
workers engaged in hazardous waste operations
and emergency response. The OSHA regulations,
codified at 29 CFR 1910.120, became effective on
March 6, 1990 (54 FR 9294).  Corrections to the
OSHA  regulations were published on April 13,
1990 (55 FR 14072).  The  EPA regulations,
published originally on June 23, 1989 at 54 FR
26654,  incorporate  the  OSHA standards by
reference and are codified at 40 CFR 311.

     Although  the  EPA and OSHA  worker
protection   standards  for   hazardous   waste
operations  and   emergency   response
(HAZWOPER)  contain   identical  substantive
provisions, the regulations differ with  respect to
the scope of coverage.  The OSHA standards apply
directly  to  private employees and to  federal
employees through Executive Order 12196. OSHA
has no authority to enforce regulations protecting
state and local government employees.  However,
under section 18(b) of the OSH Act, a state may
elect  to  develop  and  implement  its  • own
occupational safety and health program.  This
program must be at least as effective as the federal
OSHA  standards and must   be reviewed and
approved by OSHA prior to implementation of the
plan. Through its review  and approval authority,
OSHA requires states to extend  occupational
safety and health protection to all state and local
                        government  employees,  as well  as  to  private
                        employees, within the state's jurisdiction.

                             EPA's authority extends to state and local
                        government employees conducting hazardous waste
                        operations and emergency response in states that
                        do not have in effect a delegated OSHA program.
                        The EPA regulations also cover both compensated
                        and uncompensated workers.  Therefore, the EPA
                        standards protect volunteers, such as fire fighters.
                        Although federal OSHA recommends that states
                        with delegated  programs define  "employee"  to
                        include  both compensated and uncompensated
                        workers,  not  all states have  followed this
                        recommendation.

                             Despite the fact that the EPA and OSHA
                        regulations differ in their scope of coverage, both
                        regulations  apply  to three  primary groups  of
                        workers:  (1)  employees engaged in emergency
                        response without regard to location; (2) employees
                        engaged in routine hazardous waste operations at
                        treatment, storage, and disposal (TSD) facilities
                        regulated under the'Resource Conservation and
                        Recovery Act (RCRA); and (3) employees engaged
                        in  mandatory  or   voluntary  clean-ups  at
                        uncontrolled  hazardous  waste sites,  including
                        corrective actions at RCRA TSD facilities. The
                        standards, however, do not cover those employees
                        who will not be exposed to, or who do not have
                        the  potential  to be  exposed  to, hazardous
                        substances.

                             The purpose of this Fact Sheet is to explain
                        the principle requirements of the EPA and OSHA
                        worker  protection standards  as  they apply  to
                        employees  who perform emergency response
                        operations irrespective of location and employees
                        who perform hazardous waste operations at RCRA
                        TSD facilities.   Requirements  that  apply  at
                                        25

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uncontrolled hazardous waste sites are addressed in
a   Fact   Sheet  entitled  "Hazardous   Waste
Operations   and    Emergency   Response:
Uncontrolled Hazardous Waste Sites and RCRA
Corrective Action" Publication No. 9285.2-08FS.

      This Fact Sheet is divided into three parts.
The first two parts describe the planning, training,
and medical surveillance  requirements  as they
apply to emergency response  activities  without
regard to location and hazardous waste operations
at RCRA TSD facilities.  The final part of this
Fact  Sheet  provides important addresses and
telephone numbers.
                  PART  1:   Requirements
                  for  Planning,  Training,
                  and Medical Surveillance
                  for Emergency Response
                  Without    Regard    to
                  Location     (29     CFR
                   1910.120(q))
       This part of the Fact Sheet addresses the
 requirements in 29 CFR 1910.120(q) that apply to
 emergency responders who respond to hazardous
 waste emergencies wherever they may occur (i.e.,
 without regard to location).  Although there are
 eleven required  elements  specified  at 29  CFR
 1910.120(q) for protecting workers who perform
 emergency response operations without regard to
 location,  this  Fact Sheet addresses  only the
 planning,  training, and  medical  surveillance
 requirements.    For  a  complete  list  of the
 requirements  at  29 CFR 1910.120(q), refer to
 Exhibit 1.
                   Overview of Emergency
                   Response
                                  response"  is
                                   29  CFR
                 An "emergency
                 defined   at
                 1910.120(a)(3) as a  response
                 effort  by   employees  from
outside  the immediate release area  or  by  other
responders, such as  local  fire fighters,  to a,n
incident that  results, or is likely to  result,  in an
uncontrolled release of a hazardous substance.  A
response to an incidental release of a hazardous
substance that  can  be absorbed, neutralized, or
otherwise  controlled  by  employees   in  the
immediate area or by maintenance personnel is not
considered an emergency response within the scope
of the standard.
                                                                    EXHIBIT 1
                                                          Emergency Response Operations
                                                        Conducted without Regard to Location
                                                               (29 CFR 1910.120(q))
                                                          Emergency response plan
                                                          Elements of an emergency response
                                                          plan
                                                          Procedures for handling emergency
                                                          response
                                                          Skilled support personnel
                                                          Specialist employees
                                                          Material handling program
                                                          Training based on the duties and
                                                          functions performed by each level of
                                                          responder
                                                          Refresher training program
                                                          Medical surveillance and
                                                          consultation
                                                          Chemical protective equipment
                                                          clothing
                                                          Post-emergency response operations
      The worker protection  standards contain
several requirements that apply to workers engaged
in "emergency response."  These requirements are
specified at 29 CFR  1910.120(1)  for emergency
responders at uncontrolled hazardous waste sites;
29 CFR 1910.120(p)(8) for emergency responders
at RCRA TSD facilities; and 29 CFR 1910.120(q)
for  employees who perform emergency response
operations irrespective of location.

      The emergency response requirements at
(p) and (1) apply to site workers who will respond
to emergencies only at their specific work site; the
emergency response  requirements  at  29  CFR
1910.120(q) are specifically designed  to  protect
employees who respond to a variety of emergencies
at  different  locations with various extenuating
circumstances.  This part of the Fact Sheet only
addresses the requirements specified at (q). These
requirements  cover  a  variety   of  emergency
response  workers, including public and  private
HAZMAT teams, fire fighters, and police officers.
Examples of emergency response operations that
occur irrespective of location could  include a fire
at a gas station; a transportation accident, such as
an overturned tractor trailer or a train derailment;
or  a chemical  spill at a fixed facility,  such  as  a
                                                  26

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manufacturing plant or a pharmacy, where outside
assistance is needed to cleanup the spill.
                  Planning Requirements

                  Under 29 CFR 1910.120(q)(l),
                  employers must  develop  and
                  implement   an   emergency
                  response  plan   to   handle
                  anticipated  emergencies prior
to  the  commencement of  emergency response
operations.  In developing this plan,  the employer
must take into  account the variety of possible
emergencies that could occur within the employer's
jurisdiction.  Exhibit 2 provides a comprehensive
list of the elements that must be addressed in the
emergency response plan.   In addition to these
elements,  the emergency response plan  must
include the procedures for setting up an Incident
Command System (ICS) and identify the chain of
command  that   will  be   operative  during  an
emergency.  For example:

•      The senior response official responding to
       an emergency will become the individual in
       charge of a site-specific ICS. All emergency
       responders and their communications must
       be coordinated and controlled through the
       individual  in  charge of  the ICS.   The
       emergency response plan should address the
       responsibilities of the individual in charge;
       these responsibilities are  specified at 29
       CFR 1910.120(q)(3).

 •      The Safety Official,  designated  by  and
       accountable to the individual in charge of
       the ICS,  must be  knowledgeable in  the
       operations  being   implemented  at   the
       incident site and be able to identify and
       evaluate hazards. The Safety Official also
       has authority to alter, suspend, or terminate
       activities at a site if it is determined that an
       immediately  dangerous  to life or health
       (IDLH)  condition  or imminent danger
       condition exists.

       In addition to the  planning requirements
 specified at  29  CFR  1910.120(q),  there' are  a
 multitude of planning requirements specified under
 SARA Title  III  that address emergency response
 planning for  a community.  The goal of the  Title
 III planning requirements is to protect the public
 in  the  event  of an  emergency  involving  an
 extremely  hazardous  substance.    Emergency
 response  organizations should  incorporate the
                 EXHIBIT 2
           Required Elements of an
          Emergency Response Plan
            (29 CFR 1910.L20(q)(2)
                and (P)(8)(ii))
          Pre-emergency   planning   and
          coordination with outside parties.
          Personnel  roles, lines of authority,
          and communication.
          Emergency   recognition   and
          prevention.
          Safe distances and places of refuge.
          Site security and control.
          Evacuation routes and procedures.
          Decontamination procedures.
          Emergency medical treatment and
          first aid.
          Emergency alerting and  response
          procedures.
          Critique of response and follow-up.
          Personal    protective   equipment
          (PPE) and emergency equipment.
local  emergency  response  plan  or the  state
emergency response plan or both as part of their
emergency response plan to avoid any unnecessary
duplication of  information.    For additional
information  on  the  SARA  Title  III planing
requirements, please contact the Title III Hotline
at  (800)  535-7672,  or (202)  475-9652  in the
Washington, D.C. metropolitan area.
                  ,Training Requirements

                  The purpose of the training
                  requirements  for  emergency
                  response personnel  is to give
                  employees the knowledge and
                  skill to perform an emergency
response with minimal risk to their own health and
safety  and   the  health and safety  of others.
Employees  who  respond  to emergencies  may
become exposed  to a  hazardous substance.  The
risks of  exposure, however,  will  vary with each
response.   As such,  the  amount  and type  of
training  required under the worker protection
standards for employees who perform emergency
response  operations  is linked  directly  to   an
employee's  potential for exposure  to  hazardous
substances and to other health hazards during an
                                             27

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emergency response. No employee may participate
in an emergency response activity unless they have
been adequately trained.

       The  specific training  requirements  for
employees  who  perform  emergency  response
operations without regard to location are specified
at  29  CFR  1910.120(q)(6).    These  training
requirements  are  based  on  "Levels"  that  are
generally  recognized in the hazardous  materials
response  industry.   There are  five  Levels  of
emergency response personnel; each Level specifies
unique training requirements. The following is an
overview  of the responsibilities of each Level of
responder and a brief  summary  of the training
requirements for that Level.
              Level 1 Responders
               (Awareness Level)
         Must Have Sufficient Training
             or Proven Experience
            in Specific Competencies
 Level 1.  Level 1 Responders are most likely to
 witness or discover a hazardous  substance release
 and to initiate an emergency response sequence by
 notifying the proper authorities.  Police officers
 who do not actually respond to a release are good
 examples of a Level 1 Responder. For example, a
 State  Trooper  who responds  to an  overturned
 truck carrying hazardous materials on a highway,
 contacts  the  police  dispatcher  to  report the
 location  and the type  of accident, and uses his
 patrol  car  to  block lines of  traffic, would be a
 Level 1 Responder, so long as he does not try to
 contain the release. The number of training hours
 that a Level  1 Responder  must  receive is not
 specified in the regulation.  Level 1 Responders,
 however,   must   have  sufficient   training  or
 experience  to  demonstrate competency  in  the
 following areas:

 •      Understanding  hazardous substances and
        their risks;

 •      Understanding   the    implications   of
        hazardous substance emergencies;

 •      Recognizing  the presence  of hazardous
        substances;

  •      Identifying hazardous substances;
•     Understanding the first responder role; and

•     Recognizing  the   need  for  additional
      resources.
             Level 2 Responders
              (Operations Level)
        Must Have Level 1 Competency,
    plus a Minimum of 8 Hours  of Training
     to  Demonstrate Specific Competencies
Level 2. Level 2 Responders are part of the initial
response  to  a release  or potential  release  of
hazardous substances.  Local police officers, fire
fighters, and rescue personnel, who try to contain
the effects of a release without necessarily stopping
it, are typical Level 2 Responders.  Specifically, a
Level  2  Responder may assist  with  evacuation
proceedings, contain the  release from a  safe
distance, and prevent further exposures.  Level 2
Responders must have Level  1 competency and a
minimum  of  8  hours  training  or  sufficient
experience  to  demonstrate  competency in  the
following areas:

•     Understanding  basic   hazard   and  risk
       assessment techniques;

 •     Selecting and using PPE;

 •     Understanding basic hazardous  materials
       terms;

 •     Performing  basic  control,  containment,
       and/or confinement operations;

 •     Implementing   basic  decontamination
       procedures; and

 •     Understanding    the   relevant   standard
       operating   procedures  and   termination
       procedures.
               Level 3 Responders
             (HAZMAT Technicians)
       Must Have a Minimum of 24 Hours
           of Training at Level 2, plus
       Sufficient Experience to Demonstrate
              Specific Competencies
                                                    28

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Level  3.    Level  3  Responders  are  Hazmat
Technicians responsible for attempting to stop the
release, as compared to a Level 2 responder who
attempts only to contain the release and contact
the appropriate authorities.  Level 3 Responders
must  have a minimum of 24 hours of training at
Level 2, and sufficient experience to  demonstrate
competency in the following areas:

•      Implementing  the employer's emergency
       response plan;

•      Classifying, identifying, and verifying known
       and unknown materials by using field survey
       instruments and equipment;

•      Functioning within an assigned role in the
       Incident Command System;

•      Selecting and  using specialized chemical
       PPE;

•      Understanding hazard and risk assessment
       techniques;

•      Implementing   advance  control,   con-
       tainment, and/or confinement operations;

•      Implementing decontamination procedures;

•      Understanding termination procedures; and

•      Understanding  basic   chemical   and
       lexicological terminology and behavior.
              Level 4 Responders
             (HAZMAT Specialists)
       Must Have a Minimum of 24 Hours
           of Training at Level 3, plus
      Sufficient Experience to Demonstrate
             Specific Competencies
 Level  4.    Level  4  Responders  are Hazmat
 Specialists.   They respond  with  and provide
 support to the Hazardous Materials Technicians
 (Level 3). Level 4 Responders are expected to be
 more  knowledgeable about hazardous substances
 than are Level 3 Responders.  Hazmat Specialists
 will sometimes act as liaisons with government
 authorities, explaining site activities and associated
 risks.  Level 4 Responders must have a minimum
 of 24 hours of training at Level 3, and sufficient
experience to  demonstrate  competency  in  the
following areas:

•      Implementing the local emergency response
       plan;

•      Classifying, identifying, and verifying known
       and unknown materials;

•      Having knowledge of the state emergency
       response plan;

•      Selecting and using  specialized chemical
       PPE;

•      Understanding in-depth hazard and  risk
       techniques;

•      Performing   specialized   control,  con-
       tainment, and/or confinement operations;

•      Determining   and   implementing
       decontamination  procedures;

•      Developing a site safety and control plan;
       and

•      Understanding chemical, radiological, and
       lexicological terminology and behavior.
              Level 5 Responders
       (On-Scene Incident Commanders)
      Must Have a Minimum of 24 Hours
          of Training at Level 2, plus
      Sufficient Experience to Demonstrate
             Specific Competencies
 Level 5.  The Level 5 Responder is the On-Scene
 Incident Commander or Senior QIC. The Senior
 QIC assumes control of the emergency response
 incident  scene.   Senior  OICs  coordinate  the
 activities of all emergency responders and ensure
 that open lines of communications exist between
 them. The QIC is usually a generalist with broad
 knowledge in  managing emergency  incidents.
 Level 5  Responders must have a minimum of 24
 hours of training  at  Level 2,  and  additional
 corrpetency in the following areas:

 •     Implementing  the   Incident   Command
       System;
                                               29

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•     Implementing the  employer's emergency
      response plan;

•     Implementing the local emergency response
      plan;

•     Having knowledge of the state emergency
      response plan and the Federal  Regional
      Response Team;

•     Understanding   the  hazards  and  risks
      associated    with   chemical   protective
      clothing; and

•     Understanding   the   importance   of
      decontamination procedures.

      In addition to the aforementioned  training
requirements, each emergency  responder  must
receive either annual  refresher training, or must
demonstrate sufficient competency in the relevant
areas on a  yearly basis.  With respect to refresher
training, there are no specific hourly requirements,
however, it should be of sufficient  content and
duration to enable responders to maintain their
competencies.  If an employee does not submit to
refresher  training  but  is  able  to  demonstrate
competency to the employer in the relevant areas,
the employer must document on a yearly basis the
statement of competency and maintain a record of
the method used to determine competency.

       There are two types of workers who may be
needed during an emergency response, but are not
covered by the training requirements in  29 CFR
 191Q.120(q)(6).   These employees include skilled
support   personnel and  specialist  employees.
Skilled support  personnel are trained in  the
operation  of specialized mechanical equipment
 such as  crane  and  hoisting  equipment  or  a
 backhoe, and generally are not employed by the
 same organization as the other emergency response
 personnel at the  incident  scene.   Such skilled
 personnel would be used in special  situations to
 assist with an emergency.  Although they may be
 exposed to hazards during an emergency response,
 they are only at the scene temporarily to perform
 immediate emergency support work that cannot
 reasonably be performed by fully trained hazardous
 response personnel.

       The only training required for such skilled
 personnel is that they receive  an initial briefing of
 the  site, which  must  include  instruction on  the
 proper  use of PPE,  a review  of  the  potential
hazards at the site, an overview of the duties to be
performed, and an overview of other  safety  and
health  precautions.   Such  personnel must  be
briefed at the  site prior to their participation in
any emergency response operations.

      In addition to skilled support personnel, an
employer  may call upon specialist employees to
assist in an emergency response effort. Specialist
employees have specialized knowledge about some
aspect  of emergency   response  or  hazardous
substances. These individuals are called upon on
an as needed basis to provide technical advice or
assistance to the individual in charge at an incident
where there has  been  a release of a hazardous
substance. For example, if an emergency release
involves  two  or  more  hazardous substances, a
chemist may be called in to  predict  the potential
reactivity  of the agents involved at the scene.

      Although there is no statutory limitation on
a specialist employee's functions, they must receive
proper training prior to performing any operations.
Specifically, specialist   employees must  receive
training   commensurate  with  their area   of
specialization  on  an annual basis.   There are,
however, no hourly training requirements specified
under   the worker  protection  standards   for
specialist employees.
                  Medical Surveillance
                  Requirements

                  Employers whose employees
                  engage in emergency response
                  operations without regard  to
                  location   must  develop  and
 implement  a  medical surveillance  program that
 includes  provisions for baseline,  periodic, and
 termination medical examinations.

       As specified  in 29 CFR  1910.120(q)(9), a
 medical surveillance program must be provided for
 the following three groups of employees:

 •     Hazardous Materials Specialists;

 •     Members of an organized and designated
       HAZMAT Team; and

 •     Employees who exhibit signs or symptoms
       that may have resulted from  exposure to
       hazardous substances during the course of
       an emergency incident, either immediately
       or subsequently.
                                                 30

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      Employers are not required to provide  a
formal  medical  monitoring  program  for  first
responders at the awareness and operations levels
(i.e., Levels I and 2) and Level 3 Responders who
are not  members of designated HAZMAT teams.
These employees, however, must be provided with
medical examinations if they are  injured due to
overexposure  during  an  emergency  incident.
Furthermore,  because coverage  under 29  CFR
1910.120(f)(2)  does  not apply  to  emergency
responders without regard to location, fire fighters
who wear respirators for 30 days or more per year
are only required to undergo medical surveillance
if they  are members of designated  HAZMAT
Teams  or are injured  due  to overexposure to
hazardous  substances   during   an   emergency
incident.

       If employees fall within the first two groups
listed above, they must undergo a baseline medical
examination prior to an assignment.  After this
initial examination, employees must have a follow-
up medical examination once a year; an attending
physician may suggest a shorter or longer interval,
but this period  may  not exceed  two years.  The
content of these examinations is to be determined
by  the  attending  physician,  but  certain key
elements must  be included.  For  example, the
physician  must complete a medical and  work
history  and determine the employee's fitness for
the type  of duties to be assigned,  including the
ability of the employee to wear PPE.

        In  addition  to  these requirements, an
employee must  receive a medical examination  as
soon as  possible  if  the employee  is injured  or
becomes  ill from exposure to hazardous substances
during  an emergency, or the employee develops
signs   or  symptoms  that  indicate  a  possible
 overexposure to hazardous substances. In addition,
 employees must receive a final examination when
 they are  reassigned or terminate employment and
 thus  no  longer  are  exposed  to  hazardous
 substances.  This  examination is only required if
 the employee has not had an examination within
 the  past six months.   All  required  medical
 examinations must be provided without cost to the
 employee, without loss of pay, and at a reasonable
 time and place.

        Medical records for  employees must  be
 maintained for a  period of thirty years following
 termination of employment. These records must
 include the name and social security number of the
 employee;  the  physician's  written  opinions,
including recommended occupational limitations
and  results  of  examinations  and  tests;  any
employee medical complaints related to exposure
to  hazardous  substances;  and a  copy of  the
information provided to the examining physician by
the employer.  The employer  is responsible for
retaining the records if the employee or physician
leaves  the  area.  For additional information on
medical recordkeeping requirements, refer to 29
CFR 1910.20.
                  PART  2:   Requirements
                  for  Planning,  Training,
                  and Medical Surveillance
                  at RCRA TSD Facilities
                  (29 CFR 1910.120(p))
       This part  of  the Fact Sheet explains the
 applicability of 29 CFR I910.120(p) and describes
 several of the requirements specified in the OSHA
 standards  for  personnel  involved in hazardous
 waste operations and emergency response activities
 at RCRA TSD facilities. Although there are eight
 required elements specified at 29 CFR 1910.120(p)
 for  protecting workers who perform hazardous
 waste operations and emergency  response  at
 RCRA TSD facilities, this  Fact Sheet addresses
 only  the  planning,  training,   and  medical
 surveillance requirements.  For a  complete list of
 the requirements at  29 CFR 1910.120(p), refer to
 Exhibit 3.
                  EXHIBIT 3
        Operations Conducted Under the
               RCRA Act of 1976
              (29 CFR 1910.120(p))
           Safety and health program
           Hazard communication program
           Medical surveillance program
           Decontamination program
           New technology program
           Material handling program
           Training program
           Emergency response program
                                            31

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                 Applicability of 29 CFR
                 1910.120(p)

                 The requirements under  the
                 worker  protection  standards
                 for  personnel  engaged   in
                 hazardous   waste  operations
and emergency response at a RCRA TSD facility
are specified at  29 CFR  1910.120(p).   These
requirements apply  to any TSD facility regulated
under 40 CFR 264 and 265, or by a state program
authorized under RCRA; the requirements apply
to both  permitted  and  interim  status  facilities.
Facilities that have been granted exemptions from
the RCRA TSD  requirements  (as detailed at 40
CFR 264 and 265),  however, are exempt from the
worker protection requirements, except those at 29
CFR 1910.120(p)(8) which detail the requirements
for an  emergency  response  plan, emergency
response  training,  and  other  procedures   for
handling emergencies.
   Iti
                 Planning Requirements

                 Employers  at  RCRA  TSD
                 facilities   must develop  and
                 implement a written safety and
                 health  program    for  their
                 employees   engaged  in
hazardous waste operations.  The program must be
designed to identify, evaluate, and control  safety
and health hazards at the facility, and provide for
emergency  response  during  hazardous  waste
operations at the TSD facility.  In addition,  the
program must address appropriate site  analysis,
engineering controls,  maximum exposure limits,
hazardous waste handling procedures, and uses of
new technologies.  One important component of
the safety and health program is the emergency
response plan.  This plan must be developed  and
implemented as  a separate part of the safety  and
health program.

       The emergency  response  plan must  be
developed  prior   to  the  commencement   of
operations at the facility. This plan  must include
a  description of how an  emergency would be
handled at the facility and how the risks associated
with  a  response  would  be  minimized.    The
elements required in an emergency response plan
for a  RCRA TSD  facility  are  identical to  the
requirements  shown in Exhibit 2;  the RCRA
requirements   are  codified   at   29  CFR
      In addition to the requirements outlined in
Exhibit  2,  the  emergency  response plan  must
include information on site topography, layout, and
prevailing weather conditions, and procedures for
reporting incidents  to  local,  state,  and federal
agencies.  The  emergency response  plan should
also   be  rehearsed  regularly  and   reviewed
periodically to ensure that it accounts for new or
changing site conditions or new information on
potential hazards at the site.

      When  preparing  an emergency  response
plan,  employer's need  not duplicate any  of  the
subjects that are addressed fully in the contingency
plan required under RCRA regulations, provided
that the contingency plan is incorporated into the
emergency  response plan.  Employer's  may also
incorporate  local emergency  response  plans or
state emergency response plans, or both, into the
emergency response plan, if appropriate.

       In lieu of preparing an emergency response
plan under 29 CFR 1910.120(p)(8), employers may
prepare an emergency action  plan in accordance
with 29 CFR 1910.38(a).  This plan may only be
developed in lieu of the emergency response plan
if employers plan to evacuate their employees from
the facility when an emergency occurs, and  not
permit  employees to assist in  responding to the
emergency.

       In addition  to  developing an  emergency
response plan,  employers must also address the
following items in their safety and health plan, as
appropriate:  the selection of engineering controls,
hazardous waste handling procedures, and uses of
new technologies.
                                                                      Training Requirements

                                                                      An employer must develop and
                                                                      implement a training program
                                                                      as part of the safety and health
                                                                      program,    for   employees
                                                                      engaged in  hazardous waste
                                                     operations at RCRA TSD facilities.  The worker
                                                     protection standards  reflect a tiered  approach to
                                                     training; the amount and type of training is linked
                                                     directly to an employee's potential for exposure to
                                                     hazardous substances and to other hazards during
                                                     a hazardous waste operation. The standards require
                                                     that   onfy   those  employees   that  have  been
                                                     appropriately trained may perform hazardous waste
                                                     operations or emergency response at a facility.  A
                                                     summary of the training requirements for workers
                                                 32

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engaged in hazardous waste operations at RCRA
TSD facilities is provided below. An overview of
the basic hourly  training requirements  is  also
provided in Exhibit 4.
              THE RULE IS:
      IF YOU ARE NOT TRAINED,
     YOU CANNOT PARTICIPATE
                  EXHIBIT 4
    Training Requirements for Employees at
             RCRA TSD Facilities
      (29 CFR  1910.120(p)(7) and p(8)(iii))
    General Site Employees
    Emergency Response
    Personnel
24   Hours   or
Equivalent  and  8
hours   of  annual
refresher training
Trained to a Level
of Competency  -
no specific  hourly
requirements
       The training requirements specified at 29
 CFR  1910.120(p)(7)(i)  for  all new  employees
 engaged in hazardous waste operations at RCRA
 TSD facilities include a  minimum of 24 hours of
 initial training.  The purpose of this training is to
 prepare employees  to "perform their  duties  and
 functions in a safe and healthful manner so as not
 to endanger other  employees."  The regulation
 does not specify what topics and issues should be
 covered during training.

       The initial training requirements  can be
 waived for current employees, if it is determined
 that their  prior work  experience  or  training  is
 equivalent to the initial training requirements  in
 the standard.   Equivalent training includes the
 training an employee may have already  received
 from  actual  site work  experience.

        In   addition  to  the  initial   training
 requirements,  all new  and  current  employees
 subject  to  the  worker  protection  standards,
 including managers and supervisors, must receive
 a minimum of eight hours of refresher  training
annually.  The purpose of refresher training is to
ensure   that   employees   maintain   certain
competencies. There are several ways to satisfy the
annual  refresher training  requirement,  such  as
attending applicable seminars or participating in a
critique of an actual response.

      The  training requirements  for  employees
who engage in emergency response  operations at a
RCRA TSD facility differ from the initial training
requirements specified  above;  there  are  no
specified hourly  requirements for either training or
refresher training  for emergency  responders at
RCRA TSD facilities. The training requirements
for emergency personnel are specified at 29 CFR
1910.120(p)(8)(iii)  and  require employees who
participate in emergency response  activities to be
familiar  with  the  elements  of the  emergency
response plan,   standard  operating  procedures
established for the response, and appropriate PPE.
Employees must also be  trained  to  a level of
competence in  the recognition  of various  health
and safety  hazards at the  facility.  Specifically,
training should include information on the safe use
of control equipment and the proper techniques of
coordination among parties   involved in the
incident.
                                             Medical Surveillance
                                             Requirements

                                             Employers  at  RCRA TSD
                                             facilities  must  provide   a
                                             medical  monitoring program
                                             for the following four  groups
                                             of employees:
                           •      Employees who wear a respirator for more
                                  than 30 days a year;

                           •      Hazardous Materials Specialists;

                           •      Members  of an organized and designated
                                  HAZMAT Team; and

                           •      Employees who exhibit signs or symptoms
                                  that may  have resulted  from exposure to
                                  hazardous substances during the  course of
                                  an emergency incident, either immediately
                                  or subsequently.

                           The medical  surveillance requirements  for these
                           four groups of employees are  identical to those
                           requirements outlined earlier in this Fact Sheet for
                           emergency responders without  regard to location
                                               33

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(pages 6 and 7).  The requirements for medical
examinations and recordkeeping for employees at
RCRA  TSD facilities are specified at 29 CFR
1910.120(p)(3).
protection
operations
to Exhibit
telephone
below.
       PART  3:     Sources   of
       Additional Information

       The   following  is  a  brief
       summary of where to obtain
       additional  information on the
       EPA  and  OSHA  worker
  standards   on   hazardous   waste
and emergency response.  Please refer
5  for the appropriate  addresses  and
numbers  of the  contacts referenced
       If you have questions regarding the existing
       relationship between EPA and OSHA with
       respect  to  the  implementation  of  the
       standards,   contact  the   Environmental
       Response Team (ERT) in Edison, NJ.

       For  information  about EPA's  training
       courses, contact ERTs Operations Section
       in Cincinnati, OH.

       For  information  on  guidance  on  the
       substance of 29 CFR 1910.120, contact the
       appropriate  OSHA Regional Office.   If
       additional information is needed, contact
       OSHA's Office of  Health  Compliance
       Assistance in  Washington, D.C.

       For  information on how  to establish a
       Hazmat Team,  refer to the Hazmat Team
       Planning Guidance Document (U.S. EPA,
       1990, Pub.  No. EPA/540/G-90/003).  This
       Document identifies equipment that may be
       necessary for an emergency response and
       suggests ways to acquire and maintain such
       equipment.   In addition,  the Document
       offers   guidance  in  determining  actual
       HAZMAT response requirements.

       To obtain  a copy  of the  Hazmat  Team
       Planning Guidance  Document, please call
       the National Technical Information Service
       at (703) 487-4600.  When requesting  the
       Document,   be certain  to  specify  the
       publication number.

       There are four other Fact Sheets that are
       available   on   the  worker  protection
     standards  for hazardous waste operations
     and emergency response:

           Hazardous  Waste  Operations  and
           Emergency   Response:      General
           Information  and Comparison  (Pub.
           No. 9285.2-09FS) explains the scope
           of the worker protection standards
           and  distinguishes  these  standards
           from   regulations  and consensus
           standards  covering  the  same  or
           similar subject matter.

           Hazardous   Waste  Operations  and
           Emergency Response:   Uncontrolled
           Hazardous  Waste Sites and RCRA
           Corrective Action (Pub. No. 9285.2-
           08FS)   explains    the   specific
           requirements   for   operations
           conducted at uncontrolled hazardous
           waste  sites,  including  corrective
           actions at RCRA TSD facilities.

           Establishing   Work  Zones   at
           Uncontrolled Hazardous Waste Sites
           (Pub. No. 9285.2-06FS) describes the
           requirements  and  procedures   for
           establishing   support   zones   at
           uncontrolled hazardous waste sites.

           Hazardous   Waste   Operations  and
           Emergency   Response:    Available
           Guidance (Pub. No. 9285.2-10FS)
           describes   guidance  materials
           developed   by  the  Environmental
           Response  Team to  help  workers
           engaged   in   hazardous   waste
           operations and emergency  response
            understand  the   HAZWOPER
            requirements.

      Copies  of  these  Fact  Sheets   may  be
obtained by calling or writing ERT in Edison,  NJ.
(Refer to Exhibit 5 for the appropriate address and
telephone  number.)  Please specify the  title and
publication number of the Fact Sheet(s).

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                                     EXHIBIT 5
                    Important Telephone Numbers and Addresses
      U.S. EPA/ERT
      2890 Woodbridge Avenue
      Building 18 (MS-101)
      Edison, NJ 08837-3679
      (908) 321-6740 or (FTS) 340-6740

      U.S. EPA/ERT
      Operations Section
      26 West Martin Luther King
      Cincinnati, OH 45268
      (513) 569-7537 or (FTS) 684-7537

•     U.S. Department of Labor, OSHA
      Office of Health Compliance Assistance
      200 Constitution Avenue, NW
      Washington, D.C.  20210
      (202) 523-8036 or (FTS) 523-8036

OSHA Regional Offices

•     U.S. Department of Labor, OSHA
      Region 1
      133 Portland Street, 1st Floor
      Boston, MA  02114
      (617) 565-7164 or (FTS) 835-7164

•     U.S. Department of Labor, OSHA
      Region 2
      201 Varick Street, Room 670
      New York, NY 10014
      (212) 337-2325 or (FTS) 660-2378

•     U.S. Department of Labor, OSHA
      Region 3
      Gateway Building, Suite 2100
      3535 Market Street
      Philadelphia, PA  19104
      (215) 596-1201 or (FTS) 596-1201

•     U.S. Department of Labor, OSHA
      Region 4
      1375 Peachtree Street, NE, Suite 587
      Atlanta, GA  30367
      (404) 347-3573 or (FTS) 257-3573
•     U.S. Department of Labor, OSHA
      Region 5
      230 South Dearborn Street
      32nd Floor, Room 3244
      Chicago, IL  60604
      (312) 353-2220 or (FTS) 353-2220

•     U.S. Department of Labor, OSHA
      Region 6
      525 Griffin Street, Room 602
      Dallas, TX 75202
      (214) 767-4731 or (FTS) 729-4731

•     U.S. Department of Labor, OSHA
      Region 7
      911 Walnut Street
      Kansas City, MO 64106
      (816) 426-5861 or (FTS) 867-5861

•     U.S. Department of Labor, OSHA
      Region 8
      1951 Stout Street
      Denver, CO 80204
      (303) 844-3061 or (FTS) 564-3061

•     U.S. Department of Labor, OSHA
      Region 9
      71 Stevenson Street, Suite 415
      San Francisco, CA 94105
      (415) 744-6670 or (FTS) 484-6670

•     U.S. Department of Labor, OSHA
      Region 10
      1111 Third Avenue, Suite 715
      Seattle, WA 98101-3212
      (206) 442-5930 or (FTS) 399-5930

EPA Regional Offices

 •     U.S. Environmental Protection Agency
      Region 1
      John F. Kennedy Federal Building
      Room 2203
      Boston, MA 02203
      (617) 565-3715 or (FTS) 835-3715
                                         35

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                                EXHIBIT 5 (continued)
                     Important Telephone Numbers and Addresses
EPA Regional Offices (continued)
      U.S. Environmental Protection Agency
      Region 2
      Jacob K. Javitz Federal Building
      26 Federal Plaza
      New York, NY  10278
      (212) 264-2657 or (FTS) 264-2657

      U.S. Environmental Protection Agency
      Region 3
      841 Chestnut Building
      Philadelphia, PA 19107
      (215) 597-9800 or (FTS) 597-9800

      U.S. Environmental Protection Agency
      Region 4
      345 Courtland Street, NE
      Atlanta, GA 30365
      (404) 347-4727 or (FTS) 257-4727

      U.S. Environmental Protection Agency
      Region 5
      230 South Dearborn Street
      Chicago, IL  60604
      (312) 353-2000 or (FTS) 353-2000

      U.S. Environmental Protection Agency
      Region 6
      1445 Ross Avenue, 9th Floor
      Dallas, TX  75202
      (214) 655-6444 or (FTS) 255-6444

      U.S. Environmental Protection Agency
      Region 7
      726 Minnesota Avenue
      Kansas City, KS 66115
      (913) 551-7000 or (FTS) 276-7000
U.S. Environmental Protection Agency
Region 8
999 18th Street, Suite 500
Denver, CO  80202-2405
(303) 293-1603 or (FTS) 293-1603

U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA  94105
(415) 556-6322 or (FTS) 556-6322

U.S. Environmental Protection Agency
Region  10
1200 6th Avenue
Seattle,  WA 98101
(206) 442-1200 or (FTS) 399-1200

Call the Emergency Planning and
Community Right-to-Know Information
Hotline for the addresses and telephone
numbers of state emergency response
commissions and local emergency planning
committees in your area. The  telephone
numbers for the Hotline are: toll-free
800-535-7672, or 202-475-9652 in the
Washington, D.C. area.
                                              36

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                     SECTION 3

            QUICK REFERENCE FACT SHEETS

                      PART 4

HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
        UNCONTROLLED HAZARDOUS WASTE SITES
            AND RCRA CORRECTIVE ACTIONS
                        37

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&EPA
                      United States
                      Environmental Protection
                      Agency
                         Office of
                         Solid Waste and
                         Emergency Response
Publication 9285 2-08FS
April 1991
Hazardous  Waste  Operations
and  Emergency  Response:
Uncontrolled Hazardous Waste Sites
and RCRA Corrective Actions
 Office of Emergency and Remedial Response
 Emergency Response Division     MS-101
                                             Quick Reference Fact Sheet
INTRODUCTION
                Under the authority of section
                126 of the Superfund Amend-
                ments and Reauthorization Act
                of  1986  (SARA), the U.S.
                Environmental   Protection
                Agency  (EPA)  and  the U.S.
                Occupational   Safety   and
Health  Administration  (OSHA)  promulgated
identical health and safety standards to protect
workers engaged in hazardous waste operations
and emergency response. The OSHA regulations,
codified at 29 CFR 1910.120, became effective on
March 6,  1990 (54 FR 9294). Corrections to the
OSHA  regulations were published on April  13,
1990 (55 FR 14072).   The  EPA  regulations,
published on June 23,  1989  at 54 FR  26654,
incorporate the OSHA standards by reference and
are codified at 40 CFR 311.

     The EPA and OSHA worker protection
standards for  hazardous waste operations  and
emergency response (HAZWOPER) apply to three
primary groups of workers: (1) employees engaged
in  voluntary   and mandatory  clean-ups  at
uncontrolled  hazardous waste sites,  including
corrective actions at  treatment, storage,  and
disposal  (TSD)  facilities  regulated under  the
Resource  Conservation  and  Recovery  Act
(RCRA); (2) employees  engaged  in  routine
hazardous waste   operations  at  RCRA TSD
facilities; and (3) employees engaged in emergency
response operations without regard to location.

      The purpose of this Fact Sheet is to explain
the principle requirements of the EPA and OSHA
worker protection standards  as they  apply to
employees engaged in hazardous waste operations
at uncontrolled hazardous waste sites,  including
                        employees  who  perform  corrective  actions at
                        RCRA TSD facilities.  The other two groups of
                        employees  affected  by   the  regulations  are
                        addressed  in  a  separate  Fact Sheet  entitled
                        Hazardous  Waste  Operations  and  Emergency
                        Response:  RCRA TSD and Emergency Response
                        Without   Regard   to   Location  (Publication
                        No. 9285.2-07FS). The requirements that apply to
                        individuals engaged in hazardous waste operations
                        at RCRA TSD facilities and emergency responders
                        who respond to  emergencies without regard to
                        location are specified at 29 CFR 1910.120(p) and
                        (q), respectively.

                              The   HAZWOPER  requirements   for
                        workers who engage in hazardous waste operations
                        and emergency response at uncontrolled hazardous
                        waste  sites are specified at 29  CFR I910.120(a)
                        through  (o),  and are summarized  in Exhibit  1,
                        these  requirements also apply  to those workers
                        who perform corrective actions at RCRA TSD
                        facilities.    These requirements apply  to any
                        employee working  at  an uncontrolled hazardous
                        waste  site who has  the potential to be exposed to
                        hazardous  substances.   As such, the On-Scene
                        Coordinator  (OSC) and  me  Remedial  Project
                        Manager (RPM) are both covered by the standards
                        and must fully implement the standards for other
                        employees engaged in hazardous waste sue clean-
                        ups. These provisions also apply to any activities
                        performed during the preliminary  planning and
                        evaluation stages of the remedial investigation and
                        feasibility study (RI/FS), such as the preliminary
                        assessment and site investigation (PA/SI)

                              In sum, all stages of a removal and remedial
                        operation performed at a site in which there is a
                        potential for exposure to  hazardous substances
                        must be conducted in accordance with the worker
                        protection  standards  specified  at  29  CFR
                                          39

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                 EXHIBIT 1
      Hazardous Waste Operations and
     Emergency Response at Uncontrolled
           Hazardous Waste Sites
          (29 CFR 1910.L20(a)-(o))
   (a)  Scope, application, and definitions

   (b)  Safety and health program

   (c)  Site characterization and analysis

   (d)  Site control

   (e)  Training.

   (f)  Medical surveillance

   (g)  Engineering controls, work practices, and
       personal protective equipment for employee
       protection.

   (h)  Monitoring

   (i)  Informational programs

   (j)  Handling drums and containers.

   (k)  Decontamination.

   (1)  Emergency response by employees at
       uncontrolled hazardous waste sues.

   (m) Illumination.

   (n)  Sanitation at temporary workplaces.

   (o)  New technology programs
1910.120(a) through (o). The standards, however,
do not apply to employees who do not have the
potential to be exposed to hazardous substances.
For example, administrative support personnel  in
the Incident Command Post may not be covered  by
HAZWOPER.  These employees, however, must
be made aware of the provisions of the emergency
response plan.  Specifically, they must be briefed
on the procedures to take during an emergency a,t
the site, and they must be familiar with general site
operations, such as the location  of work zones.
Employees not  covered by HAZWOPER are,  of
course,  protected   by  other  OSHA  standards
including  the  Hazard  Communication Standard
(HAZCOM).
      In addition to the requirements specified at
29 CFR 1910.120(a) through (o),  other  worker
protection   requirements   may   also  apply  at
uncontrolled hazardous waste sites  For example,
29 CFR 1910.120(q) applies to  workers, such as
local HAZMAT team members, who come on-sitc
specifically  to  perform   emergency  response
operations.  The  requirements  specified  at  (q),
however, do not apply to regular site employees
who perform  routine clean-up operations at  the
site and who may also perform emergency response
operations;  these  individuals are covered  by  the
requirements in 29 CFR 1910.120(e)

      This  Fact Sheet is divided  into SLX parts.
The  first   three  parts  describe  the  planning,
training, and medical surveillance requirements for
workers engaged  in hazardous  waste operations
and emergency response at uncontrolled hazardous
waste sites.  The  fourth part of this  Fact Sheet
discusses other requirements of HAZWOPER that
must be implemented at  uncontrolled hazardous
waste sites.  The  fifth part  of this  Fact Sheet
discusses employee rights under section 8 of the
Occupational  Safety and  Health Act of  1970, as
amended (OSH Act).  The  final part of this Faci
Sheet provides important addresses and telephone
numbers.

                   PART I:  PLANNING
                   REQUIREMENTS

                   Part   1  of  this  Fact  Sheet
                   explains  the purpose  of the
                   comprehensive    safety   and
                   health  program and the site-
 specific health and safety plan (HASP); describes
 the specific steps  that must be taken to develop a
 HASP; explains the type of information that must
 be included  in the HASP; and summarizes the
 responsibilities  of the  OSC,  RPM,  and  the
 Environmental   Response   Team   (ERT)   in
 developing a  HASP at an EPA-lead site.

        There are many different types of entities,
 including state agencies, private corporations, and
 the  federal  government,  that may  have  lead
 responsibility  in  cleaning  up  an  uncontrolled
 hazardous  waste site or a contaminated RCRA
 TSD facility.   Each of these entities uses different
 titles  to  identify  the  person  who  has overall
 responsibility for  site activities. For purposes of
 this Fact Sheet, this responsible person is referred
 to as the OSC/RPM, as it is at EPA-lead sites.
                                                   40

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Safety and Health Program

      Any  employer whose workers engage  in
hazardous   waste   operations  and  emergency
response at an uncontrolled hazardous waste site
or who perform corrective actions at a RCRA TSD
facility  must develop and implement a written
safety and health program.  This program must  be
designed to identify, evaluate, and control  safety
and health hazards at any site, and to provide for
emergency response during site operations.  The
written  safety and health program must include  an
organizational structure; a site-specific health and
safety plan (HASP); a comprehensive workplan; a
medical surveillance program; and a description of
the employer's standard operating procedures. For
a  complete list of  the elements required  in the
written  safety and health program, refer to 29 CFR
       The  primary purpose  of  the safety  and
health program is  to serve as the organization's
comprehensive health and safety policy that applies
to all  employees of the  company, irrespective of
the  location of  the actual site where they are
working.  This program must be maintained by the
employer and made available to any employee or
employee representative; contractor, subcontractor,
or other representative working for the employer
who  will be potentially exposed  to  hazardous
substances;  OSHA  personnel;  and personnel of
federal, state, and  local  agencies with regulatory
authority over the site. It is important to note that
only one safety  and health program  should be
developed by an employer, even  if the employer
has  workers that perform  operations at several
different sites.

       If  an employer has already developed a
safety  and  health  program  to   meet   the
requirements of other  federal, state, and  -local
regulations, the  employer  may use the  existing
program to  satisfy the HAZWOPER requirements,
so long as any additional information not covered
in   the  existing  program but  required  under
HAZWOPER is incorporated into the program.

Site-Specific  HASP

       Although the standards require employers
 to  develop and  implement only  one safety and
 health program,  a site-specific  HASP  must be
 developed  and implemented for each site where
workers  are potentially  exposed  to hazardous
 substances.
      The purpose of the site-specific HASP is to
address  the safety  and  health  hazards  that may
exist  at  each phase of site operations and  to
identify  procedures  for  protecting  employees.
Exhibit  2  presents  a comprehensive list of the
elements that must be included in the HASP.

       Information   gained   during   the   site
characterization,  as   specified   at   29   CFR
1910.120(c), must be considered in developing the
HASP.  The site characterization  may be divided
into three stages:   preliminary evaluation (PE),
initial site entry, and ongoing monitoring. Under
the requirements of 29 CFR 1910.120(b)(4), the
HASP must  be  developed after the PE has been
performed  and  before  any site entry.   The
following is a brief discussion of the specific steps
that must be taken to develop,  implement, and
maintain  a HASP.

Step 1:  Preliminary Evaluation

       The first step in developing a  HASP is to
perform a preliminary evaluation (PE) of the site's
characteristics.  The PE must be accomplished off-
site, so  as not to endanger the health and safety of
site workers.   The purpose of the  PE is to obtain
preliminary  information  to help  identify the
specific  hazards at the  site  and determine the
appropriate  safety  and  health control  procedures
(e.g., engineering  controls, personal  protective
equipment (PPE),  and  any additional medical
surveillance needs) that are necessary to ensure the
protection of employees who perform tasks on-site
The  specific  information that must  be obtained
during  the PE is summarized below and outlined
in Exhibit 3.  The information obtained during the
PE should be used to develop the HASP

       There are   several  ways  in  which the
information  specified in Exhibit 3 can be obtained.
For example, records of the sue or interviews with
persons who are knowledgeable about the sue can
 provide  useful  information about the  potential
 hazards at a site.   Potentially useful sources of
 information include:   company records, receipts,
 logbooks, or ledgers that describe sue  activities,
 records from state and federal pollution control
 regulatory and enforcement agencies  and state
 occupational and  health offices;  local fire and
 police department records;  site photos, and media
 reports.

        In addition to interviewing knowledgeable
 persons  and researching the history of the sue,
                                              41

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                 EXHIBIT 2
          The Specific Components
                 of a HASP
     Key personnel.

     Safety and health risk or hazards analysis
     for each site task and operation found in
     the workplan.

     Employee training assignments to assure
     that each employee receives the training
     required  before  they engage in any
     operation that could potentially lead to
     exposure to a hazardous substance or to
     safety or  health  hazards

     Personal  protective equipment appropriate
     for each site task or operation conducted

     Medical surveillance requirements

     Employee and air monitoring equipment
     and environmental sampling techniques  and
     instrumentation to be used.

     Site control measures that include at a
      minimum - a site map, a buddy system, site
     communications system  (including
      emergency alerting), standard operating
      procedures or safe work practices, and
      identification of the nearest medical
      assistance.

      Decontamination procedures both for
      individuals and  equipment on site and in
      places where there is a potential for
      exposure to a hazardous substance.

      An emergency  response plan for safe and
      effective responses to emergencies.

      Confined space entry procedures.

      A spill containment program to contain and
      isolate the entire volume of any hazardous
      substance spilled in the course of a transfer.

      Hazard  communications plan (29 CFR
       1910.12CO and 29 CFR 1926.59).
data-gathering at the site perimeter (i.e., perimeter
reconnaissance)  may  help  in  identifying  site
hazards and potential pathways for exposure, and
determining the  appropriate level  of PPE for the
initial site entry.  Perimeter reconnaissance activities
during the PE  must be  conducted off-site.   To
identify the appropriate sampling techniques for
perimeter  reconnaissance,  the  safety and  health
officer should  review  the  information obtained
during the records/interview research.   The most
important   thing  to  remember  is   that   the
OSC/RPM  must  not,  under any circumstances,
allow  a  worker  to  enter the  site  to   collect
information for the PE.
        THE PE MUST BE COMPLETED
                    PRIOR TO
         ANYONE ENTERING THE SITE
Step 2  Developing (he HASP

       Once  the  PE  is  completed   and  the
appropriate   information   is   obtained,   the
OSC/RPM at the site must use the information
gathered during the PE to develop the initial draft
of the site-specific HASP.  The initial draft of the
HASP  must include all elements listed  in  Exhibit
2.  Specifically, it must identify  each anticipated
safety and health hazard for each work operation
or activity, and describe how those hazards will be
eliminated or controlled.   In addition,  the HASP
should identify appropriate monitoring procedures
and PPE for the initial site entry. The HASP must
 remain on-sive at ail limes and only one  HASP
 should be developed for each site.
           NO ONE MAY ENTER THE
       SITE UNTIL THE HASP HAS BEEN
        DEVELOPED, APPROVED, AND
                IMPLEMENTED
 Step 3: Initial Site Entry

        Once  the  HASP   is  developed  and
 implemented,  the second  stage  of  the  site
 characterization  and analysis (i.e., the initial site
 entry) may begin.  The purpose of the initial site
 entry  is  to  gather  additional  information and
 further evaluate the site's specific characteristics to
 identify and confirm existing site  hazards and to
 aid  in the selection  of appropriate engineering
 controls and  PPE.

         At a minimum, activities during the initial
 site entry should consist  of a  visual survey for
                                                 42

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                  EXHIBIT 3
          Specific Components of the
            Preliminary Evaluation
           (29 CFR 1910.120(c)(4))
          Site location and size
          Description of response activity and/or
          the job to be performed
          Duration of the planned activity.
          Site topography and accessibility by air
          and roads.
          Safety and health hazards expected ai
          the site.
          Pathways for hazardous substance
          dispersion.
          Present status and capabilities of
          emergency response teams thai would
          provide assistance for on-site
          emergencies.
          Hazardous substances and health
          hazards involved or expected at the
          site, and the chemical and physical
          properties of these substances.
potential hazards and, when there is potential for
exposure, air monitoring.  Multi-media sampling
should also be  performed if  the  OSC/RPM  has
reason to  believe that contamination may have
occurred.

       An  accurate and  comprehensive  visual
survey of  the site will  assist  the OSC/RPM in
identifying  and  determining  what  additional
information (e.g., sampling of soil or containers)
may be needed.  This visual survey could include
noting the condition of waste containers (e.g.,
undamaged  or  rusted);   noting  any  unusual
conditions; and determining potential pathways for
exposure.

       When  entering  the site,  entry personnel
should  monitor  the air  using  direct  reading
instruments for  immediately dangerous to life and
health (IDLH)  conditions (e.g., combustable or
explosive  atmospheres,  oxygen deficiency^  toxic
substances)  and  for ionizing  radiation.   Such
monitoring, however, need only be conducted if the
PE produces information that  indicates (1) existing
IDLH conditions, or (2) the potential for ionizing
radiation,  or if the  information  from the PE is
insufficient to reasonably conclude that neither of
these  two conditions exists.   When monitoring,
entry personnel should look for signs of actual or
potential  IDLH  hazards or  other  dangerous
conditions.   Examples  of hazards that  may  be
identified at a site include confined space entry,
visible  vapor  clouds,   or areas  that  contain
biological indicators such as dead vegetation. The
specific monitoring requirements for  initial site
entry are specified at 29 CFR  19l0.120(c)(6) and
       In addition to air monitoring, multi-media
sampling should be performed during the initial
site entry, if the OSC/RPM believes contamination
may exist.  The soil sampling techniques employed
will  differ with each site.  Prior to beginning site
activities, it is imperative that the purpose of the
effort  and the  ultimate use  of the  data  be
established.  Specific strategies should be selected
based on the information required

       One important goal of the initial site entry
is to identify the risks and hazards at  the site so
that the work zones can be established. The three
most frequently identified zones are the Exclusion
Zone, the Contamination Reduction Zone, and the
Support Zone (also known  as the Clean Zone).
The Support Zone should be an area of the site
that is free from contamination and that may safely
be used as a staging area for other hazardous waste
operations at the site.  For additional information
and guidance  on how to designate work zones,
consult  the Fact Sheet entitled Establishing Work
Zones  at  Uncontrolled  Hazardous Waste Sites
(Publication No. 9285.2-06FS).

       Any information concerning the chemical,
physical, and toxicological properties of hazardous
substances identified  during the initial site entry
must be made available to employees prior to the
commencement of operations at the site.
       INITIAL SITE ENTRY ACTIVITIES
     MUST, AT A MINIMUM, INCLUDE A
     VISUAL SURVEY AND, WHEN THERE
       IS POTENTIAL FOR EXPOSURE,
               AIR MONITORING
 Step 4:  Update the HASP

        Once the initial site entry is completed, the
 OSC/RPM is responsible for updating the HASP
 to ensure  that  it adequately identifies any new
                                              43

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tasks or hazards at the site.  At most sites, any air
and multi-media sampling performed during the
initial site entry will provide the OSC/RPM with
more    accurate  information   regarding   the
appropriate  level of  PPE  to be  worn  by site
employees and the  proper designation of work
zones.
      UPDATE THE HASP AFTER
      THE INITIAL SITE ENTRY
Step 5:  On-Going Site Activities

       Once the HASP is  revised  to  reflect the
information gathered during the initial site entry,
on-going  monitoring  must occur at the site to
ensure  that all  new hazards are  identified in a
timely manner and that the appropriate controls
are implemented to protect site employees.

       If new  tasks or  hazards are  identified at a
site, do not develop a new HASP; instead, update
 the original HASP. If a subcontractor is working
 at  a  site,  the  subcontractor should  carefully
 evaluate and identify all tasks  associated with the
 subcontracted activities, and prepare a health and
 safety plan addressing any identified hazards. This
 plan should be  submitted to the OSC/RPM who
 will incorporate it  into the general site  HASP after
 it has been reviewed for concurrence with the site
 workplan.
               THE RULE IS:
          ONE  SITE, ONE HASP
        When developing a  HASP, be careful to
 ensure that all required information as specified at
 29  CFR  1910.120(b)(4)(ii)  is addressed in the
 HASP.  The remainder of this part of  the Fact
 Sheet will explain the specific elements that must
 be included in the HASP.

 Elements of the HASP

        The information that must be included in
  the   HASP    is   specified   at   29   CFR
  19l0.120(b)(4)(ii) and summarized  in Exhibit 2.
  Some of the areas that must be addressed in the
  HASP, such  as the  employer's monitoring and
decontamination programs, are discussed in further
detail below.  In addition to the elements specified
at 29 CFR  1910.120(b)(4)(ii),  the  HASP  must
identify   key   personnel    and   HAZCOM
requirements and provide for prc-entry briefings to
be held before  site  activity is  initiated.   These
meetings should be held at any time they appear
necessary to ensure that employees are adequately
apprised of the safety and health procedures being
followed at the  site.

Monitoring program (29 CFR I910.120(h)).  The
OSC/RPM's proposed  monitoring program must
be  included in  the  HASP   The  monitoring
program must include procedures for initial entry
monitoring, periodic monitoring,  and monitoring
of  high  risk   employees.     The   monitoring
requirements for initial site  entry are specified  at
29  CFR   1910.120(c)(6)  and (h)(2) and are
discussed  in detail on p. 5.

       In  general, monitoring must  be performed
whenever there is any possibility that employees
may  be exposed to hazardous substances   The
purpose of monitoring is to ensure that the proper
engineering controls, work practices, and PPE are
used  to protect  employees at the site.

       Periodic  monitoring  should  be conducted
whenever there is any indication that exposures
 have risen above the permissible exposure limits
 (PELs), or  other dangerous conditions exist such
 as  the presence  of flammable  atmospheres  or
 environments   that   are   oxygen-deficient.
 Monitoring  of high  risk  employees  should  be
 conducted on those employees suspected of having
 the highest exposures to hazardous substances and
 health hazards.

       In addition to the monitoring requirements
 specified in 29 CFR 1910.120,  there are other
 applicable OSHA standards, specifically Subpart Z,
 29 CFR 1910.1000, that  refer to  particular  air
 sampling and monitoring procedures for chemical
 contaminants.  These standards also specify certain
  PPE and recordkeeping requirements for a variety
 of  compounds.    The  compounds  and  their
  accompanying regulations are listed in Exhibit 4.

  SUe  control program (29 CFR  1910.120(d)). The
  site  control program in  the  HASP  specifies  the
  procedures that will be used to minimize employee
  exposure to hazardous substances before clean-up
  operations commence and  during site operations.
  The  site  control  program  must   be developed
                                                 44

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EXHIBIT 4
Toxic and Hazardous Substances
Subpart Z, 29 CFR 1910.1000
Compound
Asbestos
Coal tar pitch volatiles
4-nitrobiphenyl
Alpha-Naphthylamme
Methyl chloromethyl ether
3,3'-dichlorobenzidine
bis-chloromethyl ether
Benzidme
4-ammodiphenyl
Ethyleneimine
beta-propiolactone
2-acetylaminofluorene
4-dimeihyiarmnoazo-
benzene
N-nitrosodimethylamine
Vinyl chloride
Inorganic arsenic
Lead
Benzene
Coke oven emissions
l,2-dibromo-3-chloro
propane
Acrylonitrile
Ethylene oxide
Formaldehyde
OSHA Reference
29 CFR 1910.1001
29 CFR 1910.1002
29 CFR 1910.1003
29 CFR 1910.1004
29 CFR 1910.1006
29 CFR 1910.1007
29 CFR 1910.1008
29 CFR 1910.1010
29 CFR 19101011
29 CFR 1910.1012
29 CFR 1910.1013
29 CFR 1910.1014
29 CFR 1910.1015
29 CFR 1910.1016
29 CFR 1910.1017
29 CFR 1910.1018
29 CFR 1910.1025
29 CFR 1910.1028
29 CFR 1910.1029
29 CFR 1910.1044
29 CFR 1910.1045
29 CFR 1910.1047
29 CFR 1910.1048
during the planning stages of a hazardous waste
clean-up operation, and must be modified as any
new information  becomes  available.   The site
control program must, at a  minimum, include  a
site   map,   work    zones,   communications,
identification of the nearest medical assistance, and
safe work practices.

       Engineering  controls  and  safe  work
practices  must  be specified in the site  control
program to protect  employees from exposure to
hazardous substances and other safety and health
hazards. Engineering controls and work practices
should be implemented  to  reduce and maintain
employee exposure to  levels at or below the PELs
for  those  hazardous  substances  at   the  site.
Examples of engineering controls that may be used
include pressurized cabins and control booths on
equipment. If, for whatever reason, it is not possible
to maintain employee exposure to levels at or below
PELs, technical assistance should be obtained from
other sources before proceeding with site activities
(e.g., ERT or OSHA).

       PPE  should be  used as a last resort  to
protect employees against  possible  exposure  to
hazardous substances. It should only be used when
engineering  controls  and  work practices  arc
insufficient to adequately protect against exposure.
'Hie PPE used at the site must be reflective of the
potential site hazards  identified during the PE and
initial  site characterization

Decontamination program (29 CFR 1910.120(k)).
The  decontamination   procedures   should   be
developed and  appropriately communicated to all
employees before they enter a site where potential
for exposure to hazardous substances exists.  The
OSC/RPM   must   develop   and   include
decontamination  procedures  in  the  HASP that
identify standard operating procedures at the sue,
such  procedures should provide employees with
information on how to minimize their contact with
hazardous   substances.     In   addition,   the
decontamination program must include procedures
for employees  who leave a  contaminated  area on
the site. Such employees must be decontaminated
and their equipment  must  be disposed of or
decontaminated.     The   requirements  for  a
decontamination program are codified at  29 CFR
 I910.120(k).

Emergency response plan (29 CFR 1910.120(1)). One
of the most important components of the HASP is
 the written site-specific emergency response plan.
This   plan  must  include  a description  of  how
 anticipated emergencies would  be handled at  the
site and how the risks  associated with a  response
would be minimized. The emergency response plan
 must  be  developed  and  implemented  prior  to
 commencing operations at a site.

       The  requirements   for  an  emergency
 response plan  at an uncontrolled hazardous waste
 site are summarized  in Exhibit 5 and are codified
 at 29  CFR 1910.120(1)(2)

        In   addition   to   these  elements,   the
 emergency response plan must include information
 relevant  for conducting emergency  operations at
 the site,  such  as  information on site topography,
 layout,  and prevailing weather  conditions, and
 procedures  for reporting incidents to local, state,
 and  federal agencies.   The emergency  response
 plan must also be rehearsed regularly and reviewed
 periodically to ensure  that it accounts for new or
                                               45

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                 EXHIBIT 5
           Required Elements of an
        Emergency Response Plan at an
      Uncontrolled Hazardous Waste Site
           (29 CFR 1910.120(1)(2))
      Pre-emergency planning.
      Personnel roles, lines of authority, and
      communication.
      Emergency recognition and prevention.
      Safe distances and places of refuge.
      Site security and control.
      Evacuation routes and procedures.
      Decontamination procedures.
      Emergency medical treatment and first aid
      Emergency alerting and response
      procedures.
      Critique of response and follow-up
      PPE and emergency equipment.
changing site conditions or new information on
potential hazards at the site.

      In lieu of preparing an emergency response
plan, OSC/RPMs may prepare an emergency action
pjan in accordance with 29 CFR 1910.38(a).  This
plan  may  only be  developed  in  lieu  of  the
emergency  response   plan  if  employees   are
evacuated from the site when an emergency occurs,
and are not permitted to assist in responding to
the  emergency.    An  emergency action  plan
includes  an  evacuation plan  in  which  persons
responsible for an  orderly exit  are  identified.
These designated individuals will direct employees
to leave the site, maintain a safe distance, and call
the appropriate emergency response organization.

       If an  emergency  action plan  is prepared,
arrangements  must  be  made  with  the  local
response community (e.g., fire department or other
local response services) for them to  respond to
emergencies that may occur during site operations.
The local  response community must be provided
with  sufficient information  on  site activities,
including the types of operations being conducted
at the site, the type and degree of contamination'at
the site, the location of work zones, and any other
relevant information  that may be  necessary for an
appropriate response.  Such information must be
 provided  prior to  the commencement  of site
 operations.  Regardless of whether an emergency
 action  plan or an   emergency response plan  is
prepared, local response officials must be notified of
site operations prior to the commencement of any
site activities.

Spill   containment   program   (29   CFR
I910.120(j)(l)(viii)).  In the event of a major spill
or a release on-site, the spill containment program
must  be implemented to contain and isolate the
hazardous substance release.

Responsibilities  of the OSC/RPM

       The OSC/RPM is responsible for reviewing
the HASP for consistency with the  workplan and
accepting the HASP for the site. The HASP  must
accurately reflect the work being performed at the
site, and  must be reviewed and approved again
when any additions or revisions are made to the
HASP throughout the course of work at the site.

       The  OSC/RPM  is also  responsible  for
ensuring that  employees are adequately informed
of the  procedures to  report a health and safety
violation, as well  as the procedures  for filing a
workman's  compensation  report.    Specifically,
employees should  be told that a health and safety
complaint may be made either  in writing  or
verbally,  and  that  such complaints should  be
addressed to the OSC/RPM, the contractor's health
and safety officer, and the EPA contract officer.
The OSC/RPM should also ensure  that workman
compensation  forms are available  on-site.   For
additional information on employee rights, refer to
Part  5 of this Fact Sheet.

Role of the Environmental  Response  Team
 (ERT)

        If additional guidance is needed or desired,
 the OSC/RPM may submit the HASP to ERT for
 review or may request a site audit.  It is important
 to note that ERT does not approve HASPs; ERT
 will    only   review   them  and   provide
 recommendations. As soon as the HASP has been
 accepted by the OSC/RPM, covered operations at
 the  site   may   commence;   a plan   may  be
 implemented without ERT concurrence.

        In  general,  it is the Agency's policy to
 encourage the development of an effective HASP
 and  to  assist the  Regions  with  the  task  of
 reviewing and processing HASPs.  As such, ERT
 will  provide  consultation and  assistance if such
 assistance is requested. For further  information on
 ERT assistance,  contact the OSWER Health  and
 Safety Manager in ERT in Edison, New Jersey, at
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(FTS)  340-6740  or  (908) 321-6740.  Regional
Health and Safety Officers may also be available
for  plan  review and  consultation.  Refer  to your
Regional directory for the relevant addresses and
telephone numbers.
                  PART 2:  TRAINING
                  REQUIREMENTS

                  This part of  the  Fact  Sheet
                  addresses  the  HAZWOPER
                  training   requirements   that
                  apply to employees engaged in
hazardous   waste  operations   and  emergency
response at uncontrolled hazardous waste sites and
employees  who  perform  corrective  actions  at
RCRA TSD facilities.

General Training Requirements

       Each  employer at a site is responsible for
ensuring   that  their  respective  employees  are
properly   trained   and   equipped   prior   to
commencing work  at a site.  The HAZWOPER
training required for site workers  must identify the
hazards present on-site, the medical  surveillance
requirements, certain elements of the HASP, and
operating  practices and procedures, including the
use of PPE and proper engineering controls. The
specific issues and  topics that are required to be
addressed  during training are specified at 29 CFR
 19l0.120(e)(2). The amount of training required
for site workers is linked directly  to an employee's
potential for exposure to hazardous substances and
to other health hazards at the site, and is specified
at 29 CFR 1910.120(e)(3) and (4). Employees may
not participate in or supervise any-site activity until
they have been adequately trained.

       The HAZWOPER standards specify hourly
 requirements for four different categories  of site
workers.   The amount of training a worker must
 receive  is commensurate  with  the  employee's
 potential   for  exposure;   the  hourly training
 requirements  are  described briefly  below  and
 summarized in Exhibit 6.

        General site  workers at  an  uncontrolled
 hazardous waste site include equipment operators
 and general laborers engaged in routine hazardous
 waste removal.  These routine site workers must
 have a minimum of 40 hours of instruction off-site
 and   24   hours  of field  experience  under  the
 supervision  of   a   trained  and  experienced
 supervisor.
EXHIBIT 6
Initial Training Requirements for
Employees at Uncontrolled
Hazardous Waste Sites
(29 CFR
Routine Site 40
Employees 24
Occasional 24
Employees and 8
Routine Site
Employees Unlikely
to be Exposed
Above PELs
Supervisors 8
Sue Employees
Assigned Site
Emergency
Response
Duties
All Sue 8
Workers
1910.120(e))
Hours Off-Site
Hours Field Experience
Hours Off-Sue
Hours Field Experience

Hours of Specialized
Training, in addition to
the Requirements for
the Employees they
Supervise
Trained to a Ixvel
of Competency in
Addition to above
Requirements
Hours Annual
Refresher Training
      Workers who are on-site only occasionally
to perform  a  specific  job, such as groundwater
monitoring,  and who are  unlikely  to be exposed
over PELs, are required to have a minimum of 24
hours of instruction off-site  and a minimum of
eight hours of supervised field experience.

      Routine site workers who  work only in
areas where the exposure levels are  monitored and
determined to be below PELs are also required to
receive 24 hours of instruction off-site and 8 hours
of supervised field experience.

      Supervisors   of  the   three  groups  of
employees described above are required to  receive
the  same amount of initial  training  and  field
experience as  the employees they supervise, plus 8
additional  hours  of  specialized  training  in
managing  hazardous  waste  operations.     For
example, if  a  supervisor only manages employees
who work on site occasionally, the supervisor must
                                                47

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have a minimum of 24 hours of instruction off-site
and 8 hours of supervised field experience, plus an
additional eight hours of specialized management
training.

      In addition to the requirements listed above,
any worker who receives 24 hours of training and
who then becomes a general site worker or whose
job function  requires that a respirator be worn,
must have an additional 16  hours  of  instruction
off-site and 16 hours of supervised field experience
before commencing the new duties  at the site.

      Some of the training requirements specified
above may be waived if the employee has had prior
work experience or training.  For example, certain
training  requirements   may  be waived if  the
employee  has  had  experience  working  at an
uncontrolled  hazardous  waste  site  or if  the
employee  has  participated  in  training courses
offered  by independent  and  federal organizations
(e.g., EPA).    If  the employer  believes that an
employee  has  sufficient  prior  experience or
training  to waive  some or all of the HAZWOPER
training   requirements,  the   employer   must
document the basis for his belief, denoting length
and type of experience or training.

       Although  there are no specific additional
 training   requirements   for   employees   with
 emergency   response  duties  at  a  site,   such
 employees must be trained commensurate with the
 duties that will be assumed.

 Refresher Training

       All  employees  who  perform  clean-up
 operations at uncontrolled hazardous waste sites,
 including managers and supervisors,  must  receive
 a  minimum of  eight  hours of annual refresher
 training.  The purpose of refresher training is to
 maintain certain competencies.  There are several
 ways  to  satisfy  the  annual  refresher training
 requirement. For example, as explained on p. 7 of
 this Fact  Sheet, the emergency response plan of
 the HASP must be rehearsed  regularly.   These
 rehearsals can be used to  meet some of the annual
 refresher  training requirements.  Attendance  at
 applicable  seminars   and   critiques   of  actual
 responses are also acceptable methods of satisfying
 the annual refresher training requirements. Proper
 documentation of attendance, however, should be
 maintained.
Training Accreditation

      On January 26,  1990, OSHA published a
Notice of Proposed Rulemakmg (NPRM) (55 FR
2776) that proposed accreditation procedures for
programs to train employees engaged in  clean-up
operations at uncontrolled hazardous waste sites,
and for employees engaged in certain hazardous
waste operations  at RCRA TSD facilities. The
NPRM  also  proposed  amendments to  29 CFR
1910.120 to include appropriate references to the
provisions set forth in  the proposed rule.  If this
regulation is  promulgated as it was proposed, all
employees  subject   to  29  CFR  1910.120  at
uncontrolled  hazardous waste sites will be required
to attend an  accredited training program  or to
document equivalent training and experience.

                  PART 3:  MEDICAL
                  SURVEILLANCE
                  REQUIREMENTS

                  Part  3 of  this  Fact  Sheet
                  discusses   the   medical
                  surveillance   requirements  in
 HAZWOPER that apply to employees engaged in
 hazardous   waste  operations   and  emergency
 response at  uncontrolled hazardous waste sites,
 including  employees  who   perform  corrective
 actions at RCRA TSD facilities

 General Medical Surveillance Requirements

       The   HAZWOPER  medical  surveillance
 requirements (29 CFR  1910.120(f)) provide the
 framework for a  medical monitoring program for
 workers at  uncontrolled hazardous waste sites.
 The  standards contain provisions for baseline,
 periodic, and termination medical examinations.

       A  medical   surveillance  program  must
 include monitoring for the following four groups of
 employees:

 •     Employees who are, or may be, exposed to
       PELs or health hazards for 30 or more days
       a year;

 •      Employees who wear a respirator for 30 or
        more days a year;

 •      Members of  organized HAZMAT Teams;
        and
                                                 48

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•     Employees  who  are  injured  due   to
      overexposure during an emergency incident,
      or who show symptoms of illness that may
      have resulted from exposure to hazardous
      substances.

      If employees  fall within the first three
groups  specified  above, they  must  undergo  a
baseline  medical examination  prior  to  a  site
assignment.     After  this   initial  examination,
employees   must  have  a  follow-up  medical
examination once a year; an attending physician
may suggest a shorter or longer interval, but  this
period may not exceed two years. The content of
these examinations  should be determined by the
attending physician, but certain key elements must
be  included.  For  example, the physician must
complete a  medical   and  work   history  and
determine the employee's  fitness for the  type of
duties to be assigned, including the employee's
ability  to  wear  PPE.    Once  the  medical
examination  has  been completed,  the employer
must obtain and furnish the employee with a copy
of the physician's written opinion. The physician's
written opinion must include the  results of the
medical examination and tests, any recommended
work  limitations, and  the physician's opinion
concerning the  medical condition of the employee.

       In addition  to the  initial  and  follow-up
examinations, employees must  receive a  medical
examination as soon as possible if they are injured
or   become  ill  from  exposure  to  hazardous
substances on-site or during an emergency, or they
 develop signs or symptoms that indicate a possible
 overexposure to hazardous substances. In addition,
 employees  who   are   reassigned  or  terminate
 employment and,  therefore, will  no longer be
 exposed to  hazardous substances must receive a
 final examination.   This  examination  is  only
 required  if the  employee  has  not  had  an
 examination within the past  six  months.   All
 required  medical examinations must be provided
 without cost to the employee, without loss of pay,
 and at a reasonable time and place.

       Additional  guidance on  these  medical
 surveillance requirements can be found in:

 •     U.S.   EPA  OERR  Medical  Monitoring
       Program  Guidelines, OSWER  Directive
       9285.3-04.  To obtain a  copy of these
       guidelines,  contact   the   Environmental
        Response Team (ERT)  of EPA in Edison,
      New Jersey.  (Refer to Exhibit 8 for the
      appropriate address and telephone number.)

•     Standard Operating Safety Guides, OSWER
      Directive 9285.1-OIC. To obtain a copy of
      this document, contact ERT in Edison, New
      Jersey.

•     Hazmat   Team   Planning   Guidance,
      Publication Number EPAy540/G-90/003. To
      obtain a copy of this document, contact the
      National Technical Information Service at
      (703) 487-4600.

•     Occupational Safety and Health Guidance
      Manual for Hazardous Waste Site Activities
      (Chapter   5   -  Medical   Monitoring),
      Publication Number 017-033-00419-6. To
      obtain a copy of this document,  contact the
      Superintendent  of Documents at the  U.S
      Government Printing Office in Washington,
      D.C.  20402 ((202) 783-3238).

Medical Records

      Medical records  for  employees must be
maintained for a period of thirty years following
termination of employment.  These records must
include  the name and social security number of the
employee;   the  physician's  written  opinions,
including recommended occupational limitations
and  results   of  examinations  and  tests;  any
employee medical complaints related to exposure
to  hazardous  substances;  and a  copy  of the
 information provided to the examining physician by
 the employer.  The employer  is responsible for
 retaining the records if the employee or physician
 leaves  the area, or  the company goes  out of
 business. For additional information on  medical
 recordkeeping equirements, refer to 29  CFR
 1910.20.
                   PART 4:  OTHER
                   REQUIREMENTS

                   This part  of the Fact Sheet
                   discusses other requirements in
                   HAZWOPER that  apply  to
                   employees   engaged   in
 hazardous  waste   operations   and emergency
 response at uncontrolled hazardous waste  sites.
 Specifically, this part outlines the requirements for:
 (1)   handling   drums  and   containers,    (2)
 illumination and sanitation requirements, and  (3)
 informational and  new technology programs.
                                               49

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Requirements  for  Handling  Drums  and
Containers (29 CFR 1910.120(j))

      When   performing   site   operations,
HAZWOPER specifies some basic requirements
for handling drums and  containers  on-site.   In
general, site operations should be organized to
minimize  the amount of drum  and container
movement.  However, if drums or containers must
be  moved,   the  following  are  a  few   of  the
requirements that must be met.

•     Drums and containers must be inspected
      prior to being moved.  If this is not possible
      because the drums are buried beneath the
      earth  or  stacked  several tiers high,  the
      drums or containers should be moved to an
      accessible location and then inspected prior
      to further handling.

•     Prior to  the  movement  of  drums,  all
      employees who  have a  potential  to be
      exposed to hazardous  substances as a result
      of  the transfer operation  must be  notified
      of the potential  hazards associated with the
       contents of the drums or containers.

       In  addition  to the  above requirements,
 HAZWOPER  provides  specific procedures  for
 (1) opening drums and  containers; (2)  selecting
 and operating material handling equipment; (3)
 handling radioactive and shock-sensitive wastes and
 laboratory waste packs; (4) sampling the contents
 of  drums   or  containers;  (5) shipping  and
 transporting drums or containers; and (6) handling
 tanks and vaults containing  hazardous substances.

 Illumination and Sanitation Requirements
 (29 CFR 1910.120(m)  and (n))

       The employer  is  responsible  for ensuring
 that  appropriate procedures exist at  the site to
 maintain certain minimum illumination intensities
 and an adequate supply of water. There must be
 two  separate  systems  for  furnishing water:  a
 potable and a nonpotable  system.   The  potable
 system should provide drinking water  only; the
 nonpotable system should  provide water  for fire
 fighting purposes. There are also requirements for
 toilet facilities, food handling, sleeping quarters,
 washing facilities, and shower/change rooms.
Informational and New Technology
Programs (29 CFR 1910.120(i) and (o))

      Two additional  programs  that  must be
developed, implemented, and included as part of
the employer's safety and health program are the
information  and new technology  programs.   A
program must be developed and implemented to
inform employees of the nature, level, and degree
of  exposure  that   may  occur  as a  result of
performing  hazardous  waste  operations.   In
developing  this  informational   program,   the
employer   should   consult   the  Hazard
Communications  Standard  (HCS)   (29  CFR
1910.1200 and 29 CFR 1926.59).  The HCS may
contain information  that would  be  useful  to
incorporate  into the  informational  program or
emergency response plan for a site.

       In addition to developing an informational
program, the employer must include as part of the
safety  and   health  program  procedures  for
introducing new and innovative technologies into
the work area. The purpose of the new technology
program  is  to ensure  that  new  and  improved
technologies  and equipment  are  developed  and
introduced to provide for the improved protection
of employees engaged in hazardous waste clean-up
operations.    As part  of the new  technology
program, the employer must carefully evaluate new
technologies,  equipment,  and  control  measures,
such as absorbents  and neutralizers, as they are
introduced and made available on the market.  The
evaluation, which must be completed prior to using
the new  technology at the site, must identify the
effectiveness of the new equipment, method, or
 material. Any data or information obtained during
 the evaluation must be made available to OSHA
 upon request.
                  PARTS: EMPLOYEE
                  RIGHTS UNDER
                  SECTION 8 OF THE OSH
                  ACT
                  Section 8  of  the  OSH  Act,
                  Inspections, Investigations, and
 Recordkeeping, gives  employees certain  rights  to
 inspect documents, and request and participate in
 inspections.  Exhibit  7 provides a summary of the
 principle provisions of section 8 of the OSH Act.

       OSHA has authority to inspect  a site on
 their own initiative at any reasonable time. Under
 paragraph  (f)(l)  of  section 8,  however,  an
                                                  50

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                 EXHIBIT 7
            Principal Provisions of
           Section 8 of the OSH Act
   Paragraph 8(c)(l):

   •  Employers are required to inform
      employees of their rights under the
      OSH Act

   Paragraph 8(c)(3):

   •  Employees are entitled access to any
      required records that indicate the
      person's exposure to toxic materials

   Paragraph 8(e):

   •  An employee and employer
      representative must be given the
      opportunity  to accompany OSHA
      during any workplace  inspection

   Paragraph 8(0:

   •  An employee or employee
      representative may request an OSHA
      inspection if the person believes that
      there is a violation of a safety or
      health standard that threatens physical
      harm, or that causes an imminent
      danger
employee or  employee  representative also  can
request an OSHA inspection if the person making
the request believes either that there is a violation
of  a  safety  or  health standard  that  threatens
physical harm, or that an imminent danger exists.
The request must be written and signed, and must
include a reasonable statement of the violation or
danger.  An employer is  entitled to get a copy of
the request, but  the employee can ask OSHA not
to disclose his name. When an employee makes a
request under this provision, OSHA must conduct
an  inspection if they  determine that  there are
reasonable grounds to believe a violation or danger
exists. If OSHA makes a contrary determination,
the person who made the request must be notified.

       Under paragraph (0(2), before or during an
inspection,   an    employee  or   employee
representative has the right to notify OSHA in
writing of any violation of the OSH Act that the
person  has  reason  to believe  exists  in  the
workplace. If the person making the request asks,
OSHA  must explain any determination not to
sanction the employer.

       If  there  is an  OSHA inspection, under
section   8(e),   an   authorized   employee
representative  must  be  given  the  chance  to
accompany OSHA during any inspection.  If there
is no  authorized employee representative, the
OSHA inspector has a further duty to consult with
a reasonable number of employees on matters of
health and safety. Under section 8(e), employers
are also provided with the opportunity to designate
a  representative to accompany OSHA  on the
inspection.   An important point  to remember,
however,  is that under  no circumstances  may the
employer designate the employee representative

       Section  8 sets out three other important
employee  rights.   Paragraph  (c)(l)   requires
employers to post a  notice or use some  other
appropriate means to inform employees of how the
OSH Act protects them, as well as what employee
obligations are.   Further, where  the OSH Act
requires measuring or monitoring potentially toxic
materials or harmful physical agents (e.g., Subpart
Z,  29 CFR 1910.1000), paragraph  (c)(3)  gives an
employee  or   an   authorized  employee
representative  the  right  to  observe any such
activity, and to have access to the  records.  This
same paragraph states that an employee or former
employee is entitled to have access to any required
records that indicate the person's exposure to toxic
materials or harmful  physical agents.   When an
employee is so exposed, the employer must notify
him of an exposure above levels prescribed by an
applicable   OSHA  standard,  and   inform  the
employee of actions taken to correct the conditions
that led to the impermissible exposure.

       There are other provisions of the OSH Act
 that  set  forth employee rights.   For additional
 information, consult the OSH Act.  Another useful
 source to consult on  this  subject  is the OSHA
 publication  entitled Employee Workplace  Rights
 (OSHA Publication No. 3021).  To obtain a copy
 of this document, contact OSHA's  Publications
 Office.   (Refer  to Exhibit  8 for the appropriate
 address and telephone number.)  When ordering
 the document, be certain to specify the publication
 number.
                                               51

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                 PART 6:  SOURCES OF
                 ADDITIONAL
                 INFORMATION AND
                 REFERENCE
                 MATERIALS
      Part  6  of  this  Fact  Sheet  provides
information on where you can obtain a copy of a
generic HASP; describes a set of Guidelines that
can help an OSC/RPM assess the efficacy  of a
HASP;  and provides  important  addresses  and
telephone numbers for additional information on
HAZWOPER requirements.

Generic HASPs

      ERT has developed a  computer software
package to assist  field  personnel  in preparing a
site-specific health and safety plan, complete with
all the elements required by HAZWOPER.  You
can  obtain  a copy  of  the  generic  HASP  by
contacting:
   ERC - Health and Safety
   U.S. EPA/ERT
   2890 Woodbridge Avenue
   Building 18 (MS-101)
   Edison, NJ 08837-3679
   Attention:  Generic HASP
       Single copies are available without charge.
 Requestors  must specify their  desired disk  size
 (i.e., either 3 1/2 or 5 1/4 inch disk) and whether a
 high density or double density disk is preferred.

 Health and Safety Audit Guidelines

       ERT has developed step-by-step  guidance
 for evaluating the comprehensiveness and efficacy
 of the preliminary evaluation and  the HASP for
 activities  at uncontrolled  hazardous  wastes sites.
 These "Health and Safety Audit Guidelines" may
 be used  in conducting a health  and safety site
 audit,  or  simply  to  assist  OSC/RPMs   in
 determining whether a  HASP is likely to comply
 with the HAZWOPER requirements.

       A copy of the  "Health and Safety Audit
 Guidelines"   (Publication  Number  EPA/540/G-
 89/010)  may be obtained by calling  the National
 Technical Information Service at (703) 487-4600.
Additional Sources of Information

      The following is a brief summary of where
to  obtain  additional  information   on   the
HAZWOPER standards. Please refer to Exhibit 8
for  the  appropriate  addresses  and  telephone
numbers of the contacts referenced below.

•     If you have questions regarding the existing
      relationship between EPA and OSHA with
      respect  to  the  implementation of  the
      standards, contact the ERT in Edison, NJ.

•     For information  about  EPA's  training
      courses, contact ERTs Operations Section
      in Cincinnati, OH.

•     For information  and  guidance  on  the
      substance of 29 CFR 1910.120, contact the
      appropriate  OSHA Regional  office.  If
      additional  information is  needed, contact
      the OSHA Office  of Health Compliance
      Assistance in Washington, D.C.

•     For information on how to obtain technical
      assistance   from   OSHA,  contact  the
      appropriate OSHA Regional office. (Refer
      to  Exhibit 8 for appropriate addresses and
      telephone numbers.)

      There are four other  HAZWOPER Fact
      Sheets that are available:

            Hazardous  Waste  Operations  and
            Emergency   Response:     General
            Information  and  Comparison  (Pub.
             No. 9285.2-09FS) explains the scope
             of the HAZWOPER standards, and
             distinguishes them  from  regulations
             and consensus standards covering the
             same or similar subject matter;

             Hazardous  Waste  Operations  and
             Emergency Response:  RCRA TSD
             and  Emergency  Response  Without
             Regard to Location (Pub.  No. 9285.2-
             07FS)   explains  the   principal
             HAZWOPER   requirements   for
             emergency  response without regard
             to location  and routine hazardous
             waste  operations  at  RCRA TSD
             facilities.
                                                 52

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         Establishing   Work  Zone:,  at
         Uncontrolled Hazardous Waste Sites
         (Pub. No. 9285.2-06FS) describes the
         requirements  and  procedures  for
         establishing   support   zones  at
         uncontrolled hazardous waste sites.

         Hazardous  Waste  Operations  and
         Emergency  Response:    Available
         Guidance  (Pub.  No. 9285.2-10FS)
         describes    guidance    materials
            developed   by  the  Environmental
            Response  Team  of EPA  to  help
            workers engaged in hazardous waste
            operations and emergency response
            understand   the   HAZWOPER
            requirements.

      Copies  of  these  Fact  Sheets  may  be
obtained by calling or writing ERT in Edison, NJ.
Please specify the title and directive number of the
Fact Sheet(s).   (Refer  to  Exhibit  8  for  the
appropriate address and telephone number.)
                                      EXHIBIT 8
                    Important Telephone Numbers and Addresses
      U.S. EPA/ERT
      2890 Woodbridge Avenue
      Building 18 (MS-101)
      Edison, NJ  08837-3679
      (908) 321-6740 or (FTS) 340-6740

      U.S. EPA/ERT
      Operations Section
      26 West Martin Luther King
      Cincinnati, OH 45268
      (513) 569-7537 or (FTS) 684-7537

•     U.S. Department of Labor, OSHA
      Office of Health Compliance Assistance
      200 Constitution Avenue, NW
      Washington, D.C.  20210
      (202) 523-8036 or (FTS) 523-8036

•     U.S. Department of Labor, OSHA
      Publications Office
      Room N 3101
      200 Constitution Avenue, NW
      Washington, D.C.  20210
      (202) 523-9667

OSHA Regional Offices

•     U.S. Department of Labor, OSHA
      Region 1
      133 Portland Street, 1st Floor
      Boston, MA 02114
      (617) 565-7164 or (FTS) 835-7164
    U.S. Department of Labor, OSHA
    Region 2
    201 Vanck Street, Room 670
    New York, NY  10014
    (212) 337-2325 or (FTS) 660-2378

    U.S. Department of Labor, OSHA
    Region 3
    Gateway Building, Suite 2100
    3535 Market Street
    Philadelphia, PA  19104
    (215) 596-1201 or (FTS) 596-1201

    U.S. Department of Labor, OSHA
    Region 4
    1375 Peachtree Street, NE, Suite 587
    Atlanta, GA  30367
    (404) 347-3573 or (FTS) 257-3573

    U.S. Department of Labor, OSHA
    Region 5
    230 South Dearborn Street
    32nd Floor, Room 3244
    Chicago, IL  60604
    (312) 353-2220 or (FTS) 353-2220

    U.S. Department of Labor, OSHA
    Region 6
    525 Griffin Street, Room 602
    Dallas, TX 75202
    (214) 767-4731 or (FTS) 729-4731

    U.S. Department of Labor, OSHA
    Region 7
    911 Walnut Street
    Kansas City, MO 64106
    (816) 426-5861 or (FTS) 867-5861
                                            53

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                                 EXHIBIT 8 (continued)
                     Important Telephone Numbers  and Addresses
OSHA Reeional Offices (continued)

•     U.S. Department of Labor, OSHA
      Region 8
      1951 Stout Street
      Denver, CO 80204
      (303) 844-3061 or (FTS) 564-3061

•     U.S. Department of Labor, OSHA
      Region 9
      71 Stevenson Street, Suite 415
      San  Francisco, CA 94105
      (415) 744-6670 or (FTS) 484-6670

•     U.S. Department of Labor, OSHA
      Region  10
       1111 Third Avenue, Suite 715
      Seattle, WA  98101-3212
      (206) 442-5930 or (FTS) 399-5930

EPA Regional Offices

 •      US. Environmental Protection Agency
       Region 1
       John F. Kennedy Federal Building
       Room 2203
       Boston, MA 02203
       (617) 565-3715 or (FTS) 835-3715

 •      U.S. Environmental Protection Agency
       Region 2
       Jacob K. Javitz Federal Building
       26 Federal Plaza
       New York,  NY  10278
       (212) 264-2657 or (FTS) 264-2657

 •     U.S. Environmental Protection Agency
       Region 3
       841 Chestnut Building
       Philadelphia, PA  19107
       (215) 597-9800 or (FTS) 597-9800

 >     U.S. Environmental Protection Agency
       Region 4
       345 Oourtland Street, NE
       Atlanta, GA  30365
       (404) 347-4727 or (FTS) 257-4727
U.S. Environmental Protection Agency
Region 5
230 South Dearborn Street
Chicago, IL  60604
(312) 353-2000 or (FTS) 353-2000

U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue, 9th  Floor
Dallas, TX 75202
(214) 655-6444 or (FTS) 255-6444

U.S. Environmental Protection Agency
Region 7
726 Minnesota Avenue
Kansas City, KS  66115
(913) 551-7000 or (FTS) 276-7000

U.S. Environmental Protection Agency
Region  8
999 18th Street, Suite 500
Denver, CO 80202-2405
(303)  293-1603 or (FTS) 293-1603

U.S. Environmental Protection Agency
Region  9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322

U.S. Environmental Protection Agency
Region 10
1200 6th Avenue
Seattle, WA  98101
(206) 442-1200 or (FTS) 399-1200

Call the Emergency Planning and
Community Right-to-Know Information
 Hotline for the addresses and telephone
 numbers of state emergency response
commissions and local  emergency planning
committees in your area.  The telephone
 numbers for the Hotline are:  toll-free
 800-535-7672, or 202-475-9652 in the
 Washington, D.C. area.
                                             54

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                    SECTION 3

            QUICK REFERENCE FACT SHEETS

                      PARTS

HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
        GENERAL INFORMATION AND COMPARISON
                        55

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                  United States
                  Environmental Protection
                  Agency
Office of
Solid Waste and
Emergency Response
Publication 9285.2-09FS
April 1991
       EPA   Hazardous Waste  Operations
                  and  Emergency  Response:
                  General Information  and Comparison
   Office of Emergency and Remedial Response
   Emergency Response Division     MS-101
                   Quick Reference Fact Sheet
INTRODUCTION
                Under the authority of section
                126 of the Superfund Amend-
                ments and Reauthorization Act
                of 1986 (SARA Title I), the
                U.S. Environmental Prelection
                Agency  (EPA) and the U.S.
                Occupational   Safety   and
Health  Administration (OSHA) issued identical
health and safety standards to protect workers
engaged in  hazardous  waste  operations  and
emergency  response.   The OSHA  regulations,
codified at 29 CFR 1910.120, became  effective on
March 6, 1990 (54 FR 9294). Corrections to these
regulations were published on April 13, 1990 (55
FR 14072) to clarify certain medical  surveillance
requirements and to identify which employers must
comply with  29 CFR  1910.120(p).  The  EPA
regulations, published  on June 23, 1989 at 54 FR
26654,  incorporate  the  OSHA  standards  by
reference and are codified at 40 CFR  Part 311.

      The EPA and  OSHA worker protection
standards for hazardous  waste operations and
emergency    response  (HAZWOPER)    affect
employers whose  employees are engaged  in the
following activities.

•     Clean-up   operations   at  uncontrolled
      hazardous waste sites when a  government
      authority  requires  the cleanup (29 CFR
      Corrective  actions at  treatment,  storage,
      and disposal (TSD)  facilities regulated
      under  the  Resource  Conservation  and
      Recovery   Act   (RCRA)   (29  CFR
                                        57
        Voluntary   clean-up  operations   at
        uncontrolled hazardous waste sites (29 CFR
   •     Hazardous waste operations conducted at
         RCRA   TSD  facilities  (29  CFR
         1910.120(a)(iv)); and

   •     Emergency  response  operations  without
         regard to location, where there  is  the
         release or a substantial threat of release of
         a   hazardous  substance  (29  CFR
         1910.120(a)(v)).

         The purpose of this Fact Sheet is to explain
   the scope and purpose of the worker protection
   standards  issued under SARA Title  I, and to
   distinguish these standards from other regulations
   and consensus standards  covering the same or
   similar subject matter. This Fact Sheet is  also
   designed  to facilitate  compliance  with  the
   HAZWOPER requirements by helping employers
   and other interested readers to understand their
   special  responsibilities   under  these  worker
   protection  standards.  For a summary  of the
   HAZWOPER requirements, refer to Exhibit  1.

         This Fact Sheet is divided into five sections.
   Section one gives a brief legislative history of the
   EPA and OSHA worker protection standards for
   hazardous  waste  operations  and  emergency
   response, and explains the responsibilities of these
   two  agencies  in  implementing the  standards.
   Sections two, three, and four compare the 1910.120
   standards with other programs governing the same
   kinds  of activities.  Finally, section five explains
   how to obtain the publications discussed in this
   Fact Sheet.
                                                                            Printed on Recycled Paper

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                 EXHIBIT 1
      The Worker Protection Standards
    for Hazardous Waste Operations and
            Emergency Response
             (29 CFR 1910.120)
  (a)  Scope, application, and definitions

  (b)  Safety and health program

  (c)  Sue characterization and analysis

  (d)  Site control

  (e)  Training

  (f)  Medical surveillance

  (g)  Engineering controls, work practices, and
      personal protective equipment for employee
      protection

  (h) Monitoring

  (i)  Informational programs

  (j)  Handling drums and containers

  (k) Decontamination

   (1)   Emergency response by employees at
       uncontrolled hazardous waste sites.

   (ra) Ulucmnaiion.

   (n)  Sanitation at temporary workplaces

   (o)  New technology programs.

   (p)  Certain operations conducted under the
       Resource Conservation and Recovery Act of
       1976.

   (q)  Emergency response to hazardous substance
       releases by employees not previously covered.
                  Overview of EPA and
                  OSHA Worker
                  Protection Authority

                  The Occupational Safety and
                  Health   Act   of   1970,   as
amended, (OSH Act) established health and safety
standards for the American workplace.  Section 6
of the OSH Act established  Federal authority to
issue general  health  and  safety  standards  for
private industry; section 19 addresses standards for
Federal  government  employees.     Under  the
authority  of section 6 of the OSH Act, OSHA
promulgated  general   industry  standards  and
standards that apply specifically to the construction
industry; these  standards are codified at 29 CFR
1910 and  1926, respectively.  These standards set
forth the minimum health and safety requirements
necessary to ensure protection for all private sector
employees in the United States.  The scope of the
coverage of the standards set forth in 29 CFR 1910
and  1926 changed dramatically on February 26,
1980,  when  President  Jimmy  Carter  signed
Executive  Order 12196, requiring  the  Federal
government to  comply with the more  stringent
general industry  standards issued under section 6
of the OSH Act.

       SARA section 126(a) requires the Secretary
of Labor to issue health and safety standards under
section 6 of the OSH Act for the benefit of private
sector employees — and through  the  Executive
Order, Federal employees - engaged in hazardous
waste operations and emergency response. Federal
OSHA has  no authority to  enforce regulations
protecting state and local government employees.

       Under section  18 of the OSH Act, a state
may  elect  to  develop  and  implement  its own
occupational safety and health program if: (1) the
state is willing to document its program in a state
plan, and (2) the state's requirements are at least
as stringent as the Federal regulations.   Before a
state  program  can become effective,  however,
 OSHA must review and approve  the state plan.
Through its review and approval authority, OSHA
 requires  states to extend occupational safety and
 health protection to  state  and local government
 employees, as well as  to private sector employees,
within the state's jurisdiction. Currently, there are
 23 states and two territories with delegated OSHA
 programs.  These state plans must be amended to
 incorporate the newly promulgated standards in 29
 CFR  1910.120, to address the safety and health of
 employees engaged in hazardous waste operations
 and emergency response.

        SARA section 126(f)  requires  the EPA
 Administrator  to issue  standards for  hazardous
 waste operations and  emergency response that are
 identical to OSHA's standards. Although the  two
 sets  of  standards  contain  identical  substantive
 provisions,  EPA and  OSHA address  different
 audiences.  EPA's  authority extends to  state  and
 local government employers conducting hazardous
 waste operations and emergency response in states
                                                   58

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that  do not have  in  effect  a  delegated OSHA
program.  Currently, 27 states,  one territory, and
the  District  of  Columbia  fall  under  EPA's
authority.    The  EPA  regulations  cover both
compensated and uncompensated state and local
government employees engaged  in  the  covered
activities.  Therefore,  the EPA standards protect
volunteers, such as volunteer fire fighters who are
responding to hazardous substance emergencies.
Although   Federal  OSHA  recommends  that
delegated   state   programs   also   cover
uncompensated employees,  not  all states have
followed this recommendation.

       In  summary, in states without an OSHA-
approved  plan, Federal OSHA standards protect
all private sector and  Federal employees engaged
in hazardous  waste operations  and emergency
response;  the  EPA worker  protection standards
protect all state and local government employees,
including  volunteer workers.  In states with  an
OSHA-approved plan, the state program covers all
private sector employees, as well as state and local
government employees;  Federal  OSHA covers
Federal employees in those states.  The shaded
area in Exhibit 2  shows jurisdictions without an
OSHA-delegated program.
Inter-Agency Agreement

      EPA and  OSHA have an  agreement  to
share responsibility for implementing the Title I
worker protection standards.  Under the terms of
this  agreement, OSHA  performs  the  following
activities:
       Support of the National Response Team and
       Regional Response Teams.

       Technical Assistance.  OSHA advises EPA
       on the types of actions EPA should take at
       uncontrolled  hazardous  waste  sites  to
       ensure   full   compliance   with   the
       HAZWOPER requirements. As an advisor,
       OSHA will identify problems that EPA may
       face and suggest appropriate solutions.

       Compliance Activities.   OSHA conducts
       inspections and takes enforcement actions
       to ensure  compliance with  the  worker
       protection standards at Superfund sites.

       Implementation Activities.  OSHA supports
       EPA in conducting workshops to  explain
       the requirements of  the  standards,  and
       provides  official  interpretations  of the
       health and safety requirements.
                                           EXHIBIT 2
                        Shaded States Do Not Have Delegated OSHA Programs
                                               59

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   If you have questions on the substance of
   the   worker  protection  standards  for
   hazardous waste operations and emergency
   response, contact an OSHA Regional Office
   or OSHA's Office of Health Compliance
   Assistance in Washington, D.C  Refer to
   Exhibit  4  for  relevant  addresses  and
   telephone numbers.
      The next three sections of this Fact Sheet
compare OSHA's health and safety standards for
hazardous  waste  operations   and   emergency
response   with   several  related   regulations,
standards, and  guidelines developed  by  OSHA,
EPA, and the National Fire Protection Association
(NFPA).   Be aware that in the context of this
discussion,   we   will   talk  about   "hazardous
substances,"  "extremely  hazardous   substances"
(EHSs), "hazardous materials," "hazardous wastes,"
and "highly hazardous  chemicals."  Each of these
terms  means   something  different,  and   the
regulatory  programs   that  employ  them   are
intended  to  prevent or mitigate the  effects from
exposure to a distinct set of hazardous chemicals.
                  Comparing Regulatory
                  Requirements Under
                  SARA Title I, SARA
                  Title III, and OSHA's
                  Proposed Rule on Highly
                  Hazardous Chemicals
SARA Title I
       Under the authority of Title I, section 126
 of  SARA,  EPA  published  worker  protection
 standards for  hazardous  waste  operations  and
 emergency   response  (HAZWOPER).
 HAZWOPER  specifies certain health and safety
 requirements   to   ensure  the   protection  of
 employees engaged in hazardous waste operations
 and  emergency response during  five specified.
 activities (see  page  1   of  this  Fact  Sheet).
 HAZWOPER   does  not  address   emergency
 responders who engage only in handling traditional
 fire  and  medical  emergencies;  other  OSHA
 programs protect these employees. HAZWOPER,
 however, requires that an employer provide, among
 other things, proper emergency response planning,
 training, and  medical  surveillance.    Affected
 workers  must be protected during  the entire
remedial process, from the preliminary evaluation
and initial site entry to final closure of the site.

      Emergency Response Planning. An employer
must  develop an emergency response plan  to
protect workers in an emergency resulting from the
release of all  kinds  of hazardous substances,
including EHSs, CERCLA hazardous substances,
RCRA hazardous wastes, and any substance listed
by the U.S. Department of Transportation as  a
hazardous material.

      Training.   An employer also  must  ensure
that workers receive the kind of training specified
in the regulation.  The standard  reflects a tiered
approach to training, linking the amount and type
of training to an employee's potential for exposure
to hazardous substances  and  to  other  health
hazards during a hazardous waste operation or an
emergency response.  The greater the potential
hazard, the more extensive and stringent  are the
training requirements.

      Medical   Surveillance.     HAZWOPER
establishes a framework  for a medical monitoring
program for certain workers engaged in hazardous
waste operations and emergency response.   The
medical   surveillance  requirements   include
provisions for a baseline, periodic, and termination
medical   examination  for   specific groups   of
employees.   HAZWOPER  also  requires  that
employees receive a medical examination  as soon
as possible if they are injured or become  ill from
exposure to hazardous substances on-site or during
an emergency, or develop signs or symptoms that
 indicate  a  possible overexposure to  hazardous
substances. Although an attending physician may
 determine the  content  of  medical  examinations
 required under the standard, the examination must
 address key elements related to handling hazardous
 substances.

 SARA Title HI

       SARA Title III, or the Emergency Planning
 and  Community Right-to-Know Act, is a  law
 enacted  to improve state and local government
 capacity to respond to an emergency caused by an
 accidental release of an EHS; and to disseminate
 information to the public on dangerous chemicals
 made, used, or stored in their community.

       Think of this law as having four main parts.
 The  first part, sections 302 and 303, requires each
 state to  create a State  Emergency Response
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Commission (SERC).  In turn, these SERCs must
create  Local  Emergency  Planning Committees
(LEPCs)  that  correspond to  local emergency
planning districts.   LEPCs develop and  update
emergency response plans  for accidents involving
EHSs;  and receive, manage, and provide  public
access  to  information  about  toxic and  other
hazardous  substances  in  the  district.   SERCs
review emergency  response plans, and generally
supervise and coordinate LEPC activities.

       The second  part of SARA Title III (section
304)   sets  out  emergency   release   reporting
requirements.   Under this part of the law, the
owner  or operator  of a facility from which an EHS
or CERCLA hazardous substance is released at or
above  a reportable quantity (RQ) must  notify
SERCs and  LEPCs  in  the  affected area  by
telephone.  There must be a written  follow-up
report to this immediate  notification.  Both the
initial  and follow-up reports must give  details on
known or anticipated  health  risks  and  advice
regarding medical  attention.

       The third part  of SARA Title HI (sections
311 and 312) gives people the right to know what
substances are being made, used, or stored in their
communities.  The OSHA Hazard Communication
Standard  (HCS) requires owners and operators to
keep "material safety data sheets" (or MSDSs) with
information about the health hazards of chemicals
at the  facility, and  to make these MSDSs available
to their employees. SARA Title III piggy-backs on
the MSDS  requirements  in the  HCS.   Under
SARA Title III, the owner or operator also must
send copies of MSDSs, or lists of chemicals with
MSDSs, to SERCs, LEPCs, and fire departments.
LEPCs, in turn, make this  information available to
the public during  normal business hours.

       The  final part of SARA Title III (section
313)  requires  certain owners  and operators to
report toxic substances released from their facility
-- whether the release is routine or accidental; and
to  report  toxic  substances  they  transport to
another site as waste.

       Of these  four parts, the one  that most
closely  parallels  the  SARA  Title  I   worker
protection  standards is  the  part dealing  with
emergency response planning (section 303). There
are nine emergency response planning elements in
section 303 of SARA Title III.  Although these
 planning elements do  not correspond point-for-
 point  with  the  emergency  response planning
 elements in the worker protection standards issued
under SARA Title I, each program covers similar
subjects.   Title  I  (HAZWOPER) and Title III
emergency response planning elements both:

•     Highlight the need for planning before there
      is  an emergency;

•     Require  planners  to  identify  emergency
      response    decision-makers  and   other
      personnel;

•     Require planners to develop guidelines for
      recognizing and evaluating releases;

•     Require evacuation planning;

•     Require that the emergency response  plan
      set out an orderly sequence of steps  to
      follow in  an emergency;

•     Direct  planners to specify equipment that
      may be needed for various levels and types
      of emergencies; and

•     Require  testing  the  plan  and providing
      appropriate   training   for   emergency
      res ponders.

      On  the   other  hand,  there  are  some
important differences  in  emergency  response
planning requirements under Title I and Title III.
For example, a Title I plan must address a number
of chemical hazards, while a Title III plan  must
cover only  those emergencies arising from the
release  of an EHS.  Further,  a  plan to protect
employees under Title I may require far more
specificity than a Title III plan.  Although a  Title
III plan may  be too  general  for  use as  an
employer's  Title  I  plan, the  Title  I plan  may
reference  the  Title  III  plan   to  avoid   any
unnecessary duplication of information.  If a  Title
III plan is  referenced,  a copy of the referenced
document must  be kept with the Title I plan.

       The most important thing to remember in
distinguishing Title  I  and Title III emergency
response planning is that Title I plans focus on
worker safety; Title  III plans focus on community
safety.   The similarities and differences  between
the Title  I and Title  III  emergency  response
 planning requirements are addressed in greater
detail in a paper entitled "SARA Title I/Title III
 Emergency Response Planning Requirements." To
 obtain   a  copy  of  this  document,  contact the
 Environmental Response Team (ERT) of EPA in
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Edison, New Jersey.  (Refer to Exhibit 4 for the
appropriate address and telephone number.)

OSHA's Highly Hazardous Chemicals NPRM

       On July 17,1990, OSHA published a Notice
of Proposed Rulemaking (NPRM),  proposing  a
new   regulation   entitled   "Process   Safety
Management of Highly Hazardous Chemicals" (55
FR 29150).  The NPRM proposes requirements
that will  eliminate  or mitigate the harm  to
employees as a consequence of chemical  releases
during the manufacturing or processing of highly
hazardous chemicals.  OSHA's proposed  rule
emphasizes management of hazards associated with
highly hazardous chemicals, and defines a "highly
hazardous chemical" as:

       A  substance  possessing toxic, flammable,
       reactive, or explosive properties.

       The NPRM identifies 140 highly hazardous
chemicals and proposes threshold quantities for
each  of  the  listed  chemicals.    The proposed
requirements are similar to the worker protection
standards issued under SARA Title I and the self-
implementing provisions of SARA Title III in that
each of these programs contains requirements for
emergency  response  planning  and employee
training.

       The  NPRM  requires  an   employer   to
establish and implement an emergency action plan
under 29 CFR 1910.38(a).  An  emergency action
plan  must include an evacuation  plan through
which an employer identifies  persons responsible
 for an orderly exit and work area  check in the
 event of an emergency; and directs  employees  to
 leave  an  emergency incident site, maintain a safe
 distance,  and call  an  appropriate emergency
 response organization. However, if  an employer's
 highly hazardous chemical operation falls within
 one of the activities covered by HAZWOPER, the
 emergency response planning elements of 1910.120
 apply. (Under HAZWOPER,  an employer also
 may  prepare  a 1910.38(a) plan if  the employer
 does  not allow employees  to respond  to  an
 emergency. If employees are allowed to respond,
 however, a more detailed emergency response plan
 is required.)   Title I, Title  III, and the Highly
 Hazardous Chemicals NPRM also require training
 for workers  commensurate  with  their assigned
 duties.
                 Comparing General
                 Requirements Under 29
                 CFR Parts 1910 and
                 1926 with  the Particular
                 Requirements of 29 CFR
                 1910.120
      The  occupational   safety  and   health
standards published in 29 CFR set out minimum
requirements to ensure protection for all private
sector  employees  in  the  United States.   The
general industry standards contained in Part 1910
of Title 29 were  derived largely from standards
developed by industry consensus organizations and
non-OSHA Federal safety and health standards.
The 1910 requirements reflect practices  already
recognized in most industrial sectors before  there
was   an  Occupational   Safety   and   Health
Administration.  Part 1910, however, makes  those
practices mandatory.

      Many  of the Part 1910 standards set out
generic specifications for worker tools, tolerances
and   specifications  for  industrial   structures,
requirements for  installing equipment that  make
the workplace safer (e.g., sprinkler systems), rules
for providing medical attention, and other general
health and safety practices applicable to all types
of  employment.   Other sections in Part  1910,
however, are specific to an  identified activity or
industry; HAZWOPER is an example of the latter
type of standard.

       Section 1910.120 (HAZWOPER) contains
specific requirements to minimize the health and
safety  hazards   associated  with  conducting
hazardous  waste  operations   and  emergency
response at uncontrolled hazardous waste sites and
RCRA TSD facilities, and performing emergency
response  operations without regard  for location.
 In some instances, 1910.120 incorporates general
worker protection provisions by reference. For
 example,  1910.120(g), Engineering controls,  work
practices,  and personal protective  equipment for
 employee protection, requires employers engaged in
 hazardous  waste  operations   and  emergency
 response to  follow  the  provisions in 1910.94
 through 1910.100 in setting up controls to protect
 employees from exposure to hazardous substances
 and safety and health hazards.  Those referenced
 sections  may apply  to other  industries and
 activities as well, but HAZWOPER applies only to
 hazardous   waste  operations  and emergency
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response  during  the  covered  activities  and
locations.
   If  ever there  appears  to be  a conflict
   between the general industry standards in
   1910  or  1926  and  HAZWOPER,  the
   HAZWOPER requirements take precedent
   during the covered activities.
       In addition to the requirements set forth
under Part 1910, OSHA codified regulations in 29
CFR 1926 Subpart  C that set  forth safety  and
health  standards  specifically  applicable  to  the
construction   industry.    Part  1926  Subpart C
includes safety standards for  worker  tools,  and
other standards relevant to health and safety in the
construction  environment (e.g.,  29 CFR 1926.21
addresses programs for the education and training
of employees and employers).

       Parts  1910 and 1926 both require employers
to  provide  whatever training  and education is
appropriate for employees to perform a given  task
safely.  Appendix B in EPA's Health and Safety
Audit Guidelines briefly summarizes the OSHA
standards in 1910 and  1926  that  may be most
applicable to hazardous waste  site  activities;
Exhibit 3 presents a  list of these OSHA standards.
For additional information on the standards listed
in Exhibit 3  or on other  OSHA standards, contact
your local OSHA  Regional  Office.   (Refer to
Exhibit  4 for relevant  addresses  and telephone
numbers.)
                   Comparing the Section
                   1910.120 Standards and
                   the NFPA's Hazardous
                   Materials Incidents
                   Publications
       Private organizations  sometimes  publish
 consensus documents addressing subject matter
 covered in Federal regulations. The National Fire
 Protection Association (NFPA) has published two
 highly relevant documents: Recommended Practice
 for Responding to Hazardous Materials Incidents
 (NFPA  471),  and  Standard for  Professional
 Competence of Responders to Hazardous Materials
 Incidents (NFPA  472).  The NFPA standards are
 not Federal  regulations.
                EXHIBIT 3
      Other Potentially  Applicable
             OSHA Standards
          (by section in 29 CFR)
   1910.20    Access to Employee Exposure and
             Medical Records
   1910.24    Fixed Industrial Stairs
   1910 27    Fixed Ladders
   1910-28    Safety Requirements for Scaffolding
   1910.38    Employee Emergency Plans and
             Fire Prevention Plans
   1910.57    Ventilation
   1910.95    Occupational Noise Exposure
   1910.101   Compressed Gases
   1910.133   Eye and Face Protection
   1910.134   Respiratory Protection
   1910.135   Occupational Head Protection
   1910.136   Occupational Foot Protection
   1910.141   Sanitation
   1910.151   Medical Sendees and First Aid
   1910.165   Employee Alarm Systems
   1910.181   Derricks
   1910.252   Welding, Cutting,  and Brazing
   1910.307   Hazardous Locations
   1910.1000 Toxic and Hazardous Substances
   1910.1200 Hazard Communication
   1926.20    General Safety and Health
             Provisions
   1926.21    Safety Training and Education
   1926.56    Illumination
   1926.59    Hazard Communication
   1926.151   Fire Prevention
   1926.152   Flammable and Combustible
             Liquids
   1926.200   Accident Prevention Signs and Tags
   1926.301   Hand Tools
   1926.651   Specific Excavation Requirements
   1926.652   Trenching Requirements
       NFPA 471 offers guidance in identifying the
minimum competencies a responsible  authority
should attain  before responding to  a hazardous
materials   incident,   and  specifies  operating
guidelines  for  a  response.  Like HAZWOPER,
NFPA 471 covers, among other things, planning
for  an   emergency  response,  ensuring  that
responders have  the proper equipment at  their
disposal, and conducting an emergency response.

       NFPA  472  is a competency  standard for
workers  who  respond  to hazardous  materials
incidents.  NFPA 472 training criteria differ from
the 1910.120 standards in that  the former do not
                                               63

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establish specific hourly training requirements for
emergency  response personnel.   There  is  no
Incident Commander category in  NFPA 472,  but
an Appendix to the standard does  identify the role
of an Incident Commander.

       Indeed,   the   NFPA   publications   on
hazardous materials incident response are similar
in  approach   and  breadth   of  coverage   to
HAZWOPER.    In   many  instances,  NFPA
references  the Federal standards.   You  must
remember, however,  that  although  the  NFPA
documents provide useful guidance to emergency
response planners and responders, only the EPA
and  OSHA  standards  are mandatory  Federal
standards.  If your organization  falls within  the
scope of  29  CFR  1910.120, you  must comply.
Therefore, in any  conflict between  the  NFPA
Standard/Practice and the Title I worker protection
standards, the Federal standards govern.

                  Where to Get
                  Information and
                  Publications

                  You can get any volume of the
                  CFR by contacting the  U.S.
 Government Printing Office (GPO) or any Federal
 Depository Library in your state. To contact GPO,
 call or write:

        Superintendent of Documents
        Government Printing Office (GPO)
        Washington, D.C. 20402
        (202) 783-3238

        Many state college and university libraries
 are  also  Federal  Depository  Libraries.  For a
 complete  list of these libraries, ask  GPO for A
 Directory of U.S. Government Libraries.

        OSHA offers  a  catalogue listing Agency-
 issued publications and audiovisual aids that  help
 employers  and other  interested  persons  to
 understand both the scope of OSHA regulations,
 and  specific substantive provisions in health and
 safety standards.  You can obtain a  free copy 'of
 the catalogue, OSHA Publications and Audiovisual
 Programs, by sending your request  with a  self-
 addressed mailing label to:

        U.S. Department of Labor, OSHA
        Publications Office, Room N3101
        200 Constitution Avenue, NW
        Washington, D.C.  20210
      To get  a  copy of the NFPA publications
discussed in this Fact Sheet, or to obtain additional
information on the substance of the publications,
write:

  National Fire Protection Association (NFPA)
              1 Batterymarch Park
                P.O. Box 9101
           Quincy, MA 02269-9904

      For additional information on the SARA
Title  HI  requirements, contact  the Emergency
Planning and Community-Right-to-Know Hotline.
The telephone numbers for the Hotline are: toll-
free  800-535-7672,   or 202-475-9652  in  the
Washington, D.C. area.

      Currently, there are four other Fact Sheets
that  are  available  on  the  worker  protection
standards for  hazardous  waste operations  and
emergency response:

            Hazardous  Waste  Operations  and
            Emergency Response:  Uncontrolled
            Hazardous  Waste  Sites  and  RCRA
            Corrective  Action (Pub.  No. 9285.2-
            08FS)  explains   the   specific
            requirements   for  hazardous waste
            operations conducted at uncontrolled
            hazardous  waste  sites,  including
            corrective actions  at  RCRA TSD
            facilities.

            Establishing   Work  Zones   at
             Uncontrolled Hazardous Waste Sites
             (Pub. No. 9285.2-06FS) describes the
             requirements  and  procedures  for
             establishing  support   zones   at
             uncontrolled hazardous waste sites.

             Hazardous Waste  Operations  and
             Emergency Response:   RCRA  TSD
             and  Emergency  Response  Without
             Regard to Location (Pub. No. 9285.2-
              07FS)    describes    the   principal
              requirements of  the standards for
              hazardous waste operations at RCRA
              TSD    facilities    and    emergency
              response  operations  without regard
              to location.

              Hazardous  Waste  Operations  and
              Emergency  Response:     Available
              Guidance  (Pub.  No. 9285.2-10FS)
              describes    guidance     materials
                                                 64

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         developed  by  the  Environmental
         Response Team  to  help workers
         engaged   in  hazardous  waste
         operations  and emergency response
         understand  the   HAZWOPER
         requirements.
      Copies  of  these  Fact Sheets  may  be
obtained by calling or writing the Environmental
Response Team of EPA  in Edison,  New Jersey.
(Refer to Exhibit 4 for the appropriate address and
telephone numbers.)  Please specify  the title and
publication number of the Fact Sheet(s).
                                      EXHIBIT 4
                     Important Telephone Numbers and Addresses
•     U.S. EPA/ERT
      2890 Woodbridge Avenue
      Building 18 (MS-101)
      Edison, NJ  08837-3679
      (908) 321-6740 or (FTS) 340-6740

•     U.S. Department of Labor, OSHA
      Office of Health Compliance Assistance
      200 Constitution Avenue, NW
      Washington, D.C.  20210
      (202) 523-8036 or (FTS) 523-8036

OSHA Regional Offices

•     U.S. Department of Labor, OSHA
      Region 1
      133 Portland Street, 1st Floor
      Boston,  MA 02114
      (617) 565-7164 or (FTS) 835-7164

•     U.S. Department of Labor, OSHA
      Region 2
      201 Varick  Street, Room 670
      New York,  NY  10014
      (212) 337-2325 or (FTS) 660-2378

•     U.S. Department of Labor, OSHA
      Region 3
      Gateway Building, Suite 2100
      3535 Market Street
      Philadelphia, PA 19104
      (215) 596-1201 or  (FTS) 596-1201

•     U.S. Department of Labor, OSHA
      Region 4
      1375 Peachtree  Street, NE, Suite 587
      Atlanta, GA  30367
      (404) 347-3573 or (FTS) 257-3573
    U.S. Department of Labor, OSHA
    Region 5
    230 South Dearborn Street
    32nd Floor, Room 3244
    Chicago, IL 60604
    (312) 353-2220 or (FTS) 353-2220

    U.S. Department of Labor, OSHA
    Region 6
    525 Griffin Street, Room 602
    Dallas, TX  75202
    (214) 767-4731 or (FTS) 729-4731

    U.S. Department of Labor, OSHA
    Region 7
    911 Walnut Street
    Kansas City, MO  64106
    (816) 426-5861 or (FTS) 867-5861

    U.S. Department of Labor, OSHA
    Region 8
    1951 Stout Street
    Denver, CO 80204
    (303) 844-3061 or  (FTS) 564-3061

    U.S. Department of Labor, OSHA
    Region 9
    71 Stevenson Street, Suite 415
    San Francisco, CA 94105
    (415) 744-6670 or (FTS) 484-6670

    U.S. Department of Labor, OSHA
    Region 10
    1111 Third Avenue, Suite 715
    Seattle, WA 98101-3212
    (206) 442-5930 or (FTS) 399-5930
                                             65

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                                EXHIBIT 4 (continued)
                     Important Telephone Numbers and Addresses
EPA Regional Offices
      U.S. Environmental Protection Agency
      Region 1
      John F. Kennedy Federal Building
      Room 2203
      Boston, MA 02203
      (617) 565-3715 or (FTS) 835-3715

      U.S. Environmental Protection Agency
      Region 2
      Jacob K. Javitz Federal Building
      26 Federal Plaza
      New York,  NY  10278
      (212) 264-2657 or (FTS) 264-2657

      U.S. Environmental Protection Agency
      Region 3
      841 Chestnut Building
      Philadelphia, PA 19107
      (215) 597-9800 or (FTS) 597-9800

      U.S. Environmental Protection Agency
      Region 4
      345 Courtland Street, NE
      Atlanta, GA 30365
      (404) 347-4727 or (FTS) 257-4727

      U.S. Environmental Protection Agency
      Region 5
      230 South Dearborn Street
      Chicago, IL 60604
       (312) 353-2000 or (FTS) 353-2000
U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue, 9th Floor
Dallas, TX 75202
(214) 655-6444 or (FTS) 255-6444

U.S. Environmental Protection Agency
Region 7
726 Minnesota Avenue
Kansas City, KS  66115
(913) 551-7000 or (FTS) 276-7000

U.S. Environmental Protection Agency
Region 8
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1603 or (FTS) 293-1603

U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322

U.S. Environmental Protection Agency
Region  10
1200 6th Avenue
Seattle,  WA 98101
(206) 442-1200 or (FTS) 399-1200

Call the Emergency Planning and
Community Right-to-Know Information
Hotline for the addresses and telephone
numbers of state emergency response
commissions and local emergency planning
committees in your area. The telephone
numbers for the Hotline are: toll-free
800-535-7672,  or 202-475-9652 in the
 Washington, D.C. area.
                                                66

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                     SECTION 3

            QUICK REFERENCE FACT SHEETS

                      PART 6

HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:
                AVAILABLE GUIDANCE
                        67

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                              United States
                              Environmental Protection
                              Agency
                          Office of
                          Solid Waste and
                          Emergency Response
Publication 9285 2-10FS
April 1991
       EPA
Hazardous Waste  Operations
and  Emergency  Response:
Available  Guidance
   Office of Emergency and Remedial Response
   Emergency Response Division      MS-101
                                              Quick Reference Fact Sheet
                INTRODUCTION

                The U.S. Environmental Protection
                Agency   (EPA)   and   the   U.S.
                Occupational  Safety  and  Health
                Administration (OSHA) have issued
                identical health and safety standards
to protect workers engaged in hazardous waste operations
and emergency response (HAZWOPER).  The  EPA
regulations are codified at 40 CFR Part 311 (54 FR
6654).  The OSHA regulations are codified at 29  CFR
1910.120 (54 FR 9294 and 55 FR 14072).

       The Environmental  Response Team  (ERT) at
EPA developed this Fact Sheet to alert interested parties
to the availability of guidance materials that will help
employers, employees,  On-Scene Coordinators (OSCs),
and  Remedial  Project Managers  (RPMs)  to better
understand and  comply  with  the  new HAZWOPER
standards.   This Fact  Sheet  is organized  into  four
sections, representing the four distinct formats used to
present information about  the new requirements:  (1)
Software; (2) HAZWOPER Fact Sheets;  (3) Guidance
Documents; and (4) Training.   Exhibit 1  presents at a
glance the various guidance that is described in this Fact
Sheet.
                COMPUTER SOFTWARE

                Two major ERT software systems are
                currently available for HAZWOPER.
                The topics addressed by these systems
                are discussed below and are listed in
                Exhibit 2.
Health and Safety Planner (U.S. EPA, 1990)

       The Health and Safety Planner (HASP) — often
called the generic health and safety plan — is a  menu-
                        driven computerized software system designed to assist
                        health and safety officers in designing, implementing, and
                        updating a site health and safety plan.  HASP contains
                        several valuable data bases that include information on
                        chemical hazards associated with many of the chemicals
                        typically found at an uncontrolled hazardous waste  site.
                        HASP allows  the  user to retrieve data on  chemical
                        hazards,  suggests  appropriate  monitoring   devices,
                        identifies likely routes of exposure, and recommends
                        levels of personal protective equipment based on those
                        hazards and the tasks that will be performed at the  site
                        HASP  also  includes  standard  protocols  for  typical
                        assessment and remediation activities.   Finally, HASP
                        uses standard text components to actually produce a  site-
                        specific health and  safety plan, addressing the potential
                        hazards identified for the site.  The health and safety  plan
                        format generated by HASP is consistent with OSHA's 29
                        CFR 1910.120 requirements. HASP is available on either
                        3'/2" or 5'/T diskettes, for either double density or  high
                        density disk drives; it runs on most IBM-compatible
                        personal computers, and  it comes with a User's Guide
                        (OSWER Directive 9285.8-01).

                        Field Certification Tracking System (U.S. EPA, 1989)

                               The Field Certification Tracking System (FCTS)
                        is a computerized  software system that  simplifies  the
                        recordkeeping associated with  the health  and' safety
                        requirements under HAZWOPER.  The system creates
                        personnel files, updates the personnel files, and produces
                        personnel reports.  FCTS is essentially a tracking system;
                        it cannot be  used to  identify training and  medical
                        monitoring requirements, but rather allows  the user to
                        specify  the requirements and to track the employee's
                        fulfillment of those requirements. Employees working at
                        a location, for example, may be grouped  into categories,
                        such as HAZMAT Team Member, routine site worker, or
                        first responder, and then training and medical monitoring
                        requirements for each worker or each category of workers
                                              69

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                                                   EXHIBIT 1
                                               Available Guidance
                    Computer Software

       Health and Safety Planner (HASP)
       Field Certification Tracking System (FCTS)
                  HAZWOPER Fact Sheets

       Hazardous Waste Operations and Emergency Response
       General Information and Comparison
       Hazardous Waste Operations and Emergency Response
       Uncontrolled Hazardous Waste Sues and RCRA
       Corrective Action
       Hazardous Wasie Operations and Emergency Response
       RCRA TSD and Emergency Response Without Regard 10
       Location
       Establishing Work Zones at Uncontrolled Hazardous
       Waste Sites
               Guidance Documents

  Hazmat Team Planning Guidance
  Occupational Medical Monitoring Program Guidelines for
  SARA Hazardous Waste Field Activity Personnel
  Health and Safety Audit Guidelines
  Standard Operating Safety Guides
  Field Standard Operating Procedures
                    Training

   Hazardous Materials Incident Response Training Program
   Course Schedule

EXHIBIT 2
Computer Software
Health and Safely Planner
• Identification of chemical hazards
• Selection of monitoring devices
• Identification of likely routes of exposure
• Selection of personal protective equipment

Field Certification Tracking System
• Simplification of recordkeeping for field personnel
• Creation of personnel files for health and safety
requirements
• Updating of personnel files



must be input into the FCTS system. The training and
medical  monitoring  requirements  entered  for each
employee may  be more or  less stringent than  those
specified in 29 CFR 1910.120. Thus, although all affected
employees must comply with  the training  and medical
monitoring  requirements  in  29  CFR 1910.120, FCTS
provides the user  with flexibility regarding the elements
that will be tracked. Once a personnel fi!e is created, the
system can be  used to  list the required training for an
employee's category, update an employee's file to reflect
newly  acquired training, and target personnel  files  to
identify employees who are overdue for a particular type
of training.  FCTS is  available  on either 3'/z"  or 5W
diskettes, for either double density or high density disk
drives,  it  runs  on  most  IBM-compatible personal
computers, and it comes with a User's Guide (OSWER
Directive 9285.3-03).

                   HAZWOPER FACT SHEETS

                   Currently, there are four available
                   ERT Fact Sheets (in addition to this
                   one) that provide  guidance  on the
                   HAZWOPER  requirements.   The
                   topics addressed by these Fact Sheets
are discussed below and are presented in Exhibit 3.

Hazardous Waste Operations and Emergency Response:
General Information and Comparison (U.S. EPA,  1991,
Pub. No. 9285.2-09FS)

        This Fact Sheet explains the scope and  purpose
of (he HAZWOPER  standards, and  distinguishes the
Title  I   standards  from  regulations  and  consensus
standards  covering the same or  similar subject matter.
Specifically, this Fact  Sheet provides a brief legislative
history of HAZWOPER,  and compares it with  other
programs governing the same kinds of activities, such as
                                                            70

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                     EXHIBIT 3
              HAZWOPER Fact Sheets
                General Information and
                      Comparison

       Overview of EPA and OSHA Authonly
       Comparing Regulatory Requirements
       Comparing General Requirements
       NFPA's Hazardous Materials Incidents Publications
       Sources of Additional Information
            Unconlrolled Hazardous Waste Sites
               and RCRA Corrective Action

       Planning Requirements
       Training Requirements
       Medical Surveillance Requirements
       Other Requirements
       Employee Rights
       Sources of Additional Information
                RCRA TSD and Emergency
            Response Without Regard to Location

       Requirements for Planning, Training, and Medical
       Surveillance for Emergency Response Without
       Regard to Location
       Requirements for Planning, Training, and Medical
       Surveillance at RCRA TSD Facilities
       Sources of Additional Information
          Establishing Work Zones at Unconlrolled
                  Hazardous Waste Sites

       Definitions of Work Zones
       Data Collection Requirements
       Selection of Work Zones
       Ensuring Integrity of Work Zones
       Consultation and References
SARA Title III  and OSHA's proposed  rule on  highly
hazardous substances. This Fact Sheet also discusses how
the HAZWOPER requirements relate to the industry-
specific standards  at  29 CFR  1910 and  the standards
applicable to the construction industry at 29 CFR 1926.
Finally, this Fact Sheet  describes relevant National Fire
Protection Association  (NFPA) publications and their
relationship to HAZWOPER.
Hazardous Waste Operations and Emergency Response:
Unconlrolled Hazardous Waste Sites and RCRA Corrective
Action (U.S. EPA, 1991, Pub. No.  9285.2-08FS)

        This   Fact   Sheet   explains   the   principle
HAZWOPER requirements as they apply to employees
engaged in hazardous  waste operations and  emergency
response at uncontrolled hazardous waste sites, including
employees who perform corrective actions at RCRA TSD
facilities.    Specifically, this Fact Sheet  describes  the
relevant  planning,  training, and medical surveillance
requirements in HAZWOPER, including the site control
and decontamination programs, the emergency response
plan, the  spill containment program, and the  specific
responsibilities of  the OSC/RPM and  ERT.   Other
requirements, such as the procedures for handling drums
and containers, illumination and sanitation requirements,
and the informational and new technology programs also
are addressed.    Finally,  this  Fact Sheet discusses
employee  rights under section  8 of the Occupational
Safety and  Health Act of  1970, as amended (OSH Act)

Hazardous  Waste Operations and Emergency Response:
RCRA TSD and Emergency Response Without Regard to
Location (U.S. EPA, 1991, Pub. No. 9285.2-07FS)

        This  Fact Sheet describes the planning, training,
and medical surveillance requirements in HAZWOPER
as  they apply to  emergency responders regardless of
location,  and employees who perform routine hazardous
waste operations at RCRA TSD facilities.   The Fact
Sheet explains the applicable HAZWOPER planning and
medical monitoring requirements, as well  as the  five
specific levels of  training  required  for  responders to
emergencies  that could occur at any location.

Establishing Work Zones at Uncontrolled Hazardous Waste
Sites (U.S.  EPA, 1991,  Pub. No. 9285.2-06FS)

        This  Fact  Sheet  summarizes the  requirements
and procedures for  establishing and maintaining Support
Zones  (i.e., Clean Zones) at hazardous waste sues   The
Fact Sheet defines the  different work zones usually found
at  a hazardous waste site (i.e., Exclusion, Contamination
Reduction, and Support), describes data collection  and
site  characterization  requirements   for  establishing  a
Support  Zone  (both  prior to and  during  initial  site
entry), provides information on selecting and maintaining
work zones (i.e., data  compilation and  evaluation),  and
provides information on maintaining the work zones (i.e.,
use of site controls, periodic monitoring of the support
zone, and  other considerations).  This Fact Sheet  also
references a  number  of  technical  guidance  documents
                                                      71

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that address some of the activities that are conducted in
establishing work zones (e.g., air monitoring).
                  GUIDANCE DOCUMENTS

                  Five major ERT guidance documents
                  are  currently   available   for
                  HAZWOPER. The topics addressed
                  by these documents are  discussed
                  briefly below and are presented in
                  Exhibit 4.
Haunal Team Planning Guidance (U.S. EPA,  1990, Pub.
No. EPA/540/G-90/003)

        The Hazmat Team Planning Guidance document
assists  local  fire  departments and  other response
organizations in establishing  a  HAZMAT Team.  The
document identifies  necessary equipment  and suggests
ways to acquire and maintain the equipment and to train
personnel for the HAZMAT Team.  The document offers
guidance  in  determining actual HAZMAT response
requirements,  establishing  the goals  and   levels of
expertise  needed  to  meet  those  requirements,  and
estimating  the costs  of meeting   those goals.  The
document also  provides assistance in preparing response
plans and standard operating procedures (SOPs).  The
Appendices to  the document provide a summary of how
to begin the  hazards analysis  process and how to design
a medical program.  The Appendices also contain a list
of  EPA  Regional  Superfund  training contacts  and
selected guidance and reference documents.

Occupational Medical Monitoring Program Guidelines for
SARA Hazardous Waste Field Activity Personnel (U.S. EPA,
 1990, Pub. No. OSVVER Directive 9285.3-04)

        This  summary document  provides  guidelines
 covering   the   requirements  for  a  comprehensive
 occupational medical monitoring program for personnel
 involved  in  hazardous  waste  field  activities.   This
 document   outlines  general   medical   monitoring
 requirements such as the  type of physician who  must
 perform or supervise examinations, and the procedures
 required  of  the  personnel  who  must  undergo  the
 monitoring.  The four types of examinations — baseline,
 periodic,  unscheduled, and termination — are described,
 as well as reporting requirements, special requirements
 (i.e., immunizations,  research  tests, and reproductive
 hazards),  and the  relationship  between occupational
 medical monitoring and workers' compensation.  The
 Appendices  to the  document address the minimum
 examination types and content, and provide guidelines for
 immunization requirements. References are also provided.
EPA Health and Safety Audit Guidelines (U.S. EPA, 1989,
Pub. No. EPA/540/G-89/010)

        These Guidelines provide a representative sample
of the HAZWOPER requirements at different stages of
cleanup at an uncontrolled hazardous waste site, as well
as during emergency response operations that  occur
without regard to location.   It is in  a workbook format
that provides the user with space for notes regarding the
comprehensiveness and efficacy of the written site-specific
health and safety plan, as well as the  health and  safety
measures being implemented in the field and during off-
site emergency response operations.  The Guidelines may
be used to  assist  an  auditor  or  site supervisor  in
obtaining a sense of the likely level of compliance with
the HAZWOPER requirements; they, however, are not
meant  to  be  a  comprehensive  compilation  of all
requirements. If compliance with the specific elements in
a  subsection  of  these guidelines is  excellent, then it is
likely that  all requirements  under that  subsection have
besn met. If, on the other hand, compliance is sketchy or
weak, it is advisable to pursue additional questions and to
further investigate compliance with that subsection. The
EPA Audit Guidelines are in a simple, easy to follow,
question and  answer format.   The Appendices to the
document  provide an incident safety  check-off  list,  a
description of levels of personnel protection, and a log
and summary form for occupational injuries and illnesses.

Standard Operating  Safety  Guides   (U.S.  EPA,  1988,
OSWER Directive 9285.1-OIC)

         The  Standard Operating Safety Guides  (SOSG)
 provide guidelines  for  use  by any   organization  in
developing its own specific operation  safety procedures.
These Guides should be adapted to address the safety
 criteria  required for protection of response personnel
 from  the  hazards created  by a specific operation or
 incident.   This  document  is  not   meant  to  be  a
 comprehensive  safety manual,  but rather  it  provides
 technical  information  that  should be considered in
 developing instructions on how  to accomplish specific
 hazardous waste operations in a safe manner.

 Field Standard Operating Procedures  (FSOPs)

         EPA has  published  a series of  FSOPs  that
 provides procedures to minimize the risk of exposure to
 hazardous substances.  These procedures were derived
 from  early drafts of EPA's Standard  Operating Safety
 Guides  and  are presented in a format that is more
 appropriate  for use in the  field.    Five  of the most
 relevant FSOPs are described below.
                                                           72

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                                                     EXHIBIT 4
                                                Guidance Documents
             Hazmal Team Planning Guidance

     Do you need a hazmat learn?
     Training and equipping your hazmat team
     Preparing response plans and standard operating
     procedures
             Health and Safely Audi! Guidelines

  •  Preliminary evaluation
  •  Wntlen health and safety plan review
  •  Health and safety field review
  •  Off-site emergency response review
         Occupational Medical Monitoring Program
           Guidelines for SARA Hazardous Waste
                  Field Activity Personnel

       General requirements
       Baseline examination
       Periodic examination
       Unscheduled examination
       Termination examination
       Reporting requirements
       Special requirements
       Relationship between occupational medical monitoring
       and workers' compensation
       Minimum examination types and requirements
       Guidelines for immunization requirements
             Standard Operating Safely Guides

     Environmental incidents
     Standard operating procedures
     Health and safety requirements
     Sue safety plan
     Initial site survey and reconnaissance
     Levels of persona!  protective equipment
     Effects of stress
     Work zones
     Decontamination
     Air surveillance
                                            Field Standard Operating Procedures

                                   •  Sue entry
                                   •  Work zones
                                   •  Decontamination of response personnel
                                   •  Air surveillance
                                   •  Site safety plan
        FSOP #4:  Site Entry (U.S. EPA,  1985, OSWER
Directive 9285.2-01).  This document discusses site entry
procedures,   including  proper  selection,   use,  and
decontamination of personal protective equipment; use of
field equipment;  activities conducted during  initial site
entry;  and  check-out  procedures for  a  self-contained
breathing apparatus.

        FSOP #6:  Work Zones (U.S. EPA, 1985, OSWER
Directive 9285.2-04).  This document discusses a number
of topics related  to work zones, including definitions of
work  zones,  methodology  for  selecting work zone
locations, personal protective levels, and air monitoring.

        FSOP #7: Decontamination of Response Personnel
(U.S. EPA,  1985, OSWER Directive  9285.2-02).  This
document  provides flow   charts  for  decontamination
layouts,  descriptions  of personal protective  equipment,
procedures   for   decontamination,   and    lists    of
decontamination equipment.

         FSOP #8:   Air Surveillance (U.S.  EPA,  1985,
OSWER Directive 9285.2-03).  This document describes
the types and methods of air surveillance, procedures and
equipment for air monitoring, and a method for analyzing
organic  solvents by gas chromatography

         FSOP #9:   Sue Safety Plan (U.S.  EPA,  1985,
OSWER Directive 9285.2-05).  This document describes
the general requirements for  a  site safety plan, discusses
development and  implementation of a site  safety plan,
and  provides sample  plans  and a checklist.
                                                           73

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                  TRAINING

                  As  part  of EPA's  comprehensive
                  program for protecting the public and
                  the enviionment  from  releases of
                  hazardous materials, ERT developed
                  the  Hazardous  Materials   Incident
Response Training (HMIRT)  Program.  A list of the
HMIRT courses is provided in  Exhibit 5  A schedule of
these courses is available from ERT in Cincinnati, Ohio.
                     EXHIBIT 5
                      Training
           Hazardous Materials incident Response
           Training Program Schedule of Courses

        Personal Protection and Safely
        Hazardous Materials Treatment Technologies
        Air Surveillance for Hazardous Materials
        Hazardous Materials Incident Response Operations
        Risk Assessment Guidance for Superfund
        Introduction to Groundwater Investigations
        Safety and Health Compliance for Managers
        Sampling for Hazardous Materials
        Radiation Safety at Superfund Sues
        Emergency Response to Hazardous Materials
        Incidents
        Advanced Air Sampling lor Ha/jrdous Materials
        Removal Cost Management System
 Hazardous Materials Incident Response Training
 Program Course Schedule

         The HMIRT program is designed for emergency
 responders and for personnel who investigate and clean
up  uncontrolled  hazardous waste sites.  The HMIRT
program currently has a .curriculum of 12 courses.  (See
Exhibit 5.)  The curriculum covers emergency operations,
as well as the scientific and technical aspects of response
to hazardous materials incidents.  The courses provide
specific  training  in  worker  health  and  safety and  in
various  technical operations that must be performed by
site  personnel  and  emergency  responders  to identify,
evaluate, and control releases of hazardous substances.

        All HMIRT courses, which generally last  from
three to  five days, emphasize the practical application of
lecture material through  problem solving, case studies,
and  demonstrations, along with actual  exercises using
response equipment and  instruments.   Many  of the
HMIRT courses are accredited by the American Council
on  Education.   The  program  also offers  continuing
education  units and  American  Board of  Industrial
Hygiene (ABIH) certificate maintenance credits  for
course participants.  Tuition for HMIRT courses is free
to any government worker, including federal, state, and
local personnel, as well as to volunteer fire companies;
however, there is a  nominal tuition fee  for members of
industry.

                  WHERE TO OBTAIN
                   GUIDANCE

                   The guidance described in this Fact
                   Sheet   can   be  obtained  from  the
                   sources shown  in Exhibit  6.   When
                   calling or writing, please be certain to
specify the title and identification number (if available)
of the guidance.
                                                         74

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                                                        EXHIBIT 6
                                                Where to Obtain Guidance
To Obtain:
•  Computer Software
   - HASP (and User's Guide, 9285.8-01)
   - FCTS (and User's Guide, 9285 3-03)

.  HAZWOPER Fact Sheets
   -• General Information and Comparison (9285 2-09FS)
   -- Uncontrolled Hazardous Waste Sites and RCRA
     Corrective Action (9285 2-08FS)
   -- RCRA TSD and Emergency Response Without Regard
     to Location (9285.2-07FS)
   -- Establishing Work Zones at Uncontrolled Hazardous
     Waste Sites (9285 2-06FS)

•  Occupational Medical Monitoring Program  Guidelines for
   SARA Hazardous Waste Field Activity Personnel
   (9285 3-04)

•  Standard Operating Safety Guides (9285 1-OIC)

•  Field Standard Operating Procedures
   -- FSOP #4  Sue Entry (9285 2-01)
   -- FSOP #6  Work Zones (9285 2-04)
   -- FSOP #1  Decontamination of Response Personnel
     (9285 2-02)
   -  FSOP #8  Air Surveillance (9285 2-03)
   - FSOP #9  Sue Safety Plan (9285 2-05)

Call or Write
.  U S  EPA/ERT ERC HAS
   2890 Wood bridge Avenue
   Building 18 (MS-101)
   Edison, NJ 08837-3679
   (908) 321-6740 or (FTS) 340-6740
To Obtain:
•  Hazmal Team Planning Guidance (I-PA/540/G-90/003)

.  Health and Safety Audit Guidelines (l£PA/540/G-89/OIO)

Cull or Write.
•  National Technical Information Sei^'i
   5285 Port  Royal Road
   Springfield, VA  22161
   (703) 487-4600
 To obtain:
 .   HMIRT Course Schedule

 Call or Write:
 .   U.S. EPA/ERT
    26 West Martin Luther King
    Cincinnati, OH 45268
    (513) 569-7537 or (FTS) 684-7537
To Obtain:
•  Other information on worker protection standards

Call or WriU:
•  Emergency  Planning and Community Right-to-Kjiow
    Information
   U.S  EPA(OS-120)
   401 M Street, SW
   Washington, D.C. 20460
   (800) 535-0202 or (202) 479-2449

•  Superfund Docket/U.S EPA
   401 M Street, SW
   Room 2427 SDIC
   Washington, D.C. 20460
   (202) 382-3046

•  U.S  Department of Labor
   Occupational Safety and Health Administration (OSHA)
   OSHA Publications  Office, Room N3101
   200 Constitution Avenue, NW
   Washington, D.C. 20210
   (202) 523-9667

•  National Institute of Occupational Safely and Healih
   NIOSH Publications
   4676  Columbia  Parkway
   Cincinnati,  OH  45226

 •  Federal Emergency  Management Agency (FEMA)
   P.O  Box 70274
   Washington, D C. 20024
   (or contact FEMA Regional Office directly)

 •  Emergency Management Institute (EMI)/
     National  Fire  Protection Academy (NFA)
   Federal Emergency  Management Agency
   16825 South Seton Avenue
   Emmitsburg, MD 21727
   (301) 447-1122

 •  National Fire Protection Association (NFPA)
   1 Bauerymarch Park
   P O  Box 9101
   Qumcy, MA  02269-9101
   (617) 770-3000

 •  Fire Protection  Publications
   Oklahoma  State University
   Snllwater, OK  74078-0118
   (405) 744-7576

 •  Superintendent  of Documents
    U S  Government Pnnting Office
    Washington,  D.C.  20402
    (202) 783-3238

 •   National Technical  Information Service (NTIS)
    5285 Port Royal Road
    Springfield, VA 22161
    (703) 487-4600
                                                            75

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    SECTION 4




AIR SURVEILLANCE

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                              AIR SURVEILLANCE



SECTION OBJECTIVE

The objectives of this section are to:

       •      Discuss charactersics and types of air monitoring and sampling equipment.

       •      Provide students with a list of manufacturers and suppliers of air monitoring and
             sampling equipment.



STUDENT PERFORMANCE OBJECTIVES

After completing this section and related lesson(s), the student will be able to:

       •      Identify various types of air surveillance equipment.

       •      Discuss the basics of initial site survey and long term monitoring, and identify factors
             affecting an air surveillance plan.

       •      Compare and contrast available air surveillance techniques.

       •      Identify manufacturers and  suppliers of air monitoring and sampling equipment.

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                                     SECTION 4

                               AIR SURVEILLANCE

                                        PART 1

      CHARACTERISTICS AND TYPES OF AIR SURVEILLANCE EQUIPMENT



I.      INTRODUCTION

       Airborne contaminants can present a significant threat to human health. Identifying and
       quantifying these contaminants by air monitoring is an essential component of a health and
       safety program at a hazardous waste site.  Air monitoring data is useful for:

              Assessing the health risks to the public and response workers.
              Selecting personal protective equipment.
              Delineating areas where protection is needed.
              Determining actual or  potential effects on the environment.
              Selecting actions to mitigate the hazards safely and effectively.

       Direct-reading instruments were developed as early warning devices for use  in industrial
       settings, where leaks or an accident  could release a high concentration of a known chemical.
       Today, some direct reading instruments can detect low concentrations of contaminants  as
       little as one part contaminant per million parts of air  (ppm).  Direct-reading instruments
       provide information  at the time of sampling and  do not require sending  samples  to  a
       laboratory for subsequent analysis.  This characteristic of direct-reading instruments enables
       rapid decision-making.

       Many of the common types of monitoring equipment  discussed in this part  are listed  in
       tabular form in APPENDIX I.



II.    CHARACTERISTICS OF AIR MONITORING INSTRUMENTS

       To be useful air monitoring instruments must be:

       •      Portable and rugged.
       •      Easy to operate.
       •      Inherently safe.
       •      Able to generate reliable and useful results.

       A.     Portability

              A  prime  consideration for  field instruments is portability.  Transportation shock
              resulting  from the movement from one place to  another, together with unintentional
              abuse, shortens the usable  life of an instrument.   To reduce  the effects of this
              trauma, instruments should be selected that have reinforced shells or frames, shock-
              mounted  electronic packages, or padded containers for shipment.
6/91
                                             1

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             Exposure to the elements and to the test atmosphere itself is of concern for those
             instruments  repeatedly  used  in  adverse conditions  or  as  long-term  monitors.
             Anodized or coated  finishes, weather resistant packaging and remote sensors are
             effective in reducing downtime and increasing portability.

             An internal power supply  is important for portability.   Some  instruments use
             replaceable or rechargeable batteries and some do not require a power supply.

             An instrument should not be so heavy  or bulky that  it is difficult for a response
             worker to carry.

      B.     Ease Of Operation

             Because many of these instruments were designed for industrial use, allowances may
             not have been made for  using the instrument while wearing protective equipment.
             One must consider how easy it is to use the instrument while wearing gloves or how
             difficult it  is to read the meter while wearing  a respirator.  Also, how quickly a
             worker can learn to operate the instrument correctly should be considered.

             Preparation time for use of the instrument should  be short. Rapid warm-up,  easy
             attachment  of accessories, and quick instrument checks shorten preparation time.

      C.     Inherent Safety

             The portable instrumentation used  to characterize hazardous material spills or waste
             sites  must be safe  to use.   Electrical  devices,  including instruments, must be
             constructed in such a fashion as to  prevent the ignition of a combustible atmosphere.
             The sources of this ignition could be:  an arc generated by the power  source itself
             or the associated electronics, or a flame or heat source necessary  for function of the
             instrument.    Several  engineering,  insurance,   and  safety  organizations  have
             standardized test methods,  established   inclusive  definitions,  and developed codes
             for testing  electrical devices used in  hazardous locations.  The  National  Fire
             Protection Association  (NFPA) has  created minimum standards  in  its National
             Electrical Code (NEC) published every 3 years.  This code spells out types of areas
             in which hazardous atmospheres  can be generated and the types of materials that
             generate these atmospheres, and design safeguards acceptable for use in hazardous
             atmospheres.

              1.     Hazardous Atmospheres

                     Depending upon the response  worker's background,  the term "hazardous
                     atmosphere" conjures up situations ranging from  toxic air contaminants to
                     flammable atmospheres. For NEC purposes, an atmosphere is hazardous if
                     it meets the following criteria:

                     •      It is a mixture of any flammable material in air whose concentration
                            is within  the material's flammable range (i.e. between the material's
                            lower flammable limit and its upper flammable limit).
                     •      There is the potential for an ignition source to be present.
                     •      The resulting exothermic reaction  could propagate beyond where  it
                            started.
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                    To adequately describe hazardous atmospheres, the NEC categories them
                    according to their Class, Group, and Division.

                    a.      Class and Group

                            Class  is a category  describing the type of flammable material that
                            produces the hazardous atmosphere:

                            •      Class I is flammable vapors and gases,  such as gasoline and
                                   hydrogen.   Class I is  further divided into groups A, B,  C,
                                   and D  on  the basis of similar  flammability characteristics
                                   (TABLE I).
                            •      Class II consists of combustible dusts like coal or grain and
                                   is divided into groups  E, F, and G (TABLE 2).
                            •      Class  III is  ignitable fibers such as  produced by cotton
                                   milling.

                    b.      Division

                            Division is the term describing the "location"  of generation and
                            release of the flammable material.

                            •      Division 1 is a location where the generation and release are
                                   continuous, intermittent, or periodic into an open, unconfmed
                                   area under normal conditions.
                            •      Division 2 is a location where the generation and release are
                                   only  from  ruptures,  leaks  or  other  failures from closed
                                   systems or containers.
6/91

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                                      TABLE 1
                  SELECTED CLASS I CHEMICALS BY GROUPS
 Group A    Atmospheres acetylene
 Group B    Atmospheres (not sealed in conduit 1/2 inch of larger)

      1,3-butadiene
      ethylene oxide
      formaldehyde (gas)
      hydrogen
      manufactured gas (containing greater than 30% H2 by volume)
      propylene oxide
      propyl  nitrate
      allyl glycidyl ether
      n-butyl glycidyl ether
 Group C    Atmospheres (selected chemicals)

      acetaldehyde                epichlorohydrin             tetrahydrofuran
      carbon monoxide            ethylene                    triethylamine
      crotonaldehyde              ethyl mercaptan             ethylene glycol
      dicyclopentadiene           hydrogen cyanide           monoethyl ether
      diethyl ether                hydrogen selenide           hydrazine
      di-isobutyl amine           hydrogen sulfide            chloroaldehyde
      methylacetylene             morpholine                 tetraethyl lead
      ethylene glycol              monoethyl                  (39 others)
      ether acetate                nitropropane
 Group D   Atmospheres (selected chemicals)

      acetone                    methane                    acetonitrile
      methanol                   acrylonitrile                methyl ethyl ketone
      ammonia                   naphtha                    benzene
      propane                    butane              styrene
      chlorobenzene       vinyl chloride
      Source:  Classification of Gases. Vapors and Dusts for Electrical Equipment in
      Hazardous  (classified)  Locations.  1986 National Fire  Protection  Association
      ANSI/NFPA 497M.
6/91

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                                       TABLE 2
                   SELECTED CLASS II CHEMICALS BY GROUPS
 Group E   Conductive Dusts

       Atmospheres containing metal dusts, including aluminum, magnesium, and their
       commercial alloys, and other metals of similarly hazardous characteristics.
  Group F   Semi-Volatile Dusts

       Atmospheres containing carbon black, coal or coke dust with more than 8% volatile
       material.
  Group G   Non-Conductive Dusts

       Atmospheres containing flour, starch, grain, carbonaceous, chemical thermoplastic,
       thermosetting and molding compounds.
       Source:   Classification of Gases.  Vapors and Dusts for Electrical  Equipment in
       Hazardous  (classified) Locations. 1986 National Fire  Protection  Association
       ANSI/NFPA 497M.
             2.     Using this system

                    A hazardous atmosphere can be routinely and adequately defined.  As an
                    example, an abandoned waste site containing intact closed drums of methyl
                    ethyl ketone, toluene and xylene would be considered a Class I, Division 2,
                    Group D environment. However, when transferring of the flammable liquids
                    takes place at the site, or if releases of flammable gases/vapors is considered
                    normal, the areas would be considered Class I, Division 1.

             3.     Controls

                    The following three methods of construction  exist to prevent a potential
                    source from igniting a flammable atmosphere:

                    •     Explosion-proof:  Explosion-proof instruments allow the flammable
                           atmosphere to enter.  If an arc is generated, the ensuing explosion is
                           contained within the specially built enclosure. Within it, any flames
                           or hot gases are  cooled prior to exiting into the  ambient flammable
                           atmosphere  so  that  the  explosion  does not   spread  into  the
                           environment.

                    •     Intrinsically Safe:   The potential  for arcing  among components is
                           reduced by  encasing  them in a solid  insulating  material.   Also,
                           reducing the instrument's operational current and voltage below the
                           energy level  necessary  for ignition of the flammable  atmosphere
                           provides protection. An "intrinsically safe" device, as defined by the
6/91

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                           National  Electrical  Code,  is incapable  "of releasing  sufficient
                           electrical or thermal energy under normal or abnormal conditions to
                           cause ignition of a specific hazardous atmospheric mixture in its most
                           easily ignited  concentration.  Abnormal conditions shall  include
                           accidental damage to any wiring, failure of electrical components,
                           application of over-voltage, adjustment and maintenance operations
                           and other similar conditions".
                           Purged:  The arcing or flame-producing device is buffered from the
                           flammable atmosphere with  an  inert  gas.   In  a  pressurized  or
                           "purged" system, a steady stream of, nitrogen or helium is passed by
                           the potential  arcing device,  keeping the flammable atmosphere from
                           the ignition  source.   This type of  control, however, does not
                           satisfactorily control analytical devices  that use flame or  heat for
                           analysis, such as  a combustible gas indicator (CGI).  It also  requires
                           a source of gas which  would reduce  instrument portability.
             4.     Certification
                    If a device is certified as explosion-proof,intrinsically safe, or purged for a
                    given Class, Division, and Group,  and is used, maintained, and  serviced
                    according to the manufacturer's instructions, it will not contribute to ignition.
                    The device is not, however, certified for use in atmospheres other than those
                    indicated.  All certified devices must be marked to show  Class, Division, and
                    Group,   (see FIGURE 1)   Any manufacturer wishing to have an electrical
                    device certified must submit a prototype to a laboratory for testing.   If the
                    unit passes, it is certified as submitted.  However, the  manufacturer  agrees
                    to allow the testing laboratory to randomly check the manufacturing plant at
                    any time, as well as any marketed units.  Furthermore,  any change in the
                    unit requires the manufacturer  to  notify the test laboratory,  which can
                    continue the certification  or withdraw it until  the modified unit can be
                    retested.  NFPA does not  do certification testing.  Testing is done by such
                    organizations as Underwriters' Laboratory  Inc.  (UL) or  Factory Mutual
                    Research Corp. (FM).   Currently,  these  are  the only  two testing labs
                    recognized  by OSHA.
6/91

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f^|br7^
Combustible Gas and Q2 Alarm
"~^™~* model 260 part no. 449900
^^" calibriud for Pentane

G'OVPI C ind D »nd Hon-mCf ndive lor u»< m Cljn 1. O'vmon 3. Graven A
S. C. »n(J D »h«i» uito -ll^ USA 3
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      D.     Reliable and Useful Results

             The response time, sensitivity, selectivity,  accuracy and precision of an instrument
             are important in evaluating the reliability and usefulness of the data the instrument
             generates.

             Response  time,  the  interval  between an instrument "sensing" a contaminant  and
             generating data, is important to producing reliable and useful results  in the field.
             Response  time depends  on:  test(s)  to be  performed,  dead time between sample
             periods (the time for analysis, data generation, and data display), and the sensitivity
             of the instrument.  Response times for direct-reading  instruments  may range from
             a few seconds to several minutes.

             Sensitivity is important  when slight concentration  changes  can be dangerous.
             Sensitivity is defined as the ability of an instrument to accurately measure changes
             in concentration.  Sensitive instruments can detect small changes in concentration.
             The lower detection limit  is  the lowest  concentration to which instrument  will
             respond to. The operating range is the lower and upper use limits of the instrument.
             It is defined by the lower detection limit at one end and the saturation concentration
             at the other end.  It is important to  use an instrument  with an operating range that
             will accurately measure the concentration in the range  of concern.

             Amplification,  a term often used synonymously (and incorrectly) with sensitivity, is
             the instrument's ability to increase very small electronic signals emanating from the
             detector to the  readout.  Changing the amplification of the detector does not change
             its sensitivity.  However, it may be useful in calibration.  Instruments with amplifier
             circuits can be effected  by radio frequency from pulsed DC or AC  power lines,
             transformers, generators, and radio  wave transmitters.

             Accuracy is defined as  the  relationship between  a  true value and the instrument
             reading.  Precision is the indication of the reproducibility.   These factors can be
             indicated  by the error factor. For example, some  detector  tubes may have an error
             factor of ±35% of the true value; meaning the actual concentration of  the chemical
             being measured is within a range of 35% higher and lower than the tube reading.

             Selectivity is the ability of an instrument to detect and measure a specific chemical
             or group of similar chemicals.  Additionally, selectivity is dependent upon interfering
             compounds which may produce a similar response.  Selectivity and sensitivity must
             be reviewed and interpreted together. Interferences can effect the accuracy of the
             instrument reading.

             Another consideration is that the instrument must give results that are immediately
             useful. Instruments should be direct reading,  with  little or no need to interpolate,
             integrate, or compile large amounts of data.

             When selecting an instrument, compare the desired  sensitivity,  range, accuracy,
             selectivity, and ability to vary amplification of detector signals with  the available
              instrument characteristics.
6/91

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III.    CALIBRATION AND RELATIVE RESPONSE

       For an instrument to function properly in the field, it should be calibrated prior to  use.
       Calibration is the process of adjusting the instrument readout so that it corresponds to the
       actual concentration.  Calibration  involves checking the  instrument results with  a known
       concentration of a gas or vapor to  see that the instrument
       gives the proper response.  For example, if a combustible gas meter is calibrated with a gas
       that is 20% of the lower explosive  limit (LEL), then the instrument should read 20% of the
       LEL.  If it does not read accurately, it is out of calibration  and should be adjusted until
       accurate readings are obtained.  Although an instrument is calibrated to give a one-to-one
       response for a specific chemical (the calibration  gas), its response to other chemicals  may
       be different.   This variability is  called relative response.  A combustible gas  indicator
       calibrated to  pentane will  give  a  higher instrument reading  for methane than the actual
       concentration (see TABLE 3). The relative response of an instrument to different chemicals
       can be calculated by dividing the instrument reading  by the actual concentration  and is
       expressed as a ratio or a percent. Note that for the calibration standard the relative response
       should be 1.00 or 100%.

       If the instrument is being used for a chemical that is not the calibration standard, then it may
       be possible to look at the  manufacturer's information  to get the relative response of that
       instrument for the chemical. Then  the actual concentration can be calculated. For example,
       if the instrument's  relative response for xylene  is .27  (27%) and the reading is  100  ppm
       (parts per million), then the actual concentration is 370 ppm (.27 x actual concentration =
       100 ppm, then actual concentration = 100/.27 =  370 ppm). If there is no relative response
       data for the chemical in question, it may be possible to recalibrate the instrument. If the
       instrument has adjustable settings and a known concentration is available, the instrument may
       be adjusted to read directly for  the chemical. As recalibration takes time, this  is usually
       done only if the instrument is  going  to be  used for  many  measurements of the special
       chemical.
TABLE 3
RELATIVE RESPONSE FOR A COMBUSTIBLE GAS
INDICATOR CALIBRATED TO PENTANE
Chemical
Methane
Acetylene
Pentane
1,4-Dioxane
Xylene
Concentration
(% LEL)
50
50
50
50
50
Meter Response
(% LEL)
85
60
53
37
27
Relative
Response
170%
120%
106%
74%
54%
        Source:   Portable Gas  Indicator.  Model 250  &  260. Response Curves.  Mine  Safety
        Appliances Company,  Pittsburgh, PA.
 6/91

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IV.    TYPES OF DIRECT-READING INSTRUMENTS

       A.     Introduction

              Many hazards  may be  present when responding to hazardous materials spills  or
              uncontrolled waste sites.  There are several types of instrumentation for detecting
              hazardous atmospheres. This section will discuss oxygen indicators, combustible gas
              indicators, and toxic atmosphere monitors.

       B.     Oxygen Indicators

              Oxygen indicators  are used  to evaluate an atmosphere for the following:

              •      Oxygen content for respiratory purposes.  Normal  air  is 20.9% oxygen.
                     Generally, if  the oxygen content decreases below 19.5% it  is considered
                     oxygen deficient and special respiratory protection is needed.
              •      Increased risk of  combustion.   Generally, concentrations above 25%  are
                     considered oxygen-enriched and increase the risk of combustion.
              •      Use of other instruments.  Some instruments require sufficient oxygen for
                     operation.  For example, some combustible gas indicators do not give
                     reliable results  at oxygen  concentrations below 10%.  Also, the inherent
                     safety approvals for  instruments are for normal  atmospheres and not for
                     oxygen enriched ones.
              •      Presence of contaminants.  A decrease in oxygen content can be due  to the
                     consumption (by combustion or a reaction such as rusting) of oxygen  or the
                     displacement  of air by a chemical.   If it is  due to consumption then the
                     concern is the lack of oxygen. If it is due  to displacement then there is
                     something present that could be flammable or toxic.

              Oxygen deficient atmospheres may  occur in unventilated  areas or may by due to
              terrain variations in cases  where heavier  than air  vapors may collect.   Most
              indicators have meters which display the oxygen concentration from  0-25%.  There
              are also oxygen indicators available which measure concentrations from 0-5%  and
              0-100%.  The most useful range for response is the 0-25% oxygen content readout
              since decisions involving air-supplying respirators and the use  of combustible gas
              indicators fall  into this range.

              Many instrument manufacturers  make oxygen meters.  They  can be small hand-held
              units with  or  without pumps to draw the  sample across the detector cell.  Some
              pumps are  single aspirating (hand-squeeze) bulbs,  others are  battery powered
              diaphragm  pumps. Units that combine 0^ meters and combustible gas  indicators into
              one instrument are available from a number of manufacturers.  Also, flashing and
              audible alarms can be found on many instruments.  These alarms go  off at a pre-set
              oxygen concentration to  alert the users even if they are  not watching  the  meter.
              Manufacturers of oxygen indicators  are found at the end of this manual section.

               1.     Principle of Operation

                     Oxygen indicators have two  principle components for operation.  These are
                     the oxygen sensor and the meter readout. In some units air is  drawn into the
                     oxygen detector with an aspirator bulb or pump; in other units, the ambient


 6/91                                       10

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                    air is  allowed to diffuse  to the  sensor.   The  oxygen detector uses an
                    electrochemical  sensor  to  determine  the oxygen concentration  in air.   A
                    typical  sensor consists  of:   two electrodes; a housing containing a basic
                    electrolytic solution; and a semipermeable Teflon membrane (FIGURE 2).

                    Oxygen  molecules (O2) diffuse through the membrane into  the solution.
                    Reactions between the  oxygen, the solution and the electrodes produce  a
                    minute  electric  current proportional  to the oxygen content.  The current
                    passes through the electronic circuit.  The resulting signal is shown as  a
                    needle deflection on a meter or digital reading.

             2.     Limitations and  Considerations

                    The operation of oxygen  meters depends  on the  absolute atmospheric
                    pressure.  The  concentration of  natural  oxygen (to differentiate it from
                    manufactured or generated oxygen) is  a function of the atmospheric pressure
                    at a given  altitude. While the actual percentage of oxygen does  not change
                    with altitude, at sea level the weight of the  atmosphere above is greater,  and
                    more O2 molecules (and the other  components of air) are compressed into a
                    given  volume   than at higher elevations.   As  elevation increases,  this
                    compression decreases, resulting in fewer  air  molecules being  "squeezed"
                    into a given  volume. Consequently,  an Oj indicator calibrated at sea level
                    and operated at  an altitude of several thousand feet  will falsely  indicate an
                    oxygen deficient atmosphere because less oxygen is being "pushed" into the
                    sensor.  Therefore, it is necessary to  calibrate at  the altitude the instrument
                    is used.
                                                             o
                                          1       I           I
MEMBRANE/COVER
                                                                         ELECTRODE
                                                                         ELECTRODE
                                                                          ELECTROLYTE
                                                  FIGURE 2
                                    SCHEMATIC OF OXYGEN SENSOR
              Selection from Product Literature. Rexnard Electronic Products Division. Biomarine
              Oxygen Sensor, by Rexnard, Inc., reprinted with permission of publisher.
6/91
                                            11

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                    High concentrations of carbon dioxide (CO,) shorten the useful life of the
                    oxygen sensor.   As a general  rule, the unit can be used  in atmospheres
                    greater than 0.5% CO2 only with frequent replacing or rejuvenating of the
                    sensor.  Lifetime in a  normal  atmosphere (0.04% COj) can be from one
                    week to one year depending on the manufacturer's design.

                    Temperature can  affect  the response of oxygen  indicators.  The normal
                    operating range for them is between 32°F and 120°F.  Between O°F and 32°F
                    the response of the unit is slower.  Below 0°F the sensor may be damaged
                    by the solution freezing. The  instrument should be calibrated  at the tem-
                    perature at  which  it will be used.

                    Strong oxidizing  chemicals, like ozone and chlorine, can  cause increased
                    readings and indicate high or normal  C^ content when the actual content is
                    normal or even low.

      C.     Combustible Atmosphere Indicators

             Combustible gas indicators (CGIs) measure the concentration of a flammable vapor
             or gas in air, indicating  the results as a percentage of the lower explosive limit
             (LEL) of the  calibration gas.

             The LEL (or LFL - lower flammable limit)  of a combustible gas or vapor is the
             minimum concentration of the material in air  which will propagate flame on contact
             with  an  ignition  source.  The upper  explosive limit  (UEL) is the maximum
             concentration. Above the UEL, the mixture is too "rich" to support combustion so
             ignition  is not possible.   Below the LEL  there  is insufficient  fuel to support
             combustion.

             CGI's are available in many styles and configurations.  All units have some type of
             pump to  draw the air sample into the detector.  The pumps are either hand operated
             square bulbs or automatic (battery-powered) diaphragm  types.   Many units are
             "combination meters".  This means they have an Oj meter and CGI (and sometimes
             one or two specific gas indicators) combined in the same instrument. Flashing and
             audible  alarms  are options on many units.   The  alarms  go  off at a  pre-set
             concentration to  warn  the  instrument   operator  of  potentially   hazardous
             concentrations.  Other options  such as larger sampling lines, moisture taps,  all dust
             filters are also available.  Manufacturers of CGIs are listed at the end of this manual
             section.

             Concentrations between the LEL and the UEL are considered flammable.

             1.     Principle of Operation

                    Combustible gas  indicators use a combustion chamber containing a filament
                    that combusts the flammable gas.  To facilitate combustion the filament is
                    heated or is coated with a catalyst (like platinum or palladium), or both.  The
                    filament  is part of a balanced  resistor circuit called a Wheatstone  Bridge.
                    The hot filament  combusts the  gas on the immediate surface of the element,
                    thus raising the  temperature  of the  filament.   As the temperature of the
                    filament  increases so does its resistance.  This change in resistance causes an
6/91                                        12

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                   imbalance in  the Wheatstone Bridge.   This  is measured as the ratio of
                   combustible vapor present compared to the total required to reach the LEL.
                   For example,  if the meter reads 0.5 (or 50%, depending upon the readout),
                   this means that 50% of the concentration of combustible gas needed to reach
                   a flammable or combustible situation is present.  If the LEL for the gas is
                   5% then the meter indicates that a 2.5%  concentration is present.  Thus, the
                   typical meter readout indicates concentration up to the LEL of the gas.  See
                   FIGURE 3a.

                   If a concentration greater than LEL and lower than the UEL is present, then
                   the meter needle will stay beyond  the 1.0 (100%) level on the  meter.  See
                   FIGURE 3b.  This  indicates that  the ambient  atmosphere is  readily
                   combustible.  When the atmosphere has a gas  concentration above the UEL
                   the meter needle will usually rise above the 1.0 (100%) mark and then return
                   to zero.  See FIGURE  3c.  This occurs because  the gas mixture in the
                   combustion cell is too rich to burn. This permits the filament to conduct a
                   current just as if the atmosphere contained no combustibles at all.  Some
                   instruments have a lock mechanism that prevents the needle from returning
                   to zero when it has reached 100% and must be reset  in an atmosphere below
                   the LEL.
                                         I DO
                               %LEL
                                                          IOO
   %LEL
                                                                           IOO
    LEL
                                a
                         Lower than the
                               LEL
Between the LEL
and the UEL
Above the UEL
                                               FIGURE 3
                               COMPARISON OF METER READINGS TO
                               COMBUSTIBLE GAS CONCENTRATIONS
6/91
                                          13

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             2.     Limitations and Considerations

                    The response of the instrument is temperature dependent. If the temperature
                    at which the instrument is zeroed differs  from the sample  temperature, the
                    accuracy  of the reading  is  affected.    Hotter  temperatures  raise  the
                    temperature of the filament and produce a higher than actual reading. Cooler
                    temperatures will reduce the reading. It works best to calibrate and zero the
                    instrument at the sample temperature.

                    The instruments are  intended for use only in normal oxygen atmospheres.
                    Oxygen-deficient atmospheres will  produce lowered readings.  Also  the
                    safety guards that prevent the combustion source from igniting a flammable
                    atmosphere  are not designed to operate in an oxygen-enriched atmosphere.

                    Organic lead vapors  (e.g. gasoline vapors), sulfur compounds, and silicone
                    compounds will  foul  the filament. Acid  gases (e.g.  hydrogen chloride  and
                    hydrogen  fluoride) can corrode the  filament.  Most units have an optional
                    filter that  protects the sensor from leaded vapors.

                    There is no differentiation between petroleum vapors and combustible gases.
                    If the flammability of the combined vapors and gases in an atmosphere is the
                    concern this  is not a problem. However, if the instrument is being used to
                    detect the  presence of a released flammable liquid - like gasoline - in a sewer
                    system where methane may be present, the operator  can't tell if the reading
                    is the contaminant or the methane.  A pre-filter can be used to remove the
                    vapors but will not remove the methane.  Thus,  if readings  are made with
                    and without the  filter, the user can  compare the readings and can conclude
                    that  differences in the  values  indicate  that  a petroleum vapor (i.e.  the
                    contaminant) is present.

      D.     Toxic Atmosphere Monitors

             Along with oxygen concentration and flammable gases or vapors, there is a concern
             about chemicals present at toxic concentrations.

             This usually involves measurements at concentrations lower  than would be indicated
             by oxygen indicators or combustible gas indicators.  There is a need  to determine if
             toxic chemicals are present and identify them so the environmental concentration can
             be compared to exposure guidelines. Toxic atmosphere monitoring  is done to:

              •     identify airborne concentrations  that  could  pose a toxic  risk to response
                    workers and the public.
              •     evaluate the need for and type of personal protective equipment.
              •     set up work zones or areas where contaminants are or are not present.

             There are several  different groups  of instruments that can  be used for these
             functions.
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             1.      Colorimetric Indicator Tubes (Detector Tubes)

                    a.      Principle of Operation

                           Colorimetric indicator tubes consist of a glass tube impregnated with
                           an indicating chemical  (FIGURE 4).  The tube is connected to  a
                           piston- or bellows- type pump. A known volume of contaminated air
                           is pulled  at a predetermined rate through the tube by the pump. The
                           contaminant reacts with the indicator chemical in the tube, producing
                           a change in  color whose length is proportional to the contaminant
                           concentration.
                              COTTON PLUG
                                  \
                                                             GLASS VIAL
                                                    I   I   I
                                                    o  o   o
                                                     L
                                PRE FILTER   INDICATING CHEMICAL
                                              ON SILICA GEL
                        COTTON PLUG
                                                     FIGURE 4
                                      DIRECT-READING COLORIMETRIC
                                                INDICATOR TUBE
                           Detector tubes are normally chemical specific.  There are different
                           tubes for different gases; for  example,  chlorine detector tube for
                           chlorine gas, acrylonitrile  tube  for acrylonitrile gas,  etc.   Some
                           manufacturers do produce tubes for groups of gases, e.g.  aromatic
                           hydrocarbons, alcohols.  Concentration ranges on the tubes may be
                           in the ppm or percent range.  A  preconditioning filter may precede
                           the indicating chemical to:

                           •     remove  contaminants (other  than the one in  question)  that
                                  may interfere with the measurement.  Many have a prefilter
                                  for removing humidity.
                           •     react with a contaminant to change it into a compound  that
                                  reacts with the indicating chemical.
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                           "Haz-mat kits are available from at least two manufacturers. These
                           kits identify or classify the contaminants as a member of a chemical
                           group such as acid gas, halogenated hydrocarbon,  etc.  This is done
                           by sampling with certain combinations of tubes at the same time by
                           using a special multiple tube holder or by using tubes in a specific
                           sampling sequence.  Detector tube manufacturers are listed at the end
                           of this manual section.

                    b.     Limitations and Considerations

                           Detector tubes have the disadvantage of poor accuracy and precision.
                           In the past, the National Institute for Occupational Safety and Health
                           (NIOSH) tested and certified detector tubes that were submitted to
                           them.  For the tubes they tested they  certified the accuracy to be
                           ±35% at concentrations at 1/2 the OSHA Permissible Exposure Limit
                           (PEL) and +25% at 1 to 5 times the PEL.  NIOSH has discontinued
                           testing and certification.  Special studies have reported error factors
                           of 50% and higher for some tubes.

                           The chemical  reactions involved in the use of the tubes are affected
                           by  temperature.  Cold weather slows  the  reactions  and thus the
                           response time. To reduce this  problem it is recommended that the
                           tubes be kept warm (for example, inside a coat pocket) until they are
                           used if the measurement is done in cold weather.  Hot temperatures
                           increase the  reaction and can cause a problem by discoloring the
                           indicator when a  contaminant is not present.  This can happen even
                           in unopened tubes.  Therefore, the  tubes should be stored  at a
                           moderate temperature or even refrigerated during  storage.

                           Some tubes do not  have a prefilter to remove humidity and  may be
                           affected by high humidity.  The manufacturer's instructions usually
                           indicate if humidity is a problem and list any correction factors to use
                           if the tube is affected by humidity.

                           The chemical used in the tubes deteriorates over time.   Thus the
                           tubes are assigned a shelf life.  This varies from 1 to 3 years.  Shelf
                           life can be extended by refrigeration but the tube should  equilibrate
                           to ambient temperature before use.

                           An advantage that detector tubes have over some other  instruments
                           is that it is possible to select a tube that is specific to  a chemical.
                           However,  some tubes  will  respond  to  interfering  compounds.
                           Fortunately, the manufacturers provide information with the tubes on
                           interfering gases and vapors.

                           Interpretation of results can  be a problem. Since the tube's length of
                           color change  indicates the contaminant concentration, the user must
                           be able to see the end of the stain.  Some stains are diffused and are
                           not clear cut; others may have  an uneven endpoint.  When in doubt
                           use the highest  value that  would be  obtained  from  reading the
                           different aspects  of the tube.
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                           The total volume to be drawn through the tube varies with the tubes.
                           The volume needed is given as the number of pump strokes needed,
                           i.e. the number of times the piston or bellows is manipulated.  Also,
                           the air does not instantaneously go through the tube.  It may take  1
                           to 2  minutes for  each volume (stroke)  to  be completely  drawn.
                           Therefore, sampling times can vary from  1 to 30 minutes per tube.
                           This can make the use of detector tubes time consuming.

                           Due to these many considerations,  it is very important to read the
                           instructions that are provided with and are specific to a set of tubes.
                           The information includes the number of pump  strokes  needed, time
                           for each  pump stroke, interfering gases and vapors,  effects of
                           humidity  and  temperature,  shelf  life, proper color change and
                           whether the tube is reusable.

                           While there are many limitations and  considerations for  using
                           detector tubes, detector tubes allow the versatility of being able to
                           measure a wide range of chemicals with a single pump.  Also, there
                           are some chemicals for which detector tubes  are the only direct-
                           reading indicators.

              2.      Specific Chemical Monitors

                     There are several gas monitors which utilize electrochemical cells or metal
                     oxide semi-conductors (MOS) for detecting  specific chemicals.    MOS
                     detectors change conductivity when exposed to certain gases or vapors.  They
                     can be designed  to respond to a  large group of chemicals or to a  specific
                     chemical.  The most common monitors are used to detect carbon monoxide
                     or  hydrogen  sulfide but  there are  also monitors available for hydrogen
                     cyanide, ammonia and chlorine. They are more accurate than detector tubes
                     but there are only about a dozen different chemicals they can monitor.

              3.      Photoionization Detector (PID)

                     These instruments detect  concentrations of gases  and vapors  in  air by
                     utilizing an ultraviolet light source to ionize the airborne contaminant. Once
                     the gas  or vapor  is  ionized  in the  instrument, it can be  detected  and
                     measured.

                     a.      Principle of Operation

                            All  atoms  and molecules are composed  of particles:   electrons,
                            protons,  and  neutrons.  Electrons,   negatively charged particles,
                            rotate in orbit around the nucleus, the dense inner core.  The nucleus
                            consists of an equal number of protons (positively charged particles)
                            as  electrons found  in  the  orbital  cloud.   The interaction of the
                            oppositely charged  particles and the laws of quantum mechanics keep
                            the electrons in orbits outside the nucleus.
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                           The energy required to remove the outermost  electron from the
                           molecule is called the ionization potential (IP) and is specific for any
                           compound or atomic species (see TABLE 4).  Ionization potentials
                           are measured in electron volts  (eV).   High frequency radiation
                           (ultraviolet and above) is capable of causing ionization and is hence
                           called ionizing radiation.

                           When a photon of ultraviolet radiation strikes a chemical compound,
                           it ionizes the molecule  if the energy of the radiation is  equal  to or
                           greater  than the IP  of the compound.   Since ions are  charged
                           particles, they may be  collected  on a charged plate and produce a
                           current.   The measured current will be directly  proportional to the
                           number of ionized molecules (see FIGURE 5).

                           The photoionization process can be illustrated as:

                                   R + h  ^   R+ + e

                           where R is an  organic or inorganic molecule and h represents a
                           photon of UV light with energy equal to or greater than the ionization
                           potential  of that particular chemical  species.   R+  is  the  ionized
                           molecule.
TABLE 4
IONIZATION POTENTIALS OF SELECTED CHEMICALS
Chemical
Hydrogen cyanide
Carbon dioxide
Methane
Hydrogen chloride
Water
Oxygen
Chlorine
Propane
Hydrogen sulfide
Hexane
Ammonia
Vinyl chloride
Acetone
Benzene
Phenol
Ethyl amine
Ionization Potential (eV)
13.9
13.8
13.0
12.5
12.6
12.1
11.5
11.1
10.5
10.2
10.1
10.0
9.7
9.2
8.5
8.0
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                        PIDs use a fan or a pump to raw air  into the  detector of the
                        instrument where the contaminants are exposed to UV light and the
                        resulting  negatively  charged  particles  (ions)  are collected  and
                        measured.
                                               AMPLIFIER
                                               /
                                     METER
                                        /
                           SAMPLE  OUT

                                            ^
                              ELECTRODE
                                               t
  UV
LAMP
            ELECTRODE
                                                        SAMPLE  IN
                                                FIGURE 5
                              DIAGRAM OF PHOTOIONIZATION DETECTOR
                                 LAMP AND COLLECTING ELECTRODES

                  b.     Photoionization Considerations and Limitations

                         Since the ability to detect a chemical  depends on the ability to ionize
                         it,  the IP of a chemical to be detected must  be compared to  the
                         energy generated by the UV lamp of the instrument. As can be seen
                         from TABLE 4 there is a  limit imposed by the components of  air.
                         That is to  say,  the lamp  cannot  be too energetic or  oxygen  and
                         nitrogen will ionize and interfere with the readings for contaminants.
                         The energy of lamps available are 8.3, 8.4, 9.5,  10.2,  10.6, 10.9,
                         11.4, 11.7  and 11.8 eV. Not all lamps  are available from a single
                         manufacturer.
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                           One use  of  the  different lamps is  for  selective  determination of
                           chemicals.  For  example, if a spill  of propane and vinyl chloride
                           were to be monitored with a PID the first check would be to see if
                           they could be detected.  The IP of propane is 11.1 eV and the IP of
                           vinyl chloride is 10.0 eV.  To detect  both, a lamp with an energy
                           greater than  11.1 eV is  needed (like a 11.7  or 11.8).   If vinyl
                           chloride was  the chemical of concern, then a lamp with an energy
                           greater than  10.0 but less than 11.1  (such as 10.2 of 10.6) could be
                           used.  The propane would neither be  ionized nor detected.  Thus,
                           propane would not interfere with the vinyl  chloride readings.  The
                           sample drawn into the instrument passes over the lamp to be ionized.
                           Dust in the  atmosphere  can collect  on the lamp  and  block the
                           transmission of UV  light. This will cause a reduction  in instrument
                           reading.  This problem will be detected during calibration and the
                           lamp should  be cleaned on a regular basis.

                           Humidity can cause  two problems.  When a cold instrument is taken
                           into a warm  moist  atmosphere, the moisture can condense on the
                           lamp. Like dust this will  reduce the available light.  Moisture in the
                           air also reduces the  ionization of chemicals  and cause a reduction in
                           readings.

                           Since an electric field  is generated in the sample chamber of the
                           instrument,  radio-frequency interference from  pulsed DC or AC
                           power lines,  transformers, generators, and  radio wave transmission
                           may produce an  error in response.

                           As the lamp  ages the intensity of the light decreases. It will still
                           have the same ionization energy, but the response will decline.  This
                           will  be detected during calibration  and adjustments can be made.
                           However, the lamp  will eventually burn out.

                           Photoionization  detectors are calibrated to  a single chemical.  The
                           instrument's  response to  chemicals  other  than  the  calibration
                           gas/vapor can vary.  TABLE 5 shows the relative responses  of
                           several chemicals for a specific PID.

                           In some  cases, at high concentrations the  instrument response can
                           decrease.  While the response may  be linear (i.e.  1 to 1 response)
                           from  1 to 600 ppm for  an  instrument, a concentration of 900 ppm
                           may only give a meter response of 700.

                           Units   which   utilize   photoionization   include   the   Thermo
                           Environmental Instruments Model 580A, the Photovac TIP and the
                           HNU PI 101.
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                                      TABLE 5
           RELATIVE RESPONSES FOR SELECTED CHEMICALS USING
   THE HNU MODEL PI 101 WITH 10.2 eV PROBE CALIBRATED TO BENZENE
                 Chemical
Relative Response
                 m-Xylene
                  Benzene
                  Phenol
               Vinyl chloride
                  Acetone
                  Hexane
                 Phosphine
                 Ammonia
      1.12
      1.00
      0.78
      0.63
      0.50
      0.22
      0.20
      0.03
      Source:  Instruction Manual for Model PI 101^ Portable Photoionization Analyzer. HNU
      Systems, Inc., Newton, MA, 1986.
                    c.     HNU PI 101 Photoionization Detector

                          The HNU PI  101  consists of two modules  connected via a single
                          power cord (FIGURE 6):

                          •     A read-out unit  consisting of a 4.5 inch analog meter, a
                                 rechargeable battery, and power supplies for operation of the
                                 amplifier and the UV lamp.
                          •     A sensor  unit consisting of the UV  light  source, pump,
                                 ionization chamber, and a preamplifier.

                          The unit has a separate sensor unit because the lamps available - 8.3,
                          9.5,  10.2  (standard)  and  11.7  eV  -  require separate electronic
                          circuits.   To change the energy  of ionization  the whole sensor or
                          probe has to  be  switched and  not just the lamp.   Lamps are
                          replaceable.

                    d.     Photovac TIP  (Total lonizables Present)

                          The TIP has components similar to those the HNU has, but they are
                          all contained in  an 18 inch long and 2.5 inch diameter unit.   The
                          standard lamp is 10.6 eV,  but it  can easily be replaced with a 8.4,
                          9.5,  10.2,  or  11.7 eV lamp.  A  separate sensor is  not used.   The
                          readout is digital with a range of 0 to 2000.  The instrument also has
                          a replaceable dust filter to eliminate collection  on the lamp.
6/91
                                          21

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                                                 REAIXDLT UK:T
                                                                            IOK CK?-M3SR
                                                    FIGURE 6
                                 PORTABLE PHOTOIONIZATION DETECTOR

                           Selection from Instruction Manual for Model PI 101 Photoionization
                           Detector, by  HNU Systems,  Inc., copyrighted 1975,  by HNU
                           Systems, Inc., reprinted with permission of Publisher.

                    e.      (Organic Vapor  Meter  Model  580A)  (Thermo  Environmental
                           Instrument)

                           The Organic Vapor Meter (OVM) is  5" by  5" by 10" with a handle
                           on top and  in the center.   It can use any of four different lamps -
                           9.5,  10.0, 10.6 (standard),  11.8 eV.  The  instrument has a digital
                           readout with a range of 0 to 2000. It has a maximum hold feature so
                           that you can  get  two  readings  - the current concentration or  the
                           maximum concentration during the survey.  The meter has a lock-out
                           if the readout exceeds 2000 so that high concentrations  are  not
                           missed.   It must  be reset in an area of low concentrations.   The
                           instrument  has  a  microprocessor for assistance in  calibration  and
                           lamp changing.

                           The unit also has connections and software for interfacing the unit
                           with a personal computer  and a data logger  for recording readings at
6/91
                                            22

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                           coded locations so  that  the  readings  can be looked  at  later or
                           unloaded into a computer.

                           Photoionization detectors  are also used in gas chromatographs made
                           by  Photovac, HNU  and Thermo Environmental Instruments.  Gas
                           chromatography will be discussed later in this part.

             4.     Flame lonization Detector (FID)

                    These units utilize combustion as the means to ionize airborne contaminants.
                    Once they  are ionized, they can be detected  and measured.

                    a.     Principle of Operation

                           Flame ionization detectors use  a hydrogen flame as the means to
                           ionize organic (toxic) vapors.  FID responds to virtually all organic
                           compounds,  that is,  compounds that contain  carbon-hydrogen  or
                           carbon-carbon bonds. The flame detector analyzes by the mechanism
                           of breaking bonds as the following reaction indicates:

                                         RH -I- 0 - RHO+ + e- - C02 +  H2O

                           Inside the detector chamber,  the sample is exposed to a hydrogen
                           flame which ionizes the organic  vapors.   When most  organic vapors
                           burn, positively charged carbon-containing ions are produced which
                           are  collected by a negatively charged   collecting electrode in  the
                           chamber. An electric field exists between the conductors surrounding
                           the  flame and a  collecting  electrode.    As the positive  ions  are
                           collected, a current proportional to the hydrocarbon concentration is
                           generated on the input electrode.  This  current is measured with a
                           preamplifier which has an output signal proportional to the ionization
                           current.  A signal conducting  amplifier  is used to amplify the signal
                           from the preamp and to condition it for subsequent meter or external
                           recorder display.

                           Flame ionization  detectors have  a  more generalized  response in
                           detecting organic vapors.  This  generalized sensitivity is due to the
                           breaking of chemical bonds which require a set amount of energy  and
                           is  a  known  reproducible  event.   When  this  is  compared  to
                           Photoionization (PID), a  major  difference should  be noted  between
                           the detectors.  PID  detection  is  dependent upon the  ionization
                           potential  (eV) and the ease  in which  an electron  can be ionized
                           (displaced) from a molecule.    This mechanism is variable, highly
                           dependent on the individual characteristics of a particular substance.
                           This results  in a more variable  response factor for the vast  majority
                           of  organics that are ionizable.  Therefore, in general,  one does  not
                           see large sensitivity shifts between different substances  when using
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                          an FID  as compared to a PID.  Flame ionization detectors are the
                          most sensitive for saturated hydrocarbons, alkanes and unsaturated
                          hydrocarbons alkenes. Substances that contain substituted functional
                          groups such as hydroxide (OH"), and chloride (Cl~), tend to reduce
                          the detector's sensitivity; however, overall, the detectabilities remain
                          good.

                          Companies that manufacture FIDs include Beckman Industrial, The
                          Foxboro Company  and Thermo Environmental  Instruments. The
                          Foxboro Century Organic Vapor Analyzer  (OVA) will be discussed
                          as an example later.

                   b.     Flame Ionization Detector Considerations

                          Flame  ionization detectors  respond  only  to organic  compounds.
                          Thus,  they  do  not  detect inorganic  compounds  like  chlorine,
                          hydrogen cyanide, or ammonia.

                          As with all instruments, flame ionization detectors respond differently
                          to different compounds.  TABLE 6 is a list of the relative responses
                          of  the   Foxboro CENTURY  OVA  to   some  common  organic
                          compounds.  Since that instrument is factory calibrated to methane,
                          all responses are relative to methane and are given by percentage,
                          with methane at  100%.

                          Thus with all survey-type instruments, the identity of the chemical of
                          interest  must be   ascertained  before  its concentration  can  be
                          determined.  However, the CENTURY OVA can be purchased as a
                          dual mode survey-gas chromatograph and can separate and define the
                          components  present in  a  gas mixture.   As with  all  instruments,
                          individuals  should be trained for best operation and performance.
                          Experience   in  gas  chromatography  is  an  important  aspect to
                          successful operation of the chromatographic option.
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                                     TABLE 6
              RELATIVE RESPONSES FOR SELECTED CHEMICALS
                  USING THE OVA CALIBRATED TO METHANE
                Compound
Relative Response
                 Methane
                  Ethane
                 Propane
                 n-Butane
                 n-Pentane
                 Ethylene
                 Acetylene
                 Benzene
                 Toluene
                 Acetone
             Methyl ethyl ketone
           Methyl isobutyl ketone
                 Methanol
                  Ethanol
              Isopropyl alcohol
             Carbon tetrachloride
                Chloroform
              Trichlorethylene
               Vinyl chloride
       100
        90
        64
        61
       100
        85
       200
       150
       120
       100
        80
       100
        15
        25
        65
        10
        70
        72
        35
Selection  from Product Literature. The Foxboro  Company,  with  permission of the  Foxboro
Company.

                   c.     Foxboro CENTURY Organic Vapor Analyzer (OVA)

                          (The Foxboro  CENTURY  OVA  consists  of  two major  parts
                          (FIGURE 7)

                          •     A 12-pound package containing the sampling pump, battery
                                pack, support electronics, flame ionization detector, hydrogen
                                gas  cylinder,  and an optional gas  chromatography  (GC)
                                column.
                          •     A hand-held meter/sampling probe assembly.
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                                                            Signal Processor   cnart Recorder
                                    Compressed Gas
                                                                                Sample
                                                    FIGURE 7
                                  ORGANIC VAPOR ANALYZER SCHEMATIC
                          Selection from Product  Literature. The Foxboro  Company, with
                          permission of the Foxboro Company.

                          The OVA is generally calibrated to methane, but can be calibrated
                          to the species of interest.

                          The OVA can operate in two modes:

                          Survey mode:  During normal survey mode operation, a sample is
                          drawn into the probe and transmitted to the detector chamber by an
                          internal  pumping system.  When the  sample reaches the FID  it is
                          ionized as described before  and the resulting signal is  translated on
                          the meter for direct-reading  concentration as total organic vapors or
                          recorded as a peak on a chart. The meter display is an integral part
                          of the probe/readout assembly and has a scale from 0 to 10 which can
                          be set to read 0-10,  0-100, or 0-1000 ppm.

                          Gas chromatography mode:  Gas chromatography  (GC) is a technique
                          for  separating  components of a  sample  and  qualitatively  and
                          quantitatively  identifying them.   The  sample to  be separated  is
                           injected into a  column packed with an inert solid. As the carrier gas
                           (for the OVA it is hydrogen) forces the sample through the column,
                          the separate components of the sample are retained on the column for
                          different periods of time. The amount of time a substance remains
                          on the column, which is  called its retention  time, is a function of its
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                           affinity for the column material, column length, column temperature,
                           and  flow rate of the  carrier gas.   Under preset  instrumental
                           conditions each component elutes from the column at a different but
                           reproducible  length of time.  As  the  components elute from the
                           column, they flow into the detector.  Since the output of the detector
                           can  be connected  to  a strip  chart recorder, separate peaks are
                           recorded  for  each  component.   This  readout  is  called  a gas
                           chromatogram (see Qualitative identification is made by measuring
                           retention time.  Retention time is defined as the period of time that
                           elapses between the injection of the compound into the column and
                           the elution of that compound  as represented by a peak.  Retention can
                           be expressed as a function of either time or the  measured distance
                           between the injection point and the peak on the strip chart recorder.
                           If the retention time  of  an unknown  chemical agrees with the
                           retention time of a known chemical recorded under the same set of
                           analytical conditions, the unknown is  tentatively identified.  In
                           addition, the area under the peak is proportional to the concentration
                           of the corresponding sample component.  If these areas are compared
                           to the areas  of standards, recorded  under identical  analytical
                           conditions,  the  concentration  of the sample components  can be
                           calculated.  (See FIGURE 8)

              5.     Catalytic Combustion Detectors

                    There are toxic monitors which use the same detection system as CGIs but
                    are more sensitive.  In a sense they are super sensitive CGIs with readouts
                    in ppm instead of %LEL.  Since tire detection method is similar, they have
                    the same limitations and considerations as CGIs.

                    Some of  these  instruments, e.g. the Bacharach TLV Sniffer,  give  only
                    readings in  parts per  million  (ppm).  There  are  combination units, e.g.
                    Gastec Models 1238 and 1314, which  give ppm readings along with %LEL
                    and oxygen  readings.

              6.     Infrared Spectrophotometer

                    a.     Principle of Operation

                           The  infrared Spectrophotometer is a compound- specific instrument.
                           Each compound being analyzed  will absorb radiation  at a  discrete
                           infrared  wavelength. The unit measures how much of the  infrared
                           energy (IR) is absorbed and gives readings of percent IR absorbed or
                           ppm of chemical.
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                                                                   Peak Height
                                       Injection
     Time  (seconds)
Peak Area
                                                    FIGURE 8
                                   EXAMPLE OF A GAS CHROMATOGRAM

                           Selection from Product Literature. The Foxboro Company, reprinted
                           with permission of The Foxboro Company.

                           Molecules  are composed  of atoms which are held together by bonds
                           of various  types and lengths.  These arrangements, as in the ball and
                           spring configurations presented in introductory chemistry, establish
                           finite locations and discrete movements for each atom (ball) and bond
                           (spring).   These movements can be either vibrational, rotational,
                           stretching, or bending of the chemical bonds.  The  frequencies  of
                           these movements  are on the order of infrared radiation.  A given
                           bond movement can be initiated by stimulating the molecule with  IR
                           of varying  frequency.    As  the  bond   moves,  it absorbs the
                           characteristic energy associated with that movement. The frequencies
                           and intensity of IR absorbed are  specific  for a compound and  its
                           concentration, providing a  "fingerprint"  which can  be used as  an
                           analytical tool.

                           Foxboro,  Perkin-Elmer, and Beckman are producers of portable
                           infrared spectrophotometers.  The MIRAN  is  manufactured  by
                           Foxboro and is  discussed below (FIGURE 9).
6/91
                                            28

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                                                                     FILTER WHEEL
                                                              DETECTOR   I  CHOPPER
                                                                      **-*	
                             PATHLENGTH ADJUSTMENT
                                                                                 -ELECTRONIC
                                                                                  BOARD
                                      VARIABLE PATH GAS SAMPLE CELL
                            \
                            SLIT
                                                                            SOURCE
                                                     FIGURE 9
                                 OPTICAL SCHEMATIC OF MIRAN ANALYZER
                           The  MIRAN   (miniature  infrared   analyzer)   is   a   field  IR
                           spectrophotometer which uses a variable length gas cell  to measure
                           concentrations  of vapors in ambient air.  The air sample is drawn
                           into a chamber for exposure to IR.  Several movable mirrors permit
                           repeated pa^es, producing paths from several  centimeters to several
                           meters.  "^ „ longer the path length the better  the detector response.

                           Field analysis  presents  problems  not  normally encountered  with
                           spectrophotometry  in  the  laboratory.   With lab instruments, the
                           analyst can control the concentration of material entering the sample
                           cell.  Liquid or solid samples  are preferable to gas samples because
                           they  possess  more  molecules than  a  gas of  the  same volume.
                           Additionally, the spectra of analyses of the  same chemical in the
                           liquid phase and gaseous phase are markedly  different.  To analyze
                           gas samples the IR beam in the MIRAN must make repeated passes
                           to achieve reliable results.  In the  gaseous state, the molecules are
                           free to  rotate,  and  inter-molecular  actions  are at a minimum.  The
                           liquid state "locks" the molecules in a given structure.

                           Limitations and Considerations

                           The MIRAN is designed for industrial hygiene work in occupational
                           settings where known types of materials are  generated.   Thus it is
                           easy  to select the IR frequency that is  specific for the chemical in
                           question.

                           If the contents of the atmosphere are not known, a full scan of the IR
                           spectrum could be done to pick up any peaks.  However, if many
                           chemicals were present it would be difficult  to  identify a specific
6/91
29

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                           chemical because of the many absorption peaks. If the instrument is
                           just looking at a "fingerprint"  peak,  there is the  possibility that a
                           chemical could absorb at a peak that is not its "fingerprint" and cause
                           a false indication.

                           The instrument needs a flat or level surface  free from vibration so
                           that the internal  mirrors do not move and effect the light path.

             7.     Aerosol Monitors

                    Not all toxic materials  dispersed in air are in the form of a gas or vapor.
                    Solids and liquids can become suspended in air by  combustion, splashing
                    liquids or by disturbing soil.

                    There are direct-reading instruments that measure  aerosols, i.e.  dust, mist,
                    fume, smoke, fog, spray.  Most of them use a light source  and a light sensor
                    that measures the amount  of light scattered by the aerosol. Readouts are in
                    milligrams per cubic meter (mg/m3). Some examples are MIE Incorporated
                    RAM-1 and MINIRAM and TSI Incorporated's Model 5150.

                    Other methods of detection are  the piezoelectric  crystal mass monitor and
                    beta attenuation.  The piezoelectric crystal mass monitor uses  a  crystal that
                    resonates at  a  certain frequency as electric current is applied to it.   As
                    particles collect on the crystal its resonant frequency changes and the change
                    is measured.  An instrument using this detector is TSI Incorporated's Model
                    3500.

                    Beta attenuation measures  the  attenuation  of beta  radiation by particles
                    collected on  a  surface between the beta source and  a beta detector.  GCA
                    Corporation's Model  RDM-101  is an instrument using this type of detector.

                    Accessories for these types of instruments include; an attachment that only
                    allows collection of "respirable"  particles (i.e., ones that collect in the lungs)
                    instead of the total  particles in air;  and  integrators  for giving average
                    concentrations.

                    It is  important to  remember that these instruments give the total amount of
                    particulate and not the type of particulate.  Individual content, e.g., lead or
                    arsenic, must be analyzed separately.  However, if the content  of the sample
                    is known, then the direct-reading instrument could be used if content of the
                    dust is  assumed to remain constant.  For example, if the dust being detected
                    is 5% lead and 1% arsenic and the concentration of dust is 2 mg/m3 then the
                    concentration  of  lead  and arsenic  are 0.1  mg/m3   and  0.02  mg/m3
                    respectively  (0.05 x  2  mg/m3 = 0.1  mg/m3 and  0.01 x  2 mg/m3 =  0.02
                    mg/m3).

              8.     Accessories/Options

                    As mentioned earlier, instruments combining more than one detector can be
                    found.   For examples, "trimeters"  and "quadmeters" combine  an oxygen
                     indicator, a combustible gas indicator  and one or two toxic monitors.  Also
                    there are units with alarms that indicate readings that are above or below a
                     concentration of concern,  strip chart (printed) outputs, and electronic outputs
                     for data storage.

6/91                                         30

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                    Some instruments have an integrator that averages concentrations while the
                    instrument is  operating or over a specified time,  e.g.  15  minutes.  This
                    permits use of the instrument as  a  long term monitor as well as a  direct-
                    reading instrument.

                    One of the more recent additions  is the microprocessor.  This can be used
                    with a gas  chromatograph so the microprocessor  "reads"  the output and
                    compares it to calibration  information  in its memory.   That way  the
                    instrument instead of the operator qualifies and quantifies the chemicals.  In
                    some cases the operator asks the microprocessor to check for a chemical and
                    the  unit  uses its  memory  to  match  retention  time  and  peak height.
                    Microsensor's Micromonitor, the Photovac 10S50, and the Sentex Scentor
                    use this capability.  The MIRAN IB uses the microprocessor to select the
                    fingerprint frequency for the chemical requested. The main limitation with
                    the  microprocessors are  the  number  of chemicals in their memory  or
                    "library". What the microprocessor doesn't recognize it can't identify. Most
                    portable units have libraries  for up to 100 chemicals.   Also the detection
                    method (PID,  FID, etc.) used must be considered as that limits the number
                    of chemicals that can be identified.

             9.     Programmed Thermal Desorber (PTD)

                    The Programmed Thermal Desorber (Foxboro PTD-132A) is not a detection
                    system  but  does  aid in on-site evaluation of air  samples.   It utilizes the
                    principle of thermal desorption to  extract contaminants from carbon or other
                    sorbent tubes.  The instrument performs this function automatically and has
                    the ability to  store the desorbed sample in a 300 ml chamber and to make
                    replicate sample  injections  into a gas chromatograph  or other analytical
                    instrument.  It allows rapid on-site analysis of collected air samples.  Within
                    the instrument is a small oven which  is used to  heat  the  sorbent tube to
                    temperatures ranging from 100°-350°C depending upon the application. This
                    heating has the effect of separating the sample from  the sorbent, thus freeing
                    it to be carried by a flow of clean  carrier gas to the storage chamber. From
                    there,  the sample  is  released in  carefully  controlled amounts into  the
                    analytical instrument of choice.  If the instrument  is a  gas chromatograph,
                    the  chromatogram  is recorded in  the normal fashion  and the  peaks  are
                    qualitatively and  quantitatively determined. The calculations necessary to
                    find the concentration of contaminant in the original air sample  are simple
                    volumetric ratios.  While the PTD was designed to be used with the Foxboro
                    CENTURY Organic Vapor Analyzer with a gas chromatograph accessory, it
                    can be used with  other instruments.
6/91                                        31

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V.     REFERENCES

       1.     American  Conference of  Governmental  Industrial  Hygienists:   Air Sampling
             Instruments for Evaluation of Atmospheric  Contaminants.   6th  Edition.   6500
             Glenway Avenue, Building D-7, Cincinnati, OH.

       2.     Cee, R.J., J.C. Septon, J.C. Ku and T. Wilczek:  " An Evaluation of Commercial
             Detector  Tube  Systems."   Paper  presented  at  American  Industrial Hygiene
             Conference, Montreal, Canada, June 1987.

       3.     Clayton, George D. (ed.): The Industrial Environment - Its Evaluation and Control.
             3rd ed., Public Health Services Publication, 1973.

       4.     Clayton, G.D., and F.E. Clayton (ed.): Patty's Industrial Hygiene and Toxicology,
             3rd review ed., Vol. I:  General Principles. John Wiley and Sons, New York, NY,
              1978.

       5.     Conley, Robert: Infrared Spectroscopy. 2nd  ed., Allyn and Bacon, Inc., Boston,
             MA,  1972.

       6.     Klinsky,  Joseph (ed.):   Manual of Recommended Practice for Combustible Gas
             Indicators and Portable Direct-Reading Hydrocarbon  Detectors.  1st ed., American
             Industrial Hygiene Association, Akron, OH, 1980.

       7.     National  Fire Prevention Association:  National Electrical Code.  Vol. 70.   470
             Atlantic Ave., Boston, MA 02210, 1986.
 6/91                                        32

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                                                                                PART 1

                                                              DIRECT-READING INSTRUMENTS
                                                                              APPENDIX I
                                                     DIRECT-READING INSTRUMENTS USED FOR EVALUATION
                 Hazard
               Monitored
        Instrument
          Application
                Detection
                 Method
       Notes
             Combustible
             Gas/Vapor
Combustible Gas Indicator
Measures the concentration of a
combustible gas or vapor.
A filament is heated by burning the
combustible  gas/vapor.  The increase in heat
is measured.
Calibrated before
use.
             Oxygen
             Deficiency
Oxygen meter
Measures the percentage of
oxygen in air.
Uses an electrochemical sensor to measure
the partial pressure of oxygen in  air.
Calibrated before
each use in normal
air.
Ui
             Ionizing
             radiation
Geiger-Mueller (G-M)
counter; Scintillator tube.
Environmental radiation monitor.
Some monitors can distinguish
among the types  of ionizing
radiation.
G-M: Ionizing radiation reacts with inert gas
producing electric current.
Scintillator:  Ionizing radiation produces
photons of light within a crystal.  Crystals
are specific to types of radiation e.g.,
sodium iodide crystal for gamma radiation.
Must be calibrated
annually at a
specialized facility.
             Organics
1) Colorimetric tubes
Measure concentration of specific
gases and  vapors.
The substance reacts with the indicator
chemical producing  a stain whose length in
the tube is proportional to the concentration
of the substance.
Leak test before
use.  Check flow
rate and volume
periodically.
Check shelf life of
tubes before use.
                              2)  Flame Ionizing Detector
                                  (FID) with Gas
                                  Chromatograph (GC)
                                  Option
                              Measure total concentration of
                              organics in survey mode;
                              identifies  and measures specific
                              compounds in GC mode.
                                  Gases and vapors are ionized in a flame.  A
                                  current is produced in proportion to the
                                  number of carbon atoms present.
                                            Requires experience
                                            to operate.  Fuel
                                            source is hydrogen.
           6/91

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                                                                     PART 1

                                                   DIRECT-READING  INSTRUMENTS
                                                              APPENDIX I CONT'D

                                          DIRECT-READING INSTRUMENTS USED FOR EVALUATION
      Hazard
    Monitored
         Instrument
          Application
                Detection
                 Method
       Notes
                   3)  Photoionizing Detectors
                              Measures total concentrations of
                              substance(s).  Some
                              identification  of compounds is
                              possible if more than one probe
                              is used.
                                 Ultraviolet radiation ionizes molecules
                                 producing ions proportional to concentration.
                                            Does not detect
                                            methane.
                                            Compounds have
                                            different ionization
                                            potentials.
                   4)  Portable infrared
                      Spectrophotometer
                              Designed to quantify one or two
                              component mixtures.
                                 Infrared radiation (IR) is passed through a
                                 sample; each compound will absorb IR at a
                                 specific frequency.  Amount of adsorption is
                                 proportional to concentration.
                                            Requires knowledge
                                            of IR frequencies
                                            for chemicals.
                                            Short battery life.
                                            Needs to be
                                            operated at a stable
                                            location (table top).
                  5)  Catalytic Combustion
                      Meters (Super Sensitive
                      Combustible Gas
                      Indicators).
                              Measures substances capable of
                              being combusted.
                                 Oxidation takes place on the surface of a
                                 heated catalytic bead element.  Oxidation is
                                 proportional to concentration.
                                            Similar to CGI, but
                                            used for ppm
                                            measurements.
  Inorganics
  (Volatile)
1)  Colorimetric tubes
Measure concentration of
specific inorganic gases and
vapors.
See previous description of detector tubes.
See previous note.
                  2)  Photoionizing Detectors
                              Measure total concentration of
                              some inorganics.
                                 See previous description of photoionization
                                 detectors.
                                            See previous note.
                                            Detects limited
                                            number of
                                            inorganics.
6/91

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                                                                     PART 1

                                                   DIRECT-READING INSTRUMENTS
                                                               APPENDIX I CONT'D

                                          DIRECT-READING INSTRUMENTS USED FOR EVALUATION
     Hazard
    Monitored
         Instrument
          Application
                 Detection
                  Method
      Notes
                  3)  Portable Infrared
                      Spectrophotometer
                              Designed to quantify one or two
                              component mixtures.  Will detect
                              oxides of nitrogen, ammonia,
                              hydrogen cyanide, hydrogen
                              fluoride and sulfur dioxide.
                                 See previous description of infrared
                                 spectrophotometer.
                                             See previous note
                                             on 1R.
                  4) Specific Chemical
                     Monitors
                              Measure concentration of
                              specific gases and vapors.
                                 Electrochemical sensor or metal oxide semi-
                                 conductor UV light absorption for mercury
                                 vapor detection.
                                             Limited number of
                                             chemicals can be
                                             detected. Even
                                             though specific,
                                             there can
                                             interferences.
  Aerosols/*
  Particulates
Direct-Reading Instruments
for Analyzing Airborne
Particulates.
Measures the concentration of
aerosols in air.  Can separate
respirable from non-respirable
aerosols.
Operates on one of three basic techniques
1) Optical
2) Piezoelectric
4) Beta Attenuation
Individual
instruments have
specific notes.
Instruments are
available  to
measure fibers.
   These direct-reading instruments will readout total or respirable aerosol matter, not the composition of the aerosols.  The content, e.g., lead, pesticides, of a dust,
   fume, mist, fog, spray or smoke must be determined by specific analysis.
6/91

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                                     SECTION 4

                               AIR SURVEILLANCE

                                    PART TWO

                        MANUFACTURERS AND SUPPLIERS OF
                   AIR MONITORING AND SAMPLING EQUIPMENT
I.      AIR MONITORING/SAMPLING EQUIPMENT

       A.    Aerosol/Particulate Monitors:

                    Andersen Samplers Incorporated
                    Air Techniques Incorporated
                    California Measurements, Inc.
                    General Metal Works Inc.
                    HUND Corporation
             -     MDA Scientific, Inc.
                    Met One Inc.
                    MIE, Inc.
                    Pacific Scientific (HIAC/ROYCO Instrument Division)
                    Particle Measuring Systems Inc.
                    Products Production Marketing, Inc.
                    TSI Incorporated
             —     Wedding  & Associates, Inc.

       B.    Calibration Gases:     (many manufacturers of instruments provide calibration gases for
                                  use with their instruments)

             —     Airco Industrial Gases
             —     Alphagaz
                    Digicolor
                    Environics Inc.
                    GC Industries
                    Liquid Air Corporation
                    National Specialty Gases
                    Scott Specialty Gases
                    VICI Metronics

       C.    Canister Samplers:

                    Andersen Samplers Incorporated
                    Nutech Corporation
                    Scientific Instrumentation Specialists (SIS)
                    Wedding  & Associates, Inc.
6/90                                     37

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      D.     Collection Media:
                    Ace Glass Incorporated
                    BGI Incorporated
                    DACO Products
                    Gelman Sciences
                    Gilian Instrument Corp.
                    Hi-Q Environmental Products Company
                    LaMotte Chemical Products Company
                    Micro Filtration Systems.
                    Millipore Corporation
                    Mine Safety Appliances Co.
                    Nuclepore Corporation
                    Schleicher & Schuell
                    Sipin, AnatoleJ., Co., Inc.
                    SKC Inc.
      E.      Combustible Gas Meters:
                     Bacharach Instruments
                     Biosystems Inc.
                     Dynamation Incorporated
                     Enmet Corporation
                     GasTech Inc.
                     GfG America Gas Detection Ltd.
                     Grace Industries, Inc.
                     Heath Consultants Incorporated
                     Industrial Scientific Corporation
                     J and N Enterprises, Inc.
                     Lumidor Safety Products e.s.p. inc.
                     Mine Safety Appliances Co.
                     National Draeger, Inc.
                     Neotronics N.A., Inc.
                     Rexnord Safety Products
                     Scott Aviation
                     Sierra Monitor Corporation
                     Texas Analytical Controls, Inc.
       F.     Detector/Colormetric Tubes:

              -      Enmet Corporation
              —      Matheson Safety Products
                     Mine Safety Appliances Co.
              -      National Draeger, Inc.
                     Sensidyne

       G.     Gas Bags:

              -      AeroVironment Inc.
              —      The Anspec Company, Inc.


6/90                                           38

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                    BGI Incorporated
                    Calibrated Instruments, Inc.
                    Digicolor
                    Nutech Corporation
                    Plastic Film Enterprises
                    Pollution Measurement Corporation
                    SKC Inc.
      H.     Gas Chromatographs:
                    Bruker Instruments
                    CMS Research Corporation
                    The Foxboro Company
                    HNU Systems, Inc.
                    Microsensor Technology, Inc.
                    Photovac Incorporated
                    S-Cubed
                    Sentex Sensing Technology, Inc.
                    Summit Interests
                    Thermo Environmental Instruments Inc.
                    Varian
                    XonTech, Inc.
      I.     Oxygen Meters:
                    Bacharach Inc.
                    Biosystems Inc.
                    Dynamation Incorporated
                    Enmet Corporation
                    GC Industries
                    GfG America Gas Detection Ltd.
                    GasTech Inc.
                    Industrial Scientific Corporation
                    Lumidor Safety Products e.s.p., Inc.
                    MDA Scientific, Inc.
                    Metrosonics, Inc.
                    Mine Safety Appliances Co.
                    National Draeger, Inc.
                    Neotronics N.A., Inc.
                    Rexnord Safety Products
                    Scott Aviation
              —      Sensidyne
                     Sierra Monitor Corporation
              ~      Teledyne Analytical Instruments

       J.      Passive Dosimeters:

                     Advanced Chemical Sensors
                     Air Quality Research, Inc.


6/90                                      39

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R.S. Landauer, Jr. & Co.
Glenwood Science Park
Glenwood, IL  60425-1586
312/755-7000

Ludlum, Inc.
P.O. Box 248
Sweetwater, TX  79556
915/235-5494

Lumidor Safety Products e.s.p., Inc.
5364 NW 167th Street
Miami, FL  33014
305/625-6511

MDA Scientific, Inc.
405 Barclay Blvd.
Lincolnshire, IL 60069
312/634-2800
800/323-2000

MG Industries
175 Meister  Avenue
North Branch, NJ 08876
201/231-9595

MIE, Inc.
213 Burlington Road
Bedford, MA  01730
617/275-5444

Macurco, Inc.
3946 S. Mariposa Street
Englewood,  CO 80110
303/781-4062

Mast Development Company
Air Monitoring Division
2212 East 12th Street
Davenport, IA  52803
319/326-0141

Mateson Chemical Corporation
 1025 E. Montgomery Avenue
Philadelphia, PA 19125
215/423-3200
Matheson Safety Products
P.O. Box 85
East Rutherford, NJ  07073
201/933-2400

Met One, Inc.
481 California Avenue
Grants Pass, OR  97526
503/479-1248

Metrosonics, Inc.
P.O. Box 23075
Rochester, NY 14692-3075
800/654-7778

Micro Filtration Systems
6800 Sierra Court
Dublin, CA  94568
415/828-6010

Microsensor Technology, Inc.
47747 Warm Springs Blvd.
Fremont, CA 94539
415/490-0900

Millipore Corporation -
        Lab Products Division
80 Ashby Road
Bedford, MA 01730
800/225-1380

Mine Safety Appliances
P.O. Box 426
Pittsburgh, PA  15230
412/967-3000

National Draeger, Inc.
 101 Technology Drive
Pittsburgh, PA  15230
412/787-8383

National Specialty Gases
630 United Drive
Durham, NC 27713-9985

Neotronics N.A., Inc.
P.O. Box 370
411 North Bradford Street
 Gainesville, GA 30503
 404/535-0600
 6/90
                                           42

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Spectrex Corporation
3594 Haven Avenue
Redwood City, CA 94063
415/365-6567

Staplex Company
Air Sampler Division
777 Fifth Avenue
Brooklyn, NY  11232-1695
212/768-3333
800/221-0822

Summit Interests
P.O. Box 1128
Lyons, CO 80540
303/823-5303

Sybron Corporation
Analytical Products Division
221 Rivermoor Street
Boston, MA 02132
617/469-3300

3M/Occupation Health & Safety
       Products Division 3M Center
Building 220-3E
St Paul, MN  55144
800/328-1667

TIP Instruments Inc.
9101 NW 7th Avenue
Miami, FL 33150
305/757-8811

TSI Incorporated
500 Cardigan Road
P.O. Box 43394
St Paul, MN  55164
612/483-0900

Tekmar Company
P.O. Box 371856
Cincinnati, OH 45222
800/543-4461

Teledyne Analytical Instruments
16830 Chestnut Street
City of Industry, CA  91749
213/283-7181
Terradex Corporation
460 N. Wiget Lane
Walnut Creek, CA  94598
415/938-2545

Texas Analytical Controls, Inc.
P.O. Box 42520
Houston, TX  77242
713/240^160

Thermo Environmental Instruments
108 South Street
Hopkinton, MA 01748
617/435-5321

Thompson &  Nielsen Electronics Ltd.
303-4019 Carling Avenue
Kanata, Ontario, Canada
613/592-3019

VICI Metronics
2991  Corvin Drive
Santa Clara, CA  95051
408/737-0550

Victoreen Instrument Inc.
10101 Woodland Avenue
Cleveland,  OH 44104
216/795-8200

Warrington Laboratories, Inc.
P.O.  Box  15147
7801  N. Lamar, D-lll
Austin, TX 78752
512/452-2590

Wedding & Associates, Inc.
P.O.  Box  1756
Fort Collins,  CO 80522
303/221-0678

Whatman Paper Division
9 Bridewell Place
Clifton, NJ 07014
201/773-5800

Wheaton Scientific
1000 North 10th Street
Millville, NJ 08332
609/825-1400
 6/90
                                           43

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      B.      Aerosols
             Aerosol is a term used to describe fine particulates (solid or liquid) suspended in air.
             Particulates ranging in diameter from 5 to 30 microns are deposited in the nasal and
             pharyngeal passages. The trachea and smaller conducting tubes collect particulates
              1-5 microns in diameter. For particulates to diffuse from the bronchioles into alveoli
             they must be less than 0.5 microns in diameter. Larger particles do reach the alveoli
             due to gravity. The smallest particulates may never be deposited in the alveoli and
             so may diffuse back into the conducting tubes to be exhaled.

             Aerosols  can be classified in two ways:  by their physical form and origin and by the
             physiological effect on the body.

              1.     Physical Classification Examples:

                            Mechanical dispersoid:  liquid or solid particle
                            mechanically produced.

                            Condensation dispersoid:  liquid or solid
                            particle often produced by combustion.

                            Spray:  visible liquid mechanical  dispersoid.

                            Fume:  extremely small solid condensation
                            dispersoid.

                            Mist: liquid condensation dispersoid.

                            Fog:  mist dense enough to  obscure vision.

                            Smoke: liquid or solid organic particles
                            resulting from  incomplete combustion.

                            Smog:  mixture of smoke and fog.

              2.     Physiological Classification Examples:

                            Nuisance:  no lung injury but proper lung functioning
                            inhibited.

                            Inert pulmonary reaction causing: non-specific reaction.

                            Pulmonary fibrosis causing:  effects ranging from nodule
                            production in  lungs to serious diseases such as asbestosis.

                            Chemical irritation:  irritation, inflammation, or
                            ulceration of lung tissue.
6/91

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                            Systemic poison:  diseases in other parts of the body.

                            Allergy-producing:  causes allergic hyper sensitivity
                                   reactions such as itching or sneezing.

       C.     Gaseous Contaminants

              Gases and vapors are filtered to some degree on their trip through the respiratory
              tract.  Soluble gases and vapors are absorbed by the conducting tubes in route to the
              alveoli.  Not all will be absorbed so that along with insoluble gases, they finally
              diffuse into the alveoli where they can be directly absorbed into the bloodstream.

              Gaseous contaminants can be classified as chemical and physiological  hazards.

              1.      Chemical

                            Acidic:  acids or react with water to form
                            acids.

                            Alkaline:  bases or react with water to
                            form bases.

                            Organic:  compounds which contain carbon;
                            may range from methane to chlorinated organic solvents.

                            Organometallic: organic compounds containing
                            metals.

                            Hydrides:  compound in which hydrogen is
                            bonded  to another metal.

                            Inert:  no chemical reactivity.

              2.      Physiological

                            Irritants:  corrosive substances which  injure
                            and inflame tissue.

                            Asphyxiants:  substances which displace oxygen
                            or prevent the use of oxygen in the body.

                            Anesthetics:  substances which depress the
                            central nervous system, causing  a loss of
                            sensation or intoxication.

                            Systemic poisons: substances which can cause
                            disease  in various organ systems.
6/91

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IV.    RESPIRATORY PROTECTION DEVICES

       The basic function of a respirator is to reduce the risk of respiratory injury due to breathing
       airborne contaminants. A respirator provides protection by removing the contaminants from
       ambient air or by supplying the wearer with an alternate source of clean breathing air.

       All respiratory apparatus are composed of two main parts:  (1) the device which supplies or
       purifies air,  and  (2) the facepiece which covers the nose and mouth and seals out  the
       contaminants. The first component defines what class of respirator the device is; the second
       determines the relative measure of protection afforded by that respirator.

       A.     Classes of Respirators

              Respirators are divided into two major classifications according to their mode of
              operation:

               1.     Air Purifying  Respirators (APR's) remove contaminants  by  passing  the
                     breathing air through  a purifying  element.   There are a wide variety of
                     APR's available to protect against specific contaminants, but they all fall  into
                     two  subclasses: (1) particulate APR's which employ  a  mechanical filter
                     element,  and  (2) gas  and  vapor APR's  that  utilize  chemical  sorbents
                     contained in a cartridge or canister.

                     It  is important to realize that there are limitations on the applications of
                     APR's. These devices are specific for certain types of contaminants, so the
                     identity  of  the hazardous agent must be  known.   There are  maximum
                     concentration limits; this requires a knowledge of the ambient  concentration
                     of the contaminant, as  well  as the  Maximum  Use Limit (MUL) of the
                     respirator.  Since APR's only clean  the air, the ambient concentration of
                     oxygen must be sufficient (> 19.5%) for the user.

               2.     Atmosphere - Supplying Respirators (ASR's) provide a substitute  source of
                     clean breathing air.  The respirable air is supplied to the worker from either
                     a stationary source through a long hose, or  from a  portable container.  The
                     first type are called supplied-air respirators and the latter are known as self-
                     contained breathing apparatus (SCBA).

                     These  devices  can  be  used  regardless  of  the  type   of  airborne
                      contaminant  or  oxygen  concentration.     However,  the   contaminant
                      concentration limits vary for the different  types of ASR's and the wearer
                      must be aware of the limitations of his/her respirator.

        B.     Respiratory Protection

               The protection provided the respirator wearer is  a function of how well the facepiece
               (mask) fits. No matter how efficient the purifying element or how clean the supplied
               air, there is little protection afforded if the respirator mask does not provide a leak-
               free  facepiece-to-face seal. Facepieces are available in three basic configurations
               (see  FIGURE 2) which relate to their protective capacity.
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                     Quarter-Mask (Type B Half-Mask) fits over the bridge of the nose, along the
                     cheek, and  across  the top  of  the chin.   The headbands which  hold the
                     respirator in place are attached  at two or four places of the mask (i.e.  two-
                     or four-point suspension). Limited protection is expected because the respir-
                     ator can be easily dislodged, creating a breach in the seal.

                     Half-Mask (Type A Half-Mask) fits over the  bridge of the nose, along the
                     cheek, and under the chin. Headbands have a fourpoint suspension. Because
                     they maintain a better  seal  and are less  likely to be dislodged, half-masks
                     give greater protection than quarter-masks.

                     Full-Facepiece  fits  across the forehead,  down over  the temples and cheeks,
                     and under the chin.  They typically have a head harness with a five or six-
                     point suspension. These masks give the greatest protection because they are
                     held in place more  securely and because it is  easier to maintain a good seal
                     along the forehead than it is across the top of the nose.  An added benefit is
                     the eye protection from the  clear lens in the full-facepiece.
                           FACCrlECE

                     INHALATION VAIV
                     AIR PURIFYING
                     ELEMENT
                       EXHALATION VALVE
                                                                  QUARTER-MASK RESPIRATOR
HEADBANDS
                             HALF-MASK RESPIRATOR
                                                        INHALATION VALVE
                                                        AIR PUHIFTIH
                                                        CLEMENT
                                                                  FACEPIECE
                                                              AIR DIRECTING
                                                              INLET
                                                                   EXHALATION VALVE
                                                            FULL FACEPIECE RESPIRATOR
                                        FIGURE 2

                         TYPES OF RESPIRATOR FACEPIECES
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             Not all respirators  fit  everyone,  so  each  individual  must  find  out which
             manufacturer's masks he/she can properly wear.  At best, any given respirator will
             fit  60% of the working  population.  But with the large number of respirators
             available, at least one type should  be found to fit an individual.

             The use of respirators is prohibited when conditions prevent a good facepiece-to-face
             seal.  Some examples of these conditions are facial hair, skullcaps, long hair, make-
             up,  temple pieces on  eyeglasses.   Because maintaining  a  leak-free  seal  is  so
             important, personnel required to wear respirators must successfully pass a fit-test
             designed  to  check  the  integrity  of the  seal.There  are  two  types  of fit-tests:
             quantitative and qualitative.  The quantitative test is an analytical determination of
             the concentration of a test agent inside the facepiece compared to  that  outside the
             mask.   This concentration ratio  is  called the Assigned  Protection Factor (APF) and
             is a measure of the relative protection offered by a respirator.  For example, if the
             ambient concentration of the test agent is 1000 and the concentration inside the mask
             is 10 ppm, the respirator  gives the tested individual an APF of 100.  So:
                            Concentration outside mask
                  APF =    	
                  rt         Concentration inside mask
              Because quantitative tests are expensive  and tedious,  qualitative tests  are  most
              often performed to  check respirator fit. A qualitative fit-test is not an  analytical
              measurement.  It is a subjective test where an irritant or aroma is used to determine
              if there is a good facepiece-to-face seal.   If the test subject does not respond (by
              smelling, tasting, coughing,  etc.) to the  test agent, he/she can wear the tested
              respirator  with the  APF for  that  type of mask.  Table 2 lists several  types of
              respirators and their APFs.

              A Protection Factor is  used  to determine the  Maximum Use  Limit (MUL) of a
              successfully fit-tested respirator.   The  MUL  is the highest  concentration, not
              exceeding IDLH concentration, of a specific contaminant in which a  respirator can
              be worn:
                                    MUL  = APF x TLV
              For example, if a contaminant has a TLV-TWA of 10 ppm, then the MUL for any
              half-mask respirator is  100 ppm; the  MUL  for a full-facepiece APR or demand
              SCBA is 1000 ppm.  If the ambient concentration is greater than 1000 ppm, then a
              pressure demand SCBA is required.

              Fit testing and Assigned Protection Factors are only two of the several considerations
              for selecting the proper respirator. Much more detailed information on the types and
              applications of APR's and ASR's is covered in  the other Parts of this Section.
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TABLE 2
RESPIRATOR ASSIGNED PROTECTION FACTORS*
Type of Respirator
Air-purifying
quarter-mask
half-mask
Air-line
quarter-mask
half-mask
Hose mask
full facepiece
SCBA, demand
quarter-mask
half-mask
Air-purifying
full facepiece
Air-line, demand
full facepiece
SCBA, demand
full facepiece
Airline, pressure-demand,
with escape provision
full facepiece (no test required)
SCBA, pressure-demand or
positive pressure
full facepiece (no test required)
NIOSH
APF (Qualitative Test)
5
10
10
10
10
10
10
50
50
50
10,000
10,000
* For more detailed information consult Table 5. "Respirator Protection Factors" in ANSI Z88.2-
1980.
V.     RESPIRATOR USE AND SELECTION

       A.     User Requirements

              The health of a respirator wearer is based on how the respirator is used.  The
              American National Standards Institute (ANSI) has prepared the "American National
              Standard Practices for Respiratory Protection",  and updates it periodically.  The
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      rescinded.  This is intended to protect the respirator user.  Also, any unauthorized changes
      or hybridization of a respirator by the user invalidates the respirator approval and all the
      guarantees understood with the approval.

      Appendix I presents the approval schedules for specific types of respirators.  The schedule
      number came from the  original Bureau of Mines respirator approval requirements.  The
      Bureau of Mines preceded the Mining Enforcement and  Safety Administration (NESA),
      which eventually became MSHA.

      Many agencies were responsible for respirator certification at  one time or another.  Thus
      respirators in use today may bear  approval numbers issued to the manufacturers by the
      Bureau of Mines, MESA, and MSHA.  The approval number must be displayed on the
      respirator  or its  container.   It consists of the prefix TC  (Testing and Certification), the
      schedule number, followed by the approval number.  For example in TC-13F-69, "13" is
      the schedule for self-contained breathing apparatus, "F" indicates the number of revisions
      to the schedule,  and 69 is  the consecutive approval number.  Also,  the  approval  label
      includes the certifying agencies.

      Periodically, NIOSH publishes a list of all approved respirators and respirator components.
      The current edition, issued in 1988, is entitled the NIQSH Certified Equipment List as of
      September. (DHHS [NIOSH] Publication No. 87-102). This document is used to answer two
      basic questions about respiratory protection:

             Is this respirator appropriate (approved) for  the
             existing work conditions?

             Is this respirator (mask and purifying-elements)
             an approved assembly?

      If the answer to either of these questions is "no", then the worker is prohibited  from using
      that respirator (or type  of respirator). Table 3  in Appendix I presents an  example of the
       "NIOSH Certified Equipment List".
VII.   RESPIRATOR CARE AND CLEANING

       Once a respirator has been used it must be cleaned.  All detachable parts such  as straps,
       valves, and gaskets  are removed. Cartridges cannot be cleaned. They can be used  again
       if their service life has not been exhausted and they are stored properly.  The facepiece and
       other parts can be washed separately in sanitizer solution.  The parts should go through two
       water rinses and be left to air dry.  When dry, the parts are reassembled and the  respirator
       is put in  a clean plastic bag and stored where it will be protected from high temperatures,
       very dusty environments or conditions that could alter the shape of the mask.  Additional
       details  are provided in Part 2, Appendix IV.
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                                     APPENDIX I

                        NIOSH CERTIFIED EQUIPMENT LIST
I.      RESPIRATOR SELECTION

       The selection of an appropriate respirator for use in a given situation can only be made by
       carefully considering a number of interrelated environmental, equipment, work situation, and
       human factors.

       Once a type of respirator is selected, then the user can refer to appropriate table for a list
       of all approved devices of that type:
RESPIRATOR TYPE
S elf-Contained Breathing Apparatus
Gas Masks
Supplied-Air Respirators
Dust, Fume, and Mist Respirators
Chemical Cartridge Respirators
Vinyl Chloride Respirators
APPROVED SCHEDULE
TC-13F-
TC-14G-
TC-19C-
TC-21C-
TC-23C-
TC-11-
       Also, if the user chooses a specific respirator, he/she can look up the approval number for
       that device and determine the type of respirator protection it provides.  For example, if you
       were to choose an MSA half-mask respirator with organic vapor cartridges, you would first
       find the approval  number  on the cartridge label.  Next you look under the  schedule for
       chemical  cartridge respirators organic vapor until you  find the correct listing, in this case
       TC-23C-201.  From TABLE 3 (next page), it can be seen that this respirator can be  used
       for organic vapors, paints-lacquers-enamels, and dusts  or mists under specified conditions.
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         The difference in applications is the Maximum Use Concentration (MUC) for which the
         cartridge or canister can be used in accordance with its NIOSH/MSHA  approval. For
         example, organic vapors can be removed by the appropriate cartridges, chin canister, or
         gas-mask canister.  Cartridges are approved for use in atmospheres up to 1,000 ppm
         (0.1%) organic  vapors, chin style canisters up to 5000 ppm (0.5%),  and gas mask
         canisters up to 20,000 ppm (2.0%).  However, no air-purifying respirator is permitted
         in an IDLH atmosphere.

      2. Service Life

         Each sorbent has a finite  capacity for  removing contaminants and when this  limit is
         reached  the cartridge or canister is said to be saturated.  At this point the element will
         allow the contaminant to pass through  and enter the facepiece.  The length of time a
         cartridge or canister will effectively sorb the contaminant is known as the service life of
         the  element.  Service life of a type of cartridge or canister is  dependent on several
         factors:   the breathing  rate of the wearer; contaminant concentration; and  sorption
         efficiency.

         a.  Breathing Rate

             If the breathing rate of the user is rapid, the flow rate of the contaminated air drawn
             through the  cartridge is greater than it is at a moderate or slow respiration rate.  A
             higher flow  rate brings a larger  amount of contaminant in contact with the sorbent
              in a  given period  of time which, in turn, increases the rate of sorbent saturation and
              shortens service life.

          b.   Contaminant Concentration

              The   expected service life  of an organic  vapor  cartridge decreases  as  ambient
              contaminant concentration increases.  As concentration goes up, the mass flow rate
              increases, bringing more contaminant in contact with the  sorbent in a given period
              of time.  For example, at any constant breathing rate, ten times as much contaminant
              contacts the element when the concentration is 500 ppm compared to 50 ppm.

          c.   Cartridge Efficiency

              Chemical sorbents vary in their ability to remove  contaminants from air.  Table 5
              compares the efficiency of organic vapor  cartridges for  a number of solvents by
              recording the amount of time until a 1 % breathrough concentration was measured in
              the cartridge-filtered air. The initial test concentration is 1000 ppm of solvent vapor;
              the breathrough concentration is 10 ppm.  From the table it can be seen that it takes
              107  minutes for chlorobenzene to reach a 1% breakthrough, while it only takes 3.8
              minutes for vinyl chloride.   The sorbent  (activated  carbon) in the organic vapor
              cartridge is much better for removing chlorobenzene than vinyl chloride under the
              test  conditions.  Cartridge efficiencies need to be considered when selecting  and
              using APR's. References for cartridge efficiency studies can be found  in Appendix
              I.
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                                   TABLE 5
                       EFFECT OF SOLVENT VAPOR ON
                    RESPIRATOR CARTRIDGE EFFICIENCY1
                  SOLVENT
   TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
       MINUTES (2)
       Aromatics3
          Benzene
          Toluene
          Ethyl benzene
          m-Xylene
          Cumene
          Mestiylene
            73
            94
            84
            99
            81
            86
       Alcohols3
           Methanol
           Ethanol
           Isopropanol
           Allyl alcohol
           n-Propanol
           sec-Butanol
           Butanol
           2-Methoxyethanol
           Isoarayl alcohol
           4-Methyl-2-pentanol
           2-Ethoxyethanol
           Amyl alcohol
           2-Ethyl-l-butanol
            0.2
            28
            54
            66
            70
            96
            115
            116
            97
            75
            77
            102
            76.5
        Monochlorides
           Methyl chloride
           Vinyl chloride
           Ethyl chloride
           Allyl chloride
           1-Chloropropane
           1-Chlorobutane
           Chlorocyclopentane
            0.05
            3.8
            5.6
            31
            25
            72
            78
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                                TABLE 5 CONT'D
                        EFFECT OF SOLVENT VAPOR ON
                    RESPIRATOR CARTRIDGE EFFICIENCY1
                   SOLVENT
   TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
       MINUTES (2)
       Monochlorides3
           Chlorobenzene
           1-Chlorohexane
           o-Chlorotoluene
           1 -Chloroheptane
           3-(Choromethyl heptane)
             107
             77
             102
             82
             63
       Bichlorides3
           Dichloromethane
           trans-1,2-Dichloroethylene
           1,1-Dichloroethane
           cis-1,2-Dichloroethylene
           1,2-Dichloroethane
           1,2-Dichloropropane
           1,4-Dichlorobutane
           o-Dichlorobenzene
             10
             33
             23
             30
             54
             65
             108
             109
        Trichlorides3
           Chloroform
           Methyl chloroform
           Trichloroethylene
           1,1,2-Trichlorethane
           1,2,3-Trichloropropane
             33
             40
             55
             72
             111
        Tetra- anmd Pentachlorides3
           Carbon tetrachloride
           Perchloroethylene
           1,1,2,2-Tetrachloroethane
           Pentachloroethane
             77
             107
             104
             93
        Acetates3
           Methyl acetate
           Vinyl acetate
           Ethyl acetate
           Isopropyl acetate
             33
             55
             67
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                                TABLE 5 CONT'D
                        EFFECT OF SOLVENT VAPOR ON
                     RESPIRATOR CARTRIDGE EFFICIENCY1
                   SOLVENT
   TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
       MINUTES (2)
        Acetates3 Cont'd
           Isopropenyl acetate
           Propyl acetate
           Allyl acetate
           sec-Butyl acetate
           Butyl acetate
           Isopentyl acetate
           2-Methoxyethyl acetate
           1,3-Dimethylbutyl acetate
           Amyl acetate
           2-Ethoxyethyl acetate
           Hexyl acetate
             83
             79
             76
             83
             77
             71
             93
             61
             73
             80
             67
        Ketones4
           Acetone
           2-Butanone
           2-Pentanone
           4-Methyl-2-pentanone
           Mesityl oxide
           Cyclopentanone
           3-Hepanone
           2-Heptanone
           Cyclohexanone
           5-Methyl-3-heptanone
           3-Methylcyclohexanone
           Diisobutyl ketone
           4-Methylcyclohexanone
             37
             82
             104
             94
             96
             122
             141
             91
             101
             126
             86
             101
             71
             111
        Alkanes4
           Pentane
           Hexane
           Methylcyclopentane
           Cyclohexane
           2,2,4-Trimethylpentane
           Heptane
           Methylcyclohexane
           5-Ethyl idene-2-norbornene
           Nonane
           Decane
             61
             52
             62
             69
             68
             78
             69
             87
             76
             71
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                                TABLE 5 CONT'D
                        EFFECT OF SOLVENT VAPOR ON
                    RESPIRATOR CARTRIDGE EFFICIENCY1
                   SOLVENT
       Amines4
           Methyl amine
           Ethyl amine
           Isopropyl amine
           Propyl amine
           Diethyl amine
           Butyl amine
           Triethyl  amine
           Dipropyl amine
           Diisopropyl amine
           Cyclohexyl amine
           Ditbutyl amine
   TIME TO REACH 1%
BREAKTHROUGH (10 ppm)
       MINUTES (2)
             12
             40
             66
             90
             88
             110
             81
             93
             77
             112
             76
        Miscellaneous materials4
           Acrylonitrile
           Pyridine
           1 -Nitropropane
           Methyl iodide
           Dibromomethane
           1,2-Dibromoethane
           Acetic anhydride
           Bromobenzene
             49
             119
             143
             12
             82
             141
             124
             142
          Nelson, G. O., and  C. A. Harder.  Respirator Cartridge Efficiency Studikes,
          University of California, Livermor.  1976.

          Cartridge pairs tested at 1000 ppm, 50%  relative humidity, 22'C, and 53.3
          liters/minute  (equivalent to a moderately heavey work  rate).  Pair cartridges
          preconditioned at room temperature  and 50% relative humidity for at least 24
          hours prior to testing.

          Mine Safety Appliances Cartridges.

          American Optical Cartridges.
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                                         24

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3.      Warning Properties

   A warning property is used as a sign that a cartridge or canister in use is beginning to lose its
   effectiveness.  A warning property can be detected as an odor, taste, or irritation.  At the first
   such signal, the old cartridge or canister must be exchanged for a fresh one. Without a warning
   property, respirator efficiency may drop without the knowledge of the wearer, ultimately causing
   a health hazard.

   Most substances have warning properties at some concentration. A warning property detected
   only at dangerous levels  —  that is,  greater than EL—is not considered adequate.  An odor,
   taste, or irritation detected at extremely low concentrations  is also not adequate because the
   warning is being given all the time or long before the filter begins to lose its effectiveness.  In
   this case, the wearer would never realize when the filter actually becomes ineffective.

   The best concentration for a warning property  to be  first detected is around the EL.   For
   example, toluene has an odor threshold of 40 ppm and an EL of 100 ppm.   This is usually
   considered an adequate warning property. Conversely, dimethylformamide has an EL of 10 ppm
   and an odor threshold of 100 ppm.  An odor threshold ten times the  EL is   not  an adequate
   warning   property.   Adequate warning  properties  are  discussed  in more detail  in  the
   NIOSH/OSHA Respirator Decision Logic  (Section 5, Part 4, I of this manual).  A list of
   warning properties is found in Section 5, Part 2, Appendix V.

   If a substance causes  rapid olfactory fatigue (that is, the sense of smell is no longer effective),
   its odor is not  an adequate  warning property.   For example, upon  entering an  atmosphere
   containing hydrogen sulfide,  the odor is quite noticeable, After a short period of time, it is no
   longer detectable.
V.  REQUIREMENTS FOR RESPIRATOR USE

    The use of an air-purifying respirator is contingent upon a number of criteria.  If the conditions
    spelled-out in this section of the text cannot be met, then use of an APR is prohibited.  Figure
    2-2 illustrates the selection criteria in a flow diagram.

    A. Oxygen Content

       The normal atmosphere contains approximately 21%  oxygen.  The physiological effects of
       reduced  oxygen  begin to be  evident  at  16%.   Without regard  to  contaminants, the
       atmosphere must contain a minimum of 19.5% oxygen to permit use of an air-purifying res-
       pirator.  This is a legal  requirement of 30 CFR Part 11 and a recommendation of ANSI
       Z88.2 -  1980.   Below  19.5%  oxygen, atmosphere-supplying respirators must  be used
       instead.

    B. Identification of Contaminants

       It is absolutely imperative that the contaminant(s) be known so that:

           the toxic effects of inhaling the contaminant can be determined;

           appropriate particulate filters or cartridges/canisters can be chosen;


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          it can be determined that adequate warning properties exist for the contaminant;

          the appropriate facepiece be selected (full-face mask is necessary if the agent causes eye
          irritation).

   C. Known Contaminant Concentration

      The maximum concentration depends on the contaminant and the respirator.

          concentration must not exceed IDLH;

      -   the Maximum Use Limit of the respirator  cannot be exceeded (MUL=APF x1 EL);

          the Maximum Use Concentration of a particular type and size cartridge or canister must
          not be surpassed;

          expected service life (cartridge/canister efficiency) should be determined, if possiblt.

   D. Periodic Monitoring of Hazards

      Because  of the importance of knowing the identity and concentration of the  contaminant(s),
      monitoring  of the work area with  appropriate equipment must  occur at Ipast periodically
      during the work day. This is done to ensure that no significant changes have occurred  and
      the respirators being used are adequate  for the work conditions.

   E. Approval of Respirators

      The respirator assembly (facepiece and air-purifying  elements)  is approved for protection
      against  the contaminant  at the concentration which  is present in the  work area.  The
      concentration must not exceed the NIOSH/MSHA  designated MUC for that type and size
      cartridge or canister.

   F. Fit-test

      The wearer must pass a qualitative fit-test for the make,  model, and size  of air-purifying
      device used (Appendices II and III) provide instructions for the qualitative tests. The OSHA
      regulations, in 29 CFR 1910.1345 (e) (5)  (i),  state: "Every respirator wearer shall receive
      fitting instructions including demonstrations and practice in how  the respirator is worn, how
      to adjust it, and  how to determine if it fits properly.  Respirators shall not be worn when
      conditions prevent a good face seal.  Such conditions may be growth of beard, sideburns,
      a skull cap that projects under the facepiece, or temple pieces on  glasses.  Also, the absence
      of one or both dentures can seriously affect the fit of a facepiece.  The worker's diligence
      in observing these factors shall be evaluated by periodic check. To assure proper protection,
      the facepiece fit  shall  be  checked by the wearer each time he puts on the respirator.  This
      may be  done by  giving filing instructions".
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                                     APPENDIX I

      REFERENCE FOR RESPIRATOR CARTRIDGE EFFICIENCIES STUDIES
   Ruch, W.E.,  G.O. Nelson, C.L. Lindeken, R.E. Johjnsen, and D.J. Hodgkins.  "Respirator
   Cartridge Efficiency  Studies:    1.  Experimental Design."   American Industrial  Hygiene
   Association i.33. 105 (1972)

   Nelson, G.O., and D.H. Hodgkins.  "Respirator Cartridge Efficiency Studies:
   II.  Preparation of Test  Atmospheres." American Industrial Hygiene Association J. 33, 110
   (1972).

   Nelson, G.O., R.E. Johnsen, C.L. Lindeken, and R.D. Taylor.  "Respirator
   Cartridge Efficiency Studies:   III.   A Mechanical  Breathing Machine to Simulate Human
   Respiration."  American Industrial Hygiene Association J. 33, 745 (1972).

   Nelson, G.O., C.A. Harder. "Respirator Cartridge Efficienty Studies:  IV.
   Effects of Steady-State and Pulsating Flow."  American  Industrial Hygiene Association J. 33,
   797 (1972).

   Nelson, G.O., C.A. Harder, and B.E. Bigler.  "Respirator Cartridge Efficiency
   Studies:, VI. Effect of Concentration". Lawrence Livermore Laboratory, Rept. UCRL-76184
   (November, 1974).

   Nelson, G.O., and C.A. Harder. "Respirator Cartridge  Efficiency Studies:  V.
   Effect of Solvent Vapor."  American Industrial Hygiene  Association J. 35, 391 (1974).

   Nelson, G.O., C.A. Harder, and B.E. Bigler.  "Respirator Cartridge Efficiency
   Studies:  VII. Effect of Relative Humidity and Temperature."  Lawrence Liver more Laboratory,
   Rept. UCRL-77390 (August, 1975).

   Nelson, G.O., and A.N. Correia. "Respirator Cartridge Efficiency Studies:
   VIII.  Summary and Conclusions."   American Industrial Hygiene Association J. 37,9 (1976).
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                                       APPENDIX II

                               RESPIRATOR FIT-TESTING
I.   INTRODUCTION

    All users of potential users of demand-type respiratory protection devices should be fit tested
    to ensure a proper facepiece-to-face seal.   Either isoamyl acetate or irritant smoke should be
    used with one of the four methods described below.  A selection of respirators should be tested,
    with users allowed to choose the most comfortable from those that fit satisfactorily.
II. METHODS

    A. Method No 1  - Swab or Brush (Organic Vapors)

           Use only facepieces equipped with organic vapor cartridges.

           Perform the test in area with no noticeable air movement.

           Saturate a tissue, cloth, or brush with isoamyl acetate.

           Prior to testing, expose subject to a very low concentration of isoamyl acetate to assure
           that he/she can detect the odor.

           After subject dons the respirator, tester visually inspects facepiece-to-face seal.  If seal
           obviously leaks, test  ends and  mask  is  recorded  as unsatisfactory.  If subject is
           uncomfortable, test ends.

           Move  saturated material  slowly around entire  sealing surface of the respirator at  a
           distance of 3 to 6 inches.  Perform first with test subject sedentary,  then with subject
           moving head and face (i.e., talking, moving head side to side and up and down). End
           test if any leakage occurs.

           If the subject detects the odor during  fitting, record that respirator  as unsatisfactory,
           remove it from the subject, and visually inspect the facepiece-to-face seal. If any doubt
           exists about the respirator or cartridges, test a duplicate to assure that the leakage was
           due to  facepiece-to-face seal.


    B. Method No. 2 - Around Seal (Particulates)

           Use respirators equipped with high-efficiency filters  (HEPA)

           Perform test  in area with no noticeable  air movement.
6/91                                         29

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          Break both ends of a ventilation smoke tube.  Insert one
          end into the tube connected to the positive-pressure end of a two-way aspirator bulb and
          cover the other end  with  1- to 2  inch length  of Tygon, surgical, or rubber tubing.
          Squeeze the aspirator bulb to generate the test aerosol.

          After subject dons the respirator, tester visually inspects facepiece-to-face seal.  If seal
          obviously leaks, test ends  and  mask is recorded as  unsatisfactory.   If  subject  is
          uncomfortable, test ends.

      -   Direct the smoke around entire sealing surface of the respirator at a distance of 3 to 6
          inches.   Instruct subject to  breathe shallowly during  initial test  around surface and
          normally  thereafter  if no leakage is detected.  If a half-mask is being tested, instruct
          subject to close his/her  eyes for the duration of the  test.  Perform the test first with
          subject sedentary, then with subject moving head and face (i.e., talking, moving head
          side to side and up and down).  End test if any leakage occurs.

          If the subject detects the odor during fitting, record that respirator  as unsatisfactory,
          remove it from the subject, and visually inspect the sealing surface.  If any doubt exists
          about the respirator or cartridges, test a duplicate to assure that the leakage was due to
          the facepiece-to-face seal.

   C. Method No. 3 - Enclosure in Plastic Bag (Organic  Vapors)

   Use facepieces equipped with organic vapor cartridges.

          Saturate a tissue or  cloth with isoamyl acetate and suspend it inside the top of a plastic
          garbage bag or harvard hood.

          Prior to testing, expose subject to a very low concentration of the isoamyl  acetate to
          assure that he/she can detect the odor.

          After subject dons the respirator,  tester visually inspects facepiece-to-face seal. If seal
          obviously leaks,  test ends  and mask  is  recorded  as  unsatisfactory.   If subject is
          uncomfortable, test ends.

          Instruct subject to put his/her head  into the bag or  hood and breathe normally during a
          short (30-60 seconds) sedentary period.  If no leakage is detected, instruct the subject
          to perform  various exercises simulating, as  nearly as possible, work conditions (i.e.,
          talking,  running in place, head  movements, bending over).  End test if any leakage
          occurs.

       -   If the subject detects the odor during fitting,  record that respirator as unsatisfactory,
          remove it from the subject, and visually  inspect the sealing surface. If any doubt exists
          about the respirator or cartridges, test a duplicate to  assure that leakage was due to the
          facepiece-to-face seal.

   D. Method No.  4 - Enclosure in Plastic Bag (Particulates)

          Use respirators equipped with high-efficiency filters  (HEPA).
6/91                                          30

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           Break both ends of a ventilation smoke tube.  Insert one end into the tube connected to
           the positive-pressure end of a two-way aspirator bulb and cover the end with 1- to 2-inch
           length of Tygon, surgical, or rubber tubing.  Squeeze the aspirator bulb to generate the
           test aerosol.

           After subject dons the respirator, tester visually inspects facepiece-to-face seal.  If seal
           obviously leaks,  test ends and  mask  is  recorded as  unsatisfactory.   If subject is
           uncomfortable, test ends.

           Generate smoke into a hole punched in the top of the closed plastic bag until smoke can
           be visually detected throughout the bag or hood.

           Instruct subject to put his/her head into the bag or hood and breath shallowly during a
           short (30-60 seconds) sedentary period.  If a half-mask is being tested, instruct subject
           to close his/her eyes before entering and keep them closed until exiting.  If no  leakage
           is detected  during sedentary period, instruct  subject  to  perform  various exercises
           simulating, as nearly as possible, work conditions (i.e.,  talking, running  in place, head
           movements, bending over) while breathing normally. End test if any leakage occurs.

           If the subject detects the odor during fitting, record that respirator as unsatisfactory,
           remove it from the subject, and visually inspect the sealing surface. If any doubt exists
           about the respirator or cartridges, test a duplicate to assure that leakage was due to the
           facepiece-to-face seal.
6/91                                          31

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                                     APPENDIX III

             RESPIRATOR NEGATIVE AND POSITIVE PRESSURE TEST
I.      FITTING

   Place the respirator over the face and draw the straps evenly and securely. The mask should
   not be so tight as to cause discomfort or a headache. Secure bottom straps first, progressing to
   the top straps.
II.     NEGATIVE PRESSURE TEST

   This test (and the positive pressure test) should be used only as a very gross determination of
   fit. The wearer should use this test just before entering the hazardous atmosphere. In this test,
   the user closes off the inlet of the canister, cartridge(s), or filter(s) by covering with the palm(s),
   inhales gently so that the facepiece collapses slightly; and holds breath for about 10 seconds. If
   the facepiece remains slightly collapsed and no inward leakage is  detected, the respirator is
   probably tight enough.

   Although this test  is simple, it  has drawbacks; primarily that the wearer must handle the
   respirator after it has been positioned on his face. This handling can modify the facepiece seal.
III.   POSITIVE PRESSURE TEST

    This test, similar to the negative pressure test, is conducted by closing off the exhalation valve
    and exhaling gently into the facepiece.   The fit is considered satisfactory if slight  positive
    pressure can be built up  inside the facepiece without any evidence of outward leakage.  For
    some respirators, this method requires that the wearer remove the exhalation valve cover; this
    often disturbs the respirator fit even more than does the negative pressure test.  Therefore, this
    test should be used sparingly if it requires removing and replacing a valve cover.  The test is
    easy for respirators whose valve  cover has a single small port  that can be closed by the palm
    or a finger.
 6/91                                         33

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                                      APPENDIX IV

                       CARE AND CLEANING OF RESPIRATORS
I.      GENERAL REQUIREMENTS

   Any organization using respirators on a routine basis should have a program for their care and
   cleaning.  The purpose of a program is to assure that all respirators are maintained at their
   original effectiveness.  If they are modified in any way, their Protection Factors may be voided.
   Usually one person in  an organization is trained to inspect, clean, repair, and store respirators.

   The program should be based on the number and types of respirators, working conditions, and
   hazards involved. In general, the program should include:

   -   Inspection (including a leak check)

       Cleaning and disinfection

       Repair

   -   Storage
II.    INSPECTION

    Inspect respirators after each use.  Inspect monthly a respirator that is kept ready for emergency
    use to assure it will perform satisfactorily.

    On air-purifying respirators, thoroughly check all connections for gaskets and "O" rings and for
    proper tightness.  Check the condition of the facepiece and all  its parts, connecting air tube, and
    headbands.  Inspect rubber or elastomer parts for pliability and signs of deterioration.

    Maintain a record for each respirator inspection, including date, inspector, and  any unusual
    conditions or findings.
III.   CLEANING AND DISINFECTION

    Collect respirators at a central location.  Brief employees required to wear respirators on the
    respirator program and assure them that they will always receive a clean and sanitized respirator.
    Clean and disinfect respirators as follows:

       Remove all cartridges, canisters, and filters, plus gaskets or seals not affixed to their seats.

    -   Remove elastic headbands.

       Remove exhalation cover.


6/91                                         35

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       Remove speaking diaphragm or speaking diaphragm-exhalation valve assembly.

       Remove inhalation valves.

   -   Wash facepiece and breathing tube in cleaner/sanitizer powder  mixed with warm water,
       preferably at 120° to 140° F. Wash components separately from the facemask, as necessary.
       Remove heavy soil from surfaces with a hand brush.

       Remove all parts from the wash  water and rinse twice in clean warm water.

       Air dry parts in a designated clean area.

       Wipe facepieces, valves, and seats with a damp lint-free cloth to remove any remaining soap
       or other foreign materials.

   NOTE:    Most respirator manufacturers market their own cleaners/sanitizers as dry mixtures
              of a bactericidal agent and a mild detergent.  One-ounce packets for quantity use are
              usually available.
IV.    REPAIRS

    Only a trained person with proper tools and replacement parts should work on respirators.  No
    one should ever attempt to  replace components or to make adjustments or repairs beyond the
    manufacturer's recommendations.

    Make repairs as follows:
       Replace all faulty or questionable parts or assemblies. Use parts only specifically designed
       for the particular respirator.

       Reassemble the entire respirator and visually inspect the completed assembly.

       Insert new filters, cartridges, or canisters, as required.  Make sure that gaskets or seals are
       in place and tightly sealed.
V.  STORAGE

    Follow manufacturers' storage instructions, which are always furnished with new respirators or
    affixed to the lid of the carrying case.  In addition, these general instructions may be helpful:
       After respirators have been inspected, cleaned, and repaired, store them so as  to protect
       against dust,  excessive moisture, damaging chemicals, extreme temperatures and  direct
       sunlight.
6/91                                         36

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       Do not store respirators in clothes lockers, bench drawers,  or tool boxes.  Place them in
       wall compartments at work stations or in a work area designated for emergency equipment.
       Store them in the original  carton or carrying case.

       Draw clean respirators from storage for each use.  Each unit can be sealed in a plastic bag,
       placed in a separate box, and tagged for immediate use.
6/91
                                             37

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                                     APPENDIX V

                WARNING CONCENTRATIONS OF VARIOUS CHEMICALS

The following table is a compilation of warning concentrations of various chemicals taken from
several sources.  A warning concentration is that concentration in air at which a person can detect
the material either by its odor, by its taste,  or by it causing irritation.  Exposure limits, where they
exist, are included so that a  comparison can be made to determine if a chemical has adequate
warning properties.  A material has adequate warning properties if the effects (odor, taste, irritation)
are detectable and persistent at concentrations "at" or "below" the exposure limit.  Please note that
some sources give a statement like  "adequate" or "inadequate" for the warning properties. Since
the statement may be used in conjunction with a different exposure limit than is used in this table,
it should be used with caution. Some of the chemicals have a range of concentrations  because the
different sources have different values. This can be due to the variability of human  perceptions or
different test methods. The sources may have used different end points for their testing. This value
could be when the first person detected the odor, when everyone could smell it,  or when 50% of
the test  subjects could  detect  it.  Because of  these  variations the full range  of warning
concentrations is given so that the user can decide on which value to use.

The warning concentrations given are generally odor thresholds with irritation thresholds given in
parentheses. Taste thresholds are noted as special cases. The concentration units used in the table
are parts per million unless otherwise noted.
                                       39

-------
                                                                                  Exposure Limits1
CHEMICALS
Acetaldehyde
Acetamide
Acetic acid
Acetic anhyride
Acetone
Acetonitrile
Acetophenone
Acetyl bromide
Acetyl chloride
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile

Akrol
Aldrin
Allyl alcohol
Allylamine
Allyl chloride

Allyl chloroformate
Allyl disulfide
Allyl glycidyl ether
Allyl isocyanide
Ally isothiocyanate
WARNING CONCENTRATIONS2
0.0001 - 2.3 (50)
"odorless when pure*
0.1 - 24 (10 - 15)
0.1 -81.2 (5)
0.1 - 699
40- 170
0.002 - 0.60
5.0 x 10'4
1
0.05 - 16.6 (0.21 -0.5)
"odorless"
0.1 - 1
1.6 - 100, fatigue

10
0.2536 - 0.4027 mg/rn3
0.08 - 7.2, (0.75 - 25)
6.3 - 28.7
0.1 - 10 (50 - 100)

1.4
0.0012
<10
0.018
0.15 -0.42

PEL-TWA/STEL REL
100/150
10
C-5
750/1000 250
40/60 20
WEEL - 10
0.1/0.3
0.3 mg/m3 0.3 mg/m3
10
2 1
C-10 C-10
0.25 mg/m3 LD
2/4
1/2 1
C-3

TLV®-TWA/STEL
100/150
10/15
C-5
750/1000
40/60

0.1/0.3
0.3 mg/m3,A2
10
2,A2

0.25 mg/m3
2/4
1/2

IDLH
LEVEL
10000
1000
1000
20000
4000

5
N.A.

Ca

Ca
150
300

5/10
WEEL -/1
C-9.6
                                             5/10
                                                                           270

-------
                                                                               Exposure Limits1
 CHEMICALS
 Allyl mercaptan
 Allyl sulfide
 Ammonia
 Ammonium hydroxide
 Ammonium sulfamate

 n-Amyl acetate
 sec-Amyl acetate
 tert-Amyl acetate
 n-Amyl alcohol
  (1-Pentanol)
 Amylene
  (2-Methyl-2-Butene)
Amyl  isovalerate
 n-Amyl mercaptan
 n-Amyl Methyl Ketone
Amyl Sulfide
Anethole
Aniline
Apiol
Arsenic anhydride
  (Arsenic pentoxide)
  Arsine

Benzaldehyde
WARNING CONCENTRATIONS2   PEL-TWA/STEL
0.00005 - 0.21
0.000014 -0.01
0.04-55(55-140}            -/35
50
"odorless"
0.00090 - 10 (200)
0.0017 -0.082
0.0017

0.0065 - 35
0.0022 - 2.3

0.11
0.07
0.0009 - 0.35
0.0030 - 0.005
0.003
0.5 - 70
0.0063
1

0.21 -0.63

0.003 - 0.69 (4.6)
                      REL
                      C-50
 10 mg/m3 {Total dust)
 5 mg/m3 (Respirable fraction)
 100
 125
0.01 mg/m3
(as As)
0.05

WEEL - 2/4
                      TLV®-TWA/STEL
                      25/35

                      10 mg/m3

                      100
                      125
C-0.002 mg/m3
(as As)
C-0.002 mg/m3
(as As)
0.2 mg/m3
(as As)
0.05
                             IDLH
                             LEVEL
                             500
                             5000 mg/m3

                             4000
                             9000
                                                                       4000
                                                                       100
Ca
Ca

-------
                                                                                          Exposure Limits1
to
CHEMICALS
Benzene

Benzoyl peroxide
Benzyl alcohol
Benzyl chloride
Benzyl mercaptan
Benzyl sulfide
Bornyl acetate
Boron oxide

Boron trifluoride
Bromine
Bromoacetone
Bromoacetophenone
Bromoform
1,3-Butadiene
n-Butane
2-Butoxyethanol
Butyl acetate
sec-Butyl acetate
tert-Butyl acetate
Butyl acrylate
Butyl alcohol
sec-Butyl alcohol
tert-Butyl alcohol
WARNING CONCENTRATIONS2
1.4-120 (2817)

"odorless"
5.5
0.01 -0.31 (8)
0.00019 -0.04 (4.5)
0.0021  - 0.07
0.0078
"immediate irritation"

1-1.5
0.05 - 3.5 (0.6 intolerable)
0.090
0.015 -0.17 (0.04)
1.3 - 530
0.16 - 1.8 O8000)
5.5 - 5000
0.1 - 60 (100 - 195)
0.037 -  20 (300)
3 - 7
0.004 -  47
0.04 - 0.9
0.1 - 20 (25 - 100)
0.1 - 43
0.1 - 73 (100)
                                                                    PEL-TWA/STEL
                                                                    1/5

                                                                    5 mg/m3
                      REL
                      0.1
                      C-1
                      5 mg/m3

                      C-5  mg/m3
                      0.1
10 mg/m3 (Total dust)
5 mg/m3  (Respirable fraction)
C-1                   NE
0.1/0.3
                                                                   0.5
                                                                   1000
                                                                   800
                                                                   25
                                                                   150/200
                                                                   200
                                                                   200
                                                                   10
                                                                   C-50
                                                                   100
                                                                   100/150
                      LL
TLV«-TWA/STEL
10, A2

5 mg/m3
                                                                                                               10 mg/m3
IDLH
LEVEL
Ca
7000 mg/m3
                                                                                                                                            10
                             N.A.
C-1
0.1/0.3
0.5
10, A2
800
25
1 50/200
200
200
10
C-50
100/150
100/150
100
10
N.A.


700
10000
10000
10000

8000
10000
8000

-------
CHEMICALS
Butylamine
sec-Butylamine
tert-Butylamine
WARNING CONCENTRATIONS2   PEL-TWA/STEL
0.1 - 5 (10- 15)
0.24 (as n-Butylamine)
0.24 (as n-Butylamine)
Butyl cellosolve (see 2-Butoxyethanol)
Butyl cellosolve acetate
n-Butyl chloride
1-Butylene (1-Butene)
2-Butylene (2-Butene)
Butylene oxide
Butyl ether
n-Butyl formate
n-Butyl lactate
mercaptan
tert-Butyl mercaptan
Butyl sulfide
p-tert-Butyltoluene
n-Butyraldehyde
Butyric acid
Cadmium dust

Cadmium fume

Calcium dodecylbenzene
  sulfonate
Calcium hydroxide
0.20
0.9 - 13
0.07 - 26
0.57 - 22
0.71
0.24 - 0.47
17-20
1 - 7
0.00082 - 0.38
0.00009 - 0.06
0.015 -0.18
5 (5 - 8)
0.0046 - 0.039
0.00056 - 0.001
"inadequate"

"inadequate"

0.3

"odorless"
C-5
C-5
C-5
5
0.5
10/20
0.2 mg/m3
C-0.6 mg/m3
0.1 mg/m3
C-0.3 mg/m3
                      Exposure Limits1

                      BEL
C-0.5
LL
LL
                      TLV»-TWA/STEL

                      C-5
                      C-5
                      C-5
5
0.5
10/20


0.05 mg/m3

C-0.05 mg/m3
                             IDLH
                             LEVEL
                             2000
                                                        n-Butyl
2500
                                                                         1000
Ca
Ca
                                            5 mg/m3

-------
                                                                                Exposure Limits1
CHEMICALS
Calcium hypochlorite
Calcium phosphide
Camphor-synthetic
Caprolactam

Carbaryl (Sevin®)
Carbitol acetate
Carbon dioxide

Carbon disulfide

Carbon monoxide

Carbon tetrachloride
Cavacrol
Chloral
Chlordane
Chlorine
Chlorine dioxide
Chloroacetaldehyde
Chloracetic acid
Chloroacetophenone
  (CN, Tear Gas)
Chlorobenzene
 WARNING CONCENTRATIONS2  PEL-TWA/STEL
                      REL
 3.5 (as Chlorine)
 0.13 - 13.4
 0.003  - 200 (1.77)
 0.001  - 0.065

 "essentially odorless"
 0.157  -0.263
 "odorless"

 0.0011 - 7.7

 "odorless"

 2 - 700
 0.0023
 0.047
 "odorless"
 0.01 -  5 (1  - 6)
 0.1 (5.0)
 0.93 (0.01  - 1)
 0.045
0.01 -  1.35 (0.024 -0.063)

0.1 - 60
 2 mg/m3
 Dust - 1 /3 mg/m3
 Vapor 5/10
 5 mg/m3

 10,000/30,000

 4/12

 35
0.5 mg/m3
0.5/1
0.1/0.3
C-1
WEEL - 0.3/1
0.05

75
5 mg/m3

10000
C-30000
1
C-10
35
C-200
C-2
C-0.5
                      TLV«-TWA/STEL
 12/18 mg/m3
 Dust  1/3 mg/m3
 Vapor 5/10
 5 mg/m3

 5000/30000

 10

 50/400

 5,A2
0.5/2.0 mg/m3
1/3
0.1/0.3
C-1

0.05

75
                             IDLH
                             LEVEL
                                                  200 mg/m3
 600 mg/m3
50000
500
1500
                                                                        Ca
500 mg/m3
30
10
250

100 mg/m3

2400

-------
                                                                                Exposure Limits1
CHEMICALS
WARNING CONCENTRATIONS2
(0.2)
o-Chlorobenzylidene
  malononitiile
Chlorobromomethane         100-400
Chloroform                  50 - 307, fatigue (>4096)
Chloromethane (see  Methyl chloride)
Chlorophenol
o-Chlorophenol
p-Chlorophenol
Chloropicrin
B-Chloroprene
Chlorosulfonic acid
o-Chlorotoluene
Chlorovinyl arsine
Cinnamaldehyde
Citric acid
Cobalt, Metal Fume & Dust
Coumarin (Coumaphos,
  Baymix)
Crag® Herbicide

m-Cresol
o-Cresol
p-Cresol
Crotonaldehyde
Crotyl Mercaptan
0.034
0.0036
1.2-30
0.8 - 1.1  (0.3- 0.37)
0.1 - 138
1 - 5 (from HC1  produced)
0.32
1.6
0.0026
"odorless"
(>1 mg/m3)
0.0033 - 0.2

"none"

0.25 - 0.68
0.26 - 0.68
0.00047 - 0.0455
0.01 - 7.35 (45)
0.00016 - 0.0099
PEL-TWA/STEL
 C-0.05

200
2
REL
0.1
10
WEEL - 0.3
50
                                                    C-2
C-1
0.05 mg/m3
10 mg/m3 (Total dust)
5 mg/m3 (Respirable fraction)
5                     2.3
5                     2.3
5                     2.3
2
TLV«-TWA/STEL
C-0.05

200/250
10.A2
0.1/0.3
10

50/75
                      0.05 mg/m3
                      5
                      5
                      5
                      2
IDLH
LEVEL
2 mg/m3
                                                  5000
                                                  Ca
4
Ca
                             20 mfl/m3


                             5000 mg/m3

                             250
                             250
                             250
                             400

-------
                                                                                         Exposure Limits1
ON
          CHEMICALS
          Crude-Heavy
            (loganillas-Crude)
          Crude-Light
            (Louisiana-Crude)
          Crude-Medium
            (Barbados-Crude)
          Cumene
Cyclohexane
Cyclohexanol
Cyclohexanone
Cyclohexene
Cyclohexylamine
Cyclopentadiene
2,4-D esters
DDT (Dichlorodiphenyl
  trichloroethane)
Decaborane
Decanoic acid
Decanal
1-Decylene
Diacetone alcohol
Diacetyl
Diallyl ketone
                            WARNING CONCENTRATIONS2  PEL-TWA/STEL
                            0.1 -0.5

                            0.1 -0.5

                            0.1 -0.5
                                                    Bit
                            0.04 - 1.2
          Cyanogen chloride (CNCL)   1  C-0.3
0.1 -300 (300)
0.06 -  160  (100)
0.01 -  4
0.18 -  300
2.6
0.01 -  250
0.02 -0.1
2.9 mg/m3

0.05 -  0.35 (fatigue)
0.0020 - 0.35
0.0064-0.168
0.12
0.1 - 1.7
0.025
9.0
                              50
300
50
25
300
10
75
10 mg/m3
1 mg/m3

0.05/0.15
                                                                   50
                                                                                C-0.3
                                                                                         25
                                                                                         LD
                     50
                                            TLV-TWA/STEL
                                                                                                              0.05/0.15
50
                             IDLH
                             LEVEL
50
50 mg/m3

300
50
25
300
10
75
10 mg/m3
1 mg/m3
8000

(as CN)
10000
3500
5000
10000

2000
500 mg/m3
Ca
                             20
2100

-------
CHEMICALS
Diazomethane
Diborane
Di-N-Buty! amine
Dibutyl phosphate
Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
Dichlorodiethyl sulfide
  (Mustard Gas)
Dichlorodifluoromethane
1,3-Dichloro-5,5-dimethyl
  hydatoin
1,1 -Dichloroethane
1,2-Dichloroethylene
Dichloroethyl ether
bis-a-Dichloroethyl sulfide
Dichloroispropyl ether
WARNING CONCENTRATIONS2   PEL-TWA/STEL
                      Exposure Limits1

                      PEL
"inadequate"
1.8 - 4, "not reliable"
0.08 - 0.48
"inadequate"
0.005
0.3 - 50 (20 - 30)
0.18-30 (80- 160)
0.0023-0.19

"odorless"
"adequate", 0.01 (1.14)

50 - 1350,  "adequate"
0.085 - 500
0.0005 -35 (100-200)
0.0023
0.32
Dichloromethane (see Methylene chloride)
Dichloromonofluoromethane "nearly odorless"
2,4-Dichlorophenol
1,2-Dichloropropane
2,2-Dichloropropionic acid
  (Dalapon)
Dichlorotetrafluoroethane
Dicyclopentadiene
0.21 - 0.008
0.1 - 70
428

"nearly odorless"
0.003 - 0.020
0.2
0.1

1/2
(see o-, p-)
C-50
75/110
1000
0.2/0.4 mg/m3

100
200
5/10
HWC
10

75/110
1

1000
5
                      TLV«-TWA/STEL
                      0.2
                      0.1

                      1/2

                      C-50
                      75/110
1000
0.2/0.4 mg/m3

200/250
200
5/10
                      10

                      75/110
                      1

                      1000
                      5
                             IDLH
                             LEVEL
                             10
                             40

                             125

                             1700
                             1000
50000
5 mg/m3

4000
4000
250
                                                                                                         50000
                              50000

-------
                                                                                          Exposure Limits1
oo
CHEMICALS
Dieldrin
Diesel Fuel No. 1-D
Diesel Fuel No. 2-D
Diesel Fuel No. 4-D
Diethanolamine
Diethylamine
Diethylaminoethanol
Diethylene glycol

Diethylene triamine
Diethyl ketone
Diethyl selenide
Diethyl succinate
Difluorodibromomethane
Diglycidyl ether
Diisobutyl  carbinol
Diisobutyl  ketone
Diisopropylamine
Dimethyl acetamide
Dimethylamine
Dimethylaminoethanol
Dimethylaniline
Dimethyl ether
Dimethylformamide
1,1 -Dimethylhydrazine
 WARNING CONCENTRATIONS2  PEL-TWA/STEL
 0.041                         0.25 mg/m3
 0.25
 0.08
 0.01
 0.011 - 0.27
 0.01 - 38 (50, animals)
 0.01 - 0.25
 "almost odorless"

 10
 1 - 10
 0.00014
 0.021
 "inadequate"
,5
 0.048 -0.160
 0.11 -0.31 (25.8)              25
 0.1-4 (25 -50, injury)          5
 21 -47                        10
 0.01 -6 (97- 183, animals)      10
 0.015 -0.045
 0.001 -0.2                    5/10
 0.3 - 9                        WEEL - 500
 0.1 - 100                      10
 1  - 14                         0.5
                                                                                          Bit.
                                                                                          LD
                                            TLV«-TWA/STEL
                                            0.25 rrtQ/m3
                              IDLH
                              LEVEL
                              Ca
3
10/25
10
WEEL - 50 ppm, Total
     - 10 mg/m3, Aerosol only
1
200
0.2 mg/m3 (as Se)      0.2 mg/m3 (as Se)

100
0.1
                                                                                         25
                                                                                         0.06
                                                                                                               3
                                                                                                               10/25
                                                                                                               10
 1
 200
 0.2 mg/m3 (as Se)

 100
 0.1

 25
 5
 10
 10

5/10

 10
0.5,A2
                             2000
                             500
2500
Ca

2000
1000
400
2000

100

3500
Ca

-------
                                                                                  Exposure Limits1
CHEMICALS
Dimethyl sulfate
Dimethyl sulfide
Dimethyl sulfoxide
Dimethyl trithiocarbonate
Dinitro-o-cresol
2,6-Dinitrophenol
Dinitrotoluene
Dioxane
Dioxolane
Diphenyl (Biphenyl)
Diphenylamine chlorarsine
Diphenyl chloroarsine
Diphenylcyanoarsine
Diphenyl ether (see Phenyl
Diphenyl sulfide
Diphosgene (Trichloro-
 methyl chloroformate)
Dipropylamine
Dipropylene glycol
Dipropylene glycol
  methyl ether
Dithioethylene glycol
Dodecanol
Dodecyclbenzene sulfonic
  acid
    WARNING CONCENTRATIONS2   PEL-TWA/STEL
                      Blk
    "nearly odorless"
    0.001 - 0.020
    "practically no odor"
    0.0058 -0.18 mg/m3
    "odorless"
    0.21 (as phenol)
    "inadequate"
    0.003 - 278 (200 - 300)
    64- 128
    0.0008 -  0.06 {3 - 4)
    0.22
    0.030
    0.3
ether)
    0.00034  - 0.0047
    1.2

    0.02 • 55
    "practically odorless"
    34.7 - 1000 (74.3)

    0.031
    0.0064
    0.4 -8
0.1
                      TLV»-TWA/STEL

                      0.1.A2
0.2 mg/m3

1.5 mg/m3
25

0.2
0.2 mg/m3

LL
C-1
0.2 mg/m3

1.5 mg/m3
25

0.2
100/150
                      100
                             IDLH
                             LEVEL
                             10
5 mg/m3

Ca
Ca

300 ms/m3
                             N.A.

-------
                                                                                Exposure Limits1
CHEMICALS
Epichlorohydrin
EPN
Ethane
1,2-Ethanedithiol
Ethanol
Ethanolamine
2-Ethoxy-3,4-dihydro-1,
  2-pyran
2-Ethoxyethanol
  (Cellosolve solvent)
2 Ethoxyethyl acetate
  (Cellosolve acetate)
Ethyl acetate
Ethyl acrylate
Ethylamine
Ethyl benzene
Ethyl bromide
2-Ethylbutanol
Ethyl butyl ketone
Ethyl butyrate
Ethyl chloride
   (Chloroethane)
Ethyl disulfide
Ethylene
Ethylene bromide (see Ethylene
WARNING CONCENTRATIONS2
0.1 - 16 (100)
"inadequate"
150 - 899
0.0042
1 - 5100 (5041)
2 -4
0.10 -  0.60

0.55 -  50

0.056 - 50 (600, animals)

0.01 -  50 (200 - 400)
0.00024 - 1 (75)
0.01 -  1 (100, delayed)
0.1 -200 (200)
3.1 - 200 (6500)
0.07 - 0.77
0.1 - 10
0.0082 -0.015
4.2

0.0028
261 - 4010
dibromide)
PEL-TWA/STEL
2
0.5 me/m3
1000
3/6
200

100

400
5/10
10
100/125
200/250

50

1000
BEL
ME
LL
HWC
TLV-TWA/STEL
2
0.5 mg/m3
(a)
0.5
1000
3/6
                      50
1000
                                           (a)
IDLH
LEVEL
Ca
50 mg/m3
                                                   1000
                             NN
                                                  2500
400
5/25
10
100/125
200/250
10000
2000
4000
2000
3500
                             3000
20000

-------
                                                                                   Exposure Limits1
CHEMICALS
Ethyiene chloride (see Ethylene dichloride)
Ethylene chlorohydrin
Ethylene diamine
Ethylene dibromide
Ethylene dichloride

Ethylene glycol
Ethylene imine
Ethylene oxide

Ethyl ether
Ethyl formate
Ethyl fllycol
Ethyl hexanol
Ethyl hexanoate
Ethyl hexyl acetate
Ethyl hexyl acrylate
Ethylidene norbornene
Ethyl isothiocyanate
Ethyl mercaptan
Ethyl methacrylate
n-Ethylmorpholine
Ethyl pelargonate
"odorless", 0.4
1 - 11.2 (100)
10-25
6.2- 185

0.08 - 40
"inadequate" 1  - 100 +
0.1 - 700

0.1-9 (200)
18-33 (330)
25
0.075 -0.138
0.0056
0.073 - 0.21
0.18
0.007 - 0.073
1.6 - 10.7
0.00051 -0.075
0.0067
0.1 - 25, fatigue (40 - 100)
0.0014
PEL-TWA/STEL
C-1
10
20
C-30
P-50
1/2

C-50
LL
1

400/500
100
BiL


0.045
C-0.13

1
C-2

LL
0.1
C-5


TLV«-TWA/STEL
C-1
10
A2


10

C-50
0.5
1.A2

400/500
100
IDLH
LEVEL
10
2000
Cs


Ca


Ca
Ca

19000
8000
C-5

0.5
C-0.5
                       C-5
0.5
2500

2000

-------
N>
CHEMICALS
Ethyl phthalate
Ethyl selenide
Ethyl selenomercaptan
Ethyl silicate
Ethyl sulfide
Ethyl isovalerate
Ethyl decanoate
Ethyldichlorarsine
Ethyl n-valerate
Ethyl undecanoate
Eugenol
Fluoride dust
Fluorine
Fluorotrichloromethane
Formaldehyde

Formic acid
Fuel Oil #1
  (Kerosene, Jet Fuel)
Fuel Oil #2
  (Diesel Oil)
Fuel Oil #4
Fuel Oil #6 (Bunker-C)
Furfural
Furfuryl alcohol
                                      WARNING CONCENTRATIONS2  PEL-TWA/STEL
 "odorless"
 0.0003 -0.014 mg/m3
 0.0003
 17-85 (250)
 0.00060 - 0.068
 0.12
 0.00017
 0.14- 1.4
 0.060
 0.00054
 0.0046
 (5.0mg/m3)
 0.035 -3 (25- 100)
 5-100. "odorless"
 0.01 - 60 (0.25 - 2)

 0.024-340 (15)
 0.082 - 1

 0.082

 0.5
 0- 13
0.006 - 5 (12.2 - 50)
8
                                                                    0.2 mg/m3 (as Se)
                                                                    0.2 mg/m3 (as Se)
                                                                    100
                                                                    2.5 mg/m3
                                                                    0.1
                                                                    C-1000
                                                                    3
                                                                    C-10
                                                                    5
Exposure Limits1

Bli

0.2 mg/m3 (as Se)
0.2 mg/m3 (as Se)
2.5 mg/m3 (as F)
0.016
C-0.1
TLV-TWA/STEL

0.2 mg/m3 (as Se)
0.2 mg/m3 (as Se)
10
2.5 mg/m3
1/2
C-1000
1/2, A2
                                                                                                       IDLH
                                                                                                       LEVEL
                                                   1000
500 mg/m3
25
10000
Ca

100
                                                                    2
                                                                    10/15
50
2
10/15
250
250

-------
 CHEMICALS
 Fumaric acid (trans-
  Butenedioic)
 Gasoline
 Glutaraldehyde
 Glycol diacetate
 Halothane
 n-Heptal chloride
 Heptachlor
 Heptaldehyde
 n-Heptane

 Heptanol
 HETP (see TEPP)
 Hexachlorocyclopentadiene
 Hexachloroethane
 Hexamethlyenediamine
 n-Hexane

 Hexanoic acid
 Hexanol
Hexanone (see Methyl Butyl
            Ketone)
sec-Hexyl acetate
Hexylene  glycol
Hydrazine
WARNING CONCENTRATIONS2   PEL-TWA/STEL
"odorless"
0.005 -  10
0.04
0.077 -0.312
33
0.060
0.306 mg/m3
0.050
0.5 - 329

0.057 - 20

0.03 - 0.33
0.15
0.0009
65 - 248 (1400 - 1500)

0.0061
0.0050 - 0.09
0.1  - 100 (100)
50
3 -4
300/500
C-0.2
0.5 mg/rn3

400/500
0.1
1
WEEL - 5 mg/rn3
500/100
50
C-25
0.1
                      Exposure Limits1

                      Elk
85
C-440
LL

100
C-510
TLV«-TWA/STEL


300/500
C-0.2

50

0.5 mg/m3

400/500
                                                  IDLH
                                                  LEVEL
0.01
10

50
C-0.03
50
C-25
0.1,A2
100 mg/m3

5000
Ca
5000
                                                 400
Ca

-------
 CHEMICALS
 Hydrocinnamyl alcohol
 Hydrogen bromide
 Hydrogen chloride
 Hydrogen cyanide
 Hydrogen fluoride

 Hydrogen peroxide
 Hydrogen selenide
 Hydrogen sulfide

 2-Hydroxpropyl acrylate
 Indene
 Iodine

 lodoform
lonone
Isoamyl acetate
Isoamyl alcohol
Isoamyl mercaptan
Isobutyl acetate
Isobutyl alcohol
Isobutyl acrylate
Isobutyl cellosolve
Isobutyl mercaptan
Isobutyraldehyde
WARNING CONCENTRATIONS2  PEL-TWA/STEL
0.00027
2 (3 - 6)                      C-3
1 -  10 (35)                    C-5
0.00027 - 5, fatigue            -74.7
0.04-0.163                   3/6

"odorless" (100)               1
0.0005 - 3.6, fades fast (1.5)    0.05
0.00001 - 1.4 (50 - 100)        10/15
(fatigue at high concentration)
0.05                          0.5
0.02                          10
1.73 (1.63 - disappears within    C-0.1
    2 minutes)
0.0004 - 0.5                   0.6
5.9 x 10'8 - 73
0.001 - 1                      100
0.01 -35 (100 - 150)           100/125
0.0043  - 0.7
0.002-7 «150)               150
0.0009  - 74 (99)               50
0.009 -0.012
0.114 -0.191
0.00054 - 0.00097
0.047 - 0.336
Exposure Limits1

BIL
C-4.7
3
C-6
C-10
TLV«-TWA/STEL
C-3
C-5
C-10
C-3
1
0.05
10/15
0.5
10
C-0.1
IDLH
LEVEL
50
100
50
30
75
2
300


10
                     0.6

                     100
                     100/125

                     150/187
                     50
3000
8000

7500
8000

-------
Ul
          CHEMICALS
          Isobutyric acid
          Isocyanochloride
          Isodecanol
          Isopentanoic acid
                            WARNING CONCENTRATIONS2  PEL-TWA/STEL
                            0.001
                            0.98
                            0.31 - 0.042
                            0.005 - 0.026
          Isopentyl acetate (see Isoamyl acetate)
Isophorone
Isoprene (2-
  Methylbutadiene)
Isopropanolamine
  dodecylbenzene sulfate
tsopropyl acetate
Isopropyl alcohol

Isopropylamine
Isopropyl ether
Isopropyl glycidyl ether
Isopropyl Mercaptan
Kerosene
Ketene
Kuwait-Crude
Lactic acid
Laurie acid
Lauryl mercaptan
Light Gasoline
0.18 -8.85 (8.85)
0.005

0.3

0.5 • 400 (200)
7.5-300 (400)

0.1 - 10 (10-20)
0.02 - 300 (800)
300
0.00025
0.082 - 1
(23)
0.1 -0.5
4 x 10'7
0.0034
4 mg/m3
800
                                                                    4
                                                                    WEEL - 50
                                                                    250/310
                                                                    400/500

                                                                    5/10
                                                                    500
                                                                    50/75
                                                                    0.5/1.5
                                                    Exposure Limits1

                                                    BEL
                                                                                                               TLVQ-TWA/STEL
                             IDLH
                             LEVEL
C-5
0.5/1.5
                                                                                                                                            800

400
C-800


C-50
100 mg/m3
250/310
400/500

5/10
250/310
50/75

16000
12000

4000
10000
1500

50
                                                                                                               300/500

-------
                                                                                        Exposure Limits1
o\
CHEMICALS
Lindane

Linoieyl acetate
Lithium hydride
LPG
Magnesium dodecyl sulfate
Malathion

Maleic anhydride
Menthol
2-Mercaptoethanol
Mercury, Inorganic
  (except Mercury pernitrate)
Mercury, vapor
WARNING CONCENTRATIONS2
"practically odorless"
3.9 mg/m3 - 21.3 mg/m3
0.0016
(0.1 mg/m3)
20,000 (propane)
0.2
10-13.5 mg/m3

0.1 -0.5 (0.25 - 1.83)
1.5
0.12 -0.64
"odorless"
                                     "odorless"
          Mesitylene (see Trimethybenzene)
          Mesityl oxide
          Methoxynaphthalene
          3-Methoxypropylamine
          Methyl acetate
          Methyl acetylene-
           Propadiene Mixture
          Methyl acrylate
          Methylacrylonitrile
          Methyl alcohol
                           0.017-25
                           0.00012
                           0.2 - 42
                           0.2-300 (10,000)
                           100

                           0.0005 - 20 (75)
                           2-14 (fatigue)
                           10 - 20482 (7500-69000)
                                                                  PEL-TWA/STEL         REL
                                                                  0.5 mg/m3
                                                                  0.025 mg/m3
                                                                  1000

                                                                  10 mg/m3 (Total dust) 15 mg/m3
                                                                  5 mg/m3  (Respirable fraction)
                                                                  0.25
                                                                  C-0.1 mg/m3 (as Hg)   0.05 mg/m3 (as Hg)
                             0.05 mg/m3
                             15/25

                             WEEL-10
                             200/250
                             1000/1250

                             10
                             1
                             200/250
                             C-800
10
200
TLV*-TWA/STEL
0.5 mg/m3


0.025 mg/m3
1000

10 mg/m3

0.25


0.1  mg/m3

0.05 mg/m3

15/25
200/250
1000/1250

10
1
200/250
                                                  IDLH
                                                  LEVEL
                                                  1000 mg/m3
55 mg/m3
19000

5000 mg/m3

500


28 mg/m3

28 mg/m3

5000


10000
20000

1000

25000

-------
CHEMICALS
Methylamine
Methyl amyl acetate
Methyl amyl alcohol
  (Methyl isobutyl carbinol)
n-Methylaniline
Methyl anthranilate
Methyl bromide
2-Methyl-2-butanol
  (tert-Amyl alcohol)
Methyl n-butyl  ketone
Methyl n-butyrate
Methyl cellosolve
Methyl cellosolve acetate
Methyl chloride

Methyl chloroform
Methyl 2-cyanoacrylate
Methylcyclohexane
Methylcyclohexanol
Methyl dichloroarsine
Methyl bisphenyl
  isocyanate (MDI)
Methylene choride
  (Dichloromethane)
WARNING CONCENTRATIONS2   PEL-TWA/STEL
                      Exposure Limits1

                      BEL
0.001 - 10, fatigue (20 - 100)
0.002 - 1048 (1048)
0.01- 50 (24 - 50)

1.6-2
0.00066 - 0.06
20.6 -  1030
0.23 - 2.3

0.07 - 0.09
0.0026
0.0925 -92.5 (118)
0.64 - 50
10- 250, "no odor"
(500 -  1000)
20-714 (500-  1000)
1 -3
500 - 630
500 (500)
0.11
0.39 {0.05 -0.1)

"can adapt to odor"
25 - 227 (5000)
10
25/40
0.5
                      LL
TLV»-TWA/STEL
10

25/40

0.5
IDLH
LEVEL
100
2000
100
                             Ca
                                                                        5000
25 LL
25
50/100 LL
350/450
2/4
400
50
C - 0.02 0.005
C-0.02
500 LL
C-1000
P-2000
5
5
50/100
350/450
2/4
400
50
0.005

50/175, A2


NN
4000
Ca
1000

10000
10000
10

Ca



-------
t-f\
00
CHEMICALS
Methyl ethanol amine
Methyl ethyl ketone (MEK)
Methylethyl pyridine
Methyl formate
Methyl glycol (1,2-
  propylene glycol)
5-Methyl-3-heptanone
  (Ethyl amyl ketone)
Methyl hydrazine
Methyl iodide
Methyl isoamyl alcohol
Methyl isoamyl ketone
Methyl isobutyl ketone
Methyl isocyanate
Methyl isopropyl ketone
Methyl mercaptan
Methyl methacrylate
2-Methylpentaldehyde
2-Methyl-1-pentanol
2-Methylpropene
  (Isobutylene)
Methyl salicylate
a-Methyl styrene
                                      WARNING CONCENTRATIONS2   PEL-TWA/STEL
                                      3.4
                                      0.25 - 85 (200)                 C - 0.7
                                      0.006 - 19
                                      204 - 3000, fatigue (3563)       100/150
                                      60-90

                                      6 (50)                         25
1 -3
(4300)
0.20
0.01 -0.28
0.01 -47 (100)
2.0 (2)
0.1 -4.8
0.0001 - 1.1
0.01 - 1 (170 - 250)
0.09 -0.136
0.024 - 0.082
0.57 - 20
                                      0.1 -0.14
                                      0.1 - 200 (200)                 50/100
                                                    Exposure Limits1

                                                    BEL

                                                    200
TLV-TWA/STEL
200/300
                                                                          100/150
                                                                         25
                                                                         50/100
IDLH
LEVEL
3000
                             5000
                             3000
C-0.2
2
50
50/175
0.02
200
0.5
100
C-0.04
LL
100
50


0.5

C-0.2.A2
2,A2
50
50/75
0.02
200
0.5
100
Ca
Ca

3000
20

400
4000
                            5000
          Methyl sulfide (see Dimethyl  Sulfide)
          Methyl thiocyanate            0.25 - 3.2

-------
<-f\
CHEMICALS
Methyltrichlorosilane
Methyl vinyl ketone
Methylvinyl pyridine
Mineral spirits
Morpholine
Musk (Synthetic)
Naptha - coal tar
Naptha - petroleum
  (rubber solvent)
Naphthalene
2-Napthol
Nickel carbonyl
Nitric acid
Nitric oxide
p-Nitroaniline
Nitrobenzene
o-Nitrochlorobenzene
Nitroethane
Nitrogen dioxide
Nitrogen tetroxide
Nitrogen trifluoride

Nitromethane
1-Nitropropane
2-Nitropropane
                                      WARNING CONCENTRATIONS2  PEL-TWA/STEL
                                      1
                                      0.2
                                      0.040
                                      30
                                      0.01 -0.14
                                      4.0 x 10'7
                                      4.68 - 100 (200 - 300)
                                      <500
                                                     Exposure Limits1

                                                     Elk
0.001 -0.8 (15)
1.3
1 -3
0.3 - 1.0 (62)
"odorless", 0.3-1, "poor"
"odorless"
0.001 - 6
0.002
2.1 - 200 (100 - 500)
0.1 - 5.3 (5 -20)
5
"no odor-warning properties
at potentially dangerous levels*
3.5 - 100 (200- 500)
11-300 (99- 150)
48 - 300
20/30

100


10/15
                                                                    10

                                                                    100
                                                                    25
                                                                    10
                                            TLV'-TWA/STEL
                                                                          20/30
                                                                                                                10/15
                      LL
10

100
25
C-10.A2
                             IDLH
                             LEVEL
                             8000

                             10000


                             500
0.001 0.001
2/4 2
25
3 mo/m3
1
100
-/1 C-1
0.05 (as Ni)
2/4
25
3 mfl/m3
1
100
3/5
Ca
100
100
300 mfl/m3
200
10000
50
2000

1000
2300
Ca

-------
CHEMICALS
Nitrotoluene (m,o,p isomers)
Nitrous oxide
Nonane
n-Octane

Octanoic Acid
1-Octanol
2-Octanol
Oenanthic acid
  (Heptanoic acid)
Oxygen  difluoride
Ozone
Parathion
Pelargonic acid
  (Nonyl Alcohol)
Pentaborane
Pentachlorophenol
n-Pentane
WARNING CONCENTRATIONS2   PEL-TWA/STEL
0.05-1.74                    2
"poor"
0.1 -47                       200
0.5 - 235                      300/375
0.0014
0.0021 - 0.31
0.0026
0.015

0.1 -0.5, (fatigue)
0.0005 - 0.5 (1 - 3.7)
0.48 mg/m3
0.00086

0.8 (1)
9.3 mg/m3 (0.3 -  10.9 mg/m3)
2.2 - 1100
2,4-Pentanedione             0.01 - 0.024
2-Pentanone                 3 - 14
  (Methyl propyl ketone)
Pentanol (see amyl alcohol)
Pentene (n-Amylene)          2.2
n-Pentyl acetate (see n-Amyl acetate)
WEEL - 50
                              200
                      Exposure Limits1

                      BEL

                      25

                      75
                      C-385
                      150
TLV«-TWA/STEL
2

200
300/375
200/250
IDLH
LEVEL
200
5000
C-0.05
0.1/0.3
0.1 mg.m3
0.005/0.015
0.5 mg/m3
600/750

C-0.5

0.05 mg/m3


120
C-610
C-0.05
0.1/0.3
0.1 mg/m3
0.005/0.015
0.5 mg/m3
600/750

0.5
10
20 mg/m3
3
1 50 mg/m3
15000

5000

-------
CHEMICALS
1-Pentyl mercaptan
Perchloroethylene
  (see Tetrachloroethylene)
Perchloromethyl mercaptan 0.001
WARNING CONCENTRATIONS2   PEL-TWA/STEL
0.00021
                      Exposure Limits1

                      Elk
Perchloryl fluoride
Pero-Klean-No-818
Petroleum distillates
  (Petroleum naptha)
Phenol

Phenyl ether
Phenyl ether-biphenyl
  mixture
Phenyl isocyanide
Phenyl isothiocyanate
Phosgene

Phosphine
Phosphorous pentasulfide
Phosphorous trichloride
Phthalic anhydride
2-Picoline
Propane
Propionaldehyde
Propionic acid
10 (but not reliable)
0.005
<500

0.005 - 5 (48)

0.001 -0.10  (3 • 4)
0.1-1 (3-4)

0.029 mfl/m3
0.43
0.125-6 (dulls senses) (1-2)

0.01 - 5 (7.7)
"fatigue", 0.0047 (as H2S)
0.7 (2 - 4)
0.05 -0.12 (30mg/m3)
0.023 - 0.046
1000- 20,000
0.04 - 1
0.001 - 20
0.1
3/6

400
0.1

0.3/1
1 mg/m3
0.2/0.5
1
WEEL - 2/5
1000

10
                      5.2
                      C-15.6
0.1
C-0.2
                                                                                                       TLVP-TWA/STEL
                      0.1
                      3/6
                                            1/2
0.1

0.3/1
1/3 mg/m3
0.2/0.5
1

(a)

10/15
                                                   IDLH
                                                   LEVEL
                             10
                             385

                             10000

                             250

                             N.A.
                             N.A.
                                                   200
                                                   750 mg/m3
                                                   50
                                                   16700

                                                   20000

-------
                                                                                          Exposure Limits1
O-x
CHEMICALS
n-Propyl acetate
Propyl alcohol
Propylene
Propylene diamine
Propylene dichloride
Propylene glycol

Propylene glycol dinitrate
Propylene glycol
 monomethyl ether
Propylene oxide
Propyl mercaptan
n-Propyl nitrate
Propyl sulfide
Pyridine

Pyrolgallo
  (1,2,3-trihydroxybenzene)
Quinoline
Quinone

Resorcinol
 (1,3-dlhydroxylbenzene)
Rotenone
Safrole
                                      WARNING CONCENTRATIONS2   PEL-TWA/STEL
                      BEL
                                      0.05 - 200
                                      0.01 - 200 (5500)
                                      23 - 67.6
                                      0.014 -0.067
                                      0.25 - 130
                                      "odorless"

                                      0.24
                                      10
                                      20
                                      0.16 - 71
                                      0.08 - 0.5, fatigue
                                      (0.1 - 0.5)
                                      40

                                      "odorless", 222 mg/m3
                                      0.0032
200/250
200/250
75/110
WEEL - 500 ppm. Total;
10 mg/m3 Aerosol only
0.05
100/150
                                      10 - 210 (457 - 473, animals)    100
                                      0.00075 - 0.02
                                      50 - 90                        25/40
                                      0.011 -0.17
                                      0.001 - 5                      5
                                      (fatigue at 5, but taste remains)
WEEL -0.1
0.1

10/20

5 mg/m3
TLV-TWA/STEL
200/250
200/250
(a)

75/110
100/150

20

25/40
0.1

10/20

5 mg/m3
 IDLH
 LEVEL
 8000
 4000
2000
                             0.05
                                                                        2000
                                                                        2000
                                                                        3600
75
5000 mg/m3

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                                                                                          Exposure Limits1
LO
CHEMICALS
Selenium oxide
Silver Cyanide

Silver Nitrate
Skatole (3-Methyl indole)
Sodium butyldiphenol
  sulfonate
Sodium butylphenylphenol
  sulfonate
Sodium dodecylbenzene
  sulfonate
Sodium hydroxide
Sodium nitrochlorobenzene
  suifonate
Sodium octyl  sulfate
Sodium sulfate
Sorbitol
Stoddard solvent
Strychnine
Styrene

Styrene oxide
Sulfoxide
Sulfur dichloride (SC12)
Sulfur dioxide
                                      WARNING CONCENTRATIONS2   PEL-TWA/STEL
                                                     REL
0.0002 mg/m3
"odorless"

"odorless"
7.5 x 10'8- 1.68

0.5 (as alky aryl sulfonate)

0.5 (as alky aryl sulfonate)

0.5 (as alky aryl sulfonate)
"odorless"

0.5 (as alky aryl sulfonate)
0.2
"odorless"
"odorless"
1 - 30  (400)
"odorless"
0.001  - 200 (200 - 400)

0.40
91
0.001
0.3 - 5 (6 - 20)
                                                                    0.2 mg/m3 (as Se)
                                                                    0.01 mg/m3 (as Ag)

                                                                    0.01 mg/m3 (as Ag)
                                                                    C-2 mg/m3
                                                                    100
                                                                    0.15 mg/m3
                                                                    50/100
C-2 mg/m3
350 mg/m3

50
C-100
                      TLV«-TWA/STEL
                      0.2 mg/m3 (as Se)
                      0.01 mg/m3 (as Ag)

                      0.01 mg/m3 (as Ag)
C-2 mg/m3
100
0.15 mg/m3
50/100
                             IDLH
                             LEVEL
                             100 mg/m3
                             50 mg/m3
                             (CN)
                             N.A.
250 mg/m3
5000
3 mg/m3
5000

-------
                                                                                            Exposure Limits1
a\
CHEMICALS

SuHuric Acid
Sulfur monochloride (Sulfur
  chloride, S2C12)
Sulfuryl fluoride
Tannic acid
TEPP (HETP, Bladex,
  Vapotone)
Terphenyls
1,1,2,2-Tetrachloroethane
Tetrachlorethylene
  (Perchloroethylene)
WARNING CONCENTRATIONS2
0.3-taste
0.6 - 2.4 mg/m3
0.001 (2 - 9)
"odorless"
2-4
"odorless"
> 1
0.2-8
2-50 (106 - 690)
PEL-TWA/STEL REL
2/5 0.5
1 rng/m3 1 mg/m3
C-1
5/10

0.05 mg/m3
C-0.5
1 LL
25 ME
TLV-TWA/STEL
2/5
1 mg/m3
C-1
5/10

0.004 mg/m3
C-0.5
1
50/200
IDLH
LEVEL
100
80 mg/m3
10
1000

10 mg/m3
3500 mg/m3
Ca
Ca
          Tetraethyl-o-silicate
          Tetrahydrofuran
          Tetramethylbenzene
          Tetranitromethane
          Thiocresol (Toluenethiol)
          Thiophenol (Phenyl
            mercaptan)
          Thymol
          Toluene

          Toluene  diisocyanate (TDI)
                             5.0- 7.2
                             0.1 - 60                       200/250
                             0.0029
                             (0.40)                         1
                             0.0027 - 0.02
                             0.0001 - 85                    0.5

                             0.00086
                             0.02  - 70, fatigue (300 - 400)    100/150

                             0.2 - 2.14                      0.005/0.02
100
C-200
0.005
C-0.02
                      200/250
                      0.5
100/150
0.005/0.02
                              20000
2000
C-200
10

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                                                                                             Exposure Limits1
ON
'•St
CHEMICALS
Toxaphene (Phenatox)
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
o-Tolidine
1,1,1 -Trichloroethane
  {Methyl chloroform)
Trichloroethylene
Trichlorofluoromethane
Trichlorophenol
1,2,3-Trichloropropane
1,1,2-trichloro-1,2,2-
  trifluoroethane
Triethanolamine
  dodecylbenzene sulfonate
Triethylamine
Triethylene fllycol
Trimethylamine

Trirnethylbenzene
  (Mesitylene)
TrimetL.y[  phosphite
Trinitrobutyixylene
Triphenyl phosphate
Turpentine
n-Undecane
WARNING CONCENTRATIONS2
2.4 mg/rn3
1.4-3
0.5 - 167
0.0048 - 20
20 - 400 (500 - 1000)
0.2-400 (160)
5-209
0.1 - 0.667
100 (100)
0.5 • 200
PEL-TWA/STEL REL
0.5/1 mo/m3
C-5
10 LL
5 C-0.02 mo/m3
350/450 C-350
50/200 25
C-1000

10
1000/1250
TLV«-TWA/STEL
0.5/1 mg/m3
C-5
10
2,A2
350/450
50/200
C-1000

10
1000/1250
IDLH
LEVEL
200 mg/m3

Ca
100
1000
Ca


1000
4500
                                       0.3

                                       0.009 - 2.8 (50)
                                       "practically odorless"
                                       0.0001 - 1.7

                                       0.006 - 2.4

                                       0.001
                                       6.5 x 10'6-0.0008
                                       "odorless"
                                       50- 200 (100-200)
                                       0.12
10/1B

10/15
WEEL - 1
25
10/15

10/15

25
100
3 mg
100
1000
N.A.
1900

-------
ON
CHEMICALS
n-Valeraldehyde
Valeric acid
isoValeric acid
Vandium pentoxide - Dust
                 Fume
Vanillin
Vinyl acetate
Vinyl chloride
Vinyl toluene
Warfarin
Xylene
m-Xylene
o-Xylene
p-Xylene
Xylidine
Vinylidene chloride
 (1,1 -Dichloroethylene J
V M & P Naptha
WARNING CONCENTRATIONS2
0.001 -8.2
0.00060
0.0018
(0.5 - 2.2 mg/m3)
0.05 mg/m3
3.2 x 10'8
0.1 - 1
260 - 3000
10-50(50)
"odorless"
0.05 - 200, fatigue (100 - 200)
0.08 - 40
0.08 - 40
0.08 - 40
0.0048 - 0.06
190

10
                                                                   PEL-TWA/STEL
                                                                   50
                                                                   0.05 mg/m3
                                                                   0.1  mg/m3 (as Va)
Exposure Limits1

BEL
C-0.05 mg/m3
0.05 mg/m3
TLV»-TWA/STEL
50


0.05 mg/m3
10/20
1
100
0.1 mg/m3
100/150
100/150
100/150
100/150
2
1
C-4
LD


100. C-200
100. C-200
100. C-200
100, C-200


10/20
5.A1
50/100
0.1 mg/m3
100/150
100/150
100/150
100/150
2
5/20
IDLH
LEVEL
70 mg/m3
                                                  Ca
                                                  5000
                                                  200 mg/m3
                                                  1000
                                                  1000
                                                  1000
                                                  1000
                                                  150
                                                                   300/400
                     300

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1 The exposure limits are 8 hour Time Weighted Averages (TWA) unless otherwise noted.
2 Fatigue = Indicates that the chemical can cause olfactory fatigue.
(a)     =  Simple asphyxiant.  Check oxygen concentration.
A1     =  Confirmed Human Carinogen (ACGIH)
A2     =  Suspected Human Carcinogen (ACGIH) animal = irritation concentration based on animal studies
C      =  Ceiling Limit. Ceiling limits for REL may be limited to 10 minutes, 15 minutes or not to be exceeded for
       any time.  Check individual value.
Ca     =  NIOSH has recommended that the substance be treated as a potential human carcinogen; IDLH's are not
       listed for those substances.
HWC  =  "To be handled in the workplace with caution" (NIOSH)
IDLH   =  Immediately Dangerous to Life or Health, NIOSH Pocket Guide to Chemical Hazards. Sept. 1985.
LD     =  "Reduce exposure to lowest reliably detectable level" (NIOSH)
LL     =  "Reduce exposure to lowest feasible level" (NIOSH)
ME    =  "Minimize occupational exposure" (NIOSH)
N.A.   =  NIOSH has not assigned an IDLH
NN    =  Not applicable because of NIOSH REL
NE     =  "No exposure limit recommended due to absence of a reliable monitoring method" (NIOSH)
P      =  "Acceptable maximum peak above the acceptable ceiling concentration for an 8-hour shift." Each has a
       specific time limit.
PEL    =  Permissible Exposure Limits, "29 CFR 1910 Subpart Z," Occupational Safety and  Health Administration
       (OSHA)
REL    =  Recommended Exposure Limits, NIOSH Recommendations for Occupational Safety  and Health Standards.
       1988, National  Institute for Occupational Safety and Health (NIOSH)
TLV    =  Threshold Limit Value, Threshold Limit Values and Biological Exposure Indices for for  1988-1989, American
       Conference  of Governmental Industrial Hygienists (ACGIH)
STEL   =  Short Term Exposure Limit
WEEL  =  American Industrial Hygiene Association Workplace  Environmental  Exposure Level Guides (1988).  This
       is  not a PEL but is placed in that column due to space limitations. The  first number is an 8 hour TWA. The
       second number is a short term TWA.  The time varies from 1-15 minutes. Check individual  values.
                                             67

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                                     SECTION 5

                   PERSONAL PROTECTIVE EQUIPMENT

                                        PART 3

                    SELF-CONTAINED BREATHING APPARATUS
I.      INTRODUCTION

       Respiratory apparatus must  frequently be used during response to hazardous materials
       incidents.   If  the  contaminant is unknown or  the requirements for using air-purifying
       respirators cannot be met, then an atmosphere supplying  respirator is required.  Several
       types of atmosphere supplying devices are available:

              Oxygen-generating

              One of the oldest respirators is the oxygen-generating respirator, which utilizes a
              canister of potassium superoxide. The chemical reacts with water vapor to produce
              oxygen which replenishes the wearer's exhaled breath. Exhaled CCXj is removed by
              a scrubber device containing LiOH.  This reoxygenated air is then returned to the
              wearer.  Oxygen-generating respirators have been used by the military and for escape
              purposes in mines.   It generally is  not  used  for  hazardous material applications
              because of the chemical reaction taking place within the respirator itself.

              Hose mask

              This type of respirator consists of a facepiece attached  to a large diameter hose
              which transports clean air from a remote area.  In  units where the wearer breathes
              the air  in, the hose lines can go up to 75 feet.  With powered units the hose length
              can vary  from 50 to 250 feet.

              Airline respirator

              The airline respirator is similar to the hose mask, except that breathing grade air is
              delivered to the wearer under pressure; either from a compressor  or a bank of
              compressed air cylinders.  The air may flow continuously, or it may be the wearer
              breathes (demands it). The air source must not be depletable, and no more than 300
              feet of airline is  allowed.   An escape device  is required for entry into an IDLH
              atmosphere.

              Self-contained breathing apparatus

              The self-contained breathing apparatus (SCBA) consists of a facepiece and regulator
              mechanism connected to  a cylinder of compressed air or oxygen  carried by  the
              wearer.
6/91                                        69

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       The self-contained breathing apparatus (SCBA) is generally used because it allows the wearer
       to work without being confined by a hose or airline. The wearer of the SCBA depends on
       it to supply clean breathing air.

       If the wearer is not properly trained to  wear the SCBA or it is not properly cared  for,
       then it may fail to provide the protection  expected.

       The user should be completely familiar with the SCBA being worn. Checkout  procedures
       have been  developed  for inspecting an SCBA prior to use, allowing the user to recognize
       potential problems.   An individual who checks out the unit is more comfortable and
       confident wearing it.

       There are two types of apparatus: closed-circuit, which use compressed oxygen, and open-
       circuit, which use compressed air.  SCBA's may operate  in one of two modes,  demand or
       pressure-demand (positive-pressure). The length of time an SCBA operates is based on the
       air supply.  The units available operate from 5 minutes to over 4 hours.

       Pressure Demand (positive pressure) is the only approved type of open circuit SCBA for use
       in Hazardous Environments by the US EPA and NFPA.

       Both open-  and  closed-circuit SCBA's  will be  discussed  and  the modes  of operation
       explained.   The bulk of the  discussion deals with open  circuit pressure-demand SCBA's
       which are most widely used because they offer more protection.
II.     MODES OF OPERATION

       A.     Demand

              In the  demand mode,  a negative  pressure  is created  inside  the  facepiece and
              breathing tubes when the wearer inhales (TABLE 6). This negative pressure draws
              down a diaphragm in the regulator in an SCBA. The diaphragm depresses and opens
              the admission valve,  allowing air to be inhaled.   As long as the negative pressure
              remains, air flows to the facepiece.

              The problem with demand operation is that the wearer can inhale contaminated air
              through any gaps  in the facepiece-to-face sealing  surface.    Hence, a demand
              apparatus with a full facepiece is assigned a Protection Factor of only 100, the same
              as for a full face air-purifying respirator.

       B.     Pressure-Demand

              An SCBA operating  in the pressure-demand  mode maintains a positive pressure
              inside the facepiece at all times.  The system is designed so that the admission valve
              remains open until enough pressure is built up to close it.  The pressure builds up
              because air is  prevented from leaving the  system until the wearer exhales.  Less
              pressure is required to close the admission valve than is required to open the spring-
              loaded  exhalation valve.
6/91                                        70

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              At all times,  the pressure in the facepiece  is greater  than the ambient pressure
              outside the facepiece (TABLE 6).  If any leakage occurs, it is outward from the
              facepiece.  Because of this, the pressure-demand (positive pressure) SCBA has been
              assigned a Protection Factor of 10,000.
TABLE 6
PRESSURE INSIDE FACEPIECE OF SCBA RELATIVE TO
AMBIENT PRESSURE OUTSIDE

Inhalation
Exhalation
Static (between breaths)
Demand
-
+
same
Pressure Demand
(positive pressure)
+
+
+
III.    TYPES OF APPARATUS

       A.     Closed-Circuit

              The  closed-circuit SCBA (FIGURE 4), commonly called  the  rebreather,  was
              developed especially for  oxygen-deficient situations.  Because it recycles  exhaled
              breath and carries only a  small oxygen supply, the service time can be considerably
              greater than an open-circuit device, which must carry all of the user's breathing air.

              The  air for breathing is  mixed in a flexible breathing bag.  This air is  inhaled,
              deflating the breathing bag.  The deflation depresses the admission valve, allowing
              the oxygen to enter the bag. There it mixes with exhaled breath, from which carbon
              dioxide has just been removed by passage through a CC^ scrubber.

              Most rebreathers operate  in the demand mode.  Several rebreathers are designed to
              provide a positive pressure in the facepiece.  The approval schedule 13F under  30
              CFR Part II for closed-circuit SCBA makes no provisions for testing "demand"  or
              "pressure-demand" rebreathers.  The approval schedule was set up to certify  only
              rebreathers that happen to operate in the demand mode.  Thus, rebreathers designed
              to operate in  the positive pressure mode  can be approved strictly as closed-circuit
              apparatus.  Since regulations make no distinction, and selection is based on approval
              criteria, rebreathers designed to maintain a positive pressure can only be considered
              as a  demand-type apparatus.  Rebreathers use either compressed oxygen or liquid
              oxygen.  To assure the quality of the air to be breathed, the oxygen must be at  least
              medical grade breathing  oxygen which  meets the requirements  set by  the "U.S.
              Pharmacopeia".
6/91
                                            71

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      B.
Open-Circuit
             The open-circuit SCBA requires a supply of compressed breathing air.  The  user
             simply inhales and exhales. The exhaled air is exhausted from the system.  Because
             the air is not recycled, the wearer must carry the full air supply, which limits a unit
             to the amount of air that the wearer can easily carry.  Available SCBA's can last
             from 5  to 60 minutes.  Units which have 5-to-15  minute air supplies  are  only
             applicable to escape situations.

             The air used in open-circuit apparatus must meet the requirements in the Compressed
             Gas Association's Pamphlet G-7.1, which calls for at least "Grade D". Grade D air
             must contain 19.5 to 23.5% oxygen with the balance being predominantly nitrogen.
             Condensed hydrocarbons are limited to  5 mg/m3, carbon monoxide to 20 parts per
             million  (ppm) and  carbon dioxide to  1,000 ppm.   An undesirable odor is  also
             prohibited. Air quality can be checked using an  oxygen meter, carbon monoxide
             meter and detector tubes.
                                                         Head Harness

                                                           Faceplcce
                          Exhalation

                           Salrva Trap
                           and Pressure
                           Relief Valve
                                           Check Valve

                                           \T •C7^T\ Inhalation Tube
                                                                     Breathing Bag
                            Main Valve
                           Granular Solid Adsorbent lor Carbon Dioxide
                           Compressed.—
                           Oxygen Tank
                                                        Admission Valve

                                                  t — U A .Pressure Plate
                                          Bypass Valve
                                                   Bypass Lint
                                              FIGURE 4
                                      CLOSED-CIRCUIT SCBA
6/91
                                                   72

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IV.    COMPONENTS OF A TYPICAL OPEN-CIRCUIT PRESSURE DEMAND SCBA

       A.     Cylinder

              Compressed  air   is  considered a  hazardous  material.   For  this reason,  any
              cylinder used with a SCBA must meet the Department of Transportation's (DOT)
              "General Requirements  for  Shipments  and Packaging"  (49 CFR Part 173)  and
              "Shipping Container Specifications" (49 CFR Part 178).

              A hydrostatic test must be performed on a cylinder at regular intervals:  for steel &
              aluminum cylinders, every 5 years; for composite cylinders (glass  fiber/aluminum),
              every 3 years.  Composite cylinders are relatively new,  designed with fiberglass.
              Composite cylinders have a DOT exemption because there are no set construction
              requirements at this time.   Overall  difference is  in  weight.   The construction
              technology reduces the weight of the cylinder and thereby the overall weight of the
              SCBA.

              Air volume of 45 cubic feet of Grade D air at a pressure of 2,216 pounds per square
              inch (psi) is needed for a 30-minute supply. Cylinders are filled using a compressor
              or a cascade system of several large cylinders of breathing  air.  If the cylinder is
              overfilled,  a rupture disc  releases the pressure.  The rupture disc is  located at the
              cylinder valve, along with a cylinder pressure gauge to be accurate within _+ 5%.
              Because the gauge is exposed  and subject to  abuse, it  should  be used only for
              judging if the cylinder is full, and not for monitoring air  supply to the wearer.

       B.     High-Pressure Hose

              The high-pressure hose connects the cylinder and the regulator. The hose should be
              connected to the cylinder only by hand, never with a wrench. An O-ring inside the
              connector assures a good seal.

       C.     Alarm

              A low-pressure warning alarm is located near the connection to the cylinder.  This
              alarm sounds to alert the wearer that only 20-25% of the full cylinder air supply is
              available for retreat, usually 5 to 8 minutes.

       D.     Regulator Assembly

              Air  travels from  the  cylinder  through  the  high-pressure  hose  to  the  regulator
              (FIGURE 5).  There it can travel one of two paths.  If the by-pass valve is opened,
              air  travels directly through the breathing hose  into  the facepiece. If the mainline
              valve  is  opened, air  passes through  the regulator  and  is  controlled  by  that
              mechanism.  Also at the regulator (before air enters one of the valves) is another
              pressure gauge which also must be accurate to _+ 5%. Because it is visible  and well
              protected, this gauge should be used to monitor the  air supply.
6/91                                         73

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             Under normal conditions, the bypass valve is closed and the mainline valve opened
             so air can center the regular. Once in the regulator, the air pressure is reduced from
             the  actual  cylinder pressure to approximately 50-100 psi by reducing mechanism.
             A pressure relief valve is located after the pressure reducer for safety should the
             pressure reducer malfunction. The airflow rate to meet NIOSH standards must meet
             or exceed 40 liters/minute.  NFPA 1981 states the airflow rate must meet or exceed
             100 liters/minute.
6/91                                        74

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-J
                                                                                                       BY.PASS VALVE

                                                                                                             PRESSURE
                                                                                                          / GAUGE
                                                                                                             HIGH PRESSURE
     PRESSURE
RELIEF VALVE
                     VA(,Vt
                                                         REGULATOR COVER
                                                                                SPRING
     LOW PRESSURE
     RELIEF VALVE     CYLIHOER

   \ ADMISSION
     VALVE
                                                               FIGURE 5

                                       MSA PRESSURE DEMAND TYPE REGULATOR AIR FLOW
  Selected from MSA Product Literature,  by Mine Safety Appliances Co.,  Copyrighted by Mine  Safety Appliances Co, reprinted with permission of
  Publisher.
         6/91

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      E.     Breathing Hose and Facepiece

             The breathing hose connects the regulator to the facepiece. Rubber gaskets at both
             ends provide  tight seals.   The  hose is usually constructed  of neoprene and  is
             corrugated to allow stretching.

             Above tht point in the mask where the hose is connected, is a one way check valve.
             This valve allows air  to be  drawn  from  the hose when  the wearer inhales but
             prevents exhaled air from entering the breathing hose. If the check valve  is not in
             place, the exhaled  air may not be  completely exhausted from the facepieces.

             The facepiece is normally constructed of neoprene, but sometimes of silicone rubber.
             Five- or six-point  suspension is used to hold the mask to the face.  The visor lens
             is made of polycarbonate or other  clear,  shatter  proof, and  chemically  resistant
             material. At the bottom of the facepiece is an exhalation value.

             Some   masks  include  an  air-tight  speaking   diaphragm,   which  facilitates
             communications while preventing contaminated air from entering.

      F.     Back Pack and Harness

             A back pack and  harness support the cylinder and regulator,  allowing the user  to
             move freely.   Weight should be supported  on the hips not the shoulders.
       INSPECTION AND CHECKOUT

       The  SCBA  must  be  inspected   according  to  manufacturers  as  well  as  29  CFR
       recommendations.  In addition, the  SCBA should be checked out immediately prior to use.
       Checkout and inspection procedures should be followed closely to assure safe operation of
       the unit.
VI.    IMPORTANT INFORMATION ON CYLINDER

       A cylinder on a SCBA typically carries the following information (FIGURE 6).

       1.      DOT exemption for composite cylinder

       2.      DOT rated pressure and air volume

       3.      Cylinder number

       4.      Manufacturer's name, symbol and part number

       5.      Original hydrostatic test date, month/year
6/91                                        76

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                 D dT!T~Er 72773^2216
                                    ^^MW^ao;,

               ^CONTENTS:! AIR; .45JSCF. AT 2216 PS1G
                             AFETY- APPLIANCES"cb^r.:
                                     : NO;^460320 :;aCfe^ :
                                     FIGURE 6

                     INFORMATION ON TYPICAL SCBA CYLINDER


VII.  NFPA 1981 "OPEN CIRCUIT SELF-CONTAINED BREATHING APPARATUS FOR
     FIRE FIGHTERS" 1987 Edition

     The National Fire Protection (NFPA) has developed a standard for performance requirements
     and appropriate testing procedures designed to simulate various environmental conditions that
     fire fighter's SCBA can be exposed to during use and storage. These requirements are in
     addition to the basic NIOSH/MSHA certification requirements. This Standard, NFPA 1981,
     now applies only to open circuit SCBA.

     A.    Basic Design Requirements

           The basic design requirements for SCBA units under 1981 are:

           1.     That the units be NIOSH/MSMA certified positive-pressure.

           2.     The maximum weight shall not exceed 35 pounds, in accordance with
                      NIOSH/MSMA certification.

           3.     The rated service time shall be 30 minutes or more.

           4.     No positive-pressure unit that can be switched to demand mode.

           5.     The unit shall not be approved under the Bureau of Mines Schedule

           6.     The manufacturer shall provide with each SCBA instructions on maintenance,
                 storage,  disinfecting, inspection, use, operations,limitations and training
                 materials.
6/91
                                    77

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      B.     General Requirements

             Additionally, SCBA units must meet certain general requirements which include:

             1.     Labeling showing that the unit meets the requirements.

             2.     Initial, annual and fifth year testing of the SCBA.

             3.     Retesting of unit after any modifications.

             4.     Test series to include three categories, with on SCBA used per category.

      C.     Performance Tests

             1.     Airflow

                    This test increases the current NIOSH breathing machine requirements of 40
                    liters per minute to 100 liters per minute.  The 100 liters per minute volume
                    was derived from a review of several studies indicating that a ventilation rate
                    of 100 standard liters per minute encompasses the 98th percentile of all fire
                    fighters studies.

                    NOTE:  An airflow test is then  performed after each of the following tests,
                    with the exception of the fabric component test, to ensure breathing apparatus
                    performance.

             2.     Thermal Resistance Test

                    This  series of test expose the  breathing  apparatus  to various  temperature
                    extremes and temperature cycles that breathing apparatus might be exposed
                    to during actual  firefighting operations.

             3.     Vibration and Shock

                    This  test is designed to provide  a reasonable level of assurance that when the
                    breathing apparatus is exposed  to vibration, such as being carried on a rig
                    that often travels over rough  road surfaces, the apparatus  will perform and
                    function properly.

              4.     Fabric Components Test

                    Flame,  heat and thread tests are added  to provide a reasonable level of
                    assurance that the fabric components of a harness assembly used to hold the
                    backplate to the  wearer's  body  will  remain  intact  during  firefighting
                    operations.

              5.      Accelerated Corrosion Resistance Test

                     This test is to  provide a  reasonable  level of assurance that the breathing
                     apparatus is designed to resist corrosion that may form and interfere with the
                     apparatus performance and function.


6/91                                        78

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              6.     Particulate Resistance Test

                     This test exposes the breathing apparatus to a specified  concentration of
                     particulates to provide a reasonable level of assurance that the apparatus is
                     designed to properly function when exposed to dust conditions  commonly
                     present during firefighting operations.

              7.     Facepiece Lens Abrasion Resistance Test

                     This test is designed to  provide a reasonable level  of assurance that  the
                     facepiece lens of the breathing apparatus is not easily scratched during
                     firefighting operations  that  could  result in reduced  visibility for the fire
                     fighter.

              8.     Communications Test

                     This test is designed to assure that the facepiece of the breathing apparatus
                     does not significantly reduce a fire fighter's normal voice communications.
6/91                                         79

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           SECTION 5




PERSONAL PROTECTIVE EQUIPMENT




             PART 4



  NIOSH RESPIRATOR DECISION LOGIC
                81

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       PM
1

n

i
Respirator Decision
                   LOGIC
           83
 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
         Public Health Service
        Centers lor Disease Control
National Institute tor Occupational Safety end Health

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NIOSH   RESPIRATOR   DECISION   LOGIC
         U.S.  DEPARTMENT  OF  HEALTH  AND  HUMAN  SERVICES
                    Public Health Servfce
                 Centers for Disease Control
    National  Institute for Occupational Safety and Health
  Division of Standards Development and Technology Transfer

                          May  1987
                            84

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                DISCLAIMER
Mention of the name of any company or product
does not constitute endorsement by the National
Institute for Occupational Safety and Health.
    DHHS (NIOSH)  Publication  No.  87-108
                  85

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                                  FOREWORD

The initial Respirator Decision  Logic was developed  in  1975  as  part of the
National   Institute  for  Occupational  Safety  and Health/Occupational  Safety
and Health Administration  (NIOSH/OSHA)  Standards Completion Program and was
updated  in  1978.   Due  to  technical  advances  in   respirator  design  and
research,  NIOSH has again revised the Respirator Decision Logic.

This  revision   retains  many  aspects of  the  original   Respirator  Decision
Logic, but it differs  in  five areas:  odor warning  properties with respect
to  air-purifying   cartridge/canister   respirators,  recognition   of   the
problems in assigning protection factors,  changes  in protection  factors for
certain respirator classes,  respirator  recommendations   for carcinogens, and
medical recommendations.

The recognition of wide  variation  among workers  in  their  sensitivities for
detection   of odors has  led  to  the  recommendation  that  employers  not  rely
solely  on currently  published  data  on   odor  thresholds  to  ensure  that
workers  who   wear  air-purifying  cartridge  or  canister  respirators  are
capable of smelling  the  contaminant  at  the  applicable  exposure  limit.
Recent  research   on   in-plant   respirator    testing  suggests   that   some
previously assigned  protection  factors based  on  data  from  laboratory  fit
testing may  not   be  valid.   This  revised  Respirator  Decision  Logic  has
incorporated  assigned protection factors based on  data  from recent   in-plant
research  for some  powered  air-purifying respirators (PAPR) and some similar
respirators,   such  as   loose-fitting   and   tight-fitting   continuous   flow
air-line  respirators.  Since  NIOSH  maintains  that there is no safe exposure
to  carcinogens,  only  the  most  protective  respirators  should  be   used  to
protect workers   from  exposure to  carcinogens in the workplace.   Finally,
specific  medical   recommendations   are  included   to  assist  physicians  in
determining an  individual's fitness  to wear a  respirator.
                                       Donald  Millar,  M.D.,  D.T.P.H.  (Lond./
                                         'ant  Surgeon  General
                                    Director,  National  Institute  for
                                     Occupational Safety and Health
                                    Centers  for  Disease  Control
                                    86

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                               ACKNOWLEDGMENTS

This Respirator  Decision  Logic was  prepared  by a subcommittee of  the  NIOSH
Respiratory Protection  Committee,  Sheldon  H.  Rabinovitz,  Ph.D.,  Chairman.
The  Committee  consists  of   members   of   each  Division  of  NIOSH.    The
subcommittee consisted of  the  following  individuals:

                    Warren R.  Myers, Ph.D., Chairman, DSR
                           Nancy J. Bo I Iinger,  DSR
                        Thomas K.  Hodous,  M.D., DRDS
                         Nelson A. Leidel, Sc.D., 00
                      Sheldon H. Rabinovitz, Ph.D., DSDTT
                            Laurence D. Reed, DSR

The document was reviewed  by  the following  experts  in respiratory  protection:

                           Earle Shoub, Consultant
                Robert A.  daRoza, Chairman,  ANSI Z88  Committee
       Mark  Nicas, California Division of Occupational Safety and Health
         Christopher C. O'Leary, Chairman, American Industrial Hygiene
                Association, Respiratory Protection Committee
     Robert C. Spear,  Ph.D., Professor and  Director,  Northern California
        Occupational Health Center, University of California, Berkeley

In  addition,  appreciation is  extended  to  the  following  persons  for  their
assistance in preparing this document:

R.  Schutz  for  technical   review;   C.   Browning,  R.   Grubbs,  E.   Kuempel,
and H.  Linn  for  editorial  review;  and J.   Curless,  L.  DeVor,   B. Ellis,
J. Hamons, D.  Hill, C.  Kl inker,  N.  Morgan,  and A. Ritchey  for typing.
                                   87

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                                   CONTENTS

                                                                          Page

FOREWORD                                                                  i i j

ACKNOWLEDGMENTS                                                            i v

TABLES AND FIGURE                                                          vi

   I. INTRODUCTION                                                          1

      A.  Background and Scope                                              1
      B.  Cautionary Statements                                             2

  II. RESPIRATOR DECISION LOGIC                                             5

      A.  Criteria for Selecting Respirators                                6
      B.  Restrictions and Requirements
          for All Respirator Usage                                          7
      C.  Respirator Decision Logic Sequence                                8
      D.  Sub-paragraphs                                                    21
         1.   Oxygen-Deficient Atmosphere                                   21
         2.   Exposure Limi ts                                               21
         3.   Immediately Dangerous to Life or Health (IDLH)                22
         4.   Eye Irritation                                                23
         5.   Escape Apparatus                                              24
         6.   Potential Warning Properties for Use with
             Cartridge/Canister Air-Purifying Respirators                  26
         7.   Limitations of Respirators for Gases and Vapors               27
         8.   Assigned Protection Factors                                   27
         9.   Particulate Filter Respirators                                29
        10.   Suggested Medical Evaluation and Criteria for Respirator Use  30

  111. REFERENCES                                                           35

   IV. GLOSSARY                                                             40

   V. APPENDICES                                                           43

      A. NIOSH Policy Statement on Approval of Air-Purifying
         Respirators with End-of-Service-Life Indicators                   43

      B. NIOSH Policy Statement on Use of Single-Use and Dust
         and Mist Respirators  for Protection Against Asbestos              47

      C. Odor Warning:   Background  Information                             48

      D. Protection Factor:  Background  Information                        50

      E. Medical Aspects  of Wearing Respirators:  Background
          Information                                                       52
                                    88

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                                     TABLES

Number                                                                    Page

  1.  Assigned protection factor classifications of respirators
      for protection against participate exposures                         13

  2.  Assigned protection factor classifications of respirators
      for protection against gas/vapor exposures                           15

  3.  Assigned protection factor classifications of respirators
      for protection against combination gas/vapor and particulate
      exposures                                                            17

  4.  Selection options for escape respirators                             25

  5.  NIOSH recommended maximum use concentrations for gas
      and vapor air-purifying elements                                     28

  6.  Suggested frequency of medical  fitness determinations                32
                                     FIGURE

Number                                                                    Page

  1.  Flow Chart of Respirator Decision Logic Sequence                     19
                                     89

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                                I.  INTRODUCTION

A. Background and Scope

The National  Institute  for  Occupational  Safety and Health  (NIOSH)  routinely
makes  recommendations  regarding the  use  of  respirators  for  workers  exposed
to workplace  environments  that  contain hazardous concentrations  of  airborne
contaminants  and/or  oxygen-deficient  atmospheres.  Such  recommendations  are
made  only  when  engineering controls  are  not   technically   feasible,  while
controls  are  being   installed  or  repaired,  or when  emergency  and  other
temporary situations  arise.  Respirators  are  the  least  preferred method  of
worker protection from  respiratory  hazards because they  can be unreliable if
an  adequate  respiratory  protection  program  is  not  established  by  the
employer and  because they  require  worker  cooperation.   The   intent  of  this
decision logic  is to provide  industrial  hygienists  and  other professionals
knowledgeable   in   respirator   selection   with  a  procedure  for  selecting
suitable classes  of  respirators  for  particular  concentrations   of  specific
contaminants.   In this  decision logic,  concerns are  raised about limitations
of  the  data  used   to  set  protection   factors  for  several   classes   of
respi  rators.

To  ensure  uniformity  and  adherence  to  proper  respirator  usage,  NIOSH
recommendations have  been  based on the  Respirator  Decision  Logic  developed
jointly   in   1975   by   NIOSH   and   the   Occupational   Safety   and   Health
Administration  (OSHA)  as   part  of  the  Standards  Completion  Program  and
updated  in   June   1978.    That  decision   logic  incorporated   requirements
contained  in  30 CFR  11 and  fit   factor  data  developed  by  the Los  Alamos
National Laboratory  (LANL).  NIOSH has  now modified  that  decision  logic to
reflect  new  developments   that   include   increased  use  of   respirators  to
control  exposure  to   carcinogens  in  the  workplace,  introduction  of  new
respiratory  equipment,  and  reporting  of  field  research  data  on  workplace
protection factors (WPF's).

This  modified decision  logic identifies  the  criteria  necessary  to  determine
the classes  of  respirators that will  provide  a known degree  of respiratory
protection  for  a given work environment,  assuming that  the  respirators  are
used  correctly.   The degree of protection  is  related  in  part  to protection
factors.   Many of  the  assigned  protection  factors  (APF's)   that  appear  in
this  decision  logic  are based  on  laboratory  studies  and  should  be  regarded
as approximate.

The   selection   of   a  specific  respirator  must  be  made  by  individuals
knowledgeable   about   the   limitations   associated   with   each  class   of
respirators  and  familiar  with  the  actual  workplace  environment,  including
the job  task(s) to be performed.  The correct use of  a  respirator is  just as
important  as the selection  process   if  adequate  worker  protection  is  to be
achieved.   Without  a complete  respiratory protection program,  workers will
not  receive  the degree of protection anticipated  from  a  respirator,  even if
it  is a correct  choice for  the  situation.   Training,   motivation,  medical
                                  90

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evaluation,  fit testing, and  a respirator  maintenance program are  critical
elements for  the  successful  use  of  a respirator.  As  a  minimum,  compliance
with 29 CFR 1910.134  is  mandatory whenever respirators are used  by  workers,
whether on  a required  or voluntary basis.

B. Cautionary  Statements

NIOSH concerns about  the use  of respirators are discussed further in various
parts of  the  document  and  are summarized  in  the  following  six  cautionary
statements:

• Assigned  Protection  Factors

   In general,  the  assigned  protection  factors  (APF's)  that appear  in this
   decision logic are  not  based on measurements  of  actual  field  (workplace)
   performance.  As noted  in  the  footnotes accompanying  Tables  1,  2,  and 3,
   in only a few  instances  are the APF's based on  any workplace  performance
   testing;  the majority of the APF's have no workplace performance basis at
   all.  APF's based  solely on laboratory  fit  testing  should be  viewed  and
   applied  with  particular   caution,   even  when  the  laboratory  testing
   involves a simulated  work regimen.   To  date,  no  relation  has  been
   demonstrated  between   laboratory   fit   factors  and  measured  workplace
   performance.  As more performance testing  of respirators  is  undertaken in
   the workplace by NIOSH  and others, NIOSH  may  find  it  necessary to revise
   the  APF's  upward  or downward.   For  the  present,  APF's  should  not. be
   considered   reliable  predictors   of   performance   levels  that  will   be
   achieved during  actual   use, since APF's  are  not based  on  a  sufficient
   amount of workplace testing.

• Fit Testing

   No  qualitative  or  quantitative  fit  tests  have  been  demonstrated  to be
   capable  of  effectively   identifying  inadequately  fitting  respirators
   (i.e.,  respirator-wearer combinations  that  provide less  protection  than
   the  APF).    The   presently  used  fit  tests   (e.g.,   ANSI-recommended,
   OSHA-approved) may  fail  to identify individual  wearers  with  inadequate
   respiratory protection.  Thus  fit  tests should  be  used  with  caution  and
   with   recognition   of   their   possible   deficiencies.    As   appropriate,
   periodic evaluations  of  the effectiveness of  each  respirator  during  use
   in  the workplace should  be conducted to ensure  that each  wearer is being
   provided with adequate respiratory protection.

• QNFT Fit Factor Screening Levels

   Regarding quantitative  fit  testing  (QNFT),  no  studies  are  available to
   indicate what  fit  factor value (i.e., screening  level) will  ensure a high
   probability of  identifying  inadequately  fitting  respirators.    That  is,
   there are  no  studies demonstrating  what  fit  factor values  are  adequate
                                     91

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   accept/reject  criteria for QNFT  fit  screening.   When QNFT is used  for  fit
   screening,  the fit  factor  screening  level  should  be chosen with  caution
   and  with  recognition  of   the  uncertainty   of  its  effectiveness.    As
   appropriate,  periodic evaluation of  the  effectiveness of each  respirator
   during  use  in  the  workplace  should  be  conducted  to  ensure  that  each
   wearer is being  provided  with adequate respiratory protection.

• Adequate Warning  Properties

   No physiological  effects   in humans  (e.g., odor,  taste,  eye  irritation,
   respiratory   irritation)   have   been   demonstrated  as  being  capable   of
   consistently   providing  respirator   wearers   with   timely,   consistent,
   persistent,  and   reliable  warning  of  hazardous airborne  concentrations
   inside  a respirator.   Individual  wearers may  be  unable  to  detect  the
   warning  effect when necessary and may  fail   to take  action  necessary  to
   protect  themselves   (e.g.,   leaving   the  area  where   respirators   are
   necessary or  changing the sorbent  cartridge  or  canister).   When  warning
   properties must  be relied on as part  of  a  respiratory  protection  program,
   the  employer   should  accurately,   validly,   and  reliably  screen  each
   prospective wearer  for  the  ability  to  detect  the warning  properties  of
   the  hazardous  substance(s)  at exposure   levels  that  are  less  than  the
   exposure  limits   for the  substance(s).   Warning  properties  should   be
   regarded with  caution and with  recognition  of  their unreliability.

• Service Life Information

   For   essentially   all  gases  and   vapors,   no  adequate   service  life
   information is  available  to  respirator  wearers  or  to  those  responsible
   for  respiratory  protection  programs.   When   this   information   is  not
   available, respirators with air-purifying  sorbent  elements  should  be used
   with  caution  and  with  recognition  of  the  wide  variability of  service
   lives under differing use conditions.  Employers  should  possess  valid  and
   reliable estimates  of service  lives  for all   sorbent  elements  used in the
   respiratory  protection  program.   Service   life   test   data   should   be
   representative of  all conditions  of  intended  use  that  can be reasonably
   anticipated.   Factors  known  to  affect   the  service   lives  of  sorbent
   elements  include,  but are not  limited to, the  make  and  model  of  sorbent
   element, airborne concentrations of  contaminant(s),  and  relative humidity
   through  each  sorbent  element.   When  appropriate  service  life  data  is
   available, any reliance on the data should be  undertaken with caution  and
   with  recognition of  the  limitations and  uncertainties  of  the information.

 •  Determination of Protection Factor Levels Required for  Adequate Protection

   Workers  are  never  exposed  to  a  single unvarying  concentration of  a
   contaminant.   In  a given work area,  individual  exposures may vary widely
   between  workers,   during  a  workshift,  and  between  days.   The  range  of
   potential  exposures  should  be appropriately   determined  for  all  workers
   and   for all  circumstances   that  can  be  reasonably  anticipated.   The
                                   92

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highest anticipated exposure  for  each respirator wearer should be used to
compute  the  protection  factor  required   for   each   wearer.    Required
protection  factors  should be  used  with caution  and with  recognition  of
the!r uncertainties.
                                     93

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                          II. RESPIRATOR  DECISION  LOGIC

This decision  logic  contains a series of questions  regarding  situations which
may require  the  use  of  respirators.  (See Respirator Decision  Logic Sequence,
page 8.)   In  answering  these  questions,  the  user of  this decision  logic  is
assisted   in  identifying   specific  classes    of   respirators,   applicable
restrictions,  and  the  appropriate  respirator  selection  table  to  use.   When
using one of the tables  to  identify a suitable class of  respirators,  the user
must keep  in mind  the restrictions  identified  in the  question  section of this
decision logic.

This decision  logic identifies  the criteria necessary to  determine  the classes
of  respirators that  will  provide  the minimum  acceptable  degree  of protection
for  a  chemical  at a  given concentration.   Classes  of  respirators  offering
greater  protection can  usually be  used  in  place  of  the  minimum acceptable
class  of  respirators.   Respirator  classes  are  consistent  with  respirator
certification groupings as specified in 30 CFR 11.

The  recommendations  in  this   decision   logic  are  based  primarily  on  the
physical, chemical, and  toxicologic properties  of  the  contaminant  and  on  the
limitations  of each  class  of respirators, including filtration efficiency,  air
supply  capability, and  face  seal  characteristics and   leakage.   Thus  this
decision  logic  is  limited  to   identifying  classes of  acceptable  respirators,
rather than  individual respirators.

After various  classes  of respirators  are identified as  being  suitable  for  a
given situation, an  evaluation is made of other  factors of the particular work
environment so that  the  best  respirator  within the  recommended  classes  can  be
chosen.   In  some  situations,  the  selection  of a  respirator  classified  as
providing a higher level of protection may be advisable.

To  assist  the  user,  this decision  logic  contains  ten  subparagraphs  following
the  Respirator Decision Logic  Sequence   that describe  respirator  limitations,
use  of   applicable exposure limits,  warning  properties,   protection  factors,
oxygen   limitations,   and   medical   evaluation   of   suitability   to   wear
respirators.   Additional  supporting  information  is  contained in  Appendices  A
through  E.   To  properly use  this decision  logic,  the user  should  carefully
read the subparagraphs.

The assigned protection  factors (APF's) used in this decision  logic were based
on  quantitative  fit  factor  data developed by  Los Alamos National  Laboratories
(LANL) under contract  to  NIOSH and on field evaluation  data  gathered  by NIOSH
and  others.    Specific  references  and summaries  of  the data  used to generate
certain  protection  factors can  be  found  in  Subparagraph  8,  page 28.   Fit
factors  determined for  the individual  wearer  of a respirator  by quantitative
fit  testing or  by  any  other  method used  to  determine  fit   should  not  be
substituted  for  the  APF given   for  each class of  respirators.  However, the fit
factor  determined  through  quantitative  fit  testing must  be greater  than  the
APF; otherwise,  the  respirator  cannot be  used by  the worker.
                                    94

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^ Crjjeria for Selecting Respirators

To  use  this  decision   logic,  the  user  must  first  assemble  the  necessary
toxicologic,  safety,  and  other  relevant  information  for  each  contaminant,
including the fotlowing:

  •  General use conditions,  including determination  of contaminant(s);

  •  Physical, chemical,  and  toxicologic properties  of  the contaminant(s);

  •  Odor threshold data;

  •  NIOSH  recommended  exposure  limit (RED  or  when  no REL exists,  OSHA
     permissible exposure limit (PEL) or other applicable exposure limit;

  •  Immediately dangerous to life or health (IDLH)  concentration;.

  •  Eye irritation potential; and

  •  Any service life information available (for cartridges and canisters).

Obtaining  complete  information on  all  criteria needed  to use this decision
logic  may   be  difficult.  When  conflicting  or  inadequate  data  are  found,
experts  should  be  consulted  before decisions are made  that  could affect the
proper  use  of this  decision  logic.   In  addition,   the  adequacy  of  the
respirator  selected  is  dependent  on  the  validity  of  the  exposure  limit
used.  While  the decision  logic can be used  with any  exposure  limit,  NIOSH
recommends  that an  REL  be used when one exists for  a given contaminant.  For
a more detailed discussion  on  the  use of  exposure  limits,  especially  when
selecting  respirators for protection against carcinogens, see  Subparagraph 2,
page 21.

The  information obtained on  general  use conditions  for respirators  should
include  a   description  of the  actual  job   task,   including  the  duration  and
frequency,  location, physical  demands,  and  industrial  processes, as well  as
the  comfort  of  the respirators.  Some general use conditions may preclude the
use  of  specific types of  respirators  in certain  circumstances  because  the
individual  must be  medically  and  psychologically  suitable  to wear a  given
respirator   for  a  given   task,   particularly  if   the   respirator   is  a
self-contained breathing apparatus (SCBA).

Information  obtained on the  service  life  of  the  cartridge/canister  under
conditions of  intended use should be evaluated regardless of the  odor warning
properties  of  the  chemicals.   These  evaluations   should  be based  on  all
gas(es)  and  vapor(s)  present  at  the  temperature  and  relative  humidity
extremes  (high and  low) in  the  workplace.  NIOSH  recommends that  when  the
employer  or  a  representative  of  the  employer  conducts   the  tests,  the
challenge  concentrations of  the gases and vapors should  be  at least 10 times
the  maximum  use  concentration of  the  respirator.   The  service  life  value
                                       95

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obtained  from  these   tests   should   be  used  to  determine   how   long   a
cartridge/canister  could  provide  protection  under  actual  use  conditions.
This information  can  be used to set up  cartridge  replacement  schedules  and
should  be  used   in  conjunction with  sensory  warning properties.   Workers
should  be  trained to  exit the  contaminated  area  whenever  they detect  the
odor of  the  contaminant.   (See Subparagraph 6,  page 26,  for  a discussion on
service  life testing for chemicals with poor warning properties.)

B. Restrictions and Requirements for All  Respirator Usage

The  following  requirements  and  restrictions  must  be  considered to  ensure
that  the  respirator   selected  will   provide   adequate  protection under  the
conditions of  intended use:

  1. A  complete   respiratory protection  program should  be  instituted  which
  includes  regular worker  training;  maintenance,   inspection,  cleaning,  and
  evaluation of the respirator; use of the  respirator  in  accordance  with  the
  manufacturer's   instructions;  fit  testing;  and   environmental  monitoring.
  Whenever possible, quantitative evaluation of  the protection  factor  in  the
  workplace  should be  performed  to  confirm  the actual  degree of protection
  provided by  the  respirator to  each worker.   Minimum  respiratory protection
  requirements  for all  contaminants  can  be  found in  the OSHA  Safety  and
  Health  Standards,  29 CFR 1910.134,   and  in  separate sections  for  specific
  contaminants (e.g.,  1910.1001  for asbestos,  1910.1025 for lead, etc.).

  2. Qualitative  or  quantitative fit   tests should be provided as appropriate
  to ensure  that  the  respirator  fits  the  individual.   Periodic evaluation of
  the  effectiveness  of each respirator during use  in  the workplace should be
  conducted  to  ensure  that  each  wearer   is  being  provided   with  adequate
  respiratory  protection.   When quantitative  fit testing  (QNFT)  is used,  the
  fit  factor  screening  level  should  be  chosen with  caution  and  with  the
  recognition  of   the uncertainty of  its  effectiveness  since  no studies have
  demonstrated  what   fit  factor  values   provide   adequate   accept/reject
  criteria  for quantitative  fit  screening.

  3. Negative  pressure  respirators  should not  be  used  when  facial  scars or
  deformities  interfere with  the face  seal.

  4. No respirator (including positive pressure respirators)  should  be used
  when facial  hair interferes  with the face  seal.

  5. The  respirators   should  be  properly maintained,  correctly  used,  and
  conscientiously worn.

  6.  The usage  limitations  of air-purifying  elements,  particularly  gas  and
  vapor cartridges,  should not be  exceeded.

   7.  The  respirators  must   be  approved   by  the  Mine   Safety  and   Health
  Administration  and  the  National   Institute  for  Occupational  Safety  and
   Health (MSHA/NIOSH).
                                   96

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  8.  Workers  should  be  instructed  to  leave the contaminated area  immediately
  upon  suspicion  of  respirator  failure  and then  to determine the problem.

  9.  Workers  are  not   exposed  to  a  single  unvarying  concentration  of  a
  hazardous substance,   rather   individual  exposures may  vary  throughout  a
  workshift and  between  days.   The  highest anticipated concentration  should
  therefore be  used to  compute  the   required  protection  factor  for  each
  respi rator  wearer.

  10.  Respirator wearers   should be   aware  of  the  variability  in  human
  responses to the warning  properties  of hazardous substances.  When  warning
  properties  must be relied on as part of a  respiratory protection  program,
  the employer  should  screen  each prospective wearer  for   the  ability  to
  detect   the  warning properties  of  the  hazardous  substance(s)  at  exposure
  concentrations  that are  less  than the  R6L  for each given substance.   (See
  Subparagraph  6,   page   26,   and  Appendix   C,  page  48,   for   additional
  information.)

  11. The assigned protection  factors  (APF's) that  appear  in this  decision
  logic are .based  for  the most part  on  laboratory  studies.   However,  a  few
  APF's have been validated and revised as necessary after consideration of
  data  obtained  from studies  of  workplace protection  factors  (WPF's).   As
  more  WPF testing of respirators  is undertaken  by NIOSH  and  others,  the  APF
  values   may  be  further  revised.   For  the  present,  the APF's  should  be
  regarded as approximate if they  are  not based  on WPF's.

C. Respirator Decision  Logic Sequence

After  all  criteria have   been  identified   and  evaluated   and   after  the
requirements   and restrictions  of the  respiratory  protection  program  have
been met,  the following  sequence  of  questions  can  be used  to  identify  the
class of  respirators that should provide adequate  respiratory  protection:

  1. Is the respirator  intended for  use during fire  fighting?

     a. If yes,  only a self-contained  breathing apparatus  (SCBA)  with a full
     facepiece operated  in  pressure demand or  other  positive pressure  mode
     is recommended.

     b. If no, proceed  to Step  2.

  2. Is  the  respirator   intended  for  use  in  an oxygen-deficient  atmosphere,
  i.e.,  less  than  19.5% oxygen  at sea  level?   (Refer  to  Subparagraph  1,
  page  21, for a discussion of  oxygen  deficiency.)

     a. (f yes,  any type  of  SCBA or  supplied-air  respirator (SAR)  with an
     auxiliary SCBA  is   recommended.    Auxiliary SCBA must be of  sufficient
     duration to permit  escape to safety if  the  air supply  is  interrupted.
     If additional  contaminants are  present,  proceed to Step 3.
                                      97

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   b.  If no,  proceed  to  utep 3.

3. Is  the respirator  intended for  use  during  emergency situations?

   a.  If yes,  two types  of  respirators  are recommended:  a  SCBA with  a
   full   facepiece operated  in  pressure demand  or  other positive  pressure
   mode   or  an SAR with  a  full  facepiece operated  in  pressure demand  or
   other positive  pressure  mode  in  combination with  an  auxiliary  SCBA
   operated in pressure demand  or  other positive pressure mode.  Auxiliary
   SCBA  must be  of sufficient  duration to permit escape  to  safety  if  the
   air supply is  interrupted.

   b.  If no,  proceed  to  Step 4.

4. !s  the contaminant regulated by  the Department of Labor as  a potential
occupational   carcinogen   or   identified  by  NIOSH  as  a   potential   human
carcinogen   in  the workplace,  and  is  the  contaminant detectable   in  the
atmosphere?

   a.  If yes,  two types  of  respirators are  recommended:   a  SCBA  with  a
   full   facepiece  operated  in  pressure demand   or other  positive  pressure
   mode   or  an SAR with  a  full  facepiece operated  in  pressure demand  or
   other positive pressure  mode  in   combination  with an auxiliary  SCBA
   operated in pressure  demand or  other positive  pressure  mode.  Auxiliary
   SCBA   must  be  of sufficient  duration to  permit escape   to safety  if  the
   air supply is  interrupted.

   b.  If no,  proceed  to  Step 5.

5. Is  the  exposure  concentration of  the contaminant,  as  determined  by
acceptable   industrial hygiene methods,  less than the  NIOSH  PEL or  other
applicable  exposure  limit?  (Whenever  a  worker  is  given a respirator  to
use on  a voluntary basis  when ambient  levels are  below applicable limits,
OSHA  requires the  implementation  of  a  complete   respiratory  protection
program,   which   includes   medical   evaluation,   training,   fit  testing,
periodic   environmental   monitoring,    and   all   other   requirements   in
29 CFR  1910.134.)

   a. If yes,  a  respirator would  not  be   required  except  for an  escape
a.  ir yes,  a  respirator  wou
situation.   Proceed to Step  7.

b.  If no,  proceed to Step  6.
6. Are conditions such  that  a  worker  who is  required  to  wear  a respirator
can  escape  from  the work area and  not  suffer loss of life or immediate or
delayed  irreversible health effects if  the  respirator  fails,  i.e.,  are the
conditions  not  immediately  dangerous  to  life or  health  (IDLH)?   (Refer to
Subparagraph 3, page 22,  for additional  information on IDLH's.)
                                   98

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   a. If yes,  conditions are not  considered to be IDLH.   Proceed to Step 7.

   b. If  no,   conditions   are   considered  to  be  IDLH.    Two  types   of
   respirators are recommended:  a SCBA  with a  full  facepiece  operated in
   pressure demand or  other positive pressure  mode or  an SAR  with  a  full
   facepiece operated  in pressure  demand  or  other positive pressure mode
   in combination  with an  auxiliary  SCBA operated  in  pressure demand  or
   other positive pressure  mode.   The auxiliary SCBA must be of sufficient
   duration to permit escape to safety if the air supply is  interrupted.

7. Is the  contaminant  an  eye  irritant,  or  can the  contaminant cause  eye
damage at  the  exposure concentration?  (Refer  to  Subparagraph  4,  page  23,
for a discussion of eye irritation and damage.)

   a. If yes,   a  respirator  equipped  with a full facepiece,  helmet, or hood
   is recommended.   Proceed to  Step 8:

   b. If no,  an  orinasal  respirator  may  still  be  an option, depending on
   the exposure concentration.   Proceed to Step 8.

8. Divide  the 8-hour  time-weighted   average  (TWA)  exposure  concentration
for  the  contaminant  (or  maximum exposure  concentration for a  contaminant
with  a   ceiling  limit) determined  in Step  5  by   the  NIOSH REL  or  other
applicable  exposure   limit   to. determine  the  minimum  protection  factor
required.   For escape  respirators, determine  the  potential  for generation
of a hazardous condition caused by an accident or  equipment  failure.   If a
potentially hazardous  condition  could occur  or a minimum protection factor
has been calculated,  proceed to Step  9.

9. If the  physical  state  of the contaminant  is a  particulate (solid  or
liquid)   during periods of  respirator use,  proceed to Step 10;   if  it  is a
gas or  vapor,  proceed  t'o  Step  11; if  it  is  a combination of gas  or vapor
and particulate, proceed to Step 12.

10. Particulate Respirators

10.1. Is the particulate respirator intended only for escape purposes?

   a. If  yes,  refer   to Subparagraph 5,  page  24,  for  a  discussion  and
   selection of "escape only" respirators.

   b. If no,  the particulate respirator  is  intended  for use during normal
   work  activities.  Proceed to Step  10.2.

10.2. A   filter medium  that  will  provide  protection against  exposure to  the
particulate   in  question   is  recommended.    (Refer   to  Subparagraph   9,
page 29, for  a discussion  on limitations of approvals  for  filter  media.)
Proceed   to Step 10.3.
                                    99

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10.3. Respirators  that  have  not  been previously  eliminated  from Table  1
and that have APF's equal  to or greater than the minimum  protection  factor
determined in Step  8  are  recommended.  (Refer to  Subparagraph  8,  page 28,
and Appendix D,  page  50,  for  a  discussion of protection factors, and  to
Subparagraph  9,  page  29,   for  a  discussion  on   limitations  of  filter
approvals.)  Maximum airborne concentrations for  each  level of  respiratory
protection  can  be  calculated  by  multiplying   the  NIOSH  REL  or  other
applicable  exposure  limit   by  the  APF   for   that   class  of   respirators.
Workers wearing  respirators should  meet  the medical  guidelines  discussed
in Subparagraph 10, page 30.

11. Gas/Vapor Respirators

11.1. Is the gas/vapor respirator intended for "escape only"  purposes?

   a. If  yes,   refer  to  Subparagraph  5,  page  24,   for  a  discussion  on
   selection of "escape only" respirators.

   b. If  no,  the  gas/vapor  respirator is  intended  for  use  during  normal
   work activities.  Proceed to Step 11.2.

11.2. Are  the warning properties for  the  gas/vapor  contaminant  adequate at
or  below   the  NIOSH  REL  or  other   applicable  exposure  limit?   (Refer  to
Subparagraph  6,  page  26,  and  Appendix  C,  page  48,  for   additional
information on  requirements  for adequate warning properties.)

   a. If yes, proceed to Step 11.3.

   b. If   no,  an  air-purifying  respirator  equipped  with  an  effective
   end-of-service-Iife  indicator  (ESLI),  a  supplied-air  respirator,  or  a
   self-contained   breathing   apparatus   is    recommended.    (Refer   to
   Appendix A,   page   43,    for  additional  information  on   approval   of
   air-purifying respirators with ESLI's.)  Proceed  to Step 11.4.

11.3. An    air-purifying    chemical    cartridge/canister    respirator   is
recommended  that has a sorbent suitable  for  the  chemical  properties of the
anticipated  gas/vapor  contaminant(s)  and  for   the  anticipated  exposure
 levels.   (Refer to Subparagraph  7,   page  27,  for  the recommended maximum
use    concentrations    of    air-purifying    chemical     cartridge/canister
respirators.)   Proceed  to Step  11.4.

11.4. Respirators  that have not  been previously  eliminated  from  Table  2
and  that  have APF's equal  to  or greater  than  the minimum protection  factor
determined in  Step 8 are  recommended.   (Refer  to  Subparagraph  8,  page 28,
and  Appendix D, page 50, for  a discussion of protection  factors.)  Maximum
airborne  concentrations  for each  class   of  respiratory protection  can  be
calculated by  multiplying  the NIOSH  REL  or other  applicable  exposure  limit
by the APF  for that  class  of  respirators.  The  calculated  maximum use
concentration    limits   should  not   exceed  the   limitations   noted  in
Subparagraph  7,  page 27.    Workers  wearing  respirators  should  meet  the
medical guidelines discussed in Subparagraph  10, page  30.
                                   100

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12.  Combination Participate and  Gas/Vapor  Respirators

12.1.  Is the combination respirator  intended for  "escape  only"  purposes?

   a.  If yes,  refer  to Subparagraph  5,  page  24,  for  a  discussion and
   selection of "escape only"  respirators.

   b.  If no, the combination  respirator  is  intended for use during  normal
   work activities.   Proceed to  Step 12.2.

12.2.  Does the gas/vapor  contaminant have  adequate warning properties  at
or  below  the  NIOSH  REL  or  other   applicable  exposure  limit?  (Refer  to
Subparagraph  6,   page  26,  and  Appendix  C,  page  48,   for   additional
information on requirements for  adequate warning  properties.)
   a. If yes,  proceed to Step 12.3.
                                                               an effective
                                                                     or   a
   b. If no, either an  air-purifying respirator equipped with an e
   ESLI   (Appendix  A,   page  43),   a  supplied-air   respirator,
   self-contained respirator is recommended.   Proceed to Step 12.4.

12.3. An air-purifying chemical cartridge/canister  is  recommended that has
a particulate prefilter suitable  for the specific type(s)  of  gas/vapor and
particulate contarninant(s) and for  the exposure concentrations.   (Refer to
Subparagraphs 7,  page  27,  and  Subparagraph  9,  page  29,   for  recommended
maximum use concentrations and filter limitations.)   Proceed to Step 12.4.

12.4. Respirators that  have  not  been previously eliminated from  Table  3
and that have APF's  equal to or greater than  the minimum protection factor
determined  in Step 8  are recommended.  (Refer  to Subparagraph  8, page 28,
and  Appendix  D,  page 50,  for  a  discussion  of  protection  factors  and
Subparagraph  9,   page  29,  for   a  discussion on   limitations  of  filter
approvals.)  Maximum airborne' concentrations  for each  level  of  respiratory
protection  can  be   calculated  by  multiplying  the  NIOSH REL  or  other
applicable  exposure limit  by  the  APF for  that  class of  respirators.   The
calculated  maximum   use  concentration   limits  should   not   exceed   the
(.imitations noted in Subparagraph  7, page  27.   Workers  wearing  respirators
should meet the medical  guidelines discussed  in Subparagraph 10,  page 30.
                                    101

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      Table  1.—Assigned  protection  factor  classifications of  respirators
                 for  protection  against  particulate exposures''


Assigned protection
     factor                         Type of respirator


      5             Single-use  (see  definition  in   Glossary)   or  quarter
                    mask^ respirator

     10             Any   air-purifying    half-mask    respirator   including
                    disposable^ (see  definition in  Glossary) equipped  with
                    any type of particulate filter  except single us
                    Any  air-purifying  full  facepiece  respirator  equipped
                    with any type of particulate filter^

                    Any  supplied-air  respirator  equipped  with  a  half-mask
                    and operated in a demand (negative pressure) mode^

     25             Any  powered  air-purifying   respirator  equipped  with  a
                    hood or helmet and any type of particu'ate filter4

                    Any  supplied-air  respirator  equipped  with  a  hood  or
                    helmet and operated in a continuous flow mode4

     50             Any  air-purifying  full  facepiece  respirator  equipped
                    with a high efficiency filter^

                    Any  powered  air-purifying   respirator  equipped  with  a
                    tight-fitting facepiece and a high efficiency filter4

                    Any   supplied-air  respirator   equipped   with   a   full
                    facepiece  and  operated  in  a  demand (negative  pressure)
                    Any    supplied-air    respirator     equipped    with    a
                    tight-fitting  facepiece  and  operated   in  a  continuous
                    f low mode4
    Only   high   efficiency   filters  are  permitted   for   protection  against
    particulates having exposure  limits  less than 0.05 mg/m^.
    The  assigned protection  factors  (APF's)  were  determined   by  Los  Alamos
    National  Laboratories  (LAND by  conducting  quantitative fit  testing  on a
    panel  of human volunteers [6].
    An APF factor  of 10 can  be  assigned to disposable particulate respirators
    if they have been properly fitted using a quantitative fit test.
    APF's  were  based on  workplace  protection factor  (WPF)  data or  laboratory
    data more recently  reported  than  the LANL data [7-11, 14-17].
    The  APF was  based on  consideration of efficiency  of   dust,  fume,  and/or
    mist filters.
                                    102

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     Table 1.—Assigned protection factor classifications of respirators
           for  protection  against  particulate exposures^—Continued


Assigned protection
     factor                         Type of  respirator


        50 cont.     Any  self-contained  respirator  equipped  with   a   full
                    facepiece and  operated   in  a  demand  (negative pressure)
                    mode^

     1,000          Any supplied-air   respirator  equipped with  a  half-mask
                    and operated   in   a  pressure  demand or  other  positive
                    pressure mode^

     2,000          Any  supplied-air   respirator  equipped   with  a   full
                    facepiece and  operated  in a pressure demand or  other
                    positive pressure mode^

    10,000          Any  self-contained  respirator  equipped  with   a   full
                    facepiece and  operated  in a pressure demand or  other
                    positive pressure mode^

                    Any  supplied-air   respirator  equipped   with  a   full
                    facepiece  operated   in  a   pressure  demand   or   other
                    positive pressure  mode  in  combination with  an auxiliary
                    self-contained   breathing   apparatus   operated   in   a
                    pressure demand or other positive pressure mode^


1   Only  high  efficiency  filters  are  permitted  for  protection  against
    particulates having exposure limits less than 0.05 mg/m^.
2   The  assigned  protection  factors   (APF's) were  determined by  Los  Alamos
    National  Laboratories  (LANL) by conducting quantitative fit  testing  on  a
    panel of human volunteers [6].
3   An APF of  10  can  be  assigned  to  disposable  particulate  respirators  if
    they have been properly fitted using a quantitative fit  test.
4   The  APF's   were based  on  workplace  protection  factor   (WPF)  data  or
    laboratory data more recently reported than the LANL data [7-11, 14-17].
5   The APF  was based  on  consideration of  efficiency  of dust,  fume,  and/or
    mist fi I ters.
                                    103

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   Table 2. — Assigned protection factor classifications of respirators for
                    protection against  gas/vapor  exposures


Assigned protection
    factor1                          Type of  respirator


     10             Any   air-purifying   half  mask   respirator   (including
                    disposable)   equipped    with   appropriate    gas/vapor
                    cartridges^

                    Any  supplied-air  respirator  equipped  with a  half  mask
                    and  operated in  a demand (negative  pressure) mode^

     25             Any     powered    air-purifying    respirator    with    a
                    loose-fitting hood  or  helmet^

                    Any   supplied-air  respirator  equipped  with  a  hood  or
                    helmet  and operated in a continuous  flow  mode^

     50             Any   air-purifying   full  facepiece   respirator  equipped
                    with  appropriate  gas/vapor  cartridges   or   gas   mask
                    (canister respirator)^

                    Any   powered  air-purifying   respirator  equipped  with  a
                    tight-fitting   facepiece   and   appropriate    gas/vapor
                    cartridges or canisters^

                    Any   supplied-air   respirator   equipped   with   a   full
                    facepiece  and operated   in a  demand (negative  pressure)
                    Any  supplied-air   respirator  equipped  with   a  tight-
                    fitting facepiece operated in a continuous  flow mode^

                    Any  self-contained  respirator  equipped  with   a   full
                    facepiece  and  operated  in  a demand  (negative  pressure)
     1,000          Any  supplied-air  respirator  equipped  with  a  half-mask
                    and  operated  in  a  pressure  demand  or  other  positive
                    pressure mode^


    The assigned  protection  factor  (APF) for a given  class of  air-purifying
    respirators  may  be   further  reduced  by  considering   the   maximum  use
    concentrations  for each type of gas and vapor air-purifying  element,
    The APF ' s  were  determined by Los Alamos National  Laboratories  (LANL)  by
    conducting quantitative fit testing on a panel of human volunteers [6].
    The  APF ' s  were  based  on  workplace  protection  factor  (WPF)  data  or
    laboratory data more  recently reported than the LANL data  [7-11, 14-17].
                                     104

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   Table 2.—Assigned protection factor classifications of respirators for
              protection against gas/vapor exposures—Continued


Assigned protection
    factor''                          TYPe of  respirator


     2,000           Any   supplied-air   respirator   equipped   with   a   full
                    facepiece  and  operated  in a  pressure demand  or other
                    positive pressure mode^

    10,000           Any   self-contained  respirator  equipped  with   a   full
                    facepiece  and  operated  in a  pressure demand  or other
                    positive pressure mode^

                    Any   supplied-air   respirator   equipped   with   a   full
                    facepiece   operated   in   a  pressure  demand  or  other
                    positive  pressure mode  in  combination  with  an auxiliary
                    self-contained    breathing   apparatus   operated   in   a
                    pressure demand or other positive pressure mode^


1   The assigned protection factor  (APF)  for a given class of  air-purifying
    respirators  may be  further  reduced  by  considering  the   maximum   use
    concentrations  for each type of gas and  vapor  air-purifying  element.
2   The APF's were  determined by Los Alamos National Laboratories (LANL)  by
    conducting  quantitative fit  testing on a panel  of human volunteers [6].
3   The  APF's  were based  on  workplace protection factor  (WPF)  data  or
    laboratory  data  more  recently reported than the LANL data  [7-11,  14-17].
                                     105

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    Table 3.—Assigned  protection  factor  classifications of respirators for
      protection against combination gas/vapor and particulate exposures1


Assigned protection
     factor2                     Type of respirator


        10           Any  air-purifying  half-mask  respirator   equipped   with
                    appropriate gas/vapor cartridges  in combination  with any
                    type of particulate filter^

                    Any full  facepiece respirator with appropriate  gas/vapor
                    cartridges   in  combination  with a  dust  or mist  or  fume;
                    dust and  mist; or  dust,  mist, and  fume  filter^

                    Any supplied-air   respirator equipped  with  a  half-mask
                    and operated in a demand (negative pressure)  mode^

        25           Any  powered  air-purifying   respirator  equipped  with  a
                    loose-fitting hood or helmet^

                    Any  supplied-air   respirator  equipped  with  a   hood  or
                    helmet and  operated in a continuous flow mode^

        50           Any  air-purifying  full  facepiece  respirator   equipped
                    with  appropriate  gas/vapor  cartridges   in   combination
                    with a high  efficiency  filter  or  an  appropriate canister
                    incorporating a high  efficiency filter^

                    Any    powered    air-purifying     respirator    with    a
                    tight-fitting   facepiece   equipped   with   appropriate
                    gas/vapor   cartridges    in   combination   with   a   high
                    efficiency     filter    or    an    appropriate    canister
                    incorporating a high  efficiency filter^

                    Any   supplied-air   respirator   equipped   with   a   full
                    facepiece  and operated  in  a demand (negative  pressure)
                    mode^


^   Only  high  efficiency  filters  are   permitted  for   protection  against
    particulates having exposure  limits  less than 0.05 mg/m^.
2   The assigned protection  factor (APF) for a  given  class of  air-purifying
    respirators  may  be  further   reduced  by  considering   the  maximum  use
    concentrations for each type of gas and vapor air-purifying element.
3   The APF's  were  determined  by Los  Alamos National  Laboratories  (LAND  by
    conducting quantitative fit testing on a panel  of  human  volunteers [6].
4   The APF was  based on  consideration of  efficiency  of  dust,  fume,  and/or
    mist filters.
5   The  APF's  were  based  on  workplace  protection   factor   (WPF)  data  or
    laboratory data more  recently  reported than the LANL data  [7-11, 14-17].
                                  106

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   Table 3.—Assigned protection factor classifications of respirators for
    protection against combination gas/vapor and participate exposures'^ —
                                  Continued
Assigned protection
     factor^                    Type of respirator


        50 cont.    Any    supplied-air    respirator    equipped    with    a
                    tight-fitting  facepiece  and  operated   in  a  continuous
                    flow mode^

                    Any  self-contained  respirator  equipped  with   a  full
                    facepiece  and  operated  in  a demand  (negative  pressure)
                    mode**

     1,000          Any  supplied-air   respirator  equipped with  a  half-mask
                    and  operated  in   a  pressure  demand  or other  positive
                    pressure mode^

     2,000          Any  supplied-air   respirator  equipped  with   a   full
                    facepiece  and operated  in  a pressure  demand  or  other
                    positive pressure mode^

    10,000          Any  self-contained  respirator  equipped  with   a  full
                    facepiece  and operated  in  a pressure  demand  or  other
                    positive pressure mode^

                    Any  supplied-air   respirator  equipped  with   a   full
                    facepiece  operated   in  a   pressure  demand   or  other
                    positive pressure  mode  in  combination with  an  auxiliary
                    self-contained   breathing   apparatus    operated    in   a
                    pressure demand or other positive pressure mode^


1   Only  high  efficiency  filters  are  permitted  for  protection  against
    particulates having exposure limits less than 0.05 mg/m^.
2   The assigned protection  factor  (APF)  for a  given  class  of  air-purifying
    respirators  may be further  reduced  by  considering  the  maximum  use
    concentrations for each type of gas and vapor air-purifying element.
3   The APF's  were  determined  by Los  Alamos National  Laboratories  (LAND  by
    conducting quantitative fit testing on a panel of human volunteers [6].
4   The APF was  based  on consideration of  efficiency  of dust,  fume,  and/or
    mist fiIters.
5   The  APF's  were  based  on  workplace  protection  factor (WPF)  data  or
    laboratory data more recently reported than the LANL data [7-11, 14-17].
                                    107

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The  Respirator  Decision  Logic Sequence  is presented  in Figure  1  in  the form
of  a  flow  chart.    This  flow  chart  can  be  used  to  identify  suitable classes
of   respirators   for   adequate   protection  against   specific   environmental
conditions.   Refer  to  the  corresponding  narrative   section  for   additional
information pertaining to a  specific  part  of the flow chart.
                                                 If other contaminants
                                               11 are present
                                                    KEY: CC—Contaminant Concentration
                                                        EL—Exposure Limit
                                                        ESLI—End of Service Life Indicator
                                                        FF—Full Facepiece
                                                        IDLH —Immediately Dangerous
                                                          to Life or Health
                                                        PD—Pressure Demand
                                                        PF—Protection Factor
                                                        PFa—Assigned PF
                                                        PFmin — Minimum PF
                                                        PP—Positive Pressure
                                                        SCBA—Self-Contained
                                                          Breathing Apparatus
                                                        SAR—Supplied-Air Respirator

                                                    A* • SCBA with FF operated in PO or PP mode.
                                                    B* • Type C supplied-air respirator (airline)
                                                    operated in PD or PP mode with auxiliary SCBA.
                                                    C' • Escape respirator or gas mask with appropriate
                                                    filter/sorbent (Subparagraph 5); if 0, deficient,
                                                    then SCBA.
                   Figure 1. — Flow Chart of Respirator Decision Logic Sequence
                                        108

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  Alf-Purt tying
   Chemical
CartrldgeJCanlster
(Subparagraph 7)
Sames as
  10.3
                      Air-Purifying Respirator
                      with ESLI (Appendix A)
                        or any SAR, SCBA
    Orinasal Styla
    Respirator May
     Be Optional
                            FF.
                      Helmet, or Hood
                        Only Option
 Select Respirator Type
 Based on PFa>PFmin
(Subparagraphs 8. 9, 10.
   and Appendix D)
                           Adequate
                            Warning
                           Properties?
                            ubpar. 6 &
                            App. C)
                                                    Select
                                                  Paniculate
                                                  Type Filter
                                                (Subparagraph 9)
            Gas/Vapor/     ^^    XPartlculate
                       Contamlnmant
                           State
                                            Combination V Partlculate-Gas/Vapor
                                                                                                       (10.1s)
                                                                                                        -—s
                                                                                                         C*
                                                          No
Same as
10.3
1


Air-Purl tying
Respirator with
ESLI (Appendix A)
or any
SAR. SCBA

No / Adequate >y Yes
^ ./ Warning X ^
\ Properties? /
\ (Subpar. 6 1 /
X. App. Q/
— ^ 	
v 7
Chemical
Cartridge/
Canister with
Paniculate Premier
(Subparagraph 7)


^
           Figure 1. —  Flow Chart of Respirator Decision Logic Sequence — Continued
                                                      109

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D. Subparagraphs

   The following subparagraphs  provide  additional  information to assist  the
   reader in using  the Respirator Decision Logic Sequence:

Subparagraph 1:   Oxygen-Deficient Atmosphere

The National Institute  for  Occupational  Safety and Health  (NIOSH) defines an
oxygen-deficient  atmosphere  as  any  atmosphere  containing  oxygen   at  a
concentration below 19.5% at  sea level  [1].  NIOSH certification of air-line
or  air-purifying  respirators  is  limited  to  those  respirators   used  in
atmospheres  containing at   least  19.5%  oxygen,  except for  those  air-line
respirators  equipped   with   auxiliary   self-contained   breathing  apparatus
(SCBA).

The minimum  requirement of  19.5% oxygen at  sea  level   provides  an adequate
amount of  oxygen for   most  work  assignments  and  includes   a  safety  factor.
The  safety  factor  is  needed   because   oxygen-deficient  atmospheres  offer
little  warning   of  the  danger,  and  the  continuous  measurement   of  an
oxygen-deficient atmosphere is difficult.

At  oxygen   concentrations    below   16%   at  sea   level,   decreased   mental
effectiveness,   visual   acuity, and muscular  coordination  occur.   At  oxygen
concentrations   below   10%,  loss  of  consciousness may  occur, and  below  6%
oxygen,  death will   result.   Often only  mild subjective  changes  are  noted by
individuals exposed to  low  concentrations of oxygen, and  collapse  can occur
without  warning  [2,3,4].

Since  oxygen-deficient  atmospheres  are  life-threatening,  only  the  most
reliable  respirators  are  recommended; the most  reliable respirators  are the
self-contained   breathing  apparatus   or   the  supplied-air   respirators  with
auxiliary  self-contained  units.   Because  a  high protection  factor  is  not
necessary  to  ensure  an  adequate supply  of  oxygen  even   in  an  atmosphere
containing  no   oxygen,  any  certified self-contained  unit   is adequate.   All
aspects   of  a respiratory protection  program  must be  instituted  for  these
recommendations  to be  valid.

Subparagraph 2:   Exposure Limits

The majority of the OSHA PEL's were  adopted  from the American  Conference of
Governmental  Industrial  Hygienists  (ACGIH) TLVs® published in  1968.   The
difficulty  in   changing  PEL's  through  promulgation  of standards  when  new
toxicologic  information  is   identified  has  caused many  standards  to  become
outdated.   The   effectiveness  of this  decision  logic is  limited   to  the
adequacy  of  the  selected   exposure  limits  in  protecting  the  health  of
workers.   Exposure  limits  based  on  a thorough  evaluation  of more  recent or
extensive data  should  be given priority.

For all  chemicals that  cause  irritation or systemic effects but  do  not cause
carcinogenic  effects,   it   is currently  believed  that   a  threshold exposure
                                   110

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concentration  exists  such   that   virtually   all   persons  in   the  working
population (with the possible exception of  hypersensitive  individuals)  would
experience no adverse health effects.

For  many  carcinogenic substances,  most available  data provide no  evidence
for  the  existence  of  a  threshold exposure  concentration  below  which  the
substance would  be  safe.   As with  noncarcinogenic  substances,  there appears
to  be  a  dose-response  relationship   for   carcinogenic substances.   If  no
threshold  exists   for  a   carcinogen,   then   there   is   no  safe   exposure
concentration; however,  lower exposures would  be associated with lower risks.

For some carcinogens, NIOSH attempts to identify the lowest REL on  the  basis
of   the  quantitative  detection   Limit  for   the  method  used  to  monitor
exposures.   For  other   carcinogens,   NIOSH  does  not  identify  a  precise
exposure  limit  but  recommends  instead  that  the  employer  control  worker
exposures to the lowest  feasible limit.

Regardless  of  the   selected  exposure  limit   for  a  carcinogen,   the  best
engineering  controls  and  work  practices  should be  instituted.   Respirators
should  not  be  used as  a  substitute  for  proper   control  measures.   When
respiratory   protection   is   required  to   achieve   the   lowest   exposure
concentration, then only  the most effective respirators should be  used.   Two
types of  respirators are  recommended:   a  full facepiece  SCBA operated  in a
pressure-demand  or  other  positive  pressure  mode   or   a   full   facepiece
supplied-air   respirator  (SAR)  operated   in  a  pressure-demand  or  other
positive pressure  mode  in  combination  with  a  SCBA operated  in  a  pressure
demand or other  positive  pressure  mode.  The practicality of each  situation
must be assessed  to determine the  most  technically feasible protection  for
the worker.

Other variables  such as  the specific  situation, worker, or job  may influence
the  selection  of the appropriate  exposure  limit  for  a   given  contaminant.
For  example,  the effects of  some  hazardous substances may  be  increased  due
to exposure  to  other contaminants  present  in  the  workplace or  the general
environment  or  to   medications  or  personal   habits  of   the  worker.   Such
factors, which would  affect the  toxicity  of  a  contaminant,  would  not  have
been considered  in  the determination  of the  specific  exposure  limit.  Also,
some substances  are absorbed  by direct  contact  with the  skin  and  mucous
membranes, thus potentially increasing the  total exposure.

Subparagraph 3:  Immediately Dangerous to Life or Health (IDLH)

An  IDLH  exposure condition  is  defined  in  this decision  logic  as  one  that
poses a threat  of  exposure  to  airborne contaminants  when that exposure  is
likely  to  cause death  or  immediate  or  delayed  permanent adverse  health
effects  or  prevent  escape  from  such  an  environment.   The  purpose  of
establishing an  IDLH exposure  level is to  ensure  that the worker can escape
from  a given  contaminated  environment  in  the   event of  failure  of  the
respiratory  protection  equipment.   The IDLH   is  considered  a maximum  level
                                      111

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above  which only  a  highly  reliable  breathing apparatus  providing  maximum
worker protection  is  permitted.   Any appropriate approved  respirator  may  be
used to its maximum use concentration up to the IDLH concentration.

In  establishing the  IDLH concentration,  the  following  conditions must  be
assured:

   a.  The  ability   to  escape without  loss  of  life  or  immediate  or  delayed
   irreversible  health  effects.    (Thirty  minutes  is considered  the  maximum
   time for escape so as  to provide some margin of safety  in calculating the
   IDLH.)

   b.  The  prevention  of severe  eye  or  respiratory   irritation or  other
   reactions that would hinder escape.

Sources  of  information   for  determining whether  the  exposure  limit   for  a
contaminant represents an  IDLH condition are as follows:

   a.  Specific   IDLH  guidelines   provided  in  the  literature  such   as  the
   American  Industrial  Hygiene  Association  (AIHA)  Hygienic Guides and the
   NIOSH  Pocket Guide  for Hazardous Chemical  Substances  (previous editions
   were published  jointly by NIOSH and OSHA), and/or

   b.  Human exposure  and  effects data, and/or

   c.  Animal exposure and effects  data,  and/or

   d.  Where such data specific  to the  contaminant  are lacking,  toxicologic
   data  from analogous  substances and  chronic animal  exposure data  may  be
   considered.

Subparagraph 4:  Eye  Irritation

Eye  protection  in  the form of  respirators  with full facepieces,  helmets,  or
hoods  is   required   for  routine exposures to airborne contaminants  that  cause
any  irritation  to  the mucous membranes  of  the  conjunctivae or the cornea or
'cause  any reflex  tearing.  Eye  protection  is  required  for  contaminants that
cause  minor subjective effects  as well  as  for those that  cause any  damage,
 including   disintegration  and   sloughing   of   conjunctival   or   corneal
 epithelium,  edema, or ulceration.  NIOSH  is  not  aware  of  any standards  for
 gas-tight   goggles that  would  permit  NIOSH  to  recommend such  goggles  as
providing  adequate eye  protection.

 For  escape,  some eye  irritation  is permissible  if  the  severity of  irritation
 does not   inhibit  the escape  and if  no irreversible  scarring or  ulceration of
 the  eyes  or conjunctivae is  likely.

 When data on threshold  levels  for eye  irritation are  insufficient, quarter-
 or  half-mask  respirators can be  used,  provided that  the  worker  experiences
                                    112

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no eye discomfort and no  pathologic eye effects develop.   Workers  should be
told that if any  eye  discomfort is experienced, they  will  be provided  with
respirators  that  have  full  facepieces,  helmets,  or hoods  and  that  provide
protection equivalent  to the quarter- or half-mask  respirators.

Subparagraph 5:   Escape  Apparatus

Escape devices  have a  single  function:   to  allow a person working   in  a
normally safe environment  sufficient  time to escape from suddenly  occurring
respiratory  hazards.

Escape  devices  can  be   separated  into  two  categories:    air-purifying
respirators    and   self-contained    breathing   apparatus.     Air-purifying
respirators  remove contaminants from the air  by sorbent and/or filter media,
but because they  do not  provide air, these  respirators cannot be used in an
oxygen-deficient atmosphere.   Air-purifying  escape  respirators   include  the
escape gas  mask (canister)  respirator,  the  gas mask  (canister) respirator,
and the filter  self-rescuer.  The escape gas  mask consists of  a  half-mask or
a mouthpiece  respirator.   The  mouthpiece  respirator  can be  used  for  short
periods of  time  to  escape from  low concentrations  of  organic vapor  or  acid
gas.  The escape  gas mask,  which utilizes a half-mask,  filters  contaminants
from  the  air.    These   respirators  may  also  be  used to  escape  from  low
concentrations  of  organic vapor or acid gas.   Escape gas  mask respirators
equipped  with   full  facepieces  can  also  be  used  for   escape  from  IDLH
conditions  but   not  from  oxygen-deficient  atmospheres.   No  air-purifying
device   is   suitable   for   escape   from  a  potentially   oxygen-deficient
atmosphere.   The  filter self-rescue unit  is  the mouthpiece device,  which is
designed to protect specifically against less than  1% carbon monoxide.

A self-contained  breathing apparatus  (SCBA)  provides  air  to  the  user  for
escape from oxygen-deficient  environments.   Escape SCBA devices  are commonly
used with full  facepieces  or  hoods  and,  depending  on  the supply  of  air,  are
usually  rated as  3- to  60-minute units.  Self-contained  self-rescuer (SCSR)
devices have been  approved by  MSHA/NIOSH  for escape  from  mines,  but  these
devices may also  have application   in other  similar environments.  SCSR's are
mouthpiece  respirators that  provide a source of oxygen-enriched air  for  up
to 60 minutes.   All SCBA devices can be used  in oxygen-deficient  atmospheres.

When  selecting   escape  apparatus,  careful   consideration  must  be  given  to
potential eye  irritation.   This consideration  is   important  for determining
whether a gas mask  or  SCBA equipped with a  full  fac^piece should be selected
rather than a device equipped with  a half-mask or mouthpiece.

The majority of gas masks  or  escape  gas  masks can be  used in  situations
involving   gas(es),   vapor(s),    or    particulates.     For   escape   from
particulate-contaminated  environments,   an   air-purifying  element   must  be
selected   that   will    provide  protection   against   the   given   type   of
particulate.   The  information   in  Table 4  should  be used   to  select  the
appropriate escape apparatus.
                                      113

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              Table 4.—Selection options for escape respirators
     Escape conditions
                                                  Type of  respirator
Short distance to exit,  no
obstacles (no oxygen deficiency)
Long distance to exi t
or obstacles along the way
(no oxygen deficiency)
Potential oxygen deficiency
                                            Any escape gas mask^  (canister
                                            respirator)    or     gas    mask^
                                            (canister  respirator)

                                            Any     escape     self-contained
                                            breathing    apparatus  having   a
                                            sui table service I i fe^

                                            Any acceptable  device  for  entry
                                            into emergency situations
                                            Any gas
                                            Any escape self-contained
                                            breathing apparatus having a
                                            sui table service 1 i
                                            Any  self-contained  self-rescuer
                                            having a suitable service life

                                            Any     escape     self-contained
                                            breathing   apparatus  having   a
                                            sui table service I i
                                            Any  self-contained  self-rescuer
                                            having a suitable service life
    An escape  gas  mask  is a  respirator designed  for  use during  escape  only
    from   immediately   dangerous   to   life  or  health  (IDLH)  or  non-IDLH
    atmospheres.   It  may consist  of  a  half  mask  facepiece  or  mouthpiece,
    appropriate  air-purifying element  for the  contaminant,  and  associated
    connections.  Maximum use concentrations  for  these  types  of  respirators
    are designated by the manufacturer.
    A gas mask  consists  of  a full  facepiece and  either  chin-style  or front-
    or  back-mounted  canisters  with   associated  connections.   Maximum  use
    concentrations for canister air-purifying elements are listed in Table 5.
    Escape  self-contained  breathing apparatus  can  have  rated  service lives
    of 3  to 60 minutes.   All acceptable  devices  for  entry  into  emergency
    situations  can also be used.
                                   114

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Subparagraph 6:   Potential  Warning Properties for Use With
Cartridge/Canister Air-Purifying Respirators

For  the  purpose  of  this  decision  logic,   warning  properties  are  defined
according  to  odor,   taste,   eye  irritation,   or  respiratory  irritation.
Adequate warning properties  imply that  the  gas  or vapor  of  interest has  a
persistent odor  or  irritant  effect  at  concentrations  at  or below  the  OSHA
PEL  or  NIOSH REL.  Recognition  of an  odor  depends  on  a person's  sensory
ability  to detect  it.   Since the range  of odor  recognition thresholds within
a population is  very large,  odor  recognition should  not be relied on  as  the
only  means  for   determining  that  a  cartridge  or   canister   is  no  longer
effectively removing a contaminant from  the  air.  A more  detailed  discussion
of  variability   of  odor  detection  within  a   population  is   provided  in
Appendix C.

NIOSH  recommends  that  the  employer ensure  that   each  worker  who  is  required
to  wear  an  air-purifying   cartridge  or  canister  respirator  is capable  of
recognizing  the odor of  the substance  of concern at  a concentration at  or
below  the  applicable  exposure limit.   Such  a determination  will  necessitate
that  an  odor  screening   test  be  conducted on each  individual  for  each
substance of concern in the particular workplace.

It  is  recognized  that  existing screening tests  are  subjective  in  nature and
not  sufficiently  sensitive and that conducting   screening  tests for  a  group
of  workers exposed  to several  substances  may  be  impractical.   Therefore,
NIOSH knows of no compelling reason not  to  develop quantitative service  life
test data  to  supplement  or replace odor  screening test  results if it can be
demonstrated  that  such  a procedure  will   afford  the  wearer  a  level   of
protection at  least equivalent  to that  indicated by odor  screening.   Even
when service life test data are used,  the employer and  the respirator wearer
should not  ignore  the  usefulness of sensory detection  properties  (for  those
who  can  detect  the  contaminant's presence)  to  serve as  a warning  that  the
cartridge/canister has  failed or  that  the  integrity of  the  respirator  face
seal has been compromised.

It  is  important   to  realize that  30  CFR 11  [specifically,  30 CFR  11.90(b)
(note 4)  for  gas  masks (canister respirators) and 30 CFR 11.150 (note 7) for
chemical   cartridge   respirators],   which   provides   for   approval    of
air-purifying  (organic  vapor)  devices,  prohibits  their  approval   for  use
against organic  vapors with  poor warning properties  unless there  is  an  OSHA
standard  which  permits  their use.   A  more detailed discussion  appears  in
Appendix C.

A  recent  policy  decision by  NIOSH allows the  use  of  respirators  with
effective  end-of-service-l  ife  indicators  for protection against contaminants
with  poor  warning  properties,  provided  that  certain  conditions  are  met.
These conditions  are described in that  policy statement,  which is reproduced
in Appendix A.
                                     115

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Subparagraph 7:   Limitations of Respirators for Gases and Vapors

Air-purifying   respirators   cannot   be  used  in   IDLH   atmospheres   or   in
atmospheres  containing  less  then  19.5%  oxygen  by   volume.    Gas  masks
(canister  respirators) may  be  used  for  escape  if  the  atmosphere   is  not
oxygen-deficient.

If, after  the APF  is  multiplied by  the  REL  or  other   applicable  exposure
limit  (APF  X REL), the product  exceeds  the IDLH value,  then  the  IDLH value
shall   be  the maximum  use  concentration.    (See  Tables  1,  2,  and   3.)   In
addition,  there  are maximum  use concentrations associated with all  gas  and
vapor air-purifying elements.  (See Table 5.)

Air-purifying devices should not  be  allowed for either  entry  into or escape
from hazardous  environments when  supporting  evidence exists  to demonstrate
that  unreasonably  short   service  life  would  occur  at  the  maximum  use
concentration.

Where  there  is  reason  to  suspect that a  sorbent  has  a high heat of  reaction
with a substance,  use of  that  sorbent   is  not  recommended.   For  such  a
substance, only non-ox idizabIe sorbents should be allowed.

Air-purifying  respirators  cannot  be  used  for  protection against gases  and
vapors  with  poor  warning  properties  unless  the  respirator is  approved  with
an effective ESLI.  (See Appendix A.)

Although  limited  in  number,  there  are  specific  air-purifying   respirators
that are approved by MSHA/NIOSH  for protection against gases  and vapors  when
respirators  approved  for  a  given  class  of   contaminants  (e.g.,  organic
vapors) cannot be used due to sorbent deficiencies.

Subparagraph 8:  Assigned Protection Factors (APF's)

APF's  (sometimes   referred  to  in the  literature  as  respirator  protection
factors),  which  appear   in  the  1975  and  1978 versions  of   the  OSHA/NIOSH
•Respirator Decision Logic,  in the  1980 American  National Standards Institute
(ANSI)   standards   for   respiratory   protection,  and   in  all  OSHA  health
standards, are  based  on  quantitative  fit  testing  (QNFT) of  respirators  [6].
(See definition of  fit  factors  in Appendix D.)  No  data have  been  reported
in  the literature to demonstrate that the  results  of QNFT are sufficiently
indicative   of  the  protection   that  a  given  respirator provides   in  the
workplace.   Recent  studies  by NIOSH [7-9]  and  others  [10-12] have suggested
that  fit  factors  do  not  correlate  with  the  workplace  protection  factors
provided  by  powered air-purifying  respirators  (PAPR's)  and negative  pressure
half-mask  respirators.   (See  definition  of workplace  protection  factors in
Appendix  D.)
                                      116

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  Table 5.—NIOSH recommended maximum use concentrations (expressed in ppm)
                  for  gas and  vapor air-purifying elements
Class!

Type of gas or vapor
Organic vapors
Acid gases
Sulfur dioxide ($02)
Chlorine (C^)
Hydrochloric (HCI)
Ammonia (N^)
Methyl amine (CH3NH2)
Carbon monoxide (CO)
fi cat ion of gas

Cartridge(s)
1,000*
50
10
50
300
100
NA
and vapor ai

Chin-style
canister
5,000t
100
25
100
500
—
NA
r-purifying elements
Front- or
back-mounted
canister
20,000t
100
25
100
500
—
1,500
* Maximum use  concentration  will be  1,000 ppm or the  immediately  dangerous
  to life or health  (IDLH)  value for the  specific  organic vapor,  whichever
  is lower.
t Maximum use concentration  for  "entry  into"  will  be  limited  to  the  value
  listed or  to the  IDLH value  for  the specific organic vapor, whichever  is
  I owe r.
                                    117

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APF's  that  are  still  based  on  the  fit  factors  determined  by  Los  Alamos
National  Laboratories  (LAND  can  be  used  for  those  classes  of  respirators
for which  no  WPF data  or  simulated workplace protection  factor  (SWPF)  data
are available.   However,  as  WPF  data  are  developed,  these  APF's will  be
revised,  as  have  the  current  APF's   for  powered air-purifying  respirators
(PAPR's)   [7-9,11,14-16].    It  should  be  noted  that  a  number  of  studies
[17-20] on  the  workplace  performance  of  respirators have  appeared  in  the
literature.   However, the  results  of  these studies are of  little  value  for
establishing  APF's  because  their  protocols  did not  require  proper  fit  or
correct use and  conscientious  wearing of  the respirator  while  in-facepiece
sampling  was done.   A notable exception is the study  by Revoir  (1974) [21].

When WPF  data existed,  NIOSH  utilized the point estimate  equation proposed
by  Myers  et  al.   [13]  to  help  establish  the  APF's  recommended  in  this
decision  logic.   The point  estimate equation is as  follows:

                     protection factor (PF) =//g/SgzP

       where   /Ig  = the geometric mean of the measured WPF

                Sg  = the geometric standard deviation  of  the measured WPF

                Zp  = the value corresponding to the  selected proportion
                     (p) on the log-normal probability distribution

When WPF  data  existed,  NIOSH  selected  a  confidence  limit  of  p=0.95.   Thus
for a  given set of data and  given class of  respirators,  NIOSH  would  expect
that 95%  of the WPF's would exceed the calculated point estimate  value.

Despite the fact that  some of the  PF's  have a  statistical  basis,  they  are
still only  estimates of  an approximate level of protection.   It  must  not be
assumed that  the numerical values  of  the  APF's presented  in  this  decision
logic  represent the  absolute  minimum  level of  protection  that  would  be
achieved  for  all workers  in all jobs against  all  respiratory  hazards.   The
industrial   hygienist   or   other  professional  responsible   for   providing
respiratory  protection   or evaluating  respiratory  protection  programs  is
therefore  encouraged  to  evaluate  as  accurately  as  possible  the  actual
protection being provided by the respirator.

Subparagraph 9:  Particulate Filter Respirators

MSHA/NIOSH  particulate  respirators are  certified  according to  seven  basic
categories.  These  categories consist  of the following types of exposures:
                                    118

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   • Dusts:   Airborne  exposure  limit  not less than 0.05 mg/m3  or  2  mppcf
     (see Appendix  B);

   • Fumes:   Airborne  exposure  limit  not less than 0.05 mg/m3  or  2  mppcf;

   • Mists:   Airborne  exposure  limit  not less than 0.05 mg/m3  or  2  mppcf
     (see Appendix  B);

   • Dusts,  Fumes,  and Mists:   Airborne exposure limit less  than
     0.05 mg/m3 or  2 mppcf  and  radionuclides;

   • Radon Daughters;

   • Asbestos-Containing Dusts  and Mists (see Appendix B);  and

   • Single-Use Dust and Mist Respirators (see Appendix B).

Subparagraph 10:   Suggested  Medical  Evaluation  and Criteria  for  Respirator
Use

The  following  NIOSH  recommendations allow  latitude  for  the  physician  in
determining  a  medical  evaluation  for   a  specific situation.   More  specific
guidelines  may become  available  as  knowledge  increases   regarding  human
stresses  from  the  complex interactions of worker  health status,  respirator
usage, and job  tasks.   While  some of  the  following  recommendations should  be
part  of  any medical  evaluation  of workers who wear  respirators,  others  are
identified as being applicable  for specific situations.

   a. A  Physician   Should  Make  the  Determination  of  Fitness   to   Wear  a
   Respirator  by  Considering  the  Worker's Health,  the Type  of  Respirator,
   and the Conditions  of Respirator Use.

   The  recommendation  above satisfies  OSHA regulations and leaves the  final
   decision  of  an   individual's  fitness to wear  a respirator to  the person
   who  is  best  qualified  to   evaluate  the  multiple  clinical   and  other
   variables.   Much of  the  clinical  and other  data  could  be gathered  by
   other personnel.   It  should be emphasized  that the  clinical  examination
   alone   is   only  one   part  of  the   fitness  determination  and   that
   collaboration with   foremen,  industrial hygienists,  and  others may  often
   be  needed  to better assess  the  work  conditions  and other  factors  that
   affect an individual's fitness to  wear a respirator.

   b. A  Medical  History  and   At  Least  a Limited  Physical  Examination  are
   Recommended.

   The  medical  history   and   physical  examination  should   emphasize  the
   evaluation of the cardiopulmonary  system and should  elicit  any  history  of
   respirator  use.  The history  is  an  important  tool  in medical  diagnosis
   and  can  be  used  to  detect  most  problems  that   might  require  further
                                   119

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evaluation.  Objectives of  the  physical  examination should be  to  confirm
the  clinical  impression  based  on  the  history  and  to detect  important
medical  conditions  (such  as  hypertension)  that  may   be   essentially
asymptomat ic.

c. While  Chest  X-Ray  and/or  Spirometry  May  Be  Medically  Indicated  in
Some Fitness Determinations, These Should Not Be Routinely Performed.

In  most  cases,  the  hazardous  situations   requiring   the   wearing  of
respirators will  also  mandate periodic  chest  X-ray  and/or  spirometry for
exposed workers.  When  such information is  available,  it  should  be used
in  the  determination  of  fitness to wear respirators.  (See Recommendation
h, page 33.)

Routine chest  X-rays and  spirometry  are  not  recommended  solely  as data
for  determining  if a  respirator  should be worn.   In most  cases,  with an
essentially normal clinical examination  (history and physical)  these data
are   unlikely   to   influence   the   respirator   fitness   determination;
additionally,   the X-ray  would  be  an  unnecessary source  of  radiation
exposure  to  the  worker.   Chest  X-rays  in  general   do  not  accurately
reflect  a  person's  cardiopulmonary   physiologic   status,   and  limited
studies suggest  that mild  to moderate  impairment  detected by spirometry
would not preclude the wearing  of  respirators in most  cases.   Thus  it is
recommended  that  chest   X-ray  and/or  spirometry  be  done  only  when
clinically  indicated.   (See Appendix  E,  page  52,   for  further  discussion
on  the  pulmonary effects of wearing respirators.)

d. The  Recommended Periodicity  of  Medical  Fitness  Determinations Varies
According  to Several Factors but Could Be as Infrequent as Every 5 Years.

Federal or other  applicable  regulations  shall  be  followed  regarding the
frequency  of  respirator  fitness determinations.   The  guidelines for most
work  conditions for  which respirators are required  are  shown  in Table 6.
These   guidelines   are  similar  to   those  recommended  by  ANSI,  which
recommends  annual  determinations after  age 45  [22].   The more  frequent
examinations  with advancing  age  relate  to  the  increased  prevalence of
most   diseases    in   older   people.     More    frequent    examinations  are
recommended  for  individuals  performing  strenuous  work  involving  the use
of  SCBA.   These guidelines are based  on clinical  judgment and,  like the
other   recommendations in  this  section, should  be adjusted as  clinically
 indicated.

e.  The Respirator Wearer Should  Be   Observed  During   a  Trial  Period to
Evaluate  Potential Physiological Problems

 In  addition to considering the physical  effects  of wearing  respirators,
 the physician  should determine  if wearing  a given respirator would  cause
extreme anxiety or claustrophobic reaction  in  the  individual.   This  could
be  done during training, while  the worker is wearing  the  respirator and
                                120

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   is  engaged  in some  exercise  that  approximates  the  actual work  situation.

   Present   regulations   state  that   a   worker   should   be   provided   the
   opportunity  to  wear the  respirator  "in  normal  air for a  long familiarity
   period..."  [23].   This trial period should  also  be used  to  evaluate  the
   ability  and tolerance  of the  worker  to wear  the respirator  [24].   This
   trial  period need  not  be  associated  with  respirator  fit  testing  and
   should   not   compromise  the   effectiveness  of   the   vital   fit   testing
   procedure.

       Table 6.—Suggested frequency of medical fitness determinations*


                                          Worker  age (years)
                              <35               35 -  45            >45
   Most  work  condi-         Every 5 yrs         Every  2  yrs        1-2 yrs
   tions requiring
   respi rators


   Strenuous  work           Every 3 yrs         Every  18 mos       Annually
   condi tions wi th
   SCBAt


* Interim testing would be needed if changes  in health status  occur.
t SCBA = self-contained breathing apparatus

   f.  Examining  Physicians  Should Realize  that the  Main Stress of Heavy
   Exercise While Using a  Respirator  Is Usually on  the Cardiovascular System
   and  that  Heavy  Respirators  (e.g.,   Self-Contained Atmosphere  Supplying)
   Can Substantially Increase this  Stress.   Accordingly, Physicians May  Want
   To  Consider  Exercise  Stress  Tests  with  Electrocardiographic  Monitoring
   When   Heavy  Respirators  Are  Used,  When  Cardiovascular  Risk Factors  Are
   Present,  or  When  Extremely Stressful  Conditions Are Expected.

   Some  respirators  may weigh up  to 35  pounds and may  increase workloads  by
   20  percent.   Although  a  lower  activity  level could  compensate  for  this
   added stress [25],  a  lower  activity level might not  always  be possible.
   Physicians should also be aware  of  other  added  stresses,  such  as heavy
   protective clothing  and  intense ambient  heat, which would  .increase  the
   worker's  cardiac  demand.  As  an  extreme  example,  firefighters  who  use
   SCBA   inside  burning  buildings  may  work at  maximal  exercise  levels under
   life-threatening   conditions.    In  such  cases,  the detection  of occult
   cardiac disease,  which  might  manifest  itself during heavy stress, may  be
   important.  Some  authors have  either  recommended  stress  testing  [26]  or
                                   121

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at   least    its   consideration   in   the   fitness  determination   [22].
KiIbom [26]  has  recommended  stress  testing  at  5-year  intervals  for
firefighters below age  40  who use SCBA and  at  2-year  intervals for those
aged 40-50.  He further suggested that firemen over age 50  not  be allowed
to wear SCBA.

Exercise stress  testing has  not been  recommended for medical  screening
for coronary artery disease in the general  population  [27,28].   It  has an
estimated  sensitivity  and  specificity of 78% and  69%,  respectively,  when
the  disease is  defined by  coronary angiography  [27,29].   In a  recent
6-year prospective  study,  stress  testing  to determine  the potential  for
heart  attack  indicated a  positive  predictive  value of  27%  when  the
prevalence   of   disease was  3 1/2%  [30,31].   While   stress  testing  has
limited  effectiveness   in  medical  screening,  it  could   serve  to  detect
those  individuals  who  may not  be  able  to  complete  the  heavy  exercise
requi red in some jobs.

A definitive  recommendation  regarding exercise  stress testing  cannot be
made  at  this  time.    Further  research  may  determine  whether  this  is  a
useful tool  in selected circumstances.

g.   An   Important   Concept   Is   that  "General   Work   Limitations   and
Restrictions  Identified for  Other  Work Activities Also  Shall  Apply  for
Respirator  Use" [22].

In  many  cases,  if  a  worker  is  able to  do  an  assigned  job without  an
increased  risk  to  health  while not wearing  a  respirator,  the worker will
in most situations not  be  at  increased  risk when  performing  the  same  job
while wearing a respirator.

h.   Because of   the   Variability  in  the  Types  of   Respirators,  Work
Conditions,  and Workers'  Health  Status,  Many  Employers  May  Wish  to
Designate  Categories   of  Fitness To  Wear Respirators, Thereby  Excluding
Some  Workers  from  Strenuous  Work  Situations  Involving  the Wearing  of
Respirators.

Depending   on    the   various  circumstances,   there   could  be   several
permissible  categories of respirator usage.  One  possible  scheme  would
consist  of three overall  categories:  full  respirator  use, no  respirator
use, and limited respirator use  including "escape  only"  respirators.   The
 latter   category   excludes   heavy   respirators   and   strenuous   work
conditions.   Before identifying  the conditions  that   would  be  used  to
classify   workers  into  various  categories,  it  is  critical   that  the
physician  be aware  that these conditions have not been validated  and  are
presented  only  for  consideration.   The  physician should modify the use of
 these  conditions  based  on  actual  experience,  further  research,  and
 individual   worker  sensitivities.   The physician may wish  to  consider  the
 following  conditions in selecting or permitting the use of  respirators:
                                  122

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       • History of spontaneous pneumothorax;

       • Claustrophobia/anxiety reaction;

       • Use of contact lens (for some respirators);

       • Moderate or severe pulmonary disease;

       • Angina pectoris,  significant arrhythmias,  recent myocardial
         infarction;

       • Symptomatic or uncontrolled hypertension;  and

       • Age.

   It seems  unlikely that  wearing  a  respirator would  play any  significant
   role  in causing  lung damage such as pneumothorax.  However, without  good
   evidence  that wearing  a  respirator would not cause such  lung  damage,  it
   may  be  prudent   to  prohibit  the  individual  with a history  of  spontaneous
   pneumothorax from wearing a respirator.

   Moderate  lung  disease  is  defined  by  the  Intermountain  Thoracic  Society
   [32]  as   being  a forced  expiratory volume   in  one second  (FEV-|)  divided
   by the  forced vital  capacity  (FVC)  (i.e.,  FEV-|/FVC)  of  0.45   to  0.60  or
   an FVC of  51  to 65% of the predicted FVC value.  Similar  arbitrary limits
   could be  set  for age  and  hypertension.  It  would seem more   reasonable,
   however,  to combine several  risk  factors   into  an  overall  estimate  of
   fitness to  wear  respirators  under certain conditions.  Here the  judgment
   and clinical experience  of  the  physician are needed.  Even many  impaired
   workers would be  able  to  work  safely while  wearing  respirators  if  they
   could control  their own  work pace,  including  having sufficient  time  to
   rest.

Conclusion

Individual   judgment  is   needed  in  determining  the  factors   affecting  an
individual's  fitness to  wear a  respirator.    While  many of  the preceding
guidelines  are based  on   limited  evidence,  they  should  provide a  useful
starting point  for  a respirator  fitness screening  program.   Further  research
is needed to validate these recommendations and others currently  in  use.   Of
particular  interest  would  be laboratory  studies  involving  physiologically
impaired  individuals and   field  studies  conducted under  actual   day-to-day
work condi t ions.
                                     123

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44.  Love  RG, Muir  DCF,  Sweetland  KF,   Bentley  RA, Griffin  OG.   Acceptable
    levels for  the  breathing  resistance  of respiratory apparatus:   results
    for men over the age of  45.   Br  J  Ind Med 1977;34:126-29.

45.  Deno  NS,  Kamon  E,   Kiser   DM.   Physiological  responses  to   resistance
    breathing during  short  and  prolonged  exercise.   Am  Ind Hyg  Assoc  J
    1981;42(8):616-23.

46.  Raven  PB,   Davis  TO,  Shafer  CL,   Linnebur  AC.    Maximal  stress   test
    performance  while wearing a  self-contained  breathing apparatus.   J  Occup
    Med 1977;19(12):802-06.

47.  Craig FN, Blevins WV, Cummings  G.   Exhausting  work  limited by  external
    resistance   and  inhalation   of    carbon   dioxide.    J   Appl   Physiol
    1970;29(6):847-51.

48.  Stemler FW,  Craig FN.   Effects  of   respiratory equipment on endurance  in
    hard work.   J  Appl  Physiol  1977;42:28-32.

49.  Myhre LG, Holden RD, Baumgardner  FW, Tucker D.  Physiological  limits  of
    firefighters.   Air Force School  of Aerospace  Medicine,  Brooks AFB,  TX,
    ESL-TR-79-06,  1979.

50.  James R, Dukes-Dobos F,  Smith R.   Effects  of respirators  under  heat/work
    conditions.   Am Ind  Hyg  Assoc J  1984:45(6) -.399-404.

51.  Hermansen L, Vokac Z,  Lereim P.   Respiratory and circulatory  response  to
    added air flow resistance during exercise.   Ergonomics  1972;15(1):15-24.

52.  Meyer  E,  Gurtner  HP,  Scherrer  M.  Physiological  appraisal  of  a  new
    respirator with  positive pressure.   Pneumonology 1975;153:61-72.

53.  Dahlback GO, Balldin Ul .   Physiological  effects of pressure demand  masks
    during heavy exercise.   Am Ind Hyg  Assoc J  1984;45(3):177-181.
                                    127

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54. Arborelius M,  Dahlback GO, Data  P-G.   Cardiac  output  and gas  exchange
    during heavy  exercise  with  a  positive  pressure  respiratory  protective
    apparatus.  Scand J Work Environ Health 1983;9:471-477.

55. Bjurstedt  H,  Rosenhamer  G,   Lindborg  B,  Hesser  CM.   Respiratory  and
    circulatory  responses  to  sustained  positive-pressure   breathing  and
    exercise  in man.  Acta Physiol  Scand 1979;105:204-14.

56. Black LF,  Hyatt  RE.   Maximal   respiratory  pressures:   normal   values  and
    relationship to age and sex.   Am Rev Respir Dis 1969;99:696-702.

57. Bates DV,  Macklem  PT,  Christie RV.  Respiratory function  in disease:   an
    introduction to  the  integrated study of  the  lung,  2nd ed,  Philadelphia:
    W.B. Saunders Co., 1971, p. 43.

58. Raven PB,  Bradley  0,  Rohm-Young D, McClure FL,  Skaggs  B.   Physiological
    response  to "pressure-demand"  respirator  wear.   Am  Ind  Hyg  Assoc  J
    1982;43(10):773-81.

59. Harber P,  Tamimie  RJ,  Bhattacharya A,  Barber  M.   Physiologic  effects of
    respirator   dead   space   and   resistance    loading.    J   Occup   Med
    1982;24(9):681-84.

60. Petsonk   EL,   Hancock   J,   Boyles   C.    Physiologic   effects   of   a
    self-contained  self-rescuer.  Am  Ind Hyg Assoc J 1983;44(5):368-73.

61. Morgan   WP.   Psychological  problems  associated  with  the  wearing  of
    industrial  respirators:  a review.  Am Ind Hyg Assoc J 1983;44(9) :671-76.

62. Morgan   WP.   Psychological    problems   associated  with   the  wear   of
    industrial  respirators.  J Int  Soc Respir Prot 1983;1:67-108.

63. Ronk   R,  White   MK.    Hydrogen  sulfide  and   the  probabilities   of
    "inhalation"   through  a  tympanic   membrane  defect.     J   Occup  Med
    1985;27(5):337-40.

64. Cantekin  El,  Bluestone  CD,   Saez CA,  Bern  SA.    Airflow through  the
    eustachian tube.   Ann  Otol 1979;88:603-612.

65. daRoza   RA,  Weaver   C.    Is   it   safe  to  wear  contact   lenses  with  a
    full-facepiece   respirator?     Lawrence  Livermore   National   Laboratory
    manuscript UCRL-53653,  1985, pp.  1-3.
                                     128

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                                 IV.  GLOSSARY

The  following  definitions  of   terms  are  provided   to   assist   in   the
understanding and application of  this decision logic.

ASSIGNED PROTECTION FACTOR (APF):  See PROTECTION FACTOR.

BREAKTHROUGH:  The  penetration of challenge  material(s) through a gas  or  a
vapor air-purifying element.   The  quantity or extent of  breakthrough  during
service  life testing   is  often  referred  to as  the  percentage  of  the  input
concentration.

DISPOSABLE RESPIRATORS:   A respirator  that is  discarded after  the  end  of
its  recommended  period  of  use,  after  excessive   resistance  or  physical
damage, or when odor   breakthrough  or  other  warning  indicators  render  the
respirator unsuitable  for further use.

DUST:   A  solid,  mechanically  produced  particle  with  a size  ranging  from
submicroscopic to macroscopic.

EMERGENCY RESPIRATOR  USE SITUATION:    A situation that  requires  the use  of
respirators due to  the unplanned generation of a hazardous  atmosphere (often
of unknown composition)  caused by  an accident,  mechanical  failure, or  other
means  and that   requires  evacuation  of  personnel  or  immediate entry  for
rescue or corrective action.

ESCAPE  GAS  MASK:    A  gas  mask  that  consists of  a  half-mask  facepiece  or
mouthpiece, a canister,  and  associated connections and  that  is  designed for
use during escape only from hazardjus atmospheres (see Subparagraph 5).

ESCAPE  ONLY   RESPIRATOR:   Respiratory  devices  that are designed  for  use
only during escape from hazardous atmospheres.

FILTERING  FACEPIECE:     A   particulate  respirator  with  a  filter  as  an
integral part of  the  facepiece or  with the entire facepiece  composed of the
filtering  medium.   (See  SINGLE-USE  DUST  or DUST and  MIST  RESPIRATORS and
DISPOSABLE RESPIRATORS.)

FIT  FACTOR:   A quantitative  measure  of  the  fit  of  a  specific  respirator
facepiece  to  a  particular   individual.   (For   further discussion  of  fit
factors, refer to Appendix D.)

FUME:  A solid condensation particulate, usually of a vaporized  metal.

GAS:  An  aeriform  fluid  that   is  in  a  gaseous  state  at  standard  temperature
and pressure.

IMMEDIATELY   DANGEROUS  TO  LIFE  OR   HEALTH   (IDLH):   Acute   respiratory
exposure  that poses  an  immediate   threat  of  loss   of   life,  immediate  or
                                      129

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delayed irreversible adverse  effects  on health,  or  acute  eye  exposure  that
would prevent escape from a hazardous atmosphere.

MIST:  A liquid condensation particle.

ORINASAL RESPIRATOR:   A respirator  that  covers  the nose and mouth  and  that
generally consists of a quarter- or half-facepiece.

PLANNED or  UNPLANNED  ENTRY  into  an  IDLH  ENVIRONMENT,  AN  ENVIRONMENT  OF
UNKNOWN CONCENTRATION of HAZARDOUS CONTAMINANT,  or  an ENVIRONMENT of UNKNOWN
COMPOSITION:   A  situation   in which  respiratory devices are  recommended  to
provide  adequate   protection  to   workers   entering  an  area   where   the
contaminant  concentration is above the IDLH or is  unknown.

POTENTIAL  OCCUPATIONAL  CARCINOGEN:    Any  substance,   or   combination   or
mixture of substances,  which  causes  an increased incidence of  benign and/or
malignant neoplasms, or a substantial decrease in the  latency  period between
exposure and onset  of  neoplasms   in  humans  or in  one  or  more experimental
mammalian  species  as  the  result  of  any  oral,   respiratory,   or  dermal
exposure,  or any  other  exposure which  results  in the  induction of tumors at
a site other than the site of administration.  This  definition  also  includes
any  substance  that  is  metabolized into  one  or  more potential  occupational
carcinogens  by mammals (29 CFR 1990.103, OSHA Cancer Policy).

PROTECTION FACTORS (See Appendix D):

    ASSIGNED PROTECTION  FACTOR  (APF):    The  minimum anticipated  protection
    provided by  a properly functioning respirator or class of  respirators to
    a given  percentage of properly fitted and trained users.

    SIMULATED WORKPLACE  PROTECTION FACTOR  (SWPF):   A  surrogate   measure  of
    the workplace protection provided by a respirator.

    WORKPLACE   PROTECTION   FACTOR  (WPF):   A  measure  of   the   protection
    provided  in  the  workplace by a  properly functioning   respirator  when
    correctly worn and used.

RECOMMENDED  EXPOSURE LIMIT (REL):  An 8- or 10-hour  time-weighted average
(TWA)  or  ceiling  (C)  exposure concentration  recommended  by  NIOSH  that  is
based on an  evaluation of  the health effects data.

SERVICE  LIFE:   The  length  of time  required  for  an  air-purifying element to
reach  a  specific effluent   concentration.   Service  life  is determined by the
type  of substance  being  removed,  the concentration  of  the  substance,  the
ambient  temperature,   the  specific   element   being  tested   (cartridge  or
canister),  the  flow rate  resistance,  and the selected breakthrough value.
The  service  life for  a  self-contained  breathing   apparatus  (SC8A)  is  the
period  of   time,  as  determined  by  the NIOSH  certification   tests,   in which
adequate breathing gas  is  supplied.
                                     130

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SINGLE-USE  DUST  or  DUST  AND  MIST  RESPIRATORS:   Respirators  approved  for
use against dusts or  mists that may cause pneumoconiosis and fibrosis.

VAPOR:    The gaseous  state  of  a  substance  that   is  solid  or  liquid  at
temperatures and  pressures normally encountered.
                                     131

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                                V. APPENDICES

              APPENDIX A.   NIOSH POLICY STATEMENT ON APPROVAL OF
        AIR-PURIFYING  RESPIRATORS WITH  END-OF-SERVICE-LIFE  INDICATORS

                   Department of Health and Human Services
                             Pub Iic Health Service
                          Centers for Disease Control
            National  Institute  for Occupational  Safety and  Health

    NIOSH/MSHA TESTING AND CERTIFICATION OF  AIR-PURIFYING RESPIRATORS WITH
                        END-OF-SERVICE-LIFE  INDICATORS

Agency:   National Institute for Occupational  Safety and  Health (NIOSH)

Action:   Notice of Acceptance  of  Applications  for Approval of Air-Purifying
          Respirators with End-of-Service-Life Indicators

Summary:  30  CFR 11;  Sec.  11.150  states that  NIOSH and  MSHA may,  after  a
review of the  effects  on  wearers'  health and  safety, approve respirators for
gases  and  vapors  not  specifically  listed   in   that section.   The  current
regulations  also  permit  the use of "window  indicators"  for gas masks to warn
the  wearer  when   the  canister  will  no   longer  remove   a  contaminant
[11.102-5(c)(2)].   Although  indicators  are  not  mentioned  in  Subpart  L,
Chemical Cartridge  Respirators,  there  is  nothing  in  the  regulations  which
explicitly prohibits  their  use.   A NIOSH policy to allow end-of-service-life
indicators (ESLI's) on air-purifying  respirators  for gases and vapors  with
adequate  warning  properties has  already  been  established  (Letter  to  All
Respirator Manufacturers  from Dr. Elliott Harris, June 18, 1975).

Use of  ESLI's  on chemical  cartridge  respirators  for  use against  gases  and
vapors  with   poor   warning  properties  could  also  be  approved,  because
30 CFR 11; Sec.  11.150; footnote 7 states:

   "Not for use  against gases or vapors with poor  warning properties (except
   where MSHA  or Occupational  Safety and Health Administration standards may
   permit such use  for  a  specific gas  or  vapor)...."   Thus,  air-purifying
   respirators   with   ESLI's  could   be  approved   for  substances  such  as
   acrylonitrile, because the OSHA aerylonitrile standard  permits  the use of
   chemical  cartridge  respirators.

Under  the  present   regulations,  NIOSH  can  also  require  "any  additional
requirements deemed  necessary  to  establish  the quality,  effectiveness,  and
safety  of  any  respirator used as protection  against hazardous atmospheres"
[30 CFR 11; Sec.  11.63 (c)].  NIOSH must notify  the  applicants  in  writing of
these  additional  requirements [30 CFR 11; Sec. 11.63  (d)].

The  purpose  of  this  notification  is  to  inform  respirator manufacturers and
users  of the NIOSH  requirements  for  approving  air-purifying respirators with
                                      132

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either effective passive  or  active  ESLI's for use  against  gases and  vapors
with  adequate  warning  properties or  for use  against  gases and  vapors  with
inadequate  warning  properties  whenever  there  is  a  regulatory   standard
already permitting the  use of air-purifying respirators.

For   additional   information,    contact:    Chief,   Certification   Branch,
944 Chestnut Ridge Road,  Morgantown, WV 26505,  (304) 291-4331.

Supplemental Information

Because human  senses  are  not  foolproof  in  detecting  gases and  vapors  and
because many  gases and  vapors  found  in  the workplace do  not  have adequate
warning  properties,  NIOSH  has   been  investigating  alternate   means   of
detection for  respirator  wearers.   In 1976,  NIOSH adopted its  current policy
which allows  acceptance  of  applications  for certification of  air-purifying
respirators,  provided  that  the  respirators  are  equipped with  active ESLI's
for use against  gases  and vapors with poor  warning  properties and  are  not
specifically  listed in  30 CFR 11.

An  active   ESLI  is defined  as an  indicator  that  invokes  an  automatic  and
spontaneous warning signal (e.g.,  flashing lights,  ringing  bells,  etc.).   An
active  indicator  does   not  require  monitoring  by  the  wearer  although  a
passive indicator (normally color change indicator) does.

During the  past  several  years, NIOSH has received  notices of  concern  from
respirator   manufacturers,   regulatory  agencies,   and    general   industry
regarding   the   Institute's  policy  of  accepting  only  active  ESLI's  for
certification.   At the  October  1983  Mine Health Research Advisory  Council
(MHRAC) meeting,  NIOSH  presented  a document  briefing  on  "Consideration  of
Use  of End-of-Service-Life  Indicators  in  Respiratory Protective  Devices,"
and  requested  that  MHRAC  provide  recommendations  to   the  Institute  with
regard to  the appropriateness  of  the  use  of  both active  and passive ESLI's.
MHRAC asked their Respirator Subcommittee to review the issue.

The  Respirator  Subcommittee held  a public  meeting  in Washington,  D.C.,  on
December  19,   1983,  to  solicit  comments  from   interested  parties.   The
Subcommittee  reviewed   the  comments   and  then  reported  back   to  the  full
committee  at  the February  2, 1984,  MHRAC  meeting.   Based  on the  public
comments, the  Subcommittee also  suggested a few additions  or  modifications
be  made  to  the  NIOSH  proposed evaluation criteria.   NIOSH incorporated the
recommendations.   MHRAC  also recommended that active and passive ESLI's  are
appropriate   for  use  with  respiratory  protective  devices  provided  that
criteria are  established  for their  certification and use to ensure that the
user  is  not exposed to  increased  risk as  a  consequence of relying upon such
ESLI's.

In  order  for  NIOSH  to  determine  the potential  effects  of  ESLI's  on  user
safety and  health, NIOSH  recommends  that all  applications for  approval  of
gas and vapor  respirators with ESLI's  contain  the following information:
                                     133

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         CRITERIA FOR CERTIFICATION OF END-OF-SERVICE-LIFE INDICATORS

An applicant  for certification of  an ESLI  for  use against  substances  with
poor warning properties must provide NIOSH with the following information:

   1. Data demonstrating  that  the  ESLI  is a  reliable  indicator of  sorbent
   depletion   (< 90%   of   service    life).     These    shall    include   a
   flow-temperature  study  at  low  and high   temperatures,  humidities,   and
   contaminant concentrations  which are  representative  of  actual  workplace
   conditions where  a  given  respirator  will  be  used.    A  minimum  of   two
   contaminant levels must  be  utilized:   the exposure  limit  (PEL,  REL, TLV®,
   etc.) and the  exposure limit multiplied by  the  assigned protection  factor
   for the respirator type.

   2. Data  on desorption of any  impregnating  agents used in  the  indicator,
   including  a   flow-temperature  study  at  low  and  high  temperatures   and
   humidities which  are representative of actual  workplace  conditions where
   a given respirator will  be used.  Data shall be  sufficient  to demonstrate
   safe levels of desorbed agents.

   3. Data  on  the  effects  of industrial  interferences  which  are  commonly
   found  in workplaces  where a given  respirator will be  used.  Data  should
   be sufficient  to  show which interferences  could  impair  the  effectiveness
   of the indicator  and  the degree of impairment, and which  substances  will
   not affect the indicator.

   4. Data  on any  reaction products  produced  in  the  reaction between  the
   sorbent   and    the   contaminant    gases   and   vapors,   including    the
   concentrations and toxicities of such products.

   5. Data  which  predict   the storage  life  of  the  indicator.   (Simulated
   aging  tests will be acceptable).

 In addition  to  the  foregoing,   all  passive ESLI's  shall  meet  the  following)
 cri teria:

   1. A  passive  ESLI shall   be  placed  on  the respirator  so  that the  ESLI  iss
   visible to the wearer.

   2. If  the  passive  indicator utilizes  color change,  the  change  shall  be
   such  that  it   is  detectable to  people  with physical   impairments  such  as
   color  bl indness.

   3. If  the  passive indicator utilizes  color  change,  reference colors  for
   the  initial color of the indicator and the final (end point) color of the
   indicator shall be placed adjacent  to the indicator.
                                      134

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All ESLTs shall  meet  the following criteria:

   1. The ESLI  shall  not interfere with the effectiveness  of  the face seal.

   2. The ESLI shall  not change the weight distribution of  the  respirator  to
   the detriment  of  the facepiece fit.

   3. The ESLI  shall  not interfere with required  lines  of  sight.

   4. Any  ESLI  that  is  permanently  installed  in  the  respirator  facepiece
   shall   be  capable of  withstanding cleaning and  a drop  from a height  of
   6 feet.  Replaceable  ESLI  must  be capable of  being   easily removed  and
   shall  also be  capable of  withstanding a drop  from a  height  of 6 feet.

   5.  A   respirator  with  an  ESLI   shall   still  meet  all  other  applicable
5.  A   respirator  with  an  cbLi   sn
requirements set  forth in 30 CFR 11.
   6. If the ESLI uses any  electrical  components,  they shall conform  to  the
   provisions of  the  National  Electrical  Code and be  "intrinsically  safe."
   Where  permissibility   is   required,   the   respirator   shall   meet   the
   requirements   for   permissibility  and  intrinsic safety  set   forth  in  30
   CFR 18,   Subpart   D.    Also,  the  electrical  system  shall   include   an
   automatic warning  mechanism that indicates a loss of power.

   7.  Effects  of  industrial  substances  interferences which  are  commonly
   found where   a  given  respirator  will   be   used  and  which   hinder  ESLI
   performance,   shall  be  identified.   Substances which  are commonly  found
   where the respirator  is to be used must be  investigated.  Data  sufficient
   to  indicate whether  the  performance  of  the respirator would be  affected
   must  be   submitted  to  NIOSH.   The  user   shall  be  made aware   of   use
   conditions that could  cause false positive and  negative  ESLI  responses.

   8. The ESLI  shall  not  create any hazard to the  wearer's  health or  safety.

   9. Consideration  shall  be  given  to the  potential   impact of common human
   physical  impairments  on the effectiveness of the ESLI.
                                  135

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      APPENDIX B.   NIOSH  POLICY  STATEMENT ON USE OF SINGLE-USE  AND  DUST
             AND MIST RESPIRATORS FOR PROTECTION AGAINST ASBESTOS

                      June 21,  1984,  OSHA Public Hearings

Under Title 30,  Code  of Federal  Regulations, Part  11  (30 CFR  11),  NIOSH  is
required  to  test  and  certify  respirators  within  the  categories  specified
therein when such  devices are submitted to NIOSH by  applicants.   Currently,
30 CFR' 11,  Subpart  K defines a  number of  dust, fume,  and  mist  respirators
which may be  used   for  protection  against  certain  hazardous  particulate
atmospheres.    Among  the  respirators  defined in Subpart K are single-use dust
respirators designed as respiratory protection against pneumoconiosis-
producing and  fibrosis-producing  dusts,  or  dusts and mists.   Subpart K lists
asbestos as one of the dusts against which  the single-use  dust  respirator  is
designed  to  protect  [Subpart  K,  Sec.  11.130CH)].   Although at  the time  of
the promulgation of Subpart K,  it  may have  been assumed  appropriate to list
asbestos  as  a fibrosis-producing particulate  against which  the single-use
disposable  respirator  could   be   reasonably  expected  to  provide  adequate
protection,  NIOSH  is  no  longer  confident  that   such  an  assumption  is
reasonable because asbestos is also a potent carcinogen.

The  current  requirements  as   (specified  in 30  CFR  11)   for  approval  of  a
single-use dust  respirator or  dust  and mist  respirator  do  not  include any
tests with fibrous  challenge  aerosol.   NIOSH is currently  in  the process  of
doing a  comprehensive revision of 30 CFR 11 and intends to address  the issue
of  appropriate  respiratory  protection  for  use against  asbestos,  and  to
require  that   any  respirator  for  which such approval  is  sought be proven  to
provide   effective  protection  against  asbestos.    NIOSH  may  change  the
regulations  included  in  30  CFR  11 only  in  accordance with  procedures  set
forth  in  the  Administrative  Procedures  Act.   In  the  interim,   NIOSH  will
continue  to  consider  applications for approval of single-use and replaceable
dust/mist  respirators  for  use  against asbestos  only  because  of  the  legal
requirement  in  the  current  approval  regulations.   However, NIOSH  does  not
recommend the  use  of  such  respirators where exposures to  asbestos may occur
because  such  a recommendation would not be prudent based  on the  occupational
health  risk.

This  policy   position   is  contained   in   "The  Statement  of  the  National
Institute  for  Occupational   Safety  and  Health—The  Public   Hearings  on
Occupational Exposure to  Asbestos."
                                     136

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              APPENDIX C.   ODOR WARNING:   BACKGROUND INFORMATION

It  is  important  to  realize  that 30  CFR 11 prohibits the use  of  MSHA/NIOSH
approved air-purifying  (organic vapor)  respirators  for  protection  against
organic vapors with  poor  warning properties unless there  is  an OSHA standard
that permits such  use.  Specifically,  30 CFR 11,  Section  11.90(b),  footnote
4  gives  the standards  for gas  masks  (canister devices), while 30  CFR  11,
Section  11.150,   footnote  7  gives  the   standards  for   chemical   cartridge
respirators.  Thus the  "organic  vapor  respirator"  shall  be approved only for
organic  vapors  with   adequate  warning   properties.    In   addition,   the
requirement   for   adequate   warning   properties   also   applies   to   all
MSHA/NIOSH-approved air-purifying respirators for  protection  against  organic
gases and vapors.

A  recent  policy  decision  by  NIOSH  allows  the  use  of  respirators  for
protection against contaminants  with  poor  warning  properties,  provided  that
certain  conditions are met.   These  conditions are  outlined  in  the policy
statement  in  Appendix  A.   MSHA/NIOSH  approval   may  be   granted   for   a
respirator  designed   for   use  against  gases and  vapors  with  poor  warning
properties  if  the respirator  incorporates  an  effective  end-of-service-life
indicator (ESLI).

However,   unless    the    respirator    incorporates   an   ESLI,   wearers   of
air-purifying chemical  cartridge/canister  respirators  must  rely on  adequate
warning  properties  to alert  them  to  the breakthrough of the  sorbent in the
cartridge or canister.  Amoore and Hautala [33]  have noted:

          The ability of members of the population  to detect a  given  odor  is
          strongly   influenced   by  the   innate   variability   of   different
          persons' olfactory  powers,  their  prior  experience  with  that  odor,
          and by the degree of attention they accord to the matter.

Amoore and  Hautala [33] found that on the  average,  95%  of a population will
have  a  personal   odor  threshold  that  lies within   the  range  from  about
one-sixteenth  to   sixteen  times the  reported  mean  "odor  threshold"  for  a
substance.  That  is,  about 2.5% of  a population  will be able to detect  a
substance's  odor   at  concentrations   less  than one-sixteenth  of   the  "odor
threshold"  for a  substance.   Correspondingly, about 2.5% of  the individuals
will  need  to be  exposed   to  concentrations  exceeding by  a  factor  of 16 the
"odor  threshold"  in  order to  perceive the  odor.   Thus  for  many  substances
the  width  of distribution of  personal  odor threshold is over  two orders  of
magnitude  of   concentration.    The   "odor   thresholds"   reported   in   the
literature   generally   are   the   median   values    for   wide   population
distributions.  Also,  50% of  prospective  respirator  wearers  can detect  a
substance's  odor  only  at   levels  that  must   exceed  the   reported  "odor
threshold," and about  15% cannot detect the  odor  at  levels  that  exceed  the
"odor  threshold" by fourfold [33].

OSHA  incorporated  into the  lead standard a  new  isoamyl  acetate qualitative
fit  test protocol,  developed by  Du  Pont,  which  requires  odor  threshold
                                     137

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screening [29 CFR  1910.1025,  Appendix D  (I)(A)].   Du  Pont  realized that  a
qualitative  fit  test  depending on  odor  recognition would be  ineffective  if
every individual  were  not first screened  for  the ability to detect  the  odor
of  isoamyl  acetate at  some minimum  concentration.   This  is  also  true  for
detection of  the odor  of  the  gas or  vapor  used to  alert  the  wearer  of
sorbent element  (cartridge  or  canister)  breakthrough.   Thus  NIOSH  recommends
screening tests  for workers who  wear  air-purifying gas or vapor  respirators
to determine  their  ability to detect  the  odor below the exposure  limit  for
that gas or vapor.
                                   138

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           APPENDIX D.   PROTECTION FACTOR:   BACKGROUND INFORMATION

The U.S.  Bureau  of Mines  referred  to  the  term  "Decontamination Factor" in
their Approval  Schedule 21B, first  issued in 1965, and defined  it  to be "the
ratio  of  the concentration  of dust,  fume,  or mist  present in  the ambient
atmosphere to the concentration  of dust,  fume, or mist  within  the  facepiece
while  the  respirator  is being  worn."   The decontamination  factor  is  now
referred to  as  the  respirator protection  factor.   The original  definition
and application given  in schedule 218 has been somewhat generalized over the
years.

The protection  factor of a  respirator is an expression  of  performance based
on  the ratio of  two  measured  variables,  C|  and CQ.   The variable  C|  is
defined only  as  the  measured concentration  of   a   contaminant   inside  the
respirator  facepiece  cavity,  and  CQ   is  defined  only  as  the  measured
contaminant   concentration    outside   the    respirator   facepiece.    The
relationship between  these two  variables can  be  expressed not  only as the
protection   factor   (CQ/CJ)   but   also   as   the   penetration    (C|/C(j)   or
efficiency t(CQ-C|)/CQ] .

The protection  factor  can  be  related to the penetration  (p)  and efficiency
(E) as follows:

                       PF = CQ/CI = 1/p = 1/C1-E)

A  further  implicit   condition  on  the  PF  function   is   that   C|  <  CQ;
therefore,  the  PF will  always be greater  than unity.

Protection factor  assessments are made almost  exclusively  on man/respirator
systems, while  penetration  and  efficiency  assessments are  made  only  on
component  parts of the  respirator system.  It  is  important  to recognize that
on a  man/respirator system,  the measured variable  C| becomes  a  complicated
function  of  many  individual  sources  of  penetration  (e.g.,  air-purifying
element penetration,   exhalation  valve  penetration,  face   seal  penetration,
and other   inboard penetration) and those environmental conditions that would
effect penetration.  To  deal  with the multiple methods for  determining  and
applying  protection  factors,  a  number  of  definitions  have been  proposed
[13].    These  definitions,   described below  in greater  detail   than  in  the
Glossary,  are as  follows:

ASSIGNED  PROTECTION  FACTOR  (APF):   A special  application  of  the general
protection factor  concept,  APF  is  defined  as  a measure of  the  minimum
anticipated workplace  level of respiratory  protection that  would  be provided
by a properly functioning respirator or class of respirators  to a percentage
of  properly   fitted  and   trained  users.    The  maximum  specified  use
concentration for  a  respirator  is  generally determined  by multiplying  the
exposure limit  for  the  contaminant  by the  protection  factor  assigned to  a
specific class  of  respirators [13].
                                     139

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SIMULATED  WORKPLACE PROTECTION  FACTOR  (SWPF):  A  surrogate measure  of  the
workplace protection factor (WPF) of a respirator,  SWPF  differs  from the  WPF
only  in  that   it   is  measured  in  a  laboratory  simulation  of  a  workplace
setting   rather   than   in   the  actual   workplace.    The   definitions   and
restrictions of CQ  and C|  are as  described  for  the WPF.   For  laboratory
protection factor testing to reliably estimate WPF's,  a  relationship must  be
demonstrated   between   the   two  tests.    No   such   relationship   has  been
identified  in  the  literature.   Until  such a  relationship can  be   shown  to
exist,   the    laboratory  protection   factor   is  of  questionable   use   in
determining or predicting the WPF [13].

WORKPLACE  PROTECTION  FACTOR   (WPF):   A  measure  of   the  actual  protection
provided  in  the workplace  under  the  conditions  of  that  workplace by  a
properly  functioning respirator when correctly worn and  used,  WPF  is defined
as   the   ratio  of   the  estimated  contaminant  concentration  outside  the
respirator  facepiece   (CQ)  to  the  contaminant  concentration  inside  the
respirator  facepiece  (C|).    The  sampling  restrictions  placed on  CQ  and
C|  are  that  both  CQ   and  C-j   should  be  TWA   samples  taken  simultaneously
while  the  respirator   is being properly  worn and  used  during  normal  work
activities.    In  practice,  the  WPF  would  be  determined   by  measuring  the
concentration  inside and outside  the facepiece during  the activities  of  a
normal workday  [13].

FIT  FACTOR:    A special application  of  the  protection  factor  ratio  that
represents  a  quantitative  measure  of  the  fit of  a particular  respirator
facepiece  to a particular  individual,  the fit  factor is  defined  under  the
conditions  of  quantitative  fit testing  as the  aerosol  concentration in the
test  chamber  (CQ)   divided  by the  penetration  that  occurs  through  the
respirator  face  seal   interface (Cj)  [34].   For  Cj  to  reflect  only  face
seal  leakage,  high  efficiency  filters [greater  than  99.97% efficient against
0.3  ^rrn aerodynamic  mass median  diameter (AMMD) dioctyIphthalate aerosol] are
installed on the  respirator.   It is assumed that either  no leakage  or only a
negligible   amount   of  leakage   into   the   facepiece  occurs  through  the
exhalation valve  or  any source other  than the  face  seal.   The fit   factor is
measured  on a complete  respirator  worn  by  a test  subject  who  follows  a
regimen  of slow head movements,  deep  breathing,  and  talking; a polydispersed
oil   mist  or   sodium  chloride  aerosol   is   used   that   has  an  AMMD  of
approximately   0.6   +   0.1  /im  (with  a   geometric   standard  deviation  of
approximately  2 to  2.4).
                                        140

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APPENDIX E.   MEDICAL ASPECTS OF WEARING RESPIRATORS:   BACKGROUND INFORMATION

In recommending medical  evaluation  criteria  for  respirator  use,  one should
apply rigorous decision-making  principles  [35],  using knowledge of screening
test  sensitivity,   predictive  value,  etc.   Unfortunately,  many  gaps  in
knowledge  in  this  area  exist.  The  problem  is  complicated  by  the   large
variety of  respirators,  their  conditions of use, and  individual  differences
in  the  physiologic  and  psychologic  responses  to  them.   For  these  reasons,
the  preceding  guidelines  (see Subparagraph  10)  are  to  be  considered  as
informed  suggestions  rather  than  established NIOSH  policy  recommendations.
The  following  information  is  intended primarily to  assist   the  physician  in
developing medical  evaluation criteria for respirator use.

Health Effects of Wearing Respirators

Brief descriptions  of  the  health  effects associated with wearing respirators
are summarized below.  Interested readers are referred  to  recent  reviews for
more detailed analyses of the data [36,37].

  Pulmonary:   In  general,   the  added inspiratory and  expiratory resistances
  and dead  space of  most   respirators cause  an increased  tidal   volume and
  decreased  respiratory  rate  and  ventilation (including a small  decrease in
  alveolar ventilation).   These respirator effects  have usually  been   small
  both  among healthy  individuals  and, in  limited  studies,  among individuals
  with  impaired  lung function [38-42].  This  generalization  is applicable to
  most    respirators    meeting   Federal    regulations    when   resistances
  (particularly  expiratory  resistance)   are   low   [1,43,44].   While  most
  studies report minimal  physiologic effects  during submaximal exercise, the
  resistances  commonly  lead   to  reduced  endurance   and   reduced  maximal
  exercise  performance  [45-49].  The dead space of  a respirator (reflecting
  the amount of expired  air  that must  be  rebreathed  before  fresh air  is
  obtained)  tends  to cause increased ventilation.   At  least one  study has
  shown substantially  increased ventilation  with  a  full-face  respirator,  a
  type  which can have a large effective dead space  [50].   However,  the net
  effect  of  a  respirator's added  resistances  and  dead space  is  usually  a
  small decrease in ventilation [39,45,46-48,51].

  The potential  for adverse effects, particularly decreased cardiac  output,
  from  the  positive pressure  feature of  some respirators  has  been  reported
  [52].   Howeve-,  several  recent  studies  suggest  that  this   is  not  a
  practical  concern, at  least not in healthy  individuals [53-55].

  Theoretically,  the  increased  fluctuations   in  thoracic  pressure   while
  breathing  with a  respirator might  constitute an increased risk to  subjects
  with  a  history of  spontaneous  pneumothorax.   Few  data  are  available  in
  this  area.  While  an  individual   is using  a  negative  pressure  respirator
  with  relatively   high  resistance  during very  heavy  exercise,   the   usual
  maximal peak  negative  oral  pressure during inhalation is about 15-17  cm of
  water  [53].    Similarly,  the usual  maximal  peak   positive  oral   pressure
                                      141

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during exhalation  is  about  15-17  cm  of water,  which might  occur  with  a
respirator  in  a positive  pressure mode, again  during  very  heavy exercise
[53].  By comparison, maximal  positive pressures,  such  as those during  a
vigorous  cough,  can  generate  200  cm  of water  pressure [56].   The  normal
maximal negative pleural  pressure  at  full  inspiration  is  -40 cm of  water
[57],  and  normal  subjects  can generate -80  to -160 cm of  negative  water
pressure  [56].  Thus while vigorous exercise with  a  respirator  does  alter
pleural pressures,  the  risk of  barotrauma would seem  to  be substantially
less than that of the cough maneuver.

In some asthmatics,  an asthmatic attack may be exacerbated or  induced  by  a
variety of  factors  including exercise,  cold air, and stress,  all of  which
may  be associated  with wearing  a  respirator.   While most  asthmatics  who
are  able  to  control   their  condition  should  not  have  problems   with
respirators, a  physician's judgment  and a  field  trial  may  be   needed  in
selected cases.

Cardiac:    The  added  work  of   breathing  from  respirators   is  small  and
could  not  be detecte.d  in several   studies  [38,39].  A  typical  respirator
might  double  the work  of  breathing from 3 to 6% of the oxygen consumption,
but  this  is probably not of  clinical  significance  [38].   In  concordance
with   this  view  is   the   finding  of  several  studies   that  at  the  same
workloads heart  rate does  not change  with  the wearing  of a  respirator
[39,54,58-60].

In  contrast,  the  added   cardiac  stress  due  to  the  weight  of a  heavy
respirator  may  be  considerable.   A  self-contained  breathing  apparatus
(SCBA), particularly one  that  uses compressed air  cylinders, may weigh up
to  35 pounds.   Heavier  respirators  have  been  shown   to  reduce  maximum
external  workloads  by  20% and  similarly  increase  heart  rate  at a  given
submaximal workload [46].    In addition,  it should be  appreciated that  many
uses  of  SCBA  (e.g.,  for  firefighting and hazardous  waste  site  work)  also
necessitate  the wearing of  10-25 pounds of protective clothing.

Raven  et  at.  [40,58]  found significantly higher  systolic  and/or diastolic
blood  pressures  during  exercise for  persons  wearing respirators (although
increases  were minimal,  i.e.,  OO mmHg  systolic,  0-2  mmHg  diastolic).
Arborelius  et  al.  [54] did not  find  significant  differences  for  persons
wearing respirators during  exercise.

Body  Temperature:  Proper regulation  of body  temperature  is primarily of
concern with the closed  circuit,  self-contained breathing  apparatus that
produces  oxygen  via  an  exothermic chemical  reaction.   Inspired  air  within
these  respirators  may  reach 120°F (49°C), thus  depriving  the wearer  of  a
minor  cooling  mechanism  and   causing  discomfort.  Obviously  this  can  be
more  of  a  problem  with heavy  exercise  and  when ambient  conditions  and/or
protective  clothing  further reduce the body's  ability  to  lose  heat.   The
increase  in  heart  rate   due  to  increasing   temperature  represents  an
additional  cardiac stress.
                                142

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Closed-circuit breathing  units  of  any  type have  the potential  for  heat
stress since warm expired  gases  (after  exothermic carbon dioxide  removal
with  or  without  oxygen  addition) are rebreathed.  Respirators  with  large
dead  space  also  have this  potential  problem,  again  because  of  partial
rebreathing of warmed expired air [50].

Diminished  Senses:    Respirators   may   reduce   visual  fields,  decrease
voice clarity and  loudness,  and  decrease hearing.  Besides  the  potential
for  reduced  productivity,  these  effects may result  in reduced  industrial
safety.  These factors may also contribute to a general  feeling  of stress
[61].

Psychologic:   This   important  topic  is  discussed  in  recent   reviews  by
Morgan  [61,62].   There  is  little  doubt  that virtually everyone  suffers
some  discomfort  when  wearing a  respirator.   The large variability and the
subjective  nature  of   the   psycho-physiologic  aspects  of   wearing   a
respirator,   however,   make   studies    and   specific   recommendations
difficult.  Fit testing  obviously serves  an  important additional  function
in  providing  a   trial  to  determine if  the wearer   can  psychologically
tolerate  the  respirator.   General  experience  indicates that  the  great
majority of workers  can  tolerate respirators and that  experience  aids  in
this  tolerance   [62].   However,  some  individuals are  likely  to  remain
psychologically unfit for wearing respirators.

Local  Irritation:   Allergic  skin   reactions may occur  occasionally  from
wearing  a  respirator,   and  skin  occlusion   may  cause   irritation  or
exacerbation   of  preexisting   conditions   such  as  pseudofolIiculitis
barbae.   Facial  discomfort  from the  pressure  of   the mask  may  occur,
particularly when the fit is unsatisfactory.

In  addition  to  the   health  effects  associated with  wearing  respirators
(described  above) specific  groups  of respirator  wearers may be  affected
by the following factors:

   Perforated  Tympanic   Membrane:   While   inhalation  of toxic  materials
   through a  perforated  tympanic  membrane (ear  drum)  is possible,  recent
   evidence  indicates that  the  airflow  would  be minimal  and  rarely  if
   ever  of  clinical  importance  [63,64].   In   highly  toxic  or  unknown
   atmospheres,  use  of   positive   pressure   respirators   should  ensure
   adequate protection [63].

   Contact  Lens:   Contact   lenses are  generally not  recommended  for  use
   with  respirators,  although   little   documented   evidence  exists  to
   support  this  viewpoint  [65].    Several  possible  reasons  for  this
   recommendation are noted below:

      a.  Corneal  irritation  or  abrasion might  occur with  the  exposure.
      This  would,  of  course, be  a  problem primarily  with  quarter-  and
      half-face  masks,  especially  with particulate  exposures.   However,
      exposures  could occur with  full-face respirators due  to  leaks  or
                               143

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inadvisable  removal   of  the  respirator   for   any   reason.    While
corneal  irritation  or  abrasion might  also occur  without  contact
lenses, their presence is known to  substantially increase this risk.

b. The  loss  or  misplacement of  a  contact  lens by  an  individual
wearing  a   respirator   might   prompt   the  wearer   to  remove  the
respirator,  thereby resulting  in  exposure  to the hazard  as  well  as
to the potential problems noted in  "a." above.

c.  The  constant  airflow  of  some  respirators,  such  as  powered
air-purifying   respirators   (PAPR)   or  continuous   flow  air-line
respirators,  might irritate a contact  lens  wearer.
                              144

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              SECTION 5




   PERSONAL PROTECTIVE EQUIPMENT




                PARTS



RESPIRATORY PROTECTION PROGRAM GUIDELINES
                  145

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                             TABLE OF CONTENTS
 1.  PURPOSE AND OBJECTIVE ....................      1

 2.  BACKGROUND ..........................      1

 3.  DEFINITIONS .........................      1

 4.  THE RESPIRATORY PROTECTION PROGRAM ..............      3

 5.  ESTABLISHMENT OF THE RESPIRATORY PROTECTION PROGRAM  .....      3

 6.  SELECTION OF RESPIEATORY PROTECTIVE DEVICES .........      4

     Identification of the Hazard  ................      4

     Evaluation of the Hazard ...................      7

     Approved Respiratory Protective Devices ...........      8

 7.  RESPIRATOR USE ........................     14

     Employee Responsibilities ..................     14

     Supervision of Respirator Use ................     15

     Respirator Use Under Special Conditions ...........     15

     Special Problems in Respirator Use ..............     17

 8.  TRAINING AND FITTING .....................     18

     Training ...........................     18

     Fitting ...........................     20

 9.  RESPIRATORY PROTECTIVE DEVICE INSPECTION, CLEANING,
       'MAINTENANCE AND STORAGE  .................     24

     Inspection of Respiratory Protective Devices .........     24

     Cleaning and disinfecting ..................     27

     Maintenance .........................     28

     Storage ...........................     28

10.  MEDICAL ASPECTS OF RESPIRATORY EQUIPMENT USAGE ........     29
                                     147

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                         TABLE OF CONTENTS  (Continued)

                                                                          Page

 11.  EVALUATION OF THE RESPIRATORY PROTECTION  PROGRAM	       30

     Surveillance of the Work Area	  .       30

     Program Evaluation	       30

REFERENCES		       33

APPENDIX

A.  Respiratory Protection Device Recommendation Form	       34

B.  Model Standard Operating Procedure, Respirator Use,
       High Hazard Areas	       36

C.  Employee Training Program	       38

D.  Respirator Protection Factors	       43

E.  Checklist for Inspection of Pressure Demand SCBA	  .       46

F.  Duty Status Report	       51
 THIS DOCUMENT HAS NOT BEEN PEER AND ADMINISTRATIVELY REVIEWED WITHIN EPA
 AND IS FOR INTERNAL AGENCY USE/DISTRIBUTION ONLY.
                                       ii
                                      148

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              RESPIRATORY  PROTECTION PROGRAM GUIDELINE
1.  PURPOSE AND OBJECTIVE.   The purpose and objective of this guideline are
to provide management  personnel with  sufficient information to establish and
operate a respiratory  protection program to adequately protect its employees
as required by EPA Order  1440.3, Respiratory Protection, and by the Occupa-
tional Safety and Health  Administration (OSHA)  Regulations 29 CFR 1910.134.

2.  BACKGROUND.  OSHA  has set  maximum exposure  standards for many airborne
toxic materials.  If employee  exposure to these substances exceeds the
standards, the regulations requires  that feasible  engineering controls and/
or administrative controls be  installed or instituted to reduce employee
exposure to acceptable levels.   If  these controls  do not prove feasible,
or while they are being Installed/instituted,  the  Agency is required to
provide appropriate, approved  respiratory protection for its employees.
Respirators are the least acceptable  means for  reducing personnel exposures;
they only provide good protection if  properly  selected and fitted, worn by
employees when needed,  and replaced when their  service life is over.  Addi-
tionally, some employees  may not be able to wear a respiratory protective
device.  Despite these difficulties,  respiratory protective devices are the
only means of protection  available  to employees when engineering and work
practice controls are  not feasible  or Inadequate,  i.e.,  during field
operations.

3.  DEFINITIONS.

    a.   Approved.  Approved  means  that a respiratory protective device
        has been tested and  listed as satisfactory by the Bureau of
        Mines (BOH) of  the U.S.  Department of Interior-,  or jointly by the
        Mine Safety and Health Administration  (MSHA)  of the U.S.  Depart-
        ment of Labor  and the National Institute for Occupational Safety
        and Health (NIOSH) of  the U.S.  Department  of Health and Human
        Services.

    b.   Canister (air-purifying).  An air-purifying  canister is a container
        with a filter, and/or sorbent,  and/or catalyst which removes specific
        contaminants from the air drawn  through it.

    c.1   Canister (oxygen-generating).  An oxygen-generating canister is a
        container filled  with a  chemical  which  generates  oxygen by chemical
        reaction.

    d.  J3eilin& concentration.  The ceiling  concentration means the  concen-
        tration of an airborne substance  that shall  not  be exceeded.

    e.   Confined space.  A confined space  is a  space  defined by the  con-
        current existence of the following conditions:

          Existing ventilation  is insufficient  to remove dangerous  air
          contamination  and/or oxygen deficiency which may exist  or develop.
                                 149

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                                2.

       Ready access or egress for the removal of a suddenly disabled
       employee is difficult due to the location and/or size of the
       opening(s).

f.  Contaminant.   A contaminant is a harmful, irritating, or nuisance
    material that is foreign to the normal atmosphere.

g.  Corrective lens.  A corrective lens is a lens ground to the wearer's
    individual corrective prescription to permit normal visual acuity.

h.  Emergency respirator use.  Emergency respirator use means wearing a
    respirator when a hazardous atmosphere suddenly occurs which requires
    immediate use of a respirator either for escape only from the hazard-
    ous atmosphere  or for entry into the hazardous atmosphere to
    carry out maintenance or some other task or for rescue purposes.

 1.  Hazardous  atmosphere.  A hazardous  atmosphere  is  any  atmosphere,
    either  immediately  or not  immediately dangerous  to life  or  health,
    which is  either oxygen deficient  or which  contains a  toxic  or  disease-
    producing  contaminant exceeding  the legally  established  permissible
    exposure  limit  (PEL), or where applicable,  the Threshold Limit
    Value (TLV) established  by  the American Conference of Governmental
    Industrial Hygienists (ACGIH).

j.  Immediately dangerous to life or health.  Immediately dangerous
    to life  or health refers to any atmosphere that poses an. immediate
    hazard to life or produces  immediate irreversible effects cm health
    that will be debilitating.

k.  Not immediately dangerous to life or health.   Not immediately dan-
    gerous to life or health refers to any hazardous  atmosphere which
    may produce physical discomfort immediately,  chronic poisoning
    after repeated exposure,  or acute adverse physiological  symptoms
    after prolonged exposure.

1.  Odor threshold limit.  The  lowest concentration of a contaminant in
    air that can be detected by the olfactory sense.

m.  Permissible exposure limit  (PEL).   Permissible exposure  limit is the
    legally  established time-weighted average (TWA) concentration or
    ceiling  concentration of a  contaminant that shall not be exceeded.

n.  Protection factor.  Protection factor is the ratio of the ambient
    concentration of an airborne substance to the concentration of  the
    substance inside the respirator at the breathing  zone of the wearer.
    The protection factor is a  measure of the degree  of protection
    provided to the wearer.

o.  Time-weighted average (TWA).  Time-weighted average is the average
    concentration of a contaminant in air during a specific  time period.
                                  150

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                                     3.

4.  THE RESPIRATORY PROTECTION PROGRAM.  EPA Order 1440.3, Respiratory
Protection, sets out the Agency policy, responsibilities, and basic  require-
ments for a respiratory protection program to protect its employees  whose
Jobs require the use of respiratory protective devices.  EPA management  is
required to establish and implement a respiratory protection program at
each Agency location where the activities of employees may cause  them to
encounter atmospheres that contain or are suspected of containing unhealthy
quantities of airborne contaminants or atmospheres with insufficient oxygen
content, or where there is the threat of an imminent release of toxic
agents.  Respiratory protection may also be necessary for routine but in-
frequent operations and for non-routine operations in which the employee
is exposed briefly to high concentrations of a hazardous substance,  i.e.,
during maintenance or repair activities, or during emergency conditions.

As a minimum, a respiratory protection program must contain all the  elements
outlined in EPA Order 1440.3.   These requirements are:

    a.  Approved respiratory protective devices must be properly selected.

    b.  There must be a determination of the need for respiratory protective
        devices.

    c.  An employee training program must be established in which the
        employee becomes familiar with the respiratory protective devices
        and is trained in the  proper selection and use of respirators and
        their limitations.

    d.  There must be provisions for:

           Proper inspection,  maintenance,  storage and repair of respiratory
           protective devices.

        .   Assigning respiratory protective equipment to employees for
           their exclusive  use,  where  practical.

           Testing for the  proper fit  of the respiratory protective
           equipment.

           Surveillance  of  the work  area  and  for  employee  exposure and stress,

           Medical screening of  each employee assigned to wear  respiratory
           protective  devices  to determine  if he/she  is  physically and•
           psychologically  able  to wear a respirator.

    e.   Written standard operating procedures  must exist for  the selection
        and use of respiratory protective devices.

5.   ESTABLISHMENT OF THE RESPIRATORY PROTECTION PROGRAM.   Management  at  each
EPA location where it  has been determined a  Respiratory  Protection Program is
required should designate one person responsible  for  administering the pro-
gram at that location.   This person  should have  the responsibility for the
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                                    4.

entire respirator program and develop the standard operating procedures.
To administer effectively the respiratory protection program, the designated
person must have:

    a.  Sufficient training in all aspects of respiratory protection to
        adequately manage the program.

    b.  The ability to make sound Judgments based on hazard evaluation and
        an understanding  of the workplace hazards.

    c.  The knowledge  and authority to coordinate equipment purchasing,
        maintenance, cleaning and repair.

    d.  The knowledge  and authority to assure that written operating
        procedures are prepared for specific operations and that these
        procedures are being followed.

    e.  The knowledge  and authority to assure compliance with OSHA
        and Agency respiratory protection requirements.

    f.  The resources  to  maintain all records associated with the program,
        i.e.,  monitoring,  medical surveillance and job assignment data,
        respirator care and maintenance records, emergency equipment
        inspection/maintenance tags,  training records,  etc.

The individual assigned the respiratory program responsibility may be a
safety specialist/manager,  safety engineer,  industrial  hygienist,  or super-
visory person.  This individual must  have the full support of management
at the workplace  regardless of who assumes the program responsibility.

6.  SELECTION OF  RESPIRATORY PROTECTIVE DEVICES.  The proper selection of
respiratory protective devices basically involves three steps:

    a.  Identification of the hazard.

    b.  Evaluation of  the hazard.

    c.  The selection  of  the appropriate approved respiratory protective
        device based on the first two considerations.  (See Appendix A,
        Respiratory Protective Device Recommendation.)

Respiratory protective devices that will provide greater protection than
required may be selected, but the device selected must always be approved.

    a.  Identification of the Hazard.  It is important to know something
about the different kinds of hazardous atmospheres which may require the
use of respirators.

    o  Contaminated Atmospheres

       .  Gaseous Contaminants - These contaminants are of two types.
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                                     5.

               Gases are aeriform fluids which are  In  the gaseous  state  at
  ordinary temperature and pressure-., e.g., carbon dioxide.  Such substances
  are solids or liquids only at much  lower  temperatures or much higher  pressures
  than are commonly found in the work environment.   Carbon dioxide,  is  a  gas  at
  roocn temperature, but it occurs as solid  "dry ice" at low  temperature,  or
  as a liquid in pressurized tanks.

               Vapors are the gaseous state of a substance  that is  solid  or
  liquid at ordinary temperature and pressure.  Vapors are formed by  the
  evaporation of substances, i.e., acetone  or trichloroethylene, which
  ordinarily occur as liquid.

           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:

               Dusts are solid particles produced by such processes  as grinding,
  crushing, and mixing of powder compounds.

               Mists are tiny liquid droplets dispersed whenever a liquid is
  sprayed, vigorously mixed, or otherwise agitated.

               Fumes are solid condensation particles of extremely small
  particle size.

        .  C oa b i n a t i on Contaminan_t s  - The  two basic forms of contaminated
  atmospheres - gaseous and  particulate  - frequently occur together.

     o  Oxygen Deficient Atmospheres -  In an oxygen deficient atmosphere,
the problem "is not the presence of something harmful,  but the absence of
something essential.   These atmospheres  are most  commonly found in confined
and usually poorly ventilated spaces.   Oxygen deficient atmospheres are
classified as either immediately dangerous to life  or health or not immediately
dangerous to life or health depending on the oxygen concentration in the
atmosphere.   (An  oxygen deficient atmosphere immediately dangerous  to life and
health is an atmosphere that  contains less than 16  volume percent of oxygen
in the atmosphere at sea level.   An  oxygen deficient atmosphere not immediately
dangerous to life and health  is an atmosphere having an oxygen concentration
between 16 and 19.5 volume  percent of oxygen in the atmosphere at sea level.)

Oxygen deficient  atmospheres  occur in two different ways:   (1)  Oxygen may
be "used up" by a chemical  reaction, and (2)  Oxygen is displaced by another gas.
There is no definition of oxygen deficient atmosphere that has been universally
accepted.   OSHA has adopted and EPA  accepts an oxygen deficient atmosphere as
one that contains less than 19.5 volume  percent of  oxygen in the atmosphere at
sea level.   The following table is a partial listing of definitions of oxygen
deficient atmospheres,  their  source  and  conditions  of determination.
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                                    6.
               Definitions of Oxygen Deficient Atmospheres
Source

ACGm Threshold Limit Values
for 1973

Federal Regulations
29 CFR Part 1915.SI
(Maritime Standards)

29 CFR Part 1910.94
(Ventilation Standards)
(Respirator Approval  Tests)

ANSI Standards Z88.2-1969
(Respirator Practices)

ANSI Standards Z88.2-1980
(Practices for Respiratory
Protection)

Z88.5-1973
(Firefighting)

K13.1-1973
(Marketing of air-purifying
canisters and cartridges)
Oxygen
Content
(Vol.7.)

 18.0
 16.5
 19.5
 19.5

 16.0
 19.8
 19.5
 19.5
Conditions for Determination

"... under normal atmosphere
pressure. .  . ."

(not specified)
(not specified)
". . .  by volume at sea level.

". . .  normal air. .  .  ."
". .  .  normal air. .  .  ."
". .  .at sea level. .  .  ."
". . .at sea level. .  .  ."
It is difficult to visualize the effect of oxygen deficient atmospheres on
the individual.  He/she is not aware of the nature of their situation.
Gradual depression of the central nervous system affects powers of discrimi-
nation, logic, and auditory acuity, with muscular weakness and lack of
coordination.  Since no distressful sensations are produced, the entire
experience is comfortable and even pleasant.  In reality, however, breathing
in an oxygen deficient atmosphere is like breathing under water.  The
symptoms of oxygen deficiency also depend on the oxygen concentration pre-
sent.  The following table presents the physiological effects of atmospheres
at and below 16 volume percent of the oxygen at sea level.
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                                    7.
                      Effects of Oxygen Deficiency

  02 Vol I
at Sea Level            PhysioloRJcal Effect

   16-12                Increased breathing volume.
                        Accelerated heartbeat.
                        Impaired attention and  thinking.
                        Impaired coordination.

   14-10                Very faulty Judgment.
                        Very poor muscular coordination.
                        Muscular exertion causes rapid fatigue  that  may
                           cause permanent heart damage.
                        Intermittent respiration.

   10-6                 Nausea.
                        Vomiting.
                        Inability to perform vigorous movement,  or loss
                           of all movement.
                           or  an movement.
                        Unconsciousness,  followed by death.
Less than 6             Spasmatic breathing.
                        Convulsive movements.
                        Death in minutes.

    b.   Evaluation  of the  Hazard.  The person  who evaluates  respiratory
hazards must  have the cooperation of others in obtaining  information  on  the
work area,  work activities and materials to properly evaluate  and  determine
the appropriate respiratory  protective device  that will provide  the best
protection  for  the  employee.   Consideration of these questions will help in
the selection of the  correct equipment.

        1)  Does the  atmosphere oxygen level meet standards?   Is the  atmos-
phere oxygen  level  expected  to remain constant or decrease?

        2)  What is the  contaminant?  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 the estimated concen-
tration?  Is  eye protection  also needed?
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                                     8.

        8)  What type(s) of respirators will provide  the required  degree
  of  employee protection?

        9)  Is the recognized contaminant the only contaminant  present?

        10)  If the contaminant is a gas or vapor, is  there an effective
  sorbent for the respirator cannister?

        11)  Can the contaminant be absorbed through the skin?   If  it can, will
  it  result in a serious injury?

     c.  Selection of Approved Respiratory Protective Devices.  The person
  designated as che respiratory protection program manager should have an
  approval authority for the purchase of respiratory protective  devices.  Any
  respiratory protective devices purchased should be approved for the parti-
  cular  contaminants for which they will be used.  If  only one brand of
  respirator is approved for a particular hazard, then that brand is considered
  to  be  "available" and must be used.  The NIOSH approval on a respirator has
  the following information:

     o  An assigned identification number placed on each unit.

     o  A label identifying the type of hazard for which the respirator is
  approved.

     o  Additional information on the label which gives limitations and
  identifies the component parts approved for use with the basic unit.

  In  the past,  the BOM approved respirators.  The BOM no longer  grants
  approval; however, some older respirators which were BOM-approved may
  still  be used.

     o  BCW-approved self-contained breathing apparatus (SCBA)  may be used
  until  further notice.

     o  BCM-approved gas masks may be used until further notice.

     d.  Categories of Respiratory Protective Devices.  Respiratory protective
  devices fall  into two broad categories - air purifying and atmosphere
  supplying.

          1)   Air-purifying respirators  -  These  devices  remove the  contaminant
from the breathing  air before  it  is  inhaled.  For each model  of  air-purifying
respirator,  there  are  usually  many air-purifying  cartridges  available  for
protection against  specific contaminants.   Combination cartridges  for  pro-
tection against both particulates  and organic vapors  are also available.

         o  Particulate removing  filter respirators - These are generally
  called "dust,'"mist," or "furae"  respirators and by a filtering action remove
  particulates  before they can be  inhaled.
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                                    9.

               Single use, dust - The single-use respirator is a respirator
which  is completely disposed of after use.  They are for individual use
and should be discarded when resistance becomes excessive or the respirator
is damaged.  Generally these respirators are approved only for pneumoconiosis
or fibrosis producing dust such as coal dust, silica dust, and asbestos.

               Quarter-mask, dust and mist; half-mask, dust and mist - The
quarter-mask covers the mouth and nose; the half-mask fits over the nose
and under  the chin.  The half-mask usually produces a better facepiece to
face seal  than does the quarter-mask and is therefore preferred for use
against more toxic materials.  Dust and mist respirators are approved for
protection against dusts and mists whose TLV is^greater than 0.05 milligram
particular matter per cubic meter of air (mg/MJ).

            .  Quarter-mask, fume; half-mask, fume - These masks, similar
to the quarter-mask duat and mist; half-mask dust and mist, utilize a filter
element which can remove metal fumes in addition to dusts and mists from
the inhaled air.   The filters are approved for metal fumes having a TLV
above  0.05 mg/M3.

               Half-mask, high efficiency - These masks are the same as the
units mentioned in the two previous paragraphs above, but use a high efficiency
filter.  Because  of this high efficiency filter, they can be used against dusts,
mists, fumes, and combinations of those whose TLV is less than 0.05 mg/M .

               Full facepiece - Full  facepiece  respirators cover the face
from  the hairline  to below  the chin.  In addition  to providing more pro-
 tection  to the face and  also a measure  of eye protection,  the full-face-
piece  gives a better seal than the half- or quarter-masks.  The protection
 these  respirators provide against dusts, mists,  fumes, or any combination
of  these contaminants depends upon the  type of  filter used.

               Powered air-purifying respirators - These respirators use
a blower that passes  the contaminated air through the cartridge or  canister
where the contaminant is removed  and passes the purified air into the  face-
piece.  The air purifying element can be a filter to remove particulates,
a cartridge or canister  to remove gases  or vapors, or a combination to
remove both.   The face covering  can be a half-mask, full-face mask,  or
hood or helnet.   The  advantage to using  a powered air-purifying respirator
is that it  supplies air  at a positive pressure within the facepiece, hood
or helmet,  so that any leakage is outward.

The protection provided  depends  on the air-purifying element and the  type
and concentration of  the contaminants.  Powered  air-purifying respirators
must deliver at least  4  cubic feet per minute  (CFM) to a tight fitting
facepiece such as a mask and at  least 7  cfm to a loose fitting helmet or
hood.   If the  powered  air-purifying  respirator is battery operated,  it
should provide the airflows  mentioned for at  least 4 hours  without  having
to recharge the battery.
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                                    10.

         o  Limitations - air purifying respirators for  participates -

           .  Air-purifying respirators do not provide  oxygen, so they
must never be worn in oxygen deficient atmospheres.

              Air-purifying respirators for particulates offer n_o protection
against  atmospheres containing contaminant gases or vapors.

           ..  These respirators are not NIOSH approved  for abrasive blasting
operations and should not  be used.

         o  Problems - air  purifying respirators for particulates -

              The air flow resistance of a particulate-removing respirator
filter element increases as the quantity of particles it retains increases,
thus increasing the breathing resistance.   As a rule of thumb, when comfortable
breathing is impaired because of dust build-up, the filter should be replaced.

           .  The performance of some filter materials  is affected by open
storage  in very humid atmospheres.  Care should be taken in storing filter
elements.

         o  Chemical Cartridge and Canister Respirators, Gas and Vapors -
Vapor and gas-removing respirators use cartridges or canisters containing
chemicals to trap or react with specific vapors and gases and remove them
from the air breathed.  The basic difference between a cartridge and a
canister is the volume of  the sorbent.  Generally, a "cartridge" refers to a
chemical adsorbing element which attaches  directly to the facepiece, whereas
a "canister" refers to the chemical adsorbing^element  held in a harness and
which is connected to the  facepiece via a  corrugated breathing tube.  Some
of the typical chemical cartridge or canister respirators are:

              Half-mask and quarter-mask respirators - These are available
for protection against single chemicals such as ammonia or against entire
classes  such as organic vapors.  Be sure to read the label on the cartridge
or canister since it tells what the cartridge or canister protects against,
what the maximum concentration is for which the element can be used, and
in some  instances, the service life or expiration date of the element.

           .  Full facepiece - The full facepiece respirator may use a canister
or cartridge(s) as the protective element.  The front, back, and chin-mounted
full-facepiece canister respirators are also referred to as "gas masks."

         o  Limitations - chemical cartridge or canister, gas and vapor -

              These respirators do not supply oxygen,  so they must never be
worn in  oxygen deficient atmospheres.

              They must not be used if the hazardous chemical lacks  adequate
warning  properties - odor,  taste, or irritation,  unless their use is permitted
by applicable  OSHA or MSHA standards.   These warning properties are  necessary
                                     158

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                                    11.

 to alert  the user  that  the  sorbent  Is  saturated  and  that  the  contaminant
 is passing  through the  cartridge  or canister  into  the  respiratory  tract.

              They must not be used in atmospheres immediately  dangerous
 to life or  health,  except for escape.

              They are  intended for use only  for the specific gases  or vapors
 for which they were tested  and approved.   (They  may  be worthless for  other
 gases  or vapors.)

       2)   Atmosphere Supplying Respirators - Atmosphere  supplying respirators,
 rather than removing the hazardous  material from the air,  exclude  the workplace
 air altogether and provide  clean  air from  an  independent  source.  There are
 two kinds of atmosphere supplying respirators:   (1) A  supplied-air respirator
 in which  the user  is supplied with  respirable air  through  a hose and  (2) A
 self-contained respirator in which  the user carries a  supply of respirable
 air.

       o  Supplied-air  respirator - Supplied-air respirators use a central
 source of breathing air that is delivered  to the wearer through an air supply
 line or hose.

          .  Airline respirator devices - Airline respirator devices use
 a  stationary source of compressed air delivered  through a high-pressure hose.
 Airline respirator  devices can be equipped with a half- or full-facepiece
 masks, helmets, or hoods,  or the device can come as a  complete suit.  Air-
 line respirators can be used for protection against either particulates,
 gases, or vapors.  They provide a high degree of protection against these
 contaminants but they cannot be used in atmospheres immediately dangerous to
 life or health because  the user is completely dependent on the integrity of
 the air supply hose and the air source.  If something were to happen to
 either the hose or air supply, the user could not escape from the contaminated
 area without endangering his/her life,  since the user  is not guaranteed a
 supply of breathing air for escape.   A great advantage of the airline respirator
 is  that it can be used for long continuous periods.  There are three types of
 airline respirators.

                Demand Airline Respirator Devices - In a demand device,
 the air enters the facepiece only on demand of the user, i.e., when the user
 inhales.   This is due to the nature  of  the valve and pressure regulator.
During inhalation there is a negative pressure in the mask, so if  there is
 leakage,  contaminated air  may enter  the mask and be breathed by the user.
The leakage problem is a major drawback of the demand device.   Full face
masks provide a better seal than the half-mask against leakage.

                Pressure Demand Airline Devices  - The pressure demand
device has a regulator and valve design such that there is a continuous
flow of air into the facepiece at all times.  The air flow into the mask
creates a  positive pressure in the mask,  therefore, there  is no problem of
contaminant leakage into the facepiece.  This  is the  significant advantage
of this type of device.
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                                    12.

                  Continuous-flow Airline Devices - The continuous-flov
airline respirator maintains a constant  airflow at all times and does
not use a regulator.   Instead an airflow control valve or orifice regulates
the flow of air.   The continuous-flov device creates a positive pressure
in the facepiece.   There is no problem of inward leakage of contaminant.

        o  Air Supply System - Supply air sources (compressor or tanks)
for the supplied-air  respirators must meet the following requirements.

              The  air compressor must be located where contaminated air
cannot enter the  system.

              The  air receiver must be of sufficient capacity to enable
the wearer to escape  in the event of compressor failure.

              The  system must have alarms to indicate compressor failure
or overheating.

              If  the  compressor is oil-lubricated it must have a high
temperature and/or carbon monoxide (CO)  alarm.  If there is no CO alarm,
frequent carbon monoxide tests of the air must be made to insure that the
CO level does not  exceed 20 parts per million.

           .  All  airline couplings must be incompatible with outlets for
other gas systems.

              Breathing air quality must meet the requirements of Grade D
breathing air as described by the Compressed Gas Association.  Grade D
requirements are:

                  The oxygen content of  the compressed air should be between
19.5 - 23.5 percent oxygen and the remainder mainly nitrogen;

                  Hydrocarbon concentrations must not exceed 5 parts per
million;

                  Carbon monoxide concentration must not exceed 20 parts
per million;

                  Carbon dioxide concentrations must not exceed 1000 parts
per million; and

                  There must not be any  pronounced odor.

       .o  Limitations - Supplied-air respirators -

              These devices must not be  used in atmospheres immediately
dangerous to life  or  health since the user is dependent upon an air hose
which, if cut, crushed,  or damaged,  leaves him/her with little or no pro-
tection.
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                                     13.
            .  The  trailing  air  supply hose of  the  airline reapirator
 severely  restricts  the  wearer's mobility.  This makes the airline respirator
 unsuitable  for  the  user who must move frequently between work stations  that
 are  separated or cover  a large  area, i.e., during  field work.

        o  Self-Contained Breathing Apparatus  (SCBA).   The self-contained
 breathing apparatus  (SCBA)  allows  the user to  carry  a respirable breathing
 supply with him/her,  and does not  need a stationary  air source such as  a
 compressor  to provide breathable air.  The air supply may last from 3 minutes
 to 4 hours  depending  on the device.

            . Closed Circuit SCBA - In a closed circuit SCBA the air is
 rebreached  after the  exhaled carbon dioxide has been removed and the oxygen
 content restored by a compressed oxygen source or  an oxygen-generating  solid.
 These devices are designed  primarily for 1-4 hour  use in toxic atmospheres.
 Because negative pressure is created in the facepiece during inhalation,
 there is  increased  leakage  potential.  Therefore,  the devices should be
 used in atmospheres immediately hazardous to life  and health only when  long-
 duration  use of an  SCBA is  indicated, i.e., in mine  rescue.   Two types  of
 closed circuit SCBA are available.

                  Compressed Oxygen Cylinder Type  -  In this device,  breath-
 able air  is supplied-from an inflatable bag.   Exhaled air from the user
 goes through an adsorber to remove carbon dioxide, and the oxygen consumed is
 replenished from an oxygen  cylinder.

                  Oxygen-generating Type - This type of SCBA uses an oxygen-
 generating  solid which  reacts with water vapor and carbon dioxide from  the
 exhaled breath, to release  oxygen.  The oxygen then  passes to the inflatable
 bag.  This  device is  lighter, simpler,  and less expensive than the cylinder
 type.  However, it is useful for only about 1  hour and,  once initiated,
 cannot be turned off.

              Open Circuit  SCBA - An open circuit SCBA exhausts  the  exhaled
 air to the  atmosphere instead of recirculating it.   A  tank of compressed
 air carried on the user supplies air via a regulator to  the  facepiece.
 Because there is no recirculation of air,  the  service  life of the open
 circuit SCBA is shorter than a closed circuit  device.   Two types  of  open
 circuit SCBA's are available.

                  Demand SCBA - In a demand SCBA,  air  flows  into  the face-
 piece only on the demand of the user, i.e.,  when the user inhales.  This is
 due to the nature of  the valves and pressure regulator.   During  inhalation
 there is a negative pressure in the mask,  so if there  is  leakage,  contaminated
 air can enter the mask  and  be breathed  by  the user.  The  leakage  problem is a
major drawback of the demand device.   Because of this  problem, a  demand type
 open circuit SCBA should not be used in atmospheres  immediately dangerous to
 life or health.

                  Pressure Demand SCBA  - The pressure  demand  open  circuit
SCBA has a regulator and valve design which  maintains  a positive  pressure
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                                   14.

in the facepiece at all times  regardless of the demand of the user.  Because
of this, there is no problem of contaminant leakage into the facepiece.
This  is a significant advantage of the pressure demand device.  The use
time  of this device, though, may be reduced considerably by  air leakage
outward from the facepiece.

        o  Combination  Atmosphere Supplying Respirator - Supplied Air and
SCBA - Designed primarily as a long duration device,  this respirator combines
an airline respirator with an auxiliary air supply (usually compressed air)
to protect against  the  possible failure of the primary air  supply (the air-
line) .  The additional  supply  can be approved for  15  minutes or even longer.
The choice depends  upon how long it would take to  escape from the toxic
atccsphere if the primary air  supply failed.   This modification,  therefore,
allows these devices to be used in atmospheres immediately  dangerous to life
and health.

        o  Limitations  of atmosphere supplying respirators  -

              The air supply is limited to the amount in the cylinder (SCBA's
using a compressed  air  tank) and therefore the respirator cannot be used for
extended periods without recharging or  replacing the  cylinders.

              Because these respirators are bulky  and heavy, they are often
unsuitable for  strenuous work or use in confined spaces.

              Because of the short service time of the auxiliary air supply,
the escape portion  of the combination unit can be  used only for escape from
atmospheres  immediately hazardous to life or health unless  the escape portion
has a. minimum of 15 minutes service life.  Such devices can then be used
for entry into  immediately dangerous to life or health atmospheres provided
not more than 20 percent of the available breathing supply  is used.  These
devices may  always  be used for entry into immediately dangerous to life or
health atmospheres  when utilized with the external air supply.

            .   Because  the outward air  leakage from the facepiece of the
pressure demand device  can cause loss of air the use  time may be  shortened

7.  RESPIRATOR USE.  All employees required to wear respiratory protective
devices should, if  practical,  be assigned their protective  equipment for
their exclusive use. A system should be established  to facilitate the account-
ing of users and of the equipment.   When a respirator is assigned to a user
it should be permanently marked to indicate to whom it is assigned.  The
marking must be done in such a way that it does not hurt the respirator per-
formance.   Records  should indicate the  date of initial issue, the dates of
reissue, and a  listing  of repairs.

    a.  Employee Responsibilities.  As  a respiratory  protective device user,
employees have  these responsibilities:

        1)  Use respiratory protective  equipment as instructed.

        2)  Guard against damaging the  respirator.

        3)  Go  immediately to  an area of "clean" air  if the respirator
malfunctions.

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                                    15.

        4)  Report any malfunctioning of respiratory protective devices
 to  their supervisor.  These malfunctions would include  but not be limited
 to:

              Discomfort;

              Resistance to breathing;

              Fatigue due to respirator usage;

              Interference with vision or communication;

              Restriction of movement.

    b.  Supervision of Respirator Use.  Respirators in  use must be randomly
 inspected at frequent intervals to ensure that those selected for the job
 are being used and that they are in good condition.  This periodic monitoring
 should include:

        1)  A determination that the proper respirators are being used.

        2)  Determination that respirators are being worn properly.

        3)  Consultation with users about:

               Discomfort

               Resistance to breathing

            .  Fatigue

               Interference with vision

               Interference with communications

               Restriction of movement

               Interference with job performance

               Confidence in the respirator

 If problems are discovered during the random inspection, they should be
 rectified.

    c.  Respirator Use Under Special Conditions.   There are several  conditions
 where the use of respiratory protective devices require special preparations.

        1)   Dangerous Atmospheres - If respiratory protective devices are to
 be used in atmospheres immediately dangerous to life or health,  a standard
 operating procedure for work in high hazard areas must be written.   (See
Appendix B,  Model Standard Operating Procedure, Respirator Use,  High Hazard
Areas.)  The standard operating procedure must as a minimum cover the following
 points.
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                                    16.

               Individuals designated to enter into dangerous  atmospheres
must have  training with the proper equipment.  These  individuals must be
equipped with safety harnesses and safety lines so that  they can be removed
from the atmosphere if necessary.

               Designation and provision of a standby individual, equipped
with proper rescue equipment,  who mu3t be present in a nearby  safe area
for possible emergency rescue.

               Provision for communication between persona in  the dangerous
atmosphere and the standby person must be made.  Communication may be visual
or by voice, signal line,  telephone, radio, or other suitable means.

Other important data such  as toxicological information and emergency phone
numbers should be included.

        2)  Confined Spaces -  Confined spaces are defined as enclosures
where the existing ventilation is insufficient to remove dangerous air
contamination and/or oxygen deficiency which may exist or develop and ready
access or egress for the removal of a suddenly disabled employee is difficult
due to the location and/or size of the opening(s).   These special precautions
must be taken:

               Before entering a confined space,  tests should be made to
determine the presence and concentration of any flammable gas, toxic air-
borne particulate, vapor,  gas, and oxygen concentration.

               If the concentration of a flammable substance exceeds 25 per-
cent of the lower explosive limit, the confined space must be force ventilated
to keep the concentration  well below the lower explosive limit.  The concen-
tration of contaminant or  oxygen percent should be continuously monitored
while individuals are working  in the confined space.

               Only individuals specially trained should be allowed to enter
confined spaces and the proper respiratory protective devices must be worn.

                   Air-purifying respirators and airline type supplied-air
respirators may be worn in a confined space only if the tests show that the
atmosphere contains adequate oxygen and that air contaminants are well below
levels immediately dangerous to life or health.  While employees wearing
these types of  respirators are in a confined space, the atmosphere must be
monitored continuously.

                   If the  atmosphere in a confined space is immediately
dangerous to life or health due to a high concentration of air contaminant or
oxygen deficiency, employees entering the space must  wear a positive pressure
SCBA or a combination airline  and a positive pressure SCBA.

               A standby individual with proper rescue equipment, including
an SCBA,  must be present outside the confined space for possible emergency
rescue.   Communication must be maintained via voice,  signal line, telephone,
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                                    17.

 etc.,  between employees in  the confined space and the  standby  person.  The
 employee  inside the confined space must be equipped with  safety harnesses and
 safety  lines to allow removal in case of an emergency.

        3)  Low and High Temperatures - The use of respiratory protective
 devices in low temperatures can create several problems.  The  lenses of  the
 full  facepiece equipment may fog due to condensation of the water vapor  in
 the exhaled breath.  (Coating the inner surface of the lens with an anti-
 fogging compound will reduce fogging.  Noae cups that direct the warm, moist
 exhaled air through the exhalation valve without touching the  lens are
 available from manufacturers for insertion into the full  facepiece.)  The
 exhalation valve can freeze onto the valve seat due to the moisture in the
 exhaled air.   The user will be aware when this situation  occurs by the
 increased pressure in the facepiece.  (When unsticking the valve, care
 should be taken so as not to tear the rubber diaphragm.)

 Respirator usage in hot environments can put additional stress on the user.
 The stress can be minimized by using a light-weight respirator with low
 breathing resistance.  An airline type atmosphere-supplying respirator
 equipped with a vortex tube can be used.  The vortex tube may  either cool
 or warm the supplied air (depending on the connection and setting).  This
 protection scheme can be used in both hot and cold environments.

    d.  Special Problems in Respirator Use

        1)  Facial Hair - Facial hair lying between the sealing surface of
 a respirator facepiece and the wearer's skin will prevent a good seal.  If
 the respirator permits negative air pressure inside the facepiece during
 inhalation,  there will be excessive penetration by an air contaminant.  Even
 a few days growth of stubble will permit excessive contaminant penetration.
 Any employee  who has stubble, a moustache,  sideburns, or a beard that
 passes between his face and the sealing surface must not wear  a respirator
 that allows  negative pressure inside the facepiece during inhalation.

        2)  Corrective Lenses - Spectacle temple bars or straps that pass
 between the  sealing surface of a full facepiece and the wearer's face
 prevent a good seal.   Therefore,  spectacles that have temple bars or straps
must not be  used when a full-facepiece  respirator must be worn.  Spectacles
with short temple bars that do not protrude between the sealing surface and
 the user's face,  or spectacles without  temple bars which-are taped to the
wearer's face may be used temporarily.   Special corrective lenses that can
 be mounted inside the full facepiece are available and should  be used by
employees who need them.   The special corrective lenses must be mounted
 in the full  facepiece by a qualified person to ensure good vision,  ccxufort,
and proper sealing of the facepiece.  Spectacles or goggles may also
 interfere with quarter- or half-masks.   They must be worn so as not to
interfere with the seal of the facepiece.   If there is interference,  a full
 facepiece respirator should be worn to  avoid sealing problems.

Contact lenses must not be worn while wearing a respirator in  a comtaminated
atmosphere.   A properly fitted respirator may stretch the  skin around  the
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                                    18.

eyes, crea'ting the  possibility  that the contact lens will fall out.  Also,
contaminants that do  penetrate  the respirator could get underneath the
contact lens and cause  severe discomfort.  The user's first reaction would
be to remove the facepiece  to remedy the situation - which could be fatal
in a lethal environment.

        3)   Other Sealing Problems - Scars, hollow temples, very prominent
cheekbones, deep skin creases,  and lack of teeth or dentures may cause
respiratory facepiece sealing problems.  Full dentures should be retained
when wearing a respirator,  but  partial dentures may or may not have to be
removed, depending  upon  the  possibility of swallowing them.  With full
lower dentures, problems in  fitting quarter-masks can be expected, as the
lower part  of the mask  tends to unseat the denture.  Persons with punctured
ear drums also should not wear  respirators.

8.  TRAINING AND FITTING

    a.   Training.   Selecting the respirator appropriate for a given hazard
is important, but equally important is using the selected device properly.
Proper use  can be ensured by carefully training both supervisors and users
in selection, use,  and maintenance of respiratory protective devices.  The
content of  a training program can vary widely, depending on the needs,
however, OSHA requires  that  the training of both users and supervisors
include the following, no matter what the circumstances:

        1)   An opportunity  to handle the respirator,

        2)   Proper  fitting,

        3)   Test of facepiece to face seal,

        4)   A long  familiarizing period of wear in normal air.

The training of users and supervisors for specific use situations should
also include:

        1)   A discussion of  the engineering and administrative controls in
use and why respirators are needed.

        2)   Explanation of  the  nature of the respiratory hazard and what
would happen if the respirator  is not used properly,

        3)   Explanation of why  a particular type of respirator has been
selected,

        4)   A discussion of how to recognize and handle emergencies.

The training requirements apply to both large and small groups or units of
employees required  to wear  respiratory protective devices, with no differen-
tiation to  meet individual  needs.
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                                    19.

        1)  Supervisor - Supervisors who oversee  the daily activities of
one or more employees who wear respirators frequently  should have a know-
ledge of respirators and respiratory protec'tion practices.  Supervisory
training should include, but not be limited to, the following areas.

               Basic respiratory protection practices,

               Selection and use of respirators to protect each employee
against every respiratory hazard to which he/she may be exposed,

               The nature and extent of the respiratory hazards to which
the employees may be exposed,

               The structure and operation of  the entire respirator pro-
gram.  The supervisor should understand his/her responsibility to facilitate
the implementation of the program, including maintenance that the employee
may be expected to do,  issuance of respirators, control of their use, and
evaluation of the program's effectiveness.

               The legal requirements pertinent to use of respirators in
his/her area of jurisdiction.

These supervisory training requirements apply  to the large groups or field
units with employees required to use respiratory protective devices.  A
smaller group or field unit may have to combine the supervisor training
with that of the employee.   This will benefit  the employees because they
will receive more comprehensive training.

        2)  Employee Instruction and Training  - EPA Order 1440.3 requires
that employees receive a minimum of six hours  of initial training, and two
to four hours annually thereafter.  This is a minimum requirement.  The
extent and frequency of the employee's training will depend on the nature
and extent of the hazard.   If the hazard is a nuisance particulate,  for
example, the danger from misuse of the respirator is not likely to be serious.
However, against highly toxic particulates, a  single misuse may have serious
consequences.  The same is  true for gases  and vapors.   If the respirator
is to be used in an emergency,  training in its use should be very thorough
and complete.  In any case,  the employee must be given some instruction
and training in respiratory protection practices.   Because proper respirator
use depends upon the employee's motivation, it is important that the need
for respiratory protection  be explained fully.  The following points should
be included in a minimum acceptable respiratory protection training program.

               Instruction  in the nature of the hazard, whether acute,  chronic,
or both, and an honest  appraisal of what may happen if the respirator is
not used.

               Explanation  of why more positive control is not immediately
feasible.   This should  include recognition  that every  reasonable effort is
being made to reduce or eliminate the need  for respirators.

               Discussion of why the proper typ-2 of respirator must be
used for each particular hazard.

               Discussion of respirator capabilities and limitations.


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                                    20.

               Instruction and training in actual use of th« respirator.

               Classroom and  field training in recognizing and coping with
emergencies.

               Proper  fitting.

               Other special  training as needed.

The major thrust of  the  training is toward explaining as much as possible
the reasons for wearing  a  respirator.  This is to motivate the user to
accept the fact that protection is necessary, and to instill in him/her
the desire to wear and maintain his/her respirator properly.   Just giving
a respirator to ar. employee with orders that it must be worn because OSHA
says so is one of the  easiest  ways to ensure its misuse.  It is also a
cop-out by management.   (See Appendix C,  Employee Training  Program.)

At best, a respirator may  cause discomfort and inconvenience, so there is
a natural resistance toward wearing it conscientiously.   Most of an employee's
natural resistance can be  overcome by taking the time and effort to inform
the user why he/she needs  the  respirator.   This effort will create easier
acceptance of respirators  and  contribute to correct use.

    b»   Fitting.  The proper fitting of respiratory protective devices
requires the use of some type  of fit test.   The fit test is needed to deter-
mine a proper match between the facepiece of the respirator and the face of
the user.

        1)  Test Atmospheres -  It is required that the user be allowed to
test the facepiece to face  seal of the respirator and wear  it in a test
atmosphere.   The test atmosphere amounts to an enclosure in which the user
can enter with the equipment on,  and a "test" atmosphere (of  low toxicity)
can be generated.

Elaborate enclosures are available commercially, but a "do  it yourself"
qualitative fit test enclosure  can be put together by the use of a plastic
bag, several hangers, and  some  cotton.   This enclosure is illustrated on
the following page.

        2)  Test Methods -  There are two types of tests: Qualitative tests
and quantitative tests.  The selection of  one or both types of tests  depends
on the severity and extent  of  the respiratory hazard and the  size of  the
unit or number of employees involved in wearing respiratory protective
devices.  During any fitting test,  the respirator headstraps  must be  as
comfortable as possible.  Tightening the straps will sometimes reduce
facepiece leakage, but the  user may be unable to tolerate the respirator
for any length of time.

               Qualitative  Tests -  Qualitative tests are fast, require no
complicated expensive equipment,  and are easily performed.   However,  these
tests rely on the user's subjective response,  and so are not  entirely
reliable.   There are two major  qualitative  tests:
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                                    21.
                 Hangers
              Cotton Wad
      Ho!«
Plaslic Bag
                   Isoamyl Acetate - Isoamyl acetate,  a low toxtcity  sub-
stance with a banana  oil  like  odor,  Is."used widely  in  testing  the  facepiece  fit
of organic vapor cartridge/canister respirators.  The  substance  Is applied
to the cotton wad inside  the enclosure.   The user should put on  the respira-
tory protective device  in an area away from the test enclosure so  that  there
is no prior contamination of the cartridge or "pre-exposure" to  the isoamyl
acetate.   The user should perform the following.

                   ...  Normal breathing.

                   ...  Deep breathing,  as during heavy exertion.   This
should not be done long enough to cause hyperventilation.
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                                    22.-

                ...   Side-to-side and up-and-down head movements.  These
movements should be  exaggerated,  but should approximate those Chat 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  iosamyl acetate test is that the odor threshold
varies widely among  individuals.   Also, the sense of smell is easily dulled
and nay deteriorate  during the test so that the user can detect only high
vapor concentrations.   Another disadvantage is that isoamyl acetate smells
pleasant, even in  high  concentrations.  Therefore, a user may say that Che
respirator fits although  it has a leak.  A user may say that a respirator
fits because he/she  likes  the  fit of the particular respirator or is
following the respirator  selection of another employee.  Conversely, a
user may claim that  a particular  respirator leaks if it is uncomfortable,
etc.  Therefore, unless the employee is highly motivated toward wearing
respirators,  the results  of this  test must sometimes be suspect.

                Irritant  Smoke Test - The irritant smoke test, similar to
the isoamyl acetate  test  in concept,  Is used widely in testing the facepiece
fit of particulate filter  respirators.  This test can be used for both air-
purifying and atmosphere-supplying respirators, but an air-purifying
respirator must have a  high-efficiency filter.  The test substance is an
irritant (stannic  chloride or  titanium tetrachloride) which is available
commercially in sealed  glass tubes.  When the tube ends are broken and air
passed through them,  a  dense irritating smoke is emitted.   In this test,
the user steps into  the test enclosure and the irritant smoke is  sprayed
into the test hole.   If the user  detects any of the Irritant smoke,  it
means a defective  fit,  and adjustment  or replacement of the respirator
is required.   The  irritant smoke  test must be performed with caution
because the^ aerosol  is  highly  irritating to the eyes^ skin,  and mucous
membrane.  As a qualitative means of determining respirator fit,  this
test has a distinct  advantage  in  that the wearer usually reacts involuntarily
to leakage by coughing  or  sneezing.  The likelihood of giving a false
indication of proper fit  is reduced.

                Negative  Pressure Test - This test (and the positive pressure
test) should be used only  as a very gross determination of fit.   The wearer
should use this test just  before  entering the hazardous atmosphere.   In this
test, the user closes off  the  inlet of the canister, cartridge(s)  or filter(s)
by covering with the palm(s) or squeezing the breathing tube so that it
does not pass air; inhales gently so that the facepiece collapses slightly;
and holds his/her  breath  for about 10 seconds.

If the facepiece remains  slightly collapsed and no inward  leakage is
detected, the respirator  is probably tight enough.  This test, of course,
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                                     23.

can only be used on respirators with tight-fitting facepiecea.  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
face.  This handling can modify the facepiece seal.  A second drawback is
that, with a negative pressure in the facepiece, a leaking facepiece may
be drawn tightly to the face to form a good seal, giving a false reading
of a good seal.

            ..   Positive Pressure Test - This test, similar to the negative
pressure test,  is conducted by closing off the exhalation valve and exhaling
gently into the facepiece.  The fit is considered satisfactory if slight
positive pressure can be built up inside the facepiece without any evidence
of outward leakage.  For some respirators, this nethod requires that the
wearer remove the exhalation valve cover; this often disturbs the respirator
fit even more than does the negative pressure test.  Therefore, this test
should be used  sparingly if it requires removing and replacing a valve
cover.  The test is easy for respirators whose valve cover has a single
small port that can be closed by the palm or a finger.

        2)  Quantitative Tests - Quantitative respirator performance tests
involve placing the user wearing the device in an atmosphere containing an
easily detectable,  relatively nontoxic gas, vapor, or aerosol.  The atmos-
phere inside the respirator is sampled continuously through a probe in the
respiratory-inlet covering.  The leakage is expressed as a percentage of
the test atmosphere outside the respirator, called "percent of penetration,"
01 simply "penetration."  The greatest advantage of a quantitative test
is that it indicates respirator fit numerically, and does not rely on a
subjective response.  The quantitative fit test is highly recomended
when facepiece  leakage must be minimized for work in highly toxic atmos-
pheres or those immediately dangerous to life or health.  (See Appendix D,
Respirator Protection Factors.)

The quantitative tests require expensive (up to $10,000) equipment that
can be operated only by highly trained personnel.  Also, it is difficult
to use because  of its complexity and bulk.  Each test respirator must be
equipped with a sampling probe to allow continual removal of an air sample
from the facepiece so the same facepiece cannot be worn in actual service,
since the test  orifice negates the approval of the respirator.

                Sodium Chloride (NaCl) Test - In this test, a liquid aerosol
is generated continuously from a salt water solution, dried to produce dis-
crete submicron salt particles, and dispersed into a test chamber or hood.
A means is provided for sampling the atmosphere in the chamber or hood
and inside the  respirator.  These samples are fed to the analyzing section
where the aerosol's penetration inside the respirator is determined.   The
amount of penetration is displayed on a meter or recorder.

            ..   Dioctyl Phthalate (DOP)  Test - The dioctyl phthalate (OOP)
quantitative fitting test, which uses an air-generated DOP serosol,  differs
from the NaCl test  only in that the aerosol particle is liquid.  The aerosol
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                                    24.

is generated using  a  nozzle-type atomizer, but being an oil, DOP does not
dry into solid particles  when injected into a diluting air stream.

9.  RESPIRATORY PROTECTIVE  DEVICE INSPECTION, CLEANING, MAINTENANCE, AND
STORAGE.  Scrupulous  respirator maintenance must be made an integral part
of the overall respirator program.   Wearing poorly maintained or malfunc-
tioning respirators is, in  one sense,  more dangerous than not wearing a
respirator at all.  The employee wearing a defective device thinks he/she
is protected when,  in  reality,  he/she  is not.  Emergency escape and rescue
devices are particularly  vulnerable to poor maintenance as they generally
are used infrequently, and  then in the most hazardous and demanding cir-
curastances.  The possible consequences of a user wearing a defective
emergency escape and  rescue  device  are lethal.

A proper maintenance  program ensures that the user's respirator remains
as effective as when  it was  new.   All  programs are required to include as a
minimum:

    a.  Inspection  for defects  (including a leak check),

    b.  Cleaning and  disinfecting,

    c.  Repair,

    d.  Storage.

    a.  Inspection  of Respiratory Protective Devices.  An important part
of a respirator maintenance  program is the inspection of the devices.  If
performed carefully,  inspections will  identify damaged or malfunctioning
respirators.

        1)   Inspection Schedules -  All respiratory protective devices must
be inspected:

            o  Before and after each use; and

            o  During cleaning.

        Equipment designated for emergency use must be inspected:

            o  After  each use;

            o  During cleaning;  and

            o  At least monthly.

        Self-contained breathing apparatus must be inspected:

            o  At least monthly.

        2)   Recordxeeping -  A record must be kept of inspection dates and
findings for respirators  maintained for emergency use.
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                                    25.

        3)  Inspection Considerations - The primary defects to look for in
 the  inspection of the components of the respirator are itemized below.
 Information within the parentheses are suggested actions to be taken,

            o  Disposable respirator

                  Holes in the filter (obtain new disposable respirator);

                  Straps for elasticity and deterioration (replace straps -
 contact manufacturer); and

                  Metal nose clip for deterioration, if applicable (obtain
 new  disposable respirator).

            o  Air-purifying respirators (quarter-mask, half-mask, full
 facepiece and gas mask)

                  Rubber facepiece - check for:

                  ..   Excessive dirt (clean all  dirt from facepiece);

                  ..   Cracks,  tears, or holes (obtain new facepiece);

                      Distortion (allow facepiece to "sit" free from any
 constraints and see if distortion disappears; if not,  obtain new facepiece);
 and

                      Cracked,  scratched,  or loose fitting lenses  (contact
 respirator manufacturer to see if replacement is possible;  otherwise obtain
 new  facepiece) .

                  Headatraps  -  check for

                      Breaks  or tears  (replace headstraps);

                      Loss of  elasticity (replace headstraps);

                      Broken  or malfunctioning buckles or attachments
 (obtain new buckles);  and

                      Excessively worn serrations on the  head harness  which
might allow the  facepiece to  slip (replace headstrap).

                  Inhalation valve,  exhalation valve - check for:

                      Detergent residue, dust particles,  or  dirt  on valve
or valve seat (clean  residue with soap and water);

                      Cracks,  tears, or distortion in  the valve material
or valve seat (contact manufacturer  for instructions);  and

                      Missing  or defective valve cover (obtain  valve  cover
from manufacturer).
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replacement);
                                    26.

                  Filter element(a)  - check for:

                      Proper filter for the hazard;

                      Approval designation;

                      Missing or worn gasketa (contact manufacturer for
                      Worn threads - both filter threads and facepiece
threads (replace filter  or facepiece, whichever is applicable);
harness);  and
                      Cracks  or  dents in filter housing (replace filter);

                      Deterioration of gas mask cannister harness (replace
                  ..   Service  life indicator, or end of service date - for
expiration, gas mask  (contact  manufacturer to find out if filter element
has one; if not ask what will  indicate the "end of service").

                  Corrugated beathing tube (gas mask)  - check  for:

                      Cracks or holes (replace tube);

                      Missing  or loose hose clamps (obtain new clamps);  and

                      Broken or missing end connectors (obtain new connectors).

            o  Atmosphere  Supplying Respirators

                  Facepiece, heads traps, valves, and breathing tube -  These
items should be checked as  for the air-purifying respirators.

                  Hood, helmet, blouse, or full suit,  if applicable -
check for:

                      Rips  and torn seams (if unable to repair the tear
adequately, replace);

                      Headgear suspension (adjust properly for you);

                      Cracks or breaks in faceshield (replace  faceshield) ;  and

                      Protective screen to see that it is intact and fits
correctly crier: the faceshield, abrasive blasting hoods, and blouses (obtain
new screen).

                  Air  supply system - check for:

                      Breathing air quality;
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                                    27.

                      Breaks or kinks in air supply hosca and end  fitting
attachments (replace hoae and/or fitting);

                      Tightness of connections;

                      Proper setting of regulators and valves (consult
manufacturer's recommendations); and

                      Correct operation of air-purifying elements and carbon
monoxide or high temperature alarms.

            o  Self-contained breathing apparatus (SCBA.) - (See Appendix E.)

    b.  Cleaning and Disinfecting.   When respiratory protective devices
are used routinely,  the respirators should be cleaned and disinfected daily.
If respirators are used only occasionally, periodic cleaning and disinfecting
is appropriate.

        1)  Methods  - The actual cleaning may be done in a variety of ways.

            o  The respiratory protective device should be washed with
detergent in warm water using a brush,  thoroughly rinsed in clean water, and
then air dried in a  clean place.  Care should be taken to prevent damage
from rough handling.   This method is an accepted procedure for a small group
or unit of employees  where each employee cleans his/her own respirator.

            o  A standard 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 and where respirator
usage is extensive.

        2)  Detergents and disinfectants - If possible, detergents containing
a bactericide should  be used.   Organic  solvents should not be used, as they
can deteriorate the rubber facepiece.   If the above combination is not avail-
able,  a detergent may be used,  followed by a disinfecting rinse.   Reliable
disinfectants may be  made from some available household solutions.

            o  Hypochlorite solution (50 parts per million (ppoi)  of chlorine)
made by adding approximately two tablespoons of chlorine bleach per gallon
of water.   A two-minute immersion disinfects the respirators.

            o  Aqueous solution of  iodine (50 ppm made by adding  approxi-
mately one teaspoon of tincture of  iodine per gallon of water).   Again, a
tvo-minute Inweraion  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.

        3)   If the respirators  are  washed by hand,  a separate  disinfecting
rinse  -nay  be provided.   If  a dish or clothes washing machine  is used the
disinfectant must be  added  to  the rinse cycle,  and  the amount  of  water in the
machine at that time  will have  to be measured to determine the correct
amount of  disinfectant to  be added.
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                                    28.

        4)  Rinsing - The cleaned and disinfected respirators should be
rinsed  thoroughly in clean water (120  F maximum) to remove all traces of
detergent, cleaner and sanitizer, and disinfectant.  This is very important
to prevent dermatitis.

        5)  Drying - The respirators may be allowed to dry by themselves
on a clean surface.   They also may be hung from a horizontal wire, like
drying clothes,  but care must be taken not to damage the facepieces.

    c.  Maintenance^  Continued usage of respiratory protective devices
may require periodic repair or replacement of component parts of the
equipment.  Such repairs and parts replacement must be done by a qualified
individual(s).

Replacement of  parts and repair of air-purifying respirators, in most cases,
present little  problem.   Most equipment manufacturers supply literature which
details the component parts of their respirator and include servicing infor-
mation.  The manufacturer will also provide replacements parts.   Replacement
parts for respiratory protective devices must be those of the manufacturer
of the equipment.   Substitution of parts from a different brand or type of
respirator will  invalidate the approval of the respirator.

Defective air-supplying  respiratory protective equipment, with the exception
of the SCBA,  can be  repaired and worn if broken parts are replaced by a
qualified individual - again with the aid of the manufacturer's literature
and parts.  Maintenance  of SCBA. equipment is more difficult, primarily
because of the valve and regulator assembly.  Because of this, regulations
require that SCBA. equipment be returned to the manufacturer for adjustment
or repair.

    d.  Storage.   All the care that has gone into cleaning and maintenance
of a respirator  can  be negated by improper storage.   Respiratory protective
equipment must be stored to protect it from dust, sunlight,  heat,  extreme
cold, excessive  moisture,  and damaging chemicals.  Leaving a respirator
unprotected can  lead to  damage of the working parts or permanent distortion
of the facepiece,  thus making it ineffective.

After cleaning and disinfecting the respirators, they should be placed
individually in  heat-sealed or resealable plastic bags until reissue.   They
should be stored in  a single layer with the facepiece and exhalation  valve
in a more or less normal position to prevent the rubber or plastic from
taking a permanent distorted "set".

        1)  Air-purifying respirators - Air purifying respirators  kept
ready for nonroutine or  emergency use should be stored in a cabinet in
individual compartments.

        2)  Air-supplying respiratory protective equipment - A storage chest
for self-contained breathing apparatus may be purchased from the manuf ac turer.
All storage cabinets should be located in noncontaminated, but readily
accessible,  areas.
                                   176

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                                  29.

 10.  MEDICAL ASPECTS OF RESPIRATORY EQUIPMENT USAGE.  EPA Order 1440.3,
 Respiratory Protection, requires that employees assigned to tasks requiring
 the use of respiratory protective devices must have a medical evaluation,
 defined by the Agency's Occupational Medical Monitoring Guidelines.  There
 must be a determination that employees are physically capable of performing
 the work while wearing the devices.  These requirements are necessary because
 the use of any type of respirator may Impose some physiological stress on
 the user.  Air-purifying respirators, for example, make breathing more
 difficult because" the filter or cartridge Impedes the flow of air.  The
 special exhalation valve on an open circuit pressure demand respirator
 requires the user to exhale against significant resistance.  The bulk and
 weight of an SCBA can be a burden.   If the employee is using an airline
 respirator, he/she might have to drag up to 300 feet of hose around.  All
 of these factors can significantly Increase the employee's workload.

 So that the examining physician can give a qualified opinion regarding
 whether an employee can use a respirator, the Agency should provide the
 following information.  (See Appendix F, Duty Status Report.)

     a.  Type of respiratory protection equipment to be used,  and Its modes
 of operation;

     b.  The tasks that the employee will perform while wearing the respirator;

     c.  7isual and audio requirements associated with the task;

     d.  Length of time that the employee will wear the respiratory
 protective equipment;  and

     e.  The substance(s)  to which the employee will be exposed,  and the
 related toxicity data.

The following checklist will give the Respiratory Protection Program Manager
 a good indication of the employee's ability to wear a respirator.

     a.  Lung

         	 History of asthma or emphysema.

         	 Difficulty In breathing.

         	 Previously documented  lung  problems.

     b.  Heart

         	 High blood pressure.

         	 Artery  diseases.

         	 Documented heart  problems.

     c.  Other
                                 177

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                                    30.

        	-Missing or arthritic fingers.

        	  Facial scars.

        	  Claustrophobia.

        	  Poor eyesight.

        	  Perforated ear  drum(s).

A "yes" answer  to any of these questions would constitute a warning sign
regarding the use of respirators by an employee.   A medical opinion to
confirm any of  these situations should then be obtained.

11.  EVALUATION OF THE RESPIRATORY PROTECTION PROGRAM.   Two important aspects
of the respirator program are the periodic surveillance of the work areas
which require use of respirators, and an evaluation of  the program for effect-
iveness.

    a.  Surveillance of the  Work Area.  Many things can affect the need to
use respirators.   To determine the continued necessity  of respiratory
protection or need for additional protection, there should be appropriate
surveillance of the work area conditions and the  degree of employee exposure
or stress to allow for program changes as needed.

    b.  Program Evaluation.   The respirator program at  each Agency unit
should be evaluated at least annually, with program adjustments,  as appro-
priate, made to reflect the  evaluation results.   The following are areas
of the Respiratory Protection Program that should be evaluated.

        1)   Program Administration

            o  Program responsibility is vested in one  individual who is
knowledgeable and who can coordinate all aspects  of the program.

            o  The implementation of engineering  controls, if feasible,
to alleviate the need for respirators is in progress.

            o  There are written procedures/statements  covering these aspects
of the respirator program.

                  A Program  Manager has been designated.

                  Procedures for respirator selection are developed.

                  The purchase of approved equipment is assured.

                  The procedures for issuing respiratory  equipment are in
place.

                  The medical aspects of respirator usage are defined and a
program is  in place.
                                    178

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                                     31.

                  Employees are properly fitted  for respiratory protective
 devices.
                  Provisions for  the maintenance, storage, and repair
 of  respiratory protective equipment are being followed.

                  There is a program for regular inspection of respiratory
 protective equipment, and

                  The provisions  for use of respiratory protective  equipment
 under  special conditions are defined.

        2)  Program Operation

            o  The selection of respiratory protective equipment consider
 these  factors:

                  The work area conditions and employee exposures.

                  Respirators are selected on the basis of hazards  to
 which  the employee is exposed.

                  The selection of respirators is made by knowledgeable '
 individuals.

            o  Only approved respirators are purchased and used to provide
 adequate protection for specific hazards and concentrations of contaminants.

            o  Respirators are issued to users for their exclusive use,
 where  practical,  and records are maintained covering the issuance.

            o  The fitting of respiratory protective equipment taken into
 consideration these factors:

                  Users are given the opportunity to try on several different
 brands of respirators to assure that the make of respirator they will be
 wearing is the best fitting one.

                  Respiratory protective equipment is fit tested at appropriate
 intervals.

                  Respiratory protective equipment users who require corrective
 lenses are properly fitted.

                  Respiratory protective equipment users are prohibited from
wearing contact  lenses  when using the respirator.

                  Facepiece to  face seal is tested in a test atmosphere.

           o The maintenance  of respiratory protective equipment covers
 these  factors.

                  Cleaning and  Disinfecting -


                                  179

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                                    32.

                      Respirators are cleaned and disinfected after each
use when different employees use the same device or as frequently as
necessary for devices issued to individual users.

                      Proper methods of cleaning and disinfecting are
utilized.

                  Storage

                      Respirators are stored in a manner so as to protect
them from dust,  sunlight,  heat, excessive cold or moisture, and damaging
chemicals.

                      Respirators are stored properly to prevent them from
deforming.

                  Inspection

                      Respirators are inspected before and  after each use
and during cleaning.

                      Employees/users are instructed in inspection
techniques.

                      Respiratory protective equipment designated for
emergency use is  inspected at least monthly (in addition to after each use),

                      Records are kept of the inspection of emergency use
respiratory  protective equipment.

                  Repair

                      The  replacement parts used for repairing respirators
are those of the  manufacturer of the respirator.

                      Repairs are made by knowledgeable individuals.

                      Repairs of SCBA's are made by certified personnel
or by a manufacturer's representative.

                  Special  Use Conditions

                  ..   Procedures are developed for the use  of respiratory
protective equipment  in atmospheres iranediately dangerous to life or  health.

                      Procedures are developed for equipment usage for
entry into confined spaces.

               .   Training

                      Employees are trained in proper usage of respiratory
protective equipment.

                      Employees are trained in the basis for respirator
selection.


                                   180

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                                       33.


                                  REFERENCES

1.  EPA Order 1440.3,  Respiratory Protection. July 24, 1981.

2.  Department of  Labor,  OSHA,  Occupational Health and Safety Standards.
    29 CFR Part 1910.134,  General Respirator Requirements, Federal Register,
    Volume 37, Number  202,  October 18,  1972.

3.  Department of  Labor,  OSHA,  Occupational Health and Safety Standards,
    29 CFR 1910.94,  111,  252,  261, 262,  265, 266, 1001-1029,  Specific Respirator
    Requirements,  Federal  Register,  Volume 37, Number 202, October 18, 1972.

4.  Department of  the  Interior,  Bureau  of Mines, Respiratory  Protective Devices;
    Tests for Permissibility;  Fees,  30  CFR Part 11, Federal Register, Volume
    37, Number 59, March  25,  1972.

5.  American National  Standards  Institute, Standard Z88.2-1969,  Respirator
    Practices, ANSI,  1430  Broadway,  New York, N. Y. 10018.

6.  American National  Standards  Institute, Standard Z88.2-1980,  Practices for
    Respiratory Protection, ANSI, 1430  Broadway, New York, N. Y.  10018.

7.  American Conference of  Governmental Industrial Hygienists, Threshold Limit
    Values for 1973  (and  current year),  ACGIH, 1014 Broadway, Cincinnati,
    Ohio 45202.
NOTE:  Information  from  these  references is either used or referred  to  in this
guideline.   A copy  of  the  complete  text of the references is valuable in setting
up and managing  a respiratory  protection program.   It is recommended that copies
of these references be obtained  and filed with this guideline.
                                       181

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                                                       APPENDIX A


                                    34.

                  Respiratory Protective Device Recommendation
Kame of Employee/User
Program Office 	.	Telephone Number


Anticipated Hazards

   1.  Materials

       a.   Chemical Name       ..

       b.   Trade Name 	

       c.   Formula   •	
       d.  TLV or TWA.	OSHA 1910.1000	Other

   2.  Form of Materials

       a.  Liquid?	b.   Solid?	 c.  Gaseous?
       d.  If gaseous,  is  it an organic vapor? 	or acid gas?

           other? 	

   3.  Maximum expected concentration

       a.  	parts per million,  or

       b.  	milligrams per cubic meter

   4.  Will material be heated? 	  If so,  to what temperature?

   5.  What is the  odor threshold of the material?	
   6.  At what concentration is the material considered to be Immediately
       dangerous to life or health? 	
   7.  Can the substance be absorbed through the skin?
   8.  Irritant to eyes? 	 respiratory tract? 	 skin?

   9. At what concentration is it an irritant?	
  10, If the substance is  known to be flammable,  what are the lower and
      upper flammable limits,  in per cent by volume? 	
  11. What is the vapor pressure of the material?
                                      182

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                                     35.




   12.  Will the material b« mixed with other chemicals? 	 If  so, give




       details 	
  13.  Any possibility of oxygen deficiency? ___________________________



  14.  Can good ventilation of th« area be maintained?            .



  15.  Will exposure be continuous?	 or intermittent? 	



  16.  Will the respiratory device be used for routine exposures, or vill



       it be used as an escape device? .
Respiratory Protective Device(s) Recommended":
Other Personal Protective Clothing or Equipment Recommended:
Date                                Respiratory Protection Program Manager
                                      183

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                                                        APPENDIX B
                                   36.

                                   MODEL
                       STANDARD OPERATING PROCEDURE
                              RESPIRATOR USE
                             HIGH HAZARD AREAS
 1.  Location:
 2.  Date of Preparation

 3.  Prepared by 	
 A.  Operation or Procedures where respirators are required
 5.  Type(a)  of respirator  to  be  used
 6.  Other Protective clothing  and  equipment required:

     Harness  	          Skin	

     Safety Lines 	          Head 	
     Eye Protection 	          Other
     Body 	 (full) 	 (partial)

 7.  Training  required: 	
 8.  Provisions  for  Standby  person:

 9.  Provisions  for  communication
10.  Conditions  under which  respirator is to be used

     Oxygen deficient? 	
     Type(s)  of  contaminants  ?

     Expected Concentrations?

     Peak Concentrations?
                                     184

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                                    37.


11.   Type and Frequency of Monitoring:
12.   Emergency Procedures  (include type of respirator,  protective clothing,
     cleanup procedures,  etc.,
    Comments
                                   185

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                                                                   APPENDIX C
                                           38.
             NOTES
      TO INSTRUCTOR
       EMPLOYEE TRAINING PROGRAM
                                 A. Why U respiratory protective equipment required?
Name work area
List substances
Describe activities
Describe chemical exposure

Describe areas

Name storage areas
Describe emergency situation
which could exist in your plant
Suggested phraseology
Plan to have ...
Describe what controls are to
be/being implemented
Discuss administrative controls
(rotating work schedules,
spreading work over two shifts,
etc.)
7. The Occupational Safety and Health Administration

OSHA has »et m""""*" exposure standards for many air-
borne toxk materials and has set standards governing specific
working environment* to protect your health. A recent evalua-
tion of your working environment revealed  that;
   a. In work  areas (****), atmospheric concentrations  of
   tubetances (****) were found to be above  acceptable limits.
   6. Maintenance activities (****) during which you are ex-
   posed to (****) t high concentration for  a short period of
  lime, lead to excessive exposure.
   c. Several areas (****) were found to be "oxygen deficient"
  -{see Appendix II)
   d. Hazardous substances are stored at (****) and if these
   substances spill, etc., an emergency condition will exist, or
   <****).

2. Status of Engineering Control*
(****) gjucj ^ coujpajjy recognize* that respiratory protec-
tion  is  not  the accepted method  for  control of airborne
haxarda, we are taking stepe to implement engineering control
solutions.
  a We (*•**) installed  the following  engineering controls
  (**•*)

  b. And the following administrative controls (****).
  However,  while the above step* are  being  implemented,
  respiratory protection will be required.
                                 B. Respirator Selection and Procedure
                                 Selection procedure of the proper equipment normally involves
                                 three steps: the identification of the hazard; the evaluation of the
                                 hazard; and finally the selection of the appropriate respiratory
                                 equipment based on the first two gtepe.
                                            186

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                                                39.
      TO
  NOTES
INSTRUCTOR
 Discuss only those contaminant
 atmospheres representing
 problems in your facility. See
 following discussion.
A further discussion of ODA's
can be found in Appendix H
      EMPLOYEE  TRAINING  PROGRAM

I. Identification of the Hazard

Effort we get into the "specifics" about the respiratory protec-
tive equipment you will be wearing, a few statements about
hazard identification.
There are several kinds of hazardous atmospheres which may
require the u*< of respirators, (****)
                            a Gaseous Contaminants
                            Gaicy are the normal form of substances like carbon di-
                            oxide or hydrogen sulfide. Thes* substances are solids or li-
                            quids only at very low temperatures or extremely high pres-
                            sures.  Carbon dioxide, for  instance, is a gas at room tem-
                            perature. But H also occurs as solid "dry ice" formed at low
                            temperature*,
                            Vapor* are exactly like gases except that they are formed by
                            the evaporation of substances,  such  as  acetone  or
                            trichlorethylene, which ordinarily occur as liquids.
                            6. Particulate Contaminants .
                            Particulates are tiny particles, solid or liquid, generated by
                            such processes as grinding, crushing, and mixing of a com-
                            pound, either a solid or a liquid. There are three types of
                            particulates.
                            Dutts  are solid particles produced  by such processes as
                            grinding, crushing, and mixing of powder  compounds. Ex-
                            amples are $and snd plaster dust. By comparison  to the
                            following two  types of participates,  dust particles are
                            usually large.
                            Mists are tiny liquid droplets, usually formed whenever a
                            liquid  is sprayed, vigorously mixed, or otherwise agitated.
                            Acid mists around diptanks used for metal  cleaning, and oil
                            mista near newspaper printing presses, are two examples.
                            Fume* are «olid condensation particles of extremely small
                            particle size. Fumes are found in the air near soldering,
                            welding, and brazing operations, as well as near molten
                            metal processes such as casting and galvanizing.
                            Two basic forms — gaseous and particulate — frequently
                            occur together. Paint spraying operations, for example, pro-
                            duce both paint mist  (particulate) and  solvent  vapors
                            (gases).
                            a Oxygen Deficient Atmospheres (****). Oxygen deficient
                            atmospheres (ODA) are most commonly found in confined
                            spaces  which have poor ventilation. Examples are silos,
                            petrochemical tanks, degreaaers, and the holds of ships.
                                              187

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                                       40.
           NOTES
    TO INSTRUCTOR

 After explaining to the employe*
 the type of hazardous
 atmosphere (a and/or 6 and/or
 c) requiring respiratory
 protection, you should then
 discuss the haiard specifics.
 Check vendor literature,
 toiicologic references, or
 Material Safety Data Sheet (or
 contact OSHA or NIOSH
 regional offices).

 See Figure I.
 Refer to Appendix. 1 to describe
 the type instrument used
 (optional).
 See Appendix V.
     EMPLOYEE TRAINING  PROGRAM
 2. Hazard Specifics (****)
   a. Hazard Name
   •  Organic vapor (name)
   •  Particular (name)
   •  Gas (name)

   b. Toxkity Data (****)
   •  Effects
 See Appendix IV.
 3. Evaluation of the Hazard (****)
   a. To determine the concentration of the haiard, as iden-
   tified above, measurements were made.  (****) The  con-
   centration and/or work environment examined were com-
   pared with the published Federal Standards (**•*).
 4. Selection of the Respirator
   a. After it was determined that respirators were required,
   the Standards  Completion Program (SCP) was consulted
   to find out the required respiratory protection equipment
   <••*»).
                                 C. UM and Proper Fitting of Respiratory Protective Equip-
                                 ment
Using Appendix VII and
information supplied by the
manufacturer, show the
employee how to put on the
selected respirator. Show the
various components of the
respirator, and how the
respirator functions to remove
the contaminants.

At this time, you should have
available at least two  different
types (different manufacturer*)
of selected respiratory
equipment — for the employee
to try on.
                                   1. Ufe of Respiratory Protective Equipment
2. Proper fitting
So that respiratory protective devices, which use tight fitting
facepieces, give maximum protection, there must be a proper
"match" between the facepiece and your face. A poor face seal
f*n cause contaminants to be inhaled through the respirator
sealing surfaces, instead of through the canister, filter, or air
supply system. (****)
  a In mo«t cases, there are several different brands of the
  same type of respiratory protection equipment approved for
  use against a specific haiard or work environment. (****)
                                         188

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                                            41.
           NOTES
    TO INSTRUCTOR

 Refer to Appendix VIII for
 discusaion of fitting testa. The
 qualitative fit tetti can be used
 u a quick test to a»c*rt*in the
 proper fit However, if respirator
 use will be in an extremely
 hazardous atmosphere, or for
 emergencies, the quantitative fit
 test should be used.
 Demonstrate how the
 qualitative fit test works. Show
 illustration of a quantitative
 test set-up (if there  is not an
 actual set-up on the premises).
         EMPLOYEE  TRAINING  PROGRAM
      b. However, just because a reapirator "feels comfortable" h
      does not mean that it is protecting you to the fullest extent
      from the hazard. The key word is proper fit. To determine if
      the fit » proper, »everal torts can b* used. (****)
 Consult Appendix VII and the
 specific respiratory protective
 equipment — under
 Limitations.
 D. Limitations of Respiratory Equipment (     )
 However, the respiratory protective equipment that you will use
 does have some limitations on its usage.
                                  E. Maintenance and Storage of Respiratory Equipment
Refer to Section VII(A) for
detafla concerning cleaning of
equipment Several suggested
cleaning methods are given.
Discu*s provisions.
Refer to Section VII(B) and
discuss storage provisions by
company.
Refer to Section VIII for
discussion on inspection for
defects.
To maintain the proper functioning of respirators requires that
they be regularly cleaned and disinfected, and stored in a conve-
nient and clear location.
  /. Cleaning (****)

  Your respiratory protective equipment should  be cleaned
  daily after use. The company has made provisions for doing
  this. (****)
  2. Storage (****)

  Equipment must be stored properly at  the conclusion  of the
  work shift.

  3. Inspection for Defects (****)

  This is one of the most important functions associated with
  respirator usage. These  inspections can identify damage to
  malfunctioning respiratory protective equipment.
                                             189

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                                      42.
       NOTES                        EMPLOYEE  TRAINING  PROGRAM
 TO  INSTRUCTOR


Before you discuss thi* section       F. 8umm»ry(**")
with the user, you should firwt
prepare the summary — a» it
applies to your usage.               A summary of those aspects of the proper u»e of respiratory pro-
                                tective equipment.  Reasons  for Respiratory Protective Equip-
                                ment.

                                  1. Rapiraior Selection Procedure
                                    a. Identification of hazard.
                                    b. Hazard specifics.
                                    c Evaluation  of the hazard.
                                    d. Selection of the respirator.
                                   «  y
                                  2.-Proper Fitting and Utage
                                      *
                                    c.Us«.
                                    6. Fitting.

                                  3. Limitation*

                                  4. Maintenance and Storage
                                   190

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                                                                        APPENDIX  D
                                                43.
                           RESf 1RATOR MIOTICT1ON FACTORS'
                                                            Fsceplcic*'
    	Type Ropirmtor	       fresjuri            Factor

    L    Air-Purifying
      ,    A. Paniculate1 removing
            SmjJe-u»c,* duu5                                     —                   5
            Qusrtcr-maik, dust* •                                  —                   5
            Hdf-fimk. dust*                                      -                  10
            HiJf- or Quirter-mAsk, fume7                           —                  10
            hUlf-or Quincr-maik, High-Efficiency*                  -                  10
            Full Faccpkce, High-Efficiency                         -                  50
            Powered, High-Efficiency, all enclosures                  +               1000
            Powered, dust or furae, all endocorei                    4-                  X*
          B. G*s and Vapor-Removing1*
            Half-Muk                                            -                  10
            Full Facepkce                                        -                  50

    II.    Acmojphere-Supplying
          A. Supplied-Air
            Dcinand, Half-maik                                    -                  10
            Demand,'Full Faccpiece                                -                  50
            Hose Maik Without Blower, Full Facepiee*                -                  50
            Pimurc-Demand, Half-Maik11                           +               1000
            Prewurc-Demand, Fufl Facepiece11                     ' +               2000
            Ho*< Mask With Blower, Full Facepiece                  -                  50
            Continuouj Flow, Haif-Ma*k"                           4-               1000
            Continuouj Flow, Full  Facepiece13                       *               2000
            Continuouj Flow, Hood, Hdmct, or Suit"                +•               2000
          B, Self-Contained Breathinf Apparatus (SCBA)
            Opcn-Circurt, Demand, Full Pacepicce                    -                 JO
            Open-Circuit, Pressure-demand  Fufl Pacepicce             +             10.00014
            aojcd-Circuit, Oxyjen Tank-type, Pull Pacepiece          -                 50

    III.   Combination Rejpinttor
         A. Any combination of air-purifying and                    Use minimum protection
           anncwphcrc-jupplying respirator.                         factor listed above for
         B. Any combination of supplkd-*ir                         type of mode of operation.
           respirator and an SCBA

           Exception: Combination supplievi-air respirators, in prcavure-demand or other positive
           prc&ure mode, with an auxiliary >df-contained air Ripply, and a full faccpkce, should
           u»e me PP for pressure-demand SCBA.
NOTE:   Reference "A Guide  to  Industrial Respiratory  Protection",  NIOSH
         June 1976                                                                     '
                                           1Q1

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                                         44.
 1 TV owrrafl pnxecrioo afforded by • frrea rwpinuor desifzi (tod mode of operation) may be
 4efiaed in terms of its prottetioc factor (FF). The fF • a measure of the decree of protection
 afforded  by * respirator, defined  as  tbt taiio  of die cmcen oration of cootjrm'nant in  ttx
 wnbient atmoapoere to diat tfttktr die e*cia*ure (inualry inside die dccpiece)  under coodi-
 tx>n« of Bte. Respirator* Aouid tx teiccted to diat d*e coocentratJon inhaled by tkc wearer
 wiB not exceed tie appropriate limit. The recoexnendcd resptnox PF» are Kkctioa aad o»e
 foido, aixl Aouid ooty be oed wi>ca dx  employer ILK cfftab&faed a BxoinuJ acceptable
 rapincor progrxic M ed-»ir boocb bckoco, or juitx.

 'ladudej dura, minx, and forpej only. Does aoc apply when gases or vapoo are absorbed oc
 parricalita and may be roUaliied or for ptrricolatrj Toktflc at room tanperwure. Example:
 Coke orcfl
 4Any  ain^e-o»e dxut  rejpirator (whh or  *idiout TaJre) oot  fpecifictlly rated  apiiut a
 ipetzfied conrtmrnant.
           dint ropinton tiare Wtn tt«ed ajiin« aibe«o« and cotton dust and couJd be
        a PF of 10 for d>oc parocalatei.

 *EKin filter refers  to a don mptrator approrcd by die silica dun text, and includes all types
 of media, rim is,  bodi a oodejridxbk mechanical type media  and  dcfradible resin-imprcf-
 B*ted wool feh or combination woc4-*ynthctic felt media.

 7 Fume filter refers to a fume rtspirnor approved by tbc lead fume tot. AD types of media are
 t&dudcd.

 *Hi{h -efficiency filter refen to a hijji -efficiency parti cuiixe respirator.  The filter murt be at
 Ictn 99:97% efficient ajaLaR 0.3 ^m E>OP to be approved.

 *To be ttajrxrd, bated on dust or fume filter efficiency for specific contaminant.

 **For fases and yapocs, a M7 should only be amjned when published  test data indicate die
 cartridge or canister hat adequate torbent efficiency and tervice life for a specific gas or vapor.
 In  addition,  the PF  should not  be  applied in  gas or  rapor  concentrations thtt are: 1)
 tmmediatdy danjcrous to Hfc, 2) above dve lower exploove Emit, and  3) cause eye irritation
 when nsinj a half-mask.

 11 A poaove pressure juppUed-«ir respirator equipped wrdi a half-mailc  faccpiece may not be
 M  jtabic on ri>e face  as  a  full faccpiece. Therefore, die PF recommended is half that for a
 •smiar derice equipped wkh a full facepiece.

 UA positive  pressure  supplicd-iir respirator etjuipped  with  a full  faccpiece provides  eye
 protection but t* not appro-red for uje in  anncwphcres immedittcry dangerous to life. It b
 recognized dial  the facepiece ktJtafe. when' a po«dve presjure  is maintjined, should be the
 same  as  an  SCBA operated in die pow'trve prarurc mode.  However,  co  crnphisirc  mar i:
• b*sically is not for emergency ate, dve PF is limited to 2,OOO.
                                       192

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                                           45.
13Thc design of the supplied-air hood, wit, or helmet (with a minimum of 6 cfm of air) may
determine its overall efficiency and protection.  For example, when working with the arms
over the hod, tome hoods draw the contaminant uto tbe hood breathing zone. This may be
overcome by wearing a short hood under a cost or oreralb. Other limitations specified by the
approval agency must be considered before using in certain types of atmospheres.

MThc SCBA opcnted b chc positive prcarorc mode h« been tested  on t selected 31-tmn
pand and the facepieoe leikage recorded as less than 0.01% penetration. Therefore, a PP of
10.0OO+ is recommended. At this time, the lower limit of detection 0.01% does not warrant
listing a higher number. A positive pressure SCBA for  an unknown concentration a  recom-
mended. This is consistent with the 10,000+ ttut b listed. It is essential to have an emergency
device for use in unknown concentrations. A  combination nipplied-air respirator in pressure-
demand or other positive procure mode, with auxiliary sdf-contained   air supply  is also
recommended for use in unknown concentrations of .contaminants immediately dangerous to
life. Other limitations, such as skin absorption of HCN or tritium, must be considered.
                                        193

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                                                    APPEKDH  K
                                   46.

  CHECKLIST FOR INSPECTION Of PRESSURE DEMAND SSLF-CONTAINXD BREJT3ING
  APPARATUS HITBOUT HODS SELECT LEVZRt


  PRIOR TO BEGINNING INSPECTION:

   , 2.   Check  to assure that high pressure hose connector Is tight on
        cylinder fitting

    2.   Bypass valv* closed

    3.   Hainline valv« closed

    4.   No cover or obstruction on regulator outlet


  I.   3ACX PACX C HARNESS ASSZK3LY

     A.  Straps

          1.   Visually inspect for complete set

          2.   Visually inspect for frayed or damaged straps  that jnay
              break during use

     S.  Buckles

          1.   Visually inspect for Dating ends

          2.   Check locking function

     C.  BacJcplate £  Cylinder Lock

          1.   Visually inspect backplate for cracks and for  missing
              rivets or screws.

          2.   Visually inspect cylinder hold-^ovn strap and  physically
              check strap tightener and lock to assure that  it Is fully
              engaged

XT.  CYLINDER  £  CTLINDER VALVS ASSEMBLY

     A.  Cylinder'

        1.  Physically check  cylinder to assure that it  is  tightly fastened
            to  2>acA plate

    (H)  2.  Check  Hydrostatic Test Date to assure  it is  current

    (M)  3.  Visually  inspect  cylinder for large dents or gouges incetal

     fl.  Bead  fi  Valve  Assembly

    (H}  1.  Visually  inspect  cylinder valve lock for presence

    (H)  2.  Visually  inspect  cylinder gauge for condition of  face,  needle,
            and lens

        3.  Open cylinder valve and listen or feel for leakage  axoung
            packing.   (If leakage is noted,  do not use until  repaired.;
            Wote function of  valve loc-fc


                              194

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                                    47.
JTJ.  REGULATOR t BIGS PRESSURE BOSS

      A.  High Pressure Ease £ Connector

          I.   Listen or feel for leakage  in host or at bos* to cylinder
              connector.  (Bubble in outar hose covering nay be caused
              by seepage of air through hose when stored tutdar pressure.
              This dcwj not necessarily aean a faulty bos*.

      fl.  flegulator £ Low Pressure Alarn

          1.   Cover outlet of regulator with palm of hand.  Open main-
              line valve and read regulator gauge fmust read at .least
                   PSI and not more than  rated cylinder pressure)
          2.  Close cylinder valve and  slowly move hand from regulator
              outlet to allow slow flow of air.  Gauge should begin to
              shew immediate loss of pressure as air flows.  Low pressure
              alarm should sound between 650 and 55O ESI.  Remove hand
              completely from' outlet and close mainline valve.

          3.  Place mouth onto or over  regulator outlet and blow.  A
              positive pressure should  be created and maintained for
              5-1O seconds without any  loss of air.  Next suck a slight
              negative on regulator and hold- for 5-10 seconds.  Vacuum
              should remain constant.   This tests the integrity of the
              diaphragm.  Any loss of pressure or vacuum during this
              test indicates a leak in  the apparatus.

          4.  Open cylinder valve.

          5.  Place hand over regulator outlet and open mainline valve.
              .Remove hand from outlet And replace in rapid movement.
              tepeat twice.  Air should escape when hand is removed
              each time, indicating a positive pressure in chamber.
              Close mainline valve ind  remove hand from outlet.
          6.  Ascertain  that no  obstruction is in or over the
              regulator outlet.   Open and close bypass  valve
              momentarily  to assure flow  of air throuch  buoass
              system.                                           y*
  IV.  FACEPIECZ £ CORRUGATED BREXTBfNG TUBS

       A.  facepiece

          1.  visually inspect head harness for damaged serrations and
              deteriorated rubber.  Visually inspect rubber facepiece
              body for signs of deterioration or extreme distortion.

          2.  Visually inspect lens for proper seal in rubber facepiece,
              retaining clamp properly  in place, and cracks or large
              scratches.

          3.  Visually inspect exhalation valve for visible deterioration
              or foreign materials build-up.
                              195

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                                  48.
   8.  Arnathing ruhe £ Connector

       1.  Stretch hreathing tuh« and visually inspect for
           deterioration and hales.

       2.  Visually inspect connector to assure good condition of
           threads and for presence and proper condition of  *0*
           ring  or mbber gasket seal.

       NOTE:   Final test of facepiece would involve a negative
              pressure teat for overall sea_Z and check of
              exhalation valvf.  If nonthly inspection, aasJc
              aay nov be placed against face and following tests
              performed.   If preparing for use,  don backpack,
                   don facepiece and use following procedure.
   C.  Negative  Pressure Test on Face piece

       1.  »itb  facepiece held tightly to face or facepiece properly
           donned,  stretch breathing tube to open corrugations and
           place thumb  or hand over end of connector.  Inhale.
           Negative pressure should be created inside naskt causing
           it to pull tightly to face.  This negative pressure should
           be maintained for 5-10 seconds.  If negative pressure leaJcs
           down,  the facepiece assembly is not adequate and should not
           be vora.

V. STORAGE OF UNITS

   1.  Cylinder  refilled as necessary and unit cleaned and inspected.

   2.  Cylinder  valve closed.

   3.  High pressure hos« connector tight on cylinder

   4,  Presjura  Wed off of high pressure hose and regulator

   5.  Bypass valve  closed.

   6.  Mainline  valve closed

   7.  All straps completely loosened and laid stxaight.

   8.  Face piece properly stored to protect against dust,  sunlight,
       heat, extreme cold,  excessive moisture, and damaging chejnicals.

JTE.VS HARKED (H) would  be done on^y on monthly inspection.
NOTE:  Any discrepance found should be cause to set unit aside until
       repair can ce done  hy certified re pair-person.
                              196

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                       INSPECTION AND MAINTENANCE CHECK LISTS




Self-Contained Breathing Apparatus Serial Number	




Issued To	Date of Issue	




Location	
WEEKLY INSPECTION
DATE
INSPECTED











CYLINDER OK











CYLINDER
CHANGED











DATE
INSPECTED











CYLINDER OK











CYLINDER
CHANGED











DATE
INSPECTED











CYLINDER OK











CYLINDER
CHANGED











MONTHLY INSPECTION
DATE
INSPECTED











CYLINDER OK











CYLINDER
CHANGED











REGULATOR
OK











FACEPIECE4
BREATHING
TUBE OK











CLEANED AND
SANITIZED











ENTIRE
APPARATUS
OK











REMARKS











INSPECTED
BY











                                            197

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INSPECTION AFTER EACH USE
DATE
USED
























CYLINDER
OK
























CYLINDER
CHANGED
























FACEPffiCE
AND
BREATHING
TUBE OK
























ENTIRE
APPARATUS
OK
























CLEANED
AND
SANITIZED
























CONNECTORS
OK
























REMARKS
























INSPECTED
BY
























DATE
INSPECTED
























198

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                                                        APPENDIX F
                                     51.
                                  MODEL
                           DUTY STATUS REPORT
 1.   Employee's Name

 2.   Work Location 	

 3.   Occupation 	

 4.   Date        	
 5.  Use of Respiratory Protective Devices

    a.  Type of Respirator 	

    b.  Mode of Operation 	
    c.  Tasks Employee will perform
    d.  Visual requirements

    e.  Audio requirements
    f.  How long employee is expected to wear the device
    g.  What 8ubstance(s) will employee be exposed to (include toxicity

        data
                                Signature of Supervisor


                           Medical Surveillance

At this examination on 	 no contraindications to the
use of the equipment described above have been identified.
                                Physician's  Signature
                                199

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                                      SECTION 5

                    PERSONAL PROTECTIVE EQUIPMENT

                                        PART 6

                        CHEMICAL PROTECTIVE CLOTHING
I.      INTRODUCTION

       Chemical protective clothing (CPC) is worn to prevent harmful chemicals from coming in
       contact with the skin (or eyes). It provides a barrier between the body and chemicals which
       have a detrimental effect on the skin or which can be absorbed through the skin affecting
       other  organs.   Used  with  respiratory protection, properly  selected chemical protective
       clothing can protect  personnel  who must work in a hostile chemical  environment from
       injury.

       Protecting  workers against skin exposure requires  using  the most  effective chemical
       protective clothing. Of primary importance is selecting clothing made from a material which
       is  most resistance to  the attack chemical.   The  style  of clothing is  also  important and
       depends on whether the attack substance is in the  air  or skin exposure will be from splash
       or direct contact with solids or semi-solids.   Other selection criteria which should be
       considered include the probability of being exposed, ease of decontamination,  mobility while
       wearing clothing, durability of clothing, and to a lesser degree, cost.

       A  variety of manufactured materials exists^which are  used to make the fabric for chemical
       protective clothing. Each of these  materials provides a degree of skin protection against a
       range of chemicals. But no one material affords maximum protection against all chemicals.
       The chemical protective clothing selected must be made from a material which affords the
       greatest deterrent against the chemicals known or  expected to be encountered.

       Properly selected chemical  protective clothing can minimize risk of exposure to chemical
       substances, but may not protect against physical hazards, i.e. fire, radiation, electrical.  The
       use of other personal protective equipment must also be determined for a complete ensemble.
       Head  protection is provided by hard  hats; eye and face  protection  by  goggles or impact
       resistant lenses in spectacles; hearing protection by earmuffs or earplugs; and foot protection
       by impact resistant and chemically-resistant boots.
II.    CLASSIFICATION OF CHEMICAL PROTECTIVE CLOTHING

       Chemical protective clothing is classified by style, protective material from which the fabric
       is made, and whether the clothing is single use (disposable).
       A.     Style
                     Fully Encapsulating Suit (FESV.  Fully  encapsulating,  chemical protective
                     clothing is a one piece garment that completely encloses the wearer.  Boots,
6/91                                        201

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                    gloves and facepiece are an integral part of the suit, but may be removed.
                    If removable they are connected to  the suit by devices that provide a vapor
                    or gas proof seal.These are gas tight suits and must be periodically pressure
                    tested to insure integrity.

                    Respiratory protection  and  breathing  air is provided to the wearer by  a
                    positive-pressure, self-contained breathing apparatus worn under the suit, or
                    by an air-line respirator which maintains a positive-pressure inside the suit.

                    Fully encapsulating suits are primarily for protecting the wearer against toxic
                    vapors, gases,  mists, or particulates in air.  Concomitantly,  they protect
                    against splashes of liquids. The protection  they provide against a  specific
                    chemical depends upon the material from which they are constructed.

                    Non-Encapsulating  Suit:   Non-encapsulating chemical  protective clothing
                    (frequently called splash suits) does not have a facepiece as an integral part
                    of the suit.  A positive pressure self-contained breathing apparatus or air-line
                    respirator  is worn outside the suit, or an air-purifying respirator  is used.
                    Splash suits are of two types:  a one-piece, "coverall" or a two piece, "pants
                    and coat".  Either type may include a hood  and other accessories.

                    Non-encapsulating suits are not  designed to provide maximum protection
                    against  vapors, gases, or other  airborne substances but against splashes.
                    In effect, splash suits can be made (by taping wrist, ankle and neck joints)
                    to totally enclose  the wearer  such that no part of the  body is exposed but
                    they still are not considered to be gas tight.  They may be an acceptable
                    substitute  for   a fully encapsulating  suit if the concentration of airborne
                    contamination is low and the material  is not extremely toxic to the skin.

       B.     Protective Material

              Chemical protective clothing also  is classified based on the material from  which it
              is  made.   All materials fall  into  two general categories, elastomers and  non-
              elastomers.

                     Elastomers:  polymeric (plastic-like)  materials, that after being stretched,
                     return  to  about their  original shape.    Most  protective  materials  are
                     elastomers.  These  include:  poly vinyl  chloride, neoprene, polyethylene,
                     nitrile, polyvinyl alcohol, viton, teflon, butyl rubber and others.  Elastomers
                     may be supported (layered on to cloth-like material) or  unsupported.

                     Non-elastomers:   materials that do not have  the quality of stretchability.
                     Non-elastomers include tyvek, tyvek coated garments and other materials.
       C.     Single-Use

              A  third  classification  is single use or disposable  garment.  This classification is
              relative and based on cost, ease  of decontamination  and  quality  of construction.
              Disposable  chemical  protective clothing is  commonly  considered to  be less  than
              $25.00  per garment.   In  situations where decontamination  is a problem, more
              expensive clothing may be  considered disposable.
6/91                                         202

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III.    PERFORMANCE REQUIREMENTS FOR CHEMICAL PROTECTIVE CLOTHING

       There are a number of performance requirements that must be considered in selecting the
       appropriate protective material.  Their relative importance is determined  by the particular
       work activity and site specific conditions.

              Chemical Resistance:  The ability of a material to withstand chemical and physical
              change.    A material's chemical  resistance is  the most important performance
              requirement.   The  material must maintain its structural integrity and protective
              qualities upon  contact with a hazardous substance.  This requirement is discussed in
              detail in Section IV.

              Durability: The ability to withstand wear. The ability to resist punctures, abrasions,
              and tears. The materials' inherent strength.

              Flexibility: The ability to bend or flex; pliable.  It is extremely important both for
              glove and full-body suit materials, for it directly impacts the worker's mobility,
              agility, and range of motion.

              Temperature Resistance:   The  ability of a  material  to  maintain  its chemical
              resistance during temperature  extremes (especially heat), and to remain flexible in
              cold weather.   A general tendency for most materials is that higher temperatures
              reduce their chemical resistance; lower temperatures reduce flexibility.

              Service Life:   The ability of a  material to resist aging  and deterioration. Factors
              such as  chemicals,  extreme temperatures, moisture, ultraviolet  light,  oxidizing
              agents, and others decrease a material's service life. Storage away from and proper
              care against these conditions  can help prevent aging.  Manufacturers should be
              consulted regarding any recommendations on a suit's shelf-life.

              Cleanability:     The  ability  to  effectively   decontaminate protective materials.
              Cleanability is a relative measure of the ability of a material to release the contact
              substance.  Some materials are nearly impossible to decontaminate, so it may be
              important to  cover those materials  with disposable garments  to prevent  gross
              contamination.

              Design:  The way a suit is constructed  which includes  the general type and specific
              features it has. A variety of suit  styles and features are  manufactured including:
                      Fully encapsulating or non-encapsulating
                      One, two, or three piece suits
                      Hoods, facepieces, gloves, and boots (attached or unattached)
                      Location of zipper, buttons, storm flaps, and seams
                      (front, side and back)
                      Pockets,  cloth collars, and velcro straps
                      Exhalation valves or ventilation ports
                      Ease of compatibility with wearing respiratory
                      protection
6/91                                         203

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              Size:  The physical dimensions or proportions of clothing.  Size is directly related
              to comfort and influences the number of unnecessary physical accidents.  Ill-fitting
              clothing limits a worker's mobility, dexterity and concentration. Manufacturers offer
              standard  sizes in boots and gloves for both men and women, however standard  suit
              sizes for  women are not available.

              Color:  Brightly colored suit  material  make it  easier to maintain visual  contact
              between  personnel.  Suits of darker colors (black, green)  absorb radiant heat from
              external  sources and transfer it to the worker increasing heat related problems.

              Cost: The cost of chemical protective clothing varies considerably. Cost will often
              play a role in the selection and frequency of use of CPC.   In many situations,  less
              expensive, single use garments are  more  appropriate and as safe as  more costly
              clothing.  Other situations  require high quality, costly clothing which  may  have to
              be discarded after limited use.
IV.    CHEMICAL RESISTANCE

       The effectiveness of materials to protect against chemicals  is based on their resistance to
       penetration, degradation, and permeation.  Each of these properties must be evaluated when
       selecting the style of chemical protective clothing and the material  from which it is made.
       In choosing protective materials:

              There is no protective material that is impermeable.

              There is no one material that affords protection against all
              chemicals, and

              For  certain  contaminants  and   chemical  mixtures   there  are  no  materials
              available that will protect for more than  an hour after  initial contact.

       Penetration is the transport of chemicals through openings in  a garment.  A chemical may
       penetrate due to design or garment imperfections. Stitched  seams,  button holes, pinholes,
       zippers,  and woven fabrics can provide an avenue for the chemical to penetrate the garment.
       A well designed and constructed garment prevents this by using  selfsealing zippers, seams
       overlayed  with tape, flap closures, and  nonwoven  fabrics.   Rips, tears, punctures, or
       abrasions to the garment also allow penetration.

       Degradation is a chemical  action involving the molecular breakdown of the material due to
       chemical contact.  Degradation is evidenced by physical changes to the material. The action
       may cause the material to shrink or swell, become brittle or soft, or completely change its
       chemical properties. Other changes may be a slight discoloration, rough or gummy surface,
       or  cracks in the material.  Such changes may enhance permeation  or allow penetration by
       the contaminant.

       Degradation test data for specific chemical or generic classes of chemical (TABLE 7) is
       available from product manufacturers, suppliers, or other sources.  The published  data
       provides the user with  a general degradation  resistance rating.   The rating is  subjectively
       expressed  as  excellent, good, fair, or poor.  Degradation  data  can help in assessing  the
 6/91                                         204

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       protective capability of a material but should not replace permeation test data.  The reason
       for this is that a material with excellent degradation resistance can have poor permeation
       properties.  Degradation and permeation  are  not directly related  and cannot be used
       interchangeably. The manufacturer should be consulted by the user to determine on which
       degradation changes the rating is based.

       Permeation is a chemical action involving the movement of chemicals, on a molecular level,
       through intact material.  Permeation is a process which involves the sorption of the chemical
       on the outside surface, diffusion through, and desorption of the chemical from the inside
       surface of the protective material.  A concentration gradient (high on the outside: low on the
       inside) is established.   Because  the tendency is to achieve concentration equilibrium,
       molecular forces "drive"  the chemical into the material toward the area of no or lower
       concentration. Eventually the highest flow of permeating chemical exists and is referred  to
       as the steady flow state.

       Permeation is measured as a rate.  Permeation rate is the quantity of chemical that will move
       through an area of protective material in a given time. It is usually expressed in micrograms
       of chemical permeated per square centimeter per minute of exposure (ug/cm^/min). Several
       factors influence the rate of permeation including the type of material and  thickness.  A
       general rule of thumb is that the permeation rate is inversely proportional to the thickness
       (2 x  thickness  =  1/2  x  permeation  rate).    Other  important  factors  are chemical
       concentration, contact time, temperature, material grade, humidity, and solubility  of the
       material in the chemical.
6/91                                        205

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TABLE 7
EFFECTIVENESS OF PROTECTIVE MATERIALS AGAINST
CHEMICAL DEGRADATION (BY GENERIC CLASS)1
Generic Class
Alcohols
Aldehydes
Amines
Esters
Esters
Halogenated
hydrocarbons
Hyrocarbons
Inorganic acids
Inorganic bases
and salts
Ketones
Natural fats
and oil
Organic acids
Butyl Rubber
E
E-G
E-F
G-F
G-F
G-P
F-P
G-F
E
E
G-F
E
Polyvinyl
Chloride
E
G-F
G-F
P
G
G-P
F
E
E
P
G
E
Neoprene
E
E-G
E-G
G
E-G
G-F
G-F
E-G
E
G-F
E-G
E
Natural
Rubber
E
E-F
G-F
F-P
G-F
F-P
F-P
F-P
E
E-F
G-F
E
1       E - Excellent  F - Fair
       G - Good      P - Poor

Source: Survey of Personal Protective Clothing and Respiratory Apparatus. DOT. USCG, Office
of Research and Development (September, 1974).of material and thickness. A general rule of thumb
is that the permeation rate is  inversely proportional  to  the thickness  (2  x thickness  =  1/2 x
permeation rate).  Other important factors are chemical concentration, contact time, temperature,
material grade, humidity, and solubility of the material in  the chemical.

       Another measure of permeation is breakthrough time, expressed in minutes. Breakthrough
       is  the  elapsed time  between initial  contact of a  chemical with the outside  surface  and
       detection at the inside surface of the  material.  Like permeation rate,  breakthrough time is
       chemical specific for a particular material and is influenced by the same factors.  A rule of
       thumb  concerning breakthrough time is that it is directly proportional to the square of the
       thickness (2 x thickness = 4 x break-through time).

       Permeation and breakthrough test data is available from manufacturers which gives specific
       rates and times (TABLE 8).  A given  manufacturer's recommendations serve as  a relative
       guideline to properly selecting  their  products.  This data is obtained using the  American
6/91
206

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       Society for Testing and Materials (ASTM) standard test method F739-81. Although ASTM
       has  a standard method  for  permeation testing, considerable variation  exists between
       manufacturer's  test data.  The differences  are due to material thickness and  grade,
       manufacturing processes, temperature, chemical concentrations, and  analytical detection
       method. Therefore, caution should be used when comparing different manufacturers results.
       The results for the same material/chemical combination will differ considerably between
       manufacturers.  ASTM also has test methods for penetration and degradation resistance.

       The best protective material against a specific chemical is one that has a low permeation rate
       (if any)  and a long breakthrough time. However, these properties do not always correlate.
       Compare propyl acetate  (TABLE 8)  and 1,1,1-trichloromethane against  nitrile NBR or
       dimethyl sulfoxide and methyl alcohol against neoprene. As indicated,  a long breakthrough
       time does not  always correlate  with  a low permeation  rate or vice versa.   A  long
       breakthrough  time is usually desired.

       The literature on material testing also notes that permeation rates and breakthrough times are
       not  tested  for those materials which receive  a poor degradation rating; only breakthrough
       time is measured for those chemicals (especially corrosives) which are known to be direct
       skin hazards.  The data also reflects the testing of pure  substances and not mixtures.

       In addition to the manufacturer's chemical resistance data, the best general reference for
       selection of CPC is Guidelines For The Selection Of Chemical Protective Clothing. ACGIH
       (1985).  This  reference compiles degradation and permeation test data from manufacturers,
       vendors, and  independent laboratories with recommendations for over  300  chemicals.

       Specific chemicals are rated against a variety of protective materials. The  ratings (RR, rr,
       NN, nn) are based on two criteria; breakthrough times and vendor chemical resistance data.
       Each rating represents a combination of performance, number of sources  confirming that
       performance,  and consistency of the data.  The number and  size of the letters indicate this.

       The available  test data  and recommendations for all chemical  protective clothing is extremely
       limited in  scope and use.  The user must consider these restrictions when selecting CPC and
       use  the guidelines in the way  they were intended to be used.
6/91                                         207

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00
TABLE 8 (
PERMEATION/DEGRADATION RESISTANCE FOR EDMONT GLOVES*


Acetone
Cellosolve
Acetate
Dimethyl
Solfoxide
(DMSO)
Hydroflouric
Acid, 48%
Propyl
Acetate
Toulene
1,1,1-
Trichloro-
ethane
NITRILE NBR
Degradation
Rating
NR
F
E
E
F
F
F
Permeation
Break-
through
1.5 hr.
<4hr.
2hr.
20 min.
10 min.
1.5 hr.
Permeation
Rate
G
VG
-
G
F
P
NEOPRENE
Degradation
Rating
G
G
E
E
P
NR
NR
Permeation
Break-
through
5 min.
1.25 hr.
ND
1 hr.
-
-
-
Permeation
Rate
F
VG
E
-
-
-
-
PVC
Degradation
Rating
NR
NR
NR
G
NR
NR
NR
Permeation
Break-
though
3 hr.
40 min.
-
-
-
Permeation
Rate
_
-
-
-
-
          6/91

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KEY TO PERMEATION RATE:                      Simply Stated
                                                      Drops Per Hour
                                                      Through a Glove
                                                      (Eyedropper size drop)

ND    -      None detected during a six hour test              None

E      -      Excellent; permeation rate of less                 0 to 1/2 drop
             than .09 ug/cm2/min.

VG    -      Very Good; permeation rate of less               1 to 5 drops
             than 90 ug/cm2/min.

G      -      Good; permeation rate of less than                6 to 50 drops
             90 ug/cm2/min.

F      -      Fair; permeation rate of less than                 51 to 500 drops
             900 ug/cm2/min.

P      -      Poor; permeation rate of less than                501 to 5000 drops
             9000 ug/cm2/min.

NR    -      Not Recommended; permeation rate              5001 drops up
             greater than 9000 ug/cm2/min.

Note:        The current revision to the ASTM standard permeation test calls for permeation to
             be reported in micrograms of chemical permeated per square centimeter of garnet
             exposed per minute of exposure, *ug/cm2/min.*.
V.     PROTECTIVE MATERIALS

       There is a wide variety of protective materials.  The following is a list cf the more common
       materials used in CPC segregated as elastomers or non-elastomers.  The elastomers are not
       listed in any particular priority. The classes of chemicals rated as "good for" or "poor for"
       represent test data for both permeation breakthrough and permeation rate. They are general
       recommendations; there are many exceptions within each chemical class. Sources consulted
       for this information included Guidelines for the Selection of Chemical Protective Clothing
       (ACGIH, Vol.  1,  1985) and manufacturer's literature.  The costs are recent estimates and
       are subject to change.

       A.     Elastomers

              Butyl Rubber:  (Isobutylene/Isoprene Copolymer)
              Good for:     bases and many organics
                           heat and ozone resistance decontamination
6/91                                       209

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             Poor for:     aliphatic and  aromatic hydrocarbons
                           gasoline
                           halogenated hydrocarbons abrasion resistance

             Cost:         Gloves  - $10/pr.
                           Boots   - $25/pr.
                           FES    - $900 - $1,350

             Chlorinated Polyethylene:  (Cloropel, CPE)

             Good for:     aliphatic hydrocarbons
                           acids and bases
                           alcohols,  phenols
                           abrasion and ozone

             Poor for:     amines, esters, ketones
                           halogenated hydrocarbons
                           cold temperature (becomes rigid)

             Cost:         splash suit  - $60
                           FES      - $600

             Natural Rubber:  (Polyisoprene)

             Good for:     alcohols
                           dilute acids and bases flexibility

             Poor for:     organic chemicals
                           aging (affected by ozone)

             Cost:         Gloves     - $10-$15/doz.
                           Boot Covers - $5/pr.

             Neoprene:  (Chloroprene)

             Good for:     bases and dilute acids
                           peroxides
                           fuels and oils
                           aliphatic hydrocarbons
                           alcohols
                           glycols
                           phenols
                           abrasion and cut resistance

             Poor for:     halogenated hydrocarbons
                            aromatic hydrocarbons
                           ketones
                            concentrated acids
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              Cost:          Gloves        - $70/doz. (supported)
                                          - $13/doz. (unsupported)
                            Boots  - $35/pr.

                            Splash Suit - $40-$60
              Nitrile Rubber:(Acrylonitrile rubber, Buna-N, NBR,
                            hycar, paracril, krynac)

              Good  for:     phenols
                            PCBs
                            oils and fuels
                            alcohols
                            amines
                            bases
                            peroxides
                            abrasion and cut resistance flexibility

              Poor for:      aromatic & halogenated hydrocarbons
                            amides
                            ketones
                            esters
                            cold temperature

              Cost:          Gloves    - $2/pr.
                            Boots     - $18/pr.

              Note:         The higher the acrylonitrile concentration, the better the chemical re-
                            sistance; but also increases stiffness.

              Polyurethane:

              Good for:     bases
                            aliphatic hydrocarbons
                            alcohols
                            abrasion resistance
                            flexibility - especially at cold
                            temperatures

              Poor for:      halogenated hydrocarbons

              Cost:          Boots     - $25/pr.
                            Splash Suit - $60

              Polyvinyl Alcohol: (PVA)

              Good for:     almost all organics
                            ozone resistance
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             Poor for:      esters
                           ethers
                           acids and bases
                           water and water solutions flexibility

             Cost:         Gloves - $13/pr.

             Polvvinyl Chloride: (PVC)

             Good for:     acids and bases
                           some organics
                           amines, peroxides

             Poor for:      most organic compounds
                           cut and heat resistance decontamination

             Cost:  Gloves        - $17-$25/doz.  (outer)
                                  - $6/doz.  (inner)
                           Boots  - $15/pr.

                           Splash Suit - $10-$30
                           One-pc.  Suit - $55
                           FES - $300-$900
              Good for:     aliphatic and aromatic hydrocarbons
                           halogen at ed hydrocarbons
                           acids
                           decontamination
                           physical  properties

              Poor for:     aldehydes
                           ketones
                           esters (oxygenated solvents) amines

              Cost:         Gloves - $27/pr.
                           FES   - $1,600-$3,300

              Teflon:       Teflon has become available for chemical protective suits.  Limited
                           permeation test data is published on teflon. Teflon,  similar to viton,
                           is thought  to  afford  excellent chemical  resistance  against  most
                           chemicals.  Teflon suits are relatively expensive ($2,000-$3,000).

       Blends/Layers

       CPC Manufacturers have developed a technique of layering materials to improve chemical
       resistance.  Essentially one suit is designed with multiple layers.  Some examples of layered
       fully encapsulating suits are viton/ butyl (Trelleborg), viton/neoprene (MSA  Vautex and
       Draeger), and butyl/ neoprene (MSA Betex).


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      B.     Non-Elastomers

                            (non-woven polyethylene fibers)

                            dry participate and dust protection
                            decontamination (disposable) lightweight

             Poor for:      chemical  resistance  (penetration/
                            degradation) durability

             Cost:          Standard suit - $3-$5

             Recommendations:    Used  against  toxic particulates but provides no chemical
                                   protection;  worn   over   other  CPC  to  prevent  gross
                                   contamination of non-disposable  items and  under suits  to
                                   replace cotton.

             Polyethylene:  (coated tyvek)

             Good for:     acids and bases
                            alcohols
                            phenols
                            aldehydes
                            decontamination (disposable)
                            lightweight

             Poor for:      halogenated hydrocarbons
                            aliphatic and aromatic hydrocarbons physical properties
                            (durability) penetration (stitched  seams)

             Cost:         Suit    - $8-$ 10
                            Gloves  - $1.50/box of 100 (disposable)
                            Booties - $13/box of 50 (disposable)

             Recommendation:     Provides  limited chemical protection  against  concentrated
                                   liquids  and vapors.  Useful against low concentrations and
                                   those activities which do not create a high risk of splash; also
                                   worn over CPC to prevent gross   contamination  of  non-
                                   disposables.  The disposable  poly considtred "inner liners"
                                   and assist decontamination procedures.

             Saranex:      (laminated tyvek)

             Good for:     acids and bases
                            amines
                            some organics
                            PCBs
                            decontamination (disposable)
                            lightweight
                            durability


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              Poor for:     halogenated hydrocarbons
                           aromatic hydrocarbons
                           stitched seams (penetration may occur)

              Cost:         Suit - $15
                           "OSHA"  suit - $26

              Recommendation:    Provides greater chemical resistance and overall  protection
                                  compared  to polyethylene coated  tyvek;  used to  prevent
                                  contamination of non-disposable clothing.
VI.    SELECTING CHEMICAL PROTECTIVE CLOTHING

       Selecting the most effective chemical protective clothing is easier when the chemical for
       which protection is necessary is known. Selection becomes more difficult when the presence
       of chemicals is  unknown,  multiple chemicals (known or unknown) are involved, or  an
       unidentifiable substance is present.  As uncertainties about the substances involved increases,
       selecting the proper clothing becomes more difficult.

       Another  major difficulty in selection is  that there  is not enough   available information
       concerning the protective qualities of commonly used protective materials against the  wide
       range of chemicals that could be encountered.

       The selection process consists of:

              Deciding that workers must be in an environment where they could be exposed.

              Identifying the chemical  involved  and  determining  its physical,  chemical, and
              toxicological  properties.

              Deciding whether, at the concentrations  known or expected, the substance is a skin
              hazard.

              Selecting protective material which provides the least permeation and degradation for
              the longest period of time.

              Determining whether a fully encapsulating suit or a non-encapsulating is required.

       In those  incidents where the presence of hazardous substances is not known or they can not
       be readily identified there are usually clues  which can  assist in  choosing the  style of
       clothing.  Observations which could  indicate wearing fully encapsulating suits are:

              visible emissions of gases,  vapors, dust or smoke.

              indications of airborne hazards on direct-reading
              instruments.
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              configurations of containers or vehicles which indicate
              they contain gases or pressurized liquids.

              signs, labels, placards, or bills of lading indicating substances that could become
              airborne and are toxic
              to the skin.

              enclosed, poorly ventilated areas where toxic vapors,
              gases  and other airborne substances could accumulate.

              work functions required might expose workers to high concentrations of skin toxics.

       Unknown situations require considerable judgement as to whether maximum protection to
       the skin (fully encapsulating clothing) is necessary, or whether splash suits are appropriate.

       After determining the type of protective garment to be worn, the next step is to select the
       protective material.  Vendors or manufacturers of materials used to make chemical protective
       materials can sometimes (but  not always) supply information concerning their product's
       chemical resistance and make recommendations  about what chemicals it  is good for.  The
       number of chemicals  their product is tested  against may  be limited, for they can not test
       against the 1000's of chemicals that exist.

       Permeation is the primary selection criteria.  The best protective material against a specific
       chemical would be one that has a very low permeation rate (if any), and a long breakthrough
       time, and has been constructed free of design imperfections.

       Less useful information is degradation.  This is usually a qualitative determination of a
       materials ability to standup under the attack of a chemical, usually expressed  in subjective
       units of excellent, good, poor, or  similar terms.  Degradation data can help in  assessing the
       protective capability of a materials, if no other data is available.

       However, a fabric with good  degradation  resistance may be very permeable to the same
       chemical.   Permeation and  degradation  are not  directly  related  and  cannot be  used
       interchangeably. In those situations where a protective material can not be chosen because
       of uncertainty of the attack substance, there are some reasonable options.

              Select a protective  material which protects against the greatest range of chemicals.
              These are generally garments made from butyl rubber, viton, or teflon. Chemicals
              against which these materials (or other materials) do not provide protection could
              possibly be eliminated  as not being present.

              Clothing made of multiple protective material could be used.  Garments consisting
              of butyl-viton,  neoprene-viton,  and  neoprene-butyl  are manufactured.   If not
              commercially available, two garments made of different material could be worn with
              a disposal type garment on the outside.

              Whether fully encapsulating or non-encapsulating  clothing should be worn may not
              be self-evident. If based on an assessment of the situation it is determined that either
              style  would provide effective protection other factors to consider would be:
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              Ease in wearing:  Non-encapsulating suits are easier to wear. Wearers are less prone
              to accidents for they have better visibility and the clothing is less cumbersome.

                     Communications:  It is more difficult to communicate in fully encapsulating
                     suits.

              Decontamination:    Fully  encapsulating  suits  protect  self-contained  breathing
              apparatus,  which are difficult to decontaminate, from being contaminated.

              Heat stress: Non-encapsulating clothing generally causes less heat stress.  However
              as less area of the body is exposed by wearing gloves and hoods and taping hoods
              to respirator masks, there is little difference in the heat build-up of either style.

              Cost:  Non-encapsulating garments are less expensive.
VII.   PHYSICAL STRESS

       Wearing chemical  protective clothing  can cause problems.   These  involve  heat  stress,
       accident proneness, and fatigue.  The  major problem  is heat stress caused by protective
       clothing interfering with the body's ability to cool itself.  Clothing that provides a barrier
       against chemicals  contacting the skin, prevents the efficient dissipation of body heat.
       Evaporation, the body's primary cooling mechanism is  reduced, since ambient air is not in
       contact with the skin's surface. Other heat exchange mechanisms (convection and radiation)
       are also impeded.  Additional strain is put on the body as it  attempts to maintain it's heat
       balance. This added stress can result in health effects  ranging from transient heat  fatigue
       to serious illness or death.

       The smaller  the area of the body exposed to the air, the greater  the probability for heat
       stress.  Fully encapsulating suits allow no ambient air to contact the skin's surfaces to aid
       in the evaporation  of moisture.  Heat  in these  suits  builds up quickly.  Splash suits may
       allow more body surface (head, neck, and  hands) to be  cooled by the air, but if those areas
       are covered by hoods, gloves and respirators and the joints taped, the same conditions will
       exist as if wearing  a fully encapsulating suit.  Heat-related problems become more common
       as the ambient temperature rises above 70'F., but can  occur  at much lower temperatures.
       Although wearing protective clothing establishes conditions that are conducive to heat-related
       illness, individuals vary in their susceptibility to heat  stress  and their ability to withstand
       high temperatures.

       Accident proneness also increases when wearing chemical protective clothing.   Suits are
       heavy, cumbersome, decrease mobility and  dexterity,  lessen visual and audio acuity,  and
       increase physical exertion. The  severity of  the problems depend  on  the style of clothing
       worn. These negative qualities increase the risk of common accidental injury, for example
       slips,  falls, or being struck.

       Increased physical  exertion caused by working in protective clothing  can in itself cause
       problems.  Worker performance may decrease due to increased fatigue levels.  Other more
       serious illnesses such as stroke or heart attack could  occur.
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       To minimize the adverse effects of physical stress, workers wearing protective clothing must
       change their normal work regimen.  A  medical surveillance program, including baseline
       physicals and routine medical monitoring, should be instituted. Personnel must be allowed
       to acclimatize to stressful environmental factors by varying work and rest periods as needed.
       Projects should be scheduled for cooler  periods of the day when possible.  The intake of
       fluids must  be maintained at levels to prevent dehydration, and body electrolytes replaced
       through added salting at mealtimes. Compensatory efforts such as these must be established
       as part of Standard Operating Safety Procedures on a site-specific basis to reduce the risks
       associated with wearing protective clothing.
VIII.  INSPECTION OF PROTECTIVE CLOTHING

       Before wearing chemical protective clothing it must be properly inspected. The following
       is a checklist for visually inspecting all types of chemical protective suits.  Chemical suits
       should be inspected immediately before use and monthly when not in use.

       A.     Inspection Procedures:

              Spread suit out on a flat surface.

              Examine the outside for the following:

                     fabric for abrasions, cuts, holes, or tears
                     fabric has retained  the original flexibility and durability
                     seams for separations, or holes
                     zippers, buttons, storm flaps, and other connecting devices for proper sealing
                     and operation
                     signs of previous chemical  attack or  incomplete decontamination
                     (unusual   discoloration, rough surface, gummy feeling, cracks)
                     elastic around wrists and ankles and  the draw strings on hoods are
                     in good condition (if applicable)
                     Fully encapsulating suits require additional
                     inspection which include (if applicable):
                     Exhalation valves (positive pressure) for debris
                     and proper functioning.
                     Suit facepiece for poor visibility (cuts, scratches, dirt) and an
                     adequate facepiece to suit seal.
                     Presence and condition of waist belts, velcro  adjustments (head and hips),
                     and ankle straps.
                     Condition of integral gloves, boots, and leg
                     gaiters.
                     Presence of hard hat or ratchet head suspension.
                     Presence and condition of airline attachment
                     and hoses for cooling system.
                     Leak detection and pinholes.
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       1.     If an air source is available, secure the suit and inflate it, then using a mild soap
             solution observe for bubbles on the surface or around seams, or

       2.     Inside a dark room, run a flashlight inside the suit and look for pinpoints of light
             from outside the suit.

       3.     OSHA 1910.120 Standard has an Appendix A attachment which outlines two test
             methods for evaluating the integrity of totally encapsulating chemical suits.  One is
             an Air Pressure test and the other is an Ammonia Leak Test.  These tests are non-
             mandatory under the standard.

             Records should be maintained on each suit's inspection, use conditions, and repair
             status. These records are especially important  for fully encapsulating suits (FES)
             which are usually not individually assigned but shared. Suggestions for maintaining
             records include:

              1.      Inspection -    who, when,and any problems.

             2.      Use conditions - where, activity, and chemicals if known.

             3.      Repair status  -   what  is  the  problem,  who  repaired it (in-house or
                     manufacturer),  date of repair, and tag  the  suit "out  of  service"  if not
                     repaired.
       **Always refer to manufacturer  recommendations  for  routine or any  special inspection
       procedures.
IX.    PERSONAL COOLING DEVICES

       A.     INTRODUCTION

              Wearing chemical resistant clothing and respirators increases the risk for heat stress.
              They cause  additional strain on the body by  adding weight, increasing breathing
              resistance and  restricting movement.   They  can also  reduce  the  body's natural
              cooling mechanism.  The body  releases heat by convecting heat to cooler air,
              radiating heat to cooler surfaces in the surroundings, and evaporating moisture from
              the skin. Chemical resistant clothing interferes with these processes. This can lead
              to heat  illness, heat fatigue,  heat rash,  heat cramps,  heat syncope  (fainting),  heat
              exhaustion or  even heat stroke.  Methods used to prevent  heat  illness include
              frequent rest   breaks,  reduced  work  loads,  increased  consumption  of  fluids,
              acclimatization, and working during the cooler times of the day. Another method
              that is available is the use of personal cooling devices to remove heat from the user's
              body.  These devices are divided  into two types: those that use a coolant source
              external to the  wearer (an umbilical system) or self-contained  systems that are not
              connected to'an outside source.
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      B.     EXTERNAL COOLANT SYSTEMS

             Devices using an external cooling source need a connection between the wearer and
             the coolant source. The coolant can be compressed air or a liquid.

              1.      Compressed air systems

                     Compressed air systems use cool, dry  air to aid in  cooling  the  body.
                     Generally the air is  distributed  to  the  ankles, wrists, and  head by  an
                     arrangement of air tubes worn on the body or attached to the  protective
                     clothing (FIGURE 7). Some systems can be found in the form of a hood or
                     vest. Many manufacturers of fully encapsulating suits have air distribution
                     systems built  into their suits.

                     The air is delivered  to the  units comes from  a compressor or a large
                     compressed air container (like a cascade system). The air acts as an insulator
                     from external  heat and increases evaporation of sweat because of the constant
                     flow of dry air.  If additional cooling is needed, a vortex cooler to chill the
                     air can be connected into the airline at the user's end.  The vortex cooler
                     (FIGURE 8) takes compressed air, increases its velocity,  directs it into an
                     outer "hot" tube, and  forms a vortex.  The air spirals down the tube and a
                     fraction escapes through a valve in  the  end.  The remaining air forms a
                     second  vortex which passes through the center  of the outer vortex -flowing
                     in the opposite direction - and exits from  the "cold" tube.  The outer vortex
                     takes heat from the  inner vortex.    How much  heat is  transferred is
                     determined by how much air the valve releases; more hot air out, more cold
                     air to user. The vortex cooler is attached  to a belt or other support. It must
                     be worn on the outside of any protective clothing so that the heat can be
                     vented.

                     It is important to remember that NIOSH does not have a specific testing and
                     certification schedule  for supplied air suits.  Thus, the  suits should not be
                     used for respiratory protection. Some suits and hoods have a NIOSH/MSHA
                     respiratory approval under the SCBA or airline testing schedules.  If a vortex
                     tube is  used with a unit for respirator protection, then the respirator must be
                     tested and approved with the vortex tube.

                     Compressed air systems have two advantages. They are able to cool the
                     whole body and they allow the wearer to work as long as desired.  However,
                     they have several disadvantages.  They restrict mobility because of the airline
                     umbilical.  Since the system  is continuous flow, they use a lot of air -
                     especially if using a vortex cooler. One unit with a vortex cooler uses 25
                     cubic feet of air per minute to deliver 15 cubic feet  of useable air  to the
                     wearer. A normal airline respirator uses  6-8  cubic feet per minute.  Also,
                     the hot air from the vortex tube - as hot as 162   F - can add heat  to the
                     environment or to the outside surface of the protective clothing.
6/91                                               219

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                                      FIGURE 7
            FULLY ENCAPSULATING SUIT WITH AIR DISTRIBUTION SYSTEM

                 Used with permission of Mine Safety Appliances, Pittsburgh, PA.
                                      FIGURE 8

                VORTEX TUBE; SCHEMATIC OF VORTEX TUBE; VORTEX
                       TUBE CONNECT TO AIR-SUPPLIED HOOD

                   Used with permission of Fyrepel Products, Inc., Newark, OH.
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             2.     LIQUID-COOLED DEVICES

                    There is only one device in this category.  Water is circulated through tubing
                    in a garment resembling long Johns.  It can use an external water supply -
                    which can be chilled - or a portable chilling unit for recirculated water.

                    This unit has the same advantages and  disadvantages of the air-supplied
                    systems. It has additional disadvantages. There is additional weight due to
                    the water in the system.  At the present, fully encapsulating suits do not have
                    liquid line connections.  One advantage  is that the cooling system  can  be
                    located  away from the user  and thus not add heat to the user's immediate
                    area.

       C.    SELF-CONTAINED SYSTEMS

             Self-contained  systems  have all of the heat exchanging elements as part  of the
             wearer's ensemble. Thus, they are not hooked to an outside coolant source.  These
             systems are usually of two types - those that use ice to cool the wearer and those that
             circulated a liquid cooled by a heat  exchange system.

              1.     Ice Vests/Jackets

                    These systems use ice in a vest/jacket or in removable packets.  The size and
                    number of packets vary form manufacturer to manufacturer.  Some systems
                    come with a inner vest to prevent  direct contact with the skin.  Some have
                    an outer vest to  reduce external heat  effects on the ice.  (See FIGURE 9)

                    These  systems have several advantages.  They are simple to use, have  no
                    moving parts,  and  do  not  restrict  mobility.  They can be worn  under
                    protective clothing or an SCBA.  They also have disadvantages.  They are
                    usually limited to a maximum of 1  hour of cooling. If more time is needed,
                    extra packets are needed.  If the unit has no removable packets, the whole
                    vest has to be refrozen.  After the ice melts, the wearer is  carrying extra
                    weight  with no cooling benefit.  They weigh from  12 to 15 pounds. If there
                    is no inner insulation, they may be too cold.

             2.     Circulating Systems

                    Circulating systems use a water or a water/alcohol mixture circulated through
                    the vest to cool  the wearer. The liquid is cooled by ice or  other frozen
                    liquid contained in a pouch or container carried by the wearer (see FIGURE
                    10). In some cases, the melting ice becomes part  of the circulating system.
                    There  are a couple of experimental models  that use dry ice to cool the
                    circulating liquid.

                    The circulating systems have some  of the same advantages and disadvantages
                    as the ice vests.  They have the additional disadvantage of using an electric
                    circulator.  This  requires battery pack to power the circulator. Thus, more
                    weight  is added.  Also, while the units have waterproof and sparkproof
                    connections, none have received  an inherent  safety  rating.  Their main
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                    advantage is that the cooling rate can be controlled by controlling the flow
                    of the liquid through the vest.  They can be worn under protective clothing
                    and  a SCBA.    There is one model  that  is  incorporated  into  a fully
                    encapsulating suit.  The ice can be replenished without removing the suit.

      D.     CONCLUSION

             There are many different types of personal  cooling  devices.  At the end of this
             section is a  list of manufacturers and the types they make.  When selecting a unit,
             one  main consideration is whether it  is compatible  with the  other  protective
             equipment worn.  Mobility,  weight and duration  of  use must also be considered.
             Worker acceptance is also an important consideration. Whatever device is used, it
             must be remembered that the device reduces but doesn't  eliminate the heat stress.
                            1   Hormconxwo v»«1
                            2  £»unp connection

                            t   F»W»nmf buium - KXs
                            6  Fasi^n^o txinon — boocvn
                            7  CVHK v«H
                                  i accessor)'
           C^==%
                                                   FIGURE 9

                                         WATER  FILLED ICE VEST

                            (Whole jacket is frozen  prior to use)  Used with
                                 permission of National Draeger, Pittsburgh, PA.
6/91
222

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                                               FIGURE 10
                                         COOL VEST* Model 19.

                          (The back of unit has battery operated pump and pouch containing ice
                          and  circulating  water)   Used  with  permission  of ILC Dover,
                          Frederica, DE.
6/91
                                          223

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X.
MANUFACTURERS AND SUPPLIERS OF PERSONAL COOLING DEVICES"
KEY:
A  = airline cooling system
C  = self contained circulating vest
W = water line cooling system

Encon Manufacturing Co.
13333 Northwest Freeway
Houston, TX 77040
713/462-4723
(A)

Fyrepel Products Inc.
P.O. Box 518
Newark, OH 43055
614/344-0391
(V, I)

ILC Dover
P.O. Box 26
Frederica, DE  19946
302/335-3911
(A, C, V, W)

Life Support Systems Inc.
1400 Stierlin Road
Mountain View,  CA 94043
415/962-9800
(C)

Mine Safety Appliances
600 Penn Center Boulevard
Pittsburgh, PA 15235
412/273-5000
 1-800-MSA-2222
(A, I)

National Draeger, Inc.
401 Parkway View Drive
 Pittsburgh, PA 15205
 412/787-8383
 (I)
                                       I =  ice vest
                                       V = vortex cooler
                                       Racal Health & Safety, Inc.
                                       Racal Airstream Division
                                       7309 Grove Road, Frederick, MD 21701
                                       301/695-8200
                                       800/682-9500
                                       (V)

                                       Standard Safety Equipment (StaSafe)
                                       431  North Quentin Road
                                       Palatine, IL 60067
                                       312/359-1400
                                       (A)

                                       Steele Incorporated
                                       First and Washington
                                       P.O. Box 7304
                                       Kingston, WA 98346
                                       206/297-4555
                                        (I)

                                        3M
                                        220-7W
                                        St. Paul, MN 55144
                                        612/733-6234
                                        (V)

                                        Trusafe
                                        9369 8th Avenue South
                                        Seattle, WA 98108
                                        206/762-7407
                                        (I)

                                        Wheeler Protective Apparel, Inc.
                                        4330 W. Belmont
                                        Chicago, IL 60641
                                        312/685-5551
                                        (A)
*Mention of a particular manufacturer or product does not imply endorsement by the U.S.
Environmental Protection  Agency.   Omission of a  manufacturer  or product is  not
intentional.
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                                    224

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                                     APPENDIX I
                            PERMEATION REFERENCES
1.     Development of Performance Criteria for Protective Clothing Used Against Carcinogenic
       Liquids. NIOSH, Technical  Report No. 79-106.  NTIS.

2.     "A Discussion:  Resistance of Butyl Rubber Gloves to the Penetration of
       Aromatic Nitro and Amino Compounds'. Amer. Ind. Hyg. Assoc. J.  39:314316 (1978).

3.     Henry, N. W. Ill and  C. N. Schlatter.  "The Development  of a Standard
       Method for Evaluating Chemical Protective  Clothing by Hazardous Liquids" (1981).

4.     Lynch, A. L.  "Protective Clothing", Handbook of Laboratory Safety. 2nd ed. (1971).

5.     Middleton, H.W. Glove Corrosive Liquid Immersion and Permeability Study. No.  GEPP-
       322,  General Electric Co.,  Neutron Devices Dept., P. O. Box 11508, St. Petersburg, FL
       33733.

6.     Nelson, G. O.  and C. M. Wong.   "Glove Permeation by Organic Solvents".
       Amer. Ind. Hyg. Assoc. J., 42:217-225 (1981).

7.     Permeation  of Protective Garment Material   by Liquid  Halogenated Ethanes  and  a
       Polychlorinated Biphenyl. NIOSH Publication 81-110  (1981).

8.     Sansome, E. B. and U. B. Tewari.  "The Permeability of Laboratory Gloves to Selected
       Solvents".  Amer. Ind.  Hyg. Assoc. J. 39:164-174 (1978).

9.     Weeks, R. W. Jr.,  and  B.  J. Dean.   "Permeation of  Methanolic Aromatic
       Amine Solutions through Commercially Available Glove Materials".  Amer.
       Ind. Hyg. Assoc. J., 38:721-725 (1977).

10.    Weeks, R. W. Jr., and  M. J. McLeod.  "Permeation  of Protective Garment
       Material by Liquid Benzene and by Tritiated Water*.  Amer. Ind. Hyg.
       Assoc. J., 43:201-211 (1982).

11.    Williams, J. R. "Permeation of Glove Materials by Physiologically Harmful Chemicals".
       Amer. Ind. Hyg. Assoc. J., 40:877-882 (1979).
6/91                                      225

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                                      APPENDIX II

         DONNING AND DOFFING OF THE FULLY ENCAPSULATING SUIT
I.      INTRODUCTION

       In responding to episodes involving hazardous substances, it may be necessary for response
       personnel to wear self-contained breathing apparatus (SCBA) and fully encapsulating suits
       to protect against toxic environments.  Donning/Doffing of both is a relatively simple task,
       but  a routine must  be  established and practiced frequently. Not only do correct procedures
       help instill confidence in the wearer, they reduce the risk of exposure and the possiblity of
       damage to the suit.  It is especially important to remove the equipment systematically so as
       to prevent or minimize the transfer of contaminants from suit to  wearer.

       The following procedures for donning/doffing apply to certain types of suits.  They should
       be modified if a different suit or extra boots and gloves  are worn.  These procedures also
       assume that:

              The wearer has been trained in the SCBA.

              SCBA has been checked out.

              Appropriate decontamination steps have been taken prior to removal of the suit or
              other components.

              Sufficient air is available for routine decontamination and doffing of suit.

       Donning/doffing an encapsulating suit is more difficult if the user has to do it alone because
       of the physical  effort required.  Also  the possibility of wearer exposure to contaminants or
       damaging the suit greatly increases.  Therefore, assistance is needed in donning/doffing the
       equipment.
II.    DONNING

       A.     Before donning suit, thoroughly  inspect for deficiencies  that  will decrease its
              effectiveness as the primary barrier for protecting the body.  Do not use any suit
              with holes,  rips,  malfunctioning closures, cracked masks, etc.   If suit contains a
              hoodpiece, or a hard hat is worn, adjust it to  fit user's head.  If suit has a back
              enclosure for changing air bottles,  open it.

       B.     Use a moderate amount of talcum powder  or  cornstarch to prevent chafing and
              increase comfort.  Both also reduce rubber binding.

       C.     Use antifog  on suit and  mask facepieces.
 6/91                                        227

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      D.     While sitting (preferably), step into legs, place feet nroperly, and gather suit around
             waist.

      E.     While sitting (preferably), put on chemical-resistant, steel toe and shank boots over
             feet of suit.  Properly attach and affix suit leg over top of boot.

             1.     For one-piece suits with heavy-soled protective feet, wear leather or short
                    rubber safety boots inside suit.

             2.     Wear an additional pair of disposable boot protectors if necessary.

      F.     Put on SCBA airtank and harness assembly. Don facepiece and adjust it securely yet
             comfortably. Do not connect breathing hose.  Open valve to air tank.  (The air  tank
             and harness assembly could also be put on before stepping into legs of suit).

      G.     Depending on type of suit:

             1.     Put on inner gloves.

             2.     For suits with detachable  gloves, secure gloves to sleeves, if this has not
                    been done prior to entering the suit.  (In some cases, extra gloves are worn
                    over suit gloves).

      H.     While standing, put arms into sleeves,  and then head into hood of suit. The helper
             pulls suit up and over SCBA, resting hood on top of SCBA, adjusting suit around
             SCBA backpack and user's shoulders to assure unrestricted motion.  To facilitate
             entry into  the suit, bend at the knees as hood is placed over wearer's  head.  Avoid
             bending at the waist, as this motion tends to use up room in the suit rather that
             provide  slack.  For a tall or stout person, it is easier to put on the hood of the suit
             before getting into the sleeves.

      I.     Begin to secure suit by closing all fasteners until there is only room to connect the
             breathing hose. Also, secure all belts and/or  adjustable leg, head, and waist bands.
              Connect breathing hose while opening  main valve.

      J.     When breathing properly in SCBA, complete closing suit.

      K.    Helper should observe for a time to assure that wearer is comfortable and equipment
              is  functioning properly.
III.    DOFFING
       Exact procedures must be established and followed to remove the fully encapsulating suit and
       SCBA.  Adherence to these procedures is necessary to minimize or prevent contamination
       (or possible contamination) of the wearer through contacting the outside surface of the suit.

       The  following  procedures  assume that before the  suit is  removed, it has been properly
       decontaminated, considering the type and extent of contamination, and that a suitably attired
       helper is available.
6/91                                        228

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       A.    Remove any extraneous or disposable clothing, boot covers, or gloves.

       B.    If possible, wearer kicks  off chemical-resistant boots unassisted. To achieve this,
             oversized boots are often selected. Otherwise, helper loosens and removes chemical-
             resistant boots.

       C.    Helper  opens front of suit to allow access to SCBA regulator. As long as there is
             sufficient air pressure, hose is not disconnected.

       D.    Helper  lifts hood of the suit over wearer's head and rests hood on top of SCBA air
             tank. For  a tall or stout person it is easier to remove the arms from the sleeves of
             the suit prior to removing the hood.

       E.    Remove external gloves.

       F.    To minimize contact with contaminated clothing, helper touches only the outside of
             the suit, and the wearer touches only the inside. Remove arms, one at a time, from
             suit.  Helper lifts suit up and  away from SCBA  back pack,  avoiding any contact
             between outside surface of suit  and wearer's body. Helper lays suit  out flat behind
             wearer.

       G.    While sitting (preferably), remove both legs from suit.

       H.    After suit is completely removed, roll internal gloves  off hands, inside out.

       I.     Walk to clean area and follow procedure for doffing SCBA.

       J.     Remove inner clothing, clean body thoroughly.
IV.    ADDITIONAL CONSIDERATIONS

       A.     If work is at a very dirty site or the potential for contamination is extremely high,
              wear disposable Tyvek or PVC coveralls over fully encapsulating suit.  Make a slit
              in back to fit around bulge of the SCBA back pack.

       B.     Wear clothing inside  the  suit appropriate to outside temperatures.  Even in hot
              weather, wear long cotton underwear, which absorbs perspiration and acts as a wick
              for evaporation, thus aiding body cooling.  Long underwear also protects skin from
              contact with hot surface of suit, reducing the possibility of burns in hot weather.

       C.     Monitor wearer for heat  stress.

       D.     If a cooling device is used,  modify donning/doffing procedure.
       E.     If low-pressure warning alarm sounds  signifying  approximately  5  minutes of air
              remaining, follow these procedures:
6/91                                       229

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              1.      Quickly hose  off  suit and  scrub especially  around entrance/exit  zipper.
                     (Remove any disposable clothing.)

              2.      Open zipper sufficiently to allow access to regulator and breathing hose.

              3.      Disconnect breathing hose from regulator as main valve is closed.

              4.      Immediately attach canister  for vapor,  acid  gas,  dust,  mist,  or fume  to
                     breathing hose.  This provides  protection against contaminants still present.

              5.      Continue doffing suit as in steps A through J of previous section.  Take extra
                     care to avoid contaminating helper and wearer.
6/91                                         230

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                                 SECTION 5

                PERSONNEL PROTECTION EQUIPMENT

                                   PART?

               OSHA Regulations for Personal Protective Equipment
      29 CFR 1910.132                       41 CFR 50-204.7 General
                                           Requirements for Personal
                                           Protective Equipment

      29 CFR 1910.133 (a)                    ANSI Z87.1-1968
                                           Eye and Face Protection

      29 CFR 1910.134                       ANSI Z88.2-1969
                                           Standard Practice for
                                           Respiratory Protection

      29 CFR 1910.135                       ANSI Z89.1-1969
                                           Safety Requirements for
                                           Industrial Head Protection

      10 CFR 1910.136                       ANSI Z41.1-1967
                                           Men's Safety Toe Footwear
      ANSI - American National Standards Institute
            1430 Broadway
            New York, NY 10018
6/91                                   231

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OCCUPATIONAL SAFETY AND HEALTH                                         1910-Subpart I

                                                    STANDARDS AND INTERPRETATIONS
                                  PART  1910
               OCCUPATIONAL SAFETY AND HEALTH STANDARDS
                   SUBPART I—PERSONAL PROTECTIVE EQUIPMENT

           1910.132   General requirements.
           1910.133   Eye and face protection.
           1910.134   Respiratory protection.
           1910.135   Occupational head protection.
           1910.136   Occupational foot protection.
           1910.137   Electrical protective devices.
           1910.138   Additional delay in effective date.
           1910.139   Sources of standards.
           1910.140   Standards organizations.
                                                                       1910-Subpart I
                                   233

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 1910.132
                                                    OCCUPATIONAL SAFETY AND HEALTH
 STANDARDS AND INTERPRETATIONS
                SUBPART I— PERSONAL PROTECTIVE EQUIPMENT
                 1910.132— GENERAL REQUIREMENTS
(a) Application.

   Protective  equipment,  including- personal
protective equipment for eyes, face, head, and
extremities, protective clothing, respiratory
devices, and protective shields and barriers,
shall be provided, used, and maintained in a
sanitary and reliable condition wherever it is
necessary by reason of hazards of processes
or environment, chemical hazards, radiologi-
cal hazards, or mechanical irritants encoun-
tered in a manner capable of causing injury
or impairment in the function of any part of
the  body through  absorption,  inhalation or
physical contact.
(b) Employee-owned equipment.

  Where employees provide their own protec-
tive equipment, the employer shall be respon-
sible to assure its adequacy, including proper
maintenance, and sanitation  of such equip-
ment.
(c) Design.


  All personal protective equipment shall be
of safe design and construction for the work
to be performed.
                1910.133—EYE AND  FACE  PROTECTION
(a) General.

  (1) Protective eye and face equipment shall
  "be required  where there is a reasonable
  probability of injury that can be prevented
  by  such  equipment.   In  such   cases,
  employers shall make  conveniently avail-
  able a type of protector suitable for the work
  to  be performed, and employees shall  use
  such protectors. No  unprotected  person
  shall knowingly be subjected to a hazardous
  environmental condition. Suitable eye pro-
  tectors  shall be  provided where machines
  or operations present the hazard of flying
  objects, glare, liquids, injurious radiation,
  or a combination of these hazards.

  (2)  Protectors  shall meet  the following
  minimum requirements:

   (i) They shall provide adequate protection
   against the particular hazards for which
   they are designed.

   (ii) They shall  be reasonably confortable

1910.133(a)(3)(i)
    when worn under the designated condi-
    tions.

    (iii) They shall fit snugly  and shall not
    unduly interfere with the  movements of
    the wearer.

    (iv) They shall be durable.

    (v) They shall be capable of being disin-
    fected.

    (vi) They shall be easily cleanable.

    (vii) Protectors should be kept clean and
    in good.repair.

  (3) Persons whose vision requires the use
  of corrective lenses in spectacles, and who
  are required by this standard to wear eye
  protection, shall wear goggles or spectacles
  of one of the following types:

    (i) Spectacles whose protective lenses pro-
    vide optical correction.
                                             234

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 OCCUPATIONAL SATrTY AND  HEALTH
                             l»10.1Ut*X3>UU
                                                         STANDARDS AND INTERPRETATIONS
      (ii) Goggles that can be worn over correc-
      tive spectacles without  disturbing-  the
      adjustment of the spectacles.

      (iii) Goggles that incorporate corrective
      lenses mounted behind  the protective
      lenses.

   (4) Every  protector  shall  be  distinctly
   marked to  facilitate identification only of
   the manufacturer.
 (5) When  limitations  or precautions are
 indicated by the manufacturer, they shall
 be transmitted to the  user and care taken
 to see that such limitations and prt-cautions
 are strictly observed.

 (6) Design, construction, testing:, and use of
 devices for eye and face  protection shall be
 in accordance  with  American  National
 Standard for Occupational and Educational
 Eye and Face Protection. Z87.1-1968.
                 1910.134—RESPIRATORY  PROTECTION
 (a) Permissible practice.

   0) In the control of those occupational dis-
   eases caused by breathing- air contaminated
   with harmful  dusts,  fogs, fumes,  mists,
   pases, smokes, sprays, or  vapors, the pri-
   mary objective shall he  to  prevent  at-
   mospheric contamination. This shall be
   accomplished as far as feasible by accepted
   engineering control measures (for example,
   enclosure or confinement of the operation,
   general and local ventilation, and substitu-
   tion of less toxic materials). When effective
   engineering: controls are  not feasible, or
   while they are being instituted, appropriate
   respirators  shall be used pursuant to the
   following requirements.

   (2)  Respirators  shall be provided  by the
   employer when  such equipment is neces-
   sary to protect the health of the employee.
   The employer shall  provide the respirators
   which are  applicable and suitable for the
   purpose  intended. The employer shall be
   responsible   for  the  establishment   and
   maintenance of a  respiratory  protective
   program which shall include the require-
   ments outlined in paragraph (b) of this sec-
   tion.

   (3) The employee shall use the provided
   respiratory  protection in accordance  with
   instructions and training received.

(b) Requirements for a  minimal acceptable
program.

  {') Written standard operating procedures
     38
 governing  the  selection   and
 respirators shall be established.
use  of
 (2) Respirators shall be selected on the basis
 of hazards to which the worker is exposed.

 (3) The user shall be instructed and trained
 in the proper use of respirators  and their
 limitations.

 (4) Removed
 (5) Respirators shall be regularly cleaned and
 disinfected. Those used by more than one
 worker shall be thoroughly cleaned- and disi-
 nfected after each use.
 (6) Respirators shall be stored in a conven-
 ient, clean, and sanitary location.
(7)  Respirators used  routinely  shall  be
inspected  during   cleaning.   Worn  or
deteriorated  parts shall be replaced. Res-
pirators for emergency  use such  as  self-
contained  devices   shall  be  thoroughly
inspected at  least once a month and  after
each use.

(8) Appropriate surveillance of work area
conditions and degree of employee exposure
or stress shall be maintained.
                                   235

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l»10.134
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OCCUPATIONAL SAFTTY AND HEALTH
                                                                              1910.1M
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1910.1J4UXSXU)
          OCCUPATIONAL SAFETY AND HEALTH
STANDARDS AND INTERPRETATIONS
    tive lenses inside full facepieces. When a
    workman  must wear corrective lenses as
    part of the facepiece, the facepiece and
    lenses shall  he  fitted by  qualified in-
    dividuals to provide good vision, comfort.
    and a pas-tight seal.

    (iii) If corrective spectacles or goggles are
    required, they shall be worn so as not to
    affect  the fit of the facepiece.  Proper
    selection of equipment will minimize or
    avoid this problem.

(f) Maintenance and  care of respirators.

  (1) A program for maintenance and care of
  respirators shall be adjusted  to the type of
  plant,  working  conditions,  and hazards
  involved,  and shall include  the  following
  ba.sic services:

    (i) Inspection for defects (including a leak
    check),

    (ii) Cleaning and disinfecting,

    (iii) Repair,

    \iv) Storage

   Equipment shall be properly maintained to
   retain its original effectiveness.
  (2)
     (!)  All  respirators  shall  be  inspected
     routinely before and after each use. A
     respirator that is not routinely used but
     •s kept ready for emergency use shall  be
      •spected  after each  use and at least
     tionthly to assure that it is in satisfactory
     working condition.

        Self-contained breathing apparatus
          be inspected  monthly.  Air and
     jxygen cylinders shall be fully charged
     according to the manufacturer's instruc-
     tions. It shall be determined that the reg-
     ulator an'" earning devices function prop-
     erly.

     (iii) Respirator inspection shall include a
     check of the tightness of connections and
     the condition of the facepiece, he;ul-
  bands, valves, con nee ting tube, and canis-
  ters. Rubber or elastomer parts shall be
  inspected  for  pliability  and  signs  of
  deterioration. Stretching and manipulat-
  ing rubber or elastomer parts with a mas-
  saging action will keep them pliable and
  flexible and prevent them from taking a
  set during storage.

  (iv) A record shall be kept of inspection
  dates and findings for respirators main-
  tained for emergency use.

(3) Routinely used respirators shall be col-
lected,  cleaned,  and  disinfected  as  fre-
quently as necessary to insure that proper
protection is provided for the wearer.  Respira-
tors maintained for emergency  use  shall  be
cleaned and disinfected after each use.
(4) Replacement or repairs  shall be done
only  by experienced  persons with  parts
designed  for  the respirator. No attempt
shall be made to replace components or to
make  adjustment  or  repairs  beyond  the
manufacturer's recommendations. Reduc-
ing or admission valves or regulators shall
be returned to  the manufacturer or to a
trained technician for adjustment or repair.
(5)
  (i) After inspection, cleaning, and neces-
  sary repair, respirators shall be stored to
  protect against  dust,  sunlight,  heat,
  extreme  cold, excessive  moisture,  or
  damaging chemicals. Respirators placed
  at stations and work areas for emergency
  use should  be quickly accessible at all
  times and  should be stored  in compart-
  ments built for the purpose. The compart-
  ments  should   be   clearly   marked.
  Routinely used respirators, such as dust
  respirators, may be placed in plastic bags.
  Respirators should not be stored in such
  places as lockers or tool boxes unless they
  are in carrying cases or cartons.
                                                                                       36
                                         238

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OCCUPATIONAL SAFETY AND HEALTH
                                                                             l»10.1J4
     (ii) Respirators should be packed or stored
     so that the facepiece and exhalation valve
     will rest in a normal position and function
     will not be impaired by the elastomer set-
     ting in an abnormal position.

     (Hi) Instructions for proper storage  of
     emergency respirators, such as gas masks
     and self-contained  breathing apparatus.
     are found in "use and care"  instructions
     usually mounted inside the carrying case
     lid.

 (9) Identification of gas mask canisters.

   (1) The primary means of identifying a gas
   mask canister shall be by means of properly
   worded labels. The secondary means of iden-
   tifying a gas mask canister shall be  by a
   color code.

   (7) All who issue or use gas masks falling
   within the scope of this section shall see that
   all gas mask canisters purchased or used
   by them are properly labeled  and colored
   in  accordance with  these requirements
   before they are placed in service and  that
   the labels and colors are properly main-
   tained  at  all times  thereafter until the
   canisters have completely served their pur-
   pose.

   (3) On each canister shall appear in bold let-
   ters the following:
    (i)
    Canister for	
        (Name for atmospheric contaminant)
                     or
            Type N Gas Mask Canister

    (ii) In addition, essentially the following
    wording shall appear beneath the appro-
    priate phase on the canister label: "For
          STANDARDS AND INTERPRETATIONS

  respiratory protection in atmospheres
  containing not more  tnan 	 per-
  cent by  volume of	
(4)  Canisters  having  a special  high-effi-
ciency   filter   for   protection    against
radionuclides  and other highly toxic par-
ticulates shall be labeled with & statement
of the type and degree of protection afforded
by the filter. The label shall be affixed to
the neck end of, or to the gray stripe which
is around and  near the top of, the canister.
The degree of protection shall be  marked
as the percent of penetration of the canister
by a 0.3-micron-diameter dioctyl phthalate
(DOP) smoke at a flow rate of 85 liters per
minute.

(5) Each canister shall have a label warning
that  gas masks should be used  only in
atmospheres containing sufficient oxygen
to  support life (at least  16  percent  by
volume), since gas mask canisters are only
designed to neutralize or remove contami-
nants from the air.

(6) Each gas mask canister shall be painted
a distinctive color or combination of colors
indicated in Table 1-1. All colors used shall
be such that they are clearly identifiable
by the user and clearly distinguishable from
one another. The color coating used shall
offer a high degree of resistance to chipping,
scaling, peeling, blistering, fading,  and the
effects  of the ordinary  atmospheres  to
which they may be exposed under normal
conditions  of  storage  and use.  Appro-
priately colored pressure sensitive tape
may be used for the  stripes.
Chaaft 7
                                  239

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H10.134
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                                  SECTION 5

                  PERSONAL PROTECTIVE EQUIPMENT

                                    PARTS

    MANUFACTURERS AND SUPPLIERS OF PERSONNEL PROTECTIVE GEAR
I.
RESPIRATOR AND PROTECTIVE CLOTHING MANUFACTURER ADDRESSES
      A-Best Products
      3865 W. 150th Street
      Cleveland, OH 44111
      216/941-9400
      American Optical Corp.
      Safety Products Division
      14 Mechanic Street
      Southbridge, MA 01550
      617/765-9711

      Andover Industries, Inc.
      10 Railroad Street
      Andover, MA  01810
      617/475-1302

      Barry Manufacturing Co., Inc.
      920 Lakeshore Road East
      Mississauga, Ontario, Canada
      416/274-3691
                                            Cesco Safety Products
                                            100 E. 16th Street
                                            P.O.  Box 1237
                                            Kansas City, MO  64141
                                            816/842-8500

                                            Charkate Glove and Specialty Co.
                                            130 W. 10th Street
                                            Huntington Station, NY 11746
                                            516/427-1802
                                            800/221-0224

                                            Colonial Glove and Garmet
                                            54 Penataquit Avenue
                                            Bay Shore, NY  11706
                                            516/968-8888

                                            Cosmasec
                                            Drawer 10
                                            Niblic Road
                                            Enfield, CT 06082
                                            203/741-2207
      Bata Shoe Company, Inc.
      Industrial Products Division
      Belcamp, MD 21017
      301/272-2000

      Bendix Corp.
      12345 Starkey Road
      Largo, FL 33543
      813/536-6523

      Best Manufacturing Co.
      Edison Street
      Menlo, GA 30713
      404/862-2302
                                            Dayton Flexible Products
                                            2210 Arbor Blvd.
                                            Dayton, OH 45439
                                            513/298-7511

                                            Defense Apparel
                                            286 Murphy Road
                                            Hartford,  CT 06114
                                            800/243-3847

                                            The DeVilbis Company
                                            300 Phillips Avenue
                                            P.O. Box  913
                                            Toledo, OH 43692
                                            419/470-2169
6/91
                                           241

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      Boss Manufacturing Co.
      221 West First Street
      Kewanee, IL 61443
      309/852-2131
      E. D. Bullard  Company
      2680 Bridgeway
      Sausalito, CA  94965
      415/332-0410

      Edmont Division of Becton,
       Dickinson, and Company
      1300 Walnut Street
      Coshocton,  OH  43812
      614/622-4311

      Encon Manufacturing Co.
      4919 Dickson  Street
      Houston, TX  77007
      713/462-4723
      Expendables, Inc.
      2945 Congressman Lane
      Dallas, TX 75220
      214/350-6783

      Frommelt Industries, Inc.
      Safety Products Division
      P.O. Box 658
      2455 Kerper Boulevard
      Dubuque, IA  52001
      319/589-2736

      Fyrepel Products, Inc.
      P.O. Box 518
      Newark, OH  43055
      614/344-0391

      Glendale Optical Co., Inc.
      130 Crossway Park Drive
      Woodbury, NY 11797
      516/921-5800

      Globe Safety Products, Inc.
      125 Sunrise Place
      Dayton, OH 45407
      513/2247468
       Disposables, Inc.
       14 Locust Street
       Manhasset, NY 11030
       516/627-4554
       Durafab, Inc.
       P.O. Box 658
       Cleurne, TX  76031
       817/645-8851

       W. L. Gore & Assoc.
       Box 1130
       Elkton,  MD 21921
       301/392-3700
        Granet Div., ESB, Inc.
        25 Loring Drive
        P.O. Box 588
        Framingham, MA 01701
        617/875-3521

        H.S. Cover Company
        107 E. Alexander Street
        Buchanan, MI 49107
        616/695-9663

        Hodgeman
        207 E. Wolf Street
        Yorkville, IL  60560
        312/553-0100
        International Latex, Inc.
        213 Hanna Building
        Cleveland, OH 44115
        216/523-1000

        International Safety Instruments, Inc.
        16717 Smoketree Street
        Hesperia, CA  92345
        619/244-9404

        ILC Dover
        P.O.,  Box 266
        Frederica, DE  19946
        302/335-3911
6/91
242

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      Glover Latex, Inc.
      514 South Rose Street
      Anaheim, CA  02805
      714/535-8920

      Jomac Products, Inc.
      863 Easton Road
      Warrington, PA  18976
      215/343-0800

      Kappler Disposables, Inc.
      Post Office Drawer 218
      Guntersville, AL 35976
      205/582-2195

      Keller Glove Mfg. Co.
      Route 611
      Plumsteadville, PA  18949
      215/343-1135

      LRC Safety Products (Surety Rubber)
      Rt. 46 West
      Little Falls, NJ 07424
      201/256-5500 Ext.227

      LaCrosse Rubber Mills Co.
      Indian Hill
      LaCrosse, WI 54601
      608/782-3020

      Lehigh Safety Shoe Co.
      1100 E. Main Street
      Endicott, NY  13760
      607/754-7980

      Life Support System, Inc.
      1400 Stierlin Road
      Mountain View, CA 94043
      415/962-9800

      Lion Uniform, Inc.
      Industrial Safety Division
      P.O. Box  14165
      Northridge Branch
      Dayton, OH 45414
      513/278-6531
      800/543-9698
Iron Age Shoe Company
2408 Woodmere Drive
Pittsburgh, PA  15205
412/922/7000

Jordan David Safety Products
P.O. Box 400
Warrington,  PA  18976
215/343-6470

Mar-Mac Mfg. Co.,Inc.
Box 278
McBee, SC  29101
803/335-8211

Melco, Inc.
6603 Printz Blvd.
Wilmington, DE 19809
800/441-9749

Mine Safety  Appliances
600 Penn Center Blvd.
Pittsburgh, PA  15235
412/273-5000

Monte Glove Company
Monte Lane
Maben, MI  38750
601/263-5353

National Draeger, Inc.
401 Parkway View  Drive
Pittsburgh, PA  15205
412/787-8383

National Safety Wear, Inc.
18  East Main Street
Malone, NY  12953
518/483-7246

Neese Industries, Inc.
P.O. Box 628
Gonzales, LA  70737
504/644-6553
6/91
                                            243

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      Magid Glove Mfg. Co.
      2060 N. Kolmar Avenue
      Chicago, IL  60639
      312/384-2070
      800/621-8010
      Oak Medical Supply Company
      The Oak Rubber Company
      219 S. Sycamore Street
      Ravenna, OH
      216/296-3416

      Plastex Protective Products, Inc.
      9-T Grand Street
      Garfield, NJ 02706
      201/779-4946

      Plastimayd Corporation
      2216 S. E. Seventh Avenue
      Portland, OR  97214
      503/232-5101
      Playtex Industrial Gloves
      700 Fairfield Avenue
      Stamford, CT 06902
      203/356-8000

      Protexall Company
      Box 307
      Green Lake, WI  54941
      414/294-6511
      Pulmosan Safety Equipment Corp.
      30-48 Linden Place
      Flushing, NY 111354
      212/939-3200

      Racal Airstream, Inc.
      7309-A Grove Road
      Frederick, MD  21701
      301/695-8200

      Rainfairjnc.
      P.O. Box 1647
      Racine, WI  53401
      800/558-5990
       North Safety Equipment
         (formerly Norton)
       Division of Siebe North
       2000 Plainfield Pike
       Cranston, RI  02920
       401/943-4400

       Pioneer Industrial Products
       1831 Olive Street
       St. Louis, MO 63103
       314/621-7788
       Record Industrial Company
       P.O. Box 407
       King of Prussia, PA  19406
       215/337-2500

       Red Kap Industries
       749 Massman Drive
       Nashville, TN 37210
       615/889-6800
       800/251-1068

       Renco Corporation
       2060 Fairfax Avenue
       Cherry Hill, NJ  08003
       609/424-5755

       Rexnord Safety Products, Inc.
         (Biomarine)
       45 Great Valley Corporation Center
       Malvern, PA  19355
       215/647-7200

       Safety Clothing & Equipment Co.
       4900 Campbell Road
       Willoughby, OH  44094
       216/946-1880

       Scott Aviation
       225 Erie Street
       Lancaster, NY 14086
       716/683-5100

        Sijal, Inc.
        P.O.  Box 205
        205 Roesch Avenue
        Oreland, PA  19075
        215/572-0216
6/91
244

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      Ranger Rubber Company
      Division of Endicott Johnson
      1100 East Main Street
      Endicott, NY  13760
      607/757-4260

      Standard Safety Equipment
         (StaSafe)
      Box 188
      431  N. QuentinRoad
      Palatine, IL  60067
      312/359-1400

      Steel Grip Safety
        Apparel Co., Inc.
      700 Garfield Street
      Box 833
      Danville, IL 61832
      217/442-6240

      3M/Occupational Health & Safety
         Products Division
      220-7W 3M Center
      St. Paul, MN  55144
      612/733-6234

      Tingley Rubber Company
      P.O. Box  100
      South Plainfield, NJ  07080
      201/757-7474

      Trades Company
      100 Cabot Street
      Holyoke, MA  01040
      413/533-7141

      United States Safety Service Co.
      1535 Walnut Street
      P.O. Box  1237
      Kansas City, MO  64108
      816/842-8500

      Vidaro Corporation
      333 Martinel Drive
      P.O. Box 535
      Kent, OH 44240
      216/673-7413
Wheeler Protective Apparel,Inc.
224 W. Huron Street
Chicago, IL  60610
312/787-1156
Willson Safety Products
P.O. Box 622
Reading, PA  19603
Survivair Division
U.S. Divers Corporation
3323 W. Warner Avenue
Santa Ana, CA  92702
714/540-8010
6/91
                                             245

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       SECTION 6




REFERENCES AND GLOSSARY

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                                      SECTION 6

                          REFERENCES AND GLOSSARY

                                        PARTI

                            REFERENCES AND RESOURCES
I.      INTRODUCTION

       This list provides  the titles of references and organizations which may be of value to  those
       responding to hazardous material incidents. Other resources are available which are not names
       here.  This list can be expanded based on personal preferences and requirements.

       The references are categorized by subject.  The title, author, publisher, and place of publication
       are given for each.  The  year of publication is not always given because many are revised
       annually. The user should attempt to obtain the most recent edition.

       The last section lists sources of these references as well as other information that might be useful.
       Usually, these agencies or associations will provide a catalogue on request. Where available,
       phone number are  listed.

       Items identified with an asterisk (*) may be particularly useful in "first response"  situations.
II.     REFERENCES

       A.     Industrial Hygiene (Air Sampling and Monitoring, Respiratory Protection, Toxicology).

              1.      Air Sampling Instruments for  Evaluation of Atmospheric  Contamin- ants,
                     American Conference of Governmental Industrial Hygienists, Cincinnati, OH.

              2.      Basic  Industrial  Hygiene.  Richard  Brief,  American  Industrial  Hygiene
                     Association, Akron, OH.

              3.      Direct Reading  Calorimetric Indicator Tubes  Manual. American Industrial
                     Hygiene Association, Akron, OH.

              4.      Documentation of the Threshold Limit Values (TLV). American Conference of
                    . Governmental Industrial Hygienists, Cincinnati, OH.

              5.      Fundamentals of Industrial  Hygiene. National Safety Council, Chicago, IL.

              6.      Health   Aspects  of   the  Disposal  of Waste  Chemicals.  Grisham, J.W.,
                     Pergamon Press.

              7.      The Industrial Environment-Its Evaluation and Control.  National Institute for
                     Occupational Safety and Health, Rockville, MD.

                                             1

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      8.     Industrial Hygiene  and Toxicology.  Frank A. Patty,  John Wiley and Sons,
             Inc., New York, NY.

      9.     Industrial Toxicology -  Safety and Health in  the  Workplace. Williams and
             Burson, ACGIH.

      10.    Manual of  Recommended Practice for   Combustible Gas   Indicators and
             Portable.   Direct Reading   Hydrocarbon  Detectors.   American Industrial
             Hygiene Association, Akron, OH.

      11.    NIOSH Manual of Analytical Methods. Volumes 1-7.  NIOSH, Department of
             Health  and Human Services, Cincinnati, OH.

   *  12.    NIOSH/OSHA  Pocket  Guide to  Chemical Hazards.  DHHS  No.  85-114,
             NIOSH, Department of Health and Human Services, Cincinnati, OH.

      13.    Occupational Health  Guidelines for  Chemical Hazards.  DHHS No. 81-123,
             NIOSH, Department of  Health and Human Services, Cincinnati, OH.

      14.    Registry of Toxic Effects of Chemical Substances. DHHS  No. 83107, National
             Institute for Occupational Safety and Health, Rockville, MD.

      15.    Respiratory Protective  Devices  Manual.   American   Industrial Hygiene
             Association, Akron, OH.

   *   16.    TLVs Threshold  Limit Values and Biological Exposure  Indices (Threshold
             Limit Values for Chemical Substances and Physical Agents in the  Workroom
             Environment).  American  Conference of Governmental Industrial Hygienists,
             Cincinnati, OH.

       17.    Toxicology - The Basic Science of Poisons. John Doull, Curtis D. Klaasen and
             Mary O. Amdur,  Macmillan Publishing Co., New York, NY (1980).

B. Chemical Data

   *   1.     Chemical Hazard Response Information System (CHRIS).  U.S. Coast Guard,
             Washington, DC. Commandant Instruction M. 16565.12A.

       2.     CHRIS -  A  Condensed  Guide  Chemical    Hazards.   U.S. Coast  Guard,
              Commandant Instruction M16565.11a.

       3.      Chemical  Hazards of the  Workplace. Proctor and Hughes,  J. B. Lippincott
              Company.

       4.      Chemistry of Hazardous Materials. Eugene Meyer,  Prentice-Hall, Englewood
              Cliffs,  NJ.

       5.      Clinical Toxicology  of Commercial  Products.  Gosselin, R. E.,  William and
              Wilkins.

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*  6.     The Condensed  Chemical  Dictionary.   G. Hawley, Van Nostrand
          Reinhold Co., New York, NY.

   7.     CRC Handbook of Chemistry  and Physics. CRC  Press-Boca Raton, FL.

*  8.     Dangerous Properties of Industrial  Materials. N. Irving Sax, Van  Nostrand
          Reinhold Co., New York, NY.

*  9.     Effects of Exposure to Toxic Gases. Matheson.

*   10.    Emergency   Handling of   Hazardous Materials in Surface Transpor- ation.
          Student, P.J., Bureau of Explosives, Association of American Railroads.

    11.    Farm Chemicals Handbook. Farm Chemicals Magazine, Willoughby,  OH

*   12.    Firefighter's  Handbook of Hazardous Materials.  Baker,  Charles J., Maltese
          Enterprises, Indianapolis, IN.

*   13.    Fire  Protection  Guide  to Hazardous  Materials.  National Fire Protection
          Association, Boston, MA.

    14.    Handbook of Chemical Property Estimation Methods. Lyman, W.J., Reehl, W.
          F., and Rosenblatt, D.H.; McGraw Hill Book Company.

    15.    Handbook of Environmental Data on Organic Chemicals.Verschueren. K., Van
          Nostrand Reinhold Co.

    16.    Handbook of Reactive Chemical Hazards. Bretherick, L., Butterworths, Boston,
          MA.

    17.    Handbook  of Toxic  and   Hazardous  Chemicals.  Sittig,  Marshal, Noyes
          Publications.

    18.    Hazardous Materials Handbook. Meidl, J.H., Glencoe Press.

    19.    Hygienic  Guides. American Industrial  Hygiene  Association, Akron, OH.

    20.    The Merck Index. Merck and  Co., Inc., Rahway, NJ.

    21.    Toxic and Hazardous  Industrial Chemicals Safety Manual.  The International
          Technical Information Institute, Tokyo, Japan.

C.  EPA Methods Manuals for Sampling and Analysis
    1.      Biological Field  and  Laboratory  Methods  for  Measuring  the Quality of
           Surface Water and Effluents. EPA-670/4-73-001.

    2.      Emergency Drum Handling  at Abandoned Dump Sites. EPA Contract No. 68-
           03-3113.

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       3.      EPA  Solid  Waste  Manual,  Test Methods for  Evaluating  Solid  Waste.
              Physical/Chemical Methods. SW-846 (May 1980).

       4.      Handbook for Analytical Quality Control in Water and Waste-water Laboratories.
              EPA-600/4-79-019 (March  1979).

       5.      Methods  of Chemical   Analysis  of  Water and Wastes.   EPA-600/479020
              (March 1979).

       6.      Microbiological Methods for Monitoring the Environment.  Water and Wastes.
              EPA-600/8-78-017 (December 1978).

       7.      Procedures   Manual for  Groundwater  Monitoring at  Solid Wastes Disposal
              Facilities. EPA-530/SW-611 (August 1977).

D.     Safety and Personnel Protection

       1.      Best's Safety Directory. A.M. Best Co.,  Oldwick, NJ.

       2.      CRC Handbook of Laboratory Safety.  Norman V. Steere,  CRC Press, Boca
              Raton, FL.

       3.      Fire Protection Handbook.  National Fire Protection Association, Quincy, MA.

       4.      Flammable   Hazardous  Substances  Emergency  Response Handbook; Control
              and Safety  Procedures. EPA Contract  No. 68-03-3014.

       5.      FM Approval List, Factory Mutual, Norwood, MA.

    *  6.      Guidelines for the Selection of Chemical  Protective Clothing. Vol.  1: Field
              Guide. A.D. Schwope, P.P. Costas, J.O. Jackson, D. J. Weitzman, Arthur D.
              Little, Inc.,  Cambridge, MA (March 1983).

       7-      1 Guidelines for  the Selection  of Chemical Protective Clothing.  Volume  2:
              Technical and  Reference Manual.  A.D. Schwope,  P.P. Costas, J.O. Jackson,
              D.J. Weitzman, Arthur D.  Little, Inc., Cambridge,  MA (March 1983).

       8.     Handling Radiation Emergencies. Purington and Patterson,  NFPA.

       9.     Hazardous Materials Injuries. A Handbook for Pre-Hospital Care. Douglas R.
              Stutz,  Robert C. Ricks, Michael  F. Olsen, Bradford Communications Corp.,
              Greenbelt, MD.

        10.    National Safety Council Safety Sheets. National Safety Council, Chicago, IL.

        11.     NIOSH  Certified Equipment List.  U.S. Dept. of Health and Human Services.

        12.     Personal Protective Equipment for Hazardous Materials Incidents: A Selection
               Guide. NIOSH,  U. S. Department of Health and Human Services.

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       13.    Protecting Health and Safety at Hazardous Waste Sites:  An Overview. U.S.
              Environmental Protection Agency.

       14.    Radiation  Protection - A Guide for Scientists and Physicians. Shapiro, Jacob,
              Harvard University Press, Cambridge, MA.

       15.    Radiological Health Handbook. U.S. Dept. of Health, Education and Welfare.

    *  16.    Radiological Health  -  Preparedness  and Response  in Radiation Accidents.
              U.S. Dept. of Health and Human Services.

       17.    A Review of the Department of Transportation Regulations for Transportation
              of Radioactive Materials. U. S. Department of Transportation.

    *  18.    SCBA-A Fire Service Guide to the Selection. Use. Care, and Main- tenance of
              Self-Contained Breathing Apparatus. NFPA, Batterymarch Park, Quincy, MA.

    *  19  .   Standard First Aid and  Personal Safety.  American  Red Cross.

       20.    Underwriters  Laboratories  Testing for  Public Safety.  Annual Directory.
              Underwriters Laboratories, Inc.,  Northbrook, IL.

E.     Planning Guides

       1.     Chemical Emergency Planning Program. U.S. EPA.

       2.     Detoxification of Hazardous Wastes. Exner, Jurgen H., Ann Arbor Science.

    *  3.     Federal  Motor   Carrier Safety   Regulations   Pocketbook.   (U. S. Dept. of
              Transportation) J.J.  Keller and Associates, Inc.

       4.     Handbook for Remedial Action at Waste Disposal Sites. EPA 625/682-006 (June
               1982).

       5.     Hazardous and  Toxic  Materials:  Safe Handling  and Disposal. Fawcett,
              H.H., John Wiley and Sons.

       6.     Hazardous Chemical Spill Cleanup. Noyes Datat Corporation, Ridge Park, New
              Jersey.

       7.     Hazardous Materials Emergency Planning Guide. National Response Team, U.S.
              Environmental Protection Agency,  401 M.  Street S.W., Washington, DC 20460
              (1987).

       8.     Hazardous Materials Spills Handbook.  Gary F. Bennett, Frank S. Feates, Ira
              Wilder, McGraw-Hill Book Co., New York, NY.

       9.     Hazardous Waste Regulation-An  Interpretive  Guide.   Mallow,  Alex,  Van
              Nostrand Reinhold Company.

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              10.    Occupational Safety and Health Guidance Manual for  Hazardous Waste Site
                    Activities. NIOSH/OSHA/USCG/EPA,  U.S.  Dept.  of Health  and Human
                    Services, NIOSH.

              11.    Standard Operating Safety Guides. Environmental Response Branch,  Office of
                    Emergency and Remedial Response,  U.S. Environmental Protection Agency.

              12.    State Decision-Makers Guide for Hazardous Waste Management. SW612. U.S.
                    EPA (1977).

              13.    1984 Emergency Response Guidebook - Guidebook for Hazardous Mat-erials
                    Incidents. DOT P 5800.3 USDOT, Materials Transportation tation Bureau,
                    Attn: DMT-11, Washington, DC 20590.
III.    TECHNICAL   INFORMATION  AND  POTENTIAL   RESPONSE/INFORMATION
       SOURCES

    1.     AFX Rail Car Mfgr.
          314/724-7850

    2.     Agency for Toxic Substances Disease Registry
          Centers for Disease Control
          Shamlee28 S., Room 9
          Atlanta, GA 30333
          404/452-4100

    3.     American Conference of Governmental Industrial Hygienists
          6500 Glenway Avenue, Building D-5
          Cincinnati, OH  45211
          513/661-7881

    4.     American Industrial Hygiene Association
          475 Wolf Ledges Parkway
          Akron, OH  44311-1087
          216/762-7294

    5.     American Insurance Association (AIA)
          (National Board of Fire Underwriters)
          Engineering and Safety Service
          85 John St.
          New York, NY 10038
          212/533-4400

    6.     American National Standards Institute, Inc.
           1430 Broadway
          New York, NY 10018
          212/354-3300

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7.      American Petroleum Institute (API)
       1220 L Street N.W., 9th Floor
       Washington, DC 20005
       202/682-8000

8.      American Society of Mechanical Engineering (ASME)
       United Engineering Center
       345 East 47th Street
       New York, NY 10017
       212/644-7722

9.      ARMY ORDINANCE UNIT
10.    Ashland Chemical Company
       3849 Risher Road
       Columbus, OH  43228
       614/276-6143

11.    Association of American Railroads (AAR)
       50 F Street N.W.
       Washington, DC 20001
       202/639-2100

12.    Association of American Railroads (AAR)
       59 East Van Buren Street
       Chicago, IL 60650
       312/939-0770

13.    BOMB HANDLERS

14.    Bureau of Explosives
       American Association of Railroads
       1920 L Street, N.W.
       Washington, DC 20036
       202/293-4048

15.    Center for Disease Control
       Atlanta, GA
       404/633-5313

16.    CHEMICAL INFORMATION

17.    CHEMICAL RESPONSE INFORMATION
 18.    Chemical Manufacturer's Association
       2501 M St. N.W.
       Washington, DC 20037
       202/877-1100

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19.    CHEMISTS

20.    Chemtrec
      Washington, DC
      800/424-9300

21.    CIVIL DEFENSE CLEANUP CONTRACTORS

22.    The Clorine Institute
      342 Madison Avenue
      New York, NY  10017
      212/682-4324

23.    The Compressed Gas Association, Inc. (CGA)
      500 Fifth Avenue
      New York, NY  10036
      212/354-1130

24.    CONSTRUCTION COMPANIES (HEAVY EQUIPMENT)

25.    CRC Press, Inc.
      2000 Corporate Blvd., N.W.
      Boca Raton, FL 33431
      305/994-0555, Ext. 330

26.    DEPARTMENTS OF ENVIRONMENTAL QUALITY (STATE, LOCAL)

27.    DEPARTMENT OF TRANSPORTATION (STATE)

28,    Dow Chemical Company
      Midland, MI  48640
      517/636^400

29.    DuPont Company
       1007 Market Street
      Wilmington, DE  19898
      302/774-7500

30.   Energy Research Development Admin.
      Albuquerque Office
      Albuquerque, NM 87101
      505/264-4667(8)

31.   ENVIRONMENTAL PROTECTION AGENCY

32.    EPIDEMIOLOGISTS

33.    Factory Mutual Engineering Corp. Lab
       1150 Boston-Providence Turnpike
       Norwood, MA 02062
       617/762-4300

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34.    The Fertilizer Institute (TFI)
      1015 18th St., N.W.
      Washington, DC  20036
      202/86 M900

35.    FIRE DEPARTMENTS

36.    GAS COMPANIES

37.    GATX RAIL CAR MFGR.
      312/621-6200

38.    HAZARDOUS MATERIALS EXPERTS

39.    HAZARDOUS MATERIALS TEAMS

40.    HEALTH DEPARTMENT

41.    HIGHWAY DEPARTMENT

42.    HOSPITALS

43.    Institute of Makers of Explosives (I ME)
      420 Lexington Avenue
      New York, NY  10017
      212/986-6920

44.    J. T. Baker Chemical Company
      Phillipsburgh, NY 08856
      201/859-2151

45.    Kerr-McGee Chemical Corp.
      Kerr-McGee Center
      Oklahoma City, OK  73125
      405/270-1313

46.    LAW ENFORCEMENT AGENCIES

47.    Mallinckrodf, Inc.
      P.O. Box 5439
      St. Louis, MO 63147
      314/895-0123

48.    Manufacturing Chemists Association, Inc.
      1825 Connecticut Avenue N.W.
      Washington, DC  20009
      202/483-6126

49.    MANUFACTURERS REPRESENTATIVES

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50.     MOTOR CARRIER SAFETY

51.     National Bureau of Standards
       U.S. Department of Commerce
       Washington, DC 20234
       301/921-1000

52.     National Fire Protection Association
       Batterymarch Park
       Quincy, MA 02269
       617/328-9290

53.     National Institute for Occupational Safety and Health
       Division of Technical Services
       46765 Columbia Parkway
       Cincinnati, OH  45226
       513/684-8302

54.     National Response Center (USCG and EPA)
       800/424-8802

55.     National Safety  Council
       444 North Michigan St.
       Chicago, IL 60611
       312/527-4800

56.    National Tank Truck Carriers, Inc.
       1616 P St.
       Washington, DC  20036
       202/797-5426

57.    National Transportation Safety Board
       800 Independence Avenue
       Washington, DC  20594
       202/655-4000

58.    NATX Rail Car Mfgr.
       312/648-4000

59.    Occupational Safety  and Health Administration
       U.S. Department of Labor
       Washington, DC
       202/523-9700

60.    Oil and Hazardous Material Technical Assistance Data System
       202/245-3045

61.    Poison Control Center
       Charleston, SC
       502/432-9516
                                         10

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62.    PORT AUTHORITIES

63.    PUBLIC INFORMATION MEDIA

64.    PUBLIC WORKS

65.    RADIOACTIVE MATERIAL HAULERS

66.    Radiological Assistance Zone 3
      Savannah River Operations Office
      Aiken, SC  29801
      803/725-6211, x3333

67.    RADIO STATIONS

68.    RAILROAD DIVISION SUPERINTENDENT

69.    RAILROAD MATERIAL HANDLERS

70.    RAILROADS

71.    REGIONAL RESPONSE TEAMS

72.    SANITATION AGENCIES

73.    SHERIFF'S OFFICE

74.    SHIPPER REPRESENTATIVES

75.    STATE FIRE MARSHAL

76.    STATE POLICE

77.    STEVEDORING COMPANIES

78.    STREET DEPARTMENT

79.    STRUCTURAL ENGINEERS

80.    Superintendent of Documents
      U.S. Government Printing Office
      Washington, DC 20402
      202/783-3238

81.    TELEVISION STATIONS

82.    TOXICOLOGISTS
                                  11

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83.     Underwriters' Laboratories
       207 East Ohio St.
       Chicago, IL 60611
       312/642-6969

84.     Union Carbide Corp.
       Linde Div.
       51 Cragwood Road
       S. Plainfield, NJ 07080
       201/753-5800

85.     U.S.  Army Explosive and Ordnance Disposal
       301/677-5182

86.     U.S.  COAST GUARD

87.     U.S.  DEPARTMENT OF AGRICULTURE

88.     U.S.  Department of Defense
       Nuclear Accident Center
       505/264-4667

89.     U.S.  Department of Energy
       Washington, DC 20545
       202/252-5000

90.     U.S.  Department of Transportation
       Materials Transportation  Bureau
       Office of Hazardous Materials Operations
       400 7th St. S.W.
       Washington, DC 20590
       202/366-4555

91.    U.S.  EPA
       Office of Research and Development
       Publications - CERI
       Cincinnati, OH 45268
       513/684-7562

92.    U.S.  EPA
       Office of Solid Waste
       (WH-562)
       Superfund Hotline
       401 M. St. SW
       Washington, DC  20460
       800/424-9346
                                        12

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93.     U.S. Mine Safety and Health Administration
       Department of Labor
       4015 Wilson Blvd. Room 600
       Arlington, VA 22203
       703/235-1452

94.     U.S. National Oceanic and Atmospheric Administration
       Hazardous Materials Response Branch
       N/OMS 34
       7600 Sand Point Way, N.E.
       Seattle, WA 98115
       206/527-6317

95.     U.S. Nuclear Regulatory Commission
       Washington, DC  20555
       301/492-7000

96.     UTLX Rail Car Mfgr.
       312/431-3111

97.     UTILITIES

98.     WASTE DISPOSAL COMPANIES

99.     WATER COMPANIES

100.   WRECKING COMPANIES
                                       13

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                                       SECTION 6

                          REFERENCES AND GLOSSARY

                                         PART 2

                               GLOSSARY AND ACRONYMS
I.      GLOSSARY
       Accident - An unexpected event generally resulting in injury, loss of property, or disruption of
       service.

       Action Level -  A quantitative limit of a chemical, biological, or radiological  agent at which
       actions are taken to prevent or reduce exposure or contact.

       Acute Exposure - A dose that is delivered to a receptor in a single event or in a short period of
       time.

       Air  Surveillance - Use of air monitoring and  air sampling during a  response to  identify
       and quantify airborne contaiminants on and off-site, and monitor changes in air contaminants that
       occur over the lifetime of the incidents

       Aquifer - A water bearing formation of permeable rock, sand, or gravel capable of yielding water
       to a  well or  spring.

       Chronic Exposure - Low doses repeatedly delivered to a receptor over a long period of time.

       Confinement - Control methods  used  to limit the physical  area  or size of a  released
       material.  Examples: dams, dikes, and absorption processes.

       Containment - Control methods used keep the material in its container. Examples: plugging and
       patching.

       Contaminant/Contamination - An unwanted  and non-beneficial substance.

       Control - Chemical or physical methods used  to prevent or  reduce the hazards associated with
       a material.  Example: Neutralizing an acid  spill.

       Decontamination - The process of  physically  removing contaminants  from  individuals and
       equipment or changing their chemical nature to innocuous substances

       Degree of Hazard - A relative measure of how much harm a substance can do.

       Direct-Reading Instruments  - A  portable device  that rapidly  measures and  displays the
       concentration of a contaminant in the environment.

       Emergency - A sudden and unexpected event calling for immediate action.
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Emergency Removal  - Action or actions undertaken, in a time-critical situation,  to prevent,
minimize, or mitigate a release that poses an immediate and/or significant threat(s) to human
health or welfare or to the enivronment.  (See also Removal Action)

Environmental  Assessment - The measurement or prediction of the concentration, transport,
dispersion, and final fate of a released hazardous substance in the environment.

Environmental Emergencies - Incidents involving the release (or potential release) of hazardous
materials into the environment which require immediate  action.

Environmental Hazard - A condition capable of posing an unreasonable risk to air, water, or soil
quality, and to plants or wildlife.

Environmental  Sample - Samples  that are considered to  contain  no contaminants or  low
concentrations of contaminants as compared to hazardous samples.

Episode - Incident.

First Responder - The first personnel to arrive  on  the scene  of a  hazardous  materials
incident.  Usually officials  from local  emergency services, firefighters, and    police.

Groundwater - Water found in the saturated portions of geologic formations beneath the surface
of land or water.

Hazard -  A circumstance or condition that can do harm.  Hazards are categorized into four
groups: biological, chemical, radiation, and physical.

Hazard Evaluation - The impact or risk the hazardous substance poses to public health and the
environment.

Hazard Classes - A  series of nine descriptive terms that have been established  by the UN
Committee of Experts to categorize the hazardous nature of chemical, physical, and biological
materials.  These categories are:

        1.      Explosives,
        2.      Non-flammable and flammable gases,
        3.      Flammable liquids,
        4.      Flammable solids,
        5.      Oxidizing materials,
        6.     Poisons, irritants, and disease causing materials,
        7.     Radioactive materials,
        8.     Corrosive materials, and
        9.     Dangerous materials.

Hazardous  - Capable of posing an  unreasonable risk to health and safety (Department of
Transportation).  Capable of doing harm.
 Hazardous  Material - A substance or material which has been determined by the Secretary of
 Transportation to be capable of posing an unreasonable risk to health, safety, and property when
 transported in commerce, and which has been so designated.  (Department of Transportation)
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Hazardous Sample - Samples that are considered to contain high concentrations of contaminants.

Hazardous Substance - 1) A material and its mixtures or solutions that is identified by the letter
"E"  in  Column (1) of the  Hazardous Materials Table,  49 CFR 172.101,  when offered for
transportation in one package, or in one transport vehicle if not packaged, and when the quantity
of the material therein equals or exceeds the reportable quantity.  2)  Any  substance designated
pursuant to Section 311(b)(2) (A) of the Federal Water Pollution Control Act, (B) any element,
compound, mixture, solution, or substance designated pursuant to Section 102 of this Act, (C)
any hazardous waste having  the characteristics identified under or listed pursuant to Section 3001
of the Solid Waste Disposal Act (but not including any waste the regulation of which under the
Solid Waste Disposal Act has been suspended by Act of Congress), (D) any toxic pollutant listed
under Section 307(a) of the Federal Water Pollution Control Act, (E) any hazardous air pollutant
listed under  Section 112 of the Clean Air Act,  and (F)  any imminently hazardous chemical
substance or mixture with respect to which the Administrator has taken action pursuant to Section
7 of the Toxic Substances Control Act.  The term does not include petroleum,  including crude
oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous
substance under subparagraphs  (A) through (F) of this paragraph,  and the term does not include
natural gas, natural  gas liquids, liquified natural gas, or synthetic gas usable for fuel (of mixtures
of natural gas and such synthetic gas).

Hazardous Waste -  Any material that is subject to the hazardous waste manifest requirements of
the Environmental Protection Agency specified in 40 CFR, Part 262 or would  be subject to these
requirements  in the absence of an interim authorization  to a State under 40 CFR Part 123,
Subpart F.

Incident - The release  or  potential  release of  a  hazardous substance  or  material into the
environment.

Incident Characterization - The process of identifying the substance(s) involved in an incident,
determining exposure pathways and projecting the effect it will have on people, property, wildlife
and plants, and the disruption of services.

Incident Evaluation - The  process  of  assessing the  impact  released or potentially released
substances pose to public health and the environment.

Information - Knowledge acquired concerning the conditions or circumstances particular  to an
incident.

Inspection - Same as investigation.

Intelligence - Information obtained from existing records or  documentation, placards, labels,
signs, special configuration  of containers, visual observations, technical records, eye witnesses,
and others.

Investigation - On-site and off-site survey(s) conducted to  provide a qualitative and quantitative
assessment of hazards associated with a site.

Limited Quantity - With the  exception of Poison  B materials, the  maximum  amount of a
hazardous material  for which there is a specific labeling and packaging exception.
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Mitigation - Actions taken to prevent or reduce the severity of threats to human health and the
environment.

Monitoring - The process of sampling and measuring certain environmental parameters on a real-
time basis for  spatial and time variations. For example, air monitoring may be conducted with
direct-reading  instruments to indicate relative changes in air contaminant concentrations at various
times.

National Contingency Plan - Policies and procedures that the Federal Government follows in
implementing  responses to hazardous substances.

On-Site - Presence within the boundaries of the worksite.

Off-Site - Presence  outside of the worksite.

Pathways of Dispersion - The environmental medium (water, groundwater, soil, and air) through
which  a chemical is transported.

Persistent Chemicals - A substance which resists biodegradation and/or chemical transformation
when released into  the environment and tends to accumulate on land, in  air,  in water, or in
organic matter.

Planned Removal (Non-Time-Critical Removal) - The removal of released hazardous substances
that pose a threat or potential threat to human health or welfare or to the environment from a site
within a non-immediate time period.  Under CERCLA:  Actions intended to minimize increases
in exposure such that time and cost commitments are limited to 12 months and/or two million
dollars. (See also Emergency Removal)

Pollutant - A  substance or mixture which after release into the environment and upon exposure
to any organism will or may reasonably be anticipated to cause adverse effects in such organisms
or their offspring.

Pollutant Transport - An array of mechanisms by which a substance may migrate outside the
immediate location of the release or discharge  of the substance.  For example, pollution of
groundwater by hazardous waste leachate migrating from a landfill.

Qualified Individual - A person who through education, experience, or professional accreditation
is competent to make judgements concerning  a particular subject matter.  A Certified  Industrial
Hygienist may be a qualified individual  for preparing a site safety plan.

Regulated Material - A substance or material  that is subject to regulations set   forth    by  the
Environmental Protection Agency, the Department of Transportation,  or  any  other  federal
agency.

Release - Any spilling, leaking, pumping, pouring, emitting, emptying,  discharging,  injecting,
escaping, leaching, dumping, or disposing of hazardous substances into the environment.

Remedial Actions - As in the National  Contingency  Plan,  responses to  releases  on  a National
Priority List that are consistent with treatment-oriented remedy that is protective of human health
and the environment and that permanently and significantly reduces toxicity, mobility, or volume
of hazardous  substances.
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Removal Actions - Any  appropriate actions(s) taken to abate, minimize,  stablize, mitigate, or
eliminate the release or threat of release that poses a threat to human health or welfare or to the
environment.  As set forth in the National Contingency Plan, these actions shall be terminated
after $2 million has been obligated or 12 months have elapsed from the date of initial response.

Reportabie Quantity - As set forth in the Clean Water Act, the minimum amount (pounds or
kilograms) of a hazardous substance that may be discharged in  a 24 hour period that requires
notification of the appropriate government agency.

Response Actions - Actions taken to recognize, evaluate, and control an incident.

Response Operations - Same  as Response Actions.

Risk - The probability that harm will occur.

Risk Assessment - The use of factual base to define the health effects of exposure of individuals
or populations to hazardous materials and situations.

Risk  Management  - The process of  weighing  policy alternatives  and selecting  the  most
appropriate regulatory action  integrating the results of risk assessment with engineering data and
with social and economic concerns to reach a decision.

Routes of Exposure - The manner in which a contaminant enters the body through inhalation,
ingestion, skin absorption, and  injection.

Safety - Freedom from man, equipment, material, and environmental interactions that result in
injury or illness.

Sampling - The collection of representative portion of the universe. Example: the collection of
a water sample from a contaminated stream.

Severe - A relative term  used to describe the degree to which hazardous material releases can
cause adverse effects to human health and the environment.

Site - Location.

Site Safety Plan - Written, site-specific safety criteria that establishes requirements for protecting
the health and safety of responders during all activities conducted at an incident.

Toxicity - The ability of a substance to produce injury once it reaches a susceptible site in or on
the body.

Work Plan - Written directives  that specifically describe all work activities that are to take place
at a work site.
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II.     ACRONYMS


       ACGIH - American Conference of Governmental Industrial Hygienists

       AIHA - American Industrial Hygiene Association

       ANSI - American National Standards Institute

       ASTM - American Society of Testing and Materials

       APR - Air-Purifying respirator

       B of M - Bureau of Mines

       BOD - Biological oxygen demand

       CAG - Carcinogen Assessment Group

       CDC - Center for Disease Control

       CERCLA - Comprehensive Environmental Response Compensation and
               Liability Act (1980)

       CFR - Code of Federal Regulations

       CGI - Combustible Gas Indicator

       CHEMTREC - Chemical Transportation Emergency Center

       CHRIS - Chemical Hazard Response Information System

       CMA - Chemical Manufacturers' Association

       CPM - Counts per minute

       CRC - CRC  Press. A publisher of scientific reference books

       CRP - Community Relations Plan

       DDT - Dichlorodiphenyltrichloroethane

       DECON - Decontamination

       DFM - Diesel fuel marine

       DHHS - Department of Health  and Human Services

       POD - Department of Defense
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DPI - Department of the Interior

POL - Department of Labor

DOT - Department of Transportation

DRI - Direct-reading Instruments

EERU - Environmental Emergency Response Unit

EPA - Environmental  Protection Agency

ERGS -  Emergency Response Cleanup Services, under EPA contract

ERT - Environmental  Response Team

eV  - Electron volt

FEMA - Federal Emergency Management Agency

FID - Flame ionization detector

FIT - Field Investigation Team under contract to EPA

FM - Factory Mutual

GC - Gas chromatograph or gas chromatography

HEPA - Common use: "HEPA Filter" High efficiency particulate air
       filter.

IDLH -  Immediately dangerous to life or health

IP - Ionization potential

IR - Infrared radiation

IUPAC  - International Union of Pure and Applied Chemists

     - Lethal concentration, 50%

     - Lethal Dose, 50%

LEL - Lower explosive limit

mg/L - Milligrams per litre

mg/m3 - Milligrams per cubic meter
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MIRAN - Trade name for series of Foxboro miniature infrared analyzers




mR/hr - Milliroentgens per hour




MSDS - Materials Safety Data Sheets




MSHA - Mine Safety and Health Administration




MUC - Maximum use concentration




MUL - Maximum use limits




NBR - Nitrile-Butadiene Rubber (syn. Buna-N)




NCP - National Contingency Plan




NEC - National Electric Code




NFPA - National Fire Protection Association




NIOSH  - National Institute for Occupational Safety and Health




NOAA - National Oceanic and Atmospheric Administration




NOS or n.o.s. - Not otherwise specified




NPL - National Priorities List




NRC - Nuclear Regulatory Commission




NRT - National Response Team




OHMTADS - Oil and Hazardous Materials Technical Assistance Data System




ORM   - Other regulated material.  Various specific classes such as ORM-A, ORM-E, etc.




OSC   - On-Scene coordinator




OSHA  - Occupational Safety and Health Administration




OVA   - Organic Vapor Analyzer




PCB   - Polychlorinated Biphenyl




PEL  - Permissible exposure limit




PF   -  Protection factor




PIP  - Photoionization detector
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ppb  - Parts per billion

ppm  - Parts per million

ppt  - Parts per trillion

PVA  - Poly Vinyl Alcohol

PVC  - Poly Vinyl Chloride

OA/OC - Quality assurance/Quality control

RCRA - Resource Conservation and Recovery Act

REL - Recommended Exposure Limits

REMFIT - Field Investigation Team for remedial actions under contract
        to EPA

RI/FS - Remedial Investigation/Feasibility Study

RRP - Regional Response Plan

RRT - Regional Response Team

SBR - Styrene-Butadiene rubber

SCBA - Self contained breathing apparatus

SOPs - Standard operating procedures

SQSGs - Standard operating safety guides

STEL - Short term exposure limit

TAT - Technical Assistance Team under contract to EPA

TCDP - Tetrachlorodibenzo - p - dioxin

TCE - Trichloroethylene

TLVs - Threshold limit values

TWA - Time weighted average

2. 4. 5-T - 2, 4, 5-Trichlorophenoxyacetic acid

UEL - Upper explosive limit
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UL - Underwriters Laboratories




UN - United Nations




USCG - United States Coast Guard




USGS  - United States Geological Survey




WEEL - Workplace Environmental Exposure Levels
                                       24     •£ US. GOVERNMENT PRINTING OFFICE. 1993— 3 1+1 -835'  83011

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    EPAX 9201-0009

    Safety and heaJth derision
     «>*king for managers
EPAX 9201-0009

Safety and health decision-
 making for managers

                        BBWCO

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