United States
Environmental Protection
Agency
Technology Transfer
EPA/625/9-85/006
Protecting Health and Safety
at Hazardous Waste Sites:
An Overview
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Technology Transfer
EPA/626/9-85/006
Protecting Health and Safety
at Hazardous Waste Sites:
An Overview
September 1985
Printed on Recycled Paper.
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This publication was prepared by Eastern
Research Group, Inc., Arlington, Massachu-
setts, for the Center for Environmental
Research Information, U.S. Environmental
Protection Agency (EPA), Cincinnati, OH
45268. It was reviewed by David Weitz-
man (EPA), Gail Kleiner, Sheldon Rabinovitz
(National Institute for Occupational Safety
and Health), and Glen Wiltshire (U.S. Coast
Guard). Their contributions are gratefully
acknowledged. This booklet is based on
the Occupational Safety and Health Guid-
ance Manual for Hazardous Waste Site Ac-
tivities (DHHS/NIOSH Publication No.
85-115) available from the National Institute
for Occupational Safety and Health, Cincin-
nati, Ohio.
This booklet has been peer and administra-
tively reviewed by the U.S. Environmental
Protection Agency (EPA) and approved for
publication. No warranty, guarantee or
representation, expressed or implied, is
made by or on behalf of the EPA as to the
absolute correctness or sufficiency of any
representation contained in this document.
The EPA assumes no responsibility in con-
nection therewith, nor can it be assumed
that all acceptable safety measures are
contained in this or associated documents,
or that other or additional measures may
not be required under particular or excep-
tional conditions or circumstances. The
mention of a brand name product or com-
pany does not constitute endorsement by
the U.S. Environmental Protection Agency.
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Contents
1. Introduction 1
2. Hazards 2
3. Planning 4
4. Training 9
5. Medical Monitoring 13
6. Site Characterization 16
7. Personal Protective Equipment
8. Site Control 28
9. Decontamination 32
10. Handling Drums and Other
Containers 35
11. Site Emergencies 39
19
III
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1. Introduction
Improper disposal of commercial, industrial
and municipal hazardous wastes over the
past several decades has produced thou-
sands of sites where ground water, surface
water, soil and/or air are contaminated with
chemicals. The environmental and potential
human health consequences of improper
disposal of hazardous wastes have been
demonstrated by episodes such as New
York's Love Canal and Kentucky's Valley of
the Drums. In response to the health and
environmental impacts of improper waste
disposal, Congress enacted the Compre-
hensive Environmental Response, Compen-
sation and Liability Act (CERCLA) of 1980,
which provided for "liability, compensa-
tion, cleanup, and emergency response for
hazardous substances released into the
environment."
Cleanup operations at inactive hazardous
'waste sites are now underway throughout
the country. Thousands of workers are
involved in this national effort. Because of
the potential hazards inherent in such
operations, an interagency committee, con-
sisting of the National Institute for Occupa-
tional Safety and Health UNIOSH] the lead
agency), the U.S. Environmental Protection
Agency (EPA), the Occupational Safety and
Health Administration (OSHA), and the U.S.
Coast Guard (USCG), has developed guide-
lines for protecting worker health and
safety at inactive hazardous waste sites.
This booklet summarizes those guidelines
and presents key issues to consider in
designing, implementing, or evaluating a
health and safety program for work at
inactive hazardous waste sites. Much of
the information is also relevant to planning
for response to emergencies involving haz-
ardous substances.
This booklet is geared for nontechnical
personnel. Individuals who are directly
responsible for designing, implementing, or
evaluating occupational safety and health
programs at inactive hazardous waste sites
should refer to the more detailed guidance
document entitled Occupational Safety and
Health Guidance Manual for Hazardous
Waste Site Activities (DHHS/NIOSH Publi-
cation No. 85-115), available from the
National Institute for Occupational Safety
and Health, Cincinnati, Ohio. In addition,
the appropriate Federal, state, and local
agencies should be contacted for assist-
ance and guidance.
Responsiveness to site conditions is a fre-
quent theme throughout this document. To
be maximally effective, a health and safety
program must be tailored to the unique
conditions at each site, not only initially,
but also throughout a project in response
to changing site conditions and new infor-
mation. Thus periodic review, reassess-
ment and redefinition of a health and
safety program must take place at a
managerial level, and site workers and their
supervisors must be continually alert for
new conditions that suggest a need for
change. Awareness and responsiveness
are, therefore, key attitudes needed to
ensure an effective health and safety
program.
The protection of health and safety at a
hazardous waste site extends far beyond
individual actions such as the modification
of work practices or the use of specialized
equipment. It must be integrated into all
aspects of site operations, and must be a
conscious priority for all involvedfrom
corporate management to the most re-
cently hired field employees. This booklet
introduces the building blocks of an effec-
tive health and safety program.
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2. Hazards
Hazardous waste sites pose numerous
health and safety concerns, any one of
which could result in serious injury or
death. Several factors distinguish the haz-
ardous waste site environment from other
occupational situations involving hazardous
substances:
A large number and variety of sub-
stances may be present.
The identity of the substances is often
unknown.
The substances have not been
properly handled and controlled.
The physical environment may be dan-
gerous.
Working in protective clothing can
cause significant stress.
The combination of these conditions
results in hazards that may pose an
immediate danger to life or health; may not
be immediately obvious or identifiable; and
may change as the onsite work location
and cleanup activities vary. Potential haz-
ards include:
Chemical exposure. Chemical sub-
stances can cause toxic effects by
entering the unprotected human body
through inhalation, skin absorption,
ingestion, or puncture wounds. Toxic
effects may be temporary and re-
versible (e.g., dizziness, nausea), or
permanent (e.g., disability, organ dam-
age, or death}. They may be immedi-
ately apparent, or take months or even
years to manifest without any initial
warning signs.
Fire and explosion. Although fires and
explosions may occur spontaneously
at a site, more often they are caused
by investigative or remedial activities,
such as moving drums, mixing incom-
patible chemicals, or introducing an
ignition source
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HAZARDS
Biological hazards. Wastes from hospi-
tals and research facilities may contain
disease-causing organisms that could
infect site personnel. In addition, poi-
sonous plants, insects, animals and
indigenous pathogens are other biolog-
ical hazards which may be present.
Safety hazards. Holes or ditches, sharp
objects, slippery surfaces, steep
grades, unstable surfaces, and precari-
ously positioned objects can create
safety hazards for waste site workers.
Use of personal protective equipment
(PPE) and heavy machinery may also
increase the risk of accidents by
impairing workers' agility, hearing, and
vision.
Electrical hazards. Overhead power
lines, downed electrical wires, buried
cables, and electrical equipment may
pose a danger of shock or electro-
cution.
Heat stress. Heat stress is a major haz-
ard, especially for workers wearing
protective clothing. Depending on the
ambient conditions and the work being
performed, heat stress can occur very
rapidlywithin as little as 15 minutes.
Symptoms include rashes, drowsiness,
and cramps. Heat stress may lead to
heat stroke and death.
Cold exposure. Cold injury (frostbite
and hypothermia) and impaired ability
to work are dangers at low tempera-
tures and when the wind-chill factor is
low.
Noise, Heavy equipment used in
cleanup operations may startle, annoy
or distract workers, may cause tem-
porary and/or permanent hearing loss,
and may interfere with communi-
cation.
A health and safety program for hazardous
waste site activities must protect against
all known and potential hazards. Of partic-
ular concern are inhalation hazards that
may pose an immediate danger to life or
health {IDLH) and any other conditions that
may cause death or serious harm (see
Table 1). Protection from these conditions
is a top priority.
Determining, through information gather-
ing, inspection and monitoring, which haz-
ards are present is one of the first steps in
hazardous waste site activities (see 6. Site
Characterization). Based on this informa-
tion, specific resources can be obtained
and procedures developed to protect
personnel.
Table 1. Visible Indicators of Potential
IDLH8 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.
'IDLH = Inhalation hazards that are immediately
dangerous to life or health.
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3. Planning
Planning is the cornerstone of prevention.
By anticipating and taking steps to mini-
mize potential hazards to health and safety,
work at hazardous waste sites can proceed
with minimum risk to workers and the pub-
lic. To accomplish this, three plans should
be developed:
A Work Plan that considers each
specific phase of investigation and
response. The Work Plan establishes
the objectives of site operations and
the logistics and resources required to
achieve them. It should include an
organizational structure that identifies
the personnel needed for the overall
operation, establishes the chain-of-
command, and specifies the responsi-
bilities of each employee. Preparation
of the Work Plan may require input
from all levels of onsite and offsite
management.
A Site Safety Plan that identifies the
safety and health hazards of each
phase of operation and defines the
requirements and procedures for pro-
tecting workers and the public (see
Insert). This plan should be developed
by senior-level offsite and onsite
management and reviewed by occupa-
tional and industrial health and safety
experts.
A Contingency Plan for handling emer-
gencies that may occur on site. The
Contingency Plan should set forth
training requirements, personnel roles,
communication systems, site security
and control, decontamination proce-
dures, step-by-step emergency
SITE SAFETY PLAN
The Site Safety Plan establishes policies and procedures to protect workers and the
public from the potential hazards posed by work at a hazardous waste site. The Site
Safety Plan should be developed before site activities proceed and should be modified
as needed for every stage of site activity. At a minimum, the plan should:
Name key personnel and alternates responsible for site safety.
Describe the risks associated with each operation conducted.
Confirm that personnel are adequately trained to perform their job responsibilities ,
and to handle the specific hazardous situations they may encounter.
Describe the protective clothing and equipment to be worn by personnel during vari-
ous site operations.
Describe any site-specific medical surveillance requirements.
Describe the program for periodic air monitoring, personnel monitoring, and environ-
mental sampling, if needed.
Describe the actions to be taken to mitigate existing hazards (e.g., containment of
contaminated materials) to make the work environment less hazardous.
Define site control measures and include a site map,
Establish decontamination procedures for personnel and equipment.
Set forth the site's standard'operating procedures (SOPs). SOPs are those activities
that can be standardized (such as decontamination and respirator fit testing), and
where a checklist can be used.
* Set forth a Contingency Plan for safe and effective response to emergencies.
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PLANNING
response procedures, evacuation
routes, and documentation and report-
ing responsibilities in the event of an
emergency. It should also specify the
procedures for contacting and coor-
dinating with the existing local, state
and Federal response community dur-
ing an emergency. The Contingency
Plan is generally a separate section
within the Site Safety Plan.
ONGOING PROCESS
Planning must be viewed as an ongoing
process, since site conditions constantly
change. All three plans must be continually
adapted to new site conditions and new
information. Safety meetings should be
held prior to initiating any site activity and
before and after each work day to review
important aspects of the Work Plan and
Site Safety Plan, to describe any changes,
and to receive worker feedback. In addi-
tion, the Site Safety Officer (see Insert)
should conduct frequent inspections to
determine whether the plans are adequate
and being followed.
PERSONNEL ORGANIZATION
Figure 1 shows a generalized approach to
personnel organization for hazardous waste
site investigation and response at a large
site. For smaller efforts, single individuals
may assume several roles. Regardless of
the size of the effort, all response teams
should include a Site Safety Officer respon-
sible for implementing health and safety
requirements. The Site Safety Officer
should have ready access to other occupa-
SITE SAFETY OFFICER
The Site Safety Officer is a key individual in the protection of health and safety at
hazardous waste sites. He or she advises the Project Team Leader on all aspects of
health and safety on site and recommends stopping work if any operation threatens
worker or public health or safety. The Site Safety Officer's responsibilities include:
Selecting protective clothing and equipment.
Periodically inspecting protective clothing and equipment.
Ensuring that protective clothing and equipment are properly stored and maintained.
Controlling entry to and exit from the contaminated areas or zones of a site.
Confirming each team member's suitability for work based on a physician's recom-
mendation.
Monitoring the work parties for signs of stress, such as cold exposure, heat stress,
and fatigue.
Monitoring onsite hazards and conditions.
* Participating in the development of and implementing the Site Safety Plan.
Conducting periodic inspections to determine if the Site Safety Plan is being
followed.
Knowing (and ensuring that all site personnel also know) emergency procedures,
evacuation routes, and the telephone numbers of the ambulance, local hospital, poi-
son control center, fire department, and police department.
Notifying, when necessary, local public emergency officials.
Coordinating emergency medical care.
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Government Agency
Oversight
OFFSITE
Multidisciplinary
Advisors
Lead Organization
Senior-Level
Management
Medical Support
Project
Team Leader
ONSITE
Field Team
Leader
Work
Party
Command
Post
Supervisor
Decontamination
Station
Officers
Rescue Team
Site Safety
Officer
Scientific Financial
Advisor Officer
Security
Officer
Record-
keeper
Logistics
Officer
Photographer Public Information
Officer
OFFSITE
AND ONSITE
AS NEEDED
Bomb Squad Experts Firefighters
Communication
Personnel
Environmental
Scientists
Evacuation
Personnel
Hazardous
Chemical
Experts
* Health Physicists
Industrial
Hygienists
Meteorologists
Public Safety
Officer
Toxicologists
Figure 1. Generalized Approach to Personnel Organization for Site Investigation and
Response
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PLANNING
tiona! health and safety professionals with
specialized expertise as needed.
PROTECTING THE PUBLIC
The effective management of response
actions at hazardous waste sites requires a
commitment to the health and safety of
the general public as well as to the onsite
personnel. Onsite containment and preven-
tion of contaminant release into the sur-
rounding community should be addressed
in the planning stages of a project. Not
only must the public be protected, they
must also be made aware of the health and
safety program and have confidence in it.
To accomplish these goals, the Project
Team Leader {see Insert), or Public Informa-
tion Officer under the supervision of the
Project Team Leader, should establish com-
munity liaison well before any response
act ton is begun, and should maintain con-
tinual contact with community leaders.
MANAGEMENT OBJECTIVES
One of the most critical elements in worker
safety is the attitude of all levels of project
management. A strong and visible commit-
ment to worker safety must be present
from the beginning of a project. This initial
attitude sets the tone for the entire opera-
tion. The Site Safety Officer and the
Project Team Leader must have the clear
support of senior-level management for
establishing, implementing, and enforcing
safety programs from the outset of the
project. The importance of management's
attitude toward safety throughout the proj-
ect cannot be overemphasized; site person-
nel are more likely to cooperate with safety
programs if they sense a genuine concern
on the part of management.
Several other organizational factors are
indicators of successful worker safety pro-
grams. These factors include:
PROJECT TEAM LEADER
The Project Team Leader is in charge of all onsite activities and has the authority to
direct investigation and response operations. The Project Team Leader's responsibilities
include:
Managing the development of the Work Plan and Site Safety Plan.
Obtaining permission for site access and coordinating activities with appropriate
officials.
Supervising workers in the field and briefing them on their specific assignments.
Coordinating with the Site Safety Officer to ensure that health and safety require-
ments are met.
Ensuring that the Work Plan is completed and on schedule.
Preparing the final report and support files on the response activities.
Serving as the liaison with public officials.
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PLANNING
Close contact and interaction among
workers, supervisors, and management
enabling open communications on
safety as well as other job-related
matters.
A high level of housekeeping, orderly
workplace conditions, and effective
environmental quality control.
Wei I-developed selection, job place-
ment, and advancement procedures
plus other employee support services.
Training practices emphasizing early
indoctrination and followup instruction
in job safety procedures.
* Added features or variations in conven-
tional safety practices that enhance
the effectiveness of those practices.
An effective disciplinary plan to
encourage employees to adhere to
safety practices.
Overall, the most effective industrial safety
programs are successful in dealing with
"people" variables. Thus, translation of a
plan from written procedures to action is as
critical as the initial development of the plan.
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4. Training
Like planning, training provides the founda-
tion upon which all other protective meas-
ures depend. Because of the potential
hazards at hazardous waste sites, anyone
entering a site, including visitors, must
receive sufficient training to understand
the hazards and utilize any necessary pro-
tective measures.
CLEANUP PERSONNEL
Personnel actively involved in site cleanup
must be thoroughly familiar with programs
and procedures contained in the Site
Safety Plan and must be trained to work in
contaminated areas. The level of training
should be consistent with the worker's job
function and responsibilities. The training
program should involve both classroom
instruction in a wide range of health and
safety topics and "hands-on" practice in
equipment handling and operational proce-
dures. In the classroom, a variety of teach-
ing aids (i.e., films, slides, etc.) should be
used. Hands-on instruction should consist
of field drills that simulate site activities
and conditions. The training program
should also include onsite experience under
the direct supervision of trained, expe-
rienced personnel. Table 2 describes the
types of training that site personnel and
visitors should receive.
SITE WORKERS
General site workers, such as equipment
operators, general laborers, technicians,
and other supervised personnel, should
attend training sessions that apply to their
individual jobs and responsibilities, as well
as training sessions that provide an over-
view of the site hazards and the means of
controlling those hazards. Depending on
their individual jobs, worker training should
include classroom instruction in the follow-
ing areas:
Site Safety Plan.
Safe work practices.
The training program should involve field
drills that simulate emergency situations.
Here workers wearing Level A personal pro-
tective equipment (see Table 4) repair a
leaking pipe as part of a training exercise.
Nature of the anticipated hazards.
Handling emergencies and self-rescue.
Rules and regulations for vehicle use.
Safe use of field equipment.
Handling, storage, and transportation
of hazardous materials.
Use and care of personal protective
clothing and equipment.
Safe sampling techniques.
Employee rights and responsibilities.
In addition to classroom instruction,
general site workers should engage in
actual field activities under the direct
supervision of a trained, experienced
supervisor.
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TRAINING
Table 2. Recommended Training by Job Category*
TRAINING TOPIC
EMPHASIS OF TRAINING
ONSITE
GENERAL MANAGE-
SITE MENT AND
WORKER SUPERVISORS
HEALTH
AND
SAFETY
STAFF VISITORS
Biology, Chemistry, and
Physics of Hazardous
Materials
Toxicology
Industrial Hygiene
Rights and Responsibilities
of Workers Under OSHA
Monitoring Equipment
Hazard Evaluation
Site Safety Plan
Standard Operating
Procedures (SOPs)
Chemical and physical
properties; chemical
reactions; chemical
compatibilities.
Dosage, routes of exposure,
toxic effects, immediately
dangerous to life or health
(IDLH) values, permissible
exposure limits (PELs),
recommended exposure
limits (RELs), threshold
limit values (TLVs).
Selection and monitoring of
personal protective
clothing and equipment.
Calculation of doses and
exposure levels; evaluation
of hazards; selection of
worker health and safety
protective measures.
Applicable provisions of
Title 29 of the Code of
Federal Regulations (the
OSH Act).
Functions, capabilities,
selection, use, limitations,
and maintenance,
Techniques of sampling and
assessment.
Evaluation of field and lab
results.
Risk assessment.
Safe practices, safety brief-
ings and meetings, stan-
dard operating procedures,
site safety map.
Hands-on practice.
Development and
compliance.
R
R
R = Recommended. 0 - Optional.
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TRAINING
Table 2 (Cont.)
TRAINING TOPIC
EMPHASIS OF TRAINING
ONSITE HEALTH
GENERAL MANAGE- AND
SITE MENT AND SAFETY
WORKER SUPERVISORS STAFF VISITORS
Engineering Controls
Personal Protective
Clothing and Equipment
(PPE)
Medical Program
Decontamination
Legal and Regulatory
Aspects
Emergencies
The use of barriers, R
isolation, and distance to
minimize hazards.
Assignment, sizing, fit- R
testing, maintenance, use,
limitations, and hands-on
training.
Selection of PPE.
Ergonomics.
Medical monitoring, first R
aid, stress recognition.
Advanced first aid, cardie- 0
pulmonary resuscitation
(CPR); emergency drills.
Design, planning, and
implementation.
Hands-on training using R
simulated field conditions.
Design and maintenance. R
Applicable safety and 0
health regulations (OSHA,
EPA, etc.).
Emergency help and self- R
rescue; emergency drills.
Response to emergencies;
follow-up investigation and
documentation.
R
R
Workers who may be exposed to unique
hazards or who may occasionally supervise
others should receive additional training in
areas such as safe use of specialized
monitoring and protective equipment,
decontamination, etc.
ONSITE MANAGEMENT AND
SUPERVISORS
Onsite management and supervisors, such
as Project Team Leaders, who are respon-
sible for directing others should receive the
same training as the general site workers
for whom they are responsible, as well as
additional training to enhance their ability
to provide guidance and make informed
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TRAINING
decisions. This additional training should
include management of hazardous waste
site cleanup operations, management of
the site work zones (see 8. Site Control),
and how to communicate with the press
and local community.
HEALTH AND SAFETY STAFF
Health and safety staff with specific
responsibilities for health and safety guid-
ance on site, such as Site Safety Officers,
should be familiar with the training
provided to general site workers and their
supervisors, and should receive advanced
training in health and safety issues, poli-
cies, and techniques.
VISITORS
Visitors to the site (including elected and
appointed officials, media representatives,
senior-level management, and others) must
also receive a briefing on the Site Safety
Plan and applicable emergency procedures.
These visitors should not be permitted in
the contaminated area of the site unless
they have been trained, fit-tested, and
medically approved for respirator use. All
other visitors should observe site condi-
tions from the site's clean areas using
binoculars.
TRAINING PROGRAM
All training information should be
presented in clear, concise language. Par-
ticularly important information, such as the
site's standard operating procedures,
should be provided to each employee in
writing. All employees should complete
refresher training at least annually to
reemphaslze the initial training, to maintain
proficiency in the safe use of equipment,
and to update employees on any new poli-
cies or procedures. A record of training
should be maintained in each employee's
personnel file to confirm that every person
assigned to a task has had adequate train-
ing for that task, and that every employee's
training is up to date.
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5. Medical Monitoring
Workers handling hazardous wastes can
experience high levels of stress. Their daily
tasks may expose them to toxic chemicals,
biological hazards, radiation, and safety
hazards; they may be required to perform
strenuous tasks under physically stressful
conditions; and they may have to face life-
threatening situations and emergencies. A
medical program is essential to assess and
monitor workers' health and fitness, to
determine the adequacy of worker protec-
tion, to provide emergency and other treat-
ment as needed, and to keep accurate
records for future reference. In addition,
OSHA recommends a medical evaluation
for employees required to wear a respirator
(29 CFR Part 1910.134[b][10l), and certain
OSHA standards include specific medical
requirements {29 CFR Part 1910.95 and
1910.1001 through 1910.10451 for worker
protection. Information from a site medical
program may also be used to conduct fu-
ture epidemiological studies; to adjudicate
claims; to provide evidence in litigation;
and to report workers' medical conditions
to Federal, state, and local agencies, as
required by law.
PROGRAM MANAGEMENT
A medical program should be developed for
each site based on the specific location,
needs, and potential exposures of
employees at the site. The program should
be designed by an experienced occupa-
tional health physician or other qualified
occupational health consultant in conjunc-
tion with the Site Safety Officer. The direc-
tor of a site medical program should be the
responsibility of a physician who is board-
certified in occupational medicine or a
medical doctor who has had extensive
experience managing occupational health
services. Where necessary, the site medical
program may be managed, and relevant
examinations performed, by a local physi-
cian with assistance from an occupational
medicine consultant. These functions may
also be performed by a qualified Registered
Nurse, preferably an Occupational Health
Nurse, under the direction of a suitably
qualified physician who has responsibility
for the program, (Certified, state-licensed
[where required] Physician's Assistants
may also perform these examinations if a
physician is available on the premises.)
CONTENT
A hazardous waste site medical program
should include the following components:
Surveillance, consisting of:
Pre-employment screening to deter-
mine an individual's fitness for duty.
Screening should include an
occupational and medical history,
physical examination, and tests to
determine a person's ability to work
while wearing protective equip-
ment. Pre-employment screening
can also be used to provide baseline
data for comparison with future
medical data.
Periodic medical examinations (and
followup examinations when appro-
priate). Periodic examinations may
resemble the pre-employment
examination with modifications
based on current conditions, such
as changes in site hazards,
exposures, or any symptoms
exhibited by a worker. The fre-
quency and content of examinations
will vary, depending on the nature
of the work and the exposures.
Generally, annual medical exam-
inations are recommended. More
frequent surveillance may be neces-
sary depending on the extent of
potential or actual exposure, the
chemicals involved, the duration of
the work assignment, and the indi-
vidual worker.
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MEDICAL MONITORING
A termination examination. All
employees should have a medical
examination at the end of their
employment. This may be limited to
an interval medical history of the
period since the last full examina-
tion if (1) the last full examination
was within the last 6 months,
(2) no exposure occurred in that
time, and (3) no symptoms of
exposure occurred in that time.
Otherwise, a full physical examina-
tion and appropriate laboratory
diagnostic tests (if necessary)
should be conducted.
Treatment, both emergency and non-
emergency as needed.
Recordkeeping. Proper recordkeeping
is essential at hazardous waste sites
because of the nature of the work and
risks: employees may work at a large
number of geographically separate
sites during their careers, and adverse
effects of long-term exposure may not
become apparent for many years.
Records enable subsequent medical
care providers to be informed about
workers' previous and current
exposures.
Program review and evaluation to
ensure the medical program's effec-
tiveness and to update medical tests
and treatments. Review should be per-
formed by the Site Safety Officer,
medical consultant, and/or manage-
ment representative at least annually.
Table 3 outlines some key components of a
recommended medical program for hazard-
ous waste sites.
EFFECTIVENESS
The effectiveness of a medical program
depends on active worker involvement. In
addition, management should have a firm
commitment to worker health and safety,
and is encouraged to express this commit-
ment not only by providing medical sur-
veillance and treatment, but also through
management directives and informal en-
couragement of employees to maintain
good health through exercise, proper diet,
and avoidance of tobacco, alcohol abuse
and drug abuse. In particular, management
should:
Urge prospective employees to provide
a complete and detailed occupational
and medical history.
Assure employees of confidentiality.
Require workers to report any sus-
pected exposures, regardless of
degree.
Require workers to bring any unusual
conditions to the physician's attention.
Employee training should emphasize
that vague disturbances or apparently
minor complaints (such as skin irrita-
tion or headaches) may be important.
Except for the pre-employment examina-
tion, which helps to screen out those
individuals who may be at greater risk of
injury or illness, medical surveillance does
not reduce the risk of initial illness or injury.
Rather it helps detect signs and symptoms
of disease so that the appropriate treat-
ment or action can be taken without delay.
However, signs or symptoms of chemical
exposure may be subtle and therefore diffi-
cult to detect or treat. Thus, at hazardous
waste sites it is particularly important to
remember the critical role of prevention-
through the diligent application of a com-
prehensive health and safety programin
maintaining employee health.
14
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MEDICAL MONITORING
Table 3. Some Recommendations for a Site Medical Program
COMPONENT
RECOMMENDATIONS
PRE-EMPLOYMENT
SCREENING
PERIODIC MEDICAL
EXAMINATIONS
EMERGENCY TREATMENT
Medical history.
Occupational history.
Physical examination.
Determination of ability to work while wearing protective equipment.
* Baseline monitoring for specific exposures.8
At least yearly medical and occupational history and physical
exemination; testing based on (1) examination results and (2}
exposures.
More frequent testing based on exposure to specific hazards.0
Provide emergency first aid and decontamination on site.
Develop liaison with local hospital and medical specialists.
Arrange for transport of victims.
Arrange for transfer of medical records; give details of incident and
medical history to next care provider.
Develop mechanism for evaluation of possible site-related illness and
non-emergency health care.
An interval medical history of the period since the last full examination.
A full examination if the worker has experienced any exposures or
symptoms since the lest full examination, or if the last full examination
was given more than 6 months prior to termination.
Maintain and provide access to medical records in accordance with
OSHA regulations.
Report and record occupational injuries and illnesses.
Review Site Safety Plan regularly to determine if additional testing is
needed.
Review program periodically. Focus on current site hazards, exposures,
and industrial hygiene standards.
Some standard occupational medical tests may not be totally appropriate for hazardous waste sites. Most testing
recommendations have not been critically evaluated for efficacy.
NON-EMERGENCY
TREATMENT
TERMINATION
EXAMINATION
RECORDKEEPING
AND REVIEW
15
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6. Site Characterization
Site characterization is the process of data
gathering and assessment. It provides the
information needed to identify site hazards
and select worker protection methods.
Accurate, detailed, and comprehensive
information concerning site conditions
enables the Site Safety Officer to tailor
protective measures to the site's actual
hazards. The person with primary responsi-
bility for site characterization and assess-
ment is the Project Team Leader. In
addition, outside experts, such as
chemists, health physicists, industrial
hygienists and toxicologists, may be
needed to accurately and fully interpret all
the available information on site conditions.
Site characterization generally proceeds in
three phases (Figure 2). The information
obtained at each phase is used to assess
hazards and to develop or modify a Site
Safety Plan for the next phase of charac-
terization.
OFFSITE CHARACTERIZATION
Before initial site entry, information from
offsite interviews, records research, visual
observation, monitoring, and sampling at
the perimeter should be obtained. This
information is then used to evaluate the
potential hazards, particularly inhalation
hazards that may be immediately danger-
ous to life or health (IDLH) and other dan-
gerous conditions, and to develop a Site
Safety Plan for initial entry which specifies
protective equipment and other safety
controls.
ONSITE SURVEY
The purpose of this next phase of charac-
terization is to verify and supplement infor-
mation from the offsite characterization.
After carefully evaluating probable condi-
tions based on offsite data, priorities
should be established for hazard assess-
ment during the onsite survey. The compo-
sition of the entry team depends on the
site characteristics, but should always con-
As part of site characterization, workers
suited in Level A protective ensembles (see
Table 4) work in pairs when investigating
confined spaces.
Sample jars are labelled prior to sampling
as part of site documentation procedures.
sist of at least four people: two workers
who will enter the site and two outside
support people. Upon entering the site,
workers should first monitor for ionizing
radiation, and IDLH and other dangerous
conditions (see Table 1). If these hazards
do not exist, air monitoring and visual
inspection of the site (including the condi-
tion of waste containers, the physical con-
dition of materials, the potential pathways
of dispersion, physical hazards, etc.) may
proceed. Information from the onsite sur-
vey is used to assess the safety of the site
for cleanup activities and to modify the
Site Safety Plan for the next phase of
16
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Conduct Offsite Survey
Gather information
Assess hazards
Develop Site Safety Plan
NO
Are sufficient data available to determine
adequate protection for site survey personnel?
Conduct Onsite Survey
Gather information
Assess hazards
Modify Site Safety Plan
Are sufficient data available to determine
adequate protection for cleanup personnel?
YES
Monitor Conditions
During Cleanup
Develop monitoring plan
Gather data'
Periodically reassess hazards and
modify Site Safety Plan as
conditions change
Figure 2. Major Phases of Site Characterization.
17
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SITE CHARACTERIZATION
activity. Any hazards present should be
removed, where possible, or controlled
before cleanup.
MONITORING
During cleanup, monitoring (e.g., of atmos-
pheric chemical hazards) should be per-
formed to provide ongoing information
about site conditions. Monitoring also ,
includes evaluation of any changes in site
conditions or work activities that could
affect worker safety.
ONGOING PROCESS
It is important to recognize that site
characterization is an ongoing process. In
addition to the formal information gather-
ing that takes place during the three
phases of site characterization, personnel
should be constantly alert for new informa-
tion about site conditions.
DOCUMENTATION
Since site characterization provides the
data base upon which subsequent actions
and decisions are based, good documenta-
tion is essential. All information should be
carefully recorded using pre-established
means such as logbooks, graphs, photo-
graphs, sample labels, and chain-of-
custody forms; and all documents should
be controlled to ensure that they are
accounted for when the project is
completed.
18
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7. Personal Protective
Equipment
One of the first decisions to be made
based on the information obtained during
site characterization is the level of personal
protection necessary for personnel who
will be working on site. The purpose of per-
sonal protective clothing and equipment
(PPE) is to shield or isolate individuals from
the chemical, physical, and biological haz-
ards that may be encountered at a hazard-
ous waste site. Use of PPE is required by
OSHA regulations in 29 CFR Part 1910 and
by EPA regulations in 40 CFR Part 300.
SELECTION AND USE
Careful selection and use of PPE should
protect the respiratory system, skin, eyes,
hands, face, feet, head, body, and hearing.
However, no single piece of protective
equipment, nor any combination of equip-
ment and clothing is capable of protecting
against all hazards. Thus, PPE must be
used in conjunction with other protective
methods.
The use of PPE can itself create significant
worker hazards, such as heat stress, phys-
iological stress, and impaired vision, mobil-
ity, and communication. Equipment and
clothing should be selected to provide an
adequate level of protection for a specific
situation; overprotection can be hazardous
and should be avoided.
A program for the selection and use of PPE
should be established and documented as
part of the Work Plan. Copies should be
made available to all employees and a refer-
ence copy should be available at each work
site. Technical data on equipment, main-
tenance manuals, relevant regulations, and
other essential information should also be
made available.
RESPIRATORY EQUIPMENT
Respiratory protection is extremely impor-
tant since inhalation of toxic substances is
a major route of exposure. Respiratory pro-
tective devices consist of a facepiece con-
nected to an air source or an air-purifying
device.
Respirators with an air source are called
"atmosphere-supplying" respirators. When
atmosphere-supplying respirators are used,
only those operated in the positive-
pressure mode (i.e., a positive pressure is
maintained in the facepiece during both
inhalation and exhalation) are recom-
mended for work on hazardous waste sites.
Atmosphere-supplyirtg respirators consist
of two types (see Figure 3):
Self-contained breathing apparatus
(SCBAs) supply air from a source car-
ried by the user. They offer protection
against most types and levels of air-
borne contaminants. Certain types of
SCBA can provide the highest level of
respiratory protection available.
Supplied-air respirators (SARs) supply
air from a source located some dis-
tance away and connected to the user
by an airline. SARs can provide a high
level of protection, however, the airline
is vulnerable to damage and contami-
nation.
Air-purifying respirators, on the other hand,
do not have a separate air source. Instead,
they utilize ambient air which is "purified"
through a filter before inhalation (Figure 4).
At hazardous waste sites, they can be used
only when certain conditions have been
met; in particular, the airborne con-
taminants must be identified; their concen-
trations in air must be known; and the
ambient atmosphere must contain suffi-
cient oxygen.
All types of respirators have advantages
and disadvantages. The decision about
which respirator type offers adequate pro-
tection depends on site-specific conditions
and must be made with the advice of quali-
fied personnel.
19
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Emergency escape SCBA, hood type
Self-contained breathing apparatus
(SCBA), full facepiece
Supplied-air respirator, full
facepiece
Figure 3. Types of Atmosphere-Supplying Respirators.
20
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Full-facepiece, dual cartridge
Half-mask, facepiece-
mounted cartridge.
Full-facepiece, chin-mounted
canister
Powered air-purifying respirator, half-mask
Full-facepiece, harness-mounted
canister
Figure 4. Types of Air-Purifying Respirators.
21
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PERSONAL PROTECTIVE EQUIPMENT
PROTECTIVE CLOTHING
Protective clothing provides varying
degrees of partial and/or total body protec-
tion from chemical exposure, fire, minor
blasts or explosions. Such clothing ranges
from gloves, aprons, leggings, and sleeve
protectors to fully-encapsulating suits
(Figure 5). In addition, various accessories
may be used with a PPE ensemble. These
include flashlights, two-way radios, and
safety belts.
Each type of protective clothing has a
specific purpose, as welt as limitations. For
example, some chemical-protective cloth-
ing may protect against some chemicals
but not others. Likewise, clothing that pro-
tects against fire or heat generally does not
protect against chemical exposure.
Selection of protective clothing is a com-
plex task and should be performed by per-
sonnel with training and experience.
Clothing is selected by comparing its per-
formance characteristics to the require-
ments and limitations of the site and of the
task, and involves considerations such as:
The resistance of clothing material to
permeation and degradation by chemi-
cals known or suspected to be on site.
The resistance of clothing to pene-
tration by chemicals through such
channels as design or construction
imperfections, porous zippers, stitched
seams, button holes, and pinholes.
The ability of the clothing material to
withstand physical stress and
extremes of heat and cold.
Whether the clothing is flexible enough
to allow workers to carry out tasks.
The ease of decontaminating the
clothing; the compatibility of the cloth-
ing with decontamination solutions
and other equipment.
ENSEMBLES
Individual components of clothing and
respiratory equipment must be assembled
into an ensemble to provide the appropriate
level of protection. EPA typically uses four
ensembles that provide different levels of
protection: A, B, C, and D (Table 4). The
EPA ensembles can be used as general
guidelines for ensemble creation; however,
at each site, ensembles must be tailored to
meet site- and task-specific conditions.
TRAINING
Personal protective equipment is only
effective when used properly. All workers
at a hazardous waste site must be trained
at least annually in PPE operation and use,
including OSHA requirements, inspection,
donning, checking, fitting, doffing, and
maintenance; and emergency procedures
and self-rescue in the event of equipment
failure. Since the discomfort and incon-
venience of PPE may create worker resis-
tance towards its conscientious use,
training should emphasize the need for PPE
and motivate workers to wear and use it
properly.
HEAT STRESS
Wearing impermeable or semipermeable
protective clothing and equipment adds
weight and bulk, severely reduces the
body's access to normal heat exchange
mechanisms (evaporation, convection, and
radiation), and increases energy expendi-
ture. This puts a worker at considerable
risk of developing heat stressa condition
that results when the body is unable to
release excess heat. Symptoms range from
transient heat fatigue and lowered work
tolerance to illness and death (Table 5).
Individuals vary in their susceptibility to
heat stress. Factors that may predispose
someone to heat stress include poor physi-
cal fitness, lack of acclimatization, age,
22
-------
Apron, gloves, hardhat, faceshield,
boot covers
Fully-encapsulating suit
Figure 5. Examples of Protective Clothing.
23
-------
-------
PERSONAL PROTECTIVE EQUIPMENT
Table 4. Sample Protective Ensembles3
LEVEL OF
PROTECTION
EQUIPMENT
PROTECTIi
PROVIDE
RECOMMENDED:
Pressure-demand, fuil-
facepiece SCBA or
pressure-demand
supplied-air respirator
with escape SCBA.
Fully-encapsulating,
chemical-resistant
suit.
Inner chemical-
resistant gloves.
Chemical-resistant
safety boots/shoes.
Two-way radio
communications.
OPTIONAL:
* Cooling unit.
* Coveralls.
Long cotton
underwear.
Hard hat.
Disposable gloves
and boot covers.
The highes
available le
of respiratc
skin, and e
protection.
-------
-------
Table 4 (Cont.)
LEVEL OF
PROTECTION EQUIPMENT
B RECOMMENDED:
Pressure-demand, full-
facepiece SCBA or
pressure-demand
supplied-air respirator
with escape SCBA.
Chemical-resistant
clothing (overalls and
long-sleeved jacket;
hooded, one- or two-
piece chemical
splash suit; dispos-
able chemical-resist-
ant one-piece suit).
Inner and outer
chemical-resistant
gloves.
« Chemical-resistant
safety boots/shoes.
Hard hat.
Two-way radio
communications.
OPTIONAL:
Coveralls.
Disposable boot
covers.
Face shield.
Long cotton
underwear.
PROTECTION
PROVIDED
The same
level of respir-
atory protec-
tion but less
skin protec-
tion than
Level A.
It is the mini-
mum level
recommended
for initial site
entries until
the hazards
have been
further
identified.
S
* '
i
<
!
1
1
1
1
1
1
I
/
t
1
0
F
c
fi
g
b
o
. t(
n
a
Si
t*
o
h
c.
a!
tt
"Based on EPA protective ensembles.
-------
-------
PERSONAL PROTECTIVE EQUIPMENT
Table 4 (Cont.)
LEVEL OF
PROTECTION EQUIPMENT
C RECOMMENDED:
Full-facepiece,
air-purifying,
canister-equipped
respirator.
Chemical-resistant
clothing {overalls and
long-sleeved jacket;
hooded, one- or two-
piece chemical
splash suit; dispos-
able chemical-resist-
ant one-piece suit).
Inner and outer
chemical-resistant
gloves.
Chemical-resistant
safety boots/shoes.
Hard hat.
Two-way radio
communications.
OPTIONAL:
Coveralls.
* Disposable boot
covers.
* Face shield.
* Escape mask.
Long cotton
underwear.
RECOMMENDED:
Coveralls.
Safety boots/shoes.
* Safety glasses or
chemical splash
goggles.
Hard hat.
OPTIONAL:
-Gloves.
Escape mask.
Face shield.
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PERSONAL PROTECTIVE EQUIPMENT
Table 5. Signs and Symptoms of Heat
Stress
* Heat rash may result from continuous
exposure to heat or humid air.
* Heat cramps are caused by heavy sweating
with inadequate electrolyte replacement.
Signs and symptoms include:
muscle spasms
pain in the hands, feet, and abdomen
Heat exhaustion occurs from increased stress
on various body organs including inadequate
blood circulation due to cardiovascular insuffi-
ciency or dehydration. Signs and symptoms
include:
pale, cool, moist skin
heavy sweating
dizziness
nausea
fainting
Heat stroke is the most serious form of heat
stress. Temperature regulation fails and the
body temperature rises to critical levels. Imme-
diate action must be taken to cool the body
before serious injury and death occur. Compe-
tent medical help must be obtained. Signs and
symptoms are:
red, hot, usually dry skin
lack of or reduced perspiration
nausea
dizziness and confusion
strong, rapid pulse
coma
dehydration, obesity, alcohol and drug use,
infection, sunburn, chronic disease, and
diarrhea. Because heat stress is one of the
most common, and potentially serious, ill-
nesses at hazardous waste sites, regular
monitoring and preventive precautions are
vital. Some of these precautions include
adjusting work schedules, providing shelter
or shaded areas, and maintaining workers'
body fluids by urging them to drink liquids.
27
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8. Site Control
To create and maintain a safe working
environment, activities at a hazardous
waste site must be controlled. A site con-
trol program should be instituted prior to
site characterization and continue through-
out site activities. Site control serves
several purposes: it minimizes the potential
for worker contamination or injury, protects
the public from the site's hazards, facili-
tates work activities, and prevents vandal-
ism. Site control is especially important in
emergency situations. Site control proce-
dures may include:
Compiling a site map showing topo-
graphic features, prevailing wind direc-
tion, drainage, and the locations of
buildings, containers, impoundments,
pits, ponds, and tanks. The map should
be updated throughout the course of
site operations to reflect changes in
site conditions and activities. The map
may be used to plan site activities;
assign personnel; identify access
routes, evacuation routes, and problem
areas; and identify areas of the site
that require use of personal protective
equipment.
Preparing the site for cleanup activi-
ties. Preparation can be as hazardous
as cleanup. For this reason, extreme
care for worker safety must be taken.
Table 6 summarizes the steps that may
be taken to prepare a site.
Establishing work zones. To reduce the
accidental spread of hazardous sub-
stances by workers from the contami-
nated area of the site to the clean area,
hazardous waste sites should be
divided into as many different zones as
necessary to meet operational and
safety objectives. Three frequently
used zones are (see Figure 6):
The Exclusion Zone, i,e., the con-
taminated area of a site.
28
Table 6. Site Preparation
Construct roadways to provide ease of access
and a sound roadbed for heavy equipment and
vehicles.
Arrange traffic flow patterns to ensure safe
and efficient operations.
Eliminate physical hazards from the work area
as much as possible, including:
ignition sources in flammable hazard areas.
exposed or ungrounded electrical wiring,
and low overhead wiring that may entangle
equipment.
sharp or protruding edges, such as glass,
nails, and torn metal, which can puncture
protective clothing and equipment and in-
flict puncture wounds.
debris, holes, loose steps or flooring, pro-
truding objects, slippery surfaces, or unse-
cured railings, which can cause falls, slips,
and trips.
- unsecured objects, such as bricks and gas
cylinders, near the edges of elevated sur-
faces, such as catwalks, roof tops, and
scaffolding, which may dislodge and fall on
workers.
debris and weeds that obstruct visibility.
* Install skid-resistant strips and other anti-skid
devices on slippery surfaces.
Construct operation pads for mobile facilities
and temporary structures.
Construct loading docks, processing and
staging areas, and decontamination pads.
« Provide adequate illumination for work
activities. Equip temporary lights with guards
to prevent accidental contact.
Install all wiring and electrical equipment in
accordance with the National Electric Code. ,
The Contamination Reduction Zone
(CRZ) where decontamination takes
place.
The Support Zone, i.e., the uncon-
taminated area within which haz-
ardous conditions should not exist.
* Defining separate zones and tracking
entry and exit from these zones helps
ensure that personnel are protected
against hazards, that work activities
-------
Hotline forming the
boundary between
the CRZ and the
Exclusion Zone.
Estimated boundary
of area with highest
contamination.
Contamination
Control Line
Support Zone
Command Post
(Upwind of Exclusion Zone)
Access Control Points which control the flow of personnel and
equipment into and out of the Exclusion Zone.
Decontamination Reduction Corridor where decontamination takes place.
Contamination Reduction Zone (CRZ).
Exclusion Zone. Buffer zone between CRZ and area of highest
contamination.
Figure 6. Site Work Zones.
29
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SITE CONTROL
and contamination are confined to the
appropriate areas, and that personnel
can be located and evacuated in the
event of an emergency.
Using the buddy system when neces-
sary. Most activities in contaminated
or otherwise hazardous areas should
be conducted with a "buddy" who is
able to provide assistance, observe for
signs of chemical or heat exposure,
periodically check the integrity of his
or her partner's protective clothing,
and notify others if emergency help is
needed. The buddy system alone may
not be sufficient to ensure that help
will be provided in an emergency. At all
times, workers in the Exclusion Zone
should be in line-of-sight contact or
communications contact with a person
in the Support Zone.
Establishing and strictly enforcing
decontamination procedures for both
personnel and equipment (see
3. Decontamination].
Establishing site security measures to
prevent the exposure of unauthorized,
unprotected people to site hazards; to
prevent theft; to avoid increased haz-
ards from people seeking to abandon
other wastes on the site; and to mini-
mize interference with safe working
procedures. Security measures may
include establishing an ID system,
erecting a fence, posting signs, hiring
security guards, and enlisting public
law enforcement agencies.
Setting up communication networks.
An internal communications network is
required to alert workers to emergen-
cies, pass along safety information,
communicate changes in the work to
be accomplished, and maintain site
control. An external communication
system between on site and offsite per-
sonnel is necessary to coordinate
emergency response, report to man-
Warning signs and fences help to prevent
exposure of unauthorized and unprotected
people to site hazards.
agement, and maintain contact with
essential offsite personnel.
Enforcing safe work practices, includ-
ing a list of standing orders stating
practices that must always be followed
and those that must never occur in the
contaminated areas of the site (see
Table 7).
The degree of site control needed depends
on site size end characteristics, and on the
proximity of the surrounding community.
The site control program should be estab-
lished in the planning stages of a project
and should be modified as necessary based
on new information and site assessments.
30
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SITE CONTROL
Table 7. Sample Standing Orders
FOR PERSONNEL ENTERING THE
CONTAMINATION REDUCTION ZONE:
No smoking, eating, drinking, or application or
cosmetics in this zone.
No matches or lighters in this zone.
Check in at the entrance Access Control Point
before you enter this zone.
Check out at the exit Access Control Point
before you leave this zone.
FOR PERSONNEL ENTERING THE EXCLUSION
ZONE:
No smoking, eating, drinking, or application of
cosmetics in this zone.
No matches or lighters in this zone.
Check in at the entrance Access Control Point
before you enter this zone.
Check out at the exit Access Control Point
before you leave this zone.
Always have your buddy with you in this zone.
Wear an SCBA in this zone.
If you discover any signs of radioactivity,
exptosivity, or unusual conditions such as
dead animals at the site, exit immediately and
report this finding to your supervisor.
31
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9. Decontamination
Decontaminationthe process of removing
or neutralizing contaminants on personnel
and equipmentis an essential site control
measure at any site containing chemical or
pathogenic hazards. Decontamination is
critical to health and safety: it protects
workers from hazardous substances that
may. contaminate and eventually permeate
protective clothing, respiratory equipment,
tools, vehicles, and other equipment; it
minimizes the transfer of harmful materials
into clean areas; it prevents the mixing of
incompatible chemicals; and it protects the
community by preventing the uncontrolled
transport of contaminants from the site.
PLANNING
The Site Safety Plan must include a decon-
tamination program, which must be estab-
lished before any personnel or equipment
enter areas where the potential for
exposure to hazardous substances exists.
The plan must be revised whenever the
type of PPE used on site changes, the site
conditions change, or the site hazards are
reassessed based on new information.
PREVENTION
The first step in decontamination is preven-
tion, by establishing standard operating
procedures that minimize contact with
waste. Such procedures include:
Using remote sampling, handling, and
container-opening techniques.
Protecting monitoring and sampling
equipment by placing it in bags.
Stressing work habits that minimize
contact with hazardous substances.
Wearing disposable outer garments.
Using disposable equipment where
appropriate.
Enclosing the source of contamination.
SCOPE
All personnel, clothing, equipment, and
samples leaving the contaminated area of a
site must be decontaminated. Decontami-
nation methods either physically remove
contaminants, inactivate contaminants by
chemical detoxification or disinfec-
tion/sterilization, or remove contaminants
by a combination of both physical and
chemical means. The level and type of
decontamination required depends on site-
specific factors such as the type of wastes
present and the potential for contami-
nation.
TESTING FOR EFFECTIVENESS
The effectiveness of decontamination
methods varies depending on the proper-
ties of the contaminants and the nature of
the contamination. For example, surface
contaminants in PPE may be easy to
remove, whereas substances that have per-
meated into the material may be difficult or
impossible to remove. There is no reliable
test to immediately determine how effec-
tive decontamination is. In some cases,
effectiveness can be estimated by visual
observation using natural or ultraviolet
light. Other methods that may be useful in
assessing the effectiveness of decontami-
nation are wipe sampling using a dry or
wet cloth, glass fiber filter paper, or swab;
cleaning solution analysis, in which the
level of contaminants left in the cleaning
solutions is analyzed to determine whether
additional rinsing is needed; and testing,
through laboratory analysis, of protective
garments for permeated chemicals.
LAYOUT AND PROCEDURES
At a hazardous waste site, decontamina-
tion facilities should be located in the Con-
tamination Reduction Zone (CRZ), between
the contaminated zone (often called the
Exclusion Zone) and the clean zone (often
called the Support Zone). Decontamination
32
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Exclusion
Zone
Tank change
and redress
Fully-encapsulating suit and
hard hat removal
Inner glove wash
Inner glove rinse
Inner glove removal
Inner clothing removal
CONTAMINATION CONTROL
Contamination
Reduction
Zone
Support
Zone
Figure 7. Sample Decontamination Stations (1-19) and Layout for Workers Wearing Level A
Protection (maximum protection, see Table 4).
33
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DECONTAMINATION
Gross contaminants can be removed with
water or a liquid rinse. Here, a member of
the decontamination team rinses and
scrubs the boots of a worker with a soft-
bristled brush. Both individuals are wearing
Level C personal protective equipment A
tarp in the foreground catches runoff.
procedures must provide an organized
process to reduce levels of contamination.
Outer, more heavily contaminated items
(e.g., outer boots and gloves) should be
decontaminated and removed first, fol-
lowed by inner, less contaminated itpms.
Each procedure should be performed at a
separate station to prevent cross contami-
nation. Stations should be arranged in
order of decreasing contamination, prefer-
ably in a straight line (see Figure 7). Entry
and exit points should be conspicuously
marked; dressing stations for entry should
be separate from redressing stations for
exit. No one should enter clean areas of the
decontamination facility, such as locker
rooms, until they have been completely
decontaminated.
All equipment used for decontamination,
such as buckets, brushes, clothing, tools,
and other contaminated items, should be
collected, placed in containers, labeled, and
decontaminated or properly disposed of.
Also, all spent solutions and wash water
should be collected and disposed of
properly. Clothing that is not completely
decontaminated should be placed in plastic
bags, pending further decontamination
and/or disposal.
PRECAUTIONS
While decontamination is performed to pro-
tect worker health and safety, it can pose
hazards under certain circumstances.
Before decontamination solutions and
materials are used, their chemical and
physical compatibility with the PPE must
be determined. Any decontamination
method that permeates, degrades,
damages, or otherwise impairs PPE should
not be used. In addition, decontamination
personnel must wear adequate PPE to pro-
tect them from the decontamination solu-
tions and any contaminants adhering to the
clothing and equipment they come in con-
tact with. Decontamination personnel must
themselves be decontaminated before
entering the clean Support Zone.
34
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10. Handling Drums and
Other Containers
Handling drums and other waste containers
can be one of the most hazardous site
activities. Hazards include detonations,
fires, explosions, vapor generation, and
physical injury that may result from moving
heavy containers by hand and working
around stacked drums, deteriorated drums,
and heavy equipment. Proper work prac-
ticessuch as minimizing handling, and
using equipment and procedures to isolate
workers from hazardous substances are
essential to reduce the risks to site person-
nel. Figure 8 illustrates one way of organiz-
ing the basic steps of drum handling:
inspection, planning, staging, handling,
opening, sampling, characterization, bulk-
ing, and shipment. Handling operations
must comply with:
EPA regulations {40 CFR Part 265),
which stipulate requirements for types
of containers; maintenance of con-
tainers; maintenance of structures,
such as berms and dikes, that contain
leaking wastes; and design and main-
tenance of storage areas.
DOT regulations (49 CFR Parts 171
through 178), which stipulate require-
ments for shipping containers and
procedures for shipment of hazardous
wastes.
OSHA regulations (29 CFR Parts 1910
and 1926), which include general re-
quirements and standards for storing,
containing, and handling chemicals
and containers, and for maintaining
equipment used for handling hazard-
ous materials.
INSPECTION
Prior to handling, drums must be visually
inspected to gain as much information as'
possible about their contents. Visual
inspection may reveal signs of the drum's
contents (e.g., symbols, words, or other
marks), or signs that a drum is deteriorated
(e.g., corrosion, rust, leaks) or under pres-
sure (e.g., swelling, bulging). Monitoring
around drums (e.g., using organic vapor
monitors, radiation survey instruments,
etc.) may reveal additional information
about their contents.
PLANNING
The results of the preliminary inspection
can be used to develop a plan (part of the
Work Plan) that specifies the extent of con-
tainer handling necessary, the personnel
assigned to the job, and the most appropri-
ate procedures based on the hazards
associated with the probable drum
contents.
HANDLING, OPENING, AND
SAMPLING
The primary purposes of handling are:
To respond to obvious problems that
might impair worker safety, such as
the presence of explosive or radio-
active substances.
To unstack and reorient drums for
sampling.
To organize drums into different areas
on site to facilitate characterization
and cleanup activities.
Drums and other containers should be
handled only if necessary, since accidents
occur frequently during handling. To mini-
mize the likelihood of injury, drums should
be handled, opened and sampled using a
drum grappler, hydraulically or pneumati-
cally operated impact wrench or drum
piercer, or other piece of equipment that
physically separates the worker from the
drum. Bulging, leaking, buried, open, and
deteriorated drums, or drums containing
radioactive waste, explosive or shock-
sensitive waste, or packaged wastes (lab
packs), may be particularly hazardous and
must be handled with extreme caution,
using additional safety precautions. If at all
possible, drums should be opened and
sampled in place to minimize the potential
for accidents.
35
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INSPECTION
Inspect drums
Handling
necessary?
Staging
necessary?
Develop a
staging plan
Develop a
handling plan
OPENING
Open drums
HANDLING
Orient drums
for opening
and sampling
SAMPLING
Develop sampling
plan. Sample
drum contents.
CHARACTER
IZATION
Characterize
wastes
BULKING
Transfer drum
contents into
bulk containers
SHIPMENT
Ship bulked wastes
and/or drums to offsite
treatment, storage,
or disposal facility
' STAGING I
Move drums to I
first staging area I
| (if appropriate) .1
I Move drums to I
| opening/sampling
' area
| (if appropriate) i
I Move drums to I
second staging
area
I (if appropriate) I
Move drums to '
final staging area
| (if appropriate) .
BULKING
Transfer drum
contents into
bulk containers
OPENING
Open drums
SAMPLING
Sample drum
contents
CHARACTER-
IZATION
Characterize
wastes
Figure 8. Flow Chart for Drum Handling. (Dashed boxes indicate optional steps. Number of
staging areas necessary is site specific.)
36
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HANDLING DRUMS AND OTHER CONTAINERS
CHARACTERIZATION
After drums have been sampled, their con-
tents should be characterized and classi-
fied into general categories such as
inorganic acids, heavy metals, pesticides,
etc. Following characterization, compatible
drum contents may be mixed together and
placed in bulk containers such as tanks or
vacuum trucks for transport to treatment,
storage or disposal facilities, or the drums
may be "staged" or organized to facilitate
further characterization and site cleanup.
STAGING
Although every attempt should be made to
minimize drum handling, drums must
sometimes be staged (i.e., moved in an
organized manner to predesignated areas)
to facilitate waste characterization and
cleanup and to protect drums from poten-
tially hazardous site conditions that could
result in explosions or ignition. Staging
involves a tradeoff between the increased
hazards associated with drum movement
and the decreased hazards associated with
the enhanced organization and accessibility
of materials. Figure 9 shows possible stag-
ing areas at a hazardous waste site.
BULKING AND SHIPMENT
The final container staging (bulking) area
should be located as close as possible to
the site exit to facilitate offsite shipment of
wastes and to enhance the safety of these
operations. A traffic circulation plan that
minimizes conflict between cleanup teams
and waste haulers should be devised. Ade-
quate space for vehicles to turn around
should be provided, and vehicle drivers
should be outfitted with appropriate pro-
tective equipment. All drums should be
tightly sealed before loading, and leaking or
deteriorated drums should be placed in an
overpack drum prior to shipment. Drums
should not be double stacked for shipment.
All drums must be secured to prevent shift-
Single-stacked overpack drums awaiting
transport offsite. Worker suited in Level C
personal protective equipment will spread a
tarp over the drums to protect them during
transport.
ing during transport. Vehicles should be
decontaminated prior to leaving the site to .
ensure that contaminants are not carried
onto public roads. Lastly, procedures for
responding quickly to offsite vehicle break-
downs/accidents should be developed to
ensure minimal public impact.
OTHER CONTAINERS
Other waste containers that may be pres-
ent at a site include tanks, vaults, vacuum
trucks, compressed gas cylinders, ponds,
and lagoons. Each requires special handling
procedures. For example, with elevated
tanks, safety lines and harnesses may be
necessary to prevent workers from falling.
Ponds and lagoons present a danger of
workers drowningparticularly personnel
suited in protective equipmentand may
require special safety gear. However, there
are several basic safe handling principles
that apply to all containers, regardless of
their position, shape or size: advance plan-
ning, minimizing contact with the container
and the waste, carefully inspecting the
container prior to opening, and characteriz-
ing the waste prior to bulking or shipment.
37
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SITE EXIT
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00
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STAGING
(BULKING) AREA
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oo
0 O
0 0
O 0
oo
00
oo
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00
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oo
00
o o
0 O
0 0
0 0
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0 0
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SECOND STAGING
AREA
\
\
O
DRUM OPENING
AND SAMPLING
\ AREA /
-
/
og°o°o
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OQ -
88° I
I ORIGINAL DRUM SITE '
OOOOO OOOOOO
ooooo oooooo
I OOOOOOOO
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I FIRST STAGING AREA
Figure 9. Possible Staging Areas at a Hazardous Waste Site.
38
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11. Site Emergencies
Unforeseen circumstances may suddenly
create unexpected emergencies at hazard-
ous waste sites. An emergency may be as
limited as a worker experiencing heat
stress, or as vast as an explosion that
spreads toxic fumes throughout a commu-
nity. Some common causes of emergencies
include fire or explosion, chemical leaks,
chemical reactions, container collapse,
release of'toxic vapors, heat stress, PPE
failure, and physical injury.
Site emergencies are potentially complex
because uncontrolled toxic chemicals may
be numerous and unidentified, and their
effects may be synergistic. Advance plan-
ning, including anticipation of emergency
scenarios and thorough preparation for
contingencies, is therefore essential to pro-
tect worker and community health and
safety. Emergency response delays of
minutes can create life-threatening situa-
tions; the rapidity of response can mean
the difference between life and death.
Therefore, it is essential that personnel be
able to immediately respond or rescue, and
that equipment be on hand and in good
working order.
PLANNING
A Contingency Plan that sets forth policies
and procedures for responding to emergen-
cies should be developed for each site. A
Contingency Plan is a written document
(generally a separate section within the
Site Safety Plan) that incorporates the
following:
AH individuals and teams who will par-
ticipate in emergency response, and
their roles, responsibilities, and lines of
authority.
A detailed site map showing the loca-
tions and types of hazards, site terrain,
evacuation routes, refuges, decontami-
nation stations, and offsite populations
at risk.
Procedures for communicating on site
(e.g., bullhorns, sirens, hand signals)
and offsite (e.g., key phone numbers,
contact names, two-way radio).
Equipment necessary to rescue and
treat victims, to protect response per-
sonnel, and to mitigate hazardous con-
ditions on the site.
Medical treatment/first aid techniques,
including CPR.
Emergency response procedures that
encompass all phases of response
operations, from initial notification
through preparation of equipment and
personnel for the next emergency.
Procedures for emergency decontami-
nation, including decontaminating the
victimls), protecting medical person-
net, and disposing of contaminated
PPE and decontamination solutions.
Site security and control measures to
ensure that only authorized personnel
enter hazardous areas during emer-
gency situations.
Procedures for documenting and
reporting the incident.
The Contingency Plan should be rehearsed
regularly using drills and mock situations,
and reviewed periodically in response to
new or changing site conditions or
information.
EMERGENCY RESPONSE
PROCEDURES
Figure 10 outlines a possible flow of opera-
tions during an actual emergency. Opera-
tions can be divided into three categories:
Preparation, which involves assessing
the situation, allocating personnel and
equipment for response, and request-
ing aid from outside sources.
39
-------
Notify onsite personnel
about the incident
PREPARATION
Size-up the situation based
on available information
i
'
Request aid from
outside sources
'
Allocate personnel
and equipment
resources for response
*
Survey and assess
casualties
*
Survey and assess
hazards
Transport and
treat victims
0.
O
u,
Replace or rejuvenate damaged
or exhausted equipment
Document the
incident
Review and revise Site Safety
and Contingency Plans
Figure 10. Emergency Response Operations.
40
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SITE EMERGENCIES
Response, which involves rescuing,
decontaminating, and treating victims;
evacuating personnel and/or the public
as necessary; and controlling the
hazard.
Followup, which involves replacing
equipment, documenting the incident,
and reviewing and revising the Site
Safety and Contingency Plans.
COMMUNICATIONS
In an emergency, crucial messages must be
conveyed quickly and accurately. Site staff
must be able to communicate information
such as the location of injured personnel,
orders to evacuate the site, and notice of
blocked evacuation routes, even through
noise and confusion. Onsite support serv-
ices must be reached, help obtained, and
measures for public notification taken, as
necessary.
To do this, a separate internal emergency
communication system should be devel-
oped. Such a system may consist of a net-
work of radios or field telephones (for
communicating with workers from a dis-
tance) augmented by alarms, sirens, whis-
tles, colored flags, flares, and hand or
whole-body movements. The primary sys-
tem must have a backup (e.g., hand sig-
nals) for use if radio communications fail.
The telephone is the most common mecha-
nism used to obtain emergency assistance
from offsite sources or.to inform officials
about hazardous situations that may affect
public or environmental safety. All person-
nel should be familiar with the procedure
for contacting public emergency aid teams
such as fire departments, ambulance units,
and hospitals.
Site emergencies involving significant
chemical releases should be coordinated
with Federal response organizations by
notifying the National Response Center
(800-424-8802).
SITE SECURITY AND CONTROL
In an emergency, the Project Team Leader
must know who is on site and must be
able to control the entry of site personnel
into the hazardous areas to prevent addi-
tional injury and exposure. Only necessary
rescue and response personnel should be
allowed into the Exclusion Zone. One con-
trol technique is a checkpoint or series of
checkpoints through which all personnel
entering or exiting the site must pass.
The Project Team Leader and reserve per-
sonnel must also be able to rapidly deter-
mine where workers are located and who
may be injured. A passive locator system,
such as a site map with flags or color-
headed pins identifying each worker, is
useful in helping to find personnel in an
emergency. Active locator systems, such
as personnel locator beacons that are worn
by the worker and activated by the worker
flipping a switch, can also be used.
EQUIPMENT
In an emergency, equipment is necessary
to rescue and treat victims, to protect
emergency response personnel, and to mit-
igate hazardous conditions on site (e.g., to
fight fires or contain chemicals). All equip-
ment should be in working order, fueled,
and available when an emergency occurs.
Basic equipment that should be available at
any site is listed in Table 8. Special equip-
ment should be obtained depending on the
specific types of emergencies that may
occur at a particular site and the capabili-
ties of backup offsite personnel.
41
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SITE EMERGENCIES
Table 8. Onslte Equipment and Supplies for Emergency Response
PERSONAL PROTECTION
MEDICAL
Wire basket litter
(Stokes litter) which
can be used to carry a
victim in bad weather
and on a difficult
terrain, allows easy
decontamination of
the victim, and is
Itself easy to
decontaminate
HAZARD MITIGATION
Escape SCBA or SCBA,
which can be brought
to the victim to replace
or supplement his or
her SCBA
* Personal protective
equipment and
clothing specialized for
known site hazards
Air splints
Antiseptics
Blankets
Decontamination solu-
tions appropriate for
onsite chemical
hazards
Emergency eye wash
Emergency showers or
wash stations
Ice
Reference books con-
taining basic first-aid
procedures and
Information on
treatment of specific
chemical Injuries
Resuscltator
Safety harness
Stretchers
Water, in portable
containers
Fire-fighting
equipment and
supplies
Spill-containment
equipment, such as
absorbents and oil
booms
* Special hazardous-use
tools such as remote
pneumatic impact
wrenches, non-
sparking wrenches
and picks
Containers to hold
contaminated
materials
EVACUATION
A severe emergency, such ss a fire or
explosion, may cut workers off from the
normal site exit. Therefore, alternative
routes for evacuating victims and endan-,
gered personnel should be established in
advance, marked, and kept clear.
Safe distances for evacuation of personnel
or the surrounding community due to the
hazards cosed by a hazardous substance
42
release can only be determined at the time
of an emergency, based on a combination
of site- and incident-specific factors such
as the quantity of substance released, the
rate of release, and the wind speed and
direction.
DECONTAMINATION
In some emergency situations, decontami-
nation may be an essential part of life-
saving first aid, while in other emergencies,
-------
SITE EMERGENCIES
decontamination may aggravate the injury
or delay life-saving efforts. The decision of
whether or not to decontaminate a victim
must be based on the type and severity of
the illness or injury and the nature of the
contaminants. If decontamination does not
interfere with essential treatment, it should
be performed. If decontamination cannot
be performed, the victim should be
wrapped in blankets, plastic, or rubber to
reduce contamination of other personnel,
and offsite emergency medical personnel
should be alerted to the potential contami-
nation (and to specific decontamination
procedures, if necessary).
The Site Safety and Contingency Plans
should be reviewed and revised based on
new site conditions and lessons learned
from the emergency response.
MEDICAL TREATMENT
In emergencies, medical treatment may
range from bandaging of minor cuts and
abrasions to life-saving techniques. In
many cases, essential medical help may
not be immediately available. For this rea-
son, it is vital to train onsite emergency
personnel in on-the-spot treatment tech-
niques, to establish and maintain telephone
contact with medical experts, and to estab-
lish liaisons with local hospitals and
ambulance services.
FOLLOWUP
Immediately following a hazardous waste
site emergency, the Project Team Leader
should investigate and document the inci-
dent. This is especially important when the
incident has resulted in personal injury,
property damage, or damage to the sur-
rounding environment.
Before normal site activities are resumed,
government agencies should be notofied as
required, and personnel must be fully pre-
pared and equipped to handle another
emergency. Equipment should be repaired
or replaced, and cleaned and refueled for
future use. Supplies should be restocked.
frV.3. GOVERNMENT PRINTING OFFICE: 1991 - 548-187/40560
43
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