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  involved—from
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
     rapidly—within 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.

 10

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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
                                                                                     11

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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.
 12

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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.
                                                                                13

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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 program—in
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 stress—a 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

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  Apron, gloves, hardhat, faceshield,
  boot covers
Fully-encapsulating suit
Figure 5. Examples of Protective Clothing.
                                                                                  23

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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.

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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.


-------

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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
Decontamination—the process of removing
or neutralizing contaminants on personnel
and equipment—is 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-
tices—such 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 drowning—particularly personnel
 suited in protective equipment—and 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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      .poo.
      *boo

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0*0
0 0
00
oo


0*0
0 0
00
oo
\
      STAGING
(BULKING) AREA
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oo
0 O
0 0
O 0
oo
00
oo
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00
00
oo
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oo
00
o o
0 O
0 0
0 0
0 0
0 0
0 0
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                                          SECOND STAGING
                                               AREA
                  \
                                                          \
                                                O
    DRUM OPENING
    AND SAMPLING
 \       AREA      /

   -
                                                           /
    og°o°o
    o?,oo
                OQ   -

               88°   I
I ORIGINAL DRUM SITE  '
   OOOOO OOOOOO
   ooooo oooooo

I   OOOOOOOO
I   OOOOOOOO

I   OOOO OOO OOOO
1   OOOO OOO OOOO

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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

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                               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,

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                                                                    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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