-------
Given 29 CFR1910.146, define PRCS.
Permit-required Confined Space
A confined space that has one or more of the following
characteristics:
• Contains or has the potential to contain a hazardous
atmosphere
• Contains a material that has the potential for engulfing an
entrant
• Has an internal configuration such that an entrant could be
trapped or asphyxiated by inwardly converging walls or by
a floor which slopes downward and tapers to a smaller
cross section
• Contains any other recognized serious safety or health
hazard
Source: 29 CFR 1910.146
TP-3
SKDMFM
Confm«d Spac* Entry Program
10/96
page 10-4
-------
Given 29 CFR1910.146 and a confined space, match conditions of the confined space to the
PRCS criteria.
Hazardous Atmosphere
An atmosphere that may expose employees to the risk of
injury, illness, or death from one or more of the following:
• Flammable gas, vapor, or mist in excess of 10% of lower
explosive limit (LEL)
• Airborne combustible dust in excess of LEL
• Oxygen concentration less than 19.5% or greater than
23.5%
• Atmospheric concentration in excess of permissible
exposure limits (PELs)
• Any other atmospheric condition that is immediately
dangerous to life or health (IDLH)
Source: 29 CFR 1910.146
TP-4
Note: Only substances that are capable of causing the following conditions are covered by this provision:
• Death
* Incapacitation
• Impairment of ability to self-rescue
• Injury
Acute illness
For a substance for which there is no PEL, other sources of toxicity information (e.g., material safety
data sheets) may be used.
SHOMFM
Cionfinad Sp»c« Entry Prognm
1(V9«
page 10-5
-------
Given 29 CER 1910.146, list the 14 elements of aPRCS program.
PRCS Program Elements
1. Prevent unauthorized entry
2. Identify and evaluate hazards prior to entry
3. Implement procedures and practices for safe entry
4. Provide needed equipment
5. Evaluate space during entry operations
6. Provide outside attendant
7. Identify procedures for multiple space monitoring
by a single attendant (if necessary)
8. Designate duties and responsibilities of individuals
involved in entry operations
9. Implement procedures for rescue and emergency
services
10. Develop a system for preparation, issuance, use,
and cancellation of entry permits
11. Coordinate entry operations with workers of other
employers
12. Develop closure procedures
13. Review and correct program deficiencies as they
are identified
14. Conduct annual program reviews
Source: 29 CFR 1910.146 TP-5-7
SHDMFM " owe 10*6
Confined Space Ent rrm "
-------
Notes:
J3HDMFM
Confined Space Entry Pr
tQ/96
pa go 10-7
-------
Given the decision logic flowchart provided in 29 CFR 1910.146, review the steps taken in a
PRCS program to ensure worker protection.
Confined Space Decision Flowchart
Does workplace
contain PRCS?
1
Inform
employees
Will space be
entered?
1
Will contractors
enter space?
o
Host employees
perform work?
1
No (
No ,
Yes
No
Consult other
OSHA standards
Prevent employee
entry
Inform contractor
of PRCS hazards
Both contractor
and host
employees
1
Coordinate entry
operations
Prevent
unauthorized entry
No t
- Continued
Adapted from: 29 CFR 1910.146, Appendix A
SHDMFM
Confined Stact Entry Program
10/88
paga 10-3
-------
Confined Space Decision Flowchart (cont.)
Continued
Does space
pose hazards?
No
NotaPRCS
Can hazards be
eliminated?
Yes
Employer may
recfassrfy space
PROS made safe
by ventilation only?
Yes
Space may be
entered under
1910.146(c)(7)
Prepare entry
permit
Verify acceptable
entry conditions?
No
Deny entry
Conditions
maintained
throughout entry?
No
Evacuate PRCS
Task completed -
permit closed
J Audit permit
\ program
Consult other
OSHA standards
Evaluate program
Adapted from: 29 CFR 1910.146, Appendix A
SHOMFM
C<>nfin«d Seac* Entry Program
10/96
« 10-9
-------
Entry Permit Definition
Written or printed
that is
provided by the employer to allow and
control entry into a permit space
Contains the information specified in
paragraph (f) — Entry Permit
Source: 29 CFR 1910.146
SHOMFM
Confined Spac« Entry Program
10/96
10-10
-------
Given 29 CFR1910.146 and aPRCS, apply the 15 components of the entry permit.
Required Information for an Entry Permit
1. Identification of space to be entered
2. Purpose of entry
3. Date and authorized duration of entry permit
4. List of authorized entrants for duration of permit
5. Names of personnel serving as attendants
6. Name of entry supervisor
7. Hazards of space to be entered
8. Measures used to isolate space and to eliminate
or control hazards before entry
9, Acceptable entry conditions
10. Initial and periodic testing results along with
names or initials of testers and times of testing
11. Rescue and emergency services to be summoned
and the means for doing so
12. Communication procedures between entrants and
attendants
13. Necessary equipment
14. Any other information necessary to ensure worker
safety
15. Any additional required permits
Source: 29 CFR 1910.146 TP-8-9
SHOMFM
Confined Space Entry Piogum
1CV9S
page 10-11
-------
Given the use of a contractor in a PRCS and the host and contractor PRCS programs, compare
the elements of the two programs.
Contractor Coordination:
Contractor's Responsibilities
Obtain information on permit space hazards and
entry operations from host employer
Coordinate entry operations with host employer
(includes work near permit spaces)
Inform host employer of contractor's permit space
entry program
Inform host employer of any hazards confronted or
created during entry operations
Source: 29 CFR 1910.146
TP-10
SHOMFM
ConKnad Spaea Entry P'O9'»<"
10/98
paga 10-12
-------
Contractor Coordination:
Host Employer's Responsibilities
• Inform contractor of permit spaces and need for
permit program
• Inform contractor of identified hazards and previous
experience with the space
• Inform contractor of precautions or procedures
implemented in or near permit spaces for employee
protection
• Coordinate entry operations with contractor
• Debrief contractor to incorporate lessons learned
Source: 29 CFR 1910.146 TP-11
SHDMFM
Conftnad Sp*c* Entry Program
10/96
pas* 10-13
-------
The Blue Ridge Chemical Facility
Drum
storage
.area
Plant
nnnnnn
DDDDD
Vats
10 O0|
—io ooi
"O'O O O i
O O 00!
O O OO;
o o ooi
,Q_QO_QJ
Tank farm
TP-12
Scenario
There is a tank farm onsite that must be removed; therefore, each tank must be:
1. Drained.
2. Cleaned.
3. Verified nonexplosive.
4. Cut into segments.
These tanks contain diamine (anhydrous hydrazine).
The host is responsible for performing all valve lineups, draining or pumping tanks, isolating vessels, and
performing air monitoring.
The contractor is responsible for cleaning and cutting tanks into segments. Assume that this will require
entryintoaPRCS.
Tasks to be performed
1. Decide on necessary monitoring procedures before and during entry (permit item 10).
2 Develop information needed for permit items 7, 8, and 9.
3. Develop plans for summoning onsite rescue and emergency services and the means for doing so (permit
item 11).
4. Develop plans for summoning offsite rescue and emergency services and the means for doing so (permit
item 11).
5 Identify communication procedures you will implement during entry (permit item 12).
SHOMFM
Confinad Spaca Entry Program
10/86
paja 10-14
-------
DANGER
CONFINED SPACE
ENTRY BY
PERMIT ONLY
Conclusion
DANGER
CONFINED SPACE
ENTRY BY
PERMIT ONLY
Confined Space Entry Program
Spill Containment Program
Emergency Response Plans
TP-13
Across
Crossword Puzzle
25. One of its characteristics is limited means of access (2 words)
Down
5. The person who functions as a safety observer for entrants into a PRCS
6. A15-component document that authorizes entries into a PRCS is an
permit
SMDMFM
Confined Space Entry Profit mm
10/96
page 10-15
-------
APPENDIX A
Confined Space Scenario
-------
-------
Confined Space Senario
FACE 85-05: Confined Space Incident Kills Two workers - Company Employee and Rescuing
Fireman
INTRODUCTION
On November 15,1984, one worker died after entering a toluene storage tank. During the rescue attempt, a
fireman was killed when the tank exploded.
SYNOPSIS OF EVENTS
The owner of a bulk petroleum storage facility discovered that the toluene storage tank (10 feet in diameter and
20 feet in height) was contaminated and would have to be drained and cleaned. Since the tank's only access
portal was located on top of the upright cylindrical tank, the owner decided to have a clean-out access portal
installed at the bottom of the tank when emptied. A contractor was called to provide cost estimates for
installing the portal. The contractor performed a site survey of the tank and told the owner that the tank must be
drained, all sludge removed, and thoroughly ventilated before he would install the portal. The owner directed
his maintenance supervisor to get the tank prepared for the contractor.
On the day of the incident the supervisor and an unskilled laborer (a San Salvadorean immigrant on his first day
back on the job after working another job for approximately 2 months) drained the tank to its lowest level -
leaving 2 to 3 inches of sludge and toluene in the bottom - and prepared for a "dry run" of entry into the tank via
the top access portal.
The supervisor rented a self-contained breathing apparatus (SCBA) from a local rental store and instructed the
laborer in use of the SCBA and in the procedure they intended to follow. Since a ladder would not fit into the
16-inch diameter access hole, the supervisor secured a knotted, 1/4-inch rope to the vent pipe on top of the
tank and lowered the rope into the hole. The 16-inch diameter opening on the top of the tank was not large
enough to permit the laborer to enter wearing the SCBA. Therefore, it was decided the SCBA would be
loosely strapped to the laborer so it could be held over his head until he cleared the opening. Once entry had
been made, the supervisor was to lower the SCBA onto the laborer's back so it could be properly secured.
Immediately prior to the incident, both employees were on top of the tank. The laborer was sitting at the edge
of the opening. The supervisor turned to pick up the SCBA. While he was picking up the unit, he heard the
laborer in the tank. He turned and looked into the opening and saw the laborer standing at the bottom of the
tank. He told the laborer to come out of the tank, but there was no response. The supervisor bumped the rope
against the laborer's chest attempting to get his attention. The laborer was mumbling, but was still not
responding to his supervisor's commands. At this point, the supervisor pulled the rope out of the tank, tied the
SCBA to it and lowered the unit into the tank. Again, he yelled to the laborer in the tank, bumped him with the
unit and told him to put the mask on. There was still no response. The laborer fell to his knees, then fell onto
his back, and continued to mumble. At this point, the supervisor told the facility manager (who was on the
ground) to call the fire department.
The first call went to the police department who relayed it to the fire department. Included in the fire
department response was the hazardous materials team, due to the information received about the
SHOMFM
Ccnftned Spjce Entry Program
10/99
page A-1
-------
material in the tank. The fire department (including the rescue and the hazardous materials teams) arrived on the
scene approximately 10 minutes after the initial notification. After apprising the situation, fire officials decided to
implement a rescue procedure rather than a hazardous materials procedure. Therefore, removal of the disabled
person inside the tank was given top priority.
The 16-inch diameter opening at the top of the tank was not large enough to lower a fireman donned in fall
rescue gear. Therefore, it was decided to cut through the side of the tank to remove the victim. The firemen
were aware of the contents of the tank (toluene) and the possibility of an explosion.
The procedure developed by the fire department involved making two 19-inch vertical cuts and a 19-inch
horizontal cut with a gasoline-powered disc saw. After the cuts were completed, the steel flap would be pulled
down and the victim removed.
While the hazardous materials team was cutting, other firemen were spraying water on the saw from the exterior
to quench sparks. Two other firemen were spraying water on the interior cut from the top opening. Three
firemen with the hazardous materials team were doing the actual cutting; they were alternately operating the saw
because of the effort required to cut through the 1/4-inch thick steel. Sometime during the horizontal cut a
decision was made to bring the two firemen offthe top, which meant no water spray on the interior.
Simultaneously, the exterior water spray was removed to put out flammable liquid burning on the ground as a
result of the shower of sparks from the saw. Thus, at the precise time of the explosion, no water was being
sprayed on the saw/eut from exterior or interior. Both vertical cuts were completed and the horizontal cut was
95 percent complete when the explosion occurred.
One fireman was killed instantly from the explosion and several were injured. The man inside the tank was
presumed to be already dead at the time of the explosion.
CONCLUSIONS/RECOMMENDATIONS
The conclusions and recommendations are presented in two parts: Part I - the confined space entry; and Part n
-the rescue effort.
Part I - Confined Space Entry:
The following factors may have contributed to the confined space fatality:
The company had no confined space entry procedures.
The supervisor was not qualified to direcl confined space entry.
The laborer was inadequately trained for confined space entry - possible language barrier.
Appropriate protective clothing and equipment were not provided.
The only access portal required vertical entry.
The access portal was small.
It was the laborer's first day back on the job. (He may have felt obligated to perform any task assigned.)
SHOMFM
CH Entry Program
10/96
8« A-2
-------
RECOMMENDATIONS
Written confined space entry procedures should be developed and used. Procedures should contain the
following: permit system, testing and monitoring of the atmosphere, training of employees, safety equipment/
clothing, safe work practices, rescue procedures, standby person requirements, and use of respiratory
protection.
Selection of proper respiratory protection - whether it be a self-contained breathing apparatus (SCBA) or
supplied air system - is essential. Selection should be determined by the physical limitations, equipment
available, and work procedures.
Confined space testing and evaluation by a qualified person before entry and implementation of safety measures
will help reduce risk-taking by employees.
Vertical access from the top of a 20-foot tank by a rope was found to be physically impossible while wearing
respiratory protection and protective clothing. An additional access port on the side near ground level would
eliminate this problem. The port should be of adequate size to permit entry of a worker wearing full protective
clothing.
Workers must be properly trained (in English, Spanish, or the prevailing language) in confined space entry
procedures and use of personal protective equipment. Also, the tank contents and known potential hazards
should be discussed.
A prior accident should have alerted someone that additional protection was needed. If entry procedures are
being followed and an accident occurs, it is necessary to reevaluate the procedures and make necessary
corrections for employee safety.
Part II - The Rescue Effort:
The following factors may have contributed to the rescue effort fatality and injuries:
The condition of the person down inside the tank was not known.
The location and size of the only access portal on the tank precluded entry by a rescuer wearing full protective
clothing and equipment.
The fire department's confined space entry procedures precluded entry into a confined space containing
hazardous materials without full protective clothing and equipment.
The choice of methods to open the tank for rescue entry introduced an ignition source to an atmosphere which
was known to be potentially explosive (see tank calculations).
The use of water sprays to prevent ignition of a flammable/explosive atmosphere in a confined space may not be
effective under certain conditions.
There were combustible materials on the ground surrounding the tank which ignited prior to the explosion and
necessitated removal of exterior water spray away from the saw/cut.
The fire department chain of command possibly created confusion when orders were given without full
| knowledge of the situation.
The number of fire department personnel in the immediate area may have been excessive.
SHOMFM
Confined Space Entry Program
1CV98
g« A-3
-------
The victim (fire fighter) was directly in front of the cut during the cutting procedure and when the explosion
occurred.
RECOMMENDATIONS
While cutting the tank and assisting fellow firemen who were cutting, one fire fighter stood directly in front of the
opening, rather than to the side. This maximized the impact the victim received from the explosion. It is
recommended that procedures be outlined that minimize such risk by firemen.
When hazardous tasks are performed only essential personnel should be in the immediate area, regardless of
perceived risk by fire fighters. Nonessential personnel should be permitted only after the hazardous task(s) has
been completed.
More extensive departmental procedures for efforts involving responses to explosive environments and
hazardous materials are needed. Procedures should include command responsibilities, determinations of and
distinctions between rescue and recovery efforts, uses of potential sources of ignition, methods to minimize risks
of ignitions, etc.
City fire departments should establish a registry of confined spaces and toxic/explosive substances for specific
companies within the area in which they serve. Such a registry should provide not only the name of the
substance, but should also provide sufficient information so that emergency response personnel will have one
comprehensive source that provides information sufficient to safely effect a rescue effort.
Research is needed to determine the best methods (if any) to gain entry in such circumstances. Cutting may be
too hazardous, even with the use of water sprays.
This case was taken from the book Worker Deaths in Confined Spaces, which is available from:
Publications Dissemination, DSDTT
NIOSH
4676 Columbia Parkway
Cincinnati, OH 45226-1998
FAX: (513)533-8573
3WDMFM
Confined Spae* Entry Prognm
tO/96
-------
APPENDIX B
29 CFR 1910.146
Permit-required Confined Spaces
-------
-------
§1910.146 - Permit-required confined
spaces [Pan (a) thru (e)(2)|
STANDARD NUMBER: 1910.146
STANDARD TITLE: Permit-required
confined spaces
SUBPART NUMBER: J
SUBPART TITLE: General
Environmental Controls
TEXT:
(a) Scope and application. This section
contains requirements for practices and
procedures to protect employees in
general industry from the hazards of
entry into permit-required confined
spaces. This section docs not apply to
agriculture, to construction, or to
shipyard employment (Parts 1928, 1926,
and 1915 of this chapter, respectively).
(b) Definitions.
Acceptable entry conditions means the
conditions that must exist in a permit
space to allow entry and to ensure that
employees involved with a permit-
required confined space entry can safely
enter into and work within the space.
Attendant means an individual
stationed outside one or more permit
spaces who monitors the authorized
entrants and who performs all
attendant's duties assigned in the
employer's permit space program.
Authorized entrant means an employee
who is authorized by the employer to
enter a permit space.
Blanking or blinding means the
absolute closure of a pipe, line, or duct
by the fastening of a solid plate (such as
a spectacle blind or a skillet blind) that
completely covers the bore and that is
capable of withstanding the maximum
pressure of the pipe, line, or duct with
no leakage beyond the plate.
Confined space means a space that:
(1) Is large enough and so configured
that an employee can bodily enter and
perform assigned work; and
(2) Has limited or restricted means for
entry or exit (for example, tanks,
vessels, silos, storage bins, hoppers,
vaults, and pits are spaces that may have
limited means of entry.); and
(3) Is not designed for continuous
employee occupancy.
Double block and bleed means the
closure of a line, duct, or pipe by closing
and locking or tagging two in-line valves
and by opening and locking or tagging a
drain or vent valve in the line between
the two closed valves.
Emergency means any occurrence
(including any failure of hazard control
or monitoring equipment) or event
internal or external to the permit space
that could endanger entrants.
Engulfmenl means the surrounding and
effective capture of a person by a liquid
SNDMFM
Confined Spac* Entry Program
or finely divided (flowable) solid
substance that can be aspirated to cause
death by filling or plugging the
respiratory system or that can exert
enough force on the body to cause death
by strangulation, constriction, or
crushing.
Entry means the action by which a
person passes through an opening into a
permit-required confined space. Entry
includes ensuing work activities in that
space and is considered to have occurred
as soon as any part of the entrant's body
breaks the plane of an opening into the
space.
Entry permit (permit) means the
written or printed document that is
provided by the employer to allow and
control entry into a permit space and that
contains the information specified in
paragraph (f) of this section.
Entry supervisor means the person
(such as the employer, foreman, or crew
chief) responsible for determining if
acceptable entry conditions are present
at a permit space where entry is planned,
for authorizing entry and overseeing
entry operations, and for terminating
entry as required by this section.
NOTE: An entry supervisor also may
serve as an attendant or as an authorized
entrant, as long as that person is trained
and equipped as required by this section
for each role he or she fills. Also, the
duties of entry supervisor may be passed
from one individual to another during the
course of an entry operation.
Hazardous atmosphere means an
atmosphere that may expose employees
to the risk of death, incapacitation,
impairment of ability to self-rescue (that
is, escape unaided from a permit space),
injury, or acute illness from one or more
of the following causes:
(1) Flammable gas, vapor, or mist in
excess of 10 percent of its lower
flammable limit (LFL);
(2) Airborne combustible dust at a
concentration that meets or exceeds
its LFL;
NOTE: This concentration may be
approximated as a condition in which the
dust obscures vision at a distance of 5
feet (1.52 m) or less.
(3) Atmospheric oxygen concentration
below 19.5 percent or above 23.5
percent;
(4) Atmospheric concentration of any
substance for which a dose or a
permissible exposure limit is published
in Subpart G, Occupational Health and
Environmental Control, or in Subpart Z,
Toxic and Hazardous Substances, of this
Part and which could result in employee
exposure in excess of its dose or
permissible exposure limit;
NOTE: An atmospheric concentration
of any substance that is not capable of
causing death, incapacitation,
impairment of ability to self-rescue,
injury, or acute illness due to its health
effects is not covered by this provision.
(5) Any other atmospheric condition
that is immediately dangerous to life or
health.
NOTE: For air contaminants for which
OSHA has not determined a dose or
permissible exposure limit, other sources
of information, such as Material Safety
Data Sheets that comply with the Hazard
Communication Standard, section
1910.1200 of this Part, published
information, and internal documents can
provide guidance in establishing
acceptable atmospheric conditions.
Hot work permit means the employer's
written authorization to perform
operations (for example, riveting,
welding, cutting, burning, and heating)
capable of providing a source of ignition.
Immediately dangerous to life or health
(TDLH) means any condition that poses
an immediate or delayed threat to life or
that would cause irreversible adverse
health effects or that would interfere
with an individual's ability to escape
unaided from a permit space.
NOTE: Some materials — hydrogen
fluoride gas and cadmium vapor, for
example — may produce immediate
transient effects that, even if severe, may
pass without medical attention, but are
followed by sudden, possibly fatal
collapse 12-72 hours after exposure. The
victim "feels normal" from recovery
from transient effects until collapse.
Such materials in hazardous quantities
are considered to be "immediately"
dangerous to life or health.
Inerting means the displacement of the
atmosphere in a permit space by a
noncombustible gas (such as nitrogen) to
such an extent that the resulting
atmosphere is noncombustible.
NOTE: This procedure produces an
IDLH oxygen-deficient atmosphere.
Isolation [58 ER 4549, Jan. 14, 1993;
58 FR 34846, June 29, 1993] means the
process by which a permit space is
removed from service and completely
protected against the release of energy
and material into the space by such
means as: blanking or blinding;
misaligning or removing sections of
lines, pipes, or ducts, a double block and
bleed system, lockout or tagout of all
sources of energy, or blocking or
disconnecting all mechanical linkages.
Line breaking means the intentional
opening of a pipe, line, or duct that is or
has been carrying flammable, corrosive,
or toxic material, an inert gas, or any
10/96
p»a» 8-1
-------
fluid at a volume, pressure, or
temperature capable of causing injury.
Non-permit confined space means a
confined space that does not contain or,
with respect to atmospheric hazards,
have the potential to contain any hazard
capable of causing death or serious
physical harm.
Oxygen deficient atmosphere means an
atmosphere containing less than 19.5
percent oxygen by volume.
Oxygen enriched atmosphere means an
atmosphere containing more than 23.5
percent oxygen by volume.
Permit-required confined space (permit
space) means a confined space that has
one or more of the following
characteristics:
(I) Contains or has a potential to
contain a hazardous atmosphere;
(2) Contains a material that has the
potential for engulfing an entrant;
(3) Has an internal configuration such
that an entrant could be trapped or
asphyxiated by inwardly converging
walls or by a floor which slopes
downward and tapers to a smaller cross-
section; or
(4) Contains any other recognized
serious safety or health hazard.
Permit-required confined space
program (permit spec program) means
the employer's overall program for
controlling, and, where appropriate, for
protecting employees from, permit space
hazards and for regulating employee
entry into permit spaces.
Permit system means the employer's
written procedure for preparing and
issuing permits for entry and for
returning the permit space to service
following termination of entry.
Prohibited condition means any
condition in a permit space that is not
allowed by the permit during the period
when entry is authorized.
Rescue service means the personnel
designated to rescue employees from
permit spaces.
Retrieval system means the equipment
(including a retrieval line, chest or full-
body harness, wristlets, if appropriate,
and a lifting device or anchor) used for
non-entry rescue of persons from permit
spaces.
Testing means the process by which the
hazards that may confront entrants of a
permit space are identified and
evaluated. Testing includes specifying
the tests that are to be performed in the
permit space.
NOTE: Testing enables employers boih
to devise and implement adequate
control measures for the protection of
authorized entrants and to determine if
acceptable entry conditions arc present
SHDMFM
Confined Space £ntry Program
immediately prior to, and during, entry.
1910.146(c)
(c) General requirements. (1) The
employer shall evaluate the workplace to
determine if any spaces are permit-
required confined spaces.
NOTE: Proper application of the
decision flow chart in Appendix A to
section 1910.146 would facilitate
compliance with this requirement.
(2) If the workplace contains permit
spaces, the employer shall inform
exposed employees, by posting danger
signs or by any other equally effective
means, of the existence and location of
and the danger posed by the permit
spaces.
NOTE: A sign reading DANGER —
PERMIT-REQUIRED CONFINED
SPACE, DO NOT ENTER or using other
similar language would satisfy the
requirement for a sign.
(3) If the employer decides that its
employees will not enter permit spaces,
the employer shall take effective
measures to prevent its employees from
entering the permit spaces and shall
comply with paragraphs (cXl)> (cX2),
(cX6), and (c)(8) of this section.
19I0.146(c)(4)
(4) If the employer decides that its
employees will enter permit spaces, the
employer shall develop and implement a
written permit space program that
complies with this section. The written
program shall be available for inspection
by employees and their authorized
representatives.
(5) An employer may use the alternate
procedures specified in paragraph
(cX5)(ii) of this section for entering a
permit space under the conditions set
forth in paragraph (cXSXO of this
section.
(i) An employer whose employees enter
a permit space need not comply with
paragraphs (d) through (f) and (h)
through (k) of this section, provided that:
(A) The employer can demonstrate that
the only hazard posed by the permit
space is an actual or potential hazardous
atmosphere;
(6) The employer can demonstrate that
continuous forced air ventilation alone is
sufficient to maintain that permit space
safe for entry,
(C) The employer develops monitoring
and inspection data that supports the
demonstrations required by paragraphs
(c)(5)(i)(A) and (cX5)(i)(B) of this
section;
CD) If an initial entry of the permit
space is necessary to obtain the data
required by paragraph (c)(5)(iXC) of this
section, the entry is performed in
compliance with paragraphs (d) through
flc) of this section;
I9I0.146(c)(S)(iXE)
(E) The determinations and supporting
data required by paragraphs (cX5XiXA),
(c)(5)(i)(B), and (c)(5)(iXC) of this
section arc documented by the employer
and arc made available to each employee
who enters the permit space under the
terms of paragraph (cX5) of this section;
and
(F) Entry into the permit space under
the terms of paragraph (cXSXO of this
section is performed in accordance with
the requirements of paragraph (cXSXii)
of this section.
NOTE: Sec paragraph (cX7) of this
section for reclassification of a permit
space after all hazards within the space
have been eliminated.
(ii) The following requirements apply
to entry into permit spaces that meet the
conditions set forth in paragraph (cX^XO
of this section.
(A) Any conditions making it unsafe to
remove an entrance cover shall be
eliminated before the cover is removed.
(B) When entrance covera are removed,
the opening shall be promptly guarded
by a railing, temporary cover, or other
temporary barrier that will prevent an
accidental fall through the opening and
that will protect each employee working
in the space from foreign objects
entering the space.
l910.l46(c)(5)(iO(Q
(C) Before an employee enters the
space, the internal atmosphere shall be
tested, with a calibrated direct-reading
instrument, for the following conditions
in the order given:
{1} Oxygen content,
(2} Flammable gases and vapors, and
{3} Potential toxic air contaminants.
(D) There may be no hazardous
atmosphere within the space whenever
any employee is inside the space.
(E) Continuous forced air ventilation
shall be used, as follows:
{1} An employee may not enter the
space until the forced air ventilation has
eliminated any hazardous atmosphere;
{2} The forced air ventilation shall be
so directed as to ventilate the immediate
areas where an employee is or will be
present within the space and shall
continue until all employees have left
the space;
{3} The air supply for the forced air
ventilation shall be from a clean source
and may not increase the hazards in the
space.
10/96
pag* 8-2
-------
(F) The atmosphere within the space
shall be periodically tested as necessary
to ensure that the continuous forced air
ventilation is preventing the
accumulation of a hazardous atmosphere.
(G) If a hazardous atmosphere is
detected during entry:
{ 1 } Each employee shall leave the
space immediately;
{2} The space shall be evaluated to
determine how the hazardous
atmosphere developed; and
{3} Measures shall be implemented to
protect employees from the hazardous
atmosphere before any subsequent entry
takes place.
(H) The employer shall verify that the
space is safe for entry and that the pre-
entry measures required by paragraph
(cX5)(ii) of this section have been taken,
through a written certification that
contains the date, the location of the
space, and the signature of the person
providing the certification. The
certification shall be made before entry
and shall be made available to each
employee entering the space.
(6) When there are changes in the use
or configuration of a non-permit confined
space that might increase the hazards to
entrants, the employer shall rccvaluatc
that space and, if necessary, reclassify it
as a permit-required confined space.
(7) A space classified by the employer
as a permit-required confined space may
be reclassifled as a non-permit confined
space under the following procedures:
1910.146(cX7Xi)
(i) If the permit space poses no actual
or potential atmospheric hazards and if
all hazards within the space are
eliminated without entry into the space,
the permit space may be reclassified as a
non-permit confined space for as long as
the non-atmospheric hazards remain
eliminated.
(ii) If it is necessary to enter the permit
space to eliminate hazards, such entry
shall be performed under paragraphs (d)
through (k) of this section. If testing and
inspection during that entry demonstrate
that the hazards within the permit space
have been eliminated, the permit space
may be reclassified as a non-permit
confined space for as long as the hazards
remain eliminated.
NOTE: Control of atmospheric hazards
through forced air ventilation does not
constitute elimination of the hazards.
Paragraph (cX5) covers permit space
entry where the employer can
demonstrate that forced air ventilation
alone will control all hazards in the
space.
(iii) The employer shall document the
basis for determining that all hazards in
a permit space have been eliminated,
through a certification that contains the
date, the location of the space, and the
signature of the person making the
determination. The certification shall be
made available to each employee
entering the space.
1910.146(cX7)(iv)
(iv) If hazards arise within a permit
space that has been declassified to a
non-permit space under paragraph (c)(7)
of this section, each employee in the
space shall exit the space. The employer
shall then rcevaluatc the space and
determine whether it must be
reclassified as a permit space, in
accordance with other applicable
provisions of this section.
(8) When an employer (host employer)
arranges to have employees of another
employer (contractor) perform work that
involves permit space entry, the host
employer shall:
(i) Inform the contractor that the
workplace contains permit spaces and
that permit space entry is allowed only
through compliance with a permit space
program meeting the requirements of
this section;
(ii) Apprise the contractor of the
elements, including the hazards
identified and the host employer's
experience with the space, that make the
space in question a permit space;
(iii) Apprise the contractor of any
precautions or procedures that the host
employer has implemented for the
protection of employees in or near
permit spaces where contractor
personnel will be working;
(iv) Coordinate entry operations with
the contractor, when both host employer
personnel and contractor personnel will
be working in or near permit spaces, as
required by paragraph (dXH) of this
section; and
1910.146(c)(8Xv)
(v) Debrief the contractor at the
conclusion of the entry operations
regarding the permit space program
followed and regarding any hazards
confronted or created in permit spaces
during entry operations.
(9) In addition to complying with the
permit space requirements that apply to
all employers, each contractor who is
retained to perform permit space entry
operations shall:
(i) Obtain any available information
regarding permit space hazards and entry
operations from the host employer,
(ii) Coordinate entry operations with
the host employer, when both host
employer personnel and contractor
personnel will be working in or near
permit spaces, as required by paragraph
(dXl 1) of this section; and
(iii) Inform the host employer of the
permit space program that the contractor
will follow and of any hazards
confronted or created in permit spaces,
either through a debriefing or during the
entry operation.
(d) Permit-required confined space
program (permit space program). Under
the permit space program required by
paragraph (cX4) of this section, the
employer shall:
(1) Implement the measures necessary
to prevent unauthorized entry,
1910.146(d)(2)
(2) Identify and evaluate the hazards of
permit spaces before employees enter
them;
(3) Develop and implement the means,
procedures, and practices necessary for
safe permit space entry operations,
including, but not limited to, the
following:
(i) Specifying acceptable entry
conditions;
(ii) Isolating the permit space;
(iii) Purging, tnerttng, flushing, or
ventilating the permit space as necessary
to eliminate or control atmospheric
hazards;
(iv) Providing pedestrian, vehicle, or
other barriers as necessary to protect
entrants from external hazards; and
(v) Verifying that conditions in the
permit space are acceptable for entry
throughout the duration of an authorized
entry.
(4) Provide the following equipment
(specified in paragraphs (d)(4XO
through (d)(4)(ix) of this section) at no
cost to employees, maintain that
equipment properly, and ensure that
employees use that equipment properly:
(i) Testing and monitoring equipment
needed to comply with paragraph (dX5)
of this section;
1910.146(dX4)(ii)
(ii) Ventilating equipment needed to
obtain acceptable entry conditions;
(iii) Communications equipment
necessary for compliance with
paragraphs (hX3) and (iX5) of this
section;
(iv) Personal protective equipment
insofar as feasible engineering and work
practice controls do not adequately
SHOMFM
Confined Spacfl Entry Program
10/96
J5ig« B-3
-------
protect employees;
(v) Lighting equipment needed to
enable employees to see well enough to
work safely and to exit the space quickly
in an emergency,
(vi) Barriers and shields as required by
paragraph (dX3Xiv) of this section;
(vii) Equipment, such as ladders,
needed for safe ingress and egress by
authorized entrants;
(viii) Rescue and emergency equipment
needed to comply with paragraph (dX?)
of this section, except to the extent that
the equipment is provided by rescue
services; and
(ix) Any other equipment necessary for
safe entry into and rescue from permit
spaces.
(5) Evaluate permit space conditions as
follows when entry operations are
conducted:
1910.146(d)(5XO
(i) Test conditions in the permit space
to determine if acceptable entry
conditions exist before entry is
authorized to begin, except that, if
isolation of the space is infeasible
because the space is large or is part of a
continuous system (such as a sewer),
pre-entry testing shall be performed to
the extent feasible before entry is
authorized and, if entry is authorized,
entry conditions shall be continuously
monitored in the areas where authorized
entrants are working;
(ii) Test or monitor the permit space as
necessary to determine if acceptable
entry conditions are being maintained
during the course of entry operations;
and
(iii) When testing for atmospheric
hazards, test first for oxygen, then for
combustible gases and vapors, and then
for toxic gases and vapors.
NOTE: Atmospheric testing conducted
in accordance with Appendix B to
section 1910.146 would be considered as
satisfying the requirements of this
paragraph. For permit space operations
in sewers, atmospheric testing conducted
in accordance with Appendix B, as
supplemented by Appendix E to section
1910.146, would be considered as
satisfying the requirements of this
paragraph.
191Q.146(d}(6)
(6) Provide at least one attendant
outside the permit space into which entry
is authorized for the duration of entry
operations,
NOTE: Attendants may be assigned to
monitor more than one permit space
provided the duties described in
paragraph (i) of this section can be
SHOMFM
Confined Sp*c* Entry Progfam
effectively performed for each permit
space that is monitored. Likewise,
attendants may be stationed at any
location outside the permit space to be
monitored as long as the duties
described in paragraph (i) of this section
can be effectively performed for each
permit space that is monitored.
(7) If multiple spaces are to be
monitored by a single attendant, include
in the permit program the means and
procedures to enable the attendant to
respond to an emergency affecting one or
more of the permit spaces being
monitored without distraction from the
attendant's responsibilities under
paragraph (i) of this section;
(8) Designate the persons who are to
have active roles (as, for example,
authorized entrants, attendants, entry
supervisors, or persons who test or
monitor the atmosphere in a permit
space) in entry operations, identify the
duties of each such employee, and
provide each such employee with the
training required by paragraph (g) of this
section,
1910.146(d)(9)
(9) Develop and implement procedures
for summoning rescue and emergency
services, for rescuing entrants from
permit spaces, for providing necessary
emergency services to rescued
employees, and for preventing
unauthorized personnel from attempting
a rescue;
(10) Develop and implement a system
for the preparation, issuance, use, and
cancellation of entry permits as required
by this section;
(11) Develop and implement
procedures to coordinate entry operations
when employees of more than one
employer are working simultaneously as
authorized entrants in a permit space, so
that employees of one employer do not
endanger the employees of any other
employer;
(12) Develop and implement
procedures (such as closing off a permit
space and canceling the permit)
necessary for concluding the entry after
entry operations have been completed;
(13) Review entry operations when the
employer has reason to believe that the
measures taken under the permit space
program may not protect employees and
revise the program to correct deficiencies
found to exist before subsequent entries
are authorized; and
NOTE. Examples of circumstances
requiring the review of the permit space
program are: any unauthorized entry of a
permit space, the detection of a permit
space hazard not covered by the permit,
the detection of a condition prohibited by
the permit, the occurrence of an injury or
near-miss during entry, a change in the
use or configuration of a permit space,
and employee complaints about the
effectiveness of the program.
1910.146(d)(14)
(14) Review the permit space program,
using the canceled permits retained
under paragraph (e)(6) of this section
within 1 year after each entry and revise
the program as necessary, to ensure that
employees participating in entry
operations are protected from permit
space hazards.
NOTE: Employers may perform a
single annual review covering all entries
performed during a 12-month period. IT
no entry is performed during a 12-month
period, no review is necessary.
Appendix C to section 1910.146
presents examples of permit space
programs that are considered to comply
with the requirements of paragraph (d)
of this section.
(e) Permit system. (1) Before entry is
authorized, the employer shall document
the completion of measures required by
paragraph (dX3) of this section by
preparing an entry permit.
NOTE: Appendix D to section
1910.146 presents examples of permits
whose elements are considered to
comply with the requirements of this
section.
1910.146(e)(2)
(2) Before entry begins, the entry
supervisor identified on the permit shall
sign the entry permit to authorize entry.
1910.146 - Permit-required confined
spaces (Para (eX3) thru end]
(3) The completed permit shall be
made available at the time of entry to all
authorized entrants, by posting it at the
entry portal or by any other equally
effective means, so that the entrants can
confirm that pre-entry preparations have
been completed.
(4) The duration of the permit may not
exceed the time required to complete the
assigned task or job identified on the
permit in accordance with paragraph
(fX2) of this section.
(5) The entry supervisor shall terminate
entry and cancel the entry permit when:
(i) The entry operations covered by the
entry permit have been completed; or
(ii) A condition that is not allowed
under the entry permit arises in or near
the permit space.
(6) The employer shall retain each
canceled entry permit for at least 1 year
to facilitate the review of the permit-
required confined space program
10/96
-------
required by paragraph (dXl4) of this
section. Any problems encountered
during an entry operation shall be noted
on the pertinent permit so that
appropriate revisions to the permit space
program can be made.
1910.146(0
(0 Entry permit The entry permit that
documents compliance with this section
and authorizes entry to a permit space
shall identify:
(1) The permit space to be entered;
(2) The purpose of the entry,
(3) The date and the authorized
duration of the entry permit;
(4) The authorized entrants within the
permit space, by name or by such other
means (for example, through the use of
rosters or tracking systems) as will
enable the attendant to determine
quickly and accurately, for the duration
of the permit, which authorized entrants
are inside the permit space;
NOTE: This requirement may be met
by inserting a reference on the entry
permit as to the means used, such as a
roster or tracking system, to keep track
of the authorized entrants within the
permit space.
(5) The personnel, by name, currently
serving as attendants;
(6) The individual, by name, currently
serving as entry supervisor, with a space
for the signature or initials of the entry
supervisor who originally authorized
entry,
1910,1.46(0(7)
(7) The hazards of the permit space to
be entered;
(8) The measures used to isolate the
permit space and to eliminate or control
permit space hazards before entry;
NOTE: Those measures can include the
lockout or tagging of equipment and
procedures for purging, merting,
ventilating, and flushing permit spaces.
(9) The acceptable entry conditions;
(10) The results of initial and periodic
tests performed under paragraph (d)(5)
of this section, accompanied by the
names or initials of the testers and by an
indication of when the tests were
performed,
(11) The rescue and emergency services
that can be summoned and the means
(such as the equipment to use and the
numbers to call) for summoning those
services;
(12) The communication procedures
used by authorized entrants and
attendants to maintain contact during the
entry;
(13) Equipment, such as persona)
protective equipment, testing equipment,
communications equipment, alarm
systems, and rescue equipment, to be
provided for compliance with this
section;
1910.146(0(14)
(14) Any other information whose
inclusion is necessary, given the
circumstances of the particular confined
space, in order to ensure employee
safety; and
(15) Any additional permits, such as for
hot work, that have been issued to
authorize work in the permit space.
(g) Training. (1) The employer shall
provide training so that all employees
whose work is regulated by this section
acquire the understanding, knowledge,
and skills necessary for the safe
performance of the duties assigned under
this section.
(2) Training shall be provided to each
affected employee:
(i) Before the employee is first
assigned duties under this section;
(ii) Before there is a change in assigned
duties;
(iii) Whenever there is a change in
permit space operations that presents a
hazard about which an employee has not
previously been trained;
(iv) Whenever the employer has reason
to believe either that there are deviations
from the permit space entry procedures
required by paragraph (dX3) of this
section or that there are inadequacies in
the employee's knowledge or use of
these procedures.
1910.146(g)(3)
(3) The training shall establish
employee proficiency in the duties
required by this section and shall
introduce new or revised procedures, as
necessary, for compliance with this
section.
(4) The employer shall certify that the
training required by paragraphs (g)(l)
through (gX3) of this section has been
accomplished. The certification shall
contain each employee's name, the
signatures or initials of the trainers, and
the dates of training. The certification
shall be available for inspection by
employees and their authorized
representatives.
(h) Duties of authorized entrants. The
employer shall ensure that all authorized
entrants:
(1) Know the hazards that may be faced
during entry, including information on
the mode, signs or symptoms, and
consequences of the exposure;
(2) Properly use equipment as required
by paragraph (dX4) of this section;
(3) Communicate with the attendant as
necessary to enable the attendant to
monitor entrant status and to enable the
attendant to alert entrants of the need to
evacuate the space as required by
paragraph (i)(6) of this section;
(4) Alert the attendant whenever
{i} The entrant recognizes any warning
sign or symptom of exposure to a
dangerous situation, or
{ii} The entrant detects a prohibited
condition; and
(5) Exit from the permit space as
quickly as possible whenever:
{i} An order to evacuate is given by the
attendant or the entry supervisor,
{ii} The entrant recognizes any
warning sign or symptom of exposure to
a dangerous situation,
{iii} The entrant detects a prohibited
condition, or
{iv} An evacuation alarm is activated.
(i) Duties of attendants. The employer
shall ensure that each attendant:
(1) Knows the hazards that may be
faced during entry, including information
on the mode, signs or symptoms, and
consequences of the exposure;
(2) Is aware of possible behavioral
effects of hazard exposure in authorized
entrants;
1910.146(i)(3)
(3) Continuously maintains an accurate
count of authorized entrants in the
permit space and ensures that the means
used to identify authorized entrants
under paragraph (fX4) of this section
accurately identifies who is in the permit
space;
(4) Remains outside the permit space
during entry operations until relieved by
another attendant;
NOTE: When the employer's permit
entry program allows attendant entry for
rescue, attendants may enter a permit
space to attempt a rescue if they have
been trained and equipped for rescue
operations as required by paragraph
(kXU of this section and if they have
been relieved as required by paragraph
(iX-J) of this section
(5) Communicates with authorized
entrants as necessary to monitor entrant
status and to alert entrants of the need to
evacuate the space under paragraph
(iX6) of this section;
(6) Monitors activities inside and
outside the space to determine if it is
safe for entrants to remain in the space
and orders the authorized entrants to
evacuate the permit space immediately
SHOMFM
Confined Space Entry Progum
10/96
page 3-5
-------
under any of the following conditions;
(i) If the attendant detects a prohibited
condition;
(ii) If the attendant detects the
behavioral effects of hazard exposure in
an authorized entrant;
(iii) If the attendant detects a situation
outside the space that could endanger the
authorized entrants; or
(iv) If the attendant cannot effectively
'and safely perform all the duties
required under paragraph (i) of this
section;
(7) Summon rescue and other
emergency services as soon as the
attendant determines that authorized
entrants may need assistance to escape
from permit space hazards;
(8) Takes the following actions when
unauthorized persons approach or enter a
permit space while entry is underway:
(i) Warn the unauthorized persons that
they must stay away from the permit
space;
(it) Advise the unauthorized persons
that they must exit immediately if they
have entered the permit space; and
(iii) Inform the authorized entrants and
the entry supervisor if unauthorized
persons have entered the permit space;
1910.146(i)(9)
(9) Performs non-entry rescues as
specified by the employer's rescue
procedure; and
(10) Performs no duties that might
interfere with the attendant's primary
duty to monitor and protect the
authorized entrants.
(j) Duties of entry supervisors. The
employer shall ensure that each entry
supervisor:
(1) Knows the hazards that may be
faced during entry, including information
on the mode, signs or symptoms, and
consequences of the exposure;
(2) Verifies, by checking that the
appropriate entries have been made on
the permit, that all tests specified by the
permit have been conducted and that all
procedures and equipment specified by
the permit are in place before endorsing
the permit and allowing entry to begin;
(3) Terminates the entry and cancels
the permit as required by paragraph
(eX5) of this section.
(4) Verifies that rescue services are
available and that the means for
summoning them are operable,
(5) Removes unauthorized individuals
who enter or who attempt to enter the
permit space during entry operations;
and
SHOMFM
Confined Sp*c* Entry Program
1910.1460X6)
(6) Determines, whenever
responsibility for a permit space entry
operation is transferred and at intervals
dictated by the hazards and operations
performed within the space, that entry
operations remain consistent with terms
of the entry permit and that acceptable
entry conditions are maintained, (k)
Rescue and emergency services. (I) The
following requirements apply to
employers who have employees enter
permit spaces to perform rescue services.
(i) The employer shall ensure that each
member of the rescue service is provided
with, and is trained to use properly, the
personal protective equipment and
rescue equipment necessary for making
rescues from permit spaces.
(ii) Each member of the rescue service
shall be trained to perform the assigned
rescue duties. Each member of the
rescue service shall also receive the
training required of authorized entrants
under paragraph (g) of this section.
(iii) Each member of the rescue service
shall practice making permit space
rescues at least once every 12 months, by
means of simulated rescue operations in
which they remove dummies, manikins,
or actual persons from the actual permit
spaces or from representative permit
spaces. Representative permit spaces
shall, with respect to opening size,
configuration, and accessibility, simulate
the types of permit spaces from which
rescue is to be performed.
1910.146(kXD(iv)
(iv) Each member of the rescue service
shall be trained in basic first-aid and in
cardiopulmonary resuscitation (CPR).
At least one member of the rescue
service holding current certification in
first aid and in CPR shall be available.
(2) When an employer (host employer)
arranges to have persons other than the
host employer's employees perform
permit space rescue, the host employer
shall:
(i) Inform the rescue service of the
hazards they may confront when called
on to perform rescue at the host
employer's facility, and
(ii) Provide the rescue service with
access to all permit spaces from which
rescue may be necessary so that the
rescue service can develop appropriate
rescue plans and practice rescue
operations.
(3) To facilitate non-entry rescue,
retrieval systems or methods shall be
used whenever an authorized entrant
enters a permit space, unless the
retrieval equipment would increase the
overall risk of entrv or would not
contribute to the rescue of the entrant
Retrieval systems shall meet the
following requirements.
(i) Each authorized entrant shall use a
chest or full body harness, with a
retrieval line attached at the center of
the entrant's back near shoulder level, or
above the entrant's head. Wristlets may
be used in lieu of the chest or fiiU body
harness if the employer can demonstrate
that the use of a chest or full body
harness is tnfeasible or creates a greater
hazard and that the use of wristlets is the
safest and most effective alternative.
(ii) The other end of the retrieval line
shall be attached to a mechanical device
or fixed point outside the permit space in
such a manner that rescue can begin as
soon as the rescuer becomes aware that
rescue is necessary. A mechanical
device shall be available to retrieve
personnel from vertical type permit
spaces more than 5 feet (1.52 m) deep.
(4) If an injured entrant is exposed to a
substance for which a Material Safety
Date Sheet (MSDS) or other similar
written information is required to be
kept at the worksite, that MSDS or
written information shall be made
available to the medical facility treating
the exposed entrant.
[58 FR 4549, Jan. 14, 1993; 58 FR
34845, June 29, 1993; 59 FR 26115,
May 19, 1994]
10/98
page 3-8
-------
Appendix A to §1910.146 — Permit-required
Confined Space Decision Flow Chart
Does the workplace contain confined spaces as defined by §1910.146(b)? NO •
YES '
1
Inform employees as required by §1910.146(c)(2).
1
Consult other
applicable OSHA
standards.
STOP
Will permit space be entered?
YES
I
Prevent employee entry as required by
§1910.146(c)(3). Do task from outside of space.
Will contractors enter? YES-
NO '
Task will be done by contractors' employees. Inform contractor as
required by §1910.146(c)(8)(i), (ii). and (iii). Contractor obtains
information required by §1910 146(c)(9)(i), (ii), and (iii) from host
Both contractors and host employees will enter the space? NO •*
YES '
Will host employees enter to perform
6ntfytaSkS? YES-NO
j Coordinate entry operations as required by
|§1910.146(c)(S)(iv) and (d)(11). Prevent unauthorized entry.
u
Prevent unauthorized entry. STOP
Does space have known or potential hazards? NO
Yf—;—'
Not a permit-required confined space. §1910.146 does not
apply. Consult other OSHA standards.
Can the hazards be eliminated? YES
Employer may choose to reclassify space to non-permit eTnpi
required confined space using §1910.146(c)(7). 5>mr
Can the space be maintained in a condition safe to y-^ Space may be entered under gTOP -j
enter by continuous forced air ventilation only? , \ §19l0.146(c)(5). ,
NO
Prepare for entry via permit procedures.
JL
Verify acceptable entry conditions (Test results recorded, space isolated if needed, ^
rescuers/means to summon available, entrants properly equipped, etc.). y®'
YES
Permit not valid
until conditions
meet permit
specifications.
Permit issued by authorizing signature. Acceptable '
entry conditions maintained throughout entry. y*O •
YES
Entry tasks completed. Permit returned and canceled.
I
Audit permit program and permit based on evaluation of entry
by entrants, attendants, testers and preparers, etc.
Emergency exists (prohibited
condition). Entrants evacuated, entry
aborts (Call rescuers if needed).
Permit is void. Re-evaluate program
to correct/prevent prohibited condition.
Occurrence of emergency (usually) is
proof of deficient program. No re-entry
until program (and permit) is amended.
(May require new program.)
CONTINUE
1
Spaces may have to be evacuated and re-evaluated if hazards arise during entry.
SHOMFM
Conftnad Space Entry Program
10/96
-7
-------
§1910.146 App B • Procedures for
Atmospheric Testing.
STANDARD NUMBER:
1910.146 App B
STANDARD TITLE : Procedures for
Atmospheric Testing.
SUBPART NUMBER: J
SUBPART TITLE: General
Environmental Controls
TEXT:
Atmospheric testing is required for two
distinct purposes: evaluation of the
hazards of the permit space and
verification that acceptable entry
conditions for entry into that space exist
(1) Evaluation testing. The
atmosphere of a confined space should
be analyzed using equipment of
sufficient sensitivity and specificity to
identify and evaluate any hazardous
atmospheres that may exist or arise, so
that appropriate permit entry procedures
can be developed and acceptable entry
conditions stipulated for that space.
Evaluation and interpretation of these
data, and development of the entry
procedure, should be done by, or
reviewed by, a technically qualified
professional (e.g., OSHA consultation
service, or certified' industrial hygienist,
registered safety engineer, certified
safety professional, certified marine
chemist, etc.) based on evaluation of all
serious hazards.
(2) Verification testing. The
atmosphere of a permit space which may
contain a hazardous atmosphere should
be tested for residues of all contaminants
identified by evaluation testing using
permit specified equipment to determine
that residual concentrations at the time
of testing and entry are within the range
of acceptable entry conditions. Results
of testing (i.e., actual concentration, etc.)
should be recorded on the permit in the
space provided adjacent to the stipulated
acceptable entry condition.
(3) Duration of testing. Measurement
of values for each atmospheric parameter
should be made for at least the minimum
response time of the test instrument
specified by the manufacturer.
(4) Testing stratified atmospheres.
When monitoring for entries involving a
descent into atmospheres that may be
stratified, the atmospheric envelope
should be tested a distance of
approximately 4 feet (1.22 m) in the
direction of travel and to each side. If a
sampling probe is used, the entrant's rate
of progress should be slowed to
accommodate the sampling speed and
detector response.
(5) Order of testing. A test for oxygen
is performed first because most
combustible gas meters are oxygen
dependent and will not provide reliable
readings in an oxygen deficient
atmosphere. Combustible gases are
tested for next because the threat of fire
or explosion is both more immediate and
more life threatening, in most cases,
than exposure to toxic gases and vapors.
If tests for toxic gases and vapors are
necessary, they are performed last.
[58 FR 4549, Jan. 14, 1993; 58 FR
34846, June 29, 1993]
1910.146 App C - Examples of Permit-
required Confined Spice Programs
STANDARD NUMBER:
1910.146 App C
STANDARD TITLE : Examples of
Permit-required Confined Space
Programs
SUBPART NUMBER: J
SUBPART TITLE: General
Environmental Controls
TEXT:
Example 1.
Workplace. Sewer entry.
Potential hazards. The employees could
be exposed to the following:
Engulfment.
Presence of toxic gases. Equal to or
more than 10 ppm hydrogen sulfide
measured as an 8-hour time-weighted
average. If the presence of other toxic
contaminants is suspected, specific
monitoring programs will be developed.
Presence of explosive/flammable gases.
Equal to or greater than 10% of the
lower flammable limit (LFL).
Oxygen Deficiency. A concentration of
oxygen in the atmosphere equal to or
less than 19.5% by volume.
A. ENTRY WITHOUT PERMIT/
ATTENDANT
Certification. Confined spaces may be
entered without the need for a written
permit or attendant provided that the
space can be maintained in a safe
condition for entry by mechanical
ventilation alone, as provided in
1910 146(cX5). All spaces shall be
considered permit-required confined
spaces until the pre-entry procedures
demonstrate otherwise. Any employee
required or permitted to pre-check or
enter an enclosed/confined space shall
have successfully completed, as a
minimum, the training as required by the
following sections of these procedures.
A written copy of operating and rescue
procedures as required by these
procedures shall be at the work site for
ihe duration of the job. The Confined
Space Pre-Entry Check List must be
completed by the LEAD WORKER
before entry into a confined space. This
list verifies completion of items listed
below. This check list shall be kept at
the job site for duration of the job. If
circumstances dictate an interruption in
the work, the permit space must be re-
evaluated and a new check list must be
completed.
Control of atmospheric and engulfinenl
hazards.
Pumps and Lines. All pumps and lines
which may reasonably cause
contaminants to flow into the space shall
be disconnected, blinded and locked out,
or effectively isolated by other means to
prevent development of dangerous air
contamination or engulfment Not all
laterals to sewers or storm drains require
blocking. However, where experience or
knowledge of industrial use indicates
there is a reasonable potential for
contamination of air or engulfment into
an occupied sewer, then all affected
laterals shall be blocked. If blocking
and/or isolation requires entry into the
space the provisions for entry into a
permit-required confined space must be
implemented.
Surveillance. The surrounding area shall
be surveyed to avoid hazards such
as drifting vapors from the tanks, piping,
or sewers.
Testing. The atmosphere within the
space will be tested to determine
whether dangerous air contamination
and/or oxygen deficiency exists. Detector
tubes, alarm only gas monitors and
explosion meters are examples of
monitoring equipment that may be used
to test permit space atmospheres.
Testing shall be performed by the LEAD
WORKER who has successfully
completed the Gas Detector training for
the monitor he will use. The minimum
parameters to be monitored are oxygen
deficiency, LFL, and hydrogen sulfide
concentration. A written record of the
pre-entry test results shall be made and
kept at the work site for the duration of
the job. The supervisor will certify in
writing, based upon the results of the
pre-entry testing, that all hazards have
been eliminated. Affected employees
shall be able to review the testing
results. The most hazardous conditions
shall govern when work is being
performed in two adjoining, connecting
spaces.
Entry Procedures. If there are no non-
atmospheric hazards present and if the
pre-entry tests show there is no
dangerous air contamination and/or
oxygen deficiency within the space and
there is no reason to believe that any is
likely to develop, entry into and work
within may proceed. Continuous testing
SHDMFM
Confin*a Space Entry Program
1W98
-------
of the atmosphere in the immediate
vicinity of the worker* within the space
shall be accomplished. The workers will
immediately leave the permit space
when any of the gas monitor alarm set
points are reached as defined. Workers
will not return to the area until a
SUPERVISOR who has completed the
gas detector training has used a direct
reading gas detector to evaluate the
situation and has determined that it is
safe to enter.
Rescue. Arrangements for rescue
services are not required where there is
no attendant. See the rescue portion of
section B., below, for instructions
regarding rescue planning where an
entry permit is required.
B. ENTRY PERMIT REQUIRED
Permits. Confined Space Entry Permit
All spaces shall be considered permit'
required confined spaces until the pre-
entry procedures demonstrate otherwise.
Any employee required or permitted to
pre-check or enter a permit-required
confined space shall have successfully
completed, as a minimum, the training
as required by the following sections of
these procedures. A written copy of
operating and rescue procedures as
required by these procedures shall be at
the work site for the duration of the job.
The Confined Space Entry Permit must
be completed before approval can be
given to enter a permit-required confined
space. This permit verifies completion
of items listed below. This permit shall
be kept at the job site for the duration of
the job. If circumstances cause an
interruption in the work or a change in
the alarm conditions for which entry was
approved, a new Confined Space Entry
Permit must be completed.
Control of atmospheric and engulfinent
hazards.
Surveillance. The surrounding area shall
be surveyed to avoid hazards such as
drifting vapors from tanks, piping or
sewers.
Testing. The confined space atmosphere
shall be tested to determine whether
dangerous air contamination and/or
oxygen deficiency exists. A direct
reading gas monitor shall be used.
Testing shall be performed by the
SUPERVISOR who has successfully
completed the gas detector training for
the monitor he will use. The minimum
parameters to be monitored are oxygen
deficiency, LFL and hydrogen sulfide
concentration. A written record of the
pre-entry test results shall be made and
kept at the work site for the duration of
the job. Affected employees shall be
able to review the testing results. The
most hazardous conditions shall govern
*d Soac0 Entry Program
when work is being performed in two
adjoining, connected spaces.
Space Ventilation. Mechanical
ventilation systems, where applicable,
shall be set at 100% outside air. Where
possible, open additional manholes to
increase air circulation. Use portable
blowers to augment natural circulation if
needed. After a suitable ventilating
period, repeat the testing. Entry may not
begin until testing has demonstrated that
the hazardous atmosphere has been
eliminated.
Entry Procedures. The following
procedure shall be observed under any of
the following conditions: 1.) Testing
demonstrates the existence of dangerous
or deficient conditions and additional
ventilation cannot reduce concentrations
to safe levels; 2.) The atmosphere tests
as safe but unsafe conditions can
reasonably be expected to develop; 3.)
It is not feasible to provide for ready exit
from spaces equipped with automatic
fire suppression systems and it is not
practical or safe to deactivate such
systems; or 4.) An emergency exists and
it is not feasible to wait for pre-entry
procedures to take effect. All personnel
must be trained. A self contained
breathing apparatus shall be worn by any
person entering the space. At least one
worker shall stand by the outside of the
space ready to give assistance in case of
emergency. The standby worker shall
have a self contained breathing
apparatus available for immediate use.
There shall be at least one additional
worker within sight or call of the standby
worker. Continuous powered
communications shall be maintained
between the worker within thcconfined
space and standby personnel. If at any
time there is any questionable action or
non-movement by the worker inside, a
verbal check will be made. If there is no
response, the worker will be moved
immediately. Exception: If the worker
is disabled due to falling or impact, he/
she shall not be removed from the
confined space unless there is immediate
danger to his/her life. Local fire
department rescue personnel shall be
notified immediately. The standby
worker may only enter the confined
space in case of an emergency (wearing
the self contained breathing apparatus)
and only after being relieved by another
worker. Safety belt or harness with
attached lifeline shall be used by all
workers entering the space with the free
end of the line secured outside the entry
opening. The standby worker shall
attempt to remove a disabled worker via
his lifeline before entering the space.
When practical, these spaces shall be
entered through side 'openings — those
within 3 1/2 feet (1.07 m) of the bottom.
When entry must be through a top
opening, the safety belt shall be of the
harness type that suspends a person
upright and a hoisting device or similar
apparatus shall be available for lifting
workers out of the space. In any
situation where their use may endanger
the worker, use of a hoisting device or
safety belt and attached lifeline may be
discontinued. When dangerous air
contamination is attributable to
flammable and/or explosive substances,
lighting and electrical equipment shall
be Class 1, Division 1 rated per National
Electrical Code and no ignition sources
shall be introduced into the area.
Continuous gas monitoring shall be
performed during all confined space
operations. If alarm conditions change
adversely, entry personnel shall exit the
confined space and a new confined space
permit issued.
Rescue. Call the fire department
services for rescue. Where immediate
hazards to injured personnel are present,
workers at the site shall implement
emergency procedures to fit the
situation.
Example 2.
Workplace. Meat and poultry rendering
plants.
Cookers and dryers are either batch or
continuous in their operation. Multiple
batch cookers arc operated in parallel.
When one unit of a multiple set is shut
down for repairs, means are available to
isolate that unit from the others which
remain in operation. Cookers and dryers
are horizontal, cylindrical vessels
equipped with a center, rotating shaft
and agitator paddles or discs. If the
inner shelf is jacketed, it is usually
heated with steam at pressures up to ISO
psig (1034.25 kPa). The rotating shaft
assembly of the continuous cooker or
dryer is also steam heated.
Potential Hazards. The recognized
hazards associated with cookers and
dryers are the risk that employees could
be:
1. Struck or caught by rotating agitator,
2. Engulfed in raw material or hot,
recycled fat;
3. Burned by steam from leaks into the
cooker/dryer steam jacket or the
condenser duct system if steam valves
are not properly closed and locked our,
4. Burned by contact with hot metal
surfaces, such as the agitator shaft
assembly, or inner shell of the cooker'
dryer;
5. Heat stress caused by warm
atmosphere inside cooker/dryer;
sagt 3-9
-------
6. Slipping and falling on grease in the
cooker/dryer,
7. Electrically shocked by faulty
equipment taken into the cooker/dryer,
8. Burned or overcome by fire or
products of combustion; or
9. Overcome by fumes generated by
welding or cutting done on grease
covered surfaces.
Permits. The supervisor in this case is
always present at the cooker/dryer or
other permit entry confined space when
entry is made. The supervisor must
follow the pre-entry isolation procedures
described in the entry permit in
preparing for entry, and ensure that the
protective clothing, ventilating
equipment and any other equipment
required by the permit are at the entry
site.
Control of hazards. Mechanical. Lock
out main power switch to agitator motor
at main power panel. Affix tag to the
lock to inform others that a permit entry
confined space entry is in progress.
Engulfment. Close all valves in the raw
material blow line. Secure each valve in
its closed position using chain and lock.
Attach a tag to the valve and chain
warning that a permit entry confined
space entry is in progress. The same
procedure shall be used for securing the
fat recycle valve.
Burns and heat stress. Close steam
supply valves to jacket and secure with
chains and tags. Insert solid blank at
flange in cooker vent line to condenser
manifold duct system. Vent cooker/dryer
by opening access door at discharge end
and top center door to allow natural
ventilation throughout the entry. If faster
cooling is needed, use an portable
ventilation fan to increase ventilation.
Cooling water may be circulated through
the jacket to reduce both outer and inner
surface temperatures of cooker/dryers
faster. Check air and inner surface
temperatures in cooker/dryer to assure
they are within acceptable limits before
entering, or use proper protective
clothing.
Fire and fume hazards. Careful site
preparation, such as cleaning the area
within 4 inches (10.16 cm) of all
welding or torch cutting operations, and
proper ventilation are the preferred
controls. All welding and cutting
operations shall be done in accordance
with the requirements of 29 CFR Part
1910, Subpart Q, OSHA's welding
standard. Proper ventilation may be
achieved by local exhaust ventilation, or
the use of portable ventilation fans, or a
combination of the two practices.
Electrical shock. Electrical equipment
used in cooker/dryers shall be in
SHOMFM
Confir>«d Sp*c« Entry Program
serviceable condition.
Slips and falls. Remove residual grease
before entering cooker/dryer.
Attendant. The supervisor shall be the
attendant for employees entering cooker/
dryers.
Permit. The permit shall specify how
isolation shall be done and any other
preparations needed before making
entry. This is especially important in
parallel arrangements of cooker/dryers
so that the entire operation need not be
shut down to allow safe entry into one
unit.
Rescue. When necessary, the attendant
shall call the Gre department as
previously arranged.
Example 3.
Workplace. Workplaces where tank cars,
trucks, and trailers, dry bulk tanks and
trailers, railroad tank cars, and similar
portable tanks arc fabricated or serviced.
A. During fabrication. These tanks and
dry-bulk carriers arc entered repeatedly
throughout the fabrication process.
These products are not configured
identically, but the manufacturing
processes by which they are made are
very similar.
Sources of hazards. In addition to the
mechanical hazards arising from the
risks that an entrant would be injured
due to contact with components of the
tank or the toots being used, there is also
the risk that a worker could be injured
by breathing fumes from welding
materials or mists or vapors from
materials used to coat the tank interior.
In addition, many of these vapors and
mists are flammable, so the failure to
properly ventilate a tank could lead to a
fire or explosion.
Control of hazards.
Welding. Local exhaust ventilation shall
be used to remove welding fumes once
the tank or carrier is completed to the
point that workers may enter and exit
only through a manhole. (Follow the
requirements of 29 CFR 1910, Subpart
Q, OSHA's welding standard, at all
times.) Welding gas tanks may never be
brought into a tank or carrier that is a
permit entry confined space.
Application of interior coatings/linings.
Atmospheric hazards shall be controlled
by forced air ventilation sufficient to
keep the atmospheric concentration of
flammable materials below 10% of the
lower flammable limit (LFL) (or lower
explosive limit (LEL), whichever term is
used locally). The appropriate respirators
are provided and shall be used in
addition to providing forced ventilation
if the forced ventilation docs not
maintain acceptable respiratory
conditions.
Permits. Because of the repetitive
nature of the entries in these operations,
an "Area Entry Permit" will be issued
for a I month period to cover those
production areas where tanks are
fabricated to the point that entry and exit
are made using manholes.
Authorization. Only the area supervisor
may authorize an employee to enter a
tank within the permit area. The area
supervisor must determine that
conditions in the tank trailer, dry bulk
trailer or truck, etc. meet permit
requirements before authorizing entry.
Attendant. The area supervisor shall
designate an employee to maintain
communication by employer specified
means with employees working in tanks
to ensure their safety. The attendant
may not enter any permit entry confined
space to rescue an entrant or for any
other reason, unless authorized by the
rescue procedure and, even then, only
after calling the rescue team and being
relieved by an attendant or another
worker. Communications and
observation. Communications between
attendant and entrants) shall be
maintained throughout entry. Methods
of communication that may be specified
by the permit include voice, voice
powered radio, tapping or rapping codes
on tank walls, signalling tugs on a rope,
and the attendant's observation that
work activities such as chipping,
grinding, welding, spraying, etc., which
require deliberate operator control
continue normally. These activities often
generate so much noise that the
necessary hearing protection makes
communication by voice difficult.
Rescue procedures. Acceptable rescue
procedures include entry by a team of
employee-rescuers, use of public
emergency services, and procedures for
breaching the tank. The area permit
specifies which procedures are available,
but the area supervisor makes the final
decision based on circumstances.
(Certain injuries may make it necessary
to breach the tank to remove a person
rather than risk additional injury by
removal through an existing manhole.
However, the supervisor must ensure
that no breaching procedure used for
rescue would violate terms of the entry
permit. For instance, if the tank must be
breached by cutting with a torch, the
tank surfaces to be cut must be free of
volatile or combustible coatings within 4
inches (10.16 cm) of the cutting line and
the atmosphere within the tank must be
below the LFL
Retrieval line and harnesses. The
retrieval lines and harnesses generally
required under this standard are usually
-------
impractical for use in tanks because the
internal configuration of the tanks and
their interior baffles and other structures
would prevent rescuers from hauling out
injured entrants. However, unless the
rescue procedure calls for breaching the
tank for rescue, the rescue team shall be
trained in the use of retrieval lines and
harnesses for removing injured
employees through manholes.
B. Repair or service of "used" tanks and
bulk trailers.
Sources of hazards. In addition to facing
the potential hazards encountered in
fabrication or manufacturing, tanks or
trailers which have been in service may
contain residues of dangerous materials,
whether left over from the transportation
of hazardous cargoes or generated by
chemical or bacterial action on residues
of non-hazardous cargoes.
Control of atmospheric hazards. A
"used" tank shall be brought into areas
where tank entry is authorized only after
the tank has been emptied, cleansed
(without employee entry) of any
residues, and purged of any potential
atmospheric hazards.
Welding. In addition to tank cleaning for
control of atmospheric hazards, coating
and surface materials shall be removed 4
inches (10.16 cm) or more from any
surface area where welding or other
torch work will be done and care taken
that the atmosphere within the tank
remains well below the LFL. (Follow the
requirements of 29 CFR 1910, Subpart
Q, OSHA's welding standard, at all
times.)
Permits. An entry permit valid for up to
1 year shall be issued prior to
authorization of entry into used tank
trailers, dry bulk trailers or trucks. In
addition to the pre-cntry cleaning
requirement, this permit shall require
the employee safeguards specified for
new tank fabrication or construction
permit areas.
Authorization. Only the area supervisor
may authorize an employee to enter a
tank trailer, dry bulk trailer or truck
within the permit area. The area
supervisor must determine that the entry
permit requirements have been met
before authorizing entry.
SHDMFM - -
Confined Space Eniry Pfos'am P*S» B-11
-------
Appendix D-1A
Confined Space Pre-entry Checklist
See Safety Procedure.
A confined space is entered through an opening other than a door (such as a manhole or a side port) or
requires the use of a ladder or rungs to reach the working level. Testing should be done to determine
whether atmospheric concentrations are satisfactory. This checklist must be filled out whenever the job
site meets these criteria.
Yes No
1. Does your survey of the surrounding area show it to be free of hazards such as ( ) ( )
drifting vapors from tanks, piping, or sewers?
2. Does your knowledge of industrial or other discharges indicate that this area is ( ) ( )
likely to remain free of dangerous air contaminants while occupied?
3. Are you certified in the operation of the gas monitor to be used? ( ) ( )
4. Has a gas monitor functional test (Bump Test) been performed during this shift ( ) ( )
on the gas monitor to be used?
5. Did you test the atmosphere of the confined space prior to entry? ( ) ( )
6. Did the atmosphere check as acceptable (no alarms given)? ( ) ( )
7. Will the atmosphere be continuously monitored while the space is occupied? ( ) ( )
Contact County Centrex for personnel rescue by the local fire department in the ( ) ( )
event of an emergency. If onsite at the Regional Treatment Plant, contact the Plant
Control Center (PCC).
Notice: If any of the above questions are answered "no," do not enter.
Contact your immediate supervisor.
Job Location
Lead Person Signature
Date
SHOMFM
Confined Sp*c« Ent
icvea
« S-12
-------
o
Z
£
*4
•a
y 1
"|
per
r
« tr
d bac
eted
•8
O^Jp^ - *> « ~
,
!i*m
SHDMFM
Cocf>n«d Spaca Entry Program
'S3
e
t
c
S
p«g* B-13
-------
O
Ed
H
Ed
cu
O
U
M
ffl
O
"3
J
Z
< 3
Is
00 "«
=> CQ
r> o
ENTRY PERMIT
) SPAPP UA7ADPW
L_
r»
k^
- ""»»»-'-• — — ILTUUniVU*
PERMIT WILL REMAIN AT J(
6fa
! n
11
j*— » MM
Oa-
C-
Q
X
"2
1
c.
OURS ONLY. ALL CO!
CRIPTION
£
u
U
0
u
^
3
s
PERMIT VALID FOR 8 H
SITE LOCATION and DESi
PURPOSE OF ENTRY
SUPERVISOR(S) in charge
u
1
«
> u
H fe
Z Q
Ed
O
P""11
OS
o
1
o
_Q.
CO
O
X
£31 >
Bg.?5 ^ 1
> S c > 9.« >
§IM ? II g
o8^« i £t §
15 minutes.
longer with appropriate respiratory
+3
M _
iS^gg^s
is'^ul
^gl^-i!;
.£§£^25?
< >, G r
* BOLD DENOTES MINI
REQUIREMENTS COMPL
Lock Out/De-energize/Try-
Line(s) Broken-Capped-Bk
Purge-Flush and Vent
Ventilation
IE cu a,
S 'e^0- fl-
— ^2 o <^i
+ 52-+ +
II
-g|
C
w 3
ll
f*
|u
fi ,ll gzis« 11
IgSiS |Sg3|g ||
«ij*4 Igglllfl. 15
flit! }!-
i|!i-s illllllpMffl
isl|l ow id o < s'S.'l.i |« «> w
M CO OS OT Z U H a. J U < X Z crt < • +2
t>
<
^1
*•
oo
f
V
T
5s
C*2
I/
r
%
b
tti
1
••S
2
00
(
t
O U
> §
(U CJ
11
i"
?l
; «
3 v
|£
jl
) C.
u, O a
u
2
CO
^H .^
W S
USED MODEL &/OR TYPE
_^^
'£•
z
*-ri
'CHECKS INSTRU1V
a
Z
<
IX
I
u
&
'J3
C/3
<
a
S REQUIRED FOR ALL CONFIN
OF SAFETY STANDBY PERSON
Ul
f^t ^^
||
*"
O « 4
o '5
IS
<
§
a.
2
LLl
i
a
SHOWFM
Confin«d SD»C* Entry Ptografti
-------
1910.146 App E - Sewer System Entry.
STANDARD NUMBER:
1910.146 App E
STANDARD TITLE : Sewer System
Entry.
SUBPART NUMBER: J
SUBPART TITLE: General
Environmental Controls
TEXT:
Sewer entry differs in three vital
respects from other permit entries; first,
there rarely exists any way to completely
isolate the space (a section of a
continuous system) to be entered;
second, because isolation is not
complete, the atmosphere may suddenly
and unprcdictably become lethally
hazardous (toxic, flammable or
explosive) from causes beyond the
control of the entrant or employer, and
third, experienced sewer workers are
especially knowledgeable in entry and
work in their permit spaces because of
their frequent entries. Unlike other
employments where permit space entry
is a rare and exceptional event, sewer
workers' usual work environment is a
permit space.
(1) Adherence to procedure. The
employer should designate as entrants
only employees who are thoroughly
trained in the employer's sewer entry
procedures and who demonstrate that
they follow these entry procedures
exactly as prescribed when performing
sewer entries.
(2) Atmospheric monitoring. Entrants
should be trained in the use of, and be
equipped with, atmospheric monitoring
equipment which sounds an audible
alarm, in addition to its visual readout,
whenever one of the following
conditions are encountered: Oxygen
concentration less than 19.5 percent;
flammable gas or vapor at 10 percent or
more of the lower flammable limit
(LFL); or hydrogen sulflde or carbon
monoxide at or above 10 ppm or 35 ppm,
respectively, measured as an 8-hour
time-weighted average. Atmospheric
monitoring equipment needs to be
calibrated according to the
manufacturer's instructions. The oxygen
sensor/broad range sensor is best suited
for initial use in situations where the
actual or potential contaminants have not
been identified, because broad range
sensors, unlike substance-specific
sensors, enable employers to obtain an
overall reading of the hydrocarbons
(flammables) present in the space.
However, such sensors only indicate that
a hazardous threshold of a class of
chemicals has been exceeded. They do
not measure the levels of contamination
of specific substances. Therefore,
substance-specific devices, which
measure the actual levels of specific
substances, are best suited for use where
actual and potential contaminants have
been idenlifted. The measurements
obtained with substance-specific devices
arc of vital importance to the employer
when decisions are made concerning the
measures necessary to protect entrants
(such as ventilation or personal
protective equipment) and the setting
and attainment of appropriate entry
conditions. However, the sewer
environment may suddenly and
unpredictably change, and the substance-
specific devices may not detect the
potentially lethal atmospheric hazards
which may enter the sewer environment
Although OSHA considers the
information and guidance provided
above to be appropriate and useful in
most sewer entry situations, the Agency
emphasizes that each employer must
consider the unique circumstances,
including the predictability of the
atmosphere, of the sewer permit spaces
in the employer's workplace in preparing
for entry. Only the employer can decide,
based upon his or her knowledge of, and
experience with permit spaces in sewer
systems, what the best type of testing
instrument may be for any specific entry
operation. The selected testing
instrument should be carried and used by
the entrant in sewer line work to monitor
the atmosphere in the entrant's
environment, and in advance of the
entrant's direction of movement, to warn
the entrant of any deterioration in
atmospheric conditions. Where several
entrants are working together in the
same immediate location, one
instrument, used by the lead entrant, is
acceptable.
(3) Surge flow and flooding. Sewer
crews should develop and maintain
liaison, to the extent possible, with the
local weather bureau and fire and
emergency services in their area so that
sewer work may be delayed or
interrupted and entrants withdrawn
whenever sewer lines might be suddenly
Hooded by rain or fire suppression
activities, or whenever flammable or
other hazardous materials are released
into sewers during emergencies by
industrial or transportation accidents.
(4) Special Equipment. Entry into
large bore sewers may require the use of
special equipment. Such equipment
might include such items as atmosphere
monitoring devices with automatic
audible alarms, escape self-contained
breathing apparatus (ESCBA) with at
least 10 minute air supply (or other
NIOSH approved self-rescuer), and
waterproof flashlights, and may also
include boats and rafts, radios and rape
stand-offs for pulling around bends and
corners as needed.
[58 FR 4549, Jan. 14, 1993; 58 FR
34845, June 29, 1993; 59 FR 26115,
May 19, 1994]
SHDMFM
Confined Space Enliy Program
1IV96
pa a« 8-15
-------
-------
SPILL CONTAINMENT PROGRAM
-------
-------
Spill
Containment
Program
TP-l
Module Goals:
The student goals for this module are:
I. Given 29 CFR 1910.120(j), identify the general requirements of a spill containment program to be
used on a hazardous waste she.
2. Given the Comprehensive Environmental Response, Compensation and Liability Act of 1980
(CERCLA), the Superfund Amendments and Reauthorization Act of 1986 (SARA) Title HI, and
excerpts from 40 CFR 302 and 355, identify spill reporting requirements for hazardous waste
operations and emergency response.
SMDMFM
Spill Containment Program
1098
p«8«1t.2
-------
Given 29 CFR 1910.120Q, identify the general requirements of a spill containment program
to be used on a given waste site.
Spill Containment Program Considerations
Drum and
handling
of drums and containers
Material handling
wastes
-sensitive wastes
Laboratory
packs
of drum or container contents
and transport of drums or containers
Appropriate.
.for tank and vault entry
TP-2
SMOMFM
SpiH Contawmant Program
1008
fmgall-3
-------
Given 29 CFR 1910.120(j), describe the general requirements for container handling at
waste sites to reduce the incidence of spills.
Container Handling
Use U.S. Department of Transportation (DOT)
approved salvage drums
Have adequate proper absorbents present
where spills, leaks, or ruptures may occur
If there is a major spill potential, a program
should be in place to isolate and contain the
entire volume of the hazardous substance
being transferred
TP-3
SMOMFM
Spill Containment Pnjgnm r
-------
Given CERCLA, SARA Title III, and excerpts from 40 CFR 302 and 355, identify spill
reporting requirements for hazardous waste operations and emergency response.
Reporting of Spills or Releases
TP-4
SHOMfM
SpMI ConUminent Ptx>gf>m
1WS
-------
Given CERCLA Section 103, define a reportable spill of hazardous wastes or substances.
Reportable Spill
Section 103
.of any hazardous substance in
quantities equal to or greater than the
reportable quantities (RQs) found in
Section 102, CERCLA.
Adapted from: CERCLA Section 103
TP-5
SHDMFM
Spill Containment Program
pae.11-8
-------
Given CERCLA, SARA Title ID, and excerpts from 40 CFR 302 and 355, list the requirements
of reporting spilled hazardous wastes and substances.
Spill Reporting Regulations
SARA Title HI
Immediate notification of release to the Local Emergency
Planning Committee (LEPC) and the State Emergency
Response Commission (SERC):
• Extremely hazardous substances (EHSs) released
equal to or greater than their RQs
• Codified 40 CFR 355 — Extremely Hazardous
Substances
Immediate notification of release to LEPC, SERC and
National Response Center (NRC):
• Hazardous substance released equal to or greater than
itsRQ
• Codified 40 CFR 302 — Hazardous Substances and
Reportable Quantities
CERCLA 103
Immediate notification of release to NRC:
• Hazardous substance released equal to or greater than
itsRQ
• Codified 40 CFR 302 — Hazardous Substances and
Reportable Quantities
• Some substances are found on both tables and are
subject to notification of LEPC, SERC, and NRC
Source: 40 CFR 302.8, 40 CFR 355.40, and Title 111 Fact Sheet EPA 550-F-93-002 TP-6
SHOMFM
Spill Containm
-------
Given CERCLA 103 and SARA Title HI:
• List the similarities between the reporting requirements of each.
• List the differences between the reporting requirements of each.
Release Reporting
40 CFR 302.4 material released on site, equal to or
greater than RQ, leaves site boundaries:
- CERCLA 103 — ________
- SARA Title III—
40 CFR 355 material released onsite, equal to or
greater than RQ, leaves site boundaries:
- CERCLA 103 —
- SARA Title III —
Either 40 CFR 302.4 or 40 CFR 355 material released
onsite, below RQ:
- CERCLA 103 —
- SARA Title III —
TP-7
SHOMFM 1?f"
Spill Cont»mm«nl Pragrim P"0»»'«
-------
The Blue Ridge Chemical Facility
Drum
storage
.area
1846
Carbon
tetrachloride
N
Plant
iO OO
—!O OO
O O OO
o o oo
O O OO
O O OO
O O OO
Tank farm
Site Data
Temperature
Humidity
Barometric Pressure
Wind Speed
Wind Direction
Skies
70°F
50%
29.92 S
lOmph
NNEtoSW
Sunny
Considerations for a Spill Containment Program
SHDMFM
Spill Containment Program
-------
Conclusion
Confined Space Entry Program
Spill Containment Program
Emergency Response Plans
TP-8
Across
29. A spill
Down
Crossword Puzzle
program is a required part of a site-specific health and safety plan
4. Spill requirements for extremely hazardous substances can be found in SARA Title HI,
Section 304
SH0MFM
Spill Containment Program
10C8
>11-10
-------
-------
APPENDIX
Summary of Notification Requirements Matrix
-------
-------
SUMMARY OF NOTIFICATION REQUIREMENTS MATRIX
Several different regulations implement the CERCLA and CWA requirements that hazardous substance
releases and oil discharges be reported to the NRC [33 CFR Parts 153.101, 153.203; 40 CFR Parts
110.10, 117.21, 300.125, 300.170, 300.300, 300.405, 302.6, 302.8]. Other federal reporting
requirements include the following:
REQUIREMENTS TO NOTIFY STATE AND LOCAL AUTHORITIES BASED ON
STATUTORY PROVISIONS - A "one-call" system cannot be implemented by a rule change
* A release of a specific hazardous substance, such as cadmium metal, is reported to the Local
Emergency Planning Committee (LEPC) and the State Emergency Response Commission (SERC)
[29CFRParts 1915.1027, 1926.1127, 1928.1027, 1928; 40 CFR Part 355.40].
REQUIREMENTS DEALING SPECIFICALLY WITH OIL OR HAZARDOUS SUBSTANCE
SPILLS - Other Federal agencies may be notified in addition to the NRC
• Outer continental shelf oil spills are reported to the Department of Interior's Minerals Management
Service (MMS) District Supervisor and the MMS Director [30 CFR Parts 250.42, 282.27];
Suspected or actual releases of a hazardous substance or oil from an UST is reported to EPA or
approved State UST Program [40 CFR Parts 280.40, 280.50, 280.53, 280.61, 280.110, 280.230];
• Oil spills on the Ohio River, the Mississippi River above Cairo, IL, and their tributaries are reported
to the nearest lock downstream [33 CFR 207.300];
• Vessel or waterfront facility spills of oil or a hazardous substance are reported to the USCG and/or
the Captain of the Port [3 3 CFR Parts 126.29, 127.321, 135.305, 151.15, 151.26, 151.45, 156.200,
158.167, 160.215; 30 CFR Part 250.42; 49 CFR Part 176.156]; and
• Breakage, spillage, or suspected radioactive contamination involving Class 7 materials shipments is
reported to the Regional Office of DOE [49 CFR Part 175.700].
REQUIREMENTS DEALING WITH RELEASES - Notification to the NRC may sometimes be
required
• Permit violations (e.g., for the NPDES program) are reported to the regulatory authority [30 CFR
Parts 715.17, 717.17, 817.41];
• Incidents involving air, rail, highway, or water transportation are reported to the Department of
Transportation [40 CFR Parts 263.30, 279.43, 49 CFR Part 171.15];
• Incidents involving hazardous materials carried by aircraft are reported to the nearest FAA Civil
Aviation Security Office [49 CFR Part 175.45]; and
* Incidents involving etiologic agents transported over land or by aircraft are reported to the Center for
Disease Control (CDC) [49 CFR Parts 175.45, 171.15].
REQUIREMENTS DEALING WITH ACCIDENTS THAT MAY INVOLVE A RELEASE
• General facility emergency situations are reported to the OSC [40 CFR Parts 264.56, 265.56]; and
Work-related emergencies and incidents are reported to the OSHA Area Director [29 CFR Parts
1904.8, 1910.1003-1017, 1910.1045],
10/96
Spi;i Cont
-------
REQUIREMENTS FOR OTHER NRC NOTIFICATION
• Generators of hazardous waste must report fires, explosions, or other releases, in addition to spills
which have reached the surface water, to the NRC [40 CFR Parts 262.34, 307.22];
• The local government may inform the NRC within 24 hours of response in order to request
reimbursement for their response efforts [40 CFR Part 310.30]; and
• Operators of pipeline systems must give notice of a release of hazardous liquid or carbon dioxide that
is being transported and has resulted in an incident [49 CFR Part 195.52].
SHOMFM
SpM Conulnmcnt Pragtmm
10190
pas« A-2
-------
1
A
S
CA
O
•E
3
I
42
e
cr
a>
Ofi
o
a.
rt
B
O
SHDMFM
SpiH Containment Program
Description
**• .S
S9l
W
™* VpM
fc, 3
I***
•5
B
*N
"3
i*
•3 o
e >
^ «
£-2
^
B
Ed
S
o
"^2
J5
"3
u
OS
tn
B
M
B
"•C
*»
B
1
2
!
IT
5
cc
^3
B
e>
3
U
o
1
OS
u
psl
Requires that an employer report any death of
an employee or hospitalization of three or
more employees resulting from a work-related
incident.
>,
1
1
00
a
•s
i
2
8
5
3
V.
<
•<
CO
O
CO
g °
£ s
cs Ou
Requires the reporting of incidents which
result in the release of the specified carcinogen
into any area where employees may potentially
be exposed.
1
'3
8.
V)
I
E/l
1
^J
c:
2
1
5
1
5
S
c
<
<
X
o
o
(A
'yz
— ;
O
S ^
u g
^v ^3
rs CL.
1
I
3
*cL
.1
1
1
'G
8-
1
o
[^
_e
'I
o
'Q
S
!•*
<
<
ac
CO
O
«/i
^j>
o
0
g E
TM
* <9
cs D-
Requires that the employer comply with EPA
rules regarding the cleanup of toxic waste and
notify state and local authorities, if required,
or the National Response Center (NRC) if it is
a CERCLA hazardous substance and the spill
is equal or greater than 1,000 Ib/day.
1
'o
8.
O X
g^^S'cSs'c
^C 8. t; O.-— p 8.
S S. <£. < & £ <*
Requires that a release equal to or greater
than the reportable quantity (RQ) for the
substance be reported in accordance with
SARA.
g
0.
u
"5
t
(9
'"8
%/
•i
u
W) *
.s « •§
C (Q 00
G* cu o« UJ
C [Tl K CO
*> U >^ O
2 o u '55
si &1
« c 5 ss
S£ H
r-" r-" r-"
(N es cs
2 oa r m 2 en
«S x so" x oo' S eo" x
u. 2 g 2 g 2 g^S g
?J £ < £ < ££ £ <
ttvee
gram l>»9« *-3
-------
e
o
ja
w
8
O
e
<- 0
O '.£
t »— «
li
Z
j*^
.2
•3
V
E
J
"ci
3
;?£*
•3 "5
jS Z
^> o
u
c
.0
«
s
W)
r>»
M
C
s
"a
ff
K
1
CO
j
|
Q
Ov
OS °'
I. •
Is
o
3
<£
-«>"•
<9
J~ rt
— e
^
S
e
§•
•n*
5
.a
Q
)
^"
a; ®
A. (S
^J c
^5
Requires that lessees report nonroutine
hydrogen sulfide releases which result in an
atmospheric concentration of 20 parts per
million (ppm) and 50 ppm levels. The lessee
is required to develop an Oil Spill Contingency
Plan with procedures for notification of an oil
spill.
•8
£*
1
VI
3
e
-^
"3
.E
O
3
•a
CS
^
J^
*
cs
rr
ON VH
U- N
^J c
S£
Requires that lessees notify the Director when
there is a death or serious injury, fire,
explosion, or other hazardous event which
threatens damage to life, a mineral deposit, or
equipment, spills of oil, chemical reagents, or
other liquid pollutants which could cause
pollution; or damage to aquatic life or the
environment.
"8
IS
1
w>
O
C
^
"5
'•&
Q
e
0
u
Q
r-
oi 3
i.
1
3
TO
0
^
00
t^
U
~
r- r~ —
— ^ — •» ^
oi 12 i ci i
It r- r- so
° c c r
CD CQ ^ R)
m 0. Ou O.
Requires reporting of a potential hazard
concerning a coal mine waste disposal facility
and of the emergency procedures formulated
for public protection and remedial action
(refers to coal mine waste).
"8
t^
'S
§—
>>
a.
E
o
e>
1
3
03
O
00
fc-
u
~
_^ _«
SO 90
^j. *o r^*
a — — i
U- 3O 00
^ t? ti
O CQ
-------
G
J
1
Q
e
u. o
O ',3
el
£ ~
t**
u
.3
^
S
E
*^
_—
«
a
*> «i*
T3 0
S jr
^^ o
**
e
s
•2
j3
3
on
.^.
B
e
0
J3
"3
M
V
Cfi
•g
08
r »»
«
09
9
0
S
cs
•»
•£
'S
5
i
u,
U
f)
f^
•a
Requires an owner/operator of the vessel or
waterfront facility to report a discharge of
petroleum by-products or other dangerous
liquid commodities which may create a haza
or toxic condition in the port area of U.S.
waters.
1
1
V)
o
S
,>»
Is
1
S
E
.
g^
PH
O
^ «
o c
^ g
•£ 6
"o u
11
&.S5
U Q
Ov
fN
SO
tt ^^
(_> —
m «s
r^ CU
«2 3 s «
Requires reporting by the person in charge o
vessel or offshore facility that is involved in ,
incident, including occurrences which pose i
imminent threat of oil or hazardous substanc
pollution.
1
2
w*
ki
o
J
Q.
u
—
e
o
M
J«
a ^
•^ 1 °
S J? -I1 -
"S « •§ S
6 5 o •"
.1 S ^ .S
o
o
U
o) O w^ O vi *N
f^ fr^ P..M fS^ -^ fS
r*- *o — — — * ss
^ tmm, _| «_4 «_• _• 1— -.
u C C C C C C
S <£(£<£ <£ £ £
E
Requires the person in charge to report any
discharge of oil or a hazardous substance fro
a vessel or facility in violation of section
3 1 l(b)(3) of the Clean Water Act (CWA).
1
1
C/l
0
a
•77
U
1
E
S
U u
-. s
U* b$
2 c
.3 §
o Si
o-o U
fe ^^
- 0 2
5&i.I
0 3 "B
III
,0
O "J "S" O
- a o
ft,, •M 4> O .^
O c y S -.
S <£ 3r § £
states that any person may report that
reception facilities required by MARPOL
73/78 are inadequate.
i^
o
00
• S
el
g-
— i "y
kri >-,
0 ^
1
1,
Ul
0
&
8
so
^j OC
[f t ,™H
" S
a
Requires that the owner, agent, master,
operator, or person in charge to report when
there is a hazardous condition either aboard .
vessel or caused by a vessel or its operation.
"8
S
8.
vt
O
,>.
-------
B
.2
"•S
Q.
•c
w
S
o
«« o
o'S
Eoj
u
11
Z
IT
a
1
E
E
^
^
a
"2 SK
St
"3 e
£z
^a
£~
Ed
e
.2
•*»
OS
3
0£
V
(V1
M<
w
1
£
u
o
^p
Requires that the owner or operator repon any
venting of coke oven gas through a bypass/
bleeder stack that was not vented through the
bypass/bleeder stack flare system.
•g
IT"
13
8.
5»
5
J c
•S 5
<_, >
0 u
eo S
5 ~
2*
— eo
S-g
e S
2-1
'5.8
0
1
{/>
;§
T>
<
^^
•"
OS <*)'
U. \O
U t;
O <3
•* a.
Requires that any person in charge of a vessel
or an onshore or offshore facility must repon
any discharge of oil.
S
o
1
32
_>»
u
.S3
E
E
O
O"
1
G CJ
O.SS
^S
= e£
!a w
3 0
*o
y y
^ 00
2 3
o
« 2
it, —
<-> c
o ™
^ CL
Requires that any person in charge of 3 vessel
or an onshore or offshore facility must report
any discharge of a designated hazardous
substance in quantities equal to or exceeding
in any 24-hour period the reportable quantity.
References 33 CFR 153.203.
^3
I ^
*"H
i
VI
a
JS1
4>
ffl
1
e
Cfl
3
u_
o
ft>
g
M
uti
«
u S
« s
•c E
§• e
t: u
ra oo
^^
«N
B: ^
Ci. —
u c
O C3
^ cu
Requires that the permittee repon any
noncompliance with the NPDES permit which
may endanger health or the environment,
>^
CO
M
0
V)
k?
1
S 1 -^ S M
§ 1 JS? 3
35 ^^ U ^*
« S o e g
C
O «
^f CL
Requires that the supplier of water must report
the results of any test measurement or analysis
required by this part.
•8
•3
8.
K>
O
S,
•3
o
«— 1
_g
15
'*
o
3
M
^^^
P3
*»«
(•1
OS ?
0, —
w c
o «
TJ- a,
SHOMFM
Spill CanUinm«n< Progtim
10(96
pagft A-6
-------
e
e
•g
w
Q
e
IM O
o *j3
E S
ta'-g
«
•S
V
E
E
^
"as
s
*> £*
"5 ~
s 2
55
•••*
B
w
B
•,5
JO
"3
CJD
a!
«
M
,2
3
a
0>
Oil
U
W>
e
I
ft,
<*•»
V
i
e
B
U
i
— >
b
U
o
Requires that the supplier of water must report
the failure to comply with any national
primary dhnking water regulation (including
failure to comply with monitoring
requirements) set forth in this part.
"S
S
o
!
o
2
00
e
'S
1
U
i
•5*
^
rn
ai ^
u. •-
t
"* °~
Recommends reporting any accidental spill
during solid waste processing operations.
•8
S
(j
£
U]
O
t
1
.i
^
g
oo
£,
o
1
s
13
5
*"?
o
fM
*3
U, »'c
oj "° §
[r^ T3 ^j
°-| 3
? 8"§
5"^ ^
13 H 'b"
.^ o *-.
§-es
*" ® r~<
o —- u
IS$
^3
en r\
gS c
^ C J3
O C9 3
^ a. on
Requires the emergency coordinator to report
whenever there is an imminent or actual
emergency situation (i.c., release, fire,
explosion which could threaten human health
or the environment) involving a hazardous
waste.
U
B
O
"1
73
is1
"S
g
•-
_
0 .g
"™ 8
o c
v ,y>
« n.
1
"« '53
6"«
o «-
° 'u
O g
Z ea
s£> \O
V^ *A
_,•*«-!
H, ^^j x^
X
-------
j
1
«!
U
fi
e
V. 0
a '.s
*•• *rf
e S
B <•>
e>£
fci
^^
25
>>
w
.2
•3
V
E
E
**
"at
mm
2>»
> fe
11
£2
"•5
U
s
^o
•M
_«
3
Ml
^
OS
C?
i
M
.S
5
"3
toft
M
V
PS
•w^
5*
u
efi
e
.0
•*••
^
V
I
0«
"3
*l
Or
E
s
S
w
1
tf
b
U
0
•^r
Requires that any release of a hazardous waste
to the environment be reported, except if the
release is less than or equal to one pound and
is immediately contained and cleaned up, must
be reported.
•8
1
1
u>
•*
O
2
*t
r*
et
S
"§
s s
l- O
sr
II
1 ?
"3 •— /-y
^H ^^ JS
g " **
0 0 «
•a 5 -s
4J "ta <-
C6 ••* u
< U a
S Pi U
PJ Z ao
\o
Ov
I—I
a: 3
u. S
e
O !fl
•» cu
Requires reporting of a leak or spill of
hazardous waste that is greater than or
equal to a quantity of one pound or the release
of any rcpottable quantity to the Regional
Administrator within 24 hours of detection or
in accordance with 40 CFR 302.
•S
S
£
v>
1
s
1
•i
CD
S
o
£3
1
*t
i
£
y
c
V
a*
1
A)
i
•§
C4
S
<3
£
90
« >
U
ca
1?
U
E
O
a:
Z
fl
TT
as?
Lu CN
n
O «
•<»• 0.
SHOMFM -- 10S8
Spiii Conta-,nrr«nt Program paQ* *-8
-------
S
jj
U
M
Q
e
t» 0
o 'S
E S
5 t=
0 Sj
2
^
(8
1
E
E
M
^
">£
1 ®
£ Z
^^
£* 2
•^
M
"
e
.2
"«
^^
3
2?
Qi
e
w
e
"s
^
Ml
ON
u
C
Ml
C
H
£
ironmenta
1
i
OS
EC,
1
^
immediate
H
^ u
11
V 00
•g «9
'o. 3 "o
o 5 }j
Q. b< C
S o „
^« *^ a.
^ 3 ~
« *°_ ^
CJ Q" .w
ioi
c^
IO
Qj r^'
U. {N
a C
^5 ! 1^
illi!
"S I a s s
&
ei
m
00
c
c
u
a.
J
o"
10 UJ
a: g c
U.
O
^—
iff
s s
O
•—*
**
c^ i
.14 C*"4
^ C
O w(
^ Q"
1O96
Spill Conlammanl Prosf»9* **®
-------
Description
e
«» e
o *,3
E5
£«
u1
S
•3
H
S
3
•2 >,
> Js
'"i *
g* Z
•fr®
e
e
I
"3
04
44
*
M
C
"a
w
&
V
Ul
rotection
PN
^
C
§
c
2
w
1
£
U
o
Is
The owner or operator is required to re
suspected releases from a UST system
implementing agency.
•8
S
I
V)
1
1
1
Q
c
>•»
g
1
W)
•S
e
_u
o
C4
pi S
tx* csi
CJ c
o «
5- a.
g
en S tS f*i
.** — < *1 fl
Notice of an oil discharge or release of
hazardous substance in a amount equa
greater than the reportable quantity mi
made immediately in accordance with
153, Subpart B, and 40 CFR 302.
S
B
"1
a
.>.
i
=8
2
***
,
.2
E
g
„
u"
1
tu
S8
^ Sj
J °
ll
8
fl
o"
™" >«5
X m
w c
CS Cfl
"* ^
u§
PB!
discharge of a hazardous substance fro
vessel or facility that is in violation of
3ll(b)(3)oftheCWA.
Q
C
Cfl
^
H)
Cfl
> ..
"u o
Requires the OSC to report when they
a report of a discharge which is an acn
potential major discharge.
1
'o
8.
u>
O
_>,
7s
•§
^
• —
1
S
1
o
f^J
al 8
i_tn r*^
Im
O ^1
-,
I
W
O-
J
1
•a
§ u
§0
§ •<
w gj
5 °
il
u-\
O
^
oi g
Lk f**i
kM
^5 (^
1- 0,
SHDMFM
Spitt Containmant Pr
1CUS6
10
-------
c
J
ti
Q
e
«~ o
s'"
F iM
si
2
u1
.3
1
"S
1^
Is!
iS 2
>•» ®
•j
e
c
«
"s
no
*j
™
t*'
*
(
b
I
J
e
^
i
0
>i
4
e
1
"S
s
E
e
2
c
1
g
U
o
Any person in charge of a vessel or an offshore
or onshore facility shall, as soon as he has
knowledge of any release of a hazardous
substance from such vessel or facility in a
quantity equal to or exceeding the reportable
quantity in any 24-hour period, must
immediately notify the NRC.
"S
S
1L
^
§
.2
6
U
£fi
^G
. cs
£ S
w c
For continuous releases of a hazardous
substance, the person in charge must make an
initial telephone call and report the release to
the NRC for a period sufficient to establish the
continuity and stability of the release.
2
G
CL
ii
1
+iri
U
Q5
oo
csj
S S
L) ^
5 £
Requires the person to notify the NRC if there
is acute threat of fire, explosion, or direct
human contact with hazardous substances,
pollutants, or contaminants or other emergency
situation, to determine if there is sufficient time
to submit an application for preauthorization.
"8
c
i
V)
1
1
I
U
oS
fN
r-J
. t-^
U. S
U c
§£
The local government must inform EPA or the
NRC within 24 hours of response in order to
request reimbursement for their response
efforts.
1
§.
1 f
o
•s
\l
ll
^
0.
o
u
oi
Z
0
, o
U. m
;3 x ^0 *S
K o ^
•Z at 2
-------
•S
u
B
u. e
o *c
E S
41
tf
a
fi
i
fa
U
g
o
ft
h g. o
iS S "3
§ 8*
o U "3
oi ?r
u "Z
£>
&a
il
s s a I
e c« « .S
"8
1C
'o
2L
o
lib IT
•« .
I
if}
U ^^" *•
-------
•3
'"
Spill Containm«nt Profiram
10/96
pageA-13
-------
-------
EMERGENCY RESPONSE PLANS
-------
-------
Emergency
Response
Plans
TP-l
Module Goals:
The student goals for this module are:
1. Given 29 CFR 1910.120, 29 CFR 1910.38, the emergency action plan (EAP) regulation, and
conditions on a hazardous waste site, identify the components necessary to complete an emergency
response plan (ERP) to ensure worker protection at a hazardous waste site.
2. Given conditions on a hazardous waste site, identify the Superfund Amendments and Reauthorization
Act of 1986 (SARA) Title III planning requirements as they apply to hazardous waste operations and
worker protection.
SHOMFM
Emergency Raiponi* Plans
10*8
1.12-2
-------
Given 29 CFR 1910.120, list the paragraphs that apply to emergency response planning.
Emergency Response Planning
Paragraph (I)
Emergency Response by Employees at Uncontrolled
Hazardous Waste Sites
Paragraph (p)
Certain Operations Conducted under the Resource
Conservation and Recovery Act of 1976 (RCRA)
Paragraph (q)
Emergency Response to Hazardous Substance Releases
TP-2
SHOMFM
1096
(•12-3
-------
Definition of EAR
Designated
that employers and
employees must take to ensure employee
safety from fire and other emergencies at
the work location.
Source: 29 CFR 1910.38(a)
TP-3
SHDMFM
Emoraoncy R»spon» Plane
10B6
(ago 12-4
-------
EAR Elements
1. Emergency _
assignments
procedures and escape route
2.
to be followed by employees who remain
to operate critical plant operations before they
evacuate
3. Procedures to
for all employees after
emergency evacuation has been completed
4. Rescue and medical duties for those
are to perform them
who
5. The preferred means of
emergencies
fires and other
6. Names or regular job title of persons or departments
who can be for further information or
explanation of duties under the plan
Source: 29 CFR 1910.38
XP-4
SHDMFM
£m«f9«ncy Reaponmo Plant
-------
Employee Alarm System
1. The alarm system shall provide for
necessary emergency action as called for in the EAR
2. The alarm system shall be perceived ambient
noise or light levels by all affected employees
3. The employee alarm shall be distinctive and
as a signal to evacuate or perform
duties directed by the plan
4. The employer shall explain to each employee the
preferred means of emergencies, post
emergency phone numbers near phones, and provide
priority messages over site radios
5. With ten or fewer employees, communications
is an acceptable means of sounding an emergency
6. The employer shall ensure the use of
equipment, ensure proper maintenance and
of the system, maintain backup power supplies, and
ensure that manually operated systems are
Source: 29 CFR 1910.165 TP-5
SHDMFM " 1&98
Emergency Response Plan* p«ge12-8
-------
Types of Evacuations
, immediate evacuation of all employees in grave
conditions
personnel followed by
Evacuation of
essential personnel as their emergency duties end
evacuations during area-specific emergencies
TP-6
Training
The employer shall designate and train a
sufficient number of to assist in
safe and orderly evacuations.
TP-7
EAR Review
When the plan is first
When the employee's
actions under the plan change
Whenever the plan is
or designated
TP-8
SHDMFM
Emergency Response Plans
1Q9B
pag.12-7
-------
Given 29 CFR 1910.1200), list the minimum elements of an ERR
Pre-emergency Planning
- Hospitals
- Fire Department
- County Road
Department
- PublkfcUtilities
Examples of Agencies and Groups Involved In Emergencies
AGENCY OR GROUP RESCUE
FEDERAL
! Army Corps of Engineers
Coast Guard
Department of Defense
Department of Transportation
Environmental Protection
Agency (EPA)
STATE
Civil Defense
Department of Health
Department of Labor
Environmental Agency
Office of the Attorney Genera!
State Police x
LOCAL
Ambulance and rescue services x
Cleanup contractor X
Disposal companies
Fire department X
Hospital
Police x
RESPONSE
x
X
X
X
X
X
x
X
X
X
X
X
X
X
SUPPORT
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x !
X
Source: U.S. DHHS 1985
SHDMFM
Emergency Response Puns
lose
pig* 12-9
-------
Personnel Roles, Lines of Authority, Communications
TP-10
Personnel
This component of the plan includes not only onsite and offsite personnel with specific emergency
response roles, but also others who may be onsite, such as contractors, other agency representatives, and
visitors.
Emergency personnel may be deployed in a variety of ways. Depending on the nature and scope of the
emergency, the size of the site, and the number of personnel, the emergency response cadre can include
individuals, small or large teams, or several interacting teams.
In all cases the organizational structure should show a clear chain-qf-command. Every individual
should know his or her position and authority, and the chain-of-command must be flexible enough to
handle multiple emergencies, such as a rescue and spill response or two rescues with a fire and spill
response.
Project Team Leader
• Directs emergency response operations
Site Safety Officer
Oversees all aspects of safety at site
Command Post Supervisor
Notifies outside contacts
Assists site safety officer
Rescue Team
Rescues endangered site workers
Decontamination Team
Performs emergency decontamination
24-Hour Medical Team
* Transports and treats site victims
Communication Personnel
• Local emergency service networks
provide links for mutual aid
F>*
icncy Response Plans
Environmental Scientists
• Provide site predictions for chemical
concentrations and onsite and offsite
exposure levels
Hazardous Chemicals Experts
• Provide immediate advice for handling
emergencies
Fire Fighters
• Fight site fires and rescue victims
Meteorologists
• Provide meteorological information
Public Safety Personnel
• Provide site control and help with
evacuations
-------
Emergency Recognition and Prevention
TP-ll
Emergency Recognition and Prevention
On a day-to-day basis, individual personnel should be constantly alert for indicators of potentially
hazardous situations and for signs and symptoms in themselves and others that warn of hazardous
conditions and exposures. Rapid recognition of dangerous situations can avert an emergency. Before
daily work assignments, regular meetings should be held. Discussion should include:
* Tasks to be performed.
• Time constraints (e.g., rest breaks, air tank changes).
• Hazards that may be encountered, including their effects, how to recognize symptoms or monitor
them, concentration limits, or other danger signals.
• Emergency procedures.
After daily work assignments, a debriefing session should be held to review work accomplished and
problems observed.
SMDMFM
ncy Response Plans
10W
page 12-10
-------
Safe Distances and Places of Refuge
Safe Distances and Places of Refuge
Safe distances can only be determined at the time of an emergency, based on a combination of site- and
incident- specific factors. However, planning and outlining potential emergency scenarios will help
familiarize personnel with points to consider.
Factors that influence safe distances include:
Toxicological properties of the substance
Physical state of the substance
Quantity released
Rate of release
Method of release
Vapor pressure of the substance
Vapor density relative to air
Wind speed and direction
Atmospheric stability
The height of release
Air temperature and temperature change with altitude
Local topography (e.g., barriers may enhance or retard a cloud or plume, and attenuate a
blast)
SHOMFM
Em»fgentry R»*pon»o Plan*
1OS8
p^a 12-11
-------
Safe Distances and Places of Refuge (cont)
Onsite refuges (safety stations) can be set up for localized emergencies that do not require site
evacuation. These refuges should only be used for essential needs, such as short rest breaks, emergency
response strategy meetings, or temporary relief during mild cases of muscle strain and heat stress.
Other refuges can be set up in the Support Zone, or in the case of site-wide evacuations, offsite at the
safe exit destination.
Suggestions for onsite refuges:
* A sitting/resting area that is shaded if possible
• Water for decontamination
• Wind indicator
• Communication system with the Command Post
• First aid supplies (e.g., eyewash, stretcher, blanket)
• Special monitoring devices (e.g., extra detector tubes'and personal monitors)
• Bolt cutters
• Fire extinguishers
• Hand tools
Suggestions for offsite refuges:
• Decontamination supplies
* Oxygen and/or air
• Water
• Special testing equipment (e.g., pH paper, cyanide paper)
• First aid supplies
• Communication system
SHOMFM
Emergency RMPOHM Plant
-------
Site Security and Control
HAZARDOUS
WASTE
DANGER
DO NOT ENTER
GO TO MAIN SECURITY GATE
Site Security and Control
In an emergency, the Project Team Leader (or designated representative) must know who is onsite and
must be able to control the entry of personnel into the hazardous areas to prevent additional injury and
exposure. Only necessary rescue and response personnel should be allowed into the Exclusion Zone.
One control technique is a checkpoint or series of checkpoints through which all personnel entering or
exiting the site must pass, e.g., a Support Zone checkpoint and an Exclusion Zone checkpoint.
Identification or authorization must be presented to a Checkpoint Control Manager, who records each
person's:
• Name (and affiliation if offsite personnel)
• Status (in or out)
• Time of entry
• Anticipated exit time
• Zones or areas to be entered
• Team or"buddy"
• Task being performed
• Location of task
• Protective equipment worn; air time left
* Rescue and response equipment used
SHOMPW
v Response
pas* '2.13
-------
Evacuation Routes and Procedures
-_w _*w -w -w
+
TP-14
Evacuation Routes and Procedures
A severe emergency, such as a fire or explosion, may cut workers off from the normal exit near the
Command Post. Therefore, alternate routes for evacuating victims and endangered personnel should be
established in advance, marked, and kept clear. Routes should be directed (1) from the Exclusion Zone
through an upwind Contamination Reduction Zone to the Support Zone, and (2) from the Support Zone
to an offsite location in case conditions necessitate a general site evacuation.
• Place the evacuation routes in the predominantly upwind direction of the Exclusion Zone. (At a
very large site, or one with many obstacles, some exits may be placed in the downwind fenceline,
normally an undesirable location. If this is done, workers must know that they are not "out" until
they reach the designated safety area.)
• Run the evacuation routes through the Contamination Reduction Zone. Even if there is not enough
time to process the evacuees through decontamination procedures, there should be a mechanism for
accounting for all personnel.
• Consider the accessibility of potential routes. Take into account obstructions such as locked gates,
trenches, pits, tanks, drums, or other barriers, and the extra time or equipment needed to maneuver
around or through them.
SHDMFM
Emergency RaspOft** Plans
1060
112-14
-------
Evacuation Routes and Procedures (cont)
• Develop two or more routes that lead to safe areas and that are separate or remote from each other.
Multiple routes are necessary in case one is blocked by a fire, spill, or vapor cloud. These routes
must not overlap because if a common point were obstructed by a fire or other emergency, all
intersecting routes would be blocked.
• Mark routes "safe " or "not safe " on a daily basis according to wind direction and other factors.
• Mark evacuation routes with materials such as barricade tape, flagging, or traffic cones. Equally
important, mark areas that do not offer safe escape or that should not be used in an emergency, such
as low ground, which can fill with gases or vapors, or routes blocked by natural barriers, such as
cliffs or streams.
- Consider the mobility constraints of personnel -wearing protective clothing and equipment. They
will have difficulty crossing even small streams and going up and down banks.
- Place ladders across any cut or excavation that is more than 3 ft (1 m) deep. For long cuts, place
ladders at least every 25 ft (7.5 m), and for deep cuts, place plywood or planks on top of ladders.
- Provide ladders for rapid descent from areas or structures elevated more than 3 ft (1 m).
- Use only ladders capable of supporting a 250-lb (114-kg) load.
- Secure ladders to prevent slipping.
- Place standard cleated ramps ("chickenboard") across ditches and other similar obstacles. Add a
railing and toe boards if the board is narrow or steeply sloped.
- Check the toe and body clearance of ladders to make sure that personnel wearing protective
clothing and self-contained breathing apparatus (SCBA) can use them.
- Check the clearance of access ports, such as crawlspaces, hatches, manholes, and tunnels to
make sure that personnel wearing a protective ensemble can get through. In any case, access
ports should be at least 3 ft (1 m) in diameter where possible. (Standard tank manways are
smaller.)
SHOMFM
£m«rg«ncy Rftspons* Plans
lose
imgt 12-15
-------
Decontamination Not Covered by
Site Health and Safety Plan
TP-15
Decontamination Not Covered by Site Health and Safety Plan
When planning for decontamination in medical emergencies, procedures should be developed for:
• Decontaminating the victim
• Protecting medical personnel
• Disposing of contaminated protective equipment and wash solutions
These activities should be coordinated. The decision whether or not to decontaminate a victim is based
on the type and severity of the illness or injury and the nature of the contaminant. For some emergency
victims, immediate decontamination may be an essential part of lifesaving first aid. For others,
decontamination may aggravate the injury or delay lifesaving treatment. If decontamination does not
interfere with essential treatment, it should be performed.
• If decontamination cannot be done:
- Wrap the victim in blankets, plastic, or rubber to reduce contamination of other personnel.
- Alert emergency and offsite medical personnel to potential contamination; instruct them about
specific decontamination procedures if necessary.
- Send along site personnel familiar with the incident.
[See Standard Operating Safety Guides (U.S. EPA 1992), Chapter 9, Decontamination (pages 103-109),
for details on decontamination techniques and procedures.]
SHDMFM
Emergency Responga Plans
1008
fuga 12-18
-------
Emergency Medical Treatment and First Aid
TP-16
Medical Treatment/First Aid
In emergencies, toxic exposure and hazardous situations that cause injuries and illnesses will vary from
site to site. Medical treatment may range from bandaging of minor cuts and abrasions to lifesaving
techniques. In many cases, essential medical help may not be immediately available. For this reason, it is
vital to train onsite emergency personnel in on-the-spot treatment techniques, to establish and maintain
telephone contact with medical experts (e.g., lexicologists), and to establish liaisons with local hospitals
and ambulance services. Guidelines for establishing an emergency program are detailed in Chapter 5 of
the 4-Agency manual.
When designing this program, these essential points should be included:
• Train a cadre of personnel in emergency treatment such as first aid and CPR. Training should be
thorough, frequently repeated, and geared to site-specific hazards.
• Establish liaison with local medical personnel, for example: 24-hour on-call physician, medical
specialists, local hospitals, ambulance service, and poison control center. Inform and educate these
personnel about site-specific hazards so that they can be optimally helpful if an emergency occurs.
Develop procedures for contacting them and familiarize all onsite emergency personnel with these
procedures.
• Set up onsite emergency first aid stations; see that they are well supplied and restocked immediately
after each emergency.
SHDMFM
Emergency Response Plan*
1Q98
(MB* 12-17
-------
Emergency Alerting and Response Procedures
TP-17
Emergency Alerting and Response Procedures
Notification
• Alert personnel to the emergency. Sound a site alarm to:
- Notify personnel.
- Stop work activities if necessary.
- Lower background noise in order to speed communication.
- Begin emergency procedures.
• Notify onsite emergency response personnel about the emergency and include essential information:
- What happened.
- Where it happened.
- Whom it happened to.
- When it happened.
- How it happened.
- The extent of damage.
- What aid is needed.
Rescue and response action is based on the available information, the type of action required, and the
necessary steps implemented. Some actions may be done concurrently. No one should attempt
emergency response or rescue until backup personnel and evacuation routes have been identified.
SHOMPM '?**
Emergency R»ipons« Plan* page 12-18
-------
Emergency Alerting and Response Procedures (cont)
Rescue/response actions may include:
• Enforce the buddy system: Allow no one to enter an Exclusion Zone or hazardous area without a
partner.
• Survey casualties
• Assess existing and potential hazards to site personnel and to the offsite population.
• Allocate resources: Allocate onsite personnel and equipment to rescue and incident response
operations.
• Request aid: Contact the required offsite personnel or facilities, such as the ambulance, fire
department, and police.
• Control: Bring the hazardous situation under complete or temporary control; use measures to prevent
the spread of the emergency.
• Extricate: Remove or assist victims from the area.
• Decontaminate: Use established procedures to decontaminate uninjured personnel in the
Contamination Reduction Zone. If the emergency makes this area unsafe, establish a new
decontamination area at an appropriate distance. Decontaminate victims before or after stabilization as
their medical condition indicates [see Figure 12-1 for decision aid (page 12-8 of the 4-Agency
manual)].
• Stabilize: Administer any medical procedures that are necessary before the victims can be moved.
Stabilize or permanently fix the hazardous condition (e.g., empty filled runoff dikes). Attend to what
caused the emergency and anything damaged or endangered by the emergency (e.g., drums, tanks).
• Transport: Take measures to minimize chemical contamination of the transport vehicles, ambulance,
and hospital personnel. Adequately protected rescuers should decontaminate the victims before
transport. If this is not possible, cover the victims with adequate sheeting. Before transportation,
determine the level of protection necessary for transport personnel. Provide them with disposable
coveralls and gloves, and supplied air, as necessary, for their protection. If appropriate, have response
personnel accompany victims to the medical facility to advise on decontamination.
• Evacuate:
- Move site personnel to a safe distance upwind of the incident.
- Monitor the incident for significant changes. The hazards may diminish, permitting personnel to
reenter the site, or the hazards may increase, requiring public evacuation.
- Inform public safety personnel when there is a potential or actual need to evacuate the offsite
population. Do not attempt large-scale public evacuation. This is the responsibility of government
authorities [see Table 12-3 (page 12-3 of the 4-Agency manual)].
esponse Plan*
1086
112-19
-------
Critique of Response and Follow-up
Report
SOPs/SOSG
TP-18
Critique of Response and Follow-up
Critique:
Coordinate a formal critique with all parties involved in the emergency. Complete a critique report
with recommendations to improve standard operating safety guidelines, if necessary.
Review and revise all aspects of the ERP according to new site conditions and lessons learned from
the emergency response. When reviewing the information, consider typical questions such as:
- Cause: What caused the emergency?
-Prevention: Was it preventable? If so, how?
- Procedures: Were inadequate or incorrect orders given or actions taken? Were these the result of
bad judgment, wrong or insufficient information, or poor procedures? Can procedures or training
be improved?
- Site profile: How does this incident affect the site profile? How are other site cleanup activities
affected?
- Community: How is community safety affected?
- Liability: Who is liable for damage payments?
SHDMFM
Em«rg«ncy Responia Planj
tow
-------
Critique of Response and Follow-up (cont.)
Folio w-up:
• Before normal site activities are resumed, personnel must be fully prepared and equipped to handle
another emergency.
- Notify appropriate government agencies as required. For example, the Occupational Safety and
Health Administration (OSHA) must be notified if there have been any fatalities or five or more
hospitalizations.
- Restock all equipment and supplies. Replace or repair damaged equipment. Clean and refuel
equipment for future use.
- Amend the ERP based on the critique and changing site conditions.
SHOMFM
Emergency R*spon» Plan*
1Q99
(-8.12-21
-------
PPE and Emergency Equipment
TP-19
PPE and Emergency Equipment
PPE:
• Refill all empty SCBA tanks and prepare them for emergencies immediately after normal use.
• Stock higher levels of protective equipment than required for anticipated hazards (e.g., a site where
Level C equipment is normally used should have Level A and B equipment available for
emergencies).
• Provide personal protection, including:
- Escape SCBA or SCBA, which can be brought to the victim to replace or supplement his or her
SCBA.
- PPE and clothing specialized for known site hazards.
Medical:
• Air splints
• Antiseptics
• Blankets
* Decontamination solutions appropriate for onsite chemical hazards
• Emergency eye wash
SHOMFM
Emeig«ncy R«
PUnt
10M
p«8» 12-22
-------
PPE and Emergency Equipment (cont)
Medical:
• Air splints
• Antiseptics
• Blankets
• Decontamination solutions appropriate for onsite chemical hazards
• Emergency eye wash
• Emergency showers or wash stations
• Ice
• Reference books containing basic first aid procedures and information on treatment of specific
chemical injuries
• Resuscitator
• Safety harness
Stretchers
Water, in portable containers
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:
• Fire fighting equipment and supplies
* Spill containment equipment, such as absorbents and oil booms
• Special hazardous-use tools such as remote pneumatic impact wrenches, nonsparking wrenches and
picks.
• Containers to hold contaminated materials
In an emergency, equipment will be necessary to rescue and treat victims, to protect response personnel,
and to mitigate hazardous conditions onsite (e.g., to contain chemicals or fight fires). Some regular
equipment can double for emergency use. Because of its high cost, most heavy equipment (e.g.,
bulldozers, drum movers, pumps) employed in emergencies will also be used for regular work
assignments.
All equipment should be in working order, fueled, and available when an emergency occurs. Provide safe
and unobstructed access for all firefighting and emergency equipment at all times. Consider adopting the
following work procedures:
• Refuel all heavy equipment when there is still one-half to one-quarter of a tank of fuel left.
• Require all equipment repairs to take place at the time the problem is discovered.
• Separate two similar pieces of equiment (e.g., two front-loaders or a bulldozer and a front-loader);
park each at a different spot onsite and do not use them at the same time in a hazardous area.
SHDMFM
Emergency ft»»pon»»
1O98
• 12-23
-------
Procedures for Handling Emergencies
topography, layout, and prevailing weather
conditions.
Procedures for incidents to local, state,
and federal governmental agencies.
Source:29CFR1910.120(l)(3) TP-20
Procedures for Handling Emergencies (cont.)
• The ERP shall be a separate of the site
health and safety plan.
• The ERP shall be compatible and with
the disaster, fire/emergency response plans of
local, state, and federal governmental agencies.
• The ERP shall be regularly as part of
the overall training program.
Source: 29 CFR 1910.120(l)(3) TP-21
SMOMFM
toee
Emergency R*spon<* Plan* pan* 12-24
-------
Procedures for Handling Emergencies (cont.)
• The ERP shall be
periodically and, as
necessary, be amended to keep it current with new
or changing site conditions or information.
An alarm system shall be installed in accordance
with 29 CFR 1910.165 to employees of an
emergency situation.
Based upon available information at the time of
the emergency, the employer shall the
incident and the site response capabilities and
proceed with appropriate steps to implement the
site ERP.
Source: 29 CFR 1910.120(0(3)
TP-22
SHOMFM
Emergency Rttpont* Plans
-------
Given 29 CFR 1910.38 and 29 CFR 1910.120(1):
• List the similarities between an ERP and EAP.
• List the differences between an ERP and EAP.
ERP/EAP Comparisons
ERP Elements
1. Pre-emergency Planning
2. B. F. E Personnel roles, lines of authority
and communication
3. Emergency recognition and
prevention
4. A, c Safe distances and places of
refuge
5. c. E Site security and control
6. A, c. E Evacuation routes and procedures
7. D Decontamination procedures not
covered by site health and safety
plan
8. D Emergency medical treatment and
first aid
9. A Emergency alerting and response
procedures
10. Critique of response and follow-up
11. D PPE and emergency equipment
EAP Elements
A. Emergency escape procedures
B. Critical operations
C. Accounting for employees
D. Rescue and medical duties
E. Reporting emergencies
F. Names for further information
SHOMFM
Emftrgftncy Raspon** Plans
1098
-------
Find and circle the key words or phrases that complete the six elements of an EAR
Words and phrases are listed vertically and horizontally only. Words or phrases
may be used more than once. Fill in the blanks with the appropriate words or
phrases for each of the six EAP elements.
E
X
R
M
P
F
P
O
N
L
T
N
D
J
S
W
A
N
E
D
O
L
T
M
P
R
E
F
E
R
R
E
D
S
O
U
N
R
O
X
R
R
V
E
E
1
O
E
R
S
X
0
Q
E
D
B
1
Y
F
P
1
E
E
A
F
A
G
C
M
L
P
P
S
L
R
V
T
W
P
E
E
C
B
M
M
0
W
B
E
L
C
D
E
A
L
U
C
1
G
L
W
R
E
1
A
K
L
R
Q
D
X
O
B
R
Q
U
H
N
T
N
A
1
A
T
S
1
E
L
F
K
U
V
N
X
F
0
E
X
P
L
A
N
A
T
1
0
N
G
O
P
E
R
A
T
1
0
N
S
V
P
E
S
T
H
E
C
C
U
H
W
A
0
E
N
A
U
R
Y
C
P
E
W
Q
G
B
G
T
C
E
B
E
G
C
S
C
C
V
M
U
A
C
C
O
U
N
T
F
O
R
E
N
D
P
X
D
P
T
A
P
M
P
U
K
P
2
1
A
L
Y
H
N
G
H
R
0
1
G
E
Y
K
J
E
V
A
C
U
A
T
1
O
N
E
S
1
E
J
N
L
D
R
G
L
P
B
T
1
H
B
0
A
S
A
A
H
N
B
A
S
K
O
M
E
O
R
G
1
0
D
H
S
N
Z
M
D
C
1
N
F
0
R
M
A
T
1
O
N
M
R
U
K
1
0
F
E
Y
R
B
O
K
U
N
O
S
Q
V
C
U
S
B
T
R
H
S
M
S
B
E
S
C
A
P
E
R
O
U
T
E
Q
E
0
1
E
X
T
U
D
U
P
B
L
S
Y
F
1
M
C
E
D
S
N
T
E
0
C
L
L
1
X
O
N
M
E
D
1
C
A
L
D
U
T
I
E
S
C
M
T
B
R
L
R
O
T
M
E
R
1
X
O
V
R
A
K
J
A
N
M
Y
T
V
L
T
R
E
P
B
E
M
E
R
G
E
N
C
1
E
S
O
E
1
N
0
1
M
G
L
Y
F
E
W
E
T
S
1
F
H
Y
S
G
A
Y
W
M
N
U
W
O
N
X
A
R
S
E
A
P
O
U
D
E
0
M
B
P
1
G
B
1
Y
S
1
N
Y
C
J
U
Z
V
N
K
N
A
E
N
S
N
D
U
H
E
1
J
S
E
U
1
1
N
O
T
O
Y
E
M
C
Y
0
V
W
E
E
S
1
M
M
E
F
V
0
1
E
L
A
1
T
R
R
1
A
E
S
S
R
Q
U
L
M
A
0
R
E
M
P
J
E
E
G
H
A
1. Emergency
2. to be
EAP Elements
and _
_by employees who
assignments.
to critical
3.
to
before they evacuate.
all
been completed.
4. and
5. The__ J_
6. Names or regular
for further
after emergency
has
for those
who are to
them.
of
fires and other
of persons or departments who can be
or of under the plan.
SHOMFM
Em«rg«rtCY R»»pon*» Plan*
1OB8
> 12-27
-------
Given federal legislation, describe the purpose of SARA Title HI.
SARA Title
The Emergency Planning and Community Right-to-Know
Act of 1986:
Establishes requirements for federal, state, and local
governments and industry in for emergencies
and reporting on use, storage, and releases of hazardous
and toxic chemicals.
Adapted from: SARA Title III Fact Sheet, EPA/550-F-93-002 TP-23
SHDMFM
Eme*g»ncy Rospon** Plana
-------
Given SARA Title I and Title EH planning elements, identify their similarities and differences.
Title III Planning Elements
1. Identification of
and transportation
routes within the scope of the act
TP-24
SHOMFM
Emergency Rtspon**
1MB
-------
Title III Planning Elements (cont.)
2. Methods and
of emergency
response for facility owners/operators and
community fire/EMS personnel to respond to
a release .
TP-25
Title III Planning Elements (cont.)
3. Designation of community and facility
emergency
TP-26
SHOMFM
Emergency R»ipon«« Plant
1O90
we 1200
-------
Title III Planning Elements (cont.)
4. Procedures providing reliable, effective, and
timely of a release at a facility
TP-27
Title III Planning Elements (cont.)
5. Methods for determining the occurrence of a
, and the area or population that will be
affected by the release
TP-28
SHDMFM
Emergency R«*pon» Plans
1088
page 12-31
-------
Title III Planning Elements (cont.)
6. Community and facility emergency _
and facilities, and identity of persons
responsible for them
TP-29
SHDMFM
ons* Puns
1O98
pa»» 12^2
-------
Title III Planning Elements (cont.)
7. Evacuation
and alternate traffic routes
TP-30
SHDMFM
Em«rg«ncy Rtmponsi Piana
tow
WC. 12-33
-------
Title III Planning Elements (cont.)
8.
programs and schedules of training
for local responders
TP-31
SHOMFM
Emergency R«»pont« Plan*
1O9B
p*g* 12-34
-------
Title III Planning Elements (cont.)
9. Methods and plans for
emergency plan
the
TP-32
SHOMFM
Emergency Response Plant
1086
j»9» 12-35
-------
Main Gate
= X
o
03
LL
15
o
'E
pon>e Plani
-------
Conclusion
Confined Space Entry Program
Spill Containment Program
Emergency Response Plans
TP-33
Crossword Puzzle
Down
2. An emergency.
31. An emergency.
__ plan provides for the safety of workers responding to a site emergency
,plan provides for the safe and orderly evacuation of a site
SHOMFM
100)
p«9.12-37
-------
-------
-------
APPENDIX
SARA Title III Fact Sheet
I'.S. E^A Headquarters
-------
-------
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
(OS-120)
EPA550-F-93-002
January 1993
Series 9, No. 3
SARA Title III Fact Sheet
Emergency Planning And
Community Right-To-Know Act
United States Environmental Protection Agency
Overview
The Emergency Planning and Community Right-to-Know Act of 1986 establishes requirements for
Federal, State and local governments and industry regarding emergency planning and "Community
Right-to-Know" reporting on hazardous and toxic chemicals. This law builds upon EPA's Chemical
Emergency Preparedness Program (CEPP) and numerous State and local programs aimed at helping
communities to better meet their responsibilities in regard to potential chemical emergencies. The
Community Right-to-Know provisions will help to increase the public's knowledge and access to
information on the presence of hazardous chemicals in their communities and releases of these chemi-
cals into the environment States and communities, working with facilities, will be better able to
improve chemical safety and protect public health and the environment.
Nothing in this document should be construed to indicate that EPA has determined states have Title
JH authority over Indian reservations. For purposes of this document, definition of the terms "State"
and "Governor" includes "Indian Tribe" and 'Tribal Chairman." EPA has issued a final rule on July
26, 1990, regarding the application of the Emergency Planning and Community Right-to-Know law to
Indian lands.
The Emergency Planning and Community Right-to-Know Act (also known as SARA Title HI or
EPCRA) provisions has four major sections: emergency planning (Section 301-303), emergency
release notification (Section 304), community Right-to-Know reporting requirements (Sections 311,
312) and toxic chemical release inventory (Section 313). Information from these four reporting require-
ments will help States and communities develop a broad perspective of chemical hazards for the entire
community as well as for individual facilities.
Section 301-303:
Emergency Planning
The emergency planning sections are designed to
develop State and local governments' emergency
response and preparedness capabilities through
better coordination and planning, especially within
the local community.
State Emergency Response Commission
The Emergency Planning and Community Right-
to-Know Act required the Governor of each state to
designate a State Emergency Response Commis-
sion (SERC). Many SERCs include public agen-
cies and departments concerned with issues relating
to environment, natural resources, emergency
services, public health, occupational safety, and
Printed will* Soy/C*raU If* on (MOW flai
mrnmnt « IWMI 50% racycMd
-------
Apr.. 22. 1987
October 15.1987
December 17, 1987
February 16.1988
February 25. '988
My 29.1988
January 23.1989
January 26, 1989
July 24.1990
July 26,1990
August 27, 1990
Rulemaklnas In the Federal Realster
301-303 EPA published final Liu of Extremely
Hazardous Substance* and Threshold
Planning Quantities as well as Final
Rule for Sections 302,303, and 304 of
the taw.
311-312 EPA published final format for
emergency inventory forms and
reporting requirement* ax well u the
Final Rule for Sections 3 U and 312
of the law.
301-303 EPA published a Final Rule delisting
four chemicals from the Extremely
Hazardous Substance list.
313 EPA published the final Toxic
Chemical Release forma and
instruction* as well as the Final Rule
for Section 313 of the law.
301-303 EPA published a Final Rule delating
36 chemicals from the Extremely
Hazardous Substance List.
322 EPA published a Final Rule governing
trade secret claims.
301-303 EPA published a Proposed Rule
designating several Extremely
Hazardous Substances as CERCLA
Hazardous Substances.
325 EPA published a Proposed Rule
governing policies and procedures for
Citizens Suits under the law.
304 EPA published a Final Rule for the
continuous release reporting
regulation, under which the SERCs
and LEPCj will receive both initial
telephone notifications and written
reports about the continuous releases.
311-312 EPA published a Final Rule on the
reporting requirements for Sections
311and312.
September 25. 1991
301-304 EPA published an Advanced Notice
of Proposed Rulemalting seeking
comments on a proposal to specify
criteria that would be used 10 add
chemicals to the Extremely Hazardous
Substances USL
313 EPA published a proposed rule on the
additional requirements under Section
313 as mandated by the Pollution
Prevention ACL
NOTE: The middle column denotes itx section of the Title III law which applies to
the rulemaklngs ID the Federal Register. Th«s« are not all-inclusive.
transportation. Also, interested
public and private sector groups
and associations with experience in
emergency planning and Commu-
nity Right-to-Know issues may be
included in the State commission.
At this time, all governors have
established SERCs.
The SERC must also have desig-
nated local emergency planning
districts and appointed Local
Emergency Planning Committees
(LEPQ for each district SERCs
have designated over 4,000 local
districts. Thirty-five State commis-
sions chose counties as the basic
district designation (often with
separate districts for municipalities)
and ten SERCs designated substate
planning districts. The SERC is
responsible for supervising and
coordinating the activities of the
LEPC, for establishing procedures
for receiving and processing public
requests for information collected
under other sections of SARA Tide
HI, and for reviewing local emer-
gency plans.
Local Emergency Planning
Committees
This LEPC must include, at a
minimum, elected state and local
officials, police, fire, civil defense,
public health professionals, envi-
ronmental, hospital, and transporta-
tion officials as well as representa-
tives of facilities subject to the
emergency planning requirements,
community groups, and the media.
As soon as facilities are subject to
the emergency planning require-
ments, they must designate a
-- -— Emergency Planning and Community Right-to-Know Fact Sheet
-------
representative to participate in the planning
process.
The LEPC is required to complete a number of
tasks, including establishing rules, giving public
notice of its activities, and establishing procedures
for handling public requests for information;
however, the LEPC's primary responsibility is to
develop an emergency response plan by October
17,1988 and review it at least annually thereafter.
In developing this plan, the LEPC evaluates avail-
able resources for preparing for and responding to a
potential chemical accident The plan must:
• identify facilities and transportation routes of
extremely hazardous substances;
• describe emergency response procedures, on-
site and off-site;
• designate a community coordinator and facility
coordinator^) to implement the plan;
• outline emergency notification procedures;
* describe methods for determining the occur-
rence of a release and the probable affected area
and population;
* describe community and industry emergency
equipment and facilities and identify the persons
responsible for them;
• outline evacuation plans;
• describe a training program for emergency
response personnel (including schedules); and,
* present methods and schedules for exercising
emergency response plans.
Emergency Response Plans
In order to assist the LEPCs in preparing and
reviewing plans, Congress required the National
Response Team (NRT), composed of 15 Federal
agencies with emergency response responsibilities,
to publish guidance on emergency response plan-
ning. This guidance, the "Hazardous Materials
Emergency Planning Guide, (NRT-1)" was pub-
lished by the NRT in March 1987. In 1990, the
NRT also published "Developing a Hazardous
Materials Exercise Program: A Handbook for State
and Local Officials (NRT-2)" to help assist SERCs
and LEPCs exercise their emergency response
plans.
The emergency response plan must be initially
reviewed by the SERC and, at least, annually by
the LEPC. Regional Response Teams (RRTs),
composed of federal regional officials and state
representatives, may review the plans and provide
assistance to the LEPCs upon request by the SERC
or LEPC.
Planning activities of LEPCs and facilities should
be initially focused on, but not limited to, the 360
extremely hazardous substances pubb'shed in the
Federal Register. Plans should be comprehensive,
addressing all hazardous materials of concern and
transportation as well as fixed facilities. The list
includes the threshold planning quantities (mini-
mum limits) for each substance (see Code of
Federal Regulations (CFR) Part 40, Section 355).
Through rulemaking, EPA can revise the list and
threshold planning quantities based on the toxicity,
reactivity, volatility, dispersability, combustibility,
or flammability of a substance.
Any facility that has present any of the listed
chemicals in a quantity equal to or greater than its
threshold planning quantity is subject to the emer-
gency planning requirements. In addition, the
SERC or the Governor can designate additional
facilities, after public comment, to be subject to
these requirements. Covered facilities must notify
the SERC and LEPC that they are subject to these
requirements within 60 days after they begin to
have present any of the extremely hazardous
substances in an amount equal to or in excess of
threshold planning quantities.
Emergency Planning and Community Right-to-Know Fact Sheet — 3
-------
In addition, the SERC must notify the EPA re-
gional office of all facilities subject to the emer-
gency planning requirements, including facilities
designated by the SERC or the governor.
Section 304:
Emergency Notification
Facilities must immediately notify the LEPCs and
the SERCs likely to be affected if there is a release
into the environment of a hazardous substance that
exceeds the reportable quantity for that substance.
Substances subject to this requirement are those on
the list of 360 extremely hazardous substances as
published in Federal Register (40 CFR 355) as well
as the more than 700 hazardous substances subject
to the emergency notification requirements under
CERCLA Section 103(a) (40 CFR 302.4). Some
chemicals are common to both lists. The CERCLA
hazardous substances also require notification of
releases to the National Response Center (NRC),
which alerts federal responders.
Initial notification can be made by telephone, radio,
or in person. Emergency notification requirements
involving transportation incidents can be met by
dialing 911, or in the absence of a 911 emergency
number, calling the operator.
This emergency notification needs to include:
• The chemical name;
• An indication of whether the substance is
extremely hazardous;
• An estimate of the quantity released into the
environment;
• The time and duration of the release;
• Whether the release occurred into air, water,
and/or land;
* Any known or anticipated acute or chronic
health risks associated with the emergency, and
where necessary, advice regarding medical
attention for exposed individuals;
• Proper precautions, such as evacuation or
sheltering in place; and,
• Name and telephone number of contact person.
Section 304 also requires a written follow-up
emergency notice as soon as practicable after the
release. The follow-up notice or notices must
• Update information included in the initial
notice, and
• Provide information on
- actual response actions taken; and
- advice regarding medical attention necessary
for exposed individuals.
If LEPCs are not yet formed, releases should be
reported to appropriate local response officials.
Section 311-312:
Community Right-to-Know Requirements
There are two Community Right-to-Know report-
ing requirements within the Emergency Planning
and Community Right-to-Know ACL Section 311
requires faculties that must prepare material safety
data sheets (MSDS) under the Occupational Safety
and Health Administration (OSHA) regulations to
submit either copies of their MSDSs or a list of
MSDS chemicals to:
• TheLEPC,
• The SERC, and,
• The local fire department with jurisdiction over
the facility.
4 — Emergency Planning and Community Right-to~Know Fact Sheet
-------
If the facility owner or operator chooses to submit a
list of MSDS chemicals, the list must include the
chemical or common name of each substance and
must identify the applicable hazard categories.
These hazard categories are:
• Immediate (acute) health hazard,
* Delayed (chronic) health hazard,
• Fire hazard,
• Sudden release of pressure hazard, and,
• Reactive hazard.
If a list is submitted, the facility must submit a copy
of the MSDS for any chemical on the list upon the
request of the LEPC or SERC. Also, EPA has
established threshold quantities for hazardous
chemicals below which no facility must report
The current thresholds for Section 311 are:
• For extremely hazardous substances: 500
pounds or the threshold planning quantity,
whichever is lower.
• For all other hazardous chemicals: 10,000
pounds.
The initial submission of the MSDSs or a list of
MSDS chemicals was due on October 17,1987, or
three months after the facility is required to prepare
or have available an MSDS under OSHA regula-
tions. Currently, OSHA regulations require all
employers to have or prepare MSDSs for their
chemicals. Under the Emergency Planning and
Community Right-to-Know statute, facilities newly
covered by the OSHA regulations must submit
MSDSs or a list of MSDS chemicals within three
months after they become covered
An MSDS or a revised list must be provided when
new hazardous chemicals become present at a
facility in quantities at or above the established
threshold levels after the deadline. A revised
MSDS must be provided to update the original
MSDS if significant new information is discovered
about the hazardous chemical.
Reporting under section 312 requires a facility to
submit an emergency and hazardous chemical
inventory form to the LEPC, the SERC, and the
local fire department with jurisdiction over the
facility. Hazardous chemicals covered by section
312 are those for which facilities are required to
prepare or have available an MSDS under OSHA's
Hazard Communication Standard and that were
present at the facility at any time during the previ-
ous calendar year above specified thresholds.
The specific threshold quantities established by
EPA for Section 312 for hazardous chemicals,
below which no facility must report, are:
• For extremely hazardous substances: 500
pounds or the threshold planning quantity,
whichever is lower.
• For all other hazardous chemicals: 10,000
pounds.
The inventory form incorporates a "two-tier"
approach. Under Tier I, facilities must submit the
following aggregate information for each appli-
cable hazard category:
• An estimate (in ranges) of the maximum
amount of chemicals for each category present
at the facility at any time during the preceding
calendar year,
• An estimate (in ranges) of the average daily
amount of chemicals in each category; and,
• The general location of hazardous chemicals in
each category.
The Tier 0 report contains basically the same
information as the Tier I, but it must name the
Emergency Planning and Community Right-to~Kno*> Fact Sheet —5
-------
specific chemical If requested by an LEPC, SERC,
or local fire department, the facility must provide
the following Tier II information for each sub-
stance subject to the request:
• The chemical name or the common name as
indicated on the MSDS,
• An estimate (in ranges) of the maximum
amount of the chemical present at any time
during the preceding calendar year,
• A brief description of the manner of storage of
the chemical,
• The location of the chemical at the facility, and,
* An indication of whether the owner elects to
withhold location information from disclosure
to the public.
EPA published a uniform format for the inventory
forms on October 15,1987. However, because
many state commissions have additional require-
ments or have incorporated the federal contents in
their own forms, Tier I/H forms should be obtained
from the SERC. The Tier I information must be
submitted for covered facilities on or before March
1 annually.
The Tier H form may be sent by the facility instead
of a Tier I form. EPA believes that Tier II reports
provide emergency planners and communities with
more useful information and encourages facilities
to submit Tier II forms. The public may also
request Tier n information from the SERC and the
LEPC. The information submitted by facilities
under Sections 311 and 312 must generally be
made available to the public by LEPCs and SERCs
during normal working hours.
Section 313:
Toxic Chemical Release Reporting
EPA to establish an inventory of routine toxic
chemical emissions from certain facilities. Facili-
ties subject to this reporting requirement are
required to complete a Toxic Chemical Release
Inventory Form (Form R) for specified chemicals.
The form must be submitted to EPA and those state
officials designated by the governor annually on
July 1. These reports should reflect releases during
the preceding calendar year.
The purpose of this reporting requirement is to
inform the public and government officials about
routine releases of toxic chemicals to the environ-
ment It will also assist in research and the devel-
opment of regulations, guidelines, and standards.
The reporting requirement applies to owners and
operators of facilities that have 10 or more full-time
employees, that are in Standard Industrial Classifi-
cation (SIC) codes 20 through 39 (i.e., manufactur-
ing facilities) and that manufacture (including
importing), process, or otherwise use a listed toxic
chemical in excess of specified threshold quanti-
ties.
Facilities manufacturing or processing any of these
chemicals in excess of 25,000 pounds are required
to submit the form by July 1st of the following
calendar year. Facilities otherwise using listed
toxic chemicals in quantities over 10,000 pounds in
a calendar year are required to submit toxic chemi-
cal release forms by July 1 of the following calen-
dar year. EPA can revise these threshold quantities
and covered SIC codes.
The list of toxic chemicals subject to reporting
consisted initially of chemicals listed for similar
reporting purposes by the States of New Jersey and
Maryland. There are over 300 chemicals and
categories on these lists. Through rulemaking,
EPA can modify this combined list (a current toxic
chemical list may be obtained through the EPCRA
hotline, see page 9).
Section 313 of the Emergency Planning and The final Toxic Chemical Release Form and
Community Right-to-Know Act of 1986 requires regulations were published in the Federal Register
6 — Emergency Planning and Community Right-to-Know Fact Sheet
-------
on February 16,1988. (NOTE: EPA has revised
and updated the Toxic Chemical Release Form
since that time.) The following information is
required on the form:
• The name, location and type of business;
• Off-site locations to which the facility transfers
toxic chemicals in waste for recycling, energy
recovery, treatment or disposal;
• Whether the chemical is manufactured (includ-
ing importation), processed, or otherwise used
and the general categories of use of the chemi-
cal;
• An estimate (in ranges) of the maximum
amounts of the toxic chemical present at the
facility at any time during the preceding year,
• Quantity of the chemical entering each
medium—air, land, and water—annually;
• Waste treatment/disposal methods and effi-
ciency of methods for each waste stream;
• Source reduction and recycling activities; and,
• A certification by a senior facility official that
the report is complete and accurate.
Reports are sent to EPA and designated state
agencies. EPA established and maintains a na-
tional toxic chemical inventory based on the data
submitted. The public is able to access this na-
tional database and obtain the data through other
means. See the Public Access Section of this
document for further details.
Pollution Prevention Law
The Pollution Prevention Act of 1990 has signifi-
cantly expanded the Toxics Release Inventory
(TRJ). It requires collection of mandatory informa-
tion on source reduction, recycling, and treatment
beginning with the 1991 reporting year. The new
requirements include reporting of the following
information:
• Amounts released or disposed on-site or off-
site, the quantities from the previous year, the
quantities anticipated for the next two years;
• Amounts recycled on-site and sent off-site for
recycling, the quantities from the previous
year, the quantities anticipated for the next two
years;
• Amounts treated on-site and sent off-site for
treatment, the quantities from the previous
year, and the quantities anticipated for the
next two years;
• Amounts used for energy recovery on-site and
sent off-site, quantities from the previous year,
and the quantities anticipated for the next two
years;
• Types of source reduction practices imple-
mented and the techniques used to identify
those practices;
Methods of recycling used on-site;
• Production ratio or activity index to track
changes in the level of economic activity at a
facility; and,
• Amount of releases resulting from one-time
events not associated with production pro-
cesses.
Other SARA Title III Provisions
Trade Secrets
Section 322 of the Emergency Planning and
Community Right-to-Know Act addresses trade
secrets as they apply to emergency planning,
Community Right-to-Know, and toxic chemical
release reporting. A facility may withhold the
specific chemical identity on these submittals. No
Emergency Planning and Community Right-to-Know Fact Sheet — 7
-------
trade secrets are allowed to be claimed under
Section 304 of the statute. The withholder must
show that:
• The information has not been disclosed to any
person other than a member of the local plan-
ning committee, a government official, an
employee of the withholder or someone bound
by a confidentiality agreement; measures have
been taken to protect the confidentiality; and the
withholder intends to continue to take such
measures;
• The information is not required to be disclosed
to the public under any other Federal or State
law,
• Disclosure of the information is likely to cause
substantial harm to the competitive position of
the withholder, and,
• The chemical identity is not readily discoverable
through reverse engineering.
However, even if chemical identitv information can
be legally withheld from the public, section 323
provides for disclosure of this information to health
professionals who need the information for diag-
nostic and treatment purposes or local health
officials who need the information for prevention
and treatment activities. In non-emergency cases,
the health professional receiving the information
must sign a confidentiality agreement with the
facility and provide a written statement of need In
medical emergency situations, the health profes-
sional must, if requested by the facility, provide
these documents as soon as circumstances permit.
Information claimed as a trade secret and substan-
tiation for that claim must be submitted to EPA.
More detailed information on the procedure for
submitting trade secrecy claims can be found in the
trade secrets final rule, published in the Federal
Register, July 29, 1988 (40 CFR 350). Any person
may challenge trade secret claims by petitioning
EPA. The Agency must then review the claim and
rule on its validity.
The trade secret regulations cover the process for
submission of claims, petitions for disclosure, and
the review process for petitions.
SARA Title m Penalties
Section 325 of the Emergency Planning and
Community Right-to-Know Act addresses the
penalties for failure to comply with the require-
ments of this law. Civil and administrative penal-
ties ranging up to $10,000-$75,000 per violation or
per day per violation can be assessed to facilities
that fail to comply with the emergency planning
(section 302), emergency notification (section 304),
Community Right-to-Know (sections 311 and
312), toxic chemical release (section 313), and
trade secret (Sections 322 and 323) reporting
requirements.
Criminal penalties up to $50,000 or five years in
prison may also be given to any person who
knowingly and willfully fails to provide emergency
release notification. Penalties of not more than
$20,000 and/or up to one year in prison may be
given to any person who knowingly and willfully
discloses any information entitled to protection as a
trade secret. In addition, section 326 allows citi-
zens to initiate civil actions against EPA, state
emergency response commissions, and/or the
owner or operator of a facility for failure to meet
the requirements of the emergency planning and
Community Right-to-Know provisions. A state
emergency response commission, local emergency
planning committee, state or local government may
institute actions against facility owner/operators for
failure to comply with Title HI requirements. In
addition, states may sue EPA for failure to provide
trade secret information.
Training Grants
Section 305 (a) of the Emergency Planning and
Community Right-to-Know Act authorized the
8 — Emergency Planning and Community Right-to-Know Fact Sheet
-------
Federal Emergency Management Agency to
provide $5 million for each of fiscal years 1987,
1988,1989, and 1990 for training grants to support
state and local governments. These training grants
continue to be funded past 1990. These training
grants are designed to improve emergency plan-
ning, preparedness, mitigation, response, and
recovery capabilities. Such programs must provide
special emphasis to hazardous chemical emergen-
cies. The training grants may not exceed 80
percent of the cost of any such programs. The
remaining 20 percent must come from non-federal
sources. These training grants are coordinated
within each state by the state emergency response
commission.
Public Access
Section 324 of the Emergency Planning and
Community Right-to-Know Act provides for public
access to information gathered under this law.
Under this section, all material safety data sheets,
hazardous chemical inventory forms, toxic chemi-
cal release inventory forms, toxic chemical release
form follow-up emergency notices, and the emer-
gency response plan must be made available during
normal working hours by the SERC and UEPC. In
order to inform the public of the availability and
location of the information provided to the LEPC,
the LEPC must publish a notice annually in the
local newspaper.
In addition, Toxic Release Inventory (Section 313)
information collected by EPA is available by
telecommunications and other means. This infor-
mation can be accessed through a variety of
sources. Each year, EPA releases a printed report
summarizing the information that was submitted
for the annual Toxic Release Inventory. A comput-
erized on-line database of the Toxic Release
Inventory data is available through the National
Library of Medicine's TOXNET on-line system 24
hours a day. The complete Toxic Release Inven-
tory on magnetic tape is available from the Na-
tional Technical Information Service (NTIS) and
the Government Printing Office (GPO). The 1987
TRI and pertinent Hazardous Substance Fact
Sheets containing reference material on the health
and ecological effects of the regulated substances is
available on CD-ROM from both NTIS and GPO.
Also available through NTIS and GPO are floppy
diskettes containing state specific Toxic Release
Inventory information. Interested parties may view
the 1987 Toxic Release Inventory data on micro-
fiche at selected Federal Depository and public
libraries. The list of libraries is also available from
NTIS and GPO. Both state and national sets of
microfiche can also be purchased from NTIS and
GPO. Most of these products are updated on an
annual basis; therefore be sure to indicate which
year's TRI data you would like.
For general information contact the Emergency Planning and Community
Right-to-Know Information Hotline:
Hotline: 1-800-535-0202 (TDD number for the hearing impaired: 703-553-
7672)
Hours: 8:30 am - 7:30 pm (Eastern Time)
Monday -Friday
This is NOT an emergency number
For on-line access to the Toxic Release Inventory on TOXNET, call:
National Library of Medicine
Specialized Information Service
(301)496-6531
Emergency Planning and Community Right-to-Know Fact Sheet — 9
-------
Related Legislation
The Oil Pollution Act (OPA) of 1990 includes na-
tional planning and preparedness provisions for oil
spills that are similar to SARA Title in provisions for
extremely hazardous substances. Plans are to be
developed at the local, State and federal levels. The
OPA offers an opportunity far LEPCs to coordinate
their Title HI plans with area and facility oil spill plans
covering the same geographical area.
The Hazardous Materials Transportation Uniform
Safety Act (HMTUSA) includes funding grants to
States for planning and hazmat training, as well as
requiring the development of a national curriculum
for training for responders. States must certify that
they are complying with SARA Title m sections 301
and 303, and must pass through at least 75 percent of
theirplanning grant directly to LEPCs; training grants
to States and Indian tribes are to be used for training
public sector employees in hazmat response and 75%
of the training grant money must go to benefit the
local responders.
The Clean Air Act Amendments require the EPA and
the Occupational Safety and Health Administration
(OSHA) to develop regulations for chemical safety
management Facilities that have certain chemicals
above specified threshold quantities will be required
to develop a system to identify and evaluate hazards
and manage those hazards safely. Information facili-
ties develop on their hazards must be submitted to
States and local emergency planners and available to
the public.
The Pollution Prevention Act represents a fundamen-
tal shift in the traditional approach to pollution con-
trol Instead of concentrating on the treatment and
disposal of wastes, it focuses on source reduction.
Specific provisions affect section 313 reporting and
are described above.
10 — Emergency Planning and Community Righi-to-Know Fact Sheet
-------
Chemical Lists Associated With
Emergency Planning and Community Right-to-Know
List
List °f Extremely Hazardous
Substances
(40 CFR 355)
Section
§302: Emergency Planning
§304: Emergency Notification
§311/312: Material Safety Data
Sheets and Emergency In-
ventory
Purpose
Facilities with more than threshold
planning quantities of these sub-
stances must notify the SERC and
LEPC.
Initial focus for preparation of
emergency plans by local emer-
gency planning committees.
Certain releases of these substances
in excess of the reportable quantity
(RQ) trigger section 304 notifica-
tion to SERC and LEPC.
Separate and lower thresholds are
established for these substances of
concern for the MSDS and Tier WI
(section 311/312) reporting re-
quirements.
Substances requiring notification
under Section 103 (a) of CERCLA
(40 CFR 302.4)
§304: Emergency Notification
Certain releases of these substances
in excess of the RQ trigger section
304 notification to SERCo/uf LEPC
as well as section I03(a) require-
ments for National Response Cen-
ter notification.
Chemicals considered
physical or health hazards under
OSHAs Hazard Communication
Standard (29 CFR 1910. 1200) (This
is a performance standard; there is no
list of chemicals.)
§304: Emergency Notification
§311: Material Safety Data Sheets
§312: Emergency and Hazardous
Chemical Inventory
Identifies facilities subject to
emergency notification require-
ments.
MSDS or list of MSDS chemicals
provided by covered facilities to
SERC, LEPC and local fire depart-
ments.
Tier l/U hazardous chemical in-
ventory forms must be provided by
facilities to SERC, LEPC and local
fire departments.
Toxic Chemicals
(More than 300 chemicals and
categories)
(40 CFR 372)
§313: Toxic Chemical Release
Reporting
These chemicals are reported on a
Toxic Release Inventory to inform
government officials and the pub-
lic about the release of toxic chemi-
cals into the environment
Emergency Planning and Community Right-to-Know Fact Sheet —11
-------
-------
SUMMARY: SITE-SPECIFIC
HEALTH AND SAFETY PLAN
-------
-------
Summary: Site-specific
Health and Safety Plan
TP-l
Module Goal:
The student goal for this module is:
Given presented material and the components of a site-specific health and safety plan (HASP), determine
how the components relate to one another.
SHOMFM
Summary Sit»->pacific M*«tt)i and Safely Plan
1096
-------
Given presented material, list the components of a site-specific HASP.
Eleven Components of a HASP
Key personnel
Health and safety risk analysis
Site control measures
Training assignments
Medical surveillance requirements
Personal protective equipment
Air and employee monitoring
Spill containment program
Confined space procedures
Decontamination procedures
Emergency response plan
TP-2
Given presented material, order the components of a site-specific HASP sequentially.
Eleven Components of a HASP (cont.)
Key personnel
Health and safety risk analysis
Site control measures
Training assignments
Medical surveillance requirements
Personal protective equipment
Air and employee monitoring
Spill containment program
Confined space procedures
Decontamination procedures
Emergency response plan
TP-3
SHOMFM
Summmiy Sit»-»pocific Htaltti and Satoty Plan
1066
-------
Eleven Components of a HASP (cont.)
Key personnel
Health and safety risk analysis
Site control measures
Training assignments
Medical surveillance requirements
Personal protective equipment
Air and employee monitoring
Spill containment program
Confined space procedures
Decontamination procedures
Emergency response plan
TP-4
SHDMFM
Summery: S>t*-lpnd Smtoty Pt»n
-------
Case Study Review:
The Blue Ridge Chemical Facility
Health and
safety risk
analysis
Air and employee
monitorin
Medical surveillance
Plant
Training assignments!
i
Emergency response plan and
spill containment program
Debris
Personal protective equipment
Vats
iO OOi
JO OOi
O O OOi
O O O O i
O O OO!
.O O OO|
Confined space -LO__O_ O Oj
procedures /f '
Tank farm
DDDDDD
DDDDDD
TP-5
SHOMFM
Summary. Srt*-mp*ctftc H«mtft and Safety Ran
1G96
pace 13-5
-------
Given presented material and conditions that exist at a hypothetical hazardous waste site,
develop the sections needed to complete a HASP.
The Blue Ridge Chemical Facility
Drum
storage
N
1846
Carbon
tetrachloride
Debris
PMJ332-21-4
DDDDDD
DDDnD
C, / Asbestos
Vats
OO
OO
oo oo
o o oo
OO OO
o o oo
o o oo
Tank farm
TP-6
1. Key Personnel
Develop an organizational structure for a site inspection of the drum storage area.
2. Site Control Measures
A. Diagram the three work zones needed to conduct an inspection of the lagoon.
B. Develop two work practices for taking samples from the lagoon.
3. Decontamination Procedures
Determine the level of protection that would be needed for decontamination workers if a site
inspection were conducted at the debris pile and the tank farm simultaneously.
4. Visitor Policy
Develop policies for occasional onsite workers, media, and local, state, and other VIPs.
SHDMFM
Summary Sitv-ipacife Health and Safely Plan
1OS8
-------
Conclusion
Key personnel
Health and safety risk analysis
Site control measures
Training assignments
Medical surveillance requirements
Personal protective equipment
Air and employee monitoring
Spill containment program
Confined space procedures
Decontamination procedures
Emergency response plan
TP-7
Crossword Puzzle
Across
4. One of the goals of a spill containment plan is to
18. The HASP has components
the spread of contamination
Down
9. The HASP requires the designation of a site safety
28. Site control measures include the " system"
SHOMFM
Summary Sit«-»p*cific Healtji and Safety Plan
lose
p«S«t3-7
-------
AUDIT
GUIDELINES
-------
Audit Guidelines
TP-l
Module Goal:
The student goal for this module is:
Given health and safety plans (HASPs) and the U.S. Environmental Protection Agency (EPA) Health and
Safety Audit Guidelines document, perform an audit in accordance with the EPA Audit Guidelines.
SHDMFM
Audit Guideline*
10/96
page 14-2
-------
Given a selected chapter of the EPA Health and Safety Audit Guidelines, match the
sections of the chapter to the corresponding sections of a HASP.
Preliminary Evaluation
TP-2
Essential Components of a Preliminary Evaluation
A preliminary evaluation (PE) is instrumental in developing a HASP that tailors protective measures to
site-specific hazards that employees may face.
The following eight components are required in the preliminary evaluation:
1. Site location and size.
2. Description of offsite emergency response and onsite job functions.
3. Planned duration of employee activity.
4. Site topography and site accessibility by air and roads.
5 Safety and health hazards expected at the site.
6. Pathways for hazardous substance dispersion.
7. Present status of emergency response teams for onsite emergencies.
8. Hazardous substances and health hazards present or expected at the site and their chemical and
physical properties.
SHDMFM
Audit Guidelines
10/98
g* 14-3
-------
Chapter 3
Written Health and
Safety Plan
HASP
Di
D!
°;
D:
n:
Chapter 4
Health and Safety Field
Review
Chapter 5
Off-site Emergency
Response Review
TP-3
SnCMFM
Audit Gu.dei.ncl
-------
^
Environmental Response Training Program
Audit Guidelines 1995
Table of Contents
Appendix A. .Acronyms
Appendix B Other OSHA Standards
Appendix C Safety Check Off List
Appendix D Levels of Personal Protection
Appendix E Generic HASP
Appendix F~. OSHA Form No. 200
Appendix G Bibliography
TP-4
SHOMFM
Audit Guideline*
-------
Given selected sections of the EPA Health and Safety Audit Guidelines that correspond to a
HASP, determine deficiencies in the plan by answering Audit Guidelines questions.
HASP
d:
a:
a:
Site-specific Health and Safety Plan Exercise
Audit the following health and safety plan using the
worksheets, which are taken from Chapter 3 of the Audit
Guidelines document. If you answer "no" to a question,
provide an explanation in the blanks provided.
SHDMFM
Audit Guideline*
1O98
-------
Site-specific Health and Safety Plan
Site Description
The Johnson Ceramics site is located on Prairie Meadow Road in Falls Creek, Beaver County, Indiana.
The plant is an abandoned china-producing facility containing a lead-contaminated ceramic residue. This
contaminated residue was discharged from the ceramic facility into a small stream which fed into a
settling lagoon. The lagoon discharges into an overflow culvert beneath a Conrail track line that leads to
a wetland area.
Names of Key Personnel and Health and Safety Personnel
The following personnel and organizations are critical to the planned activities at the Johnson Ceramics
site:
U.S. EPA On-scene Coordinator
Prime ERCS Contractor
Jack Downs
A.J. Environmental
Response Manager
Site Health and Safety Officer
Fred Parker
Ralph McDonald
Task/Risk Analysis
Task 1 - Site walk-through assessment
Task 2 - Sampling onsite (soils and lagoons)
Task 3 - Sampling offsite (stream and wetland)
Task 4 - Excavation of contaminated soil
Task 5 - Lagoon solidification
Task Contaminant
Source
Concentration
PEL/TLV/IDLH Consite^
Route of Symptoms of Monitoring
Exposure Acute Exposure Device
1-5
Lead
0.05 mg/m3
0.15 mg/m3
100 mg/m3
soil, air, waste
Inh, Ing, weak, insom, X-ray fluores
Con low wt, anemia,
abdom pain,
tremor, kidney
dis, irrit eyes,
hypotension
Audit Guidelines
1O98
-------
Task Risk Analysis: Physical Hazard Assessment
HAZARD (Y/N) TASKNo(s).
1. Noise
2. Heat - Ambient air
- Hot process - steam
- Hot process - incinerator
3. Cold
4. Bain
5. Snow
6. Electric storms
7. Confined space entry
8. "Hot Work"
9. Heavy manual lifting/moving
10. Rough terrain
11. Housekeeping
12. Structural integrity
13. Neighborhood
14. Remote area
15. Compressed gas
16. Diving
17. Using boats
18. Working over water
19. Traffic
20. Explosives
21. Heavy equipment operation
22. Lifting equipment operation - Crane
23. - Manlifts
24. Working at elevation
25. Using ladders
26. Using scaffolding
27. Excavating/trenching
28. Materials handling
29. Hazardous materials use/storage • Flammable liquids
- Oxidizers
- Corrosives
30. Fire prevention/response plan required
31. Fire extinguishers required
32. Demolition
33. Utilities - Underground
- Overhead
34. Electrical - General
- High voltage
35. Welding/cutting/burning
36 Hand tools
37. Power hand tools
38 High pressure water
{Y
4,5
PREVENTION
bearing protection^
( Y
( Y
2,3,5
buddy system
4,5
( Y
Employee Training
At a minimum, all personnel will be trained to recognize the hazards onsite, the provisions of this site-specific HASP, and
personnel responsible for safety at the site.
-------
Worksheets
Taken from Chapter 3,
Written Health and Safety Plan,
Health and Safety Audit Guidelines
The HASP elements in the box to the right do not appear in the same
order as provided in 29 CFR 1910.120(b). Instead, these elements are
arranged in the order in which their associated relevant paragraphs
appear within 29 CFR 1910.120.
This checklist portion of the EPA Audit Guidelines permits the user to
identify inadequacies in the HASP. Answers to the HASP checklist
questions should be ascertainable by reviewing the HASP,
M t*i*mmt* HASP *~U l
i n* nlym f«r =•* au u* m*
> br <«fa rf*. *• lab mii
3.1 Names of Key Personnel and Health and Safety Personnel - 29 CFR 1910.120(b)(2)
Key personnel may include individuals with job titles such as Project Manager, Field Operations Leader,
and Site Supervisor. A Site Health and Safety Officer should also be designated and always be onsite
during operations.
3.1.1 Are key personnel identified in the HASP?
[YES]
[NO, EXPLAIN]
3.1.2 Are the health and safety personnel (including alternates) identified in the HASP?
[YES] [NO, EXPLAIN]
SHDMFM
Audit Guidelines
1096
-------
Note: During the field audit, verify key site personnel and the presence of the site "health and
safety officer.
3.1.3
3.1.4
SUMMARY OF RESPONSES
[YES]
[NO, EXPLAIN]
3.2 Safety and Health Risk Analysis for Each Site Task and Operation - 29 CFR 1910.120(b)(4)
Simple risk analyses can be conducted based on the chemical contaminants of concern, the affected
media, concentrations, and potential routes of exposure. These elements are essential to any analysis of
health risks. OSHA-PELs and IDLH levels should be provided at a minimum for compounds, which have
the potential to become airborne. These values can be located for many compounds in the NjOSH/
OSHA Pocket Guide to Chemical Hazards. 1985, as well as in 29 CFR 1910.1000 as published on
January 19, 1989 (FR Vol. 54, No. 12).
The HASP also should incorporate some safety risk analyses to address anticipated onsite operations.
Certain field operations may be less safe when conducted at a hazardous waste site than if conducted in a
more conventional environment. In addition, certain jobs at a hazardous waste site differ in their
potential hazards. For instance, the job of a heavy equipment operator or materials handler would
generally be a more hazardous job than the job of a supervisor because of the increased risk of direct
contact with the concentrated waste. Methods and procedures for reducing safety hazards should be
provided in the HASP.
The EPA Super-fund Public Health Evaluation Manual (1986), may be useful to users as a tool for
performing more sophisticated health risk analyses attributable to common chemical contaminants found
at hazardous waste sites. The Guidelines enable the user to calculate hazard indices for chemicals
without carcinogenic potential, and to calculate the likely increase in cancer incidence rates associated
with exposure to carcinogens at the hazardous waste site.
3.2.1 Does the HASP address methods to deal with potential safety problems (e.g., heavy
equipment operations, presence of live electrical sources, and slip, trip, fall hazards)?
[YES]
[NO, EXPLAIN]
SHDMFM
Auait Guidelines
1096
-------
3.2.2 Does the HASP contain a safety and health risk or hazards analysis for each site task and
operation found in the workplan?
[YES]
[NO, EXPLAIN]
Note: Verification of incorporation into the HASP of health and safety risk analysis for
each site task and operation occurring in the field should be determined during the
field audit.
3.2.3 Are chemical contaminants, affected media, concentrations, potential routes of exposure,
and health effects identified in the HASP?
[YES]
[NO, EXPLAIN]
3.2.4 Does the HASP identify the appropriate PPE level for each site task and operation?
[YES] [NO, EXPLAIN]
3.2.5
3.2.6
SUMMARY OF RESPONSES
[YES]
[NO, EXPLAIN]
SHCMFM
Audit Guideline*
tose
(•9*14.11
-------
3.4 Employee Training - 29 CFR 1910.120(e)
The employee's initial health and safety training, annual health and safety refresher training, on-
the-job training, supervisory training (where applicable), first-aid training, CPR training, and other
training relevant to the performance of hazardous waste site operations should be indicated in the
HASP for all individuals involved in onsite activities.
3.4.1 Does the HASP indicate that all onsite employees meet appropriate health and safety
training requirements?
[YES]
[NO, EXPLAIN]
If NO, please go on to questions 2-5, while if YES please go on to question 6.
3.4.2 Does the HASP indicate that all individuals expected to be onsite have the requisite initial
health and safety training?
[YES]
[NO, EXPLAIN]
3.4.3 Does the HASP indicate that individuals functioning in a supervisory capacity have the
requisite supervisory training?
[YES]
[NO, EXPLAIN]
3.4.4 Does the HASP indicate that all individuals functioning independently of an immediate
supervisor have a minimum of three days of actual field experience under a skilled
supervisor (on-the-job training)?
[YES]
[NO, EXPLAIN]
SHCMFM
1098
S14-12
-------
3.4,5 Does the HASP indicate that all individuals who had their initial health and safety training
longer than one year ago have also completed the required annual health and safety
refresher training?
[YES] [NO, EXPLAIN]
3.4.6 Does the HASP indicate that employees have had training to recognize the symptoms and
signs of overexposure to chemical hazards?
[YES] [NO, EXPLAIN]
SUMMARY OF RESPONSES [YES] [NO, EXPLAIN]
SHDMFM -- 1O98
Aud.1 Guideline! paj«14-13
-------
Case Study Exercise
HASP
D:
a-
a =
D:
Audit the following health and safety plan using the
worksheets, which are taken from Chapter 3 of the Audit
Guidelines document. If you answer "no" to a question, provide
an explanation in the blanks provided.
Once all the groups have finished, the instructor will ask for a
volunteer from each group to present group responses to
various sections. During each group presentation, the
instructor will ask for additional comments from the remaining
groups.
-------
SSP: 10-14-94
Rev. no.: 2
Safety Plan TST» • J007 -11
Site N.m. Chandler Gas Works
ABC Environmental
SITE SAFETY PLAN
Site Address' 10th Street between Main and Cedar gjte Contact; Gary Mon (PSE&G)
Streets _ Phone Number; J4UH30-7822 _
Chandler. NJ 08888
Other Contacts: Robert Bobbet (PSE&G)
(800) 762-2449
Purpose of Site Visit' Conduct onsite and offsite reconnaissance
Proposed Date of Work: 10/23/94
Proposed Site Investigation Team:
ABC Environmental Personnel:
Bob Carry
Dick Trophy
Christine Sacks
Responsibilities:
Site Manager
Site Safety Officer
Surveillance
Other:
Purpose:
Plan Preparation
Prepared by:
Approvals:
Health and Safety Manager:
Office Manager:
.U-
&*UL^*2&^fa—
Date
10 I/O
CJ^&A^v-V^M^U^A^,
/o
SHDMFM
AuQit Guideline
1096
-------
SSP: 10-14-94
Rev. no.: 2
Safety Plan No.:-
J007 -11
Site
Chandler Gas Works
Background Information:
Site Status: Active
Inactive
Unknown
Site Description (be specific; include topography, structures, size, etc.):
The site is generally level and is currently a suburban residential neighborhood. No evidence of former gas
works is apparent.
Site History:
The Chandler Gas Works site is located between Main and Cedar Streets on 10th Street in Chandler, NJ.
For approximately 11 years (1894-1905) water gas was reportedly manufactured at the site. Public service
Gas Company leased the site prior to 1905. Activities preceding its current use are unknown. Presently the
site has residential dwellings built atop of it. Five residential lots appear to be Involved with homes built
during the early 1950s based on ownership records.
Monitoring used on previous site work or previous sampling data (include dates and by whom work was done):
NJDEPE has groundwater and soil (surface and borings) data at the site. This information has not yet been
made available to ABC Environmental personnel.
SHCMFM
Audit Guidelines
10/36
page 14-18
-------
Safety Plan Mn • J°°7 ' U
Hazard Evaluation:
Waste Types: Liquid
Corrosive
S Volatile
Unknown
SSP: 10-14-94
Rev. no.: 2
cir, Nam, Chandler Gas Works
S Solid S Sludge Vapor
Ignitable Radioactive
•/ Toxic Reactive
Other:
Medium
Hazard Identification/Ranking (based on task and contaminant).
Task: Onsite reconnaissance
-------
1
— 6
c
£ >*
Jx
*•*
1
^1
A
feme- Chandler G
"^ "S S ^ « .!
llllli
.•f
si -a *
a.s ,2;fVi
ssarllelj
-
?si
.2 "«3 f> *
"5 *^s of 3 -S
1 1 gf 1 g C
*~* O* s_^ ^ a* *^s
O J-
^^ ctO
CS w
,0i±=
HO.M
u
B
^ •! Ill
T '™ ;E J -g
•-H
^*
1
r-
Tf * " 0 I
^ v, 'f r= 'C C
s^ jrt ^ O 3 ^
"fe g
£ i
u
1 J
*** is
c
5* 8
C c
3 O
trt
§
w ^
^3 .a S
c .. sa.
J2 H (23
^ 5 i " „
1 1 in
«
3 :
1 »
**
j
'
|
c
r*
*
V
IT
O
3
w
*
^ O
h
i i
E
Q
D
f^J
J»
C
i
j
• 3
1
i
a.
a
I
1
*•
i
.1
i
i
4 e
1 j
J
S
: 1
1
4
1
!
J
"o
IT
i
ll
!M
C"
&
"5
E
VI
>
E
-1
1
5
J
E
o
V)
i
in
E
2
3
r<
1
1
c
1 E
|
C
If
£
^
v
a\
SO
00
' <
: >
: c
e
ll
E
a
Q
V)
2
1
•
l
Saeciil Notice:
E
a.
a.
i/i
f«4
1
j
j
e
^
ll
>
Spedil Notice:
±
•<
>
CM
J
£
c
c
a
r»«
B
a.
•
•
>
e
i
1
E
i a
. a
o
s
Special Notice:
E
&
a.
o
f^i
1
E
_
B,
'i
j>
' 1
&
±
V O
n
£
o
•S3
'5
o
mucus membranes,
systemic irritant
eve irritant, mucus
membrane irritant
through inhalation
e
.i
^s
o
.*"
'S
o
ingestion, affects
x
^
m
S
S 1
1 1
a o
'5
M
S
J
a
c
^£
e
3
90
5?
5
o
a C
z u
« J5
g a.
'e
V,
S
J
O
c
e
3
«N
\f\
* «
§£
u
i— a
t_
c J=
S e
S <
'o
CO
e
j
o
c
jc
c
3
r-
t
fS
I J
— «
•£
M 9Q
5 Z
'S
V9
C
*
o
c
»££
e
3
1
a
1 *>
3 £
o
§
CASNo
SHOMFM KJB
Audit Guidelines ~" po(|e14-1
-------
?
V
cu >
C/5 U
J2
u
0
<
«
QP
t.
4i
•o
e
0.
E
-2 e'lx »»
I'lill
HilL
§1
111;
.
££ =
I1*!?1!
s o O* BB C *•
5j£c-> £i
° ~s»
S 0
1 pi
X Js
sl -f
IIS
u II
•O "S) 1 S 1
IJJ
*
r^
•*
5 1 a"2 S 1
•^ f |SII
,^ S M c/i o
*n 3
S 0
ll
1!
H*
C
a, -2
C- »
M
U Jj
S S
S u
!
i_i
O -S -o
Z | u£
^^^ rt ^ ,o 2
^^B ^-o? 'i -
^^^ iT -x i I -1
oo 5 = u! S
«
i
f
i
s
c
e
^^
«
CI
a.
>
IT
OS
•<£
o
o
II
i
°
0
5
1
3.
I
E
c.
a
V)
I
•o
^
C
(*
1
c
c
c
r^
r-
U
o,
>
ri
sc
00
I 1
; z
) O
ll
S
a
c
8
i-^
5
li
s
a
*•*
i
1
w
flj
i
I
1 1
|
"S
E
^.B
C
e
£
li
&
&
"5
E
Ml
O
O
5
il
s.
J
c
o
2
j
J
"B
e
in
o
o
£
}
i
&
s
fjjj
^
5
|
I
E
o
o
X
0
>
n
]
|
&
S
VI
£
' 1
j
;c
B
"S
E
**
1
li
"a
s
V)
i
1
g
j
2
2
- 1
i
>
-
d
|
g
|
o
W "^
0 U
c
V,
'c
carcinogen.
'5
VI
*>l
•^
A
•^j
eye/skin irri
.0
•o
M
cn
U
e
V
u
a
noison. mut
'c
,
(ft
a
en
U
e
_o
*•
^
poison, inha
'S
en
T3
1
g
c
C/5
U
tj
'S
Gn
E
r°
•a
'5
&
S
O
e
-X
e
3
S
s
ffi
e
o
c
^e
c
S
t
o ™
M O
< ^-
C
e
e
n*^
s
3
oo
90
i i
" 1
z S
" *
< ^
I
e
o
e
^£
B
S
as
o
Tf
p-
3 )5j
z W
3 ^
B
^
O
C
^£
e
3
-.
I *
2 4)
? £
£)
0 C
^ n
v> •*•
< ,>
V)
1
§
r-
o
z
o
Q
"Z,
VI
3
3
Z
*/l
<
0
SHQMFM
Aud*t Guidelines
1OQ6
paga 14-19
-------
2 o
OL,' >"
Wl «
CO Oi.
J2
I
OS
O
f
•o
w
T
•9
V) __
1 1
•S 3
s «
is -o
^ S
1 *
T: u
I 1
«* ^
o «j
«
w?
_O
•**
'•&
O
u
£
V)
•o
-1
letected.
£
«
•o
c
I
^
w
nt
.a
V
o
•9
o
_o
'•6
w
1
VI
£
a
1
5
I
flu
ON
•*«
e
"5
«•*
i
^
V
V
.c
-o
i
e
M
B
U
a
•o
w
3
2
o
W)
ervations
M
o
V
7r1
J=
a
o
H
^
u
Q
u
W§
u
_c
^d
-------
SSP: 10-14-94
Rev. no.: 2
Safetv Plan No.: J007 " U
SiteName:-
Chandler Gas Works
Summary of Proposed Activities:
Onsite and offsite reconnaissance of residential neighborhood that occupies the former gas plant site.
Monitoring Procedures:
Site Monitoring Equipment:
X HNu
X OVA
Photovac
Draeger Tube(s) & Pump:
X TLD Badge
X Monitor-4
Explosimeter
O2 meter
Victoreen Radiation Detector
Other:
Methods and Frequency of Surveillance: (For compounds >10% PELs, see page 4)
Continuous air monitoring using the above throughout the activity onsite. Use of TLD badge for duration of
field work activity.
Monitoring Equipment Calibration:
^ OVA
Secondary check is required as per Health and Safety SOP prior to each usage. If secondary check is
off by more than +10 percent primary a calibration will be performed.
i. HNu
A single calibration conducted prior to an activity will be considered acceptable for periods of use up to
three days, after which calibration gas must be used as per Health and Safety SOP. If the reading
deviates more than +15 percent from concentration of the calibration gas, the instrument requires
maintenance.
Monitor-4
A batter)' check and a response check was made with a check source (Coleman mantle) prior to leaving
the office and will be made prior to engaging in onsite field activities on a daily basis.
Other:
SHCWFM
Aod't Guidelines
tO/96
page
-------
SSP: 10-14-94
Rev. no.: 2
Safety Plan No.:
J007- 11
Site Name:
Chandler Gas Works
Decontamination and Disposal:
Personnel Decontamination Procedure: (X) level to be utilized
Level A - Segregated equipment drop, boot cover and glove wash, boot cover and glove rinse, tape
removal, outer glove removal, suit and hard hat removal, SCBA backpack removal, inner
glove wash, inner glove removal, inner clothing removal, field wash redress.
X Level B - Segregated equipment drop, boot cover and glove wash, boot cover and glove rinse, tape
removal, boot cover removal, outer glove removal, SCBA backpack removal, suit and
hard hat removal, inner glove removal, inner clothing removal, field wash, redress.
X Level C - Segregated equipment drop, boot cover and glove wash, boot cover and glove rinse, tape
removal, boot cover removal, outer glove removal, suit/safety boot wash, suit/safety
boot rinse (canister or mask change), safety boot removal, splash suit removal, inner
glove removal, inner clothing removal, field wash, redress.
^ Level D - Segregated equipment drop, boot and glove wash, and glove rinse.
Modifications (specify):
Equipment Decontamination: Akonoi/water solution with tap water rinse.
Personal Decontamination: Alconox/water solution with tap water rinse.
Disposal Procedure for Investigation-derived Materials: All aqueous-derived wastes will be disposed of onsite.
All dry wastes (decontaminated) will be disposed of offstte. _^_^__
IONIZING RADIATION:
Normal background 0.01 to 0.02 mR/hr.
If less than 2 mR/hr, continue investigation with caution.
If greater than 2 mR/hr, evacuate site.
NOTE: Background 10-20 CPM on Monitor-4.
10/90
pag* 14-22
-------
SSP: 10-14-94
Rev. no.: 2
Safety Plan No.:'
J007 - 11
Site Name:-
Chandler Gas Works
SITE OPERATING PROCEDURES/SAFETY GUIDELINES
1. Always observe the buddy system. Never enter or exit a site alone, and never work alone in an isolated
area. Never wander off by yourself.
2. Always maintain line-of-sight,
3. Practice contamination avoidance. Never sit down or kneel, never lay equipment on the ground, avoid
obvious sources of contamination such as puddles, and avoid unnecessary contact with onsite objects.
4. No eating, drinking, or smoking outside the designated "clean" zone.
5. la the event PPE is ripped or torn, work shall stop and PPE shall be removed and replaced as soon as
possible.
6. Be alert to any unusual changes in your own condition; never ignore warning signs. Notify Health and
Safety Coordinator as to suspected exposures or accidents.
7. A vehicle will be readily available exclusively for emergency use. All ABC Environmental personnel
going onsite shall be familiar with the most direct route to the nearest hospital.
8. In the event of direct skin contact, the affected area shall be washed immediately with soap and water.
9. Copies of the health and safety plan shall be readily accessible at the command post.
10 Note wind direction. Personnel shall remain upwind whenever possible during onsite activities.
11. Never climb over or under refuse or obstacles. Use safety harness/safety lines when sampling lagoons,
stream beds, and ravines with steep banks.
12. Hands and face must be thoroughly washed before eating, drinking, etc.
13. Any modifications to this safety plan MUST be approved by the HSM or designee.
Special Procedures:.
OFFSITE SAMPLING ACTTVTITES
Offsite activities delineated within the scope of this Site Safety Plan (SSP) will be conducted:
Yes
No
If yes, will it affect any of the following areas:
Emergency contact information
Directions to hospital
Decontamination procedures
_____ Other:
Yes
No
Provide attached pages to describe required modification for offsite activities.
SHCMFM
AuBit Guidelines
10/96
page 14-23
-------
SSP: 10-14-94
Rev. no.: 2
Safety Plan No.:
J007 -11
Site Name: Chandler Gas Works
Confined Space Entry
No attempt will be made to enter abandoned buildings, manholes, tanks, or any other confined areas.
Confined space entry will be made into the following:
Medical Surveillance
No site-specific medical surveillance is required for this task.
Medical surveillance will be as follows:
Personnel Monitoring
Personnel monitoring will include only the use of the TLD badge. No further personnel monitoring is
required.
Personnel monitoring will consist of:
SHDMFM
Audit Guidelines
10*6
(age 14-24
-------
SSF: 10-14-94
Rev. no.: 2
ATTACH PERSONNEL TRAINING SHEET TO THIS PAGE
SHDMFM
Audit Guidelines
1096
page 14-25
-------
cu >
00 «J
t
I
I
o
rt
Crt
SHDMFM
Audit Guid
O
2
u.
<
on
Q
<
H
3*8
fl
Is
4Ju
oo 53
ill
*•»*»•**•*•«*•«*
Si Si Si Si Si Si Si
o o o o o o o
>->>.>.>.>.>.
Tf •» ^t "t ^ ^ ff
Si s: Si Si s: Si s:
e8
in 1/5 «
o >?5 o
d 5 c; c c 5 c
r- TT r» i/j «n n oe
o o o o o o o
'T < ^T
g Si
H M
o 55 o 55 5? «?5 5?
I-H O «-• O O O O