. ,
00-3
United States
Environmental Protection
Agency
Region 4
345 Courtland Street. NE
Atlanta GA 30308
October 1980,
vvEPA FIELD HEALTH
AND SAFETY
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Obtbber ^3r 1980
FIELD HEALTH AND SAFETY
(1. PURPOSE. The purpose of this manual is to outline
a safety program for all employees in Region IV who
are, or could be, by virtue of their duties and
responsibilities, engaged in field activities.
2. BACKGROUND. In 1980 EPA Headquarters declared that
hazardous waste site investigations and emergency
spill response were among its top priorities. This
Agency is also mandated by a number of laws and
numerous regulations to engage in field activities
that involve or could involve exposure of Region IV
.employees to hazardous materials. A 1980 report by
EPA Headquarters Office of Occupational Health and
Safety indicated that there were 148 Region IV
employees engaged in various field activities.
EPA has a responsibility to protect.its employees,
and the employees have a duty to ensure that they do
not exceed scope of duty or expertise in such field
activities. This document then is an effort to
inform the employee of his or her function or duty
arid a commitment that the Agency make every effort
to protect the employee.
3. APPLICABILITY. This Order is effective for every
EPA Region IV employee. Most specifically, any
employee who leaves the confines of the buildings
operated by Region IV and under the jurisdiction of
the Regional Administrator is covered by this
Safety Manual. This also includes persons not
employed directly by EPA but who 'are under specific EPA
Region IV control or contract.
Rebecca W. Hanmer
Regional Administrator
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itfA^TH **© SAFETY
FIELD HEALTH
SAFETY
~
f' INDEX - REGION IV
FIELD HEALTH AND SAFETY MANUAL
SECTION
TITLES
PAGE NO.
I .
II.
IV.
V.
Purpose . ..................... ...... ..... 1
Policy ..... ............ . ..... .... ....... 1-2
Authority ........................... .... 2
Responsibility
A. Categorization ......... . . . . ......... 2-4
B. Training and Equipment ... ........ .. . 4-5
C. Medical Services ....... ............. 5-6
Procedures and Duty Categories
A. Definitions of Categories . . . . ....... 6-8
B. Definitions of Terms used in SOP..... 8-9
C. Seenafios for Safety Program by
........... . ......... ....... 9-48
Tables
1 ............ ................... . ...... .... 19-20
2 ...... ;..... ..................... . ........ 31
Appendix I ; . . . ... ................ ............. 50-52
Appendix II ... . ...... . ............ . ........... 53-56
: Appendix II I . . . . . ................ ..... , ....... 57-62
? AppeMix IV . . . » . . . . ................... . ....... 63-65
l&v
TN 1
OftteiMATOIti 4B*EE
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BWMONWEHTAt PROTECTION AGENCY
'
M ANUAL
FIELD HEALTH
JJUTO SAFETY
FIELD HEALTH AND SAFETY MANUAL
I* PURPOSE; The purpose of this manual is to establish
-Standard Operating Procedures for field health and
safety.
A. Each .person in EPA Region IV engaged in any
'field operation (operation outside the doors of any EPA
^operated facility) that involves in any way any
hazardous material that is identified by EPA as:
(1) a "hazardous substance" per CWA $311
: (2) priority pollutants per CWA §307
(3) a "toxic substance" per TSCA
(4) a "hazardous waste" per RCRA §261
(5) pesticides per FIFRA
(6) a "hazardous air pollutant" per CAA, $112
(7) a "hazardous material" per 49 CFR
shall know what her/his duty is concerning said
^substances, what specific safety scenario applies to
the execution of that duty, and shall be appropriately
trained, equipped, and medically monitored by EPA (or
;its agent) in accordance with her/his involvement with
these chemicals.
B. Any extension of duty associated with the
materials in Item I above at the initiative of an
employee, beyond the specific "field" category which
that particular employee is either assigned to or
specifically qualified for by experience and training,
is prohibited. Such an assumption of duty by an
employee or person under the control of EPA, Region IV,
involves the assumption of all risks on the part of
that person. Also, no management official or
'supervisor is authorized to order, direct or otherwise
cause an employee's attendance at a situation that is
known or reasonably suspected to be more hazardous than
that for which the employee is qualified and adequately
trained and equipped.
II. POLICY. It is the policy of EPA, Region IV, that
(1) all employees will be classified into the
TH 1 (10-23-80)'
ORIGINATOR: 4E-*EE i
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covered by the categories to whi
uri.til the requir
cation have been
tjqaih..' employees
categories established in ..th.ifj>iF:
(2) an employee ^cannot perj
MANUAL
ed health
iei$ '.Health. and Safety';.-'^.:; *;:• hx^ ••£•£:• --^
•prifr those
rn^he/he is
ig and training
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and monitpi?
as set out in th|is order
their own safety
arid local agenci
Or! FIT, shall ut
programs. In si
ch^arge* agency o
involved in that
it: is assumed thit t:h«^
follow this SOP or, to the ;ex
author i ty, be ba:: r eel f r dm
involved with chomicals.
who are EPA guesus, and
outside the Region.
:uatiops ^
: when, elno
saate
AUTHORITY.
Safety Procedure:
issued pursuant
authority in Chai
Manual to take
Health and Safetj
wars developed unc
authority in 1-4
the Safety Office
the Regional Admi
establishing a
(Appendix IV).
If and when s
in total or in ps
IV. RESPONSIBILI
Natibnai
rt replace
A. CATEGORIZ
This order
employees whose
seven categories.
personally desig
^islS^-,*^
no fornl
the
ter 1-A-
ecif ic acticins
This
er the
of the Region
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duties fall,-
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MANUAL
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FIELD HEALTH
AND SAFETY
Categories of Division Directors, the Deputy Regional
Administrator,' and Office Chiefs responsible to the
Regional Administrator.
Division Directors are delegated the authority for
the Field Health and Safety categorization of each
position in their Divisions, and will personally
designate category placement of their Branch and Office
Chiefs. ' «
The Branch Chief will then be responsible to the
Division Director for designating the collective
categories of each Section in her/his branch relative
to the Section's areas of responsibility and will give
guidance to the First Line Supervisor on how each
individual position should be categorized. The Branch
Chief will designate the categories of all supervisory
positions in the Branch.
The "First Line Supervisor", down to Section Chief
level, will ultimately be responsible for assigning
each employee under her/his supervision to the Field
Health and Safety Categories that the employee's
position description requires. The supervisor will
give to each current employee a copy of this SOP.
After the employee has had an opportunity to read a
description of the categories to which she/he has been
assigned and responsibilities, liabilities and training
involved, the employee must then sign a statement that
she/he has read and understands this SOP. The
Supervisor will amend the Position Description of each
employee (by filling out Form 3150-5, Position
Description Amendment) to indicate the categories to
which that individual has been assigned.
All new employees will have in their job
description the Field Health and Safety Categories to
which they will be assigned and will be given copies of
this SOP in their orientation packets. Their
Supervisors will be responsible for discussing the
categories with the individuals and having them sign
the statements during the new employee orientation.
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: The Safety Officer will;^i/ife
maintaining an Employee Safety Fi
all safety-relate^ matters (train
of Form 3150), pertaining to
Region
B. TRAINING \ND
Regional
responsible for ihsui:ing
Region IV, receives the
required for the field
to which she/he has been as« i
after the issuance of thiar ^CiP>
safety category(ibs) requires pel:
training shall receive
Categories l-in
identified for th
Each branch in th
ponsible for."' . •.. :-..'•'.-'-'^ ,,_,
*;iifoich will cpnta;jt»':^;#%^^
ng, duty categoric
employee "
•:- :3-,i'-:;^f SSf m
Categories I-lll
each employee. R
safety t ra in i ng a
storage of safety
division lies wit
The developme
a safety t r a i n i ng
training priority
Field Health and
EBB Branch Chief,
training pertaini
proposed training
requirements of
committee will be
this SOP. The Fi
shall be composed
have accefisj
partic'tfJ^i^.^tl
regional offi<
Bsponsib ill; ty -
'
Jiwtiply
i roployee in TSj^^m^,,:^^^^^
»g and;•mquat^^^:^^-'^:^',^-
*•*-
-:%ji>. soon as |»6iM:«Ma^Mf •?V-r-\^
^employees • wiKBii*^;-- -'v^.'- J ^-^.
refresher ,.0 ; :'':^:^:.;^T"•-ft&':
Each person' irj--:;;/---"7"..-C !..V:;:^"
leld equipment :';.;; •j^^rVv.^JV;'.'
in Section
employees in
le equipment for
funds
r^
^P
O^jj.
i','i?r •-- i • _
id
equipment;;
i the Division
ht, implementat
program shall
this
•(1)
(2)
(4)
The Chief (or alternate)
The Reg iOna 1 ~ " " "
A repres >ntative
Committee
A. Union
One repr jseritative
' ' "
(6) Represen
of the f<
TM 1 (10^23-80)
:atives
>1 lowing t
, chaired by the
art««dinq and updating
Safety SOP
to review
ng to field cafe
is appropriate
Field: Health
ponsibtfe for
>ld Health and
of: .. •"
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FIELD HEALTH
AND SAFETY
and Hazardous Materials Division
. Enforcement Division
. Water Division
. S & A Division
The responsibility for ensuring that all employees
receive the required safety training is shared jointly
by the Regional Administrator, Division Directors,
Branch Chiefs and Supervisors. However, the day-to-day
responsibility for insuring that all employees have
requested the necessary safety training must rest with
the supervisor. Approval of said requests is of course
the responsibility of the appropriate Division
Directorr who is responsible to the Regional
Administrator. Each supervisor shall keep a log and
tracking document to insure that all employees under
her/his supervision receive the required training or
refresher training for each specific safety
category(ies) to which they are assigned.
Additionally, each supervisor up to the Section Chief
level shall be required to personally take all safety
training for each SOP field safety category to which
she/he has employees assigned.
The Safety Officer will keep a copy of the Safety
training certificates for each employee in her/his
Employee Safety file, along with copies of the log and
tracking documents mentioned above. The Safety Officer
must perform an audit on each employee semi-annually to
insure that the training profile of the individual is
.always appropriate for the duty required. Deficiencies
noted by the Safety Officer will be reported to the
Regional Administrator.
C. MEDICAL SERVICES
The Regional Administrator is ultimately
responsible for providing the EPA Region IV Baseline
Medical Data Program and Medical Monitoring Program as
outlined in Appendices I and II.
The Regional Health Unit will provide the Baseline
and Monitoring programs and will maintain medical files
TO
HMJ
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te&v-
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and
i&ig^nal Jfeajth JIL.^, ...^,;
superviscjr will be
and tracking
Wedical Moni tor ing
i a problem
assistance
immediately of t*e
V. gJtC?CgDURES AND
ft; DEFINITIONS
(i.>i Catjggory I i
close proxi
or all of the mat
aT0 • Or way -be present' in $fc
state. It also includes hai
Vi JMiterials which may "
or stat
Section 311 Spill
the Louisville seWer episode,,
aafeerials, and cl
v^isalsexial sampling
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in
An«
orlng^
throuti
MANUAL
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document
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Response ,
^se pro^liBtity x
or any
ttie" handling or samplinig of
Category II involves
risik^of exposure to haiair
Section I.A, under contcO
potential for encountering,
o| equipment fail)ire,
btftyond the control of
, p«9ticide investi< jat iohs;
conducted in muni<:ipa
toxic or Ua
when s
streams or ahead of the t
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MANUAL
FIELD HEALTH
AND SAFETY
sampling); sampling of ^.eachate streams from hazardous
waste sites 'iw''Other^fcifoiples collected within
hazardous wa9te sites where it is improbable that
hazardous Conditions exist; inspection of potential
hazardous waste disp$£a$ sites where uncontrolled
hazardous materials are not in evidence; routine permit
related activities a,t controlled hazardous waste
generators, storers, treaters, disposers; and 311
hazardous waste sitf-
<3> Cat
investigations, inspections, sampling and non-sampling
investigations conducted by personnel in the vicinity
of, but off site frpinv a hazardous waste site or dumps
or facilities where hazardous materials may be
present. Also included;are sampling investigations in
areas known to be free of hazardous materials.
(4) Category IV involves contract or non-Region IV
personnel working for or with the agency in situations
where EPA is generally in charge of the total episode.
These entities will work under their own SOP dealing
with safety or if they have no SOP they will be working
subject to this SOP to the extent that EPA has legal
authority. Certain examples are Section 311
contractors in clean-up operations, Field Contract
Teams such as FIT and TAT. Other groups such as NEIC,
ERT, and Headquarter's contractors are also in this
category.
(5) Category V includes Region iv employees engaged in
"damage Survey investigations" as assigned on a mission
basis by FEMA (Federal Emergency Management Agency) and
coordinated by EPA1s disaster coordinator (the Chief of
EEB).
(6) Category VI involves legal investigation, permits
investigation, enforcement investigation, information
gathering and investigation of drinking water problems
where there is little possibility of exposure of
personnel to tpxic or hazardous materials.
(7) Category VII is referred to as the VIP category.
It involves persons who have a need to get within the
Ill ine;lu4es reconnaissance
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m:
vicinity of the situation, but n
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MANUAL
FIELD HEALTH
AND SAFETY
(9) Site - geographical boundaries of a chemically
contaminated or potentially contaminated area where
visitations by EPA personnel are required for sampling,
monitoring or directing the containment and removal of
contaminated drums, soil and/or contaminated water.
(10) Scene - a geographical area where an emergency
situation such as a spill or accidental discharge of
oil or hazardous material has occurred. The area of
the scene could be limited to location of the accident,
or expanded several miles to cover areas such as banks
of a contaminated stream where pollutants are in
movement.
(11) TAT - Technical Assistance Team; contractor group
that provides support for EPA Emergency Spill Response
operations.
(12) FIT -Field Investigation Team; contractor group
that provides support for EPA hazardous waste site
investigations.
C. SCENARIOS FOR SAFETY PROGRAM BY CATEGORY
This part discusses the safety program for each
category in a detailed manner, covering qualification
of personnel, training, pre-entry planning and
investigations required, recommended safety gear,
on-site safety and decontamination procedures as
needed. While this SOP in general is directed toward
employee initiative, this part provides for the
flexibility of "on the job training" where
circumstances allow. When the employee and the
on-scene project leader/OSC both agree that the
particular employee may be taken on scene to a
situation for which she/he is not qualified,
concurrence of the qualified individual(s) escorting
this employee must also be obtained. Responsibility
for the safety of that person rests with the on-scene
project leader/OSC.
TM
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MANUAL
CATBGORY I
This Section
for the safe conduct
to envi
4Bi^^tc;:eh«»iipil% at ^
...a High Risk
close
any'
proximity
or
conditi
ials which
ti<|n.-.pr state, :
ld be Section 311
specific
;; samplin
; proximi
;•• sampling
the handling or
•, •"'• : - • • materials.
••; '• -•"•';-- This Section! is- a«s;igrMsd
I federal \On~Scene Coor*iti*|t^irii
supervisors, project l«ad«i;sj
ea^loyees 'whose posit|pntt.-'i|rrii!
••nature of their Sob requiir*»eiit*,j
Not every safety
"'•type functions c^n t»e anticipate
--..• hazard -.be projected f<
.exaaple, personnel rei
, chemicals such as UK«e occurs
train.dera iIment
safety-related pi
discharged chemicals:||
': ^aCter the arrival of ••»
disallowing activation
until many of the variable?;-
;: Accordingly r rules caniM;^ I
e«|»rgency that c^uId arise
:' Conseguen tly, a. f unct iprta-l' •
> • -
ruwfc. ?.-•:••->:•;•'• .y..-...^,^- r,^ t ,^S
. the -site • of .-'tii^-V-tv---.^> -f |: f'^l|
sets o»---- ' :.•*#". ..^••"f./p-, :B-":rt
j#*itc tb«...-miiirj^;«f ;^->,-;-.;<%,;Ja^S
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ftvery
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FIELD HEALTH
AU0 SAFETY
consist of parameters other than simple rules in a
"cook book" type approach.
Any safety program written for employees assigned
to Category I must heavily rely on personal
experience and an intensive ongoing training program.
Common sense and a keen ability to analyze complex
situations should be prerequisites for employees
assigned to this category. These employees are
required to enforce and comply with the published
rules, but more importantly, they are required to rely
on their personal judgment and expertise on a
pase-by-case basis to maintain a high level of safety
-consciousness at all times.
The Category I employees, by weight of their
responsibility, must exercise precautions to prevent
loss of life, injury, or health hazards to themselves
-and to the general public. This responsibility
transcends all others related to Category I.
QUALIFICATIONS
To be eligible to perform the duties of a Category I
employee, the employee shall:
. be assigned to Field Health and Safety Category I
by her/his first line supervisor;
. complete the EPA Baseline Medical Data Program
(Appendix I) and participate in the EPA Medical
Monitoring Program (Appendix II) for this field
health and safety category;
v
. complete the training program for this field healtf*
and safety category and present a certificate
(Appendix III).
PRE-ARRIVAL PLANNING AND INVESTIGATION
In planning a field investigation or responding to
a spill emergency, it is the employee's responsiblity
to be aware of the purpose of the investigation, such
as "Evaluation of the XYZ hazardous waste site for
1 110-23-80)
11
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P2-/V'
^ *»..'-
i^-"
Water
cpsipliance with
, emergency response.
found oil the emp
of .
objective of the
toyee's trawl
muist
th
rsBponse team must be
Regional Spill Contir
* ., Prior to arr
will gather info
s^ate -and local
the information
will be the basis for task
assessment. Types of
include:
(1).
Nature
the site or
including:
chemical
tion
Descri
Surface tjraters
public d
private
It is recogn
lead time al
amount of ini
Arrival.
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type of containers ,.
type of i^aste*- ''"-*"'
t an4 ip
sr etc.)
the»« cheaicals
potentia . hazards of the materiaIs
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U) Physical deScrii^^nI^;|^fcKBite;.;iwf
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. exact location
. size
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MANUAL
FIELD HEALTH
AND SAFETY
It is the employee's responsibility to know who has
been designated as the project leader/OSC. The project
leader/OSC has overall responsiblity:
for the health and welfare of team members
for team actions
to brief team personnel
SITE ENTRANCE AND SPILL ATTENDANCE PLANNING
While in the field, the project leader/OSC will be
responsible for coordinating the activities of other
team members. After the project leader/OSC arrives
on-scene, information as to the nature of the hazard
may still be incomplete. To assure public health and
safety, the project leader/OSC must constantly
reevaluate the hazard level as new information becomes
available. To this end, team members must report their
activities to the project leader/OSC.
Team members should obtain the following
information from the project leader/OSC:
Identification of other associates to assure
operation under the "buddy system"
Each team member's duties and responsibilities
The overall objective of the field visit
and the objective of each member's duties
Procedures for reporting to the team
leader/OSC who will report to the office at
least once a day
Established level of protection
Established ground zero
SAFETY ON-SITE
No employee shall orally ingest any food, beverage
or medication, chew gum, or use tobacco in any form
TN
1 (10-23-80)
13
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within the contaninated zones Of (the site or in a
wotKing area dur:
Field personnel will not en
alone; the buddy
be familiar with
system will be
for Category i.
vin$i *»»*J» -''•*~!f*i»
hone nunJber of
spital),
service
•••.:. .•^T'a^v'&i
eparation of tt
respiratory tract
a written memo of an
i* memo shall
r ,. pnohe, the
£ i|5losfst emergency
act for the
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MANUAL
FIELD HEALTH
AND SAFETY
All team members shall be familiar with the
physical characteristics of investigations, including:
. wind direction in relation to the ground zero area
. accessibility to associates, equipment, vehicles,
communication systems
. hot zone
. site access (avenues of ingress and egress)
. topography of the area
. nearest surface water
. location of on-scene emergency contingency plan
The U. S. EPA Safety Manual for Hazardous Waste
_ :V
Site .Investigations will
entry procedures.
beused asa guidefor site
The field team should be especially vigilant when
entering hazardous waste sites or spill scenes.
Employees should make use of all their senses to alert
them to potentially dangerous situations in which they
should not become involved, i.e. presence of strong and
irritating or nauseating odors, dead or decaying
vegetation or wildlife, discolored soil or pools of
spilled materials, etc. The field team should use
available field instrumentation, such as pH meters,
explosivity meters, oxygen meters, etc., to test for
any unsuspected hazard if this has not been done
previously at a particular site. Guidance for these
types of procedures and measurements is given in the
U.S. EPA Safety Manual for Hazardous Waste Site
Investigations. The discovery of any condition that
would suggest the existence of a situation more
hazardous than anticipated, should result in the
evacuation of the field team and a re-evaluation of the
hazard and the level of protection required.
In the event that any member of the party
experiences any adverse effects or symptoms of exposure
TH
1 (10-23-80)
15
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on scene,
the site and
In the event
overcome, incapac
on «jcretie« the renain
protective equip*ent
retari;«ve the affected
site, the affected
. When it is de
chemical exposure
those chemicals w
to the nearest ap
case*where
persefis involved
decontaminate
spreading of cont
termined
all
11 proceed
ropriate »ed^ca
personal
shall make every
the nselves
; When on-site
the_field team mu
s«aples other tha
colUfiOted. Bmplo
sballl use samplin
exposure to chemi
BPls Safety Manual
itions vi
collection, hand!
PERSONNEL PROTECT
. The duties of
entrance into a h
risk of acute exp<
protection may be
shall determine t
required prior to
protection are e.x
Level A is de
skin and eye
iimmediately d
Pressure-dema
and totally e
per
person
MANUAL
FIELD HEALTH
AHD
tfhe entire paxty
appropriate
:hat any member
.tated, or tta
ampling invesft i
t
i those
ee« fengajged in
i proceduar«s tha
:ale ox Other t
for Hazardjwas
llt>e-- us«d
ng, and
ON
immediately leave-
aid.
if the party is
ically injured, while,
imrae^iately don
efforts to
from th*,
left unattended,
was due to
party exposed to
, in a group,
facility. In those
occurred, all
able effort to
be minimal
tians are conducted,
^caution. -No
ssary should be
operations
possible
The u. S.
Site >
the
samples.
*•- --> ; t'4.
Category I fieid p%sonnel require
zardous sijte or spi|ll s i tuation where
sure 'exls*is aiuMor respiratory
requ ired. ' The | r<>^*ct leader/OSC
e appropriate l«(vel;tof protection
levels of ,
in Table 4.
site..
lained below and
igned to ptovi
rotectioh $$•'
ngeroos to
d self contained
- '• _• n *-«^'', ,&. ••l±' !**£••'
mm r espiratory
onraent " :"-
h (IDLH).
ca
*-
-------
MANUAL
FIELD HEALTH
AND SAFETY
Level B is designed to provide maximum respiratory
protection and very high level eye and skin
protection.
Level C is designed to provide low level
respiratory protection and very high level eye and
skin protection.
Level D is designed to provide emergency escape
respiratory protection and minimum eye and skin
protection . Level D is the minimum level of
protection allowed in the performance of Category I
duties.
In determining the level of protection required,
the project leader/OSC will use the criteria itemized
in Table 1. Additional safety equipment such as
headgear may be required if the situation demands it.
In addition, field personnel engaged in sampling
operations or making field or engineering measurements
shall weari have on their person, or have immediate
access to the following equipment during Category I
field operations:
head protection (hard hat)
steel-toed safety boots or steel-toed rubber
boots
a fully stocked industrial size first aid kit
* an eyewash kit
at least 3 gallons of potable water in a
pressurized container to permit
decontamination in the event of accidental
skin or eye contact with chemicals during
operations
TN
I (10-23-80)
17
-------
field in
meter,
ionizatidn
litmis-
\
trumentatien *
osi0n JMRtpr
meter, - etc*
1 (10-23-&O)
AHD
counter;, oxygen
, photo
tv ' *.
. *>'Jf **
'"^ *r
:,-. '• - ;v;;>v:^;::|:^-|
. . •i>''f."J^
"--••:--^-.v>> .-:<*•-r
;>-^-v.r^.-^:=;K?
-------
MANUAL
FIELD HEALTH
AND SAFETY
TABLE 1
LEVELS OF PROTECTION
LEVEL
A.I.
2.
B.I
2
3
C.I
3
4
PROTECTION EQUIPMENT
Self-contained breathing
apparatus
Fully encapsulated suit
Self-contained breathing
apparatus
Rubber splash suit and hood
Surgical rubber gloves
and/or neoprene arm
length gloves
Rubber foot covers
and/or steel toed
rubber boots
Mask w/air-purifying
chemical canister for
specific chemicals
Splash suit or
coveralls
Protective gloves
Rubber foot covers
and/or steel toed
rubber boot
Safety glasses with
side shields, goggles,
or full face shield
CRITERIA
1. Unknown hazardous
materials
2. IDLH atmosphere
3. Oxygen-deficient
atmosphere •
4. Chemical which
can be absorbed
percutaneously
5. Vapor which can
injure skin
1. Oxygen-deficient,
nauseating or
irritating
atmosphere where
the exact type of
chemical present
is unknown.
1. Where the
hazardous
materials being
sampled are known
2. Where there is
danger of
splashing of
materials during
sampling
3. Where airborne
agents possess
properties that
warn of exposure
4. Atmosphere with at
least 19.5% oxygen
1 (10-23-80)
19
-------
-------
MANUAL
FIELD HEALTH
AND SAFETY
SITE DEPARTURE AND DECONTAMINATION PROCEDURES
X
Disposable clothing and foot covers should be
buried or properly disposed of at the facility or site
being investigated. Disposable sampling equipment
should be disposed of in a similar manner. Where this
is not possible, disposable clothing and sampling
equipment should be placed in an appropriate container
for proper disposal at an approved hazardous waste site.
Non-disposable sampling equipment and protective
clothing should be cleaned in a "clean" area set up
on-site. Personnel should use standard SAD cleaning
procedures (refer to Region IV Water Surveillance
Branch Standard Operating Procedures and Quality
Assurance Manual, August 29, 1980) for sampling
equipment and detergent and water for protective
clothing. Where there is any question regarding the
adequacy of these procedures, non-disposable equipment
will be placed in appropriate containers after being
cleaned as described above, returned and securely
stored pending completion of laboratory analysis of the
samples collected. After the exact nature of the
material sampled is known, appropriate decontamination
procedures can be used to clean the equipment, or the
equipment can be disposed of at an approved hazardous
waste site*
1 (10-23-80)
21
-------
CATEGORY II*
. Safe conduct of
.which include activities that
to .has.
This Section provides a basi
field operat
MANUAL
..........
rdoua water4als
I.A. (hereafter iref«?rred to
terials) under controlled
'.,.." for ehcovnfce
_ fcc .filterials in the
accident or othur cicc
^'J employee.
A Category ti eHf>loyee
ld Health and Safety
fect, unleiss he is
leader and then- only to
tivities wher^TField
|>rocedur4s, equiptt*«t.
t0
he;
exception, no s
ordered or pern
w|uM;e or spill i
following condi t iOns
Of ex:sting;
immedictely
atmospt eres
where c gents that,
percutcneousiy
/his,*
fety
tted v
where 0
skin
ther. harpful
present, or
aze
*This descripticn of
to supplant or replace
Toxics" inspectors to
afc facilities and
investigations. The
requizements of item I (B),
in all cases of esticide
p
u J
c framework for the
and investigations
.^gfsent a risk of
as defined in Section
4es«gctated haxftcdou^
is, with the
concentrations of
at failure,
the control of
<||hter into an
twaste site where
rocedures are in
&&C :or project
specific
itj: Category II
tjtaining are adequate
single preceding
shall fc>e
a hazardous
investigation where
-e^ist or are
life or health
absorbed
whicn can injure
is not intended
s'of *?>e»ticide« and
t ion* and
U8e/«iis-use
'
.
ll have been «et
field inapections
* ut
t **
*»
-------
MANUAL
FIELD HEALTH
AND SAFETY
v-
where any of the designated hazardous
materials are known to be present in an
uncontrolled condition*
Category II safety procedures, required safety
equipment, and training are designed to:
permit employees to safely complete their
assigned responsibilities in the presence of
designated hazardous materials under
controlled conditions,
permit the employees to safely escape from
situations that have become uncontrolled
creating a dangerous situation,
provide the employee with comprehensive first
aid training and equipment and basic rescue
procedures in the event of an emergency
situation during field operations,
teach the employee.
QUALIFICATIONS
In order to be eligible to perform the duties of a
Category II employee, the employee shall:
be assigned to Field Health and Safety
Category II by her/his first line supervisor,
complete the EPA Baseline Medical Data Program
(Appendix I) and participate in the EPA
Medical Monitoring Program (Appendix II) for
this field health and safety category,
complete the training program for this field
health and safety catetory and present a
certificate (Appendix ill).
PRE-ARRIVAL PLANNING AND INVESTIGATION
All Category II projects must be screened to insure
that employees participating in the projects are not
™ 1 (10-23-80)
-------
«&•:>'"'
*•"' >f-- : -.
knowingly exposed
...... and Safety
screening
first
leader
tg insor
prpce-S-S
shall
*t*d with t
In planning a
project leade
iaiMMre of the p
:e the was
irles," "con-
was
*ion of Co
a.. proj
the formal w: ittei
must al
project,
is
determination."
Prior to init
i«iU g«t
the facility, ind
ecene to be inves
Othfr EPA operati
and local
thii| information
Le which wil
for de
of pro
of informat
nature o
types of
foraatio
investig
jt :(io~z3*ild|
to the
Category
rpoe* and
.....
any ISSfi,
ect . is l
stry*
igated.
g
aencies
athering e
ection
on that
the
raw
of inte
MAHUAi
ssoc iated «ith Field
-, •• . •?."- -i.•-. •- ,.-:•• •"-;!-•••;•--&
* de^ionated , •-•-*, •.;-;- -.;^y^
or study, it is
^ponsibility to
study, i.e. ,
of ABC-:.' •':
of
a
info ration is
be found on
,tudy plan , or in
' '
.^:,"-^:--i > ^^
vfev/.J j;'-t^;
other
haaard
the "V ; ,.'•-'- :':;----X:'.'|^iN
v._ . i •./'"• ' • -> • ••'".*•--'.""•'•.,'*''•(«/-"** :o
or
include
as other federal.
«.^: *s wtiict ^eqp^i*^/•-,.-:• ,- ,,i$*+^ --»l;f>^
; JiThe wxj&**& ,-.;^::;
^^liss^iiitiftt ii«r*.:;|^^' >.'.'!'' -fef '*§rf
^^.-•^tf|tiO^.^4N»^^:'-:^V'- "..'=•, '•.?l£*i'-$$ 1-^
ied^fftSli^er-:;..,;. ;. v-^lJ;|||j|
^¥«4,:-.>;> v?;. /:!;:
:-$*;
-------
MANUAL
FIELD HEALTH
AND SAFETY
the nature and type of industrial waste
treatment processes utilized and the types of
: chemicals used (if applicable),
. type of contributing industries and the nature
of wastes discharged by these industries to
municipal sewage systems (pretreatment
investigations),
physical description of the facility, spill or
hazardous waste site,
the nature of materials stored or disposed of
on the
site and the manner in which they were
disposed of or stored (in the case of
hazardous waste sites),
the nature and kind of products spilled and
the extent of subsequent cleanup effort (in
the case of spill scenes),
the previous history of the facility,
treatment system
or spill scene including all previous
investigative efforts and enforcement history.
Category II employees should have under normal
circumstances, sufficient lead time to complete a full
hazard assessment before field operations are
initiated. Similarly, specific safety procedures and
levels of protection can be specified for the field
operation well in advance of the commencement of field
activities (pending final field verification of actual
on-site conditions). During field operations the
project leader or senior staff member- present shall be
responsible for the overall safety of field team
members.
The buddy system will be used for Category II field
operations; however, it is waived for routine pesticide
inspections performed under controlled conditions.
Where two people constitute a field team, both members
of the team must be assigned to Field Health and Safety
™ 1 (10-23-80)
mm
-------
: I
IV
jsocy I or il
o« training if a
Personnel assignejd
Categories III,
peradssion of the
;field teajn on-
' in case '-of
tirity; not
or haVe received
member is not an
to Field Healti
V, VI, or VII
project leader,
site, but
pernitted
ENTRY AND SPILL
assessment
A hazard
and determination
for a Category II
entering a facility
sejine, or commencing
potentially
lightly. The
verify, upon
con«id«rations
hazardous-
Other available
have- been
are valid
represeft tat ives
. if an
industry, the
f irst aid s t a t ion s
upon entering the
determine if there
u»«d by the
or evacuation pl
existence of speci
availa
facility
The project
and Phone numbers
rescu* squad and
cowRencing field
t««» should be supplied
entering a work a
should carefully
on entry and
emergency.
prepare
r se
of the 1
field st
hazardous
field operat
situation
leader and
at the faci
in the
The
pro ject
arrival
involved
people abouit
overlooked.
invest i gat ion
is to be
sbility of fac
ans
used byvthe
al rescue or
leader should det
for the
law
per at ionsi
rea or
observe/
escape
It*
1' (10-23-80)
MANUAL
FIELD
AND SAFETY
equivalent experience
EPA employee.
and Safety
»•£, with the
accompany a
equipped to
ift anfc
safe ty procedures
protection required
ie made prior to
or spill
Entrance into a
not be taken
team should ;
I site, that all
ning hazard
should question
t on site* or
tial hazards that
ted at an ^
aedieal and
lined iBttBediately ;
team should also
special
ty and the
teams. :
rmtne the location
facility
before
of the field
n prior to
or : field site •
s in ease of
;^:.',--'r~r-:,-.4i.
'-- ' *'~-^ **:
-' • ;••&&*•
^'•-/
' -
-------
MANUAL
FIELD HEALTH
AND SAFETY
SAFETY ON-SITE
All field personnel shall have a written memo of an
on-scene emergency contingency plan. This memo shall
contain the location of the nearest telephone, the
location and the phone number of the closest emergency
facility (i.e., hospital), and the contact for the
closest emergency service which can provide
transportation to a medical facility. The project
leader/OSC is responsible for preparation of this memo.
The field team should be especially.vigilant when
entering hazardous waste sites or spill scenes.
Employees should make use of all their senses to alert
them to potentially dangerous situations in which they
should not become involved, i.e., presence of strong and
irritating or nauseating odors, dead or decaying
vegetation or wildlife, discolored soil or pools of
spilled materials, etc. If available, the field team
should use field instrumentation such as pH meters,
litmus paper, radiation meters, oxygen meters,
explosion meters, etc., to test for any unsuspected
hazard if this has not been previously done at that
particular site. Guidance for these types of
procedures and measurements are given in the U.S. EPA
Safety Manual for Hazardous Waste Site Investigations.
The presence of any condition that would suggest the
existence of a situation more hazardous than
anticipated and/or planned for should result in the
evacuation of the field team and a re-evaluation of the
hazard and the level of protection required.
No employee shall orally ingest any food, beverage,
or medication, chew gum, or use tobacco within the
contaminated zones of the site or in a working area
during Category II operations.
Employees engaged in Category II sampling
operations shall use sampling procedures that minimize
possible exposure to chemicals or other toxic agents.
When on-site sampling investigations are conducted,
only the required number of samples should be
collected. Category II employees shall not collect
samples from closed barrels, drums, or other closed
TM
1 (10-23-80)
27
-------
vessels located
irtvestigat ions.
With all samplin
of containers
shall also excer
*. The
sh ipped utilizing
r-eguJLations,
Stte Irtves
operations
team
indication of the
Jwflieators of ad
>n si tie unless £
Field team otemb<
procedures use<
pr esierva t i vea
is«? extreme c«u
shall be
sables
ti
rob«;r6 shall
£
/er£;e effects
changes
coordin
changes
excessi
changes
coordin ition
Jlield team
fallowing
mjembers w.
of
sysjpto as
headaches
dizzinejes
vision
cramps
••irritation of eyes, ski
In the event
experiences any
while on scene
.will immediately
appropriate medical a-id.
or
In the event
.overcome, incapacitated;
during field
immediately don
person. If this
i«a»diately
sammon
th;it any »«»t>«r
adverse effects
r in -a
that any member
... - -•
operation
protective
efforts to
is -wsj*
outs
nducting pesticides
rs shall be familiar
and the proper types
o be used. Personnel
ion in preserving any
labeled and
and'DOT rules and
fQJT
:#*v*:
each other for
exposure. • • "
discoloration
ta r y r espouse*, •••.
patterns
other of the
tract
of the field team
r symptoms of exposure
^-£4tifee:.entire tea* - v
proceed to seek
of the field team is
ed trau»atically
member(s)
(if necessary) and
the affected
team member shall
, preferably in
'•; ;•<•;«
> -4.
-------
MANUAL
FIELD HEALTH
AND SAFETY
the form of a rescue or fire rescue unit. Once removed
from the site, a casualty should not be left unattended.
If it is determined that the casualty was due to
chemicals, all members of the field team will proceed
expeditiously, in a group, to the nearest appropriate
medical facility. In those cases where personal
contamination has occurred, all persons involved shall
make every reasonable effort to decontaminate
themselves so there will be minimal spreading of
contaminants.
After obtaining the necessary aid or treatment, a
team member, or other responsible party solicited by a
team member, shall immediately notify the team's first
line supervisor(s) or other appropriate agency
personnel of the nature and extent of the problem.
PERSONNEL PROTECTION
The duties of employees assigned to Category II
involve field investigations and operations that
require personnel to enter facilities or hazardous
waste sites that contain (or may contain) the
designated hazardous materials under controlled
conditions. Included in this category are
environmental and source sampling activities involving
the collection of water, soil, sediment and spillage
samples at hazardous waste sites where it has been
demonstrated that IDLH conditions and agents that can
be absorbed percutaneously are not present. The
project leader or senior staff member shall determine
the appropriate level of protection required during the
preplanning phase of the study and verify these
protective levels before entering the facility work
area or site. The protective levels are explained
below and are itemized in Table 2.
Level A is designed to provide the maximum
protection during Field Health and Safety
Category II activities and consists of maximum
respiratory protection and very high level eye
and skin protection.
29
-------
Level 3
during
low lev
level
energen
tfce
eye
eve it
Level c
those ^p
prelimi
is designed to
irsonfiei
escape
wry
I«
will use
field
rrations or
«e*r, have
to the fo
Operations:
a fully
an
eyewash
skin or
operations
field
meter,
ionizat
litmus
is designed
ategory II
! respiratory
and skin
y source of air
of «
the project
in Table 2.
on tiieir
.lowing
head pr 3te<:tiort
steel-t*>ed safety
boots
s tocked ;'•; indoc tr
kit
at leas
pressur
decontamination
3 gallons of
zed container
" " -"'
eye contact
ins
ion
paper
protection
tions and cpnsiats
v«ry
, and an
..••.• . ^x-^ Ps'^»^c W'^ •$&.!*.
• •:•;-:;:.." •<-:,"! ..'.-^-^ai ^*^£:"€£.y?S'
itsmfl^t^^Si^iag^;
'^Wflil-*!^*
^fK8|ilSi;l
•; ••': •'.••••':..• ••»^>;^*-^r: --•-i'->.U-!-;K
•* - V,, -;v- ..:•:«'{.;•''fy^'.-:-..?.-::ir ?-..;-.:%
^t .^":;'s1^-'?;5r?- •>••;• ?.: -'1
I*V-*;-,. ..-• . ..:•• .-,. • •••,:;..,:..* . ;--. <; •..--.-^t
^••'^:\'-^;S^^n'1f
.„, ^^. Jw*a^»":.^.:.;.^*j>- SftK [-.':S
^^m^^^'Q^mm^M
^.C«fc«g«W#: ;I^-f-4'^^^ft|, S fWl
St3
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first
water in a •;
»it .'-^y
ofiaccidental
:r- counter
£sx$a$\?$i
•••'-- ;*'"''•••••* «.. •••"is,-«>¥.'5- - :"^^*:- '-' .'.:.
.'•-• ;.„•; v-<- -j • 'SH* ~-2--*«t2^? : -:.-•=-;" - -fc
"
-------
LEVEL
B
MANUAL
FIELD HEALTH
AND SAFETY
TABLE 2
Levels of Protection
PROTECTIVE EQUIPMENT
1. Self-contained
breathing apparatus
2. Rubber splash suit
and hood
3. Surgical rubber
gloves and/or
neoprene arm
length gloves
4. Rubber foot covers
and/or steel toed
rubber boots
Mask w/air-
purifying chemical
canister for
specific chemicals
Splash suit or
coveralls
Protective gloves
Rubber foot covers
and/or steel toed
boots
5 minute escape
capsule or
equivalent
Safety glasses
CRITERIA
3,
4,
6.
1.
2,
3,
Coveralls
Foot covers
5 minute escape
capsule or
equivalent
Safety glasses
3.
4.
Oxygen-deficient,
nauseating or
irritating
atmosphere where
the exact type
of chemical
present is unknown
Where there is
danger of
splashing of
materials during
sampling
Where the
hazardous
materials being
sampled are known
Where there is
danger of
splashing of
material during
sampling
Where airborne
agents possess
properties that
warn of exposure
Atmosphere with at
least 19.5% oxygen
Minimum protection
permitted for
Category II
1 (10-23-80)
31
-------
:- .*•;"
^,
SITE DEPARTURE All D D ECQNTAMIMATTO J PROCEDURES
Disposable cl
othing and < foot
_ _ ' ™ . «Ji '.' ' ._!_ . -'.'
y
Bis
.«; properly
investigated
' be dispo sejd
is not possible,
e«p»ipjMint should
for proper disposal at an
e
te
Personnel
Non-disposabl
should
on^site.
(refei
Standard
Manual.
eg«ipfl»nt and det
clothing. Where
adequacy of these
will be placed ir
c&eaned as.descri
stored pending
saj^>le« col lee tec
Mfttecial sampled
procedures can be
e<99ip»ent can be
waste site.
e sampling-equip »ut
A f 1 AAMAA . I i!»---fe.- * >i^:«aii
cleaned in
should us*
to Region
Operating *i
August 23,
ergent and;
there is *
appr
bed
complet
on-d
is known, apptr^c
used; to-.c^eajfe'/qbj
disposed of
(10*-23'-80>
should be
^mpoiws-j.;. -,:Wlfcere this;
and sampling .,
rriate container
tiardowB waste site*
and protective
area set up
rd SAD cleaning
E|>Suryeillance
*s and Quality
saiapling
f OJt protect £ ve
i|n regarding the
os^jle eguipnent
r s after being
!':,and securely
y analysis of the-
nature of the
ipnent, or the
approved hazardous
t <
! ^=
*^*i
-» t '*
^ > -4,
*< S ^'
; t
-------
MANUAL
FIELD HEALTH
AND SAFETY
CATEGORY III
This Section provides a basic framework for the
safe conduct of reconnaissance investigations,
inspections, sampling and non-sampling investigations
conducted by personnel in the vicinity of but off-site
from, a facility or site where hazardous materials may
be present, as well as sampling and investigations in
areas known to be free of hazardous materials.
/
Category III personnel may be working in proximity
to a site where hazardous materials are present;
however, by definition, they will not enter into the
site boundary nor engage in operations where accidents
or equipment malfunctions could result in an acute
exposure to toxic materials. Examples of such
activities include compliance sampling inspections,
ambient air quality monitoring, and other field
activities where hazardous materials are not involved*
QUALIFICATIONS
To be eligible to perform the duties of a Category
III employee* the employee shall:
. be assigned to Field Health and Safety
Category III by her/his first line supervisor;
complete the EPA Baseline Medical Data Program
(Appendix I) and participate in the EPA
Medical Monitoring Program (Appendix II) for
this field health and safety category;
complete the training program for this field
health and safety category and present a
certificate (Appendix III).
PRE-ARRIVAL PLANNING AND INVESTIGATION
This phase of the field safety procedure involves
identification of those tasks which are to be completed
in the field and gathering of all available information
pertaining to the site to be investigated. In planning
a field investigation within this safety category, it
1 (10-23-80)
33
-------
. i , . - . ' ' • '
* is the employee
purpose of the
that it does no
abatement of th
wti 11 normally b
*
.'/ .- |*j.," •_.
MANUAL
' ''••«'iBL&':KBKfi!Et'i'-;':t^
•'-.'. .-:.««>?»*»**»»
^
' ••,. -*vi^||
^:;..: ^i>^BB
®ft^S
^-;V ;'•:-..:•• ;y®&
' - • -• - '""''fl'ff
e;j:e4i>9n*^W^;'r'to. be aware of the,. ' :: ''^;-':^ -:'k: '• ^M
field investigation and to ascertain •••.?•. X.v-7;*' ;; "M
t exceed the scope of this Category. A .-. •:.*•••?• •&•.?; vaj
e purjiiosfc *t;^^ii0d--i»vei|t.igatio.ii :;; vi^X^^vt^iU^
B' ihcl^e^ui»-'^i'e«ployee'«:';tr*ve^^
le«6.
Planning specific
to arrival at t
the Category n
exceeding the 1
is anticipated
p^oxinity to a
contingency pla
required for su
.gathered during
to be consider*
;UI nature
the wo
ihclud
typ4 of
. typo
. chenicals and
(2) Physic
It is recog
a|*d lead time a
the amount of i
site. Furtherme re,
the work site m«iy prove
these factors.
rid objectives
insure
without
Since
sonnel may be
ar4a» the: • need
the
'• "> ' •'"*•' "> ••"•;-*'<'•-"'?••'*.*,*?•':?? ':£,?.
"-• ••••.*• '..•i'Vji-U'.' y-.•;&;&!-;? I'- .&.
*-.4t :':-$^ '?^%' W> '•• ^
'"-• - •^'*-i, '-'::=' > '"-*i . *'* % -*=v'*.~ if -,' ^*T1
: ili;'- ' "\ -1"' • •"••'; ;-:''iiif : ••ii'^> t^;JV
ed.;ii^fej^v^; -?^>|Ss.^VH83
ing.
disposed of
liquids, etc*)
tiee'of these chemicals
icpt location:
siz
topbgraphy
ized
lowed for a
formation
SlTg-ENTRY AND C N-SITE PROC
Although Category III jb
Significant potential fot e:
id hatarful conce n tr atidn*^
»• 5 •* '•rii1' '• • '- -.'•:'' * « •'• - • J- *1 ,•
scene way limit
iQr;; t0, a«rlfli^S
confchai*sance '-«.. v .-_yj
;.:.^r.:i-">^
do not include any
toicic substances :
s ,> aji-;in;;.aitiy^'-;. > '• i:^
^^f^f:^
.~-J':?*i^
-------
MANUAL
FIELD HEALTH
AND SAFETY
field work, an inherent low level of risk of exposure
to hazards which, although they can be minimized,
cannot always be anticipated. While in the field, the
project leader/OSC will be responsible for coordinating
the activities of other team members so as to minimize
this exposure.
At a minimum, the team leader should consider the
following in planning field work, and should be aware
that she/he will be responsible for all that the team
does or fails to do:
(1) After the project leader/OSC arrives on-scene,
information on the nature of the hazard may still be
meager. To assure public health and safety the project
leader/OSC must constantly re-evaluate the hazard level
as new information becomes available. To this end,
team members must report their activities to the
project leader/OSC.
(2) Team members should obtain the following
information from the project leader/OSC; an organized,
although informal, briefing is encouraged.
Identification of other associates to assure
operation under the "buddy system."
Delineation of work area boundaries, which
shall not be crossed toward a higher hazard
area.
The overall objective of the field visit and
the objectives each member's duties are aimed
at attaining.
Procedures for reporting to the project
leader/OSC who will report to the office at
least once a day.
Monitoring or warning techniques which will
indicate changing conditions that could
redefine the site boundary, such as:
Meteorological changes
TM
1 (10-23-^80)
35
-------
personnel
(3) field
The buddy system
faailiar with th
C»tegory III.
any indication o
Indicators of ad
will be
e EPA
buddies
Tie
. change
lack of
changes
excessi
changes
(4) Buddies wil
effects of toxic
. headach
. dizzine
, . blurred
. . cramps
irritat
in complexion,
(5) All field
written memo of
plan. This memo
nearest telephon
the closest
the contact for
provide
,proj ect 1eader/O
this memo.
Communication
on the sit-e/:Q
environment
Catastrophic
etc.)
with personnel working
in a Category I or II
i*..':-
ncidents
*r a work site alone.
Buddies will be
h and Safety SOP
in demeanr
ve '
in speech
inform e*cli ot
exposure* *;I'::K:;;'::^
SS
s ; '; • •• : •-.>:: •'•'":•',
vision./ ;; .... ;,.>; ^
Ion of eye&r sfci
personnel shall
the on-scene e»e
shall contain/
, the locaition
emergency
:he closest
C is re
All team meifibers shall be familiar with th*
of investigation
1 (10-23-80)
M ittiiiirti''
• PM » *M*mt^np(<.
diecoloration
pj ipi liar y r esponse, - etc .•'
of non- visual
respiratory tract
ready access to a . -
contingency
location of the .
nid 'the phone nuifiber of
, hpspitalj* aiid
service which can
facility. The
••--Mi--^i
r '^ ill
•; •.;:^r|^S^
^:.:':^J'^V>p55
-------
MANUAL
FIELD HEALTH
AND SAFETY
fe.
. wind direction in relation to nearby potential
hazardous waste sites
* accessibility to associates, equipment,
vehicles, communication systems
site access - avenues of ingress and egress
topography of the area
nearest surface water
availability of on-scene emergency contingency
plan
(7) In the event that conditions are discovered in the
course of conducting a Category III activity that would
indicate a Category I or Category II hazard exists, the
team shall withdraw until personnel cleared to work
under Category I or II conditions can confirm the
hazard and define the levels of protection required.
SAFETY ON-SITE
In the event that any member of the party
experiences any adverse effects or symptoms of exposure
while on scene, the entire party will immediately leave
the site, and seek appropriate medical aid.
In the event that any member of the party is
overcome, incapacitated, or traumatically injured while
on scene, the remaining members will immediately don
protective equipment, if available, and make reasonable
efforts to retrieve the affected person. Once removed
from the site, the affected person should not be left
unattended.
When it is determined that the problem was due to
chemicals, all members of the party exposed to those
chemicals will proceed expeditiously, in a group, to
the nearest appropriate medical facility. In those
cases where personal contamination has occurred, all
persons involved shall make every reasonable effort to
decontaminate themselves so there will be minimal
spreading of contaminants.
(10-23-80)
37
-------
t*~ "f
3 f
If -
t?
PERSONNEL PROTE
Personnel w
not enter areas
eye and skin pr
respiratory pro
In determin
leader will use
D and, in some '
protective meas
sfeoes^ safety g
personnel engag
field or engine
their persons,
the criteria itemized in Table 1, Level
ases, may be without any specific
res beyond fielmwtirrk clothing, safety
asses: and/or •;a'^!wir-d;;"hat.-' F4eld' •.-''••""•
d in sailing ^pfftr^tions or making
ring .ijtf ' ' - ' " """" *" : "" '
r have
equipment during Categjo*^ III sampling
head p
eye; pr<
glasse
full f
steel-
boots
at lea
pressu
decent
skin o
sampling
field i
meter,
ioniza
litmus
TIQN
where;protection
tection and emerjency escape
ection is reqiiir ed.
ng the level of
MANUAL
PIBLD «OtfiTH
AND
rking in a Category III operation will
greater than minimum
lafety, the project
otection (hard Wat>
tection consi«J
with side sh
ce shields
^f-.aj3pr=oyed JMMBety;'
goggles or
oed safety: boots' or steel-toed rubber
a fully stocked industrial size first aid kit
an eyeWash kit
t 3 gallons of: p/ptaible water in a
a Mr : -. . *'..!•• •. '••' ff- Si .".'•• itri* •'. ' • -• - '
mination in :t
eye cdnitact
operations
nstrunentation
of accidental
during
ion meter,"
paper
(iO-23-SOy
Lger counter, oxygen
:^m
.
••;} r*
J . i * •
-------
MANUAL
FIELD HEALTH
AND SAFETY
SITE DEPARTURE AND DECONTAMINATION PROCEDURES
All sampling equipment (disposable and
non-disposable) and protective clothing should be
placed in appropriate containers for proper disposal
and/or cleaning as outlined in the SAD cleaning
procedures (refer to Region IV Water Surveillance
Branch Standard Operating Procedures and Quality
Assurance Manual, August 29, 1980).
"*.l (10-23-80)
39
-------
*** •
CATEGORY IV
This Sectioh
required for cop
ttoiek-ijtf for or
Region IV is
geaerftlly
field
group
Contractors are
Entities
•ucfc as other
private contrac
responsible for
In situati
Agency end wher
that same
that tti
tbe apfrropr late
extent of EPA'E
-proxi»ity to ax
FIELD
-••M
addresses the
tract or non-l
with the
'-ii*>
s »r^ cJ
:orH:r act
such aif '3J88CC, ,1
also included
that have their
fjederalr flt-'^kte.i
ors tTAIf or
their
s where EPA I*
another
ap ration ^
y are., under Bf*
category Bdp or
fei^Kfc
as
i£ety Peocedures
Ion XV .per*o«n*l ' .
ttuatio*s where EPA
the total -episode.
tare hired
FIT ^nd f»
and .Headquarter * s
s section.
programs,
l agencies and
shall utilize and be
^iead pr "in charge"
"ual involved
.„ ,. am, it is
col and »ust follow
, to the
.close
r i
1 (10-23-80)
VI *
-------
I*
MANUAL
FIELD HEALTH
AND SAFETY
CATEGORY V
This Section is intended to provide a basic
framework for the safe conduct of those Region IV
employees who will be involved in the preliminary
surveys and preparation of damage survey reports during
the aftermath of natural disasters (i.e., hurricanes,
tornadoes, floods, etc.). This Section specifically
addresses safety and precautionary procedures for the
designated personnel of Category V. Category V has
been defined as follows:
Employees in this category are those who are called
on to support other mission assignments from other
government entities. Examples are: Category F
Disaster for the Federal Emergency Management
Agency (FEMA).
This Section also provides guidance to engineers
and other technical staff whose positions are in
Category V due to the nature of their job requirements
and the specialized missions of their representative
programs.
Safety hazards or risks associated with Category V
can in general be anticipated and therefore be avoided
or minimized. For example, those individuals
responding to situations of natural disaster will be
able to anticipate their areas of involvement and the
types of situation they will encounter. Physical
hazards should not come front exposure to hazardous or
toxic chemicals but from simple misfortunes such as
falls, slips, or impact from falling objects.
Consequently, the safety program consists of very basic
training and the liberal use of common sense.
QUALIFICATIONS
To be eligible to perform the duties of a Category
V employee, the employee shall
be assigned to this field health and safety
category by her/his first line supervisor;
41
-------
coroplet
(Append
categor
completf the traj
Categor:
III).
A designatio
dieaatcr will be
designated disas
of current situa
daaage, work are
a brief ref
ENTRANCE
Category V
hazardous condit
event that condi
their field inve
Category I, II o
employees will
Category I, II,
hazard and
en;
determine
SAFBTY ON-SITE
In the event
discretion conce
to. prevail. Emp
event of physica
their ability to
complications sh<
PERSONNEL PROTECTION
The duties o
require the entr
-Extend ive damage
well after the
to> confused cond
,.TM
1 (10^23-80)
the EPA BaseU
xl) for thifK £
; and
•' i;?i;'.;:-^-f';i--f"
i of the geogra
« ... : v-~.~,i'.. A*J*T
prevailed
er area,;
lop
iployees
ons';whi
ions ere
tMali
III hazard eki
iiunecliateXy.
of ' physical
ning
impairn»ent
functipnVisr
uld -it not >be
Field Health
nc*; into
and
Of
onset
a. MANUAL
FIELD
i
.Medical Data
eld-health--'and
K-!^"*^>^ ^K .-' £ ^ *u. ' •^a-J .A. 1 J IH'^.'f .-A.^WA.' i'' _' ..<•'-^' " F*rv^v.w~*£'
^
m
' '•"" ';~'V •'••'v,:;;^*srf;.j.
.; ;-r%^vpy
V •-..". :-M\ i1 -:
.:> -.Fj -'
.s., 1 area (s) of
t;j -5&pon arrival at the
M ifviprovide a briefing
ryiestimate of
.,.., - tjask; objectives, and
procfldi r*« to be -followed.
• %lert ami look for -
ie«€ter area. In the
in the course of
indicate that a
the^Category V
ron^the area until
an • assess the
jprotectitfn required*
dent, personal
pedical aid will have v ',
a task in the
l$ay severely reduce
a»ay lead to further -
i: with promptly.
,tK>t*c< ntinue
*$&Safety Category V
saster areas.
evail. Although
ftermath will lead
Jtivity and ability
-
U
*-
i-.
-------
MANUAL
FIELD HEALTH
AND SAFETY
to travel, and an emotionally involved public. Safety
and protective gear will not be required unless so
designated by FEMA and will be provided by that agency.
SITE DEPARTURE AND DECONTAMINATION PROCEDURES
Unless a Category V employee was inadvertently
exposed to a hazardous material (as discussed in the
Site Entrance Section above), the employee shall at
her/his earliest convenience shower and wash the
clothing worn in detergent and water. If unexpectedly
exposed to a hazardous material, the employee shall
utilize the procedures to be followed subsequent to an
exposure as outlined in Category 1, "Safety On-Site."
TN 1 UO-23-80)
43
-------
is
B
iU'"
VI
Personnel who are assigned U> Category VI are
wbose normal duties involve s^lilpffissi^ility of
' • n ' -t i *" • ' ' -^ ' '• «• --'• i- • ^-"-J-"- ' - - - • . A " .•-' : ' . .
accidental or
Included ain
exposure,
materials.
involved in legajl and ;teeh»
arid enforcement
occur during
toxic/hazardous
defined circumst ances
exposure of Category yi per
.will occur only
MANUAl
FIELD HEft&Tff
'
investigationfi^
investigations of drinking w
toxic
are those
6tig«t ions,
f0rination gathering,
problems.
-A'-1.
Accidental exposure .. tcxj tpxieYhiafardous materials
..
in vesfcigatioias Performed for purposes
as permit issuances* ^forcfeme^t actions, and
information gath
easily regulateo
ering*
because it is u
unexpected. Hoever/ intended ecpoture to
situations
toxi
will have been identified and as
personnel will a
I-III person whc
correct safety i
ways be
will be respon
recautioiis-i are
exposure cannot be
ifoireseeable and
M?i|ie only under
i/h|i2ardous problem
when the-
minimal; these personnel 'will
investigate unkr
with toxic/hazai
QUALIFICATIONS
own situations
dous emergenc
and Category VI
by a Category
If for assuring the
eh. Deliberate
such Situations
of harm is
expected to
be trained to deal
jo be eligil
VI employee, the
. be ass:
Categoi
and
. complet
health
certif:
..:' . ' ••
de to perform th
employee shall:
gned to Fileld He
y VI by het^ii^s
e the! training p
and safety categ
cat e (Appendix I
"-• '.'=' :; . *' ''. '•"•
^^s-lfc&iiyiiii
e; duties for a Category
alth and Safety
first-line supervisor;
• : {<••••
' •' ' ' + •
rogram for this field
ory! and present a
^>ii;;, • ; •• ...
. . . y •.. _ . • ,
* ,'
, «1 '"
-------
MANUAL
FIELD HEALTH
AND SAFETY
PRE-ARglVAL PLANNING AND INVESTIGATION
This phase of the field safety procedure involves
the identification of the tasks to be completed in the
field and the gathering of available information
pertaining to the site to be investigated. The
employee should be fully cognizant of the objective of
her/his site inspection and the known facts of the
toxic/hazardous situation which has been identified at
that site.
The employee should review all existing information
on the site prior to her/his inspection and should be
advised by the project leader/OSC as to necessary
safety precautions prior to entering the site. The
project leader/OSC is responsible for determining the
appropriate safety precautions and informing Category
VI employees of her/his determinations. It is the
responsibility of the Category VI employees to
implement the necessary precautions.
SITE ENTRANCE AND PLANNING
Category VI personnel shall not enter any
toxic/hazardous site without being accompanied by
personnel in Categories I-V or without their entry
being coordinated by the project leader/OSC. The buddy
system will be utilized if there is a hazardous
situation.
SAFETY ON-SITE
The project leader/OSC is responsible for the
safety and protection of Category VI employees while
on-site. Category VI employees shall follow the
directions of the project leader/OSC.
PERSONNEL PROTECTION
The duties of Category VI personnel require
encountering a toxic/hazardous situation only after the
situation has been identified and investigated by other
lower-category personnel, unless such situations are
encountered on an accidental, chance basis. If
*" 1 "(10*-23-80)
45
-------
Category VI perfsonnel t in the
nornal duties,
they should lea|ve
their first
discover a toxi
immediately
line supervisors
; All other
-Ca-t«fory Vi
leader;
?. deter mi n ing th«
;;i;|»--e|ttsef ing. thy
ITE DEPARTURE
entries into
rsonnel, wll
/OSC w|K» vl
Category VJ
the project
1 (-23-80)
pifforraance of their
•haia rdou a s i tuation,
ahd report the discovery
iWjty/bjtp&tdQv* si.tes py
i.isj|i:na'tfed.- by' '-the. v
it^oiisible for ' -
:i^|i^f.;p4>t«ction prior
AND
personnel
leader /0SC,
MAKUAi
-•*
AND
.'i'olli-pW.-%he.' directions
>
*"r f
-* i
-------
t
MAMtML
FIELD) HEALTH
AND SAFETY
CATEGORY VII
Category VII consists of all Regional personnel who
have no field functions (those EPA employees not
assigned to Categories I, II, III, IV, V or VI), ViPs,
the press, Washington executives/ politicians and high
level Regional management personnel.
The personnel in Category VII may have a need to
get within the vicinity of a hazardous area, but not
necessarily have a need or a duty to actually enter the
area or site.
The project leader/OSC is authorized to take Category
VII employees and VIPs on-scene only when the employee
or guest is willing. The project leader/OSC is
responsible for the safety of such persons.
QUALIFICATIONS
The employee shall be assigned to Field Health and
Safety Category VII by her/his first line supervisor.
PRE-ARRIVAL PLANNING
The project leader/OSC will brief the Category VII
persons on the type and extent of the hazards present,
as well as the emergency procedures and contingency
plans she/he has implemented. The project leader/OSC
fnust specifically outline the areas in which Category
VII individuals are not allowed and any other
restrictions or limitations she/he feels are necessary.
SITE ENTRANCE AND SPILL ATTENDANCE
Individuals in Category VII should not be allowed
entrance onto a hazardous site or spill. While in the
vicinity of a hazardous site or spill they will be
under the direct supervision of the project leader/OSC.
1 (iu-23-80)
-------
OH-SITB
r The projec
Safety of all
the vicinit
leader/OSC' i;s, r
Category VII
of a
Category
• '•
Since
hazardous
ar* not normal
SITE DEPARTURE
Category V
0f ,the project
MAHIIAL
t =y • ft
AND SAFETY
PROTICTIQN
y;required.
AND
spons ibl e for .the
/14uals while they are
'
are not allowed in
^. !and eguipiient
•;.> '"'f? . ' • • "
PROQEDURES
I personnel will! iollow the directions
;JI:^":t'' ' " ;
1 .(10^23-80)
*>/
a
"ii
-------
MANUAL
FIELD HEALTH
AND SAFETY
INTRODUCTION TO MEDICAL BASELINE AND
MONITORING PROGRAMS
(Appendices I and II)
Persons in the employ of EPA Region IV, who in the
performance of their duties must encounter situations
or materials which are a threat to life, health or well
being, should undergo examinations to determine, to the
greatest extent possible, the degree to which such
activity alters their health status. .In. order that
this kind of determination be made, a baseline health
profile must be established. This can be achieved by a
system of examination and certification, establishing
for managers and supervisors a means of measuring
changes in health status. Cause and effect
relationships or correlations among activities and
health status changes can provide information for
managers and supervisors to allow utmost protection of
the safety of the staff and the accomplishment of
organizational mission with minimum casualties.
The medical baseline program and the medical
monitoring program should afford each supervisor a
statement or certificate of the results of each
physical examination and a statement by the responsible
medical official of his/her evaluation of physiological
condition or changes observed in each case. The
certification should remain in the records of each
employee and should be a condition of continued
employment in any position which requires its inclusion
in such a medical monitoring program.
r^j-
*WJ
-------
APPENDIX I
" • ; ' ' . ':
BASELINE »ffiblCAt j ft3?A PROGRAM
PRE-EXAMINATION
MANDATORY C
. Basic
Heart
Chest
Pulmon
'••.»•-. ....;'• •.'^•'"'v>-:
te,::-'^»£*4M-': •.$
CLASS A
EDITION Of EMPL9fMBNT
taiius and functions (EKG)
ry fttncti<>n ? ~f
Blood
forced expit
and
r
fuil S«AC Seri f» tSMA 32)*
poster ior-<
vital capaci ty> ...
voluiae at 1 second
Hemoglobi n -
AC*
Heavy metals -
counts, protein
activity .
Sr (complete trace
Liver
tBlood series niay need
" •-• -. ''.'(~
Chenscreen Requisitions
1 (10-23-80)
function /-: full BnBj»e profile
r ing to be done on
"-..?*?
•to
:i
^''-iM l A
•••^•••^:;-"
:.-• ' '..•-?•
• -.•>.
"***
J »
/ J*'
t-fy
• ?
»r »
*•'
>"
*'
/
-------
MANUA
FIELD HEALTH
AND SAFETY
Renal function - BUN, Creatinine,
Creatine/Creatinine ratio,
Lipoprotein count and differential
Uric acid
Urinalysis
Audiometry - audio spectrum response of ear
Eye - physical condition, visual acuity
(10-23-80)
51
-------
3-EXAMINATIO
Basic phy
Heart sta
Chest X-r
Pulmonary
Blood - S
,. Liver fun
thrijialysi
, Renal fun
Audionetr
• ; . ; •• '- '•; .;•.;' '..-•
S: CLASS B v
sical exam =:
MAMUAL '
• ... -. ••. .. '..:•'•;
:. \ .(.. . '-[ ••'•- -.••'• '""•', ••••..
' '• •'•'•,.-' ,.'':. ' •.-•••
: '" '-'^> • • • .• ' ' •• ' .:
tut andfunoti^^) '-: ^. ' .^
ay - •'•.'.. -T':'-' '' •"•
function - ;Pitv;^
MAC .' •••• sZ'-^i-'*
ct ion - SOM?^ SG?
CtlOIV- '1 '/''• .-.':•'- ;
T - ' •'"". '"' ' -::
«: CLASS ;. C ';.'" •••; : -" .
".' "..'. :•'....-.' ... ' ;
IS\-'--- . •.. '''' '
Sp.-"" -'">•' ,*:
; V .••,'''
;•; '.;'-• • ' - . . '- •.
medical reqjirement above -gOn«iral agency health
1 (10-23-80)
I
A
-------
MANUAL
FIELD HEALTH
AND SAFETY
APPENDIX II
MEDICAL EXAMINATION - MONITORING PROGRAM
MEDICAL EXAMINATION: CLASS A
MANDATORY CONDITION OF EMPLOYMENT
Basic physical exam
Heart status and function (EKG)
Chest X-ray (Roentgenogram posterior-anterior)
Pulmonary function - forced vital capacity, forced
expiratory volume at 1 second and
reserved volume
Blood - full SMAC Series {SMA 32)*
Hemoglobin - cell counts, protein
level
Acetylcholinesterase activity
Heavy metals - Pb, Cd, Hg, As, Cr,
and Sr (complete trace metals)
Liver function - full enzyme profile
*Blood series may need further tailoring to be done on
Chemscreen Requisitions
™1 (10-23-60)
53
-------
•"
Renal functj
Urinalysis
Audiometry
Sy* - phys
Monitoring exam4
/with re
exposure. For }
low or field woifk
monitoring
than* 12 monthsJ
MPOIGAL EXAMINA
j Heart states and function -
X-ra;
SMXC
Pulmonary
Blood -
Liver func
Urinalysis
Renal func
Audionetry
MANUAL
ion. • -> *BUN,
Cr*atij«/Cre>t$|i$ne ratio,
an$ d if f eieftt i al
significant
lifeerval between
may be as; great
but- no greater
ion
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MANUAL
FIELD HEALTH
AND SAFETY
MEDICAL EXAMINATION: CLASS C
No medical requirement above general agency health
policy
TM l (10-23-80)
55 =
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FIELD HEALTH
AND SAFETY
APPENDIX III
TRAINING
Training is a necessary tool in implementing this
Field Health and Safety SOP. The complexities of the
topics of interests, the variety of courses offered,
and the different needs of employees in each category
for specific training have necessitated formulation of
some ground rules as the corner stone for a
comprehensive training program to commence as soon as
this SOP becomes effective, or shortly thereafter.
To streamline the process, fifteen topics of
interest with 37 subtopics have been selected at the
present time from four existing or proposeo sources of
training, which include EPA's in-house resources as
well as courses of instruction available to Regional
employees through outside contractors and vendors.
Regional employees will receive training according
to their job requirements and classification, and their
first line supervisors will recommend courses for their
future needs and professional development. A series of
core topics (Table 1) have been designated for each
category; it will be mandatory that employees receive
training in these and repeat them at various :
intervals. Other available topics identified as
"desirable" should be taken by employees based on the
recommendations of their supervisors. For example,
under this plan, a Category l-a employee must be
trained in 11(c), Safety-Related Field Instrumentation
and Environmental Monitoring. An example of a
non-core topic for Category. I-a employees is 12(b).
Field Sampling Techniques related to water, which
should be taken by individuals only on the basis of
need and supervisor recommendation. It should be noted
that a non-core topic for a certain category may indeed
be designated a core topic for employees of another
category.
TM 1 (lfl-23-80)
57
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remain flexible
the need arises
MANUAL
FIELD HEALTH
: AND SAFETY
or new ideas ar<
Finally, t|he training plan* and program should
enough to include, or delete, topics as
introduced. Along
te should encourage
titles and other
wait new proposals on
id possible utilization.
'•.»Sa
this line, the (Training cowmitt
outside vendors
educational institutions, to su
topics of interest for review a
such as univer
i1'
1 (10-23-80)
58
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MANUAL
FIELD HEALTH
AND SAFETY
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FIELD HEALTH
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1 (10-23-80)
61
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MANUAL
FIELD HEALTH
ss&sm *
List Of training
employees and/or
Table 1 for titles
TABLE 2
course; available (or. propo ed
contractors, and topics covered
of each topic).
TRAINING COURSE
EPA Region IV -
Training Course,
Hazardous Materials
Basic Level
(Proposed) EPA Re
Materials Traininc
and Advanced Leve
EPA Headquarters
Waste Site Field
Ecology and
Training Course
Site Inspection/Investigation
fur
ion IV - Hazardous
Course, Intermediate
s • '. •
Training for Hazardous
nvestigatlons
Environment, Inc.
Hazardous Haste
to be offered) Co EPARegion IV
under each course (refer to
TOPICS OFFERED ,
2a, Sa, 6a, 7a-d, 8, 9a
la-h, 2a-b, 3, 4a-b, 5b,
7a-d, 9b, lOa-b, -lla-c. T2a-b,
13a-b, 14, 15a-c
6a, 7a-Ci lid, 12c-d, 13a-t), 15c
lb, c & f, 5a, 6a-b, 7a-d, llc-d,
12c-d, 13a-b
1 (10-23-80)
62
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'&<•••
'•gKttdR-:
AKffi SAFETY
APPENDIX IV - Nemo establishing a Task Force to
develop a Health and Field Safety SOP.
63
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MANUAL
FIELD HEALTH
AND SAFETY
,L PROTECTION ACfQ
Atltr t». 6Borg1«
UIIITEDSTA!
Wlt4««i
EPA Field Safety Procedures
Regional Ami Inlstrator
All Employees
The high agehcy priorities given hazardous Matte sites and other
emergencies concerning hazardous or tbklc cmmfcaU has significant
tapllcatlonsfTln the areas of personnelj safety In the field.
all kinds of situations Involving
ttrfotnlng a spectrum of duties.
that wt Identify what you as
•f the job that you hold
_ _ for employee protection
Met these objectives. I am
Irst step toward developMfit of
5.O.P.).
•ft
(1
Ma have mmdrous employees Involved
exposure to hazardous chemicals wMl
1 aa Regional Amilnti
are require* to do
form a safety program
t of assigned dtttles.
following actions M
a Safety'Standard Operating Procedure
and that w
In perfor
tie
(1) Effecti ve this data. I m directing that no employee of this
11 office In any situation] or at any tine, place himself.
hersel
which
comple
Tralnl
Tralnl
of proi
spill
chemlc
vlolat
In s1f
approv
(2) lama
1s to
for He
to ser
on till
j
i
w I (10-23-80)
, or others 1n close proxMty to chemicals of any kind
ny be hazardous or tcxte unless. that employee has successfully
*d and been certified by fcfion IV'$ Hazardous Hatarlala
9 Course, or has taken tnTfcttonel Hazardous Materials
t Course. By way of further explanation, the definition
tlmlt)' means Slitting over [hazardous waste sites, attending .
iplsoles, entering pesticide warafwuses where any fora of
il or spillage Is known t» exist, or responding to permit
ons t*er« t|M discharge ii known to contain a chemical
ilflcaitt ajuant1«».* EMOSftlena to the above oust be
id by me or Nr. Wttle. .:'[ '-! v •'.-'=
king A1 Smith to chair a
begin the 1maod1ate devaloi
lion IV. I «« directing «
re with A1 Smith and u pi
undartaklng.
' ' ' ' •: "64
keslgnated Task Force that
Unt of a Safety S. 0. P.
* following Individuals
icing the highest priority
, •
-------
,\i~JI*.
?U""-
MANUAL
FIELD HEALTH
AND SAFETY
.2-
Tne following persons are designated to serve. Messrs. Doug Lair,
Mayne Nathls. George Moeln. Howard Zeller, Mark McClanahan,
Kent Mill lam, Ralph Jennings, Calvin Johnson, Ms. Sara Turnlpseed,
• and a Miter of the Safety ConnUtee designated by Mr. Larry Hyde.
I u asking Al to contact these Individuals within the next few
days to give them our conceptual thoughts on the Safety S.O.P.
I urge each Division Director to ensure that these people are
given the MM needed for speedy completion of this task.
He Intend to complete this task by June 1st and have a S.O.P. available
so that each of you my be fully advised as to your duties, operational
level of activity, and safety program. Since roughly ISO people In
Region IV have taken the Hazardous Materials Training Course. I am
confident that we can Met our Regional objectives.
MDCCCA M»
I (10-23-80)
65
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