United States Office of Occupational Health
Environmental Protection Administration and Safety Staff
Agency
&EPA 1440 - Occupational Health
and Safety Manual
1986 Edition
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ftEPA TRANSMITTAL
1440
CLASSIFICATION NO.:
tOVAL DATE:
3/18/86
210R86OO1
OCCUPATIONAL HEALTH AND SAFETY MANUAL
1. PURPOSE; This Transmittal revises the^ Occupational Health
and Safety Manual.
2. EXPLANATION. The Manual establishes policy, responsibilities
and procedures for the conduct of the Agency's Occupational Health
and Safety programs.
3. SUPERSESSION. The Occupational Health and Safety Manual and
all Transmittals.
4. FILING INSTRUCTIONS. Discard the old Manual and file the
attached in a three-ring binder. Post receipt of Transmittal
in front of Manual.
Gary'M. Katz, Dir«\tor
Management and Organization Division
ORIGINATOR;
Occupational Health and Safety Staff/Office of
Administration
EPA Form 1315-12 (R«v. 7-82) REPLACES EPA FORMS 1315-1A AND THE PREVIOUS EDITION OF 1315-12.
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CHECKLIST OF EPA TRANSMITTALS
TITLE
OCCUPATIONAL HEALTH AND SAFETY MANUAL — 1986 EDITION
When kept current, this checklist permits the user to see at a glance which transmittals have been filed.
SERIES
NUMBER
1440
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DATE
3/18/86
INI-
TIAL
SERIES
NUMBER
DATE
INI-
TIAL
SERIES
NUMBER
DATE
INI-
TIAL
EPA Form 1315-4 (Rev. 7-73)
PREVIOUS EDITIONS ARE OBSOLETE.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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CONTENTS OF CHAPTERS
CHAPTER CHAPTER
TITLES NUMBERS
POLICY AND RESPONSIBILITIES 1
OCCUPATIONAL HEALTH AND SAFETY PROGRAM ADMINISTRATION 2
ACCIDENT AND ILLNESS INVESTIGATION, REPORTING AND
RECORDKEEPING REQUIREMENTS 3
INSPECTIONS AND CORRECTION OF UNHEALTHFUL OF UNSAFE
WORKING CONDITIONS 4
OCCUPATIONAL HEALTH AND SAFETY COMMITTEES 5
OCCUPATIONAL HEALTH AND SAFETY STANDARDS 6
OCCUPATIONAL HEALTH AND SAFETY TRAINING 7
LABORATORY USE OF TOXIC SUBSTANCES .., 8
HAZARDOUS SUBSTANCES RESPONSES 9
EPA DIVING SAFETY POLICY 10
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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CHAPTER 1 - POLICY AND RESPONSIBILITIES
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS
Purpose 1
Policy 2
References 3
Definitions 4
Applicabi1i ty , 5
Background , 6
Responsibilities 7
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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CHAPTER 1 - POLICY AND RESPONSIBILITIES
1. PURPOSE. This Manual establishes policy, responsibilities, and
procedures for the conduct of the Agency's Occupational Health and Safety
programs.
2. POLICY. It is the policy of the Environmental Protection Agency to
administer its programs in a manner that will assure its employees places
and conditions of employment free from recognized hazards which are
likely to cause death or serious harm.
3. REFERENCES.
a. Section 7902(c), Title 5, United States Code.
b. Occupational Safety and Health Act of 1970, Sections 6, 19, and 24.
c. Executive Order 12196, Occupational Safety and Health Programs
for Federal Employees.
d. 29 CFR 1960, Basic Program Elements for Federal Employee Occu-
pational Safety and Health Programs.
e. OMB Circular A-ll (Sections 13.2(f) and 13.5(f)).
f. EPA Conduct and Discipline Order.
g. EPA Training and Development Manual.
4. DEFINITIONS.
a. Designated Agency Occupational Health and Safety Official. The
term Designated Agency Occupational Health and Safety Official means the
senior management official who, as required by E.O. 12196, is designated
as responsible for the management of the occupational health and safety
programs within the EPA. This Official is the Assistant Administrator
for Administration and Resources Management.
b. Agency Occupational Health and Safety Officer;. The term Agency
Occupational Health and Safety Officer means the person who manages the
occupational health and safety programs at an organizational level below
the Assistant Administrator for Administration and Resources Management.
This Officer is the Director, Occupational Health and Safety Staff, under
the supervision of the Director, Office of Administration.
c. Occupational Health and Safety Designee. The term Occupational
Health and Safety Designee means a person who has been officially ap-
pointed by the Officer-in-Charge of a Reporting Unit, Establishment, or
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Workplace to be responsible to him or her for managing the occupational
health and safety programs at that location.
d. Officer-in-Charge of a Reporting Unit, an Establishment, or a
Workplace"!The terms Officer-in-Charge of a Reporting Unit, an Establish-
ment, or a Workplace means the senior official at each Agency location
designated as a Reporting Unit, Establishment, or Workplace in Chapter
3 of this Manual.
e. Occupational Health and Safety Manager/Specialist. The term Oc-
cupational Health and Safety Manager/Specialist means a person who meets
the Office of Personnel Management standards, which include but are not
limited to these occupations:
Safety Manager/Specialist, GS-018
Safety Engineer, GS-803
Fire Protection Engineer, GS 804
Industrial Hygienist, GS-690
Fire Protection Specialist/Marshal, GS-081
Health Physicist, GS-1306
Occupational Medicine Physician, GS-602
Occupational Health Nurse, GS-610
Air Safety Investigation Officer, GS-1815
Aviation Safety Specialist, GS-1825
Chemist, GS-1320
Highway Safety Manager, GS-2125
or equally qualified military, agency, or non-government personnel as
determined by the Director, Occupational Health and Safety Staff.
f. Laboratory Health Officers. Laboratory Health Officers are
laboratory-based personnel who have expertise in health effects and
chemical hazards related to laboratory operations. Laboratory
Health Officers are officially appointed by the Officer-in-Charge
and support and functionally report to the Occupational Health and
Safety Designee for that Reporting Unit, Establishment or Workplace.
g. Occupational Health and Safety Inspector. The term Occupational
Health and Safety Inspector means an Occupational Health and/or Safety
Manager/Specialist (as defined in 4.e. above) with additional experience
and/or training in health and safety hazard recognition and evaluation.
h. Representatives of Management. The term representatives of manage-
ment means a supervisor or management official as defined in the applicable
labor-management regulations program covering the affected employees.
i. Reporting Unit. The term Reporting Unit means a facility where
Agency business is conducted and may include laboratories and field
offices and other subordinate facilities that report to the primary
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facility. A Reporting Unit as used in this Manual refers to the Head-
quarters complex, all Regions, the Environmental Research Centers and
Laboratories, and other field units designated by the Director, Occupational
Health and Safety Staff, in Chapter 3 of this Manual.
j. Establishment. The term Establishment means a single physical
location where EPA programs are conducted and which receives occupational
health and safety management support from a higher level of management,
which may be located at a different facility. Establishment as used
in this Manual refers to regional laboratories and field offices, national
programs at the Assistant Administrator level and other entities as
designated by the Director, Occupational Health and Safety Staff, in
Chapter 3 of this Manual.
k. Workplace. The term Workplace means a physical location where
the agency's work or operations are performed. A Workplace as used in
this Manual refers to a satellite field unit or a distinctly separate
activity located within an Establishment but which shares in the occupa-
tional health and safety programs at the Establishment.
1. Imminent Danger. The term imminent danger means any conditions
or practices in any EPA Reporting Unit, Establishment, Workplace or at any
EPA field site that could reasonably be expected to cause death or
serious physical harm either immediately or before the danger could be
eliminated through normal administrative procedures.
m- Serious. The word "serious" when used in this Manual with
"hazard," "violation" or "condition" means a hazard, violation or
condition which has a substantial probability of causing death or
significant physical harm.
n. Occupational Health and Safety Committee. The term occupational
health and safety committee means a committee that meets the requirements
of Chapter 5 of this Manual.
o. Recordable Occupational Injuries or Illnesses. The term recordable
occupational injuries or illnesses means any occupational injuries or ill-
nesses which result in:
1) Occupationally caused deaths regardless of the time between
injury and death, or the length of illness;
2) Nonfatal occupational illnesses; or
3) Nonfatal occupational injuries which involve one or more of
the following: days away from work or medical treatment.
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p. EPA Reportable Occupational Accidents and Illnesses. The term
EPA reportable accidents and illnesses means any^ and all job-connected
incidents involving Agency personnel, property, or operations which
result in personal injury, illness, fire, potential claims against the
Government, or property damage of $100.00 or more, or to any incident
having the potential to cause death or serious injury.
q. Recognized Hazard. A source of danger which could cause physical
harm or toxic effects in humans which has been identified by printed or
written data and for which control measures have been recommended or
established.
5. APPLICABILITY.
a. Executive Order 12196, 29 CFR 1960, and the provisions of this
Manual apply to all EPA employees at all operational levels.
b. EPA employees who work in facilities of private employers are
covered by the Agency's occupational health and safety programs. EPA
employees may be withdrawn from private sector facilities if safe and
healthful working conditions cannot be assured by the use of adminis-
trative cont'rols and personal protective equipment.
c. Executive Order 12196, 29 CFR 1960, and the provisions of this
Manual do not apply to employees or to the working conditions of employees
of EPA contractors, regardless of whether the contractor employees perform
their duties in EPA owned or leased facilities, with EPA equipment, or
together with EPA personnel. Protection of employees of EPA contractors
is assured under the other provisions of the Occupational Safety and
Health Act of 1970.
6. BACKGROUND. Section 1-201 of Executive Order 12196 requires the EPA
Administrator to establish and operate an occupational health and safety
program in accordance with Section 19 of the Occupational Safety and
Health Act of 1970 and with the basic program elements issued by the
Secretary of Labor in 29 CFR 1960. The Administrator, after consulta-
tion with Agency employees or their representatives, may request that
the Secretary of Labor approve alternate occupational health and safety
program elements which are consistent with the Agency's mission, size,
and organization.
To comply with Section 19 of the Occupational Safety and Health Act of
1970, Executive Order 12196, and 29 CFR 1960, the Administrator shall:
a. Designate an Agency Occupational Health and Safety Official
at the Assistant Administrator level to manage and administer the
Agency's occupational health and safety programs and to represent his
or her interest and support.
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b. Comply with all standards issued under Section 6 of the Act,
except when the Secretary of Labor has approved alternate Agency
standards.
c. Assure prompt abatement of unsafe or unhealthful working condi-
tions or develop abatement plans and interim steps to protect employees -
when these conditions cannot be promptly corrected.
d. Establish procedures to assure that employees who file reports
of unsafe or unhealthful working conditions or who participate in other
occupational health and safety program activities are not subject to
restraint, interference, coercion, discrimination or reprisal.
e. Assure that periodic inspections are performed at all Agency
facilities by personnel having the equipment and competence to recognize
hazards, and that employee representatives accompany inspectors during
the inspections.
f. Assure response to employee reports of hazardous conditions and
require inspections within 24 hours for imminent dangers, 3 working
days for potential serious conditions, and 20 working days for other
conditions. Assure the right to anonymity of those making the reports.
g. Operate an occupational health and safety management information
system to provide sufficient data to identify unsafe and unhealthful
working conditions, and to establish program priorities.
h. Provide occupational health and safety training for top manage-
ment officials, supervisors, occupational health and safety specialists,
occupational health and safety inspectors, collateral duty health and
safety personnel, occupational health and safety committee members,
employee representatives, and other employees.
i. .Submit an annual report to the Secretary of Labor on the Agency's
occupational health and safety programs. This report will include infor-
mation on the Agency's .self evaluation programs of the previous Calendar
•Year and objectives for the current year.
j. Authorize safety and health program personnel to utilize.such
expertise from whatever source available, including but not limited to
other agencies, professional groups, consultants, universities, labor
organizations, and safety and health committees.
6. RESPONSIBILITIES.
a. Program Management.
1) Administrator. The Administrator is responsible for the develop-
ment, implementation, and evaluation of the Agency's occupational health
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and safety programs in accordance with the requirements of Section 19 of
the Act, Executive Order 12196, and the basic program elements in 29 CFR
1960, or approved alternate program elements.
2) Assistant Administrator for Administration and Resources
Management. The Assistant Administrator for Administration and Resources
Management as the Designated Agency Occupational Health and Safety
Official, through the Director, Office of Administration, is responsible
for establi shing Agency occupational health and safety policies, programs,
standards, goals, objectives, and priorities, and for establishing an
organization, including the designation of safety and health officials
at appropriate levels, with adequate budget and staff to implement the
occupational health and safety programs at all EPA operational levels.
3) Director, Occupational Health and Safety Staff. The Director,
Occupational Health and Safety Staff, under the supervision of the
Director, Office of Administration, is responsible for developing Agency
occupational health and safety policies, programs, standards, goals and
objectives, for evaluating the effectiveness of the Agency'-s occupational
health and safety programs at all operational levels, and for providing
technical support to the Agency's Occupational Health and Safety programs.
b. Programs Implementation.
1) Assistant Administrators. Regional Administrators and Laboratory
Pi rectors. The Assistant Administrators and Regional Administrators and
Laboratory Directors and others designated as Officers-In-Charge of
Reporting Units are responsible for implementing the Agency's Occupational
Health and Safety Programs at the Reporting Unit and at all Establishments
and Workplaces within their area of jurisdiction.
2) Occupational Health and Safety Designees. The Occupational
Health and Safety Uesignees at all operational levels are responsible
for assisting the Officers-i n-Charge of their Reporting Units, Establish-
ments, or Workplaces in managing, developing, organizing, directing, and
evaluating the occupational health and safety programs, and for coordinating
illness and injury reporting and recordkeeping requirements; analyzing
accidents and injuries for prevention and control; and providing technical
advice to management officials in the implementation of program policy
and standards.
3) Laboratory Health Officers. Laboratory Health Officers are
responsible for providing advice and guidance on occupational health-
related matters affecting the Reporting Unit, Establishment or Workplace;
and for otherwise providing assistance to the Occupational Health and
Safety Designee in developing, organizing, directing, and evaluating the
occupational health elements of the occupational health and safety
programs on the local level.
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c. General.
1) Supervisors. Supervisors are responsible, to the extent of
their authority, for the health and safety of their employees and for
furnishing them employment and a place of employment which are free from
recognized hazards that are likely to cause death or serious harm. They
shall comply with the Agency's occupational health and safety standards
and with all rules, regulations, and orders issued by the Agency with
respect to the occupational health and safety programs and shall enforce
correct work practices.
2) Employees. Employees shall comply with the Agency's occupa-
tional health and safety standards, rules, regulations, and orders which
are applicable to their own actions and conduct. Employees shall also use
the safety equipment, personal protective equipment, and other health
and safety devices, and shall follow the procedures, provided or as directed,
that the Agency deems necessary for their protection.
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CHAPTER 2 - OCCUPATIONAL HEALTH AND SAFETY
PROGRAM ADMINISTRATION
Table of Contents
PARAGRAPH PARAGAPH
TITLES NUMBERS
General 1
Program Resources 2
Dissemination of Occupational Health and Safety
Program Information 3
Liaison with General Services Administration and
Other Federal Agencies ......4
Al legations of Reprisal 5
Field Federal Safety and Health Councils 7
Evaluation of Occupational Health and Safety Performance 8
APPENDIX 2A - PROCEDURES FOR REPORTING ALLEGED RESTRAINT,
INTERFERENCE, COERCION, DISCRIMINATION OR
REPRISAL FOR PARTICIPATING IN THE AGENCY'S
OCCUPATIONAL HEALTH AND SAFETY ACTIVITIES
APPENDIX 2B - EXAMPLES OF JOB PERFORMANCE STANDARDS
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CHAPTER 2 - OCCUPATIONAL HEALTH AND SAFETY
PROGRAM ADMINISTRATION
1. GENERAL. The Agency Designated Occupational Health and Safety Official
shal 1 assure that occupational health and safety officials are established
at each appropriate Agency level with sufficient authority and responsibility
to assure:
a. That qualified, competent personnel are available to manage the
Agency's Occupational Health and Safety program.
b. That funds for necessary health and safety equipment, materials,
training, and medical monitoring are available.
c. That employees are made aware of the Agency's occupational health
and safety programs through dissemination of information on Agency stand-
ards, programs, employee rights and responsibilities, and the Agency's
procedures for responding to reports by employees of unsafe or unhealth-
ful working conditions.
d. That a person at each Agency Reporting Unit is appointed to
represent EPA management in the resolution of conflicts that may exist
between EPA and GSA and other Federal agencies regarding Federal build-
ings, leased space, products purchased or supplied, and other requirements
affecting Agency employees' health and safety.
e. That procedures are established to assure that no EPA employee
is subject to restraint, interference, coercion, discrimination or
reprisal for filing a report of unsafe and unhealthful working conditions
or for other participation in the Agency's occupational health and
safety activities.
f. That the program is evaluated to determine the effectiveness of
the occupational health and safety programs.
g. That active participation in Field Federal Safety and Health
Councils is supported to facilitate the exchange of ideas and information
about occupational health and safety with other Federal agencies.
h. That the performance evaluations of supervisory employees, or
other appropriate management officials, measure their performance in
meeting the requirements of the Agency's occupational health and safety
programs, consistent with their assigned responsibilities and authority.
2. PROGRAM RESOURCES. The Officers-in-Charge of Reporting Units shall
ensure that their budget submissions include appropriate furicis and other
resources to implement and administer effectively the Agency's occupational
health and safety programs at their Reporting Units, and at oil Establish-
ments and Workplaces under their jurisdictional authority.
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Appropriate funds and other resources for administering the occupational
health and safety program shall provide for, but not be limited to:
a. Sufficient personnel to implement and administer the program
at all levels, and necessary administrative costs such as training,
travel, and personal protective equipment;
b. Abatement of unsafe or unhealthful working conditions related
to Agency operations or facilities;
c. Safety and health sampling, testing, and diagnostic and analyti-
cal tools, and equipment, including laboratory analyses;
d. Any necessary contracts to identify, analyze, or evaluate unsafe
or unhealthful working conditions and operations;
e. Program motivation and promotion material such as publications
posters, or films;
f. Technical information, documents, books, standards, codes, perio-
dicals, and publications; and
*
g. Occupational medical monitoring for employees.
3. DISSEMINATION OF OCCUPATIONAL HEALTH AND SAFETY PROGRAM INFORMATION.
a. Officers-in-Charge of Reporting Units shall promote employee
awareness of the Agency's occupational health and safety programs
through:
1. Providing copies of Executive Order 12196, 29 CFR 1960, and
the Agency's occupational health and safety program to all employees
upon request. Also, copies of Agency standards and other applicable
occupational health and safety standards shall be available to all
employees for review upon request.
2. Posting in a conspicuous place at each Agency location infor-
mation regarding provisions of the Act, Executive Order 12196, 29 CFR 1960,
and the Agency's occupational health and safety programs.
3. Posting a copy of the Agency's policy poster in a conspicuous
place at each Agency location.
4. Bringing occupational health and safety matters to the
attention of employees through existing inhouse publications and memo-
randa, e.g., newsletters, bulletins, or handbooks.
b. Officers-in-Charge are encouraged to purchase health and safety
promotional items such as posters, booklets, pamphlets, and audiovisual
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materials from commercial and Governmental sources which produce these
items. The following list of potential sources is furnished for informa-
tion only. It does not include all commercial sources marketing occupa-
tional health and safety promotional materials and must not be considered
as mandatory sources of supply.
1. National Safety Council, 444 North Michigan Avenue, Chicago,
Illinois 60611;
2. National Fire Protection Association, Batterymarch Park,
Quincy, Massachusetts 02269;
3. Dray Publications, Inc., Deerf ield Massachusetts 01342;
4. Channing L. Bete, Co., Inc., 200 State Street, South Deerfield,
Massachusetts 01373;
5. U.S. Department of Labor, Office of Information, OSHA,
200 Constitution Avenue, N.W., Washington, D.C. 20210;
6. General Services Administration, National Archives and
Records Service, National Audiovisual Center, Washington, D,C, 20210;
7. American Medical Association, Department of Occupational
Health, Division of Scientific Activities, 535 Dearborn Street, Chicago,
Illinois 60610;
8. Local Fire Departments;
9. Local Municipal Offices of Public Safety;
10. Local Law Enforcement Agencies;
11. Local Safety Councils;
12. State, County, and Local Health and Safety Officials; and
13. Local chapters of The American Red Cross, and The American
Heart Association.
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4. LIAISON WITH GENERAL SERVICES ADMINISTRATION AND OTHER FEDERAL
AGENCIES.The Officers-in-Charge of Reporting Units shall appoTnt a
representative to coordinate with GSA and other Federal agencies to
assure that Agency standards are met for buildings and facilities,
product safety and other safety and health services. This coordination
will include but not be limited to:
a. Building and Facility Health and Safety.
(1) Assuring that GSA furnishes a pre-occupancy inspection
of any Federally owned or leased space offered for EPA occupancy;
(2) Providing space that meets any EPA special health and
safety requirements;
(3) Assuring that any repair, renovation, or alteration of
owned or leased space be planned and controlled to reduce or eliminate
any hazardous exposure to EPA employees; and
(4) Requesting an investigation of employee reports of unsafe
or unhealthful conditions within GSA's scope of responsibility, and
monitoring the abatement of any conditions found.
b. Product Safety.
(1) Ensuring that items procured for use by the Agency's
employees are designed and manufactured to meet applicable health and
safety standards.
(2) Ensuring that all hazardous materials procured for use
by the Agency's employees are labeled, packaged, and shipped so as
to alert users to their flammability, toxicity, compatability, first
aid procedures and normal and emergency handling and disposal procedures,
(3) Assuring that the safety rescue and personal protective
equipment available for purchase meets the Agency's occupational health
and safety specifications and standards and are approved by NIOSH.
(4) Requesting Material Safety Data Sheets on all hazardous
materials purchased for use by EPA employees either from Federal
supply sources or private suppliers.
c. Safety and Health Services.
(1) Keeping abreast of the health and safety services and
equipment available for use by EPA from other Federal sources.
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(2) Assuring that an "Occupant Emergency Plan" is prepared
for all EPA facilities in accordance with 6SA guidelines contained in
41 CFR 101.
(3) Coordinating with GSA on a maintenance program for GSA
motorpool vehicles assigned to the Agency to assure the health and
safety of EPA employees utilizing the vehicles.
(4) Maintaining contact with NIOSH to obtain hazard alerts, and
to keep current on the technical services, training materials, and train-
ing programs available that can be utilized by Agency employees.
5. ALLEGATIONS OF REPRISAL.
a. Employee Rights. Employees are afforded certain rights under
Section 19 of the Occupational Safety and Health Act, Executive Order
12196, and 29 CFR 1960. These rights are:
(1) To report and request inspections of unsafe or unhealthful
working conditions to appropriate officials (See special procedures in
Chapter 4 of this Manual);
(2) Official time and reimbursement of travel and other costs
incurred to participate in the Agency's occupational health and safety
programs and in Field Federal Safety and Health Council activities;
(3) Access to copies of Agency standards, injury and illness
statistics, and procedures;
(4) To review and comment on Agency standards, policies, and
guidelines;
(5) To appeal to the Office of Federal Agency Program, OSHA on
disagreements over the final disposition of reports of unsafe or unhealth-
ful working conditions;
(6) To request anonymity when reporting unsafe or unhealthful
working conditions or requesting an inspection for these conditions; and
(7) To decline to perform assigned tasks because of a reason-
able belief that the task poses imminent risk of death or serious bodily
harm along with a reasonable belief that there is not time to go through
the normal hazard reporting and abatement procedures outlined in Chapter 4
of this Manual.
b. Agency Responsibilities. EPA must assure that no employee is
subject to restraint, interference, coercion, discrimination or reprisal
for filing a report of an unsafe or unhealthful working condition, or
other occupational health and safety activities identified in Executive
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Order 12196 and 29 CFR 1960. To assure EPA employees of their rights,
the procedures outlined in Appendix 2-1 will be followed when a report
of alleged restraint, interference, coercion, discrimination or reprisal
is received from an employee.
6. EVALUATION OF THE AGENCY'S OCCUPATIONAL HEALTH AND SAFETY PROGRAMS.
a. General. Executive Order 12196 and 29 CFR 1960.78 requires each
Agency to establish a program for evaluating the effectiveness of its own
occupational health and safety programs, and to submit an annual summary
of this self-evaluation activity to the Secretary of Labor. This self-
evaluation program must include a qualitative assessment of the extent
to which the Agency's Reporting Units have developed and implemented
their occupational health and safety programs in accordance with Executive
Order 12196, 29 CFR 1960, and the requirements of this Manual.
b. EPA's Evaluation Program.
(1) The Occupational Health and Safety Staff shall evaluate
the occupational health and safety programs at each Agency Reporting Unit.
These evaluations shall be conducted in accordance with the criteria and
guidelines contained in the EPA Occupational Health and Safety Program
Management Evaluation Guidelines. The evaluations shall include:
(a) A complete and extensive biennial evaluation of all
elements of the Agency's occupational health and safety programs at Report-
ing Units where no hazardous work is performed, e.g., office occupancies.
(b) A complete and extensive annual evaluation of all elements
of the Agency's occupational health and safety programs where hazardous tasks
are performed, e.g., laboratories.
(2) The Occupational Health and Safety Staff shal 1 conduct special
studies and evaluations of limited areas as deemed necessary by the Director,
e.g., laboratories handling toxic and/or carcinogenic substances, and hazardous
waste site and spill operations.
7. FIELD FEDERAL SAFETY AND HEALTH COUNCILS (FFSHC).
a. General. Executive Order 12196 requires that the Secretary of
Labor facilitate the exchange of occupational health and safety ideas
and information throughout the Government. Consistent with this requirement,
the Secretary of Labor sponsors existing FFSHC's and will establish new
Councils as necessary.
b. Objectives of FFSHC's. The basic objectives of the FFSHC are
the exchange of occupational health and safety ideas and information to
reduce the incidence, severity and cost of occupational accidents,
injuries, and illnesses in the Federal community. FFSHC's will act on
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behalf of the Secretary of Labor in carrying out these functions in
their respective geographic areas:
(1) To act as a clearinghouse for information and data on
occupational accidents, injuries, and illnesses and their prevent-
ion.
(2) To plan, organize, and conduct field council meetings
or programs which will give technical advice and information on occupa-
tional health and safety to participating agency representatives and
employee organizations.
(3) To promote improvement of occupational health and safety
programs and organizations in each Federal agency represented or par-
ticipating in council activities.
(4) To promote coordination, cooperation, and sharing of
resources and expertise to aid agencies with inadequate or limited
resources, e.g., field councils may organize and conduct training
programs for occupational health and safety program personnel, and
employee representatives; coordinate and promote programs for in-
spections; or, on request, conduct inspections and evaluations of the
agencies' health and safety programs.
(5) To provide Federal Executive Boards, Federal Executive
Associations, labor union organizations and other employee representa-
tives with information on the administrative and technical aspects of
health and safety programs.
(6) To evaluate the health and safety problems peculiar to
local conditions and facilitate solutions through council activities.
(7) To develop a cooperative relationship with local com-
munity leaders by informing them of the functions and objectives of
the council and by asking them for support and participation in
council meetings and activities.
c. Agency Participation in FFSHC.
(1) The EPA supports and encourages its employees to par-
ticipate in the FFSHC meetings and programs.
(2) The Officers-in-Charge of Reporting Units, and Establish-
ments, shall ensure that EPA is officially represented at appropriate
FFSHC's in their geographical areas where they exist and are reasonably
accessible.
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(3) The Officers-in-Charge of Reporting Units, and Establish-
ments, shall appoint a minimum of one management employee and one non-
management employee, and alternates dependent on the size and needs of
each unit, as representatives to FFSHC. These representatives shall be
selected from the following employee categories:
(a) Management
Occupational health and safety program personnel
Line management officials
(b) Non-Management
1) Representatives of exclusive bargaining units
2) Other recognized employee organizations
3) Employees recommended by the occupational health
and safety committee
(4) Appointments may be made to FFSHC's through a memorandum
by the Officers-in-Charge of the Reporting Unit to the Chairperson of
the Council. A copy of this memorandum should be sent to the Director,
Occupational Health and Safety Staff (PM-273), Washington, D.C.
20460.
(5) EPA will allow participation in FFSHC during official duty
hours, and the Reporting Unit, Establishment or Workplace will reimburse
travel and other costs incurred to participate in these council programs
and activities.
(6) The Director, Occupational Health and Safety Staff, will
furnish current lists of FFSHC's to Occupational Health and Safety
Designees as these lists are issued by the Department of Labor.
(7) The Occupational Health and Safety Staff will assess the
adequacy of FFSHC participation during scheduled program evaluations,
through field visits, and through annual narrative reports and health
and safety committee minutes. The Occupational Health and Safety Staff
will provide assistance and advice upon request.
8. EVALUATION OF OCCUPATIONAL HEALTH AND SAFETY PERFORMANCE.
a. General. 29 CFR 1960.11 requires the Agency head to ensure that
the performance evaluation of management officials in charge of Agency
Reporting Units, supervisory employees, or other appropriate management
officials, measures that employee's performance in meeting the requirements
of the Agency's occupational health and safety programs, consistent with
their assigned responsibilities and authority. This requirement shall
take into consideraton any applicable regulations of the Office of
Personnel Management or other appropriate authority.
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b. EPA's Program for Evaluation of Management and Supervisory
Personnel. Management and supervisory personnel will be evaluated annually
on their occupational health and safety performance as a part of their
annual performance evaluation. The performance standards of managers
and supervisors should have performance criteria defining expected perfor-
mance in providing a safe and healthful workplace for the employees
under their supervision. Appendix 2-2 contains examples of occupational
health and safety job performance criteria for managers and supervisors.
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APPENDIX 2-A -- PROCEDURES FOR REPORTING ALLEGED RESTRAINT,
INTERFERENCE, COERCION, DISCRIMINATION OR
REPRISAL FOR PARTICIPATING IN THE AGENCY'S
OCCUPATIONAL HEALTH AND SAFETY PROGRAMS.
Any Agency employee who believes they are being subjected to restraint,
interference, coercion, discrimination, or reprisal for exercising their
rights under the Occupational Safety and Health Act of 1970, Executive
Order 12196, 29 CFR 1960 or any of the Agency's published occupational
health and safety policies and procedures should follow the outlined
procedures to seek relief and a resolution of the matter.
Employee Rights. Employees are afforded these rights under Section 19,
Occupational bafety and Health Act of 1970, Executive Order 12196, and
29 CFR 1960:
0 To report and request inspections of unsafe or unhealthful
working conditions to appropriate officials.
0 Official time and reimbursement of travel and other costs
incurred to participate in the Agency's occupational health
and safety programs and in Field Federal Safety and Health
Council activities.
0 Access to copies of Agency standards, injury and illness
statistics, and procedures.
0 To review and comment on Agency standards, policies, and
guidelines.
0 To appeal to the Office of Federal Agency Programs, Occupational
Safety and Health Administation, U.S. Department of Labor, on
disagreements over the final disposition of reports of unsafe
or unhealthful working conditions.
0 To request ananymity when reporting unsafe or unhealthful
working conditions or requesting an inspection for these
conditions.
0 To decline to perform assigned tasks because of a reasonable
belief that the task poses imminent risk of death or serioys
bodily harm along with a reasonable belief that there is not
time to go through the normal hazard reporting and abatement
procedures of the Agency.
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Procedures. Employees may file a report either orally or in writing
using these avenues:
0 A grievance through the Agency's Grievance Procedures contained
in EPA Order 3110.8.
° Report any alleged violation to the Director, Occupational
Health and Safety Staff. The Director shall:
Assure the employee anonymity if requested.
Investigate the allegation if within the Staff's
capabilities, or
Refer the complaint to the Inspector General's
Office for investigation.
0 File a complaint with the Office of Personnel Management,
Merit Systems Protection Board, under PL 95-454, Section 202,
Civil Service Reform Act of 1978.
0 File a complaint with the Inspector General's Office direct by
calling (FTS) 382-4977 or toll free 800/424-4000, under the
Inspector General Act of 1978.
The Director, Occupational Health and Safety Staff shall:
0 Keep the appropriate occupational health and safety committees
advised of Agency activity and determinations regarding these
allegations.
0 Provide appropriate occupational health and safety committees
with copies of reprisal investigation findings.
0 Provide the Secretary of Labor with copies of any reprisal
investigation findings.
0 Provide the exclusive bargaining representative with a copy of
the investigation findings.
0 Provide the employee with a copy of the investigation findings.
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APPENDIX 2-B -- EXAMPLES OF JOB PERFORMANCE STANDARDS
Applicability: Assistant Administrators, Regional Administrators,
Office of General Counsel, Inspector General,
Associate Administrators, Heads of Offices
(Headquarters)
These officials must assure:
1. That funds are available for necessary health and safety equipment,
materials, training, and medical monitoring.
2. That qualified, competent personnel are appointed to manage the
occupational health and safety program in their area of jursidiction.
3. That a person is appointed to represent them in the resolution of
conflicts that may exist between EPA and GSA and other Federal agencies
regarding Federal buildings, leased space, products purchased or
supplied.
4. That no EPA employee under their area of jurisdiction is subject to
restraint, interference, coercion, discrimination or reprisal for
filing a report of unsafe and unhealthful working conditions or for
other participation in the Agency's occupational health and safety
activities.
5. That employees are aware of the Agency's occupational health and
safety programs through dissemination of information on Agency standards,
programs, employee rights and responsibilities, and the Agency's
procedures for responding to reports of unsafe or unhealthful working
conditions.
6. That active participation in Field Federal Safety and Health Councils
is supported to facilitate the exchange of ideas and information
about occupational health and safety with other Federal agencies.
7. That the program in their area of jurisdiction is evaluated to determine
its effectiveness.
8. That the performance evaluations of supervisors and managers under
their area of jurisdiction measures their performance in meeting the
requirements of the Agency's occupational health and safety programs,
consistent with their assigned responsibilities and authority.
Critical Job Element
(The criteria for health and safety performance may be placed under the
critical job element which covers the use and development of personnel
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Objective:
Effectively manage the personnel and financial resources of the program/
region.
Performance Criteria:
Outstanding: Evaluation of the occupational health and safety
program management strongly supports the firm and clear written and oral
implementation of the Agency's occupational health and safety programs
to protect employees and that this expectation is included in all successive
performance standards of managers and supervisors under their direction.
Satisfactory: Evaluation of the occupational health and safety
program management has clearly established, through successive performance
standards and by written and oral examples, the support and implementation
of the Agency's occupational health and safety programs and the awareness
that supervisors are responsible for the health and safety of employees
under their direction.
Unsatisfactory: Evaluation of the occupational health and safety
program management establishes that the first level supervisors are
unsure as to the relative importance of employee health and safety in
conducting program/regional operations or do not feel responsible for
the employees under their jurisdiction.
Applicability: Supervisors
Supervisors must assure:
1. That employees under their supervision are provided the necessary
health and safety equipment, materials, training, and medical monitoring
applicable to the jobs they perform.
2. That employees under their supervision are aware of their rights and
that they are not subject to restraint, interference, coercion,
discrimination or reprisal for filing a report of unsafe or unhealthful
working conditions or of other participation in the Agency's occupational
health and safety programs.
3. That employees under their supervision are aware of the Agency's
occupational health and safety programs, standards, guidelines, and
procedures how to report unsafe or unhealthful conditions and that
they fully understand their occupational health and safety responsi-
bilities and that failure to assume these responsibilities may be
cause for disciplinary action.
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Critical Job Element
(The criteria for health and safety performance may be placed under the
critical job element which covers the use and development of personnel
and other resources or any other compatible critical job element.)
Objective:
To assure that all employees under their supervision comply with all
occupational health and safety standards, rules, regulations, and orders
issued by the Agency.
Performance Criteria:
Outstanding: Occupational health and safety program evaluation
shows clearly that the supervisor understands his/her responsibility for
the health and safety of employees under his/her supervision by surveying
the needs of employees for training, medical monitoring, materials, and
personal protection equipment and provides the necessary items to the
employees applicable to the jobs they perform. Supervisor strongly
supports and enforces safe work practices and initiates disciplinary
actions if needed.
Satisfactory: Occupational health and safety program evaluation
shows that the supervisor understands responsibility for the health and
safety of employees under his/her supervision and has provided the minimum
training, medical monitoring, materials, and personal protective equipment
applicable to the jobs they perform and enforces these requirements
through initiating disciplinary actions if needed.
Unsatisfactory: The supervisor is unsure of his/her occupational
health and safety responsibility and that he/he is responsible for the
health and safety of the employees he/she supervises. The minimum health
and safety training, medical monitoring, materials, and protective equipment
are not provided nor is safe work practices enforced.
NOTE: These examples are not intended as mandatory wording. They are
onl^y examples. Each Reporting Unit, Establishment and Workplace
may develop occupational health and safety performance standards
consistent with their needs.
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CHAPTER 3 - ACCIDENT AND ILLNESS INVESTIGATION, REPORTING
AND RECORDKEEPING REQUIREMENTS
Table of Contents
PARAGRAPH
TITLES
General ,
Identification of Reporting Units
Accident and Illness Investigation ,
Accident and Illness Recording and Reporting . . .
Agency Annual Reports ,
Access to Records by the Secretary of Labor . . . .
Utilization and Location of Records and Reports . ,
Retention of Records
Incidence and Severity Rates and Cost of Accidents
and Illnesses
PARAGRAPH
NUMBERS
1
2
3
4
5
6
7
8
APPENDIX 3A -
APPENDIX 3B -
APPENDIX 3C -
APPENDIX 3D -
APPENDIX 3E -
APPENDIX 3F -
APPENDIX 36 -
REPORTING UNITS
ACCIDENT/ILLNESS INVESTIGATION PROCEDURES
SUPERVISOR'S REPORT OF ACCIDENT/ILLNESS
(EPA FORM 1440-9)
LOG AND SUMMARY OF FEDERAL OCCUPATIONAL
INJURIES AND ILLNESSES, OSHA RECORDABLE,
FORM 200
LOG OF FEDERAL OCCUPATIONAL INJURIES AND
ILLNESSES, EPA REPORTABLE
ANNUAL SUMMARY OF FEDERAL OCCUPATIONAL
INJURIES AND ILLNESSES, OSHA FORM 102-F
FLOW CHART DEPICTING OSHA RECORDABLE
CRITERIA
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CHAPTER 3 - ACCIDENT AND ILLNESS INVESTIGATION AND REPORTING
AND RECORDKEEPING REQUIREMENTS
1. GENERAL. Section 24 of the Occupational Safety and Health Act of
1970, and Section l-201(j) of Executive Order 12196 require EPA to establish
and maintain an effective occupational health and safety management
information system. Regulations for the program are contained in 29 CFR
1960, Subpart I. The purpose of this Chapter is to establish uniform
requirements for collecting and compiling occupational health and safety
accident and illness data for the Agency's Management Information System.
This information will be used by the Agency to (a) identify unsafe and
unhealthful working conditions, and (b) to establish occupational health
and safety program priorities. Additionally, since comprehensive accident
and illness investigations and analyses are necessary to an effective
management information system, procedures and policies for their implemen-
tation are also included.
2. IDENTIFICATION OF REPORTING UNITS. EPA is required to provide to the
Department of Labor the names and addresses of each of the Reporting Units
covered by its occupational health and safety records program. Appendix
3-A lists EPA's Reporting Units and their sub-units.
3. ACCIDENT AND ILLNESS INVESTIGATION. The investigation of an accident
or illness is necessary to prevent similar occurrences. Investigation
should not attempt to prove guilt or innocence. Rather its purpose should
be to ascertain the existence of hazards by identifying the elements and
sources which caused the accident or illness. Additionally, proper inveS"
tigation should result in the identification of any corrective measures
which may be required.
All information or evidence uncovered during an accident or illness inves*-
tigation that would be of benefit to EPA in developing a new occupational
health and safety standard or in modifying an existing standard must be
reported promptlyu to the Headquarters Occupational Health and Safety
Staff. While all accidents and illnesses are to be investigated, including
accidents involving only property damage, the scope of the investigation
depends on the seriousness of the accident.
a. Objectives of an Accident or Illness Investigation. The objectives
of an accident or illness investigation are to:
(1) Determine the existence of any hazards or contributing
factors involved, and make recommendations for eliminating the hazards.
(2) Determine if any unsafe or unhealthful behavior or condition
was involved, and make recommendations for eliminating the unsafe or
unhealthful condition or behavior involved.
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b. Determination of Accident or Illness Causes. The cause of an
accident or illness is any behavior, condition, act, or negligence without
which the accident or illness would not have happened. One of the primary
reasons for accident or illness investigation is to determine the causal
factors involved so corrective actions can be initiated.
The cause of an accident or illness is normally a combination of
simultaneous or sequential circumstances without any of which the accident
or illness could not have happened.
The investigator should look for and identify correctly all accident
and illness causes to ensure better analysis and provide the basis for
realistic corrective action.
c. Responsibilities for an Accident or Illness Investigation.
Accident or illness investigations require a search for all factors
involved in the accident or illness. Every factor mist be found, evaluated
and considered in order to determine what actually occurred and why.
Failure to gather and consider all factors could allow recurrent accidents
or illnesses from the same cause.
(1) Supervisor. When the supervisor is advised that an accident
or illness has occurred, he/she should:
(a) Investigate promptly.
(b) Determine what happened and how it happened.
(c) Determine the results.
(d) Determine what immediate corrective action to take.
(e) Notify the Occupational Health and Safety Designee and
request assistance from the Designee and others if needed.
(2) Occupational Health and Safety Designee. When the Designee
is advised that an accident or illness has occurred, he/she should:
(a) Conduct an investigation promptly.
(b) Collect and weigh all facts, and justify the conclusions
reached by the evidence.
(c) Determine familiarity by the employee with equipment
and procedures involved.
(d) Determine the conditions or situations relative to the
cause of the accident or illness.
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(e) Determine if the accident or illness was caused by a
physical hazard or by an unsafe act.
(f) Assign one or more persons to investigate major lost
time accidents or illnesses.
(g) Be objective and independent from the individuals or
programs involved in the accident or illness.
d. Procedures for Conducting an Investigation. The Occupational
Health and Safety Designee should follow these procedures in all accident
and, in most cases, illness investigations:
(1) Arrive at the scene promptly and obtain facts quickly and
accurately.
(2) Promptly assess existing hazards to others at the scene
and, as appropriate, evacuate the area and/or seek professional assistance
to secure the premises from further such occurrences.
(3) Evidence at the scene of an accident must be preserved until
the investigation is completed, except to the extent necessary to protect
employees and the public.
(4) Get statements from all witnesses.
(5) Interview the injured person(s) as soon as possible.
(6) Obtain physical evidence. Get measurements and photograph
the scene.
(7) Record all evidence relating to the accident or illness.
(8) Recommend hazard elimination, change in standard operating
procedures, or training revision.
Appendix 3-B is a detailed outline of accident or illness investigation
procedures.
e. Distribution of Investigation Reports. Copies of accident or
illness investigation reports shall be distributed as follows:
(1) The supervisor shall:
(a) Provide a copy of his/her investigation to the local
Occupational Health and Safety Designee.
(b) Provide a copy to the employee(s) involved.
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(c) Keep a copy for his/her file.
(2) The Occupational Health and Safety Designee shall:
(a) Provide a copy to the Officer-in-Charge of the Reporting
Unit.
(b) Provide a copy to the Headquarters Occupational Health
and Safety Staff.
(c) Provide a copy to the local occupational health and
safety committee.
(d) Provide a copy to the exclusive employee representative,
if appropriate and requested.
(e) Keep a copy for his/her file.
Investigation reports shall be made available to the Secretary of
Labor or his/her authorized representative on request.
4. ACCIDENT AND ILLNESS RECORDING AND REPORTING. The accurate and
complete recording and reporting of accidents and illnesses are essential
to effective investigations.
The reasons for recording and reporting accidents and illnesses are
to notify management that a mishap has occurred; to record essential
information that will help identify causes, point to corrective action,
indicate trends, and provide a basis for future occupational health and
safety program planning; and to permit an evaluation of the progress
being made in the prevention of accidents and illnesses.
a. Reporting Forms. The following forms are used by EPA for main-
taining occupational health and safety accident and illness records and
for preparing Agency reports and reports required by the Department of
Labor.
(1) EPA Form 1440-9, "Supervisor's Report of Accident/Illness"
(See Appendix 3-C). This is the basic document for reporting all job-
related accidents and illnesses.
(2) OSHA Form 100-F, "Log of Federal Occupational Injuries and
Illnesses" (See Appendix 3-D). This is the basic document used for
compiling data under the Occupational Health and Safety Act.
(3) OSHA Form 102-F, "Annual Summary of Federal Occupational
Injuries and Illnesses" (See Appendix 3-F), This form is to be used for
annual report submissions by EPA Reporting Units to Headquarters. (The
Headquarters Occupational Health and Safety Staff will prepare and submit
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an annual summary for the Agency to the Department of Labor.) A copy
of each Reporting unit's report should be posted at its headquarters and
all sub-units covered by the report for 30 days no later than 45 days
after the beginning of the Calendar Year.
b. Reporting Requirements. EPA requires that employees report all
job-connected accidents and illnesses to their supervisor. A job-connected
accident or illness is any incident involving Agency personnel, property,
or operations which results in personal injury or illness, vehicle
collision, fire, a potential claim against the Government, or property
damage of $100.00 or more, or any incident having the potential to cause
death, serious injury or illness.
(1) Reporting Procedures. Procedures for the reporting and
distribution of information on accident or illness incidents by the
employee, the supervisor, the Personnel Office and the Reporting Unit
Occupational Health and Safety Designee follow:
(a) The employee shall:
1_ Report immediately any job-connected incidents to
his/her supervisor.
2_ Furnish accurate and sufficient information regarding
the circumstances of the incident to enable the supervisor to complete
EPA Form 1440-9.
3^ Complete CA-1, if an occupational injury is involved.
4_ Complete CA-2, if an occupational illness is involved.
(b) The supervisor shall:
1_ Investigate all job-connected incidents within two
working days and complete EPA Form 1440-9, Supervisor's Report of
Accident/Illness.
2_ Distribute copies of EPA Form 1440-9 as follows:
a Original (white) to EPA, Occupational Health and
Safety Staff (PM-273J, Washington, D. C. 20460.
b^ Furnish the employee a copy (go! den rod).
£ Retain a copy (pink) for his/her file.
d^ Furnish the Personnel Office or Employee Compensation
Coordinator with a copy (green) along with the original CA-1 or CA-2 if an
occupational injury or illness is involved.
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e_ Furnish a copy (canary) to the local Occupational
Health and Safety Designee along with a copy of the CA-1 or CA-2 if an
occupational injury or illness is invoTved.
(c) The Personnel Office or Workers' Compensation Coordinator
shall:
J_ Review the EPA Form 1440-9 and CA-1 or CA-2 if an
occupational injury or illness is involved.
2_ Contact the employee and explain his/her rights and
benefits under the Federal Employees Compensation Act.
2 If an OSHA recordable injury or illness is involved,
forward the original CA-1 or CA-2 to the Office of Workers' Compensation,
U.S. Department of Labor, and file a copy in the employee's official
personnel file, or
_4 If no OSHA recordable injury or illness is involved,
file the original CA-1 or CA-2 in the employee's official personnel file.
(d) The Occupational Health and Safety Designee shall:
]_ Assign a control number for the case.
2_ Prepare a file.
3_ Enter information regarding the indicent on the
Reporting Unit log (a separate OSHA Form 100-F may be used). See Appendix
3-E.
4^ If the incident is recordable under OSHA cirteria
enter the information on the OSHA Form 100-F log. See Appendix 3-D.
J5 Proceed with the investigation of the incident within
five working days of receipt of EPA Form 1440-9 for routine incidents and
on receipt of verbal, telephone, or written information pertaining to
the reporting of a serious incident as defined in the following section.
£ Document the findings and distribute copies as
follows:
a Original to the EPA, Occupational Health and
Safety Staff, (PM-273J, Washington, D. C. 20460.
b^ Copy to the Officer-in-Charge of the Reporting
Unit, and Establishment or Workplace if these sub-units are involved.
£ Copy to the Chairperson, Occupational Health and
Safety Committee.
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d^ Copy to the exclusive representative, if appropriate
and requested.
£ Retain a copy for his/her official file.
(2) Reporting of Serious Incidents. The supervisor and/or local
Occupational Health and Safety Designee mist report serious incidents to
the Headquarters Occupational Health and Safety Staff by telephone or
facsimile copy within 48 hours of occurrence. A serious incident involves:
(a) An accident or illness resulting in death.
(b) A disabling injury involving the loss of use of a prin-
cipal part of the body or total disability.
(c) A single incident which requires the hospitalization
of five or more employees, regardless of cause or severity;
(d) An incident stemming from EPA operations involving
non-EPA personnel which requires hospitalization of five or more persons
or results in a fatality;
(e) Damage which exceeds $10,000.00 to EPA leased or owned
property or to non-EPA property arising from EPA operations.
(f) Reports of incidents which require immediate reporting
must contain:
_]_ Name(s) of person(s) involved.
2_ Date and time of incident.
_3_ Apparent cause of the incident.
£ Location and brief circumstances.
5_ Name(s) and address(es) of the next of kin if a
fatality is involved.
j>. Type and extent of property damage.
1_ Present status (what has been and what remains to
be done).
J3 Personal contacts and telephone numbers for addi-
tional information.
c. Record or Log of Federal Occupational Injuries and Illnesses.
EPA requires that a record or log of OSHA recordable occupational injuries
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and illnesses must be maintained at each Reporting Unit identified by
the Agency in Appendix 3-A. An OSHA recordable occupational injury OP
illness involves:
(1) All work-related injuries and illnesses that result in death
regardless of the time between injury and death or the length of the illness.
(2) An injury or illness which results in one or more of the
following:
(a) Loss of consciousness,
(b) Restriction of work or motion,
(c) Transfer to another job,
(d) Days away from work,
(e) Restricted work activity, or
(f) Medical treatment beyond First Aid.
Appendix 3-G is a Flow Chart Depecting OSHA accident/illness recording
criteria.
d. Related Reports. In addition to the submission of EPA Form 1440-9,
the supervisor is responsible for other reports required under regulations.
These include:
(1) State and local police reports regarding motor vehicle
accidents;
(2) SF-91, Report of Motor Vehicle Accident;
(3) SF-91, Investigation Report of Motor Vehicle Accident;
(4) Coast Guard Form CG-3865, Boating Accident Report; and
(5) NTSB Form 6120.1, Pilot-Operator Aircraft Accident Report.
5. AGENCY ANNUAL REPORTS. EPA requires two annual reports on a Calendar
Year basis. These reports are:
a. Annual Summary of Federal OccupationalInjuries andIllnesses*
(1) Each EPA Reporting Unit shall compile an annual summary of
the occupational injuries and illnesses that have occurred at Its head-
quarters and all of its sub-units during the past Calendar Year.
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(2) The summary shall be based on the OSHA recordable record
or log of occupational injuries and illnesses. The Headquarters Occupa-
tional Health and Safety Staff will provide Reporting Units with copies
of OSHA Form 102-F for this purpose.
(3) Each Reporting Unit shall post a copy of their annual
summary report for 30 days not later than 45 calendar days after the
close of the Calendar Year at its headquarters and at each of its sub-'units.
(4) The Headquarters Occupational Health and Safety Staff shall
consolidate annual summaries from EPA Reporting Units and furnish the
Department of Labor with a consolidated report to meet its reporting
deadline after the close of the Calendar Year. Copies of this consolidated
report will be furnished to all Reporting Units.
b. Annual Narrative Report.
(1) Each EPA Reporting Unit shall be required to submit a narrar
tive report describing its occupational health and safety program for the
previous Calendar Year by February 15 of each year.
(2) The Headquarters Occupational Health and Safety Staff shall
furnish guidelines for this report to each Reporting Unit based on Depart"
ment of Labor requirements.
(3) The Headquarters Occupational Health and Safety Staff will
provldse a consolidated Agency annual narrative report to the Department
of Labor by April 1st of each year. The consolidated report shall include
a summary of the Agency's evaluation of its occupational health and safety
programs. Each Reporting Unit will be furnished a copy of this report.
6. ACCESS TO RECORDS BY THE SECRETARY OF LABOR. The records generated
by the requirements of this Chapter shall be available and accessible to
the Secretary of Labor or his/her authorized representative(s).
7. UTILIZATION AND LOCATION OF RECORDS AND REPORTS. Occupational injury
and illness information must be made available to employees and their
representatives with the basic information necessary to assure they can
actively participate in EPA's safety and health programs. Occupational
health and safety inspectors also mist have access to accident and Illness
records to better carry out their duties.
The official records may be maintained at the Reporting Unit headquarters.
Copies of the reports generated by these records must be provided to the
Establishment(s) and Workplace(s) under administrative control of the
Reporting Unit.
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8. RETENTION OF RECORDS. The records and reports required to be main-
tained under the provisions of this Chapter shall be retained by each
Reporting Unit for five years following the end of the Calendar Year to
which they relate. These records may be stored at a Federal Record
Retention Center which has reasonable access. Records required by Agency
and OSHA standards shall be retained in accordance with those standards.
9. INCIDENCE AND SEVERITY RATES, AND COST OF ACCIDENTS AND ILLNESSES.
The determination of the incidence rate, number of lost work days, and
the cost of accidents and illnesses should be periodically made. These
data should be provided to Agency managers and supervisors to keep them
informed of the progress or problems of the program. The Director,
Occupational Health and Safety Staff, will provide an annual report to
each Reporting Unit on their incidence and severity rates.
a. Incidence and Severity Rates. The incidence rate is the number
of injuries and illnesses or lost work days per 100 full-time employees.
Incidence rates are calculated as follows:
Number of recordable injuries/illnesses x 200,000
Total employee hours worked
(during a month, a quarter or a Calendar Year)
The lost work day rates or severity rates are calculated as follows:
Number of lost work days x 200,000
Total employee hours worked
b. Accident/Illness Cost Data. The indirect cost of injuries and
illnesses is a matter of concern and is a strong argument for maintaining
safe and healthful conditions and work practices. A conservative estimate
of indirect costs over direct costs is 4 to 1.
(1) The factors involved in direct costs are:
(a) Reimbursement of medical benefits to the Department
of Labor.
(b) Reimbursement of compensation benefits to the Depart-
ment of Labor.
(c) Payment of costs to the Department of Labor for the
administrative costs of the program.
3-10
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
3/18/86
(2) The factors involved in indirect costs are:
(a) Continuation of pay for the injured employee.
(b) Time lost from work by the injured employee.
(c) Time lost by fellow workers:
1_ Time lost by the supervisor during the investigation
and reporting.
_2 Time lost by other employees providing statements
to investigators and observing the incidents.
3_ Time lost by management and clerical personnel
while providing assistance in the investigating and reporting period.
(d) Cost of repairing damage to equipment and/or facilities.
(e) Cost of training a substitute or new employee.
(f) Economic loss to employee's family.
(g) Cost of damage to non-government property.
Although these indirect costs are real, they are difficult to demon-
strate to management as being a part of the overall costs of an accident
or illness. However, management should be apprised of these factors
that affect the overall costs of accidents and illnesses.
3-11
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APPENDIX 3-A - REPORTING UNITS
o Reporting Unit
oo Establishment
OOP Workplace
I. REGIONAL ORGANIZATION
o Regional Office
Region 1
JFK Federal Bldg.
Boston, MA 02203
oo Regional Laboratory
Region 1
60 Westview St.
Lexington, MA 02173
o Regional Office
Region 2
26 Federal Plaza
New York, NY 10007
oo Regional Laboratory
Region 2
Woodbridge Ave.
Edison, NJ 08837
ooo Envi ronmenttil Response Team
Woodbridge Ave.
Edison, NJ 08837
ooo Oil & Haz. Materials
Spil1 Branch
Woodbridge Ave.
Edison, NJ 08837
ooo Storm/Combined Sewsr Section
Woodbridge Ave.
Edison, NJ 08837
Officer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
o Regional Administrator
Region 1
oo Di rector, Environmental
Services Division
o Regional Administrator
Region 2
oo Di rector, Envi ronmental
Services Division
ooo Chief, Environmental
Response Section
ooo Chief, Oil & Haz.
Materials Spill Branch
ooo Chief, Storm & Combined
Sewer Section
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health &
Safety Designee -
Reporting Unit
Occupational Health &
Safety Designee -
Establishment
Occupational Health &
Safety Designee -
Reporting Unit
Occupational Health &
Safety Designee -
Establishment
Occupational Health &
Safety Designee -
Workplace
I
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o Reporting Unit
oo Establishment
OOP Workplace
oo San Juan Field Office
o Regional Office
Regi on 3
Curtis Bldg., 6th & Walnut
Philadelphia, PA 19106
oo Annapolis Field Office
839 Bestgate Rd.
Annapolis, MD 21401
oo Wheeling Field Office
303 Methodist Bldg.
Wheeling, WV 26003
o Regi onal Office
Region 4
345 Courtland St. ., NE
Atlanta, GA 30308
o Regional Office
Region 5
230 S. Dearborn St.
Chicago, IL 60604
oo Regi onal Laboratory
Region 5
536 S. Clark St.
Chicago, IL 60609
o Eastern District Office
25089 Center Ridge Rd.
West Lake, OH 44145
Officer-in-Charge of:
o Reporting Unit
oo Establishment
OOP Workplace
oo Director, San Juan
o Regional Administrator
Region 3
oo Director, Annapolis
Field Office
oo Director, Wheeling
Field Office
o Regional Administrator
Region 4
o Regi onal Administrator
Region 5
oo Di rector, Environmental
Services Division
oo Director, Eastern District
Office
Occupational
Health 8, Safety
Program Management
Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Establi shment
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Establishment
a
3
oo o
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-A-2
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o Reporting Unit
oo Establishment
_ OOP Workplace
o Regional Office
Region 6
1201 Elm St.
Dallas, TX 75270
oo Houston Branch
Environmental Services Div.
6608 Hornwood Dr.
Houston, TX 77074
o Regional Office
Region 7
726 Minnesota Ave.
Kansas City, KS 66101
oo Regional Laboratory
Region 7
25 Funston Rd.
Kansas City, KS 66115
o Regi onal Office
Region 8
One Denver Place
999 18th St.
Denver, CO 80202-2413
oo Technical Investigations Br.
Bldg. 53, DFC
Denver, CO 80225
oo Montana Operations Office
Helena, MT
o Regional Office
Region 9
Officer-in-Charge of:
o Reporting Unit
oo Establishment
OOP Workplace
o Regional Administrator
Region 6
oo Di rector, Environmental
Services Division
o Regional Administrator
Region 7
oo Di rector, Environmental
Services Division
o Regional Administrator
Region 8
oo Di rector, Environmental
Services Division
oo Chief, Montana Operations
Office
o Regional Administrator
Region 9
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
215 Fremont St.
San Francisco, CA
Occupational Health
& Safety Designee -
Reporting Unit
00 O
00
94105
3-A-:
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o Reporting Unit
oo Establishment
OOP Workplace
o Regional Office
Region 10
1200 6th Ave.
Seattle, WA 98101
oo Regional Laboratory
Region 10
P. 0. Box 549
Manchester, WA 98353
oo Oregon Operations Office
533 S. W. Fifth Ave.
Yeon Bldg., 2nd Floor
Portland, OR 97204
oo Idaho Operations Office
422 West Washington St.
Boise, ID 83702
oo Washington Operations Office
13400 Northrup Way, Suite 3
Bellevue, WA 98004
oo Alaska Operations Office
Room #535, Federal Bldg.
701 C St.
Anchorage, AL 99513
II. HEADQUARTERS ORGANIZATION
o Headquarters Complex
(Includes Waterside and Crystal
Malls and the Marfair Bldg.)
401 M St., SW
Washington, DC 20460
Of ficer-i n-Charge of:
o Reporting Unit
oo Establishment
OOP Workplace
o Regional Administrator
Region 10
oo Di rector, Environmental
Services Division
oo Director, Oregon Operations
Office
oo Director, Idaho Operations
Office
oo Di rector, Washington Operations "
Office
oo Director, Alaska Operations
Office
Occupati onal
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager -
Reporting Unit
Occupational Health
& Safety Manager -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
8
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3-A-4
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o Reporting Unit
oo Establishment
OOP Workplace
oo Office of the Administrator
401 M Street, SW
Washington, D.C. 20460
ooo Associate Administrator
for International Activities
401 M Street, SW
Washington, D.C. 20460
ooo Associate Administrator
for Regional Operations
401 M Street, SW
Washington, D.C. 20460
oo Assistant Administrator for
Administration & Resources Wgmt.
401 M Street, SW
Washington, O.C. 20460
ooo Office of Administration
401 M Street, SW
Washington, D.C. 20460
ooo Office of Comptroller
401 M Street, SW
Washington, D.C. 204150
ooo Office of Information
Resources Managenent
4-01 M St reet, Stt
Washington, D.C. 204iiO
ooo Office of Human Resources Mgmt,
401 M Street, SW
Washington, D.C. 20450
Officer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
Occupational
Wealth & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager-
Reporting Unit
ooo Associate Administrator
for International Activities
ooo Associate Administrator
for Regional Operations
oo Assistant Administrator
for Administration &
Resources Management
Occupational Health
& Safety Manager-
Reporting Unit
ooo Director, Office of
Administration
ooo Oirector,. Office of
Coup t roller
ooo Director, Office of
Information Resources Mgmt,
ooo Director, Office of Wuman
Resources Mgmt.
3-A-5
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee-
Establishment
Occupational Health
& Safety Designee-
Workplace
Occupational Health
& Safety Designee-
Establishment
Occupational Health
& Safety Designee-
Workplace
0.0
c.
c
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o Reporting Unit
oo Establishment
OOP Workplace
oo Office of Asst.
for Enforcement
Monitoring
401 M Street, SW
Washington, D.C.
Admi nistrator
& Compliance
20460
oo Office of General Counsel
401 M St., SW
Washington, DC 20460
oo Office of Asst Administrator
for Policy, Planning, &
Evaluation
401 M St., SW
Washington, DC 20460
ooo Office of Policy Analysis
401 M St., SW
Washington, DC 20460
ooo Office of Standards and
Regulations
401 M St., SW
Washington, DC 20460
ooo Office of Management
Systems and Evaluation
401 M St., SW
Washington, DC 20460
oo Office of Asst Administrator
for External Affai rs
401 M St. , SW
Washington, DC 20460
Officer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
oo Assistant Administrator
for Enforcement and
Compliance Monitoring
oo Director, Office of
General Counsel
oo Assistant Administrator
for Policy, Planning, &
Evaluation
ooo Director, Office of
Policy Analysis
ooo Director, Office of
Standards and
Regulations
ooo Director, Office of
Management Systems li
Evaluation
oo Assistant Administrator for
External Affairs
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
and Safety Manager -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Establi shment
Occupational Health
& Safety Designee -
Workplace
Occupational Health
& Safety Designee -
Establishment
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o Reporting Unit
oo Establishment
ooo Workplace
ooo Office of Private and
Public Sector Liaison
401 M St., SW
Washington, DC 20460
ooo Office of Congressional
Liaison
401 M St. , SW
Washington, DC 20460
ooo Office of Federal Activiti
401 M Street, SW
Washington, D.C. 20460
oo Office of Inspector General
401 M Street, SW
Washington, D.C. 20460
ooo Office of Audit
401 M Street, SW
Washington, D.C. 20460
ooo Office of Investigations
401 M Street, SW
Washington, D.C. 20460
ooo Office of Management and
Technical Assessment
401 M Street, SW
Washington, D.C. 20460
oo Office of Asst Administrator
for Watar
401 M Street, SW
Washington, D.C. 20460
Officer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
ooo Director, Office of
Private and Public
Sector Liaison
ooo Director, Office of
Congressional Liaison
es ooo Di rector, Office of
Federal Activities
oo Director, Office of
Inspector General
ooo Director, Office of
Audit
ooo Director, Office of
Investigations
ooo Director, Office of
Management and
Technical Assessment
oo Director, Office of
Assistant Adminstrator
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager-
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Workplace
Occupational Health
& Safety Designee -
Workplace
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Workplace
Occupational Health
& Safety Designee -
Establishment
U) M
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3-A-7
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o Reporting Unit
oo Establishment
OOP Workplace
ooo Office of Water Enforcement
& Permits
401 M Street, SW
Washington, D.C. 20460
ooo Office of Water Regulations
and Standards
401 M Street, SW
Washington, D.C. 20460
ooo Office of Marine and
Estuarine Protection
401 M Street, SW
Washington, D.C. 20460
ooo Office of Marine and
Estuarine Protection
401 M Street, SW
Washington, D.C. 20460
ooo Office of Municipal
Pollution Control
401 M Street, SW
Washington, D.C. 20460
ooo Office of Groundwater
Pollution
401 M Street, SW
Washington, D.C. 20460
ooo Office of Drinking Water
401 M Street, SW
Washington, D.C. 20460
Officer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
ooo Director, Office of
Water Enforcement &
Permits
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Workplace
ooo Director, Office of Water
Regulations & Standards
ooo Director, Office of Marine
and Estuarine Protection
ooo Director, Office of Marine "
and Estuarine Protection
ooo Director, Office of
Municipal Pollution Control
ooo Director, Office of Ground-
water Pollution
ooo Director, Office of
Drinking Water
3-A-8
oo o
00
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o Reporting Unit
oo Establishment
OOP Workplace
oo Office of Asst Administrator
for Solid Waste and Emergency
Response
401 M St., SW
Washington, DC 20469
ooo Office of Waste Programs
Enforcement
401 M SU, SW
Washington* DC 20460
ooo Office of Solid Waste
401 M St., SW
Washington, DC 20460
ooo Office of Emergency and
Remedial Response
401 M St., SW
Washington, DC 20460
ooo Office of Underground
Storage Tanks
401 M St.* SW
Washington, DC 29460
oo Office of Asst Administrator
for Air and Radiation
401 M St., SW
Washington, DC 20460
ooo Office of Air Quality
Planning and Standards
401 M St., SW
Washington, DC 20460
Of f ice r-in-Charge of:
o Reporting Unit
oo £stablishment
ooo Workplace
oo Asst Administrator
OSWER
for
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager -
Reporting Unit
ooo Director, Office of
Waste Programs Enforcement
ooo Director, Office of Solid
Waste
ooo Director, Office of
Emergency and Remedial
Response
ooo Director, Office of Under-
ground Storage Tanks
oo Asst Administrator for
Air and Radiation
ooo Director, Office of
Air Quality Planning
and Standards
Occupational Health
& Safety Manager -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
and Safety Designee -
Workplace
Occupational Health
and Safety Designee
Establishment
Occupational Health
and Safety Designee
Workplace
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Wo rk pi a ce
U) K
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3-A-9
00
01
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o Reporting Unit
oo Establishment
OOP Workplace
ooo Office of Mobile Sources
401 M St., SW
Washington, DC 20460
ooo Office of Radiation Programs
401 M St. , SW
Washington, DC 20460
Officer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
ooo Director, Office of
Mobile Sources
ooo Director, Office of
Radiation Programs
ooo Office of Pesticide Programs
401 M St., SW
Washington, DC 20460
ooo Office of Toxic Substances
401 M St., , SW
Washington, DC 20460
ooo Office of Compliance Monitoring
401 M St., SW
Washington, DC 20460
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager -
Reporting Unit
oo Office of Asst Admi nistrator oo Assistant Administrator for
for Pesticides & Toxic Substances OPTS
401 M St. , SW
Washington, DC 20460
ooo Director, Office of
Pesticide Programs
ooo Director, Office of
Toxi c Substances
ooo Di rector, Office of
Compliance Monitoring
oo Office of Asst Administrator
for Research and Development
401 M St., SW
Washington, DC 20460
ooo Office of Acid Deposition,
Environmental Monitoring &
Quality Assurance
401 M St., SW
Washington, DC 20460
oo Assistant Administrator for
Research and Development
ooo Director, Office of Acid '
Deposition, Environmental
Monitoring & Quality Assurance
Facility
Occupational Health &
Safety Responsibility^
Occupational Health
& Safety Designee -
Workplace
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Work pi ace
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Workplace
CO I-1
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00
3-A-10
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o Reporting Unit
oo Establishment
OOP Workplace
ooo Office of Environmental
Engineering and Technology
401 M St., SW
Washington, DC 20460
ooo Office of Environmental
Processes & Effects Research
401 M St., SW
Washington, DC 20460
ooo Office of Health Research
401 M St., SW
Washington, DC 20460
o Chemical & Biological Investi-
gations Branch
Bldg. 402, ARC East
Beltsville, MD 20705
oo Northwest Biological Investi
gations Station
3320 Orchard Ave.
Corvallis, OR 97330
o Toxicant Analysis Center
NSTL, Bldg. 1105
Bay St. Louis, MS 39529
o Environmental Research Center
26 W. St. Clair St.
Cincinnati, OH 45268
oo Office of Administration
26 W. St. Clair St.
Cincinnati, OH 45268
Officer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
ooo Director, Office of
Env. Engineering
& Technology
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager -
Reporting Unit
ooo Director, Office of
Env. Processes &
Effects Research
ooo Director, Office of
Health Research
o Chief, Chemical & Biological Occupational Health
Investigations Branch & Safety Designee -
Reporting Unit
oo Chief, Northwest Biological
Investigations Station
o Chief, Toxicant Analysis Center
o Senior Official
Research and Development
oo Director, Office of
Administration
Occupational Health
& Safety Manager -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Workplace
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health oo*>
& Safety Designee - ^o°
Establishment ^
3-A-ll
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o Reporting Unit
oo Establi shment
OOP Workplace
oo Environmental Monitoring
& Support Lab-Cinn.
26 W. St. Clair St.
Cincinnati, OH 45268
oo Center for Environmental
Research Information
26 W. St. Clair St.
Cincinnati, OH 45268
oo Environmental Criteria &
Assessment Office
26 W. St. Clair St.
Cincinnati, OH 45268
oo Industrial Environmental
Research Lab-Cinn.
5555 Ridge Ave.
Cincinnati, OH 45268
oo Municipal Environmental
Research Lab-Cinn.
26 W. St. Clair St.
Cincinnati, OH 45268
oo Health Effects Research
Laboratory-Cinn.
26 W. St. Clair St.
Cincinnati, OH 45268
oo National Training & Operational
Technology Center
26 W. St. Clair St.
Cincinnati, OH 45268
Officer-in-Charge of:
o Reporting Unit
oo Establishment
OOP Workplace
oo Di rector, EMSL-Cinn.
oo Di rector, CERI-Cinn.
oo Di rector, ECAO-Cinn.
oo Di rector, lERL-Cinn.
oo Director, MERL-Cinn.
oo Director, HERL-Cinn.
oo Di rector, NTOTC
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Manager -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Establishment
§
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o Reporting Unit
oo Establishment
OOP Workplace
oo Technical Support Division
5555 Ridge Ave.
Cincinnati, OH 45268
o Environmental Research Lab
Research Triangle Park,
NC 27711
oo Office of Administration and
Resources Management
Research Triangle Park,
NC 27711
oo Environmental Monitoring and
Systems Lab-RTP
Research Triangle Par*,
WC 27711
oo Health Effects Research
Laboratory-RTF
Research Triangle Park,
NC 27711
oo Atmospheric Sciences Research
Laboratory-RTP
Research Triangle Park,
tIC 27711
oo Air and Energy Research Lab
Research Triangle Park,
NC 27711
oo Deputy Assistant Administrator
for Air Quality Planning &
Standards-RTP
Durham, NC 27711
Of f1cer~jt n-^,>c.rc--: :.:
o Reporting Unit
oo Establishment
OOP Workplace
oo Director, Technical
Support Division
o Senior Official
Research and Development
uii a aietv
Program Management
Responsibility
Occupational Health
& Safety Manager -
Reporting Unit
Occupational Health
& Safety Designee -
Reporting Unit
oo Director, Office of Admini-
stration and Resources
Management
oo Director, IMSL-RTP
Director, ASftt-RTP
oo Di rector, AESL-RTP
oo Deputy Assistant Administrator
for Air Quality Planning &
Standards-RTP
Durham, JC 27711 -
Occupational Health &
Safety Responslbility
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Designee -
Establishment
s
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o Reporting Unit
oo Establishment
OOP Workplace
o Environmental Monitoring Systems
Laboratory-Las Vegas
P. 0. Box 15027
Las Vegas, NV 89114
oo Vint Hill Farms Station
EPIC
P. 0. box 1587
Warrenton, VA 22186
ooo Office of Radiation Programs
P. 0. Box 18416
Las Vegas, NV 89114
ooo EPA Financial Management
Di vi sion-Las Vegas
Accounting Operations Office
P. 0. Box 18418
Las Vegas, NV 89114
ooo Office of Civil Rights
Area Office of Civil Rights
P. 0. Box 15037
Las Vegas, NV 89114
ooo Personnel Management Office-
Las Vegas
P. 0. Box 18417
Las Vegas, NV 89114
ooo Region 9 Laboratory
P. 0. Box 15027
Las Vegas, NV 89114
Of.ficer-in-Charge of:
o Reporting Unit
oo Establishment
ooo Workplace
o Director, EMSL-Las Vegas
oo Chief, Vint Hill Farms
Station-EPIC
ooo Di rector, ORP
ooo Financial Management
Officer
ooo Area Di rector
ooo Director of Personnel
Management
ooo Senior Chemi st
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Director -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Establi shment
Occupational Health
& Safety Designee -
Workplace
UJ
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o Reporting Unit
oo Establishment
OOP Workplace
o Environmental Research Lab
Sabine Island
Gulf Breeze, FL 32561
o Robert S. Kerr Environmental
Research Laboratory
P. 0. Box 1198
Ada, OK 74820
oo Ada Branch, ES Division
Region 6, P. 0. Box 1198
Ada, OK 74820
o Environmental Research Lab
College Station Rd.
Athens, GA 30613
oo Region 4, ES Division
College Station Rd.
Athens, GA 30613
o Environmental Research Lab
6201 Congdon Blvd.
Duluth, MN 30605
oo Large Lakes Research Station
P. 0. Box 500
Grossa He, MI 48138
co Ecologi ca1
Officer-in-Charge of:
o Reporting Unit
oo Establishment
OOP Workplace
o Director, Environmental
Research Laboratory
o Director, RSKERL
oo Chief, Ada Branch,
ES Division
o Director, ERL
o Di rector, ESD
o Di rector, ERL
oo Director, Large Lakes
Research Station
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Manager -
Reporting Unit
Occupational Health
& Safety Designee -
Reporting Unit
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establishment
Occupational Health
& Safety Manager -
Reporting Unit
Occupational Health
& Safety Designee -
Reporting Unit
oo Newton Fish Toxicology Station
3411 Church St.
Cincinnati, OH 45268
oo Di rector, Newton F
Station
;h Yoxicology
oo o
oo
-------
o Reporting Unit
oo Establishment
OOP Workplace
o Environmental Research Lab
South Ferry Rd.
Narragansett, RI 02882
oo CERL Marine Division
Marine Sciences Center
Newport, OR 97365
o Environmental Research Lab
200 S.W. 35th St.
Corvallis, OR 97330
oo Western Fish Toxicology Lab
1350 S.E. Goodnight Ave.
Corvallis, OR 97330
o National Enforcement Investi-
gation Center
Bldg. 53, Box 25227
Denver, CO 80225
o Motor Vehicle Emissions
Laboratory Facility
2565 Plymouth Rd.
Ann Arbor, MI 48105
o Eastern Environmental Radiation
Facility
1890 Federal Dr.
Montgomery, AL 26109
Of ficer-i n-Charge of:
o Reporting Unit
oo Establi shment
OOP Workplace
o Director, Environmental
Research Lab
Occupational
Health & Safety
Program Management
Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
oo Director, CERL Marine Division
o Director, Environmental Research Lab
oo Chief, CERL Freshwater Tox. Br.
o Director, NEIC
NEIC Occupational
Health & Safety
Designee - Reporting
Unit
o Chief, Administrative Section Occupational Health
& Safety Manager -
Reporting Unit
o Di rector, Eastern Environ.
Radiation Facility
Facility
Occupational Health &
Safety Responsibility
Occupational Health
& Safety Designee -
Reporting Unit
Occupational Health
& Safety Designee -
Establi shment
NEIC Occupational
Health & Safety
Designee - Reporting
Unit
Occupational Health
& Safety Manager -
Reporting Unit
R
H
Q
U)
CO
CO
CTi
3-A-16
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
3/18/86
APPENDIX 3-8 - ACCIDENT/ILLNESS INVESTIGATION PROCEDURES
I. Prepare log for all EPA Reportable accident, injuries, and illnesses.
2. Enter all accidents, injuries, and illnesses reports; number these
consecutively. This becomes the Control Number.
3. Prepare a log for OSHA recordable accidents/illnesses.
4. Transfer OSHA recordable accident/illness from the EPA Reportable
log to the OSHA recordable log using Control Number.
5. Prepare a separate file for each OSHA recordable accident/illness.
6. Report immediately to OHSS
a. A fatality.
b. A disabling injury
(1) Involving loss of use of principal part of the body,
(2) Total disability, or
(3) Five or more employees injured in a single accident
requiring hospitalization.
c. Property damage exceeding $10,000.00.
d. An injury requiring medical attention or a fatality to non-
EPA personnel or $10,000.00 damage to non-EPA property.
7. Priority of Accident Investigation
a. OSHA recordable.
b. EPA reportable.
c. all other incident, i.e. property, near misses, etc.
8. Accident Investigation - Within five working days after receipt of
EPA Form 1440-9, Supervisor's Report of Accident/Illness.
a. Interview the employee who had the accident;
(1) Put the employee at ease.
(2) Conduct the interview at the scene of the incident if
possible.
3-B-l
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
3/18/86
(3) Ask for the employee's version of the incident.
(4) Ask any necessary questions (what, when, where, but not
why).
(5) Repeat the employee's story - correct any misunderstandings.
(6) Close the interview on a positive note - prevention.
b. Interview witnesses or persons familiar with the circumstances
(use the same techniques as with employees).
c. Re-enact the incident only when absolutely necessary.
9. Accident Investigation Report (not accident report) should include:
a. Name of the employee.
b. Employee's occupation.
c. When and where did it happen.
d. What inflicted the injury or damage.
e. Who had the most control of what inflicted the injury or damage.
f. What happened.
g. What things caused the accident
(1) Immediate.
(2) Basic.
h. How can the incident be kept from happening again.
10. Review accident/illness reports with the Occupational Health and
Safety Comnri ttee.
3-B-2
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Occupational Health and Safety Manual
1440 TN 15
3/18/86
APPENDIX 3-C - SUPERVISOR'S REPORT OF ACCIDENT/ILLNESS
fUtt*VtSOft'S KEfORT OF ACCIDENT/ILLMCtt
• AIL TO:
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an
3-C-l
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APPENDIX 3-D - LOG AND SUMMARY ( JCUPATIONAL INJURIES AND ILLNESSES
Bureau of Latoc* Sutnttci
Log and Summery of Occupational
ln|UMA i
UJ. D»jiiiiiiiii« of l*or
Fix Ctbnil* YM> 19 .
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•Jl
-------
i*
*
1440 TN 15
I 10/24/84
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-------
APPENDIX E - EPA REPORTABLE OCf TIONAL INJURIES AND ILLNESSES
EPA requires that all Job-related
accidents be reported.
I „„....,„, POST ONLY THIS PORTION OF THE LAST PAGE NO lATiR THAN FEBRUARY I
-------
Occupational Health and Safety Manual
1440 TN 15
3/18/86
APPENDIX 3-F - ANNUAL SUMMARY OF FEDERAL OCCUPATIONAL
INJURIES AND ILLNTSSES
Annua Sj^^e'v a1 Federal
U.S. Department of Labor
'"r- ~T'r t-
the 01 .* o* **•» wcf "•• »::&/aa"*
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3-F-l
-------
1440 TO 15
3/18/86
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3-F-2
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
1440
3/18/86
APPENDIX 3-G - FLOW CHART DEPICTING
OSHA RECORDING CRITERIA
If a case
Note: A case must involve a
death, or a diagnosed illness,
or an injury to an employee.
Results from a
work accident
or from an ex-
posure in the
work envi ron-
ment and is
Does not result
from a work
accident or
from an exposure
i n the work
envi ronment
death
diagnosed
illness
An injury which
involves
Loss of
work days
Medical treatment
(other than
first aid)
None of
these
I
Then case must be recorded
Then case is not
to be recorded
3-G-l
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
3/18/86
CHAPTER 4 - INSPECTIONS AND ABATEMENT OF UNHEALTHFUL
OR UNSAFE WORKING CONDITIONS
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS
General 1
Responsibilities 2
General Requirements 3
Formal Inspections 4
Formal Evaluations 5
Informal Inspections 6
Walk-Through Inspections 7
Inspection Documentation 8
Reports on Unhealthful or Unsafe Working Conditions 9
Correction of Unhealthful or Unsafe Working Conditions 10
Imnri nent Danger 11
FIGURE FIGURE
TITLES NUMBERS
Health and Safety Inspection Checklist 4-1
Report on Unsafe or Unhealthful Conditions 4-2
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
3/18/86
CHAPTER 4 - INSPECTIONS AND ABATEMENT OF UNHEALTHF'JL
OR UNSAFE WORKING CONDITIONS
1. GENERAL. Executive Order 1?196 provides that the head of each agency
shall give prompt attention to reports by employees or others of unhealthful
or unsafe working conditions; shall assure periodic inspections of agency
workplaces by personnel with sufficient technical competence to recognize
unhealthful or unsafe working conditions; and shall assure prompt abatement
of unhealthful or unsafe working conditions.
2. RESPONSIBILITIES.
a. The Agency Designated Occupational Health and Safety Official
is responsible for assuring that formal health and safety inspections
are conducted at all EPA workplaces.
b. The Director, Occupational Health and Safety Staff, is responsible
for the performance of formal health and safety inspections at all EPA
workplaces or for approving plans developed by locations which elect to
perform their own formal inspections. The Director is also responsible for
the review of all formal health and safety inspection reports and acts as
the designee of the EPA Designated Occupational Health and Safety Official
for the review and coordination of abatement plans. The Director is
responsible for making assessments and determinations as may be required
to meet the Agency's need to conduct self-evaluations of its Occupational
Health and Safety programs.
c. Assistant Administrators, the General Counsel, the Inspector
Generali, Associate Administrators, RegiohaT Administrators, and Staff
Office'Directors are responsible for assuring that informal health and
safety inspections are conducted at workplaces under their jurisdiction
and, should they elect to rake their own formal inspection, for assuring
that plans for inspections are approved by the Director, Occupational
Health and Safety Staff. They are also responsible for taking direct
action to correct unhealthful or unsafe working conditions brought to
their attention by following the procedures outlined in paragraph 10 of
this Chapter.
d. Employees or employee representatives may submit reports of
unhealthful and unsafe working conditions to the Director, Occupational
Health and Safety Staff, or to the Designated Agency Occupational Health
and Safety Official by following the procedures specified in paragraph 9
of this Chapter.
e. Regional Safety Managers, Laboratory Safety Managers, Facilities
Safety Managers, and/or local Occupational Health and Safety Designees
are responsible to the Officer-in-Charge for the implementation and
performance of local health and safety programs.
4-1
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
3/18/86
3. GENERAL REQUIREMENTS.
a. jnspectors. Executive Order 12196 requires that each Agency
utilize as inspectors personnel with sufficient technical competence to
recognize unsafe or unhealthful working conditions in the workplace.
The qualifications of each inspector shall he reviewed and approved in
accordance with EPA Order 1440.5, Qualifications and Training Require-
ments for OHS Program Personnel.
(1) Health and safety inspections shall be made by a safety
and health specialist approved as above.
(2) Inspectors will be granted unlimited access to areas to be
inspected unless the area contains information classified in the interest
of national security. Inspectors will have unlimited access to those areas
but will be escorted at all times by personnel who have been cleared for
access to confidential information.
(3) Under normal circumstances, advance notice of formal health
and safety inspections will be given.
(4) During the course of the inspection, the inspector should
consult with employees concerning matters of occupational health and
safety to the extent that the inspector deems necessary for the conduct
of an effective and thorough inspection. Employees must be afforded the
opportunity to bring to the attention of the inspector any unhealthful
or unsafe working conditions which they have reason to believe exist in
the work pi ace.
(5) Inspectors shall comply with all health and safety rules
and practices at the establishment being inspected, and wear and use
appropriate protective clothing and equipment when necessary.
(6) The conduct of inspections should be such as to preclude
unreasonable disruption of the operations of the establishment.
(7) At the conclusion of an inspection, the inspector shall
confer with the Officer-in-Charge of the Reporting Unit or his or her
representative and an appropriate representative of the employees of the
establishment, and informally advise them of any unhealthful or unsafe
working conditions disclosed by the inspection. During the conference,
the Officer-in-Charge of the Reporting Unit and the employee representative
should be afforded an opportunity to bring to the attention of the inspector
pertinent information regarding conditions in the workplace which might
effect his or her recommendations. (The closing conference is designed
to provide a description of deficiencies and a discussion of possible
corrective actions.)
(8) Inspectors shall be in charge of the inspections and the
questioning of persons. A representative of the Officer-in-Charge of
the Reporting Unit and a representative of the employees shall be given
4-2
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
3/18/86
an opportunity to accompany the inspector during the physical inspection
of any workplace, both to aid the inspector and to provide more detailed
knowledge about the existing or potential unhealthful or unsafe working
condition. The members of an establishment's health and safety committee
may act as representatives for the purposes of this paragraph, if the
committee and the Of f icer-i n-Charge of the Reporting Unit so agree.
(9) Inspectors are authorized to deny the right of accompaniment
to any person whose participation interferes with a fair and orderly
inspection.
4. FORMAL INSPECTIONS. A formal health and safety inspection is an in-
depth evaluation of every aspect of program operations and facilities,
aimed at assessing the effectiveness of the local health and safety program,
identifying hazards and recommending corrective actions. A formal health
and safety inspection shall be conducted at each workplace, including
offices, at least once annually. For workplaces where there is an increased
risk of accident, injury, or illness due to the nature of the work being
performed, inspections should be conducted more frequently, as determined
by the Director, Occupational Health and Safety Staff.
5. FORMAL EVALUATIONS. The Occupational Health and Safety Staff has
developed a program of laboratory and facility evaluations to determine
the effectiveness of the occupational health and safety programs and
the quality of the facilities. These evaluations may be completed in
conjunction with the annual formal inspections and will be conducted by
the Occupational Health and Safety Staff or designee appointed by the
Director, Occupational Health and Safety Staff.
6. INFORMAL INSPECTIONS. An informal inspection shall be performed on
an unscheduled, frequent basis by the Facility Safety Designee, Regional
Health and Safety Designee, Laboratory Health Officer, Supervisory Manage-
ment, or members of a health and safety committee. EPA Form 1440-2,
Health and Safety Inspection Checklist, Figure 4-1, may be utilized to
note health and safety deficiencies identified during the inspection, or
a report in memo form may be used to record discrepancies. The affected
supervisor should receive copies of all inspection reports.
7. WALK-THROUGH INSPECTIONS. A walk-through inspection is similar to an
informal inspection except that the only documentation required is a list
of identified deficiencies for which corrective action is needed. This
recordkeeping is intended only for internal purposes to identify items
which appear repeatedly. For example, if blocked fire exits were noted
repeatedly during walk-through inspections, then a more formal approach
to achieving correction is indicated.
The walk-through concept encourages a more frequent review of the
facility and operational conditions without the need for documentation
and formal reporting.
4-3
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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8. INSPECTION DOCUMENTATION.
a. Formal Inspection. The results of a formal inspection shall be
documented in a comprehensive health and safety inspection report. This
report shall be transmitted by the inspector to the Of f i cer-i n-Charge of
the Reporting Unit, who will submit a copy to the Director, Occupational
Health and Safety Staff. Correction of unhealthful or jnsafe working
conditions identified by means of a formal inspection shall be accomplished
in accordance with paragraph 10 of this Chapter.
b. Informal Inspection. The results of an informal inspection
should be documented either by a memorandum or a completed EPA Form 1440-2
transmitted by the inspector or member of a health and safety committee
conducting the inspection to the Of f icer-i n-Charge. The indi vi dual(s)
making the inspection should also make a report to the Health and Safety
Com mi ttee.
c. Walk-through Inspection. A log or file of identified deficiencies
shall be kept in sufficient detail to show the hazard items and locations.
9. REPORTS OF UNHEALTHFUL OR UNSAFE WORKING CONDITIONS.
a. Reports by Employee or Employee Representative. Any employee or
representative of employees who believes that an unhealthful or unsafe
working condition exists in any workplace shall report the condition,
orally or in writing, to the supervisor within whose organizational
jurisdiction the alleged unhealthful or unsafe working condition exists.
EPA Form 1440-6, Figure 4-2, may be used to report an alleged unhealthful
or unsafe working condition and to provide written notification to the
OHS Designee. The supervisor should respond immediately to a report of
an alleged unhealthful or unsafe working condition, notifying the OHS
Designee regardless of whether the condition was reported orally or in
writing, informing the employee or representative of employees as to what
action he or she is taking or intends to take. If abatement of the
alleged unhealthful or unsafe condition is beyond the capability of the
supervisor, he or she should immediately contact his or her superior or
the Officer-in-Charge of the Reporting Unit for resolution of the problem.
Any such report should be reduced to writing, should set forth with
reasonable particularity the grounds for the report, and should be signed
by the employee or representative of employees. In case of imminent
danger situations, employees should make reports first by telephone and
then in writing as soon thereafter as practicable.
The Director, Occupational Health and Safety Staff, shall review the
report. He or she will assure response to such reports of hazardous
conditions and require inspections immediately or within 24 hours for
imminent dangers, three working days for potential serious conditions and
20 working days for other conditions.
4-4
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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The employee or representative of employees can request an inspection
of the workplace where the condition is alleged to exist by giving a
report of the alleged condition to the Director, Occupational Health and
Safety Staff.
b. Appeal to Agency Designated Occupational Health and Safety Official.
If an employee or a representative of the employee is not satisfied with
the review conducted, he or she may directly request the intervention of
the Agency Designated Occupational Health and Safety Official and/or the
Assistant Secretary of Labor, Occupational Safety and Health Administration
(OSHA).
c. Right of Anonymity. All employees have the right to anonymity
when making these reports. The Designated Occupational Health and Safety
Official or the Director, Occupational Health and Safety Staff, may find
it necessary to confer with the originator of the report if it is apparent
that further assistance is needed to determine more accurately the location
or type of conditions noted.
d. Employee Rights. No employee will be subjected to restraint, inter-
ference, coercion, discrimination or reprisal for filing a report of an
unsafe condition or for participation in Agency Occupational Safety and
Health Program activities. (See Chapter 2, Appendix 2-A.)
e. Scope. Inspections initiated pursuant to this paragraph are
not limited to matters referred to in the report of an alleged unhealthful
or unsafe working condition. Before or-during any inspection of a workplace,
any employee or representative of employees may notify the health and
safety inspector of any other unhealthful or unsafe working condition
believed to exist in the workplace.
f. Determinations.
(1) If the Director, Occupational Health and Safety Staff,
determines that there are no reasonable grounds to believe an unhealthful
or unsafe working condition exists, or if an inspection is nade on the
basis of a report alleging such condition but no such condition is determined
to exist, the employee or representative of the employees who filed the
report shall be so notified in writing. The employee or representative
of employees shall be given an opportunity for a final review of such
determination by the Director, Occupational Health and Safety Staff, and
may appeal to the Agency Designated Occupational Health and Safety Official,
pursuant to paragraph 9.c. above.
(2) The Director, Occupational Health and Safety Staff, may
also utilize an appropriate health and safety committee created pursuant
to Chapter 5 of this Manual to determine whether an unhealthful or unsafe
working condition exists, but should ensure that the identify of the person
making the report will be protected.
4-5
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OCCUPATIONAL HEALTH AND SAFETY MANUAL ]440
3/18/86
g. Unresolved Reports. Any employee or representative of employees
who files a report alleging an unhealthful or unsafe working condition,
and who is dissatisfied with the final disposition by the Agency, may
contact in writing the Office of Federal Agency Safety Programs, U.S.
Department of Labor (with a copy to the Designated Occupational Health
and Safety Official*), describing in detail the processing of his or her
report and setting forth his or her objections thereto. The Agency shall
notify each such person of his or her right to contact OSHA upon final
disposition of his or her report. The Office of Federal Agency Safety
Programs may request the Agency to submit the report of its investigation,
and may arrange for an inspection of the alleged unhealthful or unsafe
working condition if necessary. Files on such reports will be maintained
intact for five years following the end of the calendar year to which
they relate, by the Director, Occupational Health and Safety Staff, so
that the Secretary of Labor or an authorized representative will have
reasonable access to them.
10. CORRECTION OF UNHEALTHFUL OR UNSAFE WORKING CONDITIONS.
a. The Officers-in-Charge of the Reporting Units are responsible
for the correction of unhealthful and unsafe working conditions.
b. The Officer-in-Charge of the Reporting Unit shall immediately
submit an abatement plan to the Director, Occupational Health and
Safety Staff, if in his or her judgment the abatement of an unhealthful
or unsafe working condition will not be possible within 30 working days.
Such a plan must contain an explanation of the circumstances of the
delay in abatement, a proposed timetable for the abatement, and a summary
of steps being taken in the interim to protect employees from the unsafe
or unhealthful working condition. Any changes in an abatement plan will
require the submission of a new plan in accordance with the provisions
of this paragraph.
c. The Officer-in-Charge of the Reporting Unit shall keep the
Health and Safety Committee Chairperson of the establishment or report-
ing unit informed as to action being taken to correct unhealthful or unsafe
working conditions. The committee shall include this information in the
minutes of regular meetings.
d. The procedures to determine that corrective action has been
taken should include reinspection. If upon reinspection, it appears
that the correction was not made, or was not carried out in accordance
with an abatement plan submitted pursuant to subparagraph lOb, the
Director, Occupational Health and Safety Staff, will inform the Agency
Designated Occupational Health and Safety Official of the failure to
accomplish the abatement plan.
* This copy to the Designated Occupational Health and Safety
Official is not mandatory. The employee may file a report with
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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OSHA, following approved OSHA procedures, and be assured of
annonymity. Information on these procedures is posted in all
EPA locations.
11. IMMINENT DANGER. Whenever and as soon as it is concluded, on the
basis of an inspection, that a danger exists which could reasonably be
expected to cause death or serious physical harm, the Inspector shall
immediately inform the affected employees and Officer-in-Charge of the
Reporting Unit of the danger. The Officer-in-Charge, or a represent-
ative, shall undertake immediate abatement and the withdrawal of employ-
ees who are not necessary for abatement of the dangerous condition. In
the event that the Officer-in-Charge needs assistance to undertake full
abatement, the Director, Occupational Health and Safety Staff, shall
assist in the abatement effort.
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J/I8/86
1 HEALTH AND SAFETY INSPECTION CHECKLIST
INSPECTION CONDUCTED BY TITLE
DATE
NAME/NUMBER OF BUILDING INSPECTED ft/.e separate torn, for each building) REPORTING UNIT
PART 1. PHYSICAL CONDITIONS (Check each applicable item)
ITEM
1. HOUSEKEEPING AND S AN IT ATION
2. NON-HAZARDOUS MATERIALS STORAGE
3. HAZ ARDOUS MATER IALS STORAGE
4. MATERIALS HANDLING EQUIPMENT
8. AISLES AND WALKWAYS
6. LADDERS AND STAIRS
7. FLOORS. PLATFORMS AND RAILINGS
S. EGRESS
B. LIGHTING
10. VENTILATION
11. FLAMMABLE OR NOXIOUS DUST OR VAPORS
12. HAZARDOUS BIOLOGICAL AGENTS
13. FIRE DETECTION DEVICES
14. FIRE ALARM SYSTEM
15. FIRE SUPP RESSIO'N (Including exlingul there)
16. MECHANICAL EQUIPMENT
17. MACHINE GUARDS AND SAFETY DEVICES
PART II. PROCEDURES AND INSTRUCTIONS
33. MATERIALS HANDLING
34. MOTOR VEHl'Ci. E OPERA Tl ON
33. BUILDING MAIN TENANCE
36. EQUIPMENT MAINTENANCE
37. USE OF PROTECTIVE CLOTHING AND
EQUIPMENT
38. H AZ ARD MON ITORING EQUIPMENT
(carbon montxide, Radiation, etc.)
39. FACILITY SELF-PROTECTION PLAN
40. LABORATORY OPERATIONS
41. BOATING OPERATIONS
42. DIVING OPERATIONS
43. A VI ATION OPERATIONS
44. CRAFTS ANDSHOPSOPERATIONS
SAT
UNSAT
ITEM
18. ELECTRICAL AND ELECTRONIC EQUIPMENT
19. w A T ER (ffnti-syphon and cross-conn ectione)
20. ELECTRICAL (fuses, grounding, etc.)
21. COMPRESSED GAS CYLINDERS
22. STRUCTURAL CONDITION OF BUILDING
23. PARKING AREA
24. MOTOR VEHICLES
26. PORTABLE TOOLS
26. PROTECTIVE CLOTHING AND EQUIPMENT
27. HAZARDOUS WARNINGS SIGNS
28. EMISSION OF POLLU T ANTS fair, fluid, solids)
2S. OCCUPATIONAL NOISE EXPOSURE
30. MEDICAL SERVICES. INCLUDING FIRST AID
31. PROVISIONS FOR HANDICAPPED
32. OTHER
SAT
UNSAT
(Check cech applicable itern)
45. FIELD OPERATIONS, OTHER
46. SAFETY COMMITTEE ACTIVITY
47. FEDERAL SAFETY COUNCIL PARTICIPATION
48. EMPLOYEE REPRESENTATION IN
SAFETY AND HEALTH PROGRAM
49. JOB ORIENTATION
50. JOB TRAINING. INCLUDING SAFETY
AND HEALTH
51. SAFETY PROMOTIONAL AND
MOTIVATIONAL ACTIVITIES
52. PERIODIC PHYSICAL EXAMINATIONS
53. OTHER
e EPA Form 1440-6 to document in detail each unhealthlul or unaale condition)
EPA Form 1440 -2 (R«». 5- 77) PREVIOUS EDITION MA ••• BE USED UNTIL SUPPLY is EXHAUSTED
rioure 4-1 •
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
1440
3/18/86
€EPA
UNfTED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. DC 20460
EMPLOYEE REPORT OF UNSAFE OR UNHEALTHFUL CONDITION
I
CO
FROM:
Telephone
Brief Description of Unsafe or Unheetthfut Condition:
Exact Location:
Safety and Hearth Standard Violated (H known)
Recommendation To Correct the Condition
Signature
Date
Response to Employee
inature
I
Date
EPA Form 144O-6 (Rev. 6-84) Previous edition is obsolete.
Figure 4-2
Dittribuuon:
Ware
Qr»»rt
Gokbnrod
u.s.
Suptnitor
„ . .Reply to fmptoyt*
£ny>/cj'*e Sutptntt Copy
S*f»ty Dttigntt
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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CHAPTER 5 - OCCUPATIONAL HEALTH AND SAFETY COMMITTEES
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS
General 1
Occupational Health and Safety Committee Organization and
Functions 2
Types of Comnri ttees 3
Committee Membership 4
Responsibilities and Duties 5
Occupational Health and Safety Committee Meeting 6
Minutes of the Occupational Health and Safety Committee 7
Occupational Health and Safety Committee Policy and
Procedures 8
APPENDIX 5-A - Suggested Policy and Procedures for the
Administrative Control of an Executive
Occupational Health and Safety Committee
APPENDIX 5-B - Suggested Policy and Procedures for the
Administrative Control of an Operational
Occupational Health and Safety Committee
APPENDIX 5-C - Suggested Policy and Procedures for the
Administrative Control of a Specicalized
Occupational Health and Safety Committee
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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CHAPTER 5 - OCCUPATIONAL HEALTH AND SAFETY COMMITTEES
1. GENERAL. Under Executive Order 12196, Section 1-301, the EPA may,
if it chooses, establish OSHA certified occupational health and safety
committees which meet the minimum requirements of the Secretary of
Labor as described in 29 CFR 1960.36. The EPA declined to establish
OSHA certified committees choosing rather to retain its existing
committee structure. This declination was based upon EPA's feeling that
its existing committee structure adequately provides for effective
representation of all Agency employees and in no way diminishes the
Agency's goal of providing its employees with places and conditions of
employment free from recognized hazards which are likely to cause death
or serious harm. Therefore, reorganization of existing Agency occupa-
tional health and safety committees is not required.
EPA requires that an Occupational Health and Safety Committee be established
at each Agency Reporting Unit and Establishment that effectively represents
all employees. Each EPA Reporting Unit and Establishment may individually
determine (through negotiation with the exclusive bargaining representative,
if appropriate) the type and composition of its ocupational health and
safety committee(s) consitent with its size and mission and the requirements
of this Chapter.
2. OCCUPATIONAL HEALTH AND SAFETY COMMITTEE ORGANIZATION AND FUNCTIONS.
The occupational health and safety committee is the medium for achiev-
ing the participation of employees in the Agency's occupational health
and safety programs. A well-organized, balanced health and safety
committee will have the diversified knowledge of all job operations and
activities at its location. Committees should be advisory not policy-
making groups. Committees should ascertain the facts and make recommen-
dations so management can make intelligent policy decisions in the area
of health and safety matters affecting employees. Agency health and
safety committees shall be:
a. Effectively supported by management;
b. Given specific tasks to accomplish not general topics for
consideration;
c. Include personnel from the program areas which committee decisions
will affect;
d. Provide effective representation of all employees; and
e. Include a cross-section of experts who have intimate knowledge
of pertinent work conditions and practices.
The occupational health and safety committees shall be kept as small as
possible consistent with these requirements.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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3. TYPES OF COMMITTEES. The requirements for an occupational health
and safety committee at each Agency Reporting Unit and Establishment
shall be fulfilled by establishing an operational committee alone or in
combination with one or both of the types of committees listed below,
depending on the need.
a. Executive Committee. An executive occupational health and safety
committee includes key managers of the Reporting Unit or Establishment
who have maximum knowledge of policy and procedures. The Officer-in-Charge
of the Reporting Unit or Establishment or a principal deputy should be a
member.
b. Operational Committee. An operational occupational health and
safety committee consists of personnel from the programs or offices
which the committee's recommendations will affect. Members of this
committee should have access to the Executive Committee, if appropriate.
This can be accomplished by appointing the chairperson of the operational
committee as a member of the executive committee.
c. Specialized Committee. This committee consists of personnel
from a program or programs that are involved in particularly hazardous
operations that require emphasis on health and safety practices peculiar
to that operation.
4. COMMITTEE MEMBERSHIP.
a. Membership of occupational health and safety committees shall
be determined individually by the Officer-in-Charge of each Reporting
Unit and Establishment, through negotiation with the exclusive bar-
gaining representative, if appropriate.
EPA requires that operational occupational health and safety committees
shall be managed in such a way as to assure effective representation of
all employees. However, an equal membership of management and non-manage-
ment employees is not mandatory. There are several ways to select and
appoint occupational health and safety committee members.
(1) The Officer-in-Charge may select and appoint in writing
the committee members from a list of nominees developed by the Occcupa-
tional Health and Safety Designee at the Reporting Unit or Establishment.
(The Occupational Health and Safety Designee should develop the list of
names from suggestions received from program supervisors and, if appropriate,
the exclusive bargaining representative.)
(2) An election may be held and members elected from designated
program areas or functions and officially appointed in writing by the
Officer-in-Charge.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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(3) A combination of 1 and 2 above is possible with official
designation being made in writing by the Officer-in-Charge.
(4) Members may be appointed by the Officer-in-Charge from
among employees who volunteer to serve on the occupational health and
safety committee.
b. Occupational health and safety committee members shall serve
overlapping terms. These terms may be of one, one and one-half, or
two years duration depending on the requirements of the Reporting
Unit or Establishment.
c. The committee chairperson should be nominated from among the
committee's membership and elected by the committee members.
d. The Occupational Health and Safety Designee should attend committee
meetings as technical advisor but should not be an official member of
the occupational health and safety committee and should not chair the
committee. The role of the Occupational Health and Safety Designee is
to assist the committee in developing and implementing ideas and to
effectively utilize the committee members' experience, knowledge, and
talents in the health and safety program at the Reporting Unit or
Establishment.
(NOTE: OHSS strongly recommends that the occupational health and safety
committee chairperson be nominated and elected by the committee members.
If management appoints a management representative as chairperson, it
negates the intent of providing employees an opportunity to fully
participate in the Agency's Occupational Health and Safety Programs.
The Occupational Health and Safety Designee is also a representative of
management. If the Designee serves as committee chairperson, any
recommendations made by the committee and signed by the Designee as
chairperson carries no more weight or significance than if the Designee
had made the recommendation. The Designee serving as chairperson loses
at least 50 percent of the effectiveness of the committee members'
expertise in managing the occupational halth and safety programs at the
Reporting Unit or Establishment.)
5. RESPONSIBILITIES AND DUTIES.
a. Agency Responsibilities. The EPA shall make available to occupa-
tional health and safety committees all information relevant and necessary
to effectively perform their duties. The information shall include but
is not be 1imi ted to:
(1) The Agency's occupational health and safety policies and
programs;
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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(2) The human and financial resources available to implement
the program;
(3) Material Safety Data Sheets; and
(4) Data on accidents, injuries, illnesses, epidemiologica'l,
and employee exposure monitoring; and
(5) Reports on inspection, reprisal investigations, abatement
plans, NIOSH hazard evaluations, and internal and external occupational
health and safety program evaluations.
The Agency shall provide all occupational health and safety committee
members appropriate training as required in Chapter 7 of this Manual.
b. Occupational Health and Safety Committee Duties. The occupational
health and safety committees are an integral part of the Agency's effort
to insure the effective implementation of its occupational health and
safety programs at all its Reporting Units and Establishments. Duties
of the committees should include some or all of the following:
(1) Assist the Occupational Health and Safety Designee at the
Reporting Unit or Establishment under its jurisdiction and make recommen-
dations to the Officer-in-Charge on the operation of the program;
(2) Monitor findings and reports of inspections to confirm
that appropriate corrective measures are implemented;
(3) Participate in inspections when requested by the Officer-
in-Charge or when the committee deems it necessary to effectively monitor
the Agency's inspection procedures;
(4) Review internal and external evaluation reports of the
occupational health and safety program at the Reporting Unit or Establish-
ment and make recommendations for changes or improvement in the program;
(5) Review and recommend changes, as appropriate, to procedures
for handling health and safety suggestions and recommendations of .the
committee and from employees;
(6) Review and comment on standards proposed by the Agency,
Reporting Unit, or Establishment;
(7) Monitor and recommend changes, as required, in the level of
resources allocated and spent on the health and safety program at the
Reporting Unit or Establishment;
(8) Review responses to reports of hazardous conditions, safety
and health program deficiencies, and allegations of reprisal;
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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(9) Recommend changes or additions to improve protective
clothing and equipment used by employees at the Reporting Unit or
Establishment; and
(10) Promote health and safety training for members of the
committee and other employees.
6. OCCUPATIONAL HEALTH AND SAFETY COMMITTEE MEETING. Each occupational
health and safety committee shall establish a regular schedule of meet-
ings. Special meetings shall be called when critical health and safety
problems arise.
a. Frequency of Meeting^.
(1) Executive Committee - An executive occupational health and
safety committee shall meet quarterly but not less than semi-annually,
and at other times as necessary to assist the Of ficer-i n-Charge with the
resolution of a health and safety management or policy recommendation
i ssue.
(2) Operational Committee - An operational occupational health
and safety committee shall meet monthly but not less than quarterly.
Special meetings may be called by any member, the Of ficer-i n-Charge,
or the Occupatinal Health and Safety Designee when critical health
and safety problems arise.
(3) Specialized Committee - A specialized occupational health
and safety committee should meet at least quarterly, and at other times
as necessary to assist the program managers in carrying out their health
and safety responsibilities.
b. Preparation and Procedures for Meetings. To assure the maximum
utilization of committee members' time and effort, sustain their interest
and commitment, minimize the time necessary to monitor the business of
the committee, clarify the content and objectives of each business item,
and follow through on projects to assure completion without undue delay,
the following procedures are recommended:
(1) The Occupational Health and Safety Designee shall:
(a) Prepare an agenda for the approval of the committee
chairperson no later than five working days prior to the scheduled meeting;
(b) Prepare a notice of the meeting and deliver to each
member along with a copy of the minutes of the last meeting and the
agenda for the next meeting;
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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(c) Develop a brief description or explanation of each
proposed business item prior to the meeting, including the objective
of the item;
(d) Assign a title and a control number for all items
accepted as health and safety committee business; and
(e) Establish a log and enter each accepted health and
safety business item, showing the target date for completion and in-
terim dates for accomplishment of intermediate steps, if appropriate.
(2) The Chairperson of the Committee shall:
(a) Establish a good meeting program;
1_ Call the meeting to order;
2_ Call for approval or revision of the minutes of
the previous meeting;
_3 Request the members to sign the attendance sheet;
4_ Call for reports on assignments;
5_ Request suggestions and discussion of work that'
needs to be done (members should be encouraged to come forward with ideas
and suggestions);
6_ Formally accept or reject all items as health
and safety committee business;
1_ Assign responsibility for each item to a specific
member or members of the committee; and
_8 Limit the meeting of the committee to one hour.
7. MINUTES OF THE OCCUPATIONAL HEALTH AND SAFETY COMMITTEE. The Occupa-
tional Health and Safety Designee should assure that pertinent points of
the meeting are documented. The minutes of the meeting shall be prepared
in memorandum form, approved, and signed by the Committee Chai rperson.
The minutes should contain:
a. A clear identification of the organizational unit;
b. The name and title of each member present; and
c. The substance of discussions of health and safety items, including
any specific remedial actions recommended.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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A copy of the minutes of each meeting of the occupational health and
safety committees shall be forwarded to the Di rector, Occupational Health
and Safety Staff, (PM-273), Washington, D.C. 20460, within 20 working
days following the meeting. A copy of the minutes shall be furnished to
each committee member and the Officer-in-Charge. The minutes shall be
made available to any employee upon request.
8. OCCUPATIONAL HEALTH AND SAFETY COMMITTEE POLICY AND PROCEDURES. The
Occupational Health and Safety Designee, with the assistance of the com-
mittee, should develop a written policy and procedures for the adminis-
trative control of committee activities. See Appendix 5-A,5-B, and 5-C
as examples. These procedures should include:
a. The scope and purpose of the committee's activities;
b. The extent of its authority;
c. Frequency of meetings;
d. The date, time and place of meetings;
e. The order of business;
f. Records to be kept; and
g. Attendance requirements.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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APPENDIX 5-A - SUGGESTED POLICY AND PROCEDURES FOR
THE ADMINISTRATIVE CONTROL OF AN EXECUTIVE
"OCCUPATIONAL HEALTH AND SAFETY COMMITTEE
Name and Objective
The name of this Committee is (Reporting Unit or Establishment), Executive
Occupational Health and Safety Committee.
The objectives of the Committee are to recommend approval of proposed
health and safety program policy, procedures, guidelines, and training
programs to the Of ficer-i n-Charge.
The principle means for accomplishing these objectives shall be to hold
meetings to review proposed program policy, procedures, guidelines, and
training programs and recommend to the Of ficer-i n-Charge the adoption,
implementation, or revision of the proposals.
Membership
The Executive Occupational Health and Safety Committee shall consist of
members from the following areas, appointed by the Officer-in-Charge for
a period of (one, one and one-half or two years.)
o The deputy of the Officer-in-Charge;
o The program director delegated the health and safety program
responsibility;
o Program directors or their deputies (especially from areas with
serious health and safety factors);
o The chairperson of the Operational Occupational Health and Safety
Committee;
o Employee representative(s); and
o The Occupational Health and Safety Designee (non-voting).
Members of the committee should select and elect from the membership, a
Chairperson and (other officers necessary for conducting committee business)
at their first meeting each Calendar Year. (Three, fours, five, six~
etc, (a majority of the members of the committee, i.e., a committee of 5 -
3 is a majority; a committee of 6 - 4; a committee of 7 - 4; a committee
of 8 - 5; a committee of 9 - 5; etc.)) of the members present shall
constitute a quorum for the transaction of business.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
Record of Meetings
After each meeting of the committee, the minutes shall be prepared in
memorandum form, containing:
o A clear identification of the organizational unit;
o The name and title of each member present; and
o The substance of discussions of health and safety recommendations
including any specific actions recommended.
A copy of the minutes of each meeting of the Executive Occupational Health
and Safety Committee shall be forwarded to the Director, Occupational
Health and Safety Staff, (PM-273), Washington, D.C. 20460, by the
Occupational Health and Safety Designee within 20 working days following
the meeting. A copy of the minutes of each meeting shall be forwarded to
the Officer-in-Charge and each Committee member. Copies of the minutes
will be made available to employees upon request.
Vacancy
Should a vacancy occur on the committee through resignation, transfer of
responsibilities to a different program, office or location, or other
cause, the Officer-in-Charge shall appoint another employee to fill the
vacancy. A vacancy of an officer of the committee should be filled by a
majority vote of the quorum of committee members present.
Meetings
The (Reporting Unit, Establishment name), Executive Occupational Health
and Safety Committee shall meet at least quarterly, (specific day and
time), and at other times necessary to assist the Officer-in-Charge with
resolution of management or policy recommendation issues.
Duties and Responsibilities
Chairperson - The chairperson shall:
o Direct the activities of the committee in accordance with
established procedures, providing leadership and coordination of all
committee activities.
o Be empowered to appoint special sub-committees as they become
necessary on the recommendation of committee members.
o Furnish each member of the committee with a list of their
responsibilities and duties.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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o Keep the Officer-in-Charge advised of progress or lack of progress
in the management of the occupational health and safety program.
Other officers elected by the committee shall:
Assist the chairperson of the committee in directing the activities of
the committee, and in the absence of the chairperson fulfill his/her
responsibilities and duites.
General Duties
The (Reporting Unit, Establishment name), Executive Occupational Health
and Safety Committee shall:
o Provide the Officer-in-Charge to whom they report, with:
. A continuing appraisal of the health and safety program efforts;
. Recommendations on the developments and coordination of the
occupational health and safety programs; and
. Recommendations of health and safety policy.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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APPENDIX 5-B - SUGGESTED POLICY AND PROCEDURES FOR THE
ADMINISTRATIVE CONTROL OF AN OPERATIONAL OCCUPATIONAL
HEALTH AND SAFETY COMMITTEE
Name and Objective
The name of this committee is (name of Report1nff Unit or Establishment),
Operational Occupational Health arid Safety Commit'tee. "
The objectives of the committee are to advise and assist (name of Reporting
Unit or Establishment) management officials with respect to their responsi-
bilities under the Agency's Occupational Health and Safety programs.
The principle means for accomplishing these objectives shall be to hold
meetings to:
o Discuss accident/illness incidents;
o Review reports of unsafe or unhealthful working conditions;
o Seek solutions to these problems; and
o Upon request, participate in inspections.
Membership
The Operational Occupational Health and Safety Committee shall be managed
to assure the effective representation of all employees. The Committee
shall consist of a representative from each of the following areas,
elected or appointed, for a period of (one, oneand one-half or two years).
o Officer-in-Charge and Staff Offices
o Management or Administrative Division
o Employee representative(s)
o Program Offices (one representative from each area)
o Representative(s) from any other interested or affected employees
housed in the same building.
Members of the Operational Occupational Health and Safety Committee should
nominate and elect from the committee membership a chairperson and (other
officers necessary for effective committee business) at their first
meeting each calendar year. (Th'reer four, five, etc.) (a majority of
committee members would be a committee of 5 - 3; 6 - 4; 7 - 4; 8 - 5;
9-5; etc.) of the members present shall constitute a quorum for the
transaction of business.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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Record of Meetings
After each meeting of the committee, the minutes should be prepared in
memorandum for, containing:
o A clear identification of the organizational unit;
o The name and title of each member present; and
o The substance of discussions of health and safety problems,
including any specific remedial actions recommended.
A copy of the minutes of each meeting of the Operational Occupational
Health and Safety Committee shall be forwarded to the Director, Occupational
Health and Safety Staff, (PM-273), Washington, DC 20460, by the Occupational
Health and Safety Designee within 20 working days following the meeting.
A copy of the minutes of each meeting shall be furnished to the Officer-
in-Charge and to each committee member. The minutes shall be made
available to any employee upon request.
Vacancy
Should a vacancy occur on the committee through resignation, transfer of
responsibilities to a different program or office, or other cause, the
vacancy shall be filled by holding an election or appointing a new repre-
sentative from the same program area represented by the vacancy. A
vacancy of an officer of the committee shall be filled by a majority vote
of the quorum of committee members present.
The committee may, by a two-thirds vote of a quorum of members present,
declare any elective or appointive office vacant subject to the approval
of the Officer-in-Charge, on the failure of its incumbent, from inability
or otherwise, to attend committee meetings, or to perform the duties of
the office.
Meetings
The (name of Reporting Unit or Establishment), Operational Occupational
Health and Safety Committee, shall meet at least monthly, (specific day
and time), and at other times necessary to assist (name of Reporting Unit
or Establishment) management officials with the resolution of reports of
unsafe or unhealthful working conditions or imminent danger situations.
Duties and Responsibilities
Chairperson - The chairperson shall:
o Direct the activities of the committee in accordance with established
procedures, providing leadership and coordination of all activities;
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OCCUPATIONAL HEALTH AND SAFETY MANUAL 1440
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o Be empowered to appoint sub-committees as they become necessary
on recommendations of committee members;
o Furnish each committee member with a list of their responsibilities
and duties.
o Acknowledge reports of unsafe or unhealthful working conditions
from employees and others, and keep them informed of progress or lack of
progress in the resolution of the matter.
Other officers elected by the committee shall assist the chairperson of
the committee in directing the activities of the committee, and in the
absence of the chairperson fulfill his/her responsibilities and duties.
General Duties
The (name of Reporting Unit or Establishment), Operational Occupational
Health and Safety Committee, shall:
o Participate in inspections when requested by the Of ficer-i n-Charge
or when the committee deems it necessary to effectively monitor the
Agency's inspection procedures;
o Monitor findings and reports of inspections to confirm that
appropriate corrective measures are implemented;
o Review and comment on standards proposed, by the Agency, Reporting
Unit or Establishment;
o Review internal and external evaluation reports of the occupational
health and safety program and make recommendations for changes or
improvements in the program;
o Monitor and recommend changes, as required, in the level of
resources allocated and spent on the health and safety program;
o Review responses to reports of hazardous conditions, safety and
health program deficiencies, and allegations of reprisal;
o Review and recommend changes or additions to improve protective
clothing and equipment used by employees; and
o Promote health and safety training for committee members and
other employees.
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APPENDIX 5-C - SUGGESTED POLICY AND PROCEDURES FOR
THE ADMINISTRATIVE CONTROL OF A SPECIALIZED
OCCUPATIONAL HEALTH AND SAFETY COMMITTEE
Name and Objective
The title of this committee is (name of Reporting Unit or Establishment),
(Toxic Substances, Radiation, Pesticides, etc.), Occupational Health and
Safety Committee.
The objectives of the committee are to promote safety and health awareness
connected with the special hazards, disseminate information on methods of
control, and stimulate discussions of common problems and seek solutions.
Membership
The (name of committee) shall be managed to assure effective representation
of affected employees. The committee shall consist of representatives
from each program area with like special hazards, a supervisor or
supervisors and employee representative, if appropriate. Members of the
committee should elect from their membership a Chairperson and (other
officials necessary) at their first meeting each Calendar Year. A majority
of the members present shall constitute a quorum for transaction of
business.
Record of Meetings
After each meeting of the committee, the minutes shall be prepared in
memorandum form, containing:
o A clear identification of the organizational unit;
o The name and title of each member present; and
o The substance of discussions of health and safety items.
•A copy of the minutes of the meeting shall be forwarded to the Director,
Occupational Health and Safety Staff (PM-273), by the Occupational Health
and Safety Designee within 20 working days following the meeting. A copy
of the minutes of each meeting shall be forwarded to the Officer-in-Charge,
each member of the committee and the chairperson of other occupational
health and safety committees. Copies of the minutes shall be made
available to employees upon request.
Vacancy
Should a vacancy occur on the committee for any cause, the vacancy shall
be filled by either appointment or election. A vacancy of an officer of
the committee shall be filled by a majority vote of the quorum of committee
members present.
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Meetings
The (name of committee), Specialized Occupational Health and Safety
Committee shall meet (monthly, semi-monthly, quarterly, etc.), (specific
day and time), and at other times necessary to assist program managers in
carrying out their health and safety responsibilities.
Duties
The committee shall:
o Review and advise management on the development for standard
operating procedures.
o Review and recommend specialized personal protective equipment
and clothing for the unique hazards of the work.
o Recommend and promote training for committee members and other
employees for the unique hazards of the work.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
CHAPTER 6 - OCCUPATIONAL HEALTH AND SAFETY STANDARDS
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS__
General . 1
Background 2
Definitions 3
Alternate Standards 4
Other Federal Agency Standards 5
Standards Application 6
APPENDIX A - CURRENT OCCUPATIONAL HEALTH AND SAFETY STANDARDS
APPENDIX B - GENERAL REQUIREMENTS OF AN OCCUPATIONAL HEALTH
AND SAFETY STANDARD
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CHAPTER 6 - OCCUPATIONAL HEALTH AND SAF-m SIP NLA? DS
1. GENERAL. Executive Order 12196 and 29 CFR 1960.16 rennrf-s the
Agency to comply with all occupational health and safety ^tuixci'cis issued
under Section 6 of the Occupational Safety and Health Act cr, '»9;0, or
with alternate standards issued by the Agency after consultation with
employees or their representatives and approved by the Secretary of
Labor. The Agency may prescribe and enforce more stringent, standards
than the Section 6 standards if required to protect the health and safety
of its employees.
2. BACKGROUND. The overall authority for the promulgation of occupational
health and safety standards issued under the Occupational Health and
Safety Act rests with the Secretary of Labor as defined in Section 6.
Section 19 of the Act requires that the EPA adopt and comply with health
and safety standards consistent with those promulgated by the Secretary
of Labor. The EPA Administrator has adopted the occupational health and
safety standards contained in 29 CFR 1910 as initial Agency standards.
(Appendix 6-A is a listing of all current OSHAS EPA and other Federal
health and safety standards and guidelines.)
3. DEFINITIONS.
a. Standard i s an occupational safety ana heal :h s:\fv.i-A.-d which
requires conditions, or the adoption or use of one or more practices,
means, methods, operations, or processes, reasonably necessary or appro-
priate to provide safe and/or healthful employment and place of" employment.
b. Affected employees means employees who would be affoctod by the
grant or denial of a variance, limitation, variation, tolerance, or
exemption, or anyone of their authorized representatives, suc-n as their
collective bargaining agent.
c. Alternate standard is a standard adoptuu or lec.j^.o; '•.,• applica-
tion
to working conditions of Agency employees because no OSHA standard exists
that will provide adequate protection fer their health and sa~ety.
d. Emergency standard is a standard proton gated WUM i . 1 •; . iutermined
a condition exists that exposes workers to grave danger "rom toxic agents,
or physical harm, or from new hazards requiring immediate regulatory
control.
4. ALTERNATE STANDARDS. The Admi nistrator may develop in-i d,,,,;y alternate
standards if OSHA standards or if other standards do not provide a suffi-
cient level of protection necessary to assure the health and safety of
Agency employees. The EPA Occupational Health and Safety Staff shall:
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a. Provide an opportunity for written comment by all affected or
interested Agency employees.
b. Provide for an opportunity for written comment by affected employees
of one or more Federal Agencies located in the same facility.
c. Keep appropriate exclusive bargaining representatives informed
of the proposed development of alternate standards.
d. Notify the Secretary of Labor regarding the development of an
alternate standard and request approval of the Secretary. The request
for approval shall contain:
(1) A statement of why the Agency wants to adopt an alternate
standard;
(2) A description of the alternate standard;
(3) An explanation of how the alternate standard provides equiva-
lent or greater protection for affected Agency employees;
(4) A description of the interim protective measures that will
be provided Agency employees until a decision is received from the Secretary
of Labor; and
(5) A summary of the written comments, if any, from interested
employees, employee representatives and others.
Alternate standards should be based on research, demonstrations, and
other factors which includes the latest scientific data, feasibility and
experience with the Occupational Safety and Health Act and other laws.
General requirements for an occupational health and safety standard are
i n Appendi x 6-B.
Any interested Agency employee may file a written request for the promul-
gation, modification, or revocation of an occupational health and safety
standard with the Director, Occupational Health and Safety Staff, (PM-273),
401 M Street, SW, Washington, D. C. 20460. The request should include
or he accompanied by the proposed standard desired and a statement of
the reasons and intended effect.
5. OTHER FEDERAL AGENCY STANDARDS. In addition to the OSHA and EPA
standards there are standards affecting occupational health and safety
issued by other Federal Agencies, for example,
a. Federal Aviation Administration
b. U.S. Department of Energy
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c. General Services Administration
d. U.S. Department of Labor, Mine Safety and Health Administration
e. U.S. Department of Transportation
Where EPA employees and employees of other Federal agencies engage in
joint operations and/or primarily report to work or carry out operations
in the same facility or work activity, any alternate standards adopted
by the host Agency which are more protective shall govern.
If the standards of other Federal Agencies conflict with OSHA standards,
joint efforts between the Agencies involved and the Secretary of Labor
shall be undertaken to resolve the conflicts. Until conflicts are resolved,
EPA employees shall comply with the more protective of the standards.
6. STANDARDS APPLICATION. The effective use of occupational health and
safety standards is directly related to the understanding of the meaning,
intent, and application of the standard. Factors necessary for the
effective use of standards are:
a. Accessibility of all standards;
b. An understanding of the scope, intent, and meaning of the require-
ments of the standard;
c. Correct application of the requirements of the standard to the
work situation; and
d. Enforcement of standards in all areas of application with a
uniform interpretation of their intent.
The Headquarters Occupational Health and Safety Staff shall take the
following steps to provide all employees who use occupational health and
safety standards with a clear understanding of their intent and application.
a. Develop and distribute to all users an interpretation and clarifi-
cation of the intent and application of any standard which may be misunder-
stood.
b. Distribute directives that explain policy matters and background
information dealing with particular standards.
c. Develop a comprehensive collection of standards and distribute
them to all field users with an explanation of how to find and apply the
various sections.
d. Present classes, seminars, and briefing sessions to Headquarters
and Field Units on the substance, intent, and application of the standards.
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e. Develop, distribute and brief Headquarters and Field Units on
guidelines for implementing the standards.
f. Encourage field offices to communicate with the Headquarters
Occupational Health and Safety Staff on standards or the development of
standards. This communication will enable the Occupational Health and
Safety Staff to understand any problems that may evolve during the
application of a standard.
g. Advise all Field Units and offices that standards will be enforced
in all areas of application with a uniform interpretation of their intent.
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APPENDIX 6-A - CURRENT OCCUPATIONAL HEALTH AND SAFETY STANDARDS
The following list of laws, standards and issuances that impact occupa-
tional health and safety includes those most generally used to implement
an effective program. Other references, guidelines and textbooks are
available and should be used as necessary.
Laws and Executive Orders
PL 91-596 Occupational Safety and Health Act of 1970
EO 12196 Occupational Safety and Health Programs for Federal
Employees
Occupational Safety and Health Administration Standards and Regulations
29 CFR 1910 General Industry Standards
29 CFR 1926 Construction Standards
29 CFR 1960 Basic Program Elements for Federal Employee Occupational
Safety and Health Programs
Environmental Protection Agency Directives
1440
1440.2
1440.3
1440.4
1440.5
1440.6
Occupational Health and Safety Manual
Order - Health and Safety Requirements for Employees
Engaged in Field Activities
Order - Respiratory Protection
Order - Health and Safety Training Requirements for Mine
Safety
Order - Qualifications and Training Requirements for
Occupational Health and Safety Program Personnel
Order - Occupant Restraint Systems
EPA Guidelines
Respiratory Protection Program Management
Chemical Protective Clothing
Eye Protection Program
Other Agency Directives that Impact Occupational Health and Safety
1000.9 Order - Policy on Smoking in EPA-Occupied Buildings
1000.18 Order - Transportation of Hazardous Materials
3100.1 Order - Uniforms, Protective Clothing and Protective
Equipment
3100.3 Order - Authorization of Performance of Hazardous Duty
3120.1 Order - Conduct and Discipline
3140 Training and Development Manual
3180.1 Order - Federal Employees Compensation Program
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CURRENT OCCUPATIONAL HEALTH AND SAFETY STANDARDS (CONT.)
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Other Federal Agency Standards and Regulations that Impact Occupational
Health and Safety
U.S. Department of Transportation - Transportation of Hazardous
Materials, 49 CFR 100-177
U.S. Department of Energy - 10 CFR 0-199
U.S. Department of Labor, Mine Safety and Health Administration,
30 CFR 48
Consensus Standards Organizations
OSHA used standards developed by these organizations as a source for
their standards. Complete copies of the standards developed by these
organizations and referenced in the OSHA standards may be obtained from
the organizations listed. OSHA standards are not necessarily based on
the latest revision of a standard. Copies of the latest revision of
standards and also handbooks on the standards may be obtained from the
organizations listed.
Consensus Standards Organization
American Conference of Governmental
Industrial Hygienists (ACGIH)
1014 Broadway
Cincinnati, Ohio 45202
American National Standards Institute
(ANSI)
1430 Broadway
New York, N. Y. 10018
OSHA Standards
Subpart G - Occupational Health
and Environmental Control
Subpart I - Toxic and Hazardous
Substances
Subpart D - Walking-Working Surfaces
Subpart F - Powered Platforms, Man-
lifts, and Vehicle-Mounted Work
Platforms
Subpart G - Occupational Health and
Environmental Controls
Subpart H - Hazardous Materials
Subpart I - Personal Protective
Equipment
Subpart J - General Environmental
Controls
Subpart M - Compressed Gas and
Compressed Air Equipment
Subpart N - Materials Handling and
Storage
Subpart 0 - Machinery and Machine
Guarding
Subpart P - Hand and Portable Powered
Tools and Other Hand-Held Equipment
Subpart Q -
Brazi ng
Welding, Cutting, and
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
CURRENT OCCUPATIONAL HEALTH AND SAFETY
Consensus Standards Organization
American National Standards Institute
(ANSI) (Cont.)
American Petroleum Institute
1801 K Street, NW
Washington, DC 20006
America! Society of Agricultural
Engineers
2950 Niles Road
P. 0. Box 229
St. Joseph, MI 49085
American Society and Heating,
Refrigeration, and Air Conditioning
Engineers, Inc. (ASHRAE)
345 East 47th Street
New York, NY 10017
American Society of Mechanical
Engineers, Inc.
United Engineering Center
345 East 47th Street
New York, NY 10018
Compressed Gas Assn., Inc.
500 Fifth Ave.
New York, NY 10036
Crane Manufacturers Assn.
of America, Inc.
1 Thomas Circle, NW
Washington, DC 20005
Factory Mutual Engi neering Corp.
P. 0. Box 688
Norwood, MA 02062
Fertilizer Institute
1015 18th Street, NW
Washington, DC 20046
STANDARDS (CONT.)
OSHA Standards
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Subpart R - Special Industries
Subpart Z - Toxic and Hazardous
Substances
Subpart H - Hazardous Materials
Subpart Q - Welding, Cutting, and
Brazing
Subpart J - General Environmental
Controls
Subpart N - Materials Handling and
Storage
Subpart H - Hazardous Materials
Subpart 0 - Machinery and Machinery
Guarding
Subpart R - Special Industries
Subpart H - Hazardous Materials
Subpart M - Compressed Gas and
Compressed Air Equipment
Subpart Q - Welding, Cutting,
and Brazing
Subpart N - Materials Handling and
Storage
Subpart D - Walking-Working Surfaces
Subpart H - Hazardous Materials
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CURRENT OCCUPATIONAL HEALTH AND SAFETY STANDARDS (CONT.)
OSHA Standards
1440
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Consensus Standards Organization
Institute of Markers of Explosives
420 Lexi ngton Ave.
New York, NY 10017
National Association of Plumbing
and Mechanical Officials
5032 Alhambra Ave.
Los Angeles, CA 90032
National Board of Boiler and
Pressure Vessel Inspectors
1155 North High Street
Columbus, OH 43201
National Fire Protection Assn.
(NFPA)
470 Atlantic Ave.
Boston, MA 02210
National Plant Food Institute
1700 K Street, NW
Washington, DC 20006
Rubber Manufacturers Assn.
444 Madison Ave.
New York, NY 10022
Society of Automotive Engineers
485 Lexington Ave.
New York, NY 10017
Underwriters Laboratories, Inc.
(UL)
207 E. Ohio Street
Chicago, IL 60611
Subpart R - Special Industries
Subpart J - General Environmental
Controls
Subpart H - Hazardous Materials
Subpart E - Means of Egress
Subpart G - Occupational Health and
Envi ronmental Control
Subpart H - Hazardous Materials
Subpart M - Compressed Gas and
Compressed Air Equipment
Subpart Q - Welding, Cutting, and
Brazing
Subpart R - Special Industries
Subpart H - Hazardous Materials
Subpart Q - Welding, Cutting, and
Brazing
Subpart N
Storage
Subpart D
Subpart H
Subpart R
- Materials Handling and
Walking-Working Surfaces
Hazardous Materials
Special Industries
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APPENDIX 6-B - GENERAL REQUIREMENTS OF AN OCCUPATIONAL
HEALTH AND SAFETY STANDARDS
These are the general requirements of an occupational health and safety
standard that should be considered and used, if applicable, when developing
a standard.
1. Purpose
2. References
3. Definitions
4. Responsibilities
5. Handling and Storage Requirements
6. Processes
7. Methods of Compliance
a. Engineering controls
b. Administrative controls
c. Personal protective equipment
8. Caution Signs and Labels
9. Housekeeping
10. Record keepi ng
11. Medical Examinations
a. General
b. Pre-employment/Pre-placement
c. Frequency of examinations
d. Termination of employment
12. Medical Records
a. Maintenance
b. Access
13. Monitoring
a. Method(s) of measurement
b. Maximum allowable exposure
14. Training Requirements
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
CHAPTER 7 - OCCUPATIONAL HEALTH AND SAFETY TRAINING
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS
General 1
Responsibilities 2
Training Requi rements 3
Training Assistance 4
Availabl e Training Sources 5
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CHAPTER 7 - OCCUPATIONAL HEALTH AND SAFETY TRAINING
1. GENERAL. Executive Order 12196 requires that the head of each Agency
shall provide health and safety training for top management officials,
supervisory employees, employees responsible for conducting inspections,
health and safety specialist, collateral duty health and safety personnel,
members of occupational health and safety committees, employee represent-
atives, and other employees. EPA considers health and safety training
an essential part of every Agency program for protecting the health and
safety of its employees.
2. RESPONSIBILITIES.
a. The Agency Designated Occupational Health and Safety Official
shall assure that health and safety training is provided for all Agency
employees in accordance with Executive Order 12196, 29 CFR 1960, and
the provisions of this Manual.
b. The Director, Occupational Health and Safety Staff, shall
coordinate the Agency's occupational health and safety training pro-
grams, developing or recommending specific training courses designed
to instruct Agency personnel in the identification and control of
occupational illnesses and injuries, provide technical assistance and
evaluate the effectiveness of health and safety training program imple-
mentation.
c. Officers-in-Charge of Reporting Units shall assure that the
Agency's occupational health and safety training programs are fully
implemented at the Reporting Unit and at all Establishments and Work-
places under their organizational jurisdiction.
3. TRAINING REQUIREMENTS.
a. Top Management Officials. Top management officials shall
receive training in occupational health and safety which will enable
them to manage the occupational health and safety programs in their
areas of jurisdiction. This training shall include as a minimum:
(1) Management responsibilities and the requirements of
Section 19 of the Occupational Safety and Health Act, Executive Order
12196, and 29 CFR 1960;
(2) EPA's Occupational Health and Safety Programs, and
(3) Employee rights and responsibilities.
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b. Supervisors. Supervisors shall receive introductory and
specialized occupational health and safety training to enable them
to manage the occupational health and safety programs within their
work unit to assure the safe and healthful work practices of their
employees. This training shall include as a minimum instruction in
the fol lowi ng areas:
(1) Supervisors responsibility for providing and maintain-
ing safe and healthful working conditions for employees;
(2) EPA's Occupational Health and Safety Programs;
(3) Requirements of Section 19 of the Occupational Safety
and Health Act, Executive Order 12196, and 29 CFR 1960;
(4) Applicable health and safety standards;
(5) Agency procedures for reporting and investigating acci-
dents, illnesses, hazards, and allegations of reprisal;
(6) Recognition, evaluation and control of health and safety
hazards;
(7) Supervisors responsibility for employee discipline relating
to occupational health and safety contained in the EPA Order, Conduct
and Di scipline; and
(8) Employee rights and responsibilities.
c. Occupational Health and Safety Program Personnel.
(1) Health and Safety Specialist. EPA shall provide sufficient
training to health and the safety specialist, through formal courses,
laboratory experiences and field study, to enable them to meet present
and future needs of the Agency's occupational health and safety programs.
Training shall include as a minimum instruction in the following areas:
a) Occupational health and safety program development
and management;
b) Hazard recognition, evaluation, and control;
c) Occupational health and safety standards;
d) The Agency's occupational health and safety programs;
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e) Safe Design of equipment and facilities;
f) Accident and illness data analysis; and
g) Packaging, marking, labeling, transportation, and disposal
of hazardous materials and substances.
(2) Health and Safety Inspectors. EPA shall provide Health
and Safety Inspectors sufficient additional training to enable them
to recognize and evaluate health and safety hazards, and suggest general
control procedures. Training shall include as a minimum instruction
in the following areas:
a) Appropriate health and safety standards;
b) Use of appropriate evaluation equipment and procedures;
c) Hazard recognition, evaluation, and control procedures;
and
d) Preparation of reports and documentation.
(3) Collateral Duty Health and Safety Personnel. EPA shall
provide training for collateral duty health and safety program personnel
commensurate with the scope of their assigned responsiblities. Training
shall include as a minimum instruction in the following areas:
a) The Agency's occupational health and safety programs;
b) Section 19 of the Occupational Safety and Health Act,
Executive Order 12196, 29 CFR 1960;
c) EPA's reporting and recordkeeping procedures;
d) Evaluation and control of hazards;
e) Agency procedures for reporting and investigation of
employee allegations or reprisals for exercising rights under EO 12196
and 29 CFR 1960;
f) Recognition of hazardous conditions and environments;
g) Identification and use of occupational health and
safety standards; and
h) Packaging, marking, labeling, transportation and
disposal of hazardous materials and substances.
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(4) Health and Safety Committee Members. Health and safety
committee members shall be provided training commensurate with their
assigned duties. This training shall include as a minimum orientation
in the following areas:
a) The Agency's occupational health and safety programs;
b) Requirements of Section 19 of the Occupational Safety
and Health Act, Executive Order 12196, and 29 CFR 1960;
c) Agency procedures for reporting and investigating
employee allegations of reprisals for exercising rights under EO 12196
and 29 CFR 1960.
d) Identification and use of occupational health and
safety standards; and
e) Duties of the occupational health and safety committee.
(5) Employee Representatives. EPA shall provide occupational
health and safety training for Agency employees who are representatives
of employee groups, such as labor organizations which are recognized
by the Agency. This training will enable such groups to function appro-
priately to ensure safe and healthful working conditions. (Nothing in
this paragraph shall be construed to alter training provisions provided
by law, Executive Order, or collective bargaining arrangements.) This
training shall include as a minimum orientation in the following areas:
a) Duties of the occupational health and safety committee;
b) Identification and use of occupational health and
safety standards;
c) Requirements of Section 19 of the Occupational Safety
and Health Act, Executive Order 12196, and 29 CFR 1960; and
d) The Agency's occupational health and safety programs
(6) Employees. EPA shall provide employees health and safety
training appropriate to the work they perform. This training shall
include as a minimum instruction in the following areas:
a) The Agency's occupational health and safety programs;
b) Employee rights and responsibilities, and as appropriately;
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c) Specialized job health and safety training, e.g.,
1) Toxic and hazardous substances;
2) CPR and First Aid;
3) Use, handling, storage, disposal and transportation of
hazardous materials and substances;
4) Personal protective equipment and clothing;
5) Fire prevention, protection, ana emerorny procedures;
6) Materials handling and storage;
7) Machinery and machine guarding;
8) Specifications for accident pt-fY6 rt^c n ^cr? and tags;
9) Ventilation;
10) Ionizing and non-ionizing radiation;
11) Motor vehicle accident prevention and operator education;
12) Water safety, which includes diving and boating;
13) General laboratory safety;
14) Office safety;
15) Safety in underground and surfc','* uri i•<• \ . i *n
mine property; and
16) Aircraft Safety.
4. TRAINING ASSISTANCE. The implementation of the train-nq recuirements
of this Chapter are not complicated or resource intensive flu > are many
sources of low or no cost health and safety training available. The
occupational health and safety training assistance that the Department of
Labor (DOL) and the National Institute of Occupational Sci^f'; f d Health
(NIOSH) are required to provide other Federal Aqen :r i 1 in 29
CFR 1960.60. EPA shall use this occupational health ami •>.« o,, training
assistance from DOL and NIOSH where appropriate to meet the Agency's
occupational health and safety training needs and responsibilities. EPA
shall provide its employees the specialized training required qy the unique
charcteristics of its work.
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
a. Department of Labor.
(1) The DOL will provide occupational health and safety training
assistance in the following areas upon request by the Agency head and with
reimbursement.
a) Orientation for the Designated Agency Occupational Health
and Safety Official; and
b) Resident and field training courses to meet selected
training needs of occupational health and safety specialists, occupational
health and safety inspectors, and collateral duty occupational health
and safety personnel.
(2) The DOL will develop, in cooperation with the Office of
Personnel Management, guidelines and will provide materials for occupational
health and safety training programs for high-level managers, supervisors,
members of committees, and employee representatives.
b. National Institute for Occupational Safety and Health. NIOSH will
provide EPA. upon request and with reimbursement, training materials, and
it will conduct training programs on occupational health-related subjects.
c. Occupational Health and Safety Staff. The Occupational Health
and Safety Staff (OHSS) continually evalutes both Government and commercial
training programs for applicability to Agency needs. It also has training
programs available for use by field units in the following areas.
(1) Motion picture films on laboratory, office, eye, fire, and
electrical safety, respiratory protection and first aid.
(2) Slide-audio tape training programs on laboratory, office,
off-the-job and field safety, safety inspections, and compressed gases.
(3) Training manuals with audio-visuals for persons involved in field
activities and for senior managers and supervisors.
(4) A self-instruction correspondence course, which it administers,
for occupational health and safety program personnel.
OHSS should be contacted for information on training resources.
5. AVAILABLE TRAINING SOURCES. The following is a list of training
sources and is provided as information to Officers-in-Charge. This
list does not include all training sources. Officers-in-Charge are
encouraged to research other locally available training sources in the
occupational health and safety field. The EPA Office of Occupational
Health and Safety will assist in the evaluation of training sources
upon request.
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a. National Safety Council, 444 North Michigan Avenue, Chicago,
Illinois 60611
b. International Safety Academy, 10575 Katy Freeway, P.O. Box 19600,
Houston, Texas 77024
c. International Loss Control Institute, P.O. Box 345, Loganville,
Georgia 30249
d. University of Southern California, The Safety Center, University
Park, Los Angeles, California 90007
e. National Fire Protection Association, Battery march Park, Quincy,
Massachusetts 02269
f. National Institute for Occupational Safety and Health, Division
of Training and Manpower Development, 4676 Columbia Parkway, Cincinnati,
Ohio 45226
g. DOL, Occupational Safety and Health Administration, OSHA Training
Institute, 1555 Times Drive, Des Plaines, Illinois 60018
h. Local Fire Departments
i. Local safety councils
j. Local law enforcement agencies
k. Local universities and community colleges
1. State, County, and local health and safety officials
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CHAPTER 8 - LABORATORY USE OF TOXIC SUBSTANCES
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS
Policy and Responsibilities 1
Health and Safety Program Requirements 2
Work Practice and Engineering Controls 3
Additional Requirements for Animal Experimentation
Involving Toxic Substances 4
Situations Requiring Special Consideration 5
Appendix 8-A. Toxic Substances List
Appendix 8-B. Safety Plan
Appendix 8-C. Periodic Health Assessment
Appendix 8-D. Primary Containment Equipment
Appendix 8-E. Secondary Containment Facilities for Higher
Ri sk Situations
Appendix 8-F. Packaging, Marking, Labeling, and Shipping of
Toxic Substances Used by Laboratories
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CHAPTER 8 - LABORATORY USE OF TOXIC SUBSTANCES
1. POLICY AND RESPONSIBILITIES.
a. Purpose. This Chapter establishes policy, responsibilities, and
procedures for the conduct of the Agency occupational health and safety
program for the laboratory use of toxic substances.
b. Policy. The EPA is committed to providing safe and healthful
working conditions in laboratories where toxic substances are used.
c. Background. Section 19 of the Occupational Safety and Health
Act, Executive Order 12196, 29 CFR 1960 and this EPA Occupational Health
and Safety Manual requires the EPA to provide safe and healthful working
conditions for its employees. The EPA is responding to this requirement
with this Chapter, which is an adaptation of the Department of Health and
Human Services, formerly the Department of Health, Education and Welfare,
"Guidelines for the Laboratory Use of Chemical Substances Posing a
Potential Occupational Carcinogenic Risk, Revised Draft,1' March 1980.
An interagency subcommittee, which included an EPA representative, developed
the Guidelines. The control measures given in the Guidelines consist of
the laboratory work practices and engineering controls necessary to
protect laboratory workers from exposure to carcinogenic (or other highly
toxic) substances. In addition, the Guidelines provide alternative
control measures which are less demanding for low risk situations and
more demanding for high risk situations.
(1) Basis of Guidelines. The Guidelines are based on the
assumption that any exposure to a chemical carcinogen, regardless of how
small, carries some risk. While complete elimination of exposures is the
ideal objective, this is not obtainable in every case. However, the
potential for exposures must be reduced to the lowest practicable level.
The application of these Guidelines to a specific laboratory activity
must be based on the judgment of the supervisor who is responsible for
the safety of his or her laboratory operations. No set. of guidelines can
be applied uniformly to every situation. It is imperative, therefore,
that the supervisor assess those variables peculiar to each planned
activity in establishing appropriate safeguards. Variables that require
specific attention include (i) quantity of the toxic substance to be
used, (ii) physical and chemical properties of the agent, (iii) toxicity
and (iv) the type of experimental procedures in which the toxic substances
wil1 be used.
(2) Substances Considered Toxic. Appendix 8-A presents the
substances considered toxic for this Occupational Health and Safety Manual.
It consists of separate parts for substances exhibiting chronic (a list)
and acute (selection criteria) toxicity. The ultimate criteria for
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classifying a substance toxic for this Manual is whether the substance
poses a high risk of impairing the health of laboratory employees.
Since persons in addition to the Director, Occupational Health and Safety
Staff (OHSS), may be making this determination, the Manual includes the
sources of the lists and selection criteria comprising Appendix 8-A for
reference. The lists, which may be added to locally, will be updated by
the Director, OHSS, at least annually, and will include OSHA's list of
carcinogens upon publication.
d. Responsibilities.
(1) Program Management.
(a) Administrator. The Administrator is responsible for
developing, implementing, and evaluating the Agency's occupational health
and safety programs for the laboratory use of toxic substances in accordance
with the requirements of Section 19 of the Occupational Safety and health
Act, Executive Order 12196, and the basic program elements in 29 CFR
1960, or approved alternate program elements.
(b) Assistant Administrator for Administration and Resources
Management. The Assistant Administrator for Administration and Resources
Management, as the Designated Agency Occupational Health and Safety Official,
is responsible for establishing Agency occupational health and safety
policies, programs, standards, goals, objectives, and priorities, and for
establishing an organization, including the designation of safety and
health officials at appropriate levels, with adequate budget and staff to
implement occupational health and safety programs for the laboratory use
of toxic substances at all EPA operational levels.
(c) Director, Occupational Health and Safety Staff (OHSS).
The Director, OHSS, under the supervision of the Director, Office of
Administration, is responsible for: developing Agency occupational health
and safety policies, programs, standards, goals, objectives; evaluating
the effectiveness of the Agency's occupational health and safety programs
for the laboratory use of toxic substances at all operational levels; and
providing technical support to the Agency's occupational health and safety
programs for the laboratory use of toxic substances. The Director, OHSS,
is the top technical advisor for EPA on health and safety for laboratory
use of toxic substances.
(2) Program Implementation.
(a) Officers-in-Charge (OICs) of Reporting Units, Establish-
ments and Workplaces. The OICs are responsible for the implementation
of the Agency s occupational health and safety programs for the laboratory
use of toxic substances at their Reporting Unit, Establishment or Workplace.
The QIC is charged with assuring that any laboratory supervisor using
toxic substances is qualified by training or experience, has the equipment
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and facilities to handle the materials safely, and proposes a use which
is safe to all concerned. The QIC is responsible for assuring the
completion of semiannual program reviews and audits.
(b) Safety Committee (SC). The SC is responsible for aiding
and advising the QIC on employee health and safety matters and policies
and procedures for the Agency occupational health and safety program for
handling toxic substances in the laboratory. (See EPA Occupational Health
and Safety Manual, Chapter 5, paragraph 6.b. for a detailed description
of the SC's health and safety responsibilities.) SC's should review and
approve Safety Plans prepared by each supervisor and forward them to the
Occupational Health and Safety Designee. The SC should also advise the
QIC on specific programs for Health Surveillance.
(The Safety Committee should include, or have access to, individuals who
possess expertise in chemistry, toxicology, medicine, engineering and
laboratory safety.)
(c) Occupational Health and Safety Designees (OHSD's). The
OHSD's at all operational levels are responsible for assisting the Officers-
in-Charge of their Reporting Units, Establishments, or Workplaces in:
managing, developing, organizing, directing, and evaluating the occupational
health and safety programs and injury reporting and record-keeping
requirements; analyzing accidents and injuries for prevention and control;
and providing technical advice to management officials in the implementation
of program policy and standards.
OHSD's must have either background and training in recognizing, evaluating,
and controlling hazards from laboratory use of toxic substances or access
to this expertise. OHSD's must maintain inventory records for substances
considered toxic for this Manual.
(d) Laboratory Health Officers. Laboratory Health Officers
are responsible for providing technical support to the OHSD. (Laboratory
Health Officers are laboratory-based personnel who have expertise in the
health effects and chemical hazards related to laboratory operations;
they are officially appointed by the Officer-in-Charge; and they functionally
report to the OHSD.)
(e) Supervisor.
The Supervisor has the primary responsibility for:
J_ Selecting work practices and engineering controls for
handling toxic substances;
2_ Preparing a Safety Plan prior to use of toxic
substances. (See Appendix 8-B for details of the Safety Plan.);
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3_ Submitting the Safety Plan to the Safety Committee
for their review and approval;
4_ Making copies of the approved Safety Plan available
to program and support staff;
5_ Assuring that the program and support staff (including
maintenance and housekeeping personnel) are instructed and trained in the
laboratory practices and engineering controls required to ensure safety
and in planned procedures for dealing with accidents involving toxic
substances, and are informed of the potential hazards associated with the
proposed use of toxic substances;
6^ Supervising the safety performance of the staff to
ensure that the required laboratory practices and engineering controls
are empl oyed;
7_ Arranging for immediate medical attention and
reporting to the OHSD any accident that results in a_ inoculation of toxic
substances through cutaneous penetration, b_ingestion of toxic substances,
£ probable inhalation of toxic substances, or d_ any incident causing
overt exposure to personnel or danger of environmental contamination by
toxic substances;
_8 Cooperating in the occupational medical surveillance
program;
_9 Assisting the OHSD in investigating accidents;
IQ_ Investigating and reporting in writing to the OHSD
any problem pertaining to operation and implementation of laboratory
practices and engineering controls; and
_11_ Correcting work errors and conditions that may result
in the release of toxic substances.
(f) Employees. Each employee is responsible for complying
with the health and safety program for the laboratory use of toxic
substances established by this Manual. Each employee shall report to
his/her supervisor or the OHSD any unsafe condition and all facts pertaining
to accidents which resulted in employee exposure to toxic substances.
(g) Other Responsibilities. The individuals specified
above and other individuals have responsibilities for this program which
are described in relevant sections of the balance of this Chapter.
2. HEALTH AND SAFETY PROGRAM REQUIREMENTS.
a. Safety Manual. The QIC must ensure that the safety program
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covering the laboratories within his/her Reporting Unit, Establishment,
or Workplace is documented by a safety manual. The OIC must make the
Safety Manual available for distribution, provide a copy to each employee
using toxic substances, and forward an information copy to the Director,
OHSS.
b. Safety Plan. The Supervisor mist prepare, and obtain approval
of, a Safety Plan (Appendix 8-B) before using a toxic substance. The
Laboratory Safety Committee, or similar group set up for this purpose,
must review the Safety Plan and forward it to the OHSD with comments.
The OHSD and the OIC must approve the Safety Plan before the toxic
substance can be used. The OHSD must maintain the Safety Plan on file
and make it available for distribution, provide a copy to each employee
using the toxic substance, and forward an information copy to the Director,
OHSS. The supervisor may prepare, and obtain prior approval of, generic
safety plans to cover groups of toxic substances which pose similar
occupational hazards.
c. Audit. The OIC must ensure that semi-annual program reviews,
including inspections, of the health and safety program for laboratory
use of toxic substances are conducted by persons with appropriate background
and training, and that any deficiencies are corrected as soon as possible
(or immediately if the deficiency is an imminent hazard). The OIC must
forward a copy of the program review and abatement actions to the Director,
OHSS, for review. The Director, OHSS, may conduct independent audits.
d. Accident Reporting. The OHSD must coordinate the reporting of
any accident involving exposure (inoculation, ingestion, dermal contact,
inhalation) to a toxic substance in accordance with the procedures detailed
in Chapter 3 of the Occupational Health and Safety Manual. In addition,
the OHSD must forward a copy of this type of accident report to the
employee's medical record (see 2.g.(3)).
e. Training. The OIC must ensure that all employees, before using
toxic substances in the laboratory, receive a minimum of 24 hours of
training on the safe handling of toxic substances in the laboratory
(followed by 4 hour refresher courses annually) and receive training
specific to the hazards (including emergencies) of a specific operation
before conducting that operation. The OHSD must obtain the approval of
the Director, OHSS, for the initial 24 hour and annual 4 hour courses and
must issue a certificate to employees upon completion of the courses.
The training courses must be supplemented by on-the-job training. The
QIC must ensure that the supervisor, OHSD, or other persons qualified by
training and experience will periodically apprise laboratory and other
i nvolved workers, for example, those involved in housekeeping or maintenance
work, about (1) the possible sources of exposure, (?.} adverse health
effects (including chronic effects such as cancer) associated with
exposure, (3) work practice and engineering controls in use and being
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planned to limit exposure, (4) environmental and medical monitoring
procedures used to check on control procedures and on the health status
of emoloyees, and (5) their responsibilities for following proper work
practices to help protect their health and provide for the safety of
themselves and fellow employees. The trainers should also explain: the
types and functions of monitoring equipment, such as personal samplers,
so that each employee understands his or her part in environmental
monitoring; medical monitoring procedures, especially any unusual procedures
such a sputum cytology or biologic monitoring of metabolites in the urine;
and the benefits to workers of participating in these environmental and
medical monitoring procedures.
The OHSD must keep the Safety Plan, safety data sheets, and other
appropriate written information describing the relevant toxic, physical,
and chemical properties of toxic substances used or stored in the
laboratory, in a file that is continuously and readily available to
employees.
In addition, the OIC must ensure that employees identified to respond to
emergencies involving toxic substances receive additional training,
repeated at least annually, which includes directing general evacuation,
decontamination of uncontrolled releases of toxic substances, maintaining
a respirator program at least equivalent to 29 CFR 1910.134, using other
personal protective equipment, and first aid and CPR.
f. Emergency Procedures. The OHSD must develop procedures to protect
personnel in case of emergencies involving toxic substances in the
laboratory. The emergency procedures should include: notifying emergency
and other affected personnel; designating the containment area; decon-
tamination procedures; a general evacuation plan; local emergency
departments and local Poison Control Centers' locations, phone numbers,
and contacts; and should be conspicuously posted and tested with drills
at least semi-annually.
g. Medical Surveillance.
(1) Pre-assignment Health Assessment. The OIC must ensure that
a baseline health assessment is provided to all employees who work with
toxic substances or who are assigned duties in work areas where toxic
substances are regularly used. These health assessments are to be provided
under the EPA Medical Monitoring Guidelines and nust be included in
position descriptions for new assignments. The OIC, after consultation
withan occupational physician, the OHSD, and the medical monitoring
coordinator, must also determine the necessity of providing pre-assignment
health assessments for employees who may be assigned duties in work areas
where small quantities of toxic substances are infrequently used.
The purpose of this pre-assignment assessment is to establish a baseline
health record and if evidence of predisposing conditions is found, to
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inform and counsel the employee concerning the inadvisability of working
in areas where toxic substances are used. The pre-assignment assessment
will include a work history, a medical history, and a physical examination,
which includes customary laboratory studies and agent-specific studies
when appropriate.
(2) Periodic Health Assessments. The QIC must ensure that periodic
health assessments are provided to all employees who work with toxic
substances or who are assigned duties in work areas where toxic substances
are regularly used. The periodicity and content of these assessments
must be determined by the 0'IC after consultation with an occupational
physician, the OHSD, the medical monitoring coordinator, and the supervisor.
The assessments will include an updating of the employee's work and
medical histories, including occurrences of any accidental exposures
previously unreported. The following information rrust be included in the
employee's medical record: names of toxic substances to which the
employees may have been exposed, information on the probability, frequency,
and extent of exposures, and any environmental measurements relating to
toxic substances that may have been made. The periodic health assessment
may also include a physical examination, biochemical or other surveillance
of body fluids, and an evaluation of pertinent functional systems of the
body. (See Appendix 8-C.) The medical monitoring coordinator at each
location is responsible for requesting and helping to schedule examinations
and, assisted by the OHSD, must furnish to employees, prior to each
examination, exposure and environmental monitoring data as specified
above for inclusion in their medical records.
(3) Records. The records must be maintained in the local custody
of the examining physician. Access must be limited to the custodian or
duly appointed officials. A copy of these records may be maintained in
the Agency Occupational Health and Safety Office. These must be maintained
in locked cabinets with access limited to the Director or to authorized
personnel.
Upon an employee's death, retirement, resignation, or other termination of
Government service, the records must be forwarded to the U.S. Office of
Personnel Management or Public Health Service Commissioned Officer, Department
of Personnel, for inclusion with the Official Personnel Records and the
custody thereof will fall to the custodian of such records.
Medical information about an applicant, employee or annuitant must not be
made available to the public. (See EPA Medical Monitoring Program Guide-
lines, established by the OHSS, for details of the Medical Monitoring
Program recording requirements.)
3. WORK PRACTICE AND ENGINEERING CONTROLS. The work practice and
engineering controls specified in this section must be used by all
laboratories in which work involving toxic substances is carried out
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regularly. Paragraph 5 of this Chapter describes work practice and
engineering controls for situations where either more or less stringent
safeguards should be considered in providing protection to the laboratory
worker.
a. Chemical Control Procedures.
(1) "Cradle-to-Grave"
purchase requisitions for toxic substances. The QIC, after consulting
the OHSD, may add to the list of toxic substances presented in Appendix
8-A for his/her reporting unit. The OHSD subsequently monitors and records
the receipt, transport, storage, use (including a list of personnel
authorized to use) and disposal of the toxic substances. The OHSD must
update the inventory at lease semi-annually. Also, the OHSD must obtain,
maintain, and distribute safety data sheets and other information needed
to use toxic substances safely. The OHSD may request technical support
from the Director, OHSS, in obtaining this information.
(2) Storage Inventory and Identification. Stock quantities of
toxic substances must be stored in a specific area that is secured at all
times. The storage area must be posted with a sign bearing the legend:
CAUTION-TOXIC SUBSTANCE Authorized Persons Only. Supervisors must maintain
inventory records of stock quantities of toxic substances they are
individually responsible for and mist provide copies to the OHSD. The
inventory records must include the quantities of toxic substances acquired
and dates of acquisition and disposition. Storage vessels containing
stock quantities must be labeled: CAUTION-TOXIC SUBSTANCE. Additional
storage precautions may be required for compounds having other properties,
such as fl ammability, radioactivity, etc.
(3) Working Quantities. Quantities of toxic substances present
in the work area must not exceed the amounts required for use in one
week. This does not include amounts stored in a specific toxic substance
storage area or cabinet that is located within the laboratory work area.
Storage vessels containing working quantities must be labeled: CAUTION-
TOXIC SUBSTANCE.
(4) Decontamination. Contaminated materials must either be
decontaminated by procedures that decompose the toxic substance to produce
a safe product or be removed for subsequent disposal. Toxic substances
which have spilled out of a primary container so as to constitute a hazard
must be inactivated in situ or mist be absorbed by appropriate means for
subsequent disposal. Adequacy of clean-up must be tested using, for
instance, wipe-test or fluorescence tests.
(5) Laboratory Transport. Storage vessels containing toxic
substances must be placed first in an unbreakable outer container before
being transported to laboratory work areas using good transfer practices.
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Plastic coated glass bottles with polypropylene caps, which can satisfy a
4-foot drop test, are currently available which can serve as both the
storage vessel and the unbreakable outer container combined. Contaminated
materials which are transferred from work areas to disposal areas must
first be placed in a closed plastic bag or other suitable impermeable and
sealed primary container. The primary container mist be placed in a
durable outer container before being transported. The outer container'
must be labeled with both the name of the toxic substance and the warning:
CAUTION-TOXIC SUBSTANCE.
(6) Packaging and Shipping. Toxic substances must be packaged
to withstand shocks, pressure changes, and any other conditions which
might cause leakage of contents incident to ordinary handling during
transportation. Shipments must be in accordance with Department of
Transportation (DOT) regulations and EPA Order 1000.18, Transportation of
Hazardous Materials. (See Appendix 8-F for specific packaging and shipping
guidance reference.)
(7) Disposal. Prior to the start of any laboratory activity
involving a toxic substance, plans for the handling and ultimate disposal
of contaminated wastes and surplus amounts of the toxic substance must
be completed. The supervisor and OHSD should jointly determine the best
methods available that are in compliance with Federal, State and local
codes and ordinances.
b- Operational Practices.
(1) Work Area Identification. Entrances to all work areas,
where toxic substances are being used or stored, must be posted with
signs bearing the legend: "CAUTION - TOXIC SUBSTANCE - Authorized Persons
Only," followed by name of supervisor.
(2) Access Control. Work areas, where toxic substances are
being used or stored, must be entered only by persons authorized by the
supervisor. Access doors to work areas must be kept closed while
experiments involving toxic substances are in progress.
(3) Work Surfaces. All work surfaces (bench tops, hood floors,
etc.) on which toxic substances are used must be covered with stainless
steel or plastic trays, dry absorbent plastic backed paper or other
impervious material. The protective surfaces must be examined for possible
contamination immediately after each procedure involving toxic substances
has been completed. Contaminated surfaces must be decontaminated or
disposed of as appropriate.
(4) Use of Analytical Instrumentation. Vapors or aerosols
produced by analytical instruments, when used with toxic substances, must
be captured through local exhaust ventilation at the site of their
production. The instruments may be placed entirely within a laboratory
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fume hood if this will not impair hood performance (i.e., toward the back
and raised on legs to minimize turbulence of inflowing air). When a sample
is removed from the analytical instrument, it should be placed In a
tightly stoppered sample tube or otherwise safeguarded from contaminating
the laboratory. In the event that the analytical equipment becomes
contaminated, it must be labeled "CAUTION - TOXIC SUBSTANCE" until it has
been completely decontaminated. This operational practice applies to
analytical equipment even when only infrequently used for toxic substances.
(5) Use of Primary Containment Equipment. Procedures involving
volatile toxic substances and those involving solid or liquid toxic
substances that may result in the generation of aerosols must be conducted
in a laboratory fume hood, a glove box, or other containment equipment
approved for toxic substances by the OHSD. (Personnel protection factors
for Class II biological safety cabinets have not yet been established;
however, when installed with total exhaust, these devices are currently
acceptable for procedures involving toxic substances.) Examples of
aerosol producing procedures are: the opening of closed vessels, transfer
operations, weighing, preparation of feed mixtures and the application,
injection or intubation of a toxic substance into experimental animals.
Tissue culture and other biological procedures involving small quantities
of toxic substances may be conducted in a Class II Type A or B biological
safety cabinet. The selection and use of a Class II biological safety
cabinet for procedures involving toxic substances must be a joint decision
of the supervisor and the OHSD. Primary containment equipment used for
containment of toxic substances must display a label bearing the legend:
CAUTION - TOXIC SUBSTANCE. All bidding documents and installation plans
for primary containment equipment must be reviewed by the Facilities
Engineering and Real Property Management Branch prior to procurement.
(See Appendix 8-D for additional information on primary containment
equipment.)
(6) Protection of Vacuum Lines. Each vacuum service, including
water aspirators, must be protected with an absorbent or liquid trap and
a High Efficiency Particulate Aerosal (HEPA) filter to prevent entry of
any separate vacuum pump or other device place in a laboratory fume hood
approved for toxic substances must be used.
c. Personal Protective Equipment.
(1) Protective Clothing. Protective clothing such as a fully
fastened laboratory coat or a disposable jumpsuit must be worn in any
work area in which toxic substances are being used. Clean clothing nust
be provided weekly and must not be worn outside the work area,, Clothing
contaminated by toxic substances must be decontaminated or disposed of
immediately after an obvious exposure. Contaminated clothing must not be
sent to the laundry until decontaminated. (See 3.a. (4) for decontamination
procedure.) Gloves which are appropriate to the specific situation must
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be used when handling toxic substances. Disposable gloves must be discarded
after each use and immediately after known contact with a toxic substance.
Acquisition of protective clothing and equipment must be in accordance
with EPA Order 3100.1, Uniforms, Protective Clothing and Protective Equipment.
(2) Eye Protection. Devices to provide appropriate eye protection
must be worn in any laboratory work and should meet ANSI Z87.1,"Practice
for Occupational and Educational Eye and Face Protection" and the
requirements in EPA's Eye Protection Program Guideline.
(3) Use of Respirators as Personal Protective Devices. A
respirator use program nust be provided for emergency and maintenance
personnel who enter areas where a potential for inhalation exposure to a
toxic substance is present. This program nust meet the requirements of
the OSHA General Industry Standards for respiratory protection as detailed
in 29 CFR 1910.134. The respirators must be certified in accordance with
the requirements of the National Institute for Occupational Safety and
Health (NIOSH) under the provisions of 30 CFR Part 11. The selection and
use of respirators must be approved by the OHSD.
d. Work Practices.
(1) Housekeeping. General housekeeping procedures which suppress
the formation of aerosols, such as the use of a wet mop or a vacuum
cleaner equipped with a HEPA filter to remove particulates, must be used.
Dry sweeping and dry mopping are prohibited because of the hazard of
aerosol formation. Training of personnel in appropriate cleaning techniques
to avoid or minimize exposure is the responsibility of the supervisor.
In those instances where the toxic substance or contaminated material is
spilled, special procedures developed for the individual compounds must
be followed. (See 2.b.)
(2) Eating, Drinking and Smoking. There nust be no eating,
drinking, smoking, chewing of gum or tobacco, application of cosmetics or
storage of utensils, food or food containers in any laboratory area.
(3) Pipetting. Mechanical pipetting aids must be used for all
pipetting procedures. Oral pipetting is prohibited.
(4) Personal Hygiene. All personnel must wash hands immediately
after completion of any procedures in which toxic substances have been
used. Immediately after an obvious exposure to toxic substances, personnel
must wash or shower the affected area.
e. Facility Recommendations.
(1) Handwashing Facility. A handwashing facility must be available
within the work area.(This need not be a facility used exclusively for
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handwashing.) The use of liquid soap is recommended. In new facilities,
foot or elbow operated faucets should be provided.
(2) Shower Facility. A shower facility, other than emergency
drench showers, must be located in the building in which toxic substances
are used. The shower facility must be available at all times.
(3) Eye Wash Facility. An emergency eye wash facility must be
located in each laboratory. It should be designed to wash both eyes at
the same time with a continuous stream of potable water.
(4) Exhaust Air from Primary Containment Equipment. The exhaust
air from glove boxes must be treated by filtration, reaction, absorption,
adsorption, electrostatic precipitation or incineration. The need for,
and type of, treatment for other primary containment equipment, including
laboratory fume hoods and biological safety cabinets, must be determined
by the DSHD in consultation with the supervisor. Exhaust air treatment
systems that remove toxic substances from the exhaust air by collection
mechanisms such as filtration, absorption and adsorption mist be serviced
in a manner that avoids direct contact with the collection medium.
(Trained maintenance employees may remove the spent collection medium
using a bag in-bag out collection system or using appropriate personal
protective clothing and equipment.) All exhaust air from primary
containment equipment must be discharged by roof mounted blowers to the
outdoors so that it is dispersed clear of occupied buildings and air intakes.
(5) Exhaust Ventilation. A mechanical exhaust ventilation system
must be provided for controlling laboratory room air movement. The
movement of air must be from areas of lower contamination potential to
areas of higher contamination potential (i.e. from entry corridors to the
laboratory). All air from laboratories must be exhausted outdoors and
not reci rculated. However, non-contaminated air within individual
laboratories may be reconditioned. The exhaust air from laboratory areas
must be discharged outdoors in a way that entry into a building's air
supply is minimized. Exhaust air from laboratory areas which is not
derived from primary containment equipment can be discharged to the
outdoors without being treated.
4. ADDITIONAL REQUIREMENTS FOR ANIMAL EXPERIMENTATION INVOLVING TOXIC
SUBSTANCES. The work practice and engineering controls specified in
paragraph 3 apply to animal experimentation when toxic substances are
used. Additionally, animal care personnel must wear a completely closed
jumpsuit or a complete clothing change and laboratory-issue shoes or
booties, head cover and gloves. Clean clothing must be provided daily.
Animal care personnel engaged in procedures where exposure to airborne
particulates contaminated with toxic substances could occur must use
appropriate respiratory protection. The selection and use of an appropriate
respirator must be approved by the OHSD. The face mask or respirator
must not be worn outside the animal room. Used filters must be disposed
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of and the respirator housing must be decontaminated daily, and the
respirator irust be stored in a clean location- Personnel required to
wear a respirator must shower after completion of procedures that may
result in the creation of airborne contamination in the animal room.
Experimental animals must be housed in cage systems that confine feed,
feces, urine and bedding within the enclosure. When using a volatile
toxic substance the cage will be appropriately sealed or ventilated to
prevent evolution of contaminants. Alternative animal housing methods
must be approved by the OHSD.
The Safety Plan prepared for animal studies must include descriptions of
the proposed animal housing methods, safeguards appropriate for dose
preparation and challenge procedures, procedures for bulk storage and
disbursement of test material, waste management practices, and personnel
protection requirements. An operations manual trust be prepared for
facilities in which large-scale animal studies and inhalation challenge
studies are conducted. Equipment use procedures for all inhalation
challenge studies must be described in detail.
All animal use must comply with the Animal Welfare Act, Public Law 89-544,
1966, amended in 1970 and 1976 (P.L. 91-579 and P.L. 9A-279) and must
conform with the Guide for the Care and Use of Laboratory Animals, DHEW
No. 78-23, revised 1978 or succeeding editions.
5. SITUATIONS REQUIRING SPECIAL CONSIDERATION. The purpose of this
section is generally to describe situations involving toxic substances
where either more or less stringent safeguards might be considered in
providing protection to the laboratory worker. (No specific definitions
for such situations can be provided; an attempt to do so would be
misleading.) Any modification to the laboratory practices and engineering
controls described in paragraph 3 should be carefully considered and
reviewed by the supervisor, the OHSD, and the SC.
The hazard in working with toxic substances is a function of the exposure
potential and the toxicity. The risk of exposure to a toxic substance is
related, among other things, to the quantity and physical properties of
material used and the nature, frequency, and complexity of the experimental
procedure. There is a greater risk of exposure when working with 100
milligrams of material than with I microgram of material. Similarly the
potential for exposure is greater during blending, preoaration of dry
feed mixture or the manipulation of powders than during the preparation
of aliquots of stock solutions. The toxicity and carcinogenic potency
are also important factors in the selection of safeguards. For example,
experimental data suggests that the carcinogenic potency of aflatoxin
81 is magnitudes greater than that of chloroform.
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a. Low Risk Situations. Infrequent use of small quantities of
toxic substances presents a low risk situation. An infrequent or
incidental user can be described as a person who uses only a small quantity
of material on an infrequent basis. Such users may include Individuals
involved in microbial or tissue culture test procedures, persons using
small quantities of chloroform for the inactivation of microorganisms,
and the users of o-tolidine (3,3' -Dimethylbenzidine) test papers.
Safety during these operations can normally be achieved by strict adherence
to good laboratory practice. The laboratory worker must not eat, drink,
smoke, chew gum or tobacco, apply cosmetics or store food in areas where
the toxic substances are used or stored. Hands should be washed following
the completion of a procedure in which toxic substances are used. The
laboratory workers should develop the habit of keeping hands away from
mouth, nose, eyes, and face. A fully fastened laboratory coat and gloves
should be worn when handling toxic substances. Mechanical pipetting
aids must, be used for all pipetting procedures. Laboratory workers
should receive periodic laboratory safety training.
The preparation of dilute solutions or the removal of small amounts of a
toxic substance from stock quantities should always be performed within a
laboratory fume hood or glove box. The work surfaces of the hood should
be covered with stainless steel or plastic trays, dry absorbent plastic
backed paper or other impervious material.
Stock quantities of toxic substances should, be the minimum quantity
required for efficient use; the primary container should be stored in an
unbreakable outer container. Plastic coated glass bottles with poly-
propylene caps, which can satisfy a 4-foot drop test, may be used in lieu
of both containers. The outer container should be labeled with a sign
bearing the legend: CAUTION - TOXIC SUBSTANCE. The stock quantities
should be maintained in a secured and posted storage area when not is use.
Requirements for decontamination and disposal specified in paragraph 3
apply to this category of user.
b. Higher Risk Situations. More stringent safeguards may be
required for certain research investigations that present higher risk
situations than those subject to the general requirements. More stringent
requirements may also be required for research activities that involve
highly potent toxic substances. The toxic substances and laboratory
activities for which additional controls will be required must be determined
on a case by case basis by the QIC in consultation with the SC and OHSD.
Work practice and engineering controls that may be required to augment
the general requirements include: additional or more frequent changes of
protective clothing, increased showering frequency, shower facility and
change room requirements, use of primary containment devices, work area
access control, impervious floors for easy decontamination and monitoring
for environmental contamination resulting from certain laboratory activities.
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Personnel may be required in some instances to wear full protective
clothing such as pants and shirts or jumpsuits, shoes, or boots and head
covers and to shower after each exit from the work area.
Laboratory activities that involve high risk procedures with a known
potent toxic substance may be restricted to either a glove box or other
completely closed containment system. Work areas may be required to be
separated by a controlled access area from areas that are open to
unrestricted traffic flow. This controlled access area may be an anteroom,
a change room, an air lock or any other door arrangement that separates
the laboratory from areas of unrestricted traffic flow. A specially designed
"Containment Area" consisting of a Special Handling Room with adjoining
laboratory work area, change rooms, shower and toilet facilities and an
air lock may be required for the highest risk situations. (See Appendix
8-E - Secondary Containment Facilities for Higher Risk Situations.)
Environmental monitoring may be required in work areas where the potential
of exposure to a known potent toxic substance is great. An example of
such an area might be a dry feed mixing operation where a large amount of
the toxic substance is being handled in an activity that can produce
significant amounts of aerosol.
Additional controls for the safe use of a particular compound mist be
specifically identified in the Safety Plan (Appendix 8-B) for its use.
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APPENDIX A - TOXIC SUBSTANCES LIST
Chronic - This will be a listing of established carcinogenic agents.
The Carcinogen Assessment Group (CAG) listing will be used
for the first list.
Acute -This will be a listing of chemicals meeting the following
criteria:
ACUTE TOXICITY
Dosage Method Type of Measure Value of Toxicity
Oral LD50 Up to and including
50 mg/kg
Inhalation LC50 • Up to and including
0.2 mg/1 (200 mg/m3)
Dermal LD50 Up to and including
200 mg/kg
Adapted from 40 CFR 162.
A list of 927 substances meeting the above criteria was generated by
searching the current NIOSH Registry of Toxic Effects of Chemical Substances
(RTECS). (If you would like copies of the proposed initial lists, contact
the Industrial Hygiene Programs Manager at FTS 382-3640.)
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APPENDIX B - SAFETY PLAN
Assistance in preparing the safety plan can be obtained from
OHSD located in Room of Building
or by telephoning
USE CATEGORY
Regular User Infrequent User
REVIEW
Safety Committee Chairperson
APPROVALS
Supervisor
OHSD
QIC
SUPERVISOR
Laboratory or Branch
Building
Room
Phone
DATE OF PHONE PREPARATION
TOXIC SUBSTANCE
Name CAS No.
Synonyms
Safety Data Sheet Available Yes No
Location of Use
Type of Use
Location of Storage
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Inventory Data
Date Toxic Substance Ordered or Synthesized
Quantity
Period of Use
HAZARD ASSESSMENT (toxic and pharmacologic effects, reactivity, stability
flammability, and operational concerns - weighing,
mixing, etc.):
MONITORING PROCEDURES (If required by the OHSD)
Medical surveillance procedures for evidence of personal exposure:
Personnel monitoring procedures:
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Surveillance procedures for environmental contamination:
DECONTAMINATION AND DISPOSAL
Decontamination Procedures (contaminated: surfaces, materials,
instruments, equipment, etc.):
Disposal Procedures (wastes and unused stock):
EMERGENCY PROCEDURES
In event of overt personnel exposure (inhalation, ingestion,
inoculation):
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In event of environmental contamination (spill):
PERSONNEL POTENTIALLY EXPOSED TO TOXIC SUBSTANCE
Personnel Authorized to Use Toxic Substance
1.
2.
3.
4.
5.
Other Personnel Assigned to Locations Where Toxic Substance is Used
1.
2.
3.
4.
5.
ALTERNATIVE WORK PRACTICE AND ENGINEERING CONTROLS
(Describe alternative controls not specified in this Manual for
the Laboratory Use of Toxic Substances. Indicate controls specified
in the Manual for which proposed alternative controls will serve
as substitute methods.)
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SAFE PRACTICES FOR ANIMAL EXPERIMENTATION
Personnel Protective Equipment (gloves, respirator, approved clothing,
booties, goggles, etc.):
Animal Care and Housing Requirements (containment cages, exposure
procedures, bedding change, dose
preparation, cage cleaning, waste
handling methods):
Facility Operational Procedures (access control, traffic patterns, de-
contamination procedures, waste manage-
ment, species isolation requirements):
APPROPRIATE LITERATURE CITATIONS
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APPENDIX C - PERIODIC HEALTH ASSESSMENT
(ADAPTED FROM DHHS GUIDELINES)
The nature of a program for providing periodic health assessments is
complicated by several factors. Among these are (1) many laboratory workers
handle a variety of toxic substances so that the medical surveillance should
ideally seek evidence of adverse effects from all these substances,
(2) some toxic substances cause cancer but have little or no toxicity other
than the production of neoplasms, and most tumors do not become evident
until many years (often 20-30) after the initiating events.
Medical monitoring wil1, therefore, sometimes for necessity and more often
for efficiency, usually concentrate on events likely to precede overt
evidence of serious health effects such as tumorigenesis. For example,
some carcinogens, such as dimethylnitrosamine, have high acute toxicity,
especially to the liver, and evidence of such actute toxicity can be obtained
within a few hours or days following exposure. Some tumors, such as those
liver cells, usually detectable by clinical tests. Others, e.g., angi osarcomas
induced by such substances as vinyl chloride, will often cause detectable
cell changes in nearby tissue as the probable result of space occupation.
It should be noted that detection of such toxic changes does not necessarily
presage tumor development, but should nevertheless precipitate the institution
if corrective work practices and improved engineering controls. The
occupational physician, to be effective, must have relevant information
such as mode and mechanism of toxic action, freqeuncy and severity of
exposure, and exposure concentration, if known. Some of this information
will be available in individual safety data sheets. However, this information
should be supplemented by the supervi sor when appropriate.
Biologic monitoring will sometimes be a useful method of detecting exposure
and perhaps, of estimating the degree of exposure. Biologic monitoring
usually involves the analysis of body fluid or excreta (usually urine,
sometimes blood, rarely expired air) for the toxic substance or a
biotransformation product. An example is the detection of reaction products
of biphenyl amines in the urines of persons absorbing benzidine or its
derivatives. Even if exposure cannot be quantitated, as is sometimes the
case, the mere detection of the metabolite, if its presence is specific to
the individual toxic substance or class, is sufficient to indicate the need
for corrective action.
In some cases, especially with some less well known carcinogens, those in
the research laboratory will be better informed on possible biologic
monitoring procedures than will the occupational physician. In such cases,
the investigators should discuss the possibilities with the occupational
physician. It may also be that specialized analytical procedures and
equipment will be needed for some of this monitoring, procedures and
equipment that may not be available to the medical laboratory but when are
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available in the research laboratory. The investigators should undertake
such monitoring procedures themselves only with prior approval by and
participation of the occupational physician. This is to ensure that
appropriate precautions will be taken; such as (1) precautions necessary to
data interpretation, such as standard corrections for dilution of urine,
(2) precautions for the individual, such as assurance that invasive
procedures will not be used, and (3) precautions for the individual's
privacy, such as maintenance of appropriate security for individual records.
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APPENDIX D - PRIMARY CONTAINMENT EQUIPMENT
1* PUJ^PP-SJL' T^e purpose of primary containment equipment is to protect
the laboratory worker from exposure to vapors or aerosols of hazardous
materials that may be released by procedures performed within the equipment.
Primary containment equipment that is properly designed, located, maintained,
and operated can prevent or minimize the escape of hazardous materials
from the equipment into the laboratory. The laboratory fume hood, the
glove box, and the biological safety cabinet are the principal primary
containment equipment upon which laboratory workers depend for their
protection while working with toxic substances.
2. LABORATORY FUME HOOD. The laboratory fume hood (a Class I device)
is the primary hazard control device that laboratory workers depend upon
for their protection while working with toxic or other hazardous materials.
If designed, installed, operated, and maintained properly, the laboratory
fume hood will provide personnel with a high degree of protection and allow
the user to safely work with a wide range of potentially hazardous
materials.
a. Hood Function. The purpose of a laboratory fume hood is to
prevent or minimize the escape of contaminants from the hood into the
laboratory. This is accomplished by drawing air past the operator through
the zone of contaminant generation, and into the hood.
b. Conditions Affecting Hood Performance. The ability of a laboratory
hood to control contaminants generated in the hood will depend on many
factors. Of prime concern are the control velocity at the hood face, air
movement in the room, turbulence within the hood working space, and hood
location. It is the proper selection and control of these factors as a
group that determines the performance of the hood from the standpoint of
hazard control.
(1) Face Velocity. Air flow rates, to provide protection from
operations performed in the hood, must provide positive control of air
movement against competing influences. Control velocities required at
the face of the hood range from 80 FPM for "ideal" laboratory conditions
to 100 FPM for "good" conditions. (See Appendix 8-D, subparagraph 2.c.)
(2) Operator Effect. The operator standing in front of the
hood may effect the air flow patterns. The "eddies" formed around the
operator can carry contaminants from the hood to the operator's breathing
zone. Proper use of make-up air at the hood face, with emphasis on
filling the void or minimizing the low pressure area in front of the
operator, is necessary for optimum hood performance,
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(3) Air Movement in the Laboratory. Air movement within the
laboratory affects the performance of hoods and is influenced by hood
location and room air supply systems. Hood locations must be away from
doors, operable windows, and pedestrian traffic. Air from these sources
can attain velocities several times greater than the hood face velocity,
creating potential fro dragout or displacement of contaminated air from
the hood. Ceiling and wall diffusers for distribution of make-up air are
also serious potential sources of interference. Air from such outlets
should either be controlled to assist in the performance of the hood ir
directed so that the energy is lost before entering the zone of influence.
Experience indicates that air from make-up systems should not exceed
25 FPM in the hood face areas (measured with hood exhaust "off"). Air
drawn from adjacent areas (by the hood exhaust system) must enter in a
manner that does not create excessive turbulence.
(4) Hood Turbulence. Upon entering the hood, the air is drawn
past equipment and sources of contamination toward the exhaust slots.
Much of the air within the hood is in a turbulent state. At air-flows
greater than needed to provide a good vector and contain the contaminant,
the resulting turbulence can be excessive causing a "rolling effect" in
the hood chamber. This increases the potential for greater mixing of
contaminated air and room air at the hood face. Often, a combination of
poor hood arrangement and interior turbulence will result in loss of
contaminated air to the room.
(5) Hood Location. Location of a hood at the end of room or
bay, where the operator is essentially the only one who enters the zone
of influence, is the most desirable. In any arrangement, pedestrian
traffic past fume hoods should be minimized. Hood location parameters
are detailed in subparagraph 2.c.
c. Hood Location Classification.
"Ideal" (1) End of room or bay, no nearby doors or windows.
(2) Essentially no pedestrian traffic, other than hood operator.
(3) All of the required laboratory hood make-up air drawn or
induced to enhance over-all hood performance. For example,
a properly designed and located perforated ceiling section
or well designed auxiliary air hood plenum.
(4) No other grilles or diffusers exist that produce air at
measurable velocities in the hood area.
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"Good" (1) Not on a main aisle, no nearby doors or windows.
(2) Minimum traffic other than hood operator.
(3) Have air supplied to lab so velocity from diffusers or
grilles does not exceed 25 FPM in vicinity of hood.
"Poor" (1) Any one or more of the above conditions are not met.
d. Additional Specifications and Procedures. Additional specification
and performance evaluation procedures for laboratory fume hoods can be
found in:
(1) EPA Laboratory Fume Hood Specifications and Performance
Testing Requirements, available from the EPA of Occupational Health and
Safety Staff.
(2) U.S. Environmental Protection Agency Facilities Safety
Handbook, Amendment No. 1, available from the EPA Facilities Engineering
and Real Property Management Branch.
3. CLASS II BIOLOGICAL SAFETY CABINET.
The Class II biological safety cabinet is a primary containment device
designed to protect the laboratory work as well as the laboratory worker.
a. Cabinet Function. The Class II biological safety cabinet provides
a blanket of clean air over the work, contains air contaminants in the
work area, and conveys the contaminated air away from the operator.
It accomplishes these functions by combining recirculation with filtration
and exhaust. HEPA filtered air descends over the work surface and splits
at the center. A portion of the downflow air exist through a front air
intake grille, and the balance exits through a rear air exhaust grille.
The downflow air is reunified under the work surface and forced up through
a rear or side positive pressure plenum to the unit's top. Type A (30%)
or Type B (70%) of this air is filtered and exhausted and the balance is
filtered and forced down to blanket the work. The make-up air (30% Type A
or 70% Type B) enters from the room through the front intake grille and
sweeps by and protects the operator. Total exhaust Class II biological
safety cabinets which have recently become available presumably provide
high personnel protection factors.
b. Conditions Affecting Cabinet Performance. The conditions that
affect cabinet performance are essentially the same as the conditions
that affect laboratory hood performance which were presented in detail
in 2.b. above. The operator effect can be particularly pronounced since
the operator's arms interfere with the reci rculating downflow air vector.
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c. Additional Specifications and Procedures. The Occupational
Health and Safety Staff is developing standards for these cabinets using
the EPA laboratory hood standard as a model. Meanwhile, equipment
descriptions, recommended specifications and certification procedures can
be found in the following documents:
(1) Laboratory Safety Monograph, A Supplement to the NIH
Guidelines for Recombinant DNA Research. U.S. Department of Health and
Human Servi ces, Public Health Servi ce, National Institutes of Health,
January 1979.
(2) National Sanitation Foundation Standard No. 49. National
Sanitation Foundation, Ann Arbor, Michigan, 1976.
4. GLOVE BOX.
a. The Glove Box, or Class III cabinet, is a totally enclosed
ventilated cabinet of gastight construction. Operations within this
equipment are conducted through attached rubber gloves. When in use, the
equipment is maintained under negative air pressure of at least 0.5 inches
water gauge. A small volume of supply air, to prevent contamination
build-up, is drawn into the equipment through a HEPA filter and the
exhaust air is treated to prevent the discharge of contaminants in to the
environment. This equipment provides the highest level of personnel and
environmental protection.
b. The Glove Box is generally recommended for the isolation of
procedures involving stock quantities of concentrated toxic substances.
Worker protection can be compromised by puncture of the gloves or accidents
creating positive pressure. Flammable solvents should not be used in
this equipment unless a careful evaluation has been made to determine
that concentrations will not reach explosive levels. When the use is
determined safe, these materials should only be introduced into the glove
box in closed, non breakable containers. These materials should not be
stored in the glove box. Flammable gas should not be piped to this
equipment.
The Class III cabinet is also described in paragraph 3.b.(5) of this
Chapter of the Manual.
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APPENDIX E - SECONDARY CONTAINMENT FACILITIES FOR
HIGHER RISK STIUATIONS
1. PURPOSE. The purpose of secondary containment facilities is to
provide the additional engineering controls for "higher risk situations",
as defined in paragraph 5.b. of Chapter 8 of this Manual, in order to
give added protection against spread of toxic contamination into other
building areas in the event of accidental release of toxic substance
within the containment area. The major components of secondary containment
facilities are described in this Appendix.
2. SPECIAL HANDLING ROOM. The "Special Handling Room" nust be an enclosed
space dedicated for use with the "higher risk situations." this room is
not to be used for other than "higher risk situations" unless rigorous
decontamination is performed. Effluent air from any glove box and fume
hood located in the "Special Handling Room" nust pass through a solvent
resistant HEPA filter and an activated carbon adsorber. No water service
will be permitted in this room. All liquid wastes will be absorbed and
then removed as solid wastes. This Room must be maintained under negative
air pressure in relation to all adjoining areas within the "Containment
Area."
3. LABORATORY WORK AREA. A laboratory work area adjoining the Special
Handling Room must be included in the "Containment Area." This laboratory
work area will be used for moderate risk laboratory operations and may
be used conventional or lower risk laboratory operations when it is not
being used in conjunction with the Special Handling Room for higher risk
situations.
4. CHANGE ROOMS AND SHOWER FACILITIES. Dirty and clean rooms and shower-
out facilities must be provided adjacent to the "Special Handling Room."
Duplicate facilities, for each sex, are encouraged. However, for a small
"Special Handling Room," one set of change/shower facilities will be
acceptable if the entering and exiting doors are electrically interlocked.
5. TOILET ROOM. A toilet room with water closet, lavatory, and manual
internal lock is requi red within the "Containment Area."
6. AIR LOCK. The conveyance of all material and personnel between the
Containment Area and the building corridor nust be conducted through an
airtight vestibule. Containment area must be maintained under negative
pressure in relation to the corridor and adjoining building areas. The
change room and shower facility can serve as the air lock.
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APPENDIX.F - PACKAGING, MARKING, LABELING, AND SHIPPING
OF TOXIC SUBSTANCES USED BY LABORATORIES
1. GENERAL PROVISIONS. These procedures apply to substances considered
toxic for this Manual (identified in Appendix 8-A) which are shipped
between laboratories or the field. Applicable laboratories include any
EPA laboratory or private laboratory under contract with EPA to handle
these toxic substances.
a. Most of the toxic substances identified in Appendix 8-A are not
materials specifically identified in the Department of Transportation (DOT)
Hazardous Material Table (49 CFR 172.101). Any material listed in the
DOT Table should be transported according to the table or according to
applicable DOT packaging exemptions (e.g., a Poison B, n.o.s. can be
packed in Labelmaster, Inc.'s package #38, or Dow Chemical Co.'s Imbiber
Pack for shipment by Unied Parcel Service). Substances that are judged
to be environmental samples should be shipped according to EPA national
guidance (Compliance with Department of Transportation Regulations in the
Shipment of Environmental Laboratory Samples, memorandum by water media
DAAs, available from Occupational Health and Safety Staff).
b. Toxic substances may be transported by rented or common carrier,
truck, bus, railroad, and by Federal Express Corporation* (air cargo);
but they may not be transported by any other common carrier air transport
or even by "cargo only" aircraft other than Federal Express at this time.
c. If toxic substances are transported by any type of government-
owned vehicle, including aircraft, DOT regulations are not applicable.
However, EPA personnel must still use the packaging procedures described
below.
2. PRELIMINARY STEPS. The following procedures should be followed before
toxic substances are shipped:
a. Place a sufficient quantity of the toxic substance in glass
and/or polyethylene containers to determine whether it will react with or
substantially reduce the effectiveness of the container.
b. Pack toxic substances according to "Packaging, Marking, and
Labeling Requirements for Toxic Substances Used by Laboratories."
These procedures are designed to enable shipment by entities like
Federal Express and should not be construed as an endorsement by
EPA of a particular commercial carrier.
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3. PACKAGING, MARKING AND LABELING REQUIREMENTS FOR TOXIC SUBSTANCES
USED
a. Place the toxic substance in a 16-ounce* or smaller glass or
polyethylene container with nonmetallic, teflon-lined screw cap. Allow
sufficient ullage (approximately 10% by volume) so container is not liquid
full at 130°F. If an air space in the innermost container cannot be
tolerated in order to maintain sample integrity, place it within a second
container which provides the required ullage. If collecting a solid
material, the container plus contents must not exceed one pound net weight.
b. For toxic substances which are samples taken in the field, attach
properly completed sample identification tag to sample container.
c. Seal the toxic substance container and place in two-mil-thick (or
thicker) Polyethylene bag, one container per bag. Plastic coated glass
bottles with polypropylene caps, which can satisfy a four-foot drop test,
are currently available which can serve as both the container and
polyethylene bag. (Labels and/or tags should be positioned to enable
them to be read.)
d. Place sealed bag or plastic bottle inside a metal can with
incombustible, absorbent, cushioning material (e.g., vermiculite, coarse
grade to minimize dust), one bag or plastic coated bottle per can.
Pressure-close the can and use clips, nylon reinforced tape, or other
positive means to hold the lid securely, tightly, and effectively.
e. Mark and label this can as indicated in 3.h. below.
f. Place one or more metal cans (or single one-gallon bottle*)
surrounded with incombustible packaging material for stability during
transport, into a strong outside container, such a fiberboard box.
g. Mark and label the outside container and complete shipping papers
(if required) as described in 3.h. below.
* Larger capacity containers, up to one gallon, may be used to toxic
substances with a flash point of 73°F or higher. In this case, such
should be marked on the outside container (carton, etc.) but only a
single (one gallon or less) bottle may be packed in an outside container.
Ten percent ullage and requirements 2, 5, 6, and 7 below must also be
followed. On the shipping papers (if required) state that "flash point
is 73°F or higher.
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h. Marking and labeling. Use abbreviations only where specified
for DOT listed hazardous materials. Place the following information on
strong outside container, either hand printed or in label form:
(Laboratory name and address)
Toxic Substance, Not regulated by DOT (chemical name):
EPA Laboratory Sample
"THIS SIDE UP" or "THIS END UP" should also be marked on the top of the
outside container, and upward pointing arrows should be placed on all
four sides of the exterior container.
i. Shipping Papers. Shipping papers are not required for toxic
substances which are not DOT listed hazardous materials. Regulations for
shipping papers for DOT listed hazardous materials are presented in
49 CFR 172.200-204.
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CHAPTER 9 - HAZARDOUS SUBSTANCES RESPONSES
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS
Policy and Responsibilities I
Program Requirements 2
Work Practices Requirements 3
APPENDIX A - SAMPLE SAFETY PLAN
APPENDIX B - REFERENCES
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CHAPTER 9 - HAZARDOUS SUBSTANCES RESPONSE
I. POLICY AND RESPONSIBILITY.
a. Purpose. This chapter establishes policy and requirements,
and assigns responsibilities for the Agency occupational health and
safety program for EPA employees engaged In hazardous substances responses
(herein referred to as responses).
b. Pol Icy. The EPA is committed to providing safe and healthful
working conditions for EPA employees engaged In responses.
c. Background. EPA Occupational Health and Safety Manual
Chapter 6, Executive Order 12196 and 29 CFR 1960.12 require the EPA
to adopt supplementary standards for application to working conditions
for which there exists no appropriate OSHA standard. The EPA fulfills
this requirement for working conditions at responses by implementing
this chapter. This chapter was originally envisioned as an adaptation of
the "Safety Manual for Hazardous Waste Site Investigations" which was
drafted by EPA's National Enforcement Investigation Center (NEIC) and
further developed by the NEIC, the Hazardous Waste Enforcement Task
Force, and the Occupational Health and Safety Staff (OHSS). This
chapter establishes the agency's program but leaves EPA program offices
to prepare detailed guidance and procedures.
d. Discussion. Response personnel must deal with the risk of
Incurring illness or Injury while conducting responses. They cannot
anticipate every hazard, so they must take precautions to prevent
Illness or Injury to themselves, other workers, and the public.
Since response personnel cannot eliminate risk, they must reduce it
to the lowest feasible level. No set of rules can be uniformly applied
to every situation. The On-Scene Coordinator or Superfund Coordinator
(OSC/SFC) must judiciously apply the requirements of this manual chapter
at each response site (herein referred to as site.) The OSC/SFC must
assess those variables peculiar to each response In order to establish
appropriate safeguards.
e. ResponsibI11 ties.
(I) Assistant Administrators (AA), Regional Administrators (RA),
Laboratory Directors and others designated as Officers-in-Charge (OICs)
are responsible for:
(a) Implementing the requirements of this chapter for responses
conducted by employees of their reporting unit, and all establishments
and workplaces within their area of jurisdiction.
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(b) assuring that any OSC/SFC conducting a response, and other
involved programs and support staff, are qualified by training or experience,
have the equipment to conduct the response safely, and plan a response
which is safe to all concerned.
(c) assuring the completion of annual program evaluations.
(See Paragraph 2.b. of this Chapter.)
(2) Safety Committee. The OIC will establish a specialized Response
Safety Committee, consisting of EPA employees who do perform on-site
activities, that is consistent with Chapter 5 of this Manual.
(a) aiding and advising the OIC on policies and requirements
for the reporting unit's occupational health and safety program for
responses; and
(b) reviewing site-specific or generic Safety Plans (See 2.a.)
prepared by OSCs/SFCs and forwarding them to the OHS Designee. The
Response Safety Committee does not have approval authority.
(3) Occupational Health and Safety Designee (OHS Designee). The
OHS Designee:
(a) is responsible to the OIC for developing, organizing,
directing, and evaluating the occupational health and safety program for
responses; and
(b) is responsible for coordinating accident reporting, record-
keeping and often the medical monitoring program. (See Chapter 1, Para-
graph 3, of this Manual for a detailed description of the OHS Designee's
occupational health and safety responsibilities.)
OHS Designees must either have background and training in recognizing,
evaluating, and controlling hazards at responses or have access to this
expertise.
(4) On-Scene Coordinator or Superfund Coordinator (OSC/SFC). The
OSC/SFC is responsible for:
(a) selecting the level of personnel protection needed for
use at a response and assuring that the necessary personal protective
equipment is available before EPA employees are allowed to work on-site;
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(b) selecting safe work practices and other controls at
responses;
(c) preparing site specific or generic safety plans and
any needed detailed procedures; (See Paragraph 2.a. of this Chapter
for requirements, and Appendix A for a Sample Safety Plan.)
(d) submitting site specific safety plans to the Response Safety
Committee for Its review; submitting the generic safety plan to the Safety
Committee for its review well in advance of emergency responses;
(e) making copies of the approved safety plan available to
all affected program and supporting EPA personnel and provide copies to
those employees participating in specific responses;
(f) assuring that EPA employees are trained and certified In
the work practices required to ensure safety, and are Informed of the
hazards associated with the response before they are allowed to work
on-sfte (In compliance with EPA Order 1440.2, Paragraph 9);
(g) assuring that EPA employees are Included In the EPA
Occupational Medical Monitoring Program and have undergone a baseline
medical examination before they are allowed to work on-slte (In compliance
with EPA Order 1440.2, Paragraph 12);
(h) designating, If support Is needed, one member of the response
team as the Site Safety Officer, and assuring that that person fulfills
alI responsibilities necessary for safe operations;
(I) supervising the safety performance of the staff to ensure
that the required work practices are used;
(j) arranging for immediate medical attention for any Incident
that results in injury or overt exposure of personnel to hazardous
substances, and reporting the incident to the OHS Deslgnee;
(k) assisting the OHS Deslgnee In Investigating accidents;
(I) Investigating, and reporting in writing to the OHS Deslgnee,
any problem pertaining to operation and implementation of safe work
practices;
(m) correcting work errors and conditions that may result in Injury
or exposure to hazardous substances;
(n) assuring safe and healthful working conditions for all EPA
employees at the response; and
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(o) informing non-EPA employees of the hazards and appropriate
measures to assure safe and healthful working conditions for these
employees.
(5) Site Safety Officer. The Site Safety Officer, if one is designated,
is responsible for implementing the Safety Plan at the site.
(6) Employees. Employees are responsible for:
(a) complying with the occupational health and safety program
established by this chapter for responses;
(b) reporting to their supervisors, or the Site Safety Officer,
any unsafe condition and all facts pertaining to Incidents whtch resulted
in employee injury or exposure to hazardous substances;
(c) reading and understanding the site-specific or generic
Safety Plan;
(d) carrying out responses in accordance with the s!te-*-$pecI f Ic
or generic Safety Plan; and
(e) participating In the medical monitoring program when this
Is a formal condition of employment. (Employees are afforded certain rights
such as requesting Inspections of working conditions and commenting on
Agency safety standards. See Chapter 2, Paragraph 5, of this manual for
a detailed description of employee rights.)
(8) Director,Occupational Health and Safety Staff, Under the
supervision of the Director, Office of Administration, the Director,
Occupational Health and Safety Staff, Is responsible for:
(a) reviewing and coordinating the occupational health and safety
programs developed by OICs for responses for consistency with this chapter
(See I.e. (I).);
(b) evaluating responses for compliance with Agency policy and
requirements;
(c) informing responsible EPA officials of any problem areas;
(d) providing technical support;
(e) approving safety training courses; and
(f) establishing medical monitoring program requirements.
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The Director, OHSS, Is the top technical advisor for EPA on occupational
health and safety issues for responses.
2. PROGRAM REQUIREMENTS
a. Site-Specific and Generic Safety Plans. The OSC/SFC must
prepare and obtain approval of a site-specific or generic safety plan
(See Appendix A for a sample). Only one generic safety plan, prepared In
advance and reviewed annually, is needed for all emergency responses.
The Response Safety Committee must review the safety plans and forward
them to the OHS Designee with comments. The OHS Designee and the QIC
must approve the safety plans. The OHS Designee must maintain the safety
plans on file and available for distribution and forward Information
copies to the Director, OHSS. The OHS Designee must keep the safety
plans, and other information describing the hazards of responses In a
file that is readily available to employees.
b. Eva Iuation. The QIC must ensure that annual program evaluations,
including on-slte inspections, of the occupational health and safety
program for responses are conducted by persons with appropriate background
and training, and that any deficiencies are corrected as soon as possible
(or Immediately If the deficiency Is an imminent hazard). The OIC must
forward a copy of the evaluation and abatement actions to the Director,
OHSS, for review. The Director, OHSS, may conduct independent evaluations.
c. Accident Reporting. The OHS Designee must coordinate the
reporting of any incident involving injury or exposure to a hazardous
substance in accordance with the procedures detailed in Chapter 3 of this
manual.
d. Tralning. The OIC must ensure that alI employees receive a
minimum of 24 hours of occupational health and safety training and
receive training by three days of field experiences with an experienced
employee before conducting responses. The OHS Designee must issue a
certificate to employees upon completion of the courses and field
experiences. EPA Order 1440.2, "Health and Safety Requirements for
Employees Engaged in Field Activities", provides detailed training
requirements.
e. Emergency Procedures^. The OSC/SFC must develop procedures
to protect personnel Fn case of emergencies at the site. The procedures
should include notifying emergency and other affected personnel and the
locations and telephone number of the nearest emergency medical facility,
ambulance service, fire department, police department and Poison Control
Center. The locations and telephone numbers of these emergency support
groups should be compiled in advance, if possible, of a response or
on-site at an early stage of a response.
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f. Medical Monitoring. All EPA employees working on site at a
response must be included in the EPA medical monitoring program.
In addition, EPA employees must have undergone a baseline medical
examination which provides a base to measure adverse health effects of
response activities and indicates that these employees are physically
capable of using physically demanding personal protective equipment.
EPA Order 1440.2 "Health and Safety Requirements for Employees Engaged
i n Fi eld Activities" provides medical monitoring objectives and require-
ments; EPA Medical Monitoring Guidelines provides detailed requirements
of the program.
3. WORK PRACTICES REQUIREMENTS
The work practices specified in this section nust be used by all personnel
at responses.
a. Personnel Practices.
(1) Protective Clothing. Protective clothing mist be worn by
all personnel while on a response unless sufficient data have been acquired
to enable the OSC/SFC to make an informed judgement that protective
clothing is not needed. In the absence of clear indications that work
can proceed safely without protective clothing, required items includes
chemically resistant pants, jacket, boots, gloves, and hard hat or head
cover, and may include a fully encapsulating chemical protective suit.
Acquisition of protective clothing and equipment must be in accordance
with EPA Order 3100.1, Uniforms, Protective Clothing and Protective
Equipment.
(2) Use of Respiratory Protective Equipment. A respiratory
protective equipment use program must be provided for response personnel
who enter inhalation hazard areas. The program nust meet the requirements
of the OSHA standard for respiratory protection, 29 CFR 1910.134, and
EPA Order 1440.3 "Respiratory Protection." OHSS has provided additional
guidance in the "Respiratory Protection Program Guideline," available
from OHSS.
(3) Heat Stress. The OSC/SFC must establish a work/rest sche-
dule to compensate for increased heat stress caused by wearing protective
clothing in hot weather. Employees must maintain this work/rest schedule
and replace perspired water and salt.
(4) Eye Protection. Devices to provide appropriate eye protection
must be worn on any response while in the contamination and decontamination
zones (See Paragraph 3.b.(a) of this Chapter.) and nust meet the require-
ments of EPA's Eye Protection Program Guidelines.
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(5) Forbidden Practices. The following practices are forbidden on
sites in the contamination and decontamination zones (See 3,b.(a)):
(a) Smoking, eating, drinking, chewing gum or tobacco;
applying cosmetics; storing utensils, food, or food containers.
(b) Ignition of flammable liquids within, on, or through
improvised heating devices (barrels, etc.) or space heaters.
(c) Approach or entry into areas or spaces where toxic
or explosive concentrations of gases or dust may exist without wearing
proper equipment to enable safe entry.
(d) Conduct of on-site operations without off-site backup
personnel. (The OSC/SFC may waive the requirement for off-site backup
personnel for sites which have been repeatedly entered without harm or
present minimal hazards.)
(6) Emergency Procedures. All personnel mist initially flush the
affected area with a copious amount of water immediately after obvious
contact with a hazardous substance.
(7) Personal Hygiene. All personnel, except for observers and
others designated by the OSC/SFC, must shower before entering clean
areas after having been in contaminated areas. If it is not feasible to
have shower facilities available, such as for some emergency responses,
personnel nust avoid contaminating the community after leaving the site
and shower at their first opportunity.
b. Operational Practices.
(1) Information Review and Reconnaissance. The safety plan for
a response must be based upon a thorough evaluation of existing data and
a site reconnaissance (See "Waste Disposal Site Hazard Assessment Manual,"
available from NEIC.) and should include a site map. The information
may reveal chemical hazards such as incompatible chemicals, toxic gases,
explosives, etc. Similarly, a perimeter inspection, aerial imagery, and
an on-site reconnaissance, may reveal safety hazards. Response personnel
will be able to specify more appropriate safety precautions as they get
closer to, and measure, hazardous substances in air, runoff, groundwater,
soil, spilled material, barrels, etc.
(2) Protection Levels. The OSC/SFC must determine the level
of protection which is appropriate for each response.
(3) Zones. Two or more zones must be established, clearly
delineated, and posted at a site.
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(a) Decontamination Zone. A zone must be established for
decontamination of equipment and personnel, and access control, just
outside the area of suspected contamination. At least one employee
wiI I remain in this zone to:
J_ Assist in emergency removal of personnel from the site
in the event of accident or injury. The backup must have readily available
protective clothing, breathing apparatus and first aid equipment.
2_ Assist in moving equipment, samples, and supplies.
_3 Provide communication to emergency units.
_4_ Assist in decontamination or removal of contaminated
clothing from the Individuals emerging frcm the contaminated area.
_5_ As appropriate, prevent entry of unauthorized persons
to the site while operations are underway.
6_ Provide other assistance as necessary, but with the
primary objective of facilitating safe transfer of personnel and equipment
to and from the affected area.
(b) ContamInat i on Zone(s). The area(s) which contain, or are
suspected of containing, hazardous substances must be clearly delineated
and posted. The OSC/SFC may establish more than one contamination zone
for areas of different levels of hazard. Only persons authorized by the
OSC/SFC may enter a contamination zone.
(4) Radioactivity, Explosivity, and Oxygen Deficiency. AlI sites
must be checked for radioactivity, explosivity, and oxygen deficiency
during first entry unless OSC/SFC has information to determine that
these checks are unnecessary. Normal background radioactivity is
approximately 0.01 to 0.02 mR/hr. Detecting levels of activity signifi-
cantly greater than normal background Is cause for a very careful survey
of the entire site; if levels approaching 2 mR/hr are encountered, the
advice of a competent health physicist must be sought before continuing
operations on the site. (EPA's Office of Air and Radiation has radiation
specialists in each Region as well as staff at HQ, EER-Montgomery and
ORD-Las Vegas.)
If explosivfty readings greater than 10$ of the Lower Explosive Limit
(LED are detected, very careful survey of the area must be made. Readings
approaching or exceeding 25$ LEL are cause for Immediately withdrawing
personnel and notifying emergency, fire, and explosion units. The Project
Leader must be consulted before continuing operations. Oxygen levels
must be 19.5$ or greater.
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(5) Buddy System. A minimum of two employees, in constant
communication* with each other, are required to perform any work in
contaminated zones.
(6) Sampling Procedures. Sampling procedures must minimize the
risk of personnel exposure to hazardous materials during sampling,
packaging, shipping, unpacking, and analysis in the laboratory. Sampling
procedures must also minimize the risk of exposure of others to spilled
or residual waste materials. Disposable sampling equipment should be
used whenever possible.
(7) Sample Handling in Laboratories. Samples of runoff, ambient
air, or groundwater from a site or possibly affected areas may be moved
directly into laboratories and handled with normal safety precautions
unless the OSC/SFC determines that special handling is appropriate.
Samples of liquid or solid substances removed from containers or obviously
contaminated spill areas must be assumed to be toxic substances and
handled in compliance with Chapter 8 of this Manual.
(8) Respiratory Protective Equipment Selection. The OSC/SFC must
select respirators which are appropriate for the inhalation hazards of
the responses.
(9) Sampling Equipment. Sampling equipment used on a response
should be disposable if possible. Sampling instruments and other non-disposal
equipment should be kept clean with disposable protective covers. Scoops,
sampling tubes, and similar devices should be buried on-site, or placed
in plastic bags for disposal or later decontamination.
(10) Decontamination of Equipment. Equipment should be decontaminated
prior to leaving the site whenever possible. Equipment which cannot be
decontaminated at the site must be double bagged and transported to
another area for eventual decontamination. When possible, verify complete-
ness of decontamination with sniffers, swipe tests, or other appropriate
tests.
(11) Packaging and Shipping. Hazardous substances must be packaged to
withstand shocks, pressure changes, and any other conditions which might
cause the leakage of contents incident to ordinary handling during
transporation. Shipments of hazardous substances must be in accordance
with DOT regulations. (See Appendix B of this Chapter for guidance.)
* Radio contact must be maintained when visual contact cannot be maintained.
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(12) Leaving the Site. Procedures for leaving the suspect contami-
nated area must be planned before entry. Provision must be made for:
decontamination and safe packaging of protective clothing; burial or
safe packaging of disposable gear; handling of samples and preparation
of samples for shipment; transfer of equipment, gear, and samples from
the "contaminated" area to the "clean" area; etc. Sequences wiI I depend
on several variables — such as self-contained breathing apparatus
inside or outside of protective clothing — but must be worked out in
advance.
(13) Site Monitoring Equipment. Use direct reading instruments
(such as portable combustible gas and oxygen meters, photoionIzation
meters, gas chrcmatographs, infrared spectrometers, radiation survey
meters, and colorimetric detector tubes) for immediate evaluation of
potential hazards. The OSC/SFC must be aware of the limitation of these
instruments for characterizing the hazards substances at the sites.
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APPENDIX A - SAMPLE SAFETY PLAN
Assistance In preparing the safety plan can be obtained from the OHS
Designee located In Room of Bui I ding __ or
by telephoning .
REV IEW
Response Safety Committee Chairperson
APPROVALS
OSC/SFC
OHS Designee
QIC
PROJECT LEADER
Branch
Bu11di ng
Room
Phone
DATE OF PLAN PREPARATION
HAZARDOUS SUBSTANCE RESPONSE
Site Name Site No.
HAZARDOUS/SUBSTANCES (known or suspected, contamfnat ad
or in storage container, etc,,):
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HAZARD ASSESSMENT (icxlc effects, reactivity, stability, flammabiIity,
and operational hazards with sampling, decontaminating, etc.):
MONI TOR ING PROCEDURES (If required by the Project Leader)
Monitoring the site for identity and concentration of contamination
in all media:
Medical monitoring procedures for evidence of personnel exposure:
Personnel monitoring procedures:
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DECONTAMINATION AND DISPOSAL
Decontamination Procedures (contaminated: personnel surfaces,
materials, Instruments, equipment, etc):
Disposal Procedures (contaminated equipment, supplies, disposable,
washwater):
EMERGENCY PROCEDURES
In event of overt personnel exposure (skin contact, Inhalation,
IngestIon):
In event of personnel Injury:
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In event of potential or actual fire or explosion:
In event of potential or actual ionizing radiation exposure:
In event of environmental accident (spread of contamination
outside sites):
EMERGENCY SERVICES (complete here or have separate listavailable on-slte)
Location TeIephone
Emergency Medical Facility
Ambulance Service
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Location Telephone
Fire Department
Police Department
Poison Control Center
PERSONNEL POTENTIALLY EXPOSED TO HAZARDOUS SUBSTANCES
Personnel Authorized to Enter site
2.
3.
4.
5.
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Other Personnel Assigned to Handle Hazardous Substances
(decontaminate, analyze samples)
2.
3.
4.
5.
ALTERNATIVE WORK PRACTICES
(Describe alternative work practices not specified in this Chapter.
Indicate work practices specified in the Chapter for which proposed
alternative work practices will serve as substitute.)
APPROPRIATE LITERATURE CITATIONS
LEVEL OF PROTECTION
SITE MAP
(Attach a site map in advance of a response, if possible, or at
an early stage of an emergency response. Map should be properly scaled
and keyed to local landmarks.)
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APPENDIX B - REFERENCES
U.S. EPA: National Guidance Package for Compliance with Department
of Transportation Regulations in the Shipment of Environmental
Laboratory Samples, U.S. Environmental Protection Agency (March 6,
1981).
B-1.
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CHAPTER 10 - EPA DIVING SAFETY POLICY
Table of Contents
PARAGRAPH PARAGRAPH
TITLES NUMBERS
Purpose 1
S c op e 2
Administration 3
Policies 4
Diver Training and Certification 5
Di vi ng Operations 6
APPENDIX 10-A - EPA DIVING SAFETY RULES
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CHAPTER 10 - EPA DIVING SAFETY POLICY
1. PURPOSE. This Chapter establishes Agency policy regarding commercial
diving operations in accordance with Department of Labor, Occupational
Safety and Health Administration regulations at 29 CFR 1910, Subpart T.
Its purpose is to assure that all diving operations, performed under the
auspices of EPA, are conducted in a safe manner, according to uniform
procedures, and by sufficiently trained personnel. This Chapter establishes
Agency procedures for developing and administering such standard safety
practices.
2. SCOPE. The requirements and procedures specified in this Chapter
shall apply to all diving operations involving any project of the Agency
and carried out by any employee, either temporary or permanent, of the
Agency during the course of his/her employment. In addition, these
requirements shall also apply to any visiting non-Agency employee engaged
in a joint diving operation at, or under the auspices of, any Agency
facility to the extent that this person is not governed by comparable
requirements of the Agency or institution that he/she represents. This
Chapter applies, regardless of ownership of equipment, and any equipment
used in conjunction with Agency diving operations regardless of ownership,
shall conform to the provisions of this Chapter. This Chapter shall
apply to any type of open circuit SCUBA diving operation, including but
not limited to: research projects, monitoring projects, sample collections,
or equipment maintenance, with the only exception being the handling of
an actual emergency situation. It is not the intent of tnese provisions
to delay or hamper an actual rescue operation; therefore, it is the
responsibility of the Unit Diving Officer or Dive Supervisor at the
scene to determine the ultimate course of action during a particular
emergency and by doing so, must not aggravate the situation or jeopardize
the safety of additional personnel.
3. ADMINISTRATION. The Assistant Admi nistrator for Admi ni strati on and
Resources Management broadly administers the Agency's Diving Safety
Program through the Occupational Health and Safety Staff (O'ISS).
a. Designation. The Occupational Health and Safety Staff, upon
the advice of the EPA Diving Safety Committee, shall administer the
Agency's Diving Safety Program and coordinate safety policy and
procedures.
b. EPA Diving Safety Committee.
(1) Composition. The EPA Diving Safety Committee shall be
composed of the following members:
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(a) Chairperson selected or voted on by Committee Members;
(b) Active EPA Diving Officers; and
(c) OHSS Safety Programs Manager.
(2) Revisions. All recommendations for revisions of the regu-
lations must be agreed upon by the EPA Diving Safety Committee.
(3) Responsibilities. The EPA Diving Safety Committee shall
be responsible for:
(a) Recommending policy and changes in operating procedures
within EPA that will ensure a safe and efficient diving program;
(b) Reviewing existing policies, Procedures, and training
needs to ensure a continually high level of technical skills and know-
ledge throughout the EPA diving program;
(c) Planning, programming, and directing, in cooperation
with the OHSS, matters of policy pertaining to the initial certification
of new divers and refresher training of experienced divers;
(d) Recommending changes in operating policy to the Director,
Occupational Health and Safety Staff, the Assistant Admi nistrators, and
Regional Administrators;
(e) Serving as an appeal board in cases where a diver's
certification has been suspended;
(f) Planning, programming, and developing diver workshops,
seminars, and other activities considered essential to maintaining a
high level of competency among divers;
(g) Reviewing EPA diving accidents or potentially dangerous
experiences and reporting on preventive measures to ensure the avoidance
or reoccurrence of incidents; and
(h) Meeting, at least, annually to discuss recommendations
and proposed actions.
In addition, members may participate in the Safety Officer/Designees
Annual Meeting.
c. Diving Safety Committee Chairperson. The Committee wi11 select or
vote for a chairperson to represent them and act as focal point on all
EPA divi ng activi ties.
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(1) Qualification. The Chairperson shall:
(a) Be a trained diver with a wide range of experience;
(b) Be a currently certified EPA diver;
(c) Have a least 5 year's experience as a diver; and
(d) Have successfully completed a nationally recognized
instructors certification course or its equivalent.
(2) Responsibilities.
(a) Issue through OHSS, EPA Diver Certification to quali-
fied employees based on recommendations and data from the unit diving
officer;
(b) Coordinate with OHSS, and the Diving Safety Ccmnn'ttee
training certification and other safety programs for divers;
(c) Confer with the OHSS Industrial Hygiene Manager on the
approval and use of specialized breathing apparatus or mixture of gases;
(d) Review and initiate through OHSS, appropriate action
on recommendations made by the Diving Safety Committee; and
(e) Remain abreast of new diving techniques, procedures
and equipment.
d. Unit Diving Officer.
(1) Designation. Unit Diving Officers shall be selected from
various EPA installations which conduct diving operations. These diving
officers shall be appointed by the installation director.
(2) Qualifications. The Unit Diving Officer shall be a trained,
currently certified diver experienced in the types of diving conducted
by the organizational unit.
(3) Responsibilities. The Unit Diving Officer shall be responsi-
ble, within the unit, for:
(a) Ensuring that all diving gear and accessory equipment
be maintained in a safe operating condition;
(b) Ensuring the maintenance of equipment files at the
reporting unit levels, to include type, brand name, serial number, and
repairs completed on compressors, tanks, regulators, depth gauges,
pressure gauges, watches, helmets, hoses, pneunometers and decompression
meters;
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(c) Ensuring that a competent Dive Supervisor is in charge
of the diving operations conducted by the unit's various operations;
(d) Reporting immediately all diving related accidents
which occur within the unit on EPA Form 1440-9 and other appropriate
accident reports as outlined in Chapter 3 of this Manual to the
Occupational Health and Safety Staff through the local Safety Officer/
Designee;
(e) Maintaining a file of each diver in the unit, or dele-
gating the responsibility to the Dive Supervisor. Files shall include
but not be limited to: diving physical exams (subject to the requirement
of the Privacy Act of 1974), training records, letters of certification,
and monthly dive logs, etc; and
(f) Dive plan/log information.
e. Dive Supervisor.
(1) Designation. Depending on the unit organization, a Dive
Supervisor will be assigned for each operation by the Unit Diving Officer
(2) Qualification. The Dive Supervisor shall be a currently
certified diver experienced in that specific type of diving.
(3) Responsibilities. The Dive Supervisor shall be in complete
charge of the individual diving operation as a member of the dive team
at the location of the dive, and shall be responsible for and ensure
that:
(a) All diving operations are conducted safely in accord-
ance with prescribed EPA diving safety rules and regulations;
(b) All divers are certified, properly trained, and
physically fit to perform the required diving, and that the prescribed
files on the divers are maintained if the responsibility has been
delegated by the Unit Diving Officer;
(c) All equipment is in a safe operating condition, and
that the required records are maintained as directed by the Unit Diving
Officer;
(d) Dives are terminated when, in The Diver Supervi sor's
opinion, significant cant environmental, personal, or equipment problems
are encountered and emergency aid is summoned;
(e) Emergency procedures are understood by all personnel
prior to diving;
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(f) All divers are monitored after each dive for symptoms
of decompression sickness; and
(3) He/she is knowledgeable in the dive plan and overall
operation to be performed.
f. Individual Diver.
(1) Designation. Individual divers shall be certified by the
EPA Diving Safety Committee Chairperson upon recommendation from the Unit
Divi ng Officer.
(2) Qua! ifications. Divers shall be sufficiently trained to
undertake the assigned diving tasks.
(3) Responsibilities. The individual diver shall be responsible
for and ensure that:
(a) A good physical condition and a high level of diving
proficiency are maintained;
(b) The equipment is in a safe operating condition;
(c) Diving conditions are safe; and
(d) The dictates of training or diving regulations are not
violated.
g. Tender.
(1) Designation. The Dive Supervisor will select the Tender
to be used for a specific dive. The Tender's name will appear on the Dive
Plan/Log and will, therefore, be approved beforehand by the Unit Diving
Officer.
(2) Qual ifications. The Tender need not be a currently EPA
certified diver, but must, in the opinion of the Dive Supervisor and the
Unit Diving Officer, have sufficient knowledge of basic first aid,
swimming, life saving, boat operation and other procedures to be used in
an emergency.
(3) Responsibilities. The Tender will perform the following:
(a) Assist the divers, as requested, in putting on or
taking off equipment;
(b) Record in writing the "down" and "up" times of all
divers on the team;
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(c) Maintain a constant visual observation of the diver's
exhaust bubbles and,
_1 warn off boat traffic which may pose a hazard to
the submerged divers;
2_ in larger vessels, advise the vessel operator as
to the location of the divers and their readiness for being retrieved;
(d) Assist the divers, as requested, in exiting the water;
and
(e) Perform no other concurrent function which will inter-
fere with the conduct of the above duties.
4. POLICIES.
a. Individual Diver Responsibility. Each diver has the responsibility
and privilege to refuse to dive if diving conditions are unsafe or unfavor-
able; if at any specific time, the diver feels that he or she is not in
good physical or mental condition for diving; or if by diving, the diver
would violate the dictates of training or these regulations. The conditions
and reasons for refusing to dive may be required to be documented. If
requested the incident will be reviewed by the officer in charge of the
Reporting Unit with the Unit Diving Officer and diver, and appropriate
action may be taken. Any action resulting from this review may be appealed
to the EPA Diving Safety Committee.
b. SCUBA Diving Teams. Except under emergency conditions, the buddy
system of at least two (2) divers will always be required. In the event
that diving is shallow within a restricted area, with water conditions
of low velocity and turbidity, the buddy diver may remain at the surface
fully equipped, maintaining visual, verbal and/or physical contact with
the working diver at all times. A surface attendant shall be in the
immediate area any time diving conditions require it.
c. Diver Proficiency. EPA certified divers should complete and
record an average of at least two (2) diving days per month. Any time
six (6) weeks or more elapses without a dive, the diver should complete
a requalifying program. Any time three (3) months or more elapses without
a dive, the diver must complete a requalifying program before resuming
work dives. The EPA Diving Safety Committee Chairperson, with the advice
of the Diving Officer or designee, shall specify the requalifying program.
This requirement may be waived by the official in charge of the project,
program, or Reporting Unit during emergency conditions. A memorandum
requesting such a waiver rrust be submitted to the Director, Occupational
Health and Safety Staff, through the Unit Diving Officer for review by
the EPA Diving Safety Committee. Supervisors will authorize the necessary
time and payment for qualifying dives if diving is required for official
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program activities. Diving equipment will be available during non-duty
hours for purposes of maintaining diver proficiency.
5. DIVER TRAINING AND CERTIFICATION.
a. Training.
(1)
completed a
Basic. All prospective EPA divers must have successfully
basic diver training course offered by one of the nationally
recognized private agencies (e.g. NAUI, PAD I, YMCA, NASDS) or by the
U.S. Navy. Training courses given by colleges or universities must be
approved for content by the EPA Diving Officer before being accepted
for this requirement.
(2) National Oceanic and Atmospheric Administration (NOAA)
Trai ni ng. All working divers, senior divers and diving instructors
shall attend the NOAA "Diving Accident Management" class within 1 year
of adoption of this Chapter.
b. Medical Requirements.
(1) Prior to acceptance for initial diver training or certifi-
cation, and annually thereafter, each diver shall be required to undergo
a diving physical examination. The individual diver shall provide the
examining physician with the following listed NOAA medical forms, as
appropriate, in order to ensure an examination appropriate to diving
activities:
(a) NOAA Form 64-5, Part I, Medical Evaluation Criteria;
(b) NOAA Form 64-5, Part II, Diving Fitness Medical
Evaluation Report;
(c) SF-78, Certification of Medical Examination (Civilian
Personnel);
(d) SF-88, Report of Medical Examination (Commissioner
Personnel); and
(e) SF-93, Report of Medical History.
(These forms are available from the local Safety Officer/Designee.)
(2) Upon receipt of the completed medical documents from the
examining physician, the individual diver is responsible for distribution
of these forms as follows:
(a) Forward signed originals of SF-78 to the EPA Diving
Safety Committee Chairperson through the Unit Diving Officer, with copies
to OHSS;
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(4) A written statement of the Unit Diving Officer's evaluation
of the overall qualifications and performance of the prospective diver;
(5) An EPA certification issued by the Unit Diving Officer
in one of the following categories:
(a) Trainee Diver. A diver who has completed a basic
SCUBA diver training course but has performed fewer than 15 open water
dives. Diver Trainees may not be paired together to form a dive team nor
may they perform working dives. They may accompany a working diver as a
buddy on dives involving a simple task, at the discretion of the Unit
Diving Officer.
(b) Working Diver. A diver who has completed a least
15 open water dives, but who otherwise may have limited or infrequent
experience or at the judgment of either the EPA or Unit Diving Officer
should be restricted in his/her activities. A limited diver may perform
working dives within his/her restriction or abilities.
(c) Senior Diver. A diver who has demonstrated a high
level of competence, good judgment, and considerable experience and who
has logged at least 100 dives. The senior diver shall be capable of
serving as the Dive Supervisor on a given dive.
(6) At the recommendation of the Unit Diving Officer, along
with supporting documentation, the EPA Diving Safety Commi ttee Chai rperson
will issue new classifications as appropriate.
d. Reciprocity. In order to encourage and facilitate joint operations
between EPA facilities and neighboring colleges, universities, private
institutions, or other government agencies, the Unit Diving Officer may
approve such dive plans upon inspection of the credentials of the prospec-
tive non-EPA diver, providing the criteria for certification of that
diver by the institution he/she represents is comparable to those in
this Manual. The visiting diver nust also have permission from his/her
diving officer and must be covered by an accident insurance plan by
his/her institution. Questions in this matter should be directed to the
EPA Diving Safety Committee.
6. DIVING OPERATIONS.
a. Certification. Each diver who is an employee of the U.S. Environ-
mental Protection Agency must have an EPA certification at the level of
the dive being conducted. Each non-EPA diver engaged in a dive under the
auspices of any EPA facility must have a certification comparable to EPA
certification from the institution he/she represents on file with the Unit
Diving Officer.
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b. Limits.
(1) All dives shall employ open circuit SCUBA using ccmpressed
air unless otherwise specifically approved by the Unit Diving Officer
i n writing.
(2) All dives shall be within the no decompression limits as
specified in the U.S. Navy Decompression Tables. When there is a need
for dives beyond this limit the dives must be approved in advance
by the Diving Safety Committee.
(3) No solo diving will be permitted.
(4) No diving will be conducted without the submittal and
authorization of a Dive Plan.
(5) No dive exceeding the 130 foot depth will be permitted in
the absence of a working decompression chamber attended by trained
personnel.
(6) Cave and under ice diving will generally not be permitted.
Submit all requests for special dives to the Unit Diving Officer and
forward copies to the Diving Safety Committee Chairperson.
(7) Dives in waters of great depths, where the diver is not in
visual contact with the bottom (over bottom dives) and where a diver
could lose his/her orientation or descend beyond safe limits, will be
conducted with some provision for direct contact with the surface such
as a buoyed weighted line with depth markings.
c. Dive Teams. A standard SCUBA diving team shall consist of a
minimum of three members: the Dive Supervisor, the diver buddy, and the
Tender. Some situations may require a third diver in the water, but at
no time shall any diver in the water lose visual or tactile contact with
at least one other diver. If such contact is lost, all divers must
immediately surface. In the situation requiring diving from a boat, the
vessel operator's principle responsibility is for the safety of his/her
vessel and its occupants. Hence, depending on the size of the vessel
and the conditions, it may be deemed inappropriate by the Unit Diving
Officer, the Dive Supervisor, or the vessel operator, for the latter to
serve also as the Tender. When this is the case, the Dive Supervisor
will advise the vessel operator as to the safety precautions specified
in this Chapter. At the discretion of the Unit Diving Officer, a single
diver may enter the water if line tended from the surface. However, a
fully equipped stand-by diver mist be at the dive site ready to give
immediate assistance.
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d. Equipment. All items of equipment shall be visually and opera-
tionally inspected before each actual use and mist be in proper operating
condition. All dive team members shall be familiar with their use. The
following equipment shall be present at the dive site for all dives.
(1) Personal equipment.
(a) Flotation/Buoyancy Compensation Device - Each diver
must wear an adequate flotation device capable of being filled by at
least two methods.
(b) Tank Harness and Weight Belts - must have a quick
release mechanism.
(c) Tank Pressure Gauge - must be worn at all times and
monitored frequently.
(d) Depth Gauge - shall be worn by each diver when diving
in unfamiliar territory, at unknown depth, in areas of great tidal
fluctuation, in areas of uneven bottom, or under any other conditions
which might cause the diver to exceed his/her planned depth. It is
recommended that a depth gauge be worn during all diving operations.
(e) Diving Watch - shall be worn by each diver in situations
where there is any likelihood of exceeding the no decompression limit.
(f) Decompression Meter - shall not be used in lieu of
proper planning of the dive and timekeeping at the dive site.
(g) Compass - shall be worn by each diver. Divers can
become disoriented in direction at any depth.
(2) Support Equipment.
(a) Dive Flag - an appropriate dive flag shall be shown at
all times. This is especially critical while actively diving in areas
subject to boating or other hazardous traffic or when required by local
regulation. An appropriate dive flag is a square red flag with a white
diagonal stripe at least 12" square (depending on the size of the
vessel) in all waters except those frequented by international traffic.
In this case, the international code flag "Alpha" will be used in
addition to the dive flag. In any case, divers will make every effort
to avoid diving in areas in which traffic would cause a safety hazard.
(b) First Aid Kit - shall be approved by the Unit's
physician who performs the annual physicals. A copy of the American
National Red Cross publication. Standard First Aid and Personal Safety
shall be included and a copy of the NOAA/Sea Grants Book, First Aid for
Boaters and Divers. Also emergency oxygen should be on board.
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(c) Ladder - shall be provided when diving from a vessel,
dock or other surface where elevation above the surface of the water
presents a difficulty to the diver. The ladder must extend sufficiently
below the surface of the water to support the diver while still in the
water.
(d) Safety Plan - a copy of this Diving Safety Chapter,
the U.S. Navy Decompression Tables and emergency aid information shall
be present at each dive site.
(e) Communications - at each dive site, shore or vessel,
located beyond the range of other reasonable voice communication, a
2-way radi o wi 11 be provided for use in summoning emergency aid.
(f) Additional support tanks - should be on board and be
available.
(g) Underwater transponder/comnunicator should be on
board.
e. The Dive PI an/Log. Divers are required to log all dives. The
EPA Diving Plan/Log will be initiated by the prospective Dive Supervisor
desiring to conduct a dive and submitted to the Unit Diving Officer for
approval. After the dive is completed, details of the dive will be
recorded and the Dive Supervisor will certify that the regulations of
the Manual were adhered to and submit it each month to the Unit Diving
Officer.
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APPENDIX A - DIVING SAFETY RULES
1. Certification. Each diver nust have a valid EPA certification or
EPA equivalent.
2. Solo Diving. No one may dive unattended.
3. Depth Limits. Dives shall not exceed 130 feet. Proposals for planned
dives to depths greater than 130 feet will require written approval by
the Unit Diving Officer or designee.
4. Decompression Tables. Decompression tables should be copied for use
by a photographic method which reproduces an exact copy. If this method
is not available, then the hand copied schedules should be checked for
accuracy and signed by several persons.
5. Decompression Dives. Diving activities which exceed the limits of
no-decompression must be approved in advance by the EPA Diving Committee.
6. Over-Bottom Dives. Dives in waters where a diver could sense a loss
of orientation or descend below safe diving depths are to be considered
over-bottom dives. No over-bottom dives shall be made unless some direct
contact with the surface is maintained, such as net web, a marked line
suspended from a surface float, or depth gauges for all participants,
which permits the diver to determine whether ascension or descension
occurs. All such divers must be equipped with a buoyancy compensating
device.
7. Boat Tending. During dives beyond swimming distance from shore or
those in areas of strong currents, a small boat with a qualified operator
wil 1 tend the diver.
8. Recompression Chamber. The location, availability and telephone
number of all accessible and operable recompression chambers shall be
maintained by the dive supervisor who instructs the dive team.
9. Emergency Procedures. The Unit Diving Officer, with the approval of
the EPA Diving Safety Committee, will prescribe emergency procedures to
be used in handling diving-related accidents in the operational area,
and all divers shall be familiar with these procedures. All emergency
lists and procedures shall be available at the dive location.
10. First Aid Training. All divers should have appropriate Fi rst Aid
and CPR training.
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11. Equipment.
a. Life Support. Open circuit SCUBA using compressed air shall
be standard. Other types of equipment (i.e., surface-supplied diving
equipment, closed-circuit rebreathers, semiclosed units or other types
of diving apparatus utilizing gas mixtures) may be approved for use
by the Diving Safety Committee Chairperson. Individuals requesting use
of closed-circuit rebreathers, semiclosed units, or other types of
equipment must have been trained and qualified in the use of such
equipment. Dive supervisors shall also be trained in the use of such
equipment and shall be ready to assist in case of an emergency.
b. Harness and Weight Belt. All harness and weight belts must
have a quick release, operable by a single motion by either hand.
c. Flotation Device. Each diver shall wear an adequate inflatable
vest or other flotation device.
d. Compass. An underwater compass shall be carried by each diver
when, in the opinion of the Dive Supervisor, lack of underwater orientation
is likely to occur and may create a hazard.
e. Depth Gauge. One underwater depth gauge shall be carried by
each diver when diving in an area of unknown depth or an area of uneven
bottom contours when a diver might reasonably exceed the planned dive
depth.
f. Decompression Meter. Use of decompression meters will be authorized
only by the Diving Safety Committee Chairman. Decompression meters will
not be used for dives which require decompression stops. Decompression
meters can be used as an alternative method of determining the allowable
time at depths before a decompression stop is required. In all cases at
least two meters must be used simultaneously with the more conservative
meter used to determine the allowable dive time. Decompression meters
must be recalibrated every eighteen (18) months by a qualified technician.
g. Diving Match. A diving watch shall be worn by each member of a
diving team.
n« Diving Flag. A diving flag shall be shown while actively diving
in areas subject to boating or other hazardous traffic.
i. Air Compressor. No person shall operate a SCUBA air compressor
without having first read the instructions and assisted an operator
experienced in its operation. An operational log shall be maintained
EPA SCUBA compressors.
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12. Equipment Maintenance. All diving gear and accessory equipment
shall be maintained in a safe operating condition. Manufacturers recom-
mended servicing policy shall be followed. Equipment in questionable
condition shall be repaired, overhauled, or discarded. All regulatory
valves, depth gauges, and decompression meters must be critically
examined, calibrated, or checked for accuracy by a competent mechanic
or appropriate specialist every eighteen (18) months. A record of
the inspection and repair will be filed with the Unit Diving
Officer.
13. Air Tank Inspection and Testing. The interior of all cylinders must
be visually inspected annually by a trained person; cylinders shall be
hyd rostatical ly tested at least every three (3) years. The date of the
last test must be recorded on the tank.
14. Air. Tanks shall be charged only with air certified as meeting
established air standards.
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