United States
Environmental Protection
Agency
Office of Emergency and          Environmental
Remedial Response            Response
Hazardous Response Support Division    Team
Standard Operating
Safety Guides
                //

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460


                           NOV i 9  1984
                                                        OFFICE OF
                                               SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:  Standard Operating Safety Guides, November  1984

FROM:     WiHiam N. Hedeman, Jr., Di recto
          Office of Emergency and Remedial

TO:       Regional Office Addressees

     The enclosed Standard Operating Safety Guides, November  1984
replaces the Interim Standard Operating Guides, Revised
September 1982.  The Guides have been updated and revised  to
reflect additional experience EPA personnel have gained  in
responding to environmental incidents involving hazardous
substances.

     The Standard Operating Safety Guides are in accordance and
consistent with the procedures for employee health and safety
contained in EPA's Occupational Health and Safety Manual,
Chapter 9, Hazardous Substances Responses, (1440 TN12),
May 5, 1984.

     The guides are not meant to be a comprehensive safety
manual for incident response.  Rather, they provide information
on health and safety to complement professional judgement  and
experience, and to supplement existing Regional office safety
procedures.

     If you have any questions or comments concerning the
guides, please contact Mr. Stephen Lingle, Director,  Hazardous
Response Support Division or Mr. J. Stephen Dorrler,  Chief,
Environmental Response Team.

Enclosure

Addressees

Director, Ofc. of Emergence & Remedial Resp., Region  II
Director, Hazardous Waste Mgmt. Div., Region III
Director, Air & Waste Management Division,
          Regions IV, VI, VII. VIII
Director, Waste Mgmt. Div., Regions I & V
Director, Toxics & Waste Mgmt. Div., Region IX
Director, Air & Waste Division X

cc: Gene Lucero, OWPE
    John Skinner, OSW

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     STANDARD OPERATING SAFETY GUIDES
              November 1984
      ENVIRONMENTAL RESPONSE BRANCH



   HAZARDOUS RESPONSE SUPPORT DIVISION




OFFICE OF EMERGENCY AND REMEDIAL RESPONSE



   U.S. ENVIRONMENTAL PROTECTION AGENCY

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                            TABLE OF CONTENTS


Environmental Incidents, Part 1 	Page 1-1

Standard Operating Safety Procedures, Part 2 	Page 2-1

Site Entry - General Measures and Requirements, Part 3 	Page 3-1

Site Entry - Survey and Reconnaissance, Part 4 	Page 4-1

Site Entry - Levels of Protection, Part 5 	Page 5-1

Site Control - Work Zones, Part 6 	Page 6-1

Site Control - Decontamination, Part 7 	Page 7-1

     Annex 1 - Level A Decontamination 	Page Al-1

     Annex 2 - Level B Decontamination	Page A2-1

     Annex 3 - Level C Decontamination 	Page A3-1

     Annex 4 - Level A Decontamination, Minimum Layout 	Page A4-1

Air Surveillance, Part 8 	Page 8-1

     Annex 5 - Guide to Environmental Response Team's	Page A5-1
                 Air Surveillance Program

     Annex 6 - Organic Solvents in Air	Page A6-1

Site Safety Plan, Part 9 	Page 9-1

     Annex 7 - Emergency Operation Codes	Page A7-1

     Annex 8 - Response Safety Check-Off Sheet	Page A8-1

     Annex 9 - Site Safety Plan	Page A9-1

     Annex 10 - Sample Safety Plan	Page A10-1

Appendix I - Characteristics of the HNU Photoionizer	Page 1-1
               and Organic Vapor Analyzer

Appendix II - Rationale for Relating Total Atmospheric	Page II-l
                Vapor/Gas Concentrations to the Selection
                of the Level of Protection

Appendix III - Dermal  Toxicity Data	Page III-l

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                                   PART  1

                          ENVIRONMENTAL  INCIDENTS
 I.  INTRODUCTION

     An environmental   incident involves a release or threat of a  release
     of hazardous substances that pose an imminent and  substantial  danger
     to public health  and welfare or the  environment.   Each  incident  pre-
     sents special  problems.  Response personnel  must  evaluate  these prob-
     lems and  determine  an  effective  course  of action to  mitigate the
     incident.

     Any incident  represents a potentially   hostile situation.  Chemicals
     that are combustible,  explosive,  corrosive,  toxic,  or  reactive, along
     with biological  and  radioactive materials  can affect the general  pub-
     lic or the  environment  as well   as  response personnel.   Workers may
     fall, trip,  be struck by  objects,  or be subject  to danger from elec-
     tricity and  heavy equipment.  Injury and  illness may  also occur due
     to physical  stress and climate.   While the response activities  needed
     at each  incident are  unique, there  are many similarities.   One  is
     that all   responses  require protecting  the  health and  ensuring the
     safety of the  responders.
II.  EXPOSURE TO TOXIC SUBSTANCES

     Toxic (including  radioactive  material  and  etiological  agents)  or
     chemically active substances present  a  special  concern because they
     can be inhaled, ingested, absorbed through the  skin,  or destructive
     to the  skin.   They  may exist in  the  air  or  due  to site activities
     become airborne or  splash  on the  skin.   The effects  of  these sub-
     stances can vary  significantly.   Ingested  or inhaled  the substances
     can cause no apparent  illness or they  can  be  fatal.  On the skin they
     can cause  no  demonstrable  effects.   Others  however  can  damage the
     skin, or be absorbed,  leading to systemic  toxic effects.

     Two types of potential  exposure exist:

     -   Acute:   Exposures  occur for  relatively short  periods of time,
        generally hours to  1-2 days.   Concentrations  of toxic air contam-
        inants which may be inhaled are high  relative to their protection
        criteria.  In addition,  substances may  contact  the skin directly
        through splashes, immersion, or air with serious  results.

     -   Chronic:  Exposures occur over longer periods  of time, generally
        months to years.  Concentrations of  toxic air  contaminants which
        may be inhaled are  relatively  low.   Direct skin contact by  immer-
        sion, splash,  or air involves substances  exhibiting low  dermal
        activity.
                                    1-1

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      In general,  acute exposures to chemicals  in  air are more typical  in
      transportation  accidents,  fires,  or releases  at  chemical  manu-
      facturing or storage facilities.   Acute air  exposures  do  not  persist
      for long periods of time.   Acute  skin exposures  occur when  workers
      must be  close  to the  substances  in  order  to  control  the  release
      (patching a  tank  car,  off-loading a  corrosive material,  etc.)  or
      contain and  treat the  spilled material.   Once the  immediate problems
      have been alleviated,  exposures tend to become more chronic  in  nature
      as cleanup progresses.

      Chronic exposures usually  are  associated  with  longer-term remedial
      operations.   Contaminated  soil  and  debris from emergency operations
      may be involved, soil  and  ground water may  be  polluted,  or impound-
      ment systems may  contain  diluted  chemicals.   Abandoned waste  sites
      represent chronic problems.   As   activities  start at  these   sites,
      however, personnel  engaged in sampling, handling containers,  bulking
      compatible liquids,  etc.    face an  increased  risk   of acute  exposures
      to splashes, or  the generation  of vapors,  gases, or  particulates.

      At any specific  incident,  the hazardous properties of the  materials
      may only represent  a potential threat.  For example,  if a  tank  car  of
      liquified natural  gas   involved   in  an  accident  remains  intact, the
      risk from fire  and  explosion  is low.   In other incidents,  hazards are
      real  and risks  high as when toxic  or  flammable  vapors  are  being re-
      leased.  The continued   health   and   safety  of  response   personnel
      requires that  the hazards  -  real  or  potential  -  at  an  episode  be
      assessed and appropriate  preventive measures  instituted.


III.   HEALTH AND SAFETY OF RESPONSE PERSONNEL

      To reduce the  risks to  workers   responding  to  hazardous  substance
      incidents, an effective health and safety  program must be  implemented.
      This would include,  as a minimum:

      -   Safe work practices.

      -   Engineered safeguards.

      -   Medical surveillance.

      -   Environmental  and personnel monitoring.

      -   Personnel  protective equipment.

      -   Education and  training.

      -   Standard  operating safety procedures.
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    As  part  of a  comprehensive program,  standard  operating safety  pro-
    cedures  provide  instructions on  how  to accomplish  specific tasks  in  a
    safe  manner.   In  concept   and  principle,  standard  operating  safety
    procedures are independent  of the  type  of  incident.   Their  appli-
    cability at a particular  incident  must be  determined  and  necessary
    modifications  made to  match  prevailing  conditions.   For   example,
    personnel  protective  equipment,  in  principle,  is  an  initial   con-
    sideration for all  incidents;  however,  its  need  and  the  type of
    equipment  required is  based on a case-by-case evaluation.   Likewise,
    someone  must   make  the  first  entry  onto  a  site.  The  exact entry
    procedure  to   be  used  can only  be  determined  after  assessing  the
    conditions prevailing at that  incident.

    The purpose of this document  is to  provide standard operating  safety
    guides related to  site control  and  entry.   The  guidance included is
    not meant  to   be  a comprehensive treatment  of the subjects  covered.
    Rather,  it is meant to be  used  to  complement professional  training,
    experience, and  knowledge.
IV. OCCUPATIONAL HEALTH AND  SAFETY  POLICY

    EPA's Occupational  Health  and Safety staff is responsible  for devel-
    oping, supporting,  and evaluating  a  program to protect the  health and
    safety of EPA employees.   The Standard Operating Safety Guides comple-
    ment, and supplement the policies,  procedures, and practices contained
    in EPA's Occupational  Health and  Safety Manual, in particular, with
    Chapter 9 - Hazardous  Substances Responses, EPA  Order  1440.2 - Health
    and Safety Requirments for Personnel Engaged  in  Field  Activities, and
    EPA Order 1440.3 -  Respiratory  Protection.
                                 1-3

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                                   PART 2

                    STANDARD OPERATING SAFETY PROCEDURES
 I.  GENERAL
     There are many  guides or  procedures for  performing  the variety  of
     tasks associated with responding to  environmental  episodes  involving
     hazardous substances.   These  may  be administrative,  technical,  or
     management-oriented.   All   these  procedures are  intended to  provide
     uniform instructions  for accomplishing a  specific  task.   In addition
     to other types  of procedures,  safety-oriented operating  procedures
     are needed.   The  purpose  of  this  document  is  to provide  selected
     standard operating safety  guides which can  be used to  develop  more
     specific procedures.
II.  DEVELOPMENT OF STANDARD OPERATING SAFETY  PROCEDURES

     A major consideration in responding to accidental  releases  of hazard-
     ous substances or incidents  involving abandoned  hazardous waste  sites
     is the health  and safety  of  response  personnel.   Not  only must  a
     variety of technical  tasks  be conducted  efficiently  to mitigate  an
     incident, but they must be accomplished in a  manner  that protects  the
     worker.  Appropriate equipment and trained personnel,  combined with
     standard operating procedures, help reduce the possibility  of harm to
     response workers.

     For procedures to be effective:

     -  They must  be  written  in  advance.  Developing and  writing  safe,
        practical  procedures is difficult  when prepared  under the stress
        of responding  to an incident.

     -  They must  be  based  on the  best  available  information, operational
        principles, and technical  guidance.

     -  They must  be  field-tested,  reviewed, and  revised when appropriate
        by competent safety professionals.

     -  They must  be understandable, feasible,  and appropriate.

     -  All  personnel   involved in  site  activities  must  have  copies   of
        the safety procedures and  be briefed on their use.

     -  Response  personnel  must  be  trained   and  periodically   retrained
        in personnel  protection and safety.
                                  2-1

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III.   RESPONSE  ACTIVITIES

      Many of the  procedures  involved  in response activities  are  primarily
      concerned with   health  and  safety.  In concept   and  principle,  these
      are  generic  and independent  of the type of  incident.   They  are  adapted
      or modified   to  meet   site-specific   requirements.    Each  hazardous
      materials incident  must  be  evaluated  to  determine  its  hazards  and
      risks.  Various  types of  environmental  samples or measurements may be
      needed initially  to  determine the hazards or  to provide additional
      information  for  continuing  assessment.  Personnel must  go on-site to
      accomplish specific tasks. Efforts are required to prevent or reduce
      harmful substances  from migrating  from the site due to  natural   or
      human activities.  Containment,  cleanup,  and  disposal activities  may
      be required.  Each  of  these  activities   requires that  safety  procedure
      be developed  or  existing procedures   be  adapted  so that  response
      personnel  are protected.


 IV.   OPERATING GUIDES

      The  standard operating safety guides that follow cover primarily site
      control and  entry.  These guides illustrate technical considerations
      necessary in developing standard instructions.   For a given incident,
      the  procedures recommended should  be adapted to conditions imposed  by
      that specific situation.
                                 2-2

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                                   PART  3

               SITE  ENTRY  -  GENERAL MEASURES  AND  REQUIREMENTS
 I.   INTRODUCTION

     Personnel  responding  to  environmental  episodes  involving chemical
     substances encounter  conditions that are unsafe or potentially  unsafe.
     In addition to the danger due to the physical, chemical,  and  toxico-
     logical  properties of the  material  present,  other  types  of  hazards
     electricity, water, heavy equipment, falling objects, loss of balance,
     or tripping, for example - can  have  an adverse effect on  personnel.
     This part  discusses   safety measures  and precautions associated only
     with the hazardous nature  of  chemical  compounds.
II.   SAFETY PRACTICES

     A.   Personal  Precautions

         -  Eating,   drinking,  chewing  gum  or  tobacco,  smoking,  or  any
            practice that increases  the  probability  of  hand-to-mouth
            transfer and ingestion  of material  is prohibited in any  area
            designated contaminated.

         -  Hands  and  face must  be  thoroughly washed  upon leaving  the
            work area.

         -  Whenever decontamination procedures  for  outer garments are  in
            effect,  the entire  body should  be  thoroughly  washed as  soon
            as possible after  the  protective  garment  is removed.

         -  No  facial  hair which interferes  with a  satisfactory  fit  of
            the mask-to-face-seal  is  allowed   on  personnel   required  to
            wear respirators.

         -  Contact   with  contaminated  or suspected contaminated surfaces
            should be  avoided.   Whenever possible,  do  not  walk  through
            puddles, leachate, discolored surfaces,  kneel on  ground,  lean,
            sit, or   place  equipment  on  drums,   containers,  or the  ground.

         -  Medicine and alcohol can potentiate the effects  from exposure
            to toxic chemicals.  Prescribed  drugs  should not be taken  by
            personnel on  response   operations   where   the  potential   for
            absorption, inhalation,  or ingestion of  toxic substances
            exists unless specifically approved by a qualified  physician.
            Alcoholic beverage  intake  should   be  minimized or  avoided
            during response operations.
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B.  Site Safety Plans

    -  A Site  Safety Plan must be developed  for all  phases  of site
       operations and made  available to all  personnel.   Unless time
       precludes it, the plan must be written and posted.

    -  All  personnel must be familiar with  standard  operating safety
       procedures and any  additional  instructions  and  information
       contained in the  Site Safety Plan.

    -  All  personnel must adhere to the information  contained in the
       Site Safety Plan.

C.  Operations

    -  All  personnel  going   on-site  must   be  adequately  trained  and
       thoroughly briefed on anticipated  hazards, equipment to  be
       worn,  safety  practices to  be  followed,  emergency procedures,
       and communications.

    -  Any required  respiratory protective devices and  clothing must
       be worn  by  all  personnel   going  into  areas  designated  for
       wearing protective equipment.

    -  Personnel  on-site must  use  the  buddy   system  when  wearing
       respiratory protective  equipment.    As  a  minimum,  a  third
       person, suitably   equipped  as  a  safety   backup,  is  required
       during initial entries.

    -  Visual contact must  be maintained  between pairs  on-site  and
       safety personnel.  Entry   team  members   should  remain  close
       together to assist each other  during emergencies.

    -  During  continual  operations,   on-site  workers  act as  safety
       backup to  each  other.  Off-site  personnel provide  emergency
       assistance.

    -  Personnel  should  practice  unfamiliar  operations  prior  to
       doing  the actual  procedure.

    -  Entrance and  exit  locations must be designated  and emergency
       escape routes delineated.   Warning  signals for site evacuation
       must be established.

    -  Communications using  radios,  hand  signals,  signs,  or  other
       means  must be maintained between initial  entry members at all
       times.  Emergency  communications  should  be   prearranged  in
       case of  radio  failure,  necessity for  evacuation of site,  or
       other  reasons.
                             3-2

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             Wind indicators  visible to  all  personnel  should  be  strate-
             gically located throughout the site.

             Personnel  and  equipment in  the  contaminated  area  should  be
             minimized, consistent with effective  site operations.

             Work areas  for  various  operational activities must be  estab-
             1ished.

             Procedures  for  leaving  a  contaminated  area  must  be  planned
             and implemented  prior  to  going  on-site.    Work   areas   and
             decontamination procedures must be  established based on
             expected site conditions.
III.   MEDICAL PROGRAM

      To safeguard the health of response personnel,  a  medical  program must
      be developed,  established,  and  maintained.   This  program  has  two
      essential  components:   routine  health  care  and emergency  treatment.

      A.  Routine Health Care

          Routine health care and maintenance  should consist of at  least:

          -  Pre-employment   medical  examinations  to  establish  the  indi-
             vidual's state   of  health,  baseline  physiological  data,  and
             ability to  wear personnel   protective  equipment.   The  fre-
             quency and type  of  examination to   be  conducted  thereafter
             should be  determined  by  medical  personnel  knowledgeable  in
             the area of toxicology.

          -  Arrangements  to  provide  special medical  examinations,  care,
             and counseling   in  case  of  known  or suspected  exposures  to
             toxic substances.  Any  special  tests  needed depend  on  the
             chemical substance  to which  the  individual  has been  exposed.

      B.  Emergency Medical  Care and  Treatment

          The Medical  Program  must  address  emergency  medical   care  and
          treatment of response  personnel,  including possible  exposures to
          toxic  substances and injuries resulting from accidents or  physical
          hazards.  The following  items  should  be  included  in emergency
          care provisions:

          -  Name,  address,  and telephone  number of  the  nearest  medical
             treatment facility.   This  should   be  conspicuously   posted.
             A map  and directions  for  locating  the  facility,  plus  the
             travel time,  should be  readily  available.

          -  The  facility's  ability  to  provide  care  and treatment  of
             personnel exposed  or suspected of  being exposed to toxic (or
                                   3-3

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            otherwise  hazardous).   If  the  facility  lacks  toxicological
            capability,  arrangements  should  be made  for  consultant
            services.

         -   Administration arrangements for  accepting  patients.

         -   Arrangements  to  quickly  obtain ambulance,  emergency,  fire,
            and  police services.   Telephone  numbers  and  procedures  for
            obtaining  these  services  should  be conspicuously  posted.

         -   Emergency  showers, eye wash fountains, and first  aid  equipment
            readily  available  on-site.   Personnel  should  have   first  aid
            and  medical emergency training.

         -   Provisions for the  rapid identification  of the substance  to
            which  the  worker has been exposed (if this  has not previously
            been done).  This  information must be given  to  medical  person-
            nel .

            Procedures for  decontamination  of  injured  workers  and  pre-
            venting  contamination  of  medical   personnel,   equipment,  and
            facilities.
IV.   EDUCATION  AND  TRAINING

     All  personnel  involved  in  responding to environmental  incidents must
     be trained to  carry out their  response  functions.   Training must  be
     provided in the use of all  equipment,  including respiratory  protective
     apparatus  and  protective clothing;  safety  practices and procedures;
     general safety  requirements;  advanced first aid; and hazard  recogni-
     tion and evaluation.

     Safety  training  must  be a  continuing  part  of the  total  response
     program. Periodic  retraining  and  practice  sessions  not  only  create
     a  high  degree  of  safety awareness, but  also  help to maintain  profi-
     ciency  in  the  use  of equipment  and  knowledge  of safety requirements.


 V.   QUALIFIED  SAFETY PERSONNEL

     Personnel  responding to chemical  incidents must  make many complex
     decisions  regarding  safety.  Making  these  decisions  correctly re-
     quires more than  elementary  knowledge.   For example,  selecting the
     most effective  personnel  protective  equipment  requires   not  only
     expertise  in the technical  areas of respirators, protective  clothing,
     air monitoring, physical stress, etc., but also experience and profes-
     sional judgment.  Only a competent, qualified person  (specialist) has
     the technical  judgment  to evaluate  a  particular incident and  determine
     the appropriate  safety  requirements.   This  individual,   through  a
     combination of professional  education, on-the-job experience, special-
                                 3-4

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     ized training, and continual  study,  acquires  expertise to make sound
     decisions.
VI.  STRESS

     A.  Introduction

         Both physiological  and psychological  stress effect response
         personnel. Under certain  conditions,  stress  contributes  signif-
         icantly to accidents and harms workers in  other  ways.   To reduce
         the potential  for  abnormal  physical  stress  or  mental  anxiety:

         -  Workers must  be periodically examined  by  medical  authorities
            to determine  if they  are  physically,  and if possible,  psycho-
            logically fit to perform their jobs.

         -  Continual  practice  and  training  must  be  provided in  using
            personnel protective equipment, especially the self-con-
            tained breathing  apparatus  and chemical-resistant  protective
            clothing.

         -  An effective  safety  program  must  be  implemented  and  a  con-
            certed effort  made  to  protect  the  worker.   These  actions
            help assure  personnel  that  their health  and  safety will  be
            protected now and in the future.

     B.  Weather

         Adverse weather  conditions are  important  considerations in plan-
         ning and  conducting  site  operations.   Hot  or cold weather  can
         cause physical  discomfort,  loss  of  efficiency,  and  personal
         injury.   Of  particular importance is  heat stress  resulting  when
         protective clothing  decreases   natural  body  ventilation.   Heat
         stress can occur even when temperature are moderate.  One  or more
         of the  following recommendations will  help reduce heat  stress:

         -  Provide plenty of liquids.  To replace  body fluids  (water and
            electrolytes) lost  due  to  sweating,   use  a  0.1%   salt  water
            solution, more heavily  salted  foods,  or commercial  mixes. The
            commercial mixes may  be preferable for those employees  on  a
            low-sodium diet.

         -  Provide  cooling  devices  to  aid  natural  body  ventilation.
            These devices,  however,  add weight,  and  their use  should  be
            balanced against  worker  efficiency.    Long  cotton  underwear
            act as a  wick to  help  absorb moisture and protect the  skin
            from direct  contact  with  heat-absorbing  protective clothing.
            It should be the minimum undergarment worn.

            Install mobile  showers  and/or hose-down facilities  to reduce
            body temperature and cool  protective clothing.
                                  3-5

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       In  extremely  hot  weather,  conduct  nonemergency  response
       operations  in the early  morning  or evening.

    -  Ensure  that adequate  shelter  is  available to  protect  personnel
       against heat, cold,  rain,  snow, etc., which  decrease physical
       efficiency  and increase  the probability  of accidents.

    -  In  hot  weather,  rotate workers wearing protective  clothing.

C.  Heat Stress Monitoring

    For monitoring  the  body's  recuperative ability to  excess  heat,
    one or more  of   the  following   techniques  should  be  used  as  a
    screening  mechanism.  Monitoring of personnel  wearing protective
    clothing  should   commence   when  the  ambient  temperature  is   70
    degrees Fahrenheit   or  above.   Frequency  of  monitoring  should
    increase  as the  ambient  temperature increases or if  slow recovery
    rates  are   indicated.   When  temperatures  exceed  80  degrees   F
    workers must be  monitored for  heat stress  after every work period.

    -  Heart  rate  (HR)  should  be  measured by the radial pulse  for  30
       seconds as  early  as  possible in  the  resting period.  The  HR
       at  the   beginning  of  the  rest  period should  not  exceed  110
       beats  per minute.  If the  HR  is higher,  the  next work  period
       should  be shortened  by  10 minutes  (or 33%),  while  the  length
       of  the  rest period stays the  same.   If  the  pulse rate  is  100
       beats  per minute  at  the beginning  of the next  rest period,
       the following work cycle should  be  shortened  by 33%.

    -  Body  temperature  should be  measured  orally  with  a   clinical
       thermometer as early  as possible in the  resting  period.  Oral
       temperature (OT)  at  the beginning  of the  rest period  should
       not exceed  99 degrees Fahrenheit.   If it does,  the next work
       period  should be  shortened by 10  minutes  (or 33%), while  the
       length  of the rest period  stays  the same.  However,  if the  OT
       exceeds 99.7  degrees  Fahrenheit  at the  beginning of the next
       period, the following work cycle  should be further  shortened
       by  33%.  OT  should be  measured  again at the end of the rest
       period  to make  sure that  it  has dropped  below  99 degrees
       Fahrenheit.

    -   Body water  loss  (BWL) due to sweating  should  be measured  by
       weighing the  worker  in  the morning and  in  the  evening.   The
       clothing worn  should  be  similar at both weighings; preferably
       the worker  should be nude.   The scale  should  be accurate  to
       plus or minus  1/4 Ib.   BWL   should  not exceed  1.5%  of  the
       total body  weight.  If  it  does, workers should  be instructed
       to  increase their daily  intake of  fluids by  the weight  lost.
                            3-6

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        Ideally, body fluids should be maintained at a constant level
        during the work day.  This  requires  replacement  of salt lost
        in sweat as well.

    Good hygienic standards must be maintained  by  frequent  change of
    clothing and  daily  showering.  Clothing  should be  permitted to
    dry during rest periods.  Persons  who notice skin problems should
    immediately consult medical  personnel.

D.  Effects of Heat Stress

    If the  body's  physiological  processes fail to  maintain  a normal
    body temperature because of  excessive heat,  a  number of physical
    reactions can occur  ranging  from  mild (such as fatigue,  irrita-
    bility; anxiety, and decreased concentration, dexterity, or
    movement)'to fatal.  Standard reference books should be consulted
    for specific  first  aid  treatment.   Medical  help must be obtained
    for the more serious conditions.

    Heat-related problems are:

    -  Heat rash: caused by continuous exposure to  heat and humid air
       and aggravated  by  chafing  clothes.    Decreases  ability  to
       tolerate heat as well as  being  a nuisance.

    -  Heat cramps:  caused  by profuse perspiration with  inadequate
       fluid intake  and  chemical   replacement  (especially  salts).
       Signs: muscle spasm  and  pain in the  extremities  and abdomen.

    -  Heat exhaustion: caused by  increased  stress  on  various organs
       to meet  increased  demands to  cool  the body.   Signs:  shallow
       breathing; pale, cool, moist skin;  profuse sweating;  dizziness
       and lassitude.

    -  Heat stroke: the most  severe form of  heat  stress.   Body must
       be cooled  immediately to  prevent severe  injury and/or death.
       Signs: red, hot, dry skin;  no  perspiration;  nausea;  dizziness
       and confusion;  strong,  rapid pulse; coma.   Medical  help must
       be obtained immediately.

E.  Effects of Cold Exposure

    Persons working outdoors in  temperatures  at or  below freezing may
    be frostbitten.  Extreme cold  for a short time may  cause severe
    injury to exposed body surfaces, or result in profound generalized
    cooling, causing death.  Areas of  the  body which  have high surface
    area-to-volume ratio  such  as  fingers, toes,  and  ears,  are  the
    most susceptible.
                             3-7

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F.
    Two factors influence the  development  of a  cold  injury:  ambient
    temperature and the velocity of the  wind.   Wind chill  is used to
    describe the chilling  effect  of moving  air in combination  with
    low temperature.  For instance,  10 degrees Fahrenheit with a wind
    of 15 miles per hour  (mph) is  equivalent  in  chilling  effect to
    still air at -18 degrees Fahrenheit.

    As a  general   rule,  the greatest  incremental   increase  in  wind
    chill occurs when  a  wind  of  5  mph  increases  to  10  mph.  Addi-
    tionally, water conducts heat 240  times faster than  air.  Thus,
    the body  cools  suddenly  when  chemical-protective  equipment  is
    removed if the  clothing underneath  is perspiration soaked.

    Local injury resulting  from cold  is  included in the  generic term
    frostbite.  There are  several  degrees  of  damage.  Frostbite of
    the extremities can be categorized  into:

    -  Frost nip or incipient  frostbite:    characterized  by  suddenly
       blanching or whitening  of skin.

    -  Superficial  frostbite:    skin  has  a waxy  or white  appearance
       and is  firm to the  touch,  but tissue  beneath is  resilient.
    -  Deep frostbite:
       serious injury.
                   tissues are  cold,  pale, and  solid;  extremely
Systemic hypothermia is caused by exposure to freezing or rapidly
dropping temperature.  Its symptoms are usually exhibited in five
stages: 1)  shivering,  2) apathy,  1 istlessness,  sleepiness,  and
(sometimes) rapid  cooling  of  the  body to  less than  95  degrees
Fahrenheit, 3)  unconsciousness,  glassy  stare,  slow  pulse,  and
slow respiratory  rate,  4)   freezing  of  the  extremities,  and
finally, 5) death.

Standard reference  books  should  be consulted for  specific  first
aids treatments.   Medical  help  must be  obtained  for the  more
serious conditions.

Indicators of Toxic Exposure  Effects

-   Observeable by others

   --  changes in complexion,  skin  discoloration

       lack of coordination

   --  changes in demeanor

   --  excessive salivation,  pupillary  response
                             3-8

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             --  changes in speech pattern

          -  Non-Observeable by others

             —  headaches

             --  dizziness

             --  blurred vision

             --  cramps

             --  irritation of eyes, skin, or respiratory tract
VII.  SUMMARY
      The health and  safety  of  response personnel  are major considerations
      in all response  operations.   All  site operation planning must incor-
      porate an  analysis  of the hazards  involved  and procedures  for pre-
      venting or minimizing  the risk to  personnel.   The Site  Safety Plan
      establishes the  safety practices  and  procedures to  be  followed  so
      that the welfare  and  safety  of workers are protected.  The plan must
      evaluate both the nature  of the chemical  compounds  present and other
      hazards that could affect response personnel.
                                   3-9

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                                   PART  4

                   SITE ENTRY -  SURVEY AND  RECONNAISSANCE
 I.   INTRODUCTION

     The team initially  entering  the site  is  to accomplish  one or  more
     of the following objectives:

     -  Determine the  hazards  that exist  or  potentially  exist  affecting
        public health, the environment,  and response  personnel.

     -  Verify existing  information  and/or obtain  information  about  the
        incident.

     -  Evaluate  the need for prompt  mitigation.

     -  Collect supplemental  information to determine the safety  require-
        ments for personnel  initially and subsequently entering the  site.

     Before the  team  enters  the  site,   as  much  information  as  possible
     should be collected, depending on the time available,  concerning  the
     type of  hazards,  degree of  hazard(s),  and  risks  which  may exist.
     Based upon available information (shipping manifests,  transportation
     placards, existing  records,   container   labels,  etc.)   or   off-site
     studies, the team assesses  the hazards, determines the  need  to go  on-
     site, and identifies initial  safety requirements.


II.   PRELIMINARY  ON-SITE EVALUATION

     The initial  on-site  survey is to  determine,  on a preliminary basis,
     hazardous or potentially hazardous  conditions.   The main  effort  is to
     rapidly identify the  immediate  hazards  that may  affect  the public,
     response personnel,  and the  environment.   Of major  concern are  the
     real or  potential  dangers  from,  fire,  explosion,  airborne contam-
     inants and to  a  lesser  degree  radiation  and oxygen deficient atmos-
     pheres.

     A.  Organic  Vapors and Gases

         If the type of organic  substance involved in an incident  is  known
         and the  material is  volatile or can  become  airborne,  air measure-
         ments for  organics  should be made with one or more  appropriate,
         properly calibrated  survey instruments.

         When the presence or types  of  organic vapors/gases  are  unknown,
         instruments such as  a  photoionizer  (HNU  Systems*)  and/or a  por-
         table gas  chromatograph  (Foxboro  Systems OVA*),  operated in  the
         total readout  mode,  should  be used  to detect  organic vapors.

     *The use  of  any  trade  names  does not  imply   their  endorsement  by
      the U.S. Environmental  Protection  Agency.


                                  4-1

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    Until specific constituents can be  identified,  the  readout indi-
    cates total  airborne  substances   to  which   the  instrument  is
    responding.  Identification of the  individual  vapor/gas  consti-
    tuents may  permit   the  instruments  to  be   calibrated  to  these
    substances and  used for  more  specific and  accurate  analysis.

    Sufficient data should  be  obtained  during the  initial  entry  to
    map or  screen  the   site  for  various  levels   of organic  vapors.
    These gross measurements may  be used on a preliminary  basis to:
    1) determine levels  of  personnel  protection,  2) establish  site
    work zones,  and  3)  select  candidate  areas  for  more  thorough
    qualitative and quantitative studies.

    Very high  readings   on the  HNU or  OVA may also  indicate  the dis-
    placement of  oxygen or the   presence   of   combustible   vapors.

B.  Inorganic Vapors  and Gases

    The number of  direct reading  instruments  with  the capability  to
    detect and  quantify  nonspecific   inorganic  vapors  and  gases  is
    extremely limited.    Presently,  the  HNU  photoionizer  has   very
    limited detection   capability  while  the Foxboro OVA  has  none.
    (See Appendix I for characteristics).   If specific  inorganics are
    known or  suspected  to   be  present,  measurements  should  be  made
    with appropriate  instruments,  if  available.   Colorimetric  tubes
    are only practical   if   substances present  are  known or  can  be
    narrowed to a few.

C.  Radiation

    Although radiation  monitoring  is not  necessary for  all  responses,
    it should be incorporated in the initial  survey  where radioactive
    materials may be present -  for example, fires  at  warehouses  or
    hazardous material   storage  facilities,  transportation  incidents
    involving unknown materials,  or abandoned waste  sites.

    Normal  background  exposure-rate for  gamma  radiation is  approx-
    imately  0.01  to 0.02 milliroentgen  per hour  (mR/hr)  on  a  gamma
    survey  instrument.   Work  can  continue  with  elevated  radiation
    exposure-rates; however,  if  the  exposure-rate  increases  to  3-5
    times  above gamma background,  a qualified health physicist  should
    be consulted.   At  no time  should  work  continue with an  exposure
    rate  of  10 mR/hr or  above without the advice of a  health physicist.
    EPA's Office  of Air, Noise and Radiation has  radiation specialists
    in each  Region, as  well  as  at Headquarters, Montgomery, Alabama,
    and Las  Vegas,  Nevada,  to assist.   The absence  of gamma  readings
    above background should not  be interpreted as  the complete absence
    of radioactivity.   Radioactive materials emitting low-energy  gam-
                            4-2

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    ma, alpha, or beta  radiation may  be present,  but  for a  number of
    reasons may  not  cause  a  response  on  the   instrument.   Unless
    airborne, these  radioactive  materials  should  present  minimal
    hazard, but more  thorough surveys  should be  conducted as  site
    operations continue to  completely rule  out  the presence  of  any
    radioactive material.

D.  Oxygen Deficiency

    Normal air  contains about  20.5%  by  volume  of  oxygen.   At  or
    below 19.5% oxygen  air-supplied  respiratory  protective  equipment
    is needed.  Oxygen  measurements are  of particular importance  for
    work in enclosed  spaces,  low-lying areas, or  in  the vicinity of
    accidents that have produced heavier-than-air  vapors which could
    displace ambient air.   These oxygen  deficient  areas are also prime
    locations for taking  further  organic  vapor  and  combustible  gas
    measurements, since the air  has   been  displaced   by other  sub-
    stances.  Oxygen-enriched atmospheres  increase  the  potential  for
    fires.

E.  Combustible Gases

    The presence  or  absence of combustible  vapors or  gases must be
    determined.  If  readings  approach  or  exceed 10%  of the  lower
    explosive limit  (LEL),  extreme caution  should be   exercised  in
    continuing the investigation.   If readings approach or exceed  25%
    LEL, personnel should be  withdrawn  immediately.   Before  resuming
    any on-site  activities, project  personnel  in  consultation  with
    experts in  fire  or explosion prevention  must develop procedures
    for continuing operations.

F.  Visual Observations

    While on-site, the  initial entry  team should make  visual  obser-
    vations which would help in evaluating site hazards, for example,
    dead fish or other animals; land features; wind direction;  labels
    on containers indicating explosive,  flammable, toxic, or corrosive
    materials; conditions  conducive to splash  or  contact with  uncon-
    fined liquids, sludges, or  solids;  and other  general conditions.

G.  Direct-Reading Instruments

    A variety  of  toxic air pollutants,  (including  organic and  in-
    organic vapors,  gases,  or particulates) can  be produced at,  for
    example, abandoned waste  sites; fires  at chemical manufacturing,
    storage, reprocessing, or formulating facilities;  or fires  invol-
    ving pesticides.  Direct-reading field instruments will  not
    detect or  measure  all   of  these  substances.   Thus,   negative
    readings should  not be  interpreted  as  the  complete absence  of
    airborne toxic substances.  Verification  of  negative results  can
                             4-3

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          only  be  done  by collecting  air  samples and  analyzing  them in a
          laboratory.
III.   OTHER  CONSIDERATIONS

      A.   Initial Surveys

          In  general, the  initial  entry  is  considered a  relatively rapid
          screening process for collecting preliminary  data on site hazards.
          The time  needed to  conduct the  initial  survey  depends  on  the
          urgency of  the  situation,  type of  incident,  information needed,
          size  of site,  availability  of  resources, and Level  of Protection
          required for  initial  entry  personnel.   Consequently,  initial
          surveys may  need  hours  or  days to  complete and consist of more
          than  one entry.

      B.   Priority for Initial Entry Monitoring

          Of  immediate  concern to  initial entry  personnel  are atmospheric
          conditions which  could  affect  their   immediate  safety.   These
          conditions are  airborne  toxic  substances,  combustible  gases  or
          vapors, lack  of  oxygen,  and to a lesser  extent,  ionizing radia-
          tion.  Priorities  for  monitoring these  potential  hazards  should
          be  established after a careful  evaluation of conditions.

          When  the type  of material   involved  in  an  incident  is identified
          and its  release into  the   environment  suspected  or  known,  the
          material's chemical/physical properties  and the prevailing weather
          conditions may help  determine the order  of monitoring.  An unknown
          substance or  situation  presents  a  more  difficult  monitoring
          problem.

          In  general,  for  poorly-ventilated   spaces     buildings,  ship's
          holds, boxcars, or bulk tanks  -  which must be entered, combustible
          vapors/gases and oxygen-deficient atmospheres should be monitored
          first with team members wearing, as a minimum, Level B protective
          equipment (Levels of Protection  are described  in  Part 5).  Toxic
          gases/vapors and  radiation,  unless  known   not  to  be  present,
          should be measured next.

          For open,   well-ventilated   areas,   combustible  gases  and  oxygen
          deficiency are lesser hazards, and  require lower priority.
          However, areas  of  lower  elevation  on-site  (such as  ditches  and
          gulleys) and downwind areas may have combustible gas mixtures, in
          addition to toxic vapors or gases,  and  lack  sufficient oxygen to
          sustain life.   Entry teams  should  approach  and monitor whenever
          possible from the upwind  area.
                                  4-4

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C.  Periodic Monitoring

    The monitoring  surveys  made  during the initial  site  entry  phase
    are for a preliminary evaluation of atmospheric hazards.  In some
    situations, the information obtained may be sufficient  to preclude
    additional monitoring -  for  example, a chlorine tank determined
    to be  releasing  no  chlorine.   Materials  detected  during  the
    initial site  survey  call  for a more  comprehensive  evaluation of
    hazards and analyses  for  specific  components.   A program must be
    established for monitoring,  sampling,  and  evaluating  hazards  for
    the duration  of  site  operations.   Since  site  activities  and
    weather conditions change, a continuous program to monitor atmos-
    pheric changes  must   be  implemented   utilizing  a combination  of
    stationary sampling  equipment,  personal  monitoring devices,  and
    periodic area monitoring with direct-reading instruments.

D.  Off-Site Monitoring and Sampling

    Whenever possible, atmospheric  hazards  in  the  areas  adjacent to
    the on-site zone  should  be monitored with  direct-reading instru-
    ments, and air  samples  should be taken before  the  initial  entry
    for on-site  investigations.   Negative  instrument readings  off-
    site should not be  construed as definite indications  of on-site
    conditions, but only  another piece  of  information to  assist  in
    the preliminary evaluation.

E.  Monitoring Instruments

    It is  imperative  that personnel  using monitoring instruments  be
    thoroughly familiar/  with  their  use,  limitations, and  operating
    characteristics.  All  instruments  have  inherent constraints  in
    their ability to  detect  and/or  quantify  the  hazards for  which
    they were designed.   Unless trained personnel  use instruments  and
    assess data  readout,  air  hazards  can be grossly misinterpreted,
    endangering the  health  and   safety  of  response personnel.   In
    addition, only instruments approved for use in  hazardous locations
    should be  used, unless combustible  gases  or   vapors  are absent.

F.  Ambient Atmospheric Concentrations

    Any indication  of atmospheric hazards - toxic  substances, combus-
    tible gases, lack of oxygen,  and radiation - should be  viewed as a
    sign to proceed with  care and deliberation.   Readings indicating
    nonexplosive atmospheres, low concentrations of toxic  substances,
    or other  conditions  may increase  or  decrease  suddenly, changing
    the associated  risks.  Extreme  caution  should  be exercised in
    continuing surveys  when  any  atmospheric  hazards  are indicated.
                             4-5

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                                 TABLE  4-1

                      ATMOSPHERIC HAZARD  GUIDELINES
Monitoring Equipment
Hazard
Ambient Level
                                                                  Action
Combustible gas indicator    Explosive
                             atmosphere
Oxygen concentration meter    Oxygen
Radiation survey meter
Ionizing
Radiation
< 10% LEL    Continue investigation
             wtth cautions.

  10%-25%    Continue on-site
             monitoring with extreme
             caution as higher levels
             are encountered.

> 25% LEL    Explosion hazard; withdraw
             from area immediately.

< 19.5%      Monitor wearing SCBA.
             NOTE:  Combustible gas
             readings are not valid
             in atmospheres with
             < 19.5% oxygen.

  19.5%-25%  Continue investigation with
             caution.  SCBA not needed,
             based on oxygen content
             only.

> 25.0%      Discontinue inspection;
             fire hazard potential.
             Consult specialist.

< 1  mR/hr    Continue investigation.
             If radiation is detected
             above background levels,
             this signifies the presence
             of possible radiation sources;
             at this level, more thorough
             monitoring is advisable.
             Consult with a
             health physicist.

> 10 mR/hr   Potential radiation hazard;
             evacuate site.  Continue moni-
             toring only upon the advice
             of a health physicist.
                                4-6

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                           TABLE 4-1 (Cont'd.)
Monitoring Equipment
    Hazard
Ambient Level
        Action
Colorimetric tubes
Photoionization
  detector (PID)
Organic and
inorganic
vapors/gases
Organic
vapors/gases
Flame  ionization
  detector  (FID)
Organic
vapors/gases
Depends on
chemical
1) Depends on
   chemical
2) Total
   response
   mode

1) Depends on
   chemical
                                           2) Total
                                              response
                                              mode
Consult standard
reference manual for
air concentrations/
toxicity data.

Consult standard
reference manuals
for air concentrations,
toxicity data.

Consult EPA Standard
Operating Safety Guide


Consult standard refen
manuals for air concen-
trations/toxicity data

Consult EPA Standard
Operating Safety Guide;
                                 4-7

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                                  PART 5

                    SITE ENTRY - LEVELS OF PROTECTION
I.   INTRODUCTION
    Personnel  must  wear protective  equipment  when  response  activities
    involve known  or  suspected  atmospheric  contamination, when  vapors,
    gases, or particulates may  be  generated by site activities,  or  when
    direct contact with  skin-affecting  substances may  occur.   Full  face-
    piece respirators protect  lungs,  gastrointestinal tract,  and  eyes
    against airborne toxicants.  Chemical-resistant  clothing protects the
    skin from  contact  with  skin-destructive  and  absorbable  chemicals.
    Good personal  hygiene   limits   or   prevents  ingestion  of  material.

    Equipment to protect the body  against  contact with known  or  antici-
    pated toxic chemicals has been divided into four categories according
    to the degree of protection afforded:

    -  Level A:   Should  be worn  when  the  highest level  of respiratory,
       skin, and eye protection is needed.

    -  Level B:   Should be  worn when  the  highest  level   of  respiratory
       protection is  needed,   but   a  lesser  level  of skin  protection.

    -  Level C:  Should be worn when the criteria for using air-purifying
       respirators are met.

    -  Level D:   Should  be worn  only  as  a work  uniform  and  not on  any
       site with  respiratory or  skin  hazards.   It provides no protection
       against chemical  hazards.

    The Level of Protection selected should be based on:

    -  Type and measured concentration of  the chemical  substance
       in the ambient atmosphere and its toxicity.

    -  Potential  for  exposure to substances  in  air,  splashes  of liquids,
       or other  direct  contact  with material  due  to  work  being  done.

    In situations where the type of chemical, concentration, and
    possibilities of  contact  are  not  known,  the  appropriate Level  of
    Protection must  be   selected  based  on  professional   experience  and
    judgment until the hazards can be better identified.

    While personnel protective  equipment reduces the potential for contact
    with toxic  substances,  ensuring the health and  safety of responders
    requires, in  addition,   safe work  practices,  decontamination,  site
    entry protocols, and other  safety procedures.  Together, these provide
    an integrated approach for reducing harm to workers.
                                 5-1

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II.   LEVELS OF  PROTECTION

     A.   Level  A Protection

         1.  Personnel  protective  equipment

             -   Supplied-air  respirator approved  by the  Mine  Safety  and
                Health  Administration   (MSHA)  and  National  Institute  for
                Occupational  Safety  and Health  (NIOSH).
                Respirators may  be:

                --   pressure-demand,   self-contained  breathing  apparatus
                    (SCBA)

                                        or

                --   pressure-demand, airline respirator (with escape bottle
                    for Immediately  Dangerous to  Life and  Health (IDLH) or
                    potential  for  IDLH  atmosphere)

             -   Fully encapsulating  chemical-resistant  suit

             -   Coveralls*

             -   Long cotton underwear*

             -   Gloves  (inner),  chemical-resistant

             -   Boots,  chemical-resistant, steel toe and shank.  (Depending
                on  suit construction,   worn  over   or   under   suit  boot)

             -   Hard hat*  (under suit)

             -   Disposable gloves  and boot covers*  (Worn over  fully encap-
                sulating, suit)

             -   Cooling unit*

             -   2-Way radio communications*   (inherently safe)

         2.   Criteria for  selection

             Meeting any  of  these  criteria   warrants  use  of  Level   A
             Protection:

             -   The  chemical  substance  has  been  identified  and  requires
                the  highest  level  of  protection  for  skin,  eyes,  and  the
                respiratory system based on:

                --   measured  (or  potential   for)  high  concentration   of
 *0ptional


                                 5-2

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           atmospheric vapors, gases, or particulates

                                 or

       --  site  operations  and  work  functions  involves  high
           potential  for  splash,  immersion,  or exposure  to  un-
           expected vapors, gases,  or particulates  of  materials
           highly toxic to the skin.

    -  Substances with  a  high degree  of  hazard to the  skin  are
       known or  suspected to  be  present,  and  skin contact  is
       possible.

    -  Operations must  be conducted  in  confined,  poorly  venti-
       lated areas  until   the  absence  of  substances  requiring
       Level A protection  is  determined.

    -  Direct readings on  field Flame lonization Dectors (FID) or
       Photoionization Detectors  (PID)  and  similar  instruments
       indicate high levels of unidentified vapors  and  gases in
       the air.  (See Appendixes I and II.)

3.  Guidance on selection

    a.  Fully  encapsulating   suits  are  primarily  designed   to
        provide a gas  or  vapor tight  barrier  between  the  wearer
        and atmospheric contaminants.  Therefore Level  A  is  gen-
        erally worn  when   high  concentrations  of airborne  sub-
        stances are  known or  thought to  be  present   and  these
        substances could severely effect the skin.  Since Level  A
        requires the use of a  self-contained breathing apparatus,
        the eyes and  respiratory  system  are also more protected.

        Until air surveillance data  are available to assist in  the
        selection of the appropriate Level  of Protection, the  use
        of Level A may  have to be based on indirect  evidence of
        the potential for  atmospheric  contamination or other means
        of skin  contact  with  severe  skin  affecting  substances.

        Conditions that may  require Level  A  protection include:

    -  Confined spaces:  Enclosed, confined, or poorly ventilated
       areas are conducive to build up of toxic vapors, gases, or
       particulates.   (Explosive or  oxygen-deficient atmospheres
       also are more probable in confined spaces.) Confined space
       entry does not  automatically warrant wearing Level  A pro-
       tection, but  should  serve as a cue  to  carefully consider
       and to justify a lower  Level  of Protection.

    -  Suspected/known  highly toxic   substances:   Various  sub-
       stances that  are  highly  toxic  especially  through  skin
                         5-3

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   absorption for  example,  fuming  corrosives,  cyanide  com-
   pounds, concentrated pesticides, Department of Tran-
   sportation Poison  "A"  materials,  suspected  carcinogens,
   and infectious  substances may  be  known  or suspected to be
   involved.  Field  instruments  may  not  be  available  to
   detect or quantify  air concentrations  of these materials.
   Until these substances are  identified  and  concentrations
   measured, maximum protection may be necessary.

-  Visible  emissions:   Visible  air  emissions  from  leaking
   containers or  railroad/vehicular  tank  cars,  as  well  as
   smoke from chemical fires and others, indicate high
   potential for  concentrations  of substances  that  could be
   extreme respiratory or skin  hazards.

-  Job  functions:  Initial  site  entries are  generally  walk-
   throughs in  which  instruments  and   visual   observations
   are used to make  a  preliminary evaluation of the hazards.
   In initial  site  entries,  Level  A  should  be  worn  when:

   --  there  is   a  probability   for  exposure  to high  con-
       centrations of vapors,  gases,  or  particulates.

   --  substances  are  known  or suspected  of being  extremely
       toxic directly  to  the   skin   or by  being  absorbed.

Subsequent entries are to conduct the many  activities  needed
to reduce the  environmental  impact of  the  incident.   Levels
of Protection for later operations are based not only on data
obtained from the  initial  and  subsequent  environmental  moni-
toring, but also on the probability of contamination and ease
of decontamination.

Examples of  situations where  Level   A  has  been  worn  are:

-  Excavating  of  soil  to  sample  buried  drums  suspected  of
   containing high concentrations  of  dioxin.

-  Entering a cloud of chlorine to repair a valve  broken in a
   railroad accident.

-  Handling and moving drums  known to contain oleum.

-  Responding to accidents involving cyanide, arsenic, and un-
   diluted pesticides.

The fully encapsulating suit provides the highest  degree  of
protection to skin,  eyes, and  respiratory  system  if the suit
material  resists  chemicals  during the time the  suit  is  worn.
While Level  A provides maximum protection,  all  suit material
may be rapidly  permeated  and  degraded  by  certain  chemicals
                     5-4

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            from  extremely  high air concentrations, splashes, or immersion
            of  boots  or  gloves  in  concentrated  liquids  or  sludges.   These
            limitations  should  be  recognized when specifying the type  of
            fully encapsulating  suit.   Whenever possible,  the  suit
            material  should be  matched with  the  substance it  is  used
            to  protect against.
    B.   Level B Protection
        1.   Personnel  protective equipment
            -   Supplied-air respirator  (MSHA/NIOSH approved).
               Respirators  may  be:
               -- pressure-demand,  self-contained breathing  apparatus
                                     or
               — pressure-demand,  airline  respirator  (with  escape  bottle
                  for IDLH  or potential for IDLH atmosphere)
            -   Chemical-resistant   clothing  (overalls   and  long-sleeved
               jacket; hooded,  one  or  two-piece   chemical-splash   suit;
               disposable chemical-resistant, one-piece  suits)
            -   Long cotton  underwear*
            -   Coveralls*
            -   Gloves (outer),  chemical-resistant
            -   Gloves (inner),  chemical-resistant
            -   Boots  (outer),  chemical-resistant,   steel  toe  and   shank
            -   Boot covers  (outer),  chemical-resistant  (disposable)*
            -   Hard hat  (face shield)*
            -   2-Way  radio  communications*   (inherently  safe)
        2.   Criteria  for selection
            Meeting any  one  of these  criteria warrants  use  of Level B
            protection:
            -   The type  and atmospheric concentration  of toxic  substances
               has been  identified and requires a high  level of  respira-
               tory protection,  but less  skin  protection  than Level  A.
               These  would  be atmospheres:
"Optional
                                 5-5

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       --  with  concentrations  Immediately  Dangerous to  Life  and
          Health,  but  substance  or  concentration  in  the  air
          does  not  represent  a severe  skin  hazard

                                 or

       --   that do not meet the  selection  criteria  permitting  the
           use  of  air-purifying  respirators.


    -   The atmosphere  contains less than  19.5%  oxygen.

    -   It  is  highly unlikely  that the  work  being  done will  generate
       high concentrations  of  vapors,  gases  or  particulates,  or
       splashes of  material  that will  affect the  skin of  personnel
       wearing  Level B  protection.

    -   Atmospheric  concentrations  of  unidentified vapors  or  gases
       are indicated by direct readings  on  instruments such
       as  the FID  or  PID or  similar  instruments,  but  vapors  and
       gases  are  not suspected of containing  high  levels of
       chemicals  toxic  to skin.   (See  Appendixes  I and II.)

3.  Guidance  on selection

    a.   Level  B does  not  afford the  maximum  skin  (and eye)  pro-
        tection as   does  a   fully  encapsulating   suit  since  the
        chemical-resistant clothing is not  considered   gas,  vapor,
        or particulate  tight.   However,  a   good  quality,  hooded,
        chemical-resistant, one-piece  garment,  with  taped  wrist,
        ankles, and hood  does  provides a   reasonable  degree   of
        protection  against  splashes and  to lower  concentrations  in
        air.  At  most  abandoned  hazardous  waste  sites,   ambient
        atmospheric gas or vapor  levels  have  not  approached concen-
        trations  sufficiently  high  to warrant  Level A  protection.
        In all  but  a few circumstances  (where  highly toxic  mater-
        ials  are  suspected)  Level  B  should  provide  the protection
        needed  for  initial  entry.  Subsequent  operations at  a  site
        require a  reevaluation  of  Level   B  protection based  on  the
        probability of  being  splashed by  chemicals, their  effect
        on the  skin,  the  presence  of hard-to-detect air  contaim-
        inants, or  the  generation  of  highly toxic   gases,  vapors,
        or particulates, due  to  the work  being  done.

    b.   The  chemical-resistant  clothing  required  in   Level  B  is
        available  in a  wide variety of styles,  materials,  construc-
        tion  detail, and permeability.   One  or two-piece  garments
        are available  with  or without hoods.  Disposal  suits  with
        a  variety   of  fabrics  and  design  characteristics  are  also
        available.   Taping  joints  between  the  gloves, boots  and
        suit, and   between  hood   and   respirator   reduces  the  pos-
        siblity for splash  and   vapor  or  gas  penetration.   These
                         5-6

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            factors and other  selection  criteria  all  affect the degree
            of protection  afforded.   Therefore,   a  specialist  should
            select the most effective chemical-resistant clothing
            based on the known or anticipated hazards and job function.

            Level B equipment  does  provides  a high level  of protection
            to the  respiratory tract.   Generally, if  a self-contained
            breathing apparatus is required for respiratory protection,
            selecting chemical-resistant clothing  (Level B) rather than
            a fully encapsulating  suit (Level A)  is  based  on  needing
            less protection  against  known  or  anticipated  substances
            affecting the  skin.   Level B  skin protection  is  selected
            by:

            -  Comparing  the  concentrations  of   known  or  identified
               substances in air with skin toxicity data.

            -  Determining the presence of substances  that are destruc-
               tive to  or  readily  absorbed through the skin  by liquid
               splashes, unexpected  high   levels  of  gases, vapor,  or
               particulates, or other means of direct  contact.

            -  Assessing the effect  of the  substance  (at  its  measured
               air concentrations  or potential for  splashing)   on  the
               small areas left unprotected by chemical-resistant
               clothing.  A  hooded  garment   taped to  the  mask,  and
               boots and gloves taped to the  suit  further  reduces  area
               of exposure.

        c.  For  initial site entry  and  reconnaissance at an open site,
            approaching whenever possible  from upwind,  Level  B  protec-
            tion (with  good  quality,  hooded,  chemical-resistant cloth-
            ing) should protect response personnel, providing the
            conditions described  in  selecting  Level   A are  known  or
            judged to be absent.

C.  Level C Protection

    1.  Personnel protective equipment

        -  Air-purifying respirator, full-face, canister-equipped
           (MSHA/NIOSH approved)

        -  Chemical-resistant  clothing  (coveralls;  hooded,  one-piece
           or two-piece chemical  splash suit; chemical-resistant  hood
           and apron;  disposable chemical-resistant coveralls)

        -  Coveralls*

        -  Long cotton underwear*

        -  Gloves (outer), chemical-resistant
                             5-7

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*0ptional
            -  Gloves (inner),  chemical-resistant*

            -  Boots  (outer),  chemical-resistant,  steel  toe  and  shank

            -  Boot covers (outer),  chemical-resistant (disposable)*

            -  Hard hat (face shield*)

            -  Escape mask*

            -  2-Way radio communications*  (inherently safe)

            Criteria for selection

            Meeting all of these criteria permits use  of Level  C protec-
            tion:

            -  Oxygen  concentrations  are  not less than  19.5% by volume.

            -  Measured air  concentrations of  identified substances will
               be reduced by the  respirator  below the  substance's thres-
               hold limit  value  (TLV) and  the  concentration  is  within
               the service limit  of  the canister.

            -  Atmospheric contaminant concentrations do  not  exceed IDLH
               levels.

            -  Atmospheric contaminants,  liquid splashes, or other
               direct contact  will  not  adversely affect  any  body area
               left unprotected by chemical-resistant  clothing.

            -  Job  functions  do  not  require  self-contained  breathing
               apparatus.

            -  Direct  readings  are  a  few ppms  above  background on  in-
               struments such as the  FID  or  PID.  (See  Appendices  I  and
               II.)

            Guidance on selection

            a.  Level  C  protection  is distinguished  from Level  B  by  the
                equipment used  to  protect  the respiratory system, assuming
                the same type of chemical-resistant clothing is used.  The
                main selection  criterion  for  Level  C is  that conditions
                permit wearing  air-purifying  respirators.

                The air-purifying  device   must  be a full-face respirator
                (MSHA/NIOSH approved)  equipped with a  canister  suspended
                from the chin or  on  a  harness.   Canisters must be able to
                                 5-8

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                remove the  substances  encountered.   Quarter-or  half-masks
                or cheekcartridge,  full-face  masks   should  be  used  only
                with the approval  of a qualified individual.

                In addition,  a  full-face, air-purifying  mask  can  be  used
                only if:

                -  Substance has adequate warning properties.

                -  Individual  passes  a  qualitative fit-test for  the mask.

                -  Appropriate cartridge/canister  is  used, and  its  service
                   limit concentration is not exceeded.

            b.  An air  surveillance program  is  part of all response opera-
                tions when atmospheric contamination is known or suspected.
                It is  particularly  important  that the  air  be  thoroughly
                monitored when personnel are wearing air-purifying respira-
                tors.  Periodic  surveillance using direct-reading  instru-
                ments and air  sampling  is needed to  detect  any  changes  in
                air quality  necessitating a  higher  level   of  respiratory
                protection.

            c.  Level  C  protection  with a  full-face,  air-purifying respi-
                rator should  be worn  routinely in an  atmosphere  only after
                the type  of air  contaminant  is  identified,  concentrations
                measured and the  criteria  for wearing air-purifying respi-
                rator met.  To permit flexibility  in  precribing  a Level  of
                Protection at certain environmental incidents,  a specialist
                could consider  using  air-purifying respirators  in  uniden-
                tified vapor/gas  concentrations  of  a  few parts  per  million
                above background as indicated by a needle deflection on the
                FID or PID.  However a needle deflection of a few parts per
                million above background  should not be the  sole  criterion
                for selecting Level  C.  Since the individual  components may
                never be  completely  identified,  a  decision  on  continuous
                wearing of Level  C must  be made after assessing  all  safety
                considerations, including:

                -  The presence of (or potential  for)  organic  or inorganic
                   vapors/gases against which  a  canister is  ineffective  or
                   has a short service life.

                -  The  known  (or  suspected)  presence  in  air of substances
                   with low TLVs or IDLH levels.

                -  The presence of particulates in air.

                -  The  errors  associated with  both  the instruments  and
                   monitoring procedures used.
*0ptional
                                 5-9

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                     The presence of (or potential for) substances  in  air
                     which do  not  elicit  a  response  on  the  instrument
                     used.

                     The potential for higher concentrations  in  the ambient
                     atmosphere or  in  the air  adjacent to  specific  site
                     operations.

                 The continuous use of air-purifying respirators  (Level  C)
                 must be  based on  the  identification of  the  substances
                 contributing to the total  vapor  or  gas concentration  and
                 the application of published. criteria  for the routine use
                 of air-purifying  devices.   Unidentified  ambient  concen-
                 trations of organic vapors or gases in air approaching  or
                 exceeding a few ppm above  background  require,  as  a mini-
                 mum, Level B protection.
      D.   Level  D  Protection

          1.   Personnel protective equipment

                Coveralls

              -  Gloves*

                Boots/shoes,  leather  or  chemical-resistant, steel toe and
                shank

              -  Safety glasses or chemical splash goggles*

              -  Hard  hat  (face shield)*

          2.   Criteria for selection

              Meeting  any of these criteria allows use of Level D  protection:

                No  contaminants are present.

              -  Work  functions  preclude  splashes, immersion, or  potential
                for unexpected inhalation of any  chemicals.

              Level  D  protection  is  primarily  a  work uniform.   It  can  be
              worn only in areas where there is no possibility of
              contact  with contamination.


III.   PROTECTION IN  UNKNOWN ENVIRONMENTS

      In  all  incident  response,  selecting the appropriate  personnel  pro-
      tection  equipment  is  one  of  the   first  steps  in  reducing  health
      effects  from   toxic  substances.    Until   the  toxics   hazards   at  an
      environmental  incident can be identified  and  personnel  safety measures
                                  5-10

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     commensurate with the  hazards  instituted, preliminary measures  will
     have to be based on experience, judgment, and professional  knowledge.
     One of the  first  concerns  in evaluating  an  unknown  situation  is
     atmospheric hazards.   Toxic  concentrations  (or  potential  concentra-
     tions) of vapors, gases,  and particulates; low  oxygen  content explo-
     sive potential  and, to a  lesser degree,  the  possibility of radiation
     exposure all represent immediate atmospheric  hazards.   In  addition to
     making air  measurements to  determine these  hazards, visual  observa-
     tion and  review  of existing data  can  help  determine the  potential
     risks from other materials.

     Once immediate hazards, other than toxic  substances have been elimi-
     nated, the  initial   on-site  survey   and reconnaissance,   which  may
     consist of more than one entry, continues.  Its  purpose is  to further
     characterize toxic  hazards   and,   based   on  these  findings,  refine
     preliminary safety  requirements.   As data  are  obtained  from  the
     initial survey, the Level  of Protection and  other  safety  procedures
     are adjusted.   Initial dat-a also provide information on which to base
     further monitoring and  sampling. No  one  method  can  determine a Level
     of Protection  in  all   unknown  environments.   Each situation  must  be
     examined individually.
IV-  ADDITIONAL CONSIDERATIONS FOR SELECTING LEVELS OF PROTECTION

     Other factors  which  should  be  considered  in  selecting  the  appro-
     priate Level of Protection are:

     A.  Heat and Physical Stress

         The use of protective clothing and respirators increases  physical
         stress, in particular heat stress,  on the wearer.  Chemical protec-
         tive clothing greatly reduces body ventilation and diminishes  its
         ability to  regulate  its  temperature.   Even in moderate  ambient
         temperatures the  diminished  capacity  of  the  body to  dissipate
         heat can result in one or more heat-related problems.

         All chemical protective  garments  can  cause heat  stress.   Some-
         what less  stress  is associated  with  Level  B  or  C  when  the
         protective clothing does  not  require the  use of  a hood,  tightly
         fitted against  the  respirator  face  piece,  and taped   glove,
         boot, suit  interfaces,  since  more body ventilation and  evapora-
         tion may occur.   As  more  body area is covered,  the  probability
         of heat stress increases.  Whenever any chemical-protective
         clothing is  worn,  a  heat  stress recovery  monitoring  program
         must occur (see Part  3, Section V).

         Wearing protective equipment  also  increases the  risk  of  acci-
         dents.  It  is  heavy,  cumbersome,  decreases dexterity,  agility,
         interferes with vision,  and  is  fatiguing  to wear. These  factors
                                  5-11

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    all  increase physical  stress  and  the  potential  of  accidents.
    In particular the  necessity  for  selecting  Level  A  protection,
    should be balanced against the  increased  probability  of physical
    stress and accidents.  Level  B and  C protection  somewhat  reduces
    accident probability,  because  the  equipment  is  lighter,  less
    cumbersome,  and  vision  problems  less serious.

B.  Air Surveillance

    A program must  be established for routine,  periodic air surveil-
    lance.  Without  an air  surveillance program,  any changes  could
    go undetected and  jeopardize response  personnel.   Surveillance
    can be  accomplished  with  various  types  of air  pumps  and  fil-
    tering devices   followed   by  analysis  of  the  filtering  media;
    portable real-time monitoring  instruments located  strategically
    on-site; personal  dosimeters;  and  periodic walk-throughs by
    personnel carrying direct-reading   instruments.    (See   Part  8)

C.  Decision-Logic  for Selecting  Protective  Clothing

    No adequate   criteria,   similar  to   the   respiratory   protection
    decision-logic,  are available for  selecting protective  clothing.
    A concentration  of a  known substance in  the  air approaching a TLV
    or permissible   exposure   limit  for   the   skin  does  not  automa-
    tically warrant  a  fully  encapsulating  suit.   A  hooded,  high
    quality, chemical-resistant suit may provide adequate  pro-
    tection.  The selection of  Level  A  over  Level   B  is  a judgment
    that should   be  made  by  a qualified individual  considering  the
    following factors:

    -  The  physical  form  of  the  potential   contaminant.  Airborne
       substances are  more  likely  for  body  contact with  personnel
       wearing non-encapsulating  suits,   since they  are  not  consid-
       ered to be gas  or  vapor tight.

       Effect of the material  on  skin:

       --   highly hazardous  substances   are those  that  are   easily
           absorbed  through  the  skin  causing  systemic  effects,  or
           that  cause  severe  skin  destruction.   Skin  contact  with
           liquids are  generally more  hazardous than  vapors,  gases
           and particulates.

       --   less  hazardous substances  are  those that  are  not  easily
           absorbed  through  the  skin  causing  systemic  effects,  or
           that  do not cause severe  skin destruction

    -   Concentration of the material -  the higher the  concentration,
       the higher the  risk of  harm.
                            5-12

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        -  The  potential   for  contact  with  the  material  due  to  work
           function and the probability  of direct exposure to the  small
           area of skin  unprotected  by Level  B  or C  chemical-resistant
           clothing.

    D.  Chemicals Toxic to Skin

        The chemicals listed in  Appendix  III  are identified in the  Oil
        and Hazardous  Materials  Technical  Assistance  Data  Base  System
        (OHMTADS) as  having adverse skin  effects  ranging  from irritation
        to absorption into the  body.   Knowledge  concerning the  presence
        or absence of  these  materials could  be  useful in  selecting  the
        necessary Level  of Protection.   Other substances affecting  the
        skin, but  not  listed  in OHMTADS,  may be present.  Therefore,  a
        major effort  should be made to identify all  substances.

    E.  Atmospheric Conditions

        Atmospheric conditions  such as stability, temperature, wind
        direction, wind  velocity,  and barometric  pressure  determine  the
        behavior of  contaminants  in  air  or the  potential  for  volatile
        material getting  into  air.  These  parameters  should be  consid-
        ered in determining the need  for and Level of  Protection
        required.

    F.  Work in Exclusion Zone

        For operations  in the  Exclusion   Zone  (area   of  potential  con-
        tamination),  different  Levels  of  Protection  may  be  selected,
        and various  types  of   chemical-resistant clothing  worn.   This
        selection would  be  based  not  only  on  measured  air   concen-
        trations, but also on  the  job function,   reason for being  in  the
        area, the  potential   for  skin  contact   or  inhalation   of  the
        materials present, and  ability  to decontaminate the  protective
        equipment used.   (See Part 6)

    G.  Escape Masks

        The use  of escape masks is an  option in Level C  protection.   A
        specialist should  determine their use  on a case-by-case  basis.
        Escape masks  could also be strategically  located on-site  in  areas
        that have higher possibilities for harmful exposure.


V.  VAPOR OR GAS CONCENTRATIONS AS  INDICATED BY DIRECT-READING INSTRUMENTS

    Instruments such  as the FID and PID can be used to  detect the presence
    of many organic vapors or gases either as single compounds or mixtures.
    Dial readings are frequently referred  to, especially with unidentified
    substances, as total  vapor and  gas  concentrations (in  ppm).   More
                                 5-13

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correctly they are deflections  of  the needle on  the  dial  indicating
an instrument response and does  not  directly  relate to total  concen-
tration in the air.   As  a guide to  selecting Level  of Protections,
based on dial readings response, the  following  values could be used.
They should  not  be  the sole  criteria for  selecting  Levels  of Pro-
tection.

          Dial  Reading                   Level  of Protection

         Background  to 5  ppm                      C
           above  background
         5 ppm above background                   B
           to 500 ppm above  background
         500 ppm  above background                A
           to 1000 ppm above  background

Vapor or gas  concentration, as indicated by the readout on instruments
such as the FIDs  or PIDs are a useful  adjunct to professional judgment
in selecting the  Level of Protection  to  be  worn  in an  unknown  envi-
ronment.  It should  not be the single selection  criterion,  but should
be considered with all other  available  information.  Total vapor  or
gas concentration as  selection   criteria  for  Levels  of  Protection
should only by used  by qualified  persons  thoroughly familiar with  the
information contained in Appendices I  and II.
                            5-14

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                                    PART 6

                          SITE CONTROL - WORK ZONES
  I.   INTRODUCTION
      The activities  required  during  responses  to  incidents   involving
      hazardous substances may contribute to the  unwanted movement  of  con-
      taminants from the  site to uncontaminated  areas.   Response personnel
      and equipment may become contaminated  and  transfer the  material  into
      clean areas.   Material may become  airborne due to its  volatility  or
      the disturbance  of  contaminated soil  may   cause  it  to become wind-
      blown.  To minimize the transfer  of hazardous  substances from  the
      site, contamination   control   procedures   are  needed.    Two  general
      methods are used:  establishing site work zones  and  removing
      contaminants from people and  equipment.


 II.   CONTROL AT THE SITE

      A site must  be  controlled  to reduce the possibility of:   1)  contact
      with any contaminants present and 2)  removal  of contaminants  by  per-
      sonnel or equipment  leaving the site.   The  possibility  of exposure  or
      translocation of substances  can  be  reduced or eliminated in a number
      of ways, including:

      -  Setting up  security  and physical  barriers  to  exclude unnecessary
         personnel  from the general area.

      -  Minimizing the number of personnel and equipment on-site  consistent
         with effective operations.

      -  Establishing work zones  within the site.

      -  Establishing  control  points  to  regulate access  to work  zones.

      -  Conducting operations in a manner to reduce the exposure  of  person-
         nel and equipment  and  to eliminate  the  potential  for airborne
         dispersion.

      -  Implementing appropriate decontamination procedures.


III.   WORK ZONES

      One method of  preventing  or  reducing the  migration  of contaminants
      is to delineate zones  on the site in  which prescribed operations occur.
      Movement of personnel and  equipment  between zones and  onto the  site
                                   6-1

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                        HOT LINE
EXCLUSION
  ZONE
                                    ACCESS CONTROL    \
                                        POINTS
                                                                WIND DIRECTION
                                 CONTAMINATION
                                    REDUCTION
                                    CORRIDOR
CONTAMINATION
REDUCTION ZONE
                                                            . CONTAMINATION
                                                             CONTROL LINE
                                                                      COMMAND
                                                                        POST
SUPPORT
  ZONE
                        DIAGRAM OF  SITE  WORK ZONES
                                  FIGURE 6-1

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itself would be  limited  by access  control  points.  By  these  means,
Three contiguous zones (Figure 6-1) are recommended:

Zone 1:  Exclusion Zone

Zone 2:  Contamination Reduction Zone

Zone 3:  Support Zone

A.  Zone 1:  Exclusion Zone

    The Exclusion  Zone,  the  innermost  of three  areas,  is  the  zone
    where contamination does or could occur.   All  people entering the
    Exclusion Zone  must  wear  prescribed Levels  of Protection.   An
    entry and exit  check  point must be  established  at  the periphery
    of the  Exclusion  Zone  to  regulate the  flow  of  personnel  and
    equipment into and out of the zone and to verify that the proced-
    ures established to enter and exit are followed.

    The outer  boundary of Zone  1,  the Hotline,  is  initially  estab-
    lished by  visually  surveying  the  immediate  environs  of  the
    incident and determining  where  the hazardous  substances involved
    are located;  where any drairtage,  leachate, or  spilled material
    is; and  whether  any  discolorations  are  visible.   Guidance  in
    determining the  boundaries  is  also  provided by  data  from  the
    initial site  survey  indicating  the  presence   of  organic  or  in-
    organic vapors/gases or  particulates in  air,  combustible  gases,
    and radiation,   or  the  results  of  water  and  soil   sampling.

    Additional factors that should be considered include the distances
    needed to  prevent  fire or an explosion  from  affecting personnel
    outside the  zone,  the  physical  area necessary  to  conduct  site
    operations, and  the potential  for contaminants to  be  blown  from
    the area.   Once the  Hotline has  been  determined  it   should  be
    physically secured, fenced,  or  well-defined by landmarks.  During
    subsequent site  operations,   the  boundary  may  be  modified  and
    adjusted as more information becomes available.

B.  Subareas Within  the Exclusion Zone

    All personnel  within  the  Exclusion  Zone must  wear  the required
    Level of Protection.   Personnel  protective equipment is designated
    based on  site-specific  conditions including  the type  of work to
    be done  and  the hazards  that  might be  encountered.  Frequently
    within the  Exclusion  Zone,  different Levels of  Protection  are
    justified.  Subareas are specified and conspicuously marked as to
    whether Level A, B, or C protection is required (Figure 6-2). The
    Level of Protection  is  determined by the  measured concentration
    of substances  in air,  potential  for contamination, and the known
    or suspected presence of highly toxic substances.
                             6-3

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    Different  Levels  of Protection  in  the  Exclusion Zone might  also
    be designated by  job  assignment.   For example,  collecting samples
    from open  containers  might require Level B protection,  while for
    walk-through ambient  air monitoring, Level C protection  might  be
    sufficient.   The  assignment,  when  appropriate,  of different
    Levels of  Protection  within  the  Exclusion  Zone generally  makes
    for a more flexible,  effective, and  less  costly operation  while
    still maintaining a  high degree  of safety.

C.  Zone 3:  Support  Zone

    The Support  Zone, the  outermost  part- of the site, is  considered a
    noncontaminated or clean area.  Support equipment  (command post,
    equipment  trailer, etc.)  is  located  in  the   zone;  traffic  is
    restricted to authorized  response  personnel.   Since normal  work
    clothes  are  appropriate within this zone, potentially contaminated
    personnel  clothing,  equipment,  and samples are  not  permitted, but
    are left  in  the  Contamination  Reduction  Zone until  they  are
    decontaminated.

    The location of the command post and other support  facilities  in
    the Support   Zone depends  on  a   number  of  factors,  including:

    -  Accessibility: topography; open space available;  locations  of
       highways, railroad  tracks;  or other  limitations.

    -  Wind  direction: preferably the  support facilities   should  be
       located upwind  of  the  Exclusion  Zone.   However,  shifts  in
       wind  direction and other conditions may be  such  that an  ideal
       location  based on  wind direction alone  does  not  exist.

    -  Resources:   adequate  roads,  power lines,  water,   and  shelter.

D.  Zone 2:   Contamination Reduction Zone

    Between  the  Exclusion  Zone and  the Support Zone is  the  Contamina-
    tion Reduction Zone which provides a transition between  contam-
    inated and clean  zones.   Zone 2  serves  as  a  buffer to  further
    reduce the probability of the clean zone becoming contaminated  or
    being affected by other  existing hazards.  It provides  additional
    assurance  that the physical transfer of contaminating  substances
    on people, equipment,  or in the  air is  limited  through  a combina-
    tion of decontamination, distance  between  Exclusion and  Support
    Zones, air  dilution,   zone   restrictions,  and  work  functions.

    Initially, the Contamination  Reduction  Zone  is  considered to be a
    noncontaminated area.   At the boundary between  the  Exclusion and
    Contamination Reduction  Zones,  Contmination  Reduction  Corridors
    (decontamination  stations) are  established,  one  for  personnel
    and one for heavy equipment.   Depending on the  size  of the opera-
    tion, more than  two corridors  may be  necessary.  Exit  from the
                             6-4

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         Exclusion Zone is  through a Contamination Reduction  Corridor.   As
         operations proceed, the  area  around the  decontamination  station
         may become  contaminated,  but to  a much  lesser  degree than  the
         Exclusion Zone.  On a relative  basis, the amount  of contaminants
         should decrease from the Hotline  to  the Support  Zone due to  the
         distance involved  and the decontamination procedures used.

         The boundary between  the  Support Zone and the Contamination Reduc-
         tion Zone, the Contamination Control  Line, separates the possibly
         low contamination  area from the  clean  Support  Zone.  Access  to
         the Contamination  Reduction Zone from the Support  Zone  is  through
         a control point.   Personnel  entering there  would wear the pre-
         scribed personnel  protective equipment,   if  required, for  working
         in the Contamination  Reduction  Zone.   Entering  the  Support Zone
         requires removal of any protective equipment worn  in the Contami-
         nation Reduction Zone.
IV.   OTHER CONSIDERATIONS

     A.  Modifications

         The use of a three-zone  system,  access  control  p_oints,  and  exac-
         ting decontamination procedures  provides  a reasonable  assurance
         against the translocation of contaminating  substances.   This  site
         control system is based on a worst case situation.  Less  string-
         ent site control  and  decontamination  procedures may be utilized
         if more  definitive information  is  available  on  the  types of
         substances  involved and  hazards  they  present.  This information
         can be  obtained  through  air  monitoring,   instrument  survey and
         sampling, and technical  data  concerning  the characteristics and
         behavior of material present.

     B.  Area Dimensions

         The distance between the Hotline, Contamination  Control  Line, and
         command post and the size and  shape of each zone have to be  based
         on conditions specific to each site (Figures 6-2 and 6-3).   Con-
         siderable judgment is  needed to assure that the  distances  between
         zone boundaries are large enough to allow  room  for the  necessary
         operations, provide adequate distances to  prevent  the  spread of
         contaminants, and  eliminate the  possiblity of injury due to ex-
         plosion or  fire.   Long-term  operations  would involve  developing
         reasonable  methods (for example,  air surveillance,  swipe testing,
         and visible  deterioration)  to determine   if  material   is  being
         transferred between zones and to assist in modifying site bound-
         aries.

         The following criteria should be considered  in  establishing  area
         dimensions  and boundaries:
                                  6-5

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    -   Physical and topographical  features  of  the  site.

    -   Weather  conditions.

    -   Field/laboratory measurements of  air contaminants  and  environ-
       mental samples.

    -   Air  dispersion calculations.

    -   Potential  for explosion and flying debris.

    -   Physical,  chemical, toxicological, and other characteristics of
       the  substances present.

    -   Cleanup  activities  required.

    -   Potential  for fire.

    -   Area needed to conduct operations.

    -   Decontamination  procedures.

    -   Potential  for exposure.

    -   Proximity  to  residential  or industrial  areas.

C.  Monitoring  and Sampling

    To verify  that  site control  procedures  are preventing the  spread
    of contamination,  a  monitoring and  sampling program  should  be
    established.  The  Support Zone should  be  periodically monitored
    for air contaminants  using  direct-reading  instruments  and  col-
    lecting air  samples  for particulate,   gas,   or  vapor analysis.
    Analysis of soil samples collected  in the  most heavily trafficked
    area would  indicate contaminants being  carried from the Exclusion
    Zone by personnel,  equipment,   or  wind.  Occassional  swipe  tests
    should  be  taken  in trailers and  other  areas  used by personnel.

    These same  types of samples  should  be collected  and air monitored
    in the  Contamination  Reduction  Zone.  Increased  concentrations in
    air or   other environmental  media  may  indicate  a  breakdown  in
    control  over  the Contamination Reduction  Corridor,   ineffective
    decontamination procedures,  or failure  to restrict  site  access.
                             6-6

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      CONTAMINATION REDUCTION
              ZONE
EXCLUSION ZONE
   (LEVEL  C)
                                                  LEGEND
                                                 ACCESS CONTROL
                                                 POINT

                                                 DECONTAMINATION
                                                 STATION

                                                 8 ACRE,
                                                 EXCLUSION ZONE
       NEW HAMPSHIRE WASTE SITE
            FIGURE 6-2

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en
CO
                                                                                        LEGEND


                                                                                    RAILROAD TRACK

                                                                                    ACCESS CONTROL POINT

                                                                                    DECONTAMINATION STATION

                                                                                    81/2  ACRE FENCED EXCLUSION
                                                                                         ZONE
                                                                  CONTAMINATION REDUCTION
                                                                         ZONE
                                                               LOCK HAVEN WASTE SITE
                                                                    FIGURE 6-3

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                                   PART 7

                       SITE CONTROL - DECONTAMINATION
 I.  INTRODUCTION
     Personnel responding  to  hazardous   substance  incidents  may  become
     contaminated in a number of ways including:

     -  Contacting  vapors,  gases,  mists,  or  particulates   in  the  air.

     -  Being splashed by materials while  sampling  or opening containers.

     -  Walking  through  puddles   of  liquids   or  on  contaminated  soil.

     -  Using contaminated instruments or equipment.

     Protective clothing  and  respirators  help  prevent  the  wearer  from
     becoming contaminated  or  inhaling  contaminants;  while  good  work
     practices help  reduce  contamination on protective  clothing,  instru-
     ments, and equipment.

     Even with these  safeguards,  contamination may occur.   Harmful  mate-
     rials can  be  transferred  into  clean  areas,  exposing  unprotected
     personnel.  In removing contaminated  clothing, personnel  may  contact
     contaminants on the clothing  or  inhale them.  To prevent  such  occur-
     rences, methods to  reduce  contamination,  and  decontamination  proced-
     ures must be  developed  and established  before  anyone enters  a  site
     and must  continue  (modified when  necessary)  throughout  site  opera-
     tions.

     Decontamination consists of physically removing  contaminants or
     changing their chemical  nature to innocuous substances.  How extensive
     decontamination must  be  depends on a  number  of  factors,  the  most
     important being the type  of contaminants  involved.   The more  harmful
     the contaminant, the more extensive and thorough  decontamination must
     be.  Less  harmful   contaminants  may  require  less  decontamination.

     Combining decontamination, the  correct method  of  doffing  personnel
     protective equpment, and the use of site  work  zones minimizes  cross-
     contamination from protective  clothing to wearer, equipment  to
     personnel, and  one  area  to another.   Only  general guidance  can  be
     given on  methods  and  techniques   for  decontamination.   The  exact
     procedure to  use  must  be determined  after evaluating  a number  of
     factors specific to the incident.


II.   PRELIMINARY  CONSIDERATIONS

     A.  Initial  Planning

         The initial decontamination plan assumes all  personnel and equip-
         ment leaving the Exclusion Zone (area of potential contamination)


                                 7-1

-------
    are grossly contaminated.  A  system  is then  set  up for personnel
    decontamination to wash  and  rinse,  at  least once,  all  the pro-
    tective equipment  worn.   This  is  done   in  combination  with  a
    sequential  doffing of protective equipment, starting at the first
    station with the  most  heavily contaminated  item  and progressing
    to the  last  station  with the  least  contaminated  article.   Each
    piece precedure requires  a separate station.

    The spread of  contaminants during  the washing/doffing  process  is
    further reduced  by  separating each decontamination  station  by a
    minimum of 3  feet.   Ideally,  contamination  should  decrease  as a
    person moves  from  one station  to another  further along  in  the
    1 ine.

    While planning  site  operations, methods  should  be  developed  to
    prevent the contamination of people  and  equipment.   For example,
    using remote sampling techniques,  not opening containers by hand,
    bagging monitoring  instruments,  using drum  grapplers,  watering
    down dusty areas, and  not  walking through areas of obvious  con-
    tamination would  reduce the probability  of becoming contaminated
    and require a less elaborate  decontamination  procedure.

    The initial decontamination plan  is  based  on a worst-case  situ-
    ation or assumes  no  information is available about the  incident.
    Specific conditions  at the  site  are then evaluated,  including:

    -   Type of contaminant.

    -   The amount of contamination.

       Levels of protection required.

       Type of protective clothing worn.

    The initial decontamination plan is modified,  eliminating unneces-
    sary stations  or  otherwise adapting  it  to site conditions.  For
    instance, the  initial  plan  might  require a complete  wash and
    rinse of chemical  protective  garments.   If  disposable  garments
    are worn,  the  wash/rinse step  could be  omitted.   Wearing  dis-
    posable boot  covers   and  gloves   could   eliminate  washing  and
    rinsing these  items  and  reduce the  number  of  stations  needed.

B.   Contamination Reduction Corridor

    An area within the Contamination Reduction  Zone  is  designated the
    Contamination Reduction Corridor (CRC).   The CRC controls  access
    into and out  of  the  Exclusion Zone and  confines  decontamination
    activities  to a limited area.   The size  of  the corridor  depends
    on the  number  of stations  in  the  decontamination  procedure,
                             7-2

-------
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CONTAMINATION REDUCTION ZONE LAYOUT
              FIGURE 7-1
           7-3

-------
         overall dimensions  of work  control  zones,  and amount  of  space
         available at the  site.   A  corridor of 75  feet  by  15 feet  should
         be adequate  for  full  decontamination.    Whenever  possible,   it
         should be a straight path.

         The CRC boundaries should be conspicuously marked, with entry  and
         exit  restricted.   The far  end  is  the  hotline  -  the  boundary
         between the Exclusion  Zone  and the Contamination Reduction  Zone.
         Personnel exiting  the Exclusion  Zone must  go through  the CRC.
         Anyone in  the  CRC  should  be wearing the  Level   of Protection
         designated for the decontamination  crew.  Another  corridor  may  be
         required for heavy equipment needing decontamination.  Within  the
         CRC,  distinct areas  are  set aside for decontamination of person-
         nel,  portable  field  equipment,   removed   clothing,   etc.    These
         areas  should  be  marked and  personnel  restricted to those wearing
         the appropriate  Level  of Protection.  All activities within  the
         corridor are confined to decontamination.

         Personnel protective clothing, respirators, monitoring equipment,
         and sampling  supplies are  all  maintained outside  of  the CRC.
         Personnel don their  protective equipment  away from  the  CRC  and
         enter  the Exclusion  Zone through  a separate access control  point
         at the hotline.
III.   EXTENT  OF DECONTAMINATION REQUIRED

      A.   Modifications of Initial Plan

          The original  decontamination plan  must  be  adapted  to specific
          conditions  found at incidents.  These conditions may  require more
          or  less  personnel  decontamination than  planned,  depending  on a
          number of factors.

          1.   Type of Contaminant

              The extent of personnel  decontamination depends  on the effects
              the contaminants have  on the body.   Contaminants do not  ex-
              hibit the  same  degree  »f toxicity  (or  other  hazard).  When-
              ever it  is  known   or   suspected  that personnel  can  become
              contaminated with highly toxic or skin-destructive substances,
              a full decontamination procedure should be followed.  If less
              hazardous materials are  involved,  the procedure can be down-
              graded.

          2.   Amount of Contamination

              The amount of contamination on protective clothing  is usually
              determined visually.  If it is badly  contaminated,  a thorough
              decontamination is generally required. Gross material remain-
              ing on  the  protective  clothing  for  any extended  period  of
              time may degrade  or permeate it.   This  likelihood  increases
                                  7-4

-------
    with higher air concentrations  and  greater amounts of liquid
    contamination.  Gross contamination also increases the proba-
    bility of personnel  contact.   Swipe  tests  may help determine
    the type and quantity of surface contaminants.

3.  Level  of Protection

    The Level of Protection and  specific  pieces  of  clothing  worn
    determine on a preliminary  basis the layout of the decontamin-
    ation line.  Each  Level  of Protection incorporates different
    problems in decontamination and doffing of the equipment.  For
    example: decontamination of  the  harness  straps  and  backpack
    assembly of the  self-contained  breathing  apparatus  is "dif-
    ficult.  A  butyl   rubber apron  worn  over  the  harness  makes
    decontamination easier.   Clothing  variations  and  different
    Levels of Protection may require  adding  or deleting  stations
    in the original decontamination procedure.

4.  Work Function

    The work each person does determines the  potential for contact
    with hazardous materials.   In  turn,  this dictates the layout
    of the decontamination  line.   For example, observers, photo-
    graphers, operators  of air  samplers, or  others in  the  Ex-
    clusion Zone  performing  tasks that  will   not  bring  them  in
    contact with contaminants may not need to have their  garments
    washed and  rinsed.   Others   in  the  Exclusion   Zone  with  a
    potential for direct contact with the hazardous material  will
    require more thorough decontamination.  Different decontamin-
    ation lines  could  be set up  for  different  job  functions,  or
    certain stations in  a line  could be omitted  for  personnel
    performing certain tasks.

5.  .Location of Contamination

    Contamination on the upper areas of protective clothing poses
    a greater  risk  to  the worker because  volatile  compounds  may
    generate a  hazardous  breathing  concentration  both   for  the
    worker and  for  the decontamination  personnel.  There  is  also
    an increased  probability  of  contact  with  skin  when  doffing
    the upper part of clothing.

6.  Reason for Leaving Site

    The reason for leaving the Exclusion Zone also determines the
    need and  extent of  decontamination.   A  worker  leaving  the
    Exclusion Zone  to  pick up or  drop  off tools  or instruments
    and immediately returning may not require decontamination.  A
    worker leaving  to   get  a  new  air  cylinder   or  to change  a
    respirator or  canister,  however,  may require  some degree  of
    decontamination.  Individuals departing the  CRC for  a break,
    lunch, or at the end of day, must be thoroughly decontaminated.
                         7-5

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B.  Effectiveness of Decontamination

    There is no method to  immediately  determine  how effective decon-
    tamination is in removing contaminants.   Discolorations, stains,
    corrosive effects,  and  substances   adhering  to  objects may  in-
    dicate contaminants have not  been   removed.   However,  observable
    effects only indicate  surface  contamination  and  not  permeation
    (absorption) into  clothing.    Also  many  contaminants  are  not
    easily observed.

    A method for determining effectiveness of surface decontamination
    is swipe testing.  Cloth  or  paper   patches  -  swipes -  are  wiped
    over predetermined  surfaces of the  suspect object and analyzed in
    a laboratory.   Both  the inner  and  outer surfaces  of  protective
    clothing should be  swipe tested.   Positive  indications of  both
    sets of swipes  would indicate  surface  contamination has not been
    removed and substances  have  penetrated or permeated through  the
    garment.  Swipe tests can also be done  on  skin or inside clothing.
    Permeation of protective garments requires laboratory analysis of
    a piece  of  the material.   Both  swipe   and  permeation  testing
    provide after-the-fact   information.    Along  with  visual  obser-
    vations, results of  these tests  can  help evaluate the  effec-
    tiveness of decontamination.

C.  Equipment

    Decontamination equipment,  materials, and supplies  are  generally
    selected based on availability.  Other considerations are ease of
    equipment decontamination or   disposabi1ity.   Most  equipment  and
    supplies can be easily  procured. For example,  soft-bristle  scrub
    brushes or long-handle  brushes  are  used  to remove  contaminants.
    Water in buckets or  garden  sprayers  is  used  for  rinsing.  Large
    galvanized wash tubs  or  stock tanks  can  hold  wash  and  rinse
    solutions.  Children's   wading  pools  can  also  be used.   Large
    plastic garbage  cans  or other similar  containers  lined  with
    plastic bags store  contaminated clothing  and  equipment.   Contam-
    inated liquids  can  be stored temporarily  in metal  or plastic cans
    or drums.  Other gear  includes paper or  cloth towels  for drying
    protective clothing and equipment.

D.  Decontamination Solution

    Personnel  protective  equipment, sampling  tools, and  other equip-
    ment are usually decontaminated by  scrubbing with detergent-water
    using a  soft-bristle  brush   followed  by  rinsing  with  copious
    amounts of water.   While this process may not  be  fully effective
    in removing some contaminants  (or  in  a  few cases,  contaminants
    may  react with  water),  it  is  a relatively  safe  option  compared
    with using a  chemical  decontaminating solution.   This  requires
    that the contaminant  be identified.   A   decon  chemical is then
    needed that will  change  the  contaminant  into  a  less  harmful
    substance.   Especially   troublesome   are   unknown  substances   or
                            7-6

-------
         mixtures  from a  variety  of known  or  unknown  substances.   The
         appropriate decontamination solution must  be  selected  in  consul-
         tation with an experienced chemist.

     E.   Establishment of Procedures

         Once decontamination procedures  have been established, all  person-
         nel  requiring decontamination must  be  given  precise  instructions
         (and practice,  if  necessary).   Compliance  must  be  frequently
         checked.   The time  it takes for  decontamination  must be  ascer-
         tained.  Personnel wearing SCBA's  must leave  their work area  with
         sufficient air to  walk to  CRC and  go  through  decontamination.


IV.   DECONTAMINATION DURING MEDICAL EMERGENCIES

     A.   Basic Considerations

         Part of overall  planning for incident response is  managing  medical
         emergencies.  The plan should provide for:

         -  Response  team  members   fully trained in  first aid and  CPR.

         -  Arrangements with the nearest medical facility for transporta-
            tion and treatment of  injured, and  for  treatment  of personnel
            suffering from exposure to chemicals.

         -  Consultation services with a toxicologist.

         -  Emergency eye washes, showers,  and/or wash stations.

         -  First aid kits, blankets, stretcher, and resuscitator.

         In addition, the plan should establish methods for decontaminating
         personnel with  medical  problems   and  injuries.   There  is   the
         possibility that the decontamination may aggravate or  cause  more
         serious health  effects.   If  prompt  life-saving   first  aid  and
         medical treatment is  required,  decontamination procedures  should
         be omitted.  Whenever  possible,  response personnel  should  accom-
         pany contaminated victims  to the medical  facility to advise  on
         matters involving decontamination.

     B.   Physical  Injury

         Physical  injuries can  range  from  a sprained ankle to  a  compound
         fracture, from a minor cut to massive bleeding.   Depending on the
         seriousness of the  injury, treatment may be  given  at the  site by
         trained response personnel.  For more  serious injuries, additional
         assistance may be required at the  site or  the victim may have to
         be treated at a medical facility.
                                  7-7

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    Life-saving  care  should  be  instituted  immediately  without consid-
    ering decontamination.    The   outside   garments   can  be  removed
    (depending on  the weather)  if  they  do  not  cause  delays,  interfere
    with treatment,  or  aggravate the problem.  Respirators  and  back-
    pack assemblies   must  always  be  removed.   Fully  encapsulating
    suits or  chemical-resistant  clothing   can  be cut away.  If  the
    outer contaminated garments cannot be safely removed, the individ-
    ual  should  be wrapped  in  plastic,  rubber,  or  blankets to  help
    prevent contaminating the inside of ambulances and  medical  person-
    nel.  Outside  garments  are then removed at the  medical  facility.
    No attempt  should be  made to  wash or rinse the victim at  the
    site.  One  exception would be  if it is  known that the individual
    has  been  contaminated   with   an  extremely   toxic  or  corrosive
    material  which could also  cause  severe injury  or  loss  of  life.
    For  minor medical problems or injuries, the normal  decontamination
    procedure should  be  followed.

C.  Heat Stress

    Heat-related  illnesses  range  from  heat fatigue to  heat  stroke,
    the  most  serious.   Heat   stroke  requires  prompt  treatment   to
    prevent irreversible damage or  death.  Protective  clothing  may
    have to  be  cut  off.  Less  serious forms  of  heat stress  require
    prompt attention  or  they may  lead to  a heat  stroke.  Unless  the
    victim is obviously  contaminated, decontamination  should be
    omitted or minimized and treatment  begun immediately.

D.  Chemical  Exposure

    Exposure  to  chemicals can be divided into  two  categories:

    -  Injuries  from  direct  contact, such  as acid  burns  or inhalation
       of toxic  chemicals.

    -  Potential  injury  due  to gross  contamination  on clothing  or
       equipment.

    For  inhaled  contaminants  treatment   can  only  be  by  qualified
    physicians.   If  the  contaminant is  on the skin or in  the  eyes,
    immediate measures must  be  taken  to  counteract the  substance's
    effect.   First aid  treatment  usually  is   flooding  the  affected
    area with water;  however,  for  a  few  chemicals,  water may  cause
    more severe  problems.

    When protective  clothing  is   grossly  contaminated,   contaminants
    may  be transferred  to  treatment   personnel   or  the  wearer  and
    cause injuries.   Unless   severe medical  problems  have   occurred
    simultaneously with  splashes,  the protective  clothing  should  be
    washed off as  rapidly as possible and  carefully  removed.

-------
 V.   PROTECTION FOR DECONTAMINATION WORKERS

     The Level of Protection worn by decontamination workers is determined
     by:

     -  Expected or visible contamination on workers.

     -  Type  of  contaminant and associated  respiratory  and skin hazards.

     -  Total  vapor/gas  concentrations  in  the  contamination  reduction
        corridor.

     -  Participates and specific inorganic  or  organic  vapors  in the CRC.

     -  Results of'swipe tests.

     A.  Level C Use

         Level C includes a full-face, canister-type air-purifying
         respirator, hard hat  with  face shield (if  splash  is  a problem),
         chemical-resistant boots  and  gloves,  and  protective  clothing.
         The body covering recommended is chemical-resistant overalls with
         an apron, or chemical-resistant overalls  and jacket.

         A face shield  is  recommended to protect  against  splashes because
         respirators alone may not provide this protection.  The respirator
         should have a  canister approved  for filtering  any  specific  known
         contaminants such  as ammonia,  organic  vapors,  acid   gases,  and
         particulates.

     B.  Level B Use

         In situations  where  site  workers  may be  contaminated  with  un-
         knowns, highly  volatile  liquids,  or  highly  toxic   materials,
         decontamination workers should wear Level B protection.
         Level B  protection  includes  SCBA,  hard hat  with face  shield,
         chemical-resistant gloves, and protective covering.  The clothing
         suggested is  chemical-resistant overalls,  jacket, and  a  rubber
         apron.  The  rubber apron  protects the SCBA  harness assembly  and
         regulator from becoming contaminated.


VI.   DECONTAMINATION OF EQUIPMENT

     Insofar as possible, measures should be  taken to prevent contamination
     of sampling and  monitoring  equipment.   Sampling devices  become con-
     taminated, but  monitoring  instruments, unless  they  are  splashed,
     usually do  not.   Once  contaminated,   instruments  are difficult  to
     clean without damaging them.  Any delicate instrument which cannot be
     easily decontaminated should be protected while it is being used.   It
                                  7-9

-------
should be placed in a clear plastic bag, and the bag taped and secured
around the  instrument.   Openings  are made  in  the  bag  for  sample
intake.

A.  Decontamination  Procedures

    1.  Sampling devices

        Sampling devices  require special  cleaning.  The  EPA Regional
        Laboratories  can  provide information on proper decontamination
        methods.

    2.  Tools

        Wooden tools   are difficult  to  decontaminate  because  they
        absorb chemicals.  They  should  be kept  on site  and handled
        only by  protected  workers.   At  the   end   of the  response,
        wooden tools  should  be  discarded.   For decontaminating
        other tools,  Regional Laboratories  should be consulted.

    3.  Respirators

        Certain parts of  contaminated respirators, such as the harness
        assembly and leather or cloth components,  are  difficult  to
        decontaminate.   If  grossly contaminated, they may have to  be
        discarded.  Rubber  components  can  be  soaked in soap and water
        and scrubbed  with  a brush.   Regulators  must be  maintained
        according to manufacturer's recommendations.  Persons respon-
        sible for decontaminating  respirators  should be  thoroughly
        trained in respirator maintenance.

    4.  Heavy Equipment

        Bulldozers,  trucks,   back-hoes,  bulking  chambers,  and  other
        heavy equipment  are  difficult  to decontaminate.   The  method
        generally used is to wash them with water under high pressure
        and/or to scrub accessible parts with  detergent/water solution
        under pressure, if  possible.   In  some  cases, shovels, scoops,
        and lifts have been  sand  blasted or steam cleaned.  Particular
        care must be given  to those components in direct  contact with
        contaminants  such as tires and scoops.  Swipe  tests  should  be
        utilized to  measure  effectiveness.

B.  Sanitizing of Personnel  Protective Equipment

    Respirators, reusable protective  clothing,  and  other  personal
    articles not only must  be decontaminated  before being reused, but
    also sanitized.   The  inside  of masks and  clothing becomes soiled
    due to  exhalation,  body oils,  and  perspiration.  The manufac-
    turer's instructions  should  be used  to  sanitize  the  respirator
    mask.  If practical,  protective clothing  should be machine washed
    after a thorough decontamination;  otherwise it must be cleaned by
    hand.
                             7-10

-------
      C.   Persistent Contamination

          In some instances,  clothing  and  equipment will become  contamin-
          anted with substances that  cannot be removed by normal  decontamin-
          ation procedures.  A solvent  may  be used to remove such  contamin-
          ation from equipment  if  it does  not destroy or degrade  the  pro-
          tective material.  If persistent  contamination is  expected,
          disposable garments  should  be  used.   Testing  for   persistent
          contamination of protective clothing and appropriate decon-
          tamination must be done by qualified laboratory personnel.

      D.   Disposal of Contaminated Materials

          All  materials  and  equipment used  for  decontamination  must  be
          disposed of  properly.   Clothing,  tools,  buckets,  brushes,  and
          all  other equipment that is contaminated must be secured in  drums
          or other containers  and labeled.   Clothing  not completely decon-
          taminated on-site should be  secured  in  plastic bags before  being
          removed from the site.

          Contaminated wash  and   rinse  solutions  should be  contained  by
          using step-in-containers (for  example,  child's  wading  pool)  to
          hold spent  solutions.   Another  containment  method is  to  dig  a
          trench about 4  inches deep  and  line  it  with plastic.   In  both
          cases the  spent  solutions are transferred  to drums, which  are
          labeled and disposed of with  other substances on site.
VII.  ANNEXES
      Annex 1,  2,  and  3  describe basic  decontamination  procedures for  a
      worker wearing Level A, B, or C protection.  The basic decontamination
      lines (Situation  1),  consisting  of approximately  19 stations,  are
      almost identical  except  for changes  necessitated by  different  pro-
      tective clothing  or  respirators.   For  each  annex,  three  specific
      situations are described in which the basic (or full  decontamination)
      procedure is  changed  to  take  into account differences in  the extent
      of contamination, the accompanying  changes  in  equipment  worn,  and
      other factors.   The  situations  illustrate  decontamination  setups
      based on  known  or  assumed conditions  at  an  incident.   Many  other
      variations are possible.

      Annex 4 describes a minimum layout  for  Level  A personnel  decontamin-
      ation.  The number of  individual  stations  have been reduced.  Although
      the decontamination  equipment  and amount  of  space  required  is  less
      than needed  in  the  procedures  previously described,  there  is also  a
      much higher probability of cross-contamination.
                                   7-11

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                                 ANNEX 1

                         LEVEL A DECONTAMINATION
A.  EQUIPMENT WORN
    The full decontamination procedure outlined is for workers wearing
    Level A protection (with taped joints between gloves, boots, and
    suit) consisting of:

    -  Fully encapsulating suit.

    -  Self-contained breathing apparatus.

    -  Hard hat (optional).

    -  Chemical-resistant, steel toe and shank boots.

    -  Boot covers.

       Inner and outer gloves.


B.  PROCEDURE FOR FULL DECONTAMINATION

    Station 1:  Segregated Equipment Drop

    Deposit equipment used on-site (tools, sampling devices and containers,
    monitoring instruments, radios, clipboards, etc.) on plastic drop
    cloths or in different containers with plastic liners.  Each will be
    contaminated to a different degree.  Segregation at the drop reduces
    the probability of cross-contamination.

         Equipment:  various size containers
                     plastic liners
                     plastic drop cloths

    Station 2:  Boot Cover and Glove Wash

    Scrub outer boot covers and gloves with decon solution or detergent/
    water.

         Equipment:  container (20-30 gallons)
                     decon solution
                           or
                     detergent water
                     2-3 long-handle, soft-bristle scrub brushes
                                   Al-1

-------
Station 3:  Boot Cover and Glove Rinse

Rinse off decon solution from Station 2 using copious amounts of
water.  Repeat as many times as necessary.

     Equipment:  container (30-50 gallons)
                          or
                 high-pressure spray unit
                 water
                 2-3 long-handle, soft-bristle scrub brushes

Station 4:  Tape Removal

Remove tape around boots and gloves and deposit in container with
plastic liner.

     Equipment:  container (20-30 gallons)
                 plastic liners

Station 5:  Boot Cover Removal

Remove boot covers and deposit  in container with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners
                 bench or stool

Station 6:  Outer Glove Removal

Remove outer gloves and deposit in container with plastic liner.

     Equipment:  container (20-30 gallons)
                 plastic liners

Station 7:  Suit/Safety Boot Wash

Thoroughly wash fully encapsulating suit and boots.   Scrub suit
and boots with long-handle,  soft-bristle scrub brush and copious
amounts of decon solution or detergent/water.   Repeat as many
times as necessary.

     Equipment:  container (30-50 gallons)
                 decon solution
                       or
                 detergent/water
                 2-3 long-handle, soft-bristle scrub brushes
                               Al-2

-------
Station 8:  Suit/Safety Boot Rinse

Rinse off decon solution or detergent/water using copious amounts
of water.  Repeat as many times as necessary.

     Equipment:  container (30-50 gallons)
                           or
                 high-pressure spray unit
                 water
                 2-3 long handle, soft-bristle scrub brushes

Station 9:   Tank Change

If worker leaves Exclusion Zone to change air tank, this is the
last step in the decontamination procedure.  Worker's air tank is
exchanged, new outer gloves and boots covers donned, and joints
taped. Worker then returns to duty.

     Equipment:  air tanks
                 tape
                 boot covers
                 gloves

Station 10:  Safety Boot Removal

Remove safety boots and deposit in container with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners
                 bench or stool
                 boot jack

Station 11:  Fully Encapsulating Suit and Hard Hat Removal

With assistance of helper, remove fully encapsulating suit (and
hard hat).  Hang suits on rack or lay out on drop cloths.

     Equipment:  rack
                 drop cloths
                 bench or stool

Station 12:  SCBA Backpack Removal

While still wearing facepiece, remove backpack and place on table.
Disconnect hose from regulator valve and proceed to next station.

     Equipment:  table
                               Al-3

-------
Station 13:   Inner Glove  Wash

Wash with decon  solution  or  detergent/water that will not harm
skin. Repeat as  many times  as  necessary.

     Equipment:   basin  or bucket
                 decon  solution
                      or
                 detergent/water
                 small  table

Station 14:   Inner Glove  Rinse

Rinse with water.  Repeat as many times  as necessary.

     Equipment:   water  basin
                 basin  or bucket
                 small  table

Station 15:   Facepiece  Removal

Remove facepiece.  Deposit  in  container  with plastic liner.  Avoid
touching face with fingers.

     Equipment:   container (30-50 gallons)
                 plastic  liners

Station 16:   Inner Glove  Removal

Remove inner gloves and deposit  in container with plastic liner.

     Equipment:   container (20-30 gallons)
                 plastic  liners

Station 17:   Inner Clothing Removal

Remove clothing  soaked  with  perspiration.  Place in container with
plastic liner.  Inner clothing should be removed as soon as possible
since there is a possibility that small  amounts of contaminants might
have been transferred in  removing fully  encapsulating suit.

     Equipment:   container (30-50 gallons)
                 plastic  liners

Station 18:   Field Wash

Shower if highly toxic, skin-corrosive or skin-absorbable materials
are known or suspected to be present. Wash hands and face  if shower
is not available.
                               Al-4

-------
         Equipment:  water
                     soap
                     small table
                     basin or bucket
                     field showers
                     towels

    Station 19:  Redress
    Put on clean clothes.  A dressing trailer is needed in inclement  weather.
         Equipment:  tables
                     chairs
                     lockers
                     clothes
C.  FULL DECONTAMINATION (SIT. 1) AND THREE MODIFICATIONS
s
I
T
1
2
3
4
STATION NUMBER
1
X
X
X
X
2
X
X


3
X
X


4
X
X


5
X
X


6
X
X


7
X
X
X
X
8
X
X
X
X
9

X

X
10
X

X

11
X

X

12
X

X

13
X



14
X



15
X

X

16
X

X

17
X

X

18
X

X

19
X



    Situation 1:  The individual entering the Contamination Reduction
    Corridor is observed to be grossly contaminated or extremely toxic
    substances are known or suspected to be present.

    Situation 2:  Same as Situation 1 except individual  needs new air tank
    and will return to Exclusion Zone.
                                   Al-5

-------
Situation 3:   Individual  entering  the  CRC is  expected to be minimally
contaminated.   Extremely  toxic  or  skin-corrosive materials are not
present.   No  outer gloves or  boot  covers  are  worn.   Inner gloves are
not contaminated.

Situation 4:   Same as  Situation  3  except  individual  needs new air tank
and will  return to Exclusion  Zone.
                              Al-6

-------
                                 ANNEX 2

                         LEVEL B DECONTAMINATION
A.  EQUIPMENT WORN
    The full decontamination procedure outlined is for workers wearing
    Level B protection (with taped joints between gloves, boot, and suit)
    consisting of:

    -  One-piece, hooded, chemical-resistant splash suit.

    -  Self-contained breathing apparatus.

    -  Hard hat.

    -  Chemical-resistant, steel toe and shank boots.

    -  Boot covers

    -  Inner and outer gloves.


B.  PROCEDURE FOR FULL DECONTAMINATION

    Station 1:  Segregated Equipment Drop

    Deposit equipment used on-site (tools, sampling devices and containers,
    monitoring instruments, radios, clipboards, etc.) on plastic drop
    cloths or in different containers with plastic liners.  Each will  be
    contaminated to a different degree.  Segregation at the drop reduces
    the probability of cross-contamination.

         Equipment:  various size containers
                     plastic liners
                     plastic drop cloths

    Station 2:  Boot Cover and Glove Wash

    Scrub outer boot covers and gloves with decon solution or detergent/
    water.

         Equipment:  container (20-30 gallons)
                     decon solution
                           or
                     detergent water
                     2-3 long-handle, soft-bristle scrub brushes
                                   A2-1

-------
Station 3:   Boot Cover and Glove  Rinse

Rinse off decon solution from Station 2 using copious amounts of
water.  Repeat as many times  as necessary.

     Equipment:  container (30-50 gallons)
                          or
                 high-pressure spray unit
                 water
                 2-3 long-handle, soft-bristle scrub brushes

Station 4:   Tape Removal

Remove tape around boots and  gloves  and deposit in container with
plastic liner.

     Equipment:  container (20-30 gallons)
                 plastic liners

Station 5:   Boot Cover Removal

Remove boot covers and deposit in container with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners
                 bench or stool

Station 6:   Outer Glove Removal

Remove outer gloves and deposit in container with plastic liner.

     Equipment:  container (20-30 gallons
                 plastic liners

Station 7:   Suit/Safety Boot  Wash

Thoroughly wash chemical-resistant splash  suit, SCBA, gloves, and
safety boots.  Scrub with long-handle, soft-bristle scrub brush
and copious amounts of decon  solution or detergent/water.  Wrap
SCBA regulator (if belt-mounted type) with  plastic to keep out
water. Wash backpack assembly with sponges  or cloths.

     Equipment:  container (30-50 gallons)
                 decon solution
                      or
                 detergent/water
                 2-3 long-handle, soft-bristle scrub brushes
                 small buckets
                 sponges or cloths
                               A2-2

-------
Station 8:  Suit/SCBA/Boot/Glove Rinse

Rinse off decon solution or detergent/water using copious amounts
of water.  Repeat as many times as necessary.

     Equipment:  container (30-50 gallons)
                          or
                 high-pressure spray unit
                 water
                 small buckets
                 2-3 long-handle, soft-bristle scrub brushes
                 sponges or cloths

Station 9:   Tank Change

If worker leaves Exclusion Zone to change air tank, this is the last
step in the decontamination procedure.  Worker's -air tank is
exchanged, new outer gloves and boots covers donned, and joints
taped. Worker  returns to duty.

     Equipment:  air tanks
                 "tape
                 boot covers
                 gloves

Station 10:  Safety Boot Removal

Remove safety  boots and deposit in container with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners
                 bench or stool
                 boot jack

Station 11:  SCBA Backpack Removal

While still wearing facepiece, remove backpack and place on table.
Disconnect hose  from  regulator valve and  proceed to next station.

     Equipment:  table

Station 12:  Splash Suit Removal

With assistance  of helper, remove splash  suit.  Deposit in container
with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners
                 bench or stool
                               A2-3

-------
Station 13:  Inner Glove Wash

Wash inner gloves with decon solution or detergent/water that will
not harm skin.  Repeat as many times as necessary.

     Equipment:  decon solution
                      or
                 detergent/water
                 basin or bucket
                 small table

Station 14:  Inner Glove Rinse

Rinse inner gloves with water.  Repeat as many times as necessary.

     Equipment1:  water
                 basin or bucket
                 small table

Station 15:  Facepiece Removal

Remove facepiece.  Avoid touching face with gloves.  Deposit in
container with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners

Station 16:  Inner Glove Removal

Remove inner gloves and deposit in container with plastic liner.

     Equipment:  container (20-30 gallons)
                 plastic liners

Station 17:  Inner Clothing Removal

Remove clothing soaked with perspiration.  Place in container with
plastic liner.  Do not wear inner clothing off-site since there is
a possibility small  amounts of contaminants might have been
transferred in removing fully encapsulating suit.

     Equipment:  container (30-50 gallons)
                 plastic liners

Station 18:  Field Wash

Shower if highly toxic, skin-corrosive, or skin-absorbable materials
are known or suspected to be present.  Wash hands and face if shower
is not available.
                               A2-4

-------
         Equipment:  water
                     soap
                     small tables
                     basins or buckets
                     field showers

    Station 19:  Redress

    Put on clean clothes.  A dressing trailer is needed in inclement
    weather.

         Equipment:  tables
                     chairs
                     lockers
                     clothes
C.  FULL DECONTAMINATION (SIT. 1) AND THREE MODIFICATIONS
s
I
T
1
2
3
4
STATION NUMBER
1
X
X
X
X
2
X
X


3
X
X


4
X
X


5
X
X


6
X
X


7
X
X
X
X
8
X
X
X
X
9

X

X
10
X

X

11
X

X

12
X

X

13
X



14
X



15
X

X

16
X

X

17
X

X

18
X

X

19
X

X

    Situation 1:   The individual  entering the Contamination  Reduction
    Corridor is observed to be grossly contaminated  or  extremely  toxic
    substances are known or suspected to be present.

    Situation 2:   Same as Situation 1 except individual  needs  new air tank
    and will return to Exclusion  Zone.
                                   A2-5

-------
Situation 3:   Individual  entering  the CRC is expected to be minimally
contaminated.   Extremely  toxic  or  skin-corrosive materials are not
present No outer gloves or  boot  covers are worn.  Inner gloves are
not contaminated.

Situation 4:   Same  as  Situation  3  except  individual  needs new air tank
and will  return to  Exclusion  Zone.
                              A2-6

-------
                                 ANNEX 3

                         LEVEL C DECONTAMINATION


A.  EQUIPMENT WORN

    The full decontamination procedure outlined is for workers wearing
    Level C protection (with taped joints between gloves, boots, and
    suit) consisting of:

    -  One-piece, hooded, chemical-resistant' splash suit.

    -  Canister equipped, full-face mask.

    -  Hard hat.

    -  Chemical-resistant, steel toe and shank boots.

    -  Boot covers.

    -  Inner and outer gloves.


B.  PROCEDURE FOR FULL DECONTAMINATION

    Station 1:  Segregated Equipment Drop

    Deposit equipment used on-site (tools, sampling devices and containers,
    monitoring instruments, radios, clipboards, etc.) on plastic drop
    cloths or in different containers with plastic liners.  Each will  be
    contaminated to a different degree.  Segregation at the drop reduces
    the probability of cross-contamination.

         Equipment:  various size containers
                     plastic liners
                     plastic drop cloths

    Station 2:  Boot Cover and Glove Wash

    Scrub outer boot covers and gloves with decon solution or detergent/
    water.

         Equipment:  container (20-30 gallons)
                     decon solution
                          or
                     detergent water
                     2-3 long-handle, soft-bristle scrub brushes
                                   A3-1

-------
Station 3:  Boot Cover and Glove Rinse

Rinse off decon solution from Station 2 using copious amounts of
water.  Repeat as many times as necessary.

     Equipment:  container (30-50 gallons)
                          or
                 high-pressure spray unit
                 water
                 2-3 long-handle, soft bristle scrub brushes

Station 4:  Tape Removal

Remove tape around boots and gloves and deposit in container with
plastic liner.

     Equipment:  container (20-30 gallons)
                 plastic liners

Station 5:  Boot Cover Removal

Remove boot covers and deposit in container with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners
                 bench or stool

Station 6:  Outer Glove Removal

Remove outer gloves and deposit in container with plastic liner.

     Equipment:  container (20-30 gallons)
                 plastic liners

Station 7:  Suit/Safety Boot Wash

Thoroughly wash splash suit and safety boots.  Scrub with long-
handle, soft-bristle scrub brush and copious amounts of decon
solution or detergent/water.  Repeat as many times as necessary.

     Equipment:  container (30-50 gallons)
                 decon solution
                      or
                 detergent/water
                 2-3 long-handle, soft-bristle scrub brushes

Station 8:  Suit/Safety Boot Rinse
                               A3-2

-------
Rinse off decon solution or detergent/water using copious amounts
of water.  Repeat as many times as necessary.

     Equipment:  container (30-50 gallons)
                          or
                 high-pressure spray unit
                 water
                 2-3 long-handle, soft-bristle scrub brushes

Station 9:   Canister or Mask Change

If worker leaves Exclusion Zone to change canister (or mask), this
is the last step in the decontamination procedure.  Worker's canister
is exchanged, new outer gloves and boots covers donned, and joints
taped.  Worker returns to duty.

     Equipment:  canister (or mask)
                 tape
                 boot covers
                 gloves

Station 10:  Safety Boot Removal

Remove safety boots and deposit in container with plastic liner.

     Equipment:  container (30-50 gallons)
                 plastic liners
                 bench or stool
                 boot jack

Station 11;  Splash Suit Removal

With assistance of helper, remove splash suit.  Deposit in container
with plastic liner.

     Equipment:  container (30-50 gallons)
                 bench or stool
                 liner

Station 12:  Inner Glove Wash

Wash inner gloves with decon solution or detergent/water that will
not harm  skin.  Repeat as many times as necessary.

     Equipment:  decon solution
                      or
                 detergent/water
                 basin or bucket
                               A3-3

-------
Station 13:   Inner Glove  Rinse

Rinse inner  gloves with water.  Repeat  as many times as necessary.

     Equipment:   water
                 basin or bucket
                 small table

Station 14:   Facepiece Removal

Remove facepiece.   Avoid  touching  face  with gloves.   Deposit
facepiece in container with plastic liner.

     Equipment:   container (30-50  gallons)
                 plastic  liners

Station 15:   Inner Glove  Removal

Remove inner gloves and deposit  in container with plastic liner.

     Equipment:   container (20-30  gallons)
                 plastic  liners

Station 16:   Inner Clothing Removal

Remove clothing  soaked with perspiration.  Place in  container with
plastic liner.   Do not wear inner  clothing off-site  since there is
a possibility small amounts of contaminants might have been
transferred  in  removing  splash suite.

     Equipment:   container (30-50  gallons)
                 plastic  liners

Station 17:   Field Wash

Shower if highly toxic,  skin-corrosive  or skin-absorbable materials
are known or suspected to be present.   Wash hands and face if shower
is not available.

     Equipment:   water
                 soap
                 tables
                 wash basins/buckets
                 field showers

Station 18:   Redress

Put on clean clothes. A  dressing  trailer is needed  in inclement weather.
                               A3-4

-------
         Equipment:
tables
chairs
lockers
clothes
C.  FULL DECONTAMINATION  (SIT. 1) AND THREE MODIFICATIONS
s
I
T
1
2
3
4
STATION NUMBER
1
X
X
X
X
2
X
X


3
X
X


4
X
X


5
X
X


6
X
X


7
X
X
X
X
8
X
X
X
X
9
X
X

X
10
X

X

11
X

X

12
X



13
X



14
X

X

15
X

X

16
X

X

17
X

X

18
X



Situation  1:  The  individual  entering the Contamination Reduction Corridor
is observed to  be  grossly contaminated or extremely skin corrosive substances
are known  or  suspected  to be  present.

Situation  2:  Same as Situation  1 except individual needs new canister or
mask and will return to Exclusion Zone.

Situation  3:  Individual entering the CRC is expected to be minimally
contaminated.   Extremely skin-corrosive materials are not present.  No
'outer gloves  or boot covers are  worn.  Inner gloves are not contaminated.

Situation  4:  Same as Situation  3 except individual needs new canister or
mask and will return to Exclusion Zone.
                                    A3-5

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                                 ANNEX 4

                 LEVEL A DECONTAMINATION, MINIMUM LAYOUT


A.  EQUIPMENT WORN

    The decontamination procedure outlined is for workers wearing Level  A
    protection (with taped joints between gloves, boots, and suit) consisting
    of:

    -  Fully encapsulating suit with integral boots and gloves.

    -  Self-contained breathing apparatus.

    <-  Hard hat (optional).

    -  Chemical-resistant, steel toe and shank boots.

    -  Boot covers.

    -  Inner and outer gloves.


B.  PROCEDURE FOR FULL DECONTAMINATION

    Station 1:  Segregated Equipment Drop

    Deposit equipment used on-site (tools, sampling devices and containers,
    monitoring instruments, radios, clipboards, etc.) on plastic drop
    cloths or in different containers with plastic liners.   Each will  be
    contaminated to a different degree.  Segregation at. the drop reduces
    the probability of cross-contamination.

         Equipment:  various size containers
                     plastic liners
                     plastic drop clothes

    Station 2:  Outer Garment, Boots, and Gloves Wash and Rinse

    Scrub outer boots, outer gloves, and fully-encapsulating suit with
    decon solution or detergent water.  Rinse off using copious amounts
    of water.

         Equipment:  containers (30-50 gallons)
                     decon solution
                          or
                     detergent water
                                   A4-1

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                 rinse water
                 2-3 long-handle,  soft-bristle scrub brushes
Station 3:   Outer Boot and Glove Removal

Remove outer boots and gloves.   Deposit  in container with plastic
liner.

     Equipment:   container (30-50 gallons)
                 plastic liners
                 bench or stool

Station 4:   Tank Change

If worker leaves Exclusion Zone  to change air tank,  this is the last
step in the decontamination procedure.   Worker's air tank is exchanged,
new outer gloves and boot covers donned,  joints  taped, and worker
returns to duty.

     Equipment:   ai r tanks
                 tape
                 boot covers
                 gloves

Station 5:   Boot, Gloves, and Outer Garment Removal

Boots, fully-encapsulating suit, and inner gloves removed and deposited
in separate containers lined with plastic.

     Equipment:   containers (30-50 gallons)
                 plastic liners
                 bench or stool

Station 6:   SCBA Removal

SCBA backpack and facepiece is  removed.   Hands and face are thoroughly
washed.  SCBA deposited on plastic sheets.

     Equipment:   plastic sheets
                 basin or bucket
                 soap and towels
                 bench

Station 7:   Field Wash

Thoroughly  wash  hands and face.   Shower  as soon  as possible.
                               A4-2

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Equipment:   water
            soap
            tables
            wash basin/bucket
                           A4-3

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                                   PART 8

                              AIR  SURVEILLANCE


 I.   INTRODUCTION

     Accidents  involving hazardous materials or remedial actions  at  aban-
     doned waste sites can release  a  variety of substances into  the  air.
     Chemical  fires,  transportation  accidents,  open  or  leaking  containers,
     wind-blown dust, and site cleanup  activities produce  emissions  which
     can rapidly affect the health and safety- of response  workers and the
     public.   Hazardous atmospheres  can involve:

     -  Flammable  or  explosive  vapors,  gases,  and  aerosols  (explosive
        atmosphere).

     -  Displacement   of  breathable  air   (oxygen-deficient   atmosphere).

     -  Radioactive materials (radioactive environment).

     -  Toxic vapors, gases,  and  aerosols  (toxic atmosphere).

     The presence  of  one or  more  of  these  hazards determines  subsequent
     actions  to protect people or the environment,  operations  to  mitigate
     the incident, and safety considerations for response workers.

     Airborne hazards  can  be  predicted  if  the  substance  involved, its
     chemical  and  physical  properties,  and  weather  conditions are known.
     But air  surveillance is  necessary to  confirm predictions,  to  identify
     or measure contaminants, or  to detect unknown  air  pollutants.

     This part  provides guidance  primarily on longer-term air  sampling for
     toxic substances.  Information  is given in Part 4,  Initial  Site Entry-
     Survey and Reconnaissance, regarding  initial  determination of  airborne
     hazards.
II.   OBJECTIVE OF AIR SURVEILLANCE

     Air surveillance  consists  of  air monitoring  (using  direct-reading
     instruments capable of providing real-time indications  of  air
     contaminants) and 'air  sampling  (collecting  air  on  an  appropriate
     media or  in  a  suitable sampling  container  followed  by  analysis).

     The objective of air surveillance during  response  is  to determine  the
     type of  chemical  compound (and  associated hazard)  and quantity  of
     airborne contaminants on-site and off-site and changes in air contami-
     nants that occur over the lifetime of the incident.
                                  8-1

-------
      The  data  obtained  are  used to  help  establish  criteria  for  worker
      safety,  document  potential  exposures,  determine protective  measures
      for  the  public,  evaluate the  environmental  impact  of the  incident,
      and  determine  mitigation  activities.    To  accomplish  this   requires
      establishing an  effective  air  surveillance program, tailored to  meet
      the  conditions generated by each  incident.


III.   TYPES  OF  INCIDENTS

      As part   of  initial  hazard evaluation,  direct-reading   instruments
      (DRIs),  visible  indicators  (signs,  labels,  placards, type  of  con-
      tainer,  etc.),  and  other  information  (manifests,  consists,  inven-
      tories,  Agency  records,  etc.)  are  used to  evaluate the  presence  or
      potential  for air contaminant release.   Limited  air  sampling may  also
      be conducted'if  time is available.   Based on an  assessment of  this
      preliminary information, a more comprehensive air  surveillance
      strategy  is developed and "implemented.

      Two  general types of incidents are encountered:

      -  Environmental emergencies,  including  chemical  fires,  spills,  or
        other  releasesof hazardous materials which  occur over a rela-
        tively  short  period  of  time.   Since  contaminants may be  released
        rapidly, there may be  no time  for air surveillance.   In  incidents
        where  the  released material  can  be quickly identified  (and  suffi-
        cient  time  is  available),  direct-reading,   hand-held monitoring
        instruments can  be  used to provide  information  on  some  types  of
        hazards.  Air  sampling   generally  is  limited  unless  the release
        continues long  enough  for  appropriate equipment to be  brought  in.

      -  Longer-term cleanup, including planned removals and remedial
        actions at  abandoned waste  sites  as  well   as  restoration  after
        emergency problems  have  been   controlled.   During this  period,
        especially at  waste  sites,  workers and  the  public may be exposed
        to  a  wide  variety of airborne materials over a much longer  period
        of  time.  Since cleanup  activities  require more  time  (and  planning)
        to  accomplish,  appropriate equipment  for air monitoring and samp-
        ling  can  be  secured,  and an air surveillance program  established.


 IV.   GENERAL  SURVEILLANCE METHODS

      During site operations,  data are  needed about  air contaminants and  any
      changes  that may  occur.  Surveillance  for  vapors, gases, and  parti-
      culates  is  done  using DRIs  and   air  sampling systems.   DRIs  can  be
      used to  detect many organics and a few  inorganics and  provide  approxi-
      mate total  concentrations.  If   specific organics  (and   inorganics)
      have been  identified,  then  DRIs,   calibrated  to  those materials,
      can  be used  for  more accurate  on-site assessment.   In many  instances
                                  8-2

-------
    however, only air sampling (and laboratory analysis) can  be  used  for
    detection and quantification.

    The most accurate method  for  evaluating  any air  contaminant is  to
    collect samples and analyze them  at  a  reliable  laboratory.   Although
    accurate, this method has two  disadvantages:   cost and the  time  re-
    quired to  obtain  results.   Analyzing   large  numbers  of  samples  in
    laboratories is  very  expensive,  especially  if  results  are  wanted
    quickly.  On-site laboratories  tend  to reduce the  turn-around time,
    but unless they  can  analyze other  types  of  samples,  they   also  are
    costly.  In emergencies, time  is  often not available  for laboratory
    analysis of samples  either on-site or off-site.

    To obtain air monitoring  data  rapidly  at  the site,  instruments  uti-
    lizing flame  ionization  detectors  (FIDs)  photoionization detectors
    (PIDs) and other similar  instruments can  be  used.   These may be  used
    as survey instruments (total concentration  mode)  or operated as  gas
    chromatographs (gas   chromatograph  mode).    As   gas  chromatographs,
    these instruments can provide  real-time,  qualitative/quantative  data
    when calibrated with  standards of known air  contaminants.   Combined
    with selective laboratory analysis  of  samples,  they provide a  tool
    for evaluating airborne  organic  hazards  on a  realtime  basis,  at a
    lower cost than analyzing  all  samples in a  laboratory.  An example  of
    an air surveillance  program  used by the U.S.  Environmental Protection
    Agency's Environmental  Response Team  is contained  in Annex 5.
V.   AIR SAMPLING

    For more  complete  information about  air contaminants,  measurements
    obtained with DRIs must  be  supplemented by collecting and  analyzing
    air samples.  To assess air contaminants more thoroughly,  air sampling
    devices equipped with appropriate collection media  are  placed at  var-
    ious locations throughout the  area.  These samples provide air quality
    information for the period of  time they operate, and can indicate  con-
    taminant types and concentrations over the lifetime of  site  operations
    As data are  obtained  (from the analysis of samples, DRIs,  knowledge
    about materials involved, site operations,  and potential  for airborne
    toxic hazards), adjustments are  made  in the type  of samples,  number
    of samples  collected, frequency  of sampling, and  analysis  required.
    In addition to air samplers,  area  sampling  stations may  also include
    DRIs equipped with recorders  and  operated as continuous air  monitors.
    Area sampling  stations   are   located   in  various  places  including:

    -  Upwind - Because many  hazardous incidents occur  near industries  or
       highways that generate air  pollutants, samples must be  taken upwind
       of the  site  to  establish  background  levels  of   air contaminants.

    -  Support zone - Samples must be taken near the command post or other
       support facilities to  ensure  that  they are  in  fact located  in  a
       clean area, and that the area  remains  clean  throughout  operations
       at the site.
                                 8-3

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.  Contamination  reduction  zone  -  Air
   along the  decontamination  line  to
   workers are properly  protected  and
   removing their protective  gear  in  a
                                             samples   should  be  collected
                                             ensure  that  decontamination
                                            that on-site  workers are  not
                                            contaminated area.
        Exclusion
        exposure
        location
        detected
        airborne
        junction
        to verify
        exclusion
        record of
             zone  - The exclusion zone presents the greatest  risk of
            to chemicals  and  requires  the most  air   sampling.   The
            of  sampling   stations   should  be  based  upon  hot-spots
            by DRIs,  types  of substance  present,  and  potential  for
            contaminants.   The  data  from  these  stations,  in  con-
            with  intermittent walk-around  surveys  with DRIs,  are used
             the  selection of proper levels of worker protection  and
             zone   boundaries,  as  well   as to  provide  a  continual
             air  contaminants.
        Downwind  -  One  or more  sampling  stations  are  located  downwind  from
        the site  to indicate  if any  air  contaminants  are  leaving  the site.
        If there  are indications of airborne  hazards in populated  areas,
        additional  samplers should be  placed downwind.
VI.  MEDIA FOR  COLLECTING  AIR SAMPLES

     Hazardous  material  incidents,  especially  abandoned  waste  sites,
     involve  thousands of  potentially dangerous substances - gases,  vapors,
     and aerosols  that could become airborne.   A variety  of  media  -  liquids
     and solids -  are used to  collect  these substances.   Sampling  systems
     typically  include a  calibrated  air  sampling  pump which draws air  into
     selected collection media.   Some of the most common  types  of samples,
     and the  collection media used  for them are:

     -  Organic vapors  -  Activated  carbon  is  an  excellent adsorbent  for
        most  organic  vapors.   However,  other  solid adsorbents  (such  as
        Tenax,  silica gel,  and  Florisil)  are  routinely  used  to  sample
        specific organic   compounds  or  classes  of  compounds  that  do  not
        adsorb  or  desorb  well   on  activated carbon.  To  avoid stocking a
        large number  of  sorbents  for all substances  anticipated,  a  smaller
        number  chosen for  collecting the widest range of materials or for
        substances known to be  present generally  are used.   The vapors are
        collected  using  an industrial  hygiene personal  sampling pump  with
        either  one sampling port  or a  manifold capable  of simultaneously
        collecting samples on  several  sorbent tubes, for example,  a mani-
        fold  with  four sorbent  tubes (or as individual  pumps with  varying
        flow  rates).   The  tubes might contain:

        -- Activated carbon to collect  vapors  of materials with  a  boiling
           point  above  0  degrees  centigrade.  These  materials  include
           most odorous   organic  substances,   such as   solvent   vapors.

        -- A porous  polymer such as Tenax or Chromosorb  to collect  sub-
           stances (such   as high-molecular-weight  hydrocarbons,  organo-
                                 8-4

-------
             phosphorous compounds,  and the  vapors  of  certain  pesticides)
             that adsorb poorly onto activated carbon.  Some of these porous
             polymers also adsorb organic  materials  at  low ambient  tempera-
             tures more efficiently  than carbon.

         --  A polar sorbent such as  silica  gel  to collect  organic  vapors
             (aromatic amines,  for example) that exhibit  a  relatively  high
             dipole moment.


         --  Another  specialty  adsorbent  selected  for  the  specific site.
             For example, a Florisil tube could  be  used if polychlorinated
             biphenyls are expected.

      -  Inorganic gases - The  inorganic gases  present  at  an incident would
         primarily be polar compounds  such as the haloacid gases.   They can
         be adsorbed onto  silica gel  tubes  and  analyzed  by  ion chromato-
         graphy.  Impingers filled with selected liquid  reagents  can  also
         be used.

      -  Aerosols - Aerosols (solid  or liquid particulates)  that may  be en-
         countered at an  incident include  contaminated  and  noncontaminated
         soil particles,  heavy-metal  particulates,  pesticide  dusts,   and
         droplets of organic or inorganic  liquids.   An  effective method for
         sampling these  materials  is   to  collect  them  on  a  particulate
         filter such as a  glass  fiber  or  membrane type.   A  backup  impinger
         filled with a  selected  absorbing  solution  may also  be necessary.

      Colorimetric detector tubes  can  also  be  used with a  sampling  pump
      when monitoring for  some  specific compounds.   Passive  organic vapor
      monitors can be substituted for the active system  described if passive
      monitors are  available for the types  of materials  suspected to  be
      present at a given site.

      The National  Institute for Occupational  Safety and Health's  (NIOSH)
      Manual of Analytical Methods,  Volumes 1-7,  contains  acceptable
      methods for  collecting  and analyzing  air  samples  for a variety  of
      chemical substances.  Consult  it for specific  procedures.


VII.  COLLECTION AND ANALYSIS

      Samples are analyzed to determine types and quantities  of substances
      present.  The  following provides  additional  guidance  on  sample  col-
      lection and analysis.

      -  Aerosols

         Samples for aerosols should be  taken at  a relatively  high flow rate
         (generally about  2 liters/minute)  using  a  standard  industrial
         hygiene pump and  filter assembly.   To collect total particulates,
                                   8-5

-------
a membrane  filter  having a  0.8  micrometer  pore size  is  common.
The sample  can  be weighed  to determine  total  participates, then
analyzed destructively  or  non-destructively  for metals.   If the
metals analysis  is  done  nondestructively  or  if  the   filter   is
sectioned, additional analyses (for example, organics,  inorganics,
and optical particle sizing) can be performed.

Sorbent Samples

The sorbent material  chosen, the amount  used,  and  sample volume
will vary  according to the types and  concentrations of  substances
anticipated at  a  particular  site.   Polar  sorbent   material  such
as silica  gel  will collect polar substances which are not adsorbed
well onto  activated  carbon  and some of the  porous  polymers.   The
silica gel sample can be split and analyzed for the haloacid gases
and aromatic amines.

Activated carbon and  porous  polymers will  collect a  wide range of
compounds.  Exhaustive analysis  to  identify and  quantify all  the
collected species is  prohibitively expensive at  any laboratory and
technically difficult for a  field  laboratory.   Therefore, samples
should be  analyzed  for  principal  hazardous constituents (PHCs).
The selection of PHCs should  be  based upon  the  types of materials
anticipated at  a  given  site,  from  generator's   records,  and  from
information collected during  the  initial  site  survey.   To aid in
the selection  of  PHCs,  a sample could  be collected  on activated
carbon or  porous  polymer during  the  initial  site survey  and  ex-
haustively analyzed  off-site  to  identify the  major  peaks within
selected categories.   This one thorough analysis, along with  what
is already  known  about  a  particular site,  could  provide enough
information to  select   PHCs.   Standards  of  PHCs  could then  be
prepared and used to  calibrate instruments used  for field analysis
of samples.  Subsequent,  routine off-site analysis could be limited
to scanning for only PHCs,  saving time  and  money.   Special adsor-
bents and  sampling  conditions can  be used  for specific  PHCs  if
desired, while  continued multimedia  sampling will  provide a  base
for analysis of additional PHCs that  may  be identified during the
course of cleanup operations.

Passive Dosimeters

A less traditional  method of  sampling  is  the use of passive dosi-
meters.  The  few  passive dosimeters  now  available  are  only  for
gases and vapors.  Passive dosimeters are used primarily to monitor
personal exposure, but  they  can be used to monitor areas.  Passive
monitors are divided  into two groups:

--  Diffusion  samplers,  in which molecules  move across a concentra-
    tion gradient, usually achieved within a stagnant layer of air,
    between the contaminated  atmosphere and the indicator material.
                          8-6

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          --  Permeation devices,  which rely on the natural  permeation of a
              contaminant through a membrane.  A suitable membrane is select-
              ed that is easily permeated by the contaminant  of interest and
              impermeable to all  others.  Permeation dosimeters are therefore
              useful  in picking  out a single contaminant from a  mixture  of
              possible interfering contaminants.

          Some passive  dosimeters  may  be   read  directly,  as  are DRIs  and
          colorimetric length-of-stain  tubes.   Others  require   laboratory
          analysis similiar to that done on solid sorbents.
VIII.  PERSONNEL MONITORING
       In addition to area atmospheric sampling, personnel  monitoring -  both
       active and passive - can be used to sample for air contaminants. Repre-
       sentative workers are  equipped with personal samplers to indicate con-
       taminants at  specific locations  or  for specific  work  being  done.
       Placed on workers, generally within 1 foot of the mouth and nose, the
       monitors indicate  the potential  for  the worker  to inhale the  con-
       taminant.
  IX.  CALIBRATION

       As a rule, the total air  sampling  system  should be  calibrated rather
       than the  pump  alone.   Proper  calibration  is  essential  for  correct
       operation and for  accurate interpretation  of  resultant  data.  As  a
       minimum, the system should be calibrated prior to and after use.   The
       overall frequency of calibration will depend upon the general  handling
       and use of a given  sampling system.  Pump mechanisms should  be recali-
       brated after repair,  when newly  purchased, and  following  suspected
       abuse.  Calibration  methods  can  be  found  in  the  NIOSH  Manual  of
       Analytical Methods (Volumes 1-7).


   X.  METEOROLGICAL CONSIDERATIONS

       Meteorological  information is an integral  part of an air  surveillance
       program.  Data  concerning  wind  speed  and direction,  temperature,
       barometric pressure,  and  humidity,   singularly  or  in  combination,
       are needed for:

       -  Selecting air sampling locations.

       -  Calculating air dispersion.

       -  Calibrating instruments.

       -  Determining  population at  risk  or environmental  exposure  from
          airborne contaminants.
                                    8-7

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Knowledge of wind  speed  and  direction  is  necessary  to  effectively
place air samplers.   In source-oriented ambient air sampling
particularly, samplers   need  to  be  located  downwind  (at  different
distances) of the  source  and  others  placed  to  collect  background
samples.  Shifts in  wind direction  must be  known and samplers  re-
located or corrections  made for the shifts.   In addition,  atmodpheric
simulation models for  predicting  contaminant dispersion  and  concen-
tration need windspeed and direction as  inputs  for predictive calcu-
lations.  Information  may  be  needed  concerning  the  frequency  and
intensity with  which that  winds  blow from  certain directions (wind-
rose data),  consequently,  the  wind direction  must  be  continually
monitored.

Air sampling systems  need to  be calibrated before use and  corrections
in the  calibration curves  made for temperature  and  pressure.  After
sampling, sampled air  volumes  are also corrected for temperature  and
pressure variations.    This  requires  knowing  air  temperature  and
pressure.

Air sampling is  sometimes designed  to assess population exposure (and
frequently potential  worker  exposure).   Air  samplers  are  generally
located in population  centers  irrespective  of wind  direction.   Even
in these  instances,  however,  meteorological data  is  needed  for  air
dispersion modeling.    Models   are  then  used to  predict  or  verify
population-oriented  sampling  results.

Proper data is  collected  by having  meteorological  stations on  site or
obtaining it from  one  or  more   of several  government  or  private
organizations which  routinely  collect  such  data.  The  choice of  how
information is  obtained depends on the availability  of reliable data
at the  location  desired,  resources needed  to obtain  meteorological
equipment, accuracy   of  information  needed,  and  use  of information.
                            8-8

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                                 ANNEX 5

                  GUIDE TO ENVIRONMENTAL RESPONSE TEAM'S

                         AIR SURVEILLANCE PROGRAM
I.   APPROACH

    A variety of  long-term  air surveillance programs can be  designed  to
    detect a wide  range  of  airborne compounds.  To implement any program
    a number of factors must  be  considered, including type  of equipment,
    costs, personnel   required, accuracy  of analysis,  time  required  to
    obtain results  (turn-around-time),   and availability  of  analytical
    laboratories.

    One approach  to  air  surveillance,  developed  and used  by the  USEPA
    Environmental  Response  Team  (ERT),   is  described here.   This program
    achieves a  reasonable  balance  between  cost,  accuracy,  and time  in
    obtaining data  using a  combination  of direct  reading  instruments
    (DRIs) and air sampling systems to:

    -  Rapidly survey for airborne organic vapors  and gases.

    -  Identify and measure organic vapors and  gases.

    -  Identify and measure particulates and inorganic  vapors and  gases.

    The approach is based on:

    -  Using  flame  ionization detectors  (FIDs)  and/or  photoionization
       detectors  (PIDs) for initial detection  of  total  organic gases  and
       vapors and for periodic site surveys  (for total  organics).  Equip-
       ped with strip chart  recorders,  the detectors  are  used as area
       monitors to  record   total  organic  concentration and   changes   in
       concentration over  a  period  of   time.    Calibrated  to  specific
       organic contaminants, they  are used to detect  and measure  those
       substances.

    -  Collecting area air  samples  using personal  pumps and  organic gas/
       vapor collection tubes.  Samples  are  analyzed  using the gas chroma-
       tograph (GC) capabilities of field instruments.  Selected samples
       are also  analyzed  in   laboratories  accredited  by  the  American
       Industrial  Hygiene Association  (AIHA).

    -  Using PIDs  and/or FIDs  (as  a survey instrument  or GC) to provide
       real-time data  and  to  screen  the number  of  samples  needed  for
       laboratory analysis.
                                 A5-1

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         Sampling  for particulates,  inorganic  acids,  aromatic  amines, halo-
         genated pesticides,  etc., when  they  are  known  to be  involved  or
         when  there are  indications that  these substances may  be a  problem.
 II.   EQUIPMENT

      At  present,  the  following  equipment is  used for  organic  gas/vapor
      monitoring  however,  other  equivalent  equipment  can  be  substituted:

      -   HNU  Systems  Photoionizer  (PID)
      -   Foxboro  OVA  (FID)
      -   MDA  Accuhaler  808 Sampling Pump
      -   Gillian  Model  Number HFS-UT113 Sampling  Pump
      -   Tenax adsorption tubes (metal)
      -   Carbon-pac'ked  adsorption  tubes (metal)
      -   Carbon-packed  adsorption  tubes (glass)
         --   150  milligram and 6'00 milligram  sizes
III.   PROCEDURE

      This  procedure  is generally applicable  to most responses.   However,
      since each  incident  is  unique, modifications may be  needed.

      Organic  Gases and  Vapors.  The sequence  for monitoring organic  gases
      and  vapors  consists  of  several steps.

      -   Determine total background concentrations.

      -   Determine total concentration on-site.

      -   Collect  on-site area samples.

         Identify specific contaminants.

      Background  concentrations.  Background readings of total  organic gases
      and  vapors, using  DRIs  (FID/PID), are made upwind of  the  site  in  areas
      not  expected to contain air contaminants.  If  industries,  highways,  or
      other potential  sources contribute  to  concentrations on-site,  these
      contributions should be determined.  Depending on the situation and
      the  time available,   additional  monitoring should be  done nearby  to
      determine  if contaminants  are  leaving the site.

      Concentrations on-site.  The  on-site area  is  monitored  (using  DRIs)
      for  total   gas/vapor concentrations,  measured  at  both  ground and
      breathing  zone  levels.   The  initial walk-throughs  are  to determine
      general  ambient   concentrations  and  to  locate  higher-than   ambient
      concentrations  (hot-spots).
                                  A5-2

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Transient contributors  on-site,  for example,  exhausts  from engines,
should be avoided.  Concentrations are recorded and plotted on a site
map.  Additional DRI monitoring is then done to thoroughly define any
hot-spots located during the survey.

Area samples.  Sampling stations are located throughout the site.  The
number and locations depend on evaluating many  factors, including hot-
spots (by DRI), active work  areas,  potentials for high concentrations,
and wind direction.   As a  minimum,  stations  should  be  located  in  a
clean off-site area (control or  background  station),  exclusion  zone,
and downwind of the site.   As  data are accumulated, location,  number
of stations, and frequency of sampling can be adjusted.

Routinely, two 4-hour samples are collected, in the morning and after-
noon respectively, using personal  sampling  pumps  equipped with  Tenax
and/or carbon-packed,  metal  adsorption  tubes.   Total gas/vapor concen-
tration (using DRI) should also be determined at the start and finish
of each sampling  run.   The  readings obtained  may  show an approximate
relationship (depending  on  organics present)  which will  be  helpful
later in placing samplers.

Samples are desorbed with a  thermal desorber and analyzed on the OVA-6C
for total  organic  concentration and number of peaks.  Chromatograms
of samples taken at the same location  but at  different times  or  from
different stations can be  compared.   Differences in  heights of "total"
peak, number  of  independent  peaks, and  relative  peak   heights,  if
judiciously interpreted, are useful  for  making preliminary judgments
concerning air  contaminant  problems.  Page  A5-6  shows   a  suggested
format for calculating total gas/vapor concentration.

If relatively  high  concentrations  are detected  by the  initial  DRI
surveys samplers equipped with carbon-packed collection  tubes  (glass)
are run  next  to Tenax/carbon-packed,  metal  equipped  samplers.   The
latter samples are  analyzed in  the field.   The carbon-packed  collec-
tion tubes are analyzed by an AIHA accredited laboratory.

Area surveys using  DRI  are  continued  routinely two-four times daily.
These surveys  are to  monitor  for general  ambient levels,  as  well  as
levels at sampling stations, hot-spots, and other areas of site activ-
ities.  As  information  is  accumulated  on  airborne  organics,  the
frequency of surveys can be adjusted.

Specific contaminants.  Personal monitoring pumps  with  carbon-packed
collection tubes  (glass) are  run on the first  afternoon, concurrent
with samplers  equipped with  Tenax/carbon-packed,  metal  collection
tubes.  Generally, when total  gas/vapor  readings  are low and only  a
few peaks  seen  (from  the  field  GC analysis  of  morning  samples),
100-150 mg  carbon-packed  tubes  (glass)  are used  and operated  at  a
flow rate  of  100  cubic  centimeters/minute  until  approximately  30
liters of  air  have been  collected.  Depending on  suspected  contam-
inants and their concentrations, higher flow rates and/or volumes may
                         A5-3

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be needed.   When  total  gas/vapor  readings  are high and there are many
peaks (from the morning samples),  then larger glass carbon collection
tubes (600  mg)  are operated at a flow rate  from 0.5 to 1 liters/minute
to collect  90 to  150 liters  of air.

The results from  laboratory analysis  of glass carbon  tubes  are used
for a number of different  purposes,  including:

   To identify and measure organic gases and  vapors  collected during
   the sampling period.

-  To compare  laboratory  chromatograms  and field  chromatograms.   If
   only a few peaks  (but the same  number) are  seen on each chromatogram
   (and identified   on   the   laboratory  chromatogram)  from  samples
   collected at the  same  location,  it  may  be reasonable to  assume,
   until  standards  are  run on the field GC,  that the two chromatograms
   are identifying  the  same  materials.

-  To  identify major  contaminants  on  laboratory  chromatograms  and
   determine what standards  to prepare  for the field  GC.  Field GC's
   can then be used to  identify and measure  air  contaminants  against
   laboratory prepared  standards.

-  To use  the  field GC as  a screening device for determining  when
   samples  should  be  collected  for  laboratory  analysis,   or  when
   samples  previously collected should  be  analyzed.    Changes  in  the
   number of peaks  on the  field chromatograms  from samples  collected
   at the  same location indicate  changes  in the air,  suggesting  the
   need for  collecting  additional  samples  for  laboratory  analysis.

If desorption equipment is not  available for  on-site  sample  analysis,
glass collection   tubes should  be  collected  daily.   Only  samples
collected every third to fifth day are sent to AIHA accredited  labora-
tories for  analysis; the remaining samples  are stored in a cool  place
(preferably refrigerated).   Selected  stored  samples   are  analyzed  if
third to fifth day  samples  indicate  changes in  air  contaminant pat-
terns.  If  daily   on-site  surveys detect  low  contaminant(s)  levels,
then 100-150 mg glass carbon columns  are used.  If the survey  reveals
relatively  high  levels  of  contaminants,  then  600 mg glass  carbon
tubes are used.

The National  Institute  for Occupational Safety and Health P&CAM Analy-
tical Method No.  127 (see Annex 6)  should  be  followed  as closely  as
possible.  Flow  rates  and  collection tubes  described  in this  guide
are primarily for  organic  solvents.   If other than  organic solvents
are suspected,  then  the  NIOSH  Manual  of Analytical  Methods  (Volume
1-7) should  be  consulted  for  the appropriate collection  media  and
flow rates.  Table  1 lists  the  organic solvents  identified by  the
NIOSH P&CAM  No.  127,  many  of which are  found  at   hazardous  waste
sites.  These  are  identified for  possible  gas  chromatography/mass
spectrometry analysis.
                             A5-4

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Particulates and Inorganic Gases and Vapors.  Sampling  for  particu-
lates is not done  routinely.   If  these  types  of air contaminants are
known or  suspected to exist,  a  sampling  program is  instituted  for
them.  Incidents  where  these  contaminants  might   be  present  are:
fires involving  pesticides  or  chemicals,   incidents  involving  heavy
metals, arsenic, or  cyanide  compounds,  or mitigation operations that
create dust  (from  contaminated soil  and excavation  of  contaminated
soil).

Sampling media  and  analytical  methods  for  these  air  contaminants
should follow guidance given in the NIO-SH Manual of Analytical
Methods.
                             A5-5

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                            SAMPLE  CALCULATION


1.   Volume sampled by  MDA Accuhaler 808  Personal  Sampling Pump:

    Volume sampled (cc)  = (final  stroke  count -  initial  stroke count)
    X  (cc's/stroke*)   X  (multiplier  factor  for  orifice used**)

     *Specified on pump  itself.
    **Specified in pump  operations  manual  and Table  2.  (for MDA Accuhaler)

    Calculation:

    At beginning  of sampling period, Accuhaler  stroke counter reads
    16292.9.   At  end of  sampling  period, it  reads 16632.9.   What  is the
    volume of air sampled?

    Volume sampled (cc)   =  16632.9 (final stroke count) -  16292.9 (initial
    stroke count)  X  5.7 (cc/pump  stroke) X  1.1 (multiplier for orifice)

    Volume sampled  =   2131.8 cc  or 2.1  liters.

2.   Reporting Format (for OVA GC  Thermal  Desorber)

    a.  Total GC  Mode:   Total  concentration  determined  = 22 ppm  as
        CH4 (methane)

    b.  Time  weighted  =   volume desorbed (liters) X  concentration (ppm)
        average (ppm)               volume collected  (liters)

                  =  0.300 (liter)   X    22  (ppm)   =   3.14 ppm as  CH4 (methane)
                              2.1 (liters)

     c.  Peaks:  GC mode
                  4 peaks observed

     d.  Survey Concentration (total organics by  DRI)

         Start of sampling period 	 ppm, time 	

         End  of sampling period   	ppm, time
                           ATTACH CHROMATOGRAM
                                 A5-6

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                                  TABLE 1
        Organic Solvents Identified by P&CAM Analytic Method No. 127
       Organic Solvent
Molecular Weight
       Acetone

       Benzene

       Carbon tetrachloride

       Chloroform

       Dichloromethane

       p-Dioxane

       Ethylene dichloride

       Methyl ethyl ketone

       Styrene

       Tet rachloroethy1ene

       Toluene

       1,1,2-Trichloroethane

       1,1,1-Trichloroethane
       (methyl chloroform)

       Trichloroethylene

       Xylene	
     58.1

     78.1

    154.0

    119.0

     84.9

     88.1

     99.0

     72.1

    104.0

    166.0

     92.1

    133.0

    133.0


    131.0

    106.0
Reference:  Manual  of Analytical  Methods
            U.S. Department of Health Education & Welfare,
            Public Health Service, Center for Disease Control
            National Institute of Occupational Safety & Health,
            DHEW (NIOSH) Publication No. 77-157-A
                                   A5-7

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                                   TABLE  2

                   Multiplier Factor  for  MDA Accuhaler 808

                           Personal Sampling Pumps
Calibration
at 20 cc/min
Orifice Color

  Yellow

  Orange

  Red

  Brown

  Purple

  Blue

  Green

  Black
Normal  Flow Rate - cc/min

        100

         50

         20

         10

          5

          2

          1

          0.5
Volume/Stroke
  Multiplier

     1.1

     1.06

     1.00

     0.99

     0.97
Reference:   Instruction  Manual,  Accuhaler,  Personnel  Sampling Pump
            Models  808 and  818
            MDA Scientific,  Inc.,  Elmdale Avenue,
            Glenview,  IL 60025
                                   A5-8

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                                          ANNEX 6

                            ORGANIC  SOLVENTS IN AIR

                         Physical  and  Chemical  Analysis Branch

                                     Analytical  Method
  Analyte:

  Matrix:

  Procedure:



  Date Issued:

  Date Revised:
Organic Solvents
  (See Table 1)
Air

Adsorption on charcoal
desorption with carbon
disulfide, GC

9/15/72

2/15/77
Method No.:

Range:
P&CAM 127

For the specific
compound, refer
to Table 1
Precision:       10.5%  RSD

Classification:    See  Table 1
1.  Principle  of  the Method

     1.1  A known volume of air is drawn through a charcoal tube to trap the organic vapors present.

     1.2  The charcoal in the tube is transferred to a  small, graduated test tube and  desorbed with
         carbon disulfide.

     1.3  An  aliquot of the desorbed sample  is injected into a gas chromatograph.

     1.4  The area of  the resulting peak  is determined and compared with areas obtained from the
         injection  of standards.

2.  Range and Sensitivity

    The lower limit in mg/sample  for the specific compound at 16 X  1  attenuation on a gas chromato-
    graph fitted with a  10:1 splitter is shown  in Table 1. This value can  be lowered by reducing the
    attenuation or by eliminating the 10:1 splitter.

3.  Interferences
     3.1  When the amount of water in the air is so great that condensation actually occurs  in the tube,
         organic vapors  will  not  be trapped.   Preliminary  experiments indicate that high  humidity
         severely  decreases  the breakthrough  volume.
     3.2  When two or more solvents are known or suspected to be present in the air, such  information
         (including their suspected identities),  should be transmitted with the sample, since with  dif-
         ferences in polarity, one  may displace  another from the charcoal.
     3.3  It must be emphasized that any  compound which has the same retention time as  the specific
         compound under study at the operating conditions described in this method is an interference.
         Hence, retention time data on a  single column, or even on a  number of columns, cannot be
         considered as proof  of chemical  identity.  For  this  reason it  is important that a sample of
         the  bulk  solvent(s)  be submitted  at the same time so that  identity(ies) can be established by
         other means.
                                            127-1
                                           A6-1

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     3.4  If the possibility of interference exists, separation conditions (column packing, temperatures,
          etc.) must be changed to circumvent the problem.

 4.  Precision and Accuracy
     4.1  The mean relative standard  deviation of the analytical method is 8%  (11.4).

     4.2  The mean relative standard  deviation of the analytical method plus field sampling using an
          approved personal sampling  pump  is 10%  (11.4).  Part of the error  associated with the
          method is related to uncertainties in  the sample volume collected. If a more powerful vacuum
          pump with associated gas-volume integrating  equipment is  used,  sampling precision can  be
          improved.
     4.3  The accuracy of the overall  sampling and analytical method is  10%  (NIOSH-unpublished
          data) when the personal sampling pump is calibrated with a charcoal tube in  the line.

5.  Advantages and Disadvantages of the Method

     5.1  The sampling device is small, portable, and involves no liquids.  Interferences are minimal,
          and most of  those which do occur can be eliminated by altering chromatographic conditions.
          The tubes are analyzed by means of a quick, instrumental  method.  The method can also be
          used for the  simultaneous analysis of two or  more solvents suspected  to be  present in the
          same sample by simply  changing  gas chromatographic conditions from isothermal to a tem-
          perature-programmed mode of operation.
     5.2  One disadvantage of the method is that the amount of sample which can be taken is limited
          by the number of milligrams that the tube will hold before overloading.  When the sample
          value obtained for the backup  section of the charcoal tube exceeds 25% of  that found on
          the front section,  the possibility of  sample  loss  exists.  During  sample  storage,  the  more
          volatile  compounds will migrate throughout  the tube  until equilibrium  is reached (33% of
          the sample on the  backup section).

     5.3  Furthermore, the precision  of the method is  limited by the reproducibility  of the pressure
         drop across  the  tubes. This drop will affect  the  flow rate and cause the volume  to be im-
         precise,  because  the pump  is usually calibrated for one tube only.

6. Apparatus

     6.1  An  approved and  calibrated  personal sampling pump for personal samples.  For an  area
         sample,  any vacuum pump  whose flow can  be  determined  accurately at 1 liter per minute
         or less.

     6.2  Charcoal tubes:  glass tube  with both ends flame sealed, 7 cm long with a 6-mm O.D. and a
         4-mm I.D., containing 2 sections of 20/40  mesh activated charcoal separated by  a  2-mm
         portion  of urethane  foam.  The  activated charcoal  is prepared from coconut shells and  is
         fired at 600°C prior  to packing.  The absorbing  section  contains  100  mg of  charcoal, the
         backup section 50 mg. A 3-mm portion of urethane foam is placed between the outlet end of
         the  tube  and  the backup  section.  A  plug of  silylated glass wool is  placed  in front of the
         absorbing section.  The pressure drop  across the  tube must be less than one inch of mercury
         at a flow rate of  1  1pm.

    6.3  Gas chromatograph equipped  with  a  flame ionization detector.

    6.4  Column  (20 ft X  >/8 in) with 10%  FFAP stationary phase on 80/100 mesh, acid-washed
         DMCS  Chromosorb W solid support.  Other  columns capable  of  performing the  required
         separations may be used.
                                            127-2
                                            A6-2

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     6.5  A mechanical or  electronic  integrator or a recorder and some method for determining peak
         area.

     6.6  Microcentrifuge tubes, 2.5 ml, graduated.

     6.7  Hamilton syringes: 10 /*!, and convenient sizes for making standards.

     6.8  Pipets: 0.5-ml delivery pipets or 1.0-ml type graduated in 0.1-ml increments.

     6.9  Volumetric flasks: 10 ml or convenient sizes for making standard solutions.

7.  Reagents

     7.1  Spectroquality carbon disulfide  (Matheson  Coleman and Bell).

     7.2  Sample of the specific compound under study, preferably chromatoquality grade.
     7.3  Bureau of Mines Grade A helium.

     7.4  Prepurified hydrogen.

     7.5  Filtered compressed air.

8.  Procedure

     8.1  Cleaning  of  Equipment:  All glassware used for the laboratory analysis should be detergent
         washed and thoroughly rinsed with tap water and distilled water.

     8.2  Calibration of Persona] Pumps.  Each personal pump must be calibrated with a  representa-
         tive charcoal tube in  the line.  This will  minimize errors  associated with uncertainties  in
         the sample volume collected.
     8.3  Collection and  Shipping of Samples
         8.3.1  Immediately  before  sampling,  the ends of the tube  should be broken  to  provide an
                opening  at  least one-half the internal diameter of the tube (2 mm).
         8.3.2  The  small  section of charcoal  is used as a back-up and should be positioned nearest
                the sampling pump.
         8.3.3  The charcoal tube  should be vertical during sampling to reduce channeling  through
                the charcoal.
         8.3.4  Air being  sampled  should not be passed through any hose or tubing before entering
                the charcoal tube.
         8.3.5  The flow, time, and/or volume must be measured as accurately as possible.  The  sam-
                ple should  be taken  at a flow  rate of 1 1pm or  less to attain  the total sample volume
                required.  The minimum and  maximum sample volumes that  should, be collected for
                each solvent are shown in Table 1.  The minimum volume quoted must  be collected if
                the desired  sensitivity is to  be achieved.
         8.3.6  The temperature and  pressure  of the atmosphere being  sampled should be measured
                and recorded.
         8.3.7  The charcoal tubes should be capped with the supplied  plastic caps immediately
                after  sampling.  Under no  circumstances should  rubber  caps be used.
         8.3.8  One tube should be handled in the same manner as the  sample tube (break, seal, and
                transport),  except that no air is sampled through this  tube.  This  tube  should be
                labeled as a blank.
         8.3.9  Capped tubes should be packed tightly before they are shipped to minimize tube break-
                age during  shipping.
                                             127-3
                                            A6-3

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     8.3.10 Samples of the suspected  solvent(s) should be submitted to the laboratory for quali-
           tative characterization.  These liquid bulk  samples should not  be  transported  in  the
           same container as the samples or blank tube.  If possible, a bulk air sample (at least
           50  1 air drawn through tube) should be shipped for qualitative identification purposes.

8.4  Analysis of Samples
     8.4.1  Preparation of Samples.  In preparation  for analysis, each  charcoal  tube is scored
           with a file in front of the first section of charcoal and broken  open.  The glass wool is
           removed and discarded. The charcoal  in  the  first (larger)  section is transferred to a
           small stoppered test tube.   The separating section of  foam is removed and discarded;
           the second section is transferred to another test tube.  These two sections are analyzed
           separately.
     8.4.2  Desorption of Samples.  Prior to analysis,  one-half ml of carbon disulfide  is pipetted
           into each test tube.  (All work with carbon  disulfide  should  be performed in a hood
           because  of its high toxicity.)  Tests  indicate  that desorption  is complete in  30 min-
           utes if the sample is stirred occasionally during this period.
     8.4.3  GC  Conditions.  The typical  operating conditions for the gas chromatograph are:
           1.  85 cc/min. (70 psig)  helium carrier gas  flow.
           2.  65 cc/min. (24 psig)  hydrogen gas  flow to detector.
           3.  500  cc/min. (50 psig) air flow to detector.
           4.  200°C injector temperature.
           5.  200°C manifold temperature  (detector).
           6.  Isothermal oven or column temperature  — refer to  Table  1 for specific compounds.
     8.4.4  Injection. The first step in the  analysis is the injection of the sample into the gas
           chromatograph.  To eliminate difficulties  arising from blowback or distillation within
           the syringe  needle, one should  employ the solvent flush injection technique. The  10
           ti\ syringe is first flushed with solvent  several  times to wet the barrel and  plunger.
           Three  microliters  of solvent are  drawn into  the syringe to  increase the accuracy and
           reproducibility  of  the  injected sample volume.. The needle  is removed from the sol-
           vent, and the plunger is pulled back about 0.2  /j.1 to  separate the  solvent  flush  from
           the sample with a pocket of air to be used as a marker.  The needle is  then immersed
           in the sample, and a 5-/xl aliquot is  withdrawn,  taking into  consideration the volume
           of the needle, since the sample in the  needle will be completely injected.   After the
           needle is removed from the sample and prior to injection,  the plunger is pulled back
           a short distance to minimize  evaporation  of the  sample from the tip  of  the needle.
           Duplicate injections  of  each sample and standard should be made.  No more than a
           3%  difference in area  is to be expected.
     8.4.5  Measurement of area.  The area  of  the sample  peak  is measured by  an electronic
           integrator or some other  suitable form of area measurement, and  preliminary results
           are read from a standard  curve prepared as  discussed  below.

8.5  Determination of Desorption  Efficiency
     8.5.1  Importance  of determination.  The desorption efficiency of a particular  compound can
           vary from  one laboratory  to  another and  also from one batch of charcoal to another.
           Thus, it is necessary to determine at least once the percentage of the specific  compound
           that  is  removed in the desorption  process for  a given  compound, provided  the same
           batch of charcoal  is used.  NIOSH has  found  that the  desorption efficiencies for the
           compounds in Table 1  are  between 81%  and 100%  and vary with  each batch of
           charcoal.
                                        127-4
                                        A6-4

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          8.5.2  Procedure  for  determining  desorption  efficiency.  Activated charcoal equivalent  to
                the amount in the first  section of the  sampling tube (100  mg) is measured  into a
                5-cm, 4-mm I.D.  glass tube, flame-sealed at one end  (similar to commercially avail-
                able culture tubes). This charcoal must  be  from the  same batch as that used  in ob-
                taining the samples and can be obtained  from unused  charcoal tubes.  The  open end
                is capped  with  Parafilm.  A  known amount of the  compound is injected directly
                into the activated  charcoal with a microliter syringe, and the  tube is capped with more
                Parafilm.   The amount  injected  is usually equivalent to that present in a 10-liter sam-
                ple at a concentration equal  to  the federal standard.

                At teast five tubes are prepared  in this manner  and allowed to stand for at least over-
                night to  assure  complete absorption of the specific compound onto the charcoal. These
                five tubes are referred to as the samples.   A parallel  blank tube should be treated  in
                the same manner  except  that no  sample  is added to it. The sample and blank tubes
                are desorbed and analyzed in exactly the same manner as  the sampling tube described
                in  Section  8.4.

                Two  or three standards  are prepared by injecting the same volume of compound into
                0.5 ml  of  CS-_. with the  same  syringe used  in the preparation, of the  sample.  These
                are  analyzed with the  samples.

                The desorption  efficiency equals the difference  between the average peak area  of the
                samples and the peak area of the  blank divided by the average  peak area  of the
                standards,  or

                                 ,      .   _ .         Area sample — Area blank
                                desorption efficiency =  -
                                                             Area standard
 9.  Calibration  and Standards
      It is convenient to express concentration of standards in terms of mg/0.5 ml CS^ because samples
      are desorbed in this amount of CS-...  To minimize error due to the  volatility of carbon disulfide,
      one can inject 20 times the weight  into 10 ml of CS2.  For example, to prepare a 0.3  mg/0.5 ml
      standard, one would inject 6.0 mg into exactly 10  ml  of CS2 in a glass-stoppered flask.  The
      density of the specific compound is used to convert 6.0 mg into microliters for easy measurement
      with a  microliter syringe.  A series of standards,  varying in  concentration  over  the range  of
      interest, is prepared and analyzed under  the same GC conditions and during the same time period
      as the  unknown samples.  Curves  are established by plotting concentration in mg/0.5 ml versus
      peak  area.

      NOTE:  Since no internal  standard is used  in the method, standard solutions must be analyzed
      at the same time that the sample analysis is done.  This will minimize the effect of known  day-
      to-day  variations and  variations during the same day of the FID response.


10.  Calculations
    10.1  The weight, in mg. corresponding to each peak area is read from the standard curve  for the
          particular  compound.   No volume corrections are needed, because  the standard curve is
          based on mg/0.5 ml  CS_. and the volume of sample injected is  identical to the volume of the
          standards injected.

    10.2  Corrections for the blank  must be made for  each sample.

                                    Correct mg — mgs —  mgi,
                                              127-5


                                              A6-5

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          where:
            mg, = mg  found  in front section of sample tube
            mgb = mg  found  in front section of blank tube
          A  similar procedure is  followed for the backup sections.
     10.3  The' corrected amounts present in the front and backup sections of the same sample tube
          are  added to determine the total  measured amount in the sample.
     10.4  This total weight is  divided by the determined desorption efficiency to obtain  the corrected
          mg  per sample.
     10.5  The concentration of the analyte in the air sampled  can be expressed in mg per m3.
                              .  ._  Corrected mg (Section 10.4) X  1000 (liters/m3)
                           m£/m —  - T~. - ; - ; — r~rr- - \ -
                             ^                Air volume sampled (liters)
     10.6  Another, method of expressing concentration is ppm  (corrected to standard conditions of 25 °C
          and 760 mm  Hg).
                                      .  ,  v 24.45  v   760  v  (T +'273)
                           ppm = mg/m>  *—- X _  X
          where:
                P = pressure (mm Hg) of air sampled
                T = temperature (°C) of air sampled
            24.45 = molar volume (liter/mole) at 25 °C and 760 mm Hg
              MW = molecular weight
              760 = standard pressure (mm Hg)
              298 = standard temperature (°K)
1 1 .  References
    11.1  White, L. D., D. G. Taylor, P  A.  Mauer, and R. E. Kupel, "A Convenient Optimized Method
          for  the Analysis  of Selected Solvent Vapors in  the  Industrial Atmosphere",  Am  Ind  Hyg
          Assoc J 31:225,  1970.
    11.2  Young, D. M. and A. D. Crowell, Physical Adsorption of Gases, pp.  137-146, Butterworths.
          London, 1962.
    11.3  Federal Register, 37:202:22139-22142, October 18,  1972.
    11.4  NIOSH Contract HSM-99-72-98, Scott Research Laboratories,  Inc.,  "Collaborative Testing
          of Activated Charcoal Sampling Tubes for Seven Organic. Solvents", pp. 4-22, 4-27, 1973.
                                            127-6

                                           A6-6

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                                               TABLE  1

                    Parameters Associated With P&CAB Analytical Method No. 127
Method
Organic Solvent Classification
Acetone
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
p-Dioxane
Ethylene dichloride
Methyl ethyl ketone
Styrene
Tetrachloroethylene
1,1 ,2-trichloroethane
1,1,1 -trichloroethane
(methyl chloroform)
Trichloroethylene
Toluene
Xylene
D
A
A
A
D
A
D
B
D
B
B
B

A
B
A
Detection limit
(mg/sample)
—
0.01
0.20
0.10
0.05
0.05
0.05
0.01
0.10
0.06
0.05
0.05

0.05
0.01
0.02
Sample Volume (liters)
Mlnlmum(») Maximum^1)
0.5
0.5
10
0.5
0.5
1
1
0.5
1.5
1
10
0.5

1
0.5
0.5
7.7
55
60
13
3.8
18
12
13
34
25
97
13

17
22
31
GC Column
Temp.(°C)
60
90
60
80
85
100
90
80
150
130
150
150

90
120
100
Molecular
Weight
58.1
78.1
154.0
119
84.9
88.1
99.0
72.1
104
166
133
133

131
92.1
106
(a) Minimum volume, in liters, required  to measure 0.1 times the OSHA standard
(b) These are breakthrough volumes calculated  with data derived from a potential  plot (11.2) for activated coconut
   charcoal.  Concentrations of vapor in air at 5 times the OSHA standard (11.3)  or 500 ppm, whichever is  lower,
   25°C, and 760 torr were assumed.  These values will be as much as 50% .lower for atmospheres of high humidity.
   The effects of multiple contaminants  have  not been investigated, but it is  suspected  that less volatile compounds
   may displace more volatile compounds (See 3.1  and 3.2)
                                                   127-7



                                                   A6-7

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                                    PART 9

                              SITE SAFETY PLAN
 I.   INTRODUCTION

     The  purpose of the site safety plan is to establish  requirements  for
     protecting the health and safety of  responders  during  all  activities
     conducted at an incident.   It  contains safety  information,  instruc-
     tions,  and procedures.

     A site  safety  plan must be prepared  and  reviewed by qualified personnel
     for  each  hazardous   substance  response.   Before  operations  at   an
     incident commence,  safety  requirements  must  be written,  conspicuously
     posted  or distributed to  all  response  personnel, and discussed with
     them.   The  safety  plan  must   be  periodically  reviewed to  keep   it
     current and technically correct.

     In non-emergency situations, for  example,  long-term remedial  action
     at abandoned  hazardous  waste   sites,   safety  plans  are   developed
     simultaneously with   the  general   work  plan.   Workers can   become
     familiar with   the  plan   before  site  activities  begin.   Emergency
     response generally  requires verbal  safety  instructions and  reliance
     on existing standard  operating  procedures until, when time  permits,  a
     plan can be written.

     The  plan must  contain safety requirements for routine (but  hazardous)
     response activities   and  also  for  unexpected  site emergencies.   The
     major  distinction  between routine  and  emergency  site safety planning
     is the  ability to predict, monitor, and evaluate routine activities.
     A site  emergency is unpredictable and may occur  anytime.
II.   GENERAL REQUIREMENTS

     The site safety plan must:

     -  Describe the known hazards and evaluate the  risks  associated  with
        the incident and with each activity conducted.

     -  List  key  personnel  and  alternates  responsible  for  site  safety,
        response operations, and for protection of public.

     -  Describe Levels of Protection to  be worn  by personnel.

     -  Delineate work areas.

     -  Establish procedures to control  site access.

     -  Describe decontamination  procedures  for  personnel  and  equipment.

     -  Establish site emergency procedures.
                                  9-1

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      -  Address  emergency  medical   care   for  injuries  and toxicological
        problems.

      -  Describe  requirements  for an  environmental  surveillance  program.

      -  Specify any  routine  and  special training required  for  responders.

      -  Establish  procedures  for protecting workers  from  weather-related
        problems.


III.   SITE  SAFETY PLAN SCOPE AND DETAIL

      The plan's scope, detail, and length  is based on:

        Information  available about the incident.

      -  Time  available to prepare a site-specific plan.

      -  Reason for responding.

      Three general categories  of  response exist - emergencies, character-
      izations and  remedial actions.  Although considerations for personnel
      safety are  generic  and  independent  of  the  response  category,  in
      scope, detail,  and  length  safety  requirements and plans vary  consid-
      erably.  These  variations  are  generally  due  to  the   reason   for
      responding (or  category of response)  , information available,  and the
      severity of the incident  with  its concomitant dangers to the  respon-
      der.

      A.  Emergencies

         1.  Situation:

              Emergencies generally  require  prompt  action  to  prevent  or
              reduce  undesirable affects.   Immediate hazards of  fire,
              explosion,  and  release  of toxic  vapors  or gases are  of prime
              concern.  Emergencies  vary  greatly  in  respect to types  and
              quantities  of material,  numbers  of responders, type  of  work
              required, population affected, and other  factors.   Emergencies
              last  from a few hours to a few days.

                Information  available:  Varies from none  to much.   Usually
                information  about the chemicals  involved  and their associ-
                ated hazards is quickly obtained in transportation-related
                incidents, or  incidents involving fixed facilities.
                Determining  the  substances  involved  in   some incidents,
                such as  mysterious  spills, requires considerable  time and
                effort.

              -  Time available:  Little  time,   generally  requires  prompt
                action to bring the  incident under control.

              -  Reason  for  response:   To  implement  prompt and  immediate


                                  9-2

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        actions to control  dangerous or potentially dangerous
        situations.

    2.  Effects on Plan

        In emergencies, time  is not  available  to write  lengthy  and
        detailed safety plans.   Decisions  for  responder  safety  are
        based on  a  continual  evaluation  of  changing  conditions.
        Responding organizations must  rely  on their  existing written
        standard operating safety  procedures  or a generic  plan,  and
        verbal safety  instructions  adapted  to  meet  site-specific
        conditions.  Since heavy reliance is  placed  on  verbal  safety
        instructions an  effective  system  to  keep   all   responders
        informed must be established.  Whenever  possible,  these
        incident-specific instructions should be written.

B.  Incident 'Characterization

    1.  Situation:

        In non-emergency  responses,for example,  preliminary  inspec-
        tions at abandoned wastes  sites  or more  comprehensive waste
        site investigations the objective is to  determine  and charac-
        terize the  chemicals  and  hazards  involved, the  extent  of
        contamination, and risks to  people  and  the  environment.   In
        general, initial  inspections,  detailed  investigations,  and
        extent of contamination surveys are  limited in the activities
        that are required  and number of people  involved.   Initial  or
        preliminary inspections generally require  1-2 days.   Complete
        investigations may last over a longer time'period.

           Information available:   Much background information.
           Generally limited  on-site  data  for  initial  inspection.
           On-site information more fully  developed through additional
           site visits and investigations.

        -  Time available:   In  most  cases adequate time is  available
           to develop written site-specific  safety plan.

        -  Reason for  response:  To  gather  data to  verify  or  refute
           existing information, to  gather  information to  determine
           scope of subsequent investigations, or  to  collect data  for
           planning remedial  action.

    2.  Effects on Plan:

        Sufficient time is available to write safety  plans.   In scope
        and detail, plans tend to be brief containing safety require-
        ments for specific on-site work  relevant  to  collecting data.
        As information is  developed through additional investigations,
        the safety plan is modified  and,  if necessary,  more detailed
        and specific requirements added.
                             9-3

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C.  Remedial  Actions

        1.  Situation:

            Remedial  actions  are cleanups  which last over  a  long period
            of time.   They commence  after more immediate  problems  at an
            emergency have been  controlled, or they involve the mitigation
            of hazards   and  restoration   of   abandoned   hazardous  waste
            sites.   Numerous  activities are required  involving many
            people,  a logistics  and  support  base,  extensive  equipment,
            and more   involved   work  activities.   Remedial  actions  may
            require  months to years to  completely  accomplish.

            -  Information available:   Much known  about  on-site hazards.

            -  Time  available:  Ample  time for  work planning.

            -  Reason for  response:    Systematic   and  complete  control,
               cleanup,  and restoration.

        2.  Effects  on  Plan:

            Since ample  time is available  before work  commences,  site
            safety plan  tends  to be  comprehensive  and  detailed.   From
            prior investigations much  detail   may  be  known  about  the
            materials or hazards at the site and extent  of contamination.


IV. SITE SAFETY PLAN  DEVELOPMENT

    To develop the plan  as much  background  information as  possible should
    be obtained, time permitting, about the incident.   This would include,
    but not be limited to:

       Incident location and  name.

    -  Site description.

    -  Chemicals and  quantities  involved.

    -  Hazards associated  with  each chemical.

    -  Behavior and  dispersion  of material  involved.

    -  Types  of containers, storage,  or transportation methods.

    -  Physical hazards.

    -  Prevailing weather  condition and forecast.

    -  Surrounding populations  and land use.

    -  Ecologically  sensitive areas.
                                 9-4

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    -  Facility records.

    -  Preliminary assessment reports.

    -  Off-site surveys.

    -  Topographic and hydrologic information.

    The information  initially  available  or  obtained through  subsequent
    characterization provides a basis  for developing a site-specific safety
    plan.   Information is needed about the chemicals and hazards involved,
    movement of material  on  and  off  the site, and  potential  contact  with
    responders or the public.  This type of information is then used along
    with the reason  for  responding  (and work plan) to develop  the  safety
    plan.  The plan  is  tailored  to the conditions  imposed  by  the  incident
    and to  its  environmental  setting.  As additional  information  becomes
    available the  safety  plan  is modified to protect  against  the  hazards
    discerned and to provide for site emergencies that may occur.


V.  ROUTINE OPERATIONS

    Routine operations are those  activities  required in  responding  to  an
    emergency or  a  remedial  action  at a  hazardous   waste  site.   These
    activities may involve a high degree of  risk,  but  are  standard  opera-
    tions that all incident responses may require.

    Safety practices  for  routine operations  closely  parallel  accepted
    industrial hygiene  and  industrial  safety  procedures.    Whenever   a
    hazardous incident progresses to  the  point  where operations  become
    more routine,  the  associated  site safety plan  becomes a  more  refined
    document.  As a minimum, the following must be included as part  of the
    site safety plan for routine operations.

    -  Describe the Known Hazards and Risks

       This must  include all  known  or  suspected physical,  biological,
       radiological, or chemical  hazards.  It is important that all  health
       related data be kept up-to-date.  As air, water, soil, or hazardous
       substance monitoring  and  sampling data becomes available,  it  must
       be evaluated, significant risk or exposure to workers noted,  poten-
       tial impact  on public  assessed,  and changes  made  in the  plan.
       These evaluations  need to  be  repeated frequently  since much  of the
       plan is based on this information.

    -  List Key Personnel and Alternates

       The plan must  identify  key personnel (and  alternates)  responsible
       for site safety.   It should  also identify  key  personnel  assigned
       to various  site  operations.    Telephone   numbers,  addresses,  and
       organizations of  these  people  must  be  listed  in  the plan  and
       posted in a conspicuous place.
                                  9-5

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-  Designate Levels  of Protection to be Worn

   The Levels of  Protection  to  be  worn at  locations on-site  or by
   work functions  must  be designated.   This  includes  the  specific
   types of  respirators  and  clothing  to   be  worn  for  each  level.
   No one shall  be permitted in  areas  requiring personnel protective
   equipment unless  they  have been trained  in its use and are wearing
   it.

-  Delineate Work  Areas

   Work areas  (exclusion   zone,   contamination   reduction  zone,  and
   support zone)  need to  be  designated  on  the   site  map and the map
   posted.  The  size  of  zones,  zone  boundaries, and  access control
   points into each  zone  must  be marked and  made known  to  all  site
   workers.

-  List Control  Procedures

   Control procedures must  be  implemented  to   prevent  unauthorized
   access.  Site security procedures -  fences, signs, security
   patrols, and  check-in  procedures  - must be established.  Procedures
   must also be  established to  control  authorized personnel  into work
   zones where personnel  protection  is  required.

   Establish Decontamination  Procedures

   Decontamination procedures  for  personnel  and equipment  must  be
   established.   Arrangements  must   also  be  made   for  the  proper
   disposal of contaminated material,  solutions, and equipment.

-  Address  Requirements   for  an  Environmental   Surveillance Program

   A program to  monitor  site  hazards must be implemented.  This would
   include air  monitoring  and  sampling, and  other  kinds   of  media
   sampling at  or  around  the  site that  would  indicate  chemicals
   present, their hazards, possible migration,  and  associated safety
   requirements.

-  Specify Any Routine and Special Training  Required

   Personnel must be trained  not  only in general safety procedures and
   use of  safety  equipment,  but  in  any specialized  work they  may be
   expected to do.

-  Establish Procedures  for Weather-Related  Problems

   Weather conditions can  affect site  work.   Temperature  extremes,
   high winds, storms, etc. impact on personnel  safety.  Work
   practices must be  established  to protect  workers  from the effects
   of weather and  shelters  provided,   when necessary.   Temperature
   extremes, especially heat  and  its effect  on people wearing protec-
   tive clothing, must  be considered  and  procedures  established to
   monitor for and minimize heat  stress.
                             9-6

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VI. ON-SITE EMERGENCIES

    The plan  must address  site emergencies  -  occurrences  that  require
    immediate actions to  prevent  additional  problems  or  harm  to  respon-
    ders, the  public,  property,  or  the environment.   In  general,  all
    responses present a  degree of  risk to the  workers.   During  routine
    operations risk  is minimized  by establishing good work practices and
    using personnel  protective  equipment.   Unpredictable  events  such as
    fire, chemical exposure,  or  physical  injury may  occur and  must be
    anticipated.  The plan  must contain contingencies for managing them.

    -  Establish Site Emergency Procedures

       —  List  the  names  and  emergency  function  of  on-site personnel
           responsible for  emergency   actions  along  with  the  special
           training  they have.

       --  Post  the  location- of   nearest  telephone  (if  none   at  site).

       ~  Provide alternative means for emergency communications.

       —  Provide a list of emergency  services organizations that may be
           needed.   Names,  telephone   numbers,  and   locations  must  be
           posted.   Arrangements for using emergency organizations should
           be made beforehand.   Organizations that might  be needed are:

           -  Fire

           -  Police

           -  Health

           -  Explosive experts

           -  Local  hazardous material  response units

           -  Civil  defense

           -  Rescue

       --  Address  and  define  procedures  for  the  rapid evacuation  of
           workers.  Clear,  audible  warnings signals  should   be  estab-
           lished, well-marked  emergency  exits   located   throughout  the
           site, and  internal   and  external   communications  plans  devel-
           oped.  An example  of codes  that  could be  used for emergency
           operations based on direct-reading instruments  is contained in
           Annex 7.

       --  A  complete  list of emergency equipment  should  be attached to
           the safety plan.  This list  should include emergency equipment
           available on-site, as  well   as all available  medical,  rescue,
           transport, fire-fighting, and mitigative equipment.
                                 9-7

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        Address  emergency medical  care.

        --  Determine   location   of   nearest   medical   or  emergency  care
            facility.   Determine  their  capability  to handle chemical
            exposure cases.

        --  Arrange  for treating, admitting,  and  transporting  of  injured
            or exposed  workers.

        --  Post the medical  or emergency  care facilities location,  travel
            time, directions,  and telephone  number.

        --  Determine local physician's office location, travel  directions,
            availability, and  post telephone  number  if other medical  care
            is not available.

        --  Determine nearest  ambulance  service  and  post  telephone  number.

        --  List responding  organization's physicians,  safety  officers,  or
            toxicologists name and telephone  number.  Also include  nearest
            poison control center, if applicable.

        --  Maintain accurate  records on any  exposure or potential exposure
            of site  workers  during an  emergency (or routine  operations).
            The  minimum amount   of   information  needed  (along  with  any
            medical test  results) for personnel  exposure  records is
            contained in Annex 8.

        Advise workers  of their duties during an emergency.  In  particular,
        it is imperative that  the site  safety officers, standby  rescue
        personnel, decontamination workers,  and emergency  medical techni-
        cians practice  emergency  procedures.

        Incorporate  into the plan, procedures  for the  decontamination  of
        injured  workers and for their transport to medical care facilities.
        Contamination of  transport vehicles,  medical care facilities,  or
        of medical personnel  may occur  and   should  be  addressed   in  the
        plan. Whenever  feasible  these procedures should  be discussed  with
        appropriate medical  personnel in  advance of  operations.

        Establish procedures  in cooperation with local  and state officials
        for evacuating  residents  who  live  near the site.
VII. IMPLEMENTATION  OF  THE  SITE  SAFETY  PLAN

     The site  safety   plan,  (standard   operating  safety  procedure  or  a
     generic safety  plan  for emergency  response) must be  written  to  avoid
     misinterpretation, ambiguity,  and  mistakes that verbal  orders cause.
     The plan must be  reviewed and approved by qualified  personnel.   Once
     the safety plan is implemented,  its  needs  to  be periodically  examined
     and modified, if necessary, to  reflect any  changes in  site  work  and
     conditions.
                                  9-8

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      All  agencies and organizations which have an active role at the incid-
      ent  must  be familiar  with the  plan.   If  possible  the  plan  should
      be written  in  coordination  with the  organizations   involved.   Lead
      personnel  from these  organizations  should  sign  the   plan to  signify
      they agree with it and will follow its provisions.

      All  personnel involved at  the  site  must be familiar  with the safety
      plan, or  the  parts  that  pertain   to  their  specific  activities.
      Frequent safety meeting  should  be  held to  keep all  informed  about
      site hazards,  changes  in  operating plans, modifications of  safety
      requirements, and for  exchanges  of  information.   It  is the  responsi-
      bility of personnel  involved  at  the site  as  workers  or  visitors  to
      comply with the requirements in the  plan.

      Frequent audits by the incident manager or the safety designee should
      be made to  determine  compliance  with  the plan's  requirements.   Any
      deviations should be brought  to the  attention of the incident  manager.
      Modifications in the plan should  be  reviewed and approved by  appropri-
      ate  personnel.
VIII. SAMPLE SAFETY PLANS

       Annex 9 and 10 are two examples of Site  Safety  Plans.   Since  no  one
       sample plan or plan format can  adequately address all safety require-
       ments for the variety  of  incidents  that occur, they should be  used
       as a guide to help develop an incident-specific plan.   They can  also
       be used,  with necessary  adaptation,  as generic plans  for  emergency
       response.

       In some incidents, the sample  plans contained in Annex  9 and 10 might
       be satisfactory to use by themself.  Filling in  the blanks provides an
       effective safety plan.  In  many incidents they  should only be consid-
       ered as  a check list.  Since  they  do not  exhaustively  cover every
       condition which may  need addressed,  users  of these  sample  plans  and
       any other type  examples  must  realize  their application to any  one
       incident may  not  be acceptable.  Therefore  they  must  be  used  with
       discretion and  tempered  by  professional  judgement  and  experience.
       They are  not  meant to be all  inclusive  but examples  of  considera-
       tions, requirements, and format which should be adapted  for
       incident-specific conditions.
                                   9-9

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                                 ANNEX 8


                     RESPONSE SAFETY CHECK-OFF SHEET

                         (minimum required data)
Bhl-URt RESPONSE
1.
2.
3.
4.
5.
Incident: Site
a. Response Dates
Type of Response:
Incident Safety PI
Suspected chemical
(c)
Protective Level (s
(a) If Level C - 1
2


Spill
an: Region
(s) involved
) involved:
. Identify
. Describe
City

Fire Site
ERT
: (a)
(d)
A B
Canister
air monitoring source(s^
Employee
State

Train Other
Not Developed
(b)

C D

)
        (b) If Level  D JUSTIFY (in comments section at bottom of page).

    6.  SCBA-Identify Buddy:  Name/Organization 	
    7.  Last Response:  (a) Level Used:  A	 B
                        (b) Medical  Attention/Exam Performed:   Yes 	 No

II. AFTER RESPONSE

    1.  Protective Level  Used:   A            B            C            D
        a. Level C - identify cannister: 	 b. Level D (comment bel'ow)
        c. Level B or C skin protection: Tyvek/Saran	Acid/Rain 	Other	
    2.  List possible chemical exposure:  Same as above: 	(a)
        (b) 	 (c) 	W~
    3.  Equipment Decontamination:  (a) clothing  (b) respirator  (c) monitoring
                         Disposed: 	
                          Cleaned: 	
                        No Action:                                	
    4.   Approximate time in exclusion area: 	 hours per day for	days

    5.   Was medical attention/exam required for this response: Yes 	 No 	

Part  I: DATE PREPARED:                     Reviewed by	Date 	
Part II:  DATE PREPARED:	 Reviewed by 	Date

COMMENTS:	

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                                 ANNEX 9

             (Suggested format for minimum site safety plan)

                             SITE SAFETY PLAN

                   (Name of Hazardous Waste Site/Spill)

I.  General Information

    As a minimum, all personnel involved with emergency response, waste
site cleanup, drum handling and opening, sampling, site investigations,
etc., will follow the applicable Federal/State rules and regulations.  In
addition, all site personnel will follow, as a minimum, U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response, Hazardous
Response Support Division's, Standard Operating Safety Guides and Chapter
9 Hazardous Substance Response, from the EPA Occupation Health and Safety
Manual.

    In the event of conflicting plans/requirements, personnel must imple-
ment those safety practices which afford the highest personnel protection.

    If site conditions change and it is necessary to modify Levels of
Protection A, B, or C the safety designee on-site shall notify the On-Scene
Coordinator before making recommendations to site personnel.

II. APPROVALS

  (SIGNATURE)	  (SIGNATURE)	
  On-Scene-Coordinator  (OSC)       DATE   Safety Officer             DATE


  (SIGNATURE)	  (SIGNATURE)	
  REVIEW COMMITTEE                 DATE   OTHERS                     DATE

III. Summary of Minimum Requirements

    A.  The safety officer/designee shall:

        1.  Describe chemicals, hazards, and risk involved

        2.  List key personnel

            a.  Response manager (OSC)/alternate 	

            b.  Safety officer(s)/alternate 	

            c.  Other responsible site personnel/alternate 	

        3.  Prescribe Levels of Protection

        4.  Designate work zones:  Support area, contamination reduction
            area, exclusion area.

        5.  Implement procedures to control site access.
                                 A9-1

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    6.  Define decontamination procedures.

    7.  Delineate entry and escape routes.

    8.  Identify/contact medical  facility, etc.:

        a.  Fire  	

        b.  Ambulance  	

        c.  Police  	

        d.  Health  	

        e.  Etc.
    9.  List responsible parties  and emergency contacts:

        a.  Federal  Government    EPA/USCG/CDC/OSHA	

        b.  State Government     Environmental/Health Agency

        c.  County/City Government   	
    10. Establish personnel  air monitoring.

    11. Specify routine and  special  training needed

    12. Establish procedures  for  managing  weather-related  problems.

B.  Levels of Protection

    1.   Level  C protection  should  be used  for those  job  functions
        1isted belowwhere   there   is   no  potential   for  personnel
        contact with either  hazardous materials or gases, vapors,  or
        particulates exceeding requirements  for wearing air-purifying
        respirators.

        (Identify job functions in this  paragraph:
        e.g.  - monitoring/surveillance,  supervisors,
        observers, etc.)

        (Identify specific  type  of  respirator  in  this  paragraph:
        e.g.  - approved respirator and type  of  canister.)

        (Identify skin protection in  this  paragraph:
        e.g.  -  double  boots,   double   gloves,  tyvek/saran  hooded,
        disposable coveralls,  etc.)
                            A9-2

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   2.   Level B  protection  should  be  used  for those job functions
        listed below  which  based either  on potential  or known
        site  conditions  and/or  vapor  and gas concentrations,
        Level C  is  unsatisfactory.

        Identify job  functions  in  this paragraph:
        (e.g. -  Heavy equipment operations,  samplers,  equipment/
        drum  handlers, etc.)

        Identify specific  respiratory protection  in this  paragraph:
        (e.g. -  self-contained  breathing apparatus  (SCBA),  air-line
        respirator)

        Identify skin protection in this paragraph:
        (e.g. -  double boots,  double  gloves, type of  chemical  re-
        sistant  garment, etc)

    3.   If Level A  protection  is applicable, write  a  paragraph in
        plan  listing  where and  when  it  is  to be worn.

    4.   Level D  is  not adequate protection for  any  work on-site
        where potential  for exposure  is  possible.

    5.   Levels  C and  B may be  modified based on monitoring  and
        sampling data collected on-site.  Safety designee should
        not make any  modification  to  the Level  of Protection
        without  discussing it  with the On-Scene-Coordinator.

C.  Air monitoring  -  Refer to,  Standard  Operating Safety
    Guides, Part 8, Air Surveillance.

D.  Training

    Personnel will  have either formal training  or prior on-the-
    job-training for those tasks  they are assigned  to at  the
    incident.  All  unfamiliar  activities will  be rehearsed
    beforehand.

E.  Respiratory Protection Program

    All contractor and  government  personnel involved in on-site
    activities   shall  have a written respiratory protection  pro-
    gram.  All   personnel wearing air-purifying  respirator on-site
    are required to be  fit-tested.  All  personnel wearing respir-
    ators must   have been properly  trained in their  use.   All
    respirators are to  be properly decontaminated at the  end  of
    each workday.

    Persons having beards or facial  hair must  not wear a  respir-
    ator if a proper mask-to-face-seal  can not  be demonstrated by
    a fit test.   A log  of all   individuals wearing personnel
    protective  equipment shall be maintained including time in
    the exclusion  zone.
                         A9-3

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F.  All  contractor  and  government  personnel  who are  exposed to
    hazardous levels of  chemicals must be enrolled  in a medical
    monitoring program.

G.  General  Safety Rules and Equipment

    1.  There will be no eating,  drinking,  or smoking in the ex-
        clusion or contamination reduction zone.

    2.  All  personnel must  pass through the  contamination reduc-
        tion zone to enter  or exit the exclusion zone.

    3.  As a minimum, emergency eye washes will  be on the  hot side
        of the  contamination  reduction zone  and/or at  the  work
        station.

    4.  As a minimum, an emergency deluge shower/spray cans are to
        be located on the clean side  of  the  contamination reduc-
        tion area.

    5.  At the end of the work  day,  all  personnel  working in the
        exclusion area shall take  a hygienic shower.

    6.  All  supplied breathing air shall be certified as grade D or
        better.

    7.  Where practical, all tools/equipment  will be spark proof,
        explosion resistant, and/or bonded and grounded.

    8.  fire extinguishers  will be on-site for  use on equipment
        or small fires only.

    9.  Since  site  evacuation  may be  necessary  if  an explosion,
        fire, or  release occurs,  an  individual  shall be assigned
        to sound  an  alert  and   notify  the  responsible  public
        officals if required.  For example,  the evacuation signal
        may be two long blasts every 30 seconds until all person-
        nel  are evacuated and accounted for.

    10. An adequately  stocked  first-aid  kit  will be on-scene at
        all  times during operational hours.    It is suggested that
        an oxygen inhalator  respirator be available and a quali-
        fied operator present.  The  location  of these  items  and
        the operator shall  be posted.

H.  Morning Safety Meeting

    A morning  safety meeting will  be  conducted for  all site per-
    sonnel and they will sign a daily  attendance sheet and should
    sign a master sheet indicating they have  read the site safety
    plan and  will  comply.   The safety procedures,  and the day's
    planned operations should be discussed.
                         A9-4

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                             ANNEX 10                  1440 TN12

                                                     5/15/84

OCCUPATIONAL HEALTH AND SAFETY  MANUAL


                         APPENDIX A - SAMPLE SAFETY PLAN


Assistance in preparing the  safety plan can be obtained from
the OHS

Designee 	 located  in Room 	 of Building 	

or by telephoning 	.
REVIEW
     Response Safety Committee  Chairperson

APPROVALS
     OSC/SFC
     OHS Designee

     QIC


PROJECT LEADER

     Branch

     Building

     Room

     Phone

DATE OF PLAN PREPARATION
HAZARDOUS SUBSTANCE RESPONSE

Site Name                	    Site No.
HAZARDOUS/SUBSTANCES  (known  or suspected, contaminated media
                      or  in  storage container, etc.):
                              A10-1

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                                                    1440 TN12
                                                    5/15/84
OCCUPATIONAL HEALTH AND SAFETY MANUAL
HAZARD ASSESSMENT (toxic effects, reactivity, stability,
                  flammability,  and operational hazards with
                  sampling, decontaminating, etc.):
MONITORING 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:
                             A10_2

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                                                    1440 TN12
                                                    5/15/84

OCCUPATIONAL HEALTH AND SAFETY MANUAL


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:
                              A10-3

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                                                     1440  TN12
                                                     5/15/84
OCCUPATIONAL HEALTH AND SAFETY MANUAL


     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 list available
on-site)

               Location                              Telephone

Emergency Medical Facility
Ambulance Service
                               A10-4

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                                                     1440 TN12
                                                     5/15/84
OCCUPATIONAL HEALTH AND  SAFETY  MANUAL
               Location                               Telephone

Fire Department
Police Department
Poison Control Center
PERSONNEL POTENTIALLY EXPOSED  TO  HAZARDOUS SUBSTANCES

     Personnel Authorized to Enter  site

          1.   	

          2.   .	

          3.	,	

          4.	

          5.	.	
                              A10-5

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                                                    1440 TN12
                                                    5/15/84
OCCUPATIONAL HEALTH AND SAFETY MANUAL
     Other Personnel Assigned to Handle Hazardous Substances
     (decontaminate, analyze samples)
          1.

          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.)
                              A10-6

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                                 APPENDIX  I

                  CHARACTERISTICS OF  THE  HNU  PHOTOIONIZER

                                   AND

                           ORGANIC VAPOR  ANALYZER
 I.   INTRODUCTION

     The HNU Photoionizer and the Foxboro Organic Vapor Analyzer  (OVA)* are
     used in the field to  detect  a  variety of compounds in  air.  The two
     instruments differ in their modes of  operation and in the  number and
     types of compounds they detect  (Table 1-1).  Both instruments can be
     used to detect  leaks  of  volatile  substances from drums  and tanks,
     determine the presence of volatile compounds in soil and water, make
     ambient air surveys, and  collect continuous  air monitoring data.  If
     personnel  are thoroughly  trained  to  operate the  instruments and to
     interpret  the data,  these  instruments   can  be  valuable  tools  for
     helping to decide the  levels  of  protection to  be worn,  assist  in
     determining other safety  procedures,  and determine subsequent moni-
     toring or sampling locations.


II.   OVA

     The OVA operates in two different modes.  In the survey mode, it can
     determine approximate total  concentration  of all  detectable species
     in air. With  the gas chromatograph (GC)  option,  individual  components
     can be  detected and  measured  independently,   with   some  detection
     limits as  low as a few parts  per  million  (ppm).

     In the  GC  mode, a  small  sample  of  ambient  air is  injected into a
     chromatographic  column  and carried  through the  column by a stream of
     hydrogen gas.   Contaminants  with different  chemical  structures are
     retained on the  column  for different  lengths  of time  (known as reten-
     tion times) and  hence are  detected  separately by the  flame  ionization
     detector.   A strip chart  recorder can be  used to record  the retention
     times, which are then  compared to  the retention  times of a  standard
     with known chemical  constituents.  The sample can either be  injected
     into the column  from the  air sampling hose or injected  directly with
     a gas-tight syringe.

     In the survey mode,  the  OVA is  internally  calibrated  to methane by
     the manufacturer.  When the instrument is adjusted to manufacturer's
     instructions  it  indicates  the true  concentration  of  methane in air.
     In response to all other detectable compounds, however,  the  instrument
     reading may be higher or  lower  than  the true  concentration.   Relative

     *The use  of  any  trade  names  does   not  imply  their  endorsement  by
      the U.S.  Environmental  Protection Agency.
                                  1-1

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                                  TABLE  1-1

                        COMPARISON OF  THE  OVA AND  HNU
                                OVA
                                                HNU
Response
Application
Detector

Limitations




Calibration gas

Ease of
operation


Detection limits

Response time


Maintenance
Useful range

Service life
Responds to many organic gases
and vapors.
In survey mode, detects total
concentrations of gases and
vapors.  In GC mode, identifies
and measures specific compounds,
Responds to many organic
and some inorganic gases
and vapors.

In survey mode, detects
total  concentrations of
gases and vapors.  Some
identification of compounds
possible, if more than one
probe is used.
Flame ionization detector (FID)    Photoionization detector (PID)
Does not respond to inorganic
gases and vapors.  Kit available
for temperature control.


Methane

Requires experience to inter-
pret correctly, especially
in GC mode.

0.1 ppm (methane)

2-3 seconds  (survey mode)
for CH4

Periodically clean and inspect
particle filters, valve rings,
and burner chamber.  Check
calibration  and pumping system
for leaks.  Re&harge battery
after each use.

0-1000 ppm

8 hours; 3 hours with strip
chart recorder.
Does not respond to methane.
Does not detect a compound if
probe has a lower energy than
compound's ionization potential

Benzene

Fairly easy to use and
interpret.
0.1 ppm (benzene)

3 seconds for 90% of
total concentration of benzene.

Clean UV lamp frequently.
Check calibration regularly.
Recharge battery after each
use.
0-2000 ppm

10 hours; 5 hours with
strip chart recorder.
                                   1-2

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      response ratios for substances other than methane  are  available.   To
      correctly interpret the  readout,  it  is necessary  to  either make
      calibration charts  relating  the  instrument  readings  to  the true
      concentration or to adjust  the instrument so that  it  reads  correctly.
      This is done by turning  the ten-turn  gas-select knob, which  adjusts
      the response of the instrument.  The knob  is  normally set at 3.00 when
      calibrated to methane.   Calibration  to  another gas  is done  by mea-
      suring a  known  concentration of a gas  and  adjusting the  gas  select
      knob until the instrument reading  equals that concentration.

      The OVA has an inherent limitation in  that it can  detect  only  organic
      molecules.  Also,   it  should not be  used at temperatures  lower than
      about 40 degrees  Fahrenheit  because  gases  condense  in the pump and
      column.  It has no  column  temperature control,  (although temperature
      control kits  are   available)  and  since  retention  times  vary with
      ambient temperatures for a given column,  determinations  of  contam-
      inants are  difficult.   Despite these limitations,  the GC mode can
      often provide tentative  information on  the  identity  of  contaminants
      in air without relying on costly,  time-consuming laboratory analysis.
III.   HNU
      The HNU portable  photoionizer  detects the  concentration of  organic
      gases as well as  a  few inorganic gases.  The basis  for  detection  is
      the ionization of  gaseous  species.   Every molecule  has  a  character-
      istic ionization  potential  (I.P=)  which  is the  energy  required  to
      remove an  electron  from  the  molecule, yielding  a positively  charged
      ion and the free  electron.  The  incoming  gas molecules are  subjected
      to ultraviolet (UV)  radiation,  which  is  energetic  enough to  ionize
      many gaseous compounds.  Each molecule is  tranformed  into charged  ion
      pairs, creating  a current between two electrodes.

      Three probes, each containing a  different  UV light source,  are avail-
      able for use with the  HNU.   Ionizing energies  of the probe are 9.5,
      10.2, and  11.7 electron  volts  (eV).   All  three detect many aromatic
      and large  molecule hydrocarbons.  The 10.2  eV and  11.7 eV  probes,  in
      addition,  detect some  smaller organic  molecules and  some halogenated
      hydrocarbons. The 10.2 eV  probe is the most useful for environmental
      response work, as  it  is more  durable than the  11.7 eV  probe  and
      detects more compounds  than  the  9.5 eV probe.

      The HNU factory   calibration  gas is  benzene.  The span potentiometer
      (calibration) knob is turned to  9.8  for benzene calibration.  A knob
      setting of  zero  increases  the  response  to  benzene approximately
      tenfold.  As with the OVA, the instrument's response  can be adjusted
      to give more accurate  readings  for  specific gases and eliminate  the
      necessity  for calibration charts.
                                   1-3

-------
     While  the  primary  use of the HNU is as  a  quantitative  instrument, it
     can  also  be  used  to  detect  certain  contaminants,  or  at  least  to
     narrow the  range of  possiblities.   Noting  instrument  response to  a
     contaminant  source  with  different  probes  can  eliminate some  conta-
     minants from consideration.   For instance,  a  compound's  ionization
     potential  may  be such that  the 9.5  eV  probe produces  no response,  but
     the  10.2  eV and 11.7  eV probes do elicit  a  response.   The HNU  does
     not  detect methane.

     The  HNU is  easier  to use  than  the OVA.   Its  lower detection  limit
     is also in the low ppm range.  The response time  is  rapid;  the  meter
     needle reaches  90% of the  indicated  concentration in  3 seconds  for
     benzene.   It can  be  zeroed  in  a contaminated  atomosphere and  does
     not  detect methane.
IV.   GENERAL  CONSIDERATIONS

     Both  of  these instruments can monitor  only  certain vapors and  gases
     in  air.   Many nonvolatile  liquids,  toxic  solids,  particulates,  and
     other toxic  gases and vapors cannot  be detected.   Because the  types
     of  compounds  that the  HNU  and OVA  can potentially  detect  are  only
     a  fraction  of the chemicals possibly present  at  an incident, a  zero
     reading  on  either instrument does  not necessarily signify  the  absence
     of  air contaminants.

     The instruments  are  non-specific,  and  their  response  to different
     compounds  is  relative to  the calibration setting.   Instrument  readings
     may be higher or lower than the true  concentration.   This can  be an
     especially  serious  problem  when  monitoring  for  total   contaminant
     concentrations if several different compounds  are  being  detected at
     once.  In  addition,  the  response  of  these  instruments is not linear
     over  the entire  detection range.   Care  must  therefore be taken  when
     interpreting  the data.    All  identifications  should   be  reported as
     tentative  until  they  can  be  confirmed  by  more  precise analysis.
     Concentrations should be  reported  in terms of  the calibration  gas and
     span  potentiometer or gas-select-knob setting.

     Since the  OVA and HNU are small, portable instruments, they cannot be
     expected to   yield  results   as  accurate as  laboratory   instruments.
     They  were  originally designed for  specific industrial  applications.
     They  are relatively  easy to  use  and  interpret when  detecting  total
     concentrations of individually known contaminants in  air,  but
     interpretation becomes  extremely  difficult  when trying  to  quantify
     the components  of a mixture.   Neither instrument  can be used  as an
     indicator  for combustible gases or oxygen deficiency.

     The OVA  (Model   128)  is   certified  by  Factory Mutual to  be  used in
     Class I, Division 1, Groups  A,B,C,  and D  environments.  The HNU is
     certified  by  Factory Mutual  for use  in Class  I,  Division 2,  Groups,
     A,  B, C, and  D.
                                  1-4

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                                APPENDIX II

     RATIONALE FOR  RELATING  TOTAL  ATMOSPHERIC  VAPOR/GAS  CONCENTRATIONS

                TO THE SELECTION OF THE LEVEL OF PROTECTION


 I.   INTRODUCTION

     The objective of using total* atmospheric vapor/gas concentrations for
     determining the  appropriate  Level  of  Protection  is to  provide  a
     numerical criterion for selecting Level  A, B,  or C.  In  situations
     where the presence  of  vapors  or  gases  is  not known, or  if  present,
     the individual  components  are unknown,  personnel  required to  enter
     that environment  must   be   protected.   Until  the  constituents  and
     corresponding atmospheric concentrations of vapor, gas, or  particulate
     can be determined and respiratory  and  body  protection related  to the
     toxicological properties of the  identified substances chosen,  total
     vapor/gas concentration, with  judicious  interpretation,  can be  used
     as a guide for selecting personnel protection equipment.

     Although total  vapor/gas concentration  measurements  are useful  to  a
     qualified professional   for the  selection   of protective  equipment,
     caution should  be  exercised in  interpretation.   An  instrument  does
     not respond  with  the  same   sensitivity  to  several  vapor/gas contam-
     inants as it  does  to a  single contaminant.  Also since total  vapor/
     gas field instruments see  all  contaminants  in  relation to  a  specific
     calibration gas, the concentration of unknown  gases  or  vapors  may be
     over or under-estimated.

     Suspected carcinogens,  particulates, highly  hazardous substances,  or
     other substances that  do   not  elicit  an instrument   response may  be
     known or  believed  to  be   present.  Therefore, the  protection  level
     should not be based solely  on  the total  vapor/gas criterion.  Rather,
     the level should  be selected case-by-case, with  special  emphasis  on
     potential exposure and chemical  and toxicological characteristics  of
     the known or suspected  material.


II.   FACTORS FOR CONSIDERATION

     In utilizing  total  atmospheric vapor/gas  concentrations  as a  guide
     for selecting a Level  of Protection, a  number of other factors  should
     also be considered:

     -  The  uses,  limitations,  and   operating  characteristics  of  the
        monitoring instruments must be recognized and understood.
        Instruments such as  the HNU  Photoionizer,  Foxboro Organic  Vapor


 *See Part VII for explanation  of term.
                                  II-l

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        Analyzer  (OVA),  MIRAN Infrared  Spectrophotometer,  and  others  do
        not  respond  identically  to the same  concentration of a  substance
        or respond to  all  substances.  Therefore,  experience,  knowledge,
        and  good  judgement  must  be  used to  complement  the data  obtained
        with  instruments.

      -  Other hazards  may  exist  such as  gases  not  detected by the HMD  or
        OVA,  (i.e.  phosgene,  cyanides,  arsenic,   chlorine),  explosives,
        flammable materials, oxygen deficiency,  liquid/solid particles, and
        liquid or solid chemicals.

      -  Vapors/gases with a  very low TLV  or. IDLH could be  present.  Total
        readings  on  instruments,  not calibrated to these  substances, may
        not  indicate unsafe conditions.

      -  The  risk  to personnel  entering an  area  must be  weighed against
        the  need  for  entering.   Although  this assessment is  largely  a
        value judgment,  it  requires  a  conscientious  balancing  of  the
        variables involved and the risk to  personnel  against  the need  to
        enter an  unknown environment.

      -  The  knowledge  that  suspected  carcinogens  or substances extremely
        toxic or  destructive to skin are present or  suspected to  be present
        (which may  not  be  reflected  in  total vapor/gas   concentration)
        requires  an  evaluation  of factors  such as  the  potential  for ex-
        posure, chemical  characteristics  of  the material,  limitation   of
        instruments, and  other  considerations  specific  to the incident.

      -  What  needs to  be done on-site must be evaluated.  Based  upon total
        atmospheric  vapor concentrations, Level C protection may be judged
        adequate; however, tasks such as moving drums, opening containers,
        and  bulking  of materials, which increase the probability of liquid
        splashes  or  generation  of  vapors,  gases,  or  particulates,  may
        require a higher level of protection.

      -  Before any  respiratory protective apparatus  is  issued,  a respir-
        atory protection  program  must  be developed and  implemented  ac-
        cording to recognized standards (ANSI Z88.2-1980).


III.   LEVEL A PROTECTION  (500 to  1,000 PPM ABOVE BACKGROUND)

      Level A protection  provides" the highest degree of respiratory tract,
      skin, and eye protection  if the  inherent limitations of the personnel
      protective equipment  are  not  exceeded.   The  range  of 500 to 1,000
      parts per million (ppm)  total  vapors/gases concentration  in air was
      selected based  on the following  criteria:

      -  Although  Level A  provides  protection  against  air  concentrations
        greater than  1,000 ppm  for  most  substances,  an  operational  re-
        striction of   1,000  ppm  is   established  as  a  warning  flag  to:
                                   II-2

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        --  evaluate the need to enter environments with unknown
            concentrations greater than 1,000 ppm

        --  identify the  specific  constituents contributing to  the  total
            concentration and their associated toxic properties

        --  determine more precisely concentrations of constituents

        --  evaluate the  calibration  and/or sensitivity  error associated
            with the instrument(s)

        --  evaluate  instrument  sensitivity  to  wind velocity,  humidity
            temperature, etc.

     -  A limit of  500  ppm total  vapors/gases in air was  selected as  the
        value to consider upgrading from Level  B to Level  A.   This concen-
        tration was selected to fully protect the  skin  until the constit-
        uents can be  identified and  measured and  substances  affecting  the
        skin excluded.

     -  The range of 500 to 1,000  ppm is sufficiently conservative to pro-
        vide a safe margin of  protection if readings are low due to instru-
        ment error, calibration,  and sensitivity;  if  higher than antici-
        pated concentrations occur; and  if  substances highly toxic to  the
        skin are present.

     With properly operating portable field equipment, ambient  air
     concentrations approaching 500  ppm have  not  routinely been encoun-
     tered on  hazardous  waste  sites.    High  concentrations   have  been
     encountered only  in  closed  buildings,  when  containers  were   being
     opened, when  personnel  were  working  in  the  spilled  contaminants,
     or when organic vapors/gases  were released in transportation
     accidents.  A  decision  to  require Level  A  protection   should also
     consider the negative  aspects:  higher  probability  of accidents  due
     to cumbersome  equipment,  and most  importantly,  the physical  stress
     caused by heat buildup in fully encapsulating suits.


IV.   LEVEL B PROTECTION  (5 to 500  ABOVE BACKGROUND)

     Level B  protection  is the minimum Level  of  Protection  recommended
     for initially  entering  an open  site  where  the  type,  concentration,
     and presence of airborne vapors are unknown.  This Level  of Protection
     provides a high degree of respiratory  protection.   Skin  and eyes  are
     also protected, although a small portion  of  the  body (neck  and  sides
     of head)  may   be  exposed.  The  use of  a  separate  hood  or hooded,
     chemical-resistant jacket  would  further   reduce the  potential  for
     exposure to this  area of the  body.   Level  B  impermeable protective
     clothing also increases the probability of heat stress.
                                  11-3

-------
    A limit  of  500  ppm  total  atmospheric  vapor/gas  concentration  on
    portable field  instruments  has  been  selected  as  the  upper restriction
    on the  use of Level  B.  Although Level B personnel  protection  should
    be adequate  for most  commonly  encountered  substances at  air  concen-
    trations higher than   500  ppm,  this  limit  has  been selected  as  a
    decision point  for a  careful  evaluation of the  risks associated  with
    higher  concentrations.  These factors  should  be  considered:

    -  The  necessity for  entering  unknown  concentrations higher than  500
       ppm  wearing  Level B protection.

    -  The  probability that substance(s) present  are severe  skin hazards.

    -  The  work to be done and  the increased  probability  of exposure.

    -  The  need for  qualitative  and quantitative  identification  of  the
       specific  components.

    -  Inherent  limitations  of the  instruments  used for air  monitoring.

    -  Instrument  sensitivity  to winds, humidity, temperature, and other
       factors.
V.  LEVEL C  PROTECTION  (BACKGROUND TO 5  PPM ABOVE  BACKGROUND)

    Level  C  provides skin protection identical  to Level  B, assuming  the
    same  type  of chemical protective  clothing  is  worn,  but lesser  pro-
    tection  against  inhalation  hazards.   A range  of background to 5  ppm
    above ambient background concentrations of  vapors/gases  in  the  atmos-
    phere has  been   established  as  guidance  for  selecting  Level  C  pro-
    tection.   Concentrations  in  the  air  of  unidentified  vapors/gases
    approaching  or  exceeding 5  ppm  would  warrant upgrading  respiratory
    protection to a  self-contained breathing  apparatus.

    A full-face,  air-purifying  mask  equipped  with an organic  vapor  can-
    ister (or  a  combined organic  vapor/particulate  canister) provides
    protection against  low concentrations of most common organic vapors/
    gases.  There are  some  substances against which  full-face,  canister-
    equipped masks   do  not   protect,  or  substances  that  have  very  low
    Threshold  Limit  Values  or   Immediately  Dangerous to  Life  or  Health
    concentrations.  Many of the latter  substances are gases  or liquids
    in their normal  state.   Gases would  only be found in gas  cylinders,
    while the  liquids   would  not  ordinarily   be  found in  standard  con-
    tainers  or drums.   Every effort  should  be  made to identify the  in-
    dividual constituents (and the presence of particulates) contributing
    to the total  vapor readings of a few parts  per million.   Respiratory
    protective equipment  can then  be  selected accordingly.   It   is  ex-
    ceedingly  difficult,  however, to  provide  constant,  real-time  iden-
    tification of all  components in  a  vapor cloud with concentrations of
    a few parts  per million  at  a site  where ambient  concentrations  are
    constantly changing.  If  highly toxic substances have been  ruled  out,
                                 11-4

-------
     but ambient levels of a few parts per  million  persist,  it  is  unreas-
     onable to  assume  only self-contained  breathing  apparatus  should  be
     worn. The continuous use of air-purifying masks in  vapor/gas  concen-
     trations of a few parts per million  gives a  reasonable assurance  that
     the respiratory tract  is  protected,   provided  that the  absence  of
     highly toxic substances has been confirmed.

     Full-face, air-purifying devices provide respiratory protection
     against most  vapors  at  greater  than  5 ppm;  however,  until   more
     definitive qualitative  information   is  available,   concentration(s)
     greater than  5 ppm  indicates  that  a  higher  level  of  respiratory
     protection should be used.  Also, unanticipated transient  excursions
     may increase the  concentrations in  the  environment  above  the  limits
     of air-purifying devices.  The  increased probability  of  exposure due
     to the  work  being done may  require  Level  B protection, even  though
     ambient levels are low.
VI.  INSTRUMENT SENSITIVITY

     Although the measurement  of  total  vapor/gas concentrations can be  a
     useful adjunct to professional judgment in the selection of an  appro-
     priate Level  of  Protection,   caution  should  be  used  in the  inter-
     pretation of the measuring instrument's  readout.  The  response  of  an
     instrument to a gas or vapor  cloud  containing  two  or more  substances
     does not provide the  same sensitivity as  measurements  involving the
     individual pure  constituents.   Hence  the  instrument  readout may
     overestimate or underestimate the  concentration  of an  unknown  com-
     posite cloud.  This   same  type  of  inaccuracy  could  also occur  in
     measuring a  single  unknown  substance with  the instrument  calibrated
     to a different substance.  The idiosyncrasies of each instrument must
     be considered  in  conjunction with  the other  parameters  in selecting
     the protection equipment needed.

     Using the total vapor/gas concentration as a criterion used to  deter-
     mine Levels  of Protection should provide  protection  against  concen-
     trations greater than the instrument's  readout.   However, when the
     upper limits  of  Level C and  B  are  approached, serious consideration
     should be  given  to  selecting a  higher  Level  of Protection.   Cloud
     constituent(s) must  be  identified as  rapidly  as  possible  and  Levels
     of Protection  based   on  the   toxic  properties  of  the  specific  sub-
     stance^) identified.


 VII.  EXPLANATION  OF  PHRASE  TOTAL  ATMOSPHERIC VAPOR/GAS  CONCENTRATION

       The phrase  total  atmospheric  vapor/gas  concentration is  commonly
       used to  describe  the  readout, in  ppm,  on  PIDs  and FIDs.   More
       correctly it should be  called a dial  reading or needle deflection.
       In atmospheres  that contain   a   single  vapor/gas  or mixtures  of
       vapors/gases that have not  been identified,  the  instruments  do not
                                  II-5

-------
read the total  vapors/gases  present  only the instrument's response.
This response,  as  indicated  by a deflection  of the  needle  in the
dial, does  not   indicate  the  true  concentration.   Accurate  dial
readings can only be obtained  by  calibrating the instrument  to the
substance being  measured.
                          II-6

-------
                                APPENDIX III

                            DERMAL TOXICITY DATA


 I.   SELECTION OF CHEMICALS

     The approximately 350 chemicals listed  in  Table  III-l,  at the  end  of
     this appendix,  are  identified  in the  Oil  and  Hazardous  Materials
     Technical Assistance  System  (OHMTADS)  as  being   dermally  active.
     Since OHMTADS contains only about 1200 chemicals, or may not indicate
     a listed chemical as  a  skin hazard,  other reference sources  should
     also be consulted.

     The data in  Table III-l were  compiled by  a  toxicologist  through  a
     special project with  the  U.S.  Environmental  Protection  Agency.   As
     with any  source  of  information,   the  data  should  be  cross-checked
     against other standard references.
II.   USE OF TABLES

     A.   Categories

         Table III-l divides chemicals into two categories:

         Category 1 (more serious), which includes:

         -  Gases having a  systemic dermal toxicity  rating  of  moderate  to
            extremely hazardous and a skin penetration ranking  of moderate
            to high.

         -  Liquids and solids having a systemic dermal  toxicity rating  of
            extremely hazardous and a skin penetration ranking  of moderate
            to high.

         -  Gases  having  a  local  dermal  toxicity rating  of moderate  to
            extremely hazardous.

         -  Liquids and  solids having  a  local  dermal  toxicity  rating  of
            extremely hazardous.

         Category 2 (less serious), which includes:

         -  Gases  having  a  systemic  dermal  toxicity  rating  of  slightly
            hazardous and a  skin penetration  ranking  of slight.

         -  Liquids and solids having a systemic dermal  toxicity rating  of
            slightly hazardous and a  skin penetration  ranking  of moderate
            to slight.
                                  III-l

-------
          -   Gases  having a local dermal  toxicity rating of  slightly haz-
             ardous.

          -   Liquids  and solids  having a  local  dermal  toxicity  rating  of
             moderate to slightly hazardous.

      B.   Physical  State

          The physical  state of the  chemicals  listed  is  their  normal  state.
          In a fire,  some  listed as solids  or  liquids   could  vaporize  and
          represent a greater  hazard to the skin.   The chemicals listed  may
          also be found mixed  with other substances,  which  could change  how
          they affect the skin.

      C.   Skin Penetration

                Negligible  Penetration  (solid  -  polar)

          +      Slight Penetration (solid  - nonpolar)

          ++    Moderate Penetration (liquid/solid -  nonpolar)

          +++   High  Penetration  (gas/liquid  - nonpolar)

      D.   Potency (Systemic)                              Lethal  amount  to
                                                         a  70-kilogram  man

          +++   Extreme Hazard  (1059: 1  mg/kg-50 mg/kg)    drops to 20 ml

          ++    Moderate Hazard (LD$Q:  50-500 mg/kg)
1 ounce - 1 pint
   (1 pound)

1 pint - 1 quart
  (2.2 pounds)
          +      Slight  Hazard  (LD50: 500-15,000 mg/kg)


      E.   Potency  (Local )

          +++    Extreme -  Tissue destruction/necrosis

          ++     Moderate -  Irritation/infTarnation of  skin

          +      Slight   -  Reddening of  skin


III.   RELATION  OF  TABLE III-l  AND LEVELS OF PROTECTION

      The  purpose  of  Table  III-l  is to provide data that a  qualified  person
      can  use  in conjunction  with  other site-specific knowledge to  select
      protective clothing.   The  data  relate to  skin  toxicity  only  and
      should not  be  used   to  select   respiratory   protection   equipment.
                                   III-2

-------
     The known  or  suspected  presence  and/or  measured  concentration  of
     Category 1 chemicals  at  or above the  listed  concentrations  warrants
     wearing a fully  encapsulating suit  (Level  A).   The known  or  suspected
     presence and/or  measured  concentration of Category 2 chemicals at  or
     above the listed concentrations  suggests that  a lesser level of  skin
     protection (Level  B or C)  is needed.

     There is no decision-logic  for  choosing protective clothing  as there
     is for choosing  respiratory protective equipment.   The  use of a fully
     encapsulating suit over other types of chemical-resistant clothing  is
     generally a  judgment  made  by  a qualified  individual   based  on  an
     evaluation of all  pertinent  information available  about  the  specific
     incident.  Other guidance  and  criteria for selecting  personnel  pro-
     tection equipment  are  contained in  Part  5, Site  Entry  -  Levels  of
     Protection and in  Appendix II.
IV.   OTHER REFERENCES

     Table III-l  does  not  include  all   substances  affecting  the  skin.
     Other standard references should be consulted, in  particular:

     -  Threshold Limit Values for Chemical  Substances  and physical  Agents
        in the Workroom Environment With Intended Changes for 1982,
        American Conference of  Governmental  Industrial  Hygienists,  6500
        Glenway Ave., Building D-5, Cincinnati, OH 45211 (1982).

     -  NIOSH/OSHA Pocket Guide to Chemical  Hazards,  U.S. Government
        Printing Office, Washington, DC20402 (August  1981).

     -  Registry of Toxic Effects of Chemical  Substances, U.S.  Government
        Printing Office, Washington, DC  20402 (1980).


     Whenever possible, data in one reference should  be cross-checked with
     other references.
                                  III-3

-------
  TABLE III-l



DERMAL TOXICITY
Chemical
2,2 Dichloropropionic acid
2,4,5 - T Acid
2,4,5 - T Amines
2,4,5 - T Esters
2,4,5 - TP Acid
2,4,5 - TP Acid Esters
2,4,5 - T Salts
2,4 - D Acid
2,4 - Dichlorophenol
2,4 - D - Esters
2 - Ethyl hexyl Acrylate
2 - Methyl - 5 - ethyl pyri-
dine
Physical
State
solid
solid
solid
solid
solid
liquid
solid
solid
solid
liquid
liquid
1 iquid
Skin
Penetration
+
+
+
+
+
•H-
+
+
+
++
++
-H-
Dermal
Toxicity
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
local
local
Potency
++
+
++
+
++
+
+
+
++
+
+
+
+
+
++
+
++
+
+
•H-+
+
Permissible
Concentration
-
10 mg/m3/8h
10 mg/m3/8h
10 mg/m3/8h
10 mg/m3/8h
10 mg/m3/8h
10 mg/m3/8h
10 mg/m3/8h
-
10 mg/m3/8h
-
-
Category
2
2
2
2
2
2
2
2
2
2
2
2

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
2 - Napthol
3,5 - Xylenol
Acet aldehyde
Acetic Anhydride
Acetone
Acetone Cyanohydrin
Acetoacetone
Acetyl Bromide
Acetyl Chloride
Acridine
Acrolein
Acrylonitrile
Physical
State
solid
solid
liquid
liquid
liquid
liquid
liquid
fuming
liquid
fuming
liquid
solid
liquid
liquid
Skin
Penetration
+
•f
+
+
•H-+
++
•H-
+++
•H-+
+
+
+++
Dermal
Toxicity
local
systemic
local
local
systemic
local
systemic
local
systemic
local
loqal
local
local
sensitizer
local
sensitizer
systemic
local
Potency
•H-
•H-
+
++
+
•H-
+
•H-
•H-+
•H-
+++
•H-+
+++
+++
+++
++
Permissible
Concentration
-
-
200 ppm/8h
360 mg/nr/8h
5 ppm/8b
20 mg/mj/8h
1,000 ppm/8h
2,400 mg/m3/8h
10 ppm/8h
-
5 ppm/15 min
5 ppm/15 min
-
0.1 ppm/8h
.25 mg/m3/8h
2 ppm/8h
Category
2
2
2
2
2
1
2
1
1
2
2
1

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Adlpic Acid
Adiponitrile
Alkyl dimethyl 3,4 -
Dichlorobenzyl ammonium
Chloride
Allyl Alcohol
Ally! Chloride
Ammonia
Ammonium Bicarbonate
Ammonium Bichromate
Ammonium Bifluoride
Ammonium Bisulfite
Ammonium Carbamate
Ammonium Carbonate
Physical
State
solid
liquid
liquid
liquid
liquid
gas
solid
solid
solid
solid
solid
solid
Skin
Penetration
+
-H-+
+
-H-
-H-
+
+
+
+
+
+
+
Dermal
Toxicity
local
systemic
local
systemic
local
local
local
local
local
local
local
local
local
Potency
+
+++
+
•H-
-H-
++
+++
-H-
•H-
•H-
+++
+
•Hi-
Permissible
Concentration
-
18 mg/m3/8h
-
2 ppm/8h
5 mg/m3/8h
1 ppm/8h
3 mg/m3/8h
25 ppm/8h
18 mg/m3/8h
-
-
-
-
-
-
Category
2
1
2
2
2
1
2
2
2
2
2
2

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Ammonium Citrate
(Dibasic)
Ammonium Ferrocyanide
Ammonium Hydroxide
Ammonium Phosphate
(Dibasic)
Ammonium Sulfamate
Ammonium Sulfide
Ammonium Sulfite
Ammonium Tartrate
Ammonium Thiocyanate
Ammonium Thiosulfate
Aniline
Antimony
Physical
State
solid
solid
liquid
solid
solid
solid
solid
solid
solid
solid
liquid
solid
Skin
Penetration
+
+
•H-
•f
+
+
+
+
•H-
+
++
+
Dermal
Toxicity
local
local
local
local
local
local
local
local
local
systemic
local
local
systemic
local
Potency
-H-+
+
•H-+
•H-
•H-
•H-
•H-
•f+
-H-+
•H-
•H-
•H-
•H-
-H-
Permissible
Concentration
-
-
-
-
10 mg/m3/8h
-
-
-
-
-
5 ppm/8h
0.5 mg/m3/8h
Category
2
2
1
2
2
2
2
2
2
2
2
2

-------
                                                TABLE  III-l  (CONTINUED)


                                                    DERMAL TOXICITY
Chemical
Antimony Pentachloride
Argon - 37 (radjoactive)
Arslne
Arsenic
Arsenic-74 (radioactive)
Arsenic-76 (radioactive)
Arsenic-77 (radioactive)
Arsenic Acid
Arsenic Disulfide
Arsenic Pentoxide
Arsenic Tribromide
Arsenic Trichloride
Physical
State
liquid
gas
gas
solid
solid
solid
solid
solid
solid
solid
solid
solid
Skin
Penetration
++
+++
+++
-H-
++
++
++
++
-H-
++
•H-
•H-
Dermal
Toxicity
local
systemic
systemic
local
systemic
systemic
systemic
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
Potency
-H-+
+++
-H-+
+++
+++
•H-+
•H-+
+++
+++
+-»-+
-H-+
+++
•H-f
•f-H-
•H-+
-H-+
+++
+-H-
Permissible
Concentration
-
-
0.05 mg/m3/8h
.25 mg/m3/8h
-
-
-
0.5 mg/m3/8h
-
-
0.5 mg/m3/8h
0.5 mg/m3/8h
Category
2
1
1
1
1
1
1
1
1
1
1
1
I
oo

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Arsenic Trioxide
Arsenic Trisulfide
Barium
Benzene
Benzophenone
Benzoyl Chloride
Benzoyl Peroxide
Benzyl Alcohol
Benzyl Benzoate
Benzyl Bromide
Benzyl Chloride
Beryllium Nitrate
Physical
State
solid
solid
solid
liquid
solid
liquid
solid
liquid
liquid
liquid
liquid
solid
Skin
Penetration
•H-
•H-
+
•H-
+
-H-
++
•H-
•H-
-H-
•H-
+
Dermal
Toxicity
local
systemic
local
systemic
local
local
systemic
local
local
local
local
systeiriic
local
local
local
local
Potency
+++
+++
+++
+++
•H-
-H-
+++
•H-
-H-+
•H-+
•H-
+
•H-
•H-
•H-+
•H-
Permissible
Concentration
.25 mg/m3/8h
0.5 mg/m3/8h
0.5 mg/m3/8h
75 ppm/30 min
-
5 mg/m3/8h
5 mg/m3/8h
-
-
-
1 ppm/8h
0.25 mg/m3/8h
Category
1
1
2
1
2
1
1
2
2
2
2
2

-------
DERMAL TOXICITY
Chemical
Brombenzyl cyan 1 de
Calcium Hypochlorite
Calcium Oxide
Calcium Phosphide
Camphor
Captan
Carbaryl
Carbofuran
Carbon Disulfide
Carbon Monoxide
Carbon Tetrachloride
Cetyldimethylbenzyl-
ammonium Chloride
Physical
State
liquid
<77 F-solid
solid
solid
solid
solid
solid
solid
liquid
liquid
gas
liquid
solid
Skin
Penetration
++
+
+
+
+
-H-
++
-H-
++
+++
•H-+
+
Dermal
Toxicity
local
systemic
local
local
local
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
systemic
systemic
local
local
Potency
-H-
+++
-H-
++
++
-H-
-H-
•H-
++
-f
++
•H-+
+++
-H-
•H-+
•H-+
•H-f
+
+
Permissible
Concentration
-
-
10 mg/m^/30 min
-
2 ppm/8h
5 mg/m3/8h
5 mg/m3/8h
0.1 mg/m3/8h
20 ppm/8h
60 mg/m3/8h
50 ppm/8h
10 ppm/8h
-
Category
1
1
2
2
2
2
2
1
1
1
1
2

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Chloracetophenone
Chlordane
Bromine
Butyl amine
Butyl Merc apt an
Butyric Acid
Calcium Arsenate
Calcium Arsenite
Calcium Carbide
Calcium Cyanide
Chlorine
Chlorine - 36 (radioactive)
Physical
State
solid
solid
liquid
(fuming)
liquid
liquid
liquid
solid
solid
solid
solid
gas
gas
Skin
Penetration
+
+
++
•H-
•H-
•H-
+
+
+
•H-
-H-+
+++
Dermal
Toxicity
local
systemic
local
systemic
local
systemic
local
local
local
local
systemic
local
systemic
local
systemic
local
local
local
Potency
•H-
•H-
•H-
++
•H-+
++
+++
•H-
•H-
•H-
•HH-
•H-
•H-+
•H-
•H-+
++
-H-+
•m-
Permissible
Concentration
.05 ppm/8h
.5 mg/m3/8h
.1 ppm/8h
5 ppm/8h
.5 ppm/8h
-
1 mg/m3/8h
-
-
5 mg/m3/10 min
1 ppm/8h
3 mg/m3/8h
-
Category
2
2
1
1
2
2
1
1
2
1
1
1

-------
                                                TABLE III-l (CONTINUED)

                                                   DERMAL TOXICITY
Chemical
Chloroacetlc Acid
Chlorobenzene
Chlorobutadlene
Chloromethane
Chloropicrin
Chlorosulfonic Acid
Chlorthion
Chromyl Chloride
CMU
Copper Naphthenate
Coumaphos
Cresyldiphenyl Phosphate
Physical
State
solid
liquid
liquid
gas
liquid
liquid
liquid
liquid
solid
liquid
solid
liquid
Skin
Penetration
-H-
•H-
•H-
•H-f
•H-
•H-
++
•H-
+
•H-
+
++
Dermal
Toxicity
local
local
systemic
local
local
systemic
local
local
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
Potency
++
++
•H-
•H-
+
++
+++
+++
+++
+
+++
-H-
+
+
++
•H-
-H-
+++
-H-
Permissible
Concentration
-
75 ppm/8h
350 mg/m3/8h
25 ppm/8h
100 ppm/8h
0.1 ppm/8h
5 ppm/8h
-
.1 mg/m3/8h
-
500 ppm
-
-
Category
2
2
2
1
1
1
2
1
2
2
2
2
I
(—*
ro

-------
                                               TABLE  III-l  (CONTINUED)



                                                   DERMAL  TOXICITY
Chemical
Croton aldehyde
Cumene
Cupric Acetate
Cupric Acetoarsenate
Cupric Sulfate, Ammoniated
Cyanogen
Cyanogen Bromide
Cyanogen Chloride
Cyclohexanol
Cyclohexanone
Cyclohexylamine
Decaborane
Physical
State
liquid
liquid
solid
solid
solid
gas
solid
gas
liquid
liquid
liquid
solid
Skin
Penetration
-H-
•H-
+
+
+
•H-+
•H-
-H-+
+
+
-H-
+
Dermal
Toxicity
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
Potency
•H-
-H-
-H-
+
+++
++
•H-
++
•H-
-H-+
•f+
+++
++
•H-
++
•H-
+
•H-
•H
•H-
++
-H-
-H-
Permissible
Concentration
2 ppm/8h
50 ppm/8h
0.1 mg/m3/8h
0.1 mg/m3/8h
2 mg/m3/8h
10 ppm/8h
0.5 ppm/8h
10 ppm/15 min
5 mg/m3/8h
50 ppm/8h
50 ppm/8h
10 ppm/8h
.05 ppm/8h
Category
2
2
2
2
2
1
1
1
2
2
2
2
oo

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Decanal
01 acetone Alcohol
Diamylamine
Dlborane
Dicamba
Dlchlobinil
Dlchlone
Dichlorodiflouromethane
Dlchloroethyl Ether
Dlchloromethane
Dlchloropropane
Dichloropropene
Physical
State
liquid
liquid
liquid
gas
solid
solid
solid
gas
liquid
liquid
liquid
liquid
Skin
Penetration
++
•H-
•H-
•H-
+
+
+
•H-
•H-
++
•H-
•H-
Dermal
Toxicity
local
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
Potency
-H-
•H-
+
++
++
•H-
•H-
+
++
+
+
-H-
•H-
•H-
-H-
-H-
++
•H-
+
•H-
•H-
Permissible
Concentration
-
50 ppm/8h
-
.1 ppm/8h
-
-
-
1,000 ppm/8h
5 ppm/8h
200 ppm/8h
75 ppm/8h
-
Category

2
2
1
2
2
2
2
2
2
2
2

-------
TABLE III-l (CONTINUED)




   DERMAL TOXICITY
Chemical
Dichloropropene Dichloropro-
pane
Dichlorvos
D1cyclopentad1ene
Diethanol amine
D1 ethyl ami ne
Di ethyl ene Glycol
Di ethyl enetri amine
Di ethyl Phthalate; Ethyl
Formate
Dimethyl amine
N,N - dimethyl aniline
Dimethyl sulf ate
Dioxane (p-dioxane)
Physical
State
liquid
liquid
liquid
solid
liquid
liquid
liquid
liquid
oily
liquid
oily
liquid
liquid
liquid
Skin
Penetration
•H-
•H-
•H-
+
-H-
+
+
++
++
+++
++
•H-
Dermal
Toxicity
local
systemic
systemic
local
local
local
systemic
local
local
local
systemic
local
local
local
systemic
Potency
•H-
++
•H-
+++
•H-
•H-
+
-H-+
-H
+++
•H-
+
-HH-
•M-
+
Permissible
Concentration
-
.1 ppm/Sh
1 mg/nr/8h
5 ppm/8h
-
25 ppm/8h
-
1 ppm/8h
-
10 ppm/8h
18 mg/m3/8h
5 ppm/8b
25 mg/m3/8h
1 ppm/8h
50 ppm/8h
Category
2
2
2
2
2
2
2
2
2
2
2
2

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Dlphosgene
Dlquat
Dlsulfotone
Dluron
DNBP
DNBP-NH4-salt
1-Dodecanol
Endosulfan
Endothal
Epichlorohydrin
Ethlon
Ethyl Acetate
Physical
State
gas

liquid



solid
solid

liquid
liquid
liquid
Skin
Penetration
•H-
-H-
•H-
•M-
•H-
-H-
+
•H-

•H-
•H-
•H-
Dermal
Toxicity
local
local
systemic
systemic
local
systemic
systemic
systemic
local
systemic
local
local
systemic
systemic
local
Potency
•H-+
•H-
-H-
+++
•H-
++
•H-+
•H-+
+
•m-
•H-
+
•H-
-H-
•M-
Permissible
Concentration
-
0.5 mg/tn3/8h
.1 mg/m3/8h
-
-
-
-
0.1 mg/m3/8h

5 ppm/8h
19 mg/m3/8h
-
400 ppm/8h
1400 mg/m3/8h
Category
1
2
1
2
2
2
2
2

2
2
2

-------
TABLE III-l (CONTINUED)




   DERMAL TOXICITY
Chemical
Ethyl Acrylate
Ethyl Benzene
Ethyl Chloride
Ethyl ene
Ethyl ene Cyanohydrin
Ethyl ene Di bromide
Ethylene Dichloride
Ethyl ene Glycol Di acetate
Ethylene Glycol Monoethyl
Ether Acetate
Ethylene Glycol Monoethyl
Ether
Ethylene Oxide
Ethyl Ether
Physical
State
liquid
liquid
liquid
gas
liquid
liquid
liquid
liquid
liquid
liquid
liquid
liquid
Skin
Penetration
++
•H-
•H-
•H-
•H-
•H-
-H-
•H-
•H-
•H-
+
+
Dermal
Toxicity
local
systemic
local
systemic
local
frostbite
local
frostbite
systemic
local
systemic
local
systemic
systemic
systemic
local
systemic
local
local
Potency
•H-
•H-
++
-H-
•H-
-H-
+
++
•M-
•H-
++
+
+
+
+
+++
+++
Permissible
Concentration
25 ppm/8h
100 mq/m3/8h
100 ppm/8h
1,000 ppm/8h
-
-
20 ppm/8h
50 ppm/5 min
10 ppm/8h
200 ppm/5 min
-
100 ppm/8h
25 ppm/8h
50 ppm/8h
400 ppm/8h
Category
2
2
2
2
2
2
2
2
2
2
2
2

-------
                                                TABLE  III-l  (CONTINUED)

                                                   DERMAL  TOXICITY
Chemical
Ferbam
Ferric Hydroxide
Ferric Nitrate
Ferric Sulfate
Ferrous Sulfate
Ferrous Hydroxide
Ferrous Sulfite
Fish Oil
Fluorine
Formaldehyde
Formic acid
Furfural
Physical
State
solid
solid
solid
solid
solid
solid
solid
liquid
gas
liquid
liquid
liquid
Skin
Penetration
4-
-
-
-
-
-
-
•H-
+++
•H-
•H-
++
Dermal
Toxicity
local
systemic
local
local
local
local
local
local
local
allergen
local
local
systemic
local
local
Potency
4-
+
4-f
•H-
•H-
•H-
•H-
-H-
+
4-H-
+++
-H-
•m-
+++
Permissible
Concentration
15 mg/m3/8h
-
1 mg/m3/8h
-
-
-
-
-
.1 ppm
3 ppm/8h
5 ppm/8h
5 ppm/8h
Category
2
2
2
2
2
2
2
2
1
2
2
2
I
I—'
CXI

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Gas oils
Glyoxal
Guthion
Heptachlor
Heptane
Heptanol
HETP
Hexaborane
Hexamethyl enedl ami ne
Hexane
Hexanol
Hexylene Glycol
Physical
State
liquid
liquid
solid
solid
liquid
liquid
liquid
liquid
solid
liquid
liquid
liquid
Skin
Penetration
•H-
+
-H-
•H-+
-H-
•H-
•m-
-H-
++
•H-
-H-
-H-
Dermal
Toxicity
local
local
systemic
systemic
local
local
systemic
local
systemic
systemic
local
systemic
local
systemic
local
systemic
local
local
systemic
Potency
+
4-
•H-
•H-
+
+
•H-
+
++
+++
•H-
•H-
•H-+
++
•f
++
•m-
•H-
++
4-
Permissible
Concentration
-
-
-
.5 mg/m3/8h
500 ppm/8h
-
-
-
-
500 ppm/8h
-
25 ppm/8h
125 mg/m3/8h
Category
2
2
2
2
2
2
1
2
2
2
2
2

-------
                                                TABLE III-l (CONTINUED)



                                                   DERMAL TOXICITY
Chemical
Hydrazine
Hydrochloric Aoid
Hydrofluoric Acid
3H (Tritium) (Radioactive)
Hydrogen Cyanide
Hydrogen Fluoride
Hydrogen Sulfide
Hydroquinone
Hypochlorous Acid
Indole
Iron Dust
Isobutyl Alcohol
Physical
State
liquid
liquid
liquid
gas
gas
gas
gas
solid
liquid
solid
solid
liquid
Skin
Penetration
•H-
-H-
-H-
+++
+++
+++
+++
•H-
•H-
•H-
-
•H-
Dermal
Toxicity
local
systemic
local
systemic
local
systemic
systemic
systemic
local
systemic
local
systemic
local
local
local
local
systemic
Potency
+++
-H-
+++
+
+++
+
•H-+
•H-+
•HH-
+++
-H-
-H-
-H-+
•H-+
•H-
•f
•H-
Permissible
Concentration
1 ppm/8h
5 ppm/8h
3 ppm/8h
-
10 ppm/8h
3 ppm/8h
10 ppm/8h
2 mg/m3/8h
-
-
-
100 ppm/8h
Category
1
1
1
1
1
1
1
2
2
2
2
2
O

-------
TABLE  III-l (CONTINUED)
      DERMAL TOXICITY
Chemical
Isobutyraldehyde
Isobutyric Acid
Isophorone
Isophthaloyl Chloride
Isopropyl Acetate
Isopropyl ami ne
Isopropyl Ether
Kepone
Krypton 85 (radioactive)
Lead Arsenate
Lead Fluoborate
Lindane
Physical
State
liquid
liquid
liquid
solid
liquid
liquid
liquid
liquid
gas
solid
solid
solid
Skin
Penetration
•H-
+
•H-
+
•H-
++
++
•H-
•H-+
+
+
-H-
Dermal
Toxicity
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
systemic
local
systemic
local
systemic
systemic
Potency
+++
+
+++
+
•H-
•H-
•H-
+
•f
+
•H-
++
•H-
+
+
-H-
+++
•1-
-H-
•H-
++
•H-
Permissible
Concentration
-
-
25 ppm/8h
-
250 ppm/8h
5 ppm/8h
250 ppm/8h
-
-
.5 mg/m3/8h
-
.5 mg/m3/8h
Category
2
2
2
2
2
2
2
2
1
2
2
2

-------
                                                 TABLE III-l (CONTINUED)


                                                    DERMAL TOXICITY
Chemical
Malathion
MCP
Mercaptodlmethur
Mercuric Cyanide
Mercuric Nitrate
Methacrylonitrile
Methyl Acrylate
Methyl Amyl Acetate
Methyl Amyl Alcohol
Methyl Bromide
Methyl Chloride
Methylene Chloride
Physical
State
liquid
liquid

solid
solid
liquid
liquid
liquid
liquid
liquid
or gas
liquid
liquid
Skin
Penetration
•H-
•H-

+
+
++
++
•H-
•H-
+
+
-H-
Dermal
Toxicity
systemic
local
systemic
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
local
local
systemic
Potency
•H-+
•H-+
++
•H-
•H-
+++
•M-
-H-f
+
++
-HH-
•H-
+
•H-
-H-
+
+++
•H-+
-H-
++
Permissible
Concentration
10 mg/m3/8h
-
-
.01 mg/m3/8h
.05 mg/m3/8h
1 ppm/8h
10 ppm/8h
50 ppm/8h
25 ppm/8h
20 ppm/8h
100 ppm/8h
500 ppm/8h
Category
2
2
2
2
2
2
2
2
2
1
2
2
I
ro
r-o

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Methyl Mercaptan
Methyl Methacrylate
Methyl Parathion
Mexacarbate
Monochloro acetone
Monochlorodifluoromethane
Monoethylamine
Monolsopropanol amine
Monomethylamine
Morpholine
Physical
State
liquid
liquid
gas
liquid
liquid
solid
liquid
liquid
gas
liquid
gas
liquid
Skin
Penetration
•H-
•H-
-H-+
++
+++
++
++
++
•H-+
•H-
•H-+
•H-
Dermal
Toxicity
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
(frostbite)
systemic
local
local
local
local
systemic
Potency
+
++
+
+
•H-
++
+++
+++
+
+++
-H-
++
•H-+
•H-
•m-
-H-
•I-H-
•H-
•H-
Permissible
Concentration
590 mg/m3/8h
100 ppm/8h
10 ppm/8h
100 ppm/8h
200 ug/m3
-
-
l,t)00 ppm/8h
10 ppm/8h
-
10 ppm/8h
20 ppm/8h
Category
2
2
2
2
1
2
2
2
1
2
1
2

-------
                                                 TABLE  III-l  (CONTINUED)

                                                     DERMAL  TOXICITY
Chemical
Mustard Gas
m-xylene
m-xylyl Bromide
Nab am
Naled
n-amyl Acetate
Naphthalene
Naphthenic Acid
n-butyl Acetate
n-butyl Acrylate
n-butyl Alcohol
n-butyraldehyde
Physical
State
gas
liquid
liquid
solid
liquid
liquid
solid
solid
liquid
liquid
liquid
liquid
Skin
Penetration
•H-
•H-
++
-H-
•H-
•H-
+
+
•H-
-H-
•H-
•H-
Dermal
Toxicity
local
local
systemic
local
systemic
local
systemic
local
systemic
local
local
systemic
local
local
local
local
systemic
local
Potency
•H-+
•H-
+
•M-
•H-
++
•H-
-1-
•H-
-H-
-M-
++
•H-
+
•H-+
•H-
+
+++
Permissible
Concentration
-
100 ppm/8h
-
-
3 mg/m3/8h
100 ppm/8h
10 ppm/8h
50 mg/m3/8h
-
150 ppm/8h
710 mg/m3/8h
-
50 ppm/8h
-
Category
1
2
2
2
2
2
2
2
2
2
2
2
I
PO
-pi

-------
TABLLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Nickel Ammonium Sulfate
Nickel Carbonyl
Nitric Acid
Nitric Oxide
Nitrilotri acetic Acid
Nitrogen Dioxide
Nitrobenzene
Nitrogen Chloride
Nitroglycerine
Ozone
Nitrous Oxide
Nonane
Physical
State
solid
liquid
liquid
gas
solid
gas
liquid
liquid
liquid
gas
gas
liquid
Skin
Penetration
+
•H-
+
•H-
+
•H-
++
•H-
•H-
+
•H-
•H-
Dermal
Toxicity
local
local
systemic
local
local
local
local
local
systemic
local
local
systemic
local
systemic
local
local
Potency
++
++
++
-H-+
•H-+
•M-
•H-
++
•H-
-H-
•H-
++
-H-
•H-
•H-+
•H-
Permissible
Concentration
1 mg/m3/8h
.05 ppm/8h
2 ppm/8h
25 ppm/8h
-
5 ppm/15 min
1 ppm/8h
5 mg/m3/8h
-
2 mg/m3/8h
.1 ppm/8h
25 ppm/8h
-
Category
2
2
1
1
2
1
2
2
2
2
2
2

-------
                                                TABLE III-l  (CONTINUED)

                                                   DERMAL TOXICITY
Chemical
Nonyl Phenol
n-propyl Alcohol
Omazene
o-nitrophenol
o-nitroaniline
Oxydlpropionitrile
o-xylene
para-nitroaniline
Pentanal
Perch loromethyl mercaptan
Phenolcarbylamine Chloride
Phenolmercuric Acetate
Physical
State
liquid
liquid
solid
solid
solid
liquid
liquid
solid
liquid
liquid
liquid
solid
Skin
Penetration
++
-H-
+
++
+
-H-
-H-
+
•H-
•H-+
-H-
+
Dermal
Toxicity
local
local
systemic
local
systemic
local
systemic
local
systemic
systemic
local
local
systemic
local
systemic
local
systemic
local
systemic
local
local
systemic
Potency
+++
+
+
-H-
++
-H-+
+
+
+++
-H-
+
+
+
•H-
++
•H-
+
-H-
•H-
-H-
+
•H-f
Permissible
Concentration
-
200 ppm/8h
-
-
-
-
100 ppm/8h
1 ppm/8h
-
.1 ppm/8h
-
-
Category
2
2
2
2
2
2
2
2
2
2
2
2
I
1N3
cn

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Phosgene
White Phosphorous (yellow)
Phosphorous Oxychloride
Phosphorous Pentasulfide
Phosphorous Trichloride
Phthalic-Acid-Di ethyl -Ester
Phthalic Anhydride
p-nitrophenol
Potassium Ar sen ate
Potassium Arsenite
Potassium Permanganate
Propane
Physical
State
gas
solid
liquid
solid
liquid
liquid
solid
solid
solid
solid
solid
gas
Skin
Penetration
+
+
•H-
+
++
++
+
+
+
+
+
•H-
Dermal
Toxicity
local
local
systemic
local
systemic
local
systemic
local
systemic
local
local
systemic
local
systemic
local
systemic
local
systemic
local
local
frostbite
Potency
+++
+++
++
+++
++
+++
++
•H-+
++
+
-H-
+
++
-H-
-H-
•H-+
++
-I-H-
•H-+
•m-
Permissible
Concentration
.1 ppm/8h
-
-
1 mg/m3/8h
^5 ppm/Sh
3 mg/m3/8h
-
1 ppm/8h
-
.5 mg/m3/8h
-
-
1,000 ppm/8h
Category
1
1
2
2
2
2
2
2
2
2
2
2

-------
                                                 TABLE III-l (CONTINUED)


                                                    DERMAL TOXICI7Y
Chemical
Propargite
Propionaldehyde,
Proplonic Acid
Propionic Anhydride
Propyl Acetate
Propylamine
Propylene
Propylene Oxide
p-xylene
Pyrethrin I
Pyrethrin II
Pyrethrum
Physical
State

liquid
liquid
liquid
liquid
liquid
gas
liquid
liquid
liquid
liquid
solid
Skin
Penetration

•H-
-H-
•H-
++
++
+++
•H-
•H-
++
++
+
	
Dermal
Toxicity
systemic
local
local
local
local
local
systemic
local
local
local
systemic
local
(allergen)
systemic
local
(allergen)
systemic
local
(allergen]
systemic
Potency
•H-
+++
-H-
•H-+
-H-
+++
++
+
•H-
•H-
+
+
+
•t-
+
•H-
++
Permissible
Concentration
-
-
10 ppm/8h
-
200 ppm/8h
-
4,000 ppm/8h
100 ppm/8h
100 ppm/8h
-
-
5 mg/m3/8h
Category
2
2
2
2
2
2
2
2
2
2
2
2
I
rv>
co

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Pyridine
Pyrocatechol
Quinhydrone
Quinine
Quinolene
Quinone
Resorcinol
Salicyaldehyde
sec-Butyl ami ne
Selenium
Selenium 75
(Radioactive)
Sesone
Physical
State
liquid
solid
solid
solid
liquid
solid
solid
liquid
liquid
solid
solid
solid
Skin
Penetration
•H-
+
+
+
-H-
+
+
-H-
+
+
+
+
Dermal
Toxicity
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
Potency
++
+
•H-
+
-H-
4
+
+
-H-
++
++
•H-
+++
-H-
•H-
+
+++
++
•H-
-H-
-H-
•m-
-H-
Permissible
Concentration
5 ppm/8h
1 ppm/8h
-
-
-
.1 ppm/8h
10 ppm/8h
-
15 mg/m3/8h
-
-
-
Category
2
2
2
2
2
2
2
2
2
2
2
2

-------
                                                TABLE III-l (CONTINUED)

                                                   DERMAL TOXICITY
Chemical
Silver Nitrate
Slmazine
Sodium Anthraquinone
Sulfonate
Sodium Arsenate
Sodium Arsenite
Sodium Bisulfite
Sodium Borate
Sodium Butyl dlphenyl
Sulfonate
Sodium Decylbenzene Sulfonate
Sodium Fluoride
Sodium Fluorosilicate
Sodium Hydrosulfite
Physical
State
solid
liquid
solid
solid
solid
solid
solid
liquid

solid
solid
liquid
Skin
Penetration
+
++
+
+
+
+
+
•H-
+
+
+
•H-
Dermal
Toxicity
local
systemic
local
systemic
local
local
systemic
local
systemic
local
local
systemic
local
local
systemic
local
local
local
Potency
++
-H-
+
+
-H-
-H-
-HH-
-H-
•H-l-
-H-
-H-
•1-
•H-
•1-
•H-
•H-
•m-
•H-
+-H-
Permissible
Concentration
-
-
-
.5 mg/m3/8h
.5 mg/m3/8h
-
-
-
-
2.5 mg/m3/8h
2.5 mg/m3/8h
-
Category
2
2
2
2
2
2
2
2
2
2
2
2
I
CO
o

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Sodium Hypochlorite
Sodium Lauryl Sulfate
Sodium Methyl ate
Sodium Naphthalene
Sulfate
Sodium Nitrite
Sodium Octylsulfate
Sodium Selenite
Strychnine
Styrene
Sulfoxide
Sulfur
Sulfur Dioxide
Physical
State
liquid
solid
solid

solid
solid
solid
solid
liquid
solid
solid
gas
Skin
Penetration
•H-
+
+
+
+
4-
+
+
•H-
+
+
+++
Dermal
Toxicity
local
local
local
local
systemic
local
systemic
local
local
systemic
local
systemic
local
systemic
local
local
local
Potency
+++
•H-
•H-
+
-H-
•H-
•H-
+
-H-
•H-
•H-
•I-M-
•H-
•H-
+
•H-
+++
Permissible
Concentration
-
-
-
-
-
-
.2 mg/m3/8h
•^
.15 mg/m;/8h
.45 mg/m3/15
min
100 ppm/8h
125 ppm/8h
-
-
5 ppm/8h
Category
2
2
2
2
2
2
2
2
2
2
2
2
1

-------
                                                TABLE III-l  (CONTINUED)

                                                   DERMAL TOXICITY
Chemical
Sulfurlc Acid
Sulfur Monochlorlde
TBA
T-Butylhydroperoxide
TCA
TDE
Tert -butyl amide
Tetraborane
Tetradecanol
Tetraethylene Pentamine
Tetraethyl Pyrophosphate
Thallium
Physical
State
liquid
liquid
solid
liquid
solid
solid
solid
liquid
solid
liquid
liquid
solid
Skin
Penetration
•H-
-H-
+
+
+
-H-
+
-H-
+
+
-H-
+
Dermal
Toxicity
local
local
local
systemic
local
systemic
local
systemic
systemic
local
systemic
local
systemic
local
systemic
local
systemic
local
systemic
systemic
Potency
+++
+++
+
•H-
+
•H-
++
•H-
+
•f
-H
•m-
+++
+
+
-H-
++
+
-H-t-
•H--I-
Permissible
Concentration
1 mg/m3/8h
1 ppm/8h
-
-
-
-
-
-
-
-
-
0.1 mg/m3/8h
Category
1
2
2
2
2
2
2
2
2
2
2
2
I
CO
ro

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Thallous Nitrate
Thiophosgene
Thiram
Titanium 44
Titanium Chloride
Toluene
Toluene diisocyanate
Toxaphene
Trichlorfon
Trichloroethane
Tricresyl Phosphate
Tri ethyl aluminum
Physical
State
solid
liquid
solid
solid
solid
liquid
liquid
solid
solid
liquid
liquid
liquid
Skin
Penetration
+
+
•H-
+
+
+
+
•H-
•H-
•H-
•H-
+
Dermal
Toxicity
systemic
local
local
systemic
local
local
local
systemic
local
systemic
local
systemic
systemic
local
systemic
local
systemic
local
•
Potency
+++
-m-
•H-
•H-
+
•H-
+
+
-H-
•H-
•1-
++
•H-
-H-
-H-
+
++
+++
Permissible
Concentration
0.1 mg/m3/8h
-
5 mg/m3/8h
-
-
100 ppm/8h
375 mg/m3/8h
.02 ppm/8h
.14 mg/m3/8h
.5 mg/m3/8h
-
10 ppm/8h
45 mg/m3/8h
-
-
Category
2
2
2
2
2
2
2
2
2
2
2
1

-------
                                               TABLE  III-l  (CONTINUED)

                                                   DERMAL  TOXICITY
Chemical
Triethylene Glycol
Trlethylenetetramine
Tr1methylam1ne Gas
Trimethylamlne Solution
Trinitrotoluene
Uranyl Nitrate
Vanadium Oxytrlchloride
Vaparo
Vinyl Acetate
Vinyl Bromide
Vinyl Chloride
Vinyl Ether
Physical
State
liquid
liquid
gas
liquid
solid
solid
liquid
liquid
liquid
gas
gas
liquid
Skin
Penetration
++
-H-
-H-
++
•H-
+
•H-
-H-
++
+++
•H-+
•H-
Dermal
Toxicity
local
systemic
local
local
local
local
systemic
local
systemic
local
systemic
local
systemic
local
local
systemic
local
systemic
local
systemic
Potency
+
-H-
-H-+
•H-+
•H-+
++
+
++
++
-H-+
++
•H-
+
•H-
-H-+
+-H-
•H-+
+-H-
•H-
-H-
Permissible
Concentration
-
-
25 ppm/8h
25 ppm/8h
1.5 mg/m3/8h
.25 mg/m3/8h
5 ppm/15 min
-
10 ppm/8h
30 mg/m3/8h
200 ppm/8h
200 ppm/8h
-
Category
2
2
1
2
2
2
2
2
2
1
1
2
I
GO

-------
TABLE III-l (CONTINUED)



   DERMAL TOXICITY
Chemical
Xenon 133 (radioactive)
Z1nc Borate
Z1nc Chloride
Z1nc Cyanide
Z1nc Hydrosulfite
Z1nc Phenol sulfonate
Z1nc Phosphide





Physical
State
gas
solid
solid
solid
solid
solid
solid





Skin
Penetration
•f-H-
•f
+
+
+
+
+





Dermal
Toxicity
systemic
local
local
local
systemic
local
local
local
systemic





Potency
+++
•H-
•H-
+
+++
•H--I-
•H-+
•H-
++





Permissible
Concentration
-
10 mg/m3/8h
1 ppm/8h
-
-
-
-





Category
1
2
2
1
2
2
2






-------