United States Environmental Protection Agency Office of Emergency and Environmental Remedial Response Response Hazardous Response Support Division Team Standard Operating Safety Guides // ------- 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 ------- STANDARD OPERATING SAFETY GUIDES November 1984 ENVIRONMENTAL RESPONSE BRANCH HAZARDOUS RESPONSE SUPPORT DIVISION OFFICE OF EMERGENCY AND REMEDIAL RESPONSE U.S. ENVIRONMENTAL PROTECTION AGENCY ------- 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 ------- 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 ------- 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. 1-2 ------- 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 ------- 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 ------- 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 ------- 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. 3-1 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- -- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- -- 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 ------- 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 ------- *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 ------- 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 ------- 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 ------- 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 ------- 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 ------- - 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- - 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 ------- CONTAMINATION REDUCTION ZONE EXCLUSION ZONE (LEVEL C) LEGEND ACCESS CONTROL POINT DECONTAMINATION STATION 8 ACRE, EXCLUSION ZONE NEW HAMPSHIRE WASTE SITE FIGURE 6-2 ------- 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 ------- 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 ------- HEAVY EQUIPMENT DECONTAMINATION AREA L_ 1 x — i i — x r^x*! v _£*s._ v > 3 AUXILIARY £ ACCESS ^ CONTROL PATH ^ C SUPPORT ZONE CAOLl ZO CONTAMINAT REDUCTIOI ZONE JOIUIN NE EX PA ION M i — - - i ' i ] DRESSOUT i 1 AREA ! L J " 1 ENTRY PATH *T2 * CONTAMINATION l^ IT FH ^ " HtUUUIlUN ^ W CORRIDOR i 1 ^j V, LEGEND _x x HOTLINE CONTAMINATION ° ° CONTROL LINE /o> ACCESS CONTROL *y POINT - EXTRANCE r-^^ ACCESS CONTROL L=^J POINT - EXIT i REDRESS i j AREA i L -_ _ _1 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Equipment: water soap tables wash basin/bucket A4-3 ------- 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 ------- . 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 ------- -- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- - 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 ------- 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 ------- 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 ------- - 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 ------- - 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 ------- 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 ------- 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 ------- 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 ------- 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: ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- -- 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 ------- |