Washington, OC 20480
                QSWER Directive initiation Request
                                i. Directive Numbe
                                  9285.3-06
                               2. Orlglnitor Information
     Nam* o< Contact Person
       David  Weitzman
     Mail Cod*
      OS-200
Office
OERR-io
Telephone Codt
 382-2180
      3. Title
        Priority for Health & Safety Requirements, Especially Medical
        Surveillance Requriements for EPA employees who  Support OSWER
        Programs
      4. Summary ot Directive (include bnel statement ol purpose)
        Requires  procedures for protection of OSWER employees and others
        working on  OSWER  cleanup activities.
      5. Keywords
      Safety/  cleanups,  me-dica'l  surveillance.
            rfe
      DA. uoes I nis uirecuvc auperseoe previous uirecuveisj:
      b. Dots It Supplement Previous Otrective(s)?
         [x  I No   [  I Ye»   Wh«t directive (number. tWe)
         a
                                        No
     Yes   Whet dfrtcttve (number. We)
                                               9285.3-02
     7. Draft Level
         A-SignedbyAA/DAA
B - Signed by Office Director
      C - For Review & Comment
         >-ft Development
8.
Document to
be
distributed
to
States by Headquarters? | 	 | Y"
x

No
This Request Meets OSWER Directives System Format Standards.
9. Signature ol Lead Office Directives Coordinator
Betti C. VanEpps / Superfund Documents Coord.
10. Name and Tale ol Approving Official
Don Clay, Assistant Administrator
Date
3/1/90
Date
3/1/90
     EPA Form 131S-17 (Rev. S-«7) Previous editions are obsolete.

    NOTE:  Copies of this document  may  be  obtained from the Superfund
    Document & Information Center - 382-6940 - Mail Code OS-245..
   OSWER          OSWER              OSWER              0
VE     DIRECTIVE         DIRECTIVE        DIRECTIVE

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  \        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

  /                    WASHINGTON, D.C. 20460
                           MAR   I 1990
                                                       OFFICE OF
                                              SOLID WASTE AND EMERGENCY RESPONSE
                                        OSWER Directive 9285.3-06
MEMORANDUM
SUBJECT:  Priority for Health and Safety Requirements, Especially
          Medical Surveillance Requirements, for EPA Employees
          Who Support OSWER Programs
FROM:     Don R. Clay
          Assistant Admihistra'

TO:       Regional Administr
          Regions I - X


     One of my first priorities as Assistant Administrator is to
impress upon you my commitment to protect the health and safety
of EPA employees engaged in hazardous substance, oil spill, and
hazardous waste operations.  I need not "preach to the choir"
about protecting our employees from the suffering caused by
illness or injury.  This conviction is deeply ingrained in all of
us. I would, however, like to focus your attention on the effort
that must be expended to obtain and/or retain this protection.

     I recognize that your health and safety program faces
tremendous competition for the limited staff resources you have
available to you.  Indeed I contribute to this competition with
the challenging goals I have established in the various solid
waste and emergency response programs.  I would like to make it
perfectly clear, however, that I believe it is a priority that
you expend the effort needed to assure the health and safety of
your employees who are pursuing these programmatic goals.  In
addition to minimizing the risk of our employees becoming ill or
injured, we also will achieve more in the long run by avoiding
the productivity losses that inevitably occur in unsafe or
unhealthy work situations.

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                               -2-
      I am sure you are aware that we have been required,  since
 December 1986, to comply with the Occupational Safety and Health
 Administration's (OSHA's) hazardous waste and emergency response
 worker protection rule (29 CFR 1910.120).  We are also required
 to comply with Agency health and safety policies contained in the
 EPA 1440 Directives.  You were reminded of these requirements in
 a July 7, 1987 memorandum (Attachment).  OSWER Directive No.
 9285.8-02, "U.S. Environmental Protection Agency Health and
 Safety Audit Manual1*, is a very detailed guide that you can use
 to evaluate your Regional health and safety program against the
 OSHA  requirements.

      I would like to focus your attention on one of the most
 important of these requirements:  medical surveillance (sometimes
 called medical monitoring).   I am particularly concerned that
 medical surveillance may not be getting the consistent attention
 it needs in all the Regions.  Here is a brief summary of OSHA's
 medical surveillance requirements which your program must meet:

      o  Employees who may be exposed to hazardous substances, oil
 spills, or hazardous wastes must be included in the medical
 surveillance program.

      o  The medical exams must be given before the employee is
 assigned to work where exposures to these substances may occur,
 at least once every twelve months of the assignment, and at the
 end of the assignment.  Also, exams must be given as soon as
 possible after an exposure,  or after the employee develops signs
 or symptoms of exposure,  to these substances.

     o  The exams must include a medical and work history as well
 as other specific tests that Regional management and the
examining physician agree are necessary.

     o  Regional management must provide the physician with
 information about the employee's duties and exposures to these
 substances.

     o  Regional management must obtain a written opinion from
 the physician of any detected medical condition that would place
the employee at increased risk from the assignment.

     o  Regional management must keep accurate medical
surveillance records.  The records must be kept securely and
transferred intact whenever there is a change in health
providers.

     The medical surveillance program is designed to provide a
critical watch over the health status of our most valuable
resource:   our people.  Please inform me by April 15, 1990 of the
status of the implementation of this program for the employees

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                               -3-

engaged in hazardous substance, oil spill, and hazardous waste
operations in your Region.


     The OSWER contact for additional information about any
aspect of your health and safety program for OSWER activities is
Rod Turpin, Manager, OSWER's Integrated Health and Safety
Program.  He can be reached at FTS 340-6745.
Attachment

cc:  Waste Management Division Directors, Regions I-X
     Environmental Services Division Directors, Regions I-X
     Assistant Regional Administrators, Regions I-X
     Management Division Directors, Regions I-X
     Henry L.  Longest II
     Bruce Diamond
     Sylvia Lowrance
     Ronald Brand
     James L.  Makris
     Walter Kovalick Jr.
     Thaddeus  L.  Juszczak, Jr.
     John C.  Chanberlin
     David J.  Weitzman
     Rodney Turpin

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