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
-------
\ 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.
-------
-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
-------
-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
------- |