NIOSH/OSHA/USCG/EPA
Occupational Safety and
Health Guidance Manual
for Hazardous Waste
Site Activities
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Occupational Safety and Health
Guidance Manual for
Hazardous Waste Site Activities
Prepared by:
National Institute for Occupational Safety and Health (NIOSH)
Occupational Safety and Health Administration (OSHA)
U.S. Coast Guard (USCG)
U.S. Environmental Protection Agency (EPA)
U.S. Department of Health and Human Services
Public Health Service
Centers for Disease Control
National Institute for Occupational Safety and Health
October 1985
For «ale by the Superintendent of Document*, U.S. Government
Printing Office, Washington, D.C. 20402
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Contents
Acknowledgments ii
Notice ii
Chapters
1. Introduction 1-1
2. Hazards 2-1
3. Planning and Organization 3-1
4. Training 4-1
5. Medical Program 5-1
6. Site Characterization 6-1
7. Air Monitoring 7-1
8. Personal Protective Equipment 8-1
9. Site Control 9-1
10. Decontamination 10-1
11. Handling Drums and Other Containers 11-1
12. Site Emergencies 12-1
Appendices
A. List of Abbreviations and Acronyms A-1
B. Generic Site Safety Plan B-1
C. Sample Hazardous Substance
Information Form C-1
D. Sample Decontamination Procedures for
Three Typical Levels of Protection D-1
E. NIOSH, OSHA, and EPA Regional Offices
and USCG District Offices E-1
Acknowledgments
The Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities is a result of the collabora-
tive efforts of individuals representing the National Insti-
tute for Occupational Safety and Health (NIOSH), the lead
agency, and the Occupational Safety and Health Adminis-
tration (OSHA), the U.S. Coast Guard (USCG), and the U.S.
Environmental Protection Agency (EPA). Agency represen-
tatives on the steering committee for this project were:
Gail Kleiner (OSHA)
Sheldon Rabinovitz (NIOSH)
David Weitzman (EPA)
Glenn Wiltshire (USCG)
Jan Connery of Eastern Research Group, Arlington, Massa-
chusetts, edited and coordinated production of the manual.
Over 100 individuals and organizations also contributed
substantially to the development of this manual by provid-
ing technical information and review. Although they are too
numerous to name individually, the steering committee
gratefully acknowledges their valuable contributions.
Notice
No warranty, guarantee, or representation, expressed or
implied, is made by or on behalf of the U.S. Government as
to the absolute correctness or sufficiency of any represen-
tation contained in this document. The U.S. Government
assumes no responsibility in connection therewith, nor can
it be assumed that all acceptable safety measures are con-
tained in this or associated documents, or that other or
additional measures may not be required under particular
or exceptional conditions or circumstances.
The mention of a brand name product or company does
not constitute endorsement by the National Institute for
Occupational Safety and Health, the Occupational Safety
and Health Administration, the U.S. Coast Guard, or the
U.S. Environmental Protection Agency.
DHHS (NIOSH) Publication No. 85-115
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1. Introduction
In the past decade, industry, government, and the general
public have become increasingly aware of the need to
respond to the hazardous waste problem, which has
grown steadily over the past 40 years. In 1980, Congress
passed the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)—the Super-
fund law—to provide for "liability, compensation,
cleanup, and emergency response for hazardous sub-
stances released into the environment and the cleanup of
inactive waste disposal sites."
This manual is a guidance document for managers
responsible for occupational safety and health programs
at inactive hazardous waste sites. It assumes a basic
knowledge of science and experience in occupational
safety and health. It is the product of a four-agency com-
mittee (the National Institute for Occupational Safety and
Health [NIOSH], the Occupational Safety and Health
Administration [OSHA], the U.S. Coast Guard [USCG],
and the U.S. Environmental Protection Agency [EPA])
mandated by CERCLA section 301 (f) to study the prob-
lem of protecting the safety and health of workers at haz-
ardous waste sites, and by CERCLA section 111(c)(6) to
develop a program to protect the health and safety of
employees involved in response to hazardous substance
releases, removals, or remedial actions.
This manual is intended for federal, state, and local offi-
cials and their contractors. It may be used:
• As a planning tool by government or private
individuals.
• As a management tool by upper level or field
managers.
• As an educational tool to provide a comprehensive
overview of all aspects of safety and health protec-
tion at hazardous waste sites.
• As a reference document for site personnel who need
to review important aspects of health and safety.
This document is not a detailed industrial hygiene text-
book or a comprehensive source book on occupational
safety and health. It provides general guidance and
should be used as a preliminary basis for developing a
specific health and safety program. The appropriateness
of the information presented should always be evaluated
in light of site-specific conditions. Other sources and
experienced individuals should be consulted as necessary
for the detail needed to design and implement occupa-
tional safety and health programs at specific hazardous
waste sites.
Although this manual cites federal regulations, it is not a
definitive legal document and should not be taken as
such. While it represents a cooperative effort of the four
agencies to develop a document that blends their widely
differing mandates, policies, and procedures in specific
areas, the manual may not include elements of each
agency's policies that should be considered when
developing occupational safety and health programs for
hazardous waste sites. Individuals who are responsible
for the health and safety of workers at hazardous waste
sites should obtain and comply with the most recent fed-
eral, state, and local regulations relevant to these sites,
and are urged to consult with OSHA, EPA, and other
appropriate federal, state, and local agencies.
This manual will be updated regularly. Please send com-
ments and suggested revisions to any of these four
organizations:
NIOSH
Hazardous Waste Program (C-17)
4676 Columbia Parkway
Cincinnati, OH 45226
OSHA
Directorate of Technical Support
200 Constitution Avenue, NW
Washington, DC 20210
USCG
Environmental Response Division (G-WER-2)
2100 Second Street, SW
Washington, DC 20593
EPA
Occupational Health and Safety Staff (PM-273)
401 M Street, SW
Washington, DC 20460
A separate manual that specifically addresses response to
hazardous substances emergencies will be published at a
later date. In the meantime, much of the information in
this manual can be used in planning for response to emer-
gencies involving hazardous substances.
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2. Hazards
Contents
Introduction 2-1
Chemical Exposure 2-1
Explosion and Fire 2-2
Oxygen Deficiency 2-2
Ionizing Radiation 2-2
Biologic Hazards 2-3
Safety Hazards 2-3
Electrical Hazards 2-3
Heat Stress 2-3
Cold Exposure 2-3
Noise 2-3
Introduction
Hazardous waste sites pose a multitude of health and
safety concerns, any one of which could result in serious
injury or death. These hazards are a function of the
nature of the site as well as a consequence of the work
being performed. They include:
• Chemical exposure.
• Fire and explosion.
• Oxygen deficiency.
• Ionizing radiation.
• Biologic hazards.
• Safety hazards.
• Electrical hazards.
• Heat stress.
• Cold exposure.
• Noisa
Several factors distinguish the hazardous waste site
environment from other occupational situations involving
hazardous substances. One important factor is the uncon-
trolled condition of the site. Even extremely hazardous
substances do not endanger human health or safety if
they are properly handled. However, improper control of
these substances can result in a severe threat to site
workers and to the general public.
Another factor is the large variety and number of sub-
stances that may be present at a site. Any individual
location may contain hundreds or even thousands of
chemicals. Frequently, an accurate assessment of all
chemical hazards is impossible due to the large number of
substances and the potential interactions among the sub-
stances. In addition, the identity of the substances on site
is frequently unknown, particularly in the initial stages of
an investigation. The Project Team Leader (see Chapter 3,
Planning and Organization] will often be forced to select
protective measures based on little or no information.
Finally, workers are subject not only to the hazards of
direct exposure, but also to dangers posed by the disor-
derly physical environment of hazardous waste sites and
the stress of working in protective clothing.
The combination of all these conditions results in a work-
ing environment that is characterized by numerous and
varied hazards which:
• May pose an immediate danger to life or health.
• May not be immediately obvious or identifiable.
• May vary according to the location on site and the
task being performed.
• May change as site activities progress.
General categories of hazards that may be present at a
site are described in this chapter. In approaching a site, it
is prudent to assume that all these hazards are present
until site characterization has shown otherwise. A site
health and safety program, as described in the subse-
quent chapters of this manual, must provide comprehen-
sive protection against all potential hazards and specific
protection against individual known hazards. It should be
continuously adapted to new information and changing
site conditions.
Chemical Exposure
Preventing exposure to toxic chemicals is a primary con-
cern at hazardous waste sites. Most sites contain a vari-
ety of chemical substances in gaseous, liquid, or solid
form. These substances can enter the unprotected body
by inhalation, skin absorption, ingestion, or through a
puncture wound (injection). A contaminant can cause
damage at the point of contact or can act systemically,
causing a toxic effect at a part of the body distant from
the point of initial contact.
Chemical exposures are generally divided into two cate-
gories: acute and chronic. Symptoms resulting from acute
exposures usually occur during or shortly after exposure
to a sufficiently high concentration of a contaminant. The
concentration required to produce such effects varies
widely from chemical to chemical. The term "chronic
exposure" generally refers to exposures to "low" concen-
trations of a contaminant over a long period of tima The
"low" concentrations required to produce symptoms of
chronic exposure depend upon the chemical, the duration
of each exposure, and the number of exposures. For a
given contaminant, the symptoms of an acute exposure
may be completely different from those resulting from
chronic exposura
For either chronic or acute exposure, the toxic effect may
be temporary and reversible, or may be permanent (disa-
bility or death). Some chemicals may cause obvious
symptoms such as burning, coughing, nausea, tearing
eyes, or rashes. Other chemicals may cause health dam-
age without any such warning signs (this is a particular
concern for chronic exposures to low concentrations).
Health effects such as cancer or respiratory disease may
not become manifest for several years or decades after
exposura In addition, some toxic chemicals may be color-
less and/or odorless, may dull the sense of smell, or may
not produce any immediate or obvious physiological sen-
sations. Thus, a worker's senses or feelings cannot be
relied upon in all cases to warn of potential toxic
exposure.
The effects of exposure not only depend on the chemical,
its concentration, route of entry, and duration of expo-
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2-2
Hazards
sure, but may also be influenced by personal factors such
as the individual's smoking habits, alcohol consumption,
medication use, nutrition, age, and sex (see Chapter 5,
Medical Program).
An important exposure route of concern at a hazardous
waste site is inhalation. The lungs are extremely vulner-
able to chemical agents. Even substances that do not
directly affect the lungs may pass through lung tissue
into the bloodstream, where they are transported to other
vulnerable areas of the body. Some toxic chemicals pres-
ent in the atmosphere may not be detected by human
senses, i.a, they may be colorless, odorless, and their
toxic effects may not produce any immediate symptoms.
Respiratory protection is therefore extremely important if
there is a possibility that the work-site atmosphere may
contain such hazardous substances. Chemicals can also
enter the respiratory tract through punctured eardrums.
Where this is a hazard, individuals with punctured
eardrums should be medically evaluated specifically to
determine if such a condition would place them at unac-
ceptable risk and preclude their working at the task in
question.
Direct contact of the skin and eyes by hazardous sub-
stances is another important route of exposure. Some
chemicals directly injure the skin. Some pass through the
skin into the bloodstream where they are transported to
vulnerable organs. Skin absorption is enhanced by abra-
sions, cuts, heat, and moisture. The eye is particularly vul-
nerable because airborne chemicals can dissolve in its
moist surface and be carried to the rest of the body
through the bloodstream (capillaries are very close to the
surface of the eye). Wearing protective equipment, not
using contact lenses in contaminated atmospheres (since
they may trap chemicals against the eye surface), keeping
hands away from the face, and minimizing contact with
liquid and solid chemicals can help protect against skin
and eye contact.
Although ingestion should be the least significant route of
exposure at a site, it is important to be aware of how this
type of exposure can occur. Deliberate ingestion of chem-
icals is unlikely, however, personal habits such as chewing
gum or tobacco, drinking, eating, smoking cigarettes, and
applying cosmetics on site may provide a route of entry
for chemicals.
The last primary route of chemical exposure is injection,
whereby chemicals are introduced into the body through
puncture wounds (for example, by stepping or tripping
and falling onto contaminated sharp objects). Wearing
safety shoes, avoiding physical hazards, and taking com-
mon sense precautions are important protective measures
against injection.
Explosion and Fire
There are many potential causes of explosions and fires
at hazardous waste sites:
• Chemical reactions that produce explosion, fire, or
heat.
• Ignition of explosive or flammable chemicals.
• Ignition of materials due to oxygen enrichment.
• Agitation of shock- or friction-sensitive compounds.
• Sudden release of materials under pressure.
Explosions and fires may arise spontaneously. However,
more commonly, they result from site activities, such as
moving drums, accidentally mixing incompatible chemi-
cals, or introducing an ignition source (such as a spark
from equipment) into an explosive or flammable environ-
ment. At hazardous waste sites, explosions and fires not
only pose the obvious hazards of intense heat, open
flame, smoke inhalation, and flying objects, but may also
cause the release of toxic chemicals into the environ-
ment. Such releases can threaten both personnel on site
and members of the general public living or working
nearby. To protect against the hazard: have qualified per-
sonnel field monitor for explosive atmospheres and flam-
mable vapors; keep all potential ignition sources away
from an explosive or flammable environment; use non-
sparking, explosion-proof equipment; and follow safe
practices when performing any task that might result in
the agitation or release of chemicals.
Oxygen Deficiency
The oxygen content of normal air at sea level is approxi-
mately 21 percent. Physiological effects of oxygen defi-
ciency in humans are readily apparent when the oxygen
concentration in the air decreases to 16 percent. These
effects include impaired attention, judgment and coordi-
nation, and increased breathing and heart rate. Oxygen
concentrations lower than 16 percent can result in nausea
and vomiting, brain damage, heart damage, unconscious-
ness, and death. To take into account individual physio-
logical responses and errors in measurement, concentra-
tions of 19.5 percent oxygen or lower are considered to
be indicative of oxygen deficiency.
Oxygen deficiency may result from the displacement of
oxygen by another gas, or the consumption of oxygen by
a chemical reaction. Confined spaces or low-lying areas
are particularly vulnerable to oxygen deficiency and
should always be monitored prior to entry- Qualified field
personnel should always monitor oxygen levels and
should use atmosphere-supplying respiratory equipment
(see Chapter 8, Personal Protective Equipment) when oxy-
gen concentrations drop below 19.5 percent by volume.
Ionizing Radiation
Radioactive materials emit one or more of three types of
harmful radiation: alpha, beta, and gamma. Alpha radia-
tion has limited penetration ability and is usually stopped
by clothing and the outer layers of the skin. Alpha radia-
tion poses little threat outside the body, but can be haz-
ardous if materials that emit alpha radiation are inhaled or
ingested. Beta radiation can cause harmful "beta burns"
to the skin and damage the subsurface blood system.
Beta radiation is also hazardous if materials that emit beta
radiation are inhaled or ingested. Use of protective cloth-
ing, coupled with scrupulous personal hygiene and decon-
tamination, affords good protection against alpha and
beta radiation.
Gamma radiation easily passes through clothing and
human tissue and can also cause serious permanent dam-
age to the body. Chemical-protective clothing affords no
protection against gamma radiation itself; however, use of
respiratory and other protective equipment can help keep
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Hazards
2-3
radiation-emitting materials from entering the body by
inhalation, ingestion, injection, or skin absorption.
If levels of radiation above natural background are discov-
ered (see Table 6-2 in Chapter 6), consult a health physi-
cist. At levels greater than 2 mrem/hr, all site activities
should cease until the site has been assessed by health
physicists.
Biologic Hazards
Wastes from hospitals and research facilities may contain
disease-causing organisms that could infect site person-
nel. Like chemical hazards, etiologic agents may be dis-
persed in the environment via water and wind. Other
biologic hazards that may be present at a hazardous
waste site include poisonous plants, insects, animals, and
indigenous pathogens. Protective clothing and respiratory
equipment can help reduce the chances of exposure.
Thorough washing of any exposed body parts and equip-
ment will help protect against infection.
Safety Hazards
Hazardous waste sites may contain numerous safety
hazards such as:
• Holes or ditches.
• Precariously positioned objects, such as drums or
boards that may fall.
• Sharp objects, such as nails, metal shards, and
broken glass.
• Slippery surfaces.
• Steep grades.
• Uneven terrain.
• Unstable surfaces, such as walls that may cave in or
flooring that may give way.
Some safety hazards are a function of the work itself. For
example, heavy equipment creates an additional hazard
for workers in the vicinity of the operating equipment.
Protective equipment can impair a worker's agility, hear-
ing, and vision, which can result in an increased risk of an
accident.
Accidents involving physical hazards can directly injure
workers and can create additional hazards, for example,
increased chemical exposure due to damaged protective
equipment, or danger of explosion caused by the mixing
of chemicals. Site personnel should constantly look out
for potential safety hazards, and should immediately
inform their supervisors of any new hazards so that
mitigative action can be taken.
Electrical Hazards
Overhead power lines, downed electrical wires, and
buried cables all pose a danger of shock or electrocution
if workers contact or sever them during site operations.
Electrical equipment used on site may also pose a hazard
to workers. To help minimize this hazard, low-voltage
equipment with ground-fault interrupters and water-tight.
corrosion-resistant connecting cables should be used on
site In addition, lightning is a hazard during outdoor oper-
ations, particularly for workers handling metal containers
or equipment. To eliminate this hazard, weather condi-
tions should be monitored and work should be suspended
during electrical storms. An additional electrical hazard
involves capacitors that may retain a charge All such
items should be properly grounded before handling.
OSHA's standard 29 CFR Part 1910.137 describes cloth-
ing and equipment for protection against electrical
hazards.
Heat Stress
Heat stress is a major hazard, especially for workers
wearing protective clothing. The same protective
materials that shield the body from chemical exposure
also limit the dissipation of body heat and moisture. Per-
sonal protective clothing can therefore create a hazardous
condition. Depending on the ambient conditions and the
work being performed, heat stress can occur very rapidly
—within as little as 15 minutes. It can pose as great a
danger to worker health as chemical exposure In its early
stages, heat stress can cause rashes, cramps, discomfort
and drowsiness, resulting in impaired functional ability
that threatens the safety of both the individual and
coworkers. Continued heat stress can lead to heat stroke
and death. Avoiding overprotection, careful training and
frequent monitoring of personnel who wear protective
clothing, judicious scheduling of work and rest periods,
and frequent replacement of fluids can protect against
this hazard. For further information on heat stress, see
Chapter 8, Personal Protective Equipment.
Cold Exposure
Cold injury (frostbite and hypothermia) and impaired abil-
ity to work are dangers at low temperatures and when
the wind-chill factor is low. To guard against them: wear
appropriate clothing; have warm shelter readily available;
carefully schedule work and rest periods, and monitor
workers' physical conditions.
Noise
Work around large equipment often creates excessive
noise. The effects of noise can include:
• Workers being startled, annoyed, or distracted.
• Physical damage to the ear, pain, and temporary and/
or permanent hearing loss.
• Communication interference that may increase
potential hazards due to the inability to warn of dan-
ger and the proper safety precautions to be taken.
If employees are subjected to noise exceeding an 8-hour,
time-weighted average sound level of 90 dBA (decibels on
the A-weighted scale), feasible administrative or engineering
controls must be utilized. In addition, whenever employee
noise exposures equal or exceed an 8-hour, time-weighted
average sound level of 85 dBA, employers must adminis-
ter a continuing, effective hearing conservation program
as described in OSHA regulation 29 CFR Part 1910.95.
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3. Planning and Organization
Contents
Introduction 3-1
Organizational Structure 3-1
Work Plan 3-3
Site Safety Plan 3-5
Safety Meetings and Inspections 3-6
References 3-7
Introduction
Adequate planning is the first and the most critical ele-
ment of hazardous waste site activities. By anticipating
and taking steps to prevent potential hazards to health
and safety, work at a waste site can proceed with mini-
mum risk to workers and the public.
Three aspects of planning are discussed in this chapter:
developing an overall organizational structure for site
operations; establishing a comprehensive Work Plan that
considers each specific phase of the operation; and
developing and implementing a Site Safety and Health
Plan (hereinafter referred to as Site Safety Plan in accor-
dance with common usage). The organizational structure
should identify the personnel needed for the overall oper-
ation, establish the chain-of-command, and specify the
overall responsibilities of each employee. The Work Plan
should establish the objectives of site operations and the
logistics and resources required to achieve the goals. The
Site Safety Plan should determine the health and safety
concerns for each phase of the operation and define the
requirements and procedures for worker and public pro-
tection.
A fourth important aspect of planning is coordinating
with the existing response community. A national
response organization was established by a Congression-
ally mandated National Contingency Plan to implement
procedures for coordinating response to releases of haz-
ardous substances into the environment. This National
Contingency Plan establishes response teams composed
of representatives of federal agencies and state and local
governments [1]. A particularly important contact for haz-
ardous waste site activities is the EPA-designated official
responsible for coordinating federal activities related to
site cleanup.
Planning should be viewed as an ongoing process: the
cleanup activities and Site Safety Plan must be continu-
ously adapted to new site conditions and new informa-
tion. Thus, this chapter is intended to serve as a starting
point for planning the response activities at hazardous
waste sites.
Organizational Structure
An organizational structure that supports the overall
objectives of the project should be developed in the first
stage of planning. This structure should:
• Identify a leader who has the authority to direct all
activities.
• Identify the other personnel needed for the project,
and assign their general functions and responsi-
bilities.
• Show lines of authority, responsibility, and communi-
cation.
• Identify the interface with the response community.
As the project progresses, it may be necessary to modify
some organizational aspects of the project, such as per-
sonnel responsibilities and authorities, so that individual
tasks can be performed as efficiently and safely as pos-
sible. Any changes to the overall organizational structure
must be recorded in the appropriate parts of the Work or
Site Safety Plans that are developed for individual phases
or tasks and must be communicated to all parties
involved.
Figure 3-1 presents one example of an organizational
framework for a hazardous waste site response team. It
shows the lines of authority for 24 categories of offsite
and onsite personnel. The responsibilities and functions
of each category are described in Tables 3-1 through 3-4.
The onsite categories are divided into personnel that are
essential for a safe and efficient response, and optional
personnel that may be desirable in a large operation
where responsibilities can be delegated to a greater num-
ber of people. As-needed personnel are specialists that
are called upon for specific tasks, either off-site or on site.
This example is intended to illustrate the scope of respon -
sibilities and functions that must be covered. The person-
nel categories described can be used as a starting point
for designing an organizational structure appropriate to a
particular situation. For smaller investigative and response
efforts, single individuals may perform several of the
functions described.
Regardless of the size of the effort, all response teams
should include a Site Safety and Health Officer (here-
inafter referred to as Site Safety Officer in accordance
with common usage) responsible for implementing health
and safety requirements. The Site Safety Officer should
have ready access to other occupational health and
safety professionals, particularly an industrial hygienist.
Once an organizational system has been developed, all
individuals responsible for establishing and enforcing
health and safety requirements should be identified and
their respective authorities clearly explained to all mem-
bers of the response team.
One of the most critical elements in worker safety is the
attitude of all levels of project management. A strong and
visible commitment to worker safety must be present
from the beginning of a project. This initial attitude sets
the tone for the entire operation. The Site Safety Officer
and the Project Team Leader must have the clear support
of senior-level management for establishing, implement-
ing, and enforcing safety programs from the outset of the
project. The importance of management's attitude toward
safety throughout the project cannot be overemphasized;
site personnel are more likely to cooperate with safety
programs if they sense a genuine concern on the part of
management.
Several organizational factors are indicators of successful
worker safety programs. These factors include:
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3-2
Planning and Organization
Government Agency
Oversight
OFFSITE
Multidisciplinary
Advisors
Lead Organization
Senior-Level
Management
Medical Support
Project
Team Leader
LU
«
CO
Field Team
Leader
ONSITE
Command Post
Supervisor
Decontamination
Station Officers
Rescue Team
Work Party
•z.
o
• Scientific • Financial
Advisor Officer
Security
Officer
Record-
keeper
Logistics
Officer
Photographer
Public Information
Officer
OFFSITE
AND ONSITE
AS NEEDED
Site Safety and
Health Officer
• Bomb Squad Experts • Firefighters
• Communication
Personnel
• Environmental
Scientists
• Evacuation
Personnel
Hazardous
Chemical
Experts
Health Physicists
Industrial
Hygienists
Meteorologists
Public Safety
Officer
Toxicologists
Figure 3-1. Generalized Approach to Personnel Organization for Site Investigation and Response.
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Planning and Organization
3-3
• Strong management commitment to safety, as
defined by various actions reflecting management's
support and involvement in safety activities.
• Close contact and interaction among workers, super-
visors, and management enabling open communica-
tion on safety as well as other job-related matters.
• A high level of housekeeping, orderly workplace con-
ditions, and effective environmental quality control.
• Well-developed selection, job placement, and
advancement procedures plus other employee sup-
port services.
• Training practices emphasizing early indoctrination
and followup instruction in job safety procedures.
• Added features or variations in conventional safety
practices that enhance the effectiveness of those
practices.
• Effective disciplinary plan to encourage employees to
adhere to safety practices.
Overall, the most effective industrial safety programs are
successful in dealing with "people" variables. Open com-
munication among workers, supervisors, and manage-
ment concerning worksite safety is essential.
The effective management of response actions at hazard-
ous waste sites requires a commitment to the health and
safety of the general public as well as to the onsite per-
sonnel. Prevention and containment of contaminant
release into the surrounding community should be
addressed in the planning stages of a project. Not only
must the public be protected, they must also be made
aware of the health and safety program and have confi-
dence in it. To accomplish these goals, the Project Team
Leader, or Public Information Officer under the supervi-
sion of the Project Team Leader, should establish commu-
nity liaison well before any response action is begun, and
should be in continuous contact with community leaders.
Work Plan
To ensure a safe response, a Work Plan describing antici-
pated cleanup activities must be developed before begin-
ning onsite response actions. The Work Plan should be
periodically reexamined and updated as new information
about site conditions is obtained.
The following steps should be taken in formulating a com-
prehensive Work Plan:
• Review available information, including:
Site records.
Waste inventories.
Generator and transporter manifests.
Previous sampling and monitoring data.
Site photos.
State and local environmental and health agency
records.
• Define work objectives.
• Determine methods for accomplishing the objectives,
eg., sampling plan, inventory, disposal techniques.
• Determine personnel requirements.
• Determine the need for additional training of person-
nel. Evaluate their current knowledge/skill level
against the tasks they will perform and situations
they may encounter {see Chapter 4, Training).
Table 3-1. Offsite Personnel
TITLE
GENERAL DESCRIPTION
SPECIFIC RESPONSIBILITIES
Senior-Level Responsible for defining project objectives,
Management allocating resources, determining the chain-
of-command, and evaluating program
outcoma
• Provide the necessary facilities, equipment, and money.
• Provide adequate personnel and time resources to conduct
activities safely.
• Support the efforts of onsite management.
• Provide appropriate disciplinary action when unsafe acts or
practices occur.
Multi- Includes representatives from upper-level
Disciplinary management and onsite management, a field
Advisors team member, and experts in such fields as:
Chemistry Law
Engineering Medicine
Industrial hygiene Pharmacology
Information/public Physiology
relations Radiation health
physics
Toxicology
Provide advice on the design of the Work Plan and the Site Safety
Plan.
Medical
Support
Cpnsulting physicians.
Medical personnel at local hospitals and
clinics.
Ambulance personnel.
• Become familiar with the types of materials on site, the potential
for worker exposures, and recommend the medical program for the
site.
• Provide emergency treatment and decontamination procedures for
the specific type of exposures that may occur at the site. Obtain
special drugs, equipment, or supplies necessary to treat such
exposures.
• Provide emergency treatment procedures appropriate to the
hazards on site.
-------
3-4
Planning and Organization
Table 3-2. Onsite Essential Personnel
TITLE
GENERAL DESCRIPTION
SPECIFIC RESPONSIBILITIES
Project Team Reports to upper-level management. Has
Leader authority to direct response operations.
Assumes total control over site activities.
• Prepares and organizes the background review of the situation,
the Work Plan, the Site Safety Plan, and the field team.
• Obtains permission for site access and coordinates activities
with appropriate officials.
• Ensures that the Work Plan is completed and on schedule
• Briefs the field teams on their specific assignments.
• Uses the Site Safety and Health Officer to ensure that safety
and health requirements are met.
• Prepares the final report and support files on the response
activities.
• Serves as the liaison with public officials.
She Safety and
Health Officer
(hereinafter
referred to as
Site Safety
Officer in
accordance with
common usage)
Advises the Project Team Leader on all
aspects of health and safety on sita Rec-
ommends stopping work if any operation
threatens worker or public health or safety.
• Selects protective clothing and equipment.
• Periodically inspects protective clothing and equipment.
• Ensures that protective clothing and equipment are properly
stored and maintained.
• Controls entry and exit at the Access Control Points.
• Coordinates safety and health program activities with the
Scientific Advisor.
• Confirms each team member's suitability for work based on a
physician's recommendation.
• Monitors the work parties for signs of stress, such as cold
exposure, heat stress, and fatigue.
• Monitors onsite hazards and conditions.
• Participates in the preparation of and implements the Site Safety
Plan.
• Conducts periodic inspections to determine if the Site Safety
Plan is being followed.
• Enforces the "buddy" system.
• Knows emergency procedures, evacuation routes, and the
telephone numbers of the ambulance, local hospital, poison
control center, fire department, and police department.
• Notifies, when necessary, local public emergency officials.
• Coordinates emergency medical cara
Field Team May be the same person as the Project Team
Leader Leader and may be a member of the work
party. Responsible for field team operations
and safety.
• Manages field operations.
• Executes the Work Plan and schedula
• Enforces safety procedures.
• Coordinates with the Site Safety Officer in determining
protection level.
• Enforces site control.
• Documents field activities and sample collection.
• Serves as a liaison with public officials.
Command Post May be the same person as the Field Team
Supervisor Leader. Responsible for communications and
emergency assistance
• Notifies emergency response personnel by telephone or radio in
the event of an emergency.
• Assists the Site Safety Officer in a rescue, if necessary.
• Maintains a log of communication and site activities.
• Assists other field team members in the clean areas, as needed.
• Maintains line-of-sight and communication contact with the
work parties via walkie-talkies, signal horns, or other means.
Decontamina-
tion Station
Officer(s)
Responsible for decontamination proce-
dures, equipment, and supplies.
Sets up decontamination lines and the decontamination
solutions appropriate for the type of chemical contamination on
sita
Controls the decontamination of all equipment, personnel, and
samples from the contaminated areas.
Assists in the disposal of contaminated clothing and materials.
Ensures that all required equipment is available
Advises medical personnel of potential exposures and
consequences.
Rescue Team Used primarily on large sites with multiple
work parties in the contaminated area.
Stands by, partially dressed in protective gear, near hazardous
work areas.
Rescues any worker whose health or safety is endangered.
Work Party Depending on the size of the field team, any
or all of the field team may be in the Work
Patty, but the Work Party should consist of
at least two people
• Safely completes the onsite tasks required to fulfill the Work
Plan.
• Complies with Site Safety Plan.
• Notifies Site Safety Officer or supervisor of unsafe conditions.
-------
Planning and Organization 3-5
Table 3-3. Onsite Optional Personnel
TITLE GENERAL DESCRIPTION
Scientific Advisor Guides the Project Team Leader in
scientific matters.
Logistics Officer
Photographer
Financial/Contracting Officer
Public Information Officer
Security Officer
Recordkeeper
SPECIFIC RESPONSIBILITIES
• Provides advice for:
Field monitoring Scientific studies
Sample collection Data interpretation
Sample analysis Remedial plans
• Plans and mobilizes the facilities, materials, and
personnel required for the response.
• Photographs site conditions.
• Archives photographs.
• Provides financial and contractual support.
• Releases information to the news media and the public
concerning site activities.
• Manages site security.
• Maintains the official records of site activities.
• Determine equipment requirements. Evaluate the
need for special equipment or services, such as drill-
ing equipment or heavy equipment and operators.
Preparation of the Work Plan requires a multidisciplinary
approach, and may therefore require input from all levels
of onsite and offsite management. Consultants may also
be useful in developing sections of the Work Plan; for
example, chemists, occupational health and safety profes-
sionals, and statisticians may be needed to develop the
sampling plan.
Site Safety Plan
A Site Safety Plan, which establishes policies and proce-
dures to protect workers and the public from the potential
hazards posed by a hazardous waste site, must be devel-
oped before site activities proceed. The Site Safety Plan
must provide measures to minimize accidents and injuries
that may occur during normal daily activities or during
adverse conditions such as hot or cold weather. This sec-
tion describes the planning process for health and safety
during normal site operations, i.a, non-emergency situa-
tions. Chapter 12 describes planning and response to site
emergencies.
Development of a written Site Safety Plan helps ensure
that all safety aspects of site operations are thoroughly
examined prior to commencing field work. The Site
Safety Plan should be modified as needed for every stage
of site activity.
Because planning requires information, planning and site
characterization should be coordinated. An initial Site
Safety Plan should be developed so that the preliminary
site assessment can proceed in a safe manner. The infor-
mation from this assessment can then be used to refine
the Site Safety Plan so that further site activities can pro-
ceed safely. Plans should be revised whenever new infor-
mation about site hazards is obtained.
Development of a Site Safety Plan should involve both the
offsite and onsite management and be reviewed by
occupational and industrial health and safety experts,
physicians, chemists, or other appropriate personnel.
At a minimum, the plan should:
• Name key personnel and alternates responsible for
site safety (see Tables 3-1 through 3-4).
• Describe the risks associated with each operation
conducted (see Chapter 6, Site Characterization).
• Confirm that personnel are adequately trained to
perform their job responsibilities and to handle the
specific hazardous situations they may encounter
(see Chapter 4, Training).
• Describe the protective clothing and equipment to
be worn by personnel during various site opera-
tions (see Chapter 8, Personal Protective
Equipment).
• Describe any site-specific medical surveillance
requirements (see Chapter 5, Medical Program).
• Describe the program for periodic air monitoring,
personnel monitoring, and environmental sam-
pling, if needed (see Chapter 6, Site Characteriza-
tion, and Chapter 11, Handling Drums and Other
Containers).
• Describe the actions to be taken to mitigate exist-
ing hazards (eg., containment of contaminated
materials) to make the work environment less haz-
ardous.
• Define site control measures and include a site
map (see Chapter 9, Site Control).
• Establish decontamination procedures for personnel
and equipment (see Chapter 10, Decontamination).
• Set forth the site's Standard Operating Procedures
(SOPs). SOPs are those activities that can be stan-
dardized (such as decontamination and respirator fit
testing), and where a checklist can be used. These
procedures should be:
Prepared in advance.
Based on the best available information, opera-
tional principles, and technical guidance
Field-tested by qualified health and safety profes-
sionals, and revised as appropriate.
Appropriate to the types of risk at that site
Formulated to be easy to understand and practice
-------
3-6
Planning and Organization
Table 3-4. As-Needed Personnel
TITLE
GENERAL DESCRIPTION
SPECIFIC RESPONSIBILITIES
Bomb Squad Explosion
Experts
Advise on methods of handling explosive materials.
Assist in safely detonating or disposing of explosive
materials.
Communication Personnel
Civil Defense organizations; local radio
and television stations.
Local emergency service networks.
Provide communication to the public in the event of an
emergency.
Provide communication links for mutual aid.
Environmental Scientists
Consultants from industry, government,
universities, or other groups.
• Predict the movement of released hazardous materials
through the atmospheric, geologic, and hydrologic
environment.
• Assess the effect of this movement on air, groundwater,
and surface water quality.
• Predict the exposure of people and the ecosystem to the
materials.
Evacuation Personnel
Firefighters
Hazardous Chemical
Experts
Federal, state, and local public safety
organizations.
Consultants from industry, government,
universities, or other groups.
• Help plan for public evacuation.
• Mobilize transit equipment.
• Assist in public evacuation.
• Respond to fires that occur on site.
• Stand by for response to potential fires.
• Perform rescue.
• Advise on the properties of the materials on site.
• Advise. on contaminant control methods.
• Advise on the danaers of chemical mixtures that mav
result from site activities.
Provide immediate advice to those at the scene of a
chemical-related emergency.
Health Physicists
• Evaluate radiation health hazards and recommend
appropriate action.
Industrial Hygienists
Conduct health hazard assessments.
Advise on adequate health protection.
Conduct monitoring tests to determine worker exposures
to hazardous substances.
Meteorologists
Provide meteorological information.
Public Safety Personnel
The County Sheriff, industrial security
forces, National Guard, police, etc.
Control access to the sita
Toxicologists
Advise on toxicological properties and health effects of
substances on site.
Provide recommendations on protection of worker health.
Provided in writing to all site personnel, who
should be briefed on their use.
Included in training programs for site personnel.
• Set forth a Contingency Plan for safe and effective
response to emergencies.
Appendix B provides a generic Site Safety Plan that can
be adapted for hazardous waste site cleanup operations.
The generic plan should be used as a guide, not a stan-
dard, for designing a Site Safety Plan.
Safety Meetings and Inspections
To ensure that the Site Safety Plan is being followed, the
Site Safety Officer should conduct a safety meeting prior
to initiating any site activity and before and after each
work day. The purpose of these safety meetings is to:
• Describe the assigned tasks and their potential
hazards.
• Coordinate activities.
• Identify methods and precautions to prevent injuries.
• Plan for emergencies.
• Describe any changes in the Site Safety Plan.
• Get worker feedback on conditions affecting safety
and health.
• Get worker feedback on how well the Site Safety
Plan is working.
The Site Safety Officer should also conduct frequent
inspections of site conditions, facilities, equipment, and
activities to determine whether the Site Safety Plan is
adequate and being followed.
At a hazardous waste site, risks to workers can change
quickly and dramatically when there are changes in:
• Work and other site activities.
• State of degradation of containers and containment
structures.
-------
Planning and Organization
3-7
• State of equipment maintenance.
• Weather conditions.
In order to make safety inspections effective, the follow-
ing guidelines should be observed:
• Develop a checklist for each site, listing the items
that should be inspected.
• Review the results of these inspections with supervi-
sors and workers.
• Reinspect any identified problems to ensure that they
have been corrected.
• Document all inspections and subsequent followup
actions. Retain these records until site activities are
completed and as as long as required by regulatory
agencies.
The minimum frequency at which inspections should
occur varies with the characteristics of the site and the
equipment used on site. Factors that need to be consid-
ered are:
• The severity of risk on site.
• Regulatory requirements.
• Operation and maintenance requirements.
• The expected effective lifetime of clothing, equip-
ment, vehicles, and other items.
• Recommendations based on professional judgment,
laboratory test results, and field experience.
References
1. National Oil and Hazardous Substances Pollution Con-
tingency Plan, 40 CFR Part 300.
-------
4. Training
Contents
Introduction 4-1
Training Programs 4-1
Record of Training 4-3
Introduction
Anyone who enters a hazardous waste site must recog-
nize and understand the potential hazards to health and
safety associated with the cleanup of that site. Personnel
actively involved in cleanup must be thoroughly familiar
with programs and procedures contained in the Site
Safety Plan (see Chapter 3, Planning and Organization)
and must be trained to work safely in contaminated areas.
Visitors to a site must receive adequate training on hazard
recognition and on the site's Standard Operating Proce-
dures to enable them to conduct their visit safely.
The objectives of training programs for employees
involved in hazardous waste site activities are:
• To make workers aware of the potential hazards
they may encounter.
• To provide the knowledge and skills necessary to
perform the work with minimal risk to worker
health and safety.
• To make workers aware of the purpose and limita-
tions of safety equipment.
• To ensure that workers can safely avoid or escape
from emergencies.
The level of training provided should be consistent with
the worker's job function and responsibilities. The training
program should involve both classroom instruction in a
wide range of health and safety topics and "hands-on"
practice. Hands-on instruction should consist of drills in
the field that simulate site activities and conditions. Any
training program for work around hazardous substances
should also incorporate onsite experience under the direct
supervision of trained, experienced personnel.
All training information should be presented in clear, con-
cise language. Particularly important information, such as
the Standard Operating Procedures, should be provided in
writing. A variety of teaching aids (i.e., films, tapes, slides,
etc.) should be used, and lecture sessions should be inter-
spersed with class participation and hands-on training. All
employees should also complete refresher training, at
least annually, to reemphasize the initial training and to
update workers on any new policies or procedures.
Training Programs
Employees should not engage in field activities until they
have been trained to a level commensurate with their job
function and responsibilities and with the degree of antic-
ipated hazards. Specific recommendations for the areas
to be covered in training sessions are given in Table 4-1.
The training program should involve field drills that simu-
late emergency situations. Here workers wearing Level A
personal protective equipment repair a leaking pipe as
part of a training exercise.
General site workers, such as equipment operators,
general laborers, technicians, and other supervised per-
sonnel, should attend training sessions that apply to their
individual jobs and responsibilities, as well as training ses-
sions that provide an overview of the site hazards and the
means of controlling those hazards. Their training should
include classroom instruction in the following subject
areas, depending on their individual jobs:
• Site Safety Plan.
• Safe work practices.
• Nature of anticipated hazards.
• Handling emergencies and self-rescue.
• Rules and regulations for vehicle use.
• Safe use of field equipment.
• Handling, storage, and transportation of hazardous
materials.
• Employee rights and responsibilities.
• Use, care, and limitations of personal protective cloth-
ing and equipment (see Training section of Chapter 8).
• Safe sampling techniques.
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4-2
Training
Table 4-1. Recommended
TRAINING TOPIC
Biology, Chemistry, and
Physics of Hazardous
Materials
Toxicology
Industrial Hygiene
Rights and Responsibilities
of Workers Under OSHA
Monitoring Equipment
Hazard Evaluation
Site Safety Plan
Standard Operating
Procedures (SOPs)
Engineering Controls
Personal Protective Cloth-
ing and Equipment (PPE)
Medical Program
Decontamination
Legal and Regulatory
Aspects
Emergencies
Training by Job Category^
GENERAL
SITE
EMPHASIS OF TRAINING WORKER
Chemical and physical properties; chemical R
reactions; chemical compatibilities.
Dosage, routes of exposure, toxic effects, R
immediately dangerous to life or health (IDLH)
values, permissible exposure limits (PELs), recom-
mended exposure limits (RELs), threshold limit
values (TLVs).
Selection and monitoring of personal protective
clothing and equipment.
Calculation of doses and exposure levels; evalua-
tion of hazards; selection of worker health and
safety protective measures.
Applicable provisions of Title 29 of the Code of R
Federal Regulations (the OSH Act).
Functions, capabilities, selection, use, limitations, R
and maintenanca
Techniques of sampling and assessment.
Evaluation of field and lab results.
Risk assessment.
Safe practices, safety briefings and meetings, R
Standard Operating Procedures, site safety map.
Hands-on practice. R
Development and compliance.
The use of barriers, isolation, and distance to R
minimize hazards.
Assignment, sizing, fit-testing, maintenance, use, R
limitations, and hands-on training.
Selection of PPE.
Ergonomics.
Medical monitoring, first aid, stress recognition. R
Advanced first aid, cardiopulmonary resuscitation O
(CPR); emergency drills.
Design, planning, and implementation.
Hands-on training using simulated field R
conditions.
Design and maintenanca R
Applicable safety and health regulations (OSHA, O
EPA, etc.)
Emergency help and self-rescue; emergency R
drills.
Response to emergencies; follow-up investigation
and documentation.
ONSITE
MANAGE-
MENT AND
SUPERVISORS
R
R
R
R
R
R
R
R
O
R
R
R
R
R
0
R
R
R
R
R
R
R
HEALTH
AND
SAFETY
STAFF VISITORS
R
R
R
R
R
R
R
R
R
R R
R
R
R
R R
R
R
R
R
R
R
R
R
R
R
aR = Recommended.
O = Optional.
-------
Training 4-3
In addition to classroom instruction, general site workers
should engage in actual field activities under the direct
supervision of a trained, experienced supervisor.
Some general site workers who may be exposed to
unique hazards or who may occasionally supervise others
should receive additional training in the following subject
areas:
• Site surveillance.
• Site Safety Plan development.
• Use and decontamination of fully encapsulating
personal protective clothing and equipment.
• Use of instruments to measure explosivity, radio-
activity, etc.
• Safe use of specialized equipment.
• Topics specific to identified site activities.
Onsite management and supervisors, such as Project
Team Leaders, who are responsible for directing others,
should receive the same training as the general site
workers for whom they are responsible, as well as addi-
tional training to enhance their ability to provide guidance
and make informed decisions. This additional training
should include:
• Management of hazardous waste site cleanup
operations.
• Management of the site work zones (see Chapter
9, Site Control].
• How to communicate with the press and local
community.
Health and safety staff with specific responsibilities for
health and safety guidance on site should be familiar with
the training provided to general site workers and their
supervisors, and should receive advanced training in
health and safety issues, policies, and techniques.
Visitors to the site (including elected and appointed offi-
cials, reporters, senior-level management, and other
interested parties) must also receive a briefing on safety.
These visitors should not be permitted in the Exclusion
Zone (see Chapter 9, Site Control] unless they have been
trained, fit-tested, and medically approved for respirator
use. All other visitors should not enter the Exclusion
Zone; rather, they should observe site conditions from the
clean area, e.g., using binoculars.
Record of Training
A record of training should be maintained in each
employee's personnel file to confirm that every person
assigned to a task has had adequate training for that
task, and that every employee's training is up-to-date.
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5. Medical Program
Contents
Introduction 5-1
Developing a Program 5-1
Pre-Employment Screening 5-5
Determination of Fitness for Duty 5-5
Baseline Data for Future Exposures 5-6
Sample Pre-Employment Examination 5-7
Periodic Medical Examinations 5-7
Periodic Screening 5-7
Sample Periodic Medical Examination 5-8
Termination Examination 5-8
Emergency Treatment 5-8
Non-Emergency Treatment 5-9
Medical Records 5-9
Program Review 5-10
References 5-10
Introduction
Workers handling hazardous wastes can experience high
levels of stress. Their daily tasks may expose them to
toxic chemicals, safety hazards, biologic hazards, and
radiation. They may develop heat stress while wearing
protective equipment or working under temperature
extremes, or face life-threatening emergencies such as
explosions and fires. Therefore, a medical program is
essential to assess and monitor workers' health and fit-
ness both prior to employment and during the course of
work; to provide emergency and other treatment as
needed; and to keep accurate records for future reference.
In addition, OSHA recommends a medical evaluation for
employees required to wear a respirator (29 CFR Part
1910.134[b][10]), and certain OSHA standards include
specific medical requirements (eg., 29 CFR Part 1910.95
and 29 CFR Parts 1910.1001 through 1910.1045). Informa-
tion from a site medical program may also be used to
conduct future epidemiological studies; to adjudicate
claims; to provide evidence in litigation; and to report
workers' medical conditions to federal, state, and local
agencies, as required by law.
This chapter presents general guidelines for designing a
medical program for personnel at hazardous waste sites.
It includes information and sample protocols for pre-
employment screening and periodic medical examina-
tions, guidelines for emergency and non-emergency treat-
ment, and recommendations for program recordkeeping
and review. In addition, it supplies a table of some com-
mon chemical toxicants found at hazardous waste sites
with recommended medical monitoring procedures.
The recommendations in this chapter assume that
workers will have adequate protection from exposures
through administrative and engineering controls, and
appropriate personal protective equipment and decon-
tamination procedures, as described elsewhere in this
manual. Medical surveillance should be used to comple-
ment other controls.
Developing a Program
A medical program should be developed for each site
based on the specific needs, location, and potential
exposures of employees at the site. The program should
be designed by an experienced occupational health physi-
cian or other qualified occupational health consultant in
conjunction with the Site Safety Officer. The director of a
site medical program should be a physician who is board-
certified in occupational medicine or a medical doctor
who has had extensive experience managing occupa-
tional health services. A director and/or examining physi-
cian with such qualifications may be difficult to find, due
to the shortage of doctors trained in occupational medi-
cine in remote geographic areas where many hazardous
waste sites are located. If an occupational health physi-
cian is not available, the site medical program may be
managed, and relevant examinations performed, by a
local physician with assistance from an occupational
medicine consultant. These functions may also be per-
formed by a qualified Registered Nurse, preferably an
Occupational Health Nurse, under the direction of a suit-
ably qualified physician who has responsibility for the
program.1
All medical test analyses should be performed by a
laboratory that has demonstrated satisfactory perfor-
mance in an established interlaboratory testing program
[1]. The clinical or diagnostic laboratory to which samples
are sent should meet either (1) minimum requirements
under the Clinical Laboratories Improvement Act of 1967
(42 CFR Part 74 Subpart M Section 263[a]), or (2) the
conditions for coverage under Medicara These programs
are administered by the Health Care Financing Adminis-
tration (HCFA), U.S. Department of Health and Human
Services (DHHS).
A site medical program should provide the following
components:
• Surveillance:
Pre-employment screening.
Periodic medical examinations (and followup exami-
nations when appropriate).
Termination examination.
• Treatment:
Emergency
Non-emergency (on a case-by-case basis)
• Recordkeeping.
• Program review.
Table 5-1 outlines a recommended medical program;
screening and examination protocols are described in the
following sections. These recommendations are based on
known health risks for hazardous waste workers, a review
of available data on their exposures, and an assessment
of several established medical programs. Because condi-
tions and hazards vary considerably at each site, only
general guidelines are given.
The effectiveness of a medical program depends on
active worker involvement. In addition, management
should have a firm commitment to worker health and
1 Certified, state-licensed (where required) Physician's Assistants
may also perform these examinations if a physician is available
on the premises.
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5-2
Medical Program
Table 5-1. Recommended Medical Program
COMPONENT
RECOMMENDED
OPTIONAL
Pre-Employment
Screening
Medical history.
Occupational history.
Physical examination.
Determination of fitness to work wearing
protective equipment.
Baseline monitoring for specific exposures.
• Freezing pre-employment serum specimen for later
testing (limited to specific situations, see Baseline
Data for Future Exposures in this chapter).
Periodic Medical
Examinations
Yearly update of medical and occupational history;
yearly physical examination; testing based on
(1) examination results, (2) exposures, and (3) job
class and task.
More frequent testing based on specific exposures.
Yearly testing with routine medical tests.
Emergency
Treatment
• Provide emergency first aid on site.
• Develop liaison with local hospital and medical
specialists.
• Arrange for decontamination of victims.
• Arrange in advance for transport of victims.
• Transfer medical records; give details of incident
and medical history to next care provider.
Non-Emergency
Treatment
Develop mechanism for non-emergency health
care.
Recordkeeping and
Review
• Maintain and provide access to medical records in
accordance with OSHA and state regulations.
• Report and record occupational injuries and
illnesses.
• Review Site Safety Plan regularly to determine if
additional testing is needed.
• Review program periodically. Focus on current site
hazards, exposures, and industrial hygiene
standards.
safety, and is encouraged to express this commitment not
only by medical surveillance and treatment, but also
through management directives and informal encourage-
ment of employees to maintain good health through exer-
cise, proper diet, and avoidance of tobacco, alcohol abuse
and drug abuse. In particular, management should:
• Urge prospective employees to provide a complete
and detailed occupational and medical history.
• Assure employees of confidentiality.
• Require workers to report any suspected exposures,
regardless of degree.
• Require workers to bring any unusual physical or psy-
chological conditions to the physician's attention.
Employee training should emphasize that vague dis-
turbances or apparently minor complaints (such as
skin irritation or headaches) may be important.
When developing an individual program, site conditions
must be considered and the monitoring needs of each
worker should be determined based on the worker's med-
ical and occupational history, as well as current and
potential exposures on site. The routine job tasks of each
worker should be considered. For instance, a heavy equip-
ment operator exposed to significant noise levels would
require a different monitoring protocol from a field sample
collector with minimal noise exposure. Likewise, an
administrator may only need a pre-employment screening
for ability to wear personal protective equipment—if this
is an occasional requirement—rather than a more compre-
hensive program.
The potential exposures that may occur at a site must
also be considered. While it is often impossible to identify
every toxic substance that exists at each hazardous
waste site, certain types of hazardous substances or
chemicals are more likely to be present than others. Some
of these are:
• Aromatic hydrocarbons.
• Asbestos (or asbestiform particles).
• Dioxin.
• Halogenated aliphatic hydrocarbons.
• Heavy metals.
• Herbicides.
• Organochlorine insecticides.
• Organophosphate and carbamate insecticides.
• Polychlorinated biphenyls (PCBs).
Table 5-2 lists these groups, with representative com-
pounds, uses, health effects, and available medical
monitoring procedures.
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Medical Program
5-3
Table 5-2. Common Chemical Toxicants Found at Hazardous Waste Sites, Their Health Effects and Medical Monitoring
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
Aromatic
Hydrocarbons
Asbestos (or
asbestiform
particles)
Dioxin (see
Herbicides)
Halogenated
Aliphatic
Hydrocarbons
COMPOUNDS
Benzene
Ethyl benzene
Toluene
Xylene
Carbon
tetrachloride
Chloroform
Ethyl bromide
Ethyl chloride
Ethylene dibromide
Ethylene dichloride
Methyl chloride
Methyl chloroform
Methylene chloride
Tetrachloroethane
Tetrachloroethylene
(perchloroethyiene)
Trichloroethylene
Vinyl chloride
USES
Commercial
solvents and
intermediates for
synthesis in the
chemical and
pharmaceutical
industries.
A variety of
industrial uses,
including:
Building
Construction
Cement work
Insulation
Fi reproofing
Pipes and
ducts for
water, air, and
chemicals
Automobile
brake pads
and linings
Commercial
solvents and
intermediates in
organic
synthesis.
TARGET ORGANS POTENTIAL HEALTH EFFECTS
Blood All cause:
Bone marrow CNS8 depression: decreased
CNga alertness, headache, sleepi-
ness, loss of consciousness.
Eyes
Defatting dermatitis.
Respiratory
system Benzene suppresses bone-
marrow function, causing
Skin blood changes. Chronic
Liver exposure can cause leukemia.
Kidney Note: Because other aromatic
hydrocarbons may be contami-
nated with benzene during dis-
tillation, benzene-related health
effects should be considered
when exposure to any of these
agents is suspected.
Lungs Chronic effects:
Gastrointestinal Lung cancer
system Mesothelioma
Asbestosis
Gastrointestinal malignancies
Asbestos exposure coupled
with cigarette smoking has
been shown to have a
synergistic effect in the
development of lung cancer.
CNSa All cause:
Kidney CNSa depression: decreased
Liver alertness, headaches,
. sleepiness, loss of
°*'n consciousness.
Kidney changes: decreased
urine flow, swelling
(especially around eyes).
anemia.
Liver changes: fatigue,
malaise, dark urine, liver
enlargement, jaundica
Vinyl chloride is a known
carcinogen; several others in
this group are potential
carcinogens.
MEDICAL MONITORING
Occupational/general
medical history
emphasizing prior
exposure to these or
other toxic agents.
Medical examination
with focus on liver, kid-
ney, nervous system,
and skin.
Laboratory testing:
f*Df*h
CBCD
Platelet count
Measurement of kidney
and liver function.
History and physical
examination should
focus on the lungs and
gastrointestinal system.
Laboratory tests should
include a stool test for
occult blood evaluation
as a check for possible
hidden gastrointestinal
malignancy.
A high quality chest
X-ray and pulmonary
function test may help
to identify long-term
changes associated
with asbestos diseases;
however, early identifi-
cation of low-dose
exposure is unlikely.
Occupational/general
medical history
emphasizing prior
exposure to these or
other toxic agents.
Medical examination
with focus on liver.
kidney, nervous system.
and skin.
Laboratory testing for
liver and kidney
function; carboxyhemo-
globin where relevant.
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5-4
Medical Program
Table 5-2. (cont.)
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
COMPOUNDS
USES
TARGET ORGANS POTENTIAL HEALTH EFFECTS MEDICAL MONITORING
Heavy Metal*
Arsenic
Beryllium
Cadmium
Chromium
Lead
Mercury
Wide variety of
industrial and
commercial
uses.
Multiple organs
and systems
including:
Blood
Cardiopulmonary
Gastrointestinal
Kidney
Liver
Lung
CNS"
Skin
All are toxic to the kidneys.
Each heavy metal has its own
characteristic symptom cluster.
For example, lead causes
decreased mental ability,
weakness (especially hands),
headache, abdominal cramps,
diarrhea, and anemia. Lead can
also affect the blood-forming
mechanism, kidneys, and the
peripheral nervous system.
Long-term effects0 also vary.
Lead toxicity can cause perma-
nent kidney and brain damage;
cadmium can cause kidney or
lung diseasa Chromium, beryl-
lium, arsenic, and cadmium
have been implicated as human
carcinogens.
History-taking and
physical exam: search
for symptom clusters
associated with specific
metal exposure, ag., for
lead look for neurologi-
cal deficit, anemia, and
gastrointestinal
symptoms.
Laboratory testing:
Measurements of
metallic content in
blood, urine, and tis-
sues (ag., blood lead
level; urine screen for
arsenic, mercury,
chromium, and
cadmium).
Measurement of
kidney function, and
liver function where
relevant.
Chest X-ray or
pulmonary function
testing where relevant.
Herbicides Chlorophenoxy Vegetation
compounds: control.
2,4-dichloro-
phenoxyacetic
acid (2,4-D)
2,4,5-trichloro-
phenoxyacetic
acid (2,4,5-T)
Dioxin (tetrachlora-
Kidney
Liver
CNS»
Skin
Chlorophenoxy compounds can
cause chloracne, weakness or
numbness of the arms and
legs, and may result in
long-term nerve damaga
Dioxin causes chloracne and
may aggravate pre-existing liver
and kidney diseases.
History and physical
exam should focus on
the skin and nervous
system.
Laboratory tests
include:
Measurement of liver
and kidney function.
where relevant.
dibenzo-p-dioxin,
TCDD), which
occurs as a trace
contaminant in
these compounds,
poses the most
serious health risk.
Urinalysis.
Organochlorine
Insecticides
Chlorinated
ethanes:
DDT
Cyclodienes:
Alririn
mui ii i
Chlordane
Dieldrin
Endrin
Pest control. Kidney
Liver
CNSa
All cause acute symptoms of
apprehension, irritability, dizzi-
ness, disturbed equilibrium.
tremor, and convulsions.
Cyclodienes may cause
convulsions without any other
initial symptoms.
Chlorocyclohexanes can cause
History and physical
exam should focus on
the nervous system.
Laboratory tests
include:
Measurement of
kidney and liver
function.
CWerocyckrhexanes:
Lindane
anemia. Cyclodienes and
chlorocyclohexanes cause liver
toxicity and can cause
permanent kidney damaga
CBCb for exposure to
chlorocyclohexanes.
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Medical Program
5-5
Table 5-2. (cont.)
HAZARDOUS
SUBSTANCE
OR CHEMICAL
GROUP
Organo-
phosphate and
Carbamate
Insecticides
Polychlorinated
Biphenyls
(PCBs)
COMPOUNDS USES
Organophosphate: Pest control.
Diazinon
Dichlorovos
Dimethoate
Trichlorfon
Malathion
Methyl parathion
Parathion
Carbamate:
Aldicarb
Baygon
Zectran
Wide variety of
industrial uses.
TARGET ORGANS
CNS"
Liver
Kidney
Liver
CNS8
(speculative)
Respiratory
system (speculative)
Skin
POTENTIAL HEALTH EFFECTS
All cause a chain of internal
reactions leading to neuro-
muscular blockage. Depending
on the extent of poisoning.
acute symptoms range from
headaches, fatigue, dizziness,
increased salivation and crying,
profuse sweating, nausea,
vomiting, cramps, and diarrhea
to tightness in the chest,
muscle twitching, and slowing
of the heartbeat. Severe cases
may result in rapid onset of
unconsciousness and seizures.
A delayed effect may be weak-
ness and numbness in the feet
and hands. Long-term, perma-
nent nerve damage is possibla
Various skin ailments, including
chloracne; may cause liver
toxicity; carcinogenic to
animals.
MEDICAL MONITORING
Physical exam should
focus on the nervous
system.
Laboratory tests should
include:
RBCd cholinesterase
levels for recent
exposure (plasma
cholinesterase for
acute exposures).
Measurement of
delayed neurotoxicity
and other effects.
Physical exam should
focus on the skin and
liver.
Laboratory tests
include:
Serum PCB levels.
Triglycerides and.
cholesterol.
Measurement of liver
function.
aCNS = Central nervous system.
bCBC = Complete blood count.
°Long-term effects generally manifest in 10 to 30 years.
dRBC = Red blood count.
In compiling a testing protocol, bear in mind that standard
occupational medical tests were developed in factories
and other enclosed industrial environments, and were
based on the presence of specific identifiable toxic
chemicals and the possibility of a significant degree of
exposure. Some of these tests may not be totally appro-
priate for hazardous waste sites, since available data sug-
gest that site workers have low-level exposures to many
chemicals concurrently, plus brief high-level exposure to
some chemicals [2]. In addition, most testing recommen-
dations, even those for specific toxic substances, have
not been critically evaluated for efficacy.
Another important factor to consider is that risk can vary,
not only with the type, amount and duration of exposure,
but also with individual factors such as age, sex, weight,
stress, diet, susceptibility to allergic-type reactions, medi-
cations taken, and offsite exposures (ag., in hobbies such
as furniture refmishing and automotive body worR).
Pro-Employment Screening
Pre-employment screening has two major functions:
(1) determination of an individual's fitness for duty,
including the ability to work while wearing protective
equipment, and (2) provision of baseline data for compari-
son with future medical data. These functions are dis-
cussed below. In addition, a sample pre-employment
examination is described.
Determination of Fitness for Duty
Workers at hazardous waste sites are often required to
perform strenuous tasks (ag., moving 55-gallon drums)
and wear personal protective equipment, such as respira-
tors and protective clothing, that may cause heat stress
and other problems (see Chapter 8 for details). To ensure
that prospective employees are able to meet work require-
ments, the pre-employment screening should focus on
the following areas:
Occupational and Medical History
• Make sure the worker fills out an occupational and
medical history questionnaire. Review the question-
naire before seeing the worker. In the examining
room, discuss the questionnaire with the worker,
paying special attention to prior occupational
exposures to chemical and physical hazards.
• Review past illnesses and chronic diseases, partic-
ularly atopic diseases such as eczema and
asthma, lung diseases, and cardiovascular diseasa
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5-6
Medical Program
• Review symptoms, especially shortness of breath
or labored breathing on exertion, other chronic
respiratory symptoms, chest pain, high blood pres-
sure, and heat intolerance
• Identify individuals who are vulnerable to particu-
lar substances (ag., someone with a history of
severe asthmatic reaction to a specific chemical).
• Record relevant lifestyle habits (ag., cigarette
smoking, alcohol and drug use) and hobbies.
Physical Examination
• Conduct a comprehensive physical examination of
all body organs, focussing on the pulmonary,
cardiovascular, and musculoskeletal systems.
• Note conditions that could increase susceptibility
to heat stroke, such as obesity and lack of physi-
cal exercise.
• Note conditions that could affect respirator use,
such as missing or arthritic fingers, facial scars,
dentures, poor eyesight; or perforated ear drums.
Ability to Work While Wearing Protective Equipment [3]
• Disqualify individuals who are clearly unable to
perform based on the medical history and physical
exam (ag., those with severe lung disease, heart
disease, or back or orthopedic problems).
• Note limitations concerning the worker's ability to
use protective equipment (ag., individuals who
must wear contact lenses cannot wear full-
facepiece respirators).
• Provide additional testing (ag., chest X-ray, pulmo-
nary function testing, electrocardiogram) for abil-
ity to wear protective equipment where necessary.
• Base the determination on the individual worker's
profile (ag., medical history and physical exam,
age, previous exposures and testing).
• Make a written assessment of the worker's capac-
ity to perform while wearing a respirator, if wear-
ing a respirator is a job requirement. Note that the
Occupational Safety and Health Administration
(OSHA) respirator standard (29 CFR Part 1910.134)
states that no employee should be assigned to a
task that requires the use of a respirator unless it
has been determined that the person is physically
able to perform under such conditions.
Baseline Data for Future Exposures
Pre-employment screening can be used to establish base-
line data to subsequently verify the efficacy of protective
measures and to later determine if exposures have
adversely affected the worker. Baseline testing may
include both medical screening tests and biologic moni-
toring tests. The latter (ag., blood lead level) may be use-
ful for ascertaining pre-exposure levels of specific
substances to which the worker may be exposed and for
which reliable tests are available. Given the problem in
predicting significant exposures for these workers, there
are no clear guidelines for prescribing specific tests. The
following approach identifies the types of tests that may
be indicated:
• A battery of tests based on the worker's past
occupational and medical history and an assessment
of significant potential exposures. See Table 5-3 for
examples of tests frequently performed by occupa-
tional physicians.
• Standard established testing for specific toxicants in.
situations where workers may receive significant
exposures to these agents. For example, long-term
exposure during cleanup of a polychlorinated
biphenyls (PCB) waste facility can be monitored with
pre-employment and periodic serum PCB testing [4].
Standard procedures are available for determining
levels of other substances, ag., lead, cadmium,
arsenic, and organophosphate pesticides.
• Where applicable, pre-employment blood specimens
and serum frozen for later testing. (PCBs and some
pesticides are examples of agents amenable to such
monitoring.)
Table 5-3. Tests Frequently Performed by Occupational Physicians
FUNCTION
Liver:
General
Obstruction
Cell injury
Kidney:
General
Multiple Systems
and Organs
TEST
Blood tests
Enzyme test
Enzyme tests
Blood tests
Urinalysis
EXAMPLE
Total protein, albumin, globulin, total bilirubin (direct bilirubin if total is elevated).
Alkaline phosphatasa
Gamma glutamyl transpeptidase (GGTP), lactic dehydrogenase (LDH), serum glutamic-
oxaloacetic transaminase (SCOT), serum glutamic-pyruvic transaminase (SOFT).
Blood urea nitrogen (BUN), creatinine, uric acid.
Including color; appearance; specific gravity; pH; qualitative glucose, protein, bile, and ace-
tone; occult blood; microscopic examination of centrifuged sediment.
Blood-Forming Function Blood tests
Complete blood count (CBC) with differential and platelet evaluation, including white cell
count (WBC), red blood count (RBC), hemoglobin (HGB), hematocrit or packed cell volume
(HCT), and desired erythrocyte indices. Reticulocyte count may be appropriate if there is a
likelihood of exposure to hemolytic chemicals.
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Medical Program
5-7
Sample Pro-Employment Examination
Occupational and Medical History
• Do a complete medical history emphasizing these
systems: nervous, skin, lung, blood-forming, cardi-
ovascular, gastrointestinal, genitourinary, reproduc-
tive, ear, nose, and throat.
Physical Examination
Include at least the following:
• Height, weight, temperature, pulse, respiration, and
blood pressure.
• Head, nose, and throat.
• Eyes. Include vision tests that measure refraction,
depth perception, and color vision. These tests
should be administered by a qualified technician or
physician. Vision quality is essential to safety, the
accurate reading of instruments and labels, the avoid-
ance of physical hazards, and for appropriate
response to color-coded labels and signals.
• Ears. Include audiometric tests, performed at 500,
1,000, 2,000, 3,000, 4,000, and 6,000 hertz (Hz)
pure tone in an approved booth (see requirements
listed in 29 CFR Part 1910.95, Appendix D). Tests
should be administered by a qualified technician, and
results read by a certified audiologist or a physician
familiar with audiometric evaluation. The integrity of
the eardrum should be established since perforated
eardrums can provide a route of entry for chemicals
into the body. The physician evaluating employees
with perforated eardrums should consider the
environmental conditions of the job and discuss pos-
sible specific safety controls with the Site Safety
Officer, industrial hygienist, and/or other health
professionals before deciding whether such
individuals can safely work on sita
• Chest (heart and lungs).
• Peripheral vascular system.
• Abdomen and rectum (including hernia exam).
• Spine and other components of the musculoskeletal
system.
• Genitourinary system.
• Skin.
• Nervous system.
Tests
• Blood.
• Urine.
• A 14 x 17-inch posterior/anterior view chest X-ray,
with lateral or oblique views only if indicated or if
mandated by state regulations. The X-ray should be
taken by a certified radiology technician and inter-
preted by a-board-certified or board-eligible radiol-
ogist. Chest X-rays taken in the last 12-month period,
as well as the oldest chest X-ray available, should be
obtained and used for comparison. Chest X-rays
should not be repeated more than once a year, unless
otherwise determined by the examining physician.
Ability to Perform While Wearing Protective Equipment
To determine a worker's capacity to perform while wear-
ing protective equipment, additional tests may be neces-
sary, for example:
• Pulmonary function testing. Measurement should
include forced expiratory volume in 1 second (FEVi),
forced vital capacity (FVC), and FEV, —to-FVC ratio,
with interpretation and comparison to normal
predicted values corrected for age, height, race, and
sex. Other factors such as FEF, MEFR, MVV, FRC, RV,
and TLC1 may be included for additional information.
A permanent record of flow curves should be placed
in the worker's medical records. The tests should be
conducted by a certified technician and the results
interpreted by a physician.
• Electrocardiogram (EKG). At least one standard,
12-lead resting EKG should be performed at the dis-
cretion of the physician. A "stress test" (graded
exercise) may be administered at the discretion of the
examining physician, particularly where heat stress
may occur.
Baseline Monitoring
If there is likelihood of potential onsite exposure to a par-
ticular toxicant, specific baseline monitoring should be
performed to establish data relating to that toxicant.
Periodic Medical Examinations
Periodic Screening
Periodic medical examinations should be developed and
used in conjunction with pre-employment screening
examinations. Comparison of sequential medical reports
with baseline data is essential to determine biologic
trends that may mark early signs of adverse health
effects, and thereby facilitate appropriate protective
measures.
The frequency and content of examinations will vary,
depending on the nature of the work and exposures.
Generally, medical examinations have been recommended
at least yearly. More frequent examinations may be
necessary, depending on the extent of potential or actual
exposure, the type of chemicals involved, the duration of
the work assignment, and the individual worker's profile.
For example, workers participating in the cleanup of a
PCB-contaminated building were initially examined
monthly for serum PCB levels. Review of the data from
the first few months revealed no appreciable evidence of
PCB exposure. The frequency of PCB testing was then
reduced [4]. Periodic screening exams can include:
• Interval medical history, focusing on changes in
health status, illnesses, and possible work-related
symptoms. The examining physician should have
information about the worker's interval exposure his-
tory, including exposure monitoring at the job site,
supplemented by worker-reported exposure history
and general information on possible exposures at
previously worked sites.
• Physical examination.
1 FEF = forced expiratory flow; MEFR = maximal expiratory flow
rate; MVV = maximal voluntary ventilation; FRC = functional
residual capacity; RV = residual volume; TLC = total lung
capacity.
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5-8
Medical Program
Additional medical testing, depending on available
exposure information, medical history, and examina-
tion results. Testing should be specific for the pos-
sible medical effects of the worker's exposure.
Multiple testing for a large range of potential
exposures is not always useful; it may involve inva-
sive procedures (e.g., tissue biopsy), be expensive,
and may produce false-positive results.
Pulmonary function tests should be administered if
the individual uses a respirator, has been or may be
exposed to irritating or toxic substances, or if the
individual has breathing difficulties, especially
when wearing a respirator.
Audiometric tests. Annual retests are required for
personnel subject to high noise exposures (an
8-hour, time-weighted average of 85 dBA1 or more),
those required to wear hearing protection, or as
otherwise indicated.
Vision tests. Annual retests are recommended to
check for vision degradation.
Blood and urine tests when indicated.
Sample Periodic Medical Examination
The basic periodic medical examination is the same as
the pre-employment screening (see previous section,
Sample Pre-Employment Examination), modified accord-
ing to current conditions, such as changes in the worker's
symptoms, site hazards, or exposures.
Termination Examination
At the end of employment at a hazardous waste site, all
personnel should have a medical examination as
described in the previous sections (see Sample Pre-
Employment Examination). This examination may be
limited to obtaining an interval medical history of the
period since the last full examination (consisting of medi-
cal history, physical examination, and laboratory tests) if
all three following conditions are met:
• The last full medical examination was within the last
6 months.
• No exposure occurred since the last examination.
• No symptoms associated with exposure occurred
since the last examination.
If any of these criteria are not met, a full examination is
medically necessary at the termination of employment.
Emergency Treatment
Provisions for emergency treatment and acute non-
emergency treatment should be made at each site.
Preplanning is vital.
When developing plans, procedures, and equipment lists,
the range of actual and potential hazards specific to the
site should be considered, including chemical, physical
(such as heat and/or cold stress, falls and trips), and bio-
logic hazards (animal bites and plant poisoning as well as
hazardous biological wastes). Not only site workers, but
1 dBA = decibels on A-weighted scale (29 CFR Part 1910.95).
also contractors, visitors, and other personnel (particu-
larly firefighters) may require emergency treatment.
Emergency medical treatment should be integrated with
the overall site emergency response program (see Chap-
ter 12). The following are recommended guidelines for
establishing an emergency treatment program.
• Train a team of site personnel in emergency first aid.
This should include a Red Cross or equivalent certi-
fied course in cardiopulmonary resuscitation (CPR),
and first-aid training that emphasizes treatment for
explosion and burn injuries, heat stress, and acute
chemical toxicity. In addition, this team should
include an emergency medical technician (EMT) if
possible. Table 5-4 lists signs and symptoms of
exposure and heat stress that indicate potential medi-
cal emergencies.
• Train personnel in emergency decontamination proce-
dures in coordination with the Emergency Response
Plan (see Chapter 12 for details).
• Predesignate roles and responsibilities to be assumed
by personnel in an emergency.
• Establish an emergency/first-aid station on site, cap-
able of providing (1) stabilization for patients requiring
offsite treatment, and (2) general first aid (e.g., minor
cuts, sprains, abrasions).
Locate the station in the clean area adjacent to the
decontamination area to facilitate emergency
decontamination.
Provide a standard first-aid kit or equivalent sup-
plies, plus additional items such as emergency/del-
uge showers, stretchers, portable water, ice,
emergency eyewash, decontamination solutions,
and fire-extinguishing blankets.
Restock supplies and equipment immediately after
each use and check them regularly.
• Arrange for a physician who can be paged on a
24-hour basis.
• Set up an on-call team of medical specialists for
emergency consultations, e.g., a toxicologist, derma-
tologist, hematologist, allergist, opthalmologist,
cardiologist, and neurologist.
• Establish a protocol for monitoring heat stress (see
Monitoring section of Chapter 8).
• Make plans in advance for emergency transportation
to, treatment at, and contamination control proce-
dures for a nearby medical facility.
Educate local emergency transport and hospital
personnel about possible medical problems on site;
types of hazards and their consequences; potential
for exposure; scope and function of the site medi-
cal program.
Assist the hospital in developing procedures for
site-related emergencies. This will help to protect
hospital personnel and patients, and to minimize
delays due to concerns about hospital safety or
contamination.
For specific illnesses or injuries, provide details of
the incident and the worker's past medical history
to the appropriate hospital staff. This is especially
crucial when specific medical treatment is required,
e.g., for exposure to cyanide or organophosphate
pesticides.
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Medical Program
5-9
Table 5-4. Signs and Symptoms of Chemical Exposure and
Heat Stress that Indicate Potential
Medical Emergencies
TYPE OF HAZARD SIGNS AND SYMPTOMS
Chemical Hazard
Heat Exhaustion
Behavioral changes
Breathing difficulties
Changes in complexion or skin color
Coordination difficulties
Coughing
Dizziness
Drooling
Diarrhea
Fatigue and/or weakness
Irritability
Irritation of eyes, nose, respiratory tract, skin,
or throat
Headache
Light-headedness
Nausea
Sneezing
Sweating
Tearing
Tightness in the chest
Clammy skin
Confusion
Dizziness
Fainting
Fatigue
Heat rash
Light-headedness
Nausea
Profuse sweating
Slurred speech
Weak pulse
Heat Stroke Confusion
(may be fatal) Convulsions
Hot skin, high temperature (yet may feel
chilled)
Incoherent speech
Convulsions
Staggering gait
Sweating stops (yet residual sweat may be
present)
Unconsciousness
Depending on the site's location and potential hazards, it
may be important to identify additional medical facilities
capable of sophisticated response to chemical or other
exposures.
• Post conspicuously (with duplicates near the tele-
phones) the names, phone numbers, addresses,
and procedures for contacting:
On-call physicians.
Medical specialists.
Ambulance services.
Medical facility(ies).
Emergency, fire, and police services.
Poison control hotline.
• Provide maps and directions.
• Make sure at least all managers and all individuals
involved in medical response know the way to the
nearest emergency medical facility.
• Establish a radiocommunication system for emer-
gency use.
• Review emergency procedures daily with all site
personnel at safety meetings before beginning the
work shift.
Non-Emergency Treatment
Arrangements should be made for non-emergency medi-
cal care for hazardous waste site workers who are
experiencing health effects resulting from an exposure to
hazardous substances. In conjunction with the medical
surveillance program, offsite medical care should ensure
that any potential job-related symptoms or illnesses are
evaluated in the context of the worker's exposure. Offsite
medical personnel should also investigate and treat non-
job-related illnesses that may put the worker at risk
because of task requirements (ag., a bad cold or flu that
might interfere with respirator use). A copy of the
worker's medical records should be kept at the site (with
provisions for security and confidentiality) and, when
appropriate, at a nearby hospital. Treating physicians
should have access to these records.
Medical Records
Proper recordkeeping is essential at hazardous waste
sites because of the nature of the work and risks:
employees may work at a large number of geographically
separate sites during their careers, and adverse effects of
long-term exposure may not become apparent for many
years. Records enable subsequent medical care providers
to be informed about workers' previous and current
exposures.
Occupational Safety and Health Administration (OSHA)
regulations mandate that, unless a specific occupational
safety and health standard provides a different time
period, the employer must:
• Maintain and preserve medical records on exposed
workers for 30 years after they leave employment
(29 CFR Part 1910.20).
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5-10 Medical Program
• Make available to workers, their authorized represen-
tatives, and authorized OSHA representatives the
results of medical testing and full medical records
and analyses (29 CFR Part 1910.20).
• Maintain records of occupational injuries and ill-
nesses and post a yearly summary report (29 CFR
Part 1904).
Program Review
Regular evaluation of the medical program is important to
ensure its effectiveness. Maintenance and review of medi-
cal records and test results aid medical personnel, site
officers, and the parent company and/or agency managers
in assessing the effectiveness of the health and safety
program. The Site Safety Officer, medical consultant,
and/or management representative should, at least
annually:
• Ascertain that each accident or illness was
promptly investigated to determine the cause and
make necessary changes in health and safety
procedures.
• Evaluate the efficacy of specific medical testing in
the context of potential site exposures.
• Add or delete medical tests as suggested by cur-
rent industrial hygiene and environmental data.
• Review potential exposures and Site Safety Plans
at all sites to determine if additional testing is
required.
• Review emergency treatment procedures and
update lists of emergency contacts.
References
1. Proficiency Testing Programs
Division of Technology Evaluation and Assistance
Laboratory Program Office
Center for Disease Control
Atlanta, GA 30333
College of American Pathologists
7400 N. Skokie Blvd.
Skokie, IL 60077
American Association for Bioanalysts
205 W. Levee Street
Brownsville, TX 78520
2. Costello, R.J. 1983. U.S. Environmental Protection
Agency Triangle Chemical Site, Bridge City, Texas.
NIOSH Health Hazard Evaluations Determination
Report, HETA 83-417-1357.
3. ANSI. 1984. American National Standard for Respira-
tory Protection. ANSI Z88.6-1984. American National
Standards Institute, 1430 Broadway, New York, NY
10018.
t
4. Gleit, A.; Cohen, A.G.; Chase, K.H.; and J. Toth. 1985.
Summary Report of the Medical Surveillance Program
for the Binghamton State Office Building Decontami-
nation Project. Prepared for Versar New York, Inc.
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6. Site Characterization
Contents
Introduction 6-1
Offsite Characterization 6-1
Interview/Records Research 6-1
Perimeter Reconnaissance 6-2
Protection of Entry Personnel 6-2
Onsite Survey 6-2
Information Documentation 6-4
Hazard Assessment 6-5
Threshold Limit Value (TLV) 6-5
Permissible Exposure Limit (PEL) 6-5
Recommended Exposure Limit (REL) 6-6
IDLH Concentrations 6-6
Potential Skin Absorption and Irritation 6-6
Potential Eye Irritation 6-6
Explosion and Flammability Ranges 6-6
Hazardous Substance Information Form 6-7
Monitoring 6-8
References 6-8
The sections below detail the three phases of site charac-
terization and provide a general guide which should be
adapted to meet the specific situation. Within each phase
of information gathering, the most appropriate sequence
of steps should be determined, particularly if there are
time or budget considerations that limit the scope of the
work. Wherever possible, all information sources should
be pursued.
Offsite Characterization
As much information as possible should be obtained
before site entry so that the hazards can be evaluated and
preliminary controls instituted to protect initial entry per-
sonnel. Initial information-gathering missions should
focus on identifying all potential or suspected conditions
that may pose inhalation hazards that are immediately
dangerous to life or health (IDLH)1 or other conditions
that may cause death or serious harm (see Table 6-1).
Offsite information can be obtained by two methods:
interview/records research and perimeter reconnaissance.
Introduction
Site characterization provides the information needed to
identify site hazards and to select worker protection
methods. The more accurate, detailed, and comprehen-
sive the information available about a site, the more the
protective measures can be tailored to the actual hazards
that workers may encounter.
The person with primary responsibility for site characteri-
zation and assessment is the Project Team Leader. In
addition, outside experts, such as chemists, health physi-
cists, industrial hygienists, and toxicologists, may be
needed to accurately and fully interpret all the available
information on site conditions.
Site characterization generally proceeds in three phases:
• Prior to site entry, conduct offsite characterization:
gather information away from the site and conduct
reconnaissance from the site perimeter.
• Next, conduct onsite surveys. During this phase,
restrict site entry to reconnaissance personnel.
• Once the site has been determined safe for com-
mencement of other activities, perform ongoing
monitoring to provide a continuous source of infor-
mation about site conditions.
It is important to recognize that site characterization is a
continuous process. At each phase of site characteriza-
tion, information should be obtained and evaluated to
define the hazards that the site may posa This assess-
ment can then be used to develop a safety and health
plan for the next phase of work. In addition to the formal
information gathering that takes place during the phases
of site characterization described here, all site personnel
should be constantly alert for new information about site
conditions.
Table 6-1. Visible Indicators of Potential IDLH and Other
Dangerous Conditions
• Large containers or tanks that must be entered.
• Enclosed spaces such as buildings or trenches that must be
entered.
• Potentially explosive or flammable situations (indicated by bulging
drums, effervescence, gas generation, or instrument readings).
• Extremely hazardous materials (such as cyanide, phosgene, or
radiation sources).
• Visible vapor clouds.
• Areas where biological indicators (such as dead animals or
vegetation) are located.
Interview/Records Research
As much data as possible should be collected before any
personnel go on site. Where possible, the following infor-
mation should be obtained:
• Exact location of the site.
• Detailed description of the activity that occurred at
the site.
• Duration of the activity.
• Meteorologic data, e^., current weather and forecast,
prevailing wind direction, precipitation levels, temper-
ature profiles.
• Terrain, ag., historical and current site maps, site pho-
tographs, aerial photographs, U.S. Geological Survey
topographic quadrangle maps, land use maps, and
land cover maps.
MDLH conditions refer to inhalation hazards (see section on IDLH
Concentrations later in this chapter).
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6-2
Site Characterization
• Geologic and hydrologic data.
• Habitation—population centers, population at risk.
• Accessibility by air and roads.
• Pathways of dispersion.
• Present status of response and who has responded.
• Hazardous substances involved and their chemical
and physical properties. Information sources include:
Company records, receipts, logbooks, or ledgers.
Records from state and federal pollution control
regulatory and enforcement agencies, state Attor-
ney General's office, state occupational safety and
health agencies, state Fire Marshal's office.
Waste storage inventories and manifests or ship-
ping papers.
Interviews with personnel and their families (all
interview information should be verified).
Generator and transporter records.
Water department and sewage district records.
Interviews with nearby residents (note possible
site-related medical problems and verify all infor-
mation from interviews).
Local fire and police department records.
Court records.
Utility company records.
Media reports (verify all information from the
media).
• Previous surveying (including soil, ground-penetrating
radar, and magnetometer surveys), sampling, and
monitoring data.
Perimeter Reconnaissance
At a site in which the hazards are largely unknown or
there is no need to go on site immediately, visual observa-
tions should be made, atmospheric concentrations of air-
borne pollutants at the site perimeter should be monitored
(see Chapter 7, Air Monitoring), and samples should be
collected near the site. While these data are not definitive
indicators of onsite conditions, they can assist in the
preliminary evaluation. Perimeter reconnaissance of a site
should involve the following actions:
• Develop a preliminary site map, with the locations of
buildings, containers, impoundments, pits, ponds,
and tanks.
• Review historical and current aerial photographs.
Note:
Disappearance of natural depressions, quarries, or
pits.
Variation in reforestation of disturbed areas.
Mounding or uplift in disturbed areas or paved sur-
faces, or modifications in grade.
Changes in vegetation around buildings.
Changes in traffic patterns at the site.
• Note any labels, markings, or placards on containers
or vehicles.
• Note the amount of deterioration or damage of con-
tainers or vehicles.
• Note any biologic indicators, such as dead animals or
plants.
• Note any unusual conditions, such as clouds, dis-
colored liquids, oil slicks, vapors, or other suspicious
substances.
• Monitor the ambient air at the site perimeter (see
Chapter 7, Air Monitoring) for:
Toxic substances.
Combustible and flammable gases or vapors.
Oxygen deficiency.
Ionizing radiation.
Specific materials, if known.
• Note any unusual odors.
• Collect and analyze offsite samples, including (see
reference [1] for methods):
Soil.
Drinking water.
Ground water.
Site run-off.
Surface water.
Protection of Entry Personnel
The information from interview/records research and
perimeter reconnaissance is used as the basis for select-
ing the protective equipment for the initial site survey. In
addition, the proposed work to be accomplished must be
considered. For example, if the purpose of the survey is to
inspect onsite conditions, count containers, measure the
ambient air for "hot spots" (i.e., areas with high concen-
trations of toxic chemicals), and generally become famil-
iar with the site, the level of protection may be less
stringent than if containers are to be opened and samples
taken. (Chapter 8, Personal Protective Equipment, pro-
vides more detail on the selection of protective items.)
The ensemble of clothing and equipment referred to as
Level B protection is generally the minimum level recom-
mended for an initial entry until the site hazards have
been further identified and the most appropriate protec-
tive clothing and equipment chosen. Level B equipment is
described in Table 8-7, Chapter 8.
Onsite Survey
The purpose of an onsite survey is to verify and supple-
ment information from the offsite characterization. Prior
to going on site, the offsite characterization should be
used to develop a Site Safety Plan for site entry that
addresses the work to be accomplished and prescribes
the procedures to protect the health and safety of the
entry team. Priorities should be established for hazard
assessment and site activities after careful evaluation of
probable conditions. Because team members may be
entering a largely unknown environment, caution and
conservative actions are appropriate. The composition of
the entry team depends on the site characteristics but
should always consist of at least four persons: two
workers who will enter the site and two outside support
persons, suited in personal protective equipment and pre-
pared to enter the site in case of emergency. Upon enter-
ing the site, entry personnel should:
• Monitor the air for IDLH and other conditions that
may cause death or serious harm (combustible or
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Site Characterization
6-3
23133S&
nun
As part of site characterization, workers suited in Level A
protective ensembles work in pairs when investigating
confined spaces.
explosive atmospheres, oxygen deficiency, toxic sub-
stances). Chapter 7 provides detailed information on
air monitoring.
• Monitor for ionizing radiation. Survey for gamma and
beta radiation with a Geiger-Mueller detection tube or
a gamma scintillation tube; if alpha radiation is
expected, use a proportional counter.
• Visually observe for signs of actual or potential IDLH
or other dangerous conditions (see Table 6-1).
Any indication of IDLH hazards or other dangerous condi-
tions should be regarded as a sign to proceed with care
and deliberation. Extreme caution should be exercised in
continuing the site survey when such hazards are indi-
cated. Table 6-2 provides some basic guidelines for
decision-making. If IDLH or other dangerous conditions
are not present, or if proper precautions can be taken,
continue the survey:
• Conduct further air monitoring as necessary (see
Chapter 7).
• Note the types of containers, impoundments, or other
storage systems:
Paper or wood packages.
Metal or plastic barrels or drums.
Underground tanks.
Aboveground tanks.
Compressed gas cylinders.
Pits, ponds, or lagoons.
Other.
• Note the condition of waste containers and storage
systems:
Sound (undamaged).
Visibly rusted or corroded.
Leaking.
Bulging.
Types and quantities of material in containers.
Labels on containers indicating corrosive, explosive,
flammable, radioactive, or toxic materials.
• Note the physical condition of the materials:
Gas, liquid, or solid.
Color and turbidity.
Behavior, e^j., corroding, foaming, or vaporizing.
Conditions conducive to splash or contact.
• Identify natural wind barriers:
Buildings.
Hills.
Tanks.
• Determine the potential pathways of dispersion:
Air.
Biologic routes, such as animals and food chains.
Ground water.
Land surface.
Surface water.
• If necessary, use one or more of the following
remote sensing or subsurface investigative
methods to locate buried wastes or contaminant
plumes:
Electromagnetic resistivity.
Seismic refraction.
Magnetometry.
Metal detection.
Ground-penetrating radar.
• Note any indicators of potential exposure to haz-
ardous substances:
Dead fish, animals or vegetation.
Dust or spray in the air.
Fissures or cracks in solid surfaces that expose
deep waste layers.
Pools of liquid.
Foams or oils on liquid surfaces.
Gas generation or effervescence
Deteriorating containers.
Clea;ed land areas or possible landfilled areas.
• Note any safety hazards. Consider:
Conditions of site structures.
Obstacles to entry and exit.
Terrain homogeneity.
Terrain stability.
Stability of stacked material.
• Identify any reactive, incompatible, flammable, or
highly corrosive wastes.
• Note land features.
• Note the presence of any potential naturally occur-
ring skin irritants or dermatitis-inducing agents, for
example:
Poison ivy.
Poison oak.
Poison sumac.
• Note any tags, labels, markings, or other identify-
ing indicators.
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6-4
Site Characterization
Table 6-2. Guidelines for Some Atmospheric Hazards3
HAZARD"
MONITORING EQUIPMENT": MEASURED LEVEL ACTION
Explosive
atmosphere
Combustible gas indicator <10% LELd
10%-25% LEL
>25% LEL
Continue investigation.
Continue onsite monitoring with extreme caution as higher
levels are encountered.
Explosion hazard. Withdraw from area immediately.
Oxygen
Oxygen concentration
meter
<19.5% Monitor wearing self-contained breathing apparatus.
NOTE: Combustible gas readings are not valid in atmospheres
with <19.5% oxygen.
19.5%-25% Continue investigation with caution. Deviation from normal
level may be due to the presence of other substances.
>25% Fire hazard potential. Discontinue investigation. Consult a fire
safety specialist.
Radiation
Radiation survey equipment < 2 mrem/hr®-*
> 2 mrem/hr
Radiation above background levels (normally 0.01-0.02
mrem/hr)9 signifies the possible presence of radiation
sources. Continue investigation with caution. Perform
thorough monitoring. Consult with a health physicist.
Potential radiation hazard. Evacuate sita Continue investiga-
tion only upon the advice of a health physicist.
Inorganic and organic
gases and vapors
Colorimetric tubes
Chemical-specific instru-
ments, including halide
meter, hydrogen sulfide
detector, carbon monoxide
monitor, and mercury meter
Depends on Consult standard reference manuals for air concentra-
chemical tion/toxicity data. Action level depends on PEL/REL/TLV.h
Organic gases and
vapors
Portable photoionizer
Organic vapor analyzer
1) Operated in gas chro-
matography (GC) mode
2) Operated in survey mode
Depends on Consult standard reference manuals for air concentra-
chemical tion/toxicity data. Action level depends on PEL/REL/TLV.h
"Based on Standard Operating Guides. U.S EPA. December, 1984.
These are general classes of hazards. Not all components of these classes can be measured.
cConsult manufacturers' literature for use limitations associated with the specific equipment and for the specific substances the
equipment can detect. See Tables 7-1 and 7-2 for more complete descriptions.
dLEL = lower explosive limit.
emrem/hr = milliroentgen equivalent in man per hour.
'Source: U.S. Nuclear Regulatory Commission Rules and Regulations, 10 CFR Chapter 1, Part 20.105.
aSource: Sax, I.N. 1979. Dangerous Properties of Industrial Materials. Fifth Edition, p. 167. Van Nostrand Reinhold Company, New York.
hPEL = OSHA permissible exposure limit.
REL = NIOSH recommended exposure limit.
TLV = threshold limit value.
See Table 6-4.
Collect samples [1]:
Air (see Chapter 7, Air Monitoring).
Drainage ditches.
Soil (surface and subsurface).
Standing pools of liquids.
Storage containers.
Streams and ponds.
Ground water (upgradient, beneath site, down-
gradient).
Sample for or otherwise identify:
Biologic or pathologic hazards.
Radiologic hazards.
Information Documentation
Proper documentation and document control are impor-
tant for ensuring accurate communication; ensuring the
quality of the data collected; providing the rationale for
safety decisions; and substantiating possible legal
actions. Documentation can be accomplished by record-
ing information pertinent to field activities, sample analy-
sis, and site conditions in one of several ways, including:
• Logbooks.
• Field data records.
• Graphs.
• Photographs.
• Sample labels.
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Site Characterization
6-5
• Chain-ot-custody forms.
• Analytical records.
These documents should be controlled to ensure that
they are all accounted for when the project is completed.
The task of document control should be assigned to one
individual on the project team and should include the
following responsibilities:
• Numbering each document (including sample labels)
with a unique number.
• Listing each document in a document inventory.
• Recording the whereabouts of each document in a
separate document register so that any document
can be readily located. In particular, the name and
location of site personnel that have documents in
their possession should be recorded.
• Collecting all documents at the end of each work
period.
• Making sure that all document entries are made in
waterproof ink.
• Filing all documents in a central file at the completion
of the site response.
Field personnel should record all onsite activities and
observations in a field logbook—a bound book with con-
secutively numbered pages. Entries should be made dur-
ing or just after completing a task to ensure thoroughness
and accuracy. Table 6-3 shows the level of detail that
should be recorded during sampling.
Photographs can be an accurate, objective addition to a
field worker's written observations. For each photograph
taken, the following information should be recorded in the
field logbook:
• Date, time, and name of site.
• Name of the photographer.
• Location of the subject within the site.
• General compass direction of the orientation of the
photograph.
• General description of the subject.
• Sequential number of the photograph and the film roll
number.
• Camera, lens, and film type used for photography.
Serially numbered sample labels or tags should be
assigned to sampling team personnel and recorded in the
field logbook. Lost, voided, or damaged labels should be
noted in the logbook. Labels should be firmly affixed to
the sample containers using either gummed labels or tags
attached by string or wire Information should be recorded
on the tag in waterproof ink and should include items
such as:
• The unique sample log number.
• Date and time that the sample was collected.
• Source of the sample, e.g., name, location, and type
of sample.
• Preservative used.
• Analysis required.
Sample jars are labelled prior to sampling as pan of site
documentation procedure*.
• Name of collector.
• Pertinent field data.
In addition to supporting litigation, written records of
sample collection, transfer, storage, analysis, and destruc-
tion help ensure the proper interpretation of analytical
test results. Information describing the chain of custody
should be recorded on a form that accompanies the sam-
ple from collection to destruction.
Hazard Assessment
Once the presence and concentrations of specific chemi-
cals or classes of chemicals have been established, the
hazards associated with these chemicals must be deter-
mined. This is done by referring to standard reference
sources for data and guidelines on permissible levels of
exposure, flammability, etc. Some key guidelines are listed
in Table 6-4 and are described below.
Threshold Limit Value (TLV)®
TLVs can be used as a guideline for determining the
appropriate level of worker protection. These values have
been derived for many substances and can be found in
Threshold Limit Values for Chemical Substances and
Physical Agents, which is published annually by the
American Conference of Governmental Industrial
Hygienists (ACGIH) [2]. The ACGIH defines three categor-
ies of TLVs: time-weighted average (TWA); short-term
exposure limit (STEL); and ceiling (C). All three categories
may be useful in selecting levels of protection at a hazard-
ous waste site. Refer to the Threshold Limit Values for
Chemical Substances and Physical Agents [2] for addi-
tional details.
Permissible Exposure Limit (PEL)
Permissible exposure limits are enforceable standards
promulgated by OSHA. In many cases they are derived
from TLVs published in 1968. The PEL for a substance is
the 8-hour time-weighted average or ceiling concentration
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6-6
Site Characterization
Table 6-3. Example of Field Logbook Entries
to Describe Sampling
Date and time of entry.
Purpose of sampling.
Name, address, and affiliation of personnel performing sampling.
Name and address of the material's producer, if known.
Type of material, ag., sludge or wastewater.
Description of material container.
Description of sample.
Chemical components and concentrations, if known.
Number and size of samples taken.
Description and location of the sampling point.
Date and time of sample collection.
Difficulties experienced in obtaining sample (eg., is it
representative of the bulk material?).
Visual references, such as maps or photographs of the
sampling site.
Field observations, such as weather conditions during
sampling periods.
Field measurements of the materials, ag., explosiveness,
flammability, or pH.
Whether chain-of-custody forms have been filled out
for the samples.
above which workers may not be exposed. Although per-
sonal protective equipment may not be required for
exposures below the PEL, its use may be advisable where
there is a potential for overexposure. See the tables and
substance-specific standards in 29 CFR Part 1910, Sub-
part Z, for additional details.
equipment fail. At hazardous waste sites, IDLH concentra-
tions should be assumed to represent concentrations
above which only workers wearing respirators that pro-
vide the maximum protection (i.e., a positive-pressure,
full-facepiece, self-contained breathing apparatus [SCBA]
or a combination positive-pressure, full-facepiece,
supplied-air respirator with positive-pressure SCBA [see
Chapter 8]) are permitted. Specific IDLH values for many
substances can be found in the NIOSH Pocket Guide to
Chemical Hazards [3].
Potential Skin Absorption and Irritation
Information on skin absorption is provided in the ACGIH
publication. Threshold Limit Values for Chemical Sub-
stances and Physical Agents [2] and in OSHA standard
29 CFR Part 1910.1000 and other standard references.
These documents identify substances that can be readily
absorbed through the skin, mucous membranes, and/or
eyes by either airborne exposure or direct contact with a
liquid. This information, like most available information on
skin absorption is qualitative. It indicates whether, but not
to what extent, a substance may pose a dermal hazard.
Thus decisions made concerning skin hazards are neces-
sarily judgmental.
In addition, many chemicals, although not absorbed
through the skin, may cause skin irritation at the point of
contact. Signs of skin irritation range from redness, swell-
ing, or itching to burns that destroy skin tissue. Standard
references can be used to determine whether a chemical
may act as an irritant.
Recommended Exposure Limit (RED
A NIOSH recommended exposure limit (REL) is the work-
place exposure concentration recommended by NIOSH
for promulgation by OSHA as a PEL, but is not enforce-
able as is the OSHA PEL. In some cases, NIOSH has
described time-weighted average concentrations in terms
of 10-hour, rather than 8-hour, averages.
Potential Eye Irritation
Quantitative data on eye irritation are not always availa-
ble. Where a review of the literature indicates that a sub-
stance causes eye irritation, but no threshold is specified,
have a competent health professional evaluate the data to
determine the level of personal protection needed for
onsite workers.
IDLH Concentrations
IDLH exposure concentrations have been established by
the NIOSH/OSHA Standards Completion Program (SCP)
as a guideline for selecting respirators for some chemi-
cals. The definition of IDLH varies depending on the
source. For example, the Mine Safety and Health Adminis-
tration Standard (30 CFR Part 11.3[t]) defines IDLH condi-
tions as those that pose an immediate threat to life or
health or that pose an immediate threat of severe
exposure to contaminants such as radioactive materials
that are likely to have adverse cumulative or delayed
effects on health. The NIOSH Pocket Guide to Chemical
Hazards [3] defines IDLH concentration as the
". . . maximum level from which one could escape within
30 minutes without any escape-impairing symptoms or
any irreversible health effects. . . ." The American
National Standards Institute, Inc. (ANSI) defines IDLH as
". . . any atmosphere that poses an immediate hazard to
life or produces immediate irreversible debilitating effects
on health..." [4]. Regardless of their exact definition, all
IDLH values indicate those concentrations of toxic sub-
stances from which escape is possible without irre-
versible harm should a worker's respiratory protective
Explosion and Flammability Ranges
The lower explosive limit (LEL) or lower flammable limit
(LFL) of a substance is the minimum concentration of gas
or vapor in air below which the substance will not burn
when exposed to a source of ignition. This concentration
is usually expressed in percent by volume. Below this con-
centration, the mixture is too "lean" to burn or explode.
The upper explosive limit (DEL) or upper flammable limit
(UFL) of a substance is the maximum concentration of
gas or vapor above which the substance will not burn
when exposed to a source of ignition. Above this concen-
tration, the mixture is too "rich" to burn or explode.
The flammable range is the range of concentrations
between the LFL and UFL where the gas-air mixture will
support combustion.
The flashpoint of a substance is the minimum tempera-
ture at which it gives off sufficient vapor to form an
ignitable mixture with the air just above the surface of the
substance. Ignition of a substance at the flashpoint is not
continuous.
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Site Characterization
6-7
Table 6-4. Guidelines for Assessing Chemical and Physical Hazards
HAZARD
Inhalation of
airborne
contaminants
GUIDELINE
TLV
TLV-TWA
TLV-STEL
Threshold Limit Value
Threshold Limit Value-
Time-Weighted Average
Threshold Limit Value-
Short-Term Exposure
Limit
EXPLANATION
One of three categories of chemical exposure levels, defined as
follows:
The time-weighted average concentration for a normal 8-hour
workday and a 40-hour work week, to which nearly all workers
may be repeatedly exposed without adverse effect. Should be
used as an exposure guide rather than an absolute threshold.
A 15-minute time-weighted average exposure that should not be
exceeded at any time during the work day.
SOURCES
FOR
VALUES"
ACGIH
ACGIH
TLV-C Threshold Limit Value-
Ceiling
PEL Permissible Exposure
Limit
REL Recommended
Exposure Limit
IDLH Immediately Dangerous
to Life or Health
The concentration that should not be exceeded even ACGIH
instantaneously.
Time-weighted average and ceiling concentrations similar to (and OSHA
in many cases derived from) the threshold limit values published in
1968.
Time-weighted averages and ceiling concentrations based on NIOSH
NIOSH evaluations.
The maximum level from which a worker could escape without NIOSH
any escape-impairing symptoms or any irreversible health effects.1"
Dermal absorp-
tion of chemi-
cals through
airborne or
direct contact
Dermal irritation
Carcinogens
Noise
Designation
TLV
PEL
REL
TLV
PEL
"skin"
Threshold Limit Value
Permissible Exposure
Limit
Recommended
Exposure Limit
Threshold Limit Value
Permissible Exposure
The designation "skin" in the ACGIH, OSHA, and NIOSH
references9 indicates that a substance may be readily absorbed
through the intact skin; however, it is not a threshold for safe
exposure. Direct contact with a substance designated "skin"
should be avoided.
Many substances irritate the skin. Consult standard references.
Some carcinogens have an assigned TLV.
OSHA has individual standards for some specific carcinogens.
NIOSH makes recommendations regarding exposures to
carcinogens.
Sound pressure levels and durations of exposure that represent
conditions to which it is believed that nearly all workers may be
repeatedly exposed without an adverse effect on their ability to
hear and understand normal speech.
Limits for acceptable noise exposure.
ACGIH/
OSHA/
NIOSH
ACGIH
OSHA
NIOSH
ACGIH
OSHA
REL
Limit
Recommended
Exposure Limit
Limits for acceptable noise exposure.
NIOSH
Ionizing Maximum permissible body burden and maximum permissible concentrations of radionuclides in air and in NCRP
Radiation water.
PEL Permissible Exposure Dose in rems per calendar quarter. OSHA
Limit
The ignition temperature or autoignition temperature is
the minimum temperature required to initiate or cause
self-sustained combustion without an ignition source.
When evaluating the fire or explosion potential at a haz-
ardous waste site, all equipment used should be intrinsi-
cally safe or explosion-proof. Where flammable or
explosive atmospheres are detected, ventilation may
dilute the mixture to below the LEL/LFL. However, ventila-
tion is generally not recommended if concentrations
exceed the UFL/UEL, since the mixture will pass through
the flammable/explosive range as it is diluted. Note that
combustible gas indicator readings may not be accurate
when oxygen concentrations are less than 19.5 percent.
Hazardous Substance Information
Form
Information on the chemical, physical, and toxicologic
properties of each compound known or expected to occur
on site should be recorded on a Hazardous Substance
Information Form (see Appendix C). Response personnel
will then have the necessary health and safety informa-
tion in one place, and new personnel can be quickly
briefed. As many reference sources as possible should be
used to fill out the sheets because the information may
vary from one source to another. Material Safety Data
Sheets provided by chemical manufacturers are one
source for this information.
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6-8
Site Characterization
Table 6-4. (cont.)
HAZARD
Explosion
GUIDELINE
LEL Lower Explosive Limit
DEL Upper Explosive Limit
EXPLANATION
The minimum concentration of vapor in air below which propaga-
tion of a flame will not occur in the presence of an ignition source
The maximum concentration of a vapor in air above which propa-
gation of a flame will not occur in the presence of an ignition
sourca
SOURCES
FOR
VALUES"
NFPA
NFPA
Fire
Flash point
The lowest temperature at which the vapor of a combustible liquid NFPA
can be made to ignite momentarily in air.
"Sources:
ACGIH. 1984-85. Threshold Limit Values for Chemical Substances and Physical Agents in the Workplace Environment and Biological
Exposure Indices with Intended Changes for 1985-86. American Conference of Governmental Industrial Hygienists, Cincinnati, Ohio.
NIOSH. Centers for Disease Control. 1983. NIOSH Recommendations for Occupational Health Standards. Morbidity and Mortality
Weekly Report Supplement. Vol. 32, No. 1S, October 7, 1983.
NIOSH. 1985. Pocket Guide to Chemical Hazards. National Institute for Occupational Safety and Health, Cincinnati, Ohio.
NCRP. Basic Radiation Protection-Criteria. NCRP Report No. 39. National Council on Radiation Protection and Measurements, Wash-
ington, D.C.
NCRP. Maximum Permissible Body Burdens and Maximum Permissible Concentrations of Radionuclides in Air and Water for Occupational
Exposure. NCRP Report No. 22. National Council on Radiation Protection and Measurements, Washington, D.C.
NFPA. 1985. Fire Protection Guide on Hazardous Materials. Eighth Edition. National Fire Protection Association, Boston, Massachusetts.
OSHA. 29 CFR Part 1910. (OSHA standards are legally binding.)
bOther sources have slightly different definitions of IDLH (see IDLH Concentrations in this chapter).
Monitoring
Because site activities and weather conditions change, an
ongoing air monitoring program should be implemented
after characterization has determined that the site is safe
for the commencement of operations.
The ongoing monitoring of atmospheric chemical hazards
should be conducted using a combination of stationary
sampling equipment, personnel monitoring devices, and
periodic area monitoring with direct-reading instruments
(see Chapter 7, Air Monitoring). Data obtained during off-
site and onsite surveys can be used to develop a plan that
details the procedures to be used for monitoring ambient
conditions during cleanup operations. Where necessary,
routes of exposure other than inhalation should be moni-
tored. For example, skin swipe tests may be used to
determine the effectiveness of personal protective cloth-
ing (see Chapter 10, Decontamination). Depending on the
physical properties and toxicity of the onsite materials,
community exposures resulting from hazardous waste
site operations may need to be assessed [5].
Monitoring also includes continual evaluation of any
changes in site conditions or work activities that could
affect worker safety. When a significant change occurs,
the hazards should be reassessed. Some indicators of the
need for reassessment are:
• Commencement of a new work phase, such as the
start of drum sampling.
• Change in job tasks during a work phase.
• Change of season.
• Change in weather.
• Change in ambient levels of contaminants.
References
1. U.S. EPA. 1984. Characterization of Hazardous Waste
Sites—A Methods Manual: Volume II. Available Sam-
pling Methods. Second edition. EPA 600/4-84-076.
2. ACGIH. 1984-85. Threshold Limit Values for Chemical
Substances and Physical Agents in the Workplace
Environment and Biological Exposure Indices with
Intended Changes for 1985-86. American Conference
of Governmental Industrial Hygienists, Cincinnati, OH.
3. NIOSH. 1985. Pocket Guide to Chemical Hazards.
National Institute for Occupational Safety and Health,
Cincinnati, OH.
4. ANSI. 1980. Practices for Respiratory Protection. ANSI
Z88.2-1980. American National Standards Institute,
1430 Broadway, New York, NY 10018.
5. U.S. Department of Health and Human Services. 1984.
A System for Prevention, Assessment and Control of
Exposures and Health Effects from Hazardous Sites
(S.P.A.C.E. for Health), U.S. Department of Health and
Human Services, Public Health Service, Center for
Disease Control, Atlanta, GA.
-------
7. Air Monitoring
Contents
Introduction 7-1
Measuring Instr'ments 7-1
Direct-Reading Instruments 7-1
Laboratory Analysis 7-3
Site Monitoring 7-4
Monitoring for IDLH and Other
Dangerous Conditions 7-5
General Onsite Monitoring 7-5
Perimeter Monitoring 7-6
Periodic Monitoring 7-6
Personal Monitoring 7-6
Variables of Hazardous Waste Site Exposure 7-6
References 7-7
Introduction
Airborne contaminants can present a significant threat to
worker health and safety. Thus, identification and quan-
tification of these contaminants through air monitoring is
an essential component of a health and safety program at
a hazardous waste site. Reliable measurements of air-
borne contaminants are useful for:
• Selecting personal protective equipment.
• Delineating areas where protection is needed.
• Assessing the potential health effects of exposure
• Determining the need for specific medical monitoring.
This chapter delineates the factors to consider when con-
ducting air monitoring at a hazardous waste site. It
presents strategies for assessing airborne contamination
at hazardous waste sites and describes instruments and
methods for measuring exposures.
Measuring Instruments
The purpose of air monitoring is to identify and quantify
airborne contaminants in order to determine the level of
worker protection needed. Initial screening for identifica-
tion is often qualitative, i.e., the contaminant, or the class
to which it belongs, is demonstrated to be present but
the determination of its concentration (quantification)
must await subsequent testing. Two principal approaches
are available for identifying and/or quantifying airborne
contaminants:
• The onsite use of direct-reading instruments.
• Laboratory analysis of air samples obtained by gas
sampling bag, filter, sorbent, or wet-contaminant col-
lection methods.
Direct-Reading Instruments
Direct-reading instruments were developed as early warn-
ing devices for use in industrial settings, where a leak or
an accident could release a high concentration of a
known chemical into the ambient atmosphere. Today,
some direct-reading instruments can detect contaminants
in concentrations down to one part contaminant per mil-
lion parts of air (ppm), although quantitative data are diffi-
cult to obtain when multiple contaminants are present.
Unlike air sampling devices, which are used to collect
samples for subsequent analysis in a laboratory, direct-
reading instruments provide information at the time of
sampling, enabling rapid decision-making.
Direct-reading instruments may be used to rapidly detect
flammable or explosive atmospheres, oxygen deficiency,
certain gases and vapors, and ionizing radiation. They are
the primary tools of initial site characterization. The infor-
mation provided by direct-reading instruments can be
used to institute appropriate protective measures (e.g.,
personal protective equipment, evacuation), to determine
the most appropriate equipment for further monitoring,
and to develop optimum sampling and analytical pro-
tocols.
All direct-reading instruments have inherent constraints in
their ability to detect hazards:
• They usually detect and/or measure only specific
classes of chemicals.
• Generally, they are not designed to measure and/or
detect airborne concentrations below 1 ppm.
• Many of the direct-reading instruments that have
been designed to detect one particular substance
also detect other substances (interference) and, con-
sequently, may give false readings.
It is imperative that direct-reading instruments be oper-
ated, and their data interpreted, by qualified individuals
who are thoroughly familiar with the particular device's
operating principles and limitations and who have
obtained the device's latest operating instructions and
calibration curves. At hazardous waste sites, where
unknown and multiple contaminants are the rule rather
than the exception, instrument readings should be inter-
preted conservatively. The following guidelines may facili-
tate accurate recording and interpretation:
• Calibrate instruments according to the manufac-
turer's instructions before and after every use.
• Develop chemical response curves if these are not
provided by the instrument manufacturer.
• Remember that the instrument's readings have
limited value where contaminants are unknown.
When recording readings of unknown contaminants,
report them as "needle deflection" or "positive
instrument response" rather than specific concentra-
tions (i.e., ppm). Conduct additional monitoring at any
location where a positive response occurs.
• A reading of zero should be reported as "no instru-
ment response" rather than "clean" because quanti-
ties of chemicals may be present that are not
detectable by the instrument.
• The survey should be repeated with several detection
systems to maximize the number of chemicals
detected.
Tables 7-1 and 7-2 list several direct-reading instruments
and the conditions and/or substances they measure. The
flame ionization detector (FID) and the photoionization
-------
7-2
Air Monitoring
Table 7-1. Some Direct-Reading Instruments for General Survey
HAZARD
INSTRUMENT MONITORED
Combustible Combustible
Gas Indicator gases and
(CGI) vapors.
APPLICATION
Measures the
concentration
of a com-
bustible gas
or vapor.
DETECTION
METHOD
A filament,
usually
made of
platinum, is
heated by
burning the
combust-
ible gas or
vapor. The
increase in
heat is
measured.
LIMITATIONS
Accuracy de-
pends, in part.
on the difference
between the
calibration and
sampling
temperatures.
Sensitivity is a
function of the
differences in
the chemical
and physical
properties
between the cal-
ibration gas and
the gas being
sampled.
The filament can
be damaged by
certain com-
pounds such as
silicones.
halides.
tetraethyl lead,
and oxygen-
enriched
atmospheres.
Does not provide
a valid reading
under oxygen-
EASE OF
OPERATION
Effective
use re-
quires that
operator
understand
the operat-
ing princi-
ples and
procedures.
GENERAL CARE
AND MAINTENANCE
Recharge or replace
battery.
Calibrate immedi-
ately before usa
TYPICAL
OPERATING TIMES
Can be used for as
long as the battery
lasts, or for the
recommended in-
terval between
calibrations.
whichever is less.
deficient conditions.
Flame lonization Many
Detector (FID) organic
with Gas gases and
Chromatography vapors.
Option
Gamma Radia- Gamma
tlon Survey radiation.
Instrument
In survey
mode, de-
tects the
total concen-
trations of
many organic
gases and
vapors. In
gas chroma-
tography
(GO mode,
identifies and
measures
specific
compounds.
In survey
mode, all the
organic com-
pounds are
ionized and
detected at
the same
time. In GC
mode, volatile
species are
separated.
Environmen-
tal radiation
monitor.
Gases and
vapors are
ionized in a
flama A
current is
produced in
proportion
to the num-
ber of car-
bon atoms
present.
Scintillation
detector.
Does not detect
inorganic gases
and vapors, or
some synthetics.
Sensitivity
depends on the
compound.
Should not be
used at tempera-
tures less than
40 °F (4°C).
Difficult to abso-
lutely identify
compounds.
High concentra-
tions of contam-
inants or
oxygen-deficient
atmospheres
require system
modification.
In survey mode.
readings can be
only reported
relative to the
calibration
standard used.
Does not
measure alpha
or beta radiation.
Requires
experience
to interpret
data cor-
rectly, espe-
cially in the
GC moda
Specific
identifica-
tion re-
quires cali-
bration
with the
specific
analyte of
interest.
Extremely
easy to op-
erate, but
requires
experience
to interpret
data. Rug-
ged, good
in field usa
Recharge or replace
battery.
Monitor fuel and/or
combustion air
supply gauges.
Perform routine
maintenance as
described in the
manual.
Check for leaks.
Must be calibrated
annually at a special-
ized facility.
8 hours; 3 hours
with strip chart
recorder.
Can be used for as
long as the battery
lasts, or for the
recommended in-
terval between
calibrations,
whichever is less.
-------
Air Monitoring
7-3
Table 7-1. (cont.)
INSTRUMENT
Portable
Infrared (IR)
Spectro-
photometer
Ultraviolet (UV)
Photolonization
Detector (PID)
HAZARD
MONITORED APPLICATION
Many gases Measures
and vapors, concentration
of many
gases and
vapors in air.
Designed to
quantify one-
or two-
component
mixtures.
Many Detects total
organic and concentra-
some inor- tions of many
ganic gases organic and
and vapors, some inor-
ganic gases
and vapors.
Some identi-
fication of
compounds
is possible if
more than
one probe is
used.
DETECTION
METHOD
Passes dif-
ferent fre-
quencies of
IR through
the sampla
The fre-
quencies
adsorbed
are specific
for each
compound.
Ionizes
molecules
using UV
radiation;
produces a
current that
is propor-
tional to the
number of
ions.
LIMITATIONS
In the field, must
make repeated
passes to
achieve reliable
results.
Requires
115-voltAC
power.
Not approved for
use in a poten-
tially flammable
or explosive
atmosphere.
Interference by
water vapor and
carbon dioxide.
Certain vapors
and high mois-
ture may attack
the instrument's
optics, which
must then be
replaced.
Does not detect
methane.
Does not detect
a compound if
the probe used
has a lower
energy level than
the compound's
ionization
potential.
Response may
change when
gases are mixed.
Other voltage
sources may
interfere with
measurements.
Readings can
only be reported
relative to the
calibration
standard used.
Response is
affected by high
humidity.
EASE OF
OPERATION
Requires
personnel
with exten-
sive experi-
ence in IR
spectropho-
tometry.
Effective
use re-
quires that
the opera-
tor under-
stand the
operating
principles
and proce-
dures, and
be compe-
tent in
calibrating,
reading.
and inter-
preting the
instrument.
GENERAL CARE TYPICAL
AND MAINTENANCE OPERATING TIMES
As specified by
manufacturer.
Recharge or replace 10 hours; 5 hours
battery. with strip chart
Regularly clean lamp recorder.
window.
Regularly clean and
maintain the
instrument and
accessories.
detector (PID) (see Table 7-1) are commonly used at haz-
ardous waste sites. However, some of these devices may
not detect some particularly toxic agents, including hydro-
gen cyanide and hydrogen sulfide. Thus, these devices
must be supplemented with other methods of detection.
Laboratory Analysis
Direct-reading personal monitors are available for only a
few specific substances and are rarely sensitive enough
to measure the minute (i.a, parts of contaminant per bil-
lion parts of air) quantities of contaminants which may,
nevertheless, induce health changes. Thus to detect rela-
tively low-level concentrations of contaminants, long-term
or "full-shift" personal air samples must be analyzed in a
laboratory. Full-shift air samples for some chemicals may
be collected with passive dosimeters, or by means of a
pump which draws air through a filter or sorbent. Table
7-3 lists some sampling and analytical techniques used at
hazardous waste sites.
Selection of the appropriate sampling media largely
depends on the physical state of the contaminants. For
example, chemicals such as PCBs (polychlorinated
biphenyls) and PNAs (polynuclear aromatic hydrocarbons)
occur as both vapors and particulate-bound contami-
nants. A dual-media system is needed to measure both
-------
7-4
Air Monitoring
Table 7-2. Some Direct-Reading Instruments for Specific Survey
INSTRUMENT
Direct-Reading
Colorimetric
Indicator Tube
Oxygen Meter
HAZARD DETECTION
MONITORED APPLICATION METHOD
Specific Measures The compound
gases and concentre- reacts with
vapors. tions of the indicator
specific chemical in
gases and the tube, pro-
vapors, ducing a stain
whose length
or color
change is
proportional to
the com-
pound's
concentration.
Oxygen (O2). Measures the Uses an elec-
percentage of trochemical
O2 in air. sensor to
measure the
partial pres-
sure of O2 in
the air and
converts that
reading tp O2
concentration.
'/! -.
LIMITATIONS
The measured
concentration
of the same
compound
may vary
among differ-
ent manufac-
turers' tubes.
Many similar
chemicals
interfera
Greatest
sources of
error are
(1) how the
operator
judges stain's
end-point, and
(2) the tube's
limited
accuracy.
Affected by
high humidity.
Must be
calibrated prior
to use to com-
pensate for
altitude and
barometric
pressura
Certain gases,
especially oxi-
dants such as
ozone, can
affect read-
ings. Carbon
dioxide (C02)
poisons the
detector cell.
EASE OF
OPERATION
Minimal
operator
training and
expertise
required.
Effective
use re-
quires that
the opera-
tor under-
stand the
operating
principles
and
procedures.
GENERAL CARE TYPICAL
AND MAINTENANCE OPERATING TIMES
Do not use a previ-
ously opened tube
even if the indicator
chemical is not
stained.
Check pump for
leaks before and
after usa
Refrigerate prior to
use to maintain shelf
life of about 2 years.
Check expiration
date of tubes.
Calibrate pump
volume at least
quarterly.
Avoid rough handling
which may cause
channeling.
Replace detector 8 to 12 hours.
cell according to
manufacturer's
recommendations.
Recharge or replace
batteries prior to
expiration of the
specified interval.
If the ambient air is
more than 0.5%
CO2, replace or
rejuvenate the 02
detector cell
frequently.
forms of these substances. The volatile component is coir
lected on a solid adsorbent and the nonvolatile compo-
nent is collected on a filter. More than two dozen
dual-media sampling techniques have been evaluated by
NIOSH [1,2].
A major disadvantage of long-term air monitoring is the
time required to obtain data. The time lag between sam-
pling and obtaining the analysis results may be a matter
of hours, if an onsite laboratory is available, or days,
weeks, even months, if a remote laboratory is involved.
This can be a significant problem if the situation requires
immediate decisions concerning worker safety. Also, by
the time samples are returned from a remote laboratory,
the hazardous waste site cleanup may have progressed to
a different stage or to a location at which different con-
taminants or different concentrations may exist. Careful
planning and/or the use of a mobile laboratory on site
may alleviate these problems.
Mobile laboratories may be brought on site to classify
hazardous wastes for disposal. A mobile laboratory is
generally a trailer truck that houses analytical instruments
capable of rapidly classifying contaminants by a variety of
techniques. Typical instruments include gas chromato-
graphs, spectrofluorometers, and infrared spectrophotom-
eters. When not in use in the mobile laboratory, these
devices can be relocated to fixed-base facilities. Onsite
laboratory facilities and practices should meet standards
of good laboratory safety.
Usually, a few of the field samples collected are analyzed
on site to provide rapid estimates of the concentration of
airborne contaminants. These data can be used to deter-
mine the initial level of worker personal protection neces-
sary to modify field sampling procedures and to guide the
fixed-base laboratory analysis. If necessary, samples
screened in the mobile laboratory can be subsequently
reanalyzed in sophisticated fixed-base laboratories. The
mobile laboratory also provides storage space, countertop
staging areas for industrial hygiene equipment, and facili-
ties for recharging self-contained breathing apparatus.
Site Monitoring
Priorities for air monitoring should be based on the infor-
mation gathered during initial site characterization (see
-------
Air Monitoring
7-5
Table 7-3. Some Sample Collection and Analytical Methods
TYPICAL DETECTION LIMIT
OF ANALYTIC
SUBSTANCE
Anions:
Bromide
Chloride
Fluoride
Nitrate
Phosphate
Sulfate
Aliphatic Amines
Asbestos
Metals
Organics
Nitrosamines
Particulates
PCBs
Pesticides
COLLECTION DEVICE"
Prewashed silica gel tube
Silica gel
MCEF
MCEF
Charcoal tube
Thermosorb/N
MCEF
GF filter and florisil tube
13-mm GF filter and
chromosorb 102 Tube
ANALYTICAL METHODb
Ion chromatography
GC/NPD
PCM
ICP-AES
GC/MS
GC/TEA
Gravimetric
GC-ECD
GC/MS
INSTRUMENT (jig)
10
5
5
10
20
10
10
100=
0.5
10
0.01
0.001
0.05
a MCEF = mixed cellulose ester filter.
GF = glass fiber filter.
b GC/NPD = gas chromatography and nitrogen/phosphorus detector; PCM = phase contrast microscopy; ICP-AES = inductively
coupled plasma atomic emission spectrometry; GM/MS = gas chromatography and mass spectrometry; GC/TEA = gas chroma-
tography using a thermal energy analyzer; GC-ECD = gas chromatography using an electrical conductivity detector.
0 Units in fibers per mm2 of filter (Method No. 7400 from the NIOSH Manual of Analytical Methods. 3rd edition).
Chapter 6). This information serves as the basis for
selecting the appropriate monitoring equipment and per-
sonal protective equipment (PPE) to use when conducting
site monitoring. Depending on site conditions and project
goals, four categories of site monitoring may be neces-
sary: monitoring for IDLH and other dangerous condi-
tions, general onsite monitoring, perimeter monitoring,
and periodic monitoring.
Monitoring for IDLH and Other Dangerous Conditions
As a first step, air monitoring should be conducted to
identify any IDLH and other dangerous conditions, such
as flammable or explosive atmospheres, oxygen-deficient
environments, and highly toxic levels of airborne con-
taminants. Direct-reading monitoring instruments will nor-
mally include combustible gas indicators, oxygen meters,
colorimetric indicator tubes, and organic vapor monitors.
Other monitoring instruments may be necessary based on
the initial site characterization. When time permits, air
samples should be collected for laboratory analysis.
Extreme caution should be exercised in continuing a site
survey when atmospheric hazards are indicated. Monitor-
ing personnel should be aware that conditions can sud-
denly change from nonhazardous to hazardous.
Acutely hazardous concentrations of chemicals may per-
sist in confined and low-lying spaces for long periods of
time. Look for any natural or artificial barriers, such as
hills, tall buildings, or tanks, behind which air might be
still, allowing concentrations to build up. Examine any
confined spaces such as cargo holds, mine shafts, silos,
storage tanks, box cars, buildings, bulk tanks, and sumps
where chemical exposures capable of causing acute
health effects are likely to accumulata Low-lying areas,
such as hollows and trenches, are also suspect. Monitor
these spaces for IDLH and other dangerous conditions.
Also consider whether the suspected contaminants are
lighter or heavier than air. Then, based on the type of
contaminants present, consider sampling on hilltops,
under any cover or canopy where workers might work or
congregate, and in trenches and low-lying areas.
In open spaces, toxic materials tend to be emitted into
the atmosphere, transported away from the source, and
dispersed. Thus acutely hazardous conditions are not
likely to persist in open spaces for extended periods of
time unless there is a very large (and hence, readily iden-
tifiable) source, such as an overturned tankcar. Open
spaces are therefore generally given a lower monitoring
priority.
General Onsite Monitoring
Air sampling should be conducted using a variety of
media to identify the major classes of airborne con-
taminants and their concentrations. The following sam-
pling pattern can be used as a guidelina First, after
visually identifying the sources of possible generation,
collect air samples downwind from the designated source
along the axis of the wind direction. Work upwind, until
reaching or getting as close as possible to the source.
Level B protection (see Table 8-6 in Chapter 8) should be
worn during this initial sampling. Levels of protection for
subsequent sampling should be based upon the results
obtained and the potential for an unexpected release of
chemicals.
-------
7-6
Air Monitoring
After reaching the source, or finding the highest concen-
tration, sample cross-axis of the wind direction to deter-
mine the degree of dispersion. Smoke plumes, or plumes
of instrument-detectable airborne substances, may be
released as an aid in this assessment. To ensure that
there is no background interference and that the detected
substance(s) are originating at the identified source, also
collect air samples upwind of the source.
Perimeter Monitoring
Fixed-location monitoring at the "fenceline" or perimeter,
where personal protective equipment is no longer
required, measures contaminant migration away from the
site and enables the Site Safety Officer to evaluate the
integrity of the site's clean areas. Since the fixed-location
samples may reflect exposures either upwind or down-
wind from the site, wind speed and direction data are
needed to interpret the sample results.
carry multiple sampling media because of the added
strain and because it is not usually possible to draw air
through different sampling media using a single portable,
battery-operated pump. Consequently, several days may
be required to measure the exposure of a specific
individual using each of the media [3,4]. Alternatively, if
workers are in teams, a different monitoring device can be
assigned to each team member. Another method is to
place multiple sampling devices on pieces of heavy equip-
ment. While these are not personal samples, they can be
collected very close to the breathing zone of the heavy
equipment operator and thus would be reasonably
representative of personal exposure. These multimedia
samples can yield as much information as several per-
sonal samples [5].
When considering employee monitoring, procedures and
protocols found in OSHA's Industrial Hygiene Technical
Manual may be useful [6].
Periodic Monitoring
Site conditions and thus atmospheric chemical conditions
may change following the initial characterization. For this
reason, monitoring should be repeated periodically, espe-
cially when:
• Work begins on a different portion of the site.
• Different contaminants are being handled.
• A markedly different type of operation is initiated
(e.g., barrel opening as opposed to exploratory well
drilling).
• Workers are handling leaking drums or working in
areas with obvious liquid contamination (e.g., a spill
or lagoon).
Personal Monitoring
The selective monitoring of high-risk workers, i.e., those
who are closest to the source of contaminant generation,
is highly recommended. This approach is based on the
rationale that the probability of significant exposure
varies directly with distance from the source. If workers
closest to the source are not significantly exposed, then
all other workers are, presumably, also not significantly
exposed and probably do not need to be monitored.
Since occupational exposures are linked closely with
active material handling, personal air sampling should not
be necessary until site mitigation has begun. Personal
monitoring samples should be collected in the breathing
zone and, if workers are wearing respiratory protective
equipment, outside the facepiece. These samples repre-
sent the actual inhalation exposure of workers who are
not wearing respiratory protection and the potential
exposure of workers who are wearing respirators. It is
best to use pumps that automatically maintain a constant
flow rate to collect samples, since it is difficult to observe
and adjust pumps while wearing gloves, respirators, and
other personal protective equipment. Pumps should be
protected with disposable coverings, such as small plastic
bags, to make decontamination procedures easier.
Variables of Hazardous Waste Site
Exposure
Complex, multisubstance environments such as those
associated with hazardous waste sites pose significant
challenges to accurately and safely assessing airborne
contaminants. Several independent and uncontrollable
variables, most notably temperature and weather condi-
tions, can affect airborne concentrations. These factors
must be considered when developing an air monitoring
program and when analyzing data. Some demonstrated
variables include:
• Temperature. An increase in temperature increases
the vapor pressure of most chemicals.
• Windspeed. An increase in wind speed can affect
vapor concentrations near a free-standing liquid sur-
face. Dusts and particulate-bound contaminants are
also affected.
• Rainfall. Water from rainfall can essentially cap or
plug vapor emission routes from open or closed con-
tainers, saturated soil, or lagoons, thereby reducing
airborne emissions of certain substances.
• Moisture. Dusts, including finely divided hazardous
solids, are highly sensitive to moisture content.
This moisture content can vary significantly with
respect to location and time and can also affect
the accuracy of many sampling results.
• Vapor emissions. The physical displacement of
saturated vapors can produce short-term, rela-
tively high vapor concentrations. Continuing
evaporation and/or diffusion may produce long-
term low vapor concentrations and may involve
large areas.
• Work activities. Work activities often require the
mechanical disturbance of contaminated
materials, which may change the concentration
and composition of airborne contaminants.
Personal monitoring may require the use of a variety of
sampling media. Unfortunately, single workers cannot
-------
Air Monitoring
7-7
References
1. Hill, R.H. and J.E. Arnold. 1979. A personal air sampler
for pesticides. Arch. Environ. Contam. Toxicol. 8:
621-28.
2. NIOSH. 1984. Manual of Analytical Methods, 4th ed.
National Institute for Occupational Safety and Health,
Cincinnati, OH.
3. Costello, R.J. 1983. U.S. Environmental Protection
Agency Triangle Chemical Site, Bridge City, Texas.
NIOSH Health Hazard Evaluations Determination
Report HETA 83-417-1357. pp. 6-7.
4. Costello, R.J. and J. Melius. 1981. Technical
Assistance Determination Report, Chemical Control,
Elizabeth, New Jersey, TA 80-77. National Institute for
Occupational Safety and Health, Cincinnati, OH.
pp. 20-22.
5. Costello, R.J.; B. Froenberg; and J. Melius. 1981.
Health Hazard Evaluation Determination Report, Rollins
Environmental Services, Baton Rouge, Louisiana, HE
81-37. National Institute for Occupational Safety and
Health, Cincinnati, OH.
6. OSHA. March 30, 1984. Industrial Hygiene Technical
Manual. OSHA Instruction CPL 2-2.20A.
-------
8. Personal Protective Equipment (PPE)
Contents
Introduction 8-1
Developing a PPE Program 8-1
Program Review and Evaluation 8-1
Selection of Respiratory Equipment 8-2
Protection Factor 8-4
Self-Contained Breathing Apparatus (SCBA) 8-5
Supplied-Air Respirators (SARs) 8-6
Combination SCBA/SAR 8-6
Air-Purifying Respirators 8-7
Selection of Protective Clothing and Accessories 8-8
Selection of Chemical-Protective Clothing (CPC) 8-8
Permeation and Degradation 8-8
Heat Transfer Characteristics 8-13
Other Considerations 8-13
Special Conditions 8-13
Selection of Ensembles 8-13
Level of Protection 8-13
PPE Use 8-14
Training 8-15
Work Mission Duration 8-16
Personal Use Factors 8-16
Donning an Ensemble 8-17
Respirator Fit Testing 8-18
In-Use Monitoring 8-18
Doffing an Ensemble 8-18
Clothing Reuse 8-18
Inspection 8-19
Storage 8-19
Maintenance 8-20
Heat Stress and Other Physiological Factors 8-20
Monitoring 8-20
Prevention 8-21
Other Factors 8-21
References 8-23
Introduction
Anyone entering a hazardous waste site must be pro-
tected against potential hazards. The purpose of personal
protective clothing and equipment (PPE)1 is to shield or
isolate individuals from the chemical, physical, and bio-
logic hazards that may be encountered at a hazardous
waste sita Careful selection and use of adequate PPE
should protect the respiratory system, skin, eyes, face,
hands, feet, head, body, and hearing. This chapter
describes the various types of PPE that are appropriate
for use at hazardous waste sites, and provides guidance
in their selection and usa The final section discusses
heat stress and other key physiological factors that must
be considered in connection with PPE use.
'The term PPE is used in this manual to refer to both personal
protective clothing and equipment.
Use of PPE is required by Occupational Safety and Health
Administration (OSHA) regulations in 29 CFR Part 1910
(see Table 8-1) and reinforced by U.S. Environmental Pro-
tection Agency (EPA) regulations in 40 CFR Part 300
which include requirements for all private contractors
working on Superfund sites to conform to applicable
OSHA provisions and any other federal or state safety
requirements deemed necessary by the lead agency over-
seeing the activities.
No single combination of protective equipment and cloth-
ing is capable of protecting against all hazards. Thus PPE
should be used in conjunction with other protective
methods. The use of PPE can itself create significant
worker hazards, such as heat stress, physical and psycho-
logical stress, and impaired vision, mobility, and commu-
nication. In general, the greater the level of PPE
protection, the greater are the associated risks. For any
given situation, equipment and clothing should be
selected that provide an adequate level of protection.
Over-protection as well as under-protection can be haz-
ardous and should be avoided.
Developing a PPE Program
A written PPE program should be established for work at
all hazardous waste sites. (OSHA requires a written pro-
gram for selection and use of respirators [29 CFR Part
1910.134].) Some of the relevant regulations, listed in
Table 8-1, are cited throughout the text. The word "shall"
is used only when the procedure is mandated by law.
The two basic objectives of any PPE program should be
to protect the wearer from safety and health hazards, and
to prevent injury to the wearer from incorrect use and/or
malfunction of the PPE. To accomplish these goals, a
comprehensive PPE program should include hazard iden-
tification; medical monitoring; environmental surveillance;
selection, use, maintenance, and decontamination of PPE;
and training. These subjects are discussed in this chapter
and in Chapters 2, 4, 5, 6, 7, and 10.
The written PPE program should include policy state-
ments, procedures, and guidelines. Copies should be
made available to all employees, and a reference copy
should be available at each work site Technical data on
equipment, maintenance manuals, relevant regulations,
and other essential information should also be made
available
Program Review and Evaluation
The PPE program should be reviewed at least annually.
Elements which should be considered in the review
include:
• A survey of each site to ensure compliance with
regulations applicable to the specific site involved.
• The number of person-hours that workers wear
various protective ensembles.
• Accident and illness experience.
• Levels of exposure.
• Adequacy of equipment selection.
• Adequacy of the operational guidelines.
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8-2
Personal Protective Equipment
Table 8-1. OSHA Standards for Use of PPE
TYPE OF PROTECTION
REGULATION
SOURCE
General
Eye and Face
Noise Exposure
Respiratory
Head
Foot
Electrical Protective
Devices
29 CFR Part 1910.132
29 CFR Part 1910.1000
29 CFR Part 1910.1001-1045
29 CFR Part 1910.133(a)
29 CFR Part 1910.95
29 CFR Part 1910.134
29 CFR Part 1910.135
29 CFR Part 1910.136
29 CFR Part 1910.137
41 CFR Part 50-204.7 General Requirements for Personal
Protective Equipment.
41 CFR Part 50-204.50, except for Table Z-2, the source of
which is American National Standards Institute, Z37 series8.
OSHA Rulemaking.
ANSI Z87.1-19688 Eye and Face Protection.
41 CFR Part 50-204.10 and OSHA Rulemaking.
ANSI Z88.2-19698 Standard Practice for Respiratory Protection.
ANSI Z89.1-19698 Safety Requirements for Industrial Head
Protection.
ANSI Z41.1-19678 Men's Safety Toe Footwear.
ANSI Z9.4-1968. Ventilation and Safe Practices of Abrasive
Blasting Operations.
"American National Standards Institute (ANSI), 1430 Broadway, New York, NY 10018. ANSI regularly updates its standards. The ANSI
standards in this table are those that OSHA adopted in 1971. Since the ANSI standards which were then adopted had been set in
1967-1969, those standards, now required under OSHA, may be less stringent than the most recent ANSI standards.
• Adequacy of decontamination, cleaning, inspection,
maintenance, and storage programs.
• Adequacy and effectiveness of training and fitting
programs.
• Coordination with overall safety and health program
elements.
• The degree of fulfillment of program objectives.
• The adequacy of program records.
• Recommendations for program improvement and
modification.
• Program costs.
The results of the program evaluation should be made
available to employees and presented to top management
so that program adaptations may be implemented.
Selection of Respiratory Equipment
Respiratory protection is of primary importance since
inhalation is one of the major routes of exposure to chem-
ical toxicants. Respiratory protective devices (respirators)
consist of a facepiece connected to either an air source or
an air-purifying devica Respirators with an air source are
called atmosphere-supplying respirators (Figure 8-1) and
consist of two types:
• Self-contained breathing apparatus (SCBAs) which
supply air from a source carried by the user.
• Supplied-air respirators (SARs) which supply air
from a source located some distance away and
connected to the user by an air-line hosa
Supplied-air respirators are sometimes referred to
as air-line respirators.
Air-purifying respirators (Figure 8-2), on the other hand,
do not have a separate air source. Instead, they utilize
ambient air which is "purified" through a filtering
element prior to inhalation.
SCBAs, SARs, and air-purifying respirators are further
differentiated by the type of air flow supplied to the
facepiece:
• Positive-pressure respirators maintain a positive pres-
sure in the facepiece during both inhalation and exha-
lation. The two main types of positive-pressure
respirators are pressure-demand and continuous flow.
In pressure-demand respirators, a pressure regulator
and an exhalation valve on the mask maintain the
mask's positive pressure except during high breath-
ing rates. If a leak develops in a pressure-demand
respirator, the regulator sends a continuous flow of
clean air into the facepiece, preventing penetration by
contaminated ambient air. Continuous-flow respira-
tors (including some SARs and all powered air-
purifying respirators [PAPRs]) send a continuous
stream of air into the facepiece at all times. With
SARs, the continuous flow of air prevents infiltration
by ambient air, but uses the air supply much more
rapidly than with pressure-demand respirators.
Powered air-purifying respirators (PAPRs) are oper-
ated in a positive-pressure continuous-flow mode
utilizing filtered ambient air. (However, at maximal
breathing rates, a negative pressure may be created
in the facepiece of a PAPR.)
• Negative-pressure respirators draw air into the
facepiece via the negative pressure created by user
inhalation. The main disadvantage of negative-
pressure respirators is that if any leaks develop in the
system (i.e., a crack in the hose or an ill-fitting mask
or facepiece), the user draws contaminated air into
the facepiece during inhalation.
When atmosphere-supplying respirators are used, only
those operated in the positive-pressure mode are recom-
mended for work at hazardous waste sites. Table 8-2 lists
the relative advantages and disadvantages of SCBAs,
SARs, and air-purifying respirators.
Different types of facepieces are available for use with
the various types of respirators. The types generally used
at hazardous waste sites are full facepieces and half
masks.
• Full-facepiece masks cover the face from the hairline
to below the chin. They provide eye protection.
• Half masks cover the face from below the chin to
over the nose and do not provide eye protection.
Federal regulations require the use of respirators that have
been tested and approved by the Mine Safety and Health
Administration (MSHA) and NIOSH. Testing procedures
are described in 30 CFR Part 11. Approval numbers are
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Personal Protective Equipment 8-3
Emergency escape SCBA,
hood type
Self-contained
breathing apparatus
(SCBA),
full facepiece
Supplied-air respirator, full facepiece
Figure 8-1. Types of Atmosphere-Supplying Respirators.
Full-facepiece,
dual cartridge
Half-mask, facepiece
mounted cartridge.
Powered air-purifying respirator,
half-mask
Full-facepiece,
chin-mounted canister
Full-facepiece,
harness-mounted canister
Figure 8-2. Types of Air-Purifying Respirators.
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8-4
Personal Protective Equipment
Table 8-2. Relative Advantages and Disadvantages of Respiratory Protective Equipment
TYPE OF RESPIRATOR
ADVANTAGES
DISADVANTAGES
ATMOSPHERE-SUPPLYING
Self-Contained
Breathing Apparatus
(SCBA)
Positive-Pressure
Supplled-AIr Respirator
(SAR) (also called
air-line respirator)
• Provides the highest available level of
protection against airborne contaminants
and oxygen deficiency.
• Provides the highest available level of pro-
tection under strenuous work conditions.
• Enables longer work periods than an SCBA.
• Less bulky and heavy than a SCBA.
SAR equipment weighs less than 5 pounds
(or around 15 pounds if escape SCBA pro-
tection is included).
• Protects against most airborne
contaminants.
• Bulky, heavy (up to 35 pounds).
• Finite air supply limits work duration.
• May impair movement in confined spaces.
• Not approved for use in atmospheres
immediately dangerous to life or health
(IDLH) or in oxygen-deficient atmospheres
unless equipped with an emergency egress
unit such as an escape-only SCBA that can
provide immediate emergency respiratory
protection in case of air-line failure.
• Impairs mobility.
• MSHA/NIOSH certification limits hose
length to 300 feet (90 meters).
• As the length of the hose is increased, the
minimum approved air flow may not be
delivered at the facepiece.
• Air line is vulnerable to damage, chemical
contamination, and degradation. Decon-
tamination of hoses may be difficult.
• Worker must retrace steps to leave work
area.
• Requires supervision/
monitoring of the air supply line.
AIR-PURIFYING
Air-Purifying Respirator
(including powered
air-purifying respirators
[PAPRs])
Enhanced mobility.
Lighter in weight than an SCBA. Generally
weights 2 pounds (1 kg) or less (except for
PAPRs).
Cannot be used in IDLH or oxygen-deficient
atmospheres (less than 19.5 percent
oxygen at sea level).
Limited duration of protection. May be hard
to gauge safe operating time in field
conditions.
Only protects against specific chemicals
and up to specific concentrations.
Use requires monitoring of contaminant
and oxygen levels.
Can only be used (1) against gas and vapor
contaminants with adequate warning
properties, or (2) for specific gases or
vapors provided that the service is known
and a safety factor is applied or if the unit
has an ESLI (end-of-service-life indicator).
clearly written on all approved respiratory equipment;
however, not all respiratory equipment that is marketed is
approved. Periodically, NIOSH publishes a list, entitled
NIOSH Certified Equipment List of all approved respirators
and respiratory components [1].
Protection Factor
The level of protection that can be provided by a respira-
tor is indicated by the respirator's protection factor. This
number, which is determined experimentally by measur-
ing facepiece seal and exhalation valve leakage, indicates
the relative difference in concentrations of substances
outside and inside the facepiece that can be maintained
by the respirator. For example, the protection factor for
full-facepiece air-purifying respirators is 50. This means,
theoretically, that workers wearing these respirators
should be protected in atmospheres containing chemicals
at concentrations that are up to 50 times higher than the
appropriate limits. One source of protection factors for
various types of atmosphere-supplying (SCBA and SAR)
and air-purifying respirators can be found in American
National Standards Institute (ANSI) standard ANSI
Z88.2-1980.
At sites where the identity and concentration of chemi-
cals in air are known, a respirator should be selected with
a protection factor that is sufficiently high to ensure that
the wearer will not be exposed to the chemicals above
the applicable limits. These limits include the American
Conference of Governmental Industrial Hygienists'
Threshold Limit Values (TLVs), OSHA's Permissible
Exposure Limits (PELs), and the NIOSH Recommended
Exposure Limits (RELs) (see Table 6-4 in Chapter 6).
These limits are designed to protect most workers who
may be exposed to chemicals day after day throughout
their working life. The OSHA PELs are legally enforceable
exposure limits, and are the minimum limits of protection
that must be met.
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Personal Protective Equipment
8-5
It should be remembered that the protection provided by
a respirator can be compromised in several situations,
most notably, (1) if a worker has a high breathing rate,
(2) if the ambient temperature is high or low, or (3) if the
worker has a poor facepiece-to-face seal. At high breath-
ing rates, positive-pressure SCBAs and SARs may not
maintain positive pressure for brief periods during peak
inhalation. Also, at high work rates, exhalation valves may
leak. Consequently, positive-pressure respirators working
at high flow rates may offer less protection than when
working at normal rates.
A similar reduction in protection may result from high or
low ambient temperatures. For example, at high tempera-
tures excessive sweat may cause a break in the face-to-
facepiece seal. At very low temperatures, the exhalation
valve and regulator may become ice-clogged due to mois-
ture, in the breath and air. Likewise, a poor facepiece seal
—due to such factors as facial hair, missing teeth, scars,
lack of or improper fit testing, etc.—can result in the
penetration of air contaminants.
Self-Contained Breathing Apparatus (SCBA)
A self-contained breathing apparatus (SCBA) usually con-
sists of a facepiece connected by a hose and a regulator
to an air source (compressed air, compressed oxygen, or
an oxygen-generating chemical) carried by the wearer
(see Figure 8-1). Only positive-pressure SCBAs are recom-
mended for entry into atmospheres that are immediately
dangerous to life and health (IDLH). SCBAs offer protec-
tion against most types and levels of airborne con-
taminants. However, the duration of the air supply is an
important planning factor in SCBA use (see PPE Use later
in this chapter). This is limited by the amount of air car-
ried and its rate of consumption. Also, SCBAs are bulky
and heavy, thus they increase the likelihood of heat stress
and may impair movement in confined spaces. Generally,
only workers handling hazardous materials or operating in
contaminated zones require SCBAs. Under MSHA regula-
tions in 30 CFR Part 11.70(a), SCBAs may be approved
(1) for escape only, or (2) for both entry into and escape
from a hazardous atmosphere. The types of SCBAs and
their relative advantages and disadvantages are described
in Table 8-3.
Table 8-3. Types of Self-Contained Breathing Apparatus (SCBA)
TYPE
DESCRIPTION
ADVANTAGES
DISADVANTAGES
COMMENTS
ENTRY-AND-ESCAPE SCBA
Open-Circuit SCBA
Closed-Circuit SCBA
(Rebreather)
Supplies clean air to
the wearer from a
cylinder. Wearer
exhales air directly to
the atmosphere.
These devices recycle
exhaled gases (C02,
Oj, and nitrogen) by
removing C02 with an
alkaline scrubber and
replenishing the con-
sumed oxygen with
oxygen from a liquid or
gaseous source.
Operated in a positive-
pressure mode, open-
circuit SCBAs provide
the highest respiratory
protection currently
available. A warning
alarm signals when only
20 to 25 percent of the
air supply remains.
Longer operating time
(up to 4 hours), and
lighter weight (21 to
30 Ibs [9.5 to 13.6 kg])
than open-circuit
apparatus.
A warning alarm signals
when only 20 to 25
percent of the oxygen
supply remains.
Oxygen supply is
depleted before the CO2
sorbent scrubber supply,
thereby protecting the
wearer from CO:
breakthrough.
Shorter operating time
(30 to 60 minutes) and
heavier weight (up to 35
Ibs [13.6 kg]) than a
closed-circuit SCBA.
At very cold tempera-
tures, scrubber effi-
ciency may be reduced
and COa breakthrough
may occur.
Units retain the heat
normally exchanged in
exhalation and generate
heat in the C02 scrub-
bing operations, adding
to the danger of heat
stress. Auxiliary cooling
devices may be
required.
When worn outside an
encapsulating suit, the
breathing bag may be
permeated by chemi-
cals, contaminating the
breathing apparatus and
the respirable air.
Decontamination of the
breathing bag may be
difficult.
The 30- to 60-minute
operating time may
vary depending on the
size of the air tank and
the work rate of the
individual.
Positive-pressure
closed-circuit SCBAs
offer substantially
more protection than
negative-pressure
units, which are not
recommended on haz-
ardous waste sites.
While these devices
may be certified as
closed-circuit SCBAs,
NIOSH cannot certify
closed-circuit SCBAs
as positive-pressure
devices due to limita-
tions in certification
procedures currently
defined in 30 CFR
Part 11.
ESCAPE-ONLY SCBA
Supplies clean air to
the wearer from either
an air cylinder or from
an oxygen-generating
chemical. Approved for
escape purposes only.
Lightweight (10 pounds
[4.5 kg] or less), low
bulk, easy to carry.
Available in pressure-
demand and contin-
uous-flow modes.
Cannot be used for
entry.
Provides only 5 to 15
minutes of respiratory
protection, depending
on the model and
wearer breathing rata
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8-6
Personal Protective Equipment
Escape-only SCBAs are frequently continuous-flow
devices with hoods that can be donned to provide
immediate emergency protection. Employers should pro-
vide and ensure that employees carry an escape SCBA
where such emergency protection may be necessary.
Entry-and-escape SCBA respirators give workers
untethered access to nearly all portions of the worksite,
but decrease worker mobility, particularly in confined
areas, due to both the bulk and weight of the units. Their
use is particularly advisable when dealing with unidenti-
fied and unquantified airborne contaminants. There are
two types of entry-and-escape SCBAs: (1) open-circuit
and (2) closed-circuit. In an open-circuit SCBA, air is
exhaled directly into the ambient atmosphere. In a closed-
circuit SCBA, exhaled air is recycled by removing the car-
bon dioxide with an alkaline scrubber and by replenishing
the consumed oxygen with oxygen from a solid, liquid, or
gaseous source.
As required by MSHA/NIOSH 30 CFR Part 11.80, all com-
pressed breathing gas cylinders must meet minimum U.S.
Department of Transportation requirements for interstate
shipment. (For further information, see 49 CFR Parts 173
and 178.) All compressed air, compressed oxygen, liquid
air, and liquid oxygen used for respiration shall be of high
purity and must meet all requirements of OSHA 29 CFR
Part 1910.134(d). In addition, breathing air must meet or
exceed the requirements of Grade D breathing air as
specified in the Compressed Gas Association pamphlet
G-7.1 and ANSI Z86.1-1973.
Key questions to ask when considering whether an SCBA
is appropriate are:
• Is the atmosphere IDLH or is it likely to become
IDLH? If yes, a positive-pressure SCBA should be
used. A positive-pressure SAR with an escape SCBA
can also be used.
• Is the duration of air supply sufficient for accomplish-
ing the necessary tasks? If no, a larger cylinder
should be used, a different respirator should be
chosen, and/or the Work Plan should be modified.
• Will the bulk and weight of the SCBA interfere with
task performance or cause unnecessary stress? If
yes, use of an SAR may be more appropriate if condi-
tions permit.
• Will temperature effects compromise respirator effec-
tiveness or cause added stress in the worker? If yes,
the work period should be shortened or the mission
postponed until the temperature changes.
Supplied-Air Respirators (SARs)
Supplied-air respirators (also known as air-line respirators)
supply air, never oxygen, to a facepiece via a supply line
from a stationary source (see Figure 8-1). SARs are availa-
ble in positive-pressure and negative-pressure modes.
Pressure-demand SARs with escape provisions provide
the highest level of protection (among SARs) and are the
only SARs recommended for use at hazardous waste
sites. SARs are not recommended for entry into IDLH
atmospheres (MSHA/NIOSH 30 CFR Part 11) unless the
apparatus is equipped with an escape SCBA.
The air source for supplied-air respirators may be com-
pressed air cylinders or a compressor that purifies and
delivers ambient air to the facepiece. SARs suitable for
use with compressed air are classified as "Type C"
supplied-air respirators as defined in MSHA/NIOSH 30
CFR Part 11. All SAR couplings must be incompatible with
the outlets of other gas systems used on site to prevent a
worker from connecting to an inappropriate compressed
gas source (OSHA 29 CFR 1910.134[d]).
SARs enable longer work periods than do SCBAs and are
less bulky. However, the air line impairs worker mobility
and requires workers to retrace their steps when leaving
the area. Also, the air line is vulnerable to puncture from
rough or sharp surfaces, chemical permeation, damage
from contact with heavy equipment, and obstruction
from falling drums, etc. To the extent possible, all such
hazards should be removed prior to use. When in use, air
lines should be kept as short as possible (300 feet [91
meters] is the longest approved hose length for SARs),
and other workers and vehicles should be kept away from
the air line.
The use of air compressors as the air source for an SAR
at a hazardous waste site is severely limited by the same
concern that requires workers to wear respirators: that is,
the questionable quality of the ambient air. Onsite com-
pressor use is limited by OSHA standards (29 CFR Part
1910.134[d]).
Key questions to ask when considering SAR use are:
• Is the atmosphere IDLH or likely to become IDLH? If
yes, an SAR/SCBA combination or SCBA should be
used.
• Will the hose significantly impair worker mobility? If
yes, the work task should be modified or other
respiratory protection should be used.
• Is there a danger of the air line being damaged or
obstructed (e.g., by heavy equipment, falling drums,
rough terrain, or sharp objects) or permeated and/or
degraded by chemicals (e.g., by pools of chemicals)?
If yes, either the hazard should be removed or
another form of respiratory protection should be
used.
• If a compressor is the air source, is it possible for air-
borne contaminants to enter the air system? If yes,
have the contaminants been identified and are effi-
cient filters and/or sorbents available that are capable
of removing those contaminants? If no, either
cylinders should be used as the air source or another
form of respiratory protection should be used.
• Can other workers and vehicles that might interfere
with the air line be kept away from the area? If no,
another form of respiratory protection should be
used.
Combination SCBA/SAR
A relatively new type of respiratory protection is available
that uses a regulator to combine the features of an SCBA
with an SAR. The user can operate the respirator in the
SCBA or SAR mode, through either the manual or auto-
matic switching of air sources. This type of respirator
allows entry into and exit from an area using the self-
contained air supply, as well as extended work periods
within a contaminated area while connected to the air
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Personal Protective Equipment
8-7
line. It is particularly appropriate for sites where workers
must travel an extended distance to a work area within a
hot zone and remain within that area for relatively long
work periods (e.g., drum sampling). In such situations,
workers would enter the site using the SCBA mode, con-
nect to the air line during the work period, and shift back
to the SCBA mode to leave the site.
The combination SCBA/SAR should not be confused with
an SAR with escape provisions. The primary difference is
the length of air time provided by the SCBA; the combina-
tion system provides up to 60 minutes of self-contained
air, whereas the escape SCBA contains much less air,
generally enough for only 5 minutes. NIOSH certification
of the combination unit allows up to 20 percent of the
available air time to be used during entry, while the SAR
with escape provision is certified for escape only.
Air-Purifying Respirators
Air-purifying respirators consist of a facepiece and an air-
purifying device, which is either a removable component
of the facepiece or an air-purifying apparatus worn on a
body harness and attached to the facepiece by a cor-
rugated breathing hose (see Figure 8-2). Air-purifying
respirators selectively remove specific airborne con-
taminants (particulates, gases, vapors, fumes) from
ambient air by filtration, absorption, adsorption, or chemi-
cal reactions. They are approved for use in atmospheres
containing specific chemicals up to designated concentra-
tions, and not for IDLH atmospheres. Air-purifying res-
pirators have limited use at hazardous waste sites and
can be used only when the ambient atmosphere contains
sufficient oxygen (19.5 percent) (30 CFR Part 11.90[a]).
Table 8-4 lists conditions that may exclude the use of air-
purifying respirators.
Table 8-4. Conditions That Exclude or May Exclude Use of
Air-Purifying Respirators
• Oxygen deficiency.
• IDLH concentrations of specific substances.
• Entry into an unventilated or confined area where the exposure
conditions have not been characterized.
• Presence or potential presence of unidentified contaminants.
• Contaminant concentrations are unknown or exceed designated
maximum use concentration (s).
• Identified gases or vapors have inadequate warning properties and
the sorbent service life is not known and the unit has no
end-of-service-life (ESLI) indicator.
• High relative humidity (may reduce the protection offered by the
sorbent).
Air-purifying respirators usually operate only in the
negative-pressure mode except for powered air-purifying
respirators (PAPRs) which maintain a positive facepiece
pressure (except at maximal breathing rates). There ace
three types of air-purifying devices: (1) participate filters;
(2) cartridges and canisters, which contain sorbents for
specific gases and vapors; and (3) combination devices.
Their efficiencies vary considerably even for closely
related materials [2].
Cartridges usually attach directly to the respirator
facepiece. The larger-volume canisters attach to the chin
of the facepiece or are carried with a harness and
attached to the facepiece by a breathing tube. Combina-
tion canisters and cartridges contain layers of different
sorbent materials and remove multiple chemicals or
multiple classes of chemicals from the ambient air.
Though approved against more than one substance, these
canisters and cartridges are tested independently against
single substances. Thus, the effectiveness of these
canisters against two or more substances has not been
demonstrated. Filters may also be combined with car-
tridges to provide additional protection against particu-
lates. A number of standard cartridges and canisters are
commercially available. They are color-coded to indicate
the general chemicals or classes of chemicals against
which they are effective (29 CFR Part 1910.134[g]).
MSHA and NIOSH have granted approvals for manufac-
turers' specific assemblies of air-purifying respirators for a
limited number of specific chemicals. Respirators should
be used only for those substances for which they have
been approved. Use of a sorbent shall not be allowed
when there is reason to suspect that it does not provide
adequate sorption efficiency against a specific con-
taminant. In addition, it should be noted that approval
testing is performed at a given temperature and over a
narrow range of flow rates and relative humidities [3];
thus protection may be compromised in nonstandard con-
ditions. The assembly that has been approved by MSHA
and NIOSH to protect against organic vapors is tested
against only a single challenge substance, carbon tetrach-
loride; its effectiveness for protecting against other
vapors has not been demonstrated.
Most chemical sorbent canisters are imprinted with an
expiration date. They may be used up to that date as long
as they were not opened previously. Once opened, they
begin to sorb humidity and air contaminants whether or
not they are in use Their efficiency and service life
decreases and therefore they should be used immediately.
Cartridges should be discarded after use but should not
be used for longer than one shift or when breakthrough
occurs, whichever comes first.
Where a canister or cartridge is being used against gases
or vapors, the appropriate device shall be used only if the
chemical (s) have "adequate warning properties" (30 CFR
Part 11.150). NIOSH considers a substance to have ade-
quate warning properties when its odor, taste, or irritant
effects are detectable and persistent at concentrations
below the recommended exposure limit (RED (see Chap-
ter 6). A substance is considered to have poor warning
properties when its odor or irritation threshold is above
the applicable exposure limit. Warning properties are
essential to safe use of air-purifying respirators since they
allow detection of contaminant breakthrough, should it
occur. While warning properties are not foolproof,
because they rely on human senses which vary widely
among individuals and in the same individual under vary-
ing conditions (e.g., olfactory fatigue), they do provide
some indication of possible sorbent exhaustion, poor
facepiece fit, or other malfunctions. OSHA permits the
use of air-purifying respirators for protection against
specific chemicals with poor warning properties provided
that (1) the service life of the sorbent is known and a
safety factor has been applied or (2) the respirator has an
approved end-of-service-life indicator.
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8-8
Personal Protective Equipment
Selection of Protective Clothing
and Accessories
In this manual, personal protective clothing is considered
to be any article offering skin and/or body protection. It
includes:
• Fully-encapsulating suits.
• Non-encapsulating suits.
• Aprons, leggings, and sleeve protectors.
• Gloves.
• Firefighters' protective clothing.
• Proximity, or approach, garments.
• Blast and fragmentation suits.
• Cooling garments.
• Radiation-protective suits.
Each type of protective clothing has a specific purpose;
many, but not all, are designed to protect against chemi-
cal exposure. Examples of protective clothing are shown
in Figure 8-3. Table 8-5 describes various types of protec-
tive clothing available, details the type of protection they
offer, and lists the factors to consider in their selection
and use This table also describes a number of accesso-
ries that might be used in conjunction with a PPE ensem-
ble, namely:
• Knife.
• Flashlight or lantern.
• Personal locator beacon.
• Personal dosimeters.
• Two-way radio.
• Safety belts and lines.
Selection of Chemical-Protective Clothing (CPC)
Chemical-protective clothing (CPC) is available in a vari-
ety of materials that offer a range of protection against
different chemicals. The most appropriate clothing mate-
rial will depend on the chemicals present and the task to
be accomplished. Ideally, the chosen material resists
permeation, degradation, and penetration. Permeation is
the process by which a chemical dissolves in and/or
moves through a protective clothing material on a
molecular level. Degradation is the loss of or change in
the fabric's chemical resistance or physical properties due
to exposure to chemicals, use, or ambient conditions (e.g.,
sunlight). Penetration is the movement of chemicals
through zippers, stitched seams or imperfections (e^.,
pinholes) in a protective clothing material.
Selection of chemical-protective clothing is a complex
task and should be performed by personnel with training
and experience. Under all conditions, clothing is selected
by evaluating the performance characteristics of the
clothing against the requirements and limitations of the
site- and task-specific conditions. If possible, representa-
tive garments should be inspected before purchase and
their use and performance discussed with someone who
has experience with the clothing under consideration. In
all cases, the employer is responsible for ensuring that
the personal protective clothing (and all PPE) necessary to
Fully-encapsulating suit
Apron, gloves, hardhat,
faceshield, boot covers
Figure 8-3. Examples of Protective Clothing.
protect employees from injury or illness that may result
from exposure to hazards at the work site is adequate and
of safe design and construction for the work to be per-
formed (see OSHA standard 29 CFR Part 1910.132-
1910.137).
Permeation and Degradation
The selection of chemical-protective clothing depends
greatly upon the type and physical state of the con-
taminants. This information is determined during site
characterization (Chapter 6). Once the chemicals have
been identified, available information sources should be
consulted to identify materials that are resistant to
permeation and degradation by the known chemicals.
One excellent reference, Guidelines for the Selection of
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Personal Protective Equipment
8-9
Table 8-5. Protective Clothing and Accessories
BODY PART
PROTECTED
TYPE OF CLOTHING
OR ACCESSORY
DESCRIPTION
TYPE OF PROTECTION
USE CONSIDERATIONS
Full Body
Fully-encapsulating
suit
One-piece garment. Boots
and gloves may be integral,
attached and replaceable, or
separate.
Protects against splashes,
dust, gases, and vapors.
Does not allow body heat to
escape. May contribute to
heat stress in wearer, par-
ticularly if worn in conjunc-
tion with a closed-circuit
SCBA; a cooling garment
may be needed. Impairs
worker mobility, vision, and
communication.
Non-encapsulating
suit
Jacket, hood, pants, or bib
overalls, and one-piece
coveralls.
Protects against splashes,
dust, and other materials
but not against gases and
vapors. Does not protect
parts of head or neck.
Do not use where gas-tight
or pervasive splashing
protection is required.
May contribute to heat
stress in wearer.
Tape-seal connections
between pant cuffs and
boots and between gloves
and sleeves.
Aprons, leggings,
and sleeve
protectors
Fully sleeved and gloved
apron.
Separate coverings for arms
and legs.
Commonly worn over non-
encapsulating suit.
Provides additional splash
protection of chest, fore-
arms, and legs.
Whenever possible, should
be used over a non-encap-
sulating suit (instead of
using a fully-encapsulating
suit) to minimize potential
for heat stress.
Useful for sampling, label-
ing, and analysis opera-
tions. Should be used only
when there is a low proba-
bility of total body contact
with contaminants.
Firefighters'
protective clothing
Gloves, helmet, running or
bunker coat, running or
bunker pants (NFPA No.
1971, 1972, 1973), and
boots.
Protects against heat, hot
water, and some particles.
Does not protect against
gases and vapors, or
chemical permeation or
degradation. NFPA Stan-
dard No. 1971 specifies
that a garment consist of
an outer shell, an inner
liner, and a vapor barrier
with a minimum water
penetration of 25 Ibs/in2
(1.8 kg/cm2) to prevent
the passage of hot water.
Decontamination is difficult.
Should not be worn in areas
where protection against
gases, vapors, chemical
splashes, or permeation is
required.
Proximity garment
(approach suit)
One- or two-piece
overgarment with boot
covers, gloves, and hood of
aluminized nylon or cotton
fabric.
Normally worn over other
protective clothing, such as
chemical-protective cloth-
ing, firefighters' bunker
gear, or flame-retardant
coveralls.
Protects against brief
exposure to radiant heat.
Does not protect against
chemical permeation or
degradation.
Can be custom-
manufactured to protect
against some chemical
contaminants.
Auxiliary cooling and an
SCBA should be used if the
wearer may be exposed to a
toxic atmosphere or needs
more than 2 or 3 minutes of
protection.
Blast and
fragmentation suit
Blast and fragmentation
vests and clothing; bomb
blankets, and bomb carriers.
Provides some protection
against very small detona-
tions. Bomb blankets and
baskets can help redirect
a blast.
Does not provide
hearing protection.
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8-10
Personal Protective Equipment
Table 8-5. (cont.)
BODY PART
PROTECTED
TYPE OF CLOTHING
OR ACCESSORY
DESCRIPTION
TYPE OF PROTECTION
USE CONSIDERATIONS
Full Body
(cont.)
Radiation-
contamination pro-
tective suit
Various types of protective
clothing designed to
prevent contamination of
the body by radioactive
particles.
Protects against alpha
and beta particles. Does
NOT protect against
gamma radiation.
Designed to prevent skin
contamination. If radiation
is detected on site, consult
an experienced radiation
expert and evacuate person-
nel until the radiation haz-
ard has been evaluated.
Flame/fire retardant
coveralls
Normally worn as an
undergarment.
Provides protection from
flash fires.
Adds bulk and may exacer-
bate heat stress problems
and impair mobility.
Flotation gear
Life jackets or work vests.
(Commonly worn under-
neath chemical protective
clothing to prevent flotation
gear degradation by
chemicals.)
Adds 15.5 to 25 Ibs (7 to
11.3 kg) of buoyancy to
personnel working in or
around water.
Adds bulk and restricts
mobility.
Must meet USCG standards
(46 CFR Part 160).
Cooling garment
One of three methods:
(1) A pump circulates cool
dry air throughout the suit
or portions of it via an air
Una Cooling may be
enhanced by use of a vor-
tex cooler, refrigeration
coils, or a heat exchanger.
(2) A jacket or vest having
pockets into which packets
of ice are inserted.
(3) A pump circulates
chilled water from a
water/ice reservoir and
through circulating tubes,
which cover part of the
body (generally the upper
torso only).
Removes excess heat
generated by worker
activity, the equipment, or
the environment.
(1) Pumps circulating cool
air require 10 to 20 ft3 (0.3
to 0.6 m3) of respirable air
per minute, so they are
often uneconomical for use
at a waste sita
(2) Jackets or vests pose
ice storage and recharge
problems.
(3) Pumps circulating
chilled water pose ice stor-
age problems. The pump
and battery add bulk and
weight.
Head
Safety helmet (hard
hat)
For example, a hard plastic
or rubber helmet.
Protects the head from
blows.
Helmet shall meet OSHA
standard 29 CFR Part
1910.135.
Helmet liner
Insulates against cold.
Does not protect against
chemical splashes.
Hood
Commonly worn with a
helmet.
Protects against chemical
splashes, participates,
and rain.
Protective hair
covering
Protects against chemical
contamination of hair.
Prevents the entangle-
ment of hair in machinery
or equipment.
Prevents hair from inter-
fering with vision and
with the functioning of
respiratory protective
devices.
Particularly important for
workers with long hair.
Eyes and
Face*
Face shield
Full-face coverage,
eight-inch minimum.
Protects against chemical
splashes.
Does not protect ade-
quately against
projectiles.
Face shields and splash
hoods must be suitably sup-
ported to prevent them from
shifting and exposing por-
tions of the face or obscur-
ing vision. Provides limited
eye protection.
8AII eye and face protection must meet OSHA standard 29 CFR Part 1910.133.
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Personal Protective Equipment
8-11
Table 8-5. (cont.)
BODY PART
PROTECTED
TYPE OF CLOTHING
OR ACCESSORY
DESCRIPTION
TYPE OF PROTECTION
USE CONSIDERATIONS
Eyes and
Face (cont.)
Splash hood
Protects against chemical
splashes.
Does not protect
adequately against
projectiles.
Safety glasses
Protect eyes against large
particles and projectiles.
If lasers are used to survey
a site, workers should wear
special protective lenses.
Goggles
Depending on their con-
struction, goggles can
protect against vaporized
chemicals, splashes, large
particles, and projectiles
(if constructed with
impact-resistant lenses).
Sweat bands
Prevents sweat-induced
eye irritation and vision
impairment.
Ears
Ear plugs and muffs
Protect against physiolog-
ical damage and psycho-
logical disturbance
Must comply with OSHA
regulation 29 CFR Part
1910.95. Can interfere with
communication.
Use of ear plugs should be
carefully reviewed by a
health and safety profes-
sional because chemical
contaminants could be
introduced into the ear.
Headphones
Radio headset with throat
microphone.
Provide some hearing
protection while enabling
communication.
Highly desirable, particularly
if emergency conditions
arisa
Hands and
Arms
Gloves and sleeves
May be integral, attached,
or separate from other
protective clothing.
Protect hands and arms
from chemical contact.
Wear jacket cuffs over glove
cuffs to prevent liquid from
entering the glove.
Tape-seal gloves to sleeves
to provide additional
protection.
Overgloves.
Provide supplemental pro-
tection to the wearer and
protect more expensive
undergarments from abra-
sions, tears, and
contamination.
Disposable gloves.
Should be used whenever
possible to reduce decon-
tamination needs.
Foot
Safety boots
Boots constructed of
chemical-resistant material.
Protect feet from contact
with chemicals.
Boots constructed with
some steel materials (ag.,
toes, shanks, insoles).
Protect feet from com-
pression, crushing, or
puncture by falling, mov-
ing, or sharp objects.
All boots must at least meet
the specifications required
under OSHA 29 CFR Part
1910.136 and should pro-
vide good traction.
Boots constructed from
nonconductive, spark-
resistant materials or
coatings.
Protect the wearer
against electrical hazards
and prevent ignition of
combustible gases or
vapors.
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8-12
Personal Protective Equipment
Table 8-5. (cont.)
BODY PART
PROTECTED
TYPE OF CLOTHING
OR ACCESSORY
DESCRIPTION
TYPE OF PROTECTION
USE CONSIDERATIONS
Foot (cont.)
Disposable shoe or
boot covers
Made of a variety of
materials. Slip over the
shoe or boot.
Protect safety boots from
contamination.
Protect feet from contact
with chemicals.
Covers may be disposed of
after use, facilitating
decontamination.
General
Knife
Allows a person in a fully-
encapsulating suit to cut
his or her way out of the
suit in the event of an
emergency or equipment
failure.
Should be carried and used
with caution to avoid
puncturing the suit.
Flashlight or lantern
Enhances visibility in
buildings, enclosed
spaces, and the dark.
Must be intrinsically safe or
explosion-proof for use in
combustible atmospheres.
Sealing the flashlight in a
plastic bag facilitates
decontamination.
Only electrical equipment
approved as intrinsically
safe, or approved for the
class and group of hazard
as defined in Article 500 of
the National Electrical Code,
may be used.
Personal dosimeter
Measures worker expo-
sure to ionizing radiation
and to certain chemicals.
To estimate actual body
exposure, the dosimeter
should be placed inside the
fully-encapsulating suit.
Personal locator
beacon
Operated by sound, radio,
or light.
Enables emergency per-
sonnel to locate victim.
Two-way radio
Enables field workers of
communicate with per-
sonnel in the Support
Zona
Safety belts, har-
nesses, and lifelin-
Enable personnel to work
in elevated areas or enter
confined areas and pre-
vent falls. Belts may be
used to carry tools and
equipment.
Must be constructed of
spark-free hardware and
chemical-resistant materials
to provide proper protec-
tion. Must meet OSHA
standards in 29 CFR Part
1926.104.
Chemical-Protective Clothing [4], provides a matrix of
clothing material recommendations for approximately 300
chemicals based on an evaluation of permeation and
degradation data from independent tests, vendor litera-
ture, and raw material suppliers. Charts indicating the
resistance of various clothing materials to permeation and
degradation are also available from manufacturers and
other sources. It is important to note, however, that no
material protects against all chemicals and combinations
of chemicals, and that no currently available material is an
effective barrier to any prolonged chemical exposure.
In reviewing vendor literature, it is important to be aware
that the data provided are of limited value. For example,
the quality of vendor test methods is inconsistent; ven-
dors often rely on the raw material manufacturers for data
rather than conducting their own tests; and the data may
not be updated. In addition, vendor data cannot address
the wide variety of uses and challenges to which CPC
may be subjected. Most vendors strongly emphasize this
point in the descriptive text that accompanies their data.
Another factor to bear in mind when selecting CPC is that
the rate of permeation is a function of several factors,
including clothing material type and thickness, manufac-
turing method, the concentration(s) of the hazardous sub-
stance(s), temperature, pressure, humidity, the solubility
of the chemical in the clothing material, and the diffusion
coefficient of the permeating chemical in the clothing
material. Thus permeation rates and breakthrough time
(the time from initial exposure until hazardous material is
detectable on the inside of the CPC) may vary depending
on these conditions.
Most hazardous wastes are mixtures, for which specific
data with which to make a good CPC selection are not
availabla Due to a lack of testing, only limited permeation
data for multicomponent liquids are currently available.
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Personal Protective Equipment
8-13
Mixtures of chemicals can be significantly more aggres-
sive towards CPC materials than can any single compo-
nent alona Even small amounts of a rapidly permeating
chemical may provide a pathway that accelerates the
permeation of other chemicals [4]. Formal research is
being conducted on these effects. NIOSH is currently
developing methods for evaluating CPC materials against
mixtures of chemicals and unknowns in the field. For haz-
ardous waste site operations, CPC should be selected
that offers the widest range of protection against the
chemicals expected on site. Vendors are now providing
CPC material—composed of two or even three different
materials laminated together—that is capable of providing
the best features of each material.
Heat Transfer Characteristics
The heat transfer characteristics of CPC may be an impor-
tant factor in selection. Since most chemical-protective
clothing is virtually impermeable to moisture, evaporative
cooling is limited. The "clo" value (thermal insulation
value) of chemical-protective clothing is a measure of the
capacity of CPC to dissipate heat loss through means
other than evaporation. The larger the clo value, the
greater the insulating properties of the garment and, con-
sequently, the lower the heat transfer [5]. Given other
equivalent protective properties, clothing with the lowest
clo value should be selected in hot environments or for
high work rates. Unfortunately, clo values for clothing are
rarely available at present.
Other Considerations
In addition to permeation, degradation, penetration, and
heat transfer, several other factors must be considered
during clothing selection. These affect not only chemical
resistance, but also the worker's ability to perform the
required task. The following checklist summarizes these
considerations.
• Durability:
Does the material have sufficient strength to with-
stand the physical stress of the task(s) at hand?
Will the material resist tears, punctures, and
abrasions?
Will the material withstand repeated use after con-
tamination/decontamination?
• Flexibility:
Will the CPC interfere with the workers' ability to
perform their assigned tasks (this is particularly
important to consider for gloves)?
• Temperature effects:
Will the material maintain its protective integrity
and flexibility under hot and cold extremes?
• Ease of decontamination:
Are decontamination procedures available on site?
Will the material pose any decontamination
problems?
Should disposable clothing be used?
• Compatibility with other equipment:
Does the clothing preclude the use of another,
necessary piece of protective equipment (e.g., suits
that preclude hardhat use in hardhat area)?
• Duration of use:
Can the required task be accomplished before con-
taminant breakthrough occurs, or degradation of
the CPC becomes significant?
Special Conditions
Fire, explosion, heat, and radiation are considered special
conditions that require special-protective equipment.
Unique problems are associated with radiation and it is
beyond the scope of this manual to discuss them
properly. A qualified health physicist should be consulted
if a radiation hazard exists. Special-protective equipment
is described in Table 8-5 (see Full Body section of the
table). When using special-protective equipment, it is
important to also provide protection against chemicals,
since the specialized equipment may provide little or no
protection against chemicals which may also be present.
Selection of Ensembles
Level of Protection
The individual components of clothing and equipment
must be assembled into a full protective ensemble that
both protects the worker from the site-specific hazards
and minimizes the hazards and drawbacks of the PPE
ensemble itself.
Table 8-6 lists ensemble components based on the widely
used EPA Levels of Protection: Levels A, B, C, and D.
These lists can be used as a starting point for ensemble
creation; however, each ensemble must be tailored to the
specific situation in order to provide the most appropriate
level of protection. For example, if work is being con-
ducted at a highly contaminated site or if the potential for
contamination is high, it may be advisable to wear a dis-
posable covering, such as Tyvek coveralls or PVC splash
suits, over the protective ensemble. It may be necessary
to slit the back of these disposable suits to fit around the
bulge of an encapsulating suit and SCBA [6].
The type of equipment used and the overall level of pro-
tection should be reevaluated periodically as the amount
of information about the site increases, and as workers
are required to perform different tasks. Personnel should
be able to upgrade or downgrade their level of protection
with concurrence of the Site Safety Officer and approval
of the Field Team Leader.
Reasons to upgrade:
• Known or suspected presence of dermal hazards.
• Occurrence or likely occurrence of gas or vapor
emission.
• Change in work task that will increase contact or
potential contact with hazardous materials.
• Request of the individual performing the task.
Reasons to downgrade:
• New information indicating that the situation is less
hazardous than was originally thought.
• Change in site conditions that decreases the hazard.
• Change in work task that will reduce contact with
hazardous materials.
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8-14
Personal Protective Equipment
Table 8-6. Sample Protective Ensembles8
LEVEL OF
PROTECTION EQUIPMENT
PROTECTION PROVIDED SHOULD BE USED WHEN:
LIMITING CRITERIA
RECOMMENDED:
• Pressure-demand, full-facepiece
SCBA or pressure-demand sup-
plied-air respirator with escape
SCBA.
• Fully-encapsulating, chemical-
resistant suit.
• Inner chemical-resistant gloves.
• Chemical-resistant safety boots/
shoes.
• Two-way radio communications.
OPTIONAL:
• Cooling unit.
• Coveralls.
• Long cotton underwear.
• Hard hat.
• Disposable gloves and boot
covers.
The highest available level
of respiratory, skin, and
eye protection.
The chemical substance has
been identified and requires the
highest level of protection for
skin, eyes, and the respiratory
system based on either:
— measured (or potential for)
high concentration of atmos-
pheric vapors, gases, or
particulates
or
— site operations and work
functions involving a high
potential for splash, immer-
sion, or exposure to unex-
pected vapors, gases, or
particulates of materials that
are harmful to skin or capable
of being absorbed through
the intact skin.
> Substances with a high degree
of hazard to the skin are known
or suspected to be present, and
skin contact is possibla
' Operations must be conducted
in confined, poorly ventilated
• areas until the absence of con-
ditions requiring Level A
protection is determined.
Fully-encapsulating
suit material must
be compatible with
the substances
involved.
B RECOMMENDED:
• Pressure-demand, full-facepiece
SCBA or pressure-demand sup-
plied-air respirator with escape
SCBA.
• Chemical-resistant clothing
(overalls and long-sleeved
jacket; hooded, one- or two-
piece chemical splash suit;
disposable chemical-resistant
one-piece suit).
• Inner and outer chemi-
cal-resistant gloves.
• Chemical-resistant safety
boots/shoes.
• Hard hat.
• Two-way radio communications.
OPTIONAL:
• Coveralls.
• Disposable boot covers.
• Face shield.
• Long cotton underwear.
•Based on EPA protective ensembles.
The same level of respir-
atory protection but less
skin protection than
Level A.
It is the minimum level
recommended for initial
site entries until the
hazards have been further
identified.
The type and atmospheric con-
centration of substances have
been identified and require a
high level of respiratory pro-
tection, but less skin protection.
This involves atmospheres:
— with IDLH concentrations of
specific substances that do
not represent a severe skin
hazard;
or
— that do not meet the criteria
for use of air-purifying
respirators.
1 Atmosphere contains less than
19.5 percent oxygen.
1 Presence of incompletely identi-
fied vapors or gases is indicated
by direct-reading organic vapor
detection instrument, but vapors
and gases are not suspected of
containing high levels of
chemicals harmful to skin or
capable of being absorbed
through the intact skin.
Use only when the
vapor or gases
present are not
suspected of con-
taining high con-
centrations of
chemicals that are
harmful to skin or
capable of being
absorbed through
the intact skin.
1 Use only when it is
highly unlikely that
the work being
done will generate
either high concen-
trations of vapors,
gases, or particu-
lates or splashes
of material that
will affect exposed
skin.
PPE Use
PPE can offer a high degree of protection only if it is used
properly. This section covers the following aspects of PPE
use:
• Training.
• Work mission duration.
• Personal use factors.
• Fit testing.
• Donning.
• In-use monitoring.
• Doffing.
• Inspection.
• Storaga
• Maintenance.
Decontamination is covered in Chapter 10. Inadequate
attention to any of these areas could compromise the pro-
tection provided by the PPE.
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Personal Protective Equipment
8-15
Table 8-6. (cont.)
LEVEL OF
PROTECTION EQUIPMENT
PROTECTION PROVIDED SHOULD BE USED WHEN:
LIMITING CRITERIA
RECOMMENDED:
• Full-facepiece, air-purifying,
canister-equipped respirator.
• Chemical-resistant clothing
(overalls and long-sleeved
jacket; hooded, one- or two-
piece chemical splash suit;
disposable chemical-resistant
one-piece suit).
• Inner and outer chemi-
cal-resistant gloves.
• Chemical-resistant safety boots/
shoes.
• Hard hat.
• Two-way radio communications.
OPTIONAL:
• Coveralls.
• Disposable boot covers.
• Face shield.
• Escape mask.
• Long cotton underwear.
The same level of skin
protection as Level B, but
a lower level of
respiratory protection.
1 The atmospheric contaminants,
liquid splashes, or other direct
contact will not adversely affect
any exposed skin.
1 The types of air contaminants
have been identified, concentra-
tions measured, and a canister is
available that can remove the
contaminant.
All criteria for the use of air-
purifying respirators are met.
• Atmospheric
concentration of
chemicals must
not exceed IDLH
levels.
• The atmosphere
must contain at
least 19.5 percent
oxygen.
RECOMMENDED:
• Coveralls.
• Safety boots/shoes.
• Safety glasses or chemical
splash goggles.
• Hard hat.
OPTIONAL:
• Gloves.
• Escape mask.
• Face shield.
No respiratory protection.
Minimal skin protection.
1 The atmosphere contains no
known hazard.
1 Work functions preclude
splashes, immersion, or the
potential for unexpected
inhalation of or contact with
hazardous levels of any
chemicals.
1 This level should
not be worn in the
Exclusion Zona
The atmosphere
must contain at
least 19.5 percent
oxygen.
Training
Training in PPE use is recommended and, for respirators,
required by federal regulation in the OSHA standards in
29 CFR Part 1910 Subparts I and Z. This training:
• Allows the user to become familiar with the equip-
ment in a nonhazardous situation.
• Instills confidence of the user in his/her equipment.
• Makes the user aware of the limitations and capabili-
ties of the equipment.
• Increases the efficiency of operations performed by
workers wearing PPE.
• May increase the protective efficiency of PPE use.
• Reduces the expense of PPE maintenance.
Training should be completed prior to actual PPE use in a
hazardous environment and should be repeated at least
annually. At a minimum, the training portion of the PPE-,
program should delineate the user's responsibilities and
explain the following, utilizing both classroom and field
training when necessary:
• OSHA requirements as delineated in 29 CFR Part
1910 Subparts I and Z.
• The proper use and maintenance of the selected PPE,
including capabilities and limitations.
• The nature of the hazards and the consequences of
not using the PPE.
• The human factors influencing PPE performance
• Instruction in inspecting, donning, checking, fitting,
and using PPE.
• Individualized respirator fit testing to ensure proper
fit.
• Use of PPE in normal air for a long familiarity period
and, finally, wearing PPE in a test atmosphere to
evaluate its effectiveness.
• The user's responsibility (if any) for decontamination,
cleaning, maintenance, and repair of PPE.
• Emergency procedures and self-rescue in the event of
PPE failure.
• The buddy system (see Chapter 9, Site Control).
• The Site Safety Plan and the individual's responsibili-
ties and duties in an emergency.
The discomfort and inconvenience of wearing PPE can
create a resistance to the conscientious use of PPE. One
essential aspect of training is to make the user aware of
the need for PPE and to instill motivation for the proper
use and maintenance of PPE.
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8-16
Personal Protective Equipment
Work Mission Duration
Before the workers actually begin work in their PPE
ensembles, the anticipated duration of the work mission
should be established. Several factors limit mission
length. These include:
• Air supply consumption.
• Suit/ensemble permeation and penetration by
chemical contaminants.
• Ambient temperature.
• Coolant supply.
Air Supply Consumption
The duration of the air supply must be considered before
planning any SCBA-assisted work activity. The antici-
pated operating time of an SCBA'is clearly indicated on
the breathing apparatus. This designated operating time
is based on a moderate work rate, e.g., some lifting, carry-
ing, and/or heavy equipment operation. In actual opera-
tion, however, several factors can reduce the rated
operating time. When planning an SCBA-assisted work
mission, the following variables should be considered and
work actions and operating time adjusted accordingly:
• Work rate. The actual in-use duration of SCBAs
may be reduced by one-third to one-half during
strenuous work, e.g., drum handling, major lifting,
or any task requiring repetitive speed of motion
[7].
• Fitness. Well-conditioned individuals generally
utilize oxygen more efficiently and can extract
more oxygen from a given volume of air (particu-
larly when performing strenuous tasks) than unfit
individuals, thereby slightly increasing the SCBA
operating time [8].
• Body size. Larger individuals generally consume air
at a higher rate than smaller individuals [8],
thereby decreasing the SCBA operating time.
• Breathing patterns. Quick, shallow or irregular
breaths use air more rapidly than deep, regularly
spaced breaths. Heat-induced anxiety and lack of
acclimatization (see Heat Stress and Other Physio-
logical Factors in this chapter) may induce hyper-
ventilation, resulting in decreased SCBA operating
time [8].
Suit/Ensemble Permeation and Penetration
The possibility of chemical permeation or penetration of
CPC ensembles during the work mission is always a mat-
ter of concern and may limit mission duration. Possible
causes of ensemble penetration are:
• Suit valve leakage, particularly under excessively
hot or cold temperatures.
• Suit fastener leakage if the suit is not properly
maintained or if the fasteners become brittle at
cold temperatures.
• Exhalation valve leakage at excessively hot or cold
temperatures.
Also, when considering mission duration, it should be
remembered that no single clothing material is an effec-
tive barrier to all chemicals or all combinations of chemi-
cals, and no material is an effective barrier to prolonged
chemical exposure.
Ambient Temperature
The ambient temperature has a major influence on work
mission duration as it affects both the worker and the
protective integrity of the ensemble. Heat stress, which
can occur even in relatively moderate temperatures, is the
greatest immediate danger to an ensemble-encapsulated
worker. Methods to monitor for and prevent heat stress
are discussed in the final section of this chapter, Heat
Stress and Other Physiological Factors. Hot and cold
ambient temperatures also affect:
• Valve operation on suits and/or respirators.
• The durability and flexibility of suit materials.
• The integrity of suit fasteners.
• The breakthrough time and permeation rates of
chemicals.
• The concentration of airborne contaminants.
All these factors may decrease the duration of protection
provided by a given piece of clothing or respiratory
equipment.
Coolant Supply
Under warm or strenuous work conditions, adequate
coolant (ice or chilled air, see Table 8-5) should be
provided to keep the wearer's body at a comfortable tem-
perature and to reduce the potential for heat stress (see
Heat Stress and Other Physiological Factors at the end of
this chapter). If coolant is necessary, the duration of the
coolant supply will directly affect mission duration.
Personal Use Factors
As described below, certain personal features of workers
may jeopardize safety during equipment use. Prohibitive
or precautionary measures should be taken as necessary.
Facial hair and long hair interfere with respirator fit and
wearer vision. Any facial hair that passes between the
face and the sealing surface of the respirator should be
prohibited. Even a few days' growth of facial hair will
allow excessive contaminant penetration. Long hair must
be effectively contained within protective hair coverings.
Eyeglasses with conventional temple pieces (earpiece
bars) will interfere with the respirator-to-face seal of a full
facepiece. A spectacle kit should be installed in the face
masks of workers requiring vision correction.
When a worker must wear corrective lenses as part of
the facepiece, the lenses shall be fitted by qualified
individuals to provide good vision, comfort, and a gas-
tight seal. Contact lenses may trap contaminants and/or
particulates between the lens and the eye, causing irrita-
tion, damage, absorption, and an urge to remove the
respirator. Wearing contact lenses with a respirator in a
contaminated atmosphere is prohibited (29 CFR Part
Gum and tobacco chewing should be prohibited during
respirator use since they may cause ingestion of con-
taminants and may compromise the respirator fit.
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Personal Protective Equipment
8-17
Donning an Ensemble
A routine should be established and practiced periodically
for donning a fully-encapsulating suit/SCBA ensemble.
Assistance should be provided for donning and doffing
since these operations are difficult to perform alone, and
solo efforts may increase the possibility of suit damage.
Table 8-7 lists sample procedures for donning a fully-
encapsulating suit/SCBA ensemble. These procedures
should be modified depending on the particular type of
suit and/or when extra gloves and/or boots are used.
These procedures assume that the wearer has previous
training in SCBA use and decontamination procedures.
Once the equipment has been donned, its fit should be
evaluated. If the clothing is too small, it will restrict move-
ment, thereby increasing the likelihood of tearing the suit
material and accelerating worker fatigue. If the clothing
is too large, the possibility of snagging the material is
increased, and the dexterity and coordination of the
worker may be compromised. In either case, the worker
should be recalled and better fitting clothing provided.
Table 8-7. Sample Donning Procedures8'^
1. Inspect the clothing and respiratory equipment before donning
(see Inspection).
2. Adjust hard hat or headpiece if worn, to fit user's head.
3. Open back closure used to change air tank (if suit has one)
before donning suit.
4. Standing or sitting, step into the legs of the suit; ensure proper
placement of the feet within the suit; then gather the suit
around the waist.
5. Put on chemical-resistant safety boots over the feet of the suit.
Tape the leg cuff over the tops of the boots.
— If additional chemical-resistant boots are required, put these
on now.
— Some one-piece suits have heavy-soled protective feet. With
these suits, wear short, chemical-resistant safety boots inside
the suit.
6. Put on air tanks and harness assembly of the SCBA. Don the
facepiece and adjust it to be secure, but comfortabla Do not
connect the breathing hose. Open valve on air tank.
7. Perform negative and positive respirator facepiece seal test
procedures.
— To conduct a negative-pressure test, close the inlet part with
the palm of the hand or squeeze the breathing tube so it does
not pass air, and gently inhale for about 10 seconds. Any
inward rushing of air indicates a poor fit. Note that a leaking
facepiece may be drawn tightly to the face to form a good
seal, giving a false indication of adequate fit.
— To conduct a positive-pressure test, gently exhale while
covering the exhalation valve to ensure that a positive pres-
sure can be built up. Failure to build a positive pressure indi-
cates a poor fit.
8. Depending on type of suit:
— Put on long-sleeved inner gloves (similar to surgical gloves).
— Secure gloves to sleeves, for suits with detachable gloves
(if not done prior to entering the suit).
— Additional overgloves, worn over attached suit gloves, may be
donned later.
9. Put sleeves of suit over arms as assistant pulls suit up and over
the SCBA. Have assistant adjust suit around SCBA and
shoulders to ensure unrestricted motion.
10. Put on hard hat, if needed.
11. Raise hood over head carefully so as not to disrupt face seal of
SCBA mask. Adjust hood to give satisfactory comfort.
12. Begin to secure the suit by closing all fasteners on opening until
there is only adequate room to connect the breathing hose.
Secure all belts and/or adjustable leg, head, and waistbands.
13. Connect the breathing hose while opening the main valve.
14. Have assistant first ensure that wearer is breathing properly and
then make final closure of the suit.
15. Have assistant check all closures.
16. Have assistant observe the wearer for a period of time to ensure
that the wearer is comfortable, psychologically stable, and that
the equipment is functioning properly.
•Source: Based on reference [91.
bPerform the procedures in the order indicated.
cWhen donning a suit, use a moderate amount of a powder to pre-
vent chafing and to increase comfort. Powder will also reduce
rubber binding.
As part of donning operations, an assistant tape seals
boots to protective clothing to eliminate routes of entry
for chemicals.
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8-18
Personal Protective Equipment
Respirator Fit Testing
The "fit" or integrity of the facepiece-to-face seal of a
respirator affects its performance. A secure fit is impor-
tant with positive-pressure equipment, and is essential
to the safe functioning of negative-pressure equipment,
such as most air-purifying respirators. Most facepieces fit
only a certain percentage of the population; thus each
facepiece must be tested on the potential wearer in order
to ensure a tight seal. Facial features such as scars,
hollow temples, very prominent cheekbones, deep skin
creases, dentures or missing teeth, and the chewing of
gum and tobacco may interfere with the respirator-to-face
seal. A respirator shall not be worn when such conditions
prevent a good seal. The workers' diligence in observing
these factors shall be evaluated by periodic checks.
For a qualitative respirator fit testing protocol, see
Appendix D of the OSHA lead standard (29 CFR Part
1910.1025). For quantitative fit testihg, see the NIOSH
publication A Guide to Industrial Respiratory Protection
[10]. For specific quantitative testing protocols, literature
supplied by manufacturers of quantitative fit test equip-
ment should be consulted. Note that certain OSHA stan-
dards require quantitative fit testing under specific
circumstances (e.g., 29 CFR Parts 1910.1018[h][3][iii],
1910.1025lf][3][ii], and 1910.1045[h][3][iii][B]).
In-Use Monitoring
The wearer must understand all aspects of the clothing
operation and its limitations; this is especially important
for fully-encapsulating ensembles where misuse could
potentially result in suffocation.
During equipment use, workers should be encouraged to
report any perceived problems or difficulties to their
supervisor(s). These malfunctions include, but are not
limited to:
• Degradation of the protective ensemble.
• Perception of odors.
• Skin irritation.
• Unusual residues on PPE.
• Discomfort.
• Resistance to breathing.
• Fatigue due to respirator usa
• Interference with vision or communication.
• Restriction of movement.
• Personal responses such as rapid pulse, nausea, and
chest pain.
If a supplied-air respirator is being used, all hazards that
might endanger the integrity of the air line should be
removed from the working area prior to use. During use,
air lines should be kept as short as possible and other
workers and vehicles should be excluded from the area.
Doffing an Ensemble
Exact procedures for removing fully-encapsulating suit/
SCBA ensembles must be established and followed in
order to prevent contaminant migration from the work
area and transfer of contaminants to the wearer's body,
the doffing assistant, and others.
Table 8-8. Sample Doffing Procedures8
If sufficient air supply is available to allow appropriate decontami-
nation before removal:
1. Remove any extraneous or disposable clothing, boot covers,
outer gloves, and tape.
2. Have assistant loosen and remove the wearer's safety shoes or
boots.
3. Have assistant open the suit completely and lift the hood over
the head of the wearer and rest it on top of the SCBA tank.
4. Remove arms, one at a time, from suit. Once arms are free, have
assistant lift the suit up and away from the SCBA backpack —
avoiding any contact between the outside surface of the suit
and the wearer's body— and lay the suit out flat behind the
wearer. Leave internal gloves on, if any.
5. Sitting, if possible, remove both legs from the suit.
6. Follow procedure for doffing SCBA.
7. After suit is removed, remove internal gloves by rolling them off
the hand, inside out.
8. Remove internal clothing and thoroughly cleanse the body.
If the low-pressure warning alarm has sounded, signifying that
approximately 5 minutes of air remain:
1. Remove disposable clothing.
2. Quickly scrub and hose off, especially around the entrance/exit
zipper.
3. Open the zipper enough to allow access to the regulator and
breathing hose.
4. Immediately attach an appropriate canister to the breathing
hose (the type and fittings should be predetermined). Although
this provides some protection against any contamination still
present, it voids the certification of the unit.
5. Follow Steps 1 through 8 of the regular doffing procedure
above. Take extra care to avoid contaminating the assistant and
wearer.
8Source = Based on reference [91.
Sample doffing procedures are provided in Table 8-8.
These procedures should be performed only after decon-
tamination of the suited worker (see Chapter 10, Decon-
tamination). They require a suitably attired assistant.
Throughout the procedures, both worker and assistant
should avoid any direct contact with the outside surface
of the suit.
Clothing Reuse
Chemicals that have begun to permeate clothing during
use may not be removed during decontamination and may
continue to diffuse through the material towards the
inside surface, presenting the hazard of direct skin con-
tact to the next person who uses the clothing.
Where such potential hazards may develop, clothing
should be checked inside and out for discoloration or
other evidence of contamination (see next section,
Inspection). This is particularly important for fully-
encapsulating suits, which are generally subject to reuse
due to their cost. Note, however, that negative (i.e., no
chemical found) test results do not necessarily preclude
the possibility that some absorbed chemical will reach
the suit's interior.
At present, little documentation exists regarding clothing
reusa Reuse decisions must consider the known factors
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Personal Protective Equipment
8-19
of permeation rates as well as the toxicity of the con-
taminant(s). In fact, unless extreme care is taken to
ensure that clothing is properly decontaminated and that
the decontamination does not degrade the material, the
reuse of chemical protective clothing that has been
contaminated with toxic chemicals is not advisable [4].
Inspection
An effective PPE inspection program will probably feature
five different inspections:
• Inspection and operational testing of equipment
received from the factory or distributor.
• Inspection of equipment as it is issued to workers.
• Inspection after use or training and prior to main-
tenance.
• Periodic inspection of stored equipment.
• Periodic inspection when a question arises concern-
ing the appropriateness of the selected equipment, or
when problems with similar equipment arise.
Each inspection will cover somewhat different areas in
varying degrees of depth. Detailed inspection procedures,
where appropriate, are usually available from the manu-
facturer. The inspection checklists provided in Table 8-9
may also be an aid.
Records must be kept of all inspection procedures.
Individual identification numbers should be assigned to all
reusable pieces of equipment (respirators may already
have ID numbers) and records should be maintained by
that number. At a minimum, each inspection should rec-
ord the ID number, date, inspector, and any unusual con-
ditions or findings. Periodic review of these records may
indicate an item or type of item with excessive main-
tenance costs or a particularly high level of "down-time."
Storage
Clothing and respirators must be stored properly to pre-
vent damage or malfunction due to exposure to dust,
moisture, sunlight, damaging chemicals, extreme temper-
atures, and impact. Procedures must be specified for both
pre-issuance warehousing and, more importantly, post-
issuance (in-use) storage. Many equipment failures can be
directly attributed to improper storage.
Clothing:
• Potentially contaminated clothing should be stored in
an area separate from street clothing.
• Potentially contaminated clothing should be stored in
a well-ventilated area, with good air flow around each
item, if possible.
• Different types and materials of clothing and gloves
should be stored separately to prevent issuing the
wrong material by'mistake.
• Protective clothing should be folded or hung in accor-
dance with manufacturers' recommendations.
Respirators:
• SCBAs, supplied-air respirators, and air-purifying
respirators should be dismantled, washed, and disin-
fected after each use.
Table 8-9. Sample PPE Inspection Checklists
CLOTHING
Before use:
• Determine that the clothing material is correct for the specified
task at hand.
• Visually inspect for:
—imperfect seams
— non-uniform coatings
—tears
— malfunctioning closures
• Hold up to light and check for pinholes.
• Flex product:
—observe for cracks
— observe for other signs of shelf deterioration
• If the product has been used previously, inspect inside and out
for signs of chemical attack:
— discoloration
—swelling
—stiffness
During the work task, periodically inspect for:
• Evidence of chemical attack such as discoloration, swelling,
stiffening, and softening. Keep in mind, however, that chemical
permeation can occur without any visible effects.
• Closure failure.
• Tears.
• Punctures.
• Seam discontinuities.
GLOVES
• BEFORE USE, pressurize glove to check for pinholes. Either
blow into glove, then roll gauntlet towards fingers or inflate
glove and hold under water. In either case, no air should escapa
FULLY-ENCAPSULATING SUITS
Before use:
• Check the operation of pressure relief valves.
• Inspect the fitting of wrists, ankles, and neck.
• Check faceshield, if so equipped, for:
— cracks
— crazing
—fogginess
RESPIRATORS
SCBA
• Inspect SCBAs:
— before and after each use
— at least monthly when in storage
— every time they are cleaned
• Check all connections for tightness.
• Check material conditions for:
—signs of pliability
—signs of deterioration
—signs of distortion
• Check for proper setting and operation of regulators and valves
(according to manufacturers' recommendations).
• Check operation of alarm(s).
• Check faceshields and lenses for:
— cracks
—crazing
— fogginess
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8-20
Personal Protective Equipment
Table 8-9. (com.)
Supplied-Air Respirators
• Inspect SARs:
— daily when in use
— at least monthly when in storage
— every time they are cleaned
• Inspect air lines prior to each use for cracks, kinks, cuts, frays,
and weak areas.
• Check for proper setting and operation of regulators and valves
(according to manufacturers' recommendations).
• Check all connections for tightness.
• Check material conditions for:
— signs of pliability
— signs of deterioration
— signs of distortion
• Check faceshields and lenses for:
— cracks
— crazing
— fogginess
Air-Purifying Respirators
• Inspect air-purifying respirators:
— before each use to be sure they have been adequately
cleaned
— after each use
—during cleaning
— monthly if in storage for emergency use
• Check material conditions for:
— signs of pliability
—signs of deterioration
—signs of distortion
• Examine cartridges or canisters to ensure that:
—they are the proper type for the intended use
—the expiration date has not been passed
—they have not been opened or used previously
• Check faceshields and lenses for:
— cracks
—crazing
—fogginess
• SCBAs should be stored in storage chests supplied by
the manufacturer. Air-purifying respirators should be
stored individually in their original cartons or carrying
cases, or in heat-sealed or resealable plastic bags.
Maintenance
The technical depth of maintenance procedures vary.
Manufacturers frequently restrict the sale of certain PPE
parts to individuals or groups who are specially trained,
equipped, and "authorized" by the manufacturer to pur-
chase them. Explicit procedures should be adopted to
ensure that the appropriate level of maintenance is per-
formed only by individuals having this specialized training
and equipment. The following classification scheme is
often used to divide maintenance into three levels:
• Level 1: User or wearer maintenance, requiring a few
common tools or no tools at all.
• Level 2: Shop maintenance that can be performed by
the employer's maintenance shop.
• Level 3: Specialized maintenance that can be per-
formed only by the factory or an authorized repair
person.
Heat Stress and Other Physiological
Factors
Wearing PPE puts a hazardous waste worker at consid-
erable risk of developing heat stress. This can result in
health effects ranging from transient heat fatigue to seri-
ous illness or death. Heat stress is caused by a number of
interacting factors, including environmental conditions,
clothing, workload, and the individual characteristics of
the worker. Because heat stress is probably one of the
most common (and potentially serious) illnesses at haz-
ardous waste sites, regular monitoring and other preven-
tive precautions are vital.
Individuals vary in their susceptibility to heat stress. Fac-
tors that may predispose someone to heat stress include:
• Lack of physical fitness.
• Lack of acclimatization.
• Age.
• Dehydration.
• Obesity.
• Alcohol and drug usa
• Infection.
• Sunburn.
• Diarrhea.
• Chronic disease.
Reduced work tolerance and the increased risk of exces-
sive heat stress is directly influenced by the amount and
type of PPE worn. PPE adds weight and bulk, severely
reduces the body's access to normal heat exchange
mechanisms (evaporation, convection, and radiation), and
increases energy expenditure Therefore, when selecting
PPE, each item's benefit should be carefully evaluated in
relation to its potential for increasing the risk of heat
stress. Once PPE is selected, the safe duration of work/
rest periods should be determined based on the:
• Anticipated work rate.
• Ambient temperature and other environmental
factors.
• Type of protective ensemble.
• Individual worker characteristics and fitness.
Monitoring
Because the incidence of heat stress depends on a vari-
ety of factors, all workers, even those not wearing protec-
tive equipment, should be monitored.
• For workers wearing permeable clothing (e.g., stan-
dard cotton or synthetic work clothes), follow
recommendations for monitoring requirements and
suggested work/rest schedules in the current
American Conference of Governmental Industrial
Hygienists' (ACGIH) Threshold Limit Values for
Heat Stress [11]. If the actual clothing worn differs
from the ACGIH standard ensemble in insulation
value and/or wind and vapor permeability, change
the monitoring requirements and work/rest sched-
ules accordingly [12].
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Personal Protective Equipment
8-21
• For workers wearing semipermeable or imper-
meable1 encapsulating ensembles, the ACGIH
standard cannot be used. For these situations,
workers should be monitored when the tempera-
ture in the work area is above 70 °F (21 °C) [6].
To monitor the worker, measure:
• Heart rate. Count the radial pulse during a
30-second period as early as possible in the rest
period.
If the heart rate exceeds 110 beats per minute at
the beginning of the rest period, shorten the next
work cycle by one-third and keep the rest period
the same.
If the heart rate still exceeds 110 beats per minute
at the next rest period, shorten the following work
cycle by one-third [12].
• Oral temperature. Use a clinical thermometer
(3 minutes under the tongue) or similar device to
measure the oral temperature at the end of the
work period (before drinking).
If oral temperature exceeds 99.6 °F (37.6 °C),
shorten the next work cycle by one-third without
changing the rest period.
If oral temperature still exceeds 99.6 °F (37.6 °C) at
the beginning of the next rest period, shorten the
following work cycle by one-third [12].
Do not permit a worker to wear a semipermeable or
impermeable garment when his/her oral tempera-
ture exceeds 100.6 °F (38.1°C)[12].
• Body water loss, if possible. Measure weight on a
scale accurate to ±0.25 Ib at the beginning and
end of each work day to see if enough fluids are
being taken to prevent dehydration. Weights
should be taken while the employee wears similar
clothing or, ideally, is nude. The body water loss
should not exceed 1.5 percent total body weight
loss in a work day [12].
Initially, the frequency of physiological monitoring
depends on the air temperature adjusted for solar radia-
tion and the level of physical work (see Table 8-10). The
length of the work cycle will be governed by the fre-
quency of the required physiological monitoring.
Prevention
Proper training and preventive measures will help avert
serious illness and loss of work productivity. Preventing
heat stress is particularly important because once some-
one suffers from heat stroke or heat exhaustion, that per-
son may be predisposed to additional heat injuries. To
avoid heat stress, management should take the following
steps:
• Adjust work schedules:
Modify work/rest schedules according to monitor-
ing requirements.
Mandate work slowdowns as needed.
'Although no protective ensemble is "completely" impermeable,
for practical purposes an outfit may be considered impermeable
when calculating heat stress risk.
Rotate personnel: alternate job functions to mini-
mize overstress or overexertion at one task.
Add additional personnel to work teams.
Perform work during cooler hours of the day if pos-
sible or at night if adequate lighting can be
provided.
' Provide shelter (air-conditioned, if possible) or
shaded areas to protect personnel during rest
periods.
• Maintain workers' body fluids at normal levels.
This is necessary to ensure that the cardiovascular
system functions adequately. Daily fluid intake
must approximately equal the amount of water
lost in sweat, i.e., 8 fluid ounces (0.23 liters) of
water must be ingested for approximately every
8 ounces (0.23 kg) of weight lost. The normal
thirst mechanism is not sensitive enough to
ensure that enough water will be drunk to replace
lost sweat [14]. When heavy sweating occurs,
encourage the worker to drink more. The following
strategies may be useful:
Maintain water temperature at 50° to 60 °F
(10°to15.6°C).
Provide small disposable cups that hold about
4 ounces (0.1 liter).
Have workers drink 16 ounces (0.5 liters) of fluid
(preferably water or dilute drinks) before beginning
work.
Urge workers to drink a cup or two every 15 to 20
minutes, or at each monitoring break. A total of
1 to 1.6 gallons (4 to 6 liters) of fluid per day are
recommended, but more may be necessary to
maintain body weight.
Weigh workers before and after work to determine
if fluid replacement is adequate.
Encourage workers to maintain an optimal level of
physical fitness:
Where indicated, acclimatize workers to site work
conditions: temperature, protective clothing, and
workload (see Level of Acclimatization at the end of
this chapter).
Urge workers to maintain normal weight levels.
Provide cooling devices to aid natural body heat
exchange during prolonged work or severe heat
exposura Cooling devices include:
Field showers or hose-down areas to reduce body
temperature and/or to cool off protective clothing.
Cooling jackets, vests, or suits (see Table 8-5 for
details).
Train workers to recognize and treat heat stress.
As part of training, identify the signs and symp-
toms of heat stress (see Table 8-11).
Other Factors
PPE decreases worker performance as compared to an
unequipped individual. The magnitude of this effect varies
considerably, depending on both the individual and the
PPE ensemble used. This section discusses the demon-
strated physiological responses to PPE, the individual
human characteristics that play a factor in these
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8-22
Personal Protective Equipment
Table 8-10. Suggested Frequency of Physiological Monitoring for Fit and Acclimatized Workers8
ADJUSTED TEMPERATURE*"
NORMAL WORK ENSEMBLE0
IMPERMEABLE ENSEMBLE
90 °F (32.2 °C) or above
87.5°-90°F (30.8°-32.2°C)
82.5°-87.5 °F (28.1°-30.8°C)
77.5°-82.5°F (25.3°-28.1 °C)
72.5°-77.5°F
(22.5°-25.3 °C)
After each 45 minutes of work
After each 60 minutes of work
After each 90 minutes of work
After each 120 minutes of work
After each 150 minutes of work
After each 15 minutes of work
After each 30 minutes of work
After each 60 minutes of work
After each 90 minutes of work
After each 120 minutes of work
Source: Reference [13].
"For work levels of 250 kilocalories/hour.
bCalculate the adjusted air temperature (ta adj) by using this equation: ta adj °F = ta °F + (13 x % sunshine). Measure air temperature
(ta) with a standard mercury-in-glass thermometer, with the bulb shielded from radiant heat. Estimate percent sunshine by judging what
percent time the sun is not covered by clouds that are thick enough to produce a shadow. (100 percent sunshine = no cloud cover and
a sharp, distinct shadow; 0 percent sunshine = no shadows.)
CA normal work ensemble consists of cotton coveralls or other cotton clothing with long sleeves and pants.
Table 8-11. Signs and Symptoms of Heat Stress8
• Heat rash may result from continuous exposure to heat or
humid air.
• Heat cramps are caused by heavy sweating with inadequate
electrolyte replacement. Signs and symptoms include:
— muscle spasms
— pain in the hands, feet, and abdomen
• Heat exhaustion occurs from increased stress on various body
organs including inadequate blood circulation due to cardio-
vascular insufficiency or dehydration. Signs and symptoms
include:
— pale, cool, moist skin
— heavy sweating
— dizziness
— nausea
— fainting
• Heat stroke is the most serious form of heat stress. Temperature
regulation fails and the body temperature rises to critical levels.
Immediate action must be taken to cool the body before serious
injury and death occur. Competent medical help must be
obtained. Signs and symptoms are:
— red, hot, usually dry skin
— lack of or reduced perspiration
— nausea
— dizziness and confusion
— strong, rapid pulse
— coma
aSource: Reference [6].
responses, and some of the precautionary and training
measures that need to be taken to avoid PPE-induced
injury.
The physiological factors may affect worker ability to
function using PPE include:
• Physical condition.
• Level of acclimatization.
• Age.
• Gender.
• Weight.
Physical Condition
Physical fitness is a major factor influencing a person's
ability to perform work under heat stress. The more fit
someone is, the more work they can safely perform. At a
given level of work, a fit person, relative to an unfit
person, will have [5,8,15,16]:
• Less physiological strain.
• A lower heart rate.
• A lower body temperature, which indicates less
retained body heat (a rise in internal temperature
precipitates heat injury).
• A more efficient sweating mechanism.
• Slightly lower oxygen consumption.
• Slightly lower carbon dioxide production.
Level of Acclimatization
The degree to which a worker's body has physiologically
adjusted or acclimatized to working under hot conditions
affects his or her ability to do work. Acclimatized indi-
viduals generally have lower heart rates and body temper-
atures than unacclimatized individuals [17], and sweat
sooner and more profusely. This enables them to maintain
lower skin and body temperatures at a given level of
environmental heat and work loads than unacclimatized
workers [18]. Sweat composition also becomes more
dilute with acclimatization, which reduces salt loss [8].
-------
Personal Protective Equipment
8-23
Acclimatization can occur after just a few days of
exposure to a hot environment [15,16]. NIOSH recom-
mends a progressive 6-day acclimatization period for the
unacclimatized worker before allowing him/her to do full
work on a hot job [16]. Under this regimen, the first day
of work on site is begun using only 50 percent of the
anticipated workload and exposure time, and 10 percent
is added each day through day 6 [16]. With fit or trained
individuals, the acclimatization period may be shortened
2 or 3 days. However, workers can lose acclimitization in
a matter of days, and work regimens should be adjusted
to account for this.
When enclosed in an impermeable suit, fit acclimatized
individuals sweat more profusely than unfit or unacclima-
tized individuals and may therefore actually face a greater
danger of heat exhaustion due to rapid dehydration. This
can be prevented by consuming adequate quantities of
water. See previous section on Prevention for additional
information.
Age
Generally, maximum work capacity declines with increas-
ing age, but this is not always the case. Active, well-
conditioned seniors often have performance capabilities
equal to or greater than young sedentary individuals.
However, there is some evidence, indicated by lower
sweat rates and higher body core temperatures, that older
individuals are less effective in compensating for a given
level of environmental heat and work loads [19]. At
moderate thermal loads, however, the physiological
responses of "young" and "old" are similar and perfor-
mance is not affected [19].
Age should not be the sole criterion for judging whether
or not an individual should be subjected to moderate heat
stress. Fitness level is a more important factor.
Gender
The literature indicates that females tolerate heat stress
at least as well as their male counterparts [20]. Generally,
a female's work capacity averages 10 to 30 percent less
than that of a male [8]. The primary reasons for this are
the greater oxygen-carrying capacity and the stronger
heart in the male [15]. However, a similar situation exists
as with aging: not all males have greater work capacities
than all females.
Weight
The ability of a body to dissipate heat depends on the
ratio of its surface area to its mass (surface area/weight).
Heat loss (dissipation) is a function of surface area and
heat production is dependent on mass. Therefore, heat
balance is described by the ratio of the two.
Since overweight individuals (those with a low ratio) pro-
duce more heat per unit of surface area than thin individ-
uals (those with a high ratio), overweight individuals
should be given special consideration in heat stress situa-
tions. However, when wearing impermeable clothing, the
weight of an individual is not a critical factor in deter-
mining the ability to dissipate excess heat.
References
1. NIOSH. 1985. Certified Equipment List as of
October 1, 1984. DHHS (NIOSH) No. 85-101.
National Institute for Occupational Safety and
Health, Cincinnati, OH. Updated annually.
2. Moyer, E.S. 1983. Review of influential factors
affecting the performance of organic vapor air-
purifying respirator cartridges. J. Am. Ind. Hyg.
Assoc. 44:46-51.
3. MSHA/NIOSH. Canister bench tests; minimum
requirements. 30 CFR Part 11.102-5.
4. Schwope, A.D.; Costas, P.P.; Jackson, J.O.; and D.J.
Weitzman. 1985. Guidelines for the Selection of
Chemical-Protective Clothing, Second Edition.
American Conference of Governmental Industrial
Hygienists, Inc. 6500 Lynnway Avenue, Building
D-7, Cincinnati, OH 45211.
5. Goldman, R.F. 1970. Tactical Implications of the
Physiological Stress Imposed by Chemical Protec-
tive Clothing Systems. Army Science Conference,
Natick, MA.
6. U.S. EPA. 1984. Standard Operating Safety Guides.
Office of Emergency and Remedial Response, Haz-
ardous Response Support Division, Edison, NJ.
November, 1984.
7. Home Office. 1974. Breathing Apparatus and
Resuscitation. Book IV of Manual of Firemanship.
London, England.
8. McArdle, W.D.; Katch, F.I.; and V.L. Katch. 1981.
Exercise Physiology: Energy, Nutrition, and Human
Performance. Lea and Febiger, Philadelphia, PA.
9. U.S. EPA, Office of Emergency and Remedial
Response, Hazardous Response Support Division.
1985. Field Standard Operating Procedures for Site
Entry, FSOP #4.
10. NIOSH. 1976. A Guide to Industrial Respiratory Pro-
tection. NIOSH (DHEW) 76-189. Cincinnati, OH.
11. American Conference of Govermental Industrial
Hygienists. 1985. Threshold Limit Values for Chemi-
cal Substances and Physical Agents in the Work-
place Environment and Biological Exposure Indices
with Intended Changes for 1985-86. Cincinnati, OH.
12. NIOSH. 1981. Chemical Control Corporation,
Elizabeth New Jersey. Hazard Evaluation Report.
TA-80-77-853.
13. Henschel, A. 1985. Memorandum to Sheldon
Rabinovitz from Austin Henschel, NIOSH, Cincin-
nati, OH. June 20, 1985.
14. Goldman, R.F. 1983. Heat Stress in Industrial Pro-
tective Encapsulating Garments. Contract delivera-
ble to U.S. Department of Health and Human
Services, Order No. 83-211.
-------
8-24 Personal Protective Equipment
15. Dukes-Dubos, F.N. and A. Henschel, eds. 1980.
Proceedings of a NIOSH Workshop on Recom-
mended Heat Stress Standards. U.S. Department of
Health and Human Services, Cincinnati, OH. p. 153.
16. Ramsey, J.D. 1976. NIOSH, Standards Advisory
Committee on Heat Stress—Recommended Stan-
dard for Work in Hot Environments. Appendix C in
Standards for Occupational Exposure to Hot
Environments, proceedings of symposium, Cincin-
nati, OH.
17. Astrand, I.; Axelson, O.; Eriksson, U.; and L Olander.
1975. Heat stress in occupational work. Ambio
4:37-42.
18. Eichna, L.W.; Park, C.R.; Nelson, N.; Horvath, S.M.;
and E.D. Palmes. 1950. Thermal regulation during
acclimatization in a hot, dry (desert type) environ-
ment. Am. J. Physiol. 163:585-597.
19. Lind, A.R.; Humphreys, P.W.; Collins, K.J.; Foster, K.;
and K.F. Sweetland. 1970. Influence of age and
daily duration of exposure on responses of men to
work in heat. J. Appl. Physiol. 28:50-56.
20. Shapiro, Y.; Pandolf, K.B.; Avellini, B.A.; Pimental,
N.A.; and R.F. Goldman. 1981. Heat balance and
heat transfer in men and women exercising in hot-
dry and hot-wet conditions. Ergonomics
24:375-386.
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9.
Control
Contents
Introduction 9-1
Site Map 9-1
Site Preparation 9-1
Site Work Zones 9-1
Exclusion Zone 9-2
Contamination Reduction Zone 9-2
Support Zone 9-4
The Buddy System 9-4
Site Security 9-4
Communication Systems 9-6
Safe Work Practices 9-6
References 9-7
Introduction
The purpose of site control is to minimize potential con-
tamination of workers, protect the public from the site's
hazards, and prevent vandalism. Site control is especially
important in emergency situations. This chapter describes
the basic components of a program to control the activi-
ties and movements of people and equipment at a hazard-
ous waste site.
Several site control procedures can be implemented to
reduce worker and public exposure to chemical, physical,
biologic, and safety hazards:
• Compile a site map.
• Prepare the site for subsequent activities.
• Establish work zones.
• Use the buddy system when necessary.
• Establish and strictly enforce decontamination
procedures for both personnel and equipment {see
Chapter 10, Decontamination).
• Establish site security measures.
• Set up communication networks.
• Enforce safe work practices.
This chapter, based on EPA's Standard Operating Safety
Guides [1], discusses general aspects of these eight con-
trol measures.
The degree of site control necessary depends on site
characteristics, site size, and the surrounding community.
The site control program should be established in the
planning stages of a project and modified based on new
information and site assessments (see Chapter 6, Site
Characterization). The appropriate sequence for imple-
menting these measures should be determined on a site-
specific basis. In many cases, it will be necessary to
implement several measures simultaneously.
Site Map
A site map showing topographic features, prevailing wind
direction, drainage, and the location of buildings, con-
tainers, impoundments, pits, ponds, and tanks is helpful
in:
• Planning activities.
• Assigning personnel.
• Identifying access routes, evacuation routes, and
problem areas.
• Identifying areas of the site that require use of
personal protective equipment.
• Supplementing the daily safety and health brief-
ings of the field teams.
The map should be prepared prior to site entry and
updated throughout the course of site operations to
reflect:
• Accidents.
• Changes in site activities.
• Emergencies.
• Hazards not previously identified.
• New materials introduced on site.
• Vandalism.
• Weather conditions.
Overlays can be used to help portray information without
cluttering the map.
Site Preparation
Time and effort must be spent in preparing a site for the
cleanup activity to ensure that response operations go
smoothly and that worker safety is protected. Site
preparation can be as hazardous as site cleanup. There-
fore, safety measures should be afforded the same level
of care at this stage as during actual cleanup. Table 9-1
presents the major steps in site preparation prior to any
cleanup activities.
Site Work Zones
To reduce the accidental spread of hazardous substances
by workers from the contaminated area to the clean area,
zones should be delineated on the site where different
types of operations will occur, and the flow of personnel
among the zones should be controlled. The establishment
of work zones will help ensure that: personnel are
properly protected against the hazards present where
they are working, work activities and contamination are
confined to the appropriate areas, and personnel can be
located and evacuated in an emergency.
Hazardous waste sites should be divided into as many
different zones as needed to meet operational and safety
objectives. For illustration, this manual describes three
frequently used zones:
• Exclusion Zone, the contaminated area.
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9-2
Site Control
Table 9-1. Site Preparation
• Construct roadways to provide ease of access and a sound
roadbed for heavy equipment and vehicles.
• Arrange traffic flow patterns to ensure safe and efficient
operations.
• Eliminate physical hazards from the work area as much as
possible, including:
— ignition sources in flammable hazard areas.
— exposed or ungrounded electrical wiring, and low overhead
wiring that may entangle equipment.
— sharp or protruding edges, such as glass, nails, and torn metal,
which can puncture protective clothing and equipment and
inflict puncture wounds.
— debris, holes, loose steps or flooring, protruding objects,
slippery surfaces, or unsecured railings, which can cause falls,
slips, and trips.
— unsecured objects, such as bricks and gas cylinders, near the
edges of elevated surfaces, such as catwalks, roof tops, and
scaffolding, which may dislodge and fall on workers.
— debris and weeds that obstruct visibility.
• Install skid-resistant strips and other anti-skid devices on slippery
surfaces.
• Construct operation pads for mobile facilities and temporary
structures.
• Construct loading docks, processing and staging areas, and
decontamination pads.
• Provide adequate illumination for work activities. Equip temporary
lights with guards to prevent accidental contact.
• Install all wiring and electrical equipment in accordance with the
National Electric Coda
• Contamination Reduction Zone (CRZ), me area
where decontamination takes place.
• Support Zone, the uncontaminated area where
workers should not be exposed to hazardous
conditions.
Delineation of these three zones should be based on sam-
pling and monitoring results and on an evaluation of
potential routes and amount of contaminant dispersion in
the event of a release. Movement of personnel and equip-
ment among these zones should be minimized and res-
tricted to specific Access Control Points to prevent
cross-contamination from contaminated areas to clean
areas. A schematic representation of the layout of work
zones is given in Figure 9-1.
Exclusion Zone
The Exclusion Zone is the area where contamination does
or could occur. The primary activities performed in the
Exclusion Zone are:
• Site characterization, such as mapping,
photographing, and sampling.
• Installation of wells for groundwater monitoring.
• Cleanup work, such as drum movement, drum
staging, and materials bulking.
The outer boundary of the Exclusion Zone, called the Hot-
line, should be established according to the criteria listed
in Table 9-2. It should be clearly marked by lines, plac-
ards, hazard tape and/or signs; or enclosed by physical
barriers, such as chains, fences, or ropes. Access Control
Points should be established at the periphery of the Exclu-
sion Zone to regulate the flow of personnel and equip-
ment into and out of the zone and to help verify that
proper procedures for entering and exiting are followed. If
feasible, separate entrances and exits should be estab-
lished to separate personnel and equipment movement
into and out of the Exclusion Zone.
The Exclusion Zone can be subdivided into different areas
of contamination based on the known or expected type
and degree of hazard or on the incompatibility of waste
streams. This allows more flexibility in safety require-
ments, operations, decontamination procedures, and use
of resources.
The personnel working in the Exclusion Zone may include
the Field Team Leader, the work parties, and specialized
personnel such as heavy equipment operators. All person-
nel within the Exclusion Zone should wear the level of
protection required by the Site Safety Plan. Within the
zone, different levels of protection may be justified based
on the degree of hazard presented. The level of personal
protection required in each subarea (see Chapter 8,
Personal Protective Equipment) should be specified and
marked.
The required level of protection in the Exclusion Zone
varies according to job assignment. For example, a worker
who collects samples from open containers might require
Level B protection, while one that performs walk-through
ambient air monitoring might only need Level C protec-
tion. When appropriate, different levels of protection
within the Exclusion Zone should be assigned to promote
a more flexible, effective, and less costly operation, while
still maintaining a high degree of safety.
Contamination Reduction Zone
The Contamination Reduction Zone (CRZ) is the transition
area between the contaminated area and the clean area.
This zone is designed to reduce the probability that the
clean Support Zone will become contaminated or affected
by other site hazards. The distance between the Exclusion
and Support Zones provided by the CRZ, together with
decontamination of workers and equipment, limits the
physical transfer of hazardous substances into clean
areas. The boundary between the CRZ and the Exclusion
Zone is called the Hotline. The degree of contamination in
the CRZ decreases as one moves from the Hotline to the
Support Zone, due both to the distance and the decon-
tamination procedures.
Decontamination procedures take place in a designated
area within the CRZ called the Contamination Reduction
Corridor (CRC). They begin at the Hotline. At least two
lines of decontamination stations should be set up within
the CRC: one for personnel and one for heavy equipment.
A large operation may require more than two lines.
Access into and out of the CRZ from the Exclusion Zone
is through Access Control Points: one each for personnel
and equipment entrance, one each for personnel and
equipment exit, if feasible.
The boundary between the Support Zone and the CRZ,
called the Contamination Control Line, separates the pos-
sibly low contamination area from the clean Support
Zone Access to the CRZ from the Support Zone is
through two Access Control Points if feasible: one each
for personnel and equipment. Personnel entering the CRZ
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Site Control
9-3
Estimated boundary
of area with highest
contamination
Contamination
Control Line
Command Post
Prevailing wind direction
Support Zone
Access Control Points.
Contamination Reduction Corridor.
Contamination Reduction Zone (CRZ).
Exclusion Zone.
Note: Area dimensions not to scale. Distances between points may vary.
Figure 9-1. Site Work Zones. (Note that decontamination facilities are located in the Contamination Reduction Zone.)
should be required to wear the personal protective cloth-
ing and equipment prescribed for working in the CRZ. To
reenter the Support Zone, workers should remove any
protective clothing and equipment worn in the CRZ, and
leave through the personnel exit Access Control Point.
The personnel stationed in the CRZ are usually the Site
Safety Officer, 3 Personnel Decontamination Station
(PDS) Operator, and the emergency response personnel.
Additional personnel may assist the PDS Operator by con-
ducting abbreviated decontamination procedures for sam-
ple .containers.
The CRZ must be well designed to facilitate:
• Decontamination of equipment, PDS operators,
personnel, and samples.
Emergency response: transport for injured person-
nel (safety harness, stretcher), first-aid equipment
(such as bandages, blankets, eye wash, splints,
and water), containment equipment (absorbent,
fire extinguisher).
Equipment resupply: air tank changes, personal
protective clothing and equipment (such as boo-
ties and gloves), sampling equipment (such as bot-
tles and glass rods), and tools.
Sample packaging and preparation for onsite or
offsite laboratories.
Worker temporary rest area: toilet facilities, bench,
chair, liquids, and shade. Water and other potable
liquids should be clearly marked and stored
properly to ensure that all glasses and cups are
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9-4
Site Control
Table 9-2. Establishing the Hotline
• Visually survey the immediate site environs.
• Determine the locations of:
— hazardous substances
— drainage, leachate, and spilled material
— visible discolorations
• Evaluate data from the initial site survey indicating the
presence of:
— combustible gases
— organic and inorganic gases, particulates, or vapors
— ionizing radiation
• Evaluate the results of soil and water sampling.
• Consider the distances needed to prevent an explosion or fire
from affecting personnel outside the Exclusion Zona
• Consider the distances that personnel must travel to and from
the Exclusion Zona
• Consider the physical area necessary for site operations.
• Consider meteorological conditions and the potential for con-
taminants to be blown from the area.
• Secure or mark the Hotlina
• Modify its location, if necessary, as more information becomes
available.
clean. Wash facilities should be located near drink-
ing facilities to allow employees to wash before
drinking. Drinking, washing, and toilet facilities
should be located in a safe area where protective
clothing can be removed. Facilities should be
cleaned and inspected regularly. Appropriate pro-
tective measures should be taken by maintenance
workers.
• Drainage of water and other liquids that are used
during decontamination.
Personnel within the CRZ should be required to maintain
internal communications, line-of-sight contact with work
parties, work party monitoring (e.g., for air time left,
fatigue, heat stress, hypothermia), and site security.
Support facilities, listed in Table 9-3, are located in the
Support Zone. To place these facilities, consider factors
such as:
• Accessibility. Topography, open space available,
locations of highways and railroad tracks, ease of
access for emergency vehicles.
• Resources. Adequate roads, power lines, tele-
phones, shelter, and water.
• Visibility. Line-of-sight to all activities in the Exclu-
sion Zone.
• Wind direction. Upwind of the Exclusion Zone, if
possible
• Distance As far from the Exclusion Zone as prac-
ticable.
The Buddy System
Most activities in contaminated or otherwise hazardous
areas should be conducted with a buddy who is able to:
• Provide his or her partner with assistance
• Observe his or her partner for signs of chemical or
heat exposure.
• Periodically check the integrity of his or her part-
ner's protective clothing.
• Notify the Command Post Supervisor or others if
emergency help is needed.
The Access Control Point for personnel entrance to the
Exclusion Zone is a convenient location for enforcing the
buddy system for two reasons: enforcement is the
responsibility of the Project Team Leader, who is stationed
in the CRZ, and all personnel who enter the contaminated
area must pass through the control point.
The buddy system alone may not be sufficient to ensure
that help will be provided in an emergency. At all times,
workers in the Exclusion Zone should be in line-of-sight
contact or communications contact with the Command
Post Supervisor or backup person in the Support Zone
Support Zone
The Support Zone is the location of the administrative
and other support functions needed to keep the opera-
tions in the Exclusion and Contamination Reduction
Zones running smoothly. Any function that need not or
cannot be performed in a hazardous or potentially hazard-
ous area is performed here. The Command Post Supervi-
sor should be present in the Support Zone. Other
personnel present will depend on the functions being per-
formed, and may include the Project Team Leader and
field team members who are preparing to enter or who
have returned from the Exclusion Zone.
Personnel may wear normal work clothes within this zone.
Any potentially contaminated clothing, equipment, and
samples must remain in the CRZ until decontaminated.
Support Zone personnel are responsible for alerting the
proper agency in the event of an emergency. All emer-
gency telephone numbers, change for the telephone (if
necessary), evacuation route maps, and vehicle keys
should be kept in the Support Zone
Site Security
Site security is necessary to:
• Prevent the exposure of unauthorized, unprotected
people to site hazards.
• Avoid the increased hazards from vandals or per-
sons seeking to abandon other wastes on the site.
• Prevent theft.
• Avoid interference with safe working procedures.
To maintain site security during working hours:
• Maintain security in the Support Zone and at
Access Control Points.
• Establish an identification system to identify
authorized persons and limitations to their
approved activities.
• Assign responsibility for enforcing authority for
entry and exit requirements.
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Site Control
9-5
Table 9-3. Support Zone Activities
• Erect a fence or other physical barrier around the
site.
• If the site is not fenced, post signs around the
perimeter and use guards to patrol the perimeter.
Guards must be fully apprised of the hazards
involved and trained in emergency procedures.
• Have the Project Team Leader approve all visitors
to the site. Make sure they have a valid purpose
for entering the site. Have trained site personnel
accompany visitors at all times and provide them
with the appropriate protective equipment.
To maintain site security during off-duty hours:
• If possible, assign trained, in-house technicians for
site surveillance. They will be familiar with the site,
the nature of the work, the site's hazards, and
respiratory protection techniques.
• If necessary, use security guards to patrol the site
boundary. Such personnel may be less expensive
than trained technicians, but will be more difficult
to train in safety procedures and will be less confi-
dent in reacting to problems around hazardous
substances.
• Enlist public enforcement agencies, such as the
local police department, if the site presents a sig-
nificant risk to local health and safety.
• Secure the equipment.
FACILITY
FUNCTION
Warning signs and fences help to prevent exposure of
unauthorized and unprotected people to site hazards.
Command Post Supervision of all field operations and
field teams.
Maintenance of communications, includ-
ing emergency lines of communication.
Recordkeeping, including:
— accident reports
— chain-of-custody records
— daily logbooks
— manifest directories and orders
— medical records
— personnel training records
— site inventories
— site safety map
— up-to-date Site Safety Plans
Providing access to up-to-date safety and
health manuals and other reference
materials.
Interfacing with the public: government
agencies, local politicians, medical per-
sonnel, the media, and other interested
parties.
Monitoring work schedules and weather
changes.
Maintaining site security.
Sanitary facilities.
Medical Station First-aid administration.
Medical emergency response.
Medical monitoring activities.
Sanitary facilities.
Equipment and Supply, maintenance, and repair of corn-
Supply Centers munications, respiratory, and sampling
equipment.
Maintenance and repair of vehicles.
Replacement of expendable supplies.
Storage of monitoring equipment and
supplies. Storage may be here or in an
onsite field laboratory.
Administration Sample shipment.
Interface with home office.
Maintenance of emergency telephone
numbers, evacuation route maps, and
vehicle keys.
Coordination with transporters, disposal
sites, and appropriate federal, state, and
local regulatory agencies.
Field Laboratory Coordination and processing of environ-
mental and hazardous waste samples.
Copies of the sampling plans and pro-
cedures should be available for quick
reference in the laboratory.
Packaging of materials for analysis fol-
lowing the decontamination of the out-
sides of the sample containers which
should be done in the CRZ. This packag-
ing can also be done in a designated
location in the CRZ. Shipping papers and
chain-of-custody files should be kept in
the Command Post.
Maintenance and storage of laboratory
notebooks in designated locations in the
laboratory while in use, and in the Com-
mand Post when not in use.
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9-6
Site Control
Communication Systems
Two sets of communication systems should be estab-
lished: internal communication among personnel on site,
and external communication between onsite and offsite
personnel.
Internal communication is used to:
• Alert team members to emergencies.
• Pass along safety information, such as the amount
of air time left before the next rest period, air
change, heat stress check, etc.
• Communicate changes in the work to be accom-
plished.
• Maintain site control.
Verbal communication at a site can be impeded by onsite
background noise and the use- of personal protective
equipment. For example, speech transmission through a
respirator can be poor, and hearing can be impaired by
protective hoods and respirator air flow. For effective
communication, commands must be pre-arranged. In
addition, audio or visual cues can help convey the mes-
sage. The most important thing is that signals are agreed
to in advance
Table 9-4 lists common internal communication devices.
Both a primary and backup system are necessary. A set
of signals should be established for use only during emer-
gencies (see Table 12-4 in Chapter 12 for examples).
Effective internal communication also requires the iden-
tification of individual workers so that commands can be
addressed to the right worker. The worker's name should
be marked on the suit and, for long-distance identifica-
tion, color coding, numbers, or symbols can be added.
Flags may be used to help locate personnel in areas
where visibility is poor due to obstructions such as
accumulated drums, equipment, and waste piles.
All communication devices used in a potentially explosive
atmosphere must be intrinsically safe (see footnote in
Table 9-4) and not capable of sparking, and should be
checked daily to ensure that they are operating.
An external communication system between onsite and
offsite personnel is necessary to:
• Coordinate emergency response.
• Report to management.
• Maintain contact with essential offsite personnel.
The primary means of external communication are tele-
phone and radio. If telephone lines are not installed at a
site, all team members should know the location of the
nearest telephone, and the correct change and necessary
telephone numbers should be readily available in the
Support Zone.
Safe Work Practices
To maintain a strong safety awareness and enforce safe
procedures at a site, a list of standing orders should be
developed which state the practices that must always be
followed and those that must never occur in the contami-
Table 9-4. Internal Communication Devices
Radio8
— Citizen's band
-FM
Noisemakers, including:
-Bell
— Compressed air horn
— Megaphone
— Siren
-Whistle
Visual signals, including:
-Flag
— Flares or smokeb
— Hand signals
-Lights
— Signal board
— Whole body movements
"All radios used in the Exclusion and Contamination Reduction
Zones must be certified as intrinsically safe for the situation of
intended use [2,3].
bOnly from the Support Zone.
Table 9-5. Sample Standing Orders
For Personnel Entering the Contamination Reduction Zone:
No smoking, eating, drinking, or application of cosmetics in this
zone.
No matches or lighters in this zona
Check in at the entrance Access Control Point before you enter
this zone.
Check out at the exit Access Control Point before you leave this
zone.
For Personnel Entering the Exclusion Zone:
No smoking, eating, drinking, or application of cosmetics in this
zone.
No matches or lighters in this zone.
Check in at the entrance Access Control Point before you enter
this zone.
Check out at the exit Access Control Point before you leave this
zona
Always have your buddy with you in this zone
Wear an SCBA in this zona
If you discover any signs of radioactivity, explosivity, or unusual
conditions such as dead animals at the site, exit immediately and
report this finding to your supervisor.
nated areas on site. Separate standing orders should be
developed for the Contamination Reduction Zone and the
Exclusion Zone if the hazards are sufficiently different.
Sample standing orders are given in Table 9-5. To ensure
that everyone who enters the site is aware of these orders
and that a high degree of familiarity with their content is
maintained, the list should be:
• Distributed to everyone who enters the site.
• Posted conspicuously at the Command Post.
• Posted conspicuously at the entrance Access Con-
trol Points into the Contamination Reduction Zone
and/or the Exclusion Zone.
• Reviewed by the Field Team Leader or Project
Team Leader with the field crew at the beginning
of each work day. In this way, personnel are
immediately informed of any new standing orders
-------
Site Control
9-7
resulting from a change in site conditions or work
activities.
In addition to the standing orders, a hazardous substance
information form that lists the names and properties of
chemicals present on site should be prepared and posted
conspicuously. Employees should be briefed on the chem-
ical information at the beginning of the project or when-
ever they first join the work team. Daily safety meetings
should be held for all employees.
Working with tools and heavy equipment is a major haz-
ard at sites. Injuries can result from equipment hitting or
running over personnel, impacts from flying objects,
burns from hot objects, and damage to protective equip-
ment such as supplied-air respirator systems (see Chap-
ter 8). The following precautions will help preclude
injuries due to such hazards:
• Train personnel in proper operating procedures.
• Install adequate onsite roads, signs, lights, and
devices.
• Install appropriate equipment guards and engineering
controls on tools and equipment. These include roll-
over protective structures, seat belts, emergency
shutoff in case of rollover, and backup warning lights
and signals.
• Provide equipment such as cranes, derricks, and
power shovels with signs saying "Unlawful to oper-
ate this equipment within 10 feet of all power lines."
• Use equipment and tools that are intrinsically safe
(see footnote in Table 9-4) and not capable of spark-
ing, and pneumatically and hydraulically driven
equipment.
• Where portable electric tools and appliances can be
used, (i.e., where there is no potential for flammable
or explosive conditions), use three-wire grounded
extension cords to prevent electric shocks.
• In hydraulic power tools, use fire-resistant fluid that is
capable of retaining its operating characteristics at
the most extreme temperatures.
• At the start of each work day, inspect brakes, hydrau-
lic lines, light signals, fire extinguishers, fluid levels,
steering, and splash protection.
• Keep all non-essential people out of the work area.
• Prohibit loose-fitting clothing or loose long hair
around moving machinery.
• Keep cabs free of all non-essential items and
secure all loose items.
• Do not exceed the rated load capacity of a vehicle.
• Instruct equipment operators to report to their
supervisor(s) any abnormalities such as equipment
failure, oozing liquids, unusual odors, etc.
• When an equipment operator must negotiate in
tight quarters, provide a second person to ensure
adequate clearance.
• Have a signalman direct backing as necessary.
• All onsite internal combustion engines should have
spark arresters that meet requirements for hazard-
ous atmospheres. Refuel in safe areas. Do not fuel
engines while vehicle is running. Prohibit ignition
sources near a fuel area.
Lower all blades and buckets to the ground and set
parking brakes before shutting off the vehicle.
Implement an ongoing maintenance program for
all tools and equipment. Inspect all tools and mov-
ing equipment regularly to ensure that parts are
secured and intact with no evidence of cracks or
areas of weakness, that the equipment turns
smoothly with no evidence of wobble, and that it
is operating according to manufacturer's specifica-
tions. Promptly repair or replace any defective
items. Keep maintenance and repair logs.
Store tools in clean, secure areas so that they will
not be damaged, lost, or stolen.
Keep all heavy equipment that is used in the
Exclusion Zone in that zone until the job is done.
Completely decontaminate such equipment before
moving it into the clean zone.
References
1. U.S. EPA. 1984. Standard Operating Safety Guides.
EPA Office of Emergency and Remedial Response,
Hazardous Response Support Division, Edison, NJ.
2. National Fire Protection Association. National Electrical
Code, Chapter 5, Articles 500-503. National Fire
Codes, NFPA 70.
3. National Fire Protection Association. Manual for Clas-
sification of Gases, Vapors, and Dusts for Electrical
Equipment in Hazardous Classified Locations. National
Fire Codes, NFPA 497M.
-------
10. Decontamination
Contents
Introduction 10-1
Decontamination Plan 10-1
Prevention of Contamination 10-1
Types of Contamination 10-2
Decontamination Methods 10-2
Physical Removal 10-2
Chemical Removal 10-3
Testing for the Effectiveness of Decontamination 10-4
Visual Observation 10-4
Wipe Sampling 10-4
Cleaning Solution Analysis 10-4
Testing for Permeation 10-4
Health and Safety Hazards 10-4
Decontamination Facility Design 10-4
Decontamination Equipment Selection 10-6
Disposal Methods 10-6
Personal Protection 10-6
Emergency Decontamination 10-7
References 10-7
Introduction
Decontamination—the process of removing or neutraliz-
ing contaminants that have accumulated on personnel
and equipment—is critical to health and safety at hazard-
ous waste sites. Decontamination protects workers from
hazardous substances that may contaminate and eventu-
ally permeate the protective clothing, respiratory equip-
ment, tools, vehicles, and other equipment used on site; it
protects all site personnel by minimizing the transfer of
harmful materials into clean areas; it helps prevent mixing
of incompatible chemicals; and it protects the community
by preventing uncontrolled transportation of contami-
nants from the site.
This chapter describes the types of contamination that
workers may encounter at a waste site, the factors that
influence the extent of contamination, and methods for
preventing or reducing contamination. In addition, this
chapter provides general guidelines for designing and
selecting decontamination procedures at a site, and it
presents a decision aid for evaluating the health and
safety aspects of decontamination methods. The chapter
does not cover decontamination of radioactively contami-
nated personnel or equipment. A health physicist should
be consulted if this situation arises.
Decontamination Plan
A decontamination plan should be developed (as part of
the Site Safety Plan) and set up before any personnel or
equipment may enter areas where the potential for
exposure to hazardous substances exists. The decontami-
nation plan should:
• Determine the number and layout of decontamination
stations.
• Determine the decontamination equipment needed.
• Determine appropriate decontamination methods.
• Establish procedures to prevent contamination of
clean areas.
• Establish methods and procedures to minimize
worker contact with contaminants during removal of
personal protective clothing and equipment (PPE).
• Establish methods for disposing of clothing and
equipment that are not completely decontaminated.
The plan should be revised whenever the type of personal
protective clothing or equipment changes, the site condi-
tions change, or the site hazards are reassessed based on
new information.
Prevention of Contamination
The first step in decontamination is to establish Standard
Operating Procedures that minimize contact with waste
and thus the potential for contamination. For example:
• Stress work practices that minimize contact with
hazardous substances (e.g., do not walk through
areas of obvious contamination, do not directly touch
potentially hazardous substances).
• Use remote sampling, handling, and container-
opening techniques (e.g., drum grapplers, pneumatic
impact wrenches).
• Protect monitoring and sampling instruments by bag-
ging. Make openings in the bags for sample ports and
sensors that must contact site materials.
• Wear disposable outer garments and use disposable
equipment where appropriate.
• Cover equipment and tools with a strippable coating
which can be removed during decontamination.
• Encase the source of contaminants, e.g., with plastic
sheeting or overpacks.
In addition, Standard Operating Procedures should be
established that maximize worker protection. For example,
proper procedures for dressing prior to entering the Exclu-
sion Zone will minimize the potential for contaminants to
bypass the protective clothing and escape decontamina-
tion. In general, all fasteners should be used (i.a, zippers
fully closed, all buttons used, all snaps closed, etc.).
Gloves and boots should be tucked under the sleeves and
legs of outer clothing, and hoods (if not attached) should
be worn outside the collar. Another pair of tough outer
gloves is often worn over the sleeves. All junctures should
be taped to prevent contaminants from running inside the
gloves, boots, and jackets (or suits, if one-piece
construction).
Prior to each use, the personal protective equipment (PPE)
should be checked to ensure that it contains no cuts or
punctures that could expose workers to wastes. Similarly,
any injuries to the skin surface, such as cuts and
scratches, may enhance the potential for chemicals or
infectious agents that directly contact the worker's skin
to penetrate into the body. Particular care should be taken
to protect these areas. Workers with large areas of
-------
10-2
Decontamination
damaged skin should be kept from working on site until
the skin heals.
All personnel should be trained in the Standard Operating
Procedures for minimizing contact and maximizing worker
protection, and these procedures should be enforced
throughout site operations.
Types of Contamination
Contaminants can be located either on the surface of per-
sonal protective equipment or permeated into the PPE
material. Surface contaminants may be easy to detect
and remove; however, contaminants that have permeated
a material are difficult or impossible to detect and remova
If contaminants that have permeated a material are not
removed by decontamination, they may continue to
permeate to either surface of the material where they can
cause an unexpected exposure.
Five major factors affect the extent of permeation:
• Contact time. The longer a contaminant is in contact
with an object, the greater the probability and extent
of permeation. For this reason, minimizing contact
time is one of the most important objectives of a
decontamination program.
• Concentration. Molecules flow from areas of high
concentration to areas of low concentration. As con-
centrations of wastes increase, the potential for
permeation of personal protective clothing increases.
• Temperature. An increase in temperature generally
increases the permeation rate of contaminants.
• Size of contaminant molecules and pore space.
Permeation increases as the contaminant molecule
becomes smaller, and as the pore space of tne mate-
rial to be permeated increases.
• Physical state of wastes. As a rule, gases, vapors,
and low-viscosity liquids tend to permeate more read-
ily than high-viscosity liquids or solids.
Decontamination Methods
All personnel, clothing, equipment, and samples leaving
the contaminated area of a site (generally referred to as
the Exclusion Zone) must be decontaminated to remove
any harmful chemicals or infectious organisms that may
have adhered to them. Decontamination methods either
(1) physically remove contaminants, (2) inactivate con-
taminants by chemical detoxification or disinfection/
sterilization, or (3) remove contaminants by a combination
of both physical and chemical means. Various decontami-
nation methods are listed in Table 10-1.
Physical Removal
In many cases, gross contamination can be removed by
physical means involving dislodging/displacement, rins-
ing, wiping off, and evaporation. Physical methods involv-
ing high pressure and/or heat should be used only as
necessary and with caution since they can spread con-
tamination and cause burns. Contaminants that can be
removed by physical means can be categorized as
follows:
• Loose contaminants. Dusts and vapors that cling to
equipment and workers or become trapped in small
openings, such as the weave of the clothing fabrics,
can be removed with water or a liquid rinse (see pho-
tograph). Removal of electrostatically attached
materials can be enhanced by coating the clothing or
equipment with anti-static solutions. These are avail-
able commercially as wash additives or anti-static
sprays.
• Adhering contaminants. Some contaminants adhere
by forces other than electrostatic attraction. Adhe-
sive qualities vary greatly with the specific con-
taminants and the temperature. For example,
contaminants such as glues, cements, resins, and
muds have much greater adhesive properties than
elemental mercury and, consequently, are difficult to
remove by physical means. Physical removal methods
for gross contaminants include scraping, brushing,
and wiping. Removal of adhesive contaminants can
be enhanced through certain methods such as solidi-
fying, freezing (e.g., using dry ice or ice water),
adsorption or absorption (e.g., with powdered lime or
kitty litter), or melting.
• Volatile liquids. Volatile liquid contaminants can be
removed from protective clothing or equipment by
evaporation followed by a water rinse. Evaporation of
volatile liquids can be enhanced by using steam jets.
With any evaporation or vaporization process, care
must be taken to prevent worker inhalation of the
vaporized chemicals.
Table 10-1. Some Decontamination Methods
REMOVAL
• Contaminant Removal
Water rinse, using pressurized or gravity flow.
Chemical leaching and extraction.
Evaporation/vaporization.
Pressurized air jets.
Scrubbing/scraping. Commonly done using brushes, scrapers,
or sponges and water-compatible solvent cleaning solutions.
Steam jets.
• Removal of Contaminated Surfaces
Disposal of deeply permeated materials, eg., clothing, floor
mats, and seats.
Disposal of protective coverings/coatings.
INACTIVATION
• Chemical Detoxification
Halogen stripping.
Neutralization.
Oxidation/reduction.
Thermal degradation.
• Disinfection/Sterilization
Chemical disinfection.
Dry heat sterilization.
Gas/vapor sterilization.
Irradiation.
Steam sterilization.
-------
Decontamination
10-3
Gross contaminants can be removed with water or a
liquid rinse. Here, a member of the decontamination team
rinses and scrubs the boots of a worker with a soft-
bristled brush. Both individuals are wearing Level C per-
sonal protective equipment.
Chemical Removal
Physical removal of gross contamination should be fol-
lowed by a wash/rinse process using cleaning solutions.
These cleaning solutions normally utilize one or more of
the following methods:
• Dissolving contaminants. Chemical removal of sur-
face contaminants can be accomplished by dis-
solving them in a solvent. The solvent must be
chemically compatible with the equipment being
cleaned. This is particularly important when decon-
taminating personal protective clothing constructed
of organic materials that could be damaged or dis-
solved by organic solvents. In addition, care must be
taken in selecting, using, and disposing of any
organic solvents that may be flammable or potentially
toxic. Organic solvents include alcohols, ethers,
ketones, aromatics, straight-chain alkanes, and com-
mon petroleum products.
Halogenated solvents generally are incompatible with
personal protective equipment and are toxic. They
should only be used for decontamination in extreme
cases where other cleaning agents will not remove
the contaminant.
Table 10-2 provides a general guide to the solubility
of several contaminant categories in four types of
solvents: water, dilute acids, dilute bases, and
organic solvents. Because of the potential hazards,
decontamination using chemicals should be done
only if recommended by an industrial hygienist or
other qualified health professional.
• Surfactants. Surfactants augment physical cleaning
methods by reducing adhesion forces between con-
taminants and the surface being cleaned, and by
preventing redeposit of the contaminants. Household
detergents are among the most common surfactants.
Some detergents can be used with organic solvents
to improve the dissolving and dispersal of con-
taminants into the solvent [1].
• Solidification. Solidifying liquid or gel contaminants
can enhance their physical removal. The mechanisms
of solidification are: (1) moisture removal through the
use of absorbents such as grounded clay or pow-
dered lime; (2) chemical reactions via polymerization
catalysts and chemical reagents; and (3) freezing
using ice water.
Table 10-2. General Guide to Solubility of Contaminants in
Four Solvent Types
SOLVENT
SOLUBLE CONTAMINANTS
Water
Dilute Acids
Dilute Bases
For example:
— detergent
— soap
Organic Solvents8
For example:
— alcohols
— ethers
— ketones
— aromatics
— straight-chain
alkanes (e.g., hexane)
— common petroleum
products (e.g., fuel
oil, kerosene)
Low-chain hydrocarbons.
Inorganic compounds.
Salts.
Some organic acids and other polar
compounds.
Basic (caustic) compounds.
Amines.
Hydrazines.
Acidic compounds.
Phenols.
Thiols.
Some nitro and sulfonic compounds.
Nonpolar compounds (e.g., some
organic compounds).
"WARNING: Some organic solvents can permeate and/or degrade
the protective clothing.
• Rinsing. Rinsing removes contaminants through
dilution, physical attraction, and solubilization.
Multiple rinses with clean solutions remove more
contaminants than a single rinse with the same
volume of solution. Continuous rinsing with large
volumes will remove even more contaminants than
multiple rinsings with a lesser total volume.
• Disinfection/Sterilization. Chemical disinfectants
are a practical means of inactivating infectious
agents. Unfortunately, standard sterilization tech-
niques are generally impractical for large equip-
ment and for personal protective clothing and
equipment. For this reason, disposable PPE is
recommended for use with infectious agents.
Many factors, such as cost, availability, and ease of
implementation, influence the selection of a decontamina-
-------
10-4
Decontamination
tion method. From a health and safety standpoint, two
key questions must be addressed:
• Is the decontamination method effective for the
specific substances present?
• Does the method itself pose any health or safety
hazards?
Testing for the Effectiveness
of Decontamination
Decontamination methods vary in their effectiveness for
removing different substances. The effectiveness of any
decontamination method should be assessed at the
beginning of a program and periodically throughout the
lifetime of the program. If contaminated materials are not
being removed or are penetrating protective clothing, the
decontamination program must be revised. The following
methods may be useful in assessing the effectiveness of
decontamination.
Visual Observation
There is no reliable test to immediately determine how
effective decontamination is. In some cases, effective-
ness can be estimated by visual observation.
• Natural light. Discolorations, stains, corrosive
effects, visible dirt, or alterations in clothing fabric
may indicate that contaminants have not been
removed. However, not all contaminants leave visi-
ble traces; many contaminants can permeate
clothing and are not easily observed.
• Ultraviolet light. Certain contaminants, such as
polycyclic aromatic hydrocarbons, which are com-
mon in many refined oils and solvent wastes,
fluoresce and can be visually detected when
exposed to ultraviolet light. Ultraviolet light can be
used to observe contamination of skin, clothing,
and equipment; however, certain areas of the skin
may fluoresce naturally, thereby introducing an
uncertainty into the test [2,3,4]. In addition, use of
ultraviolet light can increase the risk of skin cancer
and eye damage; therefore, a qualified health
professional should assess the benefits and risks
associated with ultraviolet light prior to its use at a
waste site.
Wipe Sampling
Wipe testing provides after-the-fact information on the
effectiveness of decontamination. In this procedure, a dry
or wet cloth, glass fiber filter paper, or swab is wiped
over the surface of the potentially contaminated object
and then analyzed in a laboratory. Both the inner and
outer surfaces of protective clothing should be tested.
Skin may also be tested using wipe samples.
Cleaning Solution Analysis
Another way to test the effectiveness of decontamination
procedures is to analyze for contaminants left in the
cleaning solutions. Elevated levels of contaminants in the
final rinse solution may suggest that additional cleaning
and rinsing are needed.
Testing for Permeation
Testing for the presence of permeated chemical con-
taminants requires that pieces of the protective garments
be sent to a laboratory for analysis.
Health and Safety Hazards
While decontamination is performed to protect health and
safety, it can pose hazards under certain circumstances.
Decontamination methods may:
• Be incompatible with the hazardous substances
being removed (i.e., a decontamination method may
react with contaminants to produce an explosion,
heat, or toxic products).
• Be incompatible with the clothing or equipment being
decontaminated (e.g., some organic solvents can
permeate and/or degrade protective clothing).
• Pose a direct health hazard to workers (e.g., vapors
from chemical decontamination solutions may be
hazardous if inhaled, or they may be flammable).
The chemical and physical compatibility of the decon-
tamination solutions or other decontamination materials
must be determined before they are used. Any decon-
tamination method that permeates, degrades, damages,
or otherwise impairs the safe functioning of the PPE is
incompatible with such PPE and should not be used. If a
decontamination method does pose a direct health haz-
ard, measures must be taken to protect both decontami-
nation personnel and the workers being decontaminated.
Figure 10-1 presents a decision aid for evaluating the
health and safety aspects of decontamination methods.
Decontamination Facility Design
At a hazardous waste site, decontamination facilities
should be located in the Contamination Reduction Zone
(CRZ), i.e., the area between the Exclusion Zone (the con-
taminated area) and the Support Zone (the clean area) as
shown in Figure 9-1 in Chapter 9.
The level and types of decontamination procedures
required depend on several site-specific factors including:
• The chemical, physical, and toxicological properties
of the wastes.
• The pathogenicity of infectious wastes.
• The amount, location, and containment of con-
taminants.
• The potential for, and location of, exposure based on
assigned worker duties, activities, and functions.
• The potential for wastes to permeate, degrade, or
penetrate materials used for personal protective
clothing and equipment, vehicles, tools, buildings,
and structures.
• The proximity of incompatible wastes.
• The movement of personnel and/or equipment among
different zones.
• Emergencies.
• The methods available for protecting workers during
decontamination.
-------
Decontamination
10-5
NO
Is the method effective for
removing contaminants?
YES
NO
Are the decontamination
materials compatible with the
hazardous substances present?
YES
NO
Are the decontamination
materials compatible with the
materials to be decontaminated?
YES
Do the decontamination materials
or process pose health or safety
hazards?
NO
Take additional measures to
prevent contamination or find
another decontamination
method.
Consult specialists if necessary.
YES
NO
Can appropriate protective
measures be instituted?
YES
Method OK to use.
Figure 10-1. Decision Aid for Evaluating Health and Safety Aspects of Decontamination Methods.
• The impact of the decontamination process and com-
pounds on worker safety and health.
Decontamination procedures must provide an organized
process by which levels of contamination are reduced.
The decontamination process should consist of a series
of procedures performed in a specific sequence. For
example, outer, more heavily contaminated items (e.g.,
outer boots and gloves) should be decontaminated and
removed first, followed by decontamination and removal
of inner, less contaminated items (e.g., jackets and pants).
Each procedure should be performed at a separate station
in order to prevent cross contamination. The sequence of
stations is called the decontamination lina
Stations should be separated physically to prevent cross
contamination and should be arranged in order of
decreasing contamination, preferably in a straight line.
Separate flow patterns and stations should be provided to
isolate workers from different contamination zones con-
taining incompatible wastes. Entry and exit points should
be conspicuously marked, and the entry to the Contami-
nation Reduction Zone (CRZ) from the Exclusion Zone
should be separate from the entry to the Exclusion Zone
from the CRZ. Dressing stations for entry to the CRZ
should be separate from redressing areas for exit from the
CRZ. Personnel who wish to enter clean areas of the
decontamination facility, such as locker rooms, should be
completely decontaminated.
Examples of decontamination lines and procedures for
personnel wearing various levels of protection are
provided in Appendix D.
-------
10-6
Decontamination
A member of the decontamination team suited in Level B
personal protective equipment stands by to scrub down a
worker after an initial rinse down in the decontamination
shower.
Decontamination Equipment Selection
Table 10-3 lists recommended equipment for decontami-
nation of personnel, personal protective clothing, and
equipment. In selecting decontamination equipment, con-
sider whether the equipment itself can be decontami-
nated for reuse or can be easily disposed of. Table 10-4
lists recommended equipment for decontamination of
large equipment and vehicles. Note that other types of
equipment not listed in Tables 10-3 and 10-4 may be
appropriate in certain situations.
Disposal Methods
All equipment used for decontamination must be decon-
taminated and/or disposed of properly. Buckets, brushes,
clothing, tools, and other contaminated equipment should
be collected, placed in containers, and labeled. Also, all
spent solutions and wash water should be collected and
disposed of properly. Clothing that is not completely
decontaminated should be placed in plastic bags, pending
further decontamination and/or disposal.
Table 10-3. Some Recommended Equipment for
Decontamination of Personnel and Personal
Protective Clothing and Equipment
• Drop cloths of plastic or other suitable materials on which heavily
contaminated equipment and outer protective clothing may be
deposited.
• Collection containers, such as drums or suitably lined trash cans,
for storing disposable clothing and heavily contaminated personal
protective clothing or equipment that must be discarded.
• Lined box with absorbents for wiping or rinsing off gross con-
taminants and liquid contaminants.
• Large galvanized tubs, stock tanks, or children's wading pools to
hold wash and rinse solutions. These should be at least large
enough for a worker to place a booted foot in, and should have
either no drain or a drain connected to a collection tank or
appropriate treatment system.
• Wash solutions selected to wash off and reduce the hazards
associated with the contaminants.
• Rinse solutions selected to remove contaminants and contami-
nated wash solutions.
• Long-handled, soft-bristled brushes to help wash and rinse off
contaminants.
• Paper or cloth towels for drying protective clothing and
equipment.
• Lockers and cabinets for storage of decontaminated clothing and
equipment.
• Metal or plastic cans or drums for contaminated wash and rinse
solutions.
• Plastic sheeting, sealed pads with drains, or other appropriate
methods for containing and collecting contaminated wash and
rinse solutions spilled during decontamination.
• Shower facilities for full body wash or, at a minimum, personal
wash sinks (with drains connected to a collection tank or
appropriate treatment system).
• Soap or wash solution, wash cloths, and towels for personnel.
• Lockers or closets for clean clothing and personal item storaga
Personal Protection
Decontamination workers who initially come in contact
with personnel and equipment leaving the Exclusion Zone
will require more protection from contaminants than
decontamination workers who are assigned to the last
station in the decontamination line. In some cases, decon-
tamination personnel should wear the same levels of PPE
as workers in the Exclusion Zona In other cases, decon-
tamination personnel may be sufficiently protected by
wearing one level lower protection (ag., wearing Level C
protection while decontaminating workers who are wear-
ing Level B).
The level of protection required will vary with the type of
decontamination equipment used. For example, workers
using a steam jet may need a different type of respiratory
protection than other decontamination personnel because
of the high moisture levels produced by steam jets. In
some situations, the cleaning solutions used and wastes
removed during decontamination may generate harmful
vapors. Appropriate equipment and clothing for protecting
decontamination personnel should be selected by a quali-
fied health and safety expert.
-------
Decontamination
10-7
Table 10-4. Some Recommended Equipment for
Heavy Equipment and Vehicle Decontamination
• Storage tanks of appropriate treatment systems for temporary
storage and/or treatment of contaminated wash and rinse
solutions.
• Drains or pumps for collection of contaminated wash and rinse
solutions.
• Long-handled brushes for general exterior cleaning.
• Wash solutions selected to remove and reduce the hazards
associated with the contamination.
• Rinse solutions selected to remove contaminants and con-
taminated wash solutions.
• Pressurized sprayers for washing and rinsing, particularly
hard-to-reach areas.
• Curtains, enclosures, or spray booths to contain splashes from
pressurized sprays.
• Long-handled brushes, rods, and shovels for dislodging con-
taminants and contaminanted soil caught in tires and the under-
sides of vehicles and equipment.
• Containers to hold contaminants and contaminated soil removed
from tires and the undersides of vehicles and equipment.
• Wash and rinse buckets for use in the decontamination of opera-
tor areas inside vehicles and equipment.
• Brooms and brushes for cleaning operator areas inside vehicles
and equipment.
• Containers for storage and disposal of contaminated wash and
rinse solutions, damaged or heavily contaminated parts, and
equipment to be discarded.
References
1. Rosen, M.J. 1978. Surfactants and Interfacial
Phenomena. Wiley-lnterscience Publication, NY.
304 pp.
2. Vo-Dinh, T. 1983. Surface detection of contamination:
Principles, applications, and recent developments. J.
Environ. Sci. January/February 1983, pp. 40-43.
3. Vo-Dinh, T. and R.B. Gammage. 1981. The Use of a
Fiberoptics Skin Contamination Monitor in the Work-
place. Chemical Hazards in the Workplace, American
Chemical Society, pp 269-281.
4. Vo-Dinh, T. and R.B. Gammage. 1981. The lightpipe
luminoscope for monitoring occupational skin contami-
nation. J. Am. Ind. Hyg. Assoc. 42:112-120.
All decontamination workers are in a contaminated area
and must themselves be decontaminated before entering
the clean Support Zone. The extent of their decontamina-
tion should be determined by the types of contaminants
they may have contacted and the type of work they per-
formed.
Emergency Decontamination
In addition to routine decontamination procedures, emer-
gency decontamination procedures must be established.
In an emergency, the primary concern is to prevent the
loss of life or severe injury to site personnel. If immediate
medical treatment is required to save a life, decontamina-
tion should be delayed until the victim is stabilized. If
decontamination can be performed without interfering
with essential life-saving techniques or first aid, or if a
worker has been contaminated with an extremely toxic or
corrosive material that could cause severe injury or loss of
life, decontamination must be performed immediately. If
an emergency due to a heat-related illness develops, pro-
tective clothing should be removed from the victim as
soon as possible.to reduce the heat stress. During an
emergency, provisions must also be made for protecting
medical personnel and disposing of contaminated clothing
and equipment. See Chapter 12 for further information on
decontamination during emergencies.
-------
11. Handling Drums and Other Containers
Contents
Introduction 11-1
Inspection 11-1
Planning 11-3
Handling 11-3
Drums Containing Radioactive Waste 11-4
Drums that May Contain Explosive or Shock-
Sensitive Wastes 11-4
Bulging Drums 11-4
Drums Containing Packaged Laboratory Wastes
(Lab Packs) 11-4
Leaking, Open, and Deteriorated Drums 11-4
Buried Drums 11-5
Opening 11-5
Sampling 11-6
Characterization 11-7
Staging 11-8
Bulking 11-9
Shipment 11-9
Special Case Problems 11-11
Tanks and Vaults 11-11
Vacuum Trucks 11-12
Elevated Tanks 11-12
Compressed Gas Cylinders 11-12
Ponds and Lagoons 11-12
References 11-12
Introduction
Accidents may occur during handling of drums and other
hazardous waste containers. Hazards include detonations,
fires, explosions, vapor generation, and physical injury
resulting from moving heavy containers by hand and
working around stacked drums, heavy equipment, and
deteriorated drums. While these hazards are always pres-
ent, proper work practices—such as minimizing handling
and using equipment and procedures that isolate workers
from hazardous substances—can minimize the risks to
site personnel.
This chapter defines practices and procedures for safe
handling of drums and other hazardous waste containers.
It is intended to aid the Project Team Leader in setting up
a waste container handling program. In addition to read-
ing this chapter, the Project Team Leader should also be
aware of all pertinent regulations. OSHA regulations (29
CFR Parts 1910 and 1926) include general requirements
and standards for*storing, containing, and handling chem-
icals and containers, and for maintaining equipment used
for handling materials. EPA regulations (40 CFR Part 265)
stipulate requirements for types of containers, main-
tenance of containers and containment structures, and
design and maintenance of storage areas. DOT regula-
tions (49 CFR Parts 171 through 178) also stipulate
requirements for containers and procedures for shipment
of hazardous wastes.
Containers are handled during characterization and
removal of their contents and during other operations. A
flow chart showing one set of possible procedures for
drum handling is given in Figure 11-1. Guidance for safely
performing the procedures shown in Figure 11-1 is
provided in the following sections of this chapter. The
final section, Special Case Problems, describes the
handling of tanks, vaults, vacuum trucks, elevated tanks,
and compressed gas cylinders.
Inspection
The appropriate procedures for handling drums depend on
the drum contents. Thus, prior to any handling, drums
should be visually inspected to gain as much information
as possible about their contents. The inspection crew
should look for:
• Symbols, words, or other marks on the drum indicat-
ing that its contents are hazardous, e.g., radioactive,
explosive, corrosive, toxic, flammable.
• Symbols, words, or other marks on a drum indicating
that it contains discarded laboratory chemicals, rea-
gents, or other potentially dangerous materials in
small-volume individual containers (see Table 11-1).
• Signs of deterioration such as corrosion, rust, and
leaks.
• Signs that the drum is under pressure such as swell-
ing and bulging.
• Drum type (see Table 11-1).
• Configuration of the drumhead (see Table 11-2).
Conditions in the immediate vicinity of the drums may
provide information about drum contents and their
associated hazards. Monitoring should be conducted
around the drums using instruments such as a gamma
radiation survey instrument, organic vapor monitors, and
a combustible gas meter.
The results of this survey can be used to classify the
drums into preliminary hazard categories, for example:
• Radioactive.
• Leaking/deteriorated.
• Bulging.
• Explosive/shock-sensitive.
• Contains small-volume individual containers of
laboratory wastes or other dangerous materials.
As a precautionary measure, personnel should assume
that unlabelled drums contain hazardous materials until
their contents are characterized. Also, they should bear in
mind that drums are frequently mislabelled—particularly
drums that are reused. Thus, a drum's label may not
accurately describe its contents.
If buried drums are suspected, ground-penetrating sys-
tems, such as electromagnetic wave, electrical resistivity,
ground-penetrating radar, magnetometry, and metal
detection, can be used to estimate the location and depth
of the drums.
-------
11-2 Handling Drums and Other Containers
INSPECTION
Inspect drums
^**Han<
^^^ neces
i
'
sary? ^f~
NO
F
OPENING
Open drums
\
f
SAMPLING
Develop sampling
plan. Sample
drum contents
i
^*^r Staging ^^H
"^^. necessary? ^^^
JNO
PLANNING
Develop a
handling plan
i '
HANDLING
Orient drums
for opening
and sampling
f
CHARACTERIZATION
Characterize wastes
i
f
BULKING
Transfer drum
contents into
bulk containers
1 '
SHIPMENT
Ship bulked wastes and/or
drums to offsite treatment,
storage, or disposal facility
e PLANNING
o
-*• Develop a
staging plan
STAGING
Move drums to
first staging area
1 (if appropriate)
"J
Move drums to
opening/sampling .
area ^
(if appropriate)
3
Move drums to
second staging |
area
(if appropriate) .
~
-
r~ i
Move drums to
final staging area !•<-
(if appropriate)
1_ _i
~
r
BULKING
Transfer drum
contents into
bulk containers
OPENING
Open drums
j
SAMPLING
Sample drum contents
\
CHARACTERIZATION
Characterize wastes
Figure 11-1. Flow Chart for Drum Handling. (Dashed boxes indicate optional steps.
Number of staging areas necessary is site specific.)
-------
Handling Drums and Other Containers
11-3
Table 11-1. Special Drum Types and
Their Associated Hazards
Polyethylene or
PVC-Lined Drums
Exotic Metal
Drums (e.g., alumi-
num, nickel, stain-
less, steel, or other
unusual metall
Single-Walled
Drums Used as a
Pressure Vessel
Laboratory Packs
Often contain strong acids or bases. If the
lining is punctured, the substance usually
quickly corrodes the steel, resulting in a
significant leak or spill.
Very expensive drums that usually con-
tain an extremely dangerous material.
These drums have fittings for both
product filling and placement of an inert
gas, such as nitrogen. May contain reac-
tive, flammable, or explosive substances.
Used for disposal of expired chemicals
and process samples from university
laboratories, hospitals, and similar institu-
tions. Individual containers within the lab
pack are often not packed in absorbent
material. They may contain incompatible
materials, radioisotopes, shock-sensitive,
highly volatile, highly corrosive, or very
toxic exotic chemicals. Laboratory packs
can be an ignition source for fires at
hazardous waste sites.
Table 11-2. Information Provided by
Drumhead Configuration
CONFIGURATION
INFORMATION
Whole lid removable.
Has a bung.
Contains a liner.
Designed to contain solid
material.
Designed to contain a liquid.
May contain a highly corrosive
or otherwise hazardous material.
to facilitate characterization and remedial action (see
Staging in this chapter). Handling may or may not be
necessary, depending on how the drums are positioned at
a site.
Since accidents occur frequently during handling, particu-
larly initial handling, drums should only be handled if
necessary. Prior to handling, all personnel should be
warned about the hazards of handling, and instructed to
minimize handling as much as possible and to avoid
unnecessary handling. In all phases of handling, person-
nel should be alert for new information about potential
hazards. These hazards should be responded to before
continuing with more routine handling operations. Over-
pack drums (larger drums in which leaking or damaged
drums are placed for storage or shipment [see 49 CFR
Part 173.3(c)]) and an adequate volume of absorbent
should be kept near areas where minor spills may occur.
Where major spills may occur, a containment berm ade-
quate to contain the entire volume of liquid in the drums
should be constructed before any handling takes place. If
the drum contents spill, personnel trained in spill response
should be used to isolate and contain the spill.
Several types of equipment can be used to move drums:
(1) A drum grappler attached to a hydraulic excavator;
(2) a small front-end loader, which can be either loaded
manually or equipped with a bucket sling; (3) a rough ter-
rain forklift; (4) a roller conveyor equipped with solid
rollers; and (5) drum carts designed specifically for drum
handling. Drums are also sometimes moved manually. The
drum grappler is the preferred piece of equipment for
drum handling. It keeps the operator removed from the
drums so that there is less likelihood of injury if the drums
detonate or rupture. If a drum is leaking, the operator can
stop the leak by rotating the drum and immediately plac-
ing it into an overpack. In case of an explosion, grappler
claws help protect the operator by partially deflecting the
force of the explosion.
Planning
Since drum handling is fraught with danger, every step of
the operation should be carefully planned, based on all
the information available at the time. The results of the
preliminary inspection can be used to determine (1) if any
hazards are present and the appropriate response, and
(2) which drums need to be moved in order to be opened
and sampled. A preliminary plan should be developed
which specifies the extent of handling necessary, the per-
sonnel selected for the job, and the most appropriate
procedures based on the hazards associated with the
probable drum contents as determined by visual inspec-
tion. This plan should be revised as new information is
obtained during drum handling.
Backhoe with drum grappler.
Handling
The purpose of handling is to (1) respond to any obvious
problems that might impair worker safety, such as radio-
activity, leakage, or the presence of explosive substances,
(2) unstack and orient drums for sampling, and (3) if
necessary, to organize drums into different areas on site
The following procedures can be used to maximize
worker safety during drum handling and movement:
• Train personnel in proper lifting and moving tech-
niques to prevent back injuries.
• Make sure the vehicle selected has sufficient rated
load capacity to handle the anticipated loads, and
-------
11-4
Handling Drums and Other Containers
make sure the vehicle can operate smoothly on the
available road surface.
• Air condition the cabs of vehicles to increase opera-
tor efficiency; protect the operator with heavy splash
shields.
• Supply operators with appropriate respiratory protec-
tive equipment when needed. Normally either a com-
bination SCBA/SAR with the air tank fastened to the
vehicle, or an airline respirator and an escape SCBA
are used because of the high potential hazards of
drum handling. This improves operator efficiency and
provides protection in case the operator must aban-
don the equipment.
• Have overpacks ready before any attempt is made to
move drums.
• Before moving anything, determine the most appro-
priate sequence in which the various drums and
other containers should be moved. For example, small
containers may have to be removed first to permit
heavy equipment to enter and move the drums.
• Exercise extreme caution in handling drums that are
not intact and tightly sealed.
• Ensure that operators have a clear view of the road-
way when carrying drums. Where necessary, have
ground workers available to guide the operator's
motion.
Drums Containing Radioactive Waste
* If the drum exhibits radiation levels above back-
ground (see Table 6-2), immediately contact a health
physicist. Do not handle any drums that are deter-
mined to be radioactive until persons with expertise
in this area have been consulted.
Drums that May Contain Explosive or
Shock-Sensitive Waste
• If a drum is suspected to contain explosive or shock-
sensitive waste as determined by visual inspection,
seek specialized assistance before any handling.
• If handling is necessary, handle these drums with
extreme caution.
• Prior to handling these drums, make sure all non-
essential personnel have moved a safe distance away.
• Use a grappler unit constructed for explosive contain-
ment for initial handling of such drums.
• Palletize the drums prior to transport. Secure drums
to pallets.
• Use an audible siren signal system, similar to that
employed in conventional blasting operations, to
signal the commencement and completion of explo-
sive waste handling activities.
• Maintain continuous communication with the Site
Safety Officer and/or the command post until drum
handling operations are complete.
Bulging Drums
• Pressurized drums are extremely hazardous. Wher-
ever possible, do not move drums that may be
under internal pressure, as evidenced by bulging or
swelling.
If a pressurized drum has to be moved, whenever
possible handle the drum with a grappler unit con-
structed for explosive containment. Either move
the bulged drum only as far as necessary to allow
seating on firm ground, or carefully overpack the
drum. Exercise extreme caution when working
with or adjacent to potentially pressurized drums.
Drums Containing Packaged Laboratory Wastes
(Lab Packs)
Laboratory packs (i.e., drums containing individual con-
tainers of laboratory materials normally surrounded by
cushioning absorbent material) can be an ignition source
for fires at hazardous waste sites. They sometimes con-
tain shock-sensitive materials. Such containers should be
considered to hold explosive or shock-sensitive wastes
until otherwise characterized. If handling is required, the
following precautions are among those that should be
taken:
• Prior to handling or transporting lab packs, make sure
all non-essential personnel have moved a safe dis-
tance away.
• Whenever possible, use a grappler unit constructed
for explosive containment for initial handling of such
drums.
• Maintain continuous communication with the Site
Safety Officer and/or the command post until han-
dling operations are complete.
• Once a lab pack has been opened, have a chemist
inspect, classify, and segregate the bottles within it,
without opening them, according to the hazards of
the wastes. An example of a system for classifying
lab pack wastes is provided in Table 11-3. The objec-
tive of a classification system is to ensure safe segre-
gation of the lab packs' contents. Pack these bottles
with sufficient cushioning and absorption materials
to prevent excessive movement of the bottles and to
absorb all free liquids, and ship them to an approved
disposal facility.
• If crystalline material is noted at the neck of any
bottle, handle it as a shock-sensitive waste, due to
the potential presence of picric acid or other similar
material, and get expert advice before attempting to
handle it.
• Palletize the repacked drums prior to transport.
Secure the drums to pallets.
Leaking, Open, and Deteriorated Drums
• If a drum containing a liquid cannot be moved with-
out rupture, immediately transfer its contents to a
sound drum using a pump designed for transfering
that liquid.
• Using a drum grappler, place immediately in overpack
containers:
Leaking drums that contain sludges or semi-solids.
Open drums that contain liquid or solid waste.
Deteriorated drums that can be moved without
rupture.
-------
Handling Drums and Other Containers
11-5
Table 11-3. Example of Lab Pack Content Classification
System for Disposal
CLASSIFICATION
EXAMPLES
Inorganic acids
Inorganic bases
Strong oxidizing agents
Strong reducing agents
Anhydrous organics and
organometallics
Anhydrous inorganics and
metal hydrides
Toxic organics
Flammable organics
Inorganics
Inorganic cyanides
Organic cyanides
Toxic metals
Hydrochloric
Sulfuric
Sodium hydroxide
Potassium hydroxide
Ammonium nitrate
Barium nitrate
Sodium chlorate
Sodium peroxide
Sodium thiosulfate
Oxalic acid
Sodium sulphite
Tetraethyl lead
Phenylmercuric chloride
Potassium hydride
Sodium hydride
Sodium metal
Potassium
PCBs
Insecticides
Hexane
Toluene
Acetone
Sodium carbonate
Potassium chloride
Potassium cyanide
Sodium cyanide
Copper cyanide
Cyanoacetamide
Arsenic
Cadmium
Lead
Mercury
Buried Drums
• Prior to initiating subsurface excavation, use ground-
penetrating systems to estimate the location and
depth of the drums (see Inspection in this chapter).
• Remove soil with great caution to minimize the
potential for drum rupture.
• Have a dry chemical fire extinguisher on hand to con-
trol small fires.
Opening
Drums are usually opened and sampled in place during
site investigations. However, remedial and emergency
operations may require a separate drum opening area (see
Staging in this chapter). Procedures for opening drums
are the same, regardless of where the drums are opened.
To enhance the efficiency and safety of drum-opening
personnel, the following procedures should be instituted.
• If a supplied-air respiratory protection system is used,
place a bank of air cylinders outside the work area
and supply air to the operators via airlines and
escape SCBAs. This enables workers to operate in
relative comfort for extended periods of time.
• Protect personnel by keeping them at a safe distance
from the drums being opened. If personnel must be
located near the drums, place explosion-resistant
plastic shields between them and the drums to pro-
tect them in case of detonation. Locate controls for
drum opening equipment, monitoring equipment, and
fire suppression equipment behind the explosion-
resistant plastic shield.
• If possible, monitor continuously during opening.
Place sensors of monitoring equipment, such as
colorimetric tubes, dosimeters, radiation survey
instruments, explosion meters, organic vapor
analyzers, and oxygen meters, as close as possible
to the source of contaminants, i.e., at the drum
opening.
• Use the following remote-controlled devices for
opening drums:
Pneumatically operated impact wrench to remove
drum bungs.
Hydraulically or pneumatically operated drum
piercers (see Figure 11-2).
Backhoes equipped with bronze spikes for
penetrating drum tops in large-scale operations
(see Figure 11-3).
• Do not use picks, chisels and firearms to open
drums.
• Hang or balance the drum opening equipment to
minimize worker exertion.
• If the drum shows signs of swelling or bulging,
perform all steps slowly. Relieve excess pressure
prior to opening and, if possible, from a remote
location using such devices as a pneumatic impact
wrench or hydraulic penetration device. If pressure
must be relieved manually, place a barrier such as
explosion-resistant plastic sheeting between the
worker and bung to deflect any gas, liquid, or
solids which may be expelled as the bung is
loosened.
Two drums with rusted bungs were opened by backhoes
with bronze spikes and now await sampling. Drum in fore-
ground has been labelled "150" for sample documenta-
tion purposes.
-------
11-6
Handling Drums and Other Containers
REMOTE
LOCATION
NEEDLE VALVE
AIR/HYDRAULIC CYLINDER
55 GAL DRUM
CONVEYOR
3-WAY VALVE
APPROX. 50 FT. OF HOSE
SPLASH PLATE
REPLACEABLE 316 STAINLESS
STEEL CONICAL PLUNGER
(3 IN. DIA. X 4 IN. LG.)
DOORS (2 SIDES)
BELT CONVEYOR
DRAIN TO VACUUM TRUCK,
WASTE RECOVERY SYSTEM
OR TANK
FORK LIFT SLOTS
SPILL CONTAINMENT PAN &
SUPPORT FRAME (75-GAL. CAPACITY)
Figure 11-2. Air/Hydraulic-Operated Single-Drum Puncture Device.
Source: Reference [1].
Open exotic metal drums and polyethylene or
polyvinyl chloride-lined (PVC-lined) drums through
the bung by removal or drilling. Exercise extreme
caution when manipulating these containers.
Do not open or sample individual containers within
laboratory packs.
Reseal open bungs and drill openings as soon as
possible with new bungs or plugs to avoid explo-
sions and/or vapor generation. If an open drum
cannot be reseated, place the drum into an over-
pack. Plug any openings in pressurized drums with
pressure-venting caps set to a 5-psi (pounds per
square inch) release to allow venting of vapor
pressure
• Decontaminate equipment after each use to avoid
mixing incompatible wastes.
Sampling
Drum sampling can be one of the most hazardous activi-
ties to worker safety and health because it often involves
direct contact with unidentified wastes. Prior to collecting
any sample, develop a sampling plan:
• Research background information about the waste.
• Determine which drums should be sampled.
• Select the appropriate sampling device(s) and
container(s).
-------
Handling Drums and Other Containers
11-7
REPLACEABLE 316 STAINLESS
STEEL CONICAL PLUNGER
(3 IN. DIA. X 4 IN. LG.)
HYDRAULIC CYL
WITH 6-IN. STROKE
SPLASH PLATE
STANDARD SINGLE
DRUM GRABBER
SPILL CONTAINMENT PAN
(PORTABLE) 75-GAL CAPACITY
55-GALLON
- DRUM
HYDRAULIC LINES
DRAIN TO VACUUM TRUCK, WASTE
RECOVERY SYSTEM OR TANK
Figure 11-3. Backhoe-Mounted Drum Puncture Device.
Source: Reference 11].
• Develop a sampling plan which includes the number,
volume, and locations of samples to be taken.
• Develop Standard Operating Procedures for opening
drums, sampling, and sample packaging and trans-
portation. Some guidance in designing proper
sampling procedures can be found in References [2]
and [3].
* Have a trained health and safety professional deter-
mine, based on available information about the
wastes and site conditions, the appropriate personal
protection to be used during sampling, decontamina-
tion, and packaging of the sample.
When manually sampling from a drum, use the following
techniques:
• Keep sampling personnel at a safe distance while
drums are being opened. Sample only after opening
operations are complete
• Do not lean over other drums to reach the drum being
sampled, unless absolutely necessary.
Cover drum tops with plastic sheeting or other suit-
able noncontaminated materials to avoid excessive
contact with the drum tops.
Never stand on drums. This is extremely dangerous.
Use mobile steps or another platform to achieve the
height necessary to safely sample from the drums.
Obtain samples with either glass rods or vacuum
pumps. Do not use contaminated items such as dis-
carded rags to sample. The contaminants may con-
taminate the sample and may not be compatible with
the waste in the drum. Glass rods should be removed
prior to pumping to minimize damage to pumps.
Characterization
The goal of characterization is to obtain the data neces-
sary to determine how to safely and efficiently package
and transport the wastes for treatment and/or disposal.
If wastes are bulked, they must be sufficiently character-
-------
11-8
Handling Drums and Other Containers
SITE:
DRUM SIZE:
0 unknown
1 55 gal.
2 30 gal.
3 other
specify
DRUM NO. SAMPLE NO.
DRUM OPENING: DRUM TYPE:
0
1
2
3
4
unknown 0
ring top 1
closed top 2
open top 3
other 4
specify 5
unknown
metal
plastic
fiber
glass
other
specify
DRUM COLOR: PRI
0 unknown
1 cream
2 clear
3 black
4 white
5 red
6 green
7 blue
8 brown
9 pink
10 orange
11 yellow
12 gray
13 purple
14 amber
15 green-blue
SEC
DRUM CONTENTS COLOR:
0 unknown
1 cream
2 clear
3 black
4 white
5 red
6 green
7 blue
8 brown
9 pink
10 orange
11 yellow
12 gray
13 purple
14 amber
15 green-blue
DRUM CONDITION:
0 unknown
1 good
2 fair
3 poor
DRUM MARKING KEYWORD
'DRUM MARKING KEYWORD
DRUM MARKING KEYWORD
DRUM CONTENTS STATE:
0 unknown
1 solid
2 liquid
3 sludge
4 gas
5 trash
6 dirt
7 gel
DRUM CONTENT AMOUNT:
0 unknown
1 full
2 part
3 empty
CHEMICAL ANALYSIS:
radiation
ignitable
water reactive
cyanide
oxidizer
organic vapor
pH
1
2
3
PRI SEC
YES NO
SCREENING RESULTS (AREA):
0 unknown
1 radioactive
2 acid/oxidizer
3 caustic/reducer/cyanide
4 flammable organic
5 nonflammable organic
6 peroxide
7 air or water reactive
8 inert
SCREENING DATA:
YES NO
RADIOACTIVE > 1 mR over background
ACIDIC pH < 3
CAUSTIC pH > 12
AIR REACTIVE ~ ~^_ Reaction of £ 10° F
temp, change
WATER REACTIVE Reaction of >^ 10° F
temp, change
WATER SOLUBLE Dissolves in water
WATER BATH OVA Reading -
> 10 ppm - Yes
COMBUSTIBLE Catches fire when
torched in water bath
HALIDE Green flame when
heated with copper
INORGANIC WATER BATH OVA and
COMBUSTIBLE • No
ORGANIC INORGANIC - No
ALCOHOL/ ALDEHYDE WATER BATH OVA,
WATER SOLUBLE and
COMBUSTIBLE - Yes
CYANIDE Draeger tube over
water bath > 2 ppm
FLAMMABLE COMBUSTIBLE - Yes, and
SETA flashpoint < 140° F
OXIDIZER Starch iodine paper
shows positive reaction
INERT OR OTHER Everything "No" except
INORGANIC or ORGANIC
ppm
Figure 11-4. Sample Drum Characterization Sheet.
Source: EPA Region VII Emergency Planning and Response Branch.
(This figure is provided only as an example. Values were selected
by EPA Region VII and should be modified as appropriate.)
ized to determine which of them can be safely combined
(see Bulking later in this chapter). As a first step in
obtaining these data, standard tests should be used to
classify the wastes into general categories, including
auto-reactives, water reactives, inorganic acids, organic
acids, heavy metals, pesticides, cyanides, inorganic
oxidizers, and organic oxidizers. In some cases, further
analysis should be conducted to more precisely identify
the waste materials. See Figure 11-4 for an example of a
characterization sheet for drums.
When possible, materials should be characterized using
an onsite laboratory. This provides data as rapidly as pos-
sible, and minimizes the time lag before appropriate action
can be taken to handle any hazardous materials. Also, it
precludes any potential problems associated with trans-
porting samples to an offsite laboratory (e.g., sample
packaging, waste incompatibility, fume generation).
If samples must be analyzed off site, samples should be
packaged on site in accordance with DOT regulations
(49 CFR) and shipped to the laboratory for analysis.
Staging
Although every attempt should be made to minimize drum
handling, drums must sometimes be staged (i.e., moved in
an organized manner to predesignated areas) to facilitate
characterization and remedial action, and to protect
-------
Handling Drums and Other Containers
11-9
drums from potentially hazardous site conditions (e.g.,
movement of heavy equipment and high temperatures
that might cause explosion, ignition, or pressure buildup).
Staging involves a trade-off between the increased haz-
ards associated with drum movement and the decreased
hazards associated with the enhanced organization and
accessibility of the waste materials.
The number of staging areas necessary depends on site-
specific circumstances such as the scope of the opera-
tion, the accessibility of drums in their original positions,
and the perceived hazards. Investigation usually involves
little, if any, staging; remedial and emergency operations
can involve extensive drum staging. The extent of staging
must be determined individually for each site, and should
always be kept to a minimum. Up to five separate areas
have been used (see Figure 11-5):
• An initial staging area where drums can be
(1) organized according to type, size, and sus-
pected contents, and (2) stored prior to sampling.
• An opening area where drums are opened,
sampled, and reseated. Locate this area a safe dis-
tance from the original waste disposal or storage
site and from all staging areas to prevent a chain
reaction in case of fire or explosion.
• During large-scale remedial or emergency tasks, a
separate sampling area may be set up at some dis-
tance from the opening area to reduce the number
of people present in the opening area, and to limit
potential casualties in case of an explosion.
• A second staging area, also known as a holding
area, where drums are temporarily stored after
sampling pending characterization of their con-
tents. Do not place unsealed drums with unknown
contents in the second staging area in case they
contain incompatible materials. (Either remove the
contents or overpack the drum.)
• A final staging area, also known as a bulking area,
where substances that have been characterized
are bulked for transport to treatment or disposal
facilities.
Locate the final staging area as close as possible to
the site's exit.
Grade the area and cover it with plastic sheeting.
Construct approximately 1-foot-high (0.3-m-high)
dikes around the entire area.
Segregate drums according to their basic chemical
categories (acids, heavy metals, pesticides, etc.) as
determined by characterization. Construct separate
areas for each type of waste present to preclude
the possibility of intermingling incompatible chemi-
cals when bulking.
In all staging areas, stage the drums two wide in two
rows per area (see Figure 11-6), and space these rows
7 to 8 feet (2 to 2.5 m) apart to enable movement of the
drum handling equipment.
Bulking
Wastes that have been characterized are often mixed
together and placed in bulk containers such as tanks or
vacuum trucks for shipment to treatment or disposal
Crushed drums awaiting landfill. Note the staging of
drums on the left in a row two drums wide.
facilities. This increases the efficiency of transportation.
Bulking should be performed only after thorough waste
characterization by trained and experienced personnel.
The preliminary tests described earlier under Characteriza-
tion provide only a general indication of the nature of the
individual wastes. In most cases, additional sampling and
analysis to further characterize the wastes, and compati-
bility tests (in which small quantities of different wastes
are mixed together under controlled conditions and
observed for signs of incompatibility such as vapor gener-
ation and heat of reaction) should be conducted. Bulking
is performed at the final staging area using the following
procedures:
• Inspect each tank trailer and remove any residual
materials from the trailer prior to transferring any
bulked materials. This will prevent reactions between
incompatible chemicals.
• To move hazardous liquids, use pumps that are
properlv rated (see National Fire Protection Associa-
tion [NFPA] 70 Articles 500-503 and NFPA 497M)
and that have a safety relief valve with a splash
shield. Make sure the pump hoses, casings, fittings,
and gaskets are compatible with the material being
pumped.
• Inspect hose lines before beginning work to ensure
that all lines, fittings, and valves are intact with no
weak spots.
• Take special precautions when handling hoses as
they often contain residual material that can splash
or spill on the personnel operating the hoses. Protect
personnel against accidental splashing. Protect lines
from vehicular and pedestrian traffic.
• Store flammable liquids in approved containers.
Shipment
Shipment of materials to offsite treatment, storage, or
disposal facilities involves the entry of waste hauling
vehicles into the site. U.S. Department of Transportation
(DOT) regulations (49 CFR Parts 171-178) and EPA regula-
tions (40 CFR Part 263) for shipment of hazardous
-------
11-10 Handling Drums and Other Containers
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Figure 11-5. Possible Staging Areas at a Hazardous Waste Site.
-------
Handling Drums and Other Containers
11-11
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Figure 11-6. Sample Drum Staging Layout.
Source: Reference [1].
Single-stacked overpack drums awaiting transport off
site. Worker suited in Level C personal protective equip-
ment will spread a tarp over the drums to protect them
during transport.
wastes must be complied with. The following guidelines
can enhance the safety of these operations:
• Locate the final staging (bulking) area as close as
possible to the site exit.
• Prepare a circulation plan that minimizes conflict
between cleanup teams and waste haulers. Install
traffic signs, lights, and other control devices as
necessary.'
• Provide adequate area for onsite and hauling vehicles
to turn around. Where necessary, build or improve
onsite roads.
• Stage hauling vehicles in a safe area until ready for
loading with drivers remaining in cab. Minimize the
time that drivers spend in hazardous areas.
• Outfit the driver with appropriate protective
equipment.
• If drums are shipped, tightly seal the drums prior to
loading. Overpack leaking or deteriorated drums prior
to shipment. (Under most circumstances, overpack
drums used for hazardous wastes may not be reused
[49 CFR Part 173.3(c)l). Make sure that truck bed
and walls are clean and smooth to prevent damage to
drums. Do not double stack drums. Secure drums to
prevent shifting during transport.
• Keep bulk solids several inches below the top of the
truck container. Cover loads with a layer of clean soil,
foam, and/or tarp. Secure the load to prevent shifting
or release during transport.
• Weigh vehicles periodically to ensure that vehicle and
road weight limits are not exceeded.
• Decontaminate vehicle tires prior to leaving the site
to ensure that contamination is not carried onto pub-
lic roads.
• Check periodically to ensure that vehicles are not
releasing dust or vapor emissions off site.
• Develop procedures for responding quickly to offsite
vehicle breakdown and accidents to ensure minimal
public impact.
Special Case Problems
Tanks and) Vaults
For tanks and vaults, which are often found on hazardous
waste sites, the following procedures are recommended:
• In general, when opening a tank or vault follow the
same procedures as for a sealed drum. If necessary,
vent excess pressure if volatile substances are
stored. Place deflecting shields between workers and
the opening to prevent direct contamination of work-
ers by materials forced out by pressure when the
tank is opened.
• Guard manholes or access portals to prevent person-
nel from falling into the tank.
• Identify the contents through sampling and analysis.
If characterization indicates that the contents can be
safely moved with the available equipment, vacuum
them into a trailer for transportation to a disposal or
recycling facility.
• Empty and decontaminate the tank or vault before
disposal.
• If it is necessary to enter a tank or vault (i.e., confined
spaces) for any reason (e.g., to clean off solid
materials or sludges on the bottom or sides of the
tank or vault), the following precautions should be
taken [4]:
Ventilate thoroughly prior to entry.
Disconnect connecting pipelines.
Prior to entry, take air samples to prove the
absence of flammable or other hazardous vapors
and to demonstrate that adequate levels of oxygen
exist.
-------
11-12
Handling Drums and Other Containers
Equip the entry team with appropriate respiratory
protection, protective clothing, safety harnesses,
and ropes.
Equip a safety observer with appropriate respira-
tory protection, protective clothing, a safety har-
ness, and ropa
Establish lifeline signals prior to entry so that the
worker and safety observer can communicate by
tugs on the rope.
Have an additional person available in the immedi-
ate vicinity to assist the safety observer if needed.
Instruct the safety observer not to enter the space
until additional personnel are on scene.
Vacuum Trucks
• Wear appropriate protective clothing and equipment
when opening the hatch:
• If possible, use mobile steps or suitable scaffolding
consistent with 29 CFR Part 1910, Subpart D. Avoid
climbing up the ladder and walking across the tank
catwalk.
• If the truck must be climbed, raise and lower equip-
ment and samples in carriers to enable workers to
use two hands while climbing.
• If possible, sample from the top of the vehicle. If it is
necessary to sample from the drain spigot, take steps
to prevent spraying of excessive substances. Have all
personnel stand off to the sida Have sorbent
materials on hand in the event of a spill.
• Wherever possible, stay on shore. Avoid going out
over the water.
• Be aware that some solid wastes may float and give
the appearance of solid cracked mud. Caution should
be exercised when working along shorelines.
References
1. Mayhew, Joe J.; G.M. Sodear; and D.W. Carroll. 1982.
A Hazardous Waste Site Management Plan. Chemical
Manufacturers Association, Inc., Washington DC.
2. deVera, E.R.; B.P. Simmons; R.D. Stephens; and D.L.
Storm. 1980. Samplers and Sampling Procedures for
Hazardous Waste Streams. EPA-600/2-80-018. U.S.
Environmental Protection Agency, Cincinnati, OH.
3. U.S. EPA. 1984. Characterization of Hazardous Waste
Sites—A Methods Manual: Volume II. Available
Sampling Methods. Second edition. EPA 600/
4-84-076.
4. NIOSH. 1979. Criteria for a Recommended Standard:
Working in Confined Spaces. NIOSH No. 80-106. Also
available from U.S. Government Printing Office
(#017-033-00353-0) and National Technical Informa-
tion Service (PB-80-183015).
Elevated Tanks
In general, observe the safety precautions described for
vacuum trucks. In addition:
• Use a safety line and harness.
• Maintain ladders and railings in accordance with
OSHA requirements (29 CFR Part 1910, Subpart D).
Compressed Gas Cylinders
• Obtain expert assistance in moving and disposing of
compressed gas cylinders.
• Handle compressed gas cylinders with extreme cau-
tion. The rupture of a cylinder may result in an explo-
sion, and the cylinder may become a dangerous
projectile.
• Record the identification numbers on the cylinders to
aid in characterizing their contents.
Ponds and Lagoons
• Drowning is a very real danger for personnel suited in
protective equipment because the weight of protec-
tive equipment increases an individual's overall den-
sity and severely impairs their swimming ability.
Where there is danger of drowning, provide neces-
sary safety gear such as lifeboats, tag lines, railings,
nets, safety harnesses, and flotation gear.
-------
12. Site Emergencies
Contents
Introduction 12-1
Planning 12-1
Personnel 12-2
Onsite Personnel 12-3
Off site Personnel 12-3
Federal Response Organizations 12-3
Training 12-4
Emergency Recognition and Prevention 12-4
Communications 12-4
Internal Communications 12-5
External Communications 12-5
Site Mapping 12-5
Safe Distances and Refuges 12-6
Safe Distances 12-6
Public Evacuation 12-6
Refuges (Safety Stations) 12-6
Site Security and Control 12-6
Personal Locator Systems 12-7
Evacuation Routes and Procedures 12-7
Decontamination 12-8
Equipment 12-9
Medical Treatment/First Aid 12-11
Emergency Response Procedures 12-11
Notification 12-11
Size-Up 12-11
Rescue/Response Action 12-11
Follow-Up 12-12
Documentation 12-12
References 12-12
Introduction
The nature of work at hazardous waste sites makes
emergencies a continual possibility, no matter how
infrequently they may actually occur. Emergencies
happen quickly and unexpectedly and require immediate
response. At a hazardous waste site, an emergency may
be as limited as a worker experiencing heat stress, or as
vast as an explosion that spreads toxic fumes throughout
a community. Any hazard on site can precipitate an emer-
gency: chemicals, biologic agents, radiation or physical
hazards may act alone or in concert to create explosions,
fires, spills, toxic atmospheres, or other dangerous and
harmful situations. Table 12-1 lists common causes of site
emergencies.
Site emergencies are characterized by their potential for
complexity: uncontrolled toxic chemicals may be numer-
ous and unidentified; their effects may be synergistic.
Hazards may potentiate one another—for example, a
flammable spill feeding a fire. Rescue personnel attempt-
ing to remove injured workers may themselves become
victims. This variability means that advance planning,
including anticipation of different emergency scenarios
and thorough preparation for contingencies, is essential
to protect worker and community health and safety.
This chapter outlines important factors to be considered
when planning for and responding to emergencies. It
defines the nature of site emergencies, lists the types of
emergencies that may occur, and outlines a Contingency
Plan and its components, which include personnel roles,
lines of authority, training, communication systems, site
mapping, site security and control, refuges, evacuation
routes, decontamination, a medical program, step-by-step
emergency response procedures, documentation, and
reporting to outside agencies. Backup information is
detailed in other chapters of the manual.
Planning
When an emergency occurs, decisive action is required.
Rapidly made choices may have far-reaching, long-term
consequences. Delays of minutes can create life-
threatening situations. Personnel must be ready to
immediately rescue or respond; equipment must be on
hand and in good working order. In order to handle emer-
gencies effectively, planning is essential. For this purpose,
a Contingency Plan should be developed.
A Contingency Plan is a written document that sets forth
policies and procedures for responding to site emergen-
cies. It should incorporate the following:
• Personnel:
Roles.
Lines of authority.
Training.
Communication.
• Site:
Mapping.
Security and control.
Refuges.
Evacuation routes.
Decontamination stations.
• Medical/first aid.
• Equipment.
• Emergency procedures.
• Documentation.
• Reporting.
Overall, a Contingency Plan should:
• Be designed as a discrete section of the Site
Safety Plan.
• Be compatible and integrated with the pollution
response, disaster, fire, and emergency plans of
local, state, and federal agencies.
• Be rehearsed regularly using drills and mock situ-
ations.
• Be reviewed periodically in response to new or
changing site conditions or information.
-------
.12-2 Site Emergencies
Table 12-1. Causes of Emergencies at Hazardous Waste Sites Personnel
Worker-Related
• Minor accidents (slips, trips, falls).
• Chemical exposure
• Medical problems (heat stress, heat stroke, aggravation of
pre-existing conditions).
• Personal protective equipment failure (air source failure, tearing or
permeation of protective clothing, facepiece fogging).
• Physical injury (injuries from hot or flying objects, loose clothing
entangling in machinery, serious falls, vehicle accidents).
• Electrical (burns, shock, electrocution).
Waste-Related
• Fire.
• Explosion.
• Leak.
• Release of toxic vapors.
• Reaction of incompatible chemicals.
• Collapse of containers.
• Discovery of radioactive materials.
This component of the plan includes not only onsite and
offsite personnel with specific emergency response roles,
but also others who may be on site, such as contractors,
other agency representatives, and visitors. Emergency
personnel and their responsibilities are covered in detail in
Chapter 3 as part of the overall organizational structure.
This information is summarized in Table 12-2.
Emergency personnel may be deployed in a variety of
ways. Depending on the nature and scope of the emer-
gency, the size of the site, and the number of personnel,
the emergency response cadre can include individuals,
small or large teams, or several interacting teams.
Although deployment is determined on a site-by-site
basis, pertinent general guidelines and recommendations
are listed below. In all cases the organizational structure
should show a clear chain-of-command, every individual
should know his or her position and authority, and the
chain-of-command must be flexible enough to handle
multiple emergencies, such as a rescue and a spill
response or two rescues with a fire and spill response.
Table 12-2. Personnel Involved in Emergency Response
Project Team Leader
• Directs emergency response operations.
• Serves as liaison with appropriate government officials.
Site Safety Officer
• Recommends that work be stopped if any operation threatens
worker or public health or safety.
• Knows emergency procedures, evacuation routes, and the
appropriate telephone numbers including: the ambulance, medical
facility, poison control center, fire department, and police
department.
• Notifies local public emergency officials.
• Provides for emergency medical care on sita
Command Post Supervisor
• Notifies emergency support personnel by telephone or radio in
case rescue operations are required.
• Assists the Site Safety Officer in a rescue, if necessary.
Rescue Team
• An emergency rescue team stands by, partially dressed in protec-
tive gear, near the Exclusion Zone ready to rescue any workers
whose health or safety is endangered.
• State emergency response personnel (varies among states).
Decontamination Station Officers
• Perform emergency decontamination.
24-Hour Medical Team
• Transportation and treatment of victims by ambulance personnel,
personnel at local clinics or hospitals, and physicians.
Communication Personnel
• Local emergency service networks provide communication links
for mutual aid.
• Civil Defense organizations and local radio and television stations
provide information to the public during an emergency.
Environmental Scientists
• Predict the immediate and future movement of released hazardous
substances through the geologic and hydrologic environment and
air.
• Assess the effect of this movement on groundwater quality, sur-
face water quality, and air quality.
• Determine the probable movement of released toxic gases.
• Estimate the expected concentration of gases in the community
and the expected duration of exposure
• Predict the exposure levels of people and the ecosystem to the
materials.
Hazardous Chemicals Experts
• Provide immediate advice to those at the scene of a chemical-
related emergency.
Firefighters
• Respond to fires that occur at a site; rescue victims.
Meteorologists
• Provide meteorological information needed by environmental
scientists.
Public Safety Personnel
• The county sheriff, industrial security forces, the National Guard,
and the police control site access, crowds, and traffic.
Public Evacuation Personnel
• Civil Defense organizations plan evacuations.
• The National Guard and other military, the Red Cross, the Salva-
tion Army, and municipal transportation systems mobilize transit
equipment and assist in evacuations.
On-Scene Coordinator
• Coordinates federal response activities.
-------
Site Emergencies
12-3
Onsite Personnel
The Contingency Plan should identify all individuals and
teams who will participate in emergency response and
define their roles. All personnel, whether directly involved
in emergency response or not, should know their own
responsibilities in an emergency. They must also know
the names of those in authority, and the extent of that
authority.
Leader
In an emergency situation, one person must be able to
assume total control and decision-making on site. This
leader must:
• Be identified in the emergency response plan. This
person may be, for example, the Project Team Leader,
Site Safety Officer, or Field Team Leader.
• Be backed up by a specified alternate(s).
• Have the authority to resolve all disputes about
health and safety requirements and precautions.
• Be authorized to seek and purchase supplies as
necessary.
• Have control over activities of everyone entering the
site, for example, contractors, fire departments, and
police.
• Have the clear support of management.
Teams
Although individuals (e.g., the Site Safety Officer) may
perform certain tasks in emergencies, in most cases
teams provide greater efficiency and safety. Teams com-
posed of onsite personnel may be created for specific
emergency purposes, such as decontamination, rescue,
and entry. Rescue teams can be used during a particularly
dangerous operation, or at large sites with multiple work
parties in the Exclusion Zone. Their sole function is to
remain near hazardous work areas, partially dressed in
protective gear, ready for full suiting and immediate res-
cue of any endangered worker. These teams should be
capable of administering cardiopulmonary resuscitation
(CPR) and emergency first aid. Other teams can be
formed for responding to containment emergencies and
fire-fighting until offsite assistance arrives.
Table 12-3. Examples of Agencies and Groups Involved in
Emergencies
AGENCY OR GROUP
RESCUE* RESPONSE* SUPPORT"
FEDERAL
Army Corps of Engineers
Coast Guard"
Department of Defense*1
Department of Transportation
Environmental Protection
Agency (EPA)«
Federal Aviation Administra-
tion (FAA)
Federal Emergency Manage-
ment Agency (FEMA)
National Institute for
Occupational Safety and
Health (NIOSH)
Occupational Safety and
Health Administration
(OSHA)
STATE
Civil Defense
Department of Health
Department of Labor
Environmental Agency
Office of the Attorney
General
State Police
LOCAL
Ambulance and rescue
services
Cleanup contractor
Disposal companies
Fire department
Hospital
Police
Red Cross
Salvation Army
Transporters
Utility companies (electric,
gas, water, phone)
"Rescue = extricating and/or providing on-the-spot emergency
treatment to victims.
bResponse = controlling and stabilizing hazardous conditions.
cSupport = providing technical assistance, equipment, and/or
resources.
dThis agency may provide an On-Scene Coordinator (OSC),
depending on the jurisdiction.
Offsite Personnel
These may include individual experts such as meteorolo-
gists or toxicologists (see Table 12-2), and representatives
or groups from local, state, and federal organizations
offering rescue, response, or support (see Table 12-3 for a
listing of typical organizations). As part of advance plan-
ning, site personnel should:
• Make arrangements with individual experts to provide
guidance as needed.
• Make arrangements with the appropriate agencies
(e.g., local fire department, state environmental
agency, EPA regional office) for support.
• Alert these authorities to the types of emergencies
that may arise.
• Determine their estimated response time and
resources.
• Identify backup facilities.
• Provide training and information about hazards on
site and special procedures for handling them.
• Establish a contact person and means of notification
at each agency.
Federal Response Organizations
Site emergencies involving significant chemical releases
should be coordinated with federal response organiza-
tions. The federal government has established a National
Contingency Plan (NCP) to promote the coordination and
direction of federal and state response systems, and to
encourage the development of local government and pri-
vate capabilities to handle chemical emergencies involv-
ing chemical releases.
-------
12-4
Site Emergencies
To implement the NCR, a national organization was estab-
lished, including a National Response Team (NRT), a net-
work of Regional Response Teams (RRTs), a cadre of
On-Scene Coordinators (OSCs), and a National Response
Center (NRC). The NRC is the national terminal point for
receipt of notification of significant chemical releases,
and the OSCs are the interface between the onsite per-
sonnel and the federal response organizations. The OSC
is the federal official responsible for ensuring that neces-
sary response actions are taken to protect the public and
the environment from the effects at a chemical release.
Many federal agencies have specific technical expertise
which is available to assist the OSC.
If a significant chemical release occurs at a hazardous
waste site, the National Response Center in Washington,
D.C., should be contacted (Telephone: 800-424-8802).
The NRC will activate federal response under the National
Contingency Plan.
Training
Since immediate, informed response is essential in an
emergency, all site personnel and others entering the site
(visitors, contractors, offsite emergency response groups,
other agency representatives) must have some level of
emergency training. Any training program should:
• Relate directly to site-specific, anticipated situations.
• Be brief and repeated often.
• Be realistic and practical.
• Provide an opportunity for special skills to be
practiced regularly.
• Feature drills frequently (e.g., site-specific mock
rescue operations).
• Ensure that training records are maintained in a train-
ing logbook.
Everyone entering the site must be made aware of the
hazards and of hazardous actions which are forbidden or
should be avoided (e.g., smoking). They must also know
what to do in case of an emergency.
Visitors should be briefed on basic emergency procedures
such as decontamination, emergency signals, and evacua-
tion routes.
Personnel without defined emergency response roles (e.g.,
contractors, federal agency representatives) must still
receive a level of training that includes at a minimum:
• Hazard recognition.
• Standard Operating Procedures.
• Signaling an emergency: the alarm used, how to
summon help, what information to give and who to
give it to.
• Evacuation routes and refuges.
• The person or station to report to when an alarm
sounds.
Onsite emergency personnel, who have emergency roles
in addition to their ordinary duties, must have a thorough
nderstanding of emergency response. Training should be
directly related to their specific roles and should include
subjects such as:
• Emergency chain-of-command.
• Communication methods and signals.
• How to call for help.
• Emergency equipment and its use.
• Emergency evacuation while wearing protective
equipment.
• Removing injured personnel from enclosed spaces.
• Offsite support and how to use it.
These personnel should obtain certification in first aid and
CPR, and practice treatment techniques regularly, with an
emphasis on:
• Recognizing and treating chemical and physical
injuries.
• Recognizing and treating heat and cold stress.
Offsite emergency personnel such as local firefighters and
ambulance crews often are first responders and run a risk
of acute hazard exposure equal to that of any onsite
worker. These personnel should be informed of ways to
recognize and deal effectively with onsite hazards. Lack
of information may inadvertently worsen an emergency
by improper actions (eg., spraying water on a water-
reactive chemical and causing an explosion). Inadequate
knowledge of the onsite emergency chain-of-command
may cause confusion and delays. Site management
should, at a minimum, provide offsite emergency per-
sonnel with information about:
• Site-specific hazards.
• Appropriate response techniques.
• Site emergency procedures.
• Decontamination procedures.
Emergency Recognition and Prevention
On a day-to-day basis, individual personnel should be
constantly alert for indicators of potentially hazardous
situations and for signs and symptoms in themselves and
others that warn of hazardous conditions and exposures.
Rapid recognition of dangerous situations can avert an
emergency. Before daily work assignments, regular meet-
ings should be held. Discussion should include:
• Tasks to be performed.
• Time constraints (ag., rest breaks, air tank changes).
• Hazards that may be encountered, including their
effects, how to recognize symptoms or monitor
them, concentration limits, or other danger signals.
• Emergency procedures.
After daily work assignments, a debriefing session should
be held to review work accomplished and problems
observed.
Communications
In an emergency, crucial messages must be conveyed
quickly and accurately. Site staff must be able to commu-
-------
Site Emergencies
12-5
nicate information such as the location of injured person-
nel, orders to evacuate the site, and notice of blocked
evacuation routes, even through noise and confusion.
Outside support sources must be reached, help obtained,
and measures for public notification ensured, if neces-
sary. To do this, a separate set of internal emergency sig-
nals should be developed and rehearsed daily. External
communication systems and procedures should be clear
and accessible to all workers.
Internal Communications
Internal emergency communication systems are used to
alert workers to danger, convey safety information, and
maintain site control. Any effective system or combina-
tion may be employed. Radios or field telephones are
often used when work teams are far from the Command
Post. Alarms or short clear messages can be conveyed by
audible signals, e.g., bullhorns, megaphones, sirens, bells,
whistles, or visual signals such as colored flags, flares,
lights, and hand or whole-body movements. The primary
system must have a backup. For example, hand signals
may be used as a backup if radio communications fail.
All internal systems should be:
• Clearly understood by all personnel.
• Checked and practiced daily.
• Intrinsically safe (spark-free).
A special set of emergency signals should be set up.
These should be:
• Different from ordinary signals.
• Brief and exact.
• Limited in number so that they are easily
remembered.
Examples include: stop, evacuate, help, all clear. Any set
of signals may be used to convey these messages as long
as all personnel understand their meaning. See Table 12-4
for examples.
When designing and practicing communication systems,
remember that:
• Background noise on site will interfere with talking
and listening.
• Wearing personal protective equipment will impede
hearing and limit vision (e.g., the ability to recog-
nize hand and body signals).
• Inexperienced radio users may need practice in
speaking clearly.
External Communications
Offsite sources must be contacted to get assistance or to
inform officials.about hazardous conditions that may
affect public or environmental safety. The telephone is the
most common mode of offsite communication; phone
hook-ups are considered a necessity at all but the most
remote sites.
• The National Response Center (NRC) (Telephone:
800-424-8802) should be contacted in the event
of a significant chemical release. The NRC will
contact the appropriate federal On-Scene Coor-
dinator.
Table 12-4. Sample Internal Emergency Communication
Signals
DEVICES" AND
SIGNALS EXAMPLE
Radio (citizen's band or FM)
Noisemakers, including:
Bell
Compressed air horn
Megaphone
Siren
Whistle
Visual signal, including:
Hand signals
Whole body movements
Established code words.
One long blast: Evacuate area by
nearest emergency exit.
Two short blasts: Localized problem
(not dangerous to workers).
Two long blasts: all clear.
Hand clutching throat: Out of air/
can't breathe.
Hands on top of head: Need
assistanca
Thumbs up: OK/I'm alright/
I understand.
Thumbs down: No/negative
Grip partner's wrist or both hands
around partner's waist: Leave
area immediately.
"All devices and equipment used in the Exclusion and Contamina-
tion Reduction Zones must be intrinsically safe and not capable
of sparking.
All personnel must be familiar with the protocol
(phone number or emergency code, contact per-
son) for contacting public emergency aid teams
such as fire departments, ambulance units, and
hospitals.
If there is no site telephone system, all personnel
must know the location of the nearest public tele-
phone A supply of telephone change and the
necessary phone numbers must be readily
available
Site Mapping
Detailed information about the site is essential for ad-
vance planning. For this purpose, a site map is a valuable
tool. It serves as a graphic record of the locations and
types of hazards, a reference source, and a method of
documentation. This map can be a duplicate of the one
developed for the Site Safety Plan (see Chapter 3), but it
should focus on potential areas where emergencies may
develop. Pins and colored flags can be used to mark
changes in personnel deployment, hazard areas, and
equipment locations. The map should highlight:
• Hazard areas, especially potential IDLH conditions.
• Site terrain: topography, buildings, barriers.
• Evacuation routes.
• Site accessibility by land, sea, and air.
• Work crew locations.
• Changes (ag., work activities, vandalism, accidents).
• Offsite populations or environments at potential risk.
The map can be used for planning and training. It can
serve as a basis for developing potential emergency
scenarios and alternative response strategies.
-------
12-6
Site Emergencies
When an emergency occurs, the problem areas should be
pinpointed on the map. Pertinent information—such as
weather and wind conditions, temperature, and forecast
—should be added. The map can then be used to design
the emergency plan, e.g., to define zones; determine
evacuation routes; and identify emergency first-aid,
decontamination, and Command Post stations. When
using the map for such purposes, the accuracy of the
data obtained and the potential for over- of underestimat-
ing a hazard should be considered.
Even if the emergency develops so fast that the map can-
not be used for on-the-spot planning, prior familiarity with
it will aid in making informed decisions.
Safe Distances and Refuges
Safe Distances
No single recommendation can be given for evacuation or
safe distances because of the wide variety of hazardous
substances and releases found at sites. For example, a
"small" chlorine leak may call for an isolation distance of
only 140 feet (43 meters), while a "large" leak may
require an evacuation distance of 1 mile (1.6 kilometers)
or more, depending on the wind direction [1].
Safe distances can only be determined at the time of an
emergency, based on a combination of site- and incident-
specific factors. However, planning and outlining potential
emergency scenarios will help familiarize personnel with
points to consider. Factors that influence safe distances
include:
• The toxicological properties of the substance.
• The physical state of the substance.
• The quantity released.
• The rate of release.
• The method of release.
• The vapor pressure of the substance.
• Vapor density relative to air.
• Wind speed and direction.
• Atmospheric stability.
• The height of release.
• Air temperature and temperature change with
altitude.
• Local topography (e.g., barriers may enhance or
retard a cloud or plume, and attentuate a blast).
Public Evacuation
If an incident may threaten the health or safety of the sur-
rounding community, the public will need to be informed
and possibly evacuated from the area. Site management
should plan for this in coordination with the appropriate
local, state and federal groups, such as the Federal Emer-
gency Management Agency, the Civil Defense, county
sheriff, local radio and television stations, municipal trans-
portation systems. National Guard, and police.
Refuges (Safety Stations)
Onsite refuges (safety stations) can be set up for local-
ized emergencies that do not require site evacuation.
These refuges should only be used for essential needs,
such as short rest breaks, emergency response strategy
meetings, or temporary relief during mild cases of muscle
strain and heat stress. The refuge should be located in a
relatively safe, but not necessarily "clean" area, e.g.,
along the upwind fence line in specially cleared places or
on the periphery of the Exclusion Zone.1 The refuge
should never be used for activities such as eating, drink-
ing, or air changes. Typical items located in a refuge area
include:
• A sitting/resting area that should be shaded if
possible.
• Water for decontamination.
• Wind indicator.
• Communication system with the Command Post.
• First-aid supplies, e.g., eyewash, stretcher, blanket.
• Special monitoring devices (e.g., extra detector tubes
and personal monitors).
• Bolt cutters.
• Fire extinguishers.
• Hand tools.
Other refuges can be set up in the Support Zone, or in the
case of site-wide evacuations, offsite at the safe exit des-
tination. These will provide for emergency needs such as
first aid for injured personnel, clean dry clothing and wash
water for chemical exposure victims, and communica-
tions with the Command Post. In a sitewide evacuation,
they can be used to house evacuation exit equipment,
thereby reducing security problems. These refuges should
be stocked with such items as:
• Decontamination supplies.
• Oxygen and/or air.
• Water.
• Special testing equipment (e.g., pH paper, cyanide
paper).
• First-aid supplies.
• Communication system.
Site Security and Control
In an emergency, the Project Team Leader (or designated
representative) must know who is on site and must be
able to control the entry of personnel into the hazardous
areas to prevent additional injury and exposure. Only
necessary rescue and response personnel should be
allowed into the Exclusion Zone.
One control technique is a checkpoint or series of check-
points through which all personnel entering or exiting the
'In an emergency, as in daily work activities, the site is divided
into three areas: Exclusion (contaminated) Zone, Contamination
Reduction Zone, and Support (clean) Zone (see Chapter 9, Site
Control}.
-------
Site Emergencies
12-7
site must pass, ag., a Support Zone checkpoint and an
Exclusion Zone checkpoint. Identification or authorization
must be presented to a Checkpoint Control Manager, who
records each person's:
• Name (and affiliation if offsite personnel).
• Status (in or out).
• Time of entry.
• Anticipated exit tima
• Zones or areas to be entered.
• Team or "buddy."
• Task being performed.
• Location of task.
• Protective equipment worn; air time left.
• Rescue and response equipment used.
The emergency area Checkpoint Control Manager should
inform the Project Team Leader if a person remains in the
emergency area beyond his or her anticipated exit time.
Personal Locator Systems
In an emergency, it is vital for the Project Team Leader (or
designee) and rescue personnel to rapidly determine
where workers are located and who may be injured. A
passive locator system (i.a, a written record of the loca-
tion of all personnel on site at any time) could be used to
help find personnel in an emergency. Any such system
should be:
• Graphic (such as a drawing with a written key).
• Roughly drawn to scale, with the scale and visible
landmarks included.
• Kept current.
• Easy to locate.
• Stored outside the Exclusion Zona
A good passive locator system is a site map with flags or
color-headed pins identifying each worker.
Active locator systems can also be used. These are worn
or carried by individual personnel, and are activated by
actions such as flipping a switch, a decrease in air supply,
or a fall. They have the advantage of precisely locating
individuals.
Evacuation Routes and Procedures
A severe emergency, such as a fire or explosion, may cut
workers off from the normal exit near the Command Post.
Therefore, alternate routes for evacuating victims and
endangered personnel should be established in advance,
marked, and kept clear. Routes should be directed
(1) from the Exclusion Zone through an upwind Contami-
nation Reduction Zone to the Support Zone, and (2) from
the Support Zone to an offsite location in case conditions
necessitate a general site evacuation. The following
guidelines will help in establishing safe evacuation routes.
• Place the evacuation routes in the predominantly
upwind direction of the Exclusion Zona (At a very
large site, or one with many obstacles, some exits
may be placed in the downwind fenceline, nor-
mally an undesirable location. If this is done,
workers must know that they are not "out" until
they reach the designated safety area.)
• Run the evacuation routes through the Contamina-
tion Reduction Zona Even if there is not enough
time to process the evacuees through decontami-
nation procedures, there should be a mechanism
for accounting for all personnel.
• Consider the accessibility of potential routes. Take
into account obstructions such as locked gates,
trenches, pits, tanks, drums, or other barriers, and
the extra time or equipment needed to maneuver
around or through them.
• Develop two or more routes that lead to safe areas
and that are separate or remote from each other.
Multiple routes are necessary in case one is
blocked by a fire, spill, or vapor cloud. These
routes must not overlap because if a common
point were obstructed by a fire or other emer-
gency, all intersecting routes would be blocked.
• Mark routes "safe" or "not safe" on a daily basis
according to wind direction and other factors.
• Mark evacuation routes with materials such as
barricade tape, flagging, or traffic cones. Equally
important, mark areas that do not offer safe
escape or that should not be used in an emer-
gency, such as low ground, which can fill with
gases or vapors, or routes blocked by natural bar-
riers, such as cliffs or streams.
• Consider the mobility constraints of personnel
wearing protective clothing and equipment. They
will have difficulty crossing even small streams
and going up and down banks.
Place ladders across any cut or excavation that is
more than 3 feet (1 meter) deep. For long cuts,
place ladders at least every 25 feet (7.5 meters),
and for deep cuts, place plywood or planks on top
of ladders.
Provide ladders for rapid descent from areas or
structures elevated more than 3 feet (1 meter).
Use only ladders capable of supporting a 250-lb
(114-kg) load.
Secure ladders to prevent slipping.
Place standard cleated ramps ("chickenboard")
across ditches and other similar obstacles. Add a
railing and toe boards if the board is narrow or
steeply sloped.
Check the toe and body clearance of ladders to
make sure that personnel wearing protective cloth-
ing and SCBA can use them.
Check the clearance of access ports, such as
crawlspaces, hatches, manholes, and tunnels to
make sure that personnel wearing a protective
ensemble can get through. In any case, access
ports should be at least 3 feet (1 meter) in diameter
where possible. (Standard tank manways are
smaller.)
• Make escape routes known to all who go on sita
-------
12-8
Site Emergencies
Accident/Injury Event
Life-Saving
Procedures Required?
Contaminants
Extremely Hazardous?
Perform Life-Saving
Procedures
NO
Grossly Decontaminate
and/or Cover or Wrap
Contaminated Areas
Decontaminate as Much as
Possible
NO
Further
Medical Attention
or Surveillance
Required?
Additional Emergency
Care Required?
Report to Superiors for
Instructions
YES
Transport to Medical
Facility
Figure 12-1. Decision Aid for Emergency Decontamination.
Decontamination
When planning for decontamination in medical emergen-
cies, procedures should be developed for:
• Decontaminating the victim.
• Protecting medical personnel.
• Disposing of contaminated protective equipment and
wash solutions.
These activities should be coordinated. The decision
whether or not to decontaminate a victim is based on the
type and severity of the illness or injury and the nature of
the contaminant. For some emergency victims, immediate
decontamination may be an essential part of life-saving
first aid. For others, decontamination may aggravate the
injury or delay life-saving treatment. If decontamination
does not interfere with essential treatment, it should be
performed. Figure 12-1 is a decision aid for emergency
decontamination.
• If decontamination can be done:
-------
Site Emergencies
12-9
Wash, rinse and/or cut off protective clothing and
equipment.
• If decontamination cannot be done:
Wrap the victim in blankets, plastic, or rubber to
reduce contamination of other personnel.
Alert emergency and offsite medical personnel to
potential contamination; instruct them about
specific decontamination procedures if necessary.
Send along site personnel familiar with the
incident.
See Chapter 9, Decontamination, for details on decon-
tamination techniques and procedures.
Equipment
In an emergency, equipment will be necessary to rescue
and treat victims, to protect response personnel, and to
mitigate hazardous conditions on site (e.g., to contain
chemicals or fight fires). Some regular equipment can
double for emergency use. Because of its high cost, most
heavy equipment (e.g., bulldozers, drum movers, pumps)
employed in emergencies will also be used for regular
work assignments. All equipment should be in working
order, fueled, and available when an emergency occurs.
Provide safe and unobstructed access for all firefighting
and emergency equipment at all times. Consider adopting
the following work procedures:
• Refuel all heavy equipment when there is still one-
half to one-quarter of a tank of fuel left.
• Require all equipment repairs to take place at the
time the problem is discovered.
• Separate two similar pieces of equipment (e.g., two
front-loaders or a bulldozer and a front-loader); park
each at a different spot on site and do not use them
at the same time in a hazardous area unless abso-
lutely necessary. (This will minimize the possibility of
both pieces of equipment being damaged in the same
explosion or fire.)
For personal protective equipment:
• Refill all empty self-contained breathing apparatus
(SCBA) tanks and prepare them for emergencies
immediately after normal use.
• Stock higher levels of protective equipment than
required for anticipated hazards (e.g., a site where
Level C equipment is normally used [see Table 8-6]
should have Level A and B equipment available for
emergencies).
Basic equipment that should be available at any site is
listed in Table 12-5. Special equipment should be obtained
depending on the specific types of emergencies that may
occur at a particular site and the capabilities of backup
offsite personnel. For example, if the nearest fire depart-
ment is small and only carries one bucket of foaming
solution because of its high cost and short shelf-life, a
site may need to stock a large quantity of foam. When
determining the type and quantity of special equipment,
the following factors should be considered:
• The types of emergencies that may arise. For each
emergency, consider a probable and a worst-case
scenario.
• The types of hazards that site personnel may be
exposed to and the appropriate containment,
mitigative, and protective measures.
• The capabilities and estimated response times of
offsite emergency personnel.
• The number of site personnel who could be vic-
tims during an emergency.
• The probable number of personnel available for
response.
Table 12-5. Onsite Equipment and Supplies for Emergency Response
PERSONAL PROTECTION
MEDICAL
HAZARD MITIGATION
• Escape SCBA or SCBA, which can
be brought to the victim to
replace or supplement his or her
SCBA
• Personal protective equipment
and clothing specialized for
known site hazards
• Air splints
• Antiseptics
• Blankets
• Decontamination solutions appropriate
for onsite chemical hazards
• Emergency eye wash
• Emergency showers or wash stations
• Ice
• Reference books containing basic
first-aid procedures and information on
treatment of specific chemical injuries
• Resuscitator
• Safety harness
• Stretchers
• Water, in portable containers
• Wire basket litter (Stokes litter) which
can be used to carry a victim in bad
weather and on a difficult terrain, allows
easy decontamination of the victim, and
is itself easy to decontaminate
Fire-fighting equipment and supplies
Spill-containment equipment, such
as absorbents and oil booms
Special hazardous-use tools such as
remote pneumatic impact wrenches,
nonsparking wrenches and picks
Containers to hold contaminated
materials
-------
12-10
Site Emergencies
Notify onsite personnel
about the incident
O
oc
111
ec
Q.
Size-up the situation based
on available information
I
Request aid from
outside sources
Allocate personnel
and equipment
resources for response
u
(/)
Z
O
0.
c/>
m
ce
Survey and assess
existing and potential
hazards
Survey and assess
casualties
Stabilize
victims
Extricate
victims
Decontaminate
victims
Evacuate
site
personnel
Evacuate
nearby
public
Contain
hazard
Extinguish
hazard
Transport and
treat victims
Replace or rejuvenate damaged
or exhausted equipment
O
u.
Document the
incident
Review and revise Site Safety
and Contingency Plans
Figure 12-2. Emergency Response Operations.
-------
Site Emergencies
12-11
Medical Treatment/First Aid
In emergencies, toxic exposures and hazardous situations
that cause injuries and illnesses will vary from site to site.
Medical treatment may range from bandaging of minor
cuts and abrasions to life-saving techniques. In many
cases, essential medical help may not be immediately
available. For this reason, it is vital to train onsite emer-
gency personnel in on-the-spot treatment techniques, to
establish and maintain telephone contact with medical
experts (e.g., toxicologists), and to establish liaisons with
local hospitals and ambulance services. Guidelines for
establishing an emergency medical program are detailed
in Chapter 5. When designing this program, these essen-
tial points should be included:
• Train a cadre of personnel in emergency treatment
such as first aid and CPR. Training should be
thorough, frequently repeated, and geared to
site-specific hazards.
• Establish liaison with local medical personnel, for
example: 24-hour on-call physician, medical
specialists, local hospitals, ambulance service, and
poison control center. Inform and educate these
personnel about site-specific hazards so that they
can be optimally helpful if an emergency occurs.
Develop procedures for contacting them; familia-
rize all onsite emergency personnel with these
procedures.
• Set up onsite emergency first-aid stations; see
that they are well supplied and restocked immedi-
ately after each emergency.
Emergency Response Procedures
Response operations usually follow a sequence that
starts with the notification of trouble and continues
through the preparation of equipment and personnel for
the next emergency. This process is illustrated in
Figure 12-2.
Notification
Alert personnel to the emergency. Sound a site alarm to:
• Notify personnel.
• Stop work activities if necessary.
• Lower background noise in order to speed communi-
cation.
• Begin emergency procedures.
Notify onsite emergency response personnel about the
emergency and include essential information:
• What happened.
• Where if happened.
• Whom it happened to.
• When it happened.
• How it happened.
• The extent of damage.
• What aid is needed.
Size-Up
Available information about the incident and emergency
response capabilities should be evaluated. The following
information should be determined, to the extent possible:
• What happened:
Type of incident.
Cause of incident.
Extent of chemical release and transport.
Extent of damage to structures, equipment, and
terrain.
• Casualties:
Victims (number, location, and condition).
Treatment required.
Missing personnel.
• What could happen. Consider:
Types of chemicals on site.
Potential for fire, explosion, and release of hazard-
ous substances.
Location of all personnel on site relative to hazard-
ous areas.
Potential for danger to offsite population or
environment.
• What can be done. Consider:
Equipment and personnel resources needed for vic-
tim rescue and hazard mitigation.
Number of uninjured personnel available for
response.
Resources available on site.
Resources available from outside groups and
agencies.
Time for outside resources to reach the site.
Hazards involved in rescue and response.
Rescue/Response Action
Based on the available information, the type of action
required should be decided and the necessary steps
implemented. Some actions may be done concurrently.
No one should attempt emergency response or rescue
until backup personnel and evacuation routes have been
identified. Rescue/response actions may include:
• Enforce the buddy system: Allow no one to enter an
Exclusion Zone or hazardous area without a partner.
At all times, personnel in the Exclusion Zone should
be in line-of-sight or communications contact with
the Command Post Supervisor or designea
• Survey casualties:
Locate all victims and assess their condition.
Determine resources needed for stabilization and
transport.
• Assess existing and potential hazards to site person-
nel and to the offsite population. Determine:
Whether and how to respond.
The need for evacuation of site personnel and off-
site population.
The resources needed for evacuation and response
-------
12-12
Site Emergencies
• Allocate resources. Allocate onsite personnel and
equipment to rescue and incident response oper-
ations.
• Request aid. Contact the required offsite personnel or
facilities, such as the ambulance, fire department,
and police.
• Control. Bring the hazardous situation under com-
plete or temporary control; use measures to prevent
the spread of the emergency.
• Extricate. Remove or assist victims from the area.
• Decontaminate. Use established procedures to
decontaminate uninjured personnel in the Contamina-
tion Reduction Zone. If the emergency makes this
area unsafe, establish a new decontamination area at
an appropriate distance. Decontaminate victims
before or after stabilization as their medical condition
indicates (see Figure 12-1 for decision aid).
• Stabilize. Administer any medical procedures that are
necessary before the victims can be moved. Stabilize
or permanently fix the hazardous condition (e.g.,
repack; empty filled runoff dikes). Attend to what
caused the emergency and anything (e.g., drums,
tanks) damaged or endangered by the emergency.
• Transport. Take measures to minimize chemical
contamination of the transport vehicle and
ambulance and hospital personnel. Adequately
protected rescuers should decontaminate the vic-
tims before transport. If this is not possible, cover
the victims with adequate sheeting. Before trans-
portation, determine the level of protection neces-
sary for transport personnel. Provide them with
disposable coveralls, disposable gloves, and sup-
plied air, as necessary, for their protection. If
appropriate, have response personnel accompany
victims to the medical facility to advise on decon-
tamination.
• Evacuate:
Move site personnel to a safe distance upwind of
the incident.
Monitor the incident for significant changes. The
hazards may diminish, permitting personnel to
reenter the site, or increase and require public
evacuation.
Inform public safety personnel when there is a
potential or actual need to evacuate the offsite
population. Do not attempt large-scale public
evacuation. This is the responsibility of government
authorities (see Table 12-3).
Follow-Up
Before normal site activities are resumed, personnel must
be fully prepared and equipped to handle another
emergency.
• Notify appropriate government agencies as
required. For example, OSHA must be notified if
there have been any fatalities or five or more
hospitalizations.
• Restock all equipment and supplies. Replace or
repair damaged equipment. Clean and refuel
equipment for future use.
• Review and revise all aspects of the Contingency
Plan according to new site conditions and lessons
learned from the emergency response. When
reviewing the information, consider typical ques-
tions such as:
Cause: What caused the emergency?
Prevention: Was it preventable? If so, how?
Procedures: Were inadequate or incorrect orders
given or actions taken? Were these the result of
bad judgment, wrong or insufficient information, or
poor procedures? Can procedures or training be
improved?
Site profile: How does the incident affect the site
profile? How are other site cleanup activities
affected?
Community: How is community safety affected?
Liability: Who is liable for damage payments?
Documentation
The Project Team Leader should initiate the investigation
and documentation of the incident. This is important in all
cases, but especially so when the incident has resulted in
personal injury, onsite property damage, or damage to the
surrounding environment. Documentation may be used to
help avert recurrences, as evidence in future legal action,
for assessment of liability by insurance companies, and
for review by government agencies. Methods of docu-
menting can include a written transcript taken from tape
recordings made during the emergency or a bound field
book (not a looseleaf book) with notes. The document
must be:
• Accurate: All information must be recorded objec-
tively.
• Authentic: A chain-of-custody procedure should
be used. Each person making an entry must date
and sign the document. Keep the number of
documentors to a minimum (to avoid confusion
and because they may have to give testimony at
hearings or in court). Nothing should be erased. If
details change or revisions are needed, the person
making the notation should mark a horizontal line
through the old material and initial the change.
• Complete: At a minimum, the following should be
included:
Chronological history of the incident.
Facts about the incident and when they became
available..
Title and names of personnel; composition of
teams.
Actions: decisions made and by whom; orders
given: to whom, by whom, and when; and actions
taken: who did what, when, where, and how.
Types of samples and test results; air monitoring
results.
Possible exposures of site personnel.
History of all injuries or illnesses during or as a
result of the emergency.
References
1. U.S. Department of Transportation. 1984. DOT 1984
Emergency Response Guidebook. DOT P5800.3. U.S.
Department of Transportation, Washington, DC.
-------
Appendix A. List of Abbreviations and Acronyms
List of
cm3
C02
dBA
ft
g
g-mole
hr
1
Ib
Abbreviations
cubic centimeter
carbon dioxide
decibels on A-weighted scale
foot
gram
gram-mole
hour
liter
pound
m3
mg
ml
mrem
02
psi
ppb
ppm
ta
ta adj
cubic meter
milligram
milliliter
milliroentgen equivalent in man
oxygen
pounds per square inch
parts per billion
parts per million
ambient air temperature
adjusted ambient air temperature
List of Acronyms
ACGIH American Conference of Governmental
Industrial Hygienists
ANSI American National Standards Institute
CAA Clean Air Act
CBC Complete blood count
CERCLA Comprehensive Environmental Response,
Compensation, and Liability Act
(also called Superfund)
CFR Code of Federal Regulations
CGI combustible gas indicator
CNS central nervous system
CPR cardiopulmonary resuscitation
CRC Contamination Reduction Corridor
CRZ Contamination Reduction Zone
EPA U.S. Environmental Protection Agency
ESLI end-of-service-life indicator
FEF forced expiratory flow
FID flame ionization detector
FRC functional residual capacity
GC gas chromatography
IDLH immediately dangerous to life or health
IR infrared
LEL lower explosive limit
LFL lower flammable limit
MEFR maximal expiratory flow rate
MSHA Mine Safety and Health Administration
MVV maximal voluntary ventilation
NFPA National Fire Protection Association
NIOSH National Institute for Occupational Safety
and Health
OSHA Occupational Safety and Health Administratior
OVA organic vapor analyzer
PAPR powered air-purifying respirator
PCB polychlorinated biphenyl
PDS personnel decontamination station
PEL permissible exposure limit
PID photoionization detector
PPE personal protective clothing and equipment
PVC polyvinyl chloride
RBC red blood count
REL recommended exposure limit
RV residual volume
SAR supplied-air respirator
SCBA self-contained breathing apparatus
SOP Standard Operating Procedure
TLC total lung capacity
TLV threshold limit value
TLV-C threshold limit value—ceiling
TLV-STEL threshold limit value-
short-term exposure limit
TWA time-weighted average
UEL upper explosive limit
UFL upper flammable limit
USCG U.S. Coast Guard
UV ultraviolet
-------
Appendix B. Generic Site Safety Plan
This appendix provides a generic plan based on a plan developed by the
U.S. Coast Guard for responding to hazardous chemical releases.1 This
generic plan can be adapted for designing a Site Safety Plan for hazardous
waste site cleanup operations. It is not all inclusive and should only be
used as a guide, not a standard.
A. SITE DESCRIPTION
Date Location
Hazards
Area affected
Surrounding population_
Topog raphy
Weather conditions
Additional information
B. ENTRY OBJECTIVES - The objective of the initial entry to the contaminated
area is to (describes actions, tasks to be accomplished; i.e., identify
contaminated soil; monitor conditions, etc.)
C. ONSITE ORGANIZATION AND COORDINATION - The following personnel are
designated to carry out the stated job functions on site. (Note: One
person may carry out more than one job function.)
PROJECT TEAM LEADER
SCIENTIFIC ADVISOR
SITE SAFETY OFFICER
PUBLIC INFORMATION OFFICER_
SECURITY OFFICER
RECORDKEEPER
FINANCIAL OFFICER_
FIELD TEAM LEADER_
FIELD TEAM MEMBERS
^U.S. Coast Guard. Policy Guidance for Response to Hazardous Chemical
Releases. USCG Pollution Response COMDTINST-M16465.30.
-------
B-2 Appendix B
FEDERAL AGENCY REPS (i.e., EPA, NIOSH)
STATE AGENCY REPS
LOCAL AGENCY REPS
CONTRACTOR(S)
All personnel arriving or departing the site should log in and out with the
Recordkeeper. All activities on site must be cleared through the Project Team
Leader.
D. ONSITE CONTROL
(Name of individual or agency has been designated to coordinate
access control and security on site. A safe perimeter has been established
at (distance or description of controlled area)
No unauthorized person should be within this area.
The onsite Command Post and staging area have been established at
The prevailing wind conditions are . This location is upwind
from the Exclusion Zone.
Control boundaries have been established, and the Exclusion Zone (the
contaminated area), hotline, Contamination Reduction Zone, and Support Zone
(clean area) have been identified and designated as follows: (describe
boundaries and/or attach map of controlled area)
These boundaries are identified by: (marking of zones, i.e., red boundary
tape - hotline; traffic cones - Support Zone; etc.)
-------
Appendix B B-3
E. HAZARD EVALUATION
The following substance(s) are known or suspected to be on site. The primary
hazards of each are identified.
Substances Involved Concentrations (If Known) Primary Hazards
(chemical name) (e.g./ toxic on
inhalation)
The following additional hazards are expected on site: (i.e., slippery
ground, uneven terrain, etc.)
Hazardous substance information form(s) for the involved substance(s) have
been completed and are attached.
F. PERSONAL PROTECTIVE EQUIPMENT
Based on evaluation of potential hazards, the following levels of personal
protection have been designated for the applicable work areas or tasks:
Location Job Function Level of Protection
Exclusion Zone
Contaminat ion
Reduction Zone
A
A
A
A
A
A
A
A
B
B
B
B
B
B
B
B
C
C
C
C
C
C
C
C
D
D
D
D
D
D
D
D
Other
Other
Other
Other
Other
Other
Other
Other
Specific protective equipment for each level of protection is as follows:
Level A Fully-encapsulating suit Level C Splash gear (type)
SCBA Full-face canister resp.
(disposable coveralls)
Level B Splash gear (type) Level D
SCBA
Other
-------
B-4 Appendix B
The following protective clothing materials are required for the involved
substances:
Substance Material
(chemical name) (material name/ e.g., Viton)
If air-purifying respirators are authorized, (filtering medium) is the
appropriate canister for use with the involved substances and concentrations.
A competent individual has determined that all criteria for using this type of
respiratory protection have been met.
NO CHANGES TO THE SPECIFIED LEVELS OP PROTECTION SHALL BE MADE WITHOUT THE
APPROVAL OP THE SITE SAFETY OFFICER AND THE PROJECT TEAM LEADER.
G. ONSITE WORK PLANS
Work party(s) consisting of persons will perform the following tasks:
Project Team Leader (name) (function)
Work Party #1
Work Party #2
Rescue Team
(required for
entries to IDLH
environments)
Decontamination
Team
The work party(s) were briefed on the contents of this plan at
-------
Appendix B B-5
H. COMMUNICATION PROCEDURES
Channel has been designated as the radio frequency for personnel in the
Exclusion zone. All other onsite communications will use channel .
Personnel in the Exclusion Zone should remain in constant radio communication
or within sight of the Project Team Leader. Any failure of radio
communication requires an evaluation of whether personnel should leave the
Exclusion Zone.
(Horn blast, siren, etc.) is the emergency signal to indicate that all
personnel should leave the Exclusion Zone. In addition, a loud hailer is
available if required.
The following standard hand signals will be used in case of failure of radio
communications:
Hand gripping throat Out of air, can't breathe
Grip partner's wrist or Leave area immediately
both hands around waist
Hands on top of head Need assistance
Thumbs up OK, I am all right, I understand
Thumbs down No, negative
Telephone communication to the Command Post should be established as soon as
practicable. The phone number is .
I. DECONTAMINATION PROCEDURES
Personnel and equipment leaving the Exclusion Zone shall be thoroughly
decontaminated. The standard level decontamination protocol shall be
used with the following decontamination stations: (1)
(2) (3) (4) (5)
(6) (7) (8) (9)
(10) Other
Emergency decontamination will include the following stations:
The following decontamination equipment is required:
(Normally detergent and water) will be used as the decontamination
solution.
J. SITE SAFETY AND HEALTH PLAN
1. (name) is the designated Site Safety Officer and is
directly responsible to the Project Team Leader for safety recommendations on
site.
-------
B-6 Appendix B
2. Emergency Medical Care
(names of qualified personnel) are the qualified EMTs on site.
(medical facility names) , at (address)
phone is located minutes from this location.
(name of person) was contacted at (time) and briefed on
the situation, the potential hazards, and the substances involved. A map
of alternative routes to this facility is available at (normally Command
Post) .
Local ambulance service is available from at
phone . Their response time is minutes.
Whenever possible, arrangements should be made for onsite standby.
First-aid equipment is available on site at the following locations:
First-aid kit
Emergency eye wash
Emergency shower
(other)
Emergency medical information for substances present:
Substance Exposure Symptoms First-Aid Instructions
List of emergency phone numbers:
Agency/Facility Phone I Contact
Police
Fire
Hospital
Airport
Public Health Advisor
3. Environmental Monitoring
The following environmental monitoring instruments shall be used on site
(cross out if not applicable) at the specified intervals.
Combustible Gas Indicator - continuous/hourly/daily/other
02 Monitor - continuous/hourly/daily/other
Colorimetric Tubes - continuous/hourly/daily/other
(type)
HNU/OVA - continuous/hourly/daily/other
Other - continuous/hourly/daily/other
- continuous/hourly/daily/other
-------
Appendix B B-7
4. Emergency Procedures (should be modified as required for incident)
The following standard emergency procedures will be used by onsite
personnel. The Site Safety Officer shall be notified of any onsite
emergencies and be responsible for ensuring that the appropriate
procedures are followed.
Personnel Injury in the Exclusion Zone; Upon notification of an injury in
the Exclusion Zone, the designated emergency signal
shall be sounded. All site personnel shall assemble at the
decontamination line. The rescue team will enter the Exclusion Zone (if
required) to remove the injured person to the hotline. The Site Safety
Officer and Project Team Leader should evaluate the nature of the injury,
and the affected person should be decontaminated to the extent possible
prior to movement to the Support Zone. The onsite EMT shall initiate the
appropriate first aid, and contact should be made for an ambulance and
with the designated medical facility (if required). No persons shall
reenter the Exclusion zone until the cause of the injury or symptoms is
determined.
Personnel Injury in the Support Zone: Upon notification of an injury in
the Support Zone, the Project Team Leader and Site Safety Officer will
assess the nature of the injury. If the cause of the injury or loss of
the injured person does not affect the performance of site personnel,
operations may continue, with the onsite EMT initiating the appropriate
first aid and necessary follow-up as stated above. If the injury
increases the risk to others, the designated emergency signal
shall be sounded and all site personnel shall move
to the decontamination line for further instructions. Activities on site
will stop until the added risk is removed or minimized.
Fire/Explosion; Upon notification of a fire or explosion on site, the
designated emergency signal shall be sounded and
all site personnel assembled at the decontamination line. The fire
department shall be alerted and all personnel moved to a safe distance
from the involved area.
Personal Protective Equipment Failure; If any site worker experiences a
failure or alteration of protective equipment that affects the protection
factor, that person and his/her buddy shall immediately leave the
Exclusion Zone. Reentry shall not be permitted until the equipment has
been repaired or replaced.
Other Equipment Failure; If any other equipment on site fails to operate
properly, the Project Team Leader and Site Safety Officer shall be
notified and then determine the effect of this failure on continuing
operations on site. If the failure affects the safety of personnel or
prevents completion of the Work Plan tasks, all personnel shall leave the
Exclusion Zone until the situation is evaluated and appropriate actions
taken.
-------
B-8 Appendix B
The following emergency escape routes are designated for use in those
situations where egress from the Exclusion Zone cannot occur through
the decontamination line: (describe alternate routes to leave area in
emergencies)
In all situations, when an onsite emergency results in evacuation of the
Exclusion Zone, personnel shall not reenter until:
1. The conditions resulting in the emergency have been corrected.
2. The hazards have been reassessed.
3. The Site Safety Plan has been reviewed.
4. Site personnel have been briefed on any changes in the Site Safety
Plan.
5. Personal Monitoring
The following personal monitoring will be in effect on site:
Personal exposure sampling: (describe any personal sampling programs
being carried out on site personnel* This would include use of sampling
pumps, air monitors, etc.)
Medical monitoring: The expected air temperature will be ( °F) If
it is determined that heat stress monitoring is required (mandatory if
over 70°F) the following procedures shall be followed:
(describe procedures in effect, i.e., monitoring body temperature, body
weight, pulse rate)
All site personnel have read the above plan and are familiar with its
provisions.
Site Safety Oficer (name) (signature)
Project Team Leader
Other Site Personnel
-------
Appendix C. Sample Hazardous Substance Information Form
COMMON NAME:
CHEMICAL NAME:
I. PHYSICAL/CHEMICAL PROPERTIES
Natural physical state: Gas Liquid
(at ambient temps of 20°C-25°C)
Molecular weight
Density3
Specific gravity3
Solubility: water
Solubility13:
Boiling point
Melting point
Vapor pressure
Vapor density
Plash point
(open cup ; closed cup_
Other:
SOURCE
Solid
II. HAZARDOUS CHARACTERISTICS
A. TOXICOLOGICAL HAZARD HAZARD?
Inhalation
Ingestion
Skin/eye absorption
Skin/eye contact
Carcinogenic
Teratogenic
Mutagenic
Aquatic
Other:
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
Yes No
Yes No
No
No
Yes
Yes
B. TOXICOLOGICAL HAZARD HAZARD?
Combustibility Yes No
Toxic byproduct(s): Yes No
Flammability
LPL
UFL
Explosivity
LEL
UEL
Yes No
Yes No
g/g-mole_
g/mi
@ °F/°C
@
@
°F/°C
°F/°C
°F/°C
°F/°C
mmHg @
@
°F/°C
°F/°C
°F/°C
CONCENTRATIONS
(PEL, TLV, Other)
CONCENTRATIONS
SOURCE
SOURCE
aOnly one is necessary.
kpor organic compounds, recovery of spilled material by solvent extraction may
require solubility data.
-------
C-2
Appendix C
C. REACTIVITY HAZARD
Reactivities:
HAZARD?
Yes No
CONCENTRATIONS
SOURCE
D. CORROSIVITY HAZARD HAZARD?
ph Yes No
Neutralizing agent:
CONCENTRATIONS
SOURCE
E. RADIOACTIVE HAZARD HAZARD?
Background Yes No
Alpha particles Yes No
Beta particles Yes No
Gamma radiation Yes No
III. DESCRIPTION OF INCIDENT:
Quantity involved
Release information
EXPOSURE RATE
SOURCE
Monitoring/sampling recommended
IV. RECOMMENDED PROTECTION:
Worker
Public
V. RECOMMENDED SITE CONTROL:
Hotline
Decontamination line
Command Post location
VI. REFERENCES FOR SOURCES:
-------
Appendix C
C-3
SAMPLE HAZARDOUS SUBSTANCE INFORMATION FORM FILLED OUT FOR VINYL CHLORIDE
COMMON NAME;
C>\lor',Jc,
CHEMICAL NAME;
I. PHYSICAL/CHEMICAL PROPERTIES
Natural physical state: Gas ^ Liquid
(at ambient temps of 20°C-25°C)
Molecular weight
Density3
Specific gravity3
Solubility: water
Solubility13: alcohol
Boiling point
Melting point
Vapor pressure
Vapor density
Flash point
(open cup iX^ ; closed cup_
Other: Fbly** tribes resJ;J
-------
C-4
Appendix C
C.
D.
E.
REACTIVITY HAZARD
Reactivities:
fvlyfltfr/^ts is\ affj
fuili 4\l*'t~ «/• Hf*.i~
\J
CORROSIVITY HAZARD
Ph
Neutralizing agent:
RADIOACTIVE HAZARD
Background
Alpha particles
Beta particles
Gamma radiation
HAZARD?
(Yes) No
HAZARD?
Yes Otop
HAZARD?
Yes 09>
Yes uQ
Yes Gg/
Yes (No)
CONCENTRATIONS
CONCENTRATIONS
EXPOSURE RATE
SOURCE
III. DESCRIPTION OF INCIDENT:
Quantity involved // D0O
SOURCE
SOURCE
Release information
St*Sf>e.t*ecL
Monitoring/sampling recommended
IV. RECOMMENDED PROTECTION:
Worker Level ff prvfe cftostt Pn>te.c3~/\s-e.
or
Public
V. RECOMMENDED SITE CONTROL:
Hotline
Decontamination line
Command Post location
VI. REFERENCES FOR SOURCES:
- Oil
— Handbook,
..
tf 10. 10
-------
Appendix D. Sample Decontamination Procedures for
Three Typical Levels of Protection3
F.S.O.P. No. 7
Process: DECONTAMINATION PROCEDURES
INTRODUCTION
1.1 The objective of these procedures is to minimize the risk of
exposure to hazardous substances. These procedures were derived
from the U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response's (OERR), "Interim Standard
Operating Safety Guides (revised Sep. 82)". This version of the
?uides is in a format that is more appropriate for use in the
ield.
1.2 Protective equipment must be worn by personnel when response
activities involve known or suspected hazardous substances. The
procedures for decontaminating personnel upon leaving the
contaminated area are addressed for each of the EPA, OERR
designated levels of protection. The procedures given are for
the maximum and minimum amount of decontamination used for each
level of protection.
1.3 The maximum decontamination procedures for all levels of
protection consist of specific activities at nineteen stations.
Each station emphasizes an important aspect of decontamination.
When establishing a decontamination line, each aspect should be
incorporated separately or combined with other aspects into a
procedure with fewer steps (such as the Minimum Decontamination
Procedures).
1.4 Decontamination lines are site specific since they are dependent
upon the types of contamination and the type of work activities
on site. A cooling station is sometimes necessary within the
decontamination line during hot weather. It is usually a
location in a shaded area in which the wind can help to cool
personnel. In addition, site conditions may permit the use of
cooling devices such as cool water hose, ice packs, cool towels,
etc. When the decontamination line is no longer required,
contaminated wash and rinse solutions and contaminated articles
must be contained and disposed of as hazardous wastes in
compliance with state and federal regulations.
a Source: Excerpted from Field Standard Operating Procedures for the Decon-
tamination of Response Personnel (FSOP 7). EPA Office of Emergency
and Remedial Response, Hazardous Response Support Division,
Washington, DC. January 1985.
-------
D-2
Appendix D
P.S.O.P. No. 7
PROCESS DECON PROCEDURES
MAXIMUM DECONTAMINATION LAYOUT
LEVEL A PROTECTION
EXCLUSION 1
ZONE n „
Boot Cover
Outer Glove Tape &
Removal Removal Glove Wash
£> — C§>^-0*-HSh-HSH--ci
' k Boot Cover Boot Cover &
Removal Glove Rinse ur
i r
r
Segregated
J Equipment
' Drop
7 i Suit/Safety Boot
Wash
Tank Change k^T*
and Redress - Boot Cover/
Outer Gloves
Suit/Safety Boot
Rinse
CONTAMINATION
REDUCTION
ZONE
fto) Safety Boot
Removal
ff^| Fully Encapsulating Suit
and Hard Hat Removal
fl2) SCBA Backpack
Removal
fiol Inner Glove
L J Wash
[^4] Inner Glove
Rinse
[15] Face Piece
Removal
fje] Inner Glove
Removal
(17J Inner Clothing
Removal
Field
Wash
[18]
Redress
CONTAMINATION
'CONTROL LINE '
SUPPORT
ZONE
-------
Appendix D
D-3
P.S.O.P. No. 7
PROCESS DECON PROCEDURES
MAXIMUM DECONTAMINATION LAYOUT
LEVEL B PROTECTION
Outer Glove
Removal
EXCLUSION
ZONE
Tape
Removal
Boot Cover
&
Glove Wash
Boot Cover
Removal
Boot Cover &
Glove Rinse
Segregated
Equipment
Drop
• HOTLINE
7 J Suit/Safety Boot
Wash
Tank Change [*)+
and Redress - Boot Cover/
Outer Gloves
[10]
Suit/SCBA/Boot/Glove
Rinse
Safety Boot
Removal
[11]
CONTAMINATION
REDUCTION T12]
ZONE
SCBA Backpack
Removal
Splash Suit
Removal
113]
Inner Glove
Wash
[14]
Inner Glove
Rinse
Face Piece
Removal
Inner Glove
Removal
Inner Clothing
Removal
Field
Wash
-M19J Redress
CONTAMINATION
CONTROL LINE
SUPPORT
ZONE
-------
D-4
Appendix D
P.S.O.P. No. 7
PROCESS DECON PROCEDURES
MAXIMUM DECONTAMINATION LAYOUT
LEVEL C PROTECTION
EXCLUSION
ZONE Boot Cover
Outer Glove Tape &
Removal Removal Glove Wash
(6> {J^__0^_r^_0^_^
' k Boot Cover Boot Cover &
Removal Glove Rinse
1 r
Segregated
s. Equipment
J Drop
Canister or
Mask Change ^*J+
and Redress - Boot Cover/
Outer Gloves
7 J Suit/Safety Boot
Wash
Suit/Safety Boot
Rinse
[10] Safety Boot
Removal
CONTAMINATION
REDUCTION
ZONE
fll} Splash Suit
Removal
112]
Inner Glove
Wash
f^t\ Inner Glove
^ J Rinse
f^j Face Piece
Removal
[15]
Inner Glove
Removal
[16]
Inner Clothing
Removal
Field [17j
Wash
-W18] Redress
CONTAMINATION
CONTROL LINE
SUPPORT
ZONE
-------
Appendix D
D-5
P.S.O.P. No. 7
PROCESS DECON PROCEDURES
MINIMUM DECONTAMINATION LAYOUT
LEVELS A & B PROTECTION
WIND DIRECTION
I Redress: Boot Covers
1 and Outer Gloves
tii 1 Decon
— | Solution
o 1 (5tfe 1
1 1
^r
Decon Outer v^
Equipment Garments .X
Dr°P > y/ Remove
>^ Boot Covers
,/and Outer Gloves
b ;: b
Plastic O 1 Can
_N. i
Water Tar
^ ^^
20°**^^
k
Change-Over
Point
* * (t
>\ .
> > V^y — r
Sheet | (10 gallon)
Remove
Boots/Gloves
anH
Ql IU
Outer
Garments
(For Disposal fc
and Off Site
Decontam ination)
b
Can
(32 gallon)
I
REMOVE
SCBA
-------
D-6
Appendix D
F.S.O.P. No. 7
PROCESS DECON PROCEDURES
MINIMUM DECONTAMINATION LAYOUT
LEVEL C PROTECTION
WIND DIRECTION
Equipment
Drop
Plastic
Sheet
Redress: Boot Covers
and Outer Gloves
Decon
Solution
Decon Outer
Garments
/
Remove
Boot Covers
and Outer Gloves
lib
O I Can
L-i
Water
Can
(10 gallon)
Cartridge or Canister
Change-Over
Point
Remove
Boots/Gloves
and
Outer
Garments
(For Disposal
and Off Site
Decontamination)
Can
(32 gallon)
REMOVE
MASK
-------
Appendix D
D-7
EQUIPMENT NEEDED TO PERFORM MAXIMUM DECONTAMINATION MEASURES FOR LEVELS A, B, AND C
Station 1: a. Various Size Containers
b. Plastic Liners
c. Plastic Drop Cloths
Station 2: a. Containers (20-30 Gallons)
b. Decon Solution or Detergent Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 3: a. Containers (20-30 Gallons)
OR
High-Pressure Spray Unit
b. Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 4: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 5: a. Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
Station 6: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 7: a. Containers (20-30 Gallons)
b. Decon Solution or Detergent Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 8: a. Containers (20-30 Gallons)
OR
High-Pressure Spray Unit
b. Water
c. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 9: a. Air Tanks or Face Masks and
Cartridge Depending on Level
b. Tape
c. Boot Covers
d. Gloves
Station 10: a. Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
d. Boot Jack
Station 11: a. Rack
b. Drop Cloths
c. Bench or Stools
Station 12: a. Table
Station 13: a. Basin or Bucket
b. Decon Solution
c. Small Table
Station 14: a. Water
b. Basin or Bucket
c. Small Table
Station 15: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 16: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 17: a. Containers (20-30 Gallons)
b. Plastic Liners
Station 18: a. Water
b. Soap
c. Small Table
d. Basin or Bucket
e. Field Showers
f. Towels
Station 19: a. Dressing Trailer is Needed in
Inclement Weather
b. Tables
c. Chairs
d. Lockers
e. Cloths
EQUIPMENT NEEDED TO PERFORM MINIMUM DECONTAMINATION MEASURES FOR LEVELS A, B, AND C
Station 1: a. Various Size Containers
b. Plastic Liners
c. Plastic Drop Cloths
Station 2: a. Containers (20-30 Gallons)
b. Decon Solution
c. Rinse Water
d. 2-3 Long-Handled, Soft-Bristled
Scrub Brushes
Station 3: a. Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
Station 4: a. Air Tanks or Masks and
Cartridges Depending Upon Level
b. Tape
c. Boot Covers
d. Gloves
Station 5: a. Containers (20-30 Gallons)
b. Plastic Liners
c. Bench or Stools
Station 6: a. Plastic Sheets
b. Basin or Bucket
c. Soap and Towels
d. Bench or Stools
Station 7: a. Water
b. Soap
c. Tables
d. Wash Basin or Bucket
-------
D-8
Appendix D
FSOP 7: MAXIMUM MEASURES FOR LEVEL A DECONTAMINATION
Station 1: Segregated Equipment
Drop
Station 2: Boot Cover and
Glove Wash
Station 3: Boot Cover and
Glove Rinse
Station 4: Tape Removal
Station 5: Boot Cover
Removal
Station 6: Outer Glove
Removal
Station 7: Suit and Boot
Mash
Station 8: Suit and Boot
Station 9: Tank Change
Station 10: Safety Boot
Removal
Station 11: Fully Encapsulating
Suit and Hard Hat
Removal
Station 12: SCBA Backpack
Removal
Station 13: Inner Glove Wash
Station 14: Inner Glove Rinse
Station 15: Face Piece Removal
Station 16: Inner Glove
Removal
1. 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.
During hot weather operations, a cool down
station may be set up within this area.
2. Scrub outer boot covers and gloves with decon
solution or detergent/water.
3. Rinse off decon solution from station 2 using
copious amounts of water.
4. Remove tape around boots and gloves and deposit
in container with plastic liner.
5. Remove boot covers and deposit in container
with plastic liner.
6. Remove outer gloves and deposit In container
with plastic liner.
7. Wash encapsulating suit and boots using scrub
brush and decon solution or detergent/water.
Repeat as many times as necessary.
8. Rinse off decon solution using water. Repeat as
many times as necessary.
9. If an air tank change is desired, this Is the
last step in the decontamination procedure.
Air tank 1s exchanged, new outer gloves and boot
covers donned, and joints taped. Worker returns
to duty.
10. Remove safety boots and deposit in container
with plastic liner.
11. Fully encapsulated suit 1s removed with
assistance of a helper and laid out on a drop
cloth or hung up. Hard hat Is removed. Hot
weather rest station maybe set up within this
area for personnel returning to site.
12. While still wearing faceplece, remove backpack
and place on table. Disconnect hose from
regulator valve and proceed to next station.
13. Wash with decon solution that will not harm the
skin. Repeat as often as necessary.
14. Rinse with water.
necessary.
Repeat as many times as
15. Remove face piece. Deposit 1n container with
plastic Uner. Avoid touching face with fingers.
16. Remove Inner gloves and deposit in container
with liner.
-------
Appendix D
D-9
FSOP 7: MAXIMUM MEASURES FOR LEVEL A DECONTAMINATION
Station 17: Inner Clothing
Removal
Station 18: Field Wash
Station 19: Redress
17. Remove clothing and place 1n lined container.
Do not wear Inner clothing off-site since there
is a possibility that small amounts of
contaminants might have been transferred in
removing the fully-encapsulating suit.
18. 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.
19. Put on clean clothes.
FSOP 7: MINIMUM MEASURES FOR LEVEL A DECONTAMINATION
Station 1: Equipment Drop
Station 2: Outer Garment,
Boots, and Gloves
Wash and Rinse
Station 3: Outer Boot and
Glove Removal
Station 4: Tank Change
Station 5: Boot, Gloves
and Outer Garment
Removal
Station 6: SCBA Removal
Station 7: Field Wash
1. Deposit equipment used on-slte (tools, sampling
devices and containers, monitoring Instruments,
radios, clipboards, etc.) on plastic drop
cloths. Segregation at the drop reduces the
probability of cross contamination. During hot
weather operations, cool down stations maybe set
up within this area.
2. Scrub outer boots, outer gloves and fully-
encapsulating suit with decon solution or
detergent and water. Rinse off using copious
amounts of water.
3. Remove outer boots and gloves. Deposit In
container with plastic liner.
4. 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.
5. Boots, fully-encapsulating suit, inner gloves
removed and deposited in separate containers
lined with plastic.
6. SCBA backpack and facepiece Is removed (avoid
touching face with fingers). SCBA deposited
on plastic sheets.
7. Hands and face are thoroughly washed.
soon as possible.
Shower as
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D-10
Appendix D
FSOP 7: MAXIMUM MEASURES FOR LEVEL B DECONTAMINATION
Station 1: Segregated Equipment
Drop
Station 2: Boot Cover and
Glove Wash
Station 3: Boot Cover and
Glove Rinse
Station 4: Tape Removal
.Station 5: Boot Cover
Removal
Station 6: Outer Glove
removal
Station 7: Suit and Safety
Boot Wash
Station 8: Suit, SCBA, Boot,
and Glove Rinse
Station 9: Tank Change
Station 10: Safety Boot
Removal
Station 11: SCBA Backpack
Removal
Station 12: Splash Suit
Removal
Station 13: Inner Glove Wash
Station 14: Inner Glove Rinse
Station 15: Face Piece Removal
Station 16: Inner Glove
Removal
1. 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. Segregation at the drop reduces the
probability of cross-contamination. During hot
weather operations, cool down stations may be set
up within this area.
2. Scrub outer boot covers and gloves with decon
solution or detergent and water.
3. Rinse off decon solution from station 2 using
copious amounts of water.
4. Remove tape around boots and gloves and deposit
1n container with plastic liner.
5. Remove boot covers and deposit in container
with plastic liner.
6. Remove outer gloves and deposit In container
with plastic Uner.
7. Wash chemical-resistant splash suit, SCBA,
gloves and safety boots. Scrub with long-handle
scrub brush and decon solution. Wrap SCBA
regulator (1f belt mounted type) with plastic to
keep out water. Wash backpack assembly with
sponges or cloths.
8. Rinse off decon solution using copious amounts
of water.
9. 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, and joints taped. Worker returns to
duty.
10. Remove safety boots and deposit 1n container
with plastic liner.
11. While still wearing faceplece, remove back-
pack and place on table. Disconnect hose from
regulator valve.
12. With assistance of helper, remove splash suit.
Deposit 1n container with plastic liner.
13. Wash Inner gloves with decon solution.
14. Rinse Inner gloves with water.
15. Remove face piece. Deposit In container with
plastic liner. Avoid touching face with fingers.
16. Remove inner gloves and deposit in container
with liner.
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Appendix D
D-11
FSOP 7: MAXIMUM MEASURES FOR LEVEL B DECONTAMINATION,
Station 17: Inner Clothing
Removal
Station 18: Field Wash
Station 19: Redress
17. Remove Inner clothing. Place In container with
liner. Do not wear Inner clothing off-site
since there Is a possibility that small amounts
of contaminants might have been transferred in
removing the fully-encapsulating suit.
18. 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.
19. Put on clean clothes.
FSOP 7: MINIMUM MEASURES FOR LEVEL B DECONTAMINATION
Station 1: Equipment Drop
Station 2: Outer Garment,
Boots, and Gloves
Wash and Rinse
Station 3: Outer Boot and
Glove Removal
Station 4: Tank Change
Station 5: Boot, Gloves
and Outer Garment
Removal
Station 6: SCBA Removal
Station 7: Field Wash
1. Deposit equipment used on-site (tools, sampling
devices and containers, monitoring instruments,
radios, clipboards, etc.) on plastic drop
cloths. Segregation at the drop reduces the
probability of cross contamination. During hot
weather operations, cool down station may be set
up within this area.
2. Scrub outer boots, outer gloves and chemical-
resistant splash suit with decon solution or
detergent water. Rinse off using copious
amounts of water.
3. Remove outer boots and gloves. Deposit in
container with plastic liner.
4. If worker leaves exclusive 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.
5. Boots, chemical-resistant splash suit, inner
gloves removed and deposited in separate
containers lined with plastic.
6. SCBA backpack and facepiece is removed. Avoid
touching face with finger. SCBA deposited
on plastic sheets.
7. Hands and face are thoroughly washed.
soon as possible.
Shower as
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D-12
Appendix D
FSOP 7: MAXIMUM MEASURES FOR LEVEL C DECONTAMINATION
Station 1: Segrated Equipment
Drop
Station 2: Boot Cover and
Glove Wash
Station 3: Boot Cover and
Glove Rinse
Station 4: Tape Removal
Station 5: Boot Cover
Removal
Station 6: Outer Glove
Removal
Station 7: Suit and Boot
Wash
Station 8: Suit and Boot,
and Glove Rinse
Station 9: Canister or
Mask Change
Station 10: Safety Boot
Removal
Station 11: Splash Suit
Removal
Station 12: Inner Glove
Rinse
Station 13: Inner Glove
Mash
Station 14: Face Piece
Removal
Station 15: Inner Glove
Removal
1. Deposit equipment used on site (tools, sampling
devices and containers, monitoring instruments,
radios, clipboards, etc.) on plastic drop
cloths or in different containers with plastu
liners. Segregation at the drop reduces the
probability of cross contamination. During hot
weather operations, a cool down station may be
set up within this area.
2. Scrub outer boot covers and gloves with decon
solution or detergent and water.
3. Rinse off decon solution from station 2 using
copious amounts of water.
4. Remove tape around boots and gloves and deposit
in container with plastic liner.
5. Remove boot covers and deposit in containers
with plastic liner.
6. Remove outer gloves and deposit in container
with plastic liner.
7. Wash splash suit, gloves, and safety boots.
Scrub with long-handle scrub brush and decon
solution.
8. Rinse off decon solution using water. Repeat as
many times as necessary.
9. 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 boot
covers donned, and joints taped worker returns
to duty.
10. Remove safety boots and deposit in container
with plastic liner.
11. With assistance of helper, remove splash
suit. Deposit in container with plastic liner.
12. Wash inner gloves with decon solution.
13. Rinse inner gloves with water.
14. Remove face piece. Deposit in container with
plastic liner. Avoid touching face with fingers.
15. Remove inner gloves and deposit in lined
container.
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Appendix D
D-13
FSOP 7: MAXIMUM MEASURES FOR LEVEL C DECONTAMINATION
Station 16: Inner Clothing
Removal
Station 17: Field Wash
Station 18: Redress
16. Remove clothing soaked with perspiration and
place in lined container. Do not wear inner
clothing off-site since there is a possibility
that small amounts of contaminants might have
been transferred in removing the fully-
encapsulating suit.
17. 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.
18. Put on clean clothes.
FSOP 7: MINIMUM MEASURES FOR LEVEL C DECONTAMINATION
Station 1: Equipment Drop
Station 2: Outer Garment,
Boots, and Gloves
Wash and Rinse
Station 3: Outer Boot and
Glove Removal
Station 4: Canister or
Mask Change
Station 5: Boot, Gloves
and Outer Garment
Removal
Station 6: Face Piece
Removal
1. Deposit equipment used on-site (tools, sampling
devices and containers, monitoring instruments,
radios, clipboards, etc.) on plastic drop
cloths. Segregation at the drop reduces the
probability of cross contamination. During hot
weather operations, a cool down station may be
set up within this area.
2. Scrub outer boots, outer gloves and splash
suit with decon solution or detergent water.
Rinse off using copious amounts of water.
3. Remove outer boots and gloves. Deposit in
container with plastic liner.
4. If worker leaves exclusive zone to change
canister (or mask), this is the last step in the
decontamination procedure. Worker's canister is
exchanged, new outer gloves and boot covers
donned, joints taped, and worker returns to duty.
5. Boots, chemical-resistant splash suit, inner
gloves removed and deposited in separate
containers lined with plastic.
6. Facepiece is removed. Avoid touching face with
fingers, Facepiece deposited on plastic sheet.
Station 7: Field Wash
7. Hands and face are thoroughly washed.
soon as possible.
Shower as
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Appendix E. NIOSH, OSHA, and EPA Regional Offices and USCG District Offices
NIOSH Regional Offices
HHS Region I
Government Center
(JFK Federal Building)
Boston, MA 02203
Telephone: (617) 223-3848
HHS Region II
26 Federal Plaza, Room 3337
New York, NY 10278
Telephone: (212) 264-5747
HHS Region III
521-35 Market Street
P.O. Box 13716
Philadelphia, PA 19101
Telephone: (215) 596-6716
HHS Region IV
101 Marietta Tower, Suite 1007
Atlanta, GA 30323
Telephone: (404) 221-2396
HHS Region V
300 South Wacker Drive, 33rd Floor
Chicago, IL 60606
Telephone: (312) 886-3881
HHS Region VI
1200 Main Tower Building
Room 1835
Dallas, TX 75202
Telephone: (214) 767-3916
HHS Region VII
601 East 12th Street
Kansas City, MO 64106
Telephone: (816) 374-3491
HHS Region VIII
1185 Federal Building
1961 Stout Street
Denver, CO 80294
Telephone: (303) 844-6163 x17
HHS Region IX
50 United Nations Plaza
San Francisco, CA 94102
Telephone: (415) 556-3782
HHS Region X
2901 Third Avenue, M.S. 402
Seattle, WA 98121
Telephone: (206) 442-0530
OSHA Regional Offices
OSHA Region I
16-18 North Street
1 Dock Square Building, 4th Floor
Boston, MA 02109
Telephone: (617) 223-6710
OSHA Region II
One Astor Plaza, Room 3445
1515 Broadway
New York, NY 10036
Telephone: (212) 944-3432
OSHA Region III
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
Telephone: (215) 596-1201
OSHA Region IV
1375 Peachtree Street, N.E.
Suite 587
Atlanta, GA 30367
Telephone: (404) 881-3573
OSHA Region V
230 South Dearborn Street
32nd Floor, Room 3244
Chicago, IL 60604
Telephone: (312) 353-2220
OSHA Region VI
525 Griffin Square, Room 602
Dallas, TX 75202
Telephone: (214) 767-4731
OSHA Region VII
911 Walnut Street, Room 406
Kansas City, MO 64106
Telephone: (816) 374-5861
OSHA Region VIII
Federal Building, Room 1554
1961 Stout Street
Denver, CO 80294
Telephone: (303) 837-3061
OSHA Region IX
450 Golden Gate Avenue
Box 36017
San Francisco, CA 94102
Telephone: (415) 556-7260
OSHA Region X
Federal Office Building, Room 6003
909 First Avenue
Seattle, WA 98174
Telephone: (206) 442-5930
EPA Regional Offices
EPA Region I
JFK Federal Building
Boston, MA 02203
Telephone: (617) 223-7210
EPA Region II
26 Federal Plaza
Room 900
New York, NY 10218
Telephone: (212) 264-2525
EPA Region III
841 Chestnut Street
Philadelphia, PA 19107
Telephone: (215) 597-9800
EPA Region IV
345 Cortland Street, N.E.
Atlanta, GA 30365
Telephone: (404) 881-4727
EPA Region V
230 S. Dearborne Street
Chicago, IL 60604
Telephone: (312) 353-2000
EPA Region VI
First International Building
1201 Elm Street
Dallas, TX 75270
Telephone: (214) 767-2600
EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
Telephone: (913) 236-2800
EPA Region VIII
One Denver Place
999 18th Street, Suite 1300
Denver, CO 80202-2413
Telephone: (303) 293-1603
EPA Region IX
215 Fremont Street
San Francisco, CA 94105
Telephone: (415) 974-8153
EPA Region X
1200 6th Avenue
Seattle, WA 98101
Telephone: (206) 442-5810
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E-2
Appendix E
USCG District Offices
Commander (mep)
First Coast Guard District
150 Causeway Street
Boston, MA 02114
Telephone: (617) 223-6915
Commander (meps)
Second Coast Guard District
1430 Olive Street
St. Louis, MO 63103
Telephone: (314) 425-4655
Commander (mer)
Third Coast Guard District
Governors Island
New York, NY 10004
Telephone: (212) 668-7152
Commander (mep)
Fifth Coast Guard District
Federal Building
431 Crawfort Street
Portsmouth, VA 23705
Telephone: (804) 398-6383
Commander (mep)
Seventh Coast Guard District
Federal Building
51 S.W. 1st Avenue
Miami, FL 33130
Telephone: (305) 350-5276
Commander (mep)
Eighth Coast Guard District
Hale Boggs Federal Building
500 Camp Street
New Orleans, LA 70130
Telephone: (504) 589-6296
Commander (mep)
Ninth Coast Guard District
1240 East 9th Street
Cleveland, OH 44199
Telephone: (216) 522-3918
Commander (mep)
Eleventh Coast Guard District
Union Bank Building
400 Oceangate
Long Beach, CA 90822
Telephone: (213) 590-2301
Commander (mepps)
Twelfth Coast Guard District
Building 51
Government Island
Alameda, CA 94501
Telephone: (415) 437-3465
Commander (mep)
Thirteenth Coast Guard District
Federal Building
915 Second Avenue
Seattle, WA 98174
Telephone: (206) 442-5850
Commander (mep)
Fourteenth Coast Guard District
Prince Kalanianaole Federal Building
300 Ala Moana Boulevard, 9th Floor
Honolulu, HI 96850
Telephone: (808) 546-7510
Commander (mep)
Seventeenth Coast Guard District
P.O. Box 3-5000
Juneau, AK 99802
Telephone: (907) 586-7195
U.S. Coast Guard Districts
Pacific Area
Atlantic Area
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Appendix E E-3
NIOSH, OSHA, AND EPA REGIONS
Ifr U.S.GOVERNMENT PRINTING OFFICEi 1989-646-164/00506
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