&EPA
             Untied States
             Environ
             Agency
            Office of
            3oi'd Waste and
               Response
DIRECTIVE NUMBER: 9235.3-02

TITLE: Employee Occupational Health and Safety



APPROVAL DATE.  July 7, 1987

EFFECTIVE DATE:  July 7, 1997

ORIGINATING OFFICE: CERK

O FINAL

D DRAFT

 STATUS:
             REFERENCE (other documents):
               EPA Order 1440.3
               EPA Order 1440.2
               29 CFR Part 1910
               29 CFR Part 1926
                51 FR 45654 Decemcer 19, 198
                E.O. 12196 (February 1980)
OSWER      OS WE ft      OSWER
E   DIRECTIVE   DIRECTIVE   L

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          United Slates cnvimnmeniivPntection Agency
                Washington. DC 20460

OSWER Directive initiation Request
                                                               1 • Directive Number



                                                               9285.3-02
                                2. Originator Information
      Name of Contact Person

        JiacL
                   l Coat
Office
                                    ERD/ERT
Teiepnore Coae

 340-6745
      3. Title
         Employee Occupational Health & Safety
      4. Summary of Directive (induce one) statement of purpose)


        Provides instructions reminding EPA employees that they must comply with OSHA.
      5. Keywords  Superfurti, CEFCLA, SARA
      5a. Ooes i fin directive Supersede Previous Oirecuvetsi?
      b. Ooes it Supplement Previous Oirecttve(j)?
                     [  j No -   I	j Yet    What dirtctivt (number. We)






                         o       Y«*    W«t tfrectrve (number. We)
                             "^"•J    ^ .^ _
       draft Level
          A - Signed by AA/OAA       8 - Signed by Office Oirtctor
                                 C - For Review 4 Comment
           8. Document to b« distributed to States by Headquarters?  I   IYM
                                                      No
This Request Me«tt OSWCR Directive* System Format Standard*.
9. Signature of Lead Office Directives Coordinator
Richard Hyde
10. Name and Title at Approving Official
Win Porter, Assistant Administrator
Oat*
7/7/87
Data
7/7/87
     EPA Form 1315-17 (Rev. s-47) Previous editions are obsolete.
   OSWER          OSWER               OSWER              O

VE     DIRECTIVE         DIRECTIVE       DIRECTIVE

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         WASHINGTON, D.C. 20460
                              JUL   71987

                                                    3C
                                                      OSWER Directive 9285.3-02
                                                         OP
                                          3OUO WASTE AND KMEMQKNCV RESPONSE
MEMORANDUM
SUBJECT:
FROM:
mployee.Occupational  Health  and  Safety
 ;L  //'I1  /-ft- /<
.. Winston Porier,  Assistant  Administrator
            ;L ;/'/'
           . Wfnstb
           fflce of Solf/d Waste and Emergency  Response

TO:       Addressees


     As we Initiate our field activities under the  Superfund  Amendments
and Reauthor1zat1on Act of 1986 (SARA),  I wish to remind everyone that all
EPA employees are required to comply with the  Federal Occupational Health
and Safety Act (OSHA).  In addition to complying with such  federal standards
as 29 CFR 1910/1926, EPA employees must  also adhere to  the  appropriate EPA
orders, policies, and guidelines pertaining to employee occupational  health
and safety.  For example, EPA Order 1440.3 requires all  EPA employees
using respiratory protection devices to participate 1n  a medical monitoring
program.  I want to encourage all  Regions and  OSWER offices to  continue to
Implement effective medical monitoring programs for Its employees.  EPA
Order 1440.2 requires all EPA employees  engaged 1n  routine  field activities
to be trained and to receive training certification levels  commensurate
with the degree of anticipated hazards.   EPA Order  1440 specifies the
responsibilities of all Agency employees 1n this area.

     More recently, section 126(a) of SARA requires the Secretary of
Labor, within one year of the date of enactment, to promulgate standards
(29 CFR 1910.120) for health and safety protection  of employees engaged
in hazardous waste operations.  The Secretary  1s also  required 1n  Subsec-
tion 126(e) to Issue Interim final regulations within  60 days after
enactment of SARA.  The Interim final rule was published 1n the Federal
Register (Vol. 51, No. 244, pages 45654 - 45675) on December 19, 1986.
This Interim final rule took effect upon the date of Issuance  (December
19, 1986), and 1t was OSHA's judgment that all provisions could be fully
Implemented not later than 90 days after Issuance  (March 17, 1987).  As
with other OSHA Section 6 Standards, EPA 1s required to comply with 29
CFR 1910.120 per Executive Order  12196  (February 1980).

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                         (OSWER Directive 9285.3-02)

                                   -2-
      In  addition, section  126(f) of SARA requires the Administrator
 of EPA,  within  90 days after the promulgation of final regulations under
 section  126(a),  (January 17, 1988), to promulgate standards identical
 to 29 CFR  1910.120  (those  promulgated by the Secretary of Labor under
 section  126(a)). EPA's Workgroup No. 2427 (Hazardous Waste Operations
 and Emergency Response Worker Protection Standards), chaired by Rod Turpin,
 Safety and Occupational Health Manager, Environmental Response Team
 (ERT), Edison,  NJ,  has been established and includes representatives of
 five (5) EPA Regions, two  (2) States, and OSHA.  In addition, the following
 EPA Headquarters offices are represented:  Office of Policy, Planning and
 Evaluation, Office  of Pesticides and Toxic Substances, Office of General
 Counsel, Office of  Research and Development, Office of Solid Waste and
 Emergency Response, and the Occupational Health and Safety Staff.  The
 objective of this Workgroup is to:

      1.  Promulgate EPA Worker Health and Safety Standards
     *    Identical  to OSHA's standards  (29 CFR 1910.120)for those 27
         States which do not have in effect an approved State Plan under
         the Occupational  Safety and Health Act of 1970.

      2.  Develop an implementation/enforcement strategy for these EPA
         standards.

      In order to better implement both EPA and OSHA Occupational Health
and  Safety requirements, OSWER has established an  Integrated Health and
Safety Program for the sole purpose of assisting OSWER in providing a
safe  and healthy work environment for its field activities.  This program
Is managed by Rod Turpin,  ERT, Edison, NJ.  Please feel free to call him
at  201-321-6745 (FTS 340-6745) for any additional  information.

      Thank you in advance  for your assistance and dedication in making
our work environment a safe and healthy one.
Addressees:

Regional Administrators, Regions I - X
Henry L. Longest II (HH-548)
Marcia E. Williams (UH-562)
Ronald Brand (WH-562A)
Gene A. Lucero (WH-527)

cc:  David Weltzman (PM-273F)
     Waste Management Division Directors, EPA Regions  I-X
     Environmental Services Division Directors,  EPA  Regions  I-X

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