oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
9285.0-01
TITLE:
OSWER Integrated Health & Safety Policy
for Field Activities
APPROVAL DATE: 11/22/88
EFFECTIVE DATE:
ORIGINATING OFFICE:
; Q^INAL
D DRAFT
STATUS:
REFERENCE (other documents):
11/22/88
OSWER/OERR/ERD/ERT
Renumbered. Formerly 9010.15
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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Unneo Slates environmental Pntection Agency
Wasmngton. DC 20460
OSWER Directive Initiation Request
1. uir«cttv« Numoer
1. Originator Information
Name of Contact Person
Vickie Santoro
,M
Pfi&W
Office
ERT/ERB
T«epnore Coae
FTS 340-6917
3. Title
OSWER Integrated Health and Safety Policy for -Field Activities
4. Summary of Directive (inciuae onet statement of purpose!
This policy, signed by the Deputy Assistant Administrator, OSWER, articulates
the requirement for all EPA employees to comply with OSHA as well as EPA Health
and Safety Directives. The 27-page manual outlines the cnditions of this policy
and the roles and responsibilities of EPA employees in meeting them. The. policy '
applies to all OSWER employees engaged in hazardous substances response activities.
s.Keyworas Superfurti, CERCIA, SARA
oa. uoes This Directive Supersede Previous Oirective(s)?
b. Does It Supplement Previous Oireetive(s)?
Y NO • I y«» What directive (number, tittt)
Yea Whit directive (number, tme)
No
TTOranievei
A - Signed by AA/DAA
B - Signed by Office Director
DC-
For Review & Comment
I - In Development
8.
Document
to
be
distributed
to
States by Headquarters? |Vj y«
No
This ReouMt MMU OSWER Directives System Format Standard*.
9. Signature of Leto Office Directives Coordinator
Betti C. VanEpps
Date
11/22/88
10. Name ana Title of Approving Official ;/
Jack W. McGraw, Deputy Assistant Administrator, OSWER
Date
9/29/88
EPA Form 1315-17 (Rev. 5-87} Previous coitions are oosoiett.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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OSWER DIR. # 9010.15-01
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
AUG I 6 1988
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
Off
ER Integrated Health and Safety Policy
SUBJECT:
FROM:
uty Assistant Administrator
ice of Solid Waste and Emergency Response
TO: OSWER Office Directors
OSWER Staff Directors
PURPOSE:
To implement the OSWER Integrated Health and Safety Policy.
BACKGROUND:
As you know, all EPA employees are required to comply with Occupational
Safety and Health Act (OSHA) Standards (e.g., 29 CFR 1910.1926), as well as
EPA's Occupational Health and Safety directives. EPA Order 1440 (Occupational
Health and Safety Manual) establishes the overall Agency health and safety
policy. EPA Order 1440.2 (Health and Safety Requirements for Employees
Engaged in Field Activities) requires all EPA field activity personnel to
receive the appropriate training certification prior to any field activity.
The OSWER Interim Integrated Health and Safety Policy, which became
effective August 12, 1988, after concurrence by all Office Directors, fulfills
the requirements of EPA Order 1440. Therefore, OSWER personnel whose job
functions require them to be involved with hazardous waste sites, emergency
spill activities, chemical process ing/storage)pi ants, and/or potentially
hazardous substances, are required to have the appropriate training certifi-
cation prior to engaging in field activities. Compliance with EPA Order
1440 and 29 CFR 1910.120 are mandatory, not voluntary.
OBJECTIVES;
In order to assure that we meet all OSHA and EPA requirements in a
timely fashion, the attached subject policy is based on information received
from the various offices, workgroup members and in-house occupational health
and safety expertise existing within the Environmental Response Team (ERT) in
Edison, NJ.
Jill SEP 2 9 1988
i
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OSWER DIRECTIVE # 9010.15-01
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IMPLEMENTATION:
To assist Branch Chiefs in their Employee Health and Safety record-
keeping responsibility, the ERT has established an OSWER Integrated Health
and Safety Data System to track compliance with training and medical surveillance
requirements. Please have your first line supervisors furnish the following
employee information for employees in OSWER categories No. 1 through No. 4 by
September 15, 1988 to:
Rodney D. Turpin
U.S. Environmental Protection Agency
Environmental Response Branch
Woodbridge Ave., Bldg. 10, (MS-101)
Edison, NJ 08837
FTS-340-6741
The employee information will be furnished to you on a regularly scheduled
basis as per your request. Thank you in advance for your assistance in
making the OSWER Integrated Health and Safety Program an effective and safe
one.
LAST NAME FIRST NAME OFFICE MAIL CODE CATEGORY
Attachment
cc: OSWER Division Directors
D. Weitzman (PM-273)
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OSWER DIR. # 9010.15-01
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
INTEGRATED HEALTH AND SAFETY POLICY
FOR
FIELD ACTIVITIES
ASSISTANT ADMINISTRATOR
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
401 M Street, NU
Washington DC 20460
May 15, 1988
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ABSTRACT
PURPOSE: The purpose of this document Is to establish an Integrated Health
and Safety Policy for all Office of Solid Waste and Emergency Response
(OSWER) Superfund Amendment Reauthorlzatlon Act field activity employees who
are engaged In hazardous substances or related activities.
BACKGROUND: The Environmental Protection Agency (EPA) 1s mandated by a
number of laws and regulations to safeguard the health and safety of Its
employees. While the Occupational Health and Safety Staff (OHSS), within
the Office of Administration and Resources Management's (OARM) Office of
Administration (OA), has overall responsibility for the development,
organization, and administration of EPA's Health and Safety Programs, the
responsibilities for establishing, Implementing, and enforcing an
Occupational Health and Safety Program have been delegated to Assistant
Administrators (AA) and Regional Administrators (RA) by the EPA Occupational
Health and Safety Manual (EPA Order 1440). Since OSWER has the
responsibility for developing and Implementing specific health, safety, and
training programs for its employees, this document 1s Intended to Inform the
field activity employee of his/her duties and responsibilities 1n regard to
specific health and safety policies, and to demonstrate OSWER's overall
commitment to the protection of its employees.
APPLICABILITY: This policy is effective for all OSWER field activity
employees who are either actively or potentially Involved in various
hazardous substances field activities (I.e., RCRA major corrective actions
and RCRA storage, treatment, and disposal facilities regulated under 40 CFR
parts 264 and 265; Hazardous Waste & Emergency Response; Chemical
Preparedness; Underground Storage Tanks; Solid Wastes; etc., and other field
activities Involving hazardous or potentially hazardous substances ).
Applicability of this policy also extends to persons who are not employed by
OSWER, but are either under a specific contract or otherwise under the
jurisdiction of OSWER.
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May 15, 1988
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CONTENTS
1.0 PURPOSE 1
2.0 OSWER POLICY 1
3.0 AUTHORITY 2
4.0 RESPONSIBILITY 2
4.1 ADMINISTRATIVE 2
4.2 TRAINING 3
4.3 MEDICAL SERVICES 3
4.4 OSWER INTEGRATED HEALTH
AND SAFETY PROGRAM 4
5.0 FIELD ACTIVITY CATEGORIES
AND PROCEDURES 4
5.1 DEFINITION OF CATEGORIES 4
5.2 CATEGORY REQUIREMENTS 6
5.3 STANDARD OPERATING GUIDELINES 7
6.0 MEDICAL BASELINE AND MONITORING PROGRAMS 9
7.0 TRAINING REQUIREMENTS 9
8.0 HAZARD COMMUNICATION/RIGHT-TO-KNOW 10
APPENDIX A OSWER INCIDENT SAFETY CHECK-OFF SHEET 12
APPENDIX B OSWER MEDICAL MONITORING REQUIREMENT 13
APPENDIX C SUMMARY OF THE OSWER HEALTH AND
SAFETY TRAINING REQUIREMENTS 14
APPENDIX 0 OSWER RESPIRATORY PROTECTION PROGRAM 15
APPENDIX E OSWER INTEGRATED HEALTH & SAFETY
WORK GROUP ORGANIZATIONAL CHART 22
APPENDIX F EPA HEALTH AND SAFETY REQUIREMENTS
AND GUIDELINES 23
APPENDIX G GENERAL DESCRIPTION OF THE OERR LEVELS
OF PROTECTION AND PROTECTIVE GEAR 24
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May 15, 1988
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1.0 PURPOSE
The purpose of this document Is to establish an Integrated Health and
Safety Policy for all OSWER employees who are presently, or who may
be engaged 1n the future field activities (e.g. hazardous substance
field activities and related activities Involving hazardous
chemicals/ substances).
1.1 Each OSWER employee Involved In field activities shall receive
appropriate training, equipment, and medical monitoring 1n
accordance with the U.S. EPA Occupational Health and Safety
Manual (Order 1440), U.S. EPA Orders 1440.2 and 1440.3, the
Office of Emergency and Remedial Response (OERR), Hazardous
Response Support Division Standard Operating Safety Guides, as
well as other appropriate Federal/State requirements and
guidelines such as 29 CFR 1910/1926.
1.2 Any extension of duty associated with hazardous substances or
other similar OSWER Held activities beyond the specific field
category to which a particular employee Is assigned or for which
he/she 1s specifically qualified by training and practical
experience 1s prohibited. No supervisor is authorized to order,
direct, or otherwise instruct an employee to enter a situation
that is more hazardous than that employee's field training
certification (e.g., Occupational Health and Safety Manual
[Chapter 7], EPA Order 1440.2 and 29 CFR 1910.120). Such an
assumption of duty by an employee involves the concomitant
assumption of all risks on the part of that individual should
the employee be specifically Informed that the assumption or
duty is beyond the scope of his/her training.
2.0 OSWER POLICY
2.1 All employees who participate in field activities must be
classified into field activity categories.
2.2 An employee must receive the required training and health
monitoring prior to performing field activities.
2.3 All organizations that have their own health and safety
programs, Including private contractors and other Federal, state
and local agencies, shall utilize and be responsible for the
administration of their Individual programs as long as these
programs are at least as stringent as the OSWER requirements and
OSHA standards.
2.4 EPA has delegated to the AA, OSWER, the Health and Safety
responsibility for OSWER employees. It Is OSWER policy that
contractors shall be responsible for Implementing the Office of
Emergency and Remedial Response (OERR) Standard Operating Safety
Guides (SOSG) for Its employees and operations, including
employee rights to know. In this regard, EPA at a minimum
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May 15, 1988
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requires that each contractor know and adhere to HRSO'S SOSG 29
CFR 1910.120, and 29 CFR 1910/1926. EPA has chosen to implement
this policy by allowing the contractor to design an Internal
health and safety program and to certify to EPA that the
company's program complies with the SOSG and 29 CFR 1910/1926.
Where a contractor's health and safety program differs from the
SOSG, the contractor must certify to EPA that his program is at
least as stringent as EPA requirements.
3.0 AUTHORITY
The authority for this program is derived from: U.S. EPA, OHSS,
Occupational Health and Safety Manual, U.S. EPA Order 1440, 1440.2,
and 1440.3, and all applicable Federal requirements.
4.0 RESPONSIBILITY
4.1 ADMINISTRATIVE
4.1.1 CATEGORIZATION - This order identifies four distinct
field activity categories into which employees are
assigned based upon their field training certification
classification (EPA Order 1440.2 and 29 CFR 1910.120)
and exposure potential. The categories are defined and
outlined In Section S.O. (Procedures and Duty
Categories) of this document.
4.1.2 Office Directors are delegated the authority and
responsibility to implement and enforce this policy. To
ensure a truly integrated/coordinated program, each
Office Director is required to assign at least one
occupational and safety health person to serve as
liaison on the OSWER Integrated Health and Safety
Workgroup chaired by the Environmental Response Team
(ERT), Edison, N.J.
4.1.3 Division Directors are delegated the authority to
Identify each field activity position 1n their
Divisions.
Budgeting of funds for safety training and for the
purchase, maintenance and storage of employee safety
equipment Is the responsibility of the Division
Director.
4.1.4 Branch Chiefs are responsible for assigning field
activity categories to Section Chiefs/first line
supervisors.
The Branch Chiefs are also responsible for maintaining
Employee Safety and Training Records, which contain all
safety-related matters.
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May 15, 1988
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4.1.5 Section Chiefs/first line supervisors are responsible
for assigning field activity categories to an individual
employee. Each employee shall be provided with a
complete description of the field activity categories.
The Section Chief or designee 1s responsible for
purchasing, issuing, and training his/her personnel
concerning any phase of respiratory protection.
4.1.6 Employee must read and fully understand the OSWER policy
and sign a statement attesting to that fact.
4.1.7 OSWER Integrated Health and Safety Workgroup will
coordinate the implementation and maintenance of this
policy. The Workgroup representative is the focal point
for coordinating the office's activities with regard to
OSWER employee occupational health and safety
activities.
4.2 TRAINING
4.2.1 The development, implementation, and maintenance of
safety training programs shall be the highest OSWER
training priority. The AA, OSWER, or designee, is
ultimately responsible for ensuring that all OSWER
employees and contractors receive the appropriate safety
equipment and training or equivalent in accordance with
U.S. EPA Orders (e.g., 1440, 1440.2, 1440.3) and 29 CFR
1910/1926.
4.2.2 The responsibility for ensuring that all employees
receive the appropriate mandatory safety training is
shared jointly by the OSWER Office Directors, Division
Directors, Branch Chiefs, Section Chiefs/first line
supervisors, and employee.
4.2.3 All supervisors equivalent to or lower than Section
Chiefs in charge of field activity employees should
receive commensurate safety training In all applicable
field safety categories.
4.3 MEDICAL SERVICES
4.3.1 The AA, OSWER, (or designee) Is ultimately responsible
for ensuring that all field activity employees actively
participate in a Medical Monitoring Program (See
Appendix B).
4.3.2 It Is the employee's responsibility to seek medical
assistance and advise his/her supervisor In the event of
exposure or potential exposure to a contaminant. In
addition, the employee must report all accidents/
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May 15, 1988
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exposure to his supervisor so the required workers'
compensation form can be carried to the medical
provider.
4.3.3 If an emergency exists, the employee must contact the
supervisor and complete the necessary forms as soon as
possible (see EPA Occupational Health and Safety Manual,
Order 1440, Chapter 3).
4.4 OSWER INTEGRATED HEALTH AND SAFETY PROGRAM
The Agency's Occupational Health and Safety Manual (EPA ORDER
1440), particularly Chapter 9, establishes occupational health
and safety policy and requirements, and assigns responsibilities
for EPA employees engaged in hazardous substance field
activities. In order to meet these requirements, the
Environmental Response Team (ERT), Edison, NJ has been delegated
the responsibility to manage the OSWER Integrated Health and
Safety Program. The primary objective of the program is to
ensure that all aspects of the safety and occupational health
requirements are met in a timely fashion to afford each employee
proper protection.
5.0 FIELD ACTIVITY CATEGORIES AND PROCEDURES
5.1 DEFINITION OF CATEGORIES
In order to meet the specific needs of the individual OSWER
employees, this policy requires additional administrative
controls over those of EPA Orders 1440.2 and 1440.3. The
administrative control 1s a further restriction to EPA Order
1440.2 "Basic, Intermediate and Advanced* training
certification, and 1s accomplished by assigning Categories No.
1-4 to the appropriate field activity personnel. Because of
these additional administrative controls, Categories 2 and 3
employees are exempt from the EPA Order 1440.2 requirement of
three days of on-the-job training within three months of
classroom training unless requested by the employee. However,
when applicable, they are still required to meet the three days
of on-the-job training.
The employee's category assignment may be changed by the first
line supervisor via written notification to the Manager, OSWER
Integrated Health and Safety Program, U.S. EPA-ERT, (Mail Code
MS101) Rarltan Depot, Bldg. 10, Hoodbridge Ave., Edison, NJ
08837 (FTS 340-6740). This notification consists of Identifying
the employee's necessary change(s) and verifying that the
appropriate training, equipment, and medical examination have
been provided to the employee for the reclasslflcatlon.
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5.1.1 Category 1 is established as the OSWER highest risk
category. This category Includes all employees whose
job description/critical job elements require handling
of, or potential exposure to, Identified or unidentified
hazardous chemicals. For example, employees responding
to spill emergencies, uncontrolled hazardous waste
sites, etc. (I.e., ERT personnel) are 1n this category.
These employees are authorized to wear OERR Levels of
Personnel Protective Equipment A, B, C, and 0. Medical
examinations are given every six months. See Appendix G
for details.
5.1.2 Category 2 Includes those OSViER personnel who are
required to enter the "Exclusion Zone" or a facility's
"Treatment/Storage Activity Area* where there 1s the
potential of exposure to identified or unidentified
hazardous chemicals, for more than approximately 20
days per calendar year1. Sampling and corrective
action activities are some examples of the job
function. These employees are authorized to wear OERR
Levels of Personnel Protective Equipment C and D, and
receive Medical Examinations annually. (Those employees
that will only engage in RCRA activities will receive a
Category 2A Listing.) See Appendix G for details.
5.1.3 Category 3 includes those OSWER personnel who are
required to enter the "Exclusion Zone" or a facility's
"Treatment/Storage Activity Area" where there is the
potential of exposure to identified or unidentified
hazardous chemicals situations, etc., for less than
approximately 20 days per calendar year1. Sampling
and corrective action activities are some examples of
the job function. (Those employees that will only
engage in RCRA activities will receive a Category 3A
Listing.) See Appendix G for details.
Medical examinations are scheduled based on the
employee's number/frequency of hours of potential
exposure. This period may range from 1-4 years. These
employees are authorized to wear OERR Levels of
Personnel Protective Equipment C and D. See Appendix G
for details.
5.1.4 Category 4 Includes all other OSWER field activity
personnel not specifically addressed 1n Categories 1-3,
but who are required to perform his/her job function In
a "Secure/Clean Area" of those activities Identified in
Categories 1 through 3. These employees are not
authorized to wear OERR Levels of Personnel Protective
Equipment.
1 The period of potential exposure of greater than or less than 20 days
1s derived from the 30-day standard 1n 29 CFR 1910.120 and may be modified
as appropriate per supervisor and employee agreement.
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May 15, 1988
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Examples of this type of employee are: Certain
operations conducted under RCRA as described In 29 CFR
1910.120(0); employees and supervisors who perform
activities in the "Support Zone" at hazardous waste site
emergency spills.
5.2 CATEGORY REQUIREMENTS
This section of the OSWER policy provides a basic framework for
the safe conduct of Category 1-4 personnel while being directly
or indirectly involved in a hazardous substance activity.
5.2.1 OSWER field activity personnel must be aware, 1n
advance, of the objectives of each site visit and must
be prepared to employ safe operations to avoid potential
hazards. Each employee 1s required to enforce and
comply with this policy and exercise good personal
judgement and technical expertise on a case-by-case
basis.
5.2.2 Whenever applicable, OSWER field activity personnel are
required to implement the OERR, HRSD, Standard Operating
Safety Guides for guidance and selection criteria.
OSWER personnel must exercise extreme caution to prevent
loss of life, injury, or health hazards to themselves
and to the general public. OSWER field activity
personnel are required to adhere to this policy whether
or not the Regional requirements are as specific as this
policy.
5.2.3 In the event of conflicting safety regulations, the
employee must implement those safety practices affording
the highest level of protection 'for everyone involved.
5.2.3.1 Qualifications
To be eligible to perform Category 1-3 duties,
the employee must:
a) be assigned to the on-s1te work by his/her
supervisor;
b) complete a Baseline Medical Examination and
participate in a medical monitoring
program;
c) complete the appropriate health and safety
training program as per U.S. EPA Order
1440.2, 1440.3, and 29 CFR 1910.120 prior
to Involvement In field activities, and/or
other types of similar field activities;
d) be assigned the appropriate Field Activity
Category.
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May 15, 1988
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5.3 STANDARD OPERATING GUIDELINES
5.3.1 Pre-arr1val Planning
In planning a field activity, it is the employee's
responsibility to be aware of the purpose of the field
activity and comply with the OSWER Integrated Health and
Safety Policy, OHSS Occupational Health & Safety Orders,
29 CFR 1910.120, and all applicable requirements.
5.3.1.1 PRIOR to arrival at a field activity location,
the employee shall complete Part One of the
OSWER Incident Safety Check Sheet (refer to
Appendix A) and furnish it to the first line
supervisor or designee for review. It is
recognized that lead time and availability of
information are usually limited; however, the
employee must attempt to complete this form
(preferably prior to office departure). If any
emergency arises, it is recommended that, the
employee and his/her supervisor contact the
Environmental Response Branch's Edison, NO
Hotline (201-321-6660) for technical
assistance.
5.3.1.2 When Applicable, Site Safety Plans shall be
completed and submitted in accordance with 29
CFR 1910.120, OHSS, Occupational Health and
Safety Manual, and OERR, HRSO, Standard
Operating Safety Guides.
5.3.2 Safety OnsHe (When Applicable)
OSWER personnel shall implement on-site evaluation and
inspection in accordance with the OERR, HRSD, Standard
Operating Safety Guides.
5.3.2.1 The buddy system shall be utilized 1n the
field; OSWER field personnel shall not enter an
"Exclusion Area" or a RCRA hazardous waste TSD,
etc., alone. Employees shall make use of their
practical experience and technical expertise to
keep alert to potentially dangerous
situations. Guidance for these types of
precautionary measures and procedures 1s
provided In the OERR, HRSD, Standard Operating
Safety Guides and other state-of-the-art
technology documents.
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Hay 15, 1988
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5.3.2.2 If any condition suggestive of a situation more
hazardous than anticipated is discovered, all
field activity shall temporarily stop for a
revaluation of the hazard and the level of
protection required.
5.3.2.3 In the event that an OSHER field activity
employee experiences any adverse effects or
symptoms of exposure while engaged in field
activities, he/she must immediately leave the
site/area, and contact the site/facility
supervisor {OSC, etc.), and seek appropriate
medical attention. Such incidents must be
reported in accordance with Chapter 3 of the
EPA Occupational Health and Safety Manual (EPA
Order 1440).
5.4 Personnel Protection
If OSWER personnel are required to enter any area in which there
is a risk of potential exposure or in which respiratory
protection is needed, e.g., a hazardous site/spill exclusion
zone, RCRA storage facility, manufacturers production area,
etc., they are required to adhere to this Integrated Health and
Safety Policy whether or not the Regions have a policy or a
specific site safety plan. Employees are required to refer to
the OERR, HRSD, Standard Operating Safety Guides for a detailed
description of the levels of protection and selection criteria.
5.5 Site Departure and Decontamination Procedures
Disposable safety clothing and sampling equipment shall be
properly disposed. If appropriate disposal facilities are not
available, safety clothing, and sampling equipment shall be
placed in a suitable container pending proper disposal.
.Nondisposable safety clothing and sampling equipment shall be
decontaminated (preferably on-s1te) 1n accordance with the OERR,
HRSD, Standard Operating Safety Guides. In the event that the
adequacy of these procedures 1s questionable, nondisposable
equipment shall be placed in appropriate containers until the
exact nature of the sampled material 1s known. Suitable
decontamination procedures shall then be employed to clean the
equipment, or the equipment shall be properly disposed of at an
approved RCRA hazardous waste facility that meets the
requirements of the EPA offslte policy (OSWER Directive 9834.11)
and EPA Land Disposal Restrictions (RCRA sections 268.30 and
268.32).
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Nay 15, 1988
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6.0 MEDICAL BASELINE AND MONITORING PROGRAMS
Based on their field exposure classification, OSWER field activity
employees shall undergo routinely scheduled examinations to determine
the possible health effects of such activity. A medical baseline
health profile shall be established for this purpose. As a minimum,
the OSWER medical monitoring program shall consist of OHSS guidelines
and requirements. In general, the medical monitoring program shall
be apportioned into three classes on the basis of employee field
activities and potential exposure. In addition, OSWER field activity
personnel shall Immediately receive post-exposure medical/treatment
examinations upon notifying their Section Chief(s) of an exposure. A
tabular summary of the OSWER Medical Monitoring Requirements
according to Field Activity Category 1s Included In Appendix B of
this document.
7.0 TRAINING
An adequate training program is essential for proper Implementation
of this Integrated Health and Safety Policy. The complexities of the
topics of interest, the variety of courses offered, and the need for
specific training within each category necessitates formulation of
certain ground rules.
7.1 Each OSWER field activity employee shall receive safety training
commensurate with the job requirements and field exposure
classification. First line supervisors shall recommend
additional safety training courses for an employee's future
needs.
7.2 A series of core topics are designated for each category as
tabulated In the Summary of the OSWER Health and Safety Training
Requirements (Appendix C). These core topics are mandatory of
all OSWER Field Activities Category Employees. The other topics
identified as "desirable" should be taken by employees based
upon the recommendations of their supervisors. The level of
training provided shall be consistent with the employee's job
function and responsibilities. Supervisors are responsible for
insuring that their employees are properly trained.
7.3 The training plans and programs must remain flexible enough to
Include/delete any additional/obsolete topics as the need arises
or new Ideas are Introduced. As per EPA Order 1440.2 and 29 CFR
1910.120, 8 hours of refresher training are required annually of
most OSWER field activity personnel.
7.4 Training hour requirements vary on the specific field activity.
The following summarizes the 29 CFR 1910.120 training
requirements as It relates to the OSWER Field Activity
Categories:
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May 15, 1988
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Category 1: Forty hours of training, plus 3 days of actual
field experience under the direct supervision of a trained,
experienced supervisor. (Field supervisor in this category will
be required to have an additional 8 hours of "Supervisor
Training.") All employees shall receive 8 hours of refresher
training annually.
Category 2: Hazardous waste site and corrective action site
workers are required to have the same as Category 1 (above).
All other Category 2 personnel that do not enter an Exclusion
Zone or equivalent area, may qualify for 29 CFR 1910.120(0)
training requirements of 24 hours initial training and 8 hours
refresher training annually.
Category 3: Hazardous waste site and corrective action site
workers are required to have the same as Category 1 (above).
All other Category 3 personnel that do not enter an Exclusion
Zone or equivalent area, may qualify for 29 CFR 1910.120(0)
training requirements of 24 hours Initial training and 8 hours
refresher training annually.
Category 4: Although not required by 29 CFR 1910.120, all
Category 4 employees are required to have a minimum of 4 hours
of training In those areas Identified in Appendix C.
8.0 HAZARD COMMUNICATION/RIGHT-TO-KNOH
8.1 The EPA is required to communicate the hazards associated with
the workplace to all EPA employees. EPA Order 1440.7, Hazard
Communication, requires that employees be given information and
training on hazardous substances in their work areas.
8.2 It 1s EPA policy that 1t will extend the hazardous
communicatlon/rlght-to-know requirement to its contractors or
contractor representatives. At a minimum, OSWER employees and
contractors and their representatives must be Informed of the
physical and health hazards of known substances in the work
area, methods to detect hazardous substances, and measures
employees can take to protect themselves from the hazards. In
the case of OSWER employees, the hazardous substances are often
unknown.
8.3 All parties working together at hazardous waste sites or spill
emergencies/accidents must share all available information on
the possible hazards Involved.
8.4 As part of the hazard communication, employees are to be
Informed of the threat to human reproduction by chemicals In the
workplace. OSWER employees (both male and female) who are
potentially exposed to chemicals that affect reproduction, such
as teratogens, mutagens, and chemicals that alter fertility,
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May IS, 1988
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have the right to request a temporary change 1n job assignment
as needed to allow conception or to protect an unborn child.
Each request will be handled on an Individual basis. For each
equest the supervisor has the responsibility to assess the
eproductlve hazards associated with the job and to make
easonable accommodations of equal professional status.
•11-
Hay 15, 1988
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Appendix A
OSHER INCIDENT SAFETY CHECK-OFF LIST
I. BEFORE FIELD ACTIVITY Employee
1. Incident: Site City State.
a. Response Dates.
2. Activity Description: Environmental Sampling Product Sampling.
Residential Site Evaluation Containment Hell Drilling^
Facility Inspection
3. Type of Response: Spill Site Facility Other
4. Site Topography: Mountains Rivers Valley Rural.
Suburban Urban Level Slopes
Facility
5. Incident Safety Plan: Not Developed Reviewed
(when applicable) Region Briefed
ERT
Site Accessibility: Road: Good A1r: Good.
(when applicable) Fair Fair.
Poor Poor
7. Suspected chemical(s) and pathway with source(s) Involved: (A)
(B) (C) (D).
8. Emergency Response Teams present for First Aid, etc. Yes No
9. Protective Level(s) Selected: (A) (B) (C) (D)
(a) If Level "C," Identify Canister
If Level "D," JUSTIFY: write in comments section at bottom of page
10. If SCBA, Identify Buddy System: Office/Name.
11. Last Response: (a) Level Used: (A) (B) (C) (D)
(b) Medical Attention/Exam Performed: Yes No.
II. AFTER RESPONSE
1. Protective Level Used: (A) (B) (C) (D)
a. Level "C," Identify canister: b. Level "D" (comment below)
c. Level B/C skin protection: Tyvek Tyvek/$aran_ Ac1d/Ra1n__
Other
2. List possible chemical exposure: Same as above: (A)
(B) (C) (D).
3. Equipment Decontamination: (a) clothing (b) respirator (c) monitoring
Cleaned: . ,
No Action:
i. Approximate time In exclusion area:. _ hr/day for .
PART I: Date Prepared Reviewed bv
PART II: Date Prepared Reviewed bv
-12-
davs
Date
Date
May 15, 1988
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APPENDIX B
SUMMARY OF OSWER MEDICAL MONITORING REQUIREMENTS
PER EMPLOYEE CATEGORY
EMPLOYEE
CATEGORY
1
2
3
4
Examination
Class*
N/A
Base line plus
Medical
Monitoring
Exam every
6 months
Base line
Annual
Medical
Monitoring
Exam
plus
Base line plus
periodic medi-
cal monitoring
exam based on
potential exp-
osure freq.
(avg 1-4 yr)
* Examination rate may Increase with Increasing Incidence of exposure.
NOTE: A "calendar year" 1s a somewhat arbitrary term when discussing a
measurement of exposure. For example, 8 one-day visits to a site
where the exposure 1s great or the toxidty 1s high may be more
critical to the health of the indlvidua.1 than 19 visits at another
site. Therefore, all factors must be considered when selecting the
Medical Monitoring Exam schedule.
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May 15, 1988
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APPENDIX C
SUMMRY OF THE OSWER HEALTH AND SAFETY TRAIN1NC COURSE REQUttEKNTS
OERR
Levels
Cate- of Pro- EPA Order OSUER Policy OERR Standard Operating Properties of
gory tection 1U0.2 Clessif(cation Document Safety Guides Hazardous Ntt*. Toxicology
1 A.I.C Aitvwv* XX X
2 C Inttrmdl«tt/lMfe XXX
3 C Intermdiatt/Mtic XX X
4 NONE N/A X X N/A
X
X
X
N/A
Enplcytt
Rights «*
C«t«- Basic Off let BMfc Field Protective Respiratory Decontamination Entry Respontl-
gory First Aid First Aid CPR Clothing Protection Procedure* Procedure* bllities
10 XOXX X XX
r
20 XOXX X XX
30 XOXX X XX
4 0 0 0 H/A M/A H/A H/A X
Defensive
Driving
X
X
X
X
Key: X • Hardstory, Core Topfc*
0 • Desirable, tot Net Mndatory
N/A • Net Applicable
* • Cardiopuiwnery Resuscitation
-14-
Hay 15, 1988
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APPENDIX 0
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised March 1988)
I. Purpose
The Office of Solid Waste and Emergency Response (OSWER) respiratory
protection program 1s Intended to control exposures to those agents
that may cause occupational diseases when air Is contaminated with
harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors.
II. Objective
Respiratory protection may be properly worn when effective
engineering control methods are not feasible, while they are being
implemented, or in emergencies. Generally, most corrective actions
do not lend themselves to effective engineering controls.
Therefore, respiratory protection 1s judged to be the best approach
to ensure employee health protection. It 1s important to note,
however, that effective work practices can minimize reliance on such
devices. The primary objective of this program is to protect the
employee against "potential" exposure as well as measured exposure.
HI. Scope
This respiratory protection program 1s intended to address all OSWER
field activity employees.
IV. Responsibility
It is the responsibility of Section Chiefs/first line supervisors to
administer this program in close liaison with medical monitoring
personnel. Supervisors are required to provide both the appropriate
training and respiratory protection employees need, at no cost to
the employee.
Employees shall use the respiratory protection provided 1n
accordance with Instructions and training received. Each employee
shall guard against damage to the respirator, and report any
respirator malfunctions to the supervisor.
V. Program Elements
A. The OSWER respiratory protection program meets all provisions of
29 CFR 1910.134 and 29 CFR 1910.120. In addition, it meets all
EPA, OHSS's Occupational Health and Safety requirements and the
OERR's, HRSD Standard Operating Safety Guides.
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May IS, 1988
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B. Program Elements
1. Standard Operating Procedures. This respiratory protection
program shall function as the written standard operating
procedures governing the selection and use of respiratory
protection for OSWER personnel.
2. Respirator Fitting and Selection
a. The selection of the proper type of respiratory
protection shall be based primarily on, but not limited
to the:
1) Nature of the field activity;
2) Type of respiratory hazard;
3) Location of the hazardous area;
4) Period of time for which respiratory protection must
be provided;
5) Employee's potential exposure;
6) Employee's activities;
7) Employee's physical characteristics and functional
activities;
8) Limitations of the various types of respirators; and
9) Respirator protection factors/respirator fit.
b. Factors concerning both the potential and the measured
hazard shall be considered when requiring the use of
respiratory protection. These factors shall Include,
but not be limited to:
1) Types of hazard;
2) Physical and chemical properties;
3) Physiological effects on the-body;
4) Expected concentration/level;
5) Established ACGIH TLV's, OSHA PEL'S, AIHA WEEL's.
6) IDLH considerations; and
7) Agent warning properties.
c. U.S. EPA Environmental Response Team's (ERT) Air
Monitoring Guidelines (FSOP 18) shall be followed, when
applicable, to Identify the type of respiratory hazards,
define their nature and potential (I.e., vapor,
partIculate, etc.), and determine the concentration in
the work area.
d. Factors concerning potential and actual site activities
shall be taken Into account 1n selecting proper
respiratory protection. These factors Include a
description of work activities; description of the
potential hazards; agents of health concern, employee
exposure potential and work activities. The selected
respirator protection must be continuously evaluated to
reflect changes 1n conditions or factors.
-16-
May IS, 1988
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e. The work activity location, with respect to a safe/clean
area, shall be considered in selecting respirator
protection. Not only does this permit for a well
Identified contamination reduction zone, but also
requires the presence of emergency access and exit
areas.
f. The period of time a respirator is to be worn shall be
considered when selecting respiratory protection.
g. Worker activities and locations during site activities
shall be considered when selecting proper respiratory
protection.
h. The physical characteristics, functional capabilities,
and performance limitations of various types of
respiratory protection shall be considered when
selecting a respirator.
1. The hazards for which a particular respirator is
designed shall be considered when selecting a
respirator.
j. A qualitative respirator fit test shall be performed on
each user to determine a satisfactory fit with negative
pressure respirators. Test results shall be used to
select specific types, makes, and models for Individual
workers. All OSWER Category 1 and 2 employees will be
fit tested at least annually. Category 3 personnel will
be fit tested before each respirator use after the
initial testing. Fit testing is not required for
positive pressure respirators (e.g., SCBA units).
Individual workers shall be trained to qualitatively
check respirator fit via the positive-negative pressure
method each time a unit 1s donned. Whenever possible, a
quantitative fit test shall be incorporated.
k. Respirators shall not be worn when conditions prevent a
good seal. Employees shall not wear respirator temple
bars, straps, head coverings, etc. between the sealing
surface of the respirator. Neither shall respirators be
worn if facial hair, features, etc., prevent a good fit.
1. Respirator fit testing records shall be kept. Records
shall Include type of fit-test method used, specific
make and model of respirator tested, name of worker
tested, name of test operator, date of test, and results
of fit testing.
m. A variety of sizes of respirator facepieces shall be
available to OSWER personnel to accommodate the wide
range of facial shapes and dimensions among personnel.
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Hay 15, 1988
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e. The work activity location, with respect to a safe/clean
area, shall be considered in selecting respirator
protection. Not only does this permit for a well
identified contamination reduction zone, but also
requires the presence of emergency access and exit
areas.
f. The period of time a respirator 1s to be worn shall be
considered when selecting respiratory protection.
g. Worker activities and locations during site activities
shall be considered when selecting proper respiratory
protection.
h. The physical characteristics, functional capabilities,
and performance limitations of various types of
respiratory protection shall be considered when
selecting a respirator.
1. The hazards for which a particular respirator 1s
designed shall be considered when selecting a
respirator.
j. A qualitative respirator fit test shall be performed on
each user to determine a satisfactory fit with negative
pressure respirators. Test results shall be used to
select specific types, makes, and models for individual
workers. All OSWER Category 1 and 2 employees will be
fit tested at least annually. Category 3 personnel will
be fit tested before each respirator use after the
initial testing. Fit testing Is not required for
positive pressure respirators (e.g., SCBA units).
Individual workers shall be trained to qualitatively
check respirator fit via the positive-negative pressure
method each time a unit 1s donned. Whenever possible, a
quantitative fit test shall be Incorporated.
k. Respirators shall not be worn when conditions prevent a
good seal. Employees shall not wear respirator temple
bars, straps, head coverings, etc. between the sealing
surface of the respirator. Neither shall respirators be
worn If facial hair, features, etc., prevent a good fit.
1. Respirator fit testing records shall be kept. Records
shall Include type of fit-test method used, specific
make and model of respirator tested, nane of worker
tested, name of test operator, date of test, and results
of fit testing.
m. A variety of sizes of respirator facepleces shall be
available to OSWER personnel to accommodate the wide
range of facial shapes and dimensions among personnel.
-17-
Nay 15, 1988
-------
n. Employee preference for a particular respirator model
shall be considered when selecting suitable respiratory
protection. This Includes such factors such as comfort,
breathing resistance, weight, field of vision, etc.
However, the preferred model must have a satisfactory
fit test.
o. Where feasible, respirators shall be Individually
assigned to workers for their exclusive use. If a
respirator 1s marked for Identification purposes, the
marking shall not affect the respirator performance.
3. Training and Education
a. Each respirator wearer shall be given training that
shall Include explanations and discussions of
respiratory hazards and misuse; the need for respiratory
protection; the reason for selecting a particular
respirator; the function, capabilities, and limitations
of the selected respirator; the method for donning the
respirator and checking Us fit and operation; proper
wearing instructions; respirator maintenance;
recognizing and handling emergencies; special
instructions as required; regulations concerning
respirator use; and identification of respirator
cartridges and canisters by color code.
b. The training shall include a hands-on portion that
covers donning, wearing, and removing the respirator;
adjusting the respirator for proper fit; wearing the
respirator in a safe atmosphere and in a test
atmosphere.
c. The Section Chief or designee 1s responsible for
purchasing, issuing, and training his/her personnel
concerning any phase of respiratory protection.
d. Trainers, employees, and others associated with the
respiratory protection program shall be trained to
ensure the proper use of respirators. Training shall
Include basic respiratory protection practices, the
nature and extent of expected respiratory hazard
exposure, principles and criteria for selecting
respirators, using respirators and monitoring their use,
maintenance and storage, and regulations governing
respirator use.
e. Etch respirator wearer shall be retrained and fit tested
at least annually or as appropriate (e.g.,after large
changes in body weight, dental surgery, etc.) when
facial size or shape significantly changes (see
Paragraph V.B.2.J).
-18-
May 15, 1988
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4. Cleaning and Disinfecting
a. Respirators shall be regularly cleaned and disinfected.
Those issued for the exclusive use of one worker should
be cleaned after each day's use, or more often If
necessary. Those used by more than one worker shall be
thoroughly cleaned and disinfected after each use (e.g.,
routine, non-routine, emergency, or rescue units).
5. Equipment Storage
a. Respirators shall be stored in a convenient, clean, and
sanitary location so that they are protected against
dust, sunlight, extreme temperature, excessive moisture,
or damaging chemicals.
b. Respirators shall be stored to prevent distortion of
rubber or other elastomeric parts. Respirators shall
not be stored in such places as lockers and tool boxes
unless they are adequately protected from contamination,
distortion, and damage. Consult the "use and care"
instructions, usually mounted Inside the carrying case
lid, for proper storage of emergency respirators.
6. Inspection and Repair
a. Each respirator shall be inspected routinely before and
after each use. A respirator shall be Inspected by the
user Immediately before each use to ensure that It is in
proper working condition.
b. After cleaning and sanitizing, each respirator shall be
inspected to determine if it is in proper working
condition, if it needs replacement parts or repairs, or
if it should be discarded. Each respirator stored for
emergency or rescue use shall be Inspected at least
monthly and after each use by an experienced person.
Respirator Inspection shall Include a check for
tightness of connections; for the conditions of the
respiratory Inlet covering, head harness* valves,
connecting tubes, harness assembly, filter(s),
cartridges, canister, end-of-service-life Indicator, and
shelf life date(s); and for the proper function of
regulators, alarms, and other warning systems.
c. Each rubber or elastomeric part shall be Inspected for
pliability and signs of deterioration. Each air and
oxygen cylinder shall be Inspected to ensure that It Is
fully charged according to the manufacturer's
Instructions.
-19-
May 15, 1988
-------
d. Only parts designed for a specific respirator shall be
used in its repair. Do not replace components or make
adjustments or repairs beyond the manufacturer's
recommendations. Reducing and admission valves or
regulators shall be returned to.the manufacturer or to a
trained technician for adjustment or repair.
e. A record of inspection dates, findings, and remedial
actions shall be kept for each SCBA respirator
maintained for emergency or rescue use.
7, Surveillance
Appropriate surveillance or work area conditions and degree
of employee exposure or stress shall be maintained.
8. Evaluation of Respiratory Protection Program
a. There shall be periodic (at least annual) inspection and
evaluation to determine the continued effectiveness of
the respiratory protection program. It 1s essential to
ensure that all employees are provided with adequate
protection. The program should be Improved and
deficiencies should be eliminated based on evaluation
results.
b. Respirator wearers shall be consulted periodically about
their acceptance of respirators. Frequent Inspection of
the program shall be conducted to ensure that proper
types of respirators are selected, that users are
properly trained, that appropriate equipment is issued
and used, that respirators are worn properly, that
respirators are in good operating condition, that
respirators are inspected and maintained properly, that
respiratory storage 1s acceptable, that respiratory
hazards are monitored, and medical examinations are
given as necessary, to evaluate user health.
c. The results of the Inspection and evaluation shall be
utilized to Improve or maintain elements of the program
as appropriate. Follow up Investigations shall be
conducted to ensure that sources of concerns are
Identified and corrected. Evaluation findings shall be
documented. Plans to correct program concerns shall be
documented (I.e., problem, target dates, responsibility,
etc.).
9. Medical Approval
a. Each employee shall have a medical evaluation to
determine fitness to wear respiratory protection and
potential exposure. Adequate medical data shall be
provided as part of the preplaceroent examination and all
-20-
Hay 15, 1988
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subsequent examinations to allow a physician to make a
judgement on each worker's fitness (Refer to Appendix B
of the Integrated Health and Safety Policy for Field
Activities for examination schedule).
b. Employees shall show the examining physician their
exposure records (e.g., Incident Safety Check-off Sheet
[See Appendix A of the Integrated Health and Safety
Policy for Field Activities]) since the last
examination.
10. Approved Respiratory Protection
Only approved respiratory protection shall be selected when
available. Any modification of an approved respirator that
is not authorized by the approval agencies (e.g., HSHA and
NIOSH) voids the respirator approval.
VI. Air Quality
A. Compressed air, compressed oxygen, liquid air, and liquid oxygen
used for respiratory protection shall be of high purity.
Compressed air should be the principle source of breathing air.
Compressed gaseous air shall meet at least the requirements for
Type 1 - Grade D breathing air of Compress Gas Association
Commodity Specification G-7.1-1966.
B. Breathing air should be supplied to respirators from cylinders.
11 cylinders shall be tested for quality and maintained in
accordance with applicable DOT specifications for shipping
containers (Title 4-9, Code of Federal Regulations, Parts 173
and 178).
C. Breathing air containers shall be marked in accordance with ANSI
Z48.1-1954 (R1971) or Interim Federal Specification GG-B-675b,
September 23, 1976.
-21-
May 15, 1988
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Appendix E
OSWER INTEGRATED HEALTH AND SAFETY WORKGROUP
Rodney 0. Turpln
Occupational Health and Safety Manager
Environmental Response Team
Edison, NJ 08837
FTS: 340-6741 - COMM; 201 321-6741
OCCUPATIONAL HEALTH AND SAFETY STAFF
Sheldon Rabinovitz
FTS: 382-3649 - MAIL CODE: PM 273F
David Weitzman (Alt.)
FTS: 382-3640 - MAIL CODE: PM 273F
OFFICE OF WASTE PROGRAMS ENFORCEMENT
Charlotte White
FTS: 382-4846 - MAIL CODE: WH 527
Rolf Hill (Alt.)
FTS: 475-7037 - MAIL CODE: WH 527
Steve Henne (Alt.)
FTS: 475-7030 - MAIL CODE: WH 527
fOFFICE OF EMERGENCY AND RFMFDTAL RFSPONSF
OSWER - ANALYSIS & EVALUATION STAFF
Kate Connors
FTS: 382-6647 - MAIL CODE: WH 562A
Jim Cruickshank
FTS: 475-4515 - MAIL CODE; WH 562A
OSWER - PREPAREDNESS STAFF
Elaine Davies
FTS: 475-8600 - MAIL CODE: WH 562A
OFFICE OF UNDERGROUND STORAGE TANKS
John Heffel finger
FTS; 382-7950 - MAIL CODE: WH 565A
OFFICE OF SOLID WASTE
Jim O'leary
FTS: 382-4649 - MAIL CODE: WH562
Cynthia Folkerts
FTS: 382-7917 - MAIL CODE: WH 565A
HAZARDOUS SITE CONTROL!
DIVISION
John J. Smith
FTS: 382-7996
MAIL CODE: WH 548E
Nancy Willis (Alt.)
FTS: 382-2347
MAIL CODE: WH 548E
EMERGENCY RESPONSE
DIVISION
Victoria van Roden
FTS: 382-2188
_MA1LCQDE: WH 5488
HAZARDOUS SITE EVALUATION
DIVISION
Robert Heffernan
FTS: 475-9748 - MAIL CODE: WH548A
Scott Fredericks (Alt.)
FTS; 382-2467 - MAIL CODE: WH548A
ENVIRONMENTAL RESPONSE
TEAM
Vickie L. Santoro
FTS: 340-6917
MAIL CODE: MS101
-22-
May 15, 1988
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APPENDIX F
EPA HEALTH AND SAFETY REQUIREMENTS AND GUIDELINE
1. EPA Occupational Health and Safety Manual (1440)
Chapter 1. Policy and Responsibilities
Chapter 2. Occupational Health and Safety Program
Administration
Chapter 3. Accident and Illness Investigation, Reporting,
and Recordkeeplng Requirements
Chapter 4. Inspections and Correction of Unhealthful or
Unsafe Working Conditions
Chapter 5. Occupational Health and Safety Committees
Chapter 6. Occupational Health and Safety Standards
Chapter 7. Occupational Health and Safety Training
Chapter 8. Laboratory Use of Toxic Substances
Chapter 9. Hazardous Substances Responses
Chapter 10. EPA Diving Safety Policy
2. EPA Health and Safety Orders
1440.2 - Field Activities
1440.3 - Respiratory Protection
1440.4 • Health and Safety Training Requirements for Mine
Safety
1440.5 - Qualifications and Training Requirements for
Occupational Health and Safety Program Personnel
1440.6 • Motor Vehicle Occupant Restraining Systems
1440.7 - Hazard Communication
3. Health and Safety Guidelines
Respiratory Protection Program Guideline
Eye Protection Program Guidelines
Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities
Medical Monitoring Program Guidelines
Health and Safety Guidelines for EPA Asbestos Inspections
Guidelines for the Selection of Chemical Protective
Clothing, Second Edition
-23-
May 15, 1988
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APPENDIX G
GENERAL DESCRIPTION OF THE OERR LEVELS OF PROTECTION AND PROTECTIVE GEAR
Personal protective equipment has been divided into four categories based
on the degree of protection afforded and are as follows:
Level A - To be selected when the greatest level of skin, respiratory, and
eye protection is required.
Level A equipment; used as appropriate:
1. Pressure-demand, self-contained breathing apparatus, approved by the
Mine Safety and Health Administration (MSHA) and National Institute
of Occupational Safety and Health (NIOSH).
2. Fully encapsulating chemical-resistant suit.
3. Coveralls*
4. Long Underwear*
5. Gloves (outer) chemical-resistant
6. Gloves (inner) chemical-resistant
7. Boots, chemical-resistant, steel toe and shank. (Depending on suit
construction, worn over/or under suit boot.)
8. Hard hat (under suit)*
9. Disposable protective suit, gloves, and boots (Depending on suit
construction, may be worn over fully encapsulating suit boot.)
10. Two-way radios (worn inside encapsulating suit).
* Optional, as appropriate
-24-
Hay 15, 1988
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Level B - The highest level of respiratory protection is necessary but a
lesser level of skin protection is needed.
Level B equipment; used as appropriate:
1. Pressure-demand, self-contained breathing apparatus (MSHA/NIOSH
approved), or airline respirator.
2. Hooded chemical-resistant clothing (overalls and long-sleeved jacket;
coveralls; one or two-piece chemical-splash suit; disposable
chemical-resistant overalls).
3. Coveralls*
4. Gloves (outer) chemical-resistant
5. Gloves (inner) chemical-resistant
6. Boots (outer), chemical-resistant, steel toe and shank.
7. Boot covers (outer), chemical-resistant (disposable)*.
8. Hard hat (face shield)*
9. Two-way radios (worn inside encapsulating suit).
* Optional, as appropriate
-25-
May 15, 1988
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Level C - The concentration(s) and type(s) of airborne substance(s) is
known and the criteria for using air purifying respirators are met.
Level C equipment; used as appropriate:
1. Full-face, air purifying, canister-equipped respirators (MSHA/NIOSH
approved).
2. Hooded chemical-resistant clothing (overalls; two-piece
chemical-splash suit; disposable chemical-resistant overalls).
3. Coveralls*
4. Gloves (outer) chemical-resistant
5. Gloves (inner) chemical-resistant*
6. Boots (outer), chemical-resistant, steel toe and shank*.
7. Boot covers (outer), chemical-resistant (disposable)*.
8. Hard hat (face shield)*
9. Escape Mask *
10. Two-way radios (worn under outside protective clothing).
* Optional, as appropriate
-26-
Hay 15, 1988
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Level 0 - A work uniform.
Level D equipment; used as appropriate:
1. Coveralls
2. Gloves*
3. Boots/shoes, leather or chemical-resistant, steel toe and shank.
4. Boots (outer), chemical-resistant (disposable)*.
5. Safety glasses or chemical splash goggles*
6. Hard hat (face shield)*
7. Escape Mask*
* Optional, as appropriate
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May 15, 1988
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