Basic OSH Programs and
    Related Matters

      REGION I
       1986

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Basic OSH Prcgrams and
Related Matters
Region I
! brman A. Beddows
Jaruary 1986

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Preface
I approached this presentation in the manner of an auditor——
assessing and recommending. My standards were the mandates of
the EPA Orders, the Health Standards for General Industry
under OSHA, and the organizational structures and assigned
responsibilities which exist in many large US corporations.
Plans are presented in the approxfr ate order needed for a
strong overall OH&S program for I gion I for calendar year
1986. However, they are not highly prioritized because most
of them are mandatory. The plans should be considered to
be minimal to attaining arid maintaining the program.
The goals are achievable if managers and supervisors actively
work for employee health and safety by consistently communicating
our program to employees and making sure that they are enforced.
Commitment to the program at every level of management is
critical to its success.
I am grateful for the opportunity to present so freely my
observations and reccmmendations. Md I appreciate the support
and constructive comments of my colleagues at the EPA Lexington
Laboratory and in Boston.
Norman A. Reddows
1/11/1986

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BASIC 0611 PROGRAMS }1D REL? TED MATTERS
Table of Contents
Page
Part I: Overview . . . . . . . . . . . .
Medical Monitoring Prcgrar . . .
Medical Monitoring Contract (I issue)
Respiratory Protection Testing .
Industrial Hygiene Monitoring .
OH&S E iployee (Basic) Instruction
Right to Know Instruction . . .
Occup. H&S Ccriniittee • • • •
Executive H&S CaTirnittee • • •
Federal H&S Ccvurattee . .
OH&S Notebook for Supervisors
Advanced Training Opportunities
Auditing OH&S Region—wide
• . . . . . I — 1,2
• S I S S • 1
• . . • . . 2
• . a S S S

• . • . . . . .5
• S S S a I I 56
• I S • • I S .7
• I S • I S S •S
• S S S S I S S 59
• S I S I • S • S 1’)
• S S • S I S S 5 11
• S S S I I S S • 12
• . . . . 13
• . . . . 14
• . . . • 15
• . . . . 16
• S S • J7
•10
• I S • 5
. . . . 19
Part II: Regional Challenges . • • . . . . . •
Part III: Coals and Plans • . . • • . . . . .
.11 — 1,2,3,4
• III — 1. ‘!an No.s
Fiscal Managei ent—-OR&S . . . • •
Instruction——Respiratory Protection
Instruction——Entry into Confined Spaces
Ccr puterized Personnel Profile . •
Instruction——Protective Clothing . • •
Material Safety t ta Sheets • • •
Seiiinar Develcpinent—arld (Interinediate and
Mvanced) Instruction • . .
Serinar t:evekpuent—ard Instruct ion:
Asbestos Safety
. • . .20
Part IV: Resources, Interfaces, and Organization
. .1 — 1,2

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PART I
OVERVIEW

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It is important to all of the ?gency’s employees that every Region
has an occupational health and safety program which is not merely
one of cai pliance to basic program elements but is one which is
strong on all fronts. Programs for assuring the protection of the
Agency’s empl ’ees shuld be at least as stringent as tiose found in
General Industry, if they are to be successful. Indeed, the case
can be made for even rore stringency. Employees of the P gency, besides
being very much in the public eye, can be exposed simultaneously to
a multitude of wastes which may be toxic in a synergistic and chronic
way. c4hile, little is known about the effects of longterrn, multi—
factorial exposures, recently, synergistic toxicity or “potentiation”
has beccce an increasing concern. This has been brought about parti—
cuiarly by observed severe human reaction to exposures involving
ultrafine fly—ash particulate and sulphur dioxide, and chlorinated
hydrocarbons and alcthols. Moreover, permissible exposure standards
for single substances change, as human experience or biological
testing drives the regulatory process.
Health standards limits are not “cast in concrete” and do riot represent
a fine line between safe and unsafe conditions. The point is well
made in the drastic changes seen in the asbestos exposure standard
over a relatively short period of 13 years——a period less than a
third of a working life—tine. In 1971, the OSH asbestos standard
(at 29 CFR Part 1910) regulated (8 h.r. ThP ) exposure to 12 fibers,
longer than 5 microns, per cubic centimeter. In 1972, the limit was
5 fibers per cubic centimeter; in 1976, 2 fibers per cubic centimeter;
and in 1984, 0.2 fiber per cubic centimeter limit was proposed by
OSHA. The preavble to the 1984 051-IA proposal stated that the 0.2
fiber limit was based, in the final analysis, on the feasibility of
conventional evaluation, and a “ belief that a substantial reduction
in cancer risk is realizable.” (underlining added). The point is
further supported in noting the 4—fold reduction in the permissible
exposure limits for lead particulate which occurred in the late
1970’s, based on reported lead intoxication occurring at the then
established limit.
A precept in health standards is the need to train and instruct
employees who are exposed to hazardous substances. Of all of the
safety cavununication programs in vogue, employee training yields the
greatest benefit for the effort. A series of short seminars, repeated
regularly, on such basic topics as: the proper use of respirators
and their limitations; and health hazards with exposures to known
and unkncMn chemicals, given to EPA field workers require little in
the way of resources and contribute greatly to their protection.
The key to every successful health and safety program is periodic
formal safety instruction and training of employees.
The policy of the gency is to assure that its employees are provided
work and workplaces which are safe. Each Region is required to
implement cariprehensive administrative and exposure—control programs
for this purpose.
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Administrators are responsible for assuring programs are implemented.
Occupational health and safety personnel are responsible for assisting
Administrators in an ing, develqirxj, ortjanizing, directing and evaluating
programs. These specialists are responsible also for providing technical
advice to management on the interpretation of health and safety regulations
and standards.
Supervisors are responsible for the health and safety of their employees.
This includes asssuring that employees are informed of their rights under
occupational safety and health regulations, and are provided safety
instruction and training, exposure monitoring, and medical ronitoring.
Supervisors and cther employees are required to ccr ply with regulations,
standards, and orders of the Agency. And supervisors are required to
enforce standards for employee health and safety.
fl’ployees are required to cc iply with all safety rules as they apply to
their own actions and conduct. They are required to follow explicit
procedures and practices which are deemed necessary for their protection.
Employees have rights. They have access to procedures and practices —
documentation and to personal medical nonitoring and exposure r’onitoririg
records; they have a right to specific safety instruction and training;
and they have other rights which relate to participating in occupational
health and safety matters.
A ca iprehensive program for occupational health and safety will have a
part devoted to “basics”—-nandatory standards and regulations, and
other parts ccnprised of administrative control plans and broad instruc-
tional programs. The program would cover special occupational health
instruction for EPA personnel engaged in field activities.
This “Basic OSH Programs and Related Matters” update presents regional
challenges, goals and plans, and resources arid organization proposals to
Region I Management. In develcping the plans presented here, solicited
Divisional group participation; the challenges reflect a broad set of
perspectives.
1—2

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PART II
REGIONAL CHALLENGES

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Regional challenges in Occupational Health and Safety management fall mainly
into eight major classes:
• Medical ronitorirq
• Respiratory protection programming
• Industrial hygiene, and personal and area exposure ronitoring
• Fknployee instruction
• Ca munications
• Auditing for ccmpliance with regulations and standards
o t cumentat ion of procedures
• Fiscal management and related controls
These challenges are significant because of long—standing requirements and
either voids or weaknesses in existing programs. The nore praninent features of
these challenges are discussed here.
1. Medical Monitoring
A procedural instruction covering medical nonitorirç is required to ensure
privacy, proper record—keeping, and cost—effective examinations. The current
medical uonitoring program and procedures need to be upgraded in these three
areas.
The purpose of medical ronitoring has to be made clear to our employees.
Also, the authority of the Agency to reasonably require an employee to report for
a medical evaluation should be imparted to affected employees. Medical nonitoring
is provided to protect the health status of employees who are regularly occupa-.
tionally exposed to hazardous substances or physical agents such as ionizing
radiation. As an example, specific medical evaluation is required as a baseline,
art) periodically thereafter, when an employee is, or may reasonably be expected
to be, exposed regularly to asbestos fibers at the “action level” (a concentration
of 0.1 fiber longer than 5 microns per cubic centimeter, as an 8 hour tine weighted
average).
Medical nonitoring is not a substitute for private physician examinations,
and the medical ronitoring program must be guarded against such use. The para-
meters of an occupational medical nonitoring program are designed to purposely
address health status as correlated to work environment. There is no assurance
that such a program will identify a previously diagnosed condition affecting an
individual’s general health status.
on the point of examination authority, affected employees should be made
aware that the Agency can require an employee to report for medical evaluation
as part of an established program of medical surveillance related to occupational
exposures to hazardous sutstances or physical agents.
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Lastly, to be cost—effective, assignrent to, and maintenance of employees
in, the prcgram need to be scrutinized by the employees’ supervisors, and the
contents of the periodic medical assessments should reflect the actual or likely
specific exposures.
2. Respiratory Protection Prograrming
Misinformation on which respirators can be used, and on the efficacies of
respirator cartridges has been given within the Region. Also, conditions of
equipment storage and maintenance, and employee instruction are unsatisfactory in
s instances. A program to correct these situations and establish permissible
practices is r uired.
To be minimally acceptable, respiratory protection prograrviing must include
instruction by ca’ petent persons of supervisors, and field and laboratory workers.
Particularly, instruction on the use, limitations and selection of respirators
must be provided. Also, every respirator wearer must receive fitting instruction
including demonstration and practice in how the respirator should be worn, how to
adjust it and how to determine if it fits properly.
Self contained breathing apparatus (SCBA) for emergencies must be inspected
monthly. Eath unit must be examined to determine that the regulator and warning
devices function prcperly and the valves and elastaieric parts are in good con-
dition. A record of inspections arid dates must be maintained for each respirator
maintained for e rgency use.
3. Industrial Hygiene, and Personal and Area Exposure Monitoring
To protect the health and welfare of employees, the principles of industrial
hygiene must be applied by supervisors, and monitoring, using scientific methods,
must be objectively employed by the Industrial Hygienist. Supervisors must act
responsibly at all times in assuring healthful working envirorrients are maintained.
The provision and proper use of chemical protective clothing and respirators, arid
good personal hygiene must be a primary concern of supervisors responsible for the
health and safety of field and laboratory workers.
Personal exposure monitoring——the practice of evaluating employees’ occupa-
tional exposures—-must be performed regularly by an industrial hygienist to
assure health hazards to employees are consistently controlled. The Region
must implement canprehensive personal and area monitoring if the occupational
health of our field and laboratory workers is to be assured.
Known exposures have been reported by our field and laboratory workers to
involve the substances listed below. Also, exposures to “unknowns” have been
reported. In general, personal doses have not been known or measured.
List of Substances of Reported Exposures : Polychlorinated biphenyls (PCB’s),
benzene, toluene, phenol, vinyl chloride, cyanides and nitriles, formaldehyde,
various volatile organic canponents (VOC’s), pesticides, tetrachloroethylene,
chlorinated hydrocarbons, amines, nitric acid, organic acids, mercury, lead,
arsenic, nitrogen oxides (NOx), sulphur dioxide, and malodorous “unknowns.”
11—2

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4. Employee Instruction
If employees are to meet their responsibilities to the Agency for protecting
their own health and for maintaining a professional level of conduct when they
represent the Agency they imist be provided comprehensive and frequent instruction
in occupational safety and health and required practices in field work. Instruction
must cover the levels of protection which are required for the employees’ safety,
and it must be given frequently enough to assure the employees are thoroughly
informed of job hazards and appropriate safeguards.
An ongoing, Region—wide effort, with strong support from the Directors and
Chiefs, is essential to attaining the required level of knowledge and skill for
our employees. Instruction for RCRA and Superfund field workers will become a
critical area for compliance in the near future because of the planned expansion
of field work in these areas.
5. Communications
There is a perceived need to review and appropriately redefine protective
service policy and practice (by reissuance of the Regional Order). At this time,
no formal Executive Occupational Health and Safety c mmittee exists; and no
Occupational Health and Safety Committee exists in the Boston region. Participation
in the Federal Safety and Health council in the Region has been good, however.
The existence of an O}1&S Program Manager or a safety office is not evident in
the current EPA Region I telephone directory. The manager office should be
listed in the directory in the same manner as are the organizational units.
Instruction and training of employees using appropriate occupational safety
and health programs should be improved by a Region—wide effort to implement
programs which address related deficiencies. Also, the issuance of a Region I
Order, the establishment of an Executive OH&S CaTUnittee, and the revitalization
of the Occupational OH&S Committee are major challenges in communicationfr.
6. Auditing for Compliance with Applicable Regulations and Standards
Periodically, the Regions conduct self—audits, as required for the Annual
EPA Report. Also, audits are conducted to one or two-page lists of items for
compliance. %‘Jbile these audits may meet their intent, they do not provide the
measure of compliance status and change in status which is needed to fully evalu-
ate administrative and other controls for occupational health and safety. To
assure Region I and its employees comply with the many applicable regulations and
standards, a comprehensive audit—format needs to be developed and employed by
competent persons. The developnent and use of such an audit is necesssary to
attain and maintain an exemplary record for occupational health and safety in the
Region.
7. tr,cumentation of Procedures
Certain procedures used in managing occupational health and safety require
documenting in the form of “Instructions” which clarify terms and regulatory
requirements, establish responsibilities, and prescribe procedures to be followed.
For example, formal instructional documents covering such topics as respiratory
11—3

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protection, entry into and working in hazardous locations, especially confined
spaces, and the selection and use of protective equipment in field/laboratory
activities are required if employees are to be consistently protected when faced
with the pertinent hazards in related situations. while excellent documentation
has been provided by the EPA, certain specific Safety Instructions, written in the
imperative case, are needed at the Regional level.
8. Fiscal Management and Related Controls
Good fiscal management of any program requires line item budget forecasting
and subsequent variance analyses. Categories of planned expenditures for OH&S
supplies, services, and equipment should be employed by EACH Divisional Director
in administrating employee health and safety programs. Periodically, Region—wide
auditing of actual expenditures for occupational safety and health prograirs
should be undertaken.
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PART III
GOALS ND PLANS

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Ocoupational OH&S Goals and Plans for calendar year 1986 have
been established with the participation of interested groups in
all of the Divisions. Twenty plans have been forriulated.
Eighteen of the plans will be cciinencecl in the first quarter of
the calendar year (period of major need for clerical service).
By year end, all, except those with major continuing tasks,
slould be fully implemented.
The list of plans and the plan sheets are presented here.
PLPN Plan No.
Medical Monitoriog Program . . . . . . . 1
Medical Monitoring Contract (Reissue) . . . . . . 2
Respiratory Protection Testing . . . . . . . . . . 3
Industrial Hygiene Monitoring . . . . 4
OH&S E ’iployee (Basic) Instruction . . . . . . . . 5
RighttoKnowlnstruction ............ 6
Occup.H&SCairuttee. . •1•SSSS• . . .. 7
Executive H&S Camnittee . . . . . . 8
FederalH&SCcrrnu.ttee . . . . . . . . . . . . . . 9
OH&S NotePook for Supervisors . 10
Advanced Training Op [ xrtunities . . . . . . . . . 11
Auditing OH&S Region—wide . . . . . . . 12
FiscalManagement—-OH&S . . . .. . . . •.... 13
Instruction——Respiratory Protection . . . . . . . 14
Instruction——Entry into Confined Spaces . . . . . 15
Canputerized Personnel Profile . . . . . . . . . . 16
Instruction——Protective Clothing . . . . . . . . . 17
Material Safety t ta Sheets . . . . . . . . . . 18
Seminar Develcprient—and (Intermediate arid
Advanced) Instruction . . . . 19
SQlinar Deve lcpment—and Instruct ion:
AsbestosSafety............. 20
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EPA REGION I HEALTh & SAFETY P1 )GRAM
198 GOM.S & PLANS
GOAL CLASSIFICATION: Medical Monitoring PLAN NO. 1
Establish modified procedure for med. monitoring to expedite same and minimize
GOAL aper handling.
-
Program in place but has weaknesses —— privacy area/paperwork and is not convenient
STATUS pr1p ir i-c
Issue instruction to supervisors re. new procedure to obtain medical assessment.
PLANNEDTASK
PLANNED/ACI’UAL_TIMES
J
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A
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J
J
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0
N
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Issue instruction (after
review, comment, accominoda
tion)
Instruct supervisors in
0—
——0
procedure.
Provide document packages
0
to divisions.
Audit practices. 0 Conti uing )
nd o contract
Feedback reports 0 conti uing— erioli. I
.......— ——--. ..--—- ..-..--- ——-- -“--.. ..-— -—— —— -
KEY 0-PLANNED START A.ACI’UAL START (OR REPEAT)
— •MID-WAY POINT •-a)MPLErED TASK OR ELEMENT
FORM: NAB 12/6/85

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EPA REGION I HEALTh & SAFETY P )GRAM
198k GOALS & PLANS
GOAL CLASSIFICATION: Medical Monitoring Contract I PLAN NO. 2
GOAL Redefine Scope of Work. Reissue contract documentation. Secure new contract.
STATUS Required to continue medical monitoring. Current contract expires September 1986 .
PLAN Establish scope of work, review with management, submit documentation for new
contract to EPA.
PLANNEDTASK
PLANNED/ACTUAL_TIMES — 198...
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Scope of work definition
0
—-
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--—
——
—--.
---.
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Documentation Provision
toEPA
—-
—
.—-
Participation in Contract
Selection
r
0———
-0
Secure Contract
0
t
1
KEY 0-PLANNED STARE A-ACrLJAL START (OR REPEAT)
— 0M1D-WAY POINT S-(DMPLETED TASK OR ELEMENT
FORM: NAB 12/6/85

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EPA REGION I HEALTH & SAFETY P )GRAM
l98 GOALS & PLANS
GOAL CLASSIFICATION: Respiratory Protection I PLAN NO. 3
GOAL Establish quantitative fit tester for Region—Wide use.
STATUS Testing not in place as required for assurance of empi. health.
Purchase portable tester, set—up & debug. implement fit—testing Region—Wide.
PLAN Provide resp. prot. instruction.
PLA.NNEDTASK
PIANNED/ACIUAL_TIMES
S
F
M
A
M
J
J
A
S
0
N D
-—
Aap ire Equipment
Debug
Set up EPA Lab.
Implement (Lab) Program
Set—u1 JFK or Boston.
Implement
Set—upwil1requirea
LO ‘xlO ‘xlO’ space & a 120v
1OA outlet. The equipuent
perates at steady 8OdB(A)
ioise level in the
jrnediate area.
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KEY O.PLANNED STM A•ACFUAL START (OR REPEAT)
GMID-WAY POINT • -C0MPr2rED TASK OR ELEMENT
FORM: NAB 12/6/85

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EPA REGION I HEALTH & SAFETY PI JGRAM
198 GOALS & PLANS
GOAL CLAcSIFICATION: Industrial Hygiene—Personal Exposure Monitori 1 gPLAN NO. 4
GOAL Nonitor personal exposures to Asbestos t7CY ’s and other toxic aqents , per
mandatory standards as a minimum.
Monitoring is not currently performed in coiipliance with prescribed standards .
Obtain sampling equipment; implement testing in the field; arrange for quantit tion
PLAN services. Evaluate exposures. Record in employees’ files .
PLANNED TASK
PLANNED/ACTUAL_TIMES — 198....
J
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Equipment Evaluation
Selection’ Order
Debug Equipment
———O
O———O
0
——0
cant
nuin
Evaluate Exposures in
Field Activities
Sampling
Quantification
0
) and
Record Exposures
• Notification if
Req ‘d
• Record—Keeping
0———
———-
-——--
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con nUi
•——-—-
KEY O.PL.ANNED STARF
A-ACEUAL START (OR
RE PEAT)
JMID-WAY POINT S-COMPLF FED TASK OR ELEt’IENT
F )RM: NAB 12/6/85

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EPA REGION I HEALTh & SAFETY PI )GRAM
l98 GOAlS & PLANS
GOAL CLASSIFICATION: OH&S Employee Instruction (Basic) I PLAN NO. 5
Establish Basic OH&S Program for EPA Laboratory Personnel.and Field Workers.
STATUS Tab. recuest/servlce. Program required for new hires/ assignments hefrre
ass ignn nt to field activities. (Applicable Region-wide)
PLAN Meet with EPA Tab personnel. Identify needs. F rmu1ate program. Present
program for review. Implement.
PLANNED TASK
PLANNED/ACIUAL_‘I’IMES
J
F
M
A
M
J
1
A
S
0
N
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Meet with Lab personnel.
Develop key topics list.
Obtain information re.
audience, place, time,
etc. 0-0
Compile program; review
with Lab. personnel.
Modify. Formalize 0--0
Present to field/lab 0 0
personnel.
KEY 0-PLANNED STARF A-ACL’UAL START (OR REPEAT)
)-MID-WAY 1 )INT S -COMPLFrEI) TASK OR ELEMEI iT
FORM: NAB 12/6/85

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EPA REGION I HEALTH & SAF Y PI )GRAM
198k GOALS & PLANS
GOAL CLASSIFICATION: Right-To-Know (RTK) Seminar PLAN NO. 6
GOAL Vstahlish R—T—K Instruction for Region I.
STATUS
Nnt Tn Place.
1AN Inventory chemicals at lab. Formulate RTK program. Review with lab. personnel
Implemenr RTK progr-Lm ASAP.
PLANNED TASK
PLANNED/ACnJAL_TIMES
J
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3
J
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0 N ID
Inventory Chemicals
ev±èw with Lab. Personnel
Develope RTK presentatio
Review with Lab. Pers.
Present to Lab. Personne
in groups.
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a
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0
.. -..-
0-

.. . . -
0
. ..-I --
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KEY 0-PLANNED START A-AC [ ’UAL START (OR REPEAT)
•MID-WAY POINT •-COMPLEFEI) TASK OR ELEMENT
R)RJ’1: NAB 12/6/85

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EPA REGION I HEALTh & SAFETY PI DGRAM
198 GOALS & PLANS
GOAL crAcs lF lcxrroN: Communication I PLAN NO. 7
GOAL Implement Occupational H&S Committee per Procedures and Rules of EPA Manual.
STATUS One time Committee z w Defunct.
Establish Instruction re. OH&S Committee. Request formal establishment of
PLAN Committee. Monitor activities. Assist Committee.
PLANNED TASK
PLANNED/ACI1JAL_TIMES — 198d. ..
J
F
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A
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Firm up plan for Committe
Develope Instruction
—
0
0
—--
-0
—-
0
C
—.-
--—
——
—-..
.--
—I. -.I
—
Present “Order” for sign
off by RA
Implement Order
.__
----
Contribute to Commitee’s
Work
*Planned Meeting
,
0
—
*
0
*
o
,
j
I
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—I
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KEY O•PLANNED START AAC [ UAL START (OR REPEAT)
MID-WAY POINT •-(x)MPLErEI) TASK OR ELEMENT
APPENDIX 5-C - SUGGESTED POLICY AND PROCEDURES FOR FORM: NAF 12/6/85
THE ADMINISTRATIVE CONTROL OF A SPECIALIZED
OCCUPATIONAL HEALTH AND SAFETY COMMITTEE

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EPA REGION I HEALTh & SAFETY PROGRAM
198 COALS & PLANS
GOAL cLASSIFIcATr0N: Communication I PLAN 7). 8
GOAL Assure the Implementation & Maintenance of an Executive H&S Committee Region—Wide .
STATUS Committee not yet in place. Preliminary plans have been developed .
Request formal review and approval of preliminary plan. Finalize plan. Report out
PLAN plan. Contribute to Committee deliberations.
PLANNED/ACTUAL_TIMES — 198...
PLANNED TASK
Firm up plan for
Executive Committee
Present plan for Review
and Approval
3
-

F
M
A
M
J
J
A
S
0
—___i_.
N
1
Present suggested Order
for sign-off.
-
0
Implement Order
Contribute to Committee’:
Work
*Planned Meeting
0
*
0
*
0
*
0
*,
01
NGIES: (1) Ccr pceition—-Chairrian at Director level; branch chiefs
rninii’ ally to r resent major field/lab segments; technical OHS
resource secretary; member of legal staff. 1 riodic assignees
as indicated.
(2) Charter——Ass e fulfillment of RA’s res nsibilities for EPA
program; assure timely provision of required resources for
program; provide advise and guidance region—wide on significant
OH&S program ratters.
,
KEY 0-PLANNED START A-AcruAL START (OR REPEAT)
MID-WAY POINT •-C0MPLErED TASK OR ELEMENT
R)RM: NAB 12/6/85

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EPA REGION I HEALTh & SAFETY PI )GRAM
198k GOALS & PLANS
GOAL CLASSIFICATION: Communication I PLAN NO. 9
GOAL Regularl r represent EPA Reaion I at Federal Health & Safety Council’s Meetings
STATUS
JFK Fed. Bldg. personnel periodically attend meetings. Laboratory personnel
regularly attend meetings.
PLAN At-i- . ni-i scheduled meetings contribute to programs of Council.
PLANNEDTASK
PLANNED/ACflJAL_TIMES — 198....
3
F
M
A
M
J
J
A
S
0
N
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erso
Attend meetings on a
quarterly basis.
(a
cal:
(a
ed b
reqi
Chat
este
rper
by
on.)
hairi
Contribute to programs,
periodically.
KEY 0-PLANNED STARE AACfUAL START (OR REPEAT) —
•-MID-WAY POINT I-COMPLETED TASK OR ELEMENT
FoRM: NAB 12/6/85

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EPA REGION I HEALTh & SAFE TY P1 JGRN4
198k, GOALS & PLANS
GOAL CLASSIFICATION: Communication PLAN NO. 10
Establish an OH&S Notebook for Supervisors to provide essential instructions and
GOAL C.ii4r1 1in s ddrc sing Employee Health and Safety Programs
STATUS No simple consolidation exists for Region I
PLAN See self explanatory tasks below.
PLANNED TASK
PLANNED/ACIUAL_TIMES
J
IF
M
A
M
J
J
A
S
0
N
D
Identify contents
Prepare key sections
Integrate parts, print
Introduce & distribute
0————
-————
-———0
-
0
0
—
I
I
I
o———f
————
KEY 0-PLANNED STA1 AACFUAL STAkT (OR REPEAT)
MID-WAY POINT 1(DMPLEFED TASK OR ELEMEN1’
I
R)RM: NAB 12/6/85

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EPA REGION I HEALTh & SAF FY P1 JGRAZ4
198k GOALS & PLANS
GOAL CrAcSIFICATION: CoiptnunicatIon I PLAN NO. jj
Attend advanced training/instruction programs for Industrial Hygienists and
GOAL SaF ry Engin ers4,k1so Contract nfficer training
STATUS OH&S Manager is scheduled for contract officer trainjn in A ri1 1986.
Attend annual and national Industrial Hygiene Association and Safety Engineers
PLAN Agsoc.latfpn conventions and specialized training seminars.
PLANNED TASK
PLANNED/ACIIJAL_TIMES
3 iF
M
A
N
J
3
A
S
0
N
D
Attend annual convention
of Amer. conE. md. Hyg.
Attend annual convention
of Asse.
Attend EPA Contract
Officer Training
Attend EPA conference
(Annual Regional OH S
meeting)
0
(A
sch
dule
)
sche
uled
J
0
(As
0
I
I
As s
hedu
ed
i
KEY 0-PLANNED STARI’ A•ACPUAL START (OR REPEAT)
MID-WAY POINT •-COMPLEFED TASK OR ELEMENT
FORM: NAB 12/6/85

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)EPA REGION I HEALTh & SAFET t L ’I lW !
I98 GOALS & PLANS
GOAL CLASSIFICATIOt i: diting OH& I PLAN NO. 12
GOAL Develop & in pl n t perialic ai r h nciv u 1i1- nrr r r’ni Frir and field
activity apolication.
STATUS No canprehensive audit protocol exists. —______________________________
Critically examir e EPA manual; review annlicabi r i1atioris and industrial hvc iene
standards, and fomnulate protocoL Periodically ai id it programs and administrative
matt- rs. P giOn-w t1t .
PLANNED TASK
PLANNED/P1L’L’UAL_TIMES - 198....
J
F
1M
A
M
J
J
A
S
C)
N
D
riteria deve1o ient and
List. Criteria to -l 9 res :
dministration; ccuipl lance
to standards & EPA progr rw
ield activities.
)-
-————-
-————-
0
dvise manag nent and
3.ivisional personnel of
i.xitended audit, provide
or nonth notice.
) -C
udit syste s adrninistra—
:ion, written instructions,
xinpliance to standards,
nd rk practices in the
aboratory and field.
•
---—
JFK
Fed.
Bldg.
•H
Lab
t
flne
renc
& f:
1d
iv;ties
I
KEY 0-PLANNED START A-ACruAL START (OR REPEAT) —
— MID-WAY poitqr •-COMPLEFED TASK OR ELEMENI’
R)RM: NAB 12/6/85

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EPA REGION I HEALTH & SAFETY P1 )CRAM
198 GOALS & PLANS
GOAL CLASSIFICATION: Nscal Wanagement Program PLAN NO. 13
Establish a line item budget forecast for categories of services, expendable
GOAL materials and capital eQuipment for OH&S programs.
STATUS Fprecast: By division, group, and section.
Identify elements of lines, establish reporting format, distribute format, obtain
PLAN input, consolidate, report out.
PLANNEDTASI<
PLANNED/AC1UAL_TIMES
J
F
M IA
M
J
J
A
S
0
N
P
Identify elements
Establish report format
Distribute format
Obtain input
Consolidate input
Report out
0
0
0
0
0
0
—
KEY O.PLANNED START ,i•ACE’UAL START (OR REPEAT)
)MID-WAY POIPif S -CT)MPLFItD TASK OR ELEME T
R)RN: NAB 12/6/85

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EPA REGION I HEALTH & SAFETY PF )GRAM
198 GOALS & PLANS
GOAL CLASSIFICATION: Instruction-Written Program I PLAN NO. 14
Establish instruction re. Respiratory Protection as applicable to Region I
GOAL facilitIes/activities.
STATUS No Region I instruction in place. HQ has a R.P. Guideline.
Identify usage/types/storage factors. Prepare specific instruction. Introduce
PLAN and distribute instruct Region—Wide.
PLANNED TASK
PLANNED/ACI1JAL_TIt S
3
F’
M
A
M
J
3
A
S
0
N
P
Identification of factors
.
Write Instruction
Print
Introduce
Distribute
--
—
0
0
-. -___-
-
.- - ..
..-1. - _
0
.-...—.
-
——
C
..----
0
.--..—
-
-.
.-—
--—
-—i ....-.
KEY O.PLANNED START A-ACFUAL START (OR REPEAT)
MID-WAY PoThrr S-COMPLETED TASK OR ELEMENT
FORM: NAB 12/6/85

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EPA REGION I HEALTh & SAFETY P1 )GRAM
l98 GOALS & PLANS
GOAL CLASSIFICATION: Instruction—Written Program PLAN NO. 15
Establish instruction re. entry/testing confined spaces with potentially
GOAL dangerous atmospheres.
STATUS No specific instruction Is In place Region—Wide.
HST Factors, identify responsibilities, establish procedures introduce instruction
PLAN distribute instruction.
PLANNED TASK
PIANNED/ACI1JAL_TIMES
J
F TM
A
M
J
J
A
S
0
N ‘D
List factors
Identify responslbilitie
Establish procedures
Prite instruction
Print
Introduce
Distribute instruction
——
0——
--—
0
0————’
—--
0——

-—
—-
,—-
-.
-
.
—
0
I
0—---

——0
0——i
I
KEY O-PLANNEI) STA t -AC1’UAL START (OR REPEAT) —
()•MID-WAY POINT •-cx)MpI2rEJ) TASK OR ELEMENT
FORJ’1: NAB 12/6/85

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EPA REGION I HEALTh & SAFETY PI )GRAM
198k GOALS & PLANS
GOAL CIASSTPTCATION ini r tinn I PLAN NO. 16
GOAL Establish Region-wide CaT puterized Personnel Profile re. OH&S training, medical
monitoring status, respirator partially in place.
STATUS Resources to ccinplete/expand not currently available.
PLAN Perform planned tasks. Identify resource demands. lirplanent as resources allow.
PLANNED TASK
PLANNED/ACI1JAL_TIMES
r
F
M
A
M
J
J
S
0
N
Review existing elements
& segments of proposed
system. 0 0
Establish input format 0 ---0
Establish output format 0 0
Identify procedural
factors. Formulate
software, as needed. Ot-— 0
Review -
Present
Irrplentent ODnt
KEY O.PLANNEI) START A-ACtUAL SI’ART (OR REPEAT) —
— MID-WAY PODTF •WMPLEIt1) TASK OR ELEMEtfl
FORJI: NAB 12/6/85

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EPA REGION I HEALTh & SAFETY P1 )GRAM
198_GOALS & PLANS
GOAL cLAcsIFIcATI0N: Instruct Lon—written Program I PLAN NO. 17
GOAL Establish instruction for the selection and use of protective clothing in field!
laboratory activities for Region-wide application.
STATUS None in place at Regional level -
PLAN Conduct literature search. Pe(forrn evaluation of practices. Identify available
protective clothing. Write instruction. Implement.
PLANNED TASK
PLANNED/ACflJAL_TIMES
J
F fM
A
M
J
J
A
S
0 IN
D
Literature Search
Evaluate practices.
Identify equiprent.
Write instruction.
Revie.q & cczTment.
Print
Introduce
[ mpl nent
0--
-0
0--—
O---H
a-——-

--0
0
0
0
KEY 0-PLANNED STARF A .ACI’UAL START (OR REPEAT)
)-MID-WAY PODTF •-cOMPLErEI) TASK OR ELEMEtfl’
FORM: NAB 12/6/85

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EPA REGION I HEALTH & SAFETY PI )GRAM
198k GOALS & PLANS
GOAL CLk SIFICATION: Material Safety Data Sheets I PLAN NO. 18
GOAL Establish a portfolio of material safety data sheets with specific application to
RegiDn I for use in implementing “Right-to-Krow” program and enployee instruction
STATUS in basic safety.
PLAN Perform inventory, collect dataJ 1SDSs as available. Ca ile MSDSs or otherwise
prepare.
PLANNED TASK
PLANNED/AC’nJAL_TIMES
3
F
M
A
M
3
3
A
S
0
N ‘D
Inventory using statetent
of exposures and physical
inspection
Canpile or prepare MSDSs
Make available in cai-
solidated format.
0---—
0
0
I
0----
KEY 0-PLANNED START A•ACI’UAL START (OR REPEAT)
)MID-WAY pojirr ••COMPLErEI) TASK OR ELEME 4I’
FORM: NAJ3 12/6/85

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EPA REGION I HEALTh & SAFETY PI JGRAM
198k GOALS & PLANS
GOAL CLASS I FICAT ION: S u.nar Develop nt — Intermediate/Advanced I PLAN NO. 19 —
GOAL Establish slide presentation for instruction of engineerina-orientated personnel
in technica 1 aspects of safety engineering. For Intermediate and Advanced Training
STATUS of EPA Field ,rkers.
PLAN Establish materials, formulate presentation, make available. Implement instruction .
PLANNED TASK
PLANNED/ACTUAL_TIMES
J
F
M
A
M
3
J
A
S
0
N
Establish materials.
Formulate presentation.
Make available.
)-———-
--0
0—
--0
0
I
Make presentation(s).
I
I
0—•
-———
1
——cc
As
t. —.
ieed
----
L
——
I
KEY O.PLANNEL) START i -ACIiJAL START (OR REPEAT) —
MID-WAY MNF •CUMPLRFEI) TASK OR ELEMEI 1
R)RM: NAR 12/6/85

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EPA REGION I HEALTH & SAFETY PI )GRAM
l98 , GOALS & PLANS
GOAL CLASSIFICATION: Seminar Development I PLAN NO. 20
Establish slide presentation/script for Instruction of asbestos inspectors and
GOAL use in basic safety instruction.
STATUS None currently known/in place.
Review available materials/slides/scripts. Formulate presentation. Make
PLAN available to users.
PEANNED/AC1 JAL_TIMES
PLANNEDTASK J F M A M J J A S 0 N I D
Establish materials—
slides. )————. •———— I
-4 .---I- —
Write script ( .————.
Make available ————(
Make presentation as
needed 3————- -———- -———- , ont- -———- -——— -———- I
—-...-...“-----..-.-
KEY 0-PLANNED START A-AC!’UAL START (OR REPEAT)
— cPMID-WAY I )Ir rr •-cflMPLF. rED T 4 ASK OR ELEMEPlI
R)RM: NAB 12/6/85

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PARE IV
Prscxmc $, IWrERFAcES AND ORGANIZATION

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Achieving these goals will particularly require employee instruction on a
large scale by ca’ipetent persons using high quality instructional mdules. Unhindered,
agressive efforts must be made in this area in 1986.
Basic equipment for industrial hygiene* must be obtained for the use of the
Industrial Hygienist and the on—site coordinators arid project officers. Personal
and area ITonitoring must be employed on a large scale in the Region if i e are to
sample so as to represent with reasonable accuracy the levels of exposure of air
fiel&and laboratory workers.
Effective caTuiunications must be established across the Region between senior
level managers and the Safety Officer. Also, strong cai’iunications at other levels
including employee representatives must be on—going. Interfacing with federal
safety and health personnel outside of the Agency will be necessary periodically to
assure air programs are acceptable to the federal ccr riunity.
Interfaces, within and outside of the Agency, which will be necessary to achieving
a strong OH&S legional program are characterized in figure I.
Figure 1:
Schematic I scription of Interfaces in OH&S Program Management
To fully service and effectively manage this program, current responsibilities
should be rrodified. Consideration should also be given to integrating: (1)
workers ccr çensation program management, and (2) security management with occupational
health and safety program management. Such consolidation is cci ’it onplace in general
industry; it cane abait through the need for strong administrative control over
these interrelating functions. ( i the point of responsibility for OH&S program
manajement: each Division siDuld appoint one or i ore “contact” persons at the branch
chief level, minimally, to interface with his or her peers on safety and health
matters of mutual interest.
* INDLSTRIPL HYGIENE is that science and art devoted to the recognition,
evaluation and control of these envirorriental factors or stresses,
arising in or frc , the workplace, which riay cause sickness, impaired
health and well—heir 9 , or significant discaifort and inefficiency anong
workers or arong the citizens of the ca’Tlunity.
to Req’d Frnguancy or Iri ortance of Occasional/Ordinary
contact OHS r/others in Lriplenenting Frequent/Irç.ortant
and r’iaintalnirg the OH&S Prcgraii Weekly/Very Important
H I.S. ’
‘v— i

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2—
Finally, a prcposed OH&S organization,which fully meets the authority requirerients
ca’inensurate with these goals and plans, is presented in figure 2.
1 L CP S T1ON
Figure 2: Proposed OH&S Organization
1. 1TE
) BRANGI LEVEL
- cLERK /TYPIST
1 1 I I
(sAF I (I JSTRThL
GINE .IN / H IC IE
urcrioz s
(SB T YJ
IV—2

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