EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9285 2-06FS
April 1991
Establishing Work Zones at
Uncontrolled Hazardous
Waste Sites
Office of Emergency and Remedial Response
Emergency Response Division MS-101
Quick Reference Fact Sheet
Under the authority of section 126 of the
Superfund Amendments and Rcauthonzalion Act
of 1986 (SARA), the U.S Environmental
Protection Agency (EPA) and ^ the U.S.
Occupational Safety and Health Administration
(OSHA) promulgated identical health and safety
standards to protect workers engaged in hazardous
waste operations and emergency response. The
OSHA regulations became effective on
March 6, 1990 and are codified at 29 CFR
1910 120 (54 FR 9294, March 6, 1989). the EPA
regulations also became fully effective on March 6,
1990 and are codified at 40 CFR 311 (54 FR
26654, June 23, 1989). The EPA regulations
incorporate the OSHA standards by reference.
Although the two sets of standards contain
identical substantive provisions, EPA and OSHA
address different audiences. In states without an
OSHA-approved program, federal OSHA
standards protect all private and federal employees
engaged in hazardous waste operations and
emergency response; the EPA worker protection
standards protect all state and local government
employees. In states with an OSHA-approved
program, the state program covers all private,
state, and local government employees; OSHA
co\ers federal employees in those states. Another
Fact Sheet, Hazardous Waste Operations and
Emergency Response. Uncontrolled Hazardous
Waste Sites and RCRA Corrective Action (OS WER
Publication No 9285 2-08FS), provides a general
o\er\iew of the worker protection standards as
they apply to operations conducted at uncontiollcd
hazardous waste sues.
The purpose of this Fact Shcei is to
summarise the proceduics and ia|unemcnb lot
establishing and maintaining work zones, including
Support Zones, at hazardous waste sites This
Fact Sheet is divided into five parts The first
-provides definitions for the work zones that are
commonly designated at hazardous waste sites
The second describes the data collection
requirements for the initial site characterization.
Part 3 discusses evaluation, of site data and other
considerations in work zone selection. Part 4
describes methods for ensuring the integrity of
Support Zones during remedial or removal actions.
The final part of this Fact Sheet provides
additional references and contacts for further
information.
PART 1: INTRODUCTION TO WORK ZONES
The worker protection standards at 29 CFR
1910.120(b) require that employers with employees
engaged in hazardous waste operations at
uncontrolled hazardous waste sues develop and
implement a written health and safety program for
their employees. The purpose of this program is
to identify, evaluate, and control safety and health
hazards, and provide for emergency response
during hazardous waste operations. As part of the
overall health and safety program, 29 CFR
1910.120(d) specifies that appropriate site control
procedures must be implemented before clean-up
work begins, to minimize employee exposure to
hazardous substances One of the basic elements
of a site control program is the delineation of
work zones. This delineation specifies the type of
operations that will occur in each zone, the degree
of ha/.ard at different locations \\nhin the site, and
I he areas at the sue that should be avoided by
unauihon/ed or unprotected employees
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EXHIBIT 1
Illustration of Typical Work Zones
Estimated Boundary
Of Area With Highest
Contamination
Access
Control Points
\ ^ i—'
\ ^T- . I Contamination |. /.
. I Reduction Corridor
Contamination
Reduction Zone I . • V •
Contamination
Control Line
I Support Zone I
Command Post
Prevailing wind direction
Note: Area dimensions not to scale. Distances between points may vary.
EPA's Standard Operating Safety Guides
describes the process for establishing and
maintaining work zones. Although a site may be
divided into as many zones as necessary to ensure
minimal employee exposure to hazardous
substances, the three most frequently identified
zones are the Exclusion Zone, the Contamination
Reduction Zone (CRZ), and the Support Zone.
The purpose of establishing the zones is to (1)
reduce the accidental spread of hazardous
substances by workers or equipment from the
contaminated areas to the clean areas; (2) confine
work activities to the appropriate areas, thereby
minimizing the likelihood of accidental exposure;
and (3) facilitate the location and evacuation of
personnel in case of an emergency. Movement of
personnel and equipment among these zones is
minimized and restricted to specific access control
points to prevent cross-contamination from
contaminated areas to clean areas. A
representation of the three most commonly
designated work zones is found in Exhibit 1. A
description of each zone is provided below.
Exclusion Zone
The Exclusion Zone is the area where
contamination does or could occur and the greatest
potential for exposure exists. In order to separate
the Exclusion Zone from the rest of the site, the
outer boundary of the Exclusion Zone, known as
the Hotline, should be clearly marked. Access of
personnel and equipment to and from the
Exclusion Zone should be restricted by access
control points on the zone's periphery. All persons
who enter the Exclusion Zone should wear the
appropriate level of personal protective equipment
(PPE) for the degree and types of hazards at the site
US EPA HO.& Chemical Libraries
1200 Penn Ave NW WJC West 3340
Washington DC 20460
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The Exclusion Zone also may be subdivided
into different areas of contamination, based on the
known or expected type and degree of hazard or
the incompatibility of waste streams. If the
Exclusion Zone is subdivided in this manner,
additional demarcationS and access control points
may be necessary.
Contamination Reduction Zone
As the transition area between the
contaminated area and the clean area, the CRZ is
the area in which decontamination procedures take
place. This zone is designed to reduce the
probability that the Support Zone will become
contaminated or affected by other site hazards.
Due to both distance and decontamination
procedures, the degree of contamination in the
CRZ generally will decrease as one moves from
the Hotline to the Support Zone.
Support Zone
1,
The Support Zone is defined as the
uncontaminated area where workers should not be
exposed to hazardous conditions. Any potentially
contaminated clothing, equipment, and samples
must remain outside of the Support Zone until
decontaminated. The Support Zone is the
appropriate location for the command post,
medical station, equipment and supply center, field
laboratory, and any other administrative or support
functions that are necessary to keep site operations
running efficiently. Because the Support Zone is
free from contamination, personnel working within
it. may wear normal work clothes, and access to
and from the area is not restricted for authorized
site personnel. Such personnel, however, should
receive instruction in the proper evacuation
procedures in case of a hazardous substance
emergency.
PART 2: SITE CHARACTERIZATION -- DATA
COLLECTION
To establish a Support Zone, the specific
hazards and the degree of potential employee
exposure at the site must be considered. The site
characterization, as specified in 29 CFR
1910.120(c), is the basis for developing the site
health and safely plan (HASP). and provides
information needed to identify site ‘iazards, select
proper PPE, and implement safc work practices.
Site chat acteri7at lofl generally proeecds in three pha.
• Prior to site entry, an off-site
characterization, including data gathering
and perimeter reconnaissance.
• An on-site survey.
• Ongoing monitoring to provide a
continuous source of information about
site conditions.
Off-site characterization and the on-site survey
are discussed below. Ongoing monitoring is
discussed in Part 4 of this Fact Sheet, Ensuring
Integrity of Work Zones.
Data-Gathering Prior to Initial Site Entry
The initial stages of site characterization must
be accomplished off-site, so as not to endanger the
health and safety of workers. For example, at new
uncontrolled hazardous sites, or at those sites with
areas that have not been evaluated, the range of
potential hazards and exposure risks is unknown.
As much information as possible should be
obtained during off-site characterization tO
evaluate the hazards and institute preliminary
controls for protecting initial entry personnel.
Once the off-site characterization is completed and
the appropriate information is obtained, the
information is used to develop an initial draft of
the site-specific HASP. (For more information on
developing a HASP, refer to the fact sheet
Hazardous Waste Operations and Emergency
Response: Uncontrolled Hazardous Waste SIZeS and
RCRA Corrective Action, OSWER Publication No.
9285.2-O8FS, 1991.)
29 CFR 1910. 120(c)(i) through (c)(viii)
identifies the generic information that must be
considered and evaluated before designated
personnel enter a site. These requirements are
listed in Exhibit 2, along with resources that can
be useful for obtaining the required information.
These information sources include general
background documents (e.g., area maps), site
records, interviews with persons who have
knowledge about the site, and perimeter
reconnaissance.
Interview/Records Research. Records of the
site or interviews with persons who have
knowledgc of the site can provide useful
information about the potential hazards at a site
I
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EXHIBIT 2
Information Required Prior to Site Entry
29 CFR 1910.120(c)(4)
Regulatory Requirements
Sources of Information
General
Background
References
Recordsllnterviews
Perimeter Reconnaissance
I
Site
Manager
Assessment
Site-Specific
Interviews
Visual
Sampling
Location, Size of Site (c)(4)(i)
/
/
,p
,,‘
Description of Job or Activity
to be Performed (c)(4)(ii)
,,‘
Activity Duration (c)(4)(iii)
/
Site Topography and
Accessibility (c)(4)(iv)
/
/
.
I , ’
i
Safety and Health Hazards at
Site (c)(4)(v)
I
I
I
I
I
Pathways for Hazardous
Substance Dispersion
(c)(4)(vi)
I
I
I
Status of Response Teams
(c)(4)(vii)
I
Hazardous Substances and
Health Hazards (c)(4)(viii)
I
I
I
I
I
Examples of records that may be useful are found
in Exhibit 3.
Perimeter Reconnaissance. In addition to the
interview/records research, data-gathering at the
site perimeter may help in identifying site hazards
and determining the appropriate level of PPE for
the initial site entry Many of the activities that
occur during perimeter reconnaissance, including
making visual observations, monitoring
atmospheric concentrations of airborne pollutants,
and collecting soil samples, are similar to the
activities that occur during the initial site entry.
Perimeter reconnaissance activities, however, are
generally not as extensive or specific as the
activities undertaken during the on-site survey. To
determine the scope and level of effort for the
perimeter reconnaissance, the information from
the interview/records research should be evaluated.
Historical data on chemicals stored at the site, for
example, may help to identify the appropriate air
monitoring techniques for the perimeter
reconnaissance.
Initial Site Entry and Data Collection
The goal of the on-site survey is to gather the
additional information needed to identify the risks
and hazards presented by the site, so that the work
zones can be established and the appropriate
controls, PPE, and medical monitoring program
can be selected for the tasks that will be performed
at the site Risks that should be considered are
specified in 29 CFR Part 1910.120 (c)(7) and are
listed in Exhibit 4.
Immediately upon entering the site, entry
personnel should monitor the air for immediately
dangerous to life and health (IDLH) and other
conditions that may cause death or serious harm
(e g., combustible or explosive atmospheres, oxygen
deficiency, toxic substances) and monitor for
ionizing radiation. in addition, entry personnel
should visually observe for signs of actual or
potential IDLH hazards or othcr dangerous
conditions. Exhibit 5 provides examples of visible
indicators of potential IDLH hazards and other
dangerous conditions.
4
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EXHIBIT 3
Sources of Site-Specific Information
• Company records, receipts, logbooks, or
ledgers that describe the activity that
occurred at the site.
• Waste storage inventories and manifests
or shipment papers.
• Records from state and federal pollution
control regulatory and enforcement
agencies, state Attorney General’s Office,
state occupational safety and health
agencies, state Fire Marshal’s office.
• Water and sewage district records.
• Previous survey, sampling, and ionitoring
results.
• Local fire and police department records
• Site and aerial photos.
• Media reports (all information from the
media should be verified)
• Interviews with personnel (all interview
information should be verified)
• Interviews with nearby residents (note
possible site-related medical problems and
verify all information from interviews).
• Maps (c g, USGS, land use, etc)
• Meteorological data (e.g., wind direction,
temperature profiles)
If IDLH hazards or other dangerous conditions
are not present, or if proper precautions can be
taken, the survey can continue. At a nuniniwii , the
ininal on-site survey should consist of a visual survey
for potential hazards and air monitoring.
Visual Survey. An accurate and
comprehensive visual survey of the site will assist
in identifying potential hazards and determining
where additional information (e.g., air monitoming,
sampling of soil or conlalneis) may be needed.
EXHIBIT 4
Risks to Consider
29 CFR 1910.120 (c)(7)
Risks to consider include, but are not limited
to:
• Exposure exceeding the permissible
exposure limits (PELS) and published
exposure levels.
• IDLH concentrations.
• Potential skin absorption and irritation.
• Potential eye irritation.
• Explosion sensitivity and flammability
ranges.
• Oxygen deficiency.
EXHIBIT 5
Visible Indicators of
Potential IDLH and Other
Dangerous Conditions
• Large containers or tanks that must be
entered.
Enclosed spaces such as buildings or
trenches that must be entered
• Potentially explosive or flammable
situations (indicated by bulging drums,
effervescence, gas generation, or
instrument readings)
• Extremely hazardous materials (such as
cyanide, phosgene, or radiation sources)
• Visible vapor clouds
• Areas where biological indicators (such as
dead animals or vcgciaiion) arc located
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This visual survey should include the following
activities:
• Noting the types of containers,
impoundments, or other storage systems
(e.g., paper or wood packages, barrels or
drums, tanks, lagoons).
• Noting the condition of waste containers
and storage systems (e.g., undamaged,
rusted or corroded, leaking)
• Noting the types and quantities of
material in containers (e.g., full or empty;
labels indicating corrosive, explosive,
flammable, radioactive, or toxic materials).
• Noting the physical condition of the
materials (e.g., solid, liquid, or gas,
conditions conducive to contact).
• Noting any unusual conditions (e.g.,
clouds, discolored liquids, oil slicks,
discolored soil, free-standing liquid,
stressed vegetation).
• Determining the potential pathways of
exposure and dispersion (e.g., air, soil,
surface water, ground water).
• Noting any indicators of potential
exposure to hazardous substances (e.g.,
dead fish, animals, or vegetation; pools of
liquids; foams or oils on liquid surfaces;
deteriorating containers; discolored soils).
• Identifying natural wind barriers (e.g.,
buildings, hills, tanks).
The results of the visual survey may help to
identify a potential location for the Support Zone,
which can be confirmed through air monitoring
and soil sampling.
Mr Monitoring. The purpose of air
monitoring is to identify and quantify airborne
contaminants in order to determine the level of
worker protect ion and identify additional medical
monitoring needs in any given area of the site Air
monitoring should be used to confirm that the
areas considered for the Support Zone do not
contain concentrations of hazardous substances
that require worker protcction The two methods
that generally arc available for identifying andfor
quantifying airborne contaminants are (1) on-site
use of direct-reading instruments and
(2) laboratory analysis of air samples obtained by
gas sampling bag, filter, sorbent, or wet-
contaminant collection methods.
Direct-reading instruments may be used to
rapidly detect flammable or explosive atmospheres,
oxygen deficiency, certain gases and vapors, and
ionizing radiation, as well as to identify changing
site conditions Because direct-reading instruments
provide information at the time of sampling and
allow for rapid decision-making, they are the
primary tools of initial site characterization. All
direct-reading instruments, however, have inherent
coiistraints in their ability to detect hazards.
Direct-reading instruments detect and/or measure
only specific classes of chemicals and are usually
not designed to detect airborne concentrations
below 1 ppm. In addition, many of the direct-
reading instruments that have been designed to
detect one particular substance also detect other
substances and, consequently, may give false
readings. Direct-reading instruments must be
operated, and their data interpreted, by qualified
individuals using properly calibrated instruments and
relying on chemical response curves. Additional
monitoring should be conducted at any location
where a positive instrument response occurs.
Exhibit 6 lists several direct-reading
instruments and the conditions and/or substances
they measure. Additional information concerning
direct-reading instruments is available in the
references.
Because direct-reading instruments are
available for only a few specific subsiances and are
rarely sensitive enough to detect low
concentrations of hazardous substances that may
nonetheless present health risks, air samples must
also be collected and analyzed in a laboratory
Exhibit 7 lists some sample collection and
analytical methods that are appropriate for certain
types of substances that are likely to be
encountered at hazardous waste sites. Additional
information concerning air sampling and
monitoring is available in the references listed in
Part 5 of this Fact Sheet.
Other Information. At some sites, air
monitoring, the visual survey, and consideration of
:IUivit ics Lhat will be occurriniz .ii the iic will be
6
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Instrument Hazard Monitored
adequate to determine the appropriate level of
PPE, to establish additional medical monitoring
needs, and to define work zones. For many sites,
however, consideration of planned site activities
may re eal the need for more extensive
environmental sampling. Analysis of surface soil
and soil borings may be required if site workers are
expected to be exposed to surface and subsurface
soil that max’ be contaminated Ground water or
surface water sampling may be necessary if site
workers are likely to be exposed via these media.
To determine whether additional monitoring is
required to designate work 7oncs, the results of the
air monitoring sur ey and visual characterization of
site hazards and contaminants should be reviewed
and potential l)ath ’aYS of contaminant dispersion
should be evaluated If there i any question that
coiiItimifl ifltS ma have rni iaied into the area
EXHIBIT 7
Some Air Sampling
Collection Methods
Substance Collection Device
Anions
Bromide
Chloride
Fluoride
Nitrate
Phosphate
Sulfate
Aliphatic or Silica gel
aromatic amines
High MW
hydrocarbons
Organophosphorus
compounds
Selected pesticides
Organics Charcoal tube
PCBs Glass fiber filter
and florisil tube
Pesticides 13mm glass fiber
filter/chromosorb
102 tube
PUF/filter
considered for the Support Zone, both air and
surface soil samples should be collected and
compared with on-site and off-site background
samples.
Soil sampling can be simple or complex,
depending on site conditions. Sampling plan
designs routinely fall into the following categories.
judgmental random, stratified random, systematic.
and search Priot to beginning any sampling
activities, it is imperative that the PLi POSC of the
cffoi t and ultimate USC of tlic acquired data he
est.ihlishcd Strategies should bc selected based on
the information required Cci tarn 1.11 get
EXHIBIT 6
Some Direct-reading
Air Monitoring Instruments
Prewashed silica
gel tube
Combustible Gas
Indicator (CGJ)
Flame Ionization
Detector (FID)
with Gas Chromo-
tography Option
Gamma Radiation
Survey Instrument
Portable Infrared
(IR) Spectro-
photometer
Ultraviolet (UV)
Photoionization
Detector (PID)
Direct-reading
Colorimetric
Indicator Tube
Oxygen Meter
Combustible gases
and vapors
Many organic gases
and vapors
Gamma radiation
Many g es and
vapors
Many organic and
some inorganic
gases and vapors
Specific gases and
vapors
Oxygen (02)
Asbestos
Metals
Particutates
Mixed cellulose
ester fitter
(MCEF)
Tenax/Chromosorb
7
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contaminants may warrant special considerations.
For example, when sampling for the extent of
contamination of a dioxin site, tiered sampling and
designed grid-laying approaches should be
considered to achieve the 95 percent confidence
level. Additional information concerning soil
sampling is available in the references listed in
Part 5 of this Fact Sheet.
PART 3: SITE CHARACTERIZATION --
SELECTION OF WORK ZONES
After the off-site and on-site data collection
are complete, the collected information is used to
establish work zones. In addition, the HASP is
revised to address the specific on-site hazards.
Data Compilation
All of the information should be compiled in
a format that facilitates a decision concerning the
placement of work zones. A site map can provide
a useful format for compiling the collected data.
The locations of all the potential hazards that were
identified through the interview/records research,
the perimeter reconnaissance, and the initial on-
site survey should be plotted on the map. The
map should indicate both the hazards that were
observed and any areas that interviews or records
suggest may be contaminated with hazardous
wastes. In addition, all sampling results from the
On-site and off-site surveys should be plotted on
the map. It is important to record locations where
hazardous substances were detected and locations
where hazardous substances were not detected.
The absence of sampling results should not be
considered evidence that an area is clean.
Information concerning exposure pathways,
particularly the predominant wind direction, also
should be included on the map.
Data Evaluation
After all available site characterization data
have been compiled, the data are used to select a
location for the Support Zone. One of the most
important criteria for selection of an area for thc
Support Zone is that it must be located in a clean
area The Support Zone should be in an area that
is known to be free of elevated (i.e. higher than
background) concentrations of hazardous
substances. When evaluating on-site
concentrations of hazardous substances, it is
important to consider the background
concentrations of these substances in the area.
Non-zero background concentrations of hazardous
substances may be present at some sites.
The size and position of the Support Zone
also may be directly affected by the size of the
exclusion and contamination reduction zones For
example, the Support Zone may be constrained by
the distances needed to prevent an explosion or
fire from affecting personnel outside the Exclusion
Zone, or the physical area required for activities in
the Exclusion Zone In addition, the Support
Zone should, whenever possible, be upwind from
the Exclusion Zone. The Support Zone should be
located as far from the Exclusion Zone as
practicable. Whenever possible, line-of-sight
contact with all activities in the Exclusion Zone
should be maintained. Accessibility to support
services (e.g., power lines, access roads, telephones,
shelter, and water) also must be considered in
selecting a Support Zone. The expected duration
of the removal action also will affect the placement
of work zones.
It is also conceivable that the Support Zone
may inadvertently become contaminated after site
remediation begins, despite everyone’s best efforts.
For example, changes in wind speed and direction,
temperature, and rainfall may result in exposures
different from those experienced during the initial
on-site survey. The integrity of the Support Zone
should be reconfirmed during remedial activities
PART 4: ENSURING INTEGRITY OF WORK
ZONES
Several procedures can be used to ensure that
the area chosen for the Support Zone remains
clean during removal or remedial operations. Use
of site controls will minimize the transfer 01
contamination to the Support Zone. In addition,
periodic monitoring ol the Support Zone will
indicate whether changes in site activities or
conditions have resulted in contamination In the
event that contamination has occuried, the
boundaries ol work ioncs should he reevaluated
Other Considerations
S
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Use of Site Controls
The CRZ is designed to reduce the probability
that the clean Support Zone will become
contaminated or affected by other site hazards.
The distance between the Exclusion and Support
Zones provided by the CRZ, together with
decontamination of workers and equipment, limits
the physical transfer of hazardous substances into
clean areas. The boundary between the Support
Zone and the CRZ, called the contamination
control line, separates the Support Zone from an
area of possible low contamination. Access to the
CRZ from the Support Zone should be through
two access control points, if feasible: one for
personnel and one for equipment. Persons
entering the CRZ should be required to wear PPE
appropriate for the degree and types of hazards
they may encounter when working in this area. To
reenter the Support Zone from thQ CRZ, workers
should remove gross contamination, doff any
protective clothing, leave equipment in the CRZ,
and exit through the personnel access control
point.
Periodic Monitoring of Support Zone
A monitoring and sampling program for the
Support Zone should be established to ensure that
this area remains free from contamination.
Monitoring should take place on a routine basis
and whenever exposure is likely to change.
Situations where additional monitoring may be
appropriate are specified in 29 CFR 1910.120
(h)(3) and are listed in Exhibit 8 Increased
concentrations of hazardous substances in air, soil,
or other environmental media may indicate a
breakdown in site control procedures or a change
in on-site conditions. In addition, site personnel
should be constantly alert to changes in site
conditions or the presence of any potentially
dangerous situations. Exhibit 9 lists the
monitoring and sampling activities that may be
conducted to ensure that the Support Zone
remains clean.
Considering Additional Site Characterization
Information
Additional information concerning locations of
contaminated environmental media may become
available during monitoring or in the later stages
of site investigation and clean up, IxirticularlY for
remedial actions. For example, more detailed soil
sampling will occur during the site inspection (SI)
and remedial investigation (RI). This additional
information may indicate that areas initially
considered clean are, in fact, contaminated The
location of the Support Zone should be
reevaluated whenever new site characterization
studies are conducted.
EXHIBIT 8
Conducting Additional Monitoring
29 CFR 1910.120 (h)(3)
Situations that require consideration of the
possibility that exposures have risen are:
• When work begins on a different portion
of the site.
• When contaminants other than those
previously identified are being handled
• When a different type of operation is
initiated (e.g, drum opening as opposed to
exploratory well drilling)
• When employees are handling leaking
drums or containers or working in areas
with obvious liquid contamination (e g, a
spill or lagoon).
EXHIBIT 9
Periodic Support Zone
Monitoring Activities
• Air monitoring using direct -reading
instruments.
• Collecting air samples for particulate, gas.
or apor analysis
• Analysis of soil samples from heavily
trafticked areas.
• Occasional swipe tests in trailers and other
areas used by pcrsonnel
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PART 5: CONSULTATION AND REFERENCES
For more information regarding work zones,
the following references may be consulted.
Federal Regulations
• OSHA Regulations (particularly 29 CFR
1910 and 1926)
EPA Regulation 40 CFR 311
Guidance Documents
The following publications explain site
operating procedures and guidelines, including
safety procedures for decontamination,
considerations for establishing work zones, and
sampling and monitoring programs:
• EPA Standard Operating Safety Guides;
U.S. Environmental Protection Agency,
Office of Emergency and Remedial
Response, Environmental Response Team,
OSWER Directive 9285.1-O1C, 1988.
• Field Standard Operating Procedures for
Establishing Work Zones F.S.O.P. 6, U.S.
Environmental Protection Agency, Office
of Emergency and Remedial Response,
OSWER Directive 9285.2-04, 1985.
• Field Standard Operating Procedures forAir
Surveillance F.S.O.P. 8; U.S.
Environmental Protection Agency, Office
of Emergency and Remedial Response,
OSWER Directive 9285.2-03, 1985.
• Environmental Response Team (ERT)
Standard Operating Procedures, Soil
Sampling SOP # 2012, U.S.
Environmental Protection Agency,
Environmental Response Team, 1988.
• Occupational Safety and Health Guidance
Manual for Hazardous Waste SiteActiviries;
NIOSH/OSHA/uscG/EpA, DHHS
(NIOSH) Publication Number 85-1 15,
GPO No 017-033-00419-6, 1985
The following publication provides step-by-step
guidance for assessing prel iminaty evaluations.
health and safety plans, and off-site emergency
response plans:
• EPA Health and Safety Audit Guidelines;
U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency
Response, Emergency Response Division,
EPA-540/G-89/O10, OSWER Directive
9285.8-02, 1989.
The following publications provide general
information concerning the development of a
specific health and safety program for workers at
hazardous waste sites:
• EPA Standard Operating Safety Guides;
U.S. Environmental Protection Agency,
Office of Emergency and Remedial
Response, Environmental Response Team,
OSWER Directive 9285.1-O1C, 1988.
• Field Standard Operating Procedures for
Site Safety Plan F.S.O.P. 9; U.S.
Environmental Protection Agency, Office
of Emergency and Remedial Response,
OSWER Directive 9285.2-05, 1985.
• Generic Site Safety Plan; U.S.
Environmental Protection Agency,
OSWER Directive 9285.8-01.
• Occupational Safety and Health Guidance
Manual for Hazardous Waste Site Activities,
NIOSH/OSHA/USCG/EpA, DHHS
(NIOSH) Publication Number 85-115,
GPO No. 017-033-00419-6, 1985.
The following two volumes entitled
Characterization of Hazardous Waste Sites - A
Methods Manual address issues related to
characterization of hazardous waste sites, from
preliminary data gathering to sampling and
analysis:
• Volume I - Site Investigations; U.S.
Environmental Protection Agency, Office
of Research and Development.
Environmental Monitoring Systems
Laboratory, Las Vegas, NV, EPA-
600/4-84/075, 1985.
• Volume II - Available Sampling Methods.
Second Edition; U.S. Environmental
Protection Agency, Office of Research and
Development, Environmental Monitoring
Systems Laboratory, Las Vegas, NV, EPA-
600/4-84/076, 1984
10
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The following publication provides information
on sampling design and associated statistical
methods for determining contaminant
concentrations:
• Methods for Evaluating the Attainment of
Cleanup Standards, Volume I : Soil and
Solid Media; U.S. Environmental
Protection Agency, Office of Policy,
Planning, and Evaluation, EPA-
230/02-89-042, 1989.
The following publication provides guidance
for using portable instruments for assessing
airborne pollutants arising from hazardous waste:
• Draft International Document on Guide to
Portable Instruments forAssessingAirborne
Pollutants Arising from Haz rdous Wastes;
U.S. National Working Group (NWG-4
OIML) Pilot Secretariat PS-17:
“Measurement of Pollution” Reporting
Secretariat RS-5: “Measurement of
Hazardous Waste Pollution.” ISBN: 0-
936712-75-9.
The following four volumes collectively
entitled Procedures for Conducting Air Pathway
Analyses for Superfund Applications address a
variety of issues relevant to the air impacts at
Superfund sites:
• Volume I Application of Air Pathway
Analyses for Superfund Applications; U:S.
Environmental Protection Agency, EPA-
450/1-89-001, 1989. . NTIS PB9O
113374/AS.
• Volume II: Estimation of Baseline Air
Emissions at Superfund Sites; U.S.
Environmental Protection Agency, EPA-
450/1-89-002, 1989. NTIS PB89
180053/AS.
• Volume III: Estimation of Afr Emissions
from Clean-up Activities at Superfund Sites;
U.S. Environmental Protection Agency,
EPA-450/1-89-003, 1989. NTIS PB89
180061/AS.
• Volunie IV. Procedures for Dispersion
Modelling andAir Mon itonng for Superfund
Air Pathway Analysis; U.S. Environmental
Protection Agency, EPA-450/1-89-004, 1989. NTIS
PB9O 113382/AS.
Fact Sheets
The following fact sheet provides a sumrnaiy of
the federal regulations at 29 CFR 1910.120 and 40
CFR 311, as they pertain to worker protection at
uncontrolled hazardous waste sites:
• Hazardous Waste Operations and
Emergency Response: Uncontrolled
Hazardous Waste Sites and RCR.4
Corrective Action; U.S. Environmental
Protection Agency, Environmental
Response Team, OSWER Publication No.
9285.2-O8FS, 1991.
The following fact sheet provides a list and
description of computer software, fact sheets,
guidance documents and ERT training programs
that pertain to the worker protection standards:
• Hazardous Waste Operations and
Emergency Response: Available Guidance;
U.S Environmental Protection Agency,
Environmental Response Team, OSWER
Publication No. 9285.2-1OFS, 1991.
Contact Persons or Groups
Several contact persons or groups can provide
additional information on the establishment of
work zones at uncontrolled hazardous waste sites.
These contacts include:
• U.S. EPA’s Environmental Response Team
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or (Fl ’S) 340-6740
• U.S. Department of Labor, OSHA
Office of Health Compliance Assistance
200 Constitution Avenue, NW
Washington, D.C. 20210
(202) 523-8036 or (FTS) 523-8036
In addition, addresses and telephone numbers
for EPA and OSHA regional offices arc listed in
Exhibit [ 0.
Ill
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EXHIBIT 10
Regional Addresses and Telephone Numbers
EPA Regional Offices
OSI-IA Regional Offices
• EPA Region 1
John F. Kennedy Federal Building
Room 2203
Boston, MA 02203
(617) 565-3715 or (Fl ’S) 835-3715
• EPA Region 2
Jacob K. Javitz Federal Building
26 Federal Plaza
New York, NY 10278
(212) 264-2657 or (Fl’S) 264-2657
• EPA Region 3
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-9800 or (Fl’S) 597-9800
• EPA Region 4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727 or (FTS) 257-4727
• EPA Region 5
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000 or (FTS) 353-2000
• EPA Region 6
1445 Ross Avenue, 9th Floor
Dallas, 1’X 75202
(214) 655-6444 or (Fl’S) 255-6444
• OSHA Region 1
133 Portland Street, 1st floor
Boston, MA 02114
(617) 565-7164 or (FTS) 835-7164
• OSHA Region 2
201 Varick Street, Room 670
New York, NY 10014
(212) 337-2325 or (Fl’S) 660-2378
• OSHA Region 3
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
(215) 596-1201 or (FTS) 596-1201
• OSHA Region 4
1375 Peachtree Street, NE, Suite 587
Atlanta, GA 30367
(404) 347-3573 or (Fl’S) 257-3573
• OSI-IA Region 5
230 South Dearborn Street
32nd floor, Room 3244
Chicago, IL 60604
(312) 353-2220 or (FTS) 353-2220
• OSHA Region 6
525 Griffin Street, Room 602
Dallas, TX 75202
(214) 767-4731 or (FTS) 729-4731
• EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66115
(913) 551-7000 or (FTS) 276-7000
• OSHA Region 7
911 Walnut Street
Kansas City, MO
(816) 426-5861 or
64106
(FTS) 867-5861
• EPA Region 8
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1603 or (FTS) 293-1603
• EPA Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322
• EPA Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-1200 or (FTS) 399-I 200
• OSHA Region 8
1951 Stout Street
Denver, CO 80204
(303) 844-3061 or (Fl’S) 564-3061
• OSHA Region 9
71 Stevenson Street, Suite 415
San Francisco, CA 94105
(415) 744-6670 or (Fl’S) 484-6670
• OSHA Region 10
Ill! Third Avenue, Suite 715
Seattle, WA 98101-3212
(206) 442-5930 ot (Fl’S) 3 )9-593()
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