SEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9375.1-2A-C
' *-*•'• APPENDIX M, SITE SAFETY PLAN GUIDANCE
APPROVAL DATE: 12/30/86
EFFECTIVE DATE:
ORIGINATING OFFICE: OERR
D FINAL
0 DRAFT
CTATI 1C-
IUO. C - REG. REVIEW AND COMMENTS
REFERENCE (other documents):
OS WER OS WER OSWER
/£ DIRECTIVE DIRECTIVE DI
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DC 20460
Protection Agency Interim Direcive Numter
Initiation Request I -21L c
Information
i Teieønone Numoer
3R2-?4 ,3
Ap coveC to’ Review
Date
1?’
State Project Managers in
plans for CFRCLA remedial
on health and safety
Regional office safety
q ’)
St tus
‘ ah DN w
F,nal Revison
No Does It Supp lement Previous Directivefs)
0 Ocher f5oecf )
Date
/f/4 /i6
Sign atj 1e o OSWER Di’ectii4, Officer
)
Date
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D C 20460
Di recti ve No.
9375.1-2A-C
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Revisions to Appendix M, "Site Safety Plan" in the
State Participatjjxa in the Superfund Program manual
FROM: ; Sam Morp.kas ,
yr^State and Regi
T(f: Mail ing List
Coordi nati on Branch
As part of a continuing effort to pnsure accuracy with
recent policy directivps, the attached Appendix M has heen
revised to provide State Project Managers with thp most
current procedures in developing and reviewing site safety
plans. Any changes to Appendix M are primarily editorial in
nature; no suhstantive revisions to the text are seen as
necessary at this time.
The version of Appendix M which you presently have should
be discarded and he replaced with this attachment.
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12/2 0/85
cHAN3ES ‘10 DATE
Date/
Adaendun # Topic Instruction Location/Page
6/22/84 #1 Site Closeout . New pages . Appendix F, Pages F-22
and 23
• New page . Appendix H, Page H-23
• New pages . Appendix P, Pages
P—37 —P—47
Minority and • New page . Appendix F, Page F-24
Wcinen’s Business
Reporting
Changes to IG . Change . Appendix C, Page C-12,
Audit which must first complete paragraph
be sent within
120 days.” to
“... which
must be sent
within 90 days.”
• Add, as the . Appendix C, Page C-12
second sentence first complete paragra
in the para-
graph, “In
addition, the
Award Official
will send the
State a co ’ of
the final audit
report within 15
days of its
receipt.”
• Change “The re- . Appendix C, Page C-12
sponse must be foothote
dispatched with-
in 120 days...”
to “The response
must be dis-
patched within
90 days...”
9/12/84 #2 Qiality Assurance . New pages . Appendix L, formerly
Project Plan reserved
9/28/84 #3 Revised Letter of • Replacaiient pages • Appendix F, Pages F-3
Credit Procedures through F-6
Provision
iii
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12/2 0/85
1AI KES IO DATE (Continued)
Multi-Site Coop-
erative Agreements
• Replacement
pages
• Replacement
pages
• Replacement
pages
• Replacement
pages
• New pages
• Replacement
page
• New pages
• Replacement
pages
• New pages
• Replacement
page
• New page
• Replacement
pages
• New page
• Change “...at
quarterly inter-
vals conmencing
at the start of
the project.” to
“...within 30
days of the end
of the Federal
fiscal quarter.”
• New pages
• Replacement
pages
• New pages
• Replacement
pages
• Replacement
pages
• New pages
3, Pages 13-1,
J7
J, Pages 13-8
N, Pages N-i
Date!
Addend un #
12/10/84 #4
Topic
Instruction
Location/Page
• Table of Contents, Pages
xiii through Xvii
• List of Exhibits, Pages
xvii and xix
• List of cronyms, Pages
a - through e
• Chapter II, Pages 11-1
through 6
• Chapter II, Page 11-7
and Exhibit 11-2
• Chapter III, Page 111-17
• Chapter III, Pages
11 1-18 through 27 and
Exhibits 111-10 and
11 1—11
• Chapter IV, Pages
IV-5 through P1-7
• Chapter IV, Pages P1-8
through P1-li
• Chapter V, Page V-7 and
• V-8
• Chapter V, Page V-9
• Appendix E, Pages E-l
through E-22
• Appendix E, Page E-23
• Appendix F, Page F-16,
Section K, indented
paragraph
• Appendix F, Pages F-25
and F-26
• Appendix
13-2, and
• Appendix
arid J-9
• Appendix
through N-6
• Appendix P, Pages P-i,
P-2, and P-47
• Appendix P, Pages P-48
through P-51
iv
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12/2 0/85
Q1N GES 110 DATE (Continued)
Date/
Addendum # Topic Instruction Location/Page
1/4/85 #5 Advance Match New pages . New Appendix S, Pages
S-i through S-9
1/11/85 #6 Site Safety Plan New pages Appendix M, formerly
Guidance reserved
8/2/85 #7 Obtaining E uipT ent . New pages . New Appendix T, Pages
Under a CEFCLA T-1 through T-15
Cooperative Agreement
9/17/85 #8 Intergovernmental . Rep].acement page . Table of Contents, Pages
Review Procedures Xiii through xix
Replacement pages . List of E chibits, Pages
xx and xxi
Appendix D, Pages D-1
through D-28
State Cooperative New pages . Appendix A, formerly
Agreements for Pre- reserved
Remedial Activities
12/18/85 #9 Action M xrandum Replacement pages Table of Contents, Pages
Guidance . Replaceffent pages xiii through xix
Appendix B, Pages
B-l through B-9
12/20/85 #10 Model Statement of . Replacement pages Table of Contents, Pages
Work for a Remedial X lii through xix
Investigation/ . Appendix E, Pages
Feasibility Study E-l through E-21
12/20/85 #11 Site Safety Plan Replacement pages . Table of Contents, Pages
Guidance xiii through xix
Replacement pages . Appendix M, Pages M-l
through M-28
iva
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TABLE OF CONTENTS
12/20/85
Revised Page xiii
PAGE DATE
LIST OF ACRONYMS AND ABBREVIATIONS a 12/10/84
I. INTRODUCTION I—i
A. Purpose of the Manual 1—2
B. Background —— Key Terms I— li
3.1 Remedial Response 1—4
B.2 Remedial Response Agreements 1—4
B.3 State Assurances 1—5
B.3.a Cost—Sharing 1—5
B.3.b Off—Site Treatment, Storage, 1—6
or Disposal
B.3.c Operation and Maintenance (O&M) 1—7
B.4 State Credits 1—7
C. Overview of the Manual I—i
II. CONCURRENT ADMINISTRATIVE EVENTS II—]. 12/10/84
A. Initiation of Enforcement Activities 11—2
B. Initiation of Forward Planning 11—2
C. Development of Site—Specific Schedules 11—5
D. Development of the Remedial 11—5
Accomplishments Plan (RAP)
E. Development of the Action Memorandum 11—5
F. Identification and Review of State 11—6
Credit Submissions
G. Intergovernmental Review 11—7
I I I. DEVELOPMENT OF COOPER.AT IVE AGREEMENT I I I—i
APPLICATION PACKAGES
A. Completion of the Cooperative Agreement 111—2
Application Form
xiii
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12/20 /8 5
Revised Page xiv
PAGE DATE
A.1 Part Iv — Project Narrative 111—2
St atement
A.2 Part III — Project Budget 111—3
A.2.a Allowable Costs 111—4
A.2.b Enforcement Costs 111—5
A.2.c Calculation of State Cost Share 111—5
B. Development of Cooperative Agreement 111—6
Provisions
B.1 General Assistance Requirements 111—6
B.2 Superfund Program Requirements 11 1—7
B.2.a Provision of CERCLA 111—8
Section 104(c)(3) Assurances
B.2.b The National Environmental 111—9
Policy Act of 1969 (NEPA)
B.2.c Quality Assurance/Quality 111—10
Control (QA/QC)
B.2.d Site Safety Plan Ill—li
B.2.e Expedited Procurement 111—12
C. Completion of the Procurement System 111—12
Certification Form
D. Other Submissions 111—13
D.1 Community Relations Plan (CRP) 111-13
D.1.a Draft Community Relations 111—13
Plan
D.1.b Complete Community 111—14
Relations Plan
D.2 Certi fication Letter 111—15
D.3 Intergovernmental Review Comments 111—15
E. Deviation Requests to Permit the 111—15
Allowability of Pre—Award Costs
F. Multi—Site Cooperative Agreements 111—17 12/10/84
F.1 Activities That May Be Included 111—18
in Multi—Site Cooperative
Agreements
F.2 Intergovernmental Review 111—19
F.3 Contents of a Multi—Site Cooperative 111—20
Agreement
xiv
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12/20/85
Revised Page xv
PAGE DATE
F.3.a Cooperative Agreement 111—20
Application Form
F.3.b Multi—Site Cooperative 111—23
Agreement Application
Provisions
F.3.c Procurement System 111—23
Certification Form
F.3.d Certification and 111—23
Enforcement Letters
F.4 Accounting for Multi—Site 111—24
Cooperative Agreements
F.5 Administration of Multi—Site 111—26
Cooperative Agreements
F.5.a Project Management 111—26
F.5.b Project/Budget Periods 111—26
F.5.c Quarterly Reports 111—27
IV. DEVELOPMENT OF EPA-LEAD REMEDIAL PLANNING IV—1
AGREEMENTS
A. The Scope of Work for Remedial Planning IV—3
B. Documentation of Terms and IV—3
Responsibilities
B.1 EPA Responsibilities IV—3
3.2 State Responsibilities IV—4
B.3 General Terms IV—4
C. Other Submissions IV—5
C.1 Community Relations Plan (CRP) tV—S
C.2 Intergovernmental Review Comments IV—6
D. Management Assistance Cooperative IV—6 12/10/84
Agreements
V. DEVELOPMENT OF SUPERFUND STATE CONTRACTS V-i
A. Development of the Statement of Work (SOW) V—2
B. Development of State Cost—Sharing Terms V—2
B.l Calculation of the State’s Cost Share V—2
B.2 Negotiation of Payment Terms ‘ 1—3
C. Documentation of Other Terms and V—4
Responsibilities
xv
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12/20/85
Revised Page xvi
PAGE DATE
C.1 EPA Responsibilities V—4
C.2 State Responsibilities V—5
C.3 General Terms V—6
D. Other Submissions V—7
D.i Community Relations Plan (CRP) V—7
D.2 Certification Letter V—8
D.3 Intergovernmental Review Comments V—8
E. Multi—Site Superfund State Contracts V—8 12/10/i
VI. EXECUTION OF REMEDIAL AGREEMENTS VI-1
A. Review of the Draft Agreement VI—1
A.1 Review of the Draft Cooperative VI—2
Agreement Application Package
A.2 Review of the Draft EPA—Lead VI—2
Subm IS Si Ofl
B. Final Regional Review and Preparation VI—2
of the Concurrence Package
C. Approval and Execution VI—4
VII. ADMINISTRATION OF REMEDIAL AGREEMENTS VU-i
A. Monitoring Financial Commitments Vu—i
A.l State Drawdowns Under a Cooperative VII—2
Agreement
A.2 State Payment of Cost Share Under VII—3
a Superfund State Contract
B. Monitoring Technical Commitments VII—3
B.l Monitoring Site Activities VII—4
B.2 Monitoring State Assurances and VU—S
Compliance with Special Conditions
C. Coordinating EPA—Lead Remedial Agreements VII-5
with Performance Agreements
D. Documenting Remedial Activity VII-6
xvi
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12/20 /8 5
Revised Page xvii
PAGE DATE
D.1 Regional Files VIt—6
D.2 EPA Headquarters Files VII—6
D.3 State Files VII—7
E. Documenting Completion of Remedial
Implementation (RESERVED]
VIII. AGREEMENT MODIFICATIONS VII I—i
A. Project Adjustments VIII—l
A.1 Adjustments to State—Lead Projects VIII—l
A.2 Adjustments to EPA—Lead Projects VIII—2
B. Initiation of Remedial Design and VIII—3
Remedial Action
B.1 Records of Decision (RODs) VIII—3
B.2 Incorporating Remedial Design and VIII—6
Remedial Action into an
Agreement Between EPA and the State
C. Initiation of Operation and Maintenance VIII—7
xvii
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the Appendices
PA/SI Guidance
Action Memorandum Guidance
Procedures for Developing and Processing
CERCLA State Credit Claims
Procedures for Implementing Intergovern-
mental Review
Model Statement of Work for State—lead
Remedial Investigation/Feasibility Study
Projects
— Sample Cooperative Agreement Application
Provisions
— Sample Cooperative Agreement Application
Package
— Sample Articles for Superfund State
Contracts and Other EPA—Lead Remedial
Agreements
— Sample Superfund State Contract
— Sample Certification Letters
— Sample Community Relations Plan Format
and Sample Plan (CR ?)
— Sampi’e Quality Assurance/Quality Control
Plan
— Sample Site Safety Plan
— Instructions for Using Superfund Letter
of Credit Account Numbers Under
Cooperative Agreements
— Sample Record of Decision (ROD)
— Selected EPA Policy Papers
— Glossary of Terms
A—i 9/17/85
B—i 12/20/85
C-i
D— 1
E- 1
9/17/85
12/10/84
I—i
J—l 12/10/84
K—i
L— 1
M-1
N-i
9/12/84
12/20/85
12/10/84
12/20 /8 5
Revised Page xviii
APPEND ICES
Introduction to
Appendix A -
Appendix B —
Appendix C —
Appendix D —
Appendix E —
Appendix F
Appendix G
Appendix H
Appendix I
Appendix J
Appendix K
Appendix L
Appendix M
Appendix N
Appendix 0
Appendix P
Appendix Q
F—i
G— 1
H-i
0-i
P—i
Q- 1
xvii I
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12/20/85
Revised Page xix
Appendix R — List of References R—1
Appendix S — Advance Match Procedures S—i 1/4/85
Appendix T — Obtaining Equipment for Use Under T—1 8/9/85
a CERCLA Cooperative Agreement
xix
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9/17/85
Replacement Page xx
LIST OF EXHIBITS
Exhibit
Mumber TITLE
1—1 Site Chronology
1—2 Document Outline
u—i Concurrent Administrative Events
11—2 Sample SOW for State—Lead Forward Planning
Act iv it i e S
111—1 Development of Cooperative Agreement Application
Packages
111—2 Cooperative Agreement Application Package
Checklist
111—17 Figures for Use in Estimating Total State—Lead
Remedial Action Costs
111—4 Object Class Categories for Use in Completing
the Cooperative Agreement Application
111—5 Itemization of Object Class Categories:
Appropriate Level of Detail
111—6 State Cost—Share Calculations
111—7 Summary of Requirements for Procurement Under
Assistance Agreements (40 CFR 1717)
111—8 Summary of Superfund Program Provisions for
Cooperative Agreement Applications
111—9 Methods for Expediting Procurement
111-10 Examples of Options for Awarding and Managing
Multi—Site Cooperative Agreements
I l l—Il Sample MSCA Obligation Document
iv—i Development of Memoranda of Understanding
v—i Development of Superfund State Contracts
xx
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9/17/85
Replacement Page xxi
LIST OF EXHIBITS
Exhibit
Number TITLE
V-2 Figures for Use in Estimating Total EPA—Lead
Remedial Action Costs
V—li State Cost—Share Calculations
VI—1 Execution of Remedial Agreements
VI—2 Agreement Review and Approval Process
VI—l7 Suggested Format for the Decision Memorandum
Vu—i Administration of Remedial Agreements
VIII—1 Agreement Modifications
A—i Pre—Remedial Screening Process
A-2 CERCLA Information System (CERCLIS)
A—17 Application For Federal Assistance, Part III
Table 1 Sample Format for Pre—Remedial Program Report
Table 2 Sample Format for Work Hours Per Site (Pre—Rernedial)
Table 17 Sample Format for Expense Report (Pre—Remedial)
Table 4 Sample Format for Site Additions and Substitutions
(Pre—Remedial)
Table 5 Revised Schedule of Pre—Remedial Accomplishments
C—i Overview of Procedures for Processing State
Credit Claims
N—i Superfund Remedial Activities Code List for
Cooperative Agreements
N—2 Financial Status Report Form and Instructions for
Its Completion
T—l Sample Usage Charge Calculation
T—2 Accounting Example
xxi
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APPENDIX M
SITE SAFETY PLAN GUIDANCE
12/20 /8 5
Revised
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12/20/85
Revised Page M—1
APPENDIX M
SITE SAFETY PLAN GUIDANCE
PURPOSE
This appendix has been extracted from the Standard
Operating Safety Guidelines (SOSG), issued by EPA ’s Office
of Emergency and Remedial Response (OERR), ar..d is in ac-
cordance and consistent with the procedures for employee
health and safety contained in EPA s Occupational Health
and Safety Manual (Chapter 9, Hazardous Substances Re-
sponses) May 5, 1985. It is provided here to assist State
Project Officers (SPOs) and Remedial Project Managers
(RPMs) in developing and reviewing site safety plans for
CERCLA remedial response projects. Since field work at a
site may not begin until an acceptable site safety plan is
approved, State and Regional personnel should be familiar
with this appendix and the entire SOSG. The guides are
not meant to be a comprehensive safety manual for incident
response. Rather, they provide information in health and
safety to supplement and complement existing Regional
office safety procedures.
BACKGROUND
All CERCLA projects must have in place a site safety
plan which establishes the requirements and procedures for
protecting the health and safety of all on—site person-
nel. It should present, in a logical format, information
about the site and instructions for preparing for and re-
sponding to potential health and safety hazards. Further,
the site safety plan must specify the Levels of Protection
necessary for each field activity, establish detailed in-
structions for responding to emergency situations, list
key safety personnel and describe monitoring
requirements.
Responsibility for developing the site safety plan
depends on whether the State or EPA is leading the reme-
dial project. For State—lead remedial response, the State
(or its contractor) will prepare the plan and submit it to
EPA for review; for Federal—lead projects, an EPA con-
tractor will develop the plan.
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Revised Page M—2
APPENDIX SUMMARY
This appendix explains the key elements of a site
safety plan. It is organized into five parts, as follows:
• Information on how to prepare a site safety plan
• Suggested plan for emergency operation codes
• Safety Check—off Sheet
• Suggested format for a site safety plan
• Sample site safety plan (from the Occupational
Health and Safety Manual).
The body of this appendix is actually Part 9 of the SOSG
and should be used in conjunction with the entire docu-
ment. The SOSG give detailed information on various as-
pects of health and safety protection for personnel at a
hazardous waste site and are applicable to removal and
remedial projects. Any questions on the content of this
appendix or on the SOSG should be directed to: EPAs
Safety and Occupational Health Officer, Hazardous Response
Support Division, Woodridge Avenue, Building 10, Edison,
New Jersey 08837. (Phone: (201) 321—6745 or FTS 340—6745).
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Revised Page M—3
SITE SAFETY PLAN
I. INTRODUCTION
The purpose of the site safety plan is to establish
requirements for protecting the health and safety of re-
sponders during all activities conducted at an incident.
It contains safety information, instructions, and
procedures.
A site safety plan must be prepared and reviewed by
qualified personnel for each hazardous substance re-
sponse. Before operations at an incident commence, safety
requirements must be written, conspicuously posted or dis-
tributed to all response personnel, and discussed with
them. The safety plan must be periodically reviewed to
keep it current and technically correct.
In non—emergency situations, for example, long—term
remedial action at abandoned hazardous waste sites, safety
plans are developed simulaneously with the general work
plan. Workers can become familiar with the plan before
site activities begin. Emergency response generally re-
quires verbal safety instructions and reliance on existing
standard operating procedures until, when time permits, a
plan can be written.
The plan must contain safety requirements for routine
(but hazardous) response activities and also for unex-
pected site emergencies. The major distinction between
routine and emergency site safety planning is the ability
to predict, monitor, and evaluate routine activities. A
site emergency is unpredictable and may occur anytime.
I I. GENERAL REQUI REMENTS
The site safety plan must:
— Describe the known hazards and evaluate the risks
associated with the incident with the incident
and with each activity conducted.
— List key personnel and alternates responsible for
site safety, response operations 1 and for protec-
tion of public.
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Revised Page M—4
— Describe Levels of Protection to be worn by
personnel.
— Delineate work areas.
— Establish procedures to control site access.
— Describe decontamination procedures for personnel
and equipment.
— Establish site emergency procedures.
— Address emergency medical care for injuries and
toxicological problems.
— Describe requirements for an environmental sur-
veillance program.
— Specify any routine and special training required
for responders.
— Establish procedures for protecting workers from
weather—related problems.
III. SITE SAFETY PLAN SCOPE AND DETAIL
The plans scope, detail, and length is based on:
— Information available about the incident.
— Time available to prepare a site—specific plan.
— Reason for responding.
Three general categories of response exist — emergencies,
characterizations and remedial actions. Although consid-
erations for personnel safety are generic and independent
of the response category, in scope, detail, and length
safety requirements and plans vary considerably. These
variations are generally due to the reason for responding
(or category of response), information available, and the
severity of the incident with its concomitant dangers to
the responder.
A. Emergencies
1, Situation:
Emergencies generally require prompt action
to prevent or reduce undesirable affects. Imme—
diate hazards of fire, explosion, and release of
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Revised Page M—5
toxic vapors or gases are of prime concern.
Emergencies vary greatly in respect to types and
quantities of material, numbers of responders,
type of work required population affected, and
other factors. Emergencies last from a few hours
to a few days.
— Information available: Varies from
none to much. Usually information
about the chemicals involved and their
associated hazards is quickly obtained
in transportation—related incidents, or
incidents involving fixed facilities.
Determining the substances involved in
some incidents, such as mysterious
spills, requires considerable time and
effort.
— Time available: Little time, generally
requires prompt action to bring the
incident under control.
— Reason for response: To implement
prompt and immediate actions to control
dangerous or potentially dangerous
situations.
2. Effects on Plan
In emergencies 1 time is not available to
write lengthy and detailed safety plans. Deci-
sions for responder safety are based on a contin-
ual evaluation of changing conditions. Respond-
ing organizations must rely on their existing
written standard operating safety procedures or a
generic plan, and verbal safety instructions
adapted to meet site—specific conditions. Since
heavy reliance is placed on verbal safety in-
structions an effective system to keep all re-
sponders informed must be established. Whenever
possible 1 these incident—specific instructions
should be written.
B. Incident Characterization
1. Situation:
In non—emergency response, for example, pre—
liminary inspections at abandoned waste sites or
more comprehensive waste site investigations the
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Revised Page M—6
objective is to determine and characterize the
chemicals and hazards involved, the extent of
contamination, and risks to people and the envi—
roninent. In general, initial inspections, de—
tailed investigations, and extent of contarnina—
tion surveys are limited in the activities that
are required and number of people involved.
Initial or preliminary inspections generally re-
quire 1—2 days. Complete investigations may last
over a longer time period.
— Information available: Much background
information. Generally limited on—site
data for initial inspection. On—site
information more fully developed
through additional site visits and
investigations.
— Time available: In most cases adequate
time is available to develop written
site—specific safety plan.
— Reason for response: To gather data to
verify or refute existing information,
to gather information to determine
scope of subsequent investigations, or
to collect data for planning remedial
action.
2. Effects on Plan:
Sufficient time is available to write safety
plans. In scope and detail, plans tend to be
brief, containing safety requirements for speci-
fic on—site work relevant to collecting data. As
information is developed through additional in-
vestigations, the safety plan is modified and, if
necessary, more detailed and specific require-
ments added.
C. Remedial Actions
1. Situation:
Remedial actions are cleanups which last
over a long period of time. They commence after
more immediate problems at an emergency have been
controlled, or they involve the mitigation of
hazards and restoration of abandoned hazardous
waste sites. Numerous activities are required
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Revised Page M—7
involving many people, a logistics and support
base, extensive equipment, and more involved work
activities. Remedial actions may require months
to years to completely accomplish.
— Information available: Much known
about on—site hazards.
— Time available: Ample time for work
planning.
- Reason for response: Systematic and
complete control, cleanup, and
restoration.
2. Effects on Plan:
Since ample time is available before work
commences, site safety plan tends to be compre-
hensive and detailed. From prior investigations
much detail may be known about the materials or
hazards at the site and extent of contamination.
IV. SITE SAFETY PLAN DEVELOPMENT
To develop the plan as much backgrbund information as
possible should be obtained, time permitting, about the
incident. This would include, but not be limited to:
— Incident location and name.
— Site description.
— Chemicals and quantities involved.
— Hazards associated with each chemical.
— Behavior and dispersion of material involved.
— Types of containers, storage, or transportation
methods.
— Physical hazards.
— Prevailing weather condition and forecast.
— Surrounding populations and land use.
— Ecologically sensitive areas.
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— Facility records.
— Preliminary assessment reports.
— Off—site surveys.
— Topographic and hydrologic information.
The information initially available or obtained
through subsequent characterization provides a basis for
developing a site—specific safety plan. Information is
need about the chemicals and hazards involved, movement of
material on and off the site, and potential contact with
responders or the public. This type of information is
then used along with the reason for responding (and work
plan) to develop the safety plan. The plan is tailored to
the conditions imposed by the incident and to its environ-
mental setting. As additional information becomes avail-
able the safety plan is modified to protect against the
hazards discerned and to provide for site emergencies that
may occur.
V. ROUTINE OPERATIONS
Routine operations are those activities required in
responding to an emergency or a remedial action at a haz-
ardous waste site. These activities may involve a high
degree of risk, but are standard operations that all inci-
dent responses may require.
Safety practices for routine operations closely par-
allel accepted industrial hygiene and industrial safety
procedures. Whenever a hazardous incident progresses to
the point where operations become more routine, the asso-
ciated site safety plan becomes a more refined document.
As a minimum, the following must be included as part of
the site safety plan for routine operations.
- Describe the Known Hazards and Risks . This must
include all known or suspected physical, biologi-
cal, radiological, or chemical hazards. It is
important that all health related data be kept
up—to—date. As air, water, soil, or hazardous
substance monitoring and sampling data becomes
available, it must be evaluated, significant risk
or exposure to workers noted, potential impact on
public assessed, and changes made in the plan.
These evaluations need to be repeated frequently
since much of the plan is based on this
information.
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— List Key Personnel and Alternates . The plan must
identify key personnel (and alternates) respon-
sible for site safety. It should also identify
key personnel assigned to various site opera-
tions. Telephone numbers, addresses, and organi-
zations of these people must be listed in the
plan and posted in a conspicuous place.
— Designate Levels of Protection to Be Worn . The
Levels of Protection to be worn at locations on—
site or by work functions must be designated.
This includes the specific types of respirators
and clothing to be worn for each level. No one
shall be permitted in areas requiring personnel
protective equipment unless they have been
trained in its use and are wearing it.
— Delineate Work Areas . Work areas (exclusion
zone, contamination reduction zone, and support
zone) need to be designated on the site map and
the map posted. The size of zones, zone boun-
daries, and access control points into each zone
must be marked and made known to all site workers.
— List Control Procedures . Control procedures must
be implemented to prevent unauthorized access.
Site security procedures — fences, signs, secur-
ity patrols and check—in procedures must be es-
tablished. Procedures must also be established
to control authorized personnel entry into work
zones where personnel protection is required.
— Establish Decontamination Procedures . Decontam-
ination procedures for personnel and equipment
must be established. Arrangements must also be
made for the proper disposal of contaminated
material, solutions, and equipment.
— Address Requirements for an Environmental Sur-
veillance Program . A program to monitor site
hazards must be implemented. This would include
air monitoring and sampling, and other kinds of
media sampling at or around the site that would
indicate chemicals present, their hazards, pos-
sible migration, and associated safety
requirements.
— Specify Any Routine and Special Training Re-
quired . Personnel must be trained not only in
general safety procedures and use of safety
equipment, but in any specialized work they may
be expected to do.
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— Establish Procedures for Weather—Related Prob—
lems . Weather conditions can affect site work.
Temperature extremes, high winds, storms, etc ,.
impact on personnel safety. Work practices must
be established to protect workers from the ef—
fects of weather and shelters provided, when
necessary. Temperature extremes, especially heat
and its effect on people wearing protective
clothing, must be considered and procedures es-
tablished to monitor for and minimize heat stress.
VI. ON—SITE EMERGENCIES
The plan must address site emergencies — occurrences
that require immediate actions to prevent additional prob-
lems or harm to responders, the public, property, or the
environment. In general, all responses present a degree
of risk to the workers. During routine operations risk is
minimized by establishing good work practices and using
personnel protective equipment. Unpredictable events such
as fire, chemical exposure, or physical injury may occur
and must be anticipated. The plan must contain contingen-
cies for managing them.
— Establish site emergency procedures.
— — List the names and emergency function of
on—site personnel responsible for emergency
actions along with the special training they
have.
—— Post the location of nearest telephone (if
none at site).
—— Provide alternative means for emergency com-
munications.
—— Provide a list of emergency services organi-
zations that may be needed. Names, tele-
phone numbers, and locations must be
posted. Arrangements for using emergency
organizations should be made beforehand.
Organizations that might be needed are:
— Fire
— Police
— Health
— Explosive experts
— Local hazardous materials response units
— Civil defense
— Rescue.
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—— Address and define procedures for the rapid
evacuation of workers. Clear, audible warn-
ings signals should be established, well—
marked emergency exist located throughout
the site, and internal and external cominuni—
cations plans developed.*
—— A complete list of emergency eqi.iipment
should be attached to the safety plan. This
list should include emergency equipment
available on—site, as well as all available
medical, rescue, transport, fire—fighting,
and mitigative equipment.
— Address emergency medical care.
—— Determine location of nearest medical or
emergency care facility. Determine its
capability to handle chemical exposure cases.
—— Arrange for treating, admitting, and trans-
porting of injured or exposed workers.
—— Post the medical or emergency care facili-
ties’ location, travel time, directions, and
telephone number.
—— Determine local physician’s office loca-
tion, travel directions, availability, and
post telephone number if other medical care
is not available.
—— Determine nearest ambulance service and post
telephone number.
—— List responding organization’s physicians’,
safety officers’, or toxicologists’ names
and telephone numbers. Also include near-
est poison control center, if applicable.
* Annex 7 contains an example of codes that could be
used for emergency operations based on direct—reading
instruments.
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—— Maintain accurate records on any exposure or
potential exposure of site workers during an
emergency (or routine operations).*
— Advise workers of their duties during an emer-
gency. In particular, it is imperative that the
site safety officers, standby rescue personnel,
decontamination workers, and emergency medical
technicians practice emergency procedures.
— Incorporate into the plan procedures for the
decontamination of injured workers and for their
transport to medical care facilities.
Contamination of transport vehicles, medical care
facilities, or of medical personnel may occur and
should be addressed in the plan.
Whenever feasible these procedures should be
discussed with appropriate medical personnel in
advance of operations.
— Establish procedures in cooperation with local
and State officials for evacuating residents who
live near the site.
VII. IMPLEMENTATION OF THE SITE SAFETY PLAN
The site safety plan, (standard operating safety
procedure or a generic safety plan for emergency response)
must be written to avoid misinterpretation, ambiguity, and
mistakes that verbal orders cause.
The plan must be reviewed and approved by qualified
personnel. Once the safety plan is implemented, needs to
be periodically examined and modified, if necessary, to
reflect any changes in site work and conditions.
All agencies and organizations which have an active
role at the incident must be familiar with the plan. If
possible the plan should be written in coordination with
the organizations involved. Lead personnel from these
organizations should sign the plan to signify they agree
with and will follow its provisions.
* Annex 8 contains the minimum amount of information
needed (along with any medical test results) for
personnel exposure records.
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All personnel involved at the site must be familiar
with the safety plan, or the parts that pertain to their
specific activities. Frequent safety meetings should be
held to keep all informed about site hazards, changes in
operating plans, modifications of safety requirements and
for exchanges of information. It is the responsibility of
personnel involved at the site as workers or visitors to
comply with the requirements in the plan.
Frequent audits by the incident manager or the safety
designee should be made to determine compliance with the
plan’s requirements. Any deviations should be brought to
the attention of the incident manager. Modifications in
the plan should be reviewed and approved by appropriate
personnel. -
VIII. SAI4PLE SAFETY PLANS
Since no one sample plan or plan format can adequ-
ately address all safety requirements for the variety of
incidents that occur, they should be used as a guide to
help develop an incident—specific plan. They can also be
used, with necessary adaptation, as generic plans for
emergency response. *
In some incidents, the sample plans contained in Annex
9 and 10 might be satisfactory to use by themselves.
Filling in the blanks provides an effective safety plan.
In many incidents they should only be considered as a
check list. Since they do not exhaustively cover every
condition which may need to be addressed, users of these
sample plans and any other examples must realize that
their application to any one incident may not be
acceptable. Therefore, they must be used with discre-
tion and tempered by professional judgment and experi-
ence. They are not meant to be all—inclusive, but are
examples of considerations, requirements 1 and format which
should be adapted for incident—specific conditions.
* Annex 9 and 10 are two examples of Site Safety Plans.
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ANNEX 7
Emergency Operation Codes
Real—Time Monitor
(suggested minimum action plan)
[ Site Name]
CODE DESIGNATIONS
1. Green
A. Normal operations
2. YELLOW A
A. Cessation of specific work activity on—site
because of:
(1) Continuous organic readings on direct—
reading instrument of * ppm above back-
ground (measured 20—30 ft. from point of
suspected release), and
(2) Current or projected meteorological condi-
tions indicate a probable impact on work
activity.
B. If background readings above * ppm are ob-
tained during cessation of activity, redesign
activity to lower releases and/or delay that
on—site activity until off—site air monitoring
indicates accepted off—site concentration.
C. Site personnel will immediately notify EPA/State
of site condition.
3. Yellow B
A. Termination of all work on—site because of:
(1) Continuous organic readings on’ direct—
reading instrument * ppm above back-
ground (measured approximately 1,000 ft.
from work area or site property limits), and
(2) Current or projected meteorologic condi-
tions indicate a potential impact on in-
habited areas.
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B. Site personnel will immediately notify EPA/State
of site conditions.
C. EPA/State will modify off—site air monitoring to
meet the needs of contingency plan.
4. RED
A. Termination of all work on—site because of:
(1) Continuous organic readings on direct—
reading instruments * ppm above back-
ground (measured downwind at the nearest
occupied area off—site), and
(2) Current or projected meteorologic condi-
tions indicate a potential impact on
inhabited areas.
B. Site personnel will immediately notify EPA/State
of site conditions.
C. Local officials making evacuation/public health
decisions will be advised by EPA/State to:
(1) Release a public health advisory to poten-
tially affected areas since on—site control
methods will not reduce the source of con-
tamination; and/or
(2) Implement a temporary relocation plan
because on—site activities indicate a
potential for continuous above background!
acceptable readings at the nearest in-
habited area(s).
*Concentration should be determined by
appropriate response personnel.
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ANNEX 8
RESPONSE SAFETY CHECK-OFF SHEET
(minimum required data)
Employee
I. BEFORE RESPONSE
1. Incident: Site _______________City State
a. Response Dates _____________________________
2. Type of Response: Spill Fire Site
Train Other
3. Incident Safety Plan: Region ERT
Not Developed ___________
4. Suspected chemical(s) involved: (a) ___________
(b) ________________ (c) _________________________
(d)
5. Protective Level(s) involved: A ________ B ___
C _____ D _____
(a) If Level C: 1. Identify canister _______________
2. Describe air monitoring source(s)
(b) If Level D JUSTIFY (in comments sectioi. 3t
bottom of page).
6. SCBA-Identify Buddy: Name/Organization ____________
7. 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 cannister: ________
b. Level D (comment below)
c. Level B or C skin protection: Tyvek/Saran
Acid/Rain ______ Other _______
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2. List possible chemical exposure: Same as above:
(a) ______________ (b) _____________ (c) _______
(d) _____________
3. Epiipment Decontamination:
(a) clothing (b) respirator (c) monitoring
Disposed: ____________ ______________ ____________
Cleaned: ____________ ______________ ____________
No Action: ____________ ______________ ____________
4. Approximate time in exclusion area: ____hours per
day for ______ days
5. Was medical attention/exam required for this
response: Yes _______ No _______
Part I: DATE PREPARED: ______ Reviewed by ________ Date
Part II: DATE PREPARED: ______ Reviewed by ________ Date
COMMENTS:
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ANNEX 9
(Suggested format for minimum site safety plan)
SITE SAFETY PLAN
[ rlame of Hazardous Waste Site/Spill ]
I. General Information
As a minimum, all personnel involved with emergency re-
sponse, waste site cleanup, drum handling and opening, sam-
pling, site investigations, etc. , will follow the applicable
Federal/State rules and regulations. In addition, all site
personnel will follow, as a minimum, U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response,
Hazardous Response Support Divisions Standard Operating Safety
Guides and Chapter 9 Hazardous Substance Response , from the EPA
Occupation Health and Safety Manual.
In the event of conflicting plans/requirements, personnel
must implement those safety practices which afford the highest
personnel protection.
If site conditions change and it is necessary to modify
Levels of Protection A, B, or C, the safety designee on—site
shall notify the On—Scene Coordinator (or Remedial Project
Officer) before making recommendations to site personnel.
II. APPROVALS
( SIGNATURE) ( SIGNATURE )
On—Scene—Coordinator (OSC) DATE Safety Officer DATE
(or Remedial Project Officer (RPM))
( SIGNATURE) ( SIGNATURE )
REVIEW COMMITTEE DATE OTHERS DATE
III. Summary of Minimum Requirements
A. The safety officer/designee shall:
1. Describe chemicals, hazards, and risk involved
2. List key personnel
a. Response manager (OSC /RPM/ alter-
nate) __________
b. Safety officer(s)/alternate _______________
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c. Other responsible site personnel/alternate
3. Prescribe Levels of Protection
4. Designate work zones: Support area, contamina-
tion reduction area, exclusion area.
5. Implement procedures to control site access.
6. Define decontamination procedures.
7. Delineate entry and escape routes.
8. Identify/contact medical facility, etc.
a. Fire ___________________________________
b. Ambulance _______________________________
c. Police __________________________________
d. Health ________________________________
e. Etc. _________________________________
9. List responsible parties and emergency contacts:
a. Federal Government EPA/USCG/CDC/OSHA
b. State Government Environment/Health Agency
c. County/City Government __________________
10. Establish personnel air monitoring.
11. Specify routine and special training needed.
12. Establish procedures for managing weather—
related problems.
B. Levels of Protection
1. Level C protection should be used for those job
functions listed below where there is no poten-
tial for personnel contact with either hazardous
materials or gases, vapors, or particulates ex-
ceeding requirements for wearing air—purifying
respirators.
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(Identify job functions in this paragraph:
e.g. — monitoring/surveillance, supervisors,
observers, etc.)
(Identify specific type of respirator in this
paragraph: e.g. — approved respirator and type
of canister.)
(Identify skin protection in this paragraph:
e.g. — double boots, double gloves, tyvek/saran
hooded, disposable coveralls, etc.)
2. Level B protection should be used for those job
functions listed below for which, based either
on potential or known site conditions and/or
vapor and gas concentrations, Level C is unsat-
isfactory.
Identify job functions in this paragraph:
(e.g. — Heavy equipment operations, samplers,
equipment/drum handlers, etc.)
Identify specific respiratory protection in this
paragraph:
(e.g. — self—contained breathing apparatus
(SCBA), air—line respirator)
Identify skin protection in this paragraph:
(e.g. — double boots, double gloves, type of
chemical—resistent garment, etc.)
3. If Level A protection is applicable, write a
paragraph in plan listing where and when it is
to be worn.
4. Level D is not adequate protection for any work
on—site where potential for exposure is possible.
5. Levels C and B may be modified based on moni-
toring and sampling data collected on—site.
Safety designee should not make any modification
to the Level of Protection without discussing it
with the On—Scene—Coordinator (or Remedial
Project Manager).
C. Air monitoring — Refer to Standard Operating Safety
Guides, Part 8, Air Surveillance.
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D. Training
Personnel will have either formal training or prior
on—the—job—training for those tasks they are assigned
to at the incident. All unfamiliar activities will
be rehearsed beforehand.
E. Respiratory Protection Program
All contractor and government personnel involved in
on—site activities shall have a written respiratory
protection program. All personnel wearing air—
purifying respirators on—site are required to be
fit—tested. All personnel wearing respirators must
have been properly trained in their use. All
respirators are to be properly decontaminated at the
end of each workday.
Persons having beards or facial hair must not wear a
respirator if a proper mask—to—face—seal can not be
demonstrated by a fit test. A log of all individuals
wearing personnel protective equipment shall be main-
tained, including time in the exclusive zone.
F. All contractor and government personnel who are
exposed to hazardous levels of chemicals must be
enrolled in a medical monitoring program.
G. General Safety Rules and Equipment
1. There will be no eating, drinking, or smoking in
the exclusion or contamination reduction zone.
2. All personnel must pass through the contamina-
tion reduction zone to enter or exit the exclu-
sion zone.
3. As a minimum, emergency eye washes will be on
the hot side of the contamination reduction zone
and/or at the work station.
4. As a minimum, an emergency deluge shower/spray
cans are to be located on the clean side of the
contamination reduction area.
5. At the end of the work day, all personnel work-
ing in the exclusion area shall take a hygienic
shower.
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6. All supplied breathing air shall be certified as
grade D or better.
7. Where practical, all tools/equipment will be
spark proof, explosion resistant, and/or bonded
and grounded.
8. Fire extinguishers will be on—site for use on
equipment or small fires only.
9. Since site evacuation may be necessary if an
explosion, fire, or release occurs, an individ-
ual shall be assigned to sound an alert and
notify the responsible public officials if re-
quired. For example, the evacuation signal may
be two long blasts every 30 seconds until all
personnel are evacuated and accounted for.
10. An adequately stocked first—aid kit will be on—
scene at all times during operational hours. It
is suggested that an oxygen inhalator respirator
be available and a qualified operator present.
The location of these items and the operator
shall be posted.
H. Morning Safety Meeting
A morning safety meeting will be conducted for all
site personnel and they will sign a daily attendance
sheet and should sign a master sheet indicating they
have read the site safety plan and will comply. The
safety procedures, and the days planned operations
should be discussed.
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ANNEX 10
OCCUPATIONAL HEALTH AND SAFETY MANUAL
APPENDIX A - SANPLE SAFETY PLAN
Assistance in preparing the safety plan can be
obtained from
the OHS
Designee
located
oning
in
Room
of
Building
or by teleph
REVIEW
Response Safety Committee Chairperson
APPROVALS
OSC/SFC ________________
OHS Designee
OIC _______________
PROJECT LEADER
Branch ________________
Building
Room __________________
Phone _____________________________
DATE OF PLAN PREPARATION ___________________________
HAZARDOUS SUBSTANCE RESPONSE
Site Name ______________________Site No. ____________________
HAZARDOUS SUBSTANCES (known or suspected contaminated media or
or in storage container, etc.):
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
UAZARD ASSESSMENT (toxic effects, reactivity, stability,
flammability, and operational hazards with
sampling, decontaminating, etc.):
MONITORING PROCEStJRES (If required by the Project Leader)
Monitoring the site for identity and concentration of con-
tamination in all media:
Medical monitoring procedures for evidence of personnel ex-
posure:
Personnel monitoring procedures:
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
DECONTAMINATION AND DISPOSAL
Decontamination Procedures (contaminated: personnel
surfaces, materials, in—
struments, equipment, etc):
Disposal Procedures (contaminated equipment, supplies,
disposable, washwater):
EMERGENCY PROCEDURES
In event of overt personnel exposure
(skin contact, inhalation, ingestion):
In event of personnel injury:
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
In event of potential or actual fire or explosion:
In event of environmental accident (spread of contamina-
tion outside sites):
EMERGENCY SERVICES (complete here or have separate list avail-
able on—site)
Location Telephone
Emergency Medical Facility
Location Telephone
Ambulance Service
Fire Department
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
Police Department
Location Telephone
Poison Control Center
PERSONNEL POTENTIALLY EXPOSED TO HAZARDOUS SUBSTANCES
Personnel Authorized to Enter Site
1. _____________________________________________________
2. _______________________________________________
3. ______________________________________________
4. _______________________________________________
5. _________________________________________________
Other Personnel Assigned to Handle Hazardous Substances
(decontaminate, analyze samples)
1. ____________________
2. _________________
3. _________________
4. ___________________
5. ___________________
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OCCUPATIONAL HEALTH AND SAFETY MANUAL
ALTERNATIVE WORK PRACTICES
(Describe alternative work practices not specified in this
Chapter. Indicate work practices specified in the Chapter
for which proposed alternative work practices will serve
as substitute.)
APPROPRIATE LITERATURE CITATIONS
LEVEL OF PROTECTION
SITE MAP
(Attach a site map in advance of a response, if possible,
or at an early stage of emergency response. Map should be
properly scaled and keyed to local landmarks.)
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