OSWER PublicatIon 9285.0-OIA
July 1992
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
INTEGRATED HEALTH AND SAFETY PROGRAM
STANDARD OPERATING PRACTICES
FOR OSWER FIELD ACTIVITIES
Assistant Administrator
Office of Solid Waste and Emergency Response
U.S. Environmental ProtectIon Agency
Washington, DC 20460

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NOTICE
This guidance manual does not constitute a rulemaking by the Agency. The policies set forth in
this Directive are intended solely as guidance. They are not intended, nor can they be relied
upon, to create any substantive or procedural rights enforceable by any party in litigation with the
United States. EPA officials may decide to follow the guidance provided in this Directive, or may
take action that is at variance with the guidance, policies, and procedures in this Directive, on the
basis of an analysis of specific circumstances. The Agency also reserves the right to change this
Directive at any time without public notice. Mention of trade names or commercial products does
not constitute endorsement or recommendation for use.
Additional copies of this document can be obtained from:
National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springüeld , Virginia 22161
(703) 487-4650
When ordering this document, refer to Publication 9285.O-O1A
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ABSTRACr
PURPOSE: The purpose of this document is to establish Standard Operating Practices for all
Office of Solid Waste and Emergency Response (OSWER) workers engaged in field activities.
BACKGROUND: Several laws and regulations require the U.S. Environmental Protection Agency
(EPA) to protect the health and safety of its workers. The Safety, Health, and Environmental
Management Division (SHEMD)’ has overall responsibility for the development, organization.
and administration of EPA’s Health and Safety Policies and Programs. OSWER, however, also is
responsible for implementing certain health, safety, and training programs applicable to workers
within OSWER. OSWER’s responsibilities differ from SHEMD in that OSWER is responsible
for developing programs that specifically address the health and safety problems that OSWER
workers may encounter on the job.
This document, which is designed to inform the OSWER field worker of his/her duties
and responsibilities with regard to specific health and safety practices, is but one example of
OSWER’s overall commitment to protect its workers.
APPLICABILflY: These Standard Operating Practices are effective for all OSWER workers who
are, or potentially may become, engaged in field activities. Thus, any OSWER employee who is
involved with one of the following activities must comply with these Practices:
(1) Normal operations at treatment, storage, and disposal (TSD) facilities regulated
under the Resource Conservation and Recovery Act (RCR.A) (i.e., facilities
regulated under 40 CFR Parts 264 and 265);
(2) Corrective actions at RCRA ThD facilities;
(3) Hazardous waste operations at uncontrolled hazardous waste sites;
(4) Emergency spill response activities;
(5) Chemical emergency preparedness;
(6) Field operations involving leaking underground storage tanks;
(7) Field operations involving solid wastes; and
(8) Any other field activities involving hazardous or potentially hazardous sub tances.
‘ These Standard Operating Fraaicec appi y to OS WER fldd aaivities, both foreign and
domestic.
1 S}tEMD is a division within the Office of Mmini tration and Resources Management
(OARM) in the Office of Administration (OA) in EPA.
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TABLE OF CONTENTS
Pate
1.0 PURPOSE I
2.0 OSWER REQUIREMENTS I
2.1 Requirements for Field Categories 1
2.2 OSWER Practices as Applied to Non-EPA Organizations 2
3.0 AUTHORITY 2
4.0 RESPONSIBILITY 2
4.1 Mmini tratjve 2
4.2 Training 4
4.3 Emergency Medical Services 4
5.0 FIELD ACrIVI’IY CATEGORIES AND PROCEDURES 4
5.1 Definition of Categories 4
5.2 Category Requirements 6
53 stanciarci operating Guidelines 7
53.1 Pre-Arrival Planning 7
53.2 Safety On-Site 7
5.4 Personal Protective Equipment 8
5.5 Site Departure and Decont2mination Procedures 8
6.0 MEDICAL SURVEILLANCE PROGRAMS 9
7.0 TRAINING 9
8.0 HAZARD COMMUNICATIONIRIGHTTO-KNOW 10
8.1 Hazard Communication Requirements 11
8.2 Information and Training 12
LIST OF ACRONYMS 13
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TABLE OF CONTENTS
(Continued)
Page
APPENDICES
A OSWER Integrated Health and Safety Work Group iS
B Summary of the OSWER Health and Safety Training
Course Requirements 16
C General Description of the OERR Levels of Protection
and Protective Gear 17
D OSWER Incident Safety Check-Off List and
instructions 21
E U.S. EPA OSWER Respiratory Protection Program 24
F Summary of OSWER Medical Surveillance Requirements
Per Worker Category 31
G Available Guidance 33
H Sample Certification Form 34
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1.0 PURPOSIE
The purpose of this document is to establish Integrated Health and Safety Standard
Operating Practices for all Office of Solid Waste and Emergency Response (OSWER) workers
who are actually or potentially engaged in field activities (e.g., hazardous substance field activities
and related activities involving hazardous chemicals/substances).
Each OSWER worker involved in field activities must receive appropriate training,
equipment. and medical surveillance in accordance with the Safety, Health, and Environmental
Management Division’s (SHEMD) Health and Safety Policies and Programs, 2 the Emergency
Response Division’s (ERD) Standard Operating Safety Guides (SOSGs), 3 as well as other
appropriate FederallState requirements and guidelines such as 29 CFR 1910 and 1926.
2.0 OSWER REQUIREMENTS
2.1 REQUIREMENTS FOR FEEI.D CATEGORIES
All OSWER workers who participate in field activities must be classified into field activity
categories. Once employees are classified, they must receive the training and medical surveillance
applicable to their field certification category prior to performing any field work. (Worker field
categories and procedures are defined below in Section 5.0.)
Any extension of duty associated with hazardous materials or other potentially hazardous
OSWER field activities beyond the specific field category to which a particular worker is assigned,
or for which he/she is specifically qualified by ir tining and practical experience, is prohibited.
Therefore, supervisors are not authorized to order, direct, or otherwise instruct a worker to
engage in work activities involving hazards that are beyond the scope of the worker’s field
certification(s). In the event that a worker knowingly engages in hazardous activities on the job
that are beyond the scope of his /her qualifications, as determined by certified training and
practical experience, such worker will be deemed to have willfully self-endangered himself/herself,
in violation of EPA procedures. Such workers will be disciplined in accordanée with established
policies, and may be denied Worker’s Compensation benefits in the event of related injury or
illness. Such workers also may incur other personal liabilities.
2 SHEMD is a division within the Office of Admijthtration and Resources Management
(OARM) in the Office of Administration (OA) in EPA.
3 ERD is a division within the Office of Emergency and Remedial Response (OERR) in
OSWER. The SOSGs developed by ERD provide a comprehensive overview of the health and
safety information needed by employees engaged in operations at hazardous waste sites. The
SOSGs are meant to supplement professional training, experience, and knowledge and can be
used as a planning and management tool, an educational tool, or a reference document. The
specific topic addressed in the SOSGs include: initial planning activities; training; site control;
personal protective equipment (PPE); air monitoring; medical surveillance program; heat stress
and cold exposure; decontamination; drum handling; and other requirements and safety
considerations. To obtain a copy of the SOSGs, contact the National Technical Information
Service (NTIS) at (703) 487-4600.
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2.2 OSWER PRACflCES AS APPLIED TO NON-EPA ORGANIL411ONS
In implementing these Health and Safety Standard Practices, OSWER maintains the
position that corUractor are responsible for developing and implementing Standard Operating
Safety and Health Practices for their employees and operations. To satisfy this requirement.
OSWER has elected to allow contractors to develop and implement internal health and safety
program and standard operating procedures (SOPs). Such programs/procedures must include
employee right-to-know and must be in compliance with ERD’s SOSGs and all applicable
Occupational Safety and Health Administration (OSHA) standards. Thus, at a rmnimum.
OSWER requires that each contractor know and adhere to 29 CFR 1910, (specifically 29 CFR
1910.120 (the Hazardous Waste Operations and Emergency Response Standards (HAZWOPER))
and 29 CFR 1910.121), 29 CFR 1926, and ERD’s SOSOs.
After developing the internal health and safety programs and the SOPs, the contractor
must certify to EPA that their programs and practices comply with 29 CFR 1910 and 1926 and
the ERD SOSGs. In the event that a contractor’s health and safety program differs from these
requirements, the contractor must certify to EPA that their program and procedures are at least
as stringent as EPA’s requirements, and that they provide a commensurate level of worker safety.
Finally, all organizations that have their own health and safety programs, including private
contractors and other Federal, State, and local agencies, are fully responsible for the proper
administration of those programs. Such programs are permissible so long as they provide for a
level of worker safety equivalent to OSWER’s Practices, and they are at least as stringent as those
Practices.
3.0 AUTHORITY
The authority for this program is derived from: EPA’s SHEMD and all applicable Federal
regulations, Executive Orders, Directives, Policies, Programs, and Practices.
4.0 RESPONSIBILITY
4.1 ADMINiSTRATIVE
The following personnel are responsible for implementing and administering OSWER’s
Integrated Health and Safety Standard Operating Practices. 4
The Assistant Administrator of OSWER, or designee, is ultimately responsible for
ensuring that all field workers actively participate in the OSWER Integrated Health
and Safety Standard Operating Practices.
Office Directors are delegated the authority and responsibility for implementing and
enforcing these Practices. To ensure a truly integrated and coordinated program,
‘ These practices identify six distinct field activity categories into which workers are assigned,
based upon their field training certification classification (29 CFR 1910.120 and 29 CFR 1910.121)
and exposure potentiaL The categories are defined and outlined in Section 5.0 of this document.
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each Office Director is required to assign at least one appropriately qualified
occupational safety and health professional to serve as liaison on the OSWER
Integrated Health and Safety Workgroup, which is chaired by the Chief of the Safety
and Air Surveillance Section. Environmental Response Team (ERT), 2390
Woodbridge Avenue, Building 18 (MS 101), Edison, NJ, 08837-3679, (908) 321-6740.
(Refer to Appendix A for the list of OSWER Integrated Health and Safety
Workgroup members.)
• Division Directors are authorized to identify each field activity categoiy in their
Divisions. The Division Directors also are responsible for the budgeting of funds for
safety training and for the purchase, maintenance, and storage of worker safety
equipment.
• Branch Chiefs are responsible for assigning field activity categories to Section
Chiefs/first-line supervisors. The Branch Chiefs are also responsible for maintaining
worker safety and training records, which contain all safety-related matters. (See
below for proper procedures.)
• Section ChIefs/first-line supervisors are responsible for assigning field activity
categories to individual workers. Each worker must be provided with a complete
description of the field activity categories. The Section Chief, or designee, also is
responsible for purchasing, issuing, and training his/her personnel concerning all
phases of personal protective equipment (PPE) and medical surveillance.
Once the List of categorized workers has been compiled by the Section
Chief/first-line supervisor, the Branch Chief or the Section Chief must
transmit a copy of the list to ERT. Each list must include the worker’s first
and last name, relevant office, mail code, and worker category. Upon receipt
of these lists, ERT staff will solicit relevant employee training and medical
records, including updates. Such information will be recorded by ERT staff
into a data base. Annually, ERT will send computer-generated copies of
employee records to the appropriate Branch Chief and will request that the
Branch Chief, or designee, revise or update the information based on
employment changes or recategorizations. The Branch Chief, or designee, is
responsible for transmitting the updated information to ERT so that the
employee data base can be modified accordingly.
• Affected EPA workers must read and fully understand the OSWER Standard
Operating Practices and must sign a statement attesting to that fact. Appendix H
contains a sample certification form that may be used as a model in obtaining worker
signatures. The statement forms are provided to each worker by their immediate
supervisor. Once such forms are signed by the worker, the appropriate Branch Chief
will retain the form for documentation purposes.
A Worker” is defined as any full, part-time, temporary, or permanent EPA employee;
a detailee to the EPA from another government agency an individual enrolled in
EPA’s Senior Environmental Employment (SEE) Program; a student assigned to the
EPA; an EPA stay-in-school program participant; an intern or fellow assigned to the
EPA; and any other individual who is designated on a case-by-case basis by the
Director of SHEMD.
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• The OSWER Inte ated Health and Safety Workgroup is responsible for the
implementation and maintenance of these Standard Operating Practices. The
Workgroup representative is the focal point for coordinating the office’s activities
with regard to OSWER worker occupational health and safety activities.
If additional logistical and administrative support is required, such support may be
obtained from the ERT upon request. (Refer to Appendix A for relevant ERT
telephone numbers.)
4.2 TRAINING
The development, implementation, and ongoing management of health and safety training
programs is the highest OSWER training priority. The Assistant Administrator of OSWER, or
designee, bears the ultimate responsibility for ensuring that all OSWER workers receive the
appropriate safety equipment and training, or equivalent, in accordance with EPA Policies and
Programs and 29 CFR 1910 and 1926. Although the Assistant Administrator is ultimately
responsible for worker training, the task of ensuring that all workers receive the proper
mandatory safety training and equipment on a day-to-day basis is borne jointly by the OSWER
Office Directors, Division Directors, Branch Chiefs, Section Chiefs/first-line supervisors, and
workers.
4.3 EMERGENCY MEDICAL SERVICES
In addition to routine medical surveillance coverage, the worker may be entitled to certain
emergency and other medical services provided under Worker Compensation programs. It is the
worker’s responsibility to seek medical assistance and to immediately advise his/her supervisor in
the event of a job-related injury or illness, or acute exposure or exposures above published
exposure levels (e.g., above permissible exposure limits (PELs) or threshold limit values
(TLVs)) 5 .
5.0 FIELD ACTiVITY CATEGORIES AND PROCEDURES
5.1 DEFINITION OF CATEGORIES
Six distinct field activity categories have been identified for OSWER field personnel. Each
category requires different amounts of initial and annual training. Medical surveillance
requirements also differ by category, according to exposure potential. The training and medical
surveillance requirements for each category are described below and summarized in Appendices B
and F, respectively.
A first-line supervisor may modify a worker’s category assignment by providing written
notification to the Chief of the Safety and Air Surveillance Section, ERT. This notification must
identify the change(s) in the field activity category and verify that the appropriate training,
For additional information on TLVs, refer to the 1991-1992 Threshold Limit Value for
Chemical Substances and Physical Agents and Biological Ezposure Indices, published by the
American Conference of Governmental Industrial Hygienists (ACGIH) (1991). For further
information on PELs, refer to 29 CFR 1910.1000, Subpart Z.
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equipment and medical examination(s) have been provided to the individual, as required for
reclassification. -
‘ Cateeorv 1 is established as the OSWER highest risk calegoly. This category
includes all workers whose job description/critical job elements require handling of,
or potential exposure to, identified or unidentified hazardous chemicals. For
example, workers who respond to spill emergencies, engage in hazardous waste
operations at uncontrolled hazardous waste sites, and perform corrective actions at
RCRA ThD facilities (e.g., ERT personnel) fall within this category. Category 1
workers are authorized to wear all OERR Levels of PPE (i.e., Levels A, B, C, and
D). (Refer to Appendix C for a general description of the protective gear required
for each level of PPE.)
AU Category 1 workers are required to submit to a baseline medical examination.
Thereafter, the frequency of medical examinations and tests are based on the
individual’s job-related risks, and are determined by the OSWER Occupational
Medicine Program, in accordance with National Medical Surveillance Program
guidance.
Cate2vrv 2 includes those OSWER personnel who are required to enter a Superfund
or RCRA Corrective Action “Exclusion Zone” or a RCRA TSD facility’s “Activity
Area,” where there is the potential for exposure to identified or unidentified
hazardous chemicals. However, to fall within this category, workers must be present
in the relevant zone or area for more than approximately 20 days per calendar
y • 6 Category 2 workers are authorized to wear OERR PPE Levels C and D.
Category 2 workers also are required to submit to a baseline medical examination.
Thereafter, the frequency of medical examinations and tests are based on the
individual’s job-related risks and are determined by the OSWER Occupational
Medicine Program, in accordance with National Medical Surveillance Program
guidance.
• Cate2orv 3 includes those OSWER personnel who are required to enter a RCRA
TSD facility, where there is the potential for exposure to identified or unidentified
hazardous chemicals. A worker must be present at such a facility for more than
approximately 20 days per calendar year to fall within this category. These workers
are authorized to wear OERR PPE Levels C and D.
These workers must receive a baseline medical examination plus updates based on
potential exposure frequency, as determined by the OSWER Occupational Medicine
Program, in accordance with National Medical Surveillance Program guidance.
• Caterurv 4 includes those OSWER personnel who are required to enter a Superfund
or RCRA Corrective Action “Exclusion Zone” or a RCRA TSD facility’s “Activity
Area,” where there is the potential for exposure to identified or unidentified
hazardous chemicals. However, to fall within this category, workers must be present
6 The period of potential exposure of greater than or less than 20 days is derived from the 30-
day standard in 29 CFR 1910.120.
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in the relevant zone or area for than approximately 20 days per calendar year.
Category 4 workers are authorized to wear OERR PPE Levels C and D.
Category 4 workers also must receive a baseline medical examination with updates
based on potential exposure frequency, as deternuned by the OSWER Occupational
Medicine Program, in accordance with National Medical Surveillance Program
guidance.
Catepor9 S includes those OSWER personnel who are required to enter a RCRA
TSD facility, where there is potential for exposure to identified or unidentified
hazardous chemicals. A worker must be present at such a facility for than
approximately 20 days per caLendar year to fall within this category. Category 5
workers are authorized to wear OERR PPE Levels C and D.
These workers also must receive a baseline medical examination plus updates based
on potential exposure frequency, as determined by the OSWER Occupational
Medicine Program, in accordance with National Medical Surveillance Program
guidance.
CateEurv 6 includes all other OSWER field activity personnel not specifically
addressed in Categories 1 through 5, but who are required to perform their job
function in a Securv/Clean Area. Category 6 is limited to those personnel who,
although they work in a secure/clean area, are associated with those activities being
performed by workers in Categories 1 through 5.
These workers are authorized to wear OERR PPE Level D. A baseline medical
examination will be conducted for Category 6 workers if it is deemed necessary by
the OSWER Occupational Medicine Program, in accordance with National Medical
Surveillance Program guidance.
5.2 CATEGORY REQUIREMENTS
The following provides a basic framework for the safe conduct of OSWER field activities
and is applicable to all field personnel, whenever such personnel are either directly or indirectly
involved in a hazardous substance activity.
• OSWER field activity personnel must be aware, in advance, of the objectives of each
site visit and must be prepared to employ safe operations to avoid potential hazards.
• Each worker must comply with these Standard Operating Practices and exercise good
personal judgment and technical expertise on a case-by-case basis.
• Whenever applicable, OSWER field activity personnel must implement the ER])
SOSGs for guidance and selection criteria. OSWER personnel also must exercise
extreme caution to prevent loss of life, injury, or health hazards to themselves and to
the general public.
• OSWER field activity personnel are required to adhere to these Practices regardless
of whether local requirements are as stringent. In the event of conflicting health or
safety regulations, workers are expected to implement those practices that afford the
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highest level of protection. Managers and supervisors are responsible for ensuring
that The most stringent requirements are implemented in the event of a conflict.
To be eligible to perform Category 1 through 5 duties, the worker must:
(a) Be assigned to the on-site work by his/her supervisor;
(b) Complete the required baseline medical examination and participate in the
medical surveillance program;
(c) Complete the appropriate health and safety training program as required by
EPA policies and programs, OSHA’s HAZWOPER standards, and 29 CFR
1910.121, prior to involvement in field activities, and/or other types of
activities similar to field activities; and
(d) Be assigned to the appropriate Field Activity Category.
5.3 STANDARD OPERATING GUIDELINES
5.3.1 Pre-Arrival Planning
In planning a field activity, it is each worker’s responsibility to be aware of the purpose
of the field activity and to comply with the OSWER Integrated Health and Safety Standard Operating
Practices, SHEMD Health and Safety Policies and Programs, OSHA standards specified at 29 CFR
1910.120, and 1910.121, and all other applicable regulations and requirements.
Prior to arrival at a Superfund field activity location, each worker must complete Part
I of the OSWER Incident Safety Check-off List (provided in Appendix D), and furnish the list to the
first-line supervisor or designee for review and signature. Although lead time and availability of
information are often limited, the worker must attempt to complete this form prior to departing the
office. If an emergency arises, it is recommended that the worker and his/her supervisor contact the
Environmental Response Branch’s Edison, NJ, Hotline at (908) 321-6660 for technical assistance.
Site Safety Plans must also be completed prior to site entry, in accordance with 29 CFR 1910.120
standards and the ERD SOSGs.
5.3.2 Safety On.Slte
The general rule is that employees cannot participate in or supervise field activities until
they have been property trained to the level required by their job function and responsibility. The
purpose of this requirement is to ensure the health and safety of all workers on-site and the general
public. Because all training must be consistent with the requirements specified in 29 CFR 1910.120,
on-site training sessions must address, at a minimum: (1) the names of personnel responsible for site
safety and health; (2) the safety, health, and other hazards present on the site; (3) the proper method
to use PPE; (4) the work practices by which an employee can reduce the risk from hazards; and (5)
relevant medical surveillance requirements, including recognition of signs and symptoms that might
indicate overexposure to a particular hazard. (Refer to 29 CFR 1910.120(e) for additional training
information.)
Once workers have satisfied the relevant training requirements, they may engage in field
activities. The buddy system must always be employed in the field. OSWER field personnel shall
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not enter an Exclusion Area TM or a RCRA TSD hazardous waste facility without another
appropriately trained individual present. In addition to the buddy system requirement. OSWER
personnel must implement continuous on-site evaluation and inspection for potentially dangerous
conditions in accordance with the ERD SOSGs. if any condition is discovered to be more hazardous
than originally anticipated, all field activity must cease temporarily, until a re-evaluation of the hazards
and the level of protection occurs.
In the event that an OSWER field activity worker experiences any adverse effects or
symptoms of exposure while engaged in field activities, he/she must immediately leave the site/area.
contact the site/facility supervisor (e.g., On-Scene Coordinator (OSC)) and seek appropriate medical
attention. Such incidents must be reported in accordance with EPA SHEMD policies and programs.
(For additional information on how to comply with SKEMD policies and programs, contact one of
the OSWER Integrated Health and Safety Workgroup members. Names and telephone numbers of
Workgroup members are provided in Appendix A.)
5.4 PERSONAL PROTECTIVE EQUIPMENT (PPE)
If OSWER personnel are required to enter any area in which there is a risk of potential
exposure or in which respiratory protection is needed (e.g., a hazardous site/spill exclusion zone,
RCRA TSD facility, or manufacturer’s production area), they must adhere to these Integrated Health
and Safety Standard Operating Practices, regardless of whether the Region has a policy or a specific
site-safety plan. Workers are required to refer to the ERD SOSGs for a detailed description of the
levels of protection and selection criteria. Other relevant guidance includes the OSWER Respiratory
Protection Program, which is included in Appendix E of this document, and the Standard Operating
Guide for Site Entry (U.S. EPA, draft, Publication 92812-O1A). (Refer to Appendix G for
information on how to obtain these Standard Operating Guides.)
5.5 SrrE DEPARTURE AND DECONTAMINATION PROCEDURES
Disposable safety clothing and sampling equipment must be disposed of properly. If
appropriate disposal facilities are not available, safety clothing and sampling equipment must be
placed in a suitable container pending proper disposal. Non-disposable safety clothmg and sampling
equipment also must be decontaminated (preferably on-site) in accordance with the ERD SOSGs.
In the event that the adequacy of the decontamination procedures is questionable, non-
disposable equipment must be placed in appropriate containers until the exact nature of the
contamination is known. Either suitable decontamination procedures must be employed to clean the
equipment, or the equipment must be properly disposed of at an approved RCRA hazardous waste
facility that meets the requirements of the EPA off-site policy (OSWER Directive 9834.11) and EPA
Land Disposal Restrictions (40 CFR 268.30 and 268.32). For additional guidance regarding
decontamination procedures and requirements, refer to 29 CFR 1910.120(k) and the Standard
Operating Guide for Decontamination of Response Peryonne! (U.S. EPA, draft, Publication
9285.02A). 7
7 Refer to Appendix G for a list of other available standard operating guidelines.
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6.0 MEDICAL SURVEILlANCE PROGRAMS
OSWER field activity workers in Categories 1 through 5 must undergo a baseline health
profile. A baseline examination is also recommended for Category 6 workers; however, such an
examination is not required. Following the baseline profile, based on field exposure classification.
OSWER workers in Categories 1 through 5 also must submit to routinely scheduled examinations to
determine the possible health effects, if any, associated with their field activities.
In addition, OSWER field activity personnel must receive a medical examinattonlconsultaHon
as soon as possible after notifying their Section Chief(s) or first-line supervisors that they have either
developed signs or symptoms indicating possible overexposure to hazardous substances or health
hazards, or that they have been injured or exposed to hazardous substances above the PELS or
published exposure levels in an emergency situation.
Category 6 personnel who develop signs or symptoms or overexposure to hazardous substances
or health hazards from an emergency incident, or who are exposed during an emergency incident to
hazardous substances at concentrations above the permissible or published exposure levels without
use of the necessary PPE, are entitled to a medicaL examination or consultation as soon as possible
following the emergency incident or the development of signs or symptoms. Additional examinations
may be scheduled for such Catejoty 6 workers if the examining physician determines that such a
follow-up is medically necessaiy.o
A summary of the OSWER Medical Surveillance Requirements according to Field Activity
Category is included in Appendix F. (Also, refer to Occupaiional Medical Monitoring Program
Guidelines for SAK4 Hazardous Waste Field Activity Personnel,N U.S. EPA, 1990 Publication 9285.3-
04.)
7.0 TRAINING
An adequate training program is essential for proper implementation of these Integrated
Health and Safety Standard Operating Practices. The complexities of the topics of interest., the
vanety of courses offered, and the need for specific training within each category necessitates
formulation of certain ground rules.
• Each OSWER field activity worker must receive safety training commensurate with
his/her job requirements and field exposure classification. In addition, first-line
supervisors must recommend additional safety training courses for each worker’s future
needs.
• A series of core topics are designated for each worker field category as specified in
Appendix B, The Summary of the OSWER Health and Safety Training Requirements.
The core topics specified in Appendix B are mandatory for all OSWER field activities
category workers. The other topics identified as “desirable TM should be taken by workers
based upon the recommendations of their supervisors.
8 29 CFR 1910.120(f)(3)(i)(ii).
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• Supervisors are ultimately responsible for ensuring that their workers are properly
trained.
• The training plans and programs must remain flexible enough to include or delete any
additional or obsolete topics as the need arises or as new ideas are introduced.
Training hour requirements vary according to the specific field activity. The following
summarizes the 29 CFR 1910.120 and 1910.121 training requirements as they relate to the OSWER
Field Activity Categories.
Cateeories 1. 2. and 4 : These workers must receive 40 hours of initial training, plus 3 days of
actual field experience under the direct supervision of a trained, experienced supervisor.
(Field supervisors in these categories will be required to have an additional 8 hours of
“Supervisor Training.”) All workers must also receive 8 hours of refresher training annually.
Catewries 3 and 5 : These workers must receive 24 hours initial training and 8 hours refresher
training annually.
Cate2orv : Although not required by 29 CFR 1910.120 and 1910.121, all Category 6 workers
are by this Practice to have a minimum of 4 hours of training in those areas identified in
Appendix B.
All supervisors equivalent to, or lower than. Section Chiefs in charge of field activity
workers must receive commensurate safety training in all applicable field safety categories.
8.0 HAZARD COMMUNICATIONIRIGHT -TO-KNOW
The EPA is required to communicate the hazards associated with the workplace in accordance
with SHEMD policies and programs, the OSHA Hazard Communication Standard (29 CFR
1910.1200), and the OSHA HAZWOPER standards (29 CFR 1910.120). These regulations and
programs require that workers be given information and training on hazardous substances in their
specific work areas. (A work area is defined to include both field and office settings.)
OSWER maintains that the hazard communicationlright-to-know requirement will be extended
to contractors and/or contractor representatives. Although it is often the case that the exact nature
of the hazardous substances are unknown, OSWER workers and contractors and their representatives
must be informed of the physical and health hazards of known substances in the work area. In
addition, OSWER workers and contractors must be notified of methods to detect hazardous
substances and any measures that workers can take to protect themselves from hazards.
The OSHA Hazard Communication Standard, at 29 CFR 1910.1200, specifically excludes
hazardous waste from its requirements. Also excluded from the Hazard Communication requirements
are any products or hazardous substances brought on-site and used as they would normally be used
at home or in the office. For example, small quantities of floor cleaners with ammonia, window
cleaners, copier ink, and correction fluid, are excluded from the requirements of 29 CFR 1910.1200.
Although the OSHA Hazard Communication Standard excludes hazardous waste, the OSHA
HAZWOPER standards (29 CFR 1910.120) include requirements strikingly analogous to those
specified in 29 CFR 1910.1200. Thus, although 29 CFR 1910.1200 does not specifically apply to
10

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hazardous waste and, therefore, OSWER workers, 29 CFR 1910.120 fills the gap. For example. 29
CFR 1910.120(b) requires (1) a written site-specific health and safety plan that addresses the safety
and health risk or hazard analysis for each site task; and (2) identification of risks and communication
of those risks to workers involved with hazardous substances. In addition, 29 CFR 1910.120(c)(8)
requires that any available information on known or potential hazardous substances be made available
to workers p pr to conducting site work. 29 CFR 1910.120(1) requires the implementation of an
informational program to inform workers, contractors, subcontractors, or their representatives of the
nature, level, and degree of exposure potential. Finally, for RCR.A workers, 29 CFR 19I0.12O(p)( 2 )
requires workers to implement a hazard communication program. Thus, 29 CFR 1910.120, which
applies to all OSWER workers, effectively captures the critical requirements of the OSHA Hazard
Communication Standard.
Although not specifically required by the OSHA Hazard Communication Standard (29 CFR
1910.1200), OSWER maintains that a material data safety sheet (MSDS), or equivalent information,
must be included as part of the site-specific safety plan for any hazardous substance that is identified
or suspected to be present on-site. Inclusion of such information will thereby satisfy the requirements
of 29 CFR 1910.120.
8.1 HIL RD COMMUNICATION REQUIREMENTS
The 29 CFR 1910.1200 Hazard Communication Standard is applicable to several site activities,
including:
(a) Hazardous chemicals brought on-site for use in such a manner that workers may be
exposed under normal conditions (e.g., compressed gases);
(b) Reagents brought on-site for use in collecting samples for future analysis and on-site
testing; and
(c) Instruments used in decontaminating field personnel., equipment, and containers (such
as degreasers and chemical solutions).
The following requirements apply to the above three categories of site activities that fall within the
scope of 29 CFR 1910.1200. These requirements must be addressed in addition to the written hazard
communication program already provided in the site-specific health and safety plan: 9
(a) Labels and other forms of warning including the identity of the hazardous chemical,
hazard warnings, and the name and address of the chemical manufacturer or other
responsible party.
(b) An MSDS must be obtained or developed for each hazardous chemical, and must
include the following information:
• Identity, including the chemical and common name;
• Physical and chemical characteristies;
• Physical hazards;
• Health hazards;
29 CFR 1910.1200(e), (f), (g), and (h).
11

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• Primary routes of entry;
• PELs and TLVs or other published exposure levels;
• Whether or not the chemical is considered a carcinogen:
• Precautions for safe handling including protective measures and clean-up
procedures for spill/leaks;
• Control measures;
• Emergency and first aid procedures
• Date of MSDS preparation; and
• Name and address of individual who prepared the MSDS.
(c) Employers must provide workers with information and training on the hazardous
chemicals in the work area.
8.2 INFORMATION AND TRAINING
Prior to a worker’s initial assignment and whenever new hazards are identified or introduced,
the Section Chief(s)/first-line supervisor(s) is responsible for providing workers with information and
training on hazardous chemicals in their work area. (All parties working together at a hazardous
waste site or spill emergency/accident must share all available information on the possible hazards
present in the area.)
OSWER field workers must be informed of:
(a) Any operation in their work area where hazardous chemicals are present; and
(b) The location and availability of the written Hazard Communication Program. or
equivalent, which includes the list(s) of hazardous chemicals and MSDSs.
OSWER field worker training, at a minimum, must include:
(a) Requirements of a written Hazard Communication Program;
(b) Awareness and recognition of hazardous chemicals in the work area;
(c) Physical and health hazards of chemicals in the work area; and
(d) Measures that workers can take to protect themselves from these hazards.
In addition to the above requirements, as part of hazard communication, workers also must
be informed of any known threats to human reproduction, or fetus, by hazards in the workplace.
OSWER workers (both male and female) who are potentially exposed to chemicals that affect
reproduction. such as teratogens, mutagens, and agents that alter fertility, have the right to request
a temporary change in job assignment as needed to allow conception or to protect an unborn child.
Each request will be handled on an individual basis. For each request, the supervisor has the
responsibility to assess the reproductive hazards associated with the job and to make reasonable
accommodations of equal professional status.
12

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ACRONYMS
AA Assistant Administrator
ACGIH American Conference of Governmental Industrial Hygienists
AIHA American Industrial Hygienists Association
DOT Department of Transportation
EPA U.S. Environmental Protection Agency
ERD Emergency Response Division
ERT Environmental Response Team
IDLH Immediately Dangerous to Ufe or Health
MSDS Material Safety Data Sheet
MSHA Mine Safety and Health Administration
NIOSH National Institute of Occupational Safety and Health
NTIS National Technical Information Service
OA Office of Administration
OARM Office of Administration and Resources Management
OERR Office of Emergency and Remedial Response
OSC On-Scene Coordinator
OSHA Occupational Safety and Health Administration
OSWER Office of Solid Waste and Emergency Response
PEL Permissible Exposure Umit
PPE Personal Protective Equipment
RCRA Resource Conservation and Recovery Act
SARA Superfund Amendments and Reauthorization Act
SCBA Self-Contained Breathing Apparatus
SEE Senior Environmental Employment
SHEMD Safety, Health, and Environmental Management Division
SOP Standard Operating Procedures
SOSG Standard Operating.Safety Guides
TLV Threshold Limit Value
TSD Treatment, Storage, and Disposal
WEELS Workplace Environmental Exposure Levels
13

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APPENDIX A
OSWER INTEGRATED HEALTh AND SAFETY WORKGROUP
Safety, Health, and Environmental
Management Division
Pat Weggel
202-260-1653 (PM.273)
T hnology Innovauon Office
Marlene Situ (OS-I lOW)
703-3084847
Fax: 703-308-8528
Hazardous Site Evaluanon Division
Janet Grubbs
703-603.8860 (5204G)
Fax: 703-603-9104
Office of Emergency and Remedial Response
[
WORKGROUP CHAIR: Rodney Turpin. Chair
Safety and Air Surveillance Section
Envuonniental Response Team
Emergency Response Division
Edison, New Jersey 08837-3679
908-321-6741 (MS-101)
Office of Waste Programs Enforcement
Darleen Boeriage
703-603-8956 (5502G)
Fax: 703-603-9117
Kate Anderson
202-260-9313 (OS-520)
Fax: 202-260-7660
Chemical Emergency Preparedness
and Prevention Office
Craig Mattheissen
202-260-9781 (OS-120)
Fax: 202-260-0927
John Ferris
202-260-4043
Fax: 202-260-0927
Office of Solid Waste
Mat: Strait:
703-308-8414 (OS-320W)
Fax: 703.308-8433
Office of Underground Storage Tanks
Sieve McNeeley
703-308-8889 (OS-420WF)
Fax: 703-308-8505
Hazardous Site Conirol Division
Tracy Hopkins
703-603-8788 (5203G)
Fax: 703-603-9100
Awilda Fitentez
703-6034748
Fax: 703-603-9100
Emergency Response Division
Selia Burchene
908-321-6726 (MS-L01)
Fax: 908-321-6724
Janet Weiner
703-603-8717 (5202G)
Fax: 703-603-9116
T OARM
[ ] OSWER
cJ0ERR
15

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APPENDIX B
o .
SUMMARY OF ThE OSWER HEALTH AND SAFETY TRAINING COURSE REQUIREMENTS
y: X = Mandatory, Core Topics
o = Desirable, but not Mandatory
N/A Not Applicable
* = Cardiopulmonary Resuscitation
Category
OERR Authorized
Levels of Protection
OS WEB H&S SOP
Document
OERR Standard
Operating Safety
Guides
Properties of
Hazardous Metals
To dcology.
1
AIB,C
X
X
X
X
2
C
X
X
X
X
3
C
X
X
X
X
4
C
X
X
X
X
5
C
X
X
X
X
6
None
X
X
N/A
N/A
Category
Basic
Office
First Aid
Basic
Field
First Aid
CPR*
Protective
hij
Respiratory
Protection
Deconta-
minatlon
Procedures
Entry
Procedures
Worker
Rights &
Reepon-
aiblilties
Defensive
Driving
1
0
X
0
X
X
x
x
x
x
2
0
X
0
X
X
X
X
X
x
3
0
X
0
X
X
X
X
X
X
4
0
X
0
X
X
X
X
X
X
5
0
X
0
X
X
X
X
X
X
6
0
0
N/A
N/A
N/A
N/A
X
X
X

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APPENDIX C
GENERAL DESCRIPTiON OF ThE OERR LEVELS OF
PROTECTION AND PROTECTIVE GEAR
Personal protective equipment has been dMded into the following four categories based on the
degree of protection aftorded:
Equipment
Protection Provided
Should Be Used When:
LEVEL OF PROTECTION A
The highest available level of
respiratory, skin, and eye
protection.
1. The chemical substance
has been identified and
requires the highest level of
protection for skin, eyes,
and the respiratory system.
RECOMMENDED:
• Pressure-demand, full-face-
piece, setf-comained
breathing apparatus
(SCBA), approved by the
Mine Safety and Health
Administration (MSHA) and
the National Institute of
Occupational Safety and
Health (NIOSH).
• Fully-encapsulating,
chemical-resistant suit.
o Inner and outer chemical-
resistant gloves.
• Chemical-resistant safety
boots, steel toe and shank.
(Depending on suit
construction, work over or
under suit boot.)
• Disposable protective suit.
gloves, and boots.
(Depending on suit
construction, worn over or
under suit boot.)
• Two-way radios (worn
inside encapsulating suit).
2. Substances with a high
degree of hazard to the
skin are known or
suspected to be present.
and skin contact is
possible.
3. Operations must be
conducted in confined,
poorly ventilated areas until
the absence of conditions
requinng Level A protection
is determined.
OP11ONAL
a
S
•
Hard hat (under suit).
Coveralls.
Long cotton underwear.
17

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APPENDIX C
(Continued)
GENERAL DESCRIP11ON OF ThE OERR LEVELS OF
PROTECTiON AND PROTECTiVE GEAR
LEVEL OF PROTECTION B
RECOMMENDED:
Pressure-demand, full-face-
piece SCBA (MSHNNIOSH
approved) or airline
respirator.
• Chemical-resistant clothing
(overalls and long-sleeved
jacket; hooded, one- or
two-piece chemical splash
suit; disposable chemical-
resistant one-piece suit).
• Inner and outer chemical-
resistant gloves.
• Chemical-resistant safety
boots, steel toe and shank.
• Boot covers (outer).
• Hardhat.
• Two-way radios (worn
inside encapsulating suit).
OPT1ONAL
• Coveralls.
•
0
The same level of respiratory
protection but less skin
protection than Level A.
ft is the minimum level
recommended for initial site
entries until the hazards have
been further identified.
1. The type and atmosphenc
concentration of
substances have been
identified arid conditions
require a high level of
respiratory protection. but
less skin protection. This
involves atmospheres:
- with immediatety
dangerous to life or
health (IDLH)
concentrations of
specific substances that
do not represent a skin
hazard: or
that do not meet the
criteria for use of air-
purifying oxygen.
2. Atmosphere contains less
than 19.5 percent oxygen.
3. Presence of incomp!etely
identified vapors or gases
is indicated by direct-
reading organic vapor
detection instrument, but
vapors and gases are not
suspected of containing
high levels of chemicals
harmful to skin or capable
of being absorbed through
the intact skin.
Equipment
Protection Provided
Should Be Used When:
Face shield.
Disposable boot covers.
Long cotton underwear.
18

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APPENDIX C
(Continued)
GENERAL DESCRIPTION OF ThE OERR LEVELS OF
PROTECTiON AND PROTECTIVE GEAR
RECOMMENDED:
• Full-facepiece, air-purifying,
canister-equipped
respirator (MSHNNIOSH
approved).
• Chemical-resistant clothing
(overalls and long-sleeved
jacket; hooded, one- or
two-piece chemical splash
surt; disposable chemical-
resistant one-piece suit).
• Inner and outer chemical-
resistant gloves.
• Chemical-resistant safety
boots and boot covers
(outer).
• Hardhat
o Two-way radios (worn
inside encapsulating suit).
OP11ONAL
• Boots with steel toe arid
shank.
• Coveralls.
• Disposable boot covers.
• Face shield.
• Escape mask.
The same level of skin
protection as Level B, but a
lower level of respiratory
protection.
1. The atmospheric
contaminants, liquid
splashes, or other direct
contact will not adversely
affect any exposed skin.
2. The concentration(s) of the
type(s) of airborne
substance(s) is known and
the cntena for using air-
purifying respirators are
met.
* Use of escape mask during initial envy is optional only after characterization (29 CFR
I 91 0.120(C) (5)(1i)).
LEVEL OF PROTECTION C
Equipment
Protection Provided
Should Be Used When:
19

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APPENDIX C
(Continued)
GENERAL DESCRIPTiON OF ThE OERR LEVELS OF
PROTECTiON AND PROTECTiVE GEAR
LEVEL OF PROTEC11ON D
Equipment
Protection Provided
Should Be Used When:
RECOMMENDED:
• Coveralls.
No respiratory protection.
1.
The atmosphere
known hazard.
• Safety bootslshoes, leather
Minimal skin protection,
no
or chemical-resistant, steel
toe and shank.
2.
Work functions preclude
the
• Safety glasses.
splashes. immersion,
for
• Hard hat.
potential
unexpected
inhalation of or contact with
OP11ONAL.
hazardous levels any
• Disposable chemical-
chemicals.
resistant boots (outer).
• Gloves.
• Escape mask.
• Face shield.
• Chemical splash goggles.
20

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APPENDIX D
OSWER INCIDENT SAFETY CHECK-OFF UST INSTRUCTIONS
The OSWER Incident Safety Check-Off Ust, when completed, fulfills the requirements for
performing Preliminary Evaluations under OSHA’s HAZWOPER standards, 29 CFR 1910.120. The
checklist is divided into two parts.
Part I, which includes the preliminary evaluation criteria, must be completed prior to leaving
the office for field activities. Part I requests information, such as: the site name and location,
response dates, activity description, topography and accessibility, suspected chemicals, relevant
PPE, and identification of site-specific health and safety plan. If the answers provided on the
form are not applicable to your particular site, you may simply write in the appropriate information
and any necessary explanations. When completing Part I, be certain to verify your responses
and to have a first-line supervisor or a health and safety officer review the information provided
and sign and date the form. Once the form has been properly signed and reviewed, field
operations may commence.
The following may assist you in completing Part I of the form:
• When responding to the site accessibIlity question (Question 6), keep in mind that
this information is primarily requested to evaluate the accessibility of the site for
emergency response and first-aid vehicles, if such a response should become
necessary.
• When responding to Question 7, please include the pathway (e.g., demial, inhalation)
along with the identification of the suspected chemical contaminant.
• Question 9 requires you to identify the level of Personal Protective Equipment (PPE)
you intend to use. If Level B is selected, you must also identify your “Buddy.” If
Level C is selected, you must identify the canister. If Level D is selected, you must
provide a justification for selecting such a response.
Upon returning from the response activity, complete Part II of the form to reflect what
actually transpired on-site. Part II must also be reviewed, signed, and dated by an appropriate
supervisor or officer. if you have any questions regarding the completion of this form, please
contact the Environ mental Response Team (ERT) at (908) 321-6741.
21

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APPENDIX 0
(Continued)
OSWER SUPERFUND INCIDENT SAFETY CHECK-OFF UST
BEFORE FIELD ACTIVITY Employee
1. IncIdent: Site City State
a. Response Dates __________________________________________________
2. ActMty Description: Environmental Sampling _________ Product Sampling __________
Residential _______ Site Evaluation ________ Containment _______ Well Drilling
Facility inspection
3. Type of Response: Spill _____ Site _____ Facility _____ Other __________
4. Site Topography: Mountains _____ Rivers ____ Valley ____ Rural _____
Suburban _____ Urban Level _____ Slopes ____
Facility ________
5. IncIdent Safety Plan: Not Developed ___________ Reviewed ______________
(when applicable) Region __________________ Bneted __________________
ERT______
6. Site AccessIbility: Road: Good __________ Air Good ______________
Fair ______________ Fair ___________________
Poor ___________ Poor ________________
7. Suspected chemical(s) and pathway with source(s) Involved:
(A) __________ (B) __________ (C) ____________ (D) ______________
8. Emergency Response Teams present for FIrst Aid, etc.: Yes _______ No _________
9. ProtectIve Level(s) Selected: (A) ______ (B) _______ (C) _______ (D)
(a) If Level ‘C’, Identify Canister _______________________________________________
if Level ‘D’, JUSTIFY: __________________________________________________
10. if SCBA, Identify Buddy System: Office/Name
11. Last Response: (a) Level Used: (A) _____ (B) ______ (C) _______ (D) _______
(b) Medical Attention/Exam Performed: Yes No ________
PART I: Date Prepared __________ Reviewed by __________________ Date _______
22

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APPENDIX D
(Continued)
OSWER SUPERFUND INCIDENT SAFETY CHECK-OFF UST
II. AFTER RESPONSE
1. ProtectIve Level Used: (A) ________ (B) ________ (C) _________ (D) _________
a Level ‘C, Identify canister _________ b. Level ‘D, JUSTIFY: __________________
c. Level B/C skin protection: Tyvek ______ Tyvek/Saran ______ Acid/Rain
Other ____________
2. Ust possible chemIcal exposure: Same as above: (A) _________(B)
(C) ( 0 ) _________
3. EquIpment Decontamination: (a) clothing (b) respirator (C) monitoring
Disposed:
Cleaned: ________ ________
No Action: ________ ________
4. ApproxImate time in exclusIon area: __________ hours per day for ____________ days.
PART II: Date Prepared Reviewed by _______________ Date _______
23

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APPENDIX E
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLiD WASTE AND EMERGENCY RESPONSE
RESPiRATORY PROTECTION PROGRAM
(Revised May 1991)
PURPOSE
The Office of Solid Waste and Emergency Response (OSWER) respiratory protection
program is intended to control exposures to those agents that may cause occupational
diseases when air is contaminated with harmful dusts, fogs, fumes, mists, gases, smokes,
sprays, or vapors.
II. OBJECTIVE
Respiratory protection may be property worn when effective engineering control methods
are not feasible, while they are being implemented, or in emergencies. Generally, most
corrective actions do not lend themselves to effective engineering controls. Therefore,
respiratory protection is judged to be the best approach to ensure worker health
protection. It is important to note, however, that effective work practices can minimize
reliance on such devices. The primary objective of this program is to protect the worker
against upoter . 4 jaiu exposure as well as measured exposure.
Ill. SCOPE
This respiratory protection program is intended to address all OSWER field activity
workers.
IV. RESPONSIBILITY
It is the responsibility of Section Chiefs/first-line supervisors to administer this program
in close liaison with medical monitoring personnel. Supervisors are required to provide
both the appropnate training and respiratory protection that workers need, at no cost to
the worker.
Workers shall use the respiratory protection provided in accordance with instructions and
training received. Each worker shall guard against damage to the respirator, report any
respirator malfunctions to the supervisor, and comply with the Respiratory Program.
V. PROGRAM ELEMENTS
A. The OSWER respiratory protection program meets all provisions of 29 CFR
1910.134 and 29 CFR 1910.120. in addition, It meets all U.S. EPA SHEMD’s
Occupational Heafth and Safety requirements, and the OERR’s ERD Standard
Operating Safety Guides.
24

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APPENDIX E
(Continued)
B. Program Elements
Standard Operating Procedures. This respiratory protection program shall
function as the written standard operating procedures governing the
selection and use of respiratory protection for OSWER personnel.
2. Respirator Fitting and Selection
a. The selection of the proper type of respiratory protection shall be
based primarily on, but not limrted to, the:
(1) Nature of the field activity;
(2) Type of respiratory hazard;
(3) Location of the hazardous area;
(4) Period of time for which respiratory protection must be
provided;
(5) Worker’s potential exposure;
(6) Worker’s activities;
(7) Worker’s physical characteristics and functional activities;
(8) Umttations of the various types of respirators; and
(9) Respirator protection factors/respirator fit.
b. Factors concerning both the potential and the measured hazard
shall be considered when requiring the use of respiratory
protection. These factors shall include, but not be limited to:
(1) Types of hazard;
(2) Physical and chemical properties;
(3) Physiological effects on the body;
(4) Expected concentration/level;
(5) Established ACGIH TLVs, OSHA PELs, and AIHA WEELs;
(6) IDLH considerations: and
(7) Agent warning properties.
C. U.S. EPA Environmental Response Team’s (ERT) Air Monitoring
Guidelines shall be followed, when applicable, to identify the type
of respiratory hazards, define their nature and potential (i.e., vapor,
particulate, etc.), and determine the concentration in the work area.
d. Factors concerning potential and actual site activities shall be
taken into account in selecting proper respiratory protection.
These factors include a description of work activities; description
of the potential hazards; agents of heatth concern; worker
exposure potential: and work activities. The selected respirator
protection must be continuously evaluated to reflect changes in
conditions or factors.
25

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APPENDIX E
(Continued)
e. The work activity location, with respect to a safe/clean area, shall
be considered when selecting respirator protection Not only does
this permit for a well-identified contamination reduction zone, but
it also requires the presence of emergency access and exit areas.
f. The period of time a respirator is to be worn shall be considered
when selecting respiratory protection.
g. Worker activities and locations during site activities shall be
considered when selecting proper respiratory protection.
h. The physical characteristics, functional capabilities, and
performance limitations of vanous types of respiratory protection
shall be considered when selecting a respirator.
The hazards for which a particular respirator is designed shall be
considered when selecting a respirator.
j. A qualitative respirator fit test shall be performed on each user to
determine a satisfactory fit for negative-pressure respirators. Test
results shall be used to select specific types, makes, and models
for individual workers. All OSWER Category 1, 2, and 3 workers
will be fit tested at least annually. Category 4 and 5 personnel will
be fit tested before each respirator use after the initial testing. Fit
testing is not required for positive pressure respirators (e.g., SCBA
units). lndMdual workers shall be trained to qualitatively check
respirator fit via the positive-negative pressure method each time
a unit is donned. Whenever possible, a quantitative fit test shall be
incorporated.
k. Respirators shall not be worn when conditions prevent a good seal.
Workers shall not wear respirator temple bars, straps, head
coverings, etc., between the sealing surface of the respirator.
Neither shall respirators be work if facial hair, features, etc., prevent
a good fit.
Respirator fit testing records shall be kept. Records shall include
type of fit-test method used, specific make and model of respirator
tested, name of worker tested, name of test operator, date of test,
and results of lit testing.
m. A variety of sizes of respirator facepieces shall be available to
OSWER personnel to accommodate the wide range of facial
shapes and dimensions among personnel.
n. Worker preference for a particular respirator model shall be
considered when selecting suitable respiratory protection. This
26

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APPENDIX E
(Continued)
includes factors such as comfort, breathing resistance, weight, field
of vision, etc. However, the preferred model must have a
satisfactory fit test and be MSHA/NIOSH approved.
o. Where feasible, respirators shall be individually assigned to workers
for their exclusive use. If a respirator is marked for identification
purposes, the marking shall not affect the respirator performance.
3. Training and Education
a. Each respirator wearer shall be given training that shall include
explanations and discussions of respiratory hazards and misuse;
the need for respiratory protection; the reason for selecting a
particular respirator; the function, capabilities, and limitations of the
selected respirator; the method for donning the respirator and
checking its fit and operation; proper wearing instructions;
respirator maintenance; recognizing and handling emergencies:
special instructions as required; regulations concerning respirator
use; and Identification of respirator cartridges and canisters by
color code.
b. The training shall include a hands-on portion that covers donning,
wearing, and removing the respirator; adjusting the respirator for
proper fit; and wearing the respirator in a safe atmosphere and in
a test atmosphere.
c. The Section Chief or designee is responsible for purchasing,
issuing, and training his/her personnel concerning any phase of
respiratory protection.
d. Trainers, workers, and others associated with the respiratory
protection program shall be trained to ensure the proper use of
respirators. Training shall include basic respiratory protection
practices; the nature and extent of expected respiratory hazard
exposure; pnnciples and criteria for selecting respirators; using
respirators and monitoring their use; maintenance and storage; and
regulations governing respirator use.
e. Each respirator wearer shall be retrained and fit tested at least
annually or as appropriate (e.g., after large changes in body
weight, dental surgery, etc.) when facial size or shape significantly
changes (see Paragraph V.B.2.j, page 29).
4. Cleaning and Disinfecting
a. Respirators shall be regularly cleaned and disinfected. Those
issued for the exclusive use of one worker should be cleaned after
27

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APPENDIX E
(Continued)
each day’s use, or more often if necessary. Those used by more
than one worker shall be thoroughly cleaned and disinfected after
each use (e.g., routine, non-routine, emergency, or rescue units).
For information regarding proper decontamination and cleaning
requirements and procedures, refer to 29 CFR 1910.120(k) and the
Standard Operating Guide for Decontamination of Response
Personnel (U.S. EPA, draft, Publication 9285.2-02A).
5. EquIpment Storage
a. Respirators shall be stored in a convenient, clean, and sanitary
location so that they are protected against dust, sunlight, extreme
temperature, excessive moisture, or damaging chemicals.
b. Respirators shall be stored to prevent distortion of rubber or other
elastomenc parts. Respirators shall not be stored in such places
as lockers and tool boxes unless they are adequately protected
from contamination, distortion, and damage. Consult the “use and
care TM Instructions, usually mounted inside the carrying case lid, for
proper storage of emergency respirators.
6. Inapectlon and Repair
a. Each respirator shall be inspected routinely before and after each
use. A respirator shall be inspected by the user immediately before
each use to ensure that it is in proper working condition.
b. After cleaning and sanitizing, each respirator shall be inspected to
determine whether it is in proper working condition, whether it
needs replacement parts or repairs, or whether it should be
discarded. Each respirator stored for emergency or roscue use
shall be inspected at least monthly and after each use by an
experienced person. Respirator inspection shall include a check
for tightness of connections; for the conditions of the respiratory
inlet covering, head harness, valves, connecting tubes, harness
assembly, filter(s), cartridges, canister, end-of-service-lift indicator,
and shetf-life date(s); and for the proper function of regulators,
alarms, and other warning systems.
c. Each rubber or elaslomeric part shall be inspected for pliability and
signs of deterioration. Each air and oxygen cylinder shall be
Inspected to ensure that it Is fully charged according to the
manufacturer’s instructions.
d. Only parts designed for a specific respirator shall be used in its
repair. Do not replace components or make adjustment or repairs
beyond the manufacturer’s recommendations. Reducing and
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APPENDIX E
(Continued)
admission valves or regulators shall be returned to the
manufacturer or to a trained technician for adjustment or repair.
e. A record of inspection dates, findings, and remedial actions shall
be kept for each SCBA respirator maintained for emergency or
rescue use.
7. SurveIllance
Appropriate surveillance or work area conditions and degree of worker
exposure or stress shall be maintained.
8. Evaluation of Respiratory Protection Program
a. There shall be periodic (at least annual) inspection and evaluation
to determine the continued effectiveness of the respiratory
protection program. It Is essential to ensure that all workers are
provided with adequate protection. The program should be
improved and deficiencies should be eliminated based on
evaluation results.
b. Respirator wearers shall be consutted periodically about their
acceptance of respirators. Frequent inspection of the program
shall be conducted to ensure that proper types of respirators are
selected; users are property trained; appropriate equipment is
issued and used; respirators are worn properly; respirators are in
good operating condition; respirators are inspected and maintained
properly; respiratory storage is acceptable; respiratory hazards are
monitored; and medical examinations are given as necessary to
evaluate user health.
c. The results of the inspection and evaluation shall be utilized to
improve or maintain elements of the program as appropriate.
Follow-up investigations shall be conducted to ensure that sources
of concerns are identified and corrected. Evaluation findings shall
be documented. Plans to correct program concerns shall be
documented (i.e., problem, target dates, responsibility, etc.).
9. MedIcal Approval
a. Each worker shall have a medical evaluation to determine fitness
to wear respiratory protection and potential exposure. Adequate
medical data shall be provided as part of the preplacement
examination and all subsequent examinations to allow a physician
to make judgment on each worker’s fitness (refer to Appendix B of
the OSWER Integrated Health and Safety Standard Operating
Practice for Field Activities for examination schedule).
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APPENDIX E
(Continued)
b. Workers shall show the examining physician their exposure records
(e.g., Incident Safety Check-Off Sheet [ see Appendix D of the
OSWER Integrated Health and Safety Standard Operating Practice
for Field Activitiesi) since thelast examination.
10. Approved Respiratory Protection
Only approved respiratory protection shall be selected when available.
Any modification of an approved respirator that is not authorized by the
approval agencies (e.g., MSHA and NIOSH) voids the respirator approval.
VI. AIR QUALITY
A. Compressed air, compressed oxygen, liquid air, and liquid oxygen used for
respiratory protection shall be of high purity. Compressed air should be the
principle source of breathing air. Compressed gaseous air shall meet at least the
requirements for Type 1 - Grade 0 breathing air of Compress Gas Association
Commodity Specification G-7.1 -1966.
B. Breathing air should be supplied to respirators from cylinders. All cylinders shall
be tested for quality and maintained in accordance with applicable DOT
specifications for shipping containers (49 CFR Parts 173 and 178).
C. Breathing air containers shall be marked in accordance with ANSI Z48.i-1954
(Ri 971) or Interim Federal Specification GG-B-675b, September 23, 1976.
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APPENDIX F
SUMMARY OF OSWER MEDICAL SURVEILLANCE REQUIREMENTS
FOR EACH WORKER CATEGORY
Category I
Category 2
Category 3
(RCRA only)
Baseline plus periodic
medical surveillance exam
not less than twice
annually. 1
Baseline plus annual
medical surveillance exam. 1
Baseline plus periodic
medical surveillance exam
based on potential
exposure frequency (Avg.
1-4 years). 1
T
Category I
Category 5
(RCRA only)
Category 6
Baseline plus periodic
medical surveillance exam
based on potential
exposure frequency (Avg.
1-4 years))
Baseline plus periodic
medical surveillance exam
based on potential exposure
frequency’ (Avg. 1-4 years).
Baseline recommended.
A “calendar year” is a somewhat arbitrary temi when discussing a measurement of exposure.
For example, 8 one-day visits to a site where the exposure is great or the toxicity is high may be
more critical to the heatth of the indMdual than 19 visits at another site. Therefore, all factors
must be considered when selecting the medical surveillance exam schedule.
‘For each Category, the examination rate may increase with increasing incidence of exposure.
1 The penodicity of all routine medical surveillance examinations, and related testing, is
determined by the occupational medical program, in accordance with National Medical
Surveillance Program guidance.
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APPENDIX G
AVAILABLE GUIDANCE
Standard Operating Guide for Air Sampling and Monitoring at Emergency Responses
(U.S. EPA, draft, Publication 9285.2-03A).
Standard Operating Guide for Decontamination of Response Personnel (U.S. EPA, draft,
Publication 9285.2-02A).
• Standard Operating Guide for Establishing Work Zones, (U.S. EPA, draft, Publication
9285.2-04A).
• Standard Operating Guide for Site Entiy (U.S. EPA, draft, Publication 9285.2-01 A).
• Standard Operating Guidelines for the Use of Air Monitoring Equipment for Emergency
Response (U.S. EPA, draft).
• Standard Operating Procedures for Site Safety Planning (U.S. EPA, 1985, Publication
9285.2-05).
• Occupational Medical Monitoring Program Guidelines for SARA Hazardous Waste Field
Activity Personnel (U.S. EPA, 1990, Publication 9285.3-04).
To obtain copies of any of these documents, call or write:
When ordering documents,
please be certain to provide
the appropriate document
number.
Standard Operating Safety Guides (U.S. EPA, 1992. Publication 9285.1 -03).
To obtain copies of this document, call or write:
•EPA employees may obtain
copies from the Superfund
Document Center.
U.S. EPA ERT
2890 Woodbridge Avenue
Building 18 (MS-i 01)
Edison, NJ 08837-3679
(908) 321-6740
National Technical Information
Service*
U.S. Department of Commerce
5265 Port Royal Road
Springfield, VA 22i 61
(703) 487-4650
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