Publication 9285.0-01C
November 2002
INTEGRATED HEALTH AND SAFETY PROGRAM
STANDARD OPERATING PRACTICES
FOR OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
FIELD ACTIVITIES
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
NOTICE
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Mention of trade names or commercial products does not constitute endorsement or recommendation for use.
Additional copies of this document can be downloaded from:
ERT Homepage: www.ert.org
or
the OSWER Intranet: http://intranet.epa.gov/swerrim2/documents/index.html
or obtained by writing to:
U.S. EPAERTC
2890 Woodbridge Avenue
Buliding 18 (MS-101)
Edison, NJ 08837-3679
When ordering the document, please refer to Publication 9285.0-01C
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ACRONYMS
American Conference of Governmental Industrial Hygienists
American Industrial Hygiene Association
Department of Transportation
Environmental Protection Agency
Environmental Response Team Center
Food and Drug Administration/Centers for Disease Control
Health and Safety Plan
ACGIH
AIHA
DOT
EPA
ERTC
FDA/CDC
HASP
HAZWOPER Hazardous Waste Operations and Emergency Response Standards
IDLH Immediately Dangerous to Life 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 Limit
PPE Personal Protective Equipment
RCRA Resource Conservation and Recovery Act
SARA Superfund Amendments and Reauthorization Act
SCBA Self-Contained Breathing Apparatus
SCUBA Self-Contained Underwater Breathing Apparatus
SEE Senior Environmental Employment
SHEMD Safety, Health, and Environmental Management Division
SOP Standard Operating Procedure
SOSG Standard Operating Safety Guides
TLV Threshold Limit Value
TSD Treatment, Storage, and Disposal
WEELS Workplace Environmental Exposure Levels
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ABSTRACT
PURPOSE
The purpose of this document is to establish Integrated Health and Safety Program Standard Operating
Practices for all Office of Solid Waste and Emergency Response (OSWER) employees who are actually or
potentially engaged in field activities (e.g., hazardous substance field activities, weapons of mass destruction
responses, Federal Response Plan responses, and related activities involving hazardous chemicals/substances)
and, as such is a matter relating to agency management or personnel.
BACKGROUND
Several laws and regulations require the United States Environmental Protection Agency (EPA) to protect
the health and safety of its employees. The Safety, Health, and Environmental Management Division (SHEMD)1
has overall responsibility for the development, organization, and administration of the EPA Health and Safety
Policies and Programs. OSWER, however, is also responsible for implementing certain health, safety, and
training programs applicable to employees within OSWER. The OSWER responsibility differs from SHEMD
in that OSWER is responsible for developing programs that specifically address the health and safety problems
that OSWER employees may encounter on the job.
This document, which is designed to inform the OSWER field employee 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 employees.
APPLICABILITY
These Standard Operating Practices are effective for all OSWER employees who are, or potentially may
become, engaged in field activities, both foreign and domestic. 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 (RCRA) (i.e., facilities regulated under 40 CFR Parts
264 and 265);
(2) Corrective actions at RCRA TSD facilities;
(3) Hazardous waste operations at uncontrolled hazardous waste sites;
(4) Emergency spill activities;
(5) Chemical emergency preparedness;
(6) Operations involving underground storage tanks;
(7) Operations involving solid wastes;
(8) Weapons of Mass Destruction response;
(9) Federal Response Plan responses; and
(10) Any other field activities involving hazardous or potentially hazardous substances.
'SHEMD is a division within the Office of Administration and Resources Management (OARM) in the
Office of Administration (OA) at EPA.
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TABLE OF CONTENTS
age
1.0 PURPOSE 1
2.0 OSWER REQUIREMENTS 1
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 Administrative 2
4.2 Training 4
4.3 Emergency Medical Services 4
5.0 FIELD ACTIVITY CATEGORIES AND PROCEDURES 4
5.1 Definition of Categories 4
5.2 Category Requirements 6
5.3 Standard Operating Guidelines 7
5.3.1 Pre-Arrival Planning 7
5.3.2 Safety On-Site 7
5.4 Personal Protective Equipment (PPE) 8
5.4.1 Heat Stress 8
5.5 Site Departure and Decontamination Procedures 8
5.6 OSWER Diving Operations 9
6.0 MEDICAL SURVEILLANCE PROGRAMS 10
7.0 TRAINING 10
8.0 HAZARD COMMUNICATION/RIGHT-TO-KNOW 1 1
8.1 Hazard Communication Requirements 12
8.2 Information and Training 13
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APPENDICES
A OSWER Integrated Health and Safety WorkGroup A-l
B Summary of OSWER Medical Surveillance Requirements
for each Employee Category B-l
C General Description of the OERR Levels of Protection
and Protective Gear C-l
D OSWER Incident Safety Check-Off Sheet and
Instructions D-l
E U.S. EPA OSWER Respiratory Protection Program E-l
F Summary of the OSWER Health and Safety Training
Course Requirements F-l
G References G-l
H Sample Certification Form H-l
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1.0 PURPOSE
The purpose of this document is to establish Integrated Health and Safety Program Standard Operating
Practices for all Office of Solid Waste and Emergency Response (OSWER) employees who are actually or
potentially engaged in field activities (e.g., hazardous substance field activities, weapons of mass destruction
responses, Federal Response Plan responses, and related activities involving hazardous chemicals/substances)
and, as such is a matter relating to agency management or personnel.
Each OSWER employee involved in field activities must receive appropriate training, equipment, and
medical surveillance in accordance with the Safety, Health, and Environmental Management Division's
(SHEMD)2 Health and Safety Policies and Programs, the Office of Emergency and Remedial Response
(OERR) Standard Operating Safety Guides (SOSGs),3 as well as other appropriate Federal/state requirements
and guidelines such as 29 CFR 1910 and 1926.
2.0 OSWER REQUIREMENTS
2.1 Requirements for Field Activities
All OSWER employees who participate in field activities must be classified into field activity
categories. Once employees are classified, they must receive training and medical surveillance prior to
performing any field work. (Employee 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 employee is assigned, or for which
he/she is specifically qualified by training and practical experience, is prohibited. Therefore, supervisors are
not authorized to order, direct, or otherwise instruct an employee to engage in work activities involving hazards
that are beyond the scope of the employee's field certification(s). In the event that an employee 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 employee will be deemed to have willfully self-endangered
himself/herself, in violation of EPA procedures. Such employees will be disciplined in accordance with
established policies, and may be denied Worker's Compensation benefits in the event of related injury or
illness. Such employees also may incur other personal liabilities.
2.2 OSWER Practices as Applied to Non-EPA Organizations
In implementing these Health and Safety Standard Practices, OSWER maintains the position that,
by contract, contractors are required to satisfy all Federal, state and local statutes, regulations, ordinances,
etc., regarding health and safety. The contractor also must develop a health and safety plan in accordance
with the contract statement of work. After developing its health and safety plan, the contractor is required
2SHEMD is a division within the Office of Administration and Resource Management (OARM) in the
Office of Administration (OA) at EPA.
3ERTC is a within the Office of Emergency and Remedial Response (OERR) in OSWER. The SOSGs
developed by ERTC 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 topics 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,
refer to Appendix G or contact the National Technical Information Service (NTIS) at (800) 553-6847.
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to submit it for review to the contracting officer. Thus, at a minimum, OSWER expects each contractor to
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 OERR
SOSGs.
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 as long as they provide for a level of employee safety
equivalent to the OSWER practices, and they are at least as stringent as those practices.
3.0 AUTHORITY
The authority for this program is derived from: EPA SHEMD and all applicable Federal
regulations, Executive Orders, Directives, Policies, Programs, and Practices.
4.0 RESPONSIBILITY
The OSWER Integrated 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 activities with regard to OSWER worker occupational health and safety activities.
(Refer to Appendix A for relevant contacts, telephone numbers and e-mail addresses).
4.1 Administrative
The following personnel are responsible for implementing and administering the OSWER
Integrated Health and Safety Program Standard Operating Practices.4
The Assistant Administrator of OSWER, or designee, is ultimately responsible for
ensuring that all field activity employees 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, 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 Senior Environmental Scientist, Environmental
Response Team Center (ERTC), 2890 Woodbridge Avenue, Building 18 (MS 101),
Edison, NJ, 08837, (732) 321-6740. (Refer to Appendix A for the list of the OSWER
Integrated Health and Safety Workgroup members.)
Division Directors are delegated the authority to identify and assign each field activity to
an individual employee. The Division Director will provide the "assigned" employee with
a complete description of the field activity categories. Division Directors are responsible
for budgeting allocated funds for: (a) safety training; and (b) purchasing, maintaining, and
storing employee safety equipment. The Division Director will be held accountable for
maintaining Employee Safety and Training Records, which contain all safety-related
4These practices identify six distinct field activity categories into which employees 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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matters, and for purchasing, issuing, and training his/her personnel on all phases of
personal protective equipment and medical surveillance.
Note: Once the list of categorized employees has been compiled by the Division
Director, the information should be transmitted to ERTC. Each list must include the
following information: the employee's first and last name; office; mail code; e-mail
address; and category. Upon receipt of these lists, the ERTC staff will solicit relevant
employee training and medical records, including updates. Such information will be
recorded by the ERTC staff into a database. Annually, ERTC will send computer-
generated copies of employee records to the appropriate Division Director and will
request that the Division Director, or designee, modify the information according to
employee changes or recategorizations. The Division Director is responsible for
transmitting the updated information to ERTC so that the employee database can be
modified accordingly.
Affected EPA Employees 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 employee by the Division Director. Once such
forms are signed by the employee, the appropriate Division Director will retain the form
for documentation purposes.
An "employee" is defined as any full, part-time, temporary, or permanent EPA employee;
a detailee to EPA from another government agency; an individual enrolled in the EPA
Senior Environmental Employment (SEE) Program; a student assigned to EPA; an EPA
stay-in-school program participant; an intern or fellow assigned to EPA; and any other
individual who is designated on a case-by-case basis by the Director of SHEMD.
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 employees 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 employee training, the task
of ensuring that all employees receive the proper mandatory safety training and equipment on a day-to-day
basis is borne jointly by the OSWER Office Directors, Division Directors, and employees.
4.3 Emergency Medical Services
In addition to routine medical surveillance coverage, the employee may be entitled to certain
emergency and other medical services provided under Worker Compensation programs. It is the
employee'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.
5For additional information on TLVs, refer to the Threshold Limit Value for Chemical Substances and
Physical Agents and Biological Exposure Indices, published by the American Conference of Governmental
Industrial Hygienists (ACGIH). For further information on PELs, refer to 29 CFR 1910.1000, Subpart Z.
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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 F and B, respectively.
A Division Director may modify an employee's category assignment by providing written
notification to the Senior Environmental Scientist, ERTC. This notification must identify the changes(s) in
the field activity category and verify that the appropriate training, equipment, and medical examination(s)
have been provided to the individual, as required for reclassification.
Category 1 is established as the OSWER highest risk category. This category includes all
employees whose job description/critical job elements require handling of, or potential
exposure to, identified or unidentified hazardous chemicals. For example, employees who
respond to spill emergencies, engage in hazardous waste operations at uncontrolled
hazardous waste sites, and perform corrective actions at RCRA TSD facilities (e.g., ERTC
personnel) fall within this category. Category 1 employees 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).
All Category 1 employees 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, in accordance with National Medical Surveillance Program.
Category 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, employees must be present in the relevant zone or
area for more than approximately 20 days per calendar year.6 Category 2 employees
are authorized to wear OERR PPE Levels C and D.
Category 2 employees are also 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, in accordance with the National Medical Surveillance Program.
Category 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. To fall under this category, an employee must be present at such a facility for
more than approximately 20 days per calendar year. These employees are authorized
to wear OERR PPE Levels C and D.
These employees must receive a baseline medical examination plus updates based on
potential exposure frequency, in accordance with the National Medical Surveillance
Program.
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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Category 4 includes those OSWER personnel who are required to enter a Superfund or
RCRA Corrective Action "Exclusion Zone" or an RCRA TSD facility "Activity Area"
where there is the potential for exposure to identified or unidentified hazardous chemicals.
However, to fall within this category, employees must be present in the relevant zone or
area for fewer than approximately 20 days per calendar year. Category 4 employees
are authorized to wear OERR PPE Levels C and D.
Category 4 employees must also receive a baseline medical examination with updates
based on potential exposure frequency, in accordance with the National Medical
Surveillance Program.
Category 5 includes those OSWER personnel who are required to enter an RCRA TSD
facility where there is potential for exposure to identified or unidentified hazardous
chemicals. To fall within this category, an employee must be present at such a facility for
fewer than approximately 20 days per calendar year. Category 5 employees are
authorized to wear OERR PPE Levels C and D.
These employees must also receive a baseline medical examination plus updates based on
potential exposure frequency, in accordance with the National Medical Surveillance
Program.
Category 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
"Secure/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 employees
in Categories 1 through 5.
These employees are authorized to wear OERR PPE Level D. A baseline medical
examination will be conducted for Category 6 employees if it is deemed necessary, in
accordance with the National Medical Surveillance Program.
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 employee 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 OERR SOSGs
for guidance and selection criteria. OSWER personnel must also 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
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regulations, employees are expected to implement those practices that afford the 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 employee 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, the OSHA HAZWOPER standards, 29 CFR 1910.120, and 29 CFR
1910.134 Appendix C OSHA, Respirator Medical Evaluation Questionnaire prior to
involvement in field activities, and/or other types of activities similar to field activities;
and
(d) Be assigned the appropriate Field Activity Category.
5.3 Standard Operating Guidelines
5.3.1 Pre-Arrival Planning
In planning a field activity, it is each employee'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.
Although lead time and availability of information are often limited, the employee must attempt to
complete the OSWER Superfund Incident Safety Check-off list form (See Appendix D) prior to departing
the office. If an emergency arises, it is recommended that the employee and his/her supervisor contact the
Environmental Response Team Center Edison, NJ Hotline at (732) 321-6660, for technical assistance.
Site Safety Plans must also be completed prior to site entry, in accordance with 29 CFR 1910.120 and the
OERR SOSGs.
5.3.2 Safety On-Site
The general rule is that employees cannot participate in or supervise field activities until they have
been properly 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 employees on-site and the general public. Because all
training must be consistent with the requirements specified in 29 CFR 1910.120, training sessions must
address, at a minimum: (a) the names of personnel responsible for site safety and health; (b) the safety,
health, and other hazards present on the site; (c) the proper use of PPE; (d) the work practices by which an
employee can reduce the risk from hazards; and (e) relevant medical surveillance requirements, including
recognition of signs and symptoms which might indicate overexposure to a particular hazard. (Refer to 29
CFR 1910.120(e) for additional training information.)
Once employees have satisfied the relevant training requirements, they may engage in field
activities. The buddy system must be employed in the field. OSWER field personnel shall not enter an
"Exclusion Area" or a RCRA TSD hazardous waste facility without another appropriately trained
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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
OERR SOSGs. If any condition is discovered to be more hazardous than originally anticipated, all field
activities must cease temporarily until a re-evaluation of the hazards and the level of protection occurs.
In the event that an OSWER field activity employee 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 SHEMD 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.
Employees are required to refer to the OERR SOSGs for a detailed description of the levels of protection
and selection criteria. (Refer to Appendix G for information on how to obtain these Standard Operating
Guides). Other relevant guidance includes the OSWER Respiratory Protection Program, which is included
in Appendix E of this document.
5.4.1 Heat Stress
As covered in the OERR SOSGs, heat stress is a potential area of concern for those employees
wearing PPE. Since EPA and OSHA require the use of PPE in a hazardous work environment, the
procurement of water and commercially available liquid electrolyte replacements is a reimbursable cost. If
a question exists as to what is an acceptable commercially available liquid electrolyte replacement, the
employee must contact his/her first line supervisor and/or ERTC prior to purchasing. In general, fruit, fruit
juice, and food items are not considered to be acceptable electrolyte replacements for EPA OSWER field
activities.
5.5 Site 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 clothing and sampling equipment must also be
decontaminated (preferably on-site) in accordance with the OERR 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).
For additional guidance regarding decontamination procedures and requirements, refer to 29 CFR
1910.120(k) and the Respiratory Cleaning Procedures 29 CFR 1910.134, Appendix B-2.
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5.6 OSWER Diving Operations
Federal and state regulations apply to all areas within their respective jurisdictions. The OSWER
Health and Safety policy may require additional safety equipment or procedures beyond those required by
Federal or state regulations. Should a direct conflict arise, the more protective or conservative regulation
shall take precedence. All OSWER employees who are members of a "dive team" must read, understand,
and comply with all applicable regulations and procedures including the Site Specific Health and Safety
Plan (HASP), this SOP, 29 CFR 1910.410-Subpart T-Commercial Diving Operations, and the U.S. EPA
Diving Safety Manual, latest edition.
Only tasks to be executed by the OSWER personnel, as directed by U.S. EPA/ERTC, are
considered scientific (see below) as defined in 29 CFR 1910.410. Specific technical requirements of the
regulation are also met in that all dive team assignments are conducted and controlled under a diving
program (U.S. EPA Dive Control Safety Board) with the following elements:
A diving safety manual (U.S. EPA Diving Safety Manual) that includes procedures
covering all dive operations specific to the program; procedures for emergency care
including recompression and evacuation; and criteria for diver training and certification.
A dive control safety board, with the majority of its members being active divers, which
shall at a minimum have the authority to: approve and monitor diving projects; review and
revise the diving safety manual; assure compliance with the safety manual; certify depths
to which a diver has been trained; take disciplinary action for unsafe practices; and, assure
adherence to buddy system for Self-Contained Underwater Breathing Apparatus (SCUBA)
diving.
Scientific diving, as indicated in 29 CFR 1910.402, is diving performed solely as part
of a scientific, research, or educational activity by employees whose sole purpose for
diving is to perform scientific research tasks. Scientific diving does not include
performing any tasks usually associated with commercial diving such as: placing or
removing heavy objects underwater; inspection of pipelines and similar objects;
construction; demolition; cutting or welding; or the use of explosives. Tasks commonly
performed under Superfund and the direction of the EPA/ERTC are those of an observer
of natural phenomenon, responses of natural systems, a gatherer of data for scientific
analysis and other Superfund activities. These include: the collection of sediment or biota
samples to determine the presence or effects of low-level chemical contamination and their
subsequent environmental impacts; observation of subsurface conditions (i.e., ecological
or benthic surveys); search for the presence of containers (i.e., drums) to document
location, general condition and, if possible, contents within the container without using
any intrusive methods, and the video documentation of subsurface conditions in
conjunction with the above-mentioned tasks.
Tools commonly used during routine dive operations are usually hand-held
(i.e., measuring devices, small hammers, cameras, plastic core tubes, hand nets, and
sample collection jars). All dive team members are scientists, including chemists,
engineers, and environmental scientists, that use scientific expertise relevant to their
respective discipline in conducting dive team operations. Information and data gathered
as a result of dive team efforts are non-proprietary and available for public review. Dive
team operations do not include activities mentioned above (construction or removal of
heavy objects underwater, etc.) that are generally considered as commercial diving
operations.
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6.0 MEDICAL SURVEILLANCE PROGRAMS
OSWER field activity employees in Categories 1 through 5 must undergo a baseline health
profile. A baseline examination is also recommended for Category 6 employees; however, such an
examination is not required. Following the baseline profile, based on field exposure classification,
OSWER employees in Categories 1 through 5 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 in categories 1 through 5 must receive a medical
examination/consultation as soon as possible after notifying their supervisors that they have 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 permissible exposure levels (PELs) 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 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 Category 6 employees if the examining physician determines that such a follow-up is medically
necessary.7
Immunization. It is OSWER policy to offer pre-incident vaccinations (i.e., anthrax) in accordance
with all FDA/CDC guidelines to high-risk OSWER employees on a voluntary basis. Pre-incident
vaccination does not preclude the use of post-exposure antibiotic prophylaxis.
High-risk employees are defined as those who may be physically involved in the monitoring and
cleanup of weapons of mass destruction, biological or chemical agents.
A summary of the OSWER Medical Surveillance Requirements according to Field Activity
Category is included in Appendix B. (Also, refer to"Occupational Medical Surveillance Program
Guidelines for National Contingency Plan and Federal Response Plan Activities," U.S. EPA, 2002
Publication 9285.3-04-A.)
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 variety of courses
offered, and the need for specific training within each category necessitates formulation of certain ground
rules:
Each OSWER field activity employee must receive safety training commensurate with
his/her job requirements and field exposure classification. In addition, the supervisor must
recommend additional safety training courses for each employee's future needs.
A series of core topics are designated for each employee field category as specified in
Appendix F, "Summary of the OSWER Health and Safety Training Course
Requirements." The core topics specified in Appendix F are mandatory for all OSWER
729 CFR 1910.120(f)(3).
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field activities category employees. The other topics identified as "desirable" should be
taken by employees based upon the recommendations of their supervisors.
Division Directors are ultimately responsible for ensuring that their employees 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.
Categories 1, 2, and 4: These employees must receive 40 hours of initial training, plus three 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 eight hours of "Supervisor
Training.") All employees must also receive eight hours of refresher training annually.
Categories 3 and 5: These employees must receive 24 hours initial training and eight hours
refresher training annually.
Category 6: Although not required by 29 CFR 1910.120 and 1910.121, all Category 6 employees
are by this Practice required to have a minimum of four hours of training in those areas identified
in Appendix F.
Note: All Division Directors in charge of field activity employees must receive commensurate safety
training in all applicable field safety categories.
8.0 HAZARD COMMUNICATION/RIGHT-TO-KNOW
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 communication/right-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 employees and contractors and their representatives must be
informed of the physical and health hazards of known substances in the work area. In addition, OSWER
employees and contractors must be notified of methods to detect hazardous substances and any measures
that employees 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 inks,
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 hazardous waste
-------
and, therefore, OSWER workers, 29 CFR 1910.120 fills the gap. For example, 29 CFR 1910.120(b)
requires (a) a written site-specific health and safety plan that addresses the safety and health risk or hazard
analysis for each site task; and (b) identification of risks and communication of those risks to employees
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 prior to conducting
site work. It is required in 29 CFR 1910(i) that an informational program be implemented to inform
employees, contractors, subcontractors, or their representatives, of the nature, level, and degree of exposure
potential. Finally, for RCRA employees, 29 CFR 1910.120(p)(2) requires employees to implement a
hazardous communication program. Thus, 29 CFR 1910.120, which applies to all OSWER employees,
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 also maintains that a material safety data 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 on-site. Inclusion of such information will thereby satisfy the requirements of 29 CFR
1910.120.
8.1 Hazard 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 employees may be
exposed under normal conditions (e.g., compressed gases);
(b) Reagents brought on-site for use in collecting samples for future analysis, 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:8
(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: chemical and common name;
Physical and chemical characteristics;
Physical hazards;
Health hazards;
Primary routes of entry;
PELs and TLVs or other published exposure levels;
Whether or not the chemical is considered a carcinogen;
829 CFR 1910.1200(e), (f), (g), and (h).
11
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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 the individual who prepared the MSDS.
(c) Employers must provide employees 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
Division Director is responsible for providing employees with information and training on hazardous
chemicals in their work area. (All parties working together at hazardous waste sites or spill
emergency/accident must share all available information on the possible hazards present in the area.)
OSWER field activity employees in Categories 1 through 6 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 MSDS.
Training for OSWER activity employees in Categories 1 through 6, at a minimum, should 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 employees 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
employees (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 Division Director 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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APPENDIX A
OSWER INTEGRATED HEALTH AND SAFETY WORKGROUP
WORKGROUP CHAIR, Rod Turpin,
Chief National Health and Safety Advisor
Environmental Response Team
Edison, New Jersey
732-321-6741
Fax: 732-321-6724
turpin.rodtaiepa.gov
f Safety, Health, and
Environmental Management Division (OARM)
Dave Gibson
202-564-4242
gibson.dave(2iepa.gov
Kevin Dressman
202-564-1652
dressman.kevin(S!epa.gov
Office of Brownfields Cleanup and Redevelopment
Anthony Raia
202-566-2758
ria.anthony(S!epa.gov
Office of Solid Waste
David Carver
703-308-8603
carver. david(2jepa.gov
Mark Schuknecht
703-308-7294
schuknecht.markt^epa.gov
Frank Behan
703-308-8476
behan.frank(g)epa.gov
Nicole Schindler
703-308-8855
schindler.nicole(S!epa.gov
Chemical Emergency Preparedness and
Prevention Office
Awilda Fuentes
202-564-7996
fuentes.awilda(S!epa.gov
Craig Beasley
703-603-9015
beasley.craig(Siepa.gov
Office of Underground Storage Tanks
Stephen Fields
703-603-7144
fields. stephen(5)epa. go v
Office of Emergency and Remedial
Response
James Konz
703-603-8841
konz.james(Siepa.gov
JoAnn Griffith
703-603-8774
griffith.ioann(g)epa.gov
Environmental Response Team Center
Sella Burchette
732-321-6726
burchette. sellatajepa. go v
A-l
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APPENDIX A
OSWER INTEGRATED HEALTH AND SAFETY WORKGROUP
WORKGROUP CHAIR
Rod Turpin,
Senior Environmental Scientist
Environmental Response Team Center
Edison, New Jersey 08837 (MS-101)
732-321-6741
Fax:732-321-6724
Safety, Health, and Environmental
Management Division
Dave Gibson
. 202-564-4242-
gibson.dave@epa.gov
Chemical Emergency Preparedness and
Prevention office
Awilda Fuentes
202-564-7996
fuentes.awilda(S!epa.gov
John Ferris
202-564-7992
ferris.john(Siepa.gov
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Office of Solid Waste
David Carver
703-308-8603
carver. david(S!epa.gov
Mark Schuknecht
703-308-7294
schuknecht.mark(5)epa.gov
Frank Behan
703-308-8476
behan.frank(S!epa.gov
Nicole Schindler
703-308-8855
schindler.nicoletajepa.gov
Office of Underground Storage Tanks
Stephen Fields
703-603-7144
fields. stephen(gjepa. go v
OARM
Office of Emergency and Remedial
Response (Superfund/Oil Programs)
James Konz
703-603-8841
konz.james (5jepa.gov
JoAnn Griffith
703-603-8774
griffith.ioann(Siepa.gov
Craig Beasley
703-603-9015
beasley.craig(S!epa.gov
Environmental Response Team Center
Sella Burchette
(732)321-6726
burchette. sella(5)epa.gov
A-3
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APPENDIX B
SUMMARY OF OSWER MEDICAL SURVEILLANCE REQUIREMENTS
FOR EACH WORKER CATEGORY
Category 1
Category 2
Category 3
(RCRA only)
Baseline plus periodic medical
surveillance. Exam scheduling
based on potential exposure
frequency (not more 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
Category 4
Category 5
(RCRA only)
Category 6
Baseline plus periodic medical
surveillance exam based on
potential exposure frequency (Avg.
1-4 years).1
Baseline plus periodic medical
surveillance exam based on potential
exposure frequency (Avg. 1-4 years).
Baseline recommended.
*A "calendar year" is a somewhat arbitrary term 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 health of the individual
than 19 visits at another site. Therefore, all factors must be considered when selecting the Medical Surveillance Exam
Schedule.
"Examination rate may increase with increasing incidence of exposure.
lrThe periodicity of all routine medical surveillance examinations and related testing is determined by the occupational
medical program, in accordance with the National Medical Surveillance Program .
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APPENDIX B (continued)
MINIMUM EXAMINATION TYPES AND CONTENT
History and Physical Exam
Complete Medical History
Interval History
Physical Examination by a Physician
Visual Acuity
Routine Laboratory
Pulmonary Function
Audiometry
Electrocardiogram
Chest x-ray
Complete Blood Count1
Routine Urinalysis
Blood Chemistry
Special Tests*
Cholinesterase
Methemoglobin
Heavy Metal Screen
Urine and Sputum Cytology
Polychlorinated Biphenyl (PCB)
Cardiovascular Stress Test
*Any special test which may be
considered on a periodic basis should be
included in the baseline test.
Baseline
X
X
X
X
X
X
X
X
X
X
X
0
X
0
0
X
Periodic
0
X
X
X
X
X
0
0
X
X
X
0
0
0
0
0
0
Termination
X
X
X
X
X
X
X
X
X
X
0
0
0
0
0
Unscheduled
X
X
0
0
0
0
0
0
0
0
0
0
0
0
0
x - Recommended
0 - As indicated
1 Minimum desired contents of blood chemistry tests :
Complete blood cell (CBC) count w/differential and platelet count
Complete blood cell (RBC) indices (MCV, MCH, MCHC)
Albumin, globulin, total protein
Aspartate aminotransferase (AST)
Alanine aminotransferase (ALT)
Lactic dehydrogenase (LDH)
Alkaline phosphatase
Total bilirubin
Uric acid
Creatinine
Blood urea nitrogen (BUN)
Cholesterol
Glucose
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APPENDIX B (continued)
Recommended Occupational Medical Surveillance Program for
OSWER Categories 1 and 2 Employees
Examination Content
O - As indicated
Examination Types
Baseline
Periodic1
Termination
Unscheduled
History and Physical Exam
Complete medical history (MH)
Interval history
Physical exam by physician
Visual acuity/pupil rx
X
X
X
O
X
X
X
X
X
X
X
X
o
Routine Lab Tests/Procedures
PPE evaluation/spirometry
Audiometry
Electrocardiogram (EKG)
Chest x-ray
Routine urinalysis
Blood chemistry2
X
X
X
X
X
X
X
X
O
O
X
X
X
X
X
X
X
X
o
o
o
o
o
o
Special Tests/Procedures
Cholinesterase (ChE)
Slit-lamp examination
Intraocular pressure
Blood sample collection/storage
Methemoglobin
Heavy metal screen
Urine and sputum cytology
Polychlorinated bypheny (PCB)
Cardiovascular stress test
Sub-maximal cardiovascular stress test
X
X
X
X
O
X
O
O
O
X
x3
X
O
O
O
O
O
o4
X
X
X
X
o
o
o
o
o
o
o
o
o
o
o
o
o
Routine Vaccinations: Available upon request to all state-side personnel. Overseas deployments to follow State Department recommendations, following
Immunization Practices Advisory Committee (ACIP) Recommendations.
All Geographic Areas
Influenza
Hepatitis A & B
Tetanus-diphtheria
Anthrax (full series with annual boosters)
Smallpox (when available)
Others as recommended by CDC/public health officials
Selected Geographic Areas
Plague
Rabies
Denotes annual requirement, unless otherwise mentioned.
2Minimum desired contents of blood chemistry tests:
Complete blood cell (CBC) count w/differential and platelet count
Red blood cell (RBC) indices (MCV,MCH,MCMH)
Albumin, globulin,total protein
Aspartate aminotransferase
Alanine aminotransferase
Lactic dehydrogenase
Alkaline phosphatase
Total bilirubin
Uric acid
Creatinine
Blood urea nitrogen (BUN)
Cholesterol
Glucose
3If slit-lamp is unavailable for periodic examination, an examination of the cornea and conjunctiva using magnification lens, Wood's light, and fluorescein
strips is acceptable.
4To be given periodically when required warning signs are present or individual fails sub-maximal test.
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APPENDIX C
GENERAL DESCRIPTION OF THE OERR LEVELS OF
PROTECTION AND PROTECTIVE GEAR
Personal protective equipment has been divided into four categories based
on the degree of protection afforded:
LEVEL OF PROTECTION A
Equipment
Protection Provided
Should Be Used When:
RECOMMENDED:
Pressure-demand, full-face-
piece, self-contained
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.
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).
OPTIONAL:
Hard hat (under suit).
Coveralls.
Lone Cotton underwear.
The highest available level of
respiratory, skin, and eye
protection.
3.
The chemical substance has
been identified and requires
the highest level of
protection for skin, eyes, and
the respiratory system.
Substances with a high
degree of hazard to the skin
are known or suspected to be
present, and skin contact is
possible.
Operations must be
conducted in confined,
poorly ventilated areas until
the absence of conditions
requiring Level A protection
is determined.
C-l
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APPENDIX c (continued)
GENERAL DESCRIPTION OF THE OERR LEVELS OF
PROTECTION AND PROTECTIVE GEAR
LEVEL OF PROTECTION B
Equipment
Protection Provided
Should Be Used When:
RECOMMENDED:
Pressure-demand, full-face-
piece SCBA (MSHA/NIOSH
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).
Hard hat.
Two-way radios (worn inside
encapsulating suit).
OPTIONAL:
Coveralls.
Face shield.
Disposable boot covers.
Long cotton underwear.
The same level of respiratory
protection but less skin
protection than Level A.
It is the minimum level
recommended for initial site
entries until the hazards have
been further identified.
1. The type and atmospheric
concentration of substances
have been identified and
conditions require a high
level of respiratory
protection, but less skin
protection. This involves
atmospheres:
with immediately
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 incompletely
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.
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APPENDIX C (continued)
GENERAL DESCRIPTION OF THE OERR LEVELS OF
PROTECTION AND PROTECTIVE GEAR
LEVEL OF PROTECTION C
Equipment
Protection Provided
Should Be Used When:
The same level of skin protection
as Level B, but a lower level of
respiratory protection.
The atmospheric
contaminants, liquid
splashes, or other direct
contact will not adversely
affect any exposed skin.
The concentration(s) of the
type(s) of airborne
substance(s) is known and
the criteria for using air-
purifying respirators are met.
RECOMMENDED:
Full-face-piece, air-purifying,
canister-equipped respirator
(MSHA/NIOSH approved).
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 and boot covers
(outer).
Hard hat.
Two-way radios (worn inside
encapsulating suit).
OPTIONAL:
Boots with steel toe and
shank.
Coveralls.
Disposable boot covers.
Face shield.
Escape mask.*
* Use of escape mask during initial entry is optional only after characterization (29 CFR 1910.120(c)(5)(ii).
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APPENDIX c (continued)
GENERAL DESCRIPTION OF THE OERR LEVELS OF
PROTECTION AND PROTECTIVE GEAR
LEVEL OF PROTECTION D
Equipment
Protection Provided
Should Be Used When:
RECOMMENDED:
Coveralls.
Safety boots/shoes, leather or
chemical-resistant, steel toe
and shank.
Safety glasses.
Hard hat.
OPTIONAL:
Disposable chemical-
resistant boots (outer).
Gloves.
Escape mask.
Face shield.
* Chemical splash goggles.
No respiratory protection.
Minimal skin protection.
1. The atmosphere contains no
known hazard.
2. Work functions preclude
splashes, immersion, or the
potential for unexpected
inhalation of or contact with
hazardous levels of any
chemicals.
C-4
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APPENDIX D
OSWER INCIDENT SAFETY CHECK-OFF LIST INSTRUCTIONS
The OSWER Incident Safety Check-Off List, when completed, fulfills the
requirements for performing Preliminary Evaluations under OSHA's HAZWOPER
standards, 29 CFR 1910.120. The checklist is divided into two sections.
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 Section 1 of the form. Once the
form has been 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 pathway (e.g., dermal, inhalation, etc.)
along with the identification of the suspec ted 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 Environmental Response Team Center (ERTC) at (732) 321-6741.
D-l
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Appendix D (continued)
OSWER SUPERFUND INCIDENT SAFETY CHECK-OFF LIST
Employee:
I. BEFORE FIELD ACTIVITY
1. Incident: Site:
(a) Response dates:
City:
State:
2. Activity description: Environmental sampling D Product sampling D
Residential D Site evaluation D Containment D Well drilling D
Facility Inspection D Other D
3. Type of response: Spill D Site D Facility D Other D
4. Site topography: Mountains D Rivers D Valley D Rural D
5. Incident Safety Plan:
(when applicable)
6. Site accessibility:
Suburban D
Facility D
Not developed
Region
ERTC
Road: Good D
Fair D
Poor D
Urban D
n
n
n
Level D
Reviewed
Briefed
Facility
Air: Good D
Fair D
Poor D
Slopes D
n
n
n
7. Suspected chemical(s) and pathway with source(s) involved:
(i) (ii) (iii)
(iv).
8. Emergency Response Teams present for First Aid, etc.: Yes D
9. Protective level(s) Selected: (A) D (B) D (C) D
(a) If Level "C", identify canister
If Level "D", justify:
NO n
n
10. If SCBA, identify Buddy System: Office/Name:
11. Last response: (a) Level used: (A) D
PART I: Date prepared:
(B) n (c) n (D) n
(b) Medical attention/Exam performed: Yes D No D
Reviewed by: Date:
D-2
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APPENDIX D (continued)
OSWER SUPERFUND INCIDENT SAFETY CHECK-OFF LIST (continued)
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 D
4. Approximate time in exclusion area:
Tyvek/Saran
D Acid/Rain
D
Other D
2. List possible chemical exposure: Same as above: (a) (b)
(c) (d))
3. Equipment decontamination: (a) Clothing (b) Respirator (c) Monitoring
Disposed:
Cleaned:
No Action:
_ hr/day for days.
PART II: Date prepared:
Reviewed by:
Date:
D-3
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APPENDIX E
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised January 1999)
I. 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 properly worn when effective engineering control methods are not feasible,
while they are being implemented, or in emergencies. Generally, most corrective actions do not lend
themselves to effective engineering controls. Therefore, respiratory protection is judged to be the best
approach to ensure employee 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
employee against "potential" exposure as well as measured exposure.
III. SCOPE
This respiratory protection program is intended to address all OSWER field activity employees.
IV. RESPONSIBILITY
It is the responsibility of Division Directors to administer this program in close liaison with medical
surveillance personnel. Supervisors are required to provide both the appropriate training and respiratory
protection employees need, at no cost to the employee.
Employees shall use the respiratory protection provided in accordance with instructions and training
received. Each employee 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 Health and Safety
requirements and the OERR's Standard Operating Safety Guides
B. Program Elements
1. Standard Operating Procedures. This respiratory protection program shall function as the
written standard operating procedures governing the selection and use of respiratory
protection for OSWER personnel (29 CFR 1910.134).
2. Respirator Fitting and Selection
(a) The selection of the proper type of respiratory protection shall be based
primarily on, but not limited to, the:
(1) Nature of the field activity;
(2) Type of respiratory hazard',
(3) Location of the hazardous area;
(4) Period of time for which respiratory protection must be provided;
E-l
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APPENDIX E (continued)
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised January 1999)
(5) Worker's potential exposure;
(6) Worker's activities;
(7) Worker's physical characteristics and functional activities;
(8) Limitations of the various types of respirators; and
(9) Respirator protection factors/respirator fit.
(b) Factors concerning both the potential and the measured hazard shall be
considered when requiring the use of respiratory protection. These factors
shall include, but not be limited to:
(1) Types of hazard;
(2) Physical and chemical properties;
(3) Physiological effects on the body;
(4) Expected concentration/level;
(5) Established ACGIH TLVs, OSHA PELs, and AIHA WEELs
(6) IDLH considerations; and
(7) Agent warning properties.
(c) U.S. EPA Environmental Response Team Center (ERTC) 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 (refer to ERT website:
"www.ert.org" for specific information).
(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
health concern, employee exposure potential and work activities. The selected
respirator protection must be continuously evaluated to reflect changes in
conditions or factors.
(e) The work activity location, with respect to a safe/clean area, shall be
considered in selecting respirator protection. Not only does this permit for a
well identified contamination reduction zone, but also requires the presence of
emergency access and exit areas.
(f) The period of time a respirator is to be worn shall be considered when
selecting respiratory protection.
(g) Employee activities and locations during site activities shall be considered
when selecting proper respiratory protection.
(h) The physical characteristics, functional capabilities, and performance
limitations of various types of respiratory protection shall be considered when
selecting a respirator.
(i) The hazards for which a particular respirator is designed shall be considered
when selecting a respirator.
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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised January 1999)
(j) A qualitative respirator fit test shall be performed on each user to
determine a satisfactory fit with respirators per 29 CFR 1910.134(f)
Appendix B-l. Test results shall be used to select specific types,
makes, and models for individual employees. All OSWER Category
1, 2, and 3 employees 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). Individual employees 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.
employees shall not wear respirator temple bars, straps, head
coverings, etc., between the sealing surface of the respirator. Neither
shall respirators be worn if facial hair, features, etc., prevent a good
fit.
(1) Respirator fit testing records shall be kept. Records shall include type
of fit-test method used, specific make and model of respirator tested,
name of worker tested, name of test operator, date of test, and results
of fit testing.
(m) A variety of sizes of respirator facepieces shall be available to
OSWER personnel to accommodate the wide range of facial shapes
and dimensions among personnel.
(n) Employee preference for a particular respirator model shall be
considered when selecting suitable respiratory protection. This
includes factors such as comfort, breathing resistance, weight, field of
vision, etc. However, the preferred model must have a satisfactory fit
test and be NIOSH approved.
(o) Where feasible, respirators shall be individually assigned to
employees for their exclusive use. If a respirator is marked for
identification purposes, the marking shall not affect the respirator
performance.
E-3
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APPENDIX E (continued)
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised January 1999)
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; wearing the respirator in a safe atmosphere and in a test
atmosphere.
(c) The Division Director or designee is responsible for purchasing,
issuing, and training his/her personnel concerning any phase of
respiratory protection.
(d) Trainers, employees, and others associated with the respiratory
protection program shall be trained to ensure the proper use of
respirators. Training shall include basic respiratory protection
practices, the nature and extent of expected respiratory hazard
exposure, principles and criteria for selecting respirators, using
respirators and monitoring their use, maintenance, and storage, and
regulations governing respirator use.
(e) 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.
4. Cleaning and Disinfecting
Respirators shall be regularly cleaned and disinfected. Those used by more
than one employee 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 29 CFR 1910.134 Appendix B.
E-4
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APPENDIX E (continued)
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised January 1999)
5. Equipment Storage
(a) Respirators shall be stored in a convenient, clean, and sanitary
location so that they are protected against dust, sunlight, extreme
temperature, excessive moisture, or damaging chemicals.
(b) Respirators shall be stored to prevent distortion of rubber or other
elastomeric parts. Respirators shall not be stored in such places as
lockers and tool boxes unless they are adequately protected from
contamination, distortion, and damage. Consult the "use and care"
instructions, usually mounted inside the carrying case lid, for proper
storage of emergency respirators.
6. Inspection and Repair
(a) Each respirator shall be inspected routinely before and after each use.
A respirator shall be inspected by the user immediately before each
use to ensure that it is in proper working condition.
(b) After cleaning and sanitizing, each respirator shall be inspected to
determine if it is in proper working condition, if it needs replacement
parts or repairs, or if it should be discarded. Each respirator stored
for emergency or rescue use shall be inspected at least monthly and
after each use by an experienced persons. 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
shelf life date(s); and for the proper function of regulators, alarms, and
other warning systems.
(c) Each rubber or elastomeric part shall be inspected for pliability and signs
of deterioration. Each air and oxygen cylinder shall be inspected to
ensure that it is fully charged according to the manufacturer's instructions.
(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 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.
E-5
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APPENDIX E (continued)
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised January 1999)
7. Surveillance
Appropriate surveillance or work area conditions and degree of employee
exposure or stress shall be maintained.
8. Evaluation of Respiratory Protection Program
(a) There shall be periodic (at least annual) inspection and evaluation to
determine the continued effectiveness of the respiratory protection
program. It is essential to ensure that all employees are provided with
adequate protection. The program should be improved and deficiencies
should be eliminated based on evaluation results.
(b) Respirator wearers shall be consulted periodically about their acceptance
of respirators. Frequent inspection of the program shall be conducted to
ensure that proper types of respirators are selected, that users are properly
trained; 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 employee shall have a medical evaluation to determine fitness to
wear respiratory protection and potential exposure. Adequate medical
data shall be provided as part of the 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).
(b) Employees 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 Activities]) since the last examination.
E-6
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APPENDIX E (continued)
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE
RESPIRATORY PROTECTION PROGRAM
(Revised January 1999)
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. NIOSH) voids the respirator approval.
VI. AIR QUALITY
A. Compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiratory
protection shall be of high purity. Compressed air should be the principle source of
breathing air. Compressed gaseous air shall meet at least the requirements for Type 1
- Grade D breathing air of Compress Gas Association Commodity Specification
G-7.1-1966 with the NIOSH Respirator Certification Standard, 42 CFF Part 84.
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 Z48.1-1954
(R1971) or Interim Federal Specification GG-B-675b, September 23, 1976.
E-7
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APPENDIX F
SUMMARY OF THE OSWER HEALTH AND SAFETY TRAINING COURSE REQUIREMENTS
Category
1
2
3
4
5
6
OERR
Authorized
Levels of
Protection
A,B,C
C
C
C
C
None
OSWER H&S
SOP Document
X
X
X
X
X
X
OERR Standard
Operating Safety
Guides
X
X
X
X
X
X
Properties of
Hazardous
Metals
X
X
X
X
X
N/A
Toxicology
X
X
X
X
X
N/A
1
2
3
4
5
6
Basic
Office
First
Aid
O
0
O
0
O
0
Basic
Field
First
Aid
X
X
X
X
X
0
CPR*
O
0
O
0
O
N/A
Protective
Clothing
X
X
X
X
X
N/A
Respiratory
Protection
X
X
X
X
X
N/A
Deconta-
mination
Procedures
X
X
X
X
X
N/A
Entry
Procedures
X
X
X
X
X
X
Worker
Rights &
Respon-
sibilities
X
X
X
X
X
X
Driving
Class
X
X
X
X
X
X
_Key: X= Mandatory, core topics
O = Desirable, but not mandatory
N/A = Not applicable
* Cardiopulmonary resuscitation
F-l
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APPENDIX G
REFERENCES
1. Health Services Program. United States Code, Title 5, Part III, Subpart F, Chapter 79-Services to
Employees, Section 7901 (2001).
2. Safety Programs. United States Code, Title 5, Part III, Subpart F, Chapter 79-Services to
Employees, Section 7902 (2001).
3. Occupational Safety and Health Program for Federal Employees, Executive Order 12196, Federal
Register 45, 12769 (February 2, 1980).
4. Basic Program Elements for Federal Employee Occupational Safety and Health, Occupational
Safety and Health Administration (OSHA), Department of Labor, 29 CFR, 1960.
5. Occupational Health and Safety Manual, Chapter 8, Laboratory Use of Toxic Substances. Office of
Administration, U.S. Environmental Protection Agency, Washington, B.C. (1986).
6. Safety, Health, and Environmental Management Program. EPA Order 1440.1. Office of Administration,
U.S. Environmental Protection Agency, Washington, D.C. (1998).
7. Health and Safety Requirements for Employees Engaged in Field Activities. EPA Order 1440.2.
Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency,
Washington, D.C. (July 12, 1982).
8. Respiratory Protection. EPA Order 1440.3. Office of Solid Waste and Emergency Response, U.S.
Environmental Protection Agency, Washington, D.C. (July 24, 1981).
9. Occupational Medical Surveillance Program Guidelines for National Contingency Plan
and Federal Response Plan Activities. Publication 9285.3-04-A. Environmental Response Team,
Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency,
Washington, D.C. (2002).
10. General Industry Standards, Occupational Safety and Health Administration (OSHA), Department
of Labor, 29 CFR, 1910.
11. Standard Operating Safety Guides. Publication 9285.1-03. Environmental Response Team, Office
of Solid Waste and Emergency Response, U.S. Environmental Protection Agency, Washington, D.C.
(1992).
G-l
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APPENDIX H
SAMPLE CERTIFICATION
I,
(Print name)
do hereby certify that I have read
and I fully understand the OSWER
Integrated Health and Safety
Program Standard Operating
Practices for OSWER Field
Activities.
Date:
E-mail address:
Signature
H-l
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